RS-15-211, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML15240A308
Person / Time
Site:	LaSalle
Issue date:	08/28/2015
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-15-211
Download: ML15240A308 (24)

Text

Exvtoi Generation.

Order No. EA-12-049 RS-15-211 August 28, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012

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

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049), dated October 25, 2012

5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (RS-13-021)

6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2013 (RS-13-121)

7. Exelon Generation Company, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049), dated February 28, 2014 (RS-14-01 1)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-1 2-049 August 28, 2015 Page 2

8. Exelon Generation Company, LLC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1 2-049), dated August 28, 2014 (RS-14-209)

9. Exelon Generation Company, LLC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 27, 2015 (RS-1 5-020) 10.NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2

- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF1 121 and MF1 122), dated February 21, 2014 11.NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2

- Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF1 119, M171 120, MF1 121, and MF1 122), dated March 23, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the LaSalle County Station, Units 1 and 2 overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. References 6, 7, 8, and 9 provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for LaSalle County Station. The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Open and Confirmatory Items contained in Reference 10, and any NRC Audit Report open items contained in Reference 11.

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

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

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

Enclosure:

1. LaSalle County Station, Units 1 and 2 Fifth Six-Month Status Report for the Implementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator Region Ill NRC Senior Resident Inspector LaSalle County Station, Units 1 and 2 NRC Project Manager, NRR LaSalle County Station, Units 1 and 2 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Jack A. Davis, NRR/DPR/MSD, NRC Mr. Eric E. Bowman, NRR/DPR/MSD, NRC Mr. Jeremy S. Bowen, NRR/DPR/MSD/MSPB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency Division of Nuclear Safety

Enclosure LaSalle County Station, Units 1 and 2 Fifth Six-Month Status Report for the Implementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (20 pages)

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Enclosure 1 Introduction LaSalle County Station, Units 1 and 2 developed an Overall Integrated Plan (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

NOTE: The "Status" indicated in this document is as of July 20, 2015. This date was chosen to support the development, review, approval and submittal of this report by the required August 28, 2015 due date.

2 Milestone Accomplishments The Fourth 6-Month Update was submitted in February 2015.

The Unit 2 FLEX modifications were completed and, with the approved exception (See Ref. 4) of the installation of the hardened containment vent system, U2 FLEX compliance was achieved upon startup from the U2 Refueling Outage in February of 2015.

3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Target Revised Target Activity Activity Status Completion Date Completion Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Contract with National SAFER Response Complete Center (NSRC)

Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Complete with Update 5 Aug 2015 this submittal Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started May 2018 Submit Completion Report Sep 2017 Not Started See Section 5 of Page 1 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Target Revised Target Activity Activity Status Completion Date Completion Date this enclosure Modification Development &

Implementation:

Unit 1 Modification Development (All Jan 2015 Started Jan 2016 FLEX Phases)

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

Unit 2 Modification Development (All Jan 2014 Completed Jan 2015 FLEX Phases)

Unit 2 Modification Implementation (All Feb 2015 Completed FLEX Phases)

Procedures:

Unit 2 Completed, Unit Create Site-Specific Procedures Feb 2015 Started 1 Procedures Mar2016 Unit 2 Validate Procedures (NEI 12-06, Sect. Completed, Unit Feb 2015 Started 11.4.3) 1 Validation Mar2016 Maintenance procedures are being completed to support the Create Maintenance Procedures Feb 2015 Started PM schedule.

All to be complete by Mar 2016.

Perform Staffing Analysis Oct 2014 Completed Storage Plan and Construction Feb 2015 Completed Unit 2 Completed, Unit I equipment FLEX Equipment Acquisition Feb 2015 Started Mar 2016 Page 2 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Target Revised Target Activity Activity Status Completion Date Completion Date Unit 2 Completed, Unit Training Completion Feb 2015 Started 1 Training Mar 2016 National SAFER Response Center Dec 2014 Completed Feb 2015 Operational Mar2018 Unit 1 FLEX Implementation Mar 2016 Started See Section 5 of this enclosure Feb 2017 Unit 2 FLEX Implementation Feb 2015 Started See Section 5 of this enclosure Mar2018 Full Site FLEX Implementation Mar 2016 Started See Section 5 of this enclosure 4 Changes to Compliance Method Exelon proposes an alternate approach to NEI 12-06 Revision 0 for protection of FLEX equipment as stated in Section 5.3.1 (seismic protection of FLEX equipment), Section 7.3.1 (severe storms with high winds protection of FLEX equipment), and Section 8.3.1 (impact of snow, ice and extreme cold protection of FLEX equipment). This alternate approach will be to store "N" sets of equipment in a fully robust building and the +1 set of equipment in a commercial building. Note that for LaSalle, some of the

