RS-16-020, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
ML16057A208
Person / Time
Site: Braidwood Constellation icon.png
Issue date: 02/26/2016
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-16-020, TAC MF0895, TAC MF0896
Download: ML16057A208 (23)
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Order No. EA-12-049 RS-16-020 February 26, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Unit 1 Renewed Facility Operating License No. NPF-72 NRC Docket No. STN 50-456

Subject:

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

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-13-017)
6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2013 (RS-13-113)
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-14-007)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 26, 2016 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 049), dated August 28, 2014 (RS-14-205)
9. Exelon Generation Company, LLC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 27, 2015 (RS-15-016) 10.Exelon Generation Company, LLC 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 049), dated August 28, 2015 (RS-15-208)
11. NRC letter to Exelon Generation Company, LLC, Braidwood Station, Units 1 and 2 Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA 049 (Mitigation Strategies) (TAC Nos. MF0895 and MF0896), dated December 17, 2013 12.NRC letter to Exelon Generation Company, LLC, Braidwood Station, Units 1 and 2 Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0895 and MF0896), dated May 27, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Braidwood Station, 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, 7, 8, 9, and 10 provided the first, second, third, fourth, and fifth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Braidwood Station, Unit 1. The purpose of this letter is to provide the sixth 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 11, and the NRC Audit Report open items contained in Reference 12.

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 February 26, 2016 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 26th day of February 2016.

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

Enclosure:

1. Braidwood Station, Unit 1 Sixth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond- Design -Basis External Events cc: NRC Regional Administrator - Region III NRC Senior Resident Inspector - Braidwood Station NRC Project Manager, NRR - Braidwood Station Mr. John D. Hughey, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Braidwood Station, Unit 1 Sixth 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 (19 pages)

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 Braidwood Station, Unit 1 Sixth 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 Introduction Braidwood Station developed an Overall Integrated Plan (Reference 1 in Section 8),

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

With the report of Unit 2 full compliance (Reference 38) December 16, 2015, this six-month update provides the status of Braidwood Station, Unit 1 mitigating strategies implementation.

2 Milestone Accomplishments The following milestone(s) have been completed since July 28, 2015 and are current as of January 30, 2016.

  • Procedure Development, Unit 1 o Strategy procedures o Validate procedures (NEI 12-06, Sect. 11.4.3) o Maintenance procedures
  • Training completion NOTE: The "Status" indicated in this document is as of January 30, 2016. This date was chosen to support the development, review, approval and submittal of this report by the required February 26, 2016 due date.

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

Site: Braidwood Original Target Activity Status Revised Target Completion Date Completion Date Submit 60 Day Status Report Complete Submit Overall Integrated Complete Implementation Plan Contract with Strategic Alliance Complete Page Iof19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 for FLEX Emergency Response National SAFER Response Center Submit Six (6) month updates Aug 2013 Update 1 Complete Feb 2014 Update 2 Complete Aug 2014 Update 3 Complete Feb 2015 Update 4 Complete Aug 2015 Update 5 Complete Feb 2016 Update 6 Complete with this submittal Aug 2016 Update 7 Not Started Unit 1 Unit 2 Modification Development Unit 1 Unit 2 Unit 1 Unit 2 Feb Sept

