ML24057A306

Attachment 4: BW-SDP-006 Rev. 0 - Braidwood 2B AF Pump Fuel Oil Leak SOP Sensitivities

ML24057A306
Person / Time
Site:	Braidwood
Issue date:	02/24/2024
From:	Constellation Energy Generation
To:	NRC/RGN-III
Shared Package
ML24057A301	List: BW240007, Attachment 5: BW-MISC-062 Rev. 0 - Braidwood Station Unit 2 Diesel Driven AFW MAAP Calculations ML24057A302 ML24057A303 ML24057A304 ML24057A305 ML24057A306
References
BW240007 BW-SDP-006, Rev 0
Download: ML24057A306 (1)

Text

RM DOCUMENTATION NO. BW-SDP-006, Rev. 0 PAGE NO.1

STATION: Braidwood UNIT(S) AFFECTED: UNIT2

TITLE: Braidwood 28 AF Pump Fuel Oil Leak SDP Sensitivities

SUMMARY

This document describes the FPIE and FPRA modeling, associated results, and sensitivities discussed in reference to the 2B AF pump fuel oil leak at Braidwood.

URE(s) Impacted: None Number of pages: 32 gages, including this gage.

RM Document Level: Level 1, ger ER-AA-600-1012 [1].

Internal RM Documentation Electronic Calculation Data Files: BW-SDP-006_R0_Attachment.zip, 83,176 KB, 2/24/2024, 9:45 AM

Co-Prepared by: Andrew Christensen / Signed Via Email /2/24/2024 Print Sign Date

Co-Prepared by: Ethan Graven / Signed Via Email /2/24/2024 Print Sign Date

Co-Prepared by: Usama Farradj / Signed Via Email /2/24/2024 Print Sign Date

Co-Prepared by: Lynn Kolonauski / Signed Via Email /2/24/2024 Print Sign Date

Reviewed by: Adam Harden / Signed Via Email /2/24/2024 Print Sign Date

Reviewed by: Donald Vanover / Signed Via Email /2/24/2024 Print Sign Date

Approved by: Roy Linthicum / Signed Via Email /2/24/2024 Print Sign Date

Method of Review: [ X] Detailed [] Alternate This RM documentation supersedes: N/A in its entirety.

External RM Documentation Prepared by: N/A I I

- Print Sign Date Approved by: N/A I I

- Print Sign Date Do any ASSUMPTIONS I ENGINEER/NG JUDGEMENTS require later verification? [] Yes [ X] No Tracked By: AT#, URE# etc.)

Braidwood Unit 2

2B AF Pump Fuel Oil Leak SDP Sensitivities

CONTACTS Braidwood

Site Risk Mgmt Engineer Andrew Christensen (773) 718-6601

Fleet. Risk Mgmt Engineer Ethan Graven (224) 422-9458

Internal Events Model Owner Adam Harden

Fire PRA Model Owner Usama Farradj

2 Table of Contents

1.0 EVENT OVERVIEW....................................................................................................................................................4

2.0 MAJOR PRA MODEL REFINEMENTS FOR THE SDP.................................................................................................... 4 2.1 FPIE.................................................................................................................................................... 4 2.2 FPRA.................................................................................................................................................. 5

3.0 RESULTS................................................................................................................................................................... 5

4.0 SENSITIVITIES........................................................................................................................................................... 5 4.1 FLEX HEP Sensitivity......................................................................................................................... 5 4.2 28 AF Pump Failure Probability Sensitivity........................................................................................ 9 4.3 Sensitivity Results............................................................................................................................... 9 4.4 Impact from External Events............................................................................................................. 11 4.5 Additional Sensitivity......................................................................................................................... 11 4.6 Key Conservatisms........................................................................................................................... 12

5.0 CONCLUSION

S........................................................................................................................................................ 12

6.0 REFERENCES

........................................................................................................................................................... 13

APPENDIX A FPIE AND FPRA HEP CHANGES................................................................................................................. 14

APPENDIX B ADDITIONAL MODEL CONSERVATISMS.................................................................................................... 26

APPENDIX C SENSITIVITY CALCULATIONS AND EXTERNAL HAZARDS EXTRAPOLATION................................................ 30

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1.0 Event Overview Elevated fuel content was identified in the 2B Auxiliary Feedwater (AF) diesel engine lube oil sample during quarterly sampling. A confirmatory sample determined the fuel content was above fault limits and could not be evaluated to be acceptable. An emergent 72-hour LCO entry was made to perform repairs which found fuel leaks at compression fittings on 2 fuel injector return lines and exited on 9/23/2023. The fuel lines and fittings were originally replaced during preventative maintenance during A2R23 (spring 2023). The last previous in-range oil sample was taken on 5/19/2023. Fuel leaks were identified on fuel injectors that had been refurbished at Paragon, Inc. The 16 units were returned to stock at Byron Station on March 27, 2023, PO 1390618 was issued to Paragon March 29, 2023, and repair units were received back onsite at Braidwood Station from Paragon on April 17, 2023. Material condition deficiencies with refurbished fuel injectors, including fuel injector cap sealing surface defects and degraded O-ring, resulted in diesel fuel leaking into the diesel engine oil.

Testing was performed on a Detroit Diesel Series 149 diesel engine to determine if the 2B AF diesel engine could have performed its safety function of driving the 2B AF pump and other connected equipment for a period of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The engine started with fuel oil diluted lubricating oil representative of the 2B AF engine conditions and operated in this condition for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, with additional fuel oil being added to the lube oil during the test to represent the September 2023 as-found condition. Based on the successful performance of the test engine with the fuel oil diluted lube oil and MPR's evaluation determining the test addressed all of the likely engine failure modes, MPR concluded that there is reasonable assurance the Braidwood 2B AF Pump Diesel Drive would have performed its safety function of driving the 2B AF pump and other connected equipment for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> [1]

Based on this testing, the 2B AF pump would have met its PRA success criteria and PRA mission time.

Therefore, the 2B AF pump would be considered available for the duration of the SOP exposure period.

Following IMC 0609 Appendix A Exhibit 2, the 2B AF pump would have maintained its PRA functionality and would screen as Green [2]. The following PRA model refinements, results, and sensitivities are provided under the assumption that the pump would not have met its mission time, in the event the NRC does not agree that PRA success criteria and PRA mission time are met.

2.0 Major PRA Model Refinements for the SDP 2.1 FPIE The major model refinements made to the FPIE model are as follows:

• Refined support system initiating event (SSIE) fault trees to improve quantification times

• Included loss of ESF AC bus initiators as general transients o Controlled shutdown following loss of ESF AC bus would not need to recognize loss of secondary cooling as FW is available during shutdown.

• Incorporated more credit to the DC crosstie to opposite unit DC bus, specifically adding credit for DC crosstie (train A; train B already credited) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of associated battery charger not being energized.

o Credited the DC bus 111 to 211 DC crosstie (for controlled shutdown following loss of ESF AC bus initiating events only).

• Medium Head (MH) FLEX pump credit to supply flow to Steam Generators (SGs) from the RWST, including credit to the N+1 FLEX pump after 4 successful hours of the first FLEX pump.

• Updated loss of AC power recovery values for SOP Exposure Period 1 due to credit from ~2 hour 2B AF pump demonstrated run time during Exposure Period 1

• Updated various HEPs due to credit for ~2 hour 2B AF pump demonstrated run time during Exposure Period 1. Refer to Appendix A for additional details.

• Updated various HEPs due to applying a 10% probability that operators fail to manually trip the unit within 30 seconds of a total loss of Main Feedwater, as opposed to allowing the unit to automatically trip on low SG level.

o Applied to both the base case and Exposure Period 2

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o Refer to Appendix A for additional details 2.2 FPRA The major model refinements made to the FPRA model are as follows:

• Scenarios where no reactor trip was anticipated, for U1 (relative to the availability of the U1 cross tie to support U2) and for U2 received a conservative 0.1 unit trip probability.

