Text

Eighth 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
	ML17059D493
Person / Time
Site:	LaSalle
Issue date:	02/28/2017
From:	Kaegi G; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, RS-17-019, TAC MF1119, TAC MF1120, TAC MF1121, TAC MF1122
	Download: ML17059D493 (33)
	v • d • e

^- ExeLon Generation Order No. EA-12-049 February 28, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Eighth 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-13-021)

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

7. Exelon Generation Company, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 28, 2014 (RS-14-011)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28, 2017 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-14-209)

9. Exelon Generation Company, LLC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 27, 2015 (RS-15-020)

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-15-211)

11. Exelon Generation Company, LLC 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 049), dated February 26, 2016 (RS-16-023)

12. Exelon Generation Company, LLC Seventh 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 26, 2016 (RS-16-146)

13. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF1121 and MF1122), dated February 21, 2014 14. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF1119, MF1120, MF1121, and MF1122), dated March 23, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

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

Reference 1 requires submission of a status report at six-month intervals following submittal of the Overall Integrated Plan. Reference 3 provides direction regarding the content of the status reports. References 6, 7, 8, 9, 10, 11, and 12 provided the first, second, third, fourth, fifth, sixth, and seventh six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for LaSalle County Station. The purpose of this letter is to provide the eighth six-U.S. Nuclear Regulatory Commission Integrated Plan Report to EA 049 February 28, 2017 Page 3 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 13, and any NRC Audit Report open items contained in Reference 14.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David J. Distel at 610-765-5517.

1 declare under penalty of perjury that the foregoing is true and correct. Executed on the 28 th day of February 2017. Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

LaSalle County Station, Units 1 and 2 Eighth Six-Month Status Report for the Implementation of Order EA 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 - LaSalle County Station NRC Project Manager, NRR - LaSalle County Station Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety Enclosure LaSalle County Station, Units 1 and 2 Eighth 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 (29 pages)

LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Enclosure Introduction LaSalle County Station, Units 1 and 2 developed an Overall Integrated Plan (Reference 1), documenting the diverse and flexible strategies (FLEX), in responseto Reference2. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

NOTE: The "Status" indicated in this document is as of January 27, 2017. This date was chosen to support the development, review, approval and submittal of this report by the required February 28, 2017 due date.

2 Milestone Accomplishments

The Seventh 6-Month Update was submitted in August 2016.

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

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

Submit 6 Month Updates:

COMPLETED Update 1 Aug 2013 COMPLETED Update 2 Feb 2014 COMPLETED Update 3 Aug 2014 COMPLETED Update 4 Feb 2015 COMPLETED Update 5 Aug2015 COMPLETED Update 6 Feb 2016 COMPLETED Update 7 Aug 2016 COMPLETED Update 8 Feb 2017 Complete with this submittal Submit Completion Report (and FIP) Unit 1 Mar 2016 Not Started May 2018 See Section 5 of Feb 2015 this enclosure.

Submit Completion Report Unit 2 May 2017 See Section 5 of this enclosure.

Page 1 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Target Activity Revised Target Activity Completion Status Completion Date Date Modification Development

& Implementation:

Unit 1 Modification Development (All FLEX Phases)

Jan 2015 COMPLETED Jan 2016 Unit 1 Modification Implementation (All FLEX Phases)

Mar 2016 COMPLETED Unit 2 Modification Development (All FLEX Phases)

Jan 2014 COMPLETED Jan 2015 Unit 2 Modification Implementation (All FLEX Phases)

Feb 2015 COMPLETED Procedures:

Create Site-Specific Procedures Feb 2015 COMPLETED Mar 2016 Validate Procedures (NEI 12-06, Sect.

11.4.3) Feb 2015 COMPLETED Mar 2016 COMPLETED Mar 2016 Create Maintenance Procedures Feb 2015 Perform Staffing Analysis Oct 2014 COMPLETED Storage Plan and Construction Feb 2015 COMPLETED FLEX Equipment Acquisition Feb 2015 COMPLETED Mar 2016 Page 2 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Target Revised Target Activity Activity Status Completion Date Completion Date Training Completion Feb 2015 COMPLETED Mar 2016 National SAFER Response Center Operational Dec 2014 COMPLETED Feb 2015 Mar 2018 Unit 1 FLEX Implementation Mar 2016 Started See Section 5 of this enclosure Mar 2017 Unit 2 FLEX Implementation Feb 2015 Started See Section 5 of this enclosure Mar 2018 Full Site FLEX Implementation Mar 2016 Started See Section 5 of this enclosure 4 Changes to Compliance Method Exelon proposes an alternate approach to N E 112-06, Revision 0 for protection of FLEX equipment as stated in Section 5.3.1 (seismic-protection of