  • Phase 1 modifications Started Complete Oct Oct 2014 2014 2016 2015 Feb Sept
  • Phase 2 modifications Complete Complete Dec Dec 2014 2014 2014 2014 Feb Sept 0 Phase 3 modifications Complete Complete 2014 2014 Unit 1 Unit 2 Modification Implementation Unit 1 Unit 2 Unit 1 Apr Oct
  • Phase 1 modifications Started Complete Oct 2015 2015 2016 Apr Oct
  • Phase 2 modifications Complete Complete 2015 2015 Apr Oct 0 Phase 3 modifications Complete Complete 2015 2015 Unit 1 Unit 2 Procedure Development Unit 1 Unit 2 Unit 1 Apr Oct
  • Strategy procedures *Complete Complete Oct 2015 2015 2016 Apr Oct
  • Validate procedures (NEI *Complete Complete Oct 2015 2015 12-06, Sect. 11.4.3) 2016 Apr Oct
  • Maintenance procedures *Complete Complete Oct 2015 2015 2016 Nov 2014 Staffing analysis Complete Apr 2015 Storage plan and construction Complete Page 2 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 Apr 2015 FLEX equipment acquisition Complete Apr 2015 Training completion Complete Sept 2015 Dec 2014 National SAFER Response Complete Feb 2015 Center operational Apr 2015 Unit 1 Implementation date Started October 2016 Oct 2015 Unit 2 Implementation date Complete Notes:

  • Procedures completed. Awaiting implementation during Al R19 due to the RCP Seals.

4 Changes to Compliance Method Change 1 Section: General Integrated Plan Elements PWR - Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint.

Reason for Change: Calculations CN-LIS-15-39 and CN-LIS-15-40 have been completed.

Change:

  • Change sequence of events action, Verify DDAF Pp is operating properly, elapsed time from 5 - 50 minutes to 5 - 30 minutes.
  • Change RCS cool down rate from approximately 75°F/hr cool down to < 100 °F/hr. Also change the elapsed time from 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> - 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
  • Change SX short cycle start time from 55 - 90 minutes to 30 - 90 minutes.

Change 2 Section: Attachment 1 A, Sequence of Events time line.

Reason for Change: Calculations CN-LIS-15-39 and CN-LIS-15-40 have been completed Change:

  • Change sequence of events action, Verify DDAF Pp is operating properly, elapsed time from 5 - 50 minutes to 5 - 30 minutes. Also changed its time constraint from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 45 minutes.
  • Change line item 10 action from "Start depressurization of SGs to 260 psig at approximately 750 F/hr cool down with SG PORV local/manual operation. SG feed is controlled with Local/Manual operation of AFW flow control valves" to "Start depressurization of SGs to 260 psig at < 100°F/hr cool down with SG PORV local/manual operation. SG feed is controlled with Local/Manual operation of AFW flow control valves". Also change the elapsed time from 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> - 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and the time constraint from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Page 3 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016

  • Change SX short cycle, Sl accumulator and maintaining SG pressure actions as a result of sequence changes listed above.

Updated timeline is provided in Attachment 1 A of this document.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Braidwood Station, Unit 1 has received an 18-month extension of the Order due to Pressurized-Water Reactor Owners Group (PWROG) refining RCP Seal Leakage rate projections and is scheduled to be in compliance by October 2016 in accordance with NRC letter, dated April 15, 2015 (ADAMS Accession No. ML15068A215) stating: "Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of the order for full order implementation for Braidwood Station, Unit 1, is relaxed until the completion of the fall 2016 refueling outage. This additional time will allow Exelon to complete the engineering analysis associated with the additional information provided by the PWROG regarding the analytical basis for RCP seal leakage'.

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

NOTE: The "Status" indicated in this document is as of January 30, 2016. This date was chosen to support the development, review, approval and submittal of this report by the required February 26, 2016 due date.

Section Reference Overall Integrated Plan Open Item Status Key Site assumptions Primary and secondary storage Item Closed During Onsite NRC Audit (p.4) locations have not been selected yet; (Ref. 31).

once locations are finalized implementation strategies and routes Complete Closure supplied as part of will be assessed for hazard impact. fifth 6-month update (Ref. 36).

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

and procedures are developed.

Complete -The site FLEX procedures have been developed and validated consistent with the NEI FLEX validation process. The results have been compared to the site Phase 2 staffing study (Ref. 37). The comparison confirmed that site existing emergency response resources are sufficient to perform the required plant actions and implement the multi-unit BDBEE response strategies.

