RS-14-214, TMI, Unit 1 - 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)

TMI, Unit 1 - 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)

ML14241A251
Person / Time
Site:	Crane
Issue date:	08/28/2014
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-14-214, TMI-14-094
Download: ML14241A251 (34)

Text

RS-14-214 TMl-14-094 August 28, 2014 n

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 I

' [10 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Order No. EA-12-049

Subject:

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

References:

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

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

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

Revision 0, dated August 2012

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

5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 ( RS-13-026)

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-13-131)

7. Exelon Generation Company, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 28, 2014 (RS-14-016)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2014 Page2

8.

NRC letter to Exelon Generation Company, LLC, Three Mile Island Nuclear Station, Unit 1 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0803), dated December 17, 2013 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 O (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 Three Mile Island Nuclear Station, Unit 1 overall integrated plan.

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

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 281h day of August 2014.

Respectfully submitted, c)*(AM~ ~-

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Three Mile Island Nuclear Station, Unit 1 Third Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 August 28, 2014 Page 3 cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRG Mr. Jack R. Davis, NRR/DPR/MSD, NRG Mr. Eric E. Bowman, NRR/DPR/MSD, NRG Mr. Jeremy S. Bowen, NRR/DPR/MSD/MSPB, NRG Mr. Robert L. Dennig, NRR/DSS/SCVB, NRG Mr. John D. Hughey, NRR/DPR/MSD/MSPB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure Three Mile Island Nuclear Station, Unit 1 Third Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (30 pages)

Three Mile Island Station, Unit 1 Third Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Three Mile Island Nuclear Station, Unit 1 (TMI) developed an Overall Integrated Plan (Reference 1 in Section 7), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the last status report (February 2014), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since February 1, 2014 and are current as of August 28, 2014.

The following modification development is complete.

Reactor Coolant Pump Seal Replacement FLEX Feedwater System FLEX RCS and Spent Fuel Pool Makeup System Modifications of the Main Generator Purge System piping and Condensate System pipe supports were removed from the plan, and the Reactor Building Vent modification development has been initiated.

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.

The revised milestone target completion dates do not impact the Order implementation date.

Original Target Completion Date Activity Submit 60 Day Status Report Submit Overall Integrated Implementation Plan Complete Complete Contract with National SAFER Response Complete Center 6 Month Updates Page 1 of 30 Status

Three Mile Island Nuclear Station, Unit 1 Third Six Month Status Report for the Implementation of FLEX, August 28, 2014 Original Target Completion Date Update 1 Update 2 Update 3 Update 4 Update 5 Update 6 Oct 2014 Oct 2014 Oct 2014 Nov 2015 Activity Aug., 2013 Feb., 2014 Aug., 2014 Feb., 2015 Aug., 2015 Feb., 2016 Modification Development Phase 1 modifications (1) RCP Sea! Upgrade Phase 2 modifications

( 1) FLEX Electrical Power Supply (2) FLEX RCS & SFP Makeup (3) FLEX Feedwater System (4) FLEX Storage Facility (5} Turbine Bldg Structural (6) FLEX fuel oil supply (7) Spent Fuel Pool Level (8) Communications modification (9) Reactor Building Vent

( 10) Satellite phone storage Phase 3 modifications Modification Implementation Phase 1 modifications (1) RCP Seal Upgrade Page 2 of 30 Status Complete Complete Complete with this submittal Not Started Not Started Not Started (1) Complete (1) Started (2) Complete (3) Complete (4) Started (5) Started (6) Started (7) Started (8) Not Started (9) Started (10) Complete None Not Started

Three Mile Island Nuclear Station, Unit 1 Third Six Month Status Report for the Implementation of FLEX, August 28, 2014 Original Target Activity Status Completion Date Nov 2015 Phase 2 modifications

( 1 ) FLEX Electrical Power Supply Not Started (2) FLEX RCS & SFP Makeup (3) FLEX Feedwater System (4) FLEX Storage Facility (5) Turbine Bldg Structural (6) FLEX fuel oil supply (7) Spent Fuel Pool Level (8) Communications modification (9) Main Generator Purge (10) Reactor Building Vent

( 11 ) Satellite phone storage Complete Nov 2015 Phase 3 modifications None Original Target Activity Status Completion Date Procedure development Jun 2015

• Create Site-Specific Procedures Started Jul2015

• Validate Procedures (NEI 12-06, Started Sect. 11.4.3)

Jun 2015

• Create Maintenance Procedures Started Jul2015 Staffing analysis Started Nov 2015 Storage Plan Started Nov 2015 FLEX equipment acquisition Started Nov 2015 Training Started Jun 2015 National SAFER Response Center Started Operational Nov 2015 Unit 1 Implementation date Page 3 of 30

Three Mile Island Nuclear Station, Unit 1 Third Six Month Status Report for the Implementation of FLEX, August 28, 2014 4 Changes to Compliance Method The following changes are the most significant changes made to the FLEX conceptual design:

(1) FLEX Diesel Generator and Fuel Oil Supply (Reference Attachment 2A) o A common fuel oil "day" tank (FX-T-3) will be located with the FLEX Diesel Generators FX-Y-1 A & B in place of individual skid mounted fuel oil tanks.

(2) FLEX Electrical Distribution (Reference Attachment 28) o The BWST immersion heater will be used in extreme cold events in lieu of BWST tank heat trace.

