ML14062A050

Revised 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 No. EA-12-049)

ML14062A050
Person / Time
Site:	Watts Bar
Issue date:	02/07/2014
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14064A240	List: ML14062A050
References
CNL-14-014, EA-12-049, L44 140207 002, TAC MF0950, TAC MF1177
Download: ML14062A050 (86)

Text

ENCLOSURE 1, ATTACHEMENT 3 OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURES, THIS LETTER IS DECONTROLLED.

L44 140207 002 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37 402 CNL-14-014 February 7, 2014 10 CFR 2.202 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington , D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 1 Facility Operating License No. NPF-90 NRC Docket No. 50-390 Watts Bar Nuclear Plant, Unit 2 Construction Permit No. CPPR-92 NRC Docket No. 50-391

Subject:

Revised Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-B asis External Events (Order Number EA-12-049) for Watts Bar Nuclear Plant (TAC Nos. MF0950 and MF1177)

References:

1. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012 , Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Watts Bar Nuclear Plant," dated February 28, 2013 (ML13067A030)

2. Letter from TVA to NRC, "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) for Watts Bar Nuclear Plant," dated August 28, 2013(ML13247A288)

3. Letter from NRC to TVA, "Watts Bar Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall lntergraded Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0950 and MF1177)," dated December 20, 2013(ML13343A025)

"Enclosure(s) transmitted herewith contain(s) SUNSI. when separated from Enclosure 1, Attachment 3, this transmittal document is decontrolled ."

Printed on recycled paper

U.S. Nuclear Regulatory Commission Page2 February 7, 2014 On February 28, 2013, the Tennessee Valley Authority (TVA) submitted an Overall Integrated Plan (OIP) in response to the March 12, 2012, Commission Order modifying licenses with regards to requirements for mitigation strategies for beyond-design-basis external events, Order number EA-12-049, forthe Watts Bar Nuclear Plant (WBN), Units 1 and 2 (Reference 1). On August 28, 2013, TVA provided the first six-month status report to the OIP (Reference 2).

The OIP submitted in Reference 1 employed a strategy using reactor coolant pump (RCP) low leakage seals. TVA has revised its strategy to use the existing conventional RCP seals.

This change in RCP seals requires a revision to the OIP submitted by Reference 1. These changes mainly impact Attachment 1A, "Sequence of Events Timeline," and required a revision to the reactor coolant inventory calculation supporting this strategy.

These changes were presented and discussed with the Nuclear Regulatory Commission (NRC) through the mitigation strategies audit process. Based on a review of TVA's plan, including the six-month update, and information obtained through the mitigation strategies audit process, the NRC concluded in its Interim Staff Evaluation that the plan, when properly implemented, will meet the requirements of Order EA-12-049 at WBN, Units 1 and 2 (Reference 3). The Interim Staff Evaluation included two open items. Open item 3.2.1.6.A requires revision to the Sequence of Events due to use of the conventional RCP seals, for reanalysis by the NRC. The revised OIP provides that information. The second open item, 3.2.4.8.A, requires resolution for justification regarding use of pre-staged diesel generators.

TVA will provide justification regarding use of pre-staged diesel generators by February 28, 2014, to resolve Interim Staff Evaluation open item 3.2.4.8.A.

The purpose of this letter is to provide a revision to the OIP submitted by Reference 1.

Specifically, Enclosure 1 of this letter provides the revised OIP. This revised OIP replaces in its entirety the OIP submitted by Reference 1. This revision includes the revised RCP seal strategy and supporting changes previously discussed. This OIP employs submersible intermediate and high pressure mitigation strategy (FLEX) pumps located on elevations 692 and 737 of the auxiliary building rather than FLEX pumps located on the auxiliary building roof. The revised OIP provides information for reanalysis regarding Reference 3, open item 3.2.1.6.A. This revision updates the status to the OIP "Open Items" table. OIP open items 2, 3, 5-8, 11, and 17 are closed and item 13 has started. OIP Attachment 2, "Milestone Schedule," has been revised as noted in the revised target completion date column. This letter also serves as the second six-month status report which is due by February 28, 2014.

The information provided in Attachment 3 to Enclosure 1 is considered to contain information concerning physical protection not otherwise designated as Safeguards Information and is designated "Security Sensitive Information" as defined in 10 CFR 2.390(d)(1). Accordingly, TVA request that the information provided in Attachment 3 to the Enclosure to this letter be withheld from public disclosure.

U.S. Nuclear Regulatory Commission Page3 February 7, 2014 provides a list of regulatory commitments.

If you have any questions regarding this report, please contact Kevin Casey at (423) 751-8523.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 7th day of February 2014.

ully, Vice President, Nuclear Licensing

Enclosures:

1. Watts Bar Nuclear Plant, Mitigation Strategies for Beyond-Design-Basis External Events Revised Overall Integrated Plan

2. List of Commitments cc (Enclosures):

NRR Director - NRC Headquarters NRO Director - NRC Headquarters NRC Regional Administrator - Region II NRR Project Manager - Watts Bar Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRR Mitigation Strategies Director - NRC Mitigation Strategies Directorate

ENCLOSURE 1 WATTS BAR NUCLEAR PLANT MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS REVISED OVERALL INTEGRATED PLAN

TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT UNITS 1 AND 2 FLEX OVERALL INTEGRATED PLAN Revision 1 E-1

General Integrated Plan Elements Watts Bar Units 1 and 2 Determine Applicable Extreme External Hazard Ref: NEI 12-06 Section 4.0 -9.0 JLD-ISG-2012-01 Section 1.0 The Watts Bar site has been evaluated and the following applicable hazards have been identified:

• Seismic events

• External flooding

• Severe storms with high winds

• Snow, ice, and extreme cold

• Extreme heat The Watts Bar site has been reviewed against the Nuclear Energy Institute (NEI) guidance document NEI 12-06 (Reference 2) and determined that the hazards Flexible and Diverse Coping Mitigation Strategies (FLEX) equipment should be protected from include seismic; external flooding; severe storms with high winds; snow, ice and extreme cold; and extreme high temperatures. Watts Bar has determined the functional threats from each of these hazards and identified FLEX equipment that may be affected. The FLEX storage locations will provide the protection required from these hazards.

Watts Bar is also developing procedures and processes to further address plant strategies for responding to these various hazards.

Seismic:

Per NEI 12-06 (Reference 2), seismic hazards must be considered for all nuclear sites. As a result, the credited FLEX equipment will be assessed based on the current Watts Bar seismic licensing basis to ensure that the equipment remains accessible and available after a beyond-design-basis external event (BDBEE) and that the FLEX equipment does not become a target or source of a seismic interaction from other systems, structures or components. From References 4 and 5, Sections 2.5.2.4 and 2.5.2.7, safe shutdown earthquake (SSE) requirements are 0.18g horizontal and 0.12 g vertical maximum rock accelerations. For an operating basis earthquake (OBE), the maximum horizontal and vertical ground accelerations are 0.09g and 0.06 g, respectively. The FLEX strategies developed for Watts Bar will include documentation ensuring that any storage locations and deployment routes meet the FLEX seismic criteria.

Liquefaction TVA has assessed the potential liquefaction of its FLEX deployment routes and determined that the primary and backup deployment routes are not subject to detrimental liquefaction. (Reference 22)

External Flooding:

The types of events evaluated to determine the worst potential flood included (1) probable maximum storm on the total watershed and critical sub-water sheds including seasonal variations and potential consequent dam failures and (2) dam failures in a postulated SSE or OBE with guide specified concurrent flood conditions.

Those safety-related facilities, systems, and equipment located in the containment structure are protected from flooding by the Shield Building structure with those accesses and penetrations below the maximum flood level designed and constructed as watertight elements (References 4 and 5, Section 2.4.2.2). From References 4 and 5, Section 2.4.3.6, the Diesel Generator Buildings to the north and the pumping station to the southeast of the main building complex must be protected from flooding to assure plant safety. The Diesel Generator Buildings operating floors are at elevation E-2

742.0 ft., which are above the maximum computed elevation, including wind wave run-up. Per References 4 and 5, Section 2.4.14.2.3, the intake pumping station is designed to retain full functional capability to maintain cooling of plant loads. All equipment required to maintain the plant safely during the flood is either designed to operate submerged, is located above the maximum flood level, or is otherwise protected.

Specific analysis of Tennessee River flood levels resulting from ocean front surges and tsunamis is not required because of the inland location of the plant (References 4 and 5, Section 2.4.6). Snow melt and ice jam considerations are also unnecessary because of the temperate zone location of the plant (References 4 and 5, Sections 2.4.2.2 and 2.4.7). Flood waves from landslides into upstream reservoirs required no specific analysis, in part because of the absence of major elevation relief in nearby upstream reservoirs and because the prevailing thin soils offer small slide volume potential compared to the available detention space in reservoirs (References 4 and 5, Section 2.4.2.2). Seiches pose no flood threats because of the size and configuration of the lake and the elevation difference between normal lake level and plant grade (References 4 and 5, Sections 2.4.2.2 and 2.4.5).

Per References 4 and 5, Section 2.4.2.2, the maximum plant site flood level from any cause is elevation 734.9 ft. This information has been superseded by Reference 9. The maximum plant site flood level from any cause is elevation 739.2 ft. (still reservoir). This elevation would result from the probable maximum storm. Coincident wind wave activity results in wind waves of up to 2.2 ft. (crest to trough). Run up on the 4:1 slopes approaching the Diesel Generator Building reaches elevation 741.6 ft. Wind wave run up on the critical wall of the Intake Pumping Station reaches elevation 741.7 ft. and wind wave run up on the walls of the Auxiliary, Control and Shield Buildings reaches elevation 741.0 ft (Reference 9).

In summary, all equipment required to maintain the plant safety during all flooding events including the design basis flood (DBF) is either designed to operate submerged, is located above the maximum flood level, or is otherwise protected. Accordingly, FLEX strategies will be developed for consideration of external flooding hazards. In addition, Watts Bar is also developing procedures and strategies for delivery of offsite FLEX equipment during Phase 3 which considers regional impacts from flooding.

High Wind:

Figures 7-1 and 7-2 from Reference 2 were used for this assessment.

Watts Bar is susceptible to hurricanes as the plant site is within the contour lines shown in Figure 7-1 of Reference 2.

It was determined the Watts Bar site has the potential to experience damaging winds caused by a tornado exceeding 130 mph. Figure 7-2 of Reference 2 indicates a maximum wind speed of 200 mph for Region 1 plants, including Watts Bar. Therefore, high-wind hazards are applicable to the Watts Bar site.

In summary, based on available local data and Figures 7-1 and 7-2 of Reference 2, Watts Bar is susceptible to severe storms with high winds so the hazard is screened in.

Snow, Ice, and Extreme Cold Per the FLEX guidance all sites should consider the temperature ranges and weather conditions for their site in storing and deploying their FLEX equipment. That is, the equipment procured should be suitable for use in the anticipated range of conditions for the site, consistent with normal design practices.

Applicability of snow and extreme cold:

The Watts Bar Site is located approximately 50 miles northeast of Chattanooga in Rhea County, Tennessee, on the west bank of the Tennessee River at mile 528. The site is approximately 1-1/4 miles south of the Watts Bar Dam and approximately 31 miles north-northeast of the Sequoyah E-3

Nuclear Plant (References 4 and 5, Section 2.1.1.1). The approximate site location is given below, from References 4 and 5, Section 2.1.1.1:

LATITUDE (degrees/minutes): 35°36' N LONGITUDE (degrees/minutes): 84°47' W From References 4 and 5, Section 2.3.2.2, mean temperatures at the Watts Bar site have been in the low 40s°F in the winter. Extreme minima temperatures recorded were -20°F at Decatur and -10oF at Chattanooga in the winter.

Outside environment normal operational conditions from Environmental Data Environment Drawing 47E235-36 are given as Average 60, Maximum 95°F and Minimum 13°F. These temperatures were used as a basis in establishing Operational Abnormal temperatures of Maximum 102°F and Minimum 6°F temperatures. This condition could exist for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per excursion and will occur less than 1% of plant life. (Reference 21).

Reference 2 states plants above the 35th parallel should provide the capability to address the hindrances caused by extreme snow and cold. The Watts Bar site is above the 35th parallel; therefore, the FLEX strategies must consider the hindrances caused by extreme snowfall with snow removal equipment, as well as the challenges that extreme cold temperature may present.

Applicability of ice storms:

The Watts Bar site is not a Level 1 or 2 region as defined by Figure 8-2 of Reference 2; therefore, the FLEX strategies must consider the hindrances caused by ice storms.

In summary, based on the available local data and Figures 8-1 and 8-2 of Reference 2, the Watts Bar site does experience significant amounts of snow, ice, and extreme cold temperatures; therefore, the hazard is screened in.

Extreme Heat:

Per Reference 2, all sites must address high temperatures. Virtually every state in the lower 48 contiguous United States has experienced temperatures in excess of 110F. Many states have experienced temperatures in excess of 120F. Sites that should address high temperatures should consider the impacts of these conditions on the FLEX equipment and its deployment. From References 4 and 5, Section 2.3.2.2, mean temperatures at the Watts Bar site can reach the upper 70sF in the summer. Extreme maxima temperature recorded was 108°F at Decatur, Tennessee and 106°F at Chattanooga, Tennessee in the summer.

Outside environment normal operational conditions from Environmental Data Environment Drawing 47E235-36 are given as Average 60, Maximum 95°F and Minimum 13°F. These temperatures were used as a basis in establishing Operational Abnormal temperatures of Maximum 102°F and Minimum 6°F temperatures. This condition could exist for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per excursion and will occur less than 1% of plant life. (Reference 21).

Therefore, for selection of FLEX equipment the Watts Bar site will consider the site maximum expected temperatures in their specification, storage, and deployment requirements, including ensuring adequate ventilation or supplementary cooling, if required.

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Key Site assumptions to Provide key assumptions associated with implementation of FLEX implement NEI 12-06 Strategies:

strategies.

Assumptions are consistent with those detailed in NEI 12-06, Ref: NEI 12-06 Section 3.2.1 Section 3.2.1. Analysis has been performed consistent with the recommendations contained within the Executive Summary of the Pressurized Water Reactor owners group (PWROG) Core Cooling Position Paper (Reference 13) and assumptions from that document are incorporated in the plant specific analytical bases.

NEI 12-06 Assumptions The initial plant conditions are assumed to be the following:

• Prior to the event the reactor has been operating at 100 percent rated thermal power for at least 100 days or has just been shut down from such a power history as required by plant procedures in advance of the impending event.

• At the time of the postulated event, the reactor and supporting systems are within normal operating ranges for pressure, temperature, and water level for the appropriate plant condition. All plant equipment is either normally operating or available from the standby state as described in the plant design and licensing basis.

The following initial conditions are to be applied:

• No specific initiating event is used. The initial condition is assumed to be a loss of offsite power (LOOP) at a plant site resulting from an external event that affects the off-site power system either throughout the grid or at the plant with no prospect for recovery of off-site power for an extended period. The LOOP is assumed to affect all units at a plant site.

• All installed sources of emergency on-site ac power and station blackout (SBO) Alternate ac power sources are assumed to be not available and not imminently recoverable.

• Cooling and makeup water inventories contained in systems or structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles are available.

• Normal access to the ultimate heat sink (UHS) is lost, but the water inventory in the UHS remains available and robust piping connecting the UHS to plant systems remains intact. The motive force for UHS flow, i.e., pumps, is assumed to be lost with no prospect for recovery.

• Fuel for FLEX equipment stored in structures with designs which are robust with respect to seismic events, floods and high winds and associated missiles, remains available.

• 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.

• Other equipment, such as portable ac power sources, portable back up dc power supplies, spare batteries, and equipment for 50.54(hh) (2), may be used provided it is reasonably protected from the applicable external hazards per Sections 5 through 9 and Section 11.3 of NEI 12-06 and has predetermined hookup strategies with appropriate procedures/guidance and the equipment is stored in a relative close vicinity of the site.

• Installed electrical distribution system, including inverters and battery chargers, remain available provided they are protected consistent with current station design.

• No additional events or failures are assumed to occur immediately prior to or during the event, including security events.

• Reliance on the fire protection system ring header as a water source is acceptable only if the header meets the criteria to be considered robust with respect to seismic events, floods, and high winds, and associated missiles.

The following additional boundary conditions are applied for the reactor transient:

• Following the loss of all ac power, the reactor automatically trips and all rods are inserted.

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• The main steam system valves (such as main steam isolation valves, turbine stops, atmospheric dumps, etc.), necessary to maintain decay heat removal functions operate as designed.

• Safety/Relief Valves (S/RVs) or Power Operated Relief Valves (PORVs) initially operate in a normal manner if conditions in the reactor coolant system (RCS) so require. Normal valve reseating is also assumed.

• No independent failures, other than those causing the extended loss of alternating current (ac) power (ELAP)/loss of normal access to the ultimate heat sink (LUHS) event, are assumed to occur in the course of the transient.

Sources of expected pressurized water reactor (PWR) reactor coolant inventory loss include:

• Normal system leakage

• Losses from letdown unless automatically isolated or until isolation is procedurally directed

• Losses due to reactor coolant pump (RCP) seal leakage (rate is dependent on the (RCP) seal design)

The initial spent fuel pool (SFP) conditions are:

• All boundaries of the SFP are intact, including the liner, gates, transfer canals, etc.

• Although sloshing may occur during a seismic event, the initial loss of SFP inventory does not preclude access to the refueling deck around the pool.

• SFP cooling system is intact, including attached piping.

• SFP heat load assumes the maximum design basis heat load for the site.

Containment Isolation Valves:

• It is assumed that the containment isolation actions delineated in current SBO coping capabilities is sufficient.

Assumptions Specific to Watts Bar Site A1. The Auxiliary Feedwater Supply Tank (AFWST) and associated piping are seismically qualified or hardened against missiles and tornados. Watts Bars AFWST will be qualified to be robust with respect to high winds and seismic events.

A2. Watts Bar Unit 1 is a mirror image of Unit 2, with only minor differences existing between plants. For this reason, any sections or sketches which are only shown for a single unit would be directly analogous to the other unit.

A3. The design hardened connections added for the purposes of FLEX are protected against external events or are established at multiple and diverse locations.