• 11.4C-0 Rad Waste Control Room fire modeling refinements, specifically the size and spread of fires in this zone and how they impact the Unit 1 cables in the zone

• MH FLEX pump credit to supply flow to SGs from the Refueling Water Storage Tank (RWST),

including credit to the N+1 FLEX pump after 4 successful hours of the first FLEX pump.

• Updated various HEPs due to credit from ~2 hour 2B AF pump demonstrated run time during Exposure Period 1. Refer to Appendix A for additional details.

• Updated various HEPs due to applying a 10% probability that operators fail to manually trip the unit within 30 seconds of a total loss of Main Feedwater, as opposed to allowing the unit to automatically trip on low SG level.

o Applied to both the base case and Exposure Period 2 o Refer to Appendix A for additional details.

3.0 Results Table 3.0-1 below shows the results of Braidwood's FPIE and FPRA models following the refinements discussed in Section 2. These models were quantified with average maintenance and with the 2B AF pump Fail to Run event set to TRUE. The exposure period is split up into 2 different periods: Exposure Period 1 is the time before September 1 and Exposure Period 2 is the time after September 1. There are different PRA results before and after September 1 because the 2B AF pump ran for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on September 1. Exposure Period 1 credits this proven run time while Exposure Period 2 does not.

Table 3.0-1: SOP Results End FPIE FPRA FPIE FPRA Exposure Total State Delta Delta Time (Days)

Base CDF 7.1 E-06 2.7E-05 N/A N/A N/A N/A Case LERF 1.2E-07 3.3E-06 N/A N/A N/A N/A

Exposure CDF 1.6E-05 3.7E-05 8.5E-06 1.0E-05 105 5.4E-06 Period 1 LERF 3.6E-07 4.4E-06 2.5E-07 1.1 E-06 105 3.9E-07

Exposure CDF 1.9E-05 5.6E-05 1.2E-05 2.9E-05 22 2.5E-06 Period 2 LERF 4.6E-07 6.5E-06 3.4E-07 3.2E-06 22 2.1 E-07

Total CDF 127 7.9E-06 Exposure LERF 127 6.0E-07 Period

4.0 Sensitivities 4.1 FLEX HEP Sensitivity After detailed discussions and walkdowns, the NRC has challenged the acceptability of deploying the MH FLEX pump to pull suction from the RWST to supply the SGs. While a detailed human error probability (HEP) calculation for failing to deploy the MH FLEX pump has been completed, the challenge that the NRC has presented is understood. Therefore, the sensitivity increased the execution timing for the HEP calculation. These adjusted HEPs were then used to quantify the FPIE and FPRA models associated with Exposure Period 1. These results are summarized in Section 4.3.

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The timing used to calculate the probability that the operators fail to align the MH FLEX pump includes 5 parts:

1. The length of time for operators to decide to use FLEX per 2BwFR-H.1 - 19 minutes

2. The time to set up the high head FLEX pump - 132 minutes

3. The amount of extra time required to establish procedure steps to align the MH FLEX pump. Base case assumes an additional 20 minutes for this part of the action and this is included in the execution time.

4. The additional time required to set up the MH FLEX pump discharge hoses - 23 minutes

5. The amount of time required to depressurize the SG that will be fed with the MH FLEX pump - 20 minutes

Interval 1 - Before Operations decides to use FLEX, they must rule out the use of the AF crosstie. This, along with making the decision to use FLEX, was simulated by the Operations day shift on 12/10/23 and was determined to be 19 minutes. This time is included in Tcielay depicted in Table 4.1-1 as a 20 minute value.

Intervals 2-4 cover the MH FLEX pump alignment. The reason the high head FLEX pump execution timing is used in Interval 1 is because that action was validated as part of the ELAP FLEX strategy.

OP-BR-102-106 Rev 015 reports this timing under FTSA#8 as 132 minutes. This timing reflects the high head FLEX pump pulling suction from the RWST. Interval 3 reflects the extra time required to establish procedure steps to align the MH FLEX pump to the RWST. Sensitivity to this assumption is explored in Table 4.1-1. Finally, when aligning the MH FLEX pump to pull suction from the RWST, additional discharge hose staging is required for the pump to discharge into the SGs. Therefore, an additional 23 minutes is included as Interval 4. This time was simulated by the day shift on 12/10/23.

Interval 5 - The length of time to depressurize the SGs sufficiently such that the MH FLEX pump can inject flow is accounted for and takes 20 minutes.

Table 4.1-1: Differing Additional Time Applied Due to Procedural Complexity and AF Pump Run Times, with Resulting Action Timing and HEPs In ut Parameters HEP Values Case Available Times Time Required to Establish Procedure Steps to Ali n Medium Head FLEX Pum AFW Tsw Tdelay Tsw-20 Min 30 Min 40 Min 50 Min Pump Run (Min) (Min) Tdelay Time Min 1.88 Hours 350 132 218 6.3E-02 2.0 Hours 365 140 225 6.3E-02 3.0 Hours 440 200 240 4.7E-02 4.0 Hours 520 260 260 3.9E-02 4.?E-02

• Tree= 0; 2.2E-1 is the HEP value with no recovery. Tree= 0 if Tsw is 365 minutes and an additional 50 minutes are used to determine the alignment procedure implementation steps. Note that the MAAP runs quoted in Table 4.1-3 indicate Tsw for 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of AF run time could be as large as 370 minutes and Tsw for 3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of AF run time could be as high as 445 minutes. The Tsw values quoted in Table 4. 1-1 are slightly conservative.

The sensitivity in Table 4.1-1 adds additional time for the assumed extra time needed to establish procedure steps to align the MH FLEX pump and shows the change in HEP when the recovery time is reduced. The HEP naturally increases as execution time increases because the recovery time is shorter, which increases the dependency factor. The HEPs based on recovery time available and associated dependency factor are summarized in Table 4.1-2.

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Table 4.1-2: HEP Based on Recovery Time Available and Associated Dependency Factor

Tree (min) Dependency Factor FLEX HEP

> 60 Zero Dependence 3.9E-02

> 30 and up to 60 Low Dependence 4.7E-02

> 15 and up to 30 Medium Dependence 6.3E-02

> 0 and up to 15 High Dependence 1.2E-01 0 Complete Dependence 2.2E-01 NeQative N/A 1.0

Table 4.1-1 also varies the amount of time the 28 AF pump ran. By increasing this run time, the core will produce less decay heat when the 28 AF pump fails to run. This lengthens the time to core damage, and thus lengthens the system window time as well as the time available to deploy the MH FLEX pump.

Additional recovery time yields lower dependence and lower HEPs. System window times are determined by the thermal hydraulic analysis in Table 4.1-3, which uses MAAP.

Table 4.1-3: MAAP Quantifications Corresponding to Differing AF Pump Run Time

Case BB_506_OSG - BB_506_OSG - BB_506_OSG - BB_506_OSG -

DD188 FLEX1 DD200 FLEX1 DD300 FLEX1 DD400 FLEX1 DDAFW 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> 2 hours 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 4 hours operation time SG dryout 241.4 min 250.1 min 321.3 min 390.1 min

Core 309.6 min 318.3 min 396.1 min 466.9 min uncovery FLEX start 349.6 min 370 min 445 min 520 min time Peak core 1211 °F 1306 °F 1255 °F 1243 °F temperature

The total system window, Tsw, corresponds to the FLEX start time needed to avoid core damage. Delay time, Tdelay, is the 28 AF pump run time plus the time it takes operators to decide to use FLEX. The difference between Tsw and Tdelay is the total amount of time available for operators to complete an action, or Time Required, Tr. The difference between total available time and the time required to execute is Tree, or amount of time available for recovery. Figure 4.1-1 illustrates the timing definitions.