(3) FLEX Feedwater System (Reference Attachment 2C & 2E) o A recirculation path will be installed for FX-P-2A & B to minimize risk of pump damage during emergency response.

o The size of the portable diesel driven pump required is similar to our currently available Godwin HL 11 OM pump. The Godwin HL 130M pump described previously will be replaced with a second Godwin HL 11 OM pump.

o An alternative strategy for long term condensate supply (taking suction from river within the ISPH) was developed to deal with ice or failure of York Haven Dam.

(4) FLEX RCS and SFP Makeup System (Reference Attachment 2D) o Long term borated water supply (from National SAFER Response Center equipment) was added.

The following are the most significant changes made to the FLEX Sequence of Events and Timelines (Reference Attachment 1A (Earthquake or Tornado Event Timeline), Attachment i B (External Flood Event Timeline) and Attachment i C (Extreme Cold, Snow & Ice event time line).

o When the RCS cooldown and depressurization to the long term conditions (RCS at 400F & 400 psig) is completed, then operators will raise pressurizer level from

- 100 inches to above 300 inches to provide further margin to tolerate a temporary loss of the FLEX RCS makeup capability.

o The modified fuel supply arrangement for the FLEX diesel generators requires the operators to install an additional hose (a contingency for overflow of FX-T-3) prior to initiating transfer of fuel from DF-T-1 to FX-T-3.

Page 4 of 30

Three Mile Island Nuclear Station, Unit 1 Third Six Month Status Report for the Implementation of FLEX, August 28, 2014 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation TMI expects to comply with the Order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation Section Reference Overall Integrated Plan Open Item Status (Refer to OIP Update (Refer to OIP Update from Feb 2014)

(As of August 1, 2014) from Aug 2013)

None Page 5 of 30

Interim Staff Evaluation Open Item or Confirmatory Items Item NRC ref Description Status no.

AUG 2014 UPDATE 6

3.1.1.2.A The licensee did not specifically address deployment (1) The potential for earthquake induced liquefaction has been considerations with respect to the deployment of FLEX evaluated. Deployment of TM 11 FLEX equipment will not be equipment through areas subject to liquefaction, routing adversely impacted. (Reference 990-2179 "Assessment of earthquake-induced liquefaction potential and associated ground only through seismically robust buildings, power required failure hazards for Three Mile Island Unit 1 , Geomatrix to deploy or move equipment, and protection of the Consultants.)

means to move equipment.

(2) The evaluation of access paths through non-seismic structures is in progress. (FEB 2015 Update)

(3) A vehicle stored in the FLEX storage facility will be used to deploy or move FLEX equipment. No additional power is required.

7 3.1.1.3.A The licensee did not address the determination of FEB 2015 Update necessary instrument local readings per consideration 1 of N El 12-06 Section 5.3.2, to support the implementation of the mitigating strategies in the event that seismically qualified electrical equipment is affected by a BDBEE.

8 3.1.1.4.A The licensee did not identify the local assembly area or FEB 2015 Update describe the methods to be used to deliver the equipment to the site for all hazards. In the audit process the licensee stated that the TMI National SAFER Response Center playbook will be made available when approved to address this.

11 3.1.5.3.A The licensee provided no information regarding the heat A plan to provide portable ventilation for areas where natural up of various rooms and enclosures in the Integrated circulation may be insufficient and key FLEX equipment performance Plan, and there was no discussion of the potential effects may be adversely affected by abnormally high ambient temperature of high temperatures at the location where portable (or is being prepared.

permanently installed FLEX) equipment would actually FEB 2015 UPDATE operate in the event of high temperatures in these plant locations.

Page 6 of 30

Item NRC ref no.

22 3.2.1.6.A 31 3.2.4.1.A Three Mile Island Nuclear Station, Unit 1 Third Six Month Status Report for the Implementation of FLEX, August 28, 2014 Description During the ELAP and LUHS [Loss of Ultimate Heat Sink]

beyond-design-basis external event, the licensee has identified that times to complete actions in the Events Timeline are based on operating judgment, the conceptual designs, and the current supporting analyses.

The TMI mitigation strategy is not based upon the PWROG WCAP-17601-P ELAP mitigation strategy. In the audit process, the licensee stated that the current SOE is for the seismic event only and that another SOE would be developed for the flood event. Based on the information provided by the licensee, it is not possible to determine the validity of the time constraints provided in the preliminary sequence of events timeline for all hazards. The final timelines will be validated once detailed designs are completed and procedures are developed. The results will be provided in a future 6-month update.

The licensee did not specify if the FLEX diesel generators on the Turbine Building were of sufficient capacity to supply any additional cooling need such as the system that provides for the steam driven emergency feedwater (EFW) pump bearing cooling, or any other plant components or cooling systems needed to support the FLEX strategies. Additional formal analysis is required to determine the acceptability of the licensee's plans to provide supplemental cooling to the subject areas, e.g.,

Main Control Room (MCR), EFW room, Atmospheric Dump Valve (ADV) room, battery rooms.

Status AUG 2014 UPDATE A SOE timeline for flooding is provided as Attachment 1 B The capability to perform the actions within the period identified in analysis will be validated when the procedures are written, through table top, simulator and field simulation exercises.

Update FEB 2015 A plan to provide portable ventilation for areas where natural circulation may be insufficient and key FLEX equipment performance may be adversely affected by abnormally high ambient temperature is being prepared. Power for portable ventilation will be included to establish the FLEX diesel generator capacity.

FEB 2015 UPDATE.

Page 7 of 30

Item 32 33 34 NRC ref no.