+1 equipment will be stored in a fully robust building. For all hazards scoped in for the site, the FLEX equipment will be stored in a configuration such that no one external event can reasonably fail the site FLEX capability (N).

To ensure that no one external event will reasonably fail the site FLEX capability (N), Exelon will ensure that N equipment is protected in the robust building. To accomplish this, Exelon will develop procedures to address the unavailability allowance as stated in NEI 12-06 Revision 0 Section 11.5.3., (see Maintenance and Testing section below for further details). This section allows for a 90-day period of unavailability. If a piece of FLEX equipment stored in the robust building were to become or found to be unavailable, Exelon will impose a shorter allowed outage time of 45 days. For portable equipment that is expected to be unavailable for more than 45 days, actions will be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of this determination to restore the site FLEX capability (N) in the robust storage location and implement compensatory measures (e.g., move the +1 piece of equipment into the robust building) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> where the total unavailability time is not to exceed 45 days. Once the site FLEX capability (N) is restored in the robust storage location, Exelon will enter the 90-day allowed out of service time for the unavailable piece of equipment with an entry date and time from the discovery date and time.

MAINTENANCE AND TESTING Page 3 of 20

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

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

a. The unavailability of plant equipment is controlled by existing plant processes such as the Technical Specifications. When plant equipment which supports FLEX strategies becomes unavailable, then the FLEX strategy affected by this unavailability does not need to be maintained during the unavailability.

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

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

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

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

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

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

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

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

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

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

o All equipment (N+1) in a structure(s) that meets the plant's design basis for high wind hazards, or 1

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

Page 4 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 o (N) equipment in a structure(s) that meets the plant's design basis for high wind hazards and (+1) equipment stored in a location not protected for a high wind hazard.

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

• Storage of FLEX equipment should account for the fact that the equipment will need to function in a timely manner. The equipment should be maintained at a temperature within a range to ensure its likely function when called upon. For example, by storage in a heated enclosure or by direct heating (e.g., jacket water, battery, engine block heater, etc.).

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

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

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

Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan and the Interim Staff Evaluation (ISE) (Ref. 5), and the status of each item. NOTE: The "Status" 20th, indicated below is as of July 2015. This date was chosen to support the development, review, approval and submittal of this report by the required August 28th, 2015 due date.

Section Reference Overall Integrated Plan Open Item Status Sequence of Events (p.5) The times to complete actions in the STARTED Events Timeline are based on operating Unit 2 Complete.

judgment, conceptual designs, and current supporting analyses. The final Unit 1 to complete by timeline will be time validated once March 2016.

detailed designs are completed and procedures developed.

Sequence of Events (p.10) Initial evaluations were used to COMPLETED determine the fuel pool timelines.

Exelon determined that Formal calculations will be performed to the initial evaluations that validate this information during were performed are development of the spent fuel pool sufficient.

cooling strategy detailed design.

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

NEDC-33771P, "GEH Evaluation of Page 5 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Section Reference Overall Integrated Plan Open Item Status FLEX Implementation Guidelines and documentation of results on Att. 113, "NSSS Significant Reference Analysis Deviation Table." Planned to be completed and submitted with August 2013 Six Month Update.

Strategy Deployment (p.11) Transportation routes will be developed COMPLETED from the equipment storage area to the LOA-FSG-01 2, "FLEX FLEX staging areas. An administrative Deployment Path Debris program will be developed to ensure Removal," identifies the pathways remain clear or compensator' deployment routes for the actions will be implemented to ensure all FLEX equipment from strategies can be deployed during all the FLEX storage areas.

modes of operation.

Procedure LOS-FSG-Identification of storage areas and SRI, "FLEX Equipment creation of the administrative program Surveillance," contains a are open items.

monthly verification that the FLEX equipment deployment paths are unobstructed.

