Text

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-12-049)
	ML15246A081
Person / Time
Site:	Braidwood
Issue date:	08/28/2015
From:	Kaegi G; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, RS-15-208, TAC MF0895, TAC MF0896
	Download: ML15246A081 (38)
	v • d • e

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xeton Generationc, Order No. EA-12-049 August 28, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457

Subject:

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-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. NEt 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-1 2-049), 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-13-1 13)

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-1 2-049), dated February 28, 2014 (RS-14-007)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 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-1 2-049), 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-1 2-049), dated February 27, 2015 (RS-1 5-016)

10. 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

11. NRC letter to Exelon Generation Company, LLC, Braidwood Station, Units 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 and MF0896), dated May 27, 2015 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 Braidwood 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, 7, 8, and 9 provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Braidwood Station. The purpose of this letter is to provide the fifth 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 10, and the NRC Audit Report open items contained in Reference 11.

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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2015 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2015.

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

Enclosure:

1. Braidwood Station, Units 1 and 2 Fifth 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 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator Region Ill NRC Senior Resident Inspector Braidwood Station, Units 1 and 2 NRC Project Manager, NRR Braidwood 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, NRRIDSS/SCVB, NRC Mr. John D. Hughey, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency Division of Nuclear Safety

Enclosure Braidwood Station, Units 1 and 2 Fifth 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 (34 pages)

Braidwood Station, Units 1 and 2 Fifth Six-Month Status Report for the Implementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Introduction Braidwood Station developed an Overall Integrated Plan (Reference 1 in Section 8),

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

2 Milestone Accomplishments The following milestone(s) have been completed since February 27, 2015 and are current as of July 28, 2015.

. Modification Implementation, Phase 2 modifications, Unit 1 Storage plan and construction

. FLEX equipment acquisition

. National SAFER Response Center operational NOTE: The "Status" indicated in this document is as of July 28, 2015. This date was chosen to support the development, review, approval and submittal of this report by the required August 28, 2015 due date.

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.

Site: Braidwood Original Target Activity Status Revised Target Completion Date Completion Date Submit 60 Day Status Report Complete Submit Overall Integrated Complete Implementation Plan Contract with Strategic Alliance Complete for FLEX Emergency Response National SAFER Response Center Submit Six (6) month updates Page 1 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Aug 2013 Update 1 Complete Feb 2014 Update 2 Complete Aug 2014 Update 3 Complete Feb 2015 Update 4 Complete Aug 2015 Update 5 Complete with this submittal Feb 2016 Update 6 Not Started Aug 2016 Update 7 Not Started Unit 1 Unit 2 Modification Development Unit 1 Unit 2 Unit 1 Unit 2 Feb Sept

Phase 1 modifications Started Started Oct Oct 2014 2014 2016 2015 Feb Sept

Phase 2 modifications Complete Complete Dec Dec 2014 2014 2014 2014 Feb Sept

Phase 3 modifications Complete Complete 2014 2014 Unit 1 Unit 2 Modification Implementation Unit 1 Unit 2 Unit 1 Apr Oct

Phase 1 modifications Started Started Oct 2015 2015 2016 Apr Oct

Phase 2 modifications Complete Started 2015 2015 Apr Oct

Phase 3 modifications Complete Complete 2015 2015 Unit 1 Unit 2 Procedure Development Unit 1 Unit 2 Unit 1 Apr Oct

Strategy procedures Started Started Oct 2015 2015 2016 Apr Oct

Validate procedures (NEI Started Started Oct 2015 2015 12-06, Sect. 11.4.3) 2016 Apr Oct

Maintenance procedures Started Started Oct 2015 2015 2016 Nov 2014 Staffing analysis Complete Apr 2015 Storage plan and construction Complete Apr 2015 FLEX equipment acquisition Complete Apr 2015 Training completion Started Sept 2015 Dec 2014 National SAFER Response Complete Feb 2015 Page 2 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Center operational Apr 2015 Unit 1 Implementation date Started October 2016 Oct 2015 Unit 2 Implementation date Started 4 Changes to Compliance Method Change 1 Section: Maintain RCS Inventory Control PWR Installed Equipment Phase 1- Identify modifications.

Reason for Change: Braidwood Station has decided to install the Westinghouse reactor coolant pump (RCP) SHIELD Passive Thermal Shutdown Seals (SDS) (Generation Ill). The SHIELD SDSs will be installed in all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 in the fall of 2016.

The NRC has concluded that the use of the Westinghouse SHIELD Passive Thermal SDS is acceptable for use in ELAP evaluation for Order EA-1 2-049 as documented in ADAMS Accession No. ML14132A128.

Change: Braidwood Station will be installing Westinghouse reactor coolant pump (RCP)

SHIELD Passive Thermal Shutdown Seals (SDS) (Generation Ill) in all Unit 1 and Unit 2 RCPs.

Change 2 Section: General Integrated Plan Elements PWR Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint.

Reason for Change: FLEX strategy procedure validation and PWROG-1 4027-P Rev.3 issued.

Note: Braidwood Station has decided to install the Westinghouse reactor coolant pump (RCP)

SHIELD Passive Thermal Shutdown Seals (SDS) (Generation Ill). The SHIELD SDSs will be installed in all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 in the fall of 2016. The NRC has concluded that the use of the Westinghouse SHIELD Passive Thermal SDS is acceptable for use in ELAP evaluation for Order EA-12-049 as documented in ADAMS Accession No. ML14132A128.

Installation of the SHIELD seals will change the Unit's response in a BDBEE described in NEI 12-06. As a result, the site is in the process of performing additional calculations to ensure the site Fukushima strategy remains viable. The additional calculations will be completed prior to the completion of A2R18, in the fall of 2015. The results of these calculations will be communicated with the post outage compliance letter or in a future 6-month update.

Change:

Adjusted the timeline for closing the C and 0 SG PORV to 3 to 5 minutes ensuring SG water volume is conserved until the diesel driven auxiliary Feedwater pump is operating.

Adjusted the timeline for setting up the high pressure FLEX pump and hoses at 11 to 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months ensuring RCS makeup will be available prior to ref lux boiling based on PWROG-14027-P Rev. 3, No.1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of ALL AC Power.

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Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Change 3 Section: Attachment 1A, Sequence of Events time line.

Reason for Change: FLEX strategy procedure validation and PWROG-1 4027-P Rev.3 issued.

Note: Braidwood Station has decided to install the Westinghouse reactor coolant pump (RCP)

SHIELD Passive Thermal Shutdown Seals (SDS) (Generation Ill). The SHIELD SDSs will be installed in all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 in the fall of 2016. The NRC has concluded that the use of the Westinghouse SHIELD Passive Thermal SOS is acceptable for use in ELAP evaluation for order EA-12-049 as documented in ADAMS Accession No.

MI-14132A128.

Installation of the SHIELD seals will change the Unit's response in a BDBEE described in NEI 12-06. As a result, the site is in the process of performing additional calculations to ensure the site Fukushima strategy remains viable. The additional calculations will be completed prior to the completion of A2R1 8, in the fall of 2015. The results of these calculations will be communicated with the post outage compliance letter or in a future 6-month update.

Change:

Adjusted the timeline for closing the C and D SG PORV to 3 to 5 minutes ensuring SG water volume is conserved until the diesel driven auxiliary Feedwater pump is operating.

Adjusted the timeline for setting up the high pressure FLEX pump and hoses at 11 to 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months ensuring RCS makeup will be available prior to ref lux boiling based on PWROG-14027-P Rev. 3, No.1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of ALL AC Power.

Updated timeline is in Attachment 1A of this document.

Change 4 Section: Maintain Core Cooling & Heat Removal PWR Installed Equipment Phase 1 and Maintain RCS Inventory Control PWR Installed Equipment Phase 1.

Reason for Change: Align wording to site strategy Change: Change last paragraph to the following:

Deploying and implementing portable FLEX pumps to supply injection flow must commence immediately from the time direction is provided in site emergency procedures. This should be plausible because more personnel are on site during outages to provide the necessary resources. Strategies for makeup water include deploying a FLEX pump to take suction from the RWST and for UHS as described in the Phase 2 Core Cooling section. Guidance will be provided to ensure that sufficient area is available for deployment and that haul paths remain accessible without interference from outage equipment during refueling outages.

Change 5 Section: PWR Portable Equipment Phase 2.

Reason for Change: The Phase 2 equipment required to support Braidwood Station ELAP strategy has been refined as the strategy has been developed.

Change: Delete the Three (3) Diesel Trash pumps, Six (6) 42" Box Fans and the Ten (10) 20" portable vent fans.

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Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Change 6 Section: General Integrated Plan Elements PWR Extent to which the guidance, JLD-ISG-201 2-01 and NEI 12-06, are being followed. Identify any deviations to JLD-ISG-2012-01 and NEI 12-06.