3.2.4.2.A 3.2.4.2.B 3.2.4.2.C Three Mile Island Nuclear Station, Unit 1 Third Six Month Status Report for the Implementation of FLEX, Auaust 28, 2014 Description Habitability conditions in the MCR will be evaluated and a strategy will be developed to maintain MCR habitability.

The strategy and associated support analyses will be provided in a future 6-month update.

The analysis of battery room conditions was not complete, and the licensee noted that additional formal analysis to determine the acceptability of their actions regarding the battery room's accessibility is needed. Also additional discussion on the hydrogen gas exhaust path for each strategy is needed, and a discussion of the accumulation of hydrogen to ensure that the hydrogen gas level is below combustible level when the batteries are being recharged during Phase 2 and 3.

The licensee did not provide any information regarding temporary cooling/ventilation for areas such as the steam driven emergency feedwater pump room, ADV rooms or cable spreading rooms. The licensee's current strategies are based on preliminary analysis. The current strategy for providing cooling or ventilation for these areas is to connect a permanently staged 480V AC diesel generator and fuel tanks to be located in the Turbine Building elevation 322. The strategy is to repower 1 A and 1 B ES MCCs in four hours and hence supply power for cooling these areas. The licensee did not provide any details regarding what ventilation systems would be repowered for these areas of the plant, or the capacity of the FLEX emergency diesel generators to meet these needs, or how this would be accomplished.

Status AUG 2014 UPDATE Portable ventilation will be utilized to improve CR habitability and provide cooling for key FLEX equipment. The complete plan will be provided in the FEB 2015 UPDATE.

Portable ventilation will be utilized to prevent an excessive hydrogen concentration in the battery rooms. The complete plan will be provided in the FEB 2015 UPDATE.

Portable ventilation will be utilized to provide cooling for key FLEX equipment. The complete plan will be documented in Technical Evaluation ECR 13-00310 which will be available for review in the FEB 2015 UPDATE.

Page 8 of 30

Three Mile Island Nuclear Station, Unit 1 Third Six Month Status Report f

h I

f F EX A 28 2014 or t e I mp ementat1on o L

' uqust Item NRC ref Description Status no.

AUG 2014 UPDATE 38 3.2.4.4.8 The NRC staff reviewed the licensee communications FEB 2015 UPDATE assessment and has determined that the assessment for communications is reasonable, and the analyzed existing systems, proposed enhancements, and interim measures will help to ensure that communications are maintained.

Therefore, there is reasonable assurance that the guidance and strategies developed by Exelon will conform to the guidance of NEI 12-06 Section 3.2.2 (8) regarding communications capabilities during an ELAP.

Confirmation that upgrades to the site's communications systems have been completed will be accomplished.

39 3.2.4.5.A The licensee provided no information in the Integrated FEB 2015 UPDATE Plan regarding local access to the protected areas under ELAP.

40 3.2.4.6.A The licensee's analysis regarding access to the MCR, FEB 2015 UPDATE and battery rooms, is preliminary and additional formal analysis is required. In the audit process the licensee specified that temporary ventilation (fans and flexible ducts) will be used to maintain control room habitability, to control the ambient temperature in control building areas with credited FLEX electrical equipment and to limit the accumulation of hydrogen during battery charging.

This approach uses a "once through" air flow path. The licensee stated that the technical basis to demonstrate that this temporary capability is sufficient and that supporting documentation, ECR [engineering change Request] 13-00310, will be made available to NRC when it is completed.

Page 9 of 30

Three Mile Island Nuclear Station, Unit 1 Third Six Month Status Report f

h I I

f F EX A or t e mp ementat1on o L

uqust28,2014 Item NRC ref Description Status no.

AUG 2014 UPDATE 45 3.3.3.A The specific procedures for training, new or revised, have FEB 2015 UPDATE not yet been completed. The requirements from the analysis will be used to develop and to validate the new and revised procedures. This includes the existing design and licensing basis requirements and the new FLEX requirements. Validation of time response is performed using a composite of field simulation and performance/simulator exercises.

46 3.4.A The licensee's plans for the use of off-site resources FEB 2015 UPDATE conform to the minimum capabilities specified in NEI 12-06 Section 12.2, with regard to the capability to obtain equipment and commodities to sustain and backup the site's coping strategies, item 1. The licensee did not address the remaining items, 2 through 1 O of Section 12.2.

Page 10 of 30

7 Potential Draft Safety Evaluation Impacts No potential impact to the Draft Safety Evaluation was identified.

8 References The following references support the updates to the Overall Integrated Plan described in this 6-month update.

1. Three Mile Island Nuclear Station, Unit 1, 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 049), dated February 28, 2013.

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

4. TM-FLEX-002, Reactor Building Pressure Analysis for FLEX, Rev. 0

5. TMI Station's First Six Month Status Report for the Implementation of FLEX, dated August 28, 2013.

6. C-i 101-734-E420-009 "Extending Battery Life to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> during an ELAP"

7. TMI Station's Second Six Month Status Report for the Implementation of FLEX, dated February 28, 2014 Page 11of30

9 Attachments 1 A Sequence of Events Timeline Earthquake or Tornado @ 100% power 1 B Sequence of Events Timeline External Flood @ 100% power 1 C Sequence of Events Timeline Extreme Cold, Snow and Ice @ 100% power 2A 1 E-919-21-001, draft, FLEX Diesel Generator and Fuel Oil System 28 1 E-919-21-002, draft, FLEX Electrical Distribution 2C 1 E-919-21-003, draft, FLEX Feedwater System 20 1 E-919-21-004, draft, FLEX RCS & SFP Makeup System 2E i E-919-21-005, draft, Long Term Water Supply Page 12 of 30

ELAP Time (HR) 1 0

2 0

3

<.01 4

<.02 5

< 0.05 6

< 0.08 7

< 0.08 I

8

< 0.10 9

< 0.17 10 0.25 11 0.25 12 0.25 13 0.5 A - Sequence of Events Timeline Earthquake or Tornado@ 100°/o power Action Time Remarks/

Constraint Applicability Y/N Earthquake or tornado Causes LOOP and NA damages unprotected equipment.