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I System Window, T~w

! Time Required, TR

L R~o~ry time, ~]I Expected Performance Time, ET I *' i

---

....., 1.-I.. ----------.-.... -.**f----------....... -...,- time

t\\:c O ~\\_[~--------

Qpef.1',l,)!f' is cl.HHJ to perform action

\\ _________,----1 -~

loitiatin~ Event Occurs lrre(:ovenble eod state

Figure 4.1-1 Timing Criteria

Credit for the ~2 hour 2B AF pump run time provides enough margin to credit the MH FLEX pump deployment. Additionally, earlier in the total exposure period, the 2B AF pump demonstrated at least 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of run time, incrementally decreasing as monthly test runs were completed. Table 4.1-4 shows this demonstrated run time.

Table 4.1-4: 28 AF Pump Demonstrated Runtime Date Run Time (Hours) 6/8/2023 0.61 7/14/2023 0.57 8/10/2023 0.52 9/1/2023 1.88 Total 3.58

Along with the greater than 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run time from the Detroit Diesel test, the 2B AF pump run times currently credited in the analysis are bounding. Credit for additional run time could substantially influence the assumed boundary conditions in this analysis.

On 12/10/23, the day shift on Braidwood Unit 2 walked through a simulated operator response of what they would do after the 2B AF pump tripped after a unit trip, and the 2A AF pump, FW restoration, and the AF crosstie were all unavailable. They recognized the need to restore SG feed in time to prevent core damage would be the major objective and the MH FLEX pump pulling suction from the RWST would be faster than the using the low head FLEX pump pulling suction from the lake to supply the MH FLEX pump. The crew identified they would use the MH FLEX pump but noted concerns due to supplying the SGs with contaminated RWST water. They recognized the Shift Manager would have implemented 1 O CFR 50.54(x) which allows Operations to make decisions outside of procedures in order to protect the health and safety of the public. One identified strategy was to supply the MH FLEX pump via the fire protection system, if it were available, which would be substantially quicker than connecting the FLEX pump to the RWST and would alleviate contamination concerns. This would also alleviate the need to connect the 3400' of 5" hose required to connect the low head FLEX pump drafting off of the cooling lake to supply the MH FLEX pump, should this suction supply option be selected as described in the

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procedure. However, the crew would pursue alternate success paths in parallel provided the operator resources were available.

The operations crews are made up of highly trained individuals dedicated to protecting the health and safety of the public. If the crew lost AF, FW restoration, and the AF crosstie, they would not stop attempting alternative strategies to restore secondary cooling. While these additional operator actions were not quantified in the FPIE and FPRA models, these operator actions should be qualitatively considered in tandem with the modeled operator actions.

The discussion above demonstrates a realistic pathway towards cooling the core in the understood scenario. Operations has stated that by implementing 10 CFR 50.54(x), they would implement non proceduralized actions to protect the health and safety of the public. This includes different suction sources for the MH FLEX pump, like the Fire Protection header. While the implementation of 10 CFR 50.54(x) does introduce some level of unpredictability in operator response, operators are trained to cool the core in any way possible. While they may not take the exact actions discussed in the HEP development above, they would take action. The purpose of this HEP sensitivity is to bound this uncertainty. The sensitivity results, included in Section 4.3, considers 3 HEPs for the MH FLEX pump HFE: 0.063 (nominal or medium dependence, as shown in Table 4.1-2), 0.3, and 1.0 (no flex credit).

4.2 28 AF Pump Failure Probability Sensitivity The example Detroit Diesel testing report shows that the 2B AF pump would have met its PRA mission time and would have been considered available for the duration of the SOP exposure period. However, an additional sensitivity, modifying the 2B AF pump failure rate, is included to address any proposed uncertainty regarding the Detroit Diesel engine testing. The results of this sensitivity are included in Tables 4.3-1 through 4.3-6.

4.3 Sensitivity Results The tables below contain the results of several sensitivity studies. The FLEX HEP described in Section 4.1 is varied from its nominal value of 0.063 to 0.3 to 1.0 (True). Additionally, the 2B AF pump FTR value is varied from 0.1 to 0.5 to 1.0 (True). Tables 4.3-1 and 4.3-2 show the ~CDF and ~LERF values for the FPIE model sensitivity results, respectively. Similarly, Tables 4.3-3 and 4.3-4 show the ~CDF and ~LERF values for the FPRA model sensitivity results, respectively. Finally, the FPIE and FPRA results are combined in Tables 4.3-5 and 4.3-6 for ~CDF and ~LERF, respectively.

Due to the Detroit Diesel test running for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the pump is assumed to run for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the duration of the exposure period. Therefore, the values in these tables use the Exposure Period 1 refinements for the entire 127-day duration. This is different from the SOP calculation in Table 3.0-1, which uses the Exposure Period 2 base over the entire exposure period. The base from Exposure Period 1 was used because it credits the MH FLEX pump strategy and the demonstrated 2B AF pump/engine run time. This yields a lower base metric and therefore larger and more conservative difference between the base and sensitivity CDF and LERF.

Appendix C provides additional detail for the sensitivity calculations.

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Table 4.3-1 FPIE LiCDF Sensitivities FLEX HEP 0.063 0.3 TRUE 2BAF 0.1 2.?E-07 3.6E-07 4.8E-07 Pump 0.5 1.6E-06 1.8E-06 2.0E-06 Failure TRUE Probability 3.2E-06 3.5E-06 4.0E-06

Table 4.3-2 FPIE LiLERF Sensitivities FLEX HEP 0.063 0.3 TRUE 2BAF 0.1 7.?E-09 9.9E-09 1.3E-08 Pump 0.5 4.6E-08 5.1E-08 5.8E-08 Failure TRUE Probability 9.3E-08 1.0E-07 1.1 E-07

Table 4.3-3 FIRE LiCDF Sensitivities FLEX HEP 0.063 0.3 TRUE 2BAF 0.1 4.2E-07 7.3E-07 1.3E-06 Pump 0.5 2.2E-06 3.3E-06 5.2E-06 Failure TRUE Probability 4.0E-06 6.2E-06 9.6E-06

Table 4.3-4 FIRE b.LERF Sensitivities FLEX HEP 0.063 0.3 TRUE 2BAF 0.1 4.5E-08 7.3E-08 1.3E-07 Pump 0.5 2.3E-07 3.2E-07 5.0E-07 Failure TRUE Probability 4.3E-07 6.3E-07 9.3E-07

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Table 4.3-5 TOTAL LiCDF Sensitivities FLEX HEP 0.063 0.3 TRUE 28AF 0.1 6.9E-07 1.1 E-06 1.SE-06 Pump 0.5 3.?E-06 5.0E-06 7.2E-06 Failure TRUE Probability 7.2E-06 9.?E-06 1.4E-05

Table 4.3-6 TOTAL LiLERF Sensitivities FLEX HEP 0.063 0.3 TRUE 28AF 0.1 5.3E-08 8.3E-08 1.5E-07 Pump 0.5 2.?E-07 3.?E-07 5.6E-07 Failure TRUE Probability 5.3E-07 7.3E-07 1.0E-06

4.4 Impact from External Events The NRC provided 3 tiCDF data points for their external, high winds and seismic contributions to the SDP determination: 9.5E-7, 6.5E-7, and 5E-7. These values are highlighted in Table 4.4-1. 9.5E-7 is the base case, and then the NRC provided a sensitivity with the FLEX HEP set to 0.063 and 0.5 for the 2B AF pump FTR value. In lieu of trying to reproduce the modifications that were made to the SPAR model, an extrapolation is performed. The first step was to extrapolate to the top right value first. Then, the other values are derived after assigning their FLEX sensitivity to the bottom left as an anchor point.