Page 4 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 Identify how strategies Identification of storage area and Item Closed During Onsite NRC Audit will be deployed (p.7) creation of the administrative program. (Ref. 31).

Complete Closure supplied as part of fifth 6-month update (Ref. 36).

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

maintenance.

Complete Closure supplied as part of fifth 6-month update (Ref. 36).

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

(P-9) Complete Closure supplied as part of fifth 6-month update (Ref. 36).

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

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

imminent or actual core damage.

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

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

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

required.

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

(Generation 111). As a result of installing the SHIELD seals, calculation CN-LIS 39, Exelon Byron and Braidwood Stations Reactor Coolant System FLAP Long-Term Subcriticality Analysis with Low-Leakage Reactor Coolant Pump Seal Packages (Ref. 35), was performed.

Calculation CN-LIS-15-39 (Ref. 35) determined the timing and quantity of borated water required to maintain the reactor subcritical. Boration will need to start within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the event initiation and require approximately 6,000 gallons of 2300 ppm water injected into the RCS.

This calculation supersedes calculation BYR1 3-239/BRW-1 3-0221 -M (Ref. 10).

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

Complete Closure supplied as part of fifth 6-month update (Ref. 36).

Page 5 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 Maintain Spent Fuel Procedure development for Initial Spent Item Closed During Onsite NRC Audit Pool Cooling, Phase 1 fuel pool make-up with gravity drain (Ref. 31).

(p.39) from the RWST.

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

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

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

cooling strategy detailed design.

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

(p.39 and p.42) performed and used to determine if vent path strategy is needed. Complete - Closure supplied as part of third 6-month update (Ref. 25).

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

maintain Main Control Room.

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

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

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

and/or component survivability. Specific analyses of these rooms will be performed.

Interim Safety Evaluation Open Item Status Braidwood's ISE Response Line Item Description Answer Number Number 1 Open Item Core Subcriticality- The NRC staff Item Closed During Onsite NRC Audit 3.2.1.8.A has not endorsed the industry- (Ref. 31).

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

(Ref. 22).

Calculation CN-LIS-15-39 (Ref. 35) determined the timing and quantity of borated water required to maintain the reactor subcritical. Boration will need to start within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the event initiation and require approximately Page 6 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 6,000 gallons of 2300 ppm water injected into the RCS. This calculation supersedes calculation BYR13-239/BRW-13-0221-M (Ref. 10).

Calculation CN-LIS-15-34 (Ref. 33) determined the RCS loss of single phase natural circulation will occur 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> into the event.

The Braidwood Overall Integrated Plan (OIP) Attachment 1 A, Action Item 16 shows that the high pressure FLEX pumps are available between 11 and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> following the Beyond-Design-Basis External Event (BDBEE) which meets the timing requirements outlined in Ref. 22.

No Confirmatory Items 2 3.1.1.1.A Storage & Protection of FLEX Complete Closure supplied as part equipment - Confirm final design of of fifth 6-month update (Ref. 36).

FLEX storage structure conforms to NEI 12-06, Sections 5.3.1, 7.3.1, and 8.3.1 for storage considerations for the hazards applicable to Braidwood.

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

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

portable instrument.

4 3.1.1.4.A Off-Site Resources Confirm Item Closed During Onsite NRC Audit National SAFER Response Center (Ref. 31).

local staging area and method of Complete Closure supplied as part transportation to the site in future 6-of fifth 6-month update (Ref. 36).

month update 5 3.1.5.1.A Protection of Equipment (High Item Closed During Onsite NRC Audit Temperature) - Confirm FLEX (Ref. 31).

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

upon.

6 3.1.5.3.A Deployment of Equipment (High Item Closed During Onsite NRC Audit Temperature) - Confirm that the (Ref. 31).

effects of high temperature on FLEX Complete Closure supplied as part equipment have been evaluated in of fourth 6-month update (Ref. 29).

the locations they are intended to operate.