The LaSalle Station Snow Removal Plan has been updated to ensure these paths are cleared in a timely manner.

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

Procedure CC-LA- 1. 18-maintenance requirements will be 1001, "Site implemented.

Implementation of Diverse and Flexible Coping Strategies (FLEX) and Spent Fuel Pool Instrumentation Program," has been issued.

Core Cooling Phase 1 (p. 17) Additional work will be performed COMPLETED during detailed design development to Evaluation documented in ensure Suppression Pool temperature EC 399297, Rev. 0.

will support RCIC operation, in accordance with approved BWROG Page 6 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Section Reference Overall Integrated Plan Open Item Status analysis, throughout the event.

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

Evaluation documented in calculation L-003968, Rev. 0.

Safety Functions Support Phase 1 Evaluate the habitability conditions for COMPLETED (p.44) the Main Control Room and develop a Evaluation documented in strategy to maintain habitability, calculation L-003969 Rev. 0. Strategy defined in LOA-FSG-005, "Area Ventilation."

Safety Functions Support Phase 1 Evaluate the habitability conditions for COMPLETED (p.44) the Auxiliary Electric Equipment Room Evaluation documented in (AEER) and develop a strategy to calculation L-003969 maintain habitability.

Rev. 0. Strategy defined in LOA-FSG-005, "Area Ventilation."

Safety Functions Support Phase 2 Develop a procedure to prop open COMPLETED (p.48) battery room doors upon energizing the LOA-FSG-005, "Area battery chargers to prevent a buildup of Ventilation," addresses hydrogen in the battery rooms.

propping open the applicable battery room doors.

Page 7 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items Open Items Item Number Description Status 3.2.3.A Verify the modifications associated with Order EA 13- COMPLETED 109 on a Hardened Containment Vent System support Item Closed During the sequence of events and actions associated with the Onsite NRC Audit (Ref.

LSCS mitigating strategies.

11)

From 8/28/14 update, ML14248A239:

The modifications associated with Order EA 13-109 are scheduled to complete installation at LSCS in 2017 (Unit 2) and 2018 (Unit 1). The modifications will be designed to support the LSCS mitigating strategies.

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

Item Closed During Onsite NRC Audit (Ref.

11).

While on site the NRC staff reviewed LaSalle Station Design Analysis L-004000, "Evaluation of Liquefaction Potential for BDBEE [beyond-design-basis external event]

FLEX Staging Area and Equipment Deployment Paths." The review focused on whether the licensee's planned deployment and storage location are susceptible to seismically-induced soil Page 8 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items liquefaction to a degree that will adversely affect the implementation of FLEX strategies following a seismic event.

The calculation concludes that all haul path areas are not susceptible to liquefaction with the exception of one localized area near the deployment path associated with the 60X90 FLEX building inside the PA. The calculation stated that the vertical settlement resulting from liquefaction would be approximately 2 inches.

The licensee stated that the mobile FLEX equipment vehicles have more than sufficient capacity to traverse 2-inch localized roadway depressions, should they appear following a seismic event. The staff had no further questions regarding liquefaction potential of the FLEX deployment paths.

3.1.1.2.11 Confirm that the egress path for personnel to reach the COMPLETED FLEX storage building is seismically robust or Item Closed During multiple egress paths that are not seismically robust are Onsite NRC Audit (Ref.

identified.

11).

While on site the NRC staff reviewed and walked down egress and ingress paths for personnel to reach the FLEX storage buildings. The review focused on whether Page 9 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items ingress/egress paths are seismically robust and, if not, are multiple paths available. The licensee stated that paths for personnel responding to FLEX equipment storage buildings are partially seismically robust (portions inside seismic structures) and there are multiple paths available for personnel to leave the power block. The staff had no further questions regarding ingress or egress paths for FLEX implementation.

3.1.1.4.A Confirm that the logistics for equipment transportation, COMPLETED area set up, and other needs for ensuring the equipment Item Closed During and commodities to sustain the site's coping strategies Onsite NRC Audit (Ref.

are available from offsite resources.

11)

AREVA Document No.

51-9233422, "LaSalle County Nuclear Generating Station SAFER Response Plan,"

Rev. 0, 12/19/14, shows that Staging Area C is the Pontiac Municipal Airport, Pontiac, IL, and the alternate to that (Staging Area D) is the Illinois Valley Regional Airport, Peru, IL. Staging Area B is the plant contractor parking lot.