All control rods are inserted and the reactor is shutdown.

Emergency Diesel Generators fail to energize ES NA Failures per NEI 12-06 buses.

EFW actuated: Steam driven pump (EF-P-1) and N

Automatic plant response.

EFW Control valves (EF-V-30A & B) supply feedwater. MSSV & ADV control OTSG pressure.

EOP initiated.

NA RCS Letdown is automatically isolated on high N

Automatic plant response.

temperature (MU-V-3 closes).

Control Room operators throttle ADV to stabilize N

OTSG pressure and RCS temperature. Adequate core cooling is provided through RCS natural circulation and heat removal through the OTSG.

Control Room operators attempt to start and load N

SBO Diesel Generator.

I Control Room operator closes RCP Controlled N

Contains RCS losses within Bleed Off Isolation Valve (MU-V-26).

the Reactor Bldg.

SBO Diesel generator is not functional.

N Failure per NEI 12-06.

Operator initiates E-plan. If needed, satellite N

phones are used for offsite notifications &

communication.

Operators open main condenser vacuum breaker N

This is a pre-condition to (VA-V-8) and valves to vent Main Generator H2 to reduce DC loads.

atmosphere.

Control Room operator secures DC powered FW N

DC Load shedding pump turbine lube oil pumps (LO-P-9A & B).

Operator opens doors to inverter and battery N

Maintain acceptable rooms.

temperature for FLEX equipment.

Page 13 of 30

~*

ELAP Time (HR) 14 0.5 15

< 0.75 I 16

< 0.75 17

< 1.0 I

18 1.0 19 1.5 20

< 2.0 21 2.0 22 2.0 23 2.0 24 2.25 A - Sequence of Events Timeline Earthquake or Tornado@ 100°/o power

. - -----"-*~-- - ------*-* -------

Action Time Remarks I Constraint Applicability Y/N Operator de-energizes instrument systems not N

DC Load shedding.

required for FLEX.

Operator lines up C02 purge for main generator.

N Minimize risk of main generator fire.

If condensate is lost due to damaged hotwell or y

Minimize loss of piping, then operator closes CO-V-8, CO-V-108 condensate.

and CO-V-24.

If both CO-T-1A and CO-T-18 are damaged, then operator closes CO-V-1 OB and opens DW-V-35 to line up DW-T-2 to EF-P-1.

If necessary, operators secure fire service pumps y

Mitigates the effects of non (FS-P-1 and FS-P-3).

seismic piping failures in Class I buildings.

Control room operator secures Main Turbine Lube N

DC load shedding.

Oil Pump LO-P-6.

Operator lines up FLEX Diesel Generator.

y Pre-condition to maintain vital AC power and restore RCS makeup.

Control room operator secures Main Generator y

DC load shedding is Seal Oil Pump (GN-P-2).

complete.

Operator props open doors for initial intermediate N

building ventilation.

Operator lines up FLEX RCS Makeup Pump from y

Pre-condition to maintain BWST or Spent Fuel Pool to RCS.

vital AC power and restore RCS makeup.

Operator takes local control of MS-V-6 (EF-P-1 y

Bottled air system will last steam supply), EF-V-30A & EF-V-308 (EFW Flow at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and then Control Valves) and MS-V-4A & MS-V-48 local manual control is (Atmospheric Dump Valves).

required.

Operator strips loads from 1 P & 1 S 480V Buses, y

Pre-condition to maintain and 1 A & 1 B ES MCC to prepare to load FLEX vital AC power and restore diesel generator.

RCS makeup.

Page 14 of 30

ELAP Time (HR) 25 2.5 26 2.58 27 2.75 28 3.0 29 3.5 30 4.0 31 4.0 32 4.0 33 4.5 A - Sequence of Events Timeline Earthquake or Tornado @ 100°/o power Action Time Remarks/

Constraint Applicability Y/N Operator starts FLEX Diesel Generator, energizes y

Pre-condition to maintain FLEX MCC and closes breakers to energize 1 P-vital AC power and restore 1 S 480V cross tie bus.

RCS makeup.

Operator closes breakers to energize 1 P 480V y

Pre-condition to maintain Bus, 1 S 480V Bus, 1 A ES MCC and 1 B ES MCC.

vital AC power and restore RCS makeup.

Operator closes breakers for selected loads on 1 A y

Pre-condition to maintain and 1 B ES MCC:

vital AC power and restore Battery Chargers RCS makeup.

AC Power to Inverters & Vital Instruments FLEX RCS Makeup Pumps Emergency Lighting Operator starts FLEX RCS Makeup Pump (A or B) y Restore makeup within 4 to restore RCS inventory and increase RCS boron hours to prevent interruption concentration.

of core cooling.

Operator opens service bldg and turbine bldg N

machine shop roll up doors and aux boiler roll up door.