A4. Flood and seismic re-evaluations pursuant to the Title 10 of the Code of Federal Regulations (10 CFR) 50.54(f) letter of March 12, 2012 are not completed and therefore not assumed in this submittal. As the re-evaluations are completed, appropriate issues will be entered into the corrective action program.

A5. Required staffing levels will be determined consistent with guidance contained in NEI 12-06 for each of the site specific FLEX strategies. Assumed available staffing levels will be determined consistent with NEI 12-01, as described below.

A. Post event time: 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

B. Post event time: 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g., private resource providers or public sector support).

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C. Post event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

Staffing levels will be assessed to confirm this assumption, or adjustments will be made to plant staffing or FLEX design to meet this requirement.

A6.Watts Bar will design one new storage location to protect portable FLEX equipment against all five external hazards. This location is referred to in this document as the FLEX equipment storage building (FESB). At present, the FESB is located outside the Protected Area boundary but close to access portals. FLEX equipment will be stored/staged in the FESB or inside of site Class I structures.

A7. Exceptions to the site security plan or other license/site specific requirements will be addressed, as required.

A8. Instrumentation on FLEX equipment will be used to confirm continual performance.

A9. This plan defines strategies capable of mitigating a simultaneous loss of all alternating current (ac) power and loss of normal access to the ultimate heat sink resulting from a beyond-design-basis event by providing adequate capability to maintain or restore core cooling, containment, and SFP cooling capabilities at all units on a site. Though specific strategies are being developed, due to the inability to anticipate all possible scenarios, the strategies are also diverse and flexible to encompass a wide range of possible conditions. These pre-planned strategies developed to protect the public health and safety will be incorporated into the site emergency operating procedures in accordance with established EOP change processes, and their impact to the design basis capabilities of the unit evaluated under 10 CFR 50.59. The plant Technical Specifications contain the limiting conditions for normal unit operations to ensure that design safety features are available to respond to a design basis accident and direct the required actions to be taken when the limiting conditions are not met. The result of the beyond-design-basis event may place the plant in a condition where it cannot comply with certain Technical Specifications and/or with its Security Plan, and as such, may warrant invocation of 10 CFR 50.54(x) and/or 10 CFR 73.55(p). (Reference12)

Extent to which the guidance, Include a description of any alternatives to the guidance, and JLD-ISG-2012-01 and NEI 12- provide a milestone schedule of planned action.

06, are being followed.

Identify any deviations to JLD-ISG-2012-01 and NEI 12-06.

Ref: JLD-ISG-2012-01 Ref: NEI 12-06 Section 13.1 Watts Bar Nuclear plans to fully comply with the guidance in JLD-ISG-2012-01 (Reference 3) and NEI 12-06 (Reference 2) in implementing FLEX strategies for the Watts Bar site.

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Provide a sequence of events Strategies that have a time constraint to be successful should be and identify any time identified with a technical basis and a justification provided that constraint required for success the time can reasonably be met (for example, a walkthrough of including the technical basis deployment).

for the time constraint.

Describe in detail in this section the technical basis for the time Ref: NEI 12-06 Section 3.2.1.7 constraint identified on the sequence of events timeline Attachment 1A.

JLD-ISG-2012-01 Section 2.1 See attached sequence of events timeline (Attachment 1A).

Technical Basis Support information, see attached NSSS Significant Reference Analysis Reconciliation Table (Attachment 1B)

The sequence of events and any associated times constraints are identified below for Watts Bar Reactor Core Cooling and Heat Removal (steam generators available) strategies for FLEX Phases 1 through Phase 3. See attached sequence of events timeline (Attachment 1A) and the technical basis support information in Attachment 1B for a summary of this information.

Discussion of action items identified in Attachment 1A table: (Non-Flood Event)

1. Declare ELAP - ELAP entry conditions can be verified by control room staff and it is validated that emergency diesel generators are not available. This step is time sensitive and needs to occur within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following the start of the event to provide operators with guidance to perform ELAP actions.

2. Align and place in service the 225 kva 480vAC Diesel Generators (480v FLEX Generators). This provides charging current to the 125v DC Vital Batteries and ensures 125v DC Vital Battery power (control) and through the Vital Inverters 120v AC Vital Instrument Power (instrument indication).

3. Verify 125v DC Vital Chargers energized and supplying required load to the 125v DC Vital Batteries.

IF not, THEN complete Extended Load Shed for any Vital Battery not being supplied its required load within 90 minutes (1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) following the start of the event. This ensures 8-hour coping time for the 125v DC Vital Batteries.

4. Debris Removal (Access) - The earliest need for debris removal access paths is to support alignment of the Low Pressure (LP) FLEX Pumps to the essential raw cooling water (ERCW) headers at the Intake Pumping Station (IPS). This process will be initiated in order to support FLEX equipment deployment depending on the resources available.

5. Initiate Damage Assessment - Watts Bar will develop a post event damage assessment procedure.

The damage assessment will evaluate and document the condition of plant systems, structures and components (SSCs) after an ELAP event. The assessment will be consistent with the guidelines contained in supplement 5 of Reference 16.

6. Stage and align the LP FLEX pumps (Dominator and Triton) - staged and aligned to take suction from the intake channel with discharge routed to the Essential Raw Cooling Water (ERCW) FLEX connections inside the Intake Pumping Station (IPS). An alternate or additional raw water source could come from the Condenser Circulating Water (CCW) Cooling Tower basin supplying suction to a Dominator LP FLEX Pump with its discharge routed to FLEX (or B.5.b) connection at the 5th DG Building.

7. Initiate RCS depressurization and cooldown to commence as soon as possible due to RCP seal failure probability. At rated pressure a potential leakage rate of 21 gpm per RCP following the event is possible. An RCS cooldown rate of 75-100 °F per hour should be sustained until stabilized E-8

at ~ 300 PSIA Steam Generator (SG) Pressure. Maintain RCS pressure greater than 250 psig to avoid Cold Leg Accumulator (CLA) nitrogen injection into the RCS. The CLAs are maintained at a boron concentration of 3100 - 3300 ppm. Cooldown and depressurization should be stabilized within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

8. Complete 3 MWe FLEX Diesel Generators (6.9KV FLEX Generators), 6.9KV Shutdown Boards and emergency feeder breakers and 480v Shutdown Board alignment. This is to ensure switching at the EDG building and shutdown board rooms are complete, potential board loading is reduced and interlocks are cleared to allow the emergency feeder breaker to be used to safely power the 6.9KV Shutdown Boards from the 6.9KV FLEX DG.

9. Energize the 6.9KV Shutdown Boards with the 6.9KV FLEX DGs. Place the following components in service and restore pressurizer level: Component Cooling Water Pumps and Safety Injection Pumps (SIPs), as required to recover and maintain RCS Pressurizer level. The SIPs take suction for the RWST which maintains a boron concentration of between 3100 and 3300 ppm.

Note: While the TDAFWP is not anticipated to fail, a secondary source of steam generator makeup can be provided by the MDAFWPs, if required, as soon as the 6.9KV FLEX DGs are in service.

The Intermediate Pressure (IP) FLEX pumps will be staged and aligned as soon as feasible (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

10. Place the following equipment in service, if required: Verify 6.9KV FLEX DG loading between starts. Auxiliary Air Compressors, Motor Driven Auxiliary Feedwater Pumps (MDAFWPs) and/or Spent Fuel Pool (SFP) Cooling Pump.

11. Stage and align the High Pressure (HP) FLEX pumps (AB el. 692). The primary suction alignment is from the Refueling Water Storage Tanks RWST) which maintains a boron concentration of 3100-3300 ppm). The secondary suction alignment is from the Boric Acid Tank (BAT) which maintains a boron concentration of ~ 6900 ppm. Complete 480v AC power connections for these pumps.

12. Stage and align the IP FLEX Pumps at the AFWST as backup for SG makeup (backup to the TDAFWPs and MDAFWPs). Suction is aligned from the AFWST and discharge can be routed to FLEX connections upstream of the TDAFWP Level Control Valves (LCVs) (primary) or MDAFWP LCVs (alternate). These are diesel driven pumps.

13. Deploy hoses and spray nozzles to the SFP area as a contingency within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. Hoses can be routed to supply makeup from FLEX connections on the refuel floor or from the elevation below the refuel floor. This is the need time based on the most limiting SFP time when boil off occurs (Reference 18).

14. Alternate fuel supply will need to be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This accounts for the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in which the FLEX equipment fuel supply depletes and the deployment time.

Note: If the Condensate Storage Tanks (CSTs) survive the event they will supply additional water reserve per unit to the Auxiliary Feedwater Pumps.

15. The AFWST will be depleted in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, makeup options will need to be evaluated and directed.

Potential sources of clean water makeup are the Demineralized Water Storage Tank (DWST), U1 and U2 Primary Water Storage Tanks (PWST) and the Tritiated Water Storage Tank (TWST). If the AFWST is depleted the operating auxiliary feedwater pumps suction will be realigned to the ERCW headers to extend core cooling.The LP FLEX pumps have been aligned to the ERCW headers to provide a raw water input prior to the AFWST depleting. Available raw water in the ERCW headers (without LP FLEX pumps supply) will deplete in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> for Unit 1 and 4.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> for Unit 2 (Reference 23).

16. Acceptable control room lighting will be available for long term support. This is not a time constraint as control room lighting is available via batteries, and portable lighting will be available E-9

if required.

17. The Vital Battery Room and Shutdown Board Room heating, ventilation, and air conditioning (HVAC) study determined that ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into the ELAP event; at which point it can be monitored periodically, if needed (Reference 14).

18. The Main Control Room HVAC study determined that ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into ELAP event; at which point it can be monitored periodically if needed (Reference 14).

19. The TDAFWP room HVAC study determined that ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into ELAP event; at which point it can be monitored periodically if needed (Reference 14).

20. Venting of the SFP area will need to be evaluated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> based on the SFP time when boil off occurs. (Reference 18)

21. A time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is assumed for alignment of a mobile water purification system to provide clean water to refill the AFWST. However, cooling water via the ERCW headers is available to be provided indefinitely.

22. Large fuel truck service will need to be established within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This is based on the depletion of on-site supplies and supplying larger equipment.

Discussion of action items identified in Attachment 1A table: (Flood Event)

Note: An ELAP could occur at anytime during flood preparation or a flood event therefore FLEX equipment and strategies must be staged and ready for implementation if required.

Note: To assure that FLEX response actions do not impact on design basis flood mode preparations, Watts Bar will pre-stage FLEX Flood Mode equipment based on a 25 year flood warning from TVAs River Operations Forecasting group. Concurrent with full FLEX implementation at Watts Bar, River Operations procedure RVS-SOP-10.05.06, Nuclear Notifications and Flood Warning Procedure, and AOI-7.01, Maximum Probable Flood, will be revised to provide the notification and direct the pre-staging of FLEX equipment.

Note: The scenario described below assumes an ELAP event occurs post initial flood warning received from TVAs River System Operations and prior to a Stage 1 warning notification. This provides a 27 hour3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> period before flood waters reach grade elevation. This flood preparation time period allows for initial use of the same strategy as a non-flood event for Steps 1-9 for stabilizing the plant and staging FLEX equipment for flood mitigation strategy.

1. Declare ELAP - ELAP entry conditions can be verified by control room staff and it is validated that emergency diesel generators are not available. This step is time sensitive and needs to occur within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following the start of the event to provide operators with guidance to perform ELAP actions.

2. Align and place in service the 225 kva 480vAC Diesel Generators (480v FLEX Generators). This provides charging current to the 125v DC Vital Batteries and ensures 125v DC Vital Battery power (control) and through the Vital Inverters 120v AC Vital Instrument Power (instrument indication).

3. Verify 125v DC Vital Chargers energized and supplying required load to the 125v DC Vital Batteries.

IF not, THEN complete Extended Load Shed for any Vital Battery not being supplied its required load within 90 minutes (1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) following the start of the event. This ensures 8-hour coping time for the 125v DC Vital Batteries.

4. Debris Removal (Access) - The earliest need for debris removal access paths is to support alignment of the LP FLEX Pumps to the essential raw cooling water (ERCW) headers at the Intake Pumping Station (IPS). This process will be initiated in order to support FLEX equipment deployment depending on the resources available.

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5. Damage Assessment - Watts Bar will develop a post event damage assessment procedure. The damage assessment will evaluate and document the condition of plant systems, structures and components (SSCs) after an ELAP event. The assessment will be consistent with the guidelines contained in supplement 5 of Reference 16.

6. Stage and align the LP FLEX pumps (Dominator and Triton) - staged and aligned to take suction from the intake channel with discharge routed to the Essential Raw Cooling Water (ERCW) FLEX connections inside the Intake Pumping Station (IPS).

7. Initiate RCS depressurization and cooldown to commence as soon as possible due to RCP seal failure probability. At rated pressure a potential leakage rate of 21 gpm per RCP following the event is possible. An RCS cooldown rate of 75-100 °F per hour should be sustained until stabilized at ~ 300 PSIA Steam Generator (SG) Pressure. Maintain RCS pressure greater than 250 psig to avoid Cold Leg Accumulator (CLA) nitrogen injection into the RCS. The CLAs are maintained at a boron concentration of 3100 - 3300 ppm. Cooldown and depressurization should be stabilized within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

8. Align the 3MWe FLEX Diesel Generators (6.9KV FLEX Generators), 6.9KV Shutdown Boards and 480v Shutdown Boards for FLEX DG operation. This is to ensure switching at the EDG building and shutdown board rooms are complete, potential board loading is reduced and interlocks are cleared to allow the emergency feeder breaker to be used to safely power the 6.9KV Shutdown Boards from the 6.9KV FLEX DG.

9. Energize the 6.9KV Shutdown Boards with the 6.9KV FLEX DGs. Place the following components in service and restore pressurizer level: Component Cooling Water Pumps and Safety Injection Pumps (SIPs), as required to recover and maintain RCS Pressurizer level. The SIPs take suction for the RWST which maintains a boron concentration of between 3100 and 3300 ppm.

Note: While the TDAFWP is not anticipated to fail, a secondary source of steam generator makeup can be provided by the MDAFWPs, if required, as soon as the 6.9KV FLEX DGs are in service.

The IP FLEX pumps will be staged and aligned as soon as feasible (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

10. Place the following equipment in service, if required: Verify 6.9KV FLEX DG loading between starts. Auxiliary Air Compressors, MDAFWPs and/or Spent Fuel Pool (SFP) Cooling Pump.

Note: The above design Basis components will be removed from service and protection transitioned to the FLEX strategies prior to flood waters reaching plant grade.

Note: The Auxiliary Feedwater Supply Tank (AFWST) will not be available as a water source once flood water reaches plant grade.

11. Stage and align a second Dominator LP FLEX Pump taking suction from a Condenser Circulating Water Cooling Tower Basin with its discharge routed to the B.5.b hose connections inside the 5th DG Building. Hoses will remain isolated and pump out of service until required.

12. Stage and align a second complete set of LP FLEX pumps (Dominator and Triton) to take suction from the road just south of the 5th Diesel Generator Building with discharge routed to the ERCW FLEX connections at the 5th Diesel Generator Building. Hoses will remain isolated and pumps out of service until required.

13. Stage and align the HP FLEX Pumps (AB el. 692) with suction hoses routed from the RWST FLEX connections on AB el. 692 and discharge hoses routed to the Safety Injection Pump Discharge Header FLEX connection (B Train (primary) or A Train (secondary) (AB el. 692).

Complete 480v power supply connections for these pumps.

14. Stage and align the IP FLEX Pumps (AB el. 737) with suction hoses routed from the AB el. 737 ERCW FLEX connections and discharge hoses routed to FLEX connections upstream of the TDAFWP Level Control Valves (LCVs) (primary) (SMSVV el. 729) or MDAFWP LCVs (alternate) (AB el. 737). Complete 480v power supply connections for these pumps.

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15. Deploy hoses and spray nozzles as a contingency for SFP makeup within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. Hoses can be routed to supply makeup from an AB el. 757 ERCW - CCS Spool Piece FLEX connection (next to the CCS Surge Tanks) to the SFP area or from an AB el. 737 FLEX connection to the demineralized water makeup header FLEX connection on AB el. 737. This is based on the time when boil off decreases the water level to 10 feet above the SFP racks, determined in analyses contained in Reference 18.

16. Alternate fuel supply will need to be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This accounts for the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in which the FLEX equipment fuel supply depletes and the deployment time.

Note: If the Condensate Storage Tanks (CSTs) survive the event they will supply an additional reserve of water per unit to the Auxiliary Feedwater Pumps.

17. The AFWST will be depleted in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, makeup options will need to be evaluated and directed.

Potential sources of clean water makeup are the Demineralized Water Storage Tank (DWST), U1 and U2 Primary Water Storage Tanks (PWST) and the Tritiated Water Storage Tank (TWST). If the AFWST is depleted the operating Auxiliary Feedwater System pumps suction will be realigned to the ERCW headers to extend core cooling. LP FLEX pumps will be aligned to the ERCW headers to provide a raw water input prior to the AFWST depleting. Available raw water in the ERCW headers (without LP FLEX pumps supply) would deplete in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Unit 1 and 4.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> for Unit 2 (Reference 23).

18. Acceptable control room lighting will be available for long term support. This is not a time constraint as control room lighting is available via batteries, and portable lighting will be available, if required.

19. The Vital Battery Room and Shutdown Board Room heating, ventilation, and air conditioning (HVAC) study determined that ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into the ELAP event; at which point it can be monitored periodically, if needed (Reference 14).

20. The Main Control Room HVAC study determined that ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into ELAP event; at which point it can be monitored periodically if needed (Reference 14).

21. The TDAFWP room HVAC study determined that ventilation is not required until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into ELAP event; at which point it can be monitored periodically if needed (Reference 14).

22. Venting of the SFP area will need to be evaluated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> based on the SFP time when boil off occurs (Reference 18).

23. A time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is assumed for alignment of a mobile water purification system to provide clean water to refill the AFWST. However, cooling water via the ERCW headers is available to be provided indefinitely.

24. Large fuel truck service will need to be established within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This is based on the depletion of on-site supplies and supplying larger equipment.