Exelon Procedure EP-AA-112-400-F-04, "EOF Logistics Manager Checklist," Rev. K, Section 3.7, includes coordination for the Page 10 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items SAFER Response Plan, including notifying the facility managers for Staging Areas C and D, obtaining road conditions, becoming the single point of contact for SAFER, and preparing for the arrival of SAFER personnel. Croman Corp has filed a helo flight plan for the route from Pontiac airport to LaSalle. The State of Illinois Plan for Radiological Accidents (IPRA) shows that the State will cooperate with Exelon to provide law enforcement escorts for SAFER vehicles and provide helicopters (if available).

3.1.3.1 .A If the licensee credits separation of storage sites to COMPLETED address tornado threats, confirm that the axis of Per Ref. 11, this separation and distance between storage locations will ISE/Audit Item remains provide assurance that a single tornado would not open as it relates to use of impact all locations if the licensee relies on NET 12-06, a commercial (non-Section 7.3.1, configurations Lb or Lc for protection robust) FLEX building of the portable equipment from the high winds hazard.

for storage of the N+1 equipment.

Exelon/LaSalle is proposing the use of an alternate approach in Section 4 of this document. Therefore, response to this item is complete.

3.2.1.1 .A Confirm that benchmarks are identified and discussed COMPLETED that demonstrate that the Modular Accident Analysis Item Closed During Program (MAAP) is an appropriate code for the Onsite NRC Audit (Ref.

simulation of an ELAP event at LSCS.

11).

See LS-MISC-025 Rev. 1 Page 11 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items submitted with ML14248A239.

3.2.1.1.13 Confirm that the collapsed level remains above Top of COMPLETED Active Fuel (TAP) and the cool down rate remains Item Closed During within technical specification limits for MAAP Onsite NRC Audit (Ref.

analyses.

11).

See LS-MISC-025 Rev. 1 submitted with ML14248A239.

3.2.1.1.0 Confirm that MAAP is used in accordance with COMPLETED Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June 2013 Item Closed During position paper (ADAMS Accession No.

Onsite NRC Audit (Ref.

ML13190A201).

11).

See LS-MISC-025 Rev. 1 submitted with ML14248A239.

3.2.1.1.D Confirm that the licensee identifies and justifies the COMPLETED subset of key modeling parameters cited from Tables Item Closed During 4-1 through 4-6 of the "MAAP Application Guidance, Onsite NRC Audit (Ref.

Desktop Reference for Using MAAP Software, 11).

Revision 2" (Electric Power Research Institute Report 1020236). This should include response at a plant- See LS-MISC-025 Rev. 1 specific level regarding specific modeling options and submitted with ML parameter choices for key models that would be 14248A239.

expected to substantially affect the ELAP analysis performed for that licensee's plant.

3.2.1.1.E Confirm that the specific MAAP analysis case that was COMPLETED used to validate the timing of mitigating strategies in Item Closed During the Integrated Plan is identified and is appropriate for Onsite NRC Audit (Ref.

LSCS. Alternately, a comparable level of information 11).

may be included in the supplemental response.

See LS-MISC-025 Rev. 1 submitted with ML14248A239.

3.2.1.2.A Confirm adequacy of the technical basis for the COMPLETED assumptions made regarding the leakage rate through Item Closed During the recirculation pump seals and other sources. The Onsite NRC Audit (Ref.

analysis should include the assumed pressure-11).

dependence of the leakage rate, and whether the Page 12 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items leakage was determined or assumed to be single-phase See LS-MISC-025 Rev. 1 liquid, two-phase mixture, or steam at the donor cell, submitted with ML and how mixing the leakage flow with the drywell 14248A239.

atmosphere is modeled.

3.2.1.3.A Confirm that taking readings from a standpipe which is COMPLETED not safety related or seismic does not make the CST Item Closed During level instrumentation inadequate for the automatic Onsite NRC Audit (Ref.

swap or informing the operators of CST loss so that 11) they may respond with manual action using the control switches located in the main control room. With a potential loss of the CST Standpipe, which is located inside of the Turbine Building, the water would no longer be present to indicate high level; therefore, because the level instruments are seismically qualified, they will remain adequate to support the automatic suction source swap.