7 3.2.1.A RCS cooling & RCS inventory Item Closed During Onsite NRC Audit control - Specify which analysis (Ref. 31).

performed in WCAP-17601 is being Page 7 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 applied to Braidwood. Additionally, Complete Closure supplied as part justify the use of that analysis by of fifth 6-month update (Ref. 36).

identifying and evaluating the important parameters and assumptions demonstrating that they are representative of Braidwood and appropriate for simulating the ELAP transient.

8 3.2.1.1.A NOTRUMP - Confirm that the use of Item Closed During Onsite NRC Audit NOTRUMP in the ELAP analysis is (Ref. 31).

limited to the flow conditions before reflux condensation initiates. This Complete Closure supplied as part includes specifying an acceptable of fifth 6-month update (Ref. 36).

definition for reflux condensation cooling.

9 3.2.1.1.B ELAP Analysis - Confirm Item Closed During Onsite NRC Audit calculations to verify no nitrogen (Ref. 31).

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

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

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

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

determine whether additional boration equipment is needed for Complete Closure supplied as part Phase 3 coping strategy. of fourth 6-month update (Ref. 29).

12 3.2.1.2.13 Reactor Coolant Pump (RCP) Seal Item Closed During Onsite NRC Audit Leakage - In some plant designs, (Ref. 31).

the cold legs could experience temperatures as high as 580 OF Complete: Braidwood Station has before cooldown commences. This decided to install the Westinghouse is beyond the qualification reactor coolant pump (RCP) SHIELD temperature (550°F) of the 0-rings Passive Thermal Shutdown Seals used in the RCP seals. For those Westinghouse designs, a discussion (SDS) (Generation 111). The SHIELD should be provided to justify that (1) SDSs were installed on all 4 RCPs on the integrity of the associated 0-rings Unit 2 in the Fall of 2015 and will be will be maintained at the installed on Unit 1 in the Fall of 2016.

temperature conditions experienced Braidwood Station has Westinghouse during the ELAP event, and (2) the seal leakage rate of 21 gpm/seal RCP Model 93A. Credit for the used in the ELAP is adequate and SHIELD seals has been endorsed for acceptable. Westinghouse Model 93A RCPs as documented in ADAMS Accession No. ML14132A128. The RCP seal leakage assumed in CN-LIS-15-34, Exelon Byron and Braidwood Stations Reactor Coolant System ELAP Page 8 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 Inventory Control Analysis SHIELD Reactor Coolant Pump Seal Packages, (Ref. 33) is consistent with ADAMS Accession No. ML14132A128 limitations and conditions number 4.

The qualification testing of the shutdown seal was performed at conditions based on a cold leg temperature of 571 OF. The maximum shutdown seal temperature remains below the shutdown seal temperatures experienced during qualification testing.

Following a loss of AC power, it is possible for the RCS cold leg temperature to exceed 571 OF for short periods of time without the shutdown seal heating up beyond the temperatures experienced during qualification testing. This is due to the significant thermal inertia of the massive reactor coolant pump internals and pressure boundary. The evaluation documented in calculation CN-LIS-15-40 (Ref. 34) concludes that even if the cold leg temperature is 581 OF for the first 3000 seconds (50 minutes) following ELAP initiation, the maximum fluid temperature at the reactor coolant pump seal inlet remains below the temperatures experienced during shutdown seal qualification testing. Auxiliary Feedwater flow to the steam generators will be initiated at approximately 30 minutes into the ELAP event. Following the restoration of Auxiliary Feedwater flow to the steam generators and prior to initiating plant cooldown, cold leg temperature will be dictated by the Main Steam Safety Valves. Cold leg temperature will remain less than 571 OF during this period based on the lowest Main 1 Steam Safety Valve setting of 1175 Page 9 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 psig adjusted for setting tolerance and lift setpoint testing uncertainty.

Westinghouse LTR-RES-13-153, Documentation of 7228C Compound O-Rings at FLAP Conditions, concludes, with a high level of confidence, that the integrity of the RCS O-rings will be maintained at the temperature conditions experienced during the FLAP event.