Operator connects hose from DF-V-41 to pipe in y

Required for continued DGB, connects hose to fuel oil pipe in TB, routes operation of FX-Y-1A or B.

hose to FLEX DG Fuel Oil Tank (FX-T-3), and routes hose from FX-P-7 discharge to FX-T-2.

Operator strips loads on 1 A ESV MCC & 1 A N

Pre-condition to isolate Radwaste MCC and installs jumper between 1 A RCP controlled bleed off ESV MCC and 1 A Radwaste MCC.

flow.

Operator starts DF-P-1 C or DF-P-1 D, as needed, y

Required for continued to maintain level in FX-T-3.

operation of FX-Y-1A or B.

Pre-staged fuel supply will last 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> at full load.

Operator energizes 1 A ESV MCC and 1 A N

Isolate RCP controlled Radwaste MCC, and Closes CBO Isolation Valves bleed off flow to minimize MU-V-33A, MU-V-338, MU-V-33C and MU-V-RCS loss rate.

330.

Page 15 of 30 A - Sequence of Events Timeline Earthquake or Tornado@ 100°/o power ELAP Time (HR)

Action Time Remarks/

Constraint Applicability Y/N

>-------+----<-------------------------+-----+----------------

34 5.0 35 5.0 36 7.0 When pressurizer level reaches 100 inches, operator throttles open MS-V-4A & B to initiate a cooldown and controls pressurizer level at 100 inches. Cooldown rate will be less than 30 F/HR.

Operator sets up and starts temporary ventilation in Control Bldg, 18 and Turbine Bldg.

Operator strips loads on 1 C ESV MCC, energizes 1C ESV MCC, and closes breakers for CF-V-1A and CF-V-18.

When a reliable Pressurizer steam bubble is established or If RCS pressure drops below 300 psig, then CLOSE CF-V-1A & CF-V-1B.

37 7 to 8 Operator transfers a pressurizer heater group (RC-HTR-GRP-8 or 9) to the emergency power supply and energizes heaters.

38 8.0 Operator connects hose from FX-P-2A & B pump discharge to FLEX feedwater header, connects power cable to FX-P-2A or B starter, opens FX-V-203, FX-V-205, EF-V-67A and EF-V-67B.

N N

N N

N Contingency action.

Hydraulic control of RCS pressure can be used if required.

This is a pre-condition to use backup feedwater capability.

1------+-----+---------------------il--------t------**--*

.... --------l 39 8 to 11 Transfer portable diesel-driven pump (FX-P-3A or FX-P-38) from FLEX storage facility (FSF) to road next to the river or circ water flume, route suction hose into river/flume, and route discharge hose to CO-T-1 B or hotwell.

40

< 10.0 OTSG Pressure is now less than 200 psig.

41 Backup feedwater capability is enabled. If backup feedwater is required, operator starts FX-P-2A or Band throttles opens FX-V-206A and FX-V-2068 to control OTSG level (all action TB 322 north).

10.0 RCS cooldown is complete.

lncore temperature 400F OTSG A & B Pressure 150 psig RCS Pressure 400 psig Operator begins raising pressurizer level to > 300 inches Page 16 of 30 y

N N

For a tornado, minimum condensate supply would last greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The minimum supply is greater for an earthquake.

Design objective is to be able to establish a backup with i 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

42 43 44 A - Sequence of Events Timeline Earthquake or Tornado@ 100°/o power

---

*-----~,..............------------- ---

ELAP Action Time Remarks I Time Constraint Applicability (HR)

Y/N 12.0 Operator opens SF-V-88, connects hose from N

Spent fuel pool boiling FLEX feedwater header to the FLEX primary low occurs after 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

pressure header, monitors SF pool level and throttles FX-V-101 open as needed to maintain SFP level.

15.0 Operator lines up spent fuel pool vent path N

Spent fuel pool boiling (opening doors through U2 fuel pool to occurs after 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

atmosphere).

24.0 National SAFER Response Center resources N

On site fuel supply is begin arriving on site.

sufficient for greater than 2 National SAFER Response Center Equipment will weeks.

be used to maintain a reliable condensate supply If BWST is damaged by and to address longer term needs for fuel oil or tornado, then a borated borated water.

water supply will be required.

Page 17 of 30

ELAP Time (HR) 1

-36 2

-35 to

-12 3

-30 4

- 30 to -

18 I

i I 5 I -30 to -

I 12 6

- 22 to -

2 7

- 20 8

- 19 to

-12 9

-18 10

-16 11

-13 12

-10 13

-9 to -8

-6 14 B - Sequence of Events Timeline External Flood @ 100°/o power Action Time Remarks/

(only selected actions in AOP-002 listed)

Constraint Applicability Y/N Forecast indicates river level could exceed the height of NA Plant @100% power.

the dike within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Emergency procedure OP-TM-AOP-002 "Flood" initiated.

Operators maximize condensate tank Note 1 (CO-T-1A & CO-T-1 B) and demineralized water tank (DW-T-2} inv13ntory.

Operators install drain plugs, close drain valves and Note 1 inflate seals for AB & FHB Missile shield doors.

Operator connects hose from DF-V-41 to pipe in DGB, Note 1 DF-P-1 C can fill FX-T-2 in connects hose to fuel oil pipe in TB, and routes hose to approx 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

FLEX DG Fuel Oil Tank (FX-T-2).

Operator starts DF-P-1 C and initiates fill of FX-T-2.

Maintenance installs flood barriers and stages, Note 1 consumables within the flood protected area.