To confirm the times given above, Watts Bar will prepare procedures for each task, perform time study walkthroughs for each of the tasks under simulated ELAP conditions and account for administrative procedures that may be required to perform the task. In addition, an evaluation on the impact of FLEX response actions on design basis flood mode preparations will be performed. This evaluation will include the potential for extended preparation time for FLEX. (Open Item OI 13)

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Identify how strategies will be Describe how the strategies will be deployed in all modes.

deployed in all modes.

Ref: NEI 12-06 section 13.1.6 Deployment of FLEX equipment is described for each FLEX function in the subsequent sections below and covers all operating modes. The broad-spectrum deployment strategies do not change for the different operating modes. The deployment strategies from the storage areas to the staging areas are identical and include debris removal, equipment transport, fuel transport, and power sources and requirements. RCS makeup connections are provided for the higher flow rates required during core cooling with SGs unavailable. Each of these strategies and the associated connection points are described in detail in the subsequent sections. The electrical coping strategies are the same for all modes. Figure A3-20 shows a visual representation of the deployment strategy.

Provide a milestone schedule.

This schedule should include:

• Modifications timeline o Phase 1 Modifications o Phase 2 Modifications o Phase 3 Modifications

• Procedure guidance development complete o Strategies o Maintenance

• Storage plan (reasonable protection)

• Staffing analysis completion

• FLEX equipment acquisition timeline

• Training completion for the strategies

• Regional Response Centers operational Ref: NEI 12-06 Section 13.1 The dates specifically required by the order are obligated or committed dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

See attached milestone schedule Attachment 2.

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Identify how the programmatic controls will be met.

Ref: NEI 12-06 Section 11 JLD-ISG-2012-01 Section 6.0 Equipment associated with these strategies will be procured as commercial equipment with design, storage, maintenance, testing, and configuration control in accordance with NEI 12-06 Rev. 0 Section 11.

The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy will be managed using plant equipment control guidelines developed in accordance with NEI 12-06 Rev. 0 Section 11.5.

Programs and controls will be established to assure personnel proficiency in the mitigation of beyond-design-basis events is developed and maintained in accordance with NEI 12-06 Rev. 0 Section 11.6.

The FLEX strategies and basis will be maintained in an overall program document. Existing plant configuration control procedures will be modified to ensure that changes to the plant design, physical plant layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies in accordance with NEI 12-06 Rev. 0 Section 11.8.

Procedure Guidance Watts Bar is a participant in the PWROG project PA-PSC-0965 and will implement the FLEX Support Guidelines (FSGs) in a timeline to support the implementation of FLEX by the time of the Unit 2 startup. The PWROG has generated these guidelines in order to assist utilities with the development of site-specific procedures to cope with an ELAP in a manner compliant with the requirements of Reference NEI 12-06.

The proposed implementation strategy aligns with the procedure hierarchy described in NEI 12-06 in that actions that maneuver the plant are contained within the typical controlling procedure, and the Flex Support Instructions (FSIs) are implemented as necessary to maintain the key safety functions of Core Cooling, Spent Fuel Cooling, and Containment in parallel with the controlling procedure actions. The overall approach is symptom-based, meaning that the controlling procedure actions and FSIs are implemented based upon actual plant conditions.

Watts Bar will continue participation in PA-PSC-0965 and will update plant procedures upon the completion of the PWROG program. It is anticipated that the following FSGs will be incorporated into plant procedures in order to develop the FSG interface:

• Alternate Auxiliary Feedwater (AFW) Suction Source

• Alternate Low Pressure Feedwater

• ELAP Direct Current (DC) Load Shed/Management

• Initial Assessment and FLEX Equipment Staging

• Alternate CST Makeup

• Loss of DC Power

• Alternate RCS Boration

• Long Term RCS Inventory and Temperature Control

• Passive RCS Injection Isolation

• Alternate SFP Makeup and Cooling

• Alternate Containment Cooling

• Transition from FLEX Equipment Maintenance and Testing The FLEX mitigation equipment will be initially tested (or other reasonable means used) to verify E-14

performance conforms to the limiting FLEX requirements. It is expected the testing will include the equipment and the assembled sub-systems to meet the planned FLEX performance. Additionally, Watts Bar will implement the maintenance and testing template upon issuance by the Electric Power Research Institute (EPRI). The template will be developed to meet the FLEX guidelines established in Section 11.5 of Reference 2.

Staffing The FLEX strategies documented in the event sequence analysis assume:

• On-site staff are at administrative minimum shift staffing levels,

• No independent, concurrent events, and

• All personnel on-site are available to support site response.

Watts Bar will have to address staffing considerations in accordance with Reference 2 to fully implement FLEX at the site.

Configuration Control Per NEI 12-06 and the Interim Staff Guidance (ISG), the FLEX strategies must be maintained to ensure future plant changes do not adversely impact the FLEX strategies.

Therefore, Watts Bar will maintain the FLEX strategies and basis in an overall program document and will modify existing plant configuration control procedures to ensure changes to the plant design, physical plant layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies.

Describe training plan Training plans will be developed for plant groups such as the emergency response organization (ERO), Fire, Security, Emergency Preparedness (EP), Operations, Engineering, and Maintenance. The training plan development will be done in accordance with Watts Bar procedures using the Systematic Approach to Training, and will be implemented to ensure that the required Watts Bar staff is trained prior to implementation of FLEX.

Describe Regional Response The nuclear industry will establish two RRCs to support utilities Center plan during beyond design basis events. Each RRC will hold five sets of equipment, four of which will be able to be fully deployed when requested the fifth set will have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local Assemble Area, established by the Strategic Alliance for FLEX Emergency Response (SAFER) team and TVA. Communications will be established between Watts Bar and the SAFER team and required equipment moved to the site as needed. First arriving equipment, as established during development of Watts Bars playbook, will be delivered to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the initial request.

TVA has established an agreement with the SAFER team in accordance with the requirements of Section 12 of Reference 2.

Watts Bar has determined Phase 3 equipment staging locations.

Notes:

1. Maintenance and testing, configuration control, training, and regional response center plans are currently being developed.

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Maintain Core Cooling & Heat Removal Determine Baseline coping capability with installed coping1 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

• AFW/EFW

• Depressurize SG for Makeup with Portable Injection Source

• Sustained Source of Water Ref: JLD-ISG-2012-01 Sections 2 and 3 PWR Installed Equipment Phase 1 Core Cooling with SGs Available The coping strategy is to remove heat from the RCS by providing cooling water to the four SGs. The plant is assumed to be operating at full power at the start of the event. An SBO occurs to start the scenario and all ac power is assumed to be lost. The TDAFWP will start as designed and provide cooling through the SGs. Initial alignment of the TDAFWP suction is to the AFWST. The AFWST will provide approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of inventory to the suction of the TDAFWPs for each unit before the AFWST is depleted. If the CSTs survive the event an additional 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per unit of cooling water would be available.

When the AFWST is depleted, suction flow to the TDAFWP can be provided by standing water in the ERCW headers, for an additional 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> for Unit 1 and 4.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> for Unit 2. (Reference 23).

Core Cooling with SGs Not Available Reactor core cooling and heat removal with SGs not available is provided during Phase 1 by heating up and boiling of the RCS coolant inventory. The lowest allowed level in the RCS, when SGs are not available to provide core cooling, is not more than one foot below the vessel flange during the removal of the reactor vessel head.

RCS inventory during Phase 1 may be maintained by gravity feed from the RWST at each unit. The ability of the RWST at each unit to provide a gravity feed to the RCS is limited by the RWST fluid height, line losses through the gravity feed path, and pressure within the RCS.

If it is determined that gravity feed is not effective to cool the RCS and prevent fuel damage, Watts Bar will take actions to proceduralize administrative controls to pre-stage FLEX equipment prior to entering a condition where the SGs cannot provide adequate core cooling. (Open Item 12) (Reference 20)

Details:

Provide a brief description Confirm that procedure/guidance exists or will be developed to support of Procedures / Strategies / implementation.

Guidelines SBO Emergency Operating Instruction (EOI) ECA-0.0 currently addresses implementation of this strategy. The strategies in ECA-0.0 will be supported by the appropriate FSI for this strategy. (Reference 17)

Identify Modifications List modifications and describe how they support coping time.

1. AFWST and connections to Unit 1 and Unit 2 Auxiliary Feedwater System. (DCN 60060, DCN 62324 & DCN 61422) - Provides 500,000 gallons of demineralized water from a seismically qualified source.

2. 8 Hour Battery Coping. (EDC/DCN 60976, DCN 60384 & PIC to DCN 54871) - Increases battery coping capability.

1 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

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3. The backup instrument air/nitrogen supply to the SG Atmospheric Relief Valves (ARVs) and Auxiliary Feedwater (AFW) Level Control Valves (LCVs) will be moved to above the probable maximum flood (PMF) elevation for flood mode response. (DCN 60996 & EDCR 60749)

Key Reactor Parameters 1. SG Wide Range Level or Narrow Range Level with AFW Flow indication

2. SG Pressure

3. AFWST Level RCS instrumentation that is assumed to also be available for this function:

1. Core Exit Thermocouple (CET) Temperature**

2. RCS Hot Leg (HL) Temperature (Thot) if CETs not available

3. RCS Cold Leg (CL) Temperature (Tcold)*

4. RCS Wide Range Pressure

5. Pressurizer Level

6. Reactor Vessel Level Indicating System (RVLIS) (backup to Pressurizer level) - available for up to 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> for limiting flood scenario, at which point pressurizer level is available again.

7. Neutron Flux For all instruments listed above the normal power source and the long-term power source is the 125v DC Vital Battery.

• This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for Tcold is SG pressure when natural circulation is occurring. This substitution is allowed by guidance provided in Reference 16.

• • This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for CETs is RCS HL. This substitution is allowed by guidance provided in Reference 16.

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Notes:

1. Core cooling strategies are provided for conditions where SGs are available or where SGs are not available but a sufficient RCS vent has been established to support core cooling. This assumption is per the guidance of NEI 12-06 FAQ 2012-19. Other configurations are not considered as these occur at short durations that are exempted per NEI-12-06 Table D.

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Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain core cooling. Identify methods and strategy (ies) utilized to achieve this coping time.

Core Cooling with SGs Available Transition to Phase 2 is required before the AFWST inventory and standing water in the ERCW headers is depleted at 7.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for Unit 1 and 4.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> for Unit 2. (Reference 23)

The 6.9 KV FLEX DGs could be used to repower the Auxiliary Air Compressors and MDAFWPs to provide a secondary SG makeup source if required. This option would allow SG level and pressure control from the Main Control Room (MCR) or Auxiliary Control Room (ACR).

To provide an unlimited supply of water for core cooling during Phase 2, LP FLEX Pumps will be staged at the IPS and take suction from the intake channel and discharge to 4 ERCW FLEX connections inside the IPS.

They will be used to pressurize the ERCW headers which can then be used for direct supply to the TDAFWP suction, if required. Surviving, non-seismic, clean water tanks can also be used to refill the AFWST using transfer pumps.

An IP FLEX Pump will be provided for supplying water to the SGs for core cooling after operating conditions of the TDAFWP cannot be maintained. The IP FLEX Pumps will supply water to FLEX connections upstream of the TDAFWPs or the Motor Driven Auxiliary Feedwater Pumps (MDAFWP) Level Control valves (LCVs). The IP FLEX pumps staging location for a non flood condition is near the AFWST which is the suction source for this condition. The IP FLEX pump staging location for a flood condition would be on AB el. 737 with suction supplied from the ERCW FLEX Connections supplied with raw water from the LP FLEX Pumps. Discharge hose routing would be the same as for a non-flood event. The storage locations, deployment paths and staging locations for the FLEX equipment are provided in Attachment 3.

For non-flood conditions, Watts Bar will gradually transition to a long term core cooling strategy. This will include the use of the LP FLEX pumps on-site to provide a source of cooling water flow to the component cooling system (CCS) heat exchangers. The 6.9 KV FLEX DGs could be used to repower components such as the Auxiliary Air Compressors, MDAFWPs, CCSPs, select ventilation equipment and other components as need and load capability allows.

For flood conditions the plant would supply water to the SGs using the IP FLEX pumps supplied from the ERCW headers and/or flood waters in the Auxiliary Building.

Core Cooling with SGs Not Available For an event that occurs with a unit in core cooling with SGs not available, the transition to Phase 2 strategies will be required as inventory is lost from the RCS. Reactor core cooling and heat removal will be provided by using the IP FLEX pump to inject water into the RCS via the Safety Injection System FLEX connections.

Core cooling is maintained through heat removal from the RCS via coolant boil off. Prior to loss of gravity feed from the RWST, the IP FLEX pump must be aligned to take suction from the RWST or another acceptable alternate coolant source and deliver the coolant to the RCS.

The connections utilized for RCS Inventory Control/Long-Term Subcriticality will also be utilized for the reactor core cooling and heat removal with steam generators not available strategies (Modes 5 and 6). These connections are described in the RCS inventory control section. In addition, a flushing flow of 123 gpm at atmospheric conditions is required at 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> in order to preclude the RCS fluid from the incipient boric acid precipitation point. (Reference 20)

Details:

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Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Provide a brief description Confirm that procedure/guidance exists or will be developed to support of Procedures / Strategies / implementation with a description of the procedure / strategy / guideline.

Guidelines Procedures and guidance to support deployment and implementation, including interfaces to EOPs, special event procedures, abnormal event procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance and Watts Bars strategy aligns with the generic guidance and will consider the Nuclear Steam Supply System (NSSS) specific guidance once available.

Identify Modifications List modifications necessary for Phase 2

1. The backup instrument air supply to the SG Atmospheric Relief Valves (ARVs) and Auxiliary Feedwater (AFW) Level Control Valves (LCVs) will be moved to above the probable maximum flood (PMF) elevation for flood mode response. (DCN 60996 & EDCR 60749)

2. Connections will be made on the ERCW headers in the Auxiliary Building for supplying water to the IP FLEX pump. (DCN 60684)

3. The primary connection point for SG cooling will be upstream of the SG LCVs on the TDAFWP discharge line. (DCN 60683, DCN 61784 &

EDCR 60751)

4. The secondary connection point for SG cooling will be upstream of the SG LCVs in both the train A and train B MDAFWP discharge piping. A connection to both trains is needed for the secondary connection to ensure feed to all four SGs. (DCN 60683, DCN 61784 & EDCR 60751)

5. Auxiliary Feedwater Supply Tank (AFWST). (DCN 60060 & DCN 62324)

6. New connections to take suction from the AFWST are required. (DCN 60060 & DCN 61422)

7. New connections will be made at the ERCW headers in the Intake Pumping Station (IPS) for the LP FLEX Pumps to pressurize the ERCW headers during non-flood and flood conditions. (DCN 60684)

8. New connections will be made at the ERCW headers in the 5th Diesel Generator Building for the LP FLEX Pumps to pressurize the ERCW headers during flood conditions. (DCN 60684)

9. New connections will be made to the Tritiated Water Storage Tank (TWST), Primary Water Storage Tanks (PWSTs), and Demineralized Water Storage Tank (DWST) for transferring water to refill the AFWST.

(DCN 60683, DCN 59397, DCN 60684, DCN 61784 & EDCR 60993)

10. FLEX connections at the Safety Injection Pumps for HP FLEX Pumps RCS makeup. (DCN 60683 & EDCR 60750)

11. RWST FLEX connections for HP FLEX pump or IP FLEX Pump (mode 5 &6) suction source. (DCN 60683, DCN 61784 & EDCR 60994)

12. BAT FLEX connection for HP FLEX Pump suction supply.

(DCN 60684)

E-19

Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2

13. FLEX Equipment Storage Building (FESB). DCN 59084)

14. 225kva DGs (480v FLEX DGS). (DCN 59675)

15. 3 MWe DGs (6.9KV FLEX DGs). (DCN 60853)

16. 8 Hour Battery Coping. (EDC/DCN 60976, DCN 60384 & PIC to DCN 54871)

Key Reactor Parameters List instrumentation credited or recovered for this coping evaluation.

1. SG Wide Range Level or Narrow Range Level with AFW Flow indication

2. SG Pressure

3. AFWST Level RCS instrumentation that is assumed to also be available for this function:

1. CET Temperature**

2. RCS HL Temperature (Thot) if CETs not available

3. RCS CL Temperature (Tcold)*

4. RCS Wide Range Pressure

5. Pressurizer Level

6. RVLIS (backup to Pressurizer level) - available for up to 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> for limiting flood scenario, at which point pressurizer level is available again.

7. Neutron Flux For all instruments listed above the normal power source and the long-term power source is the 125v DC Vital Battery.

• This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for Tcold is SG pressure when natural circulation is occurring. This substitution is allowed by guidance provided in Reference 16.

• • This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for CETs is RCS HL. This substitution is allowed by guidance provided in Reference 16.

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

E-20

Storage / Protection of Equipment :

Describe storage / protection plan or schedule to determine storage requirements Seismic Portable equipment required to implement this FLEX strategy will be maintained in the FESB, the Auxiliary Building and Intake Pumping Station, which are designed for seismic loading in excess of the minimum requirements of American Society of Civil Engineers (ASCE) 7-10. The design of the FESB provides a minimum High Confidence of Low Probability Failure (HCLPF) of 2x SSE. The 480v FLEX DGs are installed on the AB roof in a protected enclosure.

Flooding Portable equipment required to implement this FLEX strategy will be Note: if stored below current flood level, maintained in the FESB, which is sited in a suitable location that is above then ensure procedures exist to move the PMF level and as such is not susceptible to flooding from any source.

equipment prior to exceeding flood level. The 480v FLEX DGs are installed on the AB roof in a protected enclosure.

Severe Storms with High Portable equipment required to implement this FLEX strategy will be Winds maintained in the FESB, which is designed to meet or exceed the licensing basis high wind hazard for Watts Bar. The 480v FLEX DGs are installed on the AB roof in a protected enclosure.

Snow, Ice, and Extreme Cold The FESB will be evaluated for snow, ice and extreme cold temperature effects and heating will be provided as required to assure no adverse effects on the FLEX equipment. The FESB will have a standalone HVAC system.

The 480v FLEX DGs are installed on the AB roof in a protected enclosure.