Reason for Change: Braidwood is taking an alternate approach to NEI 12-06 Sections 3.2 and 3.2.1.3. The alternate approach is for the method of protecting the permanently installed power operated relief valve (PORV) manual hand pumps from all design basis external events. The PORV operators are within robust structures with a non-robust access door. The PORV hand pumps are relied upon for symmetric cool down following a beyond design basis external event (BDBEE).

Basis for alternate approach:

NEI 12-06, Rev. 0, Section 3.2 states, "Installed equipment that is designed to be robust with respect to design basis external events is assumed to be fully available. Installed equipment that is not robust is assumed to be unavailable." Also, Section 3.2.1.3 states, "Permanent plant equipment that is contained in structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles, are available." Robust is defined in Appendix A as, "the design of an SSC either meets the current plant design basis for the applicable external hazards or has been shown by analysis or test to meet or exceed the current design basis."

Braidwood's PORV hand pumps do not meet all of the plant robust requirements for all design basis external events, due to the location behind a non-robust door. Specifically, the door is designed for high winds, but not tornado winds or wind driven missiles.

The PORV operators are within the Category I, robust main steam safety valve (MSSV) room concrete structures at grade elevation, surrounding the containment building. The rooms are protected from tornado missiles and wind by robust concrete labyrinth vestibules with entry via steel Category II doors. The non-safety related PORV manual operators are seismically-mounted within the labyrinth vestibules, but the components are subject to tornado winds and wind generated missiles through the non-robust door.

Per Braidwood UFSAR Section 2.3.1.2.2, the predominant tornado path is southwest to northeast. These doors are located on the east side of the site. As a result, the turbine building, auxiliary building, containment and transformer yards provide a shield protecting these doors from tornado winds and wind driven missiles traveling in the predominant tornado direction.

The Unit 1 and Unit 2 AID MSSV rooms are located back, closer to the turbine building, and protected by the turbine building structure and transformer yard firewalls. These structures provide reasonable assurance that tornado winds or wind driven missiles will not strike or damage the outer door and prevent access or disable the PORV manual controllers.

The Unit 1 and Unit 2 B/C MSSV rooms are exposed to the environment facing east.

Large concrete blocks will be placed in front of the two (2) B/C MSSV room doors to protect the PORV operators from design basis horizontal missiles. The blocks also limit Page 5 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 the amount of possible large debris build-up in front of the doors, since the blocks are placed approximately 4 feet from the entrance.

This configuration ensures all four sets of permanently installed PORV hand pumps have "reasonable protection" and will survive all BDBEEs.

Change: The site is crediting the availability of the SG PORV manual controllers to provide the operators with a method to symmetrically cool down the RCS following a BDBEE.

Change 7 Section: General Integrated Plan Elements PWR Extent to which the guidance, JLD-ISG-2012-01 and NEI 12-06, are being followed. Identify any deviations to JLD-ISG-2012-01 and NEI 12-06.

Reason for Change: Exelon proposes an alternate approach to NEI 12-06, Revision 0 for protection of FLEX equipment as stated in Section 5.3.1 (seismic,) Section 7.3.1 (severe storms with high winds), and Section 8.3.1 (impact of snow, ice and extreme cold). This alternate approach will be to store "N" sets of equipment in a fully robust building and the +1 set of equipment in a commercial building. Note that, for Braidwood Station, some of the +1 equipment will be stored in a fully robust building.

Basis for the alternate approach:

For all hazards scoped in for the site, the FLEX equipment will be stored in a configuration such that no one external event can reasonably fail the site FLEX capability (N).

To ensure that no one external event will reasonably fail the site FLEX capability (N),

Exelon will ensure that N equipment is protected in the robust building. To accomplish this, Exelon will develop procedures to address the unavailability allowance as stated in NEI 12-06, Revision 0 Section 11.5.3., (see Maintenance and Testing section below for further details). This section allows for a 90-day period of unavailability. If a piece of FLEX equipment stored in the robust building were to become or found to be unavailable, Exelon will impose a shorter allowed outage time of 45 days. For portable equipment that is expected to be unavailable for more than 45 days, actions will be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of this determination to restore the site FLEX capability (N) in the robust storage location and implement compensatory measures (e.g., move the +1 piece of equipment into the robust building) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months where the total unavailability time is not to exceed 45 days. Once the site FLEX capability (N) is restored in the robust storage location, Exelon will enter the 90-day allowed out of service time for the unavailable piece of equipment with an entry date and time from the discovery date and time.

Maintenance and Testing:

1. The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized.

a. The unavailability of plant equipment is controlled by existing plant processes such as the Technical Specifications. When plant equipment which supports Page 6 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 FLEX strategies becomes unavailable, then the FLEX strategy affected by this unavailability does not need to be maintained during the unavailability.

b. The required FLEX equipment may be unavailable for 90 days provided that the site FLEX capability (N) is met. If the site FLEX (N) capability is met but not protected for all of the site's applicable hazards, then the allowed unavailability is reduced to 45 days.'

c. The duration of FLEX equipment unavailability, discussed above, does not constitute a loss of reasonable protection from a diverse storage location protection strategy perspective.

d. If FLEX equipment or connections become unavailable such that the site FLEX capability (N) is not maintained, initiate actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the site FLEX capability (N) and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

e. If FLEX equipment or connections to permanent plant equipment required for FLEX strategies are unavailable for greater than 45/90 days, restore the FLEX capability or implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) prior to exceedance of the 45/90 days.

For Section 5, seismic hazard, Exelon will also incorporate these actions:

1. Large portable FLEX equipment such as pumps and power supplies should be secured as appropriate to protect them during a seismic event (i.e., Safe Shutdown Earthquake (SSE) level).

2. Stored equipment and structures will be evaluated and protected from seismic interactions to ensure that unsecured and/or non-seismic components do not damage the equipment.

For Section 7, severe storms with high winds, Exelon will also incorporate this action:

(N+1) of on-site FLEX equipment are required. The plant screens in per Sections 5 through 9 for seismic, wind (both tornado and hurricane), snow, ice and extreme cold, and high temperatures.

o To meet Section 7.3.1.1.a, either of the following are acceptable:

All equipment (N-i-i) in a structure(s) that meets the plant's design basis for high wind hazards, or

(N) equipment in a structure(s) that meets the plant's design basis for high wind hazards and (+1) equipment stored in a location not protected for a high wind hazard.

For Section 8, impact of snow, ice and extreme cold, Exelon will also incorporate this action:

Storage of FLEX equipment should account for the fact that the equipment will need to function in a timely manner. The equipment should be maintained at a

'The spare FLEX equipment is not required for the FLEX capability to be met. The allowance of 90- day unavailability is based on a normal plant work cycle of 12 weeks. In cases where the remaining N equipment is not fully protected for the applicable site hazards, the unavailability allowance is reduced to 45 days to match a 6-week short cycle work period. Aligning the unavailability to the site work management program is important to keep maintenance of spare FLEX equipment from inappropriately superseding other more risk-significant work activities.

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Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 temperature within a range to ensure its likely function when called upon. For example, by storage in a heated enclosure or by direct heating (e.g., jacket water, battery, engine block heater, etc.).

Exelon will meet all of the requirements in NEI 12-06, Revision 0 for Section 6.2.3.1 for external flood hazard and Section 9.3.1 for impact of high temperatures.

Change: Exelon proposes an alternate approach to NEI 12-06, Revision 0 for protection of FLEX equipment as stated in Section 5.3.1 (seismic,) Section 7.3.1 (severe storms with high winds), and Section 8.3.1 (impact of snow, ice and extreme cold). This alternate approach will be to store "N" sets of equipment in a fully robust building and the +1 set of equipment in a commercial building with the additional actions listed above.

Change 8 Section: General Integrated Plan Elements PWR Extent to which the guidance, JLD-ISG-2012-01 and NEI 12-06, are being followed. Identify any deviations to JLD-ISG-2012-01 and NEI 12-06.

Reason for Change: An alternate approach is being proposed to the Ni-i requirement applicable to hoses and cables as stated in Section 3.2.2 of NEI 12-06.

Basis for the alternate approach:

NEI 12-06, Section 3.2.2 specifically states that a site will have FLEX equipment to meet the needs of each unit on a site plus one additional spare. This is commonly known as N+1 where N is the number of units at a given site. The relevant text from NE! 12-06 is as follows:

NEI 12-06, Section 3.2.2 states: "In order to assure reliability and availability of the FLEX equipment required to meet these capabilities, the site should have sufficient equipment to address all functions at all units on-site, plus one additional spare, i.e., an Ni-i capability, where "N" is the number of units on-site. Thus, a two-unit site would nominally have at least three portable pumps, three sets of portable ac/dc power supplies, three sets of hoses & cables, etc."

NEI 12-06, Section 11.3.3 states: "FLEX mitigation equipment should be stored in a location or locations informed by evaluations performed per Sections 5 through 9 such that no one external event can reasonably fail the site FLEX capability (N)."