3.2.1.4.A Confirm that pump sizing results consider required COMPLETED water flow rates the portable/FLEX pump complete Item Closed During head/flow characteristics, suction and discharge losses, Onsite NRC Audit (Ref.

system backpressure, elevation differences and piping 11) losses to allow verification that this will be a successful strategy. While on site the NRC staff reviewed calculation L-003961 "FLEX Pump Sizing Hydraulic Calculation," FSG-TP-00 14 1, Test Procedure IP4000DIM-TCL Pump Performance, and walked down pump deployment locations and hose deployment routes. The licensee's calculation and pump performance test show that the licensee's planned FLEX pumps should have the capability to provide water to each Page 13 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items designated location with the proper flow and pressure. The Staff had no further questions regarding the FLEX hydraulic analysis.

3.2.1.4.B Confirm the generator sizing results consider COMPLETED appropriate electrical loads and adequate capacity of Item Closed During portable/FLEX electrical generators planned for use Onsite NRC Audit (Ref.

during Phase 2 and Phase 3.

11).

While on site the NRC staff reviewed Design Consideration Summary (DCS) EC 396069 Rev.

001: FLEX Primary Strategy Electrical (sections 4.1.35 Electrical Requirements)

Reviewed TODI: SEAG 14-000042 (FLEX Electrical Loads FLEX Primary Strategy LaSalle NPS U2)

Reviewed procedure LOA-FSG-002, Rev. 0:

Flex Electrical Strategy Phase rotation checks are complete and cables are color coded.

Licensee plans to cope with Phase 2 FLEX equipment. The licensee will utilize the Phase 3 480 VAC FLEX DG if necessary. LaSalle does not plan to use the Phase 3 4I60VAC FLEX DG.

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

Onsite NRC Audit (Ref.

Page 14 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items 11).

While onsite the NRC staff reviewed the licensee's plan for deploying FLEX hoses to the SIP and walked down the SFP area. The licensee plans to deploy hoses for SFP cooling before the onset of bulk boiling. Ventilation procedure LOA-FSG-005 provides the requirements for implementation of the vent path strategy.

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

Item Closed During Onsite NRC Audit (Ref.

11).

The LaSalle RCIC system was evaluated in EC 399297 Rev. 000 for the conditions during an ELAP. As shown in the study, the RCIC system can remain functional for a minimum of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> following a BDBEE.

This accounts for the peak suppression pool maximum temperature of 234°F.

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

Item Closed During Onsite NRC Audit (Ref.

11).

NRC performed walkdown of vital battery rooms (125 and 250),

Div.1 and Div. 2 Page 15 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items switchgear rooms.

NRC reviewed procedure:

LOA-FSG-005, Rev. 0:

Area Ventilation.

Licensee will open doors and use forced ventilation.

NRC reviewed calculation: VX-09, Rev.

12C: Battery Rooms Hydrogen Concentration, Hydrogen concentration less than 2% during ELAP.

3.2.4.4.A Confirm that the upgrades to the plant communication COMPLETED systems discussed in the licensee communications Item Closed During assessment (ADAMS Accession Nos. ML12306A199 Onsite NRC Audit (Ref.

and ML13056A135) in response to the March 12, 2012 11) 50.54(1) request for information letter for Limerick (sic) and, as documented in the staff analysis (ADAMS LOAFSG010, "FLEX Accession No. ML13114A067) have been completed. Communications,"

addresses the use of sound-powered phones and handheld radios in the talk-around mode. A total of 48 radios will be available (10 with on-shift personnel, 38 stored in the 60X90 protected FLEX building) for event response. Spare batteries will be available (normal on-shift charging/storage plus additional batteries/charging in the 60X90 FLEX building).

Portable EDGs are available (stored in 60X90 and 30X40 protected FLEX buildings) to power the battery chargers. Spare fuel is provided for the Page 16 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items portable EDGs as a part of the FLEX equipment fueling plan (LOA-FSG-009).

Sound-powered phone kits (headsets/extension cords) will be stored in the Aux Bldg/Control Room Area as well as other designated/protected storage areas in the plant.

Suggested patching sequences will be captured in the applicable FSGs to enable communication between key operating areas.