High Temperatures The FESB will be evaluated for high temperature effects and ventilation will be provided as required to assure no adverse effects on the FLEX equipment. The FESB will have a standalone HVAC system. The 480v FLEX DGs are installed on the AB roof in a protected enclosure.

Deployment Conceptual Design The figures provided in Attachment 3 show the deployment paths from each of the storage locations to the staging locations.

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed to protected the point of use.

SGs Available Primary connection modifications: All FLEX equipment connection points will be designed to meet or The primary connection for the IP

• A tee will be added to the exceed Watts Bar design basis FLEX pumps will be located in TDAFWP discharge line.

SSE protection requirements.

the South Main Steam Valve Vault

• An isolation valve will be (MSVV) el. 729 upstream of the added to the main line The primary connection is located LCVs on the TDAFWP discharge upstream of connection. inside the South Main Steam piping.

• An isolation valve will be Valve Vault (MSVV). The MSVV added to the new branch. is a safety related structure and is For this alignment during non-

• Storz cap/adapter will be protected from all external hazards flood conditions, suction to the IP added to new branch. except flooding. For flood FLEX Pump will be taken from conditions, procedures will ensure the AFWST or ERCW headers. AFWST modifications: that hoses are connected before During flood conditions, suction Storz hose connections will be flood levels reach the connection.

will be taken from the ERCW headers and/or flood waters in the The connections to the AFWST E-21

Auxiliary Building. Discharge of provided with the new AFWST. and ERCW will be seismically the IP FLEX Pump will be to the qualified and missile protected.

ERCW modifications:

connection points shown in For connections required during , Figure A3-1. The For non-flood conditions, one set flood conditions, procedures will proposed hose routing for the of LP FLEX pumps will be staged ensure that hoses are connected primary connection and the next to the IPS. The existing before flood levels reach the associated equipment staging area ERCW piping in the IPS will be connection.

can be found in Attachment 3, modified to add isolation valves Connections to other tanks are not Figures A3-3 and A3-4. with hose connections to allow the protected since the connections are ERCW headers to be pressurized.

ERCW connections can be found to non-protected tanks and would An alternate raw water source in Attachment 3, Figures A3-17 only be available if the tank could come from the Condenser and A3-18. survives the event. These Circulating Water (CCW) cooling connections are used to provide tower basin supplying suction additional capability above the source to a Dominator LP FLEX minimum FLEX requirements.

Pump with its discharge routed to FLEX connections (or B.5.b connections) at the 5th DG Building.

For flood conditions, a second Dominator LP FLEX Pump taking suction from a CCW Cooling Tower Basin with its discharge routed to the B.5.b hose connections inside the 5th DG Building would be stage and aligned. Hoses will remain isolated and pump out of service until required. A second complete set of LP FLEX pumps (Dominator and Triton) will be staged next to the 5th Diesel Generator Building. The existing ERCW piping inside the 5th Diesel Generator Building will be modified to add FLEX connections (isolation valves with hose connections) to allow the ERCW headers to be pressurized.

To supply water to the suction of the IP FLEX pumps, existing ERCW header cleanout ports in the Auxiliary Building elevation 737 will be utilized. The cleanout ports will be modified to add Storz hose connections.

Other tank modifications An isolation valve and Storz hose connections will be added to the TWST, PWSTs, and DWST for water transfer pump capability to E-22

supply clean water to the AFWST.

SGs Available Secondary connection All FLEX equipment connection modifications: points will be designed to meet or The secondary connection will be exceed Watts Bar design basis located in the Auxiliary Building

• Hard piping will be installed SSE protection requirements.

on Elevation 737 upstream of the between the high pressure fire LCVs on the MDAFWP discharge protection (HPFP) Train A The secondary connection is piping. and Train B flood conditions located inside the Auxiliary supply piping and the Building. The Auxiliary Building For this alignment, suction will be MDAFWP Train A and Train is a safety related structure and is taken from the AFWST or ERCW B piping which will replace protected from all external hazards and discharged through the IP the existing removable spool except flooding. For flood FLEX Pumps to the connection pieces. conditions, procedures will ensure points shown in Attachment 3, that hoses are connected before Figure A3-2. The proposed hose

• A tee will be added to this flood levels reach the connection.

routing for the secondary piping.

connection and the associated

• Add isolation valve to either The connections to the AFWST equipment staging area can be side of new tee. and ERCW will be seismically found in Attachment 3, Figure A3-

• Add isolation valve on new qualified and missile protected.

3 and Figure A3-5. branch. For connections required during

• Storz cap/adapter will be flood conditions, procedures will ERCW connections can be found added to new branch. ensure that hoses are connected in Attachment 3, Figures A3-17 before flood levels reach the and A3-18. AFWST, ERCW, and other tank connection.

modifications:

Connections to non-seismic tanks Same as primary. are not protected and would only be available if the tank survives the event. These connections are used to provide additional capability above the minimum FLEX requirements.

Steam Generators Not Available Primary Connection Modification All FLEX equipment connection points will be designed to meet or When SGs are not available,

• Install tees or weldolets, exceed Watts Bar design basis suction will be taken from the

• Add isolation valves SSE protection requirements.

RWST Flex connections (AB el.

• Add a hose adapters 692) through the Modes 5 & 6 The primary connections for the FLEX Pumps staged on AB el. RWST Modifications: Safety Injection Pump (SIP) Train 692 with pump discharge routed to

• Install pipe taps on RWST B discharge header and RWST are the primary FLEX connections on supply lines to the Refueling located inside the Auxiliary the Train B Safety Injection Water Purification Pumps on Building. The Auxiliary Building Pumps discharge headers. AB el. 692. is a safety related structure and is

• Add an isolation valves on protected from all external hazards these connection locations. except flooding. For flood

• Add Storz adapters with cap conditions, procedures will ensure on branches. that hoses are connected before Safety Injection Pump Discharge flood levels reach the connection.

Header Modifications The RWST connection is located FLEX connections on the Safety inside the AB on el. 692. For Injection Pumps discharge connections required during flood Headers for HP FLEX Pumps conditions, procedures will ensure RCS makeup are located on AB that hoses are connected before flood levels reach the connection.

E-23

el. 692.

SGs Not Available The secondary Mode 5 & 6 Flex All FLEX equipment connection connection modification for steam points will be designed to meet or When SGs are not available, generators not available is exceed Watts Bar design basis suction will be taken from the identical to the primary, except for SSE protection requirements.

RWST FLEX connections (AB el.

being located on the Safety 692) through the Modes 5 & 6 The secondary FLEX connections Injection Pump (SIP) Train A FLEX Pumps staged on AB el. for the Safety Injection Pump discharge header.

692 with pump discharge routed to (SIP) Train A discharge header and the secondary FLEX connections BAT Modification the BAT are located inside the on the Train A Safety Injection

• Install tees on discharge lines Auxiliary Building. The Auxiliary Pumps discharge headers. of BAT A on AB el. 713. Building is a safety related

• Add an isolation valve on the structure and is protected from all branch. external hazards except flooding.

• Add a Storz adapter with cap For flood conditions, procedures on the branch. will ensure that hoses are connected before flood levels reach the connection.

The BAT serves as a secondary source and is located inside the AB on el. 713. For connections required during flood conditions, procedures will ensure that hoses are connected before flood levels reach the connection.

Notes:

1. System modifications are described in the Modifications section above and are illustrated in Attachment 3.

2. Figures A3-3 through A3-5 in Attachment 3 provides the deployment routes from the staging locations for each IP FLEX pump to the pump suction source and to the primary and secondary connection points on the AFW system.

3. Core cooling strategies are provided for conditions where SGs are available or where SGs are not available but a sufficient RCS vent has been established to support core cooling. This assumption is per the guidance of NEI 12-06 FAQ 2012-19. Other configurations are not considered as these occur at short durations that are exempted per NEI-12-06 Table D.

E-24

Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain core cooling. Identify methods and strategy (ies) utilized to achieve this coping time.

Core Cooling with SGs Available For Phase 3, Watts Bar will continue the Phase 2 coping strategies with additional assistance provided from offsite equipment/resources. Backup or alternate Phase 2 FLEX equipment will be provided by the RRC as necessary. Additionally, purification of water at each unit will be supported by a mobile water purification unit from the RRC. This unit will process water from the Tennessee River or other raw water sources to remove particulate and demineralize the water. The purification unit will be self supported. This water would then be used to refill or makeup to the AFWST.

Core Cooling with SGs Not Available Reactor core cooling with SGs not available is adequately maintained via the Phase 2 strategy; however, borated sources are limited. Phase 3 deployment of a unit capable of generating borated water from the water processed through the purification unit can further extend coping times with respect to RCS inventory management.

Watts Bar has determined where Phase 3 equipment will be staged.

Details:

Provide a brief description Procedures and guidance to support deployment and implementation, of Procedures / Strategies / including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance and Watts Bar's strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

Finally, Watts Bar will include in procedures notification of the RRC to arrange for delivery and deployment of off-site equipment and sufficient supplies of commodities.

Identify Modifications Each of the Phase 3 strategies will utilize common connections where required as described for the Phase 2 connections to prevent any compatibility issues with the offsite equipment.

Key Reactor Parameters List instrumentation credited or recovered for this coping evaluation.

1. SG Wide Range Level or Narrow Range Level with AFW Flow indication

2. SG Pressure

3. AFWST Level RCS instrumentation that is assumed to also be available for this function:

1. CET Temperature**

2. RCS HL Temperature (Thot) if CETs not available

3. RCS CL Temperature (Tcold)*

4. RCS Wide Range Pressure

5. Pressurizer Level

6. RVLIS (backup to Pressurizer level) - available for up to 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> for limiting flood scenario, at which point pressurizer level is available again.

E-25

Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3

7. Neutron Flux For all instruments listed above the normal power source and the long-term power source is the 125v DC Vital Battery.

• This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for Tcold is SG pressure when natural circulation is occurring. This substitution is allowed by guidance provided in Reference 16.

• • This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for CETs is RCS HL. This substitution is allowed by guidance provided in Reference 16.

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Deployment Conceptual Design Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed to protected the point of use.

A mobile water purification Each of the Phase 3 strategies will All FLEX equipment connection system will enable water from the utilize common connections as points will be designed to meet or Tennessee River or other raw described for the Phase 2 exceed Watts Bar design basis water source to be purified. This connections to prevent any SSE protection requirements.

unit would process the water compatibility issues with the The system will take suction source and discharge improved offsite equipment.

directly from the Tennessee River quality water to the AFWST. This or other raw water source. The unit would be self supported.

discharge connections will be identical to the ones used for Phase 2. The protection of those connection points is described in the section for Phase 2.

Notes:

1. Core cooling strategies are provided for conditions where Steam Generators are available or where Steam Generators are not available but a sufficient RCS vent has been established to support core cooling. This assumption is per the guidance of NEI 12-06 FAQ 2012-19. Other configurations are not considered as these occur at short durations that are exempted per NEI-12-06 Table D.

E-26

Maintain RCS Inventory Control Determine Baseline coping capability with installed coping2 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

• RCS makeup required (standard design RCP seals)

• All Plants Provide Means to Provide Borated RCS Makeup PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain RCS inventory control. Identify methods (Low Leak RCP Seals and/or borated high pressure RCS makeup) and strategy (ies) utilized to achieve this coping time.

This section discusses RCS inventory control and subcriticality issues for conditions where SGs are available. RCS inventory control and subcriticality issues for conditions where SGs are not available are addressed in the reactor core cooling and heat removal section of this report.

Following the declaration of an ELAP, a plant depressurization and cooldown will be initiated at approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of ELAP event. Natural circulation is maintained by ensuring adequate RCS inventory.

Watts Bar Unit 1 and Unit 2 have standard Westinghouse RCP seals and given an ELAP event at rated RCS pressure a potential RCP seal leakage rate of 21 gpm exists.

Utilizing WCAP-17601 methodology (Reference 8), Reference 20 summarizes the limiting plant-specific scenarios for RCS inventory control, shutdown margin, and Mode 5/Mode 6 boric acid precipitation control with respect to the guidelines set forth in NEI 12-06 (Reference 2).

RCS inventory is a significant concern for the ELAP scenario due to the RCP seal design. Timely RCS cooldown and depressurization at 75 to 100°F per hour to ~ 300 PSIA SG pressure should result in an RCS pressure of ~325 PSIA and ~ 425°F Tavg. Holding RCS pressure to greater than 250 PSIG ensures no nitrogen injection into the RCS from Cold Leg Accumulators. RCS makeup is required to compensate for the RCP seal leakage and from shrinkage due to cooldown. For Phase 1 RCS makeup is provided from the Safety Injection System Cold Leg Accumulators. RCP seal leakage would be greatly reduced from the reduction in RCS pressure.

Details:

Provide a brief description Confirm that procedure/guidance exists or will be developed to support of Procedures / Strategies / implementation Guidelines SBO EOI ECA-0.0 addresses procedural guidance required for maintaining RCS inventory during Phase 1. (Reference 17) Procedures and guidance to support implementation of a boration strategy, including interfaces to EOPs, special event procedures, abnormal event procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

Identify Modifications List modifications

1. 8 Hour Battery Coping. (EDC/DCN 60976, DCN 60384 & PIC to DCN 54871) 2 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

³SHIELD is a registered trademark of Westinghouse Electric Company LLC in the United States and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited.

E-27

Maintain RCS Inventory Control

2. The backup instrument air/nitrogen supply to the SG Atmospheric Relief Valves (ARVs) and Auxiliary Feedwater (AFW) Level Control Valves (LCVs) will be moved to above the probable maximum flood (PMF) elevation for flood mode response. (DCN 60996 & EDCR 60749)

3. AFWST and connections to the Auxiliary Feedwater Systems (DCN 60060, DCN 62324 & DCN 61422)

Key Reactor Parameters List instrumentation credited for this coping evaluation.

1. CET Temperature**

2. RCS HL Temperature (Thot) if CETs not available

3. RCS CL Temperature (Tcold)*

4. RCS Wide Range Pressure

5. Pressurizer Level

6. RVLIS (backup to pressurizer level) - available for up to 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> for limiting flood scenario, at which point pressurizer level is available again.

7. Neutron Flux For all instruments listed above the normal power source and the long-term power source is the 125v DC Vital Battery.

• This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for Tcold is SG pressure when natural circulation is occurring. This substitution is allowed by guidance provided in Reference 16.

• • This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for CETs is RCS HL. This substitution is allowed by guidance provided in Reference 16.

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Notes: None E-28

Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain RCS inventory control. Identify methods (borated high pressure RCS makeup) and strategy (ies) utilized to achieve this coping time.

This section discusses RCS inventory control and subcriticality issues for conditions where SGs are available. RCS inventory control and subcriticality issues for conditions where SGs are not available are addressed in the reactor core cooling and heat removal section of this report.

Following the declaration of an ELAP, a plant cooldown will be initiated at approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of ELAP event. Natural circulation is maintained by ensuring adequate RCS inventory.

Watts Bar Unit 1 and Unit 2 have standard Westinghouse RCP seals and given an ELAP event and at rated RCS pressure a potential RCP seal leakage rate of 21 gpm exists.

Utilizing WCAP-17601 methodology (Reference 8), Reference 20 summarizes the limiting plant-specific scenarios for RCS inventory control, shutdown margin, and Mode 5/Mode 6 boric acid precipitation control with respect to the guidelines set forth in NEI 12-06 (Reference 2).

RCS inventory is a significant concern for the ELAP scenario due to the RCP seal design. Timely RCS cooldown and depressurization at 75 to 100°F per hour to ~ 300 PSIA SG pressure should result in an RCS pressure of ~325 PSIA and ~ 425°F Tavg. Holding RCS pressure to greater than 250 PSIG ensures no nitrogen injection into the RCS from Cold Leg Accumulators. RCS makeup is required to compensate for the RCP seal leakage and from shrinkage due to cooldown. 6.9KV switchgear, 6.9KV and 480v Shutdown Boards are aligned and powered by the 6.9KV FLEX DGs within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of the event. With the 6.9KV Shutdown Boards energized CCS pumps and Safety Injection Pumps are restored taking suction from the RWST (3100 -3300 ppm boron) and injecting through all 4 cold legs to recover RCS pressurizer level.

RCP seal leakage would be greatly reduced from the reduction in RCS pressure. The SIP operation would be as needed to maintain pressurizer level until the HP FLEX Pump assumed the task. A HP FLEX Pump would be available at 8.5 to 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> from the event. The HP FLEX pump suction would be routed from the RWST FLEX connections located on AB el.692 with the discharge routed to a Safety Injection Pump discharge header FLEX connection. The Boric Acid Storage Tank (BAT) provides a secondary source of makeup for the HP FLEX Pumps (~6900 PPM boron concentration).

Details:

Provide a brief description Procedures and guidance to support deployment and implementation, of Procedures / Strategies /

including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

E-29

Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

Identify Modifications List modifications necessary for Phase 2

1. The backup instrument air supply to the SG Atmospheric Relief Valves (ARVs) and Auxiliary Feedwater (AFW) Level Control Valves (LCVs) will be moved to above the probable maximum flood (PMF) elevation for flood mode response. (DCN 60996 & EDCR 60749)

2. FLEX connections will be made on the ERCW headers in the Auxiliary Building el. 737 for supplying water to the IP FLEX pump.(DCN 60684)

3. The primary connection point for SG cooling will be upstream of the SG LCVs on the TDAFWP discharge line. (DCN 60683, DCN 61784

& EDCR 60751)

4. The secondary connection point for SG cooling will be upstream of the SG LCVs in both the train A and train B MDAFWP discharge piping.

A connection to both trains is needed for the secondary connection to ensure feed to all four SGs.(DCN 60683, DCN 61784 & EDCR 60751)

5. Auxiliary Feedwater Supply Tank. (DCN 60060 & DCN 62324)

6. New connections to take suction from the AFWST are required. (DCN 60060 & DCN 61422)

7. New connections will be made at the ERCW headers in the Intake Pumping Station (IPS) for the LP FLEX Pumps to pressurize the ERCW headers during non-flood and flood conditions. (DCN 60684)

8. New connections will be made at the ERCW headers in the 5th Diesel Generator Building for the LP FLEX Pumps to pressurize the ERCW headers during flood conditions. (DCN 60684)

9. New FLEX connections will be made to the Tritiated Water Storage Tank (TWST), Primary Water Storage Tanks (PWSTs), and Demineralized Water Storage Tank to transfer water to the AFWST.