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

manufacturer and model number of Complete Closure supplied as part the RCP seals and discuss whether of fifth 6-month update (Ref. 36).

or not the RCP and seal combination complies with a seal leakage model described in WCAP-17601.

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

details of the WCAP 17601 -P Complete Closure supplied as part methodology to include the values of of fifth 6-month update (Ref. 36).

certain key parameters used to determine the decay heat levels.

Address the adequacy of the values used.

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

Confirm WCAP-17601-P analyses are bounding for Braidwood for Complete Closure supplied as part of fifth 6-month update (Ref. 36).

strategy response or verify plant-specific analyses if more restrictive limits are used due to more restrictive plant specific limits.

16 3.2.1.4.13 Initial Values for Key Plant Item Closed During Onsite NRC Audit Parameters and Assumptions- (Ref. 31).

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

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

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

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

imminent or actual core damage.

Page 10 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 18 3.2.1.6.A Sequence of Events - Confirm that Complete - The site FLEX procedures the final timeline has been time have been developed and validated validated after detailed designs are consistent with the NEI FLEX completed and procedures are validation process. The results have developed. The results may be been compared to the site Phase 2 provided in a future 6-month update. staffing study (Ref. 37). The comparison confirmed that site existing emergency response resources are sufficient to perform the required plant actions and implement the multi-unit event response strategies.

19 3.2.1.6.13 Sequence of Events - Confirm Item Closed During Onsite NRC Audit analysis to validate Phase 2 pump (Ref. 31).

capacities.

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

20 3.2.1.9.A Use of portable pumps - Confirm Item Closed During Onsite NRC Audit final design of strategies meets "use (Ref. 31).

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

of fourth 6 month update (Ref. 29).

21 3.22A SFP cooling -Verify procedure for Item Closed During Onsite NRC Audit SFP makeup via gravity drain; (Ref. 31).

confirm verification of timeline for Complete Closure supplied as part performing the strategy; and confirm of fourth 6-month update (Ref. 29).

evaluation of SFP area for steam and condensation affects.

22 3.2.3.A Containment - Confirm containment Complete Closure supplied as part reanalysis supports no Phase 1, 2, of fifth 6-month update (Ref. 36).

and 3 mitigation strategies are required because containment pressure and temperature are maintained within acceptable limits.

23 3.2.3.13 Containment - Confirm evaluation Item Closed During Onsite NRC Audit performed for the need to monitor (Ref. 31).

containment temperature.

Complete Closure supplied as part of fifth 6-month update (Ref. 36).

24 3.2.4.1.A Equipment cooling - Confirm Item Closed During Onsite NRC Audit modification has been performed to (Ref. 31).

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

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

25 3.2.4.2.A Ventilation - Equipment Cooling - Item Closed During Onsite NRC Audit Review licensee's evaluation of loss (Ref. 31).

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

battery rooms, control room, miscellaneous electrical equipment Page 11 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 rooms) 26 3.2.4.2.13 A discussion is needed on the Item Closed During Onsite NRC Audit extreme high/low temperatures (Ref. 31).

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

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

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

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

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

28 3.2.4.4.A Communications - Confirm that Item Closed During Onsite NRC Audit upgrades to the site's (Ref. 31).

communications systems have been Complete Closure supplied as part completed.

of fifth 6-month update (Ref. 36).

29 3.2.4.6.A Personnel Habitability - Review Item Closed During Onsite NRC Audit licensee's evaluation of loss of (Ref. 31).

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

third 6-month update (Ref. 25).

30 3.2.4.7.A Water Sources - Justify the time at Item Closed During Onsite NRC Audit which SG dryout will occur. (Ref. 31).

Complete Site specific calculation CN-LIS-15-40 (Ref. 34), demonstrates SG dry out will occur 45 minutes after the event initiation. This data supersedes the generic information used in WCAP-1 7601 -P, Table 5.4.1.1-1, Case 2A (Ref. 18).