T bl 4 4 1 LiCDF a e - ue o eIsmIc, IQ In s, an dT d d t S.. H. h w* d orna oes FLEX HEP 0.063 0.3 TRUE 28 AF Pump 0.1 2.2E-07 2.?E-07 4.1 E-07 Failure Probability 0.5 3.4E-07 4.3E-07 6.5E-07 TRUE 5.0E-07 6.3E-07 9.5E-07

Adding these extrapolated results to Table 4.3-5 leads to the following:

T bl 4 4 2 T t I LiCDF. I d. S. a e - oa, inc u InQ eIsmIc, IQ In s, an H. hW. d dT d orna oes FLEX HEP 0.063 0.3 TRUE 28 AF Pump Failure 0.1 9.1 E-7 1.4E-6 2.2E-6 Probability 0.5 4.1 E-6 5.5E-6 7.9E-6 TRUE 7.7E-6 1.0E-5 1.5E-5

4.5 Additional Sensitivity An additional sensitivity is included in Table 4.5-1 that shows the LiCDF and LiLERF representing the 2B AF pump FTR probability set to 0.053 (twice the nominal failure probability) and no MH FLEX pump credit. Since there is no MH FLEX pump credit, the Exposure Period 2 base is used in the LiCDF and LiLERF calculations, which is more appropriate for this sensitivity case. Only the case in which FLEX is not credited is performed, because these results bound any case that credits FLEX. The LiCDF for Seismic, High Winds, and Tornadoes uses the same extrapolation methodology described in Section 4.4.

yielding a conservative addition of 3.SE-07 to the total shown in Table 4.5-1.

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Appendix C provides additional detail for the sensitivity calculations.

T bl 4 5 1 AddT IS T *t R a e - 11ona ens1 IVl[Y It esu s FPIE FIRE Seismic, High Winds, Total and Tornadoes LlCDF 9.0E-08 3.SE-07 3.8E-07 8.2E-07 LlLERF 2.0E-09 3.8E-08 N/A 4.0E-08

4.6 Key Conservatisms There are conservatisms included in this analysis that should be considered for impacts on results. On 2/8/24, an Operations crew was put in a loss of feedwater scenario in the control room simulator to validate the timing used in the FLEX HEP calculation. The scenario consisted of a total loss of feedwater and failure of AF pumps to start. Operations responded to the loss of feedwater by tripping the unit and entering the Loss of Heat Sink procedure after failing to restart the AF pumps. They simulated sending an equipment operator to open the AF crosstie valves, and then attempted to restart Feedwater and Condensate/Condensate Booster pumps. After those strategies failed, the simulated equipment operator reported back that the AF crosstie valves could not be opened. The control room responded by entering FSG-3 and directing equipment operators to begin aligning the MH FLEX pump.

In summary, the operators took 13 minutes from the LOFW to trip the unit, navigate emergency operating procedures, and finally, direct equipment operators to align the MH FLEX pump for SG feed flow. The fully developed HEP assumes the operators take 20 minutes to arrive at this decision, which is conservative.

Additionally, operators in the control room simulator had to execute post-trip actions in parallel with the AF failure and had the added stress of using multiple procedures simultaneously. In the modeled scenario, the 2B AF pump provides SG feed flow for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the unit trip. In those 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, operators would have completed the post-trip actions and stabilized the unit. This is an additional conservatism because in the control room simulator, the operators had to respond to the unit trip and the loss of heat sink simultaneously.

Finally, by the time the 2B AF pump is assumed to trip at ~2 hours after the unit trip, additional Operations personnel would have reported to the station per administrative procedures in response to the plant trip.

These personnel, who are not credited in the FLEX HEP calculation, would be available to assist in the decision making or execution tasks for the MH FLEX pump alignment.

5.0 Conclusions The results of this analysis provide an overview of the impact of crediting FLEX and the Detroit Diesel testing for the SOP evaluation.

The sensitivity results show that a FLEX HEP of 0.3 or setting the 2B AF pump fail to run probability to 0.5 would yield no greater than a White finding. Considering the Detroit Diesel test ran for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, it is reasonable to conclude that the 2B AF pump would have run for longer than the assumed ~2hours.

Additionally, the operator simulation discussed in Section 4.6 provides high confidence that the FLEX strategy can be implemented.

Additional model conservatisms have also been identified that could lead to additional reductions in the calculated risk for the Detailed Risk Evaluation, which are detailed in Appendix B.

12 BW-SDP-006, Rev. 0

6.0 References

1. 4101-0031-RPT-001 Revision 0, "Test Report and Past Operability Evaluation Braidwood AF Diesel Drive Test with Lube Oil Diluted by Fuel Oil". January 2024

2. NRC Inspection Manual Chapter 0609 Appendix A, "The Significance Determination Process for Findings At-Power". January 2021.

13 d FPRA HEP Changes

) edits made to the FPIE and FPRA models for SOP quantifications. HFEs ending in "-F" signify FPRA HFEs, which have

p1E version.

HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update 1.30.2024 2022 Edits HEPs OPERATORS FAIL TO CLOSE 2.8E-02 3.8E-02 The execution time for the AF crosstie (13 minutes) was OPPOSITE UNIT AF0005 VALVES entered by mistake. The applicable execution time is 6 LOCALLY (LOFW) minutes. This is the time to close the AF005s locally per operator interviews conducted at Byron in May 2009.

OPERATOR FAILS TO XTIE 3.5E-03 #N/A This is a new action developed to replace the original TRAIN A or B DC BUS POWER action 0DC-12-XTIE-HDCOA, OPERATOR FAILS TO FROM OPPOSITE UNIT (NON-XTIE TRAIN B DC BUS POWER FROM OPPOSITE ELAP) UNIT, which was developed for ELAP scenarios.

OPERATORS FAIL TO RESTORE 1.3E-03 1.6E-03 Removed an execution subtask found to be non-critical.

LEVEL TO SX TOWER BASIN The action originally included BOP SX-12 Step F.1.c to (BYRON ONLY) "VERIFY/OPEN 0SX158A/B or 0SX157A/B, Essential Service Water Basin Inlet Valve." This subtask was removed as the SX CT System Notebook (BB-PRA-005.018 R3) states, "The basin makeup valves (0SX157A

& B, 0SX158A & B) are assumed to be normally open, do not need to change position, and therefore are not modeled.

OPS FAILS TO TRIP RCP TO 2.1 E-02 2.9E-02 1 Corrected execution time, Texe, from an overly PROTECT SD SEALS - NO SEAL conservative 5 minutes to 2 minutes based on COOLING Operations input collected on 1.2.2024 during the BW2 AF SOP effort.

OPS FAILS TO TRIP RCP TO 2.1 E-03 2.2E-03 2 Corrected execution time, Texe, from an overly PROTECT NON-SD SEALS - NO conservative 5 minutes to 2 minutes based on SEAL COOLING Operations input collected on 1.2.2024 during the BW2 AF SOP effort.

node! update HEP value was used for the FPIE SOP quantification.

nodel update HEP value was used for the FPIE SOP quantification.

14 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs OPERATORS FAIL TO STOP RH 2.3E-03 6.0E-03 Edited CBOTM element Pee, "Skip a Step in Procedure",

PUMPS (TRANSIENT) to endstate "h". The step was originally treated as 2.6E-03 "hidden" (i.e., endstate "i"), which is considered overly conservative.

Current Pee entry:

- The Note located prior to Step 25 in FRH1 specifically states that the RH pumps should not be run longer than 2.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> without CC flow applied to the RH HX. (Not treated as "hidden".)

- The crew is possibly in more than one procedure, depending on the given scenario. ("Multiple" procedures selected.)

- While the direction is located within a Note with a border, it is not considered to be graphically distinct.

-While the BBW operators use the circle/slash method of placekeeping and this method satisfies the requirements of Constellation procedure HU-AA-104-101, because the 2.4-hour direction is located in a Note and in not in a procedure step, no credit is taken for placekeeping aids.

OPERATORS FAIL TO REFILL 1.4E-04 6.9E-04 1 AF01 PB-FO-HXVOA-F is for refilling the OOAF fuel oil OOAFP FUEL OIL DAY TANK supply for the non-SOP unit (Unit 1). While there is FROM STORAGE TANK 5.7E-04 3 5.7E-03 sufficient time to support the feasibility for TSC activation

("ERF Review" in the HRAC), TSC recovery credit was not applied in the baseline HEP calc as an Alert was not assured for every scenario in which this action is credited. TSC activation is justified and applied in the SOP scenario.