(DCN 60684, DCN 60683, DCN 61784 & EDCR 60993)

10. FLEX connections at the Safety Injection Pumps for HP FLEX Pumps RCS makeup. (DCN 60683 & EDCR 60750)

11. RWST FLEX connections for HP FLEX pump or IP FLEX Pump (mode 5 &6) suction source. (DCN 60683, DCN 61784 & EDCR 60994)

12. BAT FLEX connection for HP FLEX Pump suction supply. (DCN 60684)

13. FLEX Equipment Storage Building (FESB). DCN 59084)

14. 225kva DGs (480v FLEX DGs). (DCN 59675)

15. 3 MWe DGs (6.9KV FLEX DGs) (DCN 60853)

16. 8 Hour Battery Coping. (EDC/DCN 60976, DCN 60384 & PIC to DCN 54871)

Key Reactor Parameters List instrumentation credited or recovered for this coping evaluation.

E-30

Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

1. CET Temperature**

2. RCS HL Temperature (Thot) if CETs not available

3. RCS CL Temperature (Tcold)*

4. RCS wide range pressure

5. RCS Passive Injection Level

6. Pressurizer Level

7. RVLIS (backup to Pressurizer level) - available for up to 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> for limiting flood scenario, at which point pressurizer level is available again.

8. Neutron Flux For all instruments listed above the normal power source and the long-term power source is the 125v DC Vital Battery.

• This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for Tcold is SG pressure when natural circulation is occurring. This substitution is allowed by guidance provided in Reference 16.

• • This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for CETs is RCS HL. This substitution is allowed by guidance provided in Reference 16.

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic In addition to equipment being stored in the FESB (as described in the Reactor Core Cooling and Heat Removal section) for this function, equipment will be stored in the Auxiliary Building, which is seismically qualified. The 480v FLEX DGs are installed on the AB roof in a protected enclosure.

Flooding In addition to equipment being stored in the FESB (as described in the Reactor Core Cooling and Heat Removal section) for this function, Note: if stored below current equipment will be stored in the Auxiliary Building. Equipment required flood level, then ensure for this function will be stored so that it can be deployed prior to any procedures exist to move concerns with flooding. The 480v FLEX DGs are installed on the AB equipment prior to exceeding roof in a protected enclosure.

flood level.

Severe Storms with High In addition to equipment being stored in the FESB (as described in the Winds Reactor Core Cooling and Heat Removal section) for this function, equipment will be stored in the Auxiliary Building, which is protected from high winds. The 480v FLEX DGs are installed on the AB roof in a protected enclosure.

Snow, Ice, and Extreme Cold In addition to equipment being stored in the FESB (as described in the Reactor Core Cooling and Heat Removal section) for this function, equipment will be stored in the Auxiliary Building, which is an environmentally controlled building and provides protection from snow, ice, and extreme cold effects. The 480v FLEX DGs are installed on the E-31

Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

AB roof in a protected enclosure.

High Temperatures In addition to equipment being stored in the FESB (as described in the Reactor Core Cooling and Heat Removal section) for this function, equipment will be stored in the Auxiliary Building, which is an environmentally controlled building and provides protection from high temperature effects. The 480v FLEX DGs are installed on the AB roof in a protected enclosure.

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed protected to the point of use.

The primary RCS makeup Primary Connection Modification All FLEX equipment connection FLEX connection will be on the points will be designed to meet or

• Install tees or weldolets, SIP Train B discharge line, in exceed Watts Bar design basis the SIP room at elevation 692.

• Add isolation valves SSE protection requirements.

• Add a hose adapters For this alignment, suction will The primary FLEX connection be taken from the RWST or the RWST Modifications: and RWST connection are located BAT and discharged through the The RWST FLEX connections inside the Auxiliary Building. The HP FLEX pumps to the FLEX are located on el. 692 in the Auxiliary Building is a safety connection points shown in Auxiliary Building. related structure and is protected , Figure A3-6. The from all external hazards except proposed hose routing for the Safety Injection Pump Discharge flooding.

primary connection and the Header Modifications The FLEX connections on the The RWST FLEX connections associated equipment can be Safety Injection Pumps discharge will be seismically qualified and found in Attachment 3, Figures missile protected.

A3-8 through A3-10. Headers for HP FLEX Pumps During Mode 5 and 6 with SGs RCS makeup are located on AB el.

unavailable, suction will be 692.

taken from the RWST FLEX connections and discharged through the Mode 5 & 6 FLEX pumps (staged in AB el. 692.

near the primary connection point.

The secondary RCS makeup The secondary FLEX connection All FLEX equipment connection FLEX connection will be on the modification is identical to the points will be designed to meet or SIP Train A discharge line, in the primary, except for being located exceed Watts Bar design basis SIP room at elevation 692. on SIP Train A discharge. SSE protection requirements.

For this alignment, suction will BAT Modification The secondary connection and be taken from the RWST or

• Install tees on discharge line BAT FLEX connection are located BATs and discharged through of BAT A on AB el. 713. inside the Auxiliary Building. The the HP FLEX pumps to the

• Add an isolation valve on the Auxiliary Building is a safety connection points shown in branch. related structure and is protected , Figure A3-6. The

• Add a Storz adapter with cap from all external hazards except E-32

Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

proposed hose routing for the on branch. flooding.

secondary RCS FLEX Safety Injection Pump Discharge The RWST connections will be connection and the associated Header Modifications seismically qualified and missile equipment can be found in The FLEX connections on the protected. For connections , Figure A3-8.

Safety Injection Pumps discharge required during flood conditions, During Mode 5 and 6 with SGs Headers for HP FLEX Pumps procedures will ensure that hoses unavailable, suction will be RCS makeup are located on AB are connected before flood levels taken from the RWST and el. 692. reach the connection.

discharged through the Mode 5 and 6 FLEX pumps staged on el.

692 in the Auxiliary Building.

Figure A3-11.

Notes:

1. System modifications are described in the Modifications section above and are illustrated in Attachment 3.

2. N+1 HP FLEX Pumps will be staged in the Auxiliary Building. This satisfied N+1 NEI requirements.

3. Figures A3-8 through A3-10 in Attachment 3 provides the deployment routes from the staging locations for each HP FLEX Pump to the pumps suction piping and to the primary and secondary connection points on the RCS connected systems.

E-33

Maintain RCS Inventory Control PWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain RCS Inventory Control. Identify method (borated high pressure RCS makeup) and strategy (ies) utilized to achieve this coping time.

This section discusses RCS inventory control and subcriticality issues for conditions where SGs are available. RCS inventory control and subcriticality issues for conditions where SGs are not available are addressed in the reactor core cooling and heat removal section of this report.

Reactor level and sub-criticality is adequately maintained via the Phase 2 strategy; however, borated sources are limited. Phase 3 deployment of a unit capable of generating borated water from the water processed through the purification unit can further extend coping times with respect to RCS inventory management.

For Phase 3, Watts Bar will continue the Phase 2 coping strategies with additional assistance provided from offsite equipment/resources. Backup or alternate Phase 2 FLEX equipment will be provided by the RRC as necessary.

Watts Bar will determine where Phase 3 equipment will be staged.

Details:

Provide a brief description Procedures and guidance to support deployment and implementation, of Procedures / Strategies / including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bar's strategy aligns with the generic guidance and will consider the NSSS specific guidance once available. Finally, Watts Bar will include in procedures notification of the RRC to arrange for delivery and deployment of off-site equipment and sufficient supplies of commodities.

Identify Modifications Each of the Phase 3 strategies will utilize common connections as described for the Phase 2 connections to prevent any compatibility issues with the offsite equipment.

Key Reactor Parameters List instrumentation credited or recovered for this coping evaluation.

1. CET Temperature**

2. RCS HL Temperature (Thot) if CETs not available

3. RCS CL Temperature (Tcold)*

4. RCS wide range pressure

5. RCS Passive Injection Level

6. Pressurizer Level

7. RVLIS (backup to Pressurizer level) - available for up to 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> for limiting flood scenario, at which point pressurizer level is available again.

8. Neutron Flux For all instruments listed above the normal power source and the long-term power source is the 125v DC Vital Battery.

• This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for Tcold is SG pressure when natural circulation is occurring. This substitution is allowed by guidance provided in Reference 16.

E-34

Maintain RCS Inventory Control PWR Portable Equipment Phase 3:

• • This instrumentation is only available until flood water enters the auxiliary instrument room. The potential validating indicator for CETs is RCS HL. This substitution is allowed by guidance provided in Reference 16.

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed protected to the point of use.

A mobile water purification Each of the Phase 3 strategies will All FLEX equipment connection system would allow utilize common connections as points will be designed to meet or demineralized water makeup to described for the Phase 2 exceed Watts Bar design basis the AFWST. This unit would be connections to prevent any SSE protection requirements.

self supported. compatibility issues with the The discharge connections will be offsite equipment.

identical to the ones used for Phase 2. The protection of those connection points is described in the section for Phase 2 for RCS Inventory Control.

Notes: None E-35

Maintain Containment Determine Baseline coping capability with installed coping3 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

• Containment Spray

• Hydrogen igniters (ice condenser containments only)

PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain containment. Identify method (Hydrogen igniter) and strategy (ies) utilized to achieve this coping time.

Watts Bar will perform a containment evaluation based on the boundary conditions described in Section 2 of NEI 12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrumentation function will be developed. (Open item OI 4)

There are no phase 1 actions required at this time that need to be addressed.

Details:

Provide a brief description Procedures and guidance to support implementation of this strategy, of Procedures / Strategies / including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

Identify Modifications N/A Key Containment List instrumentation credited for this coping evaluation.

Parameters

1. Containment Pressure*

2. Containment Temperature**

• For this instrumentation, the normal power source and the long-term power source is the 125v DC Vital Battery.

• • This instrumentation is only available until flood water enters the technical support center (TSC) inverter or station battery rooms. (Open item OI 10)

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Notes: None 3

Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

E-36

Maintain Containment PWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain containment. Identify method (hydrogen igniters) and strategy (ies) utilized to achieve this coping time.

Watts Bar will perform a containment evaluation based on the boundary conditions described in Section 2 of NEI 12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrumentation function will be developed. (Open item OI 4)

Additionally, the 480v FLEX DGSs discussed in the safety functions support section will provide power directly to the hydrogen igniter supply transformers.

The onsite 6.9KV FLEX DGs are available to provide power to Containment Air Return Fans or Lower Compartment Coolers (LCCs) for containment temperature control, if required. Cooling water would be provided to the LCCs by onsite LP FLEX pumps feeding the ERCW system headers.

Details:

Provide a brief description Procedures and guidance to support deployment and implementation, of Procedures / Strategies / including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

Identify Modifications Power capability will be installed to the hydrogen igniter supply transformers.

Key Containment List instrumentation credited or recovered for this coping evaluation.

Parameters

1. Containment Pressure*

2. Containment Temperature**

• For this instrumentation, the normal power source and the long-term power source are the 125v DC Vital Battery.

• • This instrumentation is only available until flood water enters the TSC inverter or station battery rooms. (Open Item OI 10)

Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic The 480v FLEX DGs will be pre-staged on the roof of the Auxiliary Building. A protection structure will be built around the DGs, which will be designed to the same Seismic Category I requirements as the Auxiliary Building. Seismic input for the design corresponds to the appropriate seismic accelerations at the roof of the Auxiliary Building. This design provides a minimum HCLPF of the protective structure of 2xSSE.

Flooding The 480v FLEX DGs will be pre-staged on the roof of the Auxiliary Building, which is sited in a suitable location that is above the PMF and as such is not susceptible to flooding from any source.

Severe Storms with High The 480v FLEX DGs will be pre-staged on the roof of the Auxiliary Winds Building. A protection structure will be built around the DGs, which is sited E-37

Maintain Containment in a suitable location that is protected from NRC region 1 tornado, missiles, and velocities as defined in Nuclear Regulatory Commission (NRC)

Regulatory Guide 1.76 Revision 1.

Snow, Ice, and Extreme Cold The 480v FLEX DGs will be pre-staged on the roof of the Auxiliary Building. A protection structure will be built around the DGs, and will be evaluated for snow, ice and extreme cold temperature effects and heating will be provided as required to assure no adverse effects on the FLEX equipment.

High Temperatures The 480v FLEX DGs will be pre-staged on the roof of the Auxiliary Building. A protection structure will be built around the DGs, and will be evaluated for high temperature effects and ventilation will be provided as required to assure no adverse effects on the FLEX equipment.

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed to protected the point of use.

The hydrogen igniters can be Diverse transfer switches will be The protection structure for the repowered by the 480v FLEX installed which directly supply the 480v FLEX DGs and the diverse DGs that will be pre-staged on the hydrogen igniter transformers. transfer switches will be designed roof of the Auxiliary Building or (DCN 59675 & DCN 60853). and installed such that each is by the 6.9KV FLEX DGs. protected from the five external Cabling will be routed from the hazards, as described in this generators to one of the diverse section.

transfer switches that will be installed.

Notes: None E-38

Maintain Containment PWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using Phase 3 equipment including modifications that are proposed to maintain containment. Identify method (hydrogen igniters) and strategy (ies) utilized to achieve this coping time.

Watts Bar will perform a containment evaluation based on the boundary conditions described in Section 2 of NEI 12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrumentation function will be developed. (Open item OI 4)

The hydrogen igniters would continue to be repowered by the 480v FLEX DGS or 6.9KV FLEX DGs . A backup or alternate set of Phase 2 equipment will be provided by the RRC as needed.

Details:

Provide a brief description Procedures and guidance to support deployment and implementation, of Procedures / Strategies / including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available. Finally, Watts Bar will include in procedures notification of the RRC to arrange for delivery and deployment of offsite equipment and sufficient supplies of commodities.

Identify Modifications The same modification as Phase 2 applies for Phase 3.

Key Containment List instrumentation credited or recovered for this coping evaluation.

Parameters

1. Containment Pressure*

2. Containment Temperature**

• For this instrumentation, the normal power source and the long-term power source is the 125v DC Vital Battery.

• • This instrumentation is only available until flood water enters the TSC inverter or station battery rooms. (Open Item OI 10)

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed to protected the point of use.

The same modification, as Phase 2 The same modification, as Phase 2 All FLEX equipment connection applies for Phase 3. applies for Phase 3. points will be designed to meet or exceed Watts Bar design basis safe shutdown earthquake (SSE) protection requirements.

The same modification, as Phase 2 applies for Phase 3.

Notes: None E-39

Maintain Spent Fuel Pool Cooling Determine Baseline coping capability with installed coping4 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

• Makeup with Portable Injection Source PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain spent fuel pool cooling. Identify methods (makeup via portable injection source) and strategy (ies) utilized to achieve this coping time.

Reference 18 summarizes that there will be no volume lost from the SFP due to sloshing. A small range of critical damping factors were investigated and it was shown that the critical damping factor had no influence on the amount of water sloshed out of the pool. However, for all critical damping factors, there was water lost into the ventilation ducts regardless of the direction of the seismic motion. The volume of the water lost in the ducts was conservatively calculated to be 59.5 ft3. Access to the SFP area as part of Phase 2 response could be challenged due to environmental conditions near the pool. Therefore, the required action is to establish ventilation in this area and establish any equipment local to the SFP required to accomplish the coping strategies (such as the primary SFP cooling strategy discussed below). If the air environment in the SFP area requires the building to be ventilated, doors will be opened to establish air movement and venting the SFP building. For accessibility, establishing the SFP vent and any other actions required inside the fuel handling building should be completed before boil off occurs.

Operating, pre-fuel transfer or post-fuel transfer Considering no reduction in SFP water inventory starting from nominal pool level, this results in a time when boil off decreases the water level to 10 feet above the SFP racks of approximately 85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br /> for an SSE seismic event with an initial bulk water temperature in the pool of 100°F. This value was calculated using the normal operating decay heat load.

Considering the maximum possible loss of water through the vents in SFP water inventory starting from nominal pool level, this results in a time when boil off occurs of approximately 18.69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br /> for an safe shutdown earthquake (SSE) seismic event and an initial bulk water temperature in the pool of 100°F. This value was calculated using the normal operating decay heat load. Time to boil the level to 10 ft above the fuel racks (~735 ft) for normal operating decay heat load is determined below. Note that the top of the fuel is at ~749 ft and the boil off rate for normal decay heat load is 32.56 gpm as stated in Reference 18. A volume of level per inch of 104.38 ft3/in is from Reference 18.

Time to boil down to 10 ft above (749-735=14 ft = 168 in) fuel racks:

104.38ft 3 1gal 1 min 1hour

= 168in x x 3 x x = 67.15 + 18.69 = 85.84hours in 0.13368ft 32.56gal 60 min Fuel in Transfer or Full Core Offload For the maximum credible heat load and an initial water temperature in the pool of 140°F, the time when boil off decreases the water level to 10 feet above the SFP racks is approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Considering the maximum possible loss of water through the vents in SFP water inventory starting from nominal pool level, this results in a time when boil off occurs of approximately 4.58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> for an SSE seismic event and an initial bulk water temperature in the pool of 140°F. This value was calculated using the maximum operating decay heat load, as summarized in Reference 18. Time to boil the level to 10 ft above the fuel racks (~735 ft) for normal operating decay heat load is determined below. Note that the top of the fuel is at ~749 ft and the boil off rate for normal decay heat load is 83.98 gpm as stated in Reference 4

Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

E-40

18.

Time to boil down to 10 ft above (749-735=14 ft = 168 in) fuel racks:

104.38 ft 3 1gal 1 min 1hour

= 168in x x x x = 26.03 + 4.58 = 30.61hours in 0.13368 ft 83.98 gal 60 min 3

In order to keep the pool at a constant level of coolant (thus covering the top of the spent fuel), the LP FLEX pumps will pressurize the ERCW headers to provide makeup to prevent a decrease in the level of the SFP.