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

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

multiple sources do not attempt to power electrical buses.

32 3.2.4.9.A Portable Equipment Fuel - Confirm Item Closed During Onsite NRC Audit that complete analysis of fuel usage (Ref. 31).

requirements has been developed Complete Closure supplied as part after the specific FLEX equipment is of fifth 6-month update (Ref. 36).

identified and the fuel usage is determined. A discussion is needed on maintaining the quality of fuel stored in the tanks for extended periods of time Page 12 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 33 3.2.4.10.A Load reduction to conserve DC Item Closed During Onsite NRC Audit power- Confirm sizing calculations (Ref. 31).

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

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

NRC Audit Open Items Status Braidwood Station Response SE#9 Please provide adequate justification for the reactor Complete Closure supplied as part coolant Pump (RCP) seal leakage rates calculated of fifth 6-month update (Ref. 36).

according to the Westinghouse seal leakage model that was revised following the issuance of NSAL-1 4-

1. The justification should include a discussion of the following factors:
a. benchmarking of the seal leakage model against relevant data from tests or operating events,
b. discussion of the impact on the seal leakage rate due to fluid temperatures greater than 550°F resulting in increased deflection at the seal interface,
c. clarification whether the second-stage RCP seal would remain closed under ELAP conditions predicted by the revised seal leakage model and a technical basis to support the determination, and,
d. justification that the interpolation scheme used to compute the integrated leakage from the RCP seals from a limited number of computer simulations (e.g.,

three) is realistic or conservative.

SE #10 The NRC staff understands that Westinghouse has Complete Closure supplied as part recently recalculated RCP seal leakoff line pressures of fifth 6-month update (Ref. 36).

under loss of seal cooling events based on a revised seal leakage model and additional design-specific information for certain plants.

a. Please clarify whether the piping and all components (e.g., flow elements, flanges, valves, etc.) in your seal leakoff line are capable of withstanding the pressure predicted during an ELAP event according to the revised seal leakage model.
b. Please clarify whether operator actions are credited with isolating low-pressure portions of the seal leakoff line and if so, please explain how these actions will be executed under ELAP conditions.
c. If overpressurization of piping or components could occur under ELAP conditions, please discuss any planned modifications to the seal leakoff piping and component design and the associated completion timeline.
d. Alternately, please identify the seal leakoff piping or components that would be susceptible to overpressurization under ELAP conditions, clarify their locations, and provide justification that the seal leakage rate would remain in an acceptable range if the affected piping or components were to rupture.

Page 13 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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

1. Braidwood Station, Units 1 and 2, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013 (RS-13-017).
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. Braidwood Station's First Six Month Status Report for the Implementation of FLEX, dated August 28, 2013.
5. Braidwood Station's Second Six Month Status Report for the Implementation of FLEX, dated February 28, 2014.
6. Braidwood Station, Units 1 and 2 NRC Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigating Strategies) JAC NOS.

MF0895 AND MF0896), dated December 17, 2013.

7. BYR99-010/BRW-99-0017-1, Rev. 2, Documentation of the Basis of the Emergency Operating Procedures (EOP) Setpoints, dated September 2014.
8. BYR1 4-060/BRW-1 4-0080-E, Rev. 0, Unit 1(2) 125 VDC Battery FLEX Coping Calculation Common Calc Beyond Design Basis, dated September 2014.
9. BYR1 3-240/BRW-1 3-0222-M, Rev. 0, Spent Fuel Pool Boil Off Analysis during an ELAP Event, dated April 2014.

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

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

12. BYR13-235/BRW-13-0217-M, Rev. 0, Containment Pressure and Temperature Response during an ELAP Event, dated September 2014.

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

Page 14 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEA February 26, 2016 14.BYR13-237/BRW-13-0219-M, Rev. 0, MEER and Battery Room Conditions Following FLAP, dated July 2014.