,.5E-04 was used in FPRA quantification.

15 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs SOP INTERVAL 1 HEP EDITS p OPERATORS FAIL TO ALIGN 6.3E-02 N/A This action was developed to reflect use of the MH FLEX FLEX PUMP FOR SG pump taking suction on the RWST for the SDP-1 INVENTORY MAKEUP (GIVEN exposure period. This baseline version adds an 1.88 HR AF SUCCESS, EXEC additional 20 minutes to the execution time for ONLY) communication between the operators executing the alignment and shift Operations management as the execution procedures do not exactly match the non-ELAP scenario and step omissions will be needed.

Given the cue timing, the same HEP applies for FPIE and Fire.

OPERATORS FAIL TO CLOSE 1.4E-03 N/A Tsw: With AF success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />, reestablishing SG OPPOSITE UNIT AF0005 VALVES feed by the 349.6 minute (5.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />) point allows LOCALLY (1.88 HR AF 2.2E-03 avoidance of core damage per MAAP run credit)_SDP BB_506_OSG_DD188_FLEXh. This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

OPERATORS FAIL TO EXECUTE 2.5E-03 N/A Tsw: With AF success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />, reestablishing SG AF CROSSTIE FROM OPPOSITE feed by the 349.6 minute (5.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />) point allows UNIT (EXE ONLY; 1.88 HR AF 2.?E-03 avoidance of core damage per MAAP run credit)_SDP BB_506_OSG_DD188_FLEXh. This is past SG dryout as allowed by 2BwFR-H.1 Attachment Band supported by multiple operator interviews.

FIRE - OPERATORS FAIL TO 6.?E-03 N/A Tsw: With AF success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />, reestablishing SG OPEN AF005 VALVES (LOCALLY feed by the 349.6 minute (5.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />) point allows FAIL AIR; LOFW w 1.88 HR AF avoidance of core damage per MAAP run credit)_SDP BB_506_OSG_DD188_FLEXh. This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

OPERATOR FAILS TO START 1.8E-03 N/A Tsw: With AF success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />, reestablishing SG MOTOR-DRIVEN AFW PUMP feed by the 349.6 minute (5.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />) point allows AFTER FAILURE OF DC (1.88 HR 5.2E-02 avoidance of core damage per MAAP run AF credit)_SDP BB_506_OSG_DD188_FLEXh. This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

16 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs OPERATORS FAIL TO LOCALLY 2.3E-03 N/A Tsw: With AF success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />, reestablishing SG START 8 AUXILIARY feed by the 349.6 minute (5.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />) point allows FEEDWATER PUMP (1.88 HR AF avoidance of core damage per MAAP run credit)_SDP 88_506_OSG_DD188_FLEXh. This is past SG dryout as allowed by 28wFR-H.1 Attachment 8 and supported by multiple operator interviews.

OPERATORS FAIL TO MANUALLY 5.4E-04 N/A Tsw: With AF success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />, reestablishing SG START AF PUMPS FROM CR feed by the 349.6 minute (5.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />) point allows (1.88 HR AF credit)_SDP 1.1 E-03 avoidance of core damage per MAAP run 88_506_OSG_DD188_FLEXh. This is past SG dryout as allowed by 28wFR-H.1 Attachment 8 and supported by multiple operator interviews.

OPERATORS FAIL TO 8.1 E-04 N/A Tsw: With AF success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />, reestablishing SG RECOGNIZE THE LOSS OF feed by the 349.6 minute (5.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />) point allows SECONDARY COOLING 7.0E-04 avoidance of core damage per MAAP run (COGNITIVE ONLY; 1.88 HR 88_506_OSG_DD188_FLEXh. This is past SG dryout as AF)_SDP allowed by 28wFR-H.1 Attachment 8 and supported by multiple operator interviews.

OPERATORS FAIL TO RESTORE 1.0E-03 N/A Tsw: With AF success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />, reestablishing SG ALTERNATE FEEDWATER (EXE feed by the 349.6 minute (5.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />) point allows ONLY; 1.88 HRAF credit)_SDP 1.4E-02 avoidance of core damage per MAAP run 88_506_OSG_DD188_FLEXh. This is past SG dryout as allowed by 28wFR-H.1 Attachment 8 and supported by multiple operator interviews.

OPERATORS FAIL TO EXECUTE 2.4E-04 N/A Tsw: For the 8&F action for the SDP-1 interval (AF TO OPEN PZR PORVS FOR 8/F success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />), MAAP run COOLING (EXE ONLY; 1.88 HR 2.8E-02 88506_ 1 PORV _ 1SI_DDAFW188d indicates core AF credit)_SDP damage can be avoided if 8&F is initiated within 204.0 minutes. This is NOT prior to SG dryout.

FIRE - OPS FAILS TO OPEN PZR 2.4E-04 N/A Tsw: For the 8&F action for the SDP-1 interval (AF PORVS FOR 8/F COOLING (EXE success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />), MAAP run ONLY, LOFW w 1.88 HR AF credit, 88506_ 1 PORV _ 1SI_DDAFW188d indicates core Pe Recovery)_SDP damage can be avoided if 8&F is initiated within 204.0 minutes. This is NOT prior to SG dryout.

17 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs OPERATORS FAIL TO INITIATE SI 1.5E-04 N/A Tsw: For the B&F action for the SDP-1 interval (AF FOR BLEED AND FEED success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />), MMP run COOLING (EXE ONLY; 1.88 HR 1.0E-02 BB506_ 1 PORV _ 1SI_DDAFW188d indicates core AF credit)_SDP damage can be avoided if B&F is initiated within 204.0 minutes. This is NOT prior to SG dryout.

FIRE - OPERATORS FAIL TO 1.5E-04 N/A Tsw: For the B&F action for the SDP-1 interval (AF INITIATE SI FOR BLEED AND success for 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />), MMP run FEED COOLING (EXE ONLY, BB506_ 1 PORV _ 1SI_DDAFW188d indicates core LOFW w 1.88 HR AF credit, Pe damage can be avoided if B&F is initiated within 204.0 Recovery) SOP minutes. This is NOT prior to SG dryout.

BASE CASE AND SOP INTERVAL 2 HEP EDITS

cenarios, the original baseline actions for SG feed restoration and Bleed and Feed (B&F) used a system window that reflected N SG level at -45 seconds. Operator interviews and observed simulator scenarios identified that the BBW crews are trained to insert

Jiately upon the recognition of the total loss of feed condition. The SG Feed restoration and B&F actions were revised to reflect a split reactor trip at 30 seconds with a failure rate of 10%. That is, the HEPs for total LOFW initiators and failure of AF were numerically

[0.1 *(HEPsase) + 0.9*(HEPsoP-2)]

1e baseline HEPs associated with the common cognitive action, 1 FW-FRH1-FHSGOA, all used the time to optimized B&F as a zed B&F time is 30 minutes for scenarios that only credit the automatic plant trip on low SG level. This is conservative for SG feed

~un BB_NoBF _Scram_AutoC (LOFW with no AFW and automatic plant trip on low SG level) indicates that the SGs will retain

>red by 39.9 minutes.

OPERATORS FAIL TO CLOSE 1.4E-03 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual OPPOSITE UNIT AF0005 VALVES reactor trip upon recognition of the LOFW. If AFW is LOCALLY (LOFW w 30s trip)_SDP initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

G OPERATORS FAIL TO CLOSE 6.6E-03 3.8E-02 Tsw: MMP Run BB_NoBF _Scram_AutoC (LOFW with OPPOSITE UNIT AF0005 VALVES no AFW and automatic plant trip on low SG level)

LOCALLY (LOFW)_SDP indicates that the SGs will retain inventory if SG feed is restored by the 39.9 minute point. (Note the 2022 HEP value includes the higher Texe value which was corrected in the SOP effort and in the working copy of the HRAC.)