Details:

Provide a brief description Procedures and guidance to support implementation of this strategy, of Procedures / Strategies / including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

Identify Modifications N/A Key SFP Parameter The implementation of this parameter will align with the requirements of by NRC Order EA 12-051.

This instrument will have initial local battery power; with the capability to be powered from the 480v FLEX DGs.

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Notes:

E-41

Maintain Spent Fuel Pool Cooling PWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain spent fuel pool cooling. Identify methods (makeup via portable injection source) and strategy (ies) utilized to achieve this coping time.

The transition to Phase 2 strategies will be as the inventory in the SFP slowly declines due to boiling. SFP cooling through makeup and spray will be provided by using a FLEX pump to inject coolant directly into the pool, into existing SFP cooling piping, or spray the coolant into the pool using portable FLEX spray nozzles.

A Spent Fuel Pool Cooling Pump may be energized utilizing 6.9KV FLEX DG to provide SFP cooling, if required.

Operating, pre-fuel transfer or post-fuel transfer Considering no reduction in SFP water inventory starting from nominal pool level, this results in a time when boil off decreases the water level to 10 feet above the SFP racks of approximately 85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br /> for an SSE seismic event with an initial bulk water temperature in the pool of 100°F. This value was calculated using the normal operating decay heat load, shown in the Phase 1 section for Maintain Spent Fuel Pool Cooling.

Fuel in Transfer or Full Core Offload For the maximum credible heat load and an initial water temperature in the pool of 140°F, the time when boil off decreases the water level to 10 feet above the SFP racks is approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, shown in the Phase 1 section for Maintain Spent Fuel Pool Cooling.

To provide an unlimited supply of water for SFP makeup during Phase 2, LP FLEX pumps will be used to pressurize the ERCW headers which can then be used for makeup to the SFP FLEX mitigation strategies.

For restoration of SFP cooling Watts Bar intends to repower one train of normal pool cooling equipment.

This will include the use of LP FLEX pumps on site to provide flow to the CCS heat exchanger and the onsite 6.9KV FLEX DGs to repower both the CCS and SFP cooling pumps.

The primary SFP makeup flow method is from the ERCW header connections on Elevation 757 from FLEX connections at the ERCW to CCS spool pieces (next to the CCS Surge Tanks) through a hose or hoses to the SFP. The secondary SFP makeup is new FLEX connection added to the SFP Demineralized Water System (DWS) makeup line on elevation 737. Supply to this FLEX connection could come from an available clean water source via transfer pump, if available or an ERCW FLEX connection on elevation 737. This secondary makeup capability provides makeup control when the refueling floor is not accessible. Both FLEX connections can be accessed during both flood and non-flood conditions.

Watts Bar will provide portable (fire-fighting) flow nozzle capability based on a flow of 500 gpm, which equals the FLEX requirement to provide 250 gpm of spray flow per unit to the spent fuel pool.

Details:

Provide a brief description Procedures and guidance to support deployment and implementation, of Procedures / Strategies /

including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

Identify Modifications List modifications E-42

Maintain Spent Fuel Pool Cooling

1. New connections will be made at the ERCW headers in the Intake Pumping Station (IPS) for the LP FLEX Pumps to pressurize the ERCW headers during non-flood and flood conditions. (DCN 60684)

2. New connections will be made at the ERCW headers in the 5th Diesel Generator Building for the LP FLEX Pumps to pressurize the ERCW headers during flood conditions. (DCN 60684)

3. FLEX connections will be made on the ERCW headers in the Auxiliary Building el. 737 for supplying raw water. (DCN 60684)

4. New FLEX connections will be made to the Tritiated Water Storage Tank (TWST), Primary Water Storage Tanks (PWSTs), and Demineralized Water Storage Tank for water transfer capability. (DCN 60684, DCN 60683, DCN 61784 & EDCR 60993)

5. The primary SFP FLEX connections with Storz fittings will be located at the ERCW to CCS spool pieces (next to the CCS Surge Tanks) on Refuel floor elevation 757. These can supply direct makeup or spray if required. (DCN 60684)

6. The secondary SFP FLEX connection is located on Auxiliary Building elevation 737 (a new tee, upstream isolation valve and FLEX connection) on the Demineralized Water System piping leading to the SFP. (DCN 60684).

Key SFP Parameter The implementation of this parameter will align with the requirements of by NRC Order EA 12-051.

These instruments will have initial local battery power with the capability to be powered from the 480v FLEX DGs.

Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic Portable equipment required to implement this FLEX strategy will be maintained in the FESB, which will be designed for seismic loading in excess of the minimum requirements of American Society of Civil Engineers (ASCE) 7-10. The design of the FESB provides a minimum HCLPF of 2x SSE. The 480v FLEX DGS are installed on the AB roof in a protected enclosure.

Flooding Portable equipment required to implement this FLEX strategy will be maintained in the FESB, which is designed to meet or exceed the licensing basis high wind hazard for Watts Bar. The 480v FLEX DGS are installed on the AB roof in a protected enclosure.

Severe Storms with High Portable equipment required to implement this FLEX strategy will be Winds maintained in the FESB, which is sited in a suitable location that is protected from NRC region 1 tornado, missiles, and velocities as defined in NRC Regulatory Guide 1.76 coupled with 360 mph wind speeds (Reference 5 Paragraph 2.3.1). The 480v FLEX DGS are installed on the AB roof in a protected enclosure.

E-43

Maintain Spent Fuel Pool Cooling Snow, Ice, and Extreme Cold The FESB will be evaluated for snow, ice and extreme cold temperature effects and heating will be provided as required to assure no adverse effects on the FLEX equipment. The FESB will have a standalone HVAC system.

The 480v FLEX DGS are installed on the AB roof in a protected enclosure.

High Temperatures The FESB will be evaluated for high temperature effects and ventilation will be provided as required to assure no adverse effects on the FLEX equipment. The FESB will have a standalone HVAC system. The 480v FLEX DGS are installed on the AB roof in a protected enclosure.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed to protected the point of use.

The primary method is flow from The primary SFP FLEX All FLEX equipment connection the ERCW headers at two connection modification will be an points will be designed to meet or locations using adapters and hose adapter where a hose connection exceed Watts Bar design basis connections at the 757 level. This can be installed at the ERCW SSE protection requirements.

strategy can be implemented in supply valve to the CCS Surge The primary and secondary flood and non-flood conditions. Tank flood mode spool piece.

connections are in the Auxiliary (DCN 60684)

The proposed hose routing for the Building, which is seismically primary method and the associated ERCW Modifications qualified and missile protected.

equipment can be found in The primary connection is above The same modifications required , Figure A3-14 the PMF.

to pressurize ERCW headers are through A3-16. The system described under Phase 2 Maintain connection point can be found in Core Cooling and Heat Removal. , Figure A3-12.

Note that SFP spray would be routed in an identical manner; however, the end of the hose could have the spray nozzle installed.

ERCW connections can be found in Attachment 3, Figures A3-17 and A3-18.

The secondary SFP connection The secondary SFP FLEX All FLEX equipment connection will be to the DWS makeup line, connection modification includes: points will be designed to meet or on Elevation 737 of the Auxiliary exceed Watts Bar design basis

• A tee added to the DWS Building. This strategy can be SSE protection requirements.

makeup line to the SFP implemented in flood and non-

• An isolation valve added to The connection point is in the flood conditions.

the main line upstream of the Auxiliary Building, which is FLEX hose will be routed from connection. seismically qualified and missile this location, across the floor on

• An isolation valve added to protected. Hose routing to the Elevation 737, to the ERCW the new branch. primary connection will be cleanout port FLEX connections.

• Storz cap/adapter added to the performed before flood conditions E-44

Maintain Spent Fuel Pool Cooling The proposed hose routing for the new branch. make the area inaccessible.

secondary connection and the The modification to add FLEX associated equipment can be found connections to the ERCW in Attachment 3, Figure A3-14 cleanout ports described in the through A3-16. The system Reactor Core Cooling and Heat connection point can be found in Removal section also applies to , Figure A3-13.

this case due to the location of the ERCW connections can be found connection point. (DCN 60684) in Attachment 3, Figures A3-17 and A3-18.

Notes:

1. System modifications are described in the Modifications section above and are illustrated in Attachment 3.

2. Figures A3-14 through A3-16 in Attachment 3 provides the hose routing for the SFP makeup strategies.

E-45

Maintain Spent Fuel Pool Cooling PWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using Phase 3 equipment including modifications that are proposed to maintain spent fuel pool cooling. Identify methods (makeup via portable injection source) and strategy (ies) utilized to achieve this coping time.

Details:

The strategies described for Phase 2 can continue as long as there is sufficient inventory available to feed the strategies. As mentioned for the Reactor Core Cooling and Heat Removal function, a mobile water purification unit will be received from the RRC to provide continued purified water to support this function.

Watts Bar has determined where Phase 3 equipment will be staged Also, a backup or alternate set of Phase 2 equipment will be provided by the RRC as needed.

Provide a brief description Procedures and guidance to support deployment and implementation, of Procedures / Strategies / including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available. Finally, Watts Bar will include in procedures notification of the RRC to arrange for delivery and deployment of offsite equipment and sufficient supplies of commodities.

Identify Modifications N/A Key SFP Parameter The implementation of this parameter will align with the requirements of NRC Order EA 12-051.

This instrument will have initial local battery power; with the capability to be powered from the 480v FLEX DGs.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed to protected the point of use.

The description for the mobile The description for the mobile The description for the mobile water purification system will be water purification system will be water purification system will be the same as was mentioned for the the same as was mentioned for the the same as was mentioned for the other functions. other functions. other functions.

Notes: None E-46

Safety Functions Support Determine Baseline coping capability with installed coping5 modifications not including FLEX modifications.

PWR Installed Equipment Phase 1 Provide a general description of the coping strategies using installed equipment including station modifications that are proposed to maintain and/or support safety functions. Identify methods and strategy (ies) utilized to achieve coping times.

Watts Bar will rely on existing installed 125v DC Vital Batteries to power key instrumentation and emergency lighting. A battery coping calculation determined that the battery coping time is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Preliminary analysis using conservative heat loads in the Auxiliary and Control Buildings has shown that installed equipment credited for mitigation response will remain available. In addition, accessibility of these areas for required actions is acceptable.

Details:

Provide a brief description Confirm that procedure/guidance exists or will be developed to support of Procedures / Strategies / implementation.

Guidelines Procedures and guidance to support deployment and implementation, including interfaces to EOPs, special event procedures, abnormal event procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bar's strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

Identify Modifications List modifications and describe how they support coping time.

8 Hour Battery Coping. (EDC/DCN 60976, DCN 60384 & PIC to DCN 54871). The replacement of incandescent lamps with LED lamps in emergency lighting for the Main Control Room, Shutdown Board Rooms and Appendix R Light Packs provides for additional margin on the 125v DC Vital Battery Systems.

Key Parameters List instrumentation credited for this coping evaluation phase.

• DC Bus Voltage For all instruments listed above the normal power source and the long-term power source are the 125v DC Vital Battery Systems.

Notes:

5 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

E-47

Safety Functions Support PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain and/or support safety functions. Identify methods and strategy (ies) utilized to achieve coping times.

The primary electrical need during Phase 2 is DC power for critical instrumentation. This will be accomplished by energizing the support power system and energizing battery chargers on both A and B trains in both Units 1 and 2.

The on-site 480v FLEX DGs are pre-staged to provide power to the 125v DC Vital Batteries and 120v AC Vital Instrument Power System. These generators will be pre-staged on the Auxiliary Building roof and will be protected from the external hazards with an adequate supply of fuel for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of operation. The 480v FLEX DGs will be connected to the battery chargers to power the DC and AC Vital Instrument Power System.

Additionally, the onsite 6.9KV FLEX DGs are pre-staged to provide power to the existing 6.9KV Shutdown Power System. The 6.9KV FLEX DGs may also serve as an alternative power source for the loads supplied by the on-site 480v FLEX DGs. These 6.9KV FLEX DGs will be staged in the FESB and protected from the external hazards discussed in this document.

Details:

Provide a brief description Confirm that procedure/guidance exists or will be developed to support of Procedures / Strategies / implementation with a description of the procedure / strategy / guideline.

Guidelines Procedures and guidance to support deployment and implementation, including interfaces to EOPs, special event procedures, abnormal event procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, and Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bar's strategy aligns with the generic guidance and will consider the NSSS specific guidance once available.

Identify Modifications For the 480v FLEX DGs, two fused distribution panels will be used to provide power to the supplied loads. Each fuse panel provides connections to two Vital Battery chargers and one train of hydrogen igniters for each unit. Each fuse distribution panel will have a connection to 480v AC distribution to close Cold Leg Accumulator Isolation valves during cooldown.

Fuel for the 480v FLEX DGs will be provided by the installed EDG 7-day tanks. Fuel lines will be installed between the 7-day fuel tanks mounted under the Diesel Generator building and Auxiliary Building roof to provide fuel to the 480v FLEX DGs with a fuel transfer pump. (DCN 59675)

To connect the existing 6.9KV Shutdown Power System to the 6.9KV FLEX DGs during FLEX operation, the connection to the existing safety-related Diesel Generator circuit is opened and the circuits to the 6.9KV FLEX DGs are closed by operating the existing interlocked transfer switches 1A-A, 1B-B, 2A-A, or 2B-B. This will be done under administrative controls, ensuring that a no-load condition exists on the load E-48

Safety Functions Support PWR Portable Equipment Phase 2 side of the transfer switches.

The permanently installed electrical connection points for the 6.9KV FLEX DGs are from the DGs integral output connection panel through conduits within the FESB to underground conduits located on the outside of the FESB south wall. One 6.9KV FLEX DG will be assigned to power Train A on both units and the second 6.9KV FLEX DG will be assigned to power Train B of both units.

The conduits will meet seismic Class I requirements for safety related and quality-related structures. Actual mechanical and electrical connections to the presently installed safety related DG equipment shall meet safety related requirements at the interfaces.

Refueling of the 6.9KV FLEX DGs will be accomplished using a separate diesel fuel transfer pump dedicated for the purpose of transferring fuel from the 7-day tanks to the 6.9KV FLEX DGs fuel oil day tanks. (DCN 60853)

Key Parameters List instrumentation credited or recovered for this coping evaluation.

• 125v DC Vital Batteries Bus Voltage For the instrument listed above the normal power source and the long-term power source are the 125v DC Vital Battery.

Watts Bar will develop procedures to read this instrumentation locally, where applicable, using a portable instrument as required by Section 5.3.3 of NEI 12-06.

Storage / Protection of Equipment :

Describe storage / protection plan or schedule to determine storage requirements Seismic Equipment for this function will either be stored or pre-staged in the FESB, in the Auxiliary Building, Intake Pumping Station or on the Auxiliary Building roof. The protection of FLEX equipment for this hazard is addressed for each of these locations in the Reactor Core Cooling and Heat Removal and Maintain RCS Inventory Control sections.

Flooding Equipment for this function will either be stored or pre-staged in the FESB, Note: if stored below current flood level, in the Auxiliary Building, Intake Pumping Station or on the Auxiliary then ensure procedures exist to move Building roof. The protection of FLEX equipment for this hazard is equipment prior to exceeding flood level. addressed for each of these locations in the Reactor Core Cooling and Heat Removal and Maintain RCS Inventory Control sections.

Severe Storms with High Equipment for this function will either be stored or pre-staged in the FESB, Winds in the Auxiliary Building, Intake Pumping Station or on the Auxiliary Building roof. The protection of FLEX equipment for this hazard is addressed for each of these locations in the Reactor Core Cooling and Heat Removal and Maintain RCS Inventory Control sections.

Snow, Ice, and Extreme Cold Equipment for this function will either be stored or pre-staged in the FESB, in the Auxiliary Building, Intake Pumping Station or on the Auxiliary Building roof. The protection of FLEX equipment for this hazard is addressed for each of these locations in the Reactor Core Cooling and Heat Removal and Maintain RCS Inventory Control sections.

E-49

Safety Functions Support PWR Portable Equipment Phase 2 High Temperatures Equipment for this function will either be stored or pre-staged in the FESB, in the Auxiliary Building, Intake Pumping Station or on the Auxiliary Building roof. The protection of FLEX equipment for this hazard is addressed for each of these locations in the Reactor Core Cooling and Heat Removal and Maintain RCS Inventory Control sections.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed to protected the point of use.

The strategy for this function is 1. 225kva DGs (480v FLEX The protection structure for the described above in the Identify DGs). (DCN 59675) 480v FLEX DGs will be designed Modifications section. 2. 3 MWe DGs (6.9KV FLEX and installed such that each is DGs) (DCN 60853) protected from the five external hazards, as described in this

3. 8 Hour Battery Coping.

section. The fuse distribution (EDC/DCN 60976, DCN panels for the 480v FLEX DGs 60384 & PIC to DCN 54871) will be located inside the Auxiliary Building which will provide protection from the external hazards, as described in this section.

Notes: None.

E-50

Safety Functions Support PWR Portable Equipment Phase 3 Provide a general description of the coping strategies using Phase 3 equipment including modifications that are proposed to maintain and/or support safety functions. Identify methods and strategy (ies) utilized to achieve coping times.

A backup or alternate set of Phase 2 equipment will be provided by the RRC, as needed. Watts Bar has determined Phase 3 equipment staging locations.

Details:

Provide a brief description Procedures and guidance to support deployment and implementation, of Procedures / Strategies / including interfaces to EOPs, special event procedures, abnormal event Guidelines procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Rev. 0, Section 11.4. Further, the PWROG has developed generic guidance, and Watts Bars strategy aligns with the generic guidance and will consider the NSSS specific guidance once available. Finally, Watts Bar will include notification of the RRC in plant procedures to arrange for delivery and deployment of off-site equipment and sufficient supplies of commodities.

Identify Modifications N/A Key Parameters No additional instrumentation is required to support the Phase 3 safety function support.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify Modifications Identify how the connection is the equipment will be deployed to protected the point of use.

A backup or alternate set of Phase Each of the Phase 3 strategies will There are no connection points for 2 equipment will be provided by utilize common connections as this strategy. All equipment will the RRC, as needed. described for the Phase 2 be provided by offsite resources.

connections to prevent any compatibility issues with the offsite equipment.