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

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

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

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

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

20. BYR1 3-144/BRW-1 3-0160-M, Rev. 2, FLEX Pump Sizing and Hydraulic Analysis, dated December 2014.
21. BRW-14-0030-M, Rev. 0, Godwin Pump Suction Line Hydraulic Analysis to Support FLEX, dated August 2014.
22. Letter to Mr. Jack Stringfellow requesting endorsement of Westinghouse position paper entitled 'Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in support of the Pressurized Water Reactor Owners Group (PWROG)", Accession Number ML13276A183, date January 8, 2014.
23. Westinghouse Correspondence LTR-FSE-14-43, Revision 0, "Exelon Generation Company, LLC Mitigation Strategies Order (EA-12-049) Design FLAP Simulation Parameters," dated June 15, 2015.
24. Westinghouse Correspondence LTR-FSE-14-61, Rev.0 "Exelon Generation Company, LLC Mitigation Strategies Order (EA-12-049) Open and Confirmatory Item Responses, dated June 15, 2015.
25. Braidwood Station's Third Six Month Status Report for the Implementation of FLEX, dated August 28, 2014.
26. BRW-14-0255-M, Rev. 1, Braidwood Units 1 and 2 FLEX Steam Generator Degraded Heat Transfer Analysis through 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, dated December 2014.
27. BYR14-129/BRW-14-0212-M, Rev. 0, RWST Usage during FLEX Scenarios, dated October 2014.
28. BRW-1 4-0211 -M, Rev.0, Evaluation of Tank and Hose Freezing during an ELAP, dated September 2014.
29. Braidwood Station's Fourth Six Month Status Report for the Implementation of FLEX, dated February 27, 2015.
30. BRW-1 5-0002-S, Rev.0, Evaluation of FLEX Equipment Haul Paths for Soil Liquefaction Potential, dated March 2015.
31. Braidwood Station, Units 1 and 2 NRC Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 JAC Nos. M F0895 and M F0896), dated May 27, 2015 (ADAMS Accession No. ML15134A459).

Page 15 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016

32. PW ROG- 14027- P, Rev. 3, No. 1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of all AC Power, dated April 2015.
33. CN-LIS-15-34, Rev. 0, Exelon Byron and Braidwood Stations Reactor Coolant System FLAP Inventory Control Analysis SHIELD Reactor Coolant Pump Seal Packages, dated July 13, 2015.
34. CN-LIS-1 5-40, Rev. 0, Exelon Byron and Braidwood Stations Delayed AFW FLEX Studies, dated September 2015.
35. CN-LIS-1 5-39, Rev.0, Exelon Byron and Braidwood Stations Reactor Coolant System FLAP Long-Term Subcriticality Analysis with Low-Leakage Reactor Coolant Pump Seal Packages, dated September 2015.
36. Braidwood Station's Fifth Six Month Status Report for the Implementation of FLEX, dated August 28, 2015.
37. Braidwood Station, Units 1 and 2 - Response Regarding Phase 2 Staffing Submittals Associated With Near-term Task Force Recommendation 9.3 Related to the Fukushima Dal-ichi Nuclear Power Plant Accident (ADAMS Accession No.: ML151568260), dated June 2015.
38. Exelon Generation Company, LLC letter to the NRC, "Braidwood Station, Unit 2, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated December 16, 2015 (RS-15-276).
39. Westinghouse Correspondence LTR-RES-13-153, "Documentation of 7228C O-Rings at FLAP Conditions," dated October 31, 2013.

Page 16 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 Attachment 1A Sequence of Events Timeline Time Action : Remarks f Elapsed Time Action Constraint item z Applicability YIN 0 Event Starts, BDBEE occurs, Unit 1 and Unit 2 reactors 1 automatically trip and all rods are inserted. NA Unit 1 and Unit 2

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

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

3 3-5 mins MCR closes C & D S/G PORVs to conserve inventory. Y-5 BwCA 0.0, Loss of minutes All AC Power, action. CN-LIS 40 (Ref. 34).