18 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs OPERATORS FAIL TO EXECUTE 2.5E-03 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual AF CROSSTIE FROM OPPOSITE reactor trip upon recognition of the LOFW. If AFW is UNIT (EXE ONLY; LOFWw 30s initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is trip)_SDP avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

3 OPERATORS FAIL TO EXECUTE 2.1 E-02 7.0E-02 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFWwith AF CROSSTIE FROM OPPOSITE no AFW and automatic plant trip on low SG level)

UNIT (EXE ONLY; LOFW)_SDP indicates that the SGs will retain inventory if SG feed is restored by the 39.9 minute point.

OPERATORS FAIL TO OPEN 4.0E-02 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual AF005 VALVES (LOCALLY FAIL reactor trip upon recognition of the LOFW. If AFW is AIR; LOFW w 30s trip)_SDP initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

~ OPERATORS FAIL TO OPEN 4.1 E-02 9.7E-02 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with J

AF005 VALVES (LOCALLY FAIL no AFW and automatic plant trip on low SG level)

AIR; LOFW)_SDP indicates that the SGs will retain inventory if SG feed is restored by the 39.9 minute point.

OPERATOR FAILS TO START 1.SE-03 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual MOTOR-DRIVEN AFW PUMP reactor trip upon recognition of the LOFW. If AFW is AFTER FAILURE OF DC (LOFW w initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is 30s trip)_SDP avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

RIG OPERATOR FAILS TO START 7.SE-03 2.SE-02 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with MOTOR-DRIVEN AFW PUMP no AFW and automatic plant trip on low SG level)

AFTER FAILURE OF DC indicates that the SGs will retain inventory if SG feed is (LOFW) SOP restored by the 39.9 minute point.

19 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs OPERATORS FAIL TO LOCALLY 2.3E-03 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual START B AUXILIARY reactor trip upon recognition of the LOFW. If AFW is FEEDWATER PUMP (LOFW w 30s initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is trip)_SDP avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

~IG OPERATORS FAIL TO LOCALLY 9.6E-03 1.5E-02 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with START B AUXILIARY no AFW and automatic plant trip on low SG level)

FEEDWATER PUMP (LOFW)_SDP indicates that the SGs will retain inventory if SG feed is restored by the 39.9 minute point.

OPERATORS FAIL TO MANUALLY 5.4E-04 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual START AF PUMPS FROM CR reactor trip upon recognition of the LOFW. If AFW is (LOFWw 30s trip)_SDP initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

RIG OPERATORS FAIL TO MANUALLY 8.7E-04 1.7E-03 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with START AF PUMPS FROM CR no AFW and automatic plant trip on low SG level)

(LOFW)_SDP indicates that the SGs will retain inventory if SG feed is restored by the 39.9 minute point.

OPERATORS FAIL RECOGNIZE 8.1 E-04 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual THE LOSS OF SECONDARY reactor trip upon recognition of the LOFW. If AFW is COOLING (COGNITIVE ONLY; initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is LOFW w 30s trip_no AF)_SDP avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

IIG OPERATORS FAIL RECOGNIZE 2.2E-03 3.3E-03 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with THE LOSS OF SECONDARY no AFW and automatic plant trip on low SG level)

COOLING (COGNITIVE ONLY; indicates that the SGs will retain inventory if SG feed is LOFW) SOP restored by the 39.9 minute point.

20 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs OPERATORS FAIL TO RESTORE 1.0E-03 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual ALTERNATE FEEDWATER (EXE reactor trip upon recognition of the LOFW. If AFW is ONLY; LOFWw 30s trip)_SDP initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

~IG OPERATORS FAIL TO RESTORE 1.0E-02 3.6E-02 Tsw: MMP Run BB_NoBF _Scram_AutoC (LOFW with ALTERNATEFEEDWATER(EXE no AFW and automatic plant trip on low SG level)

ONLY; LOFW)_SDP indicates that the SGs will retain inventory if SG feed is restored by the 39.9 minute point.

OPERATORS FAIL TO EXECUTE 2.4E-04 N/A Tsw: MMP run BB_LatestBF _Scram_30A, indicates that TO OPEN PZR PORVS FOR B/F the latest time for B&F to prevent core damage with a COOLING (EXE ONLY; LOFWw manual plant trip at 30 seconds and without SG feed is 30s trip) SOP 71.4 minutes.

, OPERATORS FAIL TO EXECUTE 4.2E-03 4.2E-03 Tsw: In order to avoid core damage, bleed and feed TO OPEN PZR PORVS FOR B/F would have to be initiated by 30 minutes (Tsw) per BBW COOLING (EXE ONLY; MMP run BB0007c (LOFW with no AFW and automatic LOFW) SOP plant trip on low SG level).

OPERATORS FAIL TO INITIATE SI 1.5E-04 NIA Tsw: MMP run BB_LatestBF _Scram_30A, indicates that FOR BLEED AND FEED the latest time for B&F to prevent core damage with a COOLING (EXE ONLY; LOFWw manual plant trip at 30 seconds and without SG feed is 30s trip) SOP 71.4 minutes.

OPERATORS FAIL TO INITIATE SI 1.6E-03 1.6E-03 Tsw: In order to avoid core damage, bleed and feed FOR BLEED AND FEED would have to be initiated by 30 minutes (Tsw) per BBW COOLING (EXE ONLY; MAAP run BB0007c (LOFW with no AFW and automatic LOFW) SOP plant trip on low SG level).

FIRE - OPERATORS FAIL TO 1.7E-03 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual CLOSE OPPOSITE UNIT AF005 reactor trip upon recognition of the LOFW. If AFW is VALVES LOCALLY (LOFWw initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is manual trip at 30s)_SDP avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

21 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs

~IG FIRE - OPERATORS FAIL TO 2.SE-02 1.0 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with CLOSE OPPOSITE UNIT AF005 no AFW and automatic plant trip on low SG level)

VALVES LOCALLY (LOFWTsw indicates that the SGs will retain inventory if SG feed is used for Fire) SOP restored by the 39.9 minute point.

FIRE - OPERATORS FAIL TO 2.SE-03 4 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual ALIGN AF XTIE FROM OPPOSITE reactor trip upon recognition of the LOFW. If AFW is UNIT (EXE ONLY; LOFWw 30s initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is trip)_SOP avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

~IG FIRE - OPERATORS FAIL TO 6.6E-02 7.0E-02 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFWwith ALIGN AF XTIE FROM OPPOSITE no AFW and automatic plant trip on low SG level)

UNIT (EXE ONLY; LOFWTsw used indicates that the SGs will retain inventory if SG feed is for Fire) SOP restored by the 39.9 minute point.

FIRE - OPERATORS FAIL TO 6.7E-03 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual OPEN AF005 VALVES (LOCALLY reactor trip upon recognition of the LOFW. If AFW is FAIL AIR; LOFWw 30s trip)_SOP initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is avoided. (Max core temperature node of 1796F). This is I past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

FIRE - OPERATORS FAIL TO 1.7E-02 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual OPEN AF005 VALVES (LOCALLY reactor trip upon recognition of the LOFW. If AFW is FAIL AIR; LOFWw 30s trip)_SOP initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is avoided. (Max core temperature node of 1796F). This is 1 past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

'.IG FIRE - OPERATORS FAIL TO 5.2E-02 2.8E-01 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with OPEN AF005 VALVES (LOCALLY no AFW and automatic plant trip on low SG level)

FAIL AIR; LOFWTsw used for indicates that the SGs will retain inventory if SG feed is Fire) SOP restored by the 39.9 minute point.

.7E-03 was used in FPRA quantification.