Notes: None E-51

PWR Portable Equipment Phase 2 Use and (potential / flexibility) diverse uses Performance Criteria1 Maintenance Maintenance / PM List portable equipment Core Containment SFP Instrumentation Accessibility requirements Two Medium Voltage 6900v AC Will follow EPRI Diesel Generator X X X X X 3 MW template requirements (Repowers 6.9 KV Shutdown Boards)

Two Low Voltage Diesel 480v AC Will follow EPRI Generators (Repowers the 225 kva template requirements 125v DC Vital Battery X X X X X System)

Three (Dominator) Low 5000 gpm Will follow EPRI Pressure FLEX Pumps 150 PSIG [350 ft. Total template requirements (Pressurizes ERCW X X X Dynamic Head (TDH)]

Headers) Diesel Driven Three (Triton) Floating 5000 gpm Will follow EPRI Booster Pumps (Supplies X X X 50 ft. lift template requirements Low Pressure FLEX Diesel Driven Pump)

Two Intermediate 150 gpm Will follow EPRI Pressure FLEX Pumps 400 PSIG (922 ft. TDH) template requirements (Core Cooling Makeup X X Diesel Driven Pumps - Non-Flood Events) 1 Performance criteria of FLEX equipment is conservative and was determined during conceptual design as a basis for the selection of required FLEX equipment.

(Reference 20).

E-52

PWR Portable Equipment Phase 2 Use and (potential / flexibility) diverse uses Performance Criteria1 Maintenance Maintenance / PM List portable equipment Core Containment SFP Instrumentation Accessibility requirements Two Intermediate 150 gpm Will follow EPRI Pressure FLEX Pumps 400 PSIG (922 ft. TDH) template requirements (Core Cooling Makeup X 480v AC Pumps - Flood Event)

Two Mode 5 & 6 FLEX 150 gpm Will follow EPRI Pumps (RCS Core 400 PSIG (922 ft. TDH) template requirements Cooling and Makeup X 480v AC Pumps - Non-Flood or Flood Event)

Three High Pressure 40 gpm Will follow EPRI FLEX Pumps (RCS 600 PSIG (1384 ft. template requirements X

Inventory Control) TDH) 480 v AC Two Water Transfer 500 gpm Will follow EPRI Pumps X X 165 PSIG (374 ft. TDH) template requirements Diesel Driven Two SFP Spray Nozzles X 250 gpm Will follow EPRI template requirements One Tow Vehicle with bed Capable of on-site Will follow EPRI mounted fuel tank and transport of 14,000 template requirements fuel transfer capability. Gross Vehicle Weight (Deployment of FLEX (GVW) trailer and fuel X X X X X Equipment and Fuel transfer with 500 gallon Transfer) truck bed mounted fuel tank and fuel transfer pump.

E-53

PWR Portable Equipment Phase 2 Use and (potential / flexibility) diverse uses Performance Criteria1 Maintenance Maintenance / PM List portable equipment Core Containment SFP Instrumentation Accessibility requirements Fuel Transfer Equipment 975 gallon trailer Will follow EPRI mounted fuel tanks. template requirements

• Two Fuel Tanks -

X X X X X with fuel transfer Trailer Mounted pumps.

• Two Diesel Powered Fuel Transfer Pumps 200 gpm Diesel Driven Debris Clearing Capable of clearing Will follow EPRI Equipment trees, light poles, template requirements building and/or Two Compact Track construction materials Loaders with Tow X X X X and miscellaneous Hitches.

debris. Provides additional FLEX equipment towing capability.

E-54

PWR Portable Equipment Phase 3 Use and (potential / flexibility) diverse uses Performance Criteria 1 Notes List portable Core Containment SFP Instrumentation Accessibility equipment Medium Voltage 6900v AC Will follow EPRI Diesel Generator X X X X X 3 MW template requirements Backup Low Voltage Diesel 480v AC Will follow EPRI X X X X X Generator 225 kva template requirements Backup Low Pressure FLEX 5000 gpm Will follow EPRI Pumps (Dominator) X X X 150 PSIG (350 ft TDH) template requirements (Pressurizes ERCW Diesel Driven Headers)

Floating Booster 5000 gpm Will follow EPRI Pumps (Triton) 50 ft. lift template requirements (Supplies Low X X X Diesel Driven Pressure FLEX Pump)

Intermediate Pressure 150 gpm Will follow EPRI FLEX Pumps (Core 400 PSIG (922 ft. TDH) template requirements Cooling Backup X X Diesel Driven Pumps Non-Flood Event)

Intermediate Pressure X X 150 gpm Will follow EPRI FLEX Pumps (Core 400 PSIG (922 ft. TDH) 1 Performance criteria of FLEX equipment is conservative and was determined during conceptual design as a basis for the selection of required FLEX equipment. Reference 20.

E-55

PWR Portable Equipment Phase 3 Use and (potential / flexibility) diverse uses Performance Criteria 1 Notes List portable Core Containment SFP Instrumentation Accessibility equipment Cooling Backup 480v AC template requirements Pump - Flood Event)

Mode 5 & 6 FLEX 150 gpm Will follow EPRI Pumps (RCS Core 400 PSIG (922 ft. TDH) template requirements Cooling and Makeup X 480v AC Pumps - Non-Flood or Flood Event)

High Pressure FLEX 40 gpm Will follow EPRI Pumps Backup (RCS X 600 PSIG (3561 ft TDH) template requirements Inventory Control) 480v AC Water Transfer Pumps 500 gpm Will follow EPRI X X Backup 165 PSIG (374 ft. TDH) template requirements Diesel Driven Fuel Transfer Tanker - 500 gallons Will follow EPRI Equipment Minimum template requirements X X X X X

• Fuel Tankers Transfer Pump - 200 gpm

• Diesel Fuel Diesel Driven Transfer Pumps Mobile Water X X Supplied by RRC Purification Unit E-56

Phase 3 Response Equipment/Commodities Item Notes Radiation Protection Equipment

• Survey instruments

• Dosimetry

• Off-site monitoring/sampling

• Radiological counting equipment

• Radiation protection supplies

• Equipment decontamination supplies

• Respiratory protection

• Portable Meteorological (MET) Towers Commodities

• Food o Meals ready to eat (MRE) o Microwaveable Meals

• Potable water Fuel Requirements

• Diesel Fuel Heavy Equipment

• Transportation equipment o 4 wheel drive tow vehicle

• Debris clearing equipment Communications Equipment

• Satellite Phones

• Portable Radios Portable Interior Lighting

• Flashlights

• Headlamps

• Batteries Portable Exterior Lighting

• Diesel generator powered light units E-57

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, March 12, 2012. [ADAMS Accession Number ML12054A735]

2. NEI 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, August 2012.

3. NRC JLD-ISG-2012-01, Revision 0, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, August 2012.

4. Watts Bar Nuclear Plant Updated Final Safety Analysis Report (UFSAR), Amendment 9, November 21, 2011.

5. Watts Bar Nuclear Plant Unit 2 Final Safety Analysis Report (FSAR), Amendment 109.

6. Not Used.

7. Not Used.

8. WCAP-17601-P, Revision 1, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, and Babcock & Wilcox NSSS Designs, PWROG Project PA-ASC-0916, January 2013.

9. LAR WBN-UFSAR-12-01, Application to Revise Watts Bar Nuclear Plant Unit 1 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, TAC No.

ME8200,July 19, 2012. (Accession No. ML12236A167)

10. TVA Drawings

a. 46W501-1, Revision J, Architectural Plan El 676.0 & 692.0.

b. 46W501-2, Revision J, Architectural Plan El 708.0 & 713.0.

c. 46W501-3, Revision K, Architectural Plan El 729.0 & 737.0.

d. 46W501-4, Revision K, Architectural Plan El 755.0 & 757.0.

e. 46W501-5, Revision F, Architectural Plan El 782.0 & 786.0.

f. 47W200-1, Revision 12, Equipment Plans - Roof

11. Replaced with References 18-20.

12. Task Interface Agreement (TIA) 2004-04, "Acceptability of Proceduralized Departures from Technical Specifications (TSs) Requirements at the Surry Power Station," (TAC Nos.

MC4331 and MC4332)," dated September 12, 2006. (Accession No. ML060590273)

13. OG-12-482, Revision 0, Transmittal of PA-PSC-0965 Core Team PWROG Core Cooling Management Interim Position Paper, November, 2012.

14. FLEX Implementation HVAC Analysis Impact Study, Project No. 12938-012.

15. AOI-40, Rev. 16, Station Blackout, March 1, 2012.

16. OG-12-515, Transmittal of Final Generic PWROG FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommended Instruments) from PA-PSC-0965, Revision 0, December 2012.

17. 1-ECA-0.0, Rev. 0, Loss of Shutdown Power.

18. Westinghouse Calculation Note, CN-SEE-II-12-40, Revision 3, Determination of Time to Boil in the Watts Bar Spent Fuel Pool after an Earthquake.

19. Westinghouse Calculation Note, CN-SEE-II-12-20, Revision 2, Supporting Chemistry Calculations for Alternate Cooling Source Usage during Extended Loss of All A.C. Power at Watts Bar Nuclear Units 1 and 2.

20. Westinghouse Calculation Note, CN-SEE-II-13-26, Revision 0, Watts Bar Unit 1 and Unit 2 Reactor Coolant System FLEX Evaluation with Standard Reactor Coolant Pump Seals.

21. TVA Drawing 47E235-36, Environmental Data Environment

22. Watts Bar White Paper - Liquification of Haul Routes for FLEX and Subsurface Investigation and Foundation Report for the Watts Bar Nuclear Plant Unit 1 Steam Generator Replacement Project. (EDMS 24900-100-KOR-CY00-00001).

E-58

23. NPG Calculation Record of Revision, MDQ00006720120190, Evaluation ERCW Availability during Extended Station Blackout E-59

Open Items Open item Description Status Notes Number The current condensate storage tank (CST) A contract has been is a non-seismic tank that is not missile awarded for the new protected. The site is currently pursuing two Auxiliary Feedwater options; the qualification and hardening of Supply Tank (AFWST).

1 the existing CST or the construction of a Closed DCN 60060 & DCN new seismically qualified and missile 62324 for AFW Tank protected CST. One of these options must be completed before the volume of the CST DCN 61422 for tie in to can be credited. existing plant piping (U1)

Liquefaction of haul routes for FLEX will 2 Closed See Reference 22 be analyzed.

No detailed analysis has been provided regarding initial FLEX fuel supplies to determine a need time for access to 7 day tank supplies or resupply of the 7 day tanks. Fuel consumption It is assumed that each FLEX component is spreadsheet completed to 3 Closed stored with a minimum supply of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of show that fuel supply will fuel at constant operation. This assumption last seven days.

will need to be assessed once all FLEX equipment has been purchased and equipment specifications are known.

No need time has been identified for action to protect containment. This includes actions to mitigate pressurization of containment due to steaming when reactor coolant system (RCS) vent paths have been MAAP Analysis due 4 Open established or actions to mitigate Feb.14 temperature effects associated with equipment survivability. An evaluation will be provided to prove indefinite containment coping.

The Phase 3 equipment staging area has not Areas are identified and been determined. will be included with the 5 Closed Regional Response Center (RRC) playbook.

E-60

Open item Description Status Notes Number A strategy for clearing and removing debris Debris removal 6 will be determined. Closed equipment is identified and storage determined A thorough analysis of the makeup flow rate Detailed FLEX Operating requirements and other equipment Conditions and pump 7 Closed characteristics will be finalized during the sizing has been completed detailed design phase of FLEX. (Reference 20)

The need time for spent fuel pool (SFP) cooling actions (deployment of hose, venting, and alignment of makeup) was determined using worst case heat loads.

8 This item will continue to be assessed and Closed (Reference 18) later action times may be acceptable. Note that the timing for this step during an outage is different, but resources will be available to complete the required actions.

Functional requirements for each of the Phase 3 strategies, equipment and 9 components will be completed at a later time Started and will be provided in the six month updates to the February 28, 2013 submittal.

Containment temperature instrumentation is only available until flood waters enter the technical support center (TSC) inverter or MAAP Analysis to 10 Started station battery rooms. A method to monitor resolve containment temperature, post-flood, will be developed.

The heating, ventilation and air conditioning Calculation ID:

11 (HVAC) analysis is preliminary, and has not Closed MDQ0003602013000272.

been finalized. RIMS #: 130830 801 Verify ability to deploy FLEX equipment to provide core cooling in Modes 5 and 6 with steam generators (SGs) unavailable. If it is Demonstration prior to determined that gravity feed is not effective implementation of the 12 to cool the RCS and prevent fuel damage, Open order and included as part Watts Bar will take actions to proceduralize of the FLEX strategy administrative controls to pre-stage FLEX (Reference 20).

equipment prior to entering a condition where the SGs cannot provide adequate core cooling.

E-61

Open item Description Status Notes Number An evaluation of the impact of FLEX An evaluation of the response actions on design basis flood mode impact of FLEX response preparations will be performed. This actions on design basis evaluation will include the potential for flood mode preparations extended preparation time for FLEX. will be performed. This Changes which affect the Integrated Plan evaluation will include 13 Open will be included in the six month update. the potential for extended preparation time for FLEX. Changes which affect the Integrated Plan will be included in the six month update.

Further analysis will be performed to The revised timelines determine the required timeline for show that the 6.9 KV implementing the 6.9 KV FLEX diesel FLEX DGs are available generators (DGs) as an alternate power within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Updated source for the loads supplied by the 480 V sequence of events for 14 FLEX DGs. Closed both flood and non-flood conditions have been completed by TVA. They are added to this letter in Attachment 1A, Sequence of Events Timeline.

The CETs are only available until water 15 enters the auxiliary instrument room. A CETs will not be required Closed method to monitor CET, post flood, will be for flood event.

evaluated and developed, if required.

Strategies to address extreme cold Initial RWST Technical conditions on the refueling water storage Specifications 16 tank (RWST) and/or boric acid tanks Closed temperature requirements (BATs), including potential need to ensure that five hours is reenergize heaters have not been finalized. not challenged.

Establish an agreement with the Strategic Agreement with Regional 17 Alliance for FLEX Emergency Response Closed Response Center (RRC) is (SAFER) team in accordance with the in place.

requirements of Section 12 of NEI 12-06.

E-62

Open item Description Status Notes Number Manual station blackout (SBO) load This open item from the shedding time in References 4 and 5, OIP submittal no longer Section 8.3.2.1.1, will be revised from 30 applies to the strategy 18 minutes to 45 minutes as supported by the 8 since Watts Bar is no Closed hour extended loss of alternating current longer doing the initial power (ELAP) battery calculations. load shed, as discussed in Attachment 1A, Sequence of Events Timeline.

ACRONYMNS ABMT auxiliary boration makeup tank AC alternating current ACR auxiliary control room ACS alternate coolant system AFW auxiliary feedwater AFWST auxiliary feedwater supply tank AOI abnormal operating instruction AOP abnormal operating procedure AOV air-operated valve APM available physical margin ARV atmospheric relief valve AUO assistant unit operator BAT boric acid tank BCS backup control station BDB beyond-design-basis BDBEE beyond-design-basis external events CCS component cooling system CCW condenser circulating water CFR Code of Federal Regulations CLA cold leg accumulator CLB current licensing basis CST condensate storage tank CVCS chemical and volume control system CWST cask washdown storage tank DBFL design basis flood level DBE design basis event DC direct current DCN design change notice DG diesel generator DGB diesel generator building DWHT demineralized water head tank DWST demineralized water storage tank EDG emergency diesel generator EDC engineering document change EDCR engineering document construction release E-63

EDMG extreme damage mitigation guideline EFW emergency feedwater ELAP extended loss of ac power EOI emergency operating instruction EOP emergency operating procedure EPRI Electric Power Research Institute ERCW essential raw cooling water ERO emergency response organization ESF engineered safety feature FESB FLEX equipment storage building FLEX Flexible and Diverse Coping Mitigation Strategies FMBMS flood mode boration makeup system FSG FLEX support guideline FSI FLEX support instructions HCLPF high confidence of low probability failure HPFP high pressure fire protection HP FLEX Pump high pressure (HP) FLEX pump HVAC heating, ventilation, and air conditioning IER Industry Event Report INPO Institute of Nuclear Power Operations IP FLEX Pump intermediate pressure (IP) FLEX pump ISG Interim Staff Guidance LCV level control valve LOCA loss of coolant accident LOOP loss of offsite power LP FLEX Pump low pressure (LP) FLEX pump LUHS loss of normal access to the ultimate heat sink MCC motor control centers MCR main control room MDAFWP motor driven auxiliary feedwater pump MOV motor operated valve MRE meals ready to eat MSL mean sea level MSVV main steam valve vault NEI Nuclear Energy Institute NPSH net positive suction head NRC Nuclear Regulatory Commission NSSS nuclear steam supply system NTTF Near-Term Task Force OBE operating basis earthquake PIC post issuance change PORV power operated relief valve PMF probable maximum flood PMP probable maximum precipitation PRA probabilistic risk assessment PWR pressurized water reactor PWROG Pressurized Water Reactor Owners Group PWST primary water storage tank QR quality related RCP reactor coolant pump RCS reactor coolant system E-64

RHR residual heat removal RRC Regional Response Center RWST refueling water storage tank RWT raw water tank SAFER Strategic Alliance for FLEX Emergency Response SAMG severe accident management guideline SBO station blackout SFP spent fuel pool SG steam generator SIP safety injection pump SIS safety injection system SPRA seismic probabilistic risk assessment SR safety related S/RVs safety/relief valves SSC systems, structures and components SSE safe shutdown earthquake TD turbine-driven TDH total dynamic head TSC technical support center TDAFWP turbine driven auxiliary feedwater pump TOAF top of active fuel TVA Tennessee Valley Authority TWST tritiated water storage tank UFSAR updated final safety analysis report UHS ultimate heat sink E-65

Attachment 1A Sequence of Events Timeline Non-Flood Event Elapsed Time Task Action New ELAP time from Event Action Duration Remarks / Applicability Item constraint Y/N Initiation (hours)

(T-0) 0 Event Starts N NA Plant @100% power 0 SBO N NA 1-ECA-0.0 (Reference 17)

ELAP entry can be verified by control room staff and it is validated that the Equal to or Emergency Diesel Generators (EDGs) are Within 1 Less Than 1 1 Declare ELAP N not available. This declaration needs to hour of T-0 hour from occur within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from T-0 to provide T-0 operators with guidance to perform ELAP actions.