Maintenance installs U2 flood barriers and stages, Note 1 consumables within the flood protected area.

Plant shutdown and cool-down initiated.

y Vent the main generator hydrogen and purge with C02.

N Reactor is shutdown.

y RC-P-1 C and RC-P-1 D shutdown and cooldown initiated N

RCS cooldown terminated N

RCS temperature at 390F RCS pressure 425 psig Pressurizer level 200 to 220 inches CF-V-1A & B closed MU-V-33C & D closed OTSG pressure A & B at 175 psig OTSG Level A & B at 97 to 99 % op ranqe RCS boron concentration exceeds cold shutdown boron N

concentration requirement.

Operator transfers a pressurizer heater group Note 1 (RC-HTR-GRP-8 or 9) to the ES power supply.

Operator connects hose from FX-P-2A & B pump Note 1 discharge to FLEX feedwater header, connects power cable to FX-P-2A or B starter, opens FX-V-203, FX-V-205, EF-V-67A and EF-V-678.

Page 18 of 30 I

ELAP Time (HR) 15

-4 16

-3 17

-2 18

-1 19 0

20 0

21

<.02 22

< 0.05

~-

23

< 0.08 24

< 0.08 25

< 0.10 B - Sequence of Events Timeline External Flood @ 100°/o power

--~----**

-~-------*--** -----.---*-

Action Time Remarks/

(only selected actions in AOP-002 listed)

Constraint Applicability Y/N Operator lines up FX-P-1A & B path from BWST to RCS.

Note 1 Operator connects hose from FLEX feedwater header to the FLEX primary low pressure header, and lines up FLEX makeup to the SF pool.

Operator connects power cable to FX-P-5A or B, hose Note 1 from FX-P-5A & B discharge to FX-T-3 and FX-P-7 discharge to FX-T-2.

Operator opens breakers for BWST tunnel sump pumps Note 1 and closes WDL-V-612 Operator strips unprotected DC circuits from DC system Nbte 1 Prevents loss of battery (OP-TM-734-903 & 904).

capacity.

River level exceeds the height of the dike.

NA Failures per NEI 12-06.

LOOP occurs and Emergency Diesel Generators tail to energize ES buses.

EFW actuated: Steam driven pump (EF-P-1) starts and NA Automatic plant response.

EFW Control valves (EF-V-30A & B) are available to supply feedwater. RCS hot leg and cold leg temperatures diverge. OTSG pressure is dropping slowly.

EOP initiated.

NA Letdown isolates (MU-V-3) automatically on high NA Automatic plant response.

temperature.

Control Room operators throttle ADV to reduce OTSG N

pressure, maintain OTSG level with EFW control valves, and stabilize RCS temperature. Adequate core cooling is provided through RCS natural circulation and heat removal through the OTSG. RCS conditions follow:

RCS temperature at 400F RCS pressure 425 psig Pressurizer level 200 to 220 inches OTSG pressure A & B at 150 psig OTSG Level A & B is at "flooded nozzle" (97 to 99 % operatinq ranqe)

Control Room operators attempt to start and load SBO N

Diesel Generator.

Control Room operator closes RCP Controlled Bleed Off N

Contain RCS losses Isolation Valve (MU-V-26).

within Reactor Bldg.

Page 19 of 30 I

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ELAP Time (HR) 26

< 0.17 27 0.25 28

< 0.25 29

< 0.5

~*

0.5 31

.75 32

< 1.0 I

33 1.0 34 1.25 35 1.5 36 2.0 37 2.0 B - Sequence of Events Timeline External Flood @ 1 OOo/o power

• -+~-*---

-* - -~----*--*-**----,.---*--.. -------*--*--

Action Time Remarks/

(only selected actions in AOP-002 listed)

Constraint Applicability Y/N Control room operators recognize SBO Diesel generator N

Failure per NEI 12-06.

is not functional.

Operator performs E-plan offsite notifications &

N communication using satellite phones.

Operator close FS-V-256 & FS-V-257 to terminate N

IA-P-1A & B cooling water flow into IB sump.

Operator lines up FLEX Diesel Generator.

y Pre-condition to maintain I I vital AC power and restore RCS makeup.

Operator opens doors to inverter and battery rooms for N

Maintain acceptable FLEX ventilation.

equipment cooling.

Operator strips loads from 1 P & 1 S 480V Buses, and 1 A y

Pre-condition to maintain

& 1 BES MCC to prepare to load FLEX diesel generator.

I vital AC power and I

restore RCS makeup.

Operator starts FLEX Diesel Generator, energizes FLEX y

Pre-condition to maintain Distribution Panel and closes breakers to energize 1 P-vital AC power and i

1 S 480V cross tie bus.

restore RCS makeup.

Operator closes breakers to energize 1 P 480V Bus, 1 S y

Pre-condition to maintain 480V Bus, 1 A ES MCC and 1 B ES MCC.

vital AC power and restore RCS makeup.

I Operator closes breakers for selected loads on 1 A and y

Pre-condition to maintain I 1B ES MCC:

vital AC power and Battery Chargers restore RCS makeup.

AC Power to Inverters & Vital Instruments FLEX RCS Makeup Pumps Emergency Lighting Pressurizer heater qroup Operator starts FLEX RCS Makeup Pump (A or B) and y

Objective to restore throttles FX-V-103A (B) and slowly raises pressurizer makeup with 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is level above 300 inches.

conservative.