Typically the hoses utilized to implement a FLEX strategy are not a single continuous hose but are composed of individual sections of a smaller length joined together to form a sufficient length. In the case of cables, multiple individual lengths are used to construct a circuit such as in the case of 3-phase power.

Proposed Alternative:

NEI 12-06 currently requires N+1 sets of hoses and cables. As an alternative, the spare quantity of hose and cable is adequate if it meets either of the two methods described below:

Method 1: Provide additional hose or cable equivalent to 10% of the total length of each type/size of hose or cable necessary for the "N" capability. For each type/size of hose or cable needed for the "N" capability, at least 1 spare of the longest single section/length must be provided.

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Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Example 1-1: An installation requiring 5,000 ft. of 5 in. diameter fire hose consisting of 100 50 ft. sections would require 500 ft. of 5 in. diameter spare fire hose (i.e., ten 50 ft. sections).

Example 1-2: A pump requires a single 20 ft. suction hose of 4 in. diameter, its discharge is connected to a flanged hard pipe connection. One spare 4 in.

diameter 20 ft. suction hose would be required.

Example 1-3: An electrical strategy requires 350 ft. cable runs of 4/0 cable to support 480 volt loads. The cable runs are made up of 50 ft. sections coupled together. Eight cable runs (2 cables runs per phase and 2 cable runs for the neutral) totaling 2800 ft. of cable (56 sections) are required. A minimum of 280 ft. spare cable would be required or 6 spare 50 ft. sections.

Example 1-4: An electrical strategy requires 100 ft. of 4/0 cable (4 cables, 100 ft. each) to support one set of 4 kv loads and 50 ft. of 4/0 (4 cables, 50 ft. each) to support another section of 4 kv loads. The total length of 4/0 cable is 600 ft.

(100 ft. x 4 plus 50 ft. x 4). One spare 100' 4/0 cable would be required representing the longest single section/length.

Method 2: Provide spare cabling and hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy.

Example 2-1 A FLEX strategy for a two unit site requires 8 runs each of 500 ft. of 5 in. diameter hose (4000 ft. per unit). The total length of 5 in. diameter hose required for the site is 8000 ft. with the longest run of 500 ft. Using this method, 500 ft. of 5 in. diameter spare hose would be required.

For either alternative method, both the N sets of hoses or cables and the spare set of hoses or cables would all be kept in a location that meets the reasonable protection requirements for the site.

The NRC has endorsed (ML15125A442) the NEI position paper (ML15126A135) for the above stated alternate approach. If using Method 2, per the endorsement letter, Exelon will ensure that the FLEX pumps and portable generators are confirmed to have sufficient capability to meet flow and electrical requirements when a longer spare hose/cable is substituted for a shorter length. Exelon acknowledges that the NRC staff has not reviewed and is not endorsing the specific examples included in the NEt endorsement request dated May 1, 2015. If necessary, Exelon will provide additional justification regarding the acceptability of various cable and hose lengths with respect to voltage drops, and fluid flow resistance, rather than merely relying on the additional, longest length cable/hose as implied by Example 1-4 in the subject letter.

Hoses and cables are passive devices unlikely to fail provided they are appropriately inspected and maintained. The most likely cause of failure is mechanical damage during handling provided that the hoses and cables are stored in areas with suitable environmental conditions (e.g., cables stored in a dry condition and not subject to chemical or petroleum products). The hoses and cables for the FLEX strategies will be stored and maintained in accordance with manufacturers' recommendations including any shelf life requirements. Initial inspections and periodic inspections or testing will be incorporated into the site's maintenance and testing program implemented in accordance with Section 11.5 of NEt 12-06.

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Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Therefore, the probability of a failure occurring during storage is minimal, resulting in the only likely failure occurring during implementation. Mechanical damage will likely occur in a single section versus a complete set of hose or cable. Therefore, the N+1 alternative addresses the longest individual section/length of hose or cable.

Providing either a spare cable or hose of a length of 10% of the total length necessary for the "N" capability or alternatively providing spare cabling or hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy is sufficient to ensure that a strategy can be implemented. Mechanical damage during implementation can be compensated for by having enough spares to replace any damaged sections with margin. It is reasonable to expect that an entire set of hoses or cables would not be damaged provided they have been reasonably protected.

Change: The spare quantity of hose and cable is adequate if it meets either of the two methods described below:

Method 1: Provide additional hose or cable equivalent to 10% of the total length of each type/size of hose or cable necessary for the "N" capability. For each type/size of hose or cable needed for the "N" capability, at least 1 spare of the longest single section/length must be provided.

Method 2: Provide spare cabling and hose of sufficient length and sizing to replace the single longest run needed to support any single FLEX strategy.

For either alternative method, both the N sets of hoses or cables and the spare set of hoses or cables would all be kept in a location that meets the reasonable protection requirements for the site.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Braidwood Station, Unit 2 expects to comply with the Order implementation date of October 2015.

Braidwood Station, Unit 1 has received an 18-month extension of the order due to Pressurized-Water Owners Group (PWROG) refining RCP Seal Leakage rate projections and is scheduled to be in compliance by October 2016. NRC letter ADAMS Accession No. ML15068A215:

"Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of the order for full order implementation for Braidwood Station, Unit 1, is relaxed until the completion of the fall 2016 refueling outage. This additional time will allow Exelon to complete the engineering analysis associated with the additional information provided by the PWROG regarding the analytical basis for RCP seal leakage".

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

NOTE: The "Status" indicated in this document is as of July 28, 2015. This date was chosen to support the development, review, approval and submittal of this report by the required August 28, 2015 due date.

Page 10 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Section Reference Overall Integrated Plan Open Item Status Key Site assumptions Primary and secondary storage Item Closed During Onsite NRC Audit (p.4) locations have not been selected yet; (Ref. 31).

once locations are finalized implementation strategies and routes Complete Exelon proposes an alternate will be assessed for hazard impact. approach to NEI 12-06 Revision 0 for protection of FLEX equipment as stated in Section 5.3.1 (seismic,) Section 7.3.1 (severe storms with high winds), and Section 8.3.1 (impact of snow, ice and extreme cold). This alternate approach will be to store "N" sets of equipment in a fully robust building and the +1 set of equipment in a commercial building.

Note that for Braidwood Station, some of the +1 equipment will be stored in a fully robust building. Braidwood Station alternate approach basis is documented in Section 4 as change number 6.

The robust and commercial buildings will be located adjacent to each other outside the protected area, southeast of the main parking lot.

Primary and alternate deployment routes for FLEX equipment have been identified and are being recorded within the site program document.

Snow removal will be addressed as part of the site snow removal plan. Post event snow removal will be accomplished by a FLEX truck with snow plow or FLEX tractor with bucket.

The site maximum flood water level is at elevation 601.91 feet resulting from a probable maximum precipitation (PMP) event. Braidwood plant grade elevation is at 600.0 feet and does not vary significantly across the site. The FLEX storage building floor will be constructed above the flood level to an elevation of 602 feet. A majority of the travel path elevations are between elevation 600 feet and 601 feet (Ref. 11). Some travel path location may be covered by a small amount of water. Since the FLEX pumps and generators are trailer mounted, they should be maintained available when being deployed to different locations at the site.

Page 11 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Debris removal impacts of the travel routes have been evaluated. Guidance exists for coping with downed power lines. The alternate travel route will be utilized in the event the primary path becomes unavailable due to debris. In addition, the site has purchased an F750 and two 15.115 New Holland tractors to assist in debris removal.

Extreme hot and cold temperatures should have little impact on the site travel paths.

BRW-1 5-0002-5, Evaluation of FLEX Equipment Haul Paths for Soil Liquefaction Potential (Ref. 30),

concludes that there is a potential for liquefaction at intermittent depths between about 6 feet to 16 feet. The induced ground settlement for the Braidwood FLEX equipment paths outside the main plant area is about 1 inch. The induced ground settlement for the Braidwood equipment paths in the main plant area is about 2 inches.

Considering the size of the haul vehicles and the trailer loads, 1-inch to 2-inch settlement should not impose a significant impediment to FLEX equipment deployment.

Sequence of events The final timeline will be time validated Item Closed During Onsite NRC Audit (p.5) once detailed designs are completed (Ref. 31).

and procedures are developed.

Started The site FLEX procedure validation is in progress. The site will utilize NEI developed validation process.

Identify how strategies Identification of storage area and Item Closed During Onsite NRC Audit will be deployed (p.7) creation of the administrative program. (Ref. 31).

Complete Exelon proposes an alternate approach to NEt 12-06, Revision 0 for protection of FLEX equipment as stated in section 5.3.1 (seismic,) section 7.3.1 (severe storms with high winds), and section 8.3.1 (impact of snow, ice and extreme cold). This alternate approach will be to store "N" sets of equipment in a fully robust building and the +1 set of equipment in a commercial building.