22 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs FIRE - OPS FAILS TO START MD 2.2E-03 5 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual AFW PUMP AFTER FAILURE OF reactor trip upon recognition of the LOFW. If AFW is DC (LOFW w 30s trip)_SDP initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is avoided. (Max core temperature node of 1796F). This is past SG dry out as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

ORIG FIRE - OPS FAILS TO START MD 1.0E-02 9.5E-02 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with AFW PUMP AFTER FAILURE OF no AFW and automatic plant trip on low SG level)

DC (LOFW Tsw used in Fire)_SDP indicates that the SGs will retain inventory if SG feed is restored by the 39.9 minute point.

FIRE - OPERATORS FAIL TO 1.1E-03 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual MANUALLY START AF PUMPS reactor trip upon recognition of the LOFW. If AFW is FROM CR (LOFW w 30s trip)_SDP initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

RIG FIRE - OPERATORS FAIL TO 1.5E-03 4.9E-03 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFW with MANUALLY START AF PUMPS no AFW and automatic plant trip on low SG level)

FROM CR (LOFW Tsw used in indicates that the SGs will retain inventory if SG feed is Fire) SDP restored by the 39.9 minute point.

FIRE - OPERATORS FAIL 7.0E-04 NIA Tsw: MAAP run BB_LatestBF _Scram_30A, indicates that RECOGNIZE THE CUE TO the latest time for B&F to prevent core damage with a SECONDARY COOLING (LOFW w manual plant trip at 30 seconds and without SG feed is 30s trip)_SDP 71.4 minutes. After this time, RCS injection flow cannot prevent core damage when the bleed path is opened.

RIG FIRE - OPERATORS FAIL 8.5E-03 8.3E-03 Tsw: MAAP Run BB_NoBF _Scram_AutoC (LOFWwith RECOGNIZE THE CUE TO no AFW and automatic plant trip on low SG level)

SECONDARY COOLING (LOFW indicates that the SGs will retain inventory if SG feed is Tsw used for Fire) SDP restored by the 39.9 minute point.

,.2E-02 was used in FPRA quantification.

23 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs FIRE - OPERATORS FAIL TO 6.7E-03 6 N/A Tsw: BB_NoBF _Scram30E includes credit for a manual RESTORE ALTERNATE reactor trip upon recognition of the LOFW. If AFW is FEEDWATER (EXE ONLY; LOFW initiated by 2.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> (147.6 minutes) core damage is w 30s trip)_SDP avoided. (Max core temperature node of 1796F). This is past SG dryout as allowed by 2BwFR-H.1 Attachment B and supported by multiple operator interviews.

HIG FIRE - OPERATORS FAIL TO 3.SE-02 4.5E-02 Tsw: MMP Run BB_NoBF _Scram_AutoC (LOFWwith RESTORE ALTERNATE no AFW and automatic plant trip on low SG level)

FEEDWATER (EXE ONLY; LOFW indicates that the SGs will retain inventory if SG feed is Tsw used in Fire) SOP restored by the 39.9 minute point.

FIRE - OPS FAILS TO OPEN PZR 2.SE-02 N/A Tsw: In order to avoid core damage, feed and bleed PORVS FOR B/F COOLING (EXE would have to be initiated by 71.4 minutes (Tsw) per ONLY; LOFWw 30s trip; NO Pe BBW MMP run BB_LatestBF _Scram_30A.

rec) SOP IG FIRE - OPS FAILS TO OPEN PZR 2.SE-02 2.SE-02 Tsw: In order to avoid core damage, bleed and feed PORVS FOR B/F COOLING (EXE would have to be initiated by 30 minutes (Tsw) per BBW ONLY; LOFWTsw; NO Pe MAAP run BB0007c (LOFW with no AFW and automatic recovery) SOP plant trip on low SG level).

FIRE - OPS FAILS TO OPEN PZR 2.4E-04 N/A Tsw: In order to avoid core damage, feed and bleed PORVS FOR B/F COOLING (EXE would have to be initiated by 71.4 minutes (Tsw) per ONLY, LOFWw 30s trip, Pe BBW MMP run BB_LatestBF _Scram_30A.

Recovery) SOP

IG FIRE - OPS FAILS TO OPEN PZR 4.2E-03 4.2E-03 Tsw: In order to avoid core damage, bleed and feed PORVS FOR B/F COOLING (EXE would have to be initiated by 30 minutes (Tsw) per BBW ONLY, LOFW Tsw, Pe MMP run BB0007c (LOFW with no AFW and automatic Recovery) SOP plant trip on low SG level).

FIRE - OPERATORS FAIL TO 1.0E-02 NIA Tsw: In order to avoid core damage, feed and bleed INITIATE SI FOR BLEED AND would have to be initiated by 71.4 minutes (Tsw) per FEED COOLING (EXE ONLY: BBW MMP run BB_LatestBF _Scram_30A.

LOFW w 30s trip, NO Pe rec) SOP

.4E-02 was used in FPRA quantification.

24 HEP EDITS MADE SINCE 2022 BBW FPIE UPDATE

HFE Description HEPs Update Edits 1.30.2024 2022 HEPs

FIRE - OPERATORS FAIL TO 1.0E-02 1.0E-02 Tsw

In order to avoid core damage, bleed and feed INITIATE SI FOR BLEED AND would have to be initiated by 30 minutes (Tsw) per BBW FEED COOLING (EXE ONLY: MAAP run BB000?c (LOFW with no AFW and automatic LOFW Tsw used in Fire, NO Pe plant trip on low SG level).

rec) SOP FIRE - OPERATORS FAIL TO 1.5E-04 N/A Tsw: In order to avoid core damage, feed and bleed INITIATE SI FOR BLEED AND would have to be initiated by 71.4 minutes (Tsw) per FEED COOLING (EXE ONLY, BBW MAAP run BB_LatestBF _Scram_30A.

LOFW w 30s trip, Pe RECV) SOP

~ FIRE - OPERATORS FAIL TO 1.6E-03 1.6E-03 Tsw: In order to avoid core damage, bleed and feed INITIATE SI FOR BLEED AND would have to be initiated by 30 minutes (Tsw) per BBW FEED COOLING (EXE ONLY, MAAP run BB0007c (LOFW with no AFW and automatic LOFW Tsw, Pe RECV) SOP plant trip on low SG level).

25

,al Model Conservatisms nements have been identified but were not pursued in the model used to generate SOP results. These refinements are md Table 4.2-2, with the Fussel Vesely metrics associated with the refinement to show relative importance and potential

~d risk.

Table 4.2-1: FPIE Additional Model Conservatisms with Estimated Delta Risk Reductions

)nservatisms Exposure Period 1 Risk Reduction Exposure Period 2 Risk Reduction

) AF pump on U1 not available due 0.15% 1%

ance, can be removed since there luring exposure period.

onservative value of 0.1 for pre-1% N/A system, lower value applicable for 1/o, assume a reduction of a factor of

ts a bounding value applicable to all

equipment, not the specific s SOP (MH pump to S/G, not Jattery chargers and HH pump for '

k reduction 1% 1%

fable 4.2-2: FPRA Additional Model Conservatisms with Estimated Delta Risk Reductions

)nservatisms Exposure Period 1 Risk Reduction Exposure Period 2 Risk Reduction for Exposure Period 2, although it is N/A 10%

np could have run for some length and JHEPs for AF related actions.

26 fable 4.2-2: FPRA Additional Model Conservatisms with Estimated Delta Risk Reductions

)nservatisms Exposure Period 1 Risk Reduction Exposure Period 2 Risk Reduction

• pump could have operated for 10% NIA J 1.88 hour0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> demonstrated run time

~ Period 1. Improved HEPs and tions.

s of MFW and reactor trip for all fire 10% 10%

Jtion of those to which a reactor trip

'or a U1 or U2 trip - a risk reduction the ASM-BW-009, Rev. 2, rhe reduction of risk due to Jment with unknown location, no

~ss specific basis for credit is ler of a 10% risk reduction from the duction due to incorporation of cable xder of half this value. However, the P configuration which is driven by

~moval would be expected to be

d and Feed requires 1 SI pump and NIA 3%

lpport a change in success criteria V. Quantification is based on the Ji res 1 SI pump and 2 PO RVs for tivity indicated that the reduction in was small, ~1 % for Exposure are expected for Exposure Period 2.