If backup feedwater is required, then operator starts N

FX-P-2A or Band throttles open FX-V-206A and FX-V-I 2068 to control OTSG level.

Operator takes local control of MS-V-6 (EF-P-1 steam y

Bottled air system will last I

supply), EF-V-30A & EF-V-308 (EFW Flow Control at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and then

• Valves) and MS-V-4A & MS-V-4B (Atmospheric Dump manual control is Valves).

required.

Page 20 of 30

38 39 40 41 I

142 I

43 i------

44 45 B - Sequence of Events Timeline External Flood @ 100°/o power

• -----------~---***-

ELAP Action Time Remarks/

Time (only selected actions in AOP-002 listed)

Constraint Applicability (HR)

Y/N 2.5 Operator strips loads on 1 A ESV MCC and installs N

jumper between 1 A ESV MCC and 1 A Radwaste MCC.

3.0 Operator energizes 1 A ESV MCC and 1 A Radwaste N

MCC, and Closes CBO Isolation Valves MU-V-33A and MU-V-33B.

3.5 Operator starts FX-P-5A or B, as needed, to maintain y

Required for continued level in FX-T-3.

operation of FX-Y-1A or B. Pre-staged fuel supply will last 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> at full load.

4.0 Operator sets up and starts temporary ventilation in CB, N

IB and TB.

15.0 Operator lines up spent fuel pool vent path N

Spent fuel pool boiling (opening doors through U2 fuel pool to atmosphere).

i occurs after 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

24.0 National SAFER Response Center resources available N

... limited capability to transport any resources until 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> due to water level on site.

> 24 Operator throttles open FX-V-101 as needed to maintain N

Spent fuel pool boiling SFP level.

occurs after 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

96 Transfer portable diesel-driven pump (FX-P-3A or FX-P-N Minimum condensate 3B) from FLEX storage facility (FSF) to road next to.the supply would last greater river, route suction hose into river, and route discharge than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after water hose to CO-T-1 B.

recedes (at 72 hrs).

NOTE 1: In the event of a flood, additional resources are applied to ensure the proactive actions can be completed within the described timeline.

Page 21of30 I

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I

ELAP Time (HR)

-8

-4 1

0 2

0 3

<.01 4

<.02 5

< 0.05 6

< 0.08 7

< 0.08 8

< 0.10 9

< 0.17 10 0.25 11 0.25 12 0.25 C - Sequence of Events Timeline Extreme Cold, Snow and Ice @ 100°/o power Action Time Remarks I Constraint Applicability Y/N Weather predicts extreme cold conditions.

NA Staff augmentation is initiated.

Staff augmentation is complete.

NA Extreme cold, snow or ice causes LOOP.

NA All control rods are inserted and the reactor is shutdown.

Emergency Diesel Generators fail to energize ES NA Failures per NEI 12-06.

buses.

EFW actuated: Steam driven pump (EF-P-1) and N

Automatic plant response.

, EFW Control valves (EF-V-30A & B) supply feedwater. MSSV & ADV control OTSG pressure.

EOP initiated.

NA RCS Letdown is automatically isolated on high N

Automatic plant response.

temperature (MU-V-3 closes).

Control Room operators throttle ADV to stabilize N

OTSG pressure and RCS temperature. Adequate core cooling is provided through RCS natural circulation and heat removal through the OTSG.

Control Room operators attempt to start and load N

SBO Diesel Generator.

Control Room operator closes RCP Controlled N

Contains RCS losses within Bleed Off Isolation Valve (MU-V-26).

the Reactor Bldg.

SBO Diesel generator is not functional.

N Failure per NEI 12-06.

Operator initiates E-plan. If needed, satellite N

phones are used for offsite notifications &

communication.

Operators open main condenser vacuum breaker N

This is a pre-condition to (VA-V-8) and valves to vent Main Generator H2 to reduce DC loads.

atmosphere.

Control Room operator secures DC powered FW N

DC Load shedding.

pump lube oil pumps (LO-P-9A and LO-P-98).

Page 22 of 30

ELAP Time (HR) 13 0.5 14 0.5 15

< 0.75 16 1.0 17 1.5 18

< 2.0 19 2.0 20 2.0 21 2.25 22 2.5 23 2.58 24 2.75 C - Sequence of Events Timeline Extreme Cold, Snow and Ice @ 100°/o power Action Time Remarks/

Constraint Applicability Y/N Operator opens doors to inverter and battery N

rooms.

Operator de-energizes instrument systems not N

DC Load shedding.

required for FLEX.

Operator lines up C02 purge for main generator.

N Minimize risk of main generator fire.

Control room operator secures Main Turbine Lube N

DC load shedding Oil Pump LO-P-6.

Operator lines up FLEX Diesel Generator.

y Pre-condition to maintain vital AC power and restore RCS makeup.

Control room operator secures Main Generator y

DC load shedding is Seal Oil Pump (GN-P-2).

complete.

Operator lines up FLEX RCS Makeup Pump from y

Pre-condition to restore BWSTto RCS.

RCS makeup.

Operator takes local control of MS-V-6 (EF-P-1 y

Bottled air system will last steam supply), EF-V-30A & EF-V-308 (EFW Flow at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and then Control Valves) and MS-V-4A & MS-V-4B manual control is required.

(Atmospheric Dump Valves).

Operator strips loads from 1 P & 1 S 480V Buses, y

Pre-condition to maintain and 1 A & 1 B ES MCC to prepare to load FLEX vital AC power and restore diesel generator.

RCS makeup.