Note that for Braidwood Station, some of 1 the +1 equipment will be stored in a fully Page 12 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 robust building. Braidwood Station alternate approach basis is documented in section 4 as change number 7.

The robust and commercial buildings will be located adjacent to each other outside the protected area, southeast of the main parking lot.

Site program document CC-BR-1 18-1001, Site Implementation of Diverse And Flexible Coping Strategies (Flex) and Spent Fuel Pool Instrumentation Program, has been approved. The program document contains a summary of the FLEX strategy, deployment paths and staging areas.

Programmatic controls Develop an administrative program for Item Closed During Onsite NRC Audit (p.8) FLEX responsibilities, and testing & (Ref. 31).

maintenance.

Complete Site program document CC-BR-1 18-1001, Site Implementation of Diverse And Flexible Coping Strategies (Flex) and Spent Fuel Pool Instrumentation Program, has been approved. The program document contains FLEX responsibilities, testing and maintenance.

National SAFER Development of Braidwood Station's Item Closed During Onsite NRC Audit Response Center plan playbook. (Ref. 31).

(p.9)

Complete CC-BR-1i8-i002, SAFER Response Plan for Braidwood Generating Station is approved.

Key Reactor Identify additional parameters that are Item Closed During Onsite NRC Audit Parameters needed in order to support key actions (Ref. 31).

identified in the plant (p. multiple) Complete Closure supplied as part of procedures/guidance or to indicate third 6-month update (Ref. 25).

imminent or actual core damage.

Deployment Conceptual Develop the storage structure Item Closed During Onsite NRC Audit Design (p. multiple) conceptual design. (Ref. 31).

Complete Closure supplied as part of fourth 6-month update (Ref. 29).

Maintain RCS Inventory A calculation will be required for the Item Closed During Onsite NRC Audit Control, Phase 2 (p.23) timing of the boration and quantity (Ref. 31).

required.

Started Calculation BYR1 3-239/BRW-13-0221 -M (Ref. 10) identifies the timing and quantity of boration required.

Specifically, boration will need to start prior to 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months into the event and require 15,240 gallons of water injected at 40 gallons per minute.

Braidwood Station has decided to install Page 13 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 the Westinghouse reactor coolant pump (RCP) SHIELD Passive Thermal Shutdown Seals (SDS) (Generation Ill).

The SHIELD SDSs will be installed in all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 in the fall of 2016. The NRC has concluded that the use of the Westinghouse SHIELD Passive Thermal SDS is acceptable for use in ELAP evaluation for order EA-1 2-049 as documented in ADAMS Accession No. ML14132A128.

Installation of the SHIELD seals will change the Unit's response in a BDBEE described in NEt 12-06. As a result, the site is in the process of performing additional calculations to ensure the site Fukushima strategy remains viable.

Calculation CN-LIS-1 5-39, Exelon Byron and Braidwood Stations Reactor Coolant System ELAP Long-Term Subcriticality Analysis with Low-Leakage Reactor Coolant Pump Seal Packages (Ref. 35),

is in progress and may impact the site strategy. These results will be reported in the post outage compliance letter or in a future 6-month update.

Maintain Containment, Additional calculations will be performed Item Closed During Onsite NRC Audit Phase 1 (p.31) to evaluate containment response. (Ref. 31).

Complete Calculation BYR13-235/BRW-13-0217-M (Ref. 12) and BYR14-046/BRW-14-0058-M (Ref. 17) evaluate containment response in all modes. In Mode 1-4, design basis temperature and pressure are not reached until > 30 days.

The results show site action during Phase 1 and Phase 2 are not necessary.

1/2BwFSG-12, Containment Cooling, provides operators with different options for restoring containment cooling to maintain containment temperature and pressure within limits.

Installation of the Westinghouse RCP SHIELD Passive SDS (Generation III) will reduce the amount of leakage into containment assumed in calculation BYR1 3-235/BRW-1 3-021 7-M (Ref. 12),

resulting in additional margin to reaching design basis temperature and pressure.

Maintain Spent Fuel Procedure development for Initial Spent Item Closed During Onsite NRC Audit Pool Cooling, Phase 1 fuel pool make-up with gravity drain (Ref. 31).

Page 14 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 (p.39) from the RWST. Complete Closure supplied as part of third 6-month update (Ref. 25).

Maintain Spent Fuel Initial calculations were used to Item Closed During Onsite NRC Audit Pool Cooling, Phase 1 determine the fuel pool timelines. (Ref. 31).

(p.39) Formal calculations will be performed to Complete Closure supplied as part of validate this information during third 6-month update (Ref. 25).

development of the spent fuel pool cooling strategy detailed design.

Maintain Spent Fuel Evaluation of the spent fuel pool area Item Closed During Onsite NRC Audit Pool Cooling, Phase 1, for steam and condensation will be (Ref. 31).

(p.39 and p.42) performed and used to determine if vent Complete Closure supplied as part of path strategy is needed.

third 6-month update (Ref. 25).

Safety Functions Habitability conditions will be evaluated Item Closed During Onsite NRC Audit Support, Phase 2 (p.51) and a strategy will be developed to (Ref. 31).

maintain Main Control Room.

Complete Closure supplied as part of third 6-month update (Ref. 25).

Safety Functions Critical ventilation assets may be Item Closed During Onsite NRC Audit Support, Phase 2 (p.51) required to support DDAF pumps, (Ref. 31).

station battery rooms, miscellaneous Complete Closure supplied as part of electric equipment rooms, and fuel fourth 6-month update (Ref. 29).

handling building personnel habitability and/or component survivability. Specific analyses of these rooms will be performed.

Interim Safety Evaluation Open Item Status Braidwood's ISE Response Line Item Description Answer Number Number Open Item Core Subcriticality- The NRC staff Item Closed During Onsite NRC Audit 3.2.1.8.A has not endorsed the industry- (Ref. 31).

proposed position paper regarding boron mixing. The licensee has Started- Braidwood will abide by the indicated that Braidwood is planning position expressed by the Nuclear on following this methodology. Thus, Regulatory Commission (NRC) staff in further resolution of this issue will be the letter dated January 8, 2014 necessary in the next phase of the regarding the boron mixing issue for audit process. Pressurized Water Reactors (PWRs)

(Ref. 22). The NRC letter states that the NRC staff has reviewed the information submitted to date and concluded that use of the industry approach dated August 15, 2013, entitled 'Westinghouse Response to NRC Generic Request for Additional Information (RAt) on Boron Mixing in I Support of the Pressurized Water Page 15 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 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 in Ref. 10 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. Installation of the SHIELD seals may change the Unit's response. As a result, the site is in the process of performing Calculation CN-LIS-15-39 (Ref. 35) to ensure the site Fukushima strategy remains viable.

Calculation CN-LIS-15-34 (Ref. 33) has extended the RCS inventory loss of single phase natural circulation to 58 hours6.712963e-4 days 0.0161 hours 9.589947e-5 weeks 2.2069e-5 months .

The Braidwood Overall integrated plan (OIP) Attachment 1A, Action Item 15 shows that the high pressure FLEX pumps are available between 11 and 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months following the Beyond-Design-Basis External Event (BDBEE) which meets the timing requirements outlined in Ref. 22, Clarifications (1) and (3) as described previously.

Therefore, the boron mixing criteria are met.

Confirmatory Items 2 3.1.1.1.A Storage & Protection of FLEX Complete Exelon proposes an equipment Confirm final design of

- alternate approach to NEI 12-06, FLEX storage structure conforms to Revision 0 for protection of FLEX NEI 12-06, Sections 5.3.1, 7.3.1, and equipment as stated in section 5.3.1 8.3.1 for storage considerations for (seismic,) section 7.3.1 (severe storms the hazards applicable to Braidwood. with high winds), and section 8.3.1 (impact of snow, ice and extreme cold). This alternate approach will be to store "N" sets of equipment in a fully robust building and the +1 set of I equipment in a commercial building.

Page 16 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Note that for Braidwood Station, some of the +1 equipment will be stored in a fully robust building. Braidwood Station alternate approach basis is documented in Section 4 as change number 7.

EC398039, FLEX Storage Robust Building Construction and EC398040, FLEX Buildings Commercial Building, contain the design details for the robust and commercial buildings respectively.

3 3.1.1.3.A Procedural Interface Considerations Item Closed During Onsite NRC Audit (Seismic) Confirm procedure for (Ref. 31).

measuring key instruments at Complete Closure supplied as part containment penetrations using of fourth 6-month update (Ref. 29).

portable instrument.

4 3.1.1.4.A Off-Site Resources Confirm

- Item Closed During Onsite NRC Audit National SAFER Response Center (Ref. 31).

local staging area and method of Complete Site primary staging area transportation to the site in future 6-(Area C) location is the Pontiac month update Municipal Airport in Pontiac, Illinois.