4 5-30 mins Verify DDAF Pp is operating properly. Y-45 BwCA 0.0, Loss of minutes All AC Power, action. CN-LIS 40 (Ref. 34).

5 10-30 mins Attempt starting Emergency D/G's. NA BwCA 0.0, Loss of All AC Power, action.

6 30 mins ELAP condition recognized and ELAP Procedures are entered. NA BwCA 0.0, Loss of All AC Power, attachment B for 1 Instructions: Provide justification if No or NA is selected in the remarks column If yes, include technical basis discussion as required by NEI 12-06, Section 3.2.1.7 Page 17 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 Time Action Remarks J Elapsed Time Action Constraint item. ,j~ , Applicability ELAP.

7 30 mins to 90 mins SX Short Cycle Cooling EC is aligned to cool the B AF Pp Y - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> BwCA 0.0, Loss of within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after pump start. All AC Power, action. BRW 003 1 -M (Ref. 16)

BRW-14-0080-E 8 30 mins to 6 hrs Connect FLEX 480V AC generators to ESF bus 32X and verify Y 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (Ref. 8) they are supplying power to Div 2 - 125V DC battery chargers.

BRW-14-0080-E 9 35 mins to 65 mins Operators dispatched to perform DC Bus Load Shed. Y-65 (Ref. 8) minutes 10 1.5 hrs 8 hrs Start depressurization of SGs to 260 psig at < 100017/hr Y - 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> BwCA 0.0, Loss of cooldown with SG PORV local/manual operation. SG feed is All AC Power, controlled with Local/Manual operation of AFW flow control action. CN-LIS valves. 39 (Ref. 35) 11 3 4.5 hrs Setup and establish ventilation in AEER and MCR. 4.75 Directed from OBFSG-51 and BYR13-236BRW-13-0218-M (Ref. 15) 12 3 hrs 10 hrs SI Accumulator borated water begins to inject into the RCS. 16 hrs CN-LIS-15-39 (Ref.

35) 13 6 - 10 hrs Deploy all hoses and connections in FHB for alternate SFP Fill Y - 10.94 Directed from strategy before FHB becomes uninhabitable from SFP Boiling. hours OBwFSG-5 and OFSG-11. BRW 0222-M (Ref. 9) 14 9 hrs 16 hrs Maintain SG pressure 260 prig and RCS temperature between NA CN-LIS-15-39 (Ref.

420F 410F with SG PORV operation. 35)

Maintain SG level.

15 9 hrs 16 hrs Isolate SI Accumulators. NA CN-LIS-15-39 (Ref.

35)

Page 18 of 19

Braidwood Station, Unit 1 Sixth 6 Month Status Report for the Implementation of FLEX February 26, 2016 Time Action Remarks /

Elapsed Time Action Constraint item: , Applicability Y/N 16 11-14 hrs Stage and connect Phase 2 high pressure FLEX Pumps and Y 16 CN-LIS-15-39 (Ref.

ensure they are available to supply borated make-up to the RCS. hours 35) 17 16 - 20 hrs Connect Phase 2 med head FLEX Pumps and ensure they are NA 1/2BwFSG-5 action available to supply make-up to the SG's.

18 24 hrs Initiate SFP Make up via OA Refueling Water Purification Pump NA OBwFSG-1 faction.

as required for level and temperature control. BRW-13-0222-M (Ref. 9) 19 24 hrs National SAFER Response Center resources begin arriving on NA National SAFER site. Response Center Guide 20 24 - 72 hrs Continue to maintain critical functions of Core Cooling (via NA End of analytical DDAF), RCS Inventory Control (via FLEX pump injection to simulation RCS) and SFP Cooling (via FLEX pump injection to SFP). Utilize initial National SAFER Response Center NRC equipment and resources.

Page 19 of 19

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