This provides charging current to the 125v DC Vital Batteries and ensures 125v DC Align and place in service the 480v 2 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Y 0.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> Vital Battery power (control) and through FLEX Diesel Generators (DGs) the Vital inverters 120v AC Vital Instrument Power (instrument indication).

Verify 125v DC Vital Battery Chargers Complete Completed with 90 minutes (1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) energized and supplying required load within 1.5 from T-0. This ensures an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping to the 125v DC Vital Batteries. hours of T-0 time for the 125v DC Vital Batteries. This 3 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> N IF not, ensures the 125v DC Vital Battery Minimum THEN complete Extended Load Shed Chargers loading is less than the load limit duration 0.5 for any Vital Battery not being supplied on the chargers (ensures charging of the hours.

its required load. batteries).

EA1-1

Elapsed Time Task Action New ELAP time from Event Action Duration Remarks / Applicability Item constraint Y/N Initiation (hours)

(T-0)

Watts Bar is developing a post event damage assessment procedure. The damage assessment will evaluate and document the condition of plant systems, structures and components (SSCs) after an ELAP event. The assessment will be Damage Assessment and Flex 4 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> consistent with guidelines contained in Equipment Staging supplement 5 of reference 16. FLEX equipment staging locations and access routes will be a priority for the damage assessment. This assessment will facilitate debris removal, if required, to support FLEX equipment staging.

Staged and aligned to take suction from the intake channel and discharge routed to the Essential Raw Cooling Water (ERCW)

FLEX connections at the Intake Pumping Stage and align Low Pressure (LP) Station (IPS). An alternate or additional 5 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Y 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> FLEX pumps raw water source could come from the CCW Cooling Tower basin supplying suction to a Dominator LP FLEX Pump with its discharge routed to FLEX (or B.5.b) connection at the 5th DG Building.

EA1-2

Elapsed Time Task Action New ELAP time from Event Action Duration Remarks / Applicability Item constraint Y/N Initiation (hours)

(T-0)

At rated RCS pressure a potential leakage rate of 21 GPM per RCP following the event is possible. RCS cooldown rate of 75 to 100° F/hr should be sustained until Within 1 stabilized at ~ 300 PSIA SG pressure.

6 RCS Depressurization and Cooldown. Y 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> hour of T-0 Maintain RCS pressure greater than 250 psig to avoid Cold Leg Accumulator nitrogen injection into the RCS.

Cooldown and depressurization should be stabilized within T-4 hours.

This is to ensure switching at the DG Alignment of 6.9KV FLEX DGs building and shutdown board rooms are (FESB), kirk-key transfer switches complete, potential board loading is 7 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (EDG Bldg.), 6.9 KV Shutdown Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reduced and interlocks are cleared to allow Boards, emergency feeder breakers and the emergency feeder breakers to be used 480 V Shutdown Board Alignment to safely power the 6.9 KV Shutdown Boards from the 6.9KV FLEX DGs.

Energize the 6.9 KV Shutdown Boards with the 6.9KV FLEX DGs. Place the following components in service and restore RCS pressurizer level: Action initiated to support repowering 8 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

• Component Cooling System (CCS) Y 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> installed pumps to restore RCS inventory.

Pumps.

• Safety Injection Pumps, as required to recover and maintain RCS pressurizer level.

EA1-3

Elapsed Time Task Action New ELAP time from Event Action Duration Remarks / Applicability Item constraint Y/N Initiation (hours)

(T-0)

Note: The MDAFWPs and the Auxiliary Air Compressors can be placed in service and serve as the secondary SG makeup source, if required.

Place the following equipment in service, if required. Verify 6.9KV FLEX DG loading between component starts. Action initiated, if required, to support 9 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

• Auxiliary Air Compressors Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> repowering various installed pumps to

• Motor Driven Auxiliary Feedwater provide indefinite coping capability.

Pumps (MDAFWP)

• Spent Fuel Pool (SFP) Cooling Pump (Restore SFP cooling).

The HP FLEX pump discharge can be Stage and align the High Pressure (HP) routed to either Safety Injection Pumps FLEX Pumps with suction from discharge headers FLEX connection.

Refueling Water Storage Tank (RWST) 10 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Y 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> RCS makeup is required to compensate FLEX connections. {Alternate is from for cooldown (shrinkage and boration).

the Boric Acid Tank (BAT) FLEX Hoses will remain isolated and pumps out connection for boration}.

of service until required.

EA1-4

Elapsed Time Task Action New ELAP time from Event Action Duration Remarks / Applicability Item constraint Y/N Initiation (hours)

(T-0)

Suction is aligned from the AFWST. The IP FLEX pump discharge can be routed to Stage and align the Intermediate FLEX connections upstream of the Pressure (IP) FLEX pumps at the TDAFWP Level Control Valves (LCV)

Auxiliary Feedwater Supply Tank (primary) or upstream of the MDAFWP 11 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Y 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (AFWST) for backup for SG makeup LCVs (secondary).

(backup to the TDAFWP (or) This is a contingency in case of loss of the MDAFWPs). normal SG makeup capabilities. Hoses will remain isolated and pumps out of service.

Hoses will be routed from an Auxiliary Building el. 757 ERCW FLEX connection Deploy hoses and spray nozzles as a to the SFP area or from an el. 737 ERCW 12 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> contingency for SFP makeup. FLEX connection to the demineralized water FLEX connection on el. 737 to allow makeup to the SFP.

This will need to be established within 8 Continuous hours. This is an assumption and will Initiate fueling operations for diesel 13 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Y from need to be assessed once all FLEX powered FLEX equipment.

initiation equipment has been purchased and specifications are known.

EA1-5

Elapsed Time Task Action New ELAP time from Event Action Duration Remarks / Applicability Item constraint Y/N Initiation (hours)

(T-0)

Makeup to the AFWST will need to be evaluated. The AFWST provides Sources of makeup to the AFWST are approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for 2 unit identified and FLEX connections are Continuous operation. If the Condensate Storage provided to facilitate transfer of quality 14 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Y from Tanks survive the event an additional water. Alignment to the ERCW system an initiation inventory of quality water will be ultimate heat sink source via the LP FLEX available, allowing additional time for pumps remains an option.

makeup to the AFWST.

This is not a time constraint. MCR and Shutdown Board Rooms are provided with Initiate portable lighting for MCR, Continuous battery backup lighting. Portable lighting 15 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Shutdown Board Room and FLEX Y from for FLEX equipment staging locations equipment locations, as required. initiation could be required. Portable lighting will be available for internal and external service, if required.

Monitor TDAFWP Room, Main Control If required, verify 6.9KV FLEX DG Continuous Room (MCR), Shutdown Board Room, loading and restore selected heating, 16 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Y from Vital Battery Board Room and SFP area ventilation and air conditioning (HVAC) initiation ventilation needs. systems to service. (Reference 14)

Evaluate, identify and address long term (within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) needs including:

17 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Y Continuous

• Mobile water purification unit

• Site diesel and gasoline fuel service.

EA1-6

Attachment 1A Sequence of Events Timeline Flood Event Elapsed Time New ELAP Task Action from Event Action time constraint Duration Remarks / Applicability Item Initiation Y/N (hours)

T-0 Note: An ELAP could occur at anytime during flood preparation or a flood event therefore FLEX equipment and strategies must be staged and ready for implementation if required.

Note: The scenario described below assumes an ELAP event occurs post initial flood warning received from TVAs River System Operations and prior to a Stage 1 warning notification. This provides a 27 hour3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> period before flood waters reach grade elevation. This flood preparation time period allows for initial use of the same strategy as a non-flood event for Steps 1-9 for stabilizing the plant and staging FLEX equipment for flood mitigation strategy.

0 Event Starts NA NA Plant @100% power 0 SBO N NA 1-ECA-0.0 (Reference 17)

ELAP entry can be verified by control room staff and it is validated that the Within 1 Within 1 Emergency Diesel Generators (EDGs) are 1 Declare ELAP N not available. This declaration needs to hour of T-0 hour of T-0 occur within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from T-0 to provide operators with guidance to perform ELAP actions.

EA1-7

Elapsed Time New ELAP Task Action from Event Action time constraint Duration Remarks / Applicability Item Initiation Y/N (hours)

T-0 This provides charging current to the 125v Align and place in service the 480v DC Vital Batteries and ensures 125v DC 2 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Y 0.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> Vital Battery power (control) and through FLEX Diesel Generators (DGs) the Vital inverters 120v AC Vital Instrument Power (instrument indication).

Verify 125v DC Vital Battery Chargers Complete Completed with 90 minutes (1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) energized and supplying required load within 1.5 from T-0. This ensures an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping to the 125v DC Vital Batteries. hours of T-0 time for the 125v DC Vital Batteries. This 3 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> IF not, N ensures the 125v DC Vital Battery THEN complete Extended Load Shed Minimum chargers loading is less than the load limit for any Vital Battery not being duration 0.5 on the chargers (ensures charging of the supplied its required load. hours batteries).

Watts Bar is developing a post event damage assessment procedure. The damage assessment will evaluate and document the condition of plant systems, structures and components (SSCs) after an Damage Assessment and Flex ELAP event. The assessment will be 4 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> consistent with guidelines contained in Equipment Staging supplement 5 of reference 16. FLEX equipment staging locations and access routes will be a priority for the damage assessment. This assessment will facilitate debris removal, if required, to support FLEX equipment staging.

EA1-8

Elapsed Time New ELAP Task Action from Event Action time constraint Duration Remarks / Applicability Item Initiation Y/N (hours)

T-0 Staged and aligned to take suction from Stage and align Low Pressure (LP) the intake channel and discharge routed to 5 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Y 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> the Essential Raw Cooling Water (ERCW)

FLEX pumps (Dominator and Triton)

FLEX connections at the Intake Pumping Station (IPS).

At rated RCS pressure a potential leakage rate of 21 GPM per RCP following the event is possible. RCS cooldown rate of 75 to 100° F/hr should be sustained until Within 1 stabilized at ~ 300 PSIA SG pressure.

6 RCS Depressurization and Cooldown. Y 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> hour of T-0 Maintain RCS pressure greater than 250 psig to avoid Cold Leg Accumulator nitrogen injection into the RCS.

Cooldown and depressurization should be stabilized within T-4 hours.

This is to ensure switching at the DG Alignment of 6.9KV FLEX DGs building and shutdown board rooms are (FESB), kirk-key transfer switches complete, potential board loading is 7 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (EDG Bldg.), 6.9 KV Shutdown Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reduced and interlocks are cleared to allow Boards, emergency feeder breakers the emergency feeder breakers to be used and 480 V Shutdown Boards. to safely power the 6.9 KV Shutdown Boards from the 6.9KV FLEX DGs.

EA1-9

Elapsed Time New ELAP Task Action from Event Action time constraint Duration Remarks / Applicability Item Initiation Y/N (hours)

T-0 Energize the 6.9 KV Shutdown Boards with the 6.9KV FLEX DGs. Place the following components in service and restore RCS pressurizer level: Action initiated to support repowering 8 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Y 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

• Component Cooling System installed pumps to restore RCS inventory.

(CCS) Pumps.

• Safety Injection Pumps, as required to recover and maintain RCS pressurizer level.

Note: The MDAFWPs and Auxiliary Air Compressors can be placed in service and serve as the secondary SG makeup source, if required.

Place the following equipment in service, if required. Verify 6.9KV FLEX DG loading between component Action initiated to support repowering starts. various installed pumps to provide coping 9 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> capability until flood waters reach plant

• Auxiliary Air Compressors grade and transition to FLEX mitigation

• Motor Driven Auxiliary Feedwater strategy occurs.

Pumps (MDAFWP).

• Spent Fuel Pool (SFP) Cooling Pump (Restore SFP cooling).

EA1-10

Elapsed Time New ELAP Task Action from Event Action time constraint Duration Remarks / Applicability Item Initiation Y/N (hours)

T-0 Stage a Dominator LP FLEX Pump with suction from the CCW Cooling Tower Stage and align the following LP basin and discharge hoses routed to B.5.b FLEX Pumps. connections at the 5th DG Building.

• A Dominator LP FLEX Pump Stage a second set of Low Pressure (LP) at the CCW Cooling Tower FLEX Pumps Aligned to take suction from 10 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> basin. Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the road just South of the 5th Diesel

• A second set of Low Pressure Building with discharge routed to the (LP) FLEX Pumps Essential Raw Cooling Water (ERCW)

(Dominator and Triton) staged FLEX connections inside the 5th DG on a pad just west of the 5th Building.

DG Building.

Hoses will remain isolated and pumps out of service until required.

The HP FLEX pump discharge can be routed to either Safety Injection Pump Stage and align the High Pressure discharge headers FLEX connection (B (HP) FLEX pumps (AB el. 692) with Train primary and A Train secondary).

11 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> suction from the Refueling Water Y 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> RCS makeup is required to compensate Storage Tank (RWST) FLEX for cooldown (shrinkage and boration).

connections (AB el. 692). Hoses will remain isolated and pumps out of service until required.

EA1-11

Elapsed Time New ELAP Task Action from Event Action time constraint Duration Remarks / Applicability Item Initiation Y/N (hours)

T-0 Suction hoses are aligned from the AB el.

737 ERCW FLEX connections. The IP FLEX pumps discharge hoses can be routed to FLEX connection upstream of Stage and align the Intermediate the TDAFWP Level Control Valves 12 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Pressure (IP) FLEX pumps AB el. 737 Y 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (LCVs) (SMSVV el. 729) (primary) or for makeup capability to the SGs. FLEX connections upstream of the MDAFWP LCVs (AB el. 737)

(secondary).

Hoses will remain isolated and pumps out of service until required.

Hoses will be routed from an Auxiliary Building el. 757 ERCW FLEX connection Deploy hoses and spray nozzles as a 13 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Y 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to the SFP area or from an el. 737 ERCW contingency for SFP makeup.

FLEX connection to the SFP demineralized water FLEX connection on el. 737 to allow makeup to the SFP.

This will need to be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This is an assumption and will Initiate fueling operations for diesel Continuous 14 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Y need to be assessed once all FLEX powered FLEX equipment. once initiated equipment has been purchased and specifications are known.

EA1-12

Elapsed Time New ELAP Task Action from Event Action time constraint Duration Remarks / Applicability Item Initiation Y/N (hours)

T-0 Makeup to the AFWST will need to be evaluated. The AFWST provides Sources of makeup to the AFWST are approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for 2 unit identified and FLEX connections are operation. If the Condensate Storage Continuous provided to facilitate transfer of quality 15 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Y Tanks survive the event an additional once initiated water. Alignment to the ERCW system an inventory of quality water will be ultimate heat sink source via the LP FLEX available prior to the requirement to pumps remains an option.

makeup to the AFWST.

This is not a time constraint. MCR and Shutdown Board Rooms are provided with Initiate portable lighting for MCR, battery backup lighting. Portable lighting Continuous 16 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Shutdown Board Room and FLEX Y for FLEX equipment staging locations once initiated equipment locations, as required. could be required. Portable lighting will be available for internal and external service, if required.

Monitor TDAFWP Room, Main If required, verify 6.9 KV DG loading and Control Room (MCR), Shutdown Continuous restore selected heating, ventilation and air 17 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Y Board Room, Vital Battery Board once initiated conditioning (HVAC) systems to service.

Room and SFP area ventilation needs. (Reference 14)

Evaluate, identify and address long term (within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) needs 18 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> including: Y Continuous

• Mobile water purification unit

• Site diesel and gasoline fuel service.

EA1-13

Attachment 1B NSSS Significant Reference Analysis Deviation Table WCAP value Plant applied Gap and Item Parameter of interest WCAP page (WCAP-17601-P January 2013 Revision 1) value discussion There are no deviations.

EA1-14

Attachment 2 Milestone Schedule The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent 6 month status reports.

Activity Status Revised Target Target (Will be Activity Completion Completion updated every Date Date 6 months)

Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Implementation Plan 2/28/2013 Complete 6 Month Status Updates Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started FLEX Strategy Evaluation June 2013 Complete Walk-throughs or Demonstrations Sep 2014 Not Started Perform Staffing Analysis June 2014 Not Started Modifications Modifications Evaluation Apr 2013 Complete Unit 1 N-1 Walkdown Apr 2013 Complete Unit 1 Design Engineering Oct 2013 Complete Unit 1 Implementation Outage Sep 2014 Not Started May 2014 Unit 2 Construction Walkdown Apr 2013 Complete Unit 2 Design Engineering Oct 2013 In Progress Feb 2014 Unit 2 Implementation (Startup) Sep 2014 In Progress Aug 2014 Storage Storage Design Engineering Complete Storage Implementation Sep 2014 In Progress Aug 2014 On-Site FLEX Equipment Purchase/Procure Dec 2013 In Progress Feb 2014 Off-Site FLEX Equipment Develop Strategies with RRC Dec 2013 In Progress Jun 2014 Identify Off-Site Delivery Stations (if necessary) Apr 2014 Complete Procedures PWROG issues Functional Support Guidelines (FSG) Jun 2013 Complete Create Watts Bar Functional Support Instructions (FSI) Jun 2014 In Progress Apr 2014 Create Maintenance Procedures Jun 2014 In Progress Apr 2014 EA2-1

Training Develop Training Plan Jan 2014 In Progress Apr 2014 Training Complete Sep 2014 Not Started Jul 2014 Unit 1 FLEX Implementation Sep 2014 In Progress Aug 2014 Unit 2 FLEX Implementation Sep 2014 In Progress Aug 2014 Full Site FLEX Implementation Sep 2014 In Progress Aug 2014 Submit Completion Report Oct 2014 Not Started Aug 2014 EA2-2

ENCLOSURE 2 WATTS BAR NUCLEAR PLANT LIST OF COMMITMENTS

1. TVA will provide justification regarding use of pre-staged diesel generators by February 28, 2014, to resolve Interim Staff Evaluation open item 3.2.4.8.A.