The Alternate staging area (Area D) location is LaSalle Nuclear Station near Marseilles, Illinois. The site has approved memorandum of understanding (MOU) with Pontiac Municipal Airport and LaSalle Nuclear Station. Primary and alternate transportation routes have been identified between these locations and the site. These routes are detailed within the site's response plan (playbook). The main transportation method will be by a heavy haul vehicle. If an accessible transportation route cannot be identified, helicopter transportation will be utilized. The EOF will coordinate SAFER communications and the transportation of equipment to the site.

This has been communicated to the State of Illinois and is in the Illinois Plan for Radiological Accidents (IPRA).

5 3.1.5.1.A Protection of Equipment (High Item Closed During Onsite NRC Audit Temperature) Confirm FLEX

- (Ref. 31).

storage structure will maintain FLEX Complete Closure supplied as part equipment at a temperature range to of fourth 6-month update (Ref. 29).

ensure its likely function when called upon.

Page 17 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 6 3.1.5.3.A Deployment of Equipment (High Item Closed During Onsite NRC Audit Temperature) Confirm that the

- (Ref. 31).

effects of high temperature on FLEX Complete Closure supplied as part equipment have been evaluated in -

the locations they are intended to of fourth 6-month update (Ref. 29).

operate.

7 3.2.1.A RCS cooling & RCS inventory Item Closed During Onsite NRC Audit control Specify which analysis

- (Ref. 31).

performed in WCAP-17601 is being applied to Braidwood. Additionally, Complete The primary system justify the use of that analysis by conditions considered are based on identifying and evaluating the the Westinghouse reference coping important parameters and cases described in Section 5.2.1 of assumptions demonstrating that they WCAP-17601-P (Ref. 18). The are representative of Braidwood and extended loss of alternating current appropriate for simulating the ELAP (AC) power (ELAP) simulation transient. parameters matrix provided in Ref. 23 outlines the comparison of items for Braidwood Station.

Braidwood Station has decided to install the Westinghouse reactor coolant pump (RCP) SHIELD Passive Thermal Shutdown Seals (SDS)

(Generation Ill). The SHIELD SDSs will be installed in all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 in the fall of 2016. The NRC has concluded that the use of the Westinghouse SHIELD Passive Thermal SDS is acceptable for use in ELAP evaluation for Order EA-12-049 as documented in ADAMS Accession No. ML14132A128.

Installation of the SHIELD seals will change the Unit's response in a BDBEE described in NEI 12-06. As a result, the site is in the process of performing additional calculations to ensure the site Fukushima strategy remains viable. These calculations may alter the site strategy from the case described in WCAP-17601-P. Calculations include CN-LlS-1 5-34, CN-LIS-15-39, and CN-LIS-15-40, which are being performed by Westinghouse. The new analyses will replace or supplement existing analyses which were previously demonstrated to be representative of Braidwood Station and remain consistent with the methodology in WCAP-1 7601-P.

CN-L IS-i 5-34, has extended the RCS Page 18 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 inventory loss of single phase natural circulation to 58 hours6.712963e-4 days 0.0161 hours 9.589947e-5 weeks 2.2069e-5 months . Calculations CN-LIS-1 5-39 and CN-LIS-1 5-40 are in progress and may impact the site strategy. These results will be reported in the response to ISE questions 3.2.4.7.A and 3.2.1.8.A with the post outage compliance letter or in a future 6-month update.

8 3.2.1.1.A NOTRUMP Confirm that the use of

- Item Closed During Onsite NRC Audit NOTRUMP in the ELAP analysis is (Ref. 31).

limited to the flow conditions before Complete Exelon has used generic ref lux condensation initiates. This ELAP analyses performed in WCAP-includes specifying an acceptable 17601 P (Ref. 18) with the NOTRUMP definition for ref lux condensation -

computer code to support the coolin" mitigating strategy in its Overall Integrated Plan (OIP). The use of NOTRUMP was limited to the thermal-hydraulic conditions before ref lux condensation initiates. The initiation of ref lux condensation cooling is defined when the one hour centered moving average (CMA) of the flow quality at the top of the steam generator u-tube bend exceeds 0.1 in anyone loop.

The timing shown in PWROG-14027-P (Ref. 32) for the Category 1 4-loop Westinghouse Nuclear Steam Supply System (NSSS) PWR5 is shown as 15.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . A plant specific evaluation (Ref. 33) was performed by Westinghouse as a result of installing the Westinghouse RCP SHIELD Passive Thermal SDS that demonstrated margin above the generic timing value. The analyses and evaluations supporting the OIP demonstrate that the Flexible and Diverse Coping Strategies (FLEX)

Reactor Coolant System (RCS) make-up pump will be aligned prior to the loop flow rate decreasing below the loop flow rate corresponding to the definition of the onset of reflux cooling.

Braidwood Station Overall integrated plan (OIP) Attachment 1A, Action Item 15 shows that the high pressure FLEX pumps are available between 11 and 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months following the Beyond-Design-Basis External Event (BDBEE) which meets the timing requirements outlined in Ref. 22, Clarifications (1) and (3).

Page 19 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 9 3.2.1.1.13 ELAP Analysis Confirm

- Item Closed During Onsite NRC Audit calculations to verify no nitrogen (Ref. 31).

injection into RCS during depressurization. Complete Closure supplied as part of fourth 6-month update (Ref. 29).

10 3.2.1.1.0 Confirm analysis for secondary side Item Closed During Onsite NRC Audit SG fouling due to the use of (Ref. 31).

abnormal water sources (RWST, Complete Closure supplied as part well water, SX water) of fourth 6-month update (Ref. 29).

11 3.2.1.1 .D Complete analysis for length of time Item Closed During Onsite NRC Audit prior to depletion of the RWST and (Ref. 31).

determine whether additional Complete Closure supplied as part boration equipment is needed for -

of fourth 6-month update (Ref. 29).

Phase 3 coping strategy.

12 3.2.1.2.13 Reactor Coolant Pump (RCP) Seal Item Closed During Onsite NRC Audit Leakage In some plant designs, the

- (Ref. 31).

cold legs could experience Started Braidwood Station has temperatures as high as 580 °F decided to install the Westinghouse before cooldown commences. This reactor coolant pump (RCP) SHIELD is beyond the qualification Passive Thermal Shutdown Seals temperature (550°F) of the 0-rings (SDS) (Generation III). The SHIELD used in the RCP seals. For those Westinghouse designs, a discussion SDSs will be installed in all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 should be provided to justify that (1) the integrity of the associated 0-rings in the fall of 2016.

will be maintained at the temperature Installation of the SHIELD seals will conditions experienced during the change the Unit's response in a ELAP event, and (2) the seal BDBEE described in NEI 12-06. As a leakage rate of 21 gpm/seal used in result, the site is in the process of the ELAP is adequate and performing additional calculations acceptable. (CN-LIS-15-34, CN-LIS-15-39, and CN-LIS-15-40) to ensure the site Fukushima strategy remains viable.

The additional calculations will be completed prior to the completion of A2R1 8, in the fall of 2015. The results of these calculations will be communicated with the post outage compliance letter or in a future 6-month update.

13 3.2.1.2.E RCP Seal Leakage Rates The - Item Closed During Onsite NRC Audit licensee is requested to provide the (Ref. 31).

manufacturer and model number of Complete Braidwood station has the RCP seals and discuss whether -

decided to install the Westinghouse or not the RCP and seal combination reactor coolant pump (RCP) SHIELD complies with a seal leakage model Passive Thermal Shutdown Seals described in WCAP-1 7601.

(SOS) (Generation Ill). The SHIELD SOSs will be installed on all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 in the fall of 2016.

Braidwood Station has Westinghouse Page 20 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 RCP Model 93A. Credit for the SHIELD seals has been endorsed for Westinghouse Model 93A RCPs as documented in ADAMS Accession No. ML14132A128. The RCP seal leakage assumed in CN-LIS-15-34, Exelon Byron and Braidwood Stations Reactor Coolant System ELAP Inventory Control Analysis SHIELD Reactor Coolant Pump Seal Packages, (Ref 33) is consistent with ADAMS Accession No. ML14132A128 limitations and conditions number 4.

14 3.2.1.3.A Decay Heat- Verify that the Item Closed During Onsite NRC Audit Integrated Plan update provides the (Ref. 31).

details of the WCAP 17601-P Complete The Westinghouse methodology to include the values of Nuclear Steam Supply System certain key parameters used to (NSSS) calculations documented in determine the decay heat levels.