Operator starts FLEX Diesel Generator, energizes y

Pre-condition to maintain FLEX MCC and closes breakers to energize 1 P-vital AC power and restore 1 S 480V cross tie bus.

RCS makeup.

Operator closes breakers to energize 1 P 480V y

Pre-condition to maintain Bus, 1 S 480V Bus, 1 A ES MCC and 1 B ES MCC.

vital AC power and restore RCS makeup.

Operator closes breakers for selected loads on 1 A y

Pre-condition to maintain and 1 B ES MCC:

vital AC power and restore Battery Chargers RCS makeup.

AC Power to Inverters & Vital Instruments FLEX RCS Makeup Pumps EmerQency LiQhtinQ Page 23 of 30

ELAP Time (HR) 25 3.0 26 4.0 27 4.0 28 4.0 29 4.5 30 5.0

~"

31 7.0 32 7 to 8 33 8.0 C - Sequence of Events Timeline Extreme Cold, Snow and Ice @ 100°/o power

---

~--,~----*----~-------*-*----"

Action Time Remarks I Constraint Applicability Y/N Operator starts FLEX RCS Makeup Pump (A or B) y Restore makeup within 4 to restore RCS inventory and increase RCS boron hours to prevent interruption concentration.

of core cooling.

Operator connects hose from DF-V-41 to pipe in y

Pre-condition to maintain DGB, connects hose to fuel oil pipe in TB, routes fuel supply to FX-Y-1 A or B.

hose to FLEX DG Fuel Oil Tank (FX-T-3) and connects hose from FX-P-7 to FX-T-2.

Operator strips loads on 1 A ESV MCC & 1 A N

Radwaste MCC and installs jumper between i A ESV MCC and 1A Radwaste MCC. Operator ensures BWST heat trace is energized.

Operator starts DF-P-1 C or DF-P-1 D, as needed, y

Required for continued to maintain level in FX-T-3.

operation of FX-Y-1A or B.

Pre-staged fuel supply will last 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> at full load.

Operator energizes 1 A ESV MCC and 1 A I

N Isolate RCP controlled Radwaste MCC, and Closes CBO Isolation Valves bleed off flow to minimize MU-V-33A, MU-V-338, MU-V-33C and MU-V-RCS loss rate.

330.

When pressurizer level reaches 100 inches, then N

Pre-condition to enable operator throttles open MS-V-4A & B to initiate a back-op feedwater cooldown and controls pressurizer level at 100 capability.

inches. Cooldown rate will be less than 30 F/HR.

Operator strips loads on 1 C ESV MCC, energizes N

Contingency actions.

1C ESV MCC, and closes breakers for CF-V-1A and CF-V-1 B.

When a reliable steam bubble is established or if RCS pressure drops below 300 psig, then CLOSE CF-V-1A & CF-V-18.

Operator transfers a pressurizer heater group N

Hydraulic control of RCS (RC-HTR-GRP-8 or 9) to the emergency power pressure can be used if supply and energizes heaters.

required.

Operator connects hose from FX-P-2A & B pump N

Pre-condition to enable discharge to FLEX feedwater header, connects back-op feedwater power cable to FX-P-2A or B starter, opens FX-V-capability.

203, FX-V-205, EF-V-67A and EF-V-678.

Page 24 of 30

ELAP Time (HR) 34

< 10.0 35 10.0 36 12.0 37 12.0 38 12.0 39 15.0 40 24.0 41 48 C - Sequence of Events Timeline Extreme Cold, Snow and Ice @ 100°/o power

--*-*~* *-

Action Time Remarks I Constraint Applicability Y/N OTSG Pressure is now less than 200 psig.

N The design objective is to Backup feedwater capability is enabled. If backup enable back-op feedwater feedwater is required, operator starts FX-P-2A or capability within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Band throttles opens FX-V-206A and FX-V-206B to control OTSG level (all action TB 322 north).

RCS cooldown is complete.

N lncore temperature 400F

• OTSG A & B Pressure 150 psig RCS Pressure 400 psig Operator begins slowly raising pressurizer level to above 300 inches.

Operator connects a hose from main steam drain N

line to piping connected to condensate tank B and initiates tank heating.

BWST immersion heater 1 A is energized from 1 A N

ESF MCC.

Operator opens SF-V-88, connects hose from N

Spent fuel pool boiling FLEX feedwater header to the FLEX primary low occurs after 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

pressure header, monitors SF pool level and throttles FX-V-101 open as needed to maintain SFP level.

Operator lines up spent fuel pool vent path N

Spent fuel pool boiling (opening doors through U2 fuel pool to occurs after 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

atmosphere).

National SAFER Response Center resources N

begin arriving on site.

National SAFER Response Center Equipment will be used to maintain a reliable condensate supply and to address longer term needs for fuel oil or borated water.

Transfer hose and portable diesel-driven pump N

Minimum condensate (FX-P-3A or FX-P-3B) from FLEX storage facility supply would last greater (FSF) to road next to the river, route suction hose than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

into river, and route discharge hose to CO-T-1 B.

Page 25 of 30 A

1 E-919-21-001, draft, FLEX Diesel Generator and Fuel Oil System 26 of 30 I

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1E-919-21-002, draft, FLEX Electrical Distribution Page 27 of 30 C

1 E-919-21-003, draft, FLEX Feedwater System of 30 0

1 E-919-21-004, draft, FLEX RCS and SFP Makeup System 29 30 E

1 E-919-21-005, draft, Long term water supply Ul'~ff ISPli of 30