3.2.4,6.A Confirm that the proceduralized "toolbox" approach COMPLETED can ensure vital area habitability and confirm the Item Closed During proper staging and protection of any equipment to Onsite NRC Audit (Ref.

implement this approach. 11).

See LOA-FSG-005, Area Ventilation and Calculation L-003968 Rev. 0 "Temperature &

Humidity Transient In The Reactor Building 843'-6" Operating Floor Following A BDBEE For Flex."

3.2.4.7.A Confirm that the design of the FLEX pump suctions COMPLETED will prevent introducing excessive amounts of Item Closed During entrained debris as a result of extreme external hazards Onsite NRC Audit (Ref.

(e.g., suspended solids especially from high wind 11) debris) in the cooling water from the Lake Screen House/Lake. The FLEX pump has 2 submersible pumps to supply the main pump suction, powered from the FLEX pump diesel; either can provide full flow Page 17 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory items capability. Both have 1/4 inch perforated screen with 11.2 ft2 free surface area. The main pump will be discharging through RHR LPCI directly inside the core shroud.

Pumps will be available at 6 hrs, but do not plan to inject until RCIC fails.

The water is from a man made lake and suction is downstream of the chad screens. Additionally, the submersible pumps float at least 34 inches below the surface of the water and at least 10 inches above the bottom of the lake.

3.2.4.10.A Confirm that the high/low temperature analysis (i.e., COMPLETED temperatures above/below those currently assumed in Item Closed During the sizing calculations) shows no adverse effects on Onsite NRC Audit (Ref.

expected battery life.

11).

The NRC performed walkdown of vital battery rooms (125 and 250),

Div. 1 and Div. 2 switchgear room NRC reviewed procedure:

LOA-FSG-005, Rev. 0:

Area Ventilation NRC reviewed calculation: L-003969, Rev. 0: U1/U2 Transient Heat-Up Analysis for the Control Room, AEERs, Div. land Div. 2 Switchgear Rooms following a BDBEE (opening doors in Page 18 of 20

LaSalle County Station, Units 1 and 2 Fifth Six Month Status Report for the Implementation of FLEX August 28, 2015 Interim Staff Evaluation Open and Confirmatory Items switchgear rooms and forced ventilation (fans),

exhaust path through roof of the DG building).

3.4.A Confirm conformance to considerations 2 through 10 COMPLETED of NEI 12-06, Section 12.2 for the use of offsite And Item Closed During resources or th at an acceptable alternate is developed.

Onsite NRC Audit (Ref.

3.1.1.4.A II).

NRC's endorsement of the NEI white paper on this topic is ML14265A107.

The SAFER Response Plan for LaSalle has been issued by SAFER and is documented in procedure CC-LA-I 18-1002.

7 Potential Draft Safety Evaluation Impacts The changes related to the FLEX strategies described in this update have the potential to impact the DRAFT Safety Evaluation.

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

1. LaSalle County Station's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (ADAMS Accession No. ML13060A421).

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

3. Exelon/LaSalle Request for Relaxation from NRC Order EA-12-049, dated February 27, 2014 (ADAMS Accession No. M L14059A076).

4. NRC Approval of Exelon/LaSalle Request for Relaxation from NRC Order EA-12-049, dated April 15, 2014 (ADAMS Accession No. ML14071A455).

5. LaSalle County Station, Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies), dated February 21, 2014 (ADAMS Accession No. ML14030A220).

6. NRC Order Number EA-13-109, "Order Modifying Licenses With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013, Page 19 of 20

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

7. LaSalle County Station, Units 1 and 2, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2013 (ADAMS Accession No. ML13241A283).

8. LaSalle County Station, Units 1 and 2 Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2014 (ADAMS Accession No. ML14059A431).

9. LaSalle County Station, Units 1 and 2, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2014 (ADAMS Accession No. ML14248A239).

10. LaSalle County Station, Units 1 and 2, Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2015 (ADAMS Accession No. ML15061A424).

11. LaSalle County Station, Units 1 and 2 Report for the Onsite Audit Regarding Implementation of Mitigation Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC NOS. MF1119, MF1120, MF1121, and MF1122), dated March 23, 2015 (ADAMS Accession No. ML15061A054).

9 Attachments

1. None Page 20 of 20