WCAP17601-P (Ref. 18) using the Address the adequacy of the values NOTRUMP code were performed with the ANS 5.1 1979 + 2 sigma decay heat model and assumed the reactor is initially operating at 100% power (NOTRUMP reference case core power is 3723 MWt). Implementation of this model includes fission product decay heat resulting from the fission of U-235, U-238, and Pu-239 and actinide decay heat from U-239 and Np-239. The power fractions are typical values expected for each of the three fissile isotopes through a three region burn-up with an enrichment based on typical fuel cycle feeds that approach 5%. With that, a conversion ratio of 0.65 was used to derive the decay power of the two actinides U-239 and Np-239. Fission product neutron capture is treated per the ANS standard. The decay heat calculation utilizes a power history of three 540-day cycles separated by two 20-day outages that bounds initial condition 3.2.1.2(1) of the Nuclear Energy Institute (NEI) document NEI 12-06 (Ref. 3), Section 3.2.1.2 (with a minimum assumption from NEI 12-06 that the reactor has been operated at 100% power for at least 100 days prior to event initiation). Therefore, the decay heat curve assumed in the Westinghouse calculations in Ref. 18 1 is representative of Braidwood Units 1 Page 21 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 and 2.

The primary-side transient profile assumed in the reactor coolant system (RCS) inventory control and long-term sub-criticality calculations for Modes 1 through 4 with steam generators available is based on the Westinghouse reference coping case of WCAP-17601-P (Ref. 18) and plant specific parameters such as reactor coolant system nominal temperature(s), pressures(s), and volumes, and accumulator cover gas pressures presented in Ref. 23. These calculations do not, however, include any decay heat model and rely on the case runs cited from WCAP-1 7601-P regarding decay heat related phenomenon.

15 3.2.1.4.A Initial Values for Key Plant Item Closed During Onsite NRC Audit Parameters and Assumptions- (Ref. 31).

Confirm WCAP-1 7601-P analyses Complete The primary system are bounding for Braidwood for conditions considered are based on strategy response or verify plant-the Westinghouse reference coping specific analyses if more restrictive cases described in Section 5.2.1 of limits are used due to more WCAP-17601-P (Ref. 18). The restrictive plant specific limits, extended loss of alternating current (AC) power (ELAP) simulation parameters matrix provided in Ref. 23 outlines the comparison of items for Braidwood Station.

Braidwood Station has decided to install the Westinghouse reactor coolant pump (RCP) SHIELD Passive Thermal Shutdown Seals (SOS)

(Generation III). The SHIELD SDSs will be installed in all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 in the fall of 2016. The NRC has concluded that the use of the Westinghouse SHIELD Passive Thermal SOS is acceptable for use in ELAP evaluation for order EA-12-049 as documented in ADAMS Accession No. ML14132A128.

Installation of the SHIELD seals will change the Unit's response in a BDBEE described in NEI 12-06. As a result, the site is in the process of performing additional calculations to ensure the site Fukushima strategy remains viable. These calculations Page 22 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 may alter the site strategy from the case described in W CAP- 17601-P. Calculations include CN-LIS-15-34, CN-LIS-1 5-39, and CN-LIS-1 5-40, which are being performed by Westinghouse. The new analyses will replace or supplement existing analyses which were previously demonstrated to be representative of Braidwood Station and remain consistent with the methodology in WCAP-1 7601-P.

CN-LIS-1 5-34, has extended the RCS inventory loss of single phase natural circulation to 58 hours6.712963e-4 days 0.0161 hours 9.589947e-5 weeks 2.2069e-5 months . Calculations CN-LIS-15-39 and CN-LIS-15-40 are in progress and may impact the site strategy. These results will be reported in the response to ISE questions 3.2.4.7.A and 3.2.1.8.A with the post outage compliance letter or in a future 6-month update.

16 3.2.1.4.8 Initial Values for Key Plant Item Closed During Onsite NRC Audit Parameters and Assumptions- (Ref. 31).

Confirm calculations to validate 8 Complete Closure supplied as part hours run time limit on ODAF pump of fourth 6-month update (Ref. 29).

batteries and DDAF room temp for pump operation and human occupancy. Also, confirm site phase 2 staffing study confirms the required time can be met for refilling diesel day tank.

17 3.2.1.5.A Monitoring Instruments and Control- Item Closed During Onsite NRC Audit Confirm additional parameters (Ref. 31).

evaluated for use in plant Complete Closure supplied as part of procedures/guidance or to indicate third 6-month update (Ref. 25).

imminent or actual core damage.

18 3.2.1.6.A Sequence of Events Confirm that

- Started The final time fine will be the final timeline has been time validated as the time sensitive actions, validated after detailed designs are listed in Attachment 1A, go through completed and procedures are the validation process. Results will be developed. The results may be provided in a future update.

provided in a future 6-month update.

19 3.2.1.6.13 Sequence of Events Confirm

- Item Closed During Onsite NRC Audit analysis to validate Phase 2 pump (Ref. 31).

capacities.

Complete Closure supplied as part of fourth 6-month update (Ref. 29).

20 3.2.1.9.A Use of portable pumps Confirm

- Item Closed During Onsite NRC Audit final design of strategies meets "use (Ref. 31).

of portable pumps" guideline in NEI Complete - Closure supplied as part 12-06 Section 3.2.2 Guideline 13.

Page 23 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 of fourth 6 month update (Ref. 29).

21 3.2.2.A SFP cooling -Verify procedure for Item Closed During Onsite NRC Audit SFP makeup via gravity drain; (Ref. 31).

confirm verification of timeline for lete ;C supplied as part performing the strategy; and confirm of fourth o update evaluation of SFP area for steam .

and condensation affects.

22 3.2.3.A Containment Confirm containment

- Complete BYR13-235/BRW -

reanalysis supports no Phase 1, 2, 0217-M, Containment Pressure and and 3 mitigation strategies are Temperature Response during an required because containment ELAP Event (Ref. 12), confirms that pressure and temperature are no actions are required to mitigate maintained within acceptable limits, containment temperature and pressure in Phases 1 and 2. These parameters will be monitored as part of the site strategy. Containment pressure and temperature will reach the FSG set point limits in > 30 days and 13.7 days, respectively. In addition, containment pressure and temperature will not reach design basis pressure and temperature limits until >30 days.

1/2BwFSG-12, Containment Cooling, provides operators with different options for restoring containment cooling to maintain containment temperature and pressure within limits.

Installation of the Westinghouse RCP SHIELD Passive SDS (Generation Ill) will reduce the amount of leakage into containment assumed in calculation BYR1 3-235/BRW-1 3-021 7-M (Ref.

12), resulting in additional margin to reaching design basis temperature and pressure.

23 3.2.3.8 Containment Confirm evaluation

- Item Closed During Onsite NRC Audit performed for the need to monitor (Ref. 31).

containment temperature.

Complete BYR13-235/BRW -

021 7-M (Ref. 12) shows containment temperature will reach the FSG setpoint limits in 13.7 days and reach design basis temperature limit in > 30 days. Even with these long timeframes, containment temperature has been added to the key parameter list to provide operators with additional tools. Monitoring of containment temperature can be performed on intermittent bases and will be Page 24 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 controlled by emergency procedures and 1/2BwFSG-7, Loss of Vital Instrument or Control Power.

Installation of the Westinghouse RCP SHIELD Passive SDS (Generation III) will reduce the amount of leakage into containment assumed in calculation BYR1 3-235/BRW-i 3-021 7-M (Ref.

12), resulting in additional margin to reaching FSG temperature setpoint and design basis temperature.

24 3.2.4.1.A Equipment cooling Confirm

- Item Closed During Onsite NRC Audit modification has been performed to (Ref. 31).

prevent DDAF pump from Complete Closure supplied as part overheating due to cooling water of fourth 6-month update (Ref. 29).

recirculation flow paths within the SX system cycling and overheating the pump within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

25 3.2.4.2.A Ventilation Equipment Cooling

- - Item Closed During Onsite NRC Audit Review licensee's evaluation of loss (Ref. 31).

of ventilation effects on equipment in Complete Closure supplied as part various rooms (DDAF pump room, of fourth 6-month update (Ref. 29).

battery rooms, control room, miscellaneous electrical equipment rooms) 26 3.2.4.2.13 A discussion is needed on the Item Closed During Onsite NRC Audit extreme high/low temperatures (Ref. 31).

effects of the battery's capability to Complete Closure supplied as part perform its function for the duration of fourth 6-month update (Ref. 29).

of the ELAP event and hydrogen gas ventilation during recharging batteries during Phase 2 and 3.

27 3.2.4.3.A Heat Tracing Confirm that potential Item Closed During Onsite NRC Audit adverse impacts from a loss of heat (Ref. 31).

tracing and normal heating on any Complete Closure supplied as part equipment credited for ELAP of fourth 6-month update (Ref. 29).

mitigation are adequately addressed.

In particular, ensure an RCS inventory and source of borated water is available for a BDBEE associated with extreme cold, ice, and snow.

28 3.2.4.4.A Communications Confirm that

- Item Closed During Onsite NRC Audit upgrades to the site's (Ref. 31).

communications systems have been Complete Communications upgrade completed.

detailed design is complete.

For the ft 2nd refuel outage (Al Ri 8),

the site will have 3 iridium satellite phones available for emergency response in the MCR area.

Page 25 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Emergency responders will use handheld radios in the talk around mode, sound powered phones, face-to-face, and bull horns.

2nd 2nd For the -

refuel outage (A2R18), the site will complete the NARS system upgrade and satellite communications system installation.

EC 399332 and EC399598 provide the design details respectively.

29 3.2.4.6.A Personnel Habitability Review

- Item Closed During Onsite NRC Audit licensee's evaluation of loss of (Ref. 31).

ventilation effects on personnel Complete Closure supplied as part of habitability and accessibility.

third 6-month update (Ref. 25).

30 3.2.4.7.A Water Sources Justify the time at

- Item Closed During Onsite NRC Audit which SG dryout will occur. (Ref. 31).

Started Braidwood Station has decided to install the Westinghouse reactor coolant pump (RCP) SHIELD Passive Thermal Shutdown Seals (SDS) (Generation Ill). The SHIELD SDSs will be installed in all 4 RCPs on Unit 2 in the fall of 2015 and on Unit 1 in the fall of 2016. The NRC has concluded that the use of the Westinghouse SHIELD Passive Thermal SDS is acceptable for use in ELAP evaluation for Order EA-1 2-049 as documented in ADAMS Accession No. ML14132A128.

Installation of the SHIELD seals will change the Units response in a BDBEE described in NEI 12-06. As a result, the site is in the process of performing additional calculations to ensure the site Fukushima strategy remains viable. Calculation CN-LIS-15-40, Exelon Byron and Braidwood Stations Delayed AFW FLEX Studies (Ref. 34), is in progress and may impact the site strategy. These results will be reported in the post outage compliance letter or in a future 6-month update.

31 3.2.4.8.A Electrical Power Sources I Isolation Item Closed During Onsite NRC Audit and interactions- confirm class 1 E (Ref. 31).

equipment is protected from faults in Complete Closure supplied as part portable/FLEX equipment and of fourth 6-month update (Ref. 29).

multiple sources do not attempt to power electrical buses.

Page 26 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 32 3.2.4.9.A Portable Equipment Fuel Confirm

- Item Closed During Onsite NRC Audit that complete analysis of fuel usage (Ref. 31).

requirements has been developed Complete The Units 1 and 2 "B" after the specific FLEX equipment is diesel fuel oil storage tanks contain identified and the fuel usage is 191,400 gallons of fuel. EC3941 49 determined. A discussion is needed and EC3941 56 provide Unit 1 and Unit on maintaining the quality of fuel 2 FLEX connections to these fuel stored in the tanks for extended sources. OBwFSG-5 provides periods of time operators the necessary direction to utilize these sources for refueling FLEX equipment. A fuel usage white paper has been developed to show this source will last for >31 days.

The site has an additional 191,400 gallons contained in the "A" train tanks. OBWFSG-50 provides the operators with the necessary direction to transfer the "A" train tanks to the "B" train tanks.

The site also has 125,000 gallons and 50,000 gallons storage tanks that are not robust and must be assumed unavailable, but would be used if available.

Fuel oil change out will be addressed in the FLEX preventive maintenance (PM) program.

33 3.2.4.10.A Load reduction to conserve DC Item Closed During Onsite NRC Audit power- Confirm sizing calculations (Ref. 31).

for FLEX generators and details of Complete Closure supplied as part load shedding.

of fourth 6-month update (Ref. 29).

NRC Audit Open Items Status Braidwood Station Response SE#9 Please provide adequate justification for the reactor Complete Braidwood station has coolant Pump (RCP) seal leakage rates calculated decided to install the Westinghouse according to the Westinghouse seal leakage model reactor coolant pump (RCP) SHIELD that was revised following the issuance of NSAL-1 4- Passive Thermal Shutdown Seals

1. The justification should include a discussion of the (SDS) (Generation Ill). The SHIELD following factors: SDSs will be installed on all four (4)

a. benchmarking of the seal leakage model against RCP5 on Unit 2 in the fall of 2015 and relevant data from tests or operating events, on all four (4) Unit 1 RCPs in the fall of

b. discussion of the impact on the seal leakage rate 2016. The use of Westinghouse seal leakage rates due to fluid temperatures greater reactor coolant pump (RCP) SHIELD than 550°F resulting in increased deflection at the Passive Thermal Shutdown Seals seal interface, (SDS) (Generation Ill) has been

c. clarification whether the second-stage RCP seal determined to be acceptable for use in would remain closed under ELAP conditions ELAP evaluations for satisfying Order predicted by the revised seal leakage model and a EA-12-049 as documented in ADAMS Page 27 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 technical basis to support the determination, and, Accession No. ML14132A128.

d. justification that the interpolation scheme used to The RCP seal leakage assumed in compute the integrated leakage from the RCP seals CN-LIS-15-34, Exelon Byron and from a limited number of computer simulations (e.g., Braidwood Stations Reactor Coolant three) is realistic or conservative. System ELAP Inventory Control Analysis SHIELD Reactor Coolant Pump Seal Packages, (Ref 33) is consistent with ADAMS Accession No. ML14132A128 limitations and conditions number 4.

SE #10 The NRC staff understands that Westinghouse has Complete -

recently recalculated RCP seal leakoff line pressures

a. Calculation NED-P-MSD-7 under loss of seal cooling events based on a revised concludes that the Number 1 seal seal leakage model and additional design-specific leakoff piping and components information for certain plants.

are capable of withstanding the

a. Please clarify whether the piping and all elevated pressures expected components (e.g., flow elements, flanges, valves, during an ELAP event as etc.) in your seal leakoff line are capable of determined by PWROG-14015-P.

withstanding the pressure predicted during an ELAP

b. Seal return to the VCT is isolated event according to the revised seal leakage model.

early in the ELAP event as

b. Please clarify whether operator actions are directed by 1/2BwCA-0.0 credited with isolating low-pressure portions of the Attachment B. This does not seal leakoff line and if so, please explain how these isolate the low pressure portions actions will be executed under ELAP conditions.

of the seal leakoff/return line. An

c. If overpressurization of piping or components could operator is dispatched to locally occur under ELAP conditions, please discuss any close the 1/2CV8100 valve planned modifications to the seal leakoff piping and (Containment Isolation Valve) component design and the associated completion using the manual override on the timeline.

MOV. This action is performed in

d. Alternately, please identify the seal leakoff piping the same step that isolates seal or components that would be susceptible to injection and seal cooling. No overpressurization under ELAP conditions, clarify credit is taken to protect the seal their locations, and provide justification that the seal leakoff lines from leakage rate would remain in an acceptable range if overpressurization by this action the affected piping or components were to rupture.

to close the 112CV8100 valves.

c. Braidwood station has decided to install the Westinghouse reactor coolant pump (RCP) SHIELD Passive Thermal Shutdown Seals (SDS) (Generation III). The SHIELD SDSs will be installed on all four (4) RCPs on Unit 2 in the fall of 2015 and on all four (4) Unit 1 RCPs in the fall of 2016.

Braidwood station has Westinghouse RCP Model 93A.

Credit for the SHIELD seals has been endorsed for Westinghouse Model 93A RCPs as documented in ADAMS Accession No. ML14132A128. Actuation of the SDS will reduce the number 1 seal leakoff pressure to values less _than _documented _in Page 28 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 PWROG-1401 5-P.

d. Calculation NED-P-MSD-7.

evaluates the potential overpressurization of the Number 1 seal leakoff lines. The lines are not expected to rupture at the pressure conditions for seal failures during an ELAP event.

NED-P-MSD-7 performed an evaluation at 2485 psig (RCS design pressure) and determined that the lines are qualified at this pressure.

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

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

1. Braidwood Station, Units 1 and 2, "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-1 2-049)," dated February 28, 2013 (RS-13-017).

2. NRC Order Number EA-1 2-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

3. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012.

4. Braidwood Station's First Six Month Status Report for the Implementation of FLEX, dated August 28th 2013.

5. Braidwood Station's Second Six Month Status Report for the Implementation of FLEX, dated February 28th, 2014.

6. Braidwood Station, Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigating Strategies) (TAC NOS. MF0895 AND MF0896), dated December 17, 2013.

7. BYR99-01 0/BRW-99-001 7-I Rev. 2, Documentation of the Basis of the Emergency Operating Procedures (EOP) Setpoints, dated September 2014.

Page 29 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015

8. BYR14-060/BRW-14-0080-E Rev. 0, Unit 1(2) 125 VDC Battery FLEX Coping Calculation

- Common CaIc Beyond Design Basis, dated September 2014.

9. BYR1 3-240/BRW-1 3-0222-M Rev. 0, Spent Fuel Pool Boil Off Analysis during an ELAP Event, dated April 2014.

10. BYR1 3-239/BRW-1 3-0221 -M Rev. 0, RCS Boration Analysis during an ELAP Event, dated August 2014.

11. Exelon Structural Drawing S-183 Rev. AF, Roadway Plan Plant and Construction Laydown Area, dated May 2014.

12.BYR1 3-235/BRW-1 3-0217-M Rev. 0, Containment Pressure and Temperature Response during an ELAP Event, dated September 2014.

13.BYR1 3-234/BRW-1 3-0216-M Rev. 0, Auxiliary FW Pump Room Temperature Analysis during and ELAP Event, dated April 2014.

14. BYR1 3-237/BRW-1 3-0219-M Rev. 0, MEER and Battery Room Conditions Flowing ELAP, dated July 2014.

15.BYR1 3-236/BRW-1 3-0218-M Rev. 0, Control Room and Auxiliary Electric Equipment Room heat up and Ventilation during an ELAP, dated June 2014.

16.BYR1 3-026/BRW-1 3-0031 -M Rev. 0, Transient Analysis of SX System Following Loss of A-C Power, dated August 2013.

17.BYR14-046/BRW-14-0058-M Rev. 0, Containment Environment Following an Extended Loss of AC Power During Shutdown, dated September 2014.

18.WCAP 17601-P Rev. 1, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs, dated January 2013.

19.BRW-97-0340-E Rev. 3, Battery Duty Cycle and Sizing for the Braidwood Diesel Driven Auxiliary Feedwater Pumps, dated August 2014.

20. BYR1 3-144/BRW-1 3-0160-M Rev. 2, FLEX Pump Sizing and Hydraulic Analysis, dated December 2014.

21. BRW-1 4-0030-M Rev. 0, Godwin Pump Suction Line Hydraulic Analysis to Support FLEX, dated August 2014.

22. Letter to Mr. Jack Stringfellow requesting endorsement of Westinghouse position paper entitled 'Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in support of the Pressurized Water Reactor Owners Group (PWROG)", Accession Number ML13276A183, date January 8, 2014.

23. Westinghouse Correspondence LTR-FSE-1 4-43, Revision 0, "Exelon Generation Company, LLC Mitigation Strategies Order (EA-12-049) Design ELAP Simulation Parameters," dated June 15, 2015.

24. Westinghouse Correspondence LTR-FSE-14-61 Rev.0 "Exelon Generation Company, LLC Mitigation Strategies Order (EA-1 2-049) Open and Confirmatory Item Responses,"

dated June 15, 2015.

25. Braidwood Station's Third Six Month Status Report for the Implementation of FLEX, dated August 28th 2014.

Page 30 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015

26. BRW-1 4-0255-M Rev. 1, Braidwood Units 1 and 2 FLEX Steam Generator Degraded Heat Transfer Analysis through 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , dated December 2014.

27. BYR14-129/BRW-14-0212-M Rev. 0, RWST Usage during FLEX Scenarios, dated October 2014.

28. BRW-1 4-0211 -M Rev.0, Evaluation of Tank and Hose Freezing during an ELAP, dated September 2014.

29. Braidwood Station's Fourth Six Month Status Report for the Implementation of FLEX, dated February 28, 2015.

30. BRW-1 5-0002-S Rev.0, Evaluation of FLEX Equipment Haul Paths for Soil Liquefaction Potential, dated March 2015.

31. Braidwood Station, Units 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 and MF0896), dated May 27, 2015 (ADAMS Accession No. ML15134A459).

32. PWROG-14027-P Rev. 3, No.1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of all AC Power, dated April 2015.

33. CN-LIS-1 5-34 Rev. 0, Exelon Byron and Braidwood Stations Reactor Coolant System ELAP Inventory Control Analysis SHIELD Reactor Coolant Pump Seal Packages, dated July, 13, 2015.

34. CN-LlS-15-40, Exelon Byron and Braidwood Stations Delayed AFW FLEX Studies, Draft

35. CN-LIS-1 5-39, Exelon Byron and Braidwood Stations Reactor Coolant System ELAP Long-Term Subcriticality Analysis with Low-Leakage Reactor Coolant Pump Seal Packages, Draft Page 31 of 34

Attachment 1A Sequence of Events Timeline Time Action Remarks /

Elapsed Time Action Constraint Item Applicability Y/N2 The times to complete actions in the Events Timeline are based on operating judgment, the conceptual designs, and the current supporting analyses. The final timeline will be time validated once detailed designs are completed, procedures are developed, and the results will be provided in a future six (6) month update.

Event Starts, BDBEE occurs, Unit 1 and Unit 2 reactors 1 0 NA Unit 1 and Unit 2 automatically trip and all rods are inserted.

@100% power Loss of off-site power (LOOP) affecting both units occurs.

2 1 min Emergency Operating Procedures, (EOPs) and Station Black NA _BwCA 0.0, Loss of Out, (SBO), Procedures are entered. All AC Power, action.

3 5-50 mins Verify DDAF Pp is operating properly. Y - 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months _BwCA 0.0, Loss of All AC Power, action. Reference WCAP 17601-P (Ref. 18).

4 3-5 mins MCR closes C & D S/G PORVs to conserve inventory. Y -5 _BwCA 0.0, Loss of minutes All AC Power, action. Reference WCAP 17601-P (Ref. 18). and operator judgment 2

Instructions: Provide justification if No or NA is selected in the remark column If yes include technical basis discussion as requires by NET 12-06, Section 3.2.1.7 Page 32 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Time Action Remarks /

Elapsed Time Action Constraint Item Applicability v/N2 5 10-30 mins Attempt starting Emergency DIG's. NA _BwCA 0.0, Loss of All AC Power, action.

6 30 mins ELAP condition recognized and ELAP Procedures are entered. NA _BwCA 0.0, Loss of All AC Power, attachment B for ELAP BRW-14-0080-E 7 35 mins to 65 mins Operators dispatched to perform DC Bus Load Shed. Y 65 minutes BR 1-8i4-0080-E 8 30 mins to 6 hrs Connect FLEX 480V AC generators to ESF bus _32X and verify Y 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months they are supplying power to Div 2 125V DC battery chargers.

SX Short Cycle Cooling EC is aligned to cool the B AF Pp Y 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months _BwCA 0.0, Loss of 9 55 mins to 90 mins -

within 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after pump start. All AC Power, action. BRW _____________________________________________________

0031-M (Ref. 16) 1.5 hrs Start depressurization of SGs to 260 psig at approximately Y 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months _BwCA 0.0, Loss of 10 -

75°F/hr cooldown with SG PORV local/manual operation. SO All AC Power, feed is controlled with Local/Manual operation of AFW flow action. BRW control valves. 0221-M (Ref. 10) 11 2.25 hrs SI Accumulator borated water begins to inject into the RCS. NA Operator Judgment Setup and establish ventilation in AEER and MCR. 475 Directed from 3 4.5 hrs OBFSG-51 and BYR13-236/BRW-13-0218-M (Ref. 15)

Maintain SG pressure 260psig and RCS temperature between NA BRW-13-0221-M 12 3.5 hrs 420F 410F with SG PORV operation.

- (Ref. 10)

Maintain SG level.

Isolate SI Accumulators. NA 1I2BwFSG -10 action 13 5 7 hrs Page 33 of 34

Braidwood Station, Units 1 and 2-Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Time Action Remarks /

Elapsed Time Action Constraint item Applicability Y/N 14 6 10 hrs

- Deploy all hoses and connections in FHB for alternate SFP Fill Y 10.94 Directed from strategy before FHB becomes uninhabitable from SFP Boiling, hours OBwFSG5 and OFSG-11. BRW 0222-M (Ref. 9) 15 11 - 14 hrs Stage and connect Phase 2 high pressure FLEX Pumps and Y 15.3

- PWROG-14027-P ensure they are available to supply borated make-up to the RCS. hours Rev. 3 16 16-20 hrs Connect Phase 2 med head FLEX Pumps and ensure they are NA 1/2BwFSG-5action available to supply make-up to the SO's.

17 24 hrs Initiate SFP Make up via OA Refueling Water Purification Pump NA OBwFSG-1 laction.

as required for level and temperature control. BRW1 30222M (Ref. 9) 18 24 hrs National SAFER Response Center resources begin arriving on NA National SAFER site. Response Center Guide 19 24 72 hrs

- Continue to maintain critical functions of Core Cooling (via NA End of analytical DDAF), RCS Inventory Control (via FLEX pump injection to simulation RCS) and SFP Cooling (via FLEX pump injection to SFP). Utilize initial National SAFER Response Center NRC equipment and resources.

Page 34 of 34

v t e Letter Sequence Other
TAC:MF0895, (Open) TAC:MF0896, (Open)
Initiation Request Acceptance, Acceptance Administration Questions Answers Results Approval... Other: ML13338A624, ML14356A004, ML15068A215, RS-13-113, 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), RS-14-195, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), RS-14-205, 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), RS-15-016, Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), RS-15-026, Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), RS-15-208, 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-12-049), 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), RS-16-020, Sixth 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)
MONTHYEAR2015-12-16 [Table View]

RS-15-208, 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-12-049)

Text

Subject:

References:

Enclosure:

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