27 fable 4.2-2: FPRA Additional Model Conservatisms with Estimated Delta Risk Reductions

>nservatisms Exposure Period 1 Risk Reduction Exposure Period 2 Risk Reduction failure data. 10% N/A

.EX system, currently 0.1 value with 4% N/A i Period 1.

) AF pump on U1 not available due 10% 17%

ance, can be removed since there luring exposure period.

onservative value of 0.1 for pre-9% N/A system, lower value applicable for o, assume a reduction of a factor of

ts a bounding value applicable to all

equipment, not the specific s SOP (MH pump to S/G, not Jattery chargers and HH pump for

,corporate EPRI realism NUREGs, 10% 10%

G-2233 ites use of the AF crosstie after a potentially not trivial, not yet quantified potentially not trivial, not yet quantified llow credit for an emergency diesel

> pump to be donated to Unit 2 via imps supply the Unit 1 AF needs, ind their support systems are not

probability for non-severe panel 5% 6%

rol room fires

28 fable 4.2-2: FPRA Additional Model Conservatisms with Estimated Delta Risk Reductions Jnservatisms Exposure Period 1 Risk Reduction Exposure Period 2 Risk Reduction non-severe panel scenarios, -2.5% -2.5%

f spurious operations. Max increase

29 1ity Calculations and External Hazards Extrapolation

30 SDPcase ExptIme Fire Delta FPIE Delta Total CDF over Total LERF over CDF LERF CDF LERF Delta CDF exp Delta LERF exp 3.64E*07 SOP-1 105 1.0lE-05 1.llE-06 8.54E-06 2 47E-07 1.87E-05 5.39E-06 1.36E-06 3.90E-07 4.SSE-07 5DP-2 22 2.94E-05 3.16E-06 1.18E-05 3.38E-07 4.12E-05 2.49E-06 3.SOE-06 2.llE-07 Total risk over exposure period 7.BBE-06 6.0lE-07 1.17E-07 1.03E-07 SDP-2tor total exp time 127 2.94E-05 3.16E-06 l.18E-05 3.39E-07 4.12E-05 1.43E-05 3.50E-06 1.22E-06

AFPmp TOTAL TOTAL Failure DELTA DELTA DELTA DELTA DELTA DELTA H1ghW1nds, Tornado, Over NewCDF FlexHEP Prob Exp Time FCDF FLERF CDF LERF CDF *127/365 LERF *127/365 and SeIsmIc delta CDF exposure Total

'i244E-07 6.30E-02 0.1 127 l.20E-06 l.30E-07 7.85E-07 2.21E-08 1.98E-06 6.91E-07 1.52E-07 5.29E-08 2.20E-07 2.20E-07 9.llE-07 1407E-07 6.30E-02 0.5 127 6.20E-06 6.50E*07 4.56E-06 1.31E-07 1.0BE-05 3.74E-06 7.BlE-07 2.72E-07 3.40E-07 3.40E-07 4.08E-06 2620E-07 6.30E-02 TRUE 127 1.16E-05 1.25E-06 9.20E-06 2.66E-07 2.08E-05 7.24E-06 1.52E-06 5.27E-07 5.00E-07 5.00E-07 7.74E-06 H46E-07 0.3 0.1 127 2.lOE-06 2.lOE-07 l.02E-06 2.84E-08 3.12E-06 1.09E-06 2.38E-07 8.29E-08 2.70E-07 2.70E-07 1.36E-06

)987E-07 0.3 0.5 127 9.40E-06 9.30E-07 5.09E-06 1.45E-07 1.45E-05 5.04E-06 1.0BE-06 3.74E-07 4.30E-07 4.30E-07 5.47E-06 l410E-07 03 TRUE 127 l.78E-05 l.BlE-06 l.OlE-05 2.90E-07 2.79E-05 9.70E-06 2.lOE-06 7.31E-07 6.30E-07 6.30E-07 l.03E-05 t940E-07 TRUE 0.1 127 3.BOE-06 3.BOE-07 1.39E-06 3.79E-08 5.19E-06 1.BOE-06 4.lBE-07 1.45E-07 4.lOE-07 4.lOE-07 2.21E-06 l587E-07 TRUE 0.5 127 1.49E-05 1.43E-06 5.89E-06 1.67E-07 2.0BE-05 7.23E-06 1.60E-06 5.56E-07 6.SOE-07 6.50E-07 7.BBE-06

'i408E-07 TRUE TRUE 127 2.77E*05 2.67E*06 1.14E-05 3.25E-07 3.91E-05 1.36E-05 2.99E-06 1.04E-06 9.SOE-07 9.SOE-07 l.46E-05 7170E-07 TRUE 0.0534 127 l.OOE-06 l.lOE-07 2.59E-07 5.87E-09 1.26E-06 4.38E-07 1.16E-07 4.03E-08 3.BOE-07 3.BOE-07 8.lBE-07

FPIE LERF FIRECDF FIRELERF 0.063 0.3 TRUE 0.063 0.3 TRUE 0.063 0.3 TRUE 0.0534,:t)i,1,t:tY f°}'l,-*c,.\\. 2.0E*09 0.0534 J.~'1;:,r:;,i;{:- '.'.:~..,:J'w,** 3.SE-07 0.0534} 3.BE-08 0.1 7.7E-09 9.9E-09 1.3E-08 0.1 4.2E-07 7.3E-07 13E-06 0.1 4.SE-08 7 3E-08 1.3E-07 0.5 4.6E-08 5.lE-08 5.BE-08 0.5 2.2E-06 3.3E-06 5.2E-06 0.5 2.3E-07 3.2E-07 5.0E-07 TRUE 9.3E-08 1.0E-07 1.lE-07 TRUE 4.0E-06 6.2E-06 9.6E-06 TRUE 4.3E-07 6.3E-07 9.3E-07

TOT AL LERF over exp Total CDFoverexplncludlngexternal 0.063 0.3 TRUE 0.063 0.3 TRUE 0.0534 4.0E-08 0.0534 ::::h'/.:' 8.2E*07 0.1 5.3E*08 8.3E-08 1.SE-07 0.1 9.lE-07 1.4E-06 2.2E-06 0.5 2.7E-07 3.7E-07 5.6E-07 0.5 4.lE-06 5.5E-06 7.9E-06 TRUE 5.3E-07 7.3E-07 1.0E*06 TRUE 7.7E-06 1.0E-05 1.SE-05 External Events Extrapolation HEP TRUE AF FTR 3.8E-07 0.1 2.2E-07 2.7E-07 4.lE-07 0.5 3.4E-07 4.3E-07 6.SE-07 TRUE 5.0E-07 6.3E-07 9.SE-07 The highlighted cells indicate values provided by the NRC in the initial choice letter. The values on the bottom right were used to extrapolate the values in the rest of the right column. Then, the value in the lower left was used as an anchor point, and the bottom middle value was calculated using linear interpolation. After the bottom row and right column were calculated, the extrapolation was then applied to the other values in the table.

Christensen, Andrew

From: Harden, Adam Sent: Saturday, February 24, 2024 10:14 AM To: Vanover, Donald; Kolonauski, Lynn; Farradj, Usama; Graven, Ethan; Christensen, Andrew

Subject:

RE: BW-SDP-006 RO Signatures

I, Adam Harden, sign BW-SDP-006 Rev. 0 as a qualified reviewer.

ADAM J. HARDEN Staff Engineer II

i F: +'i a i1 c,,,dt~:... 1 C:.i) !G n s~ r: ! : uq tv~s. cc1n

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RE: BW-SDP-006 RO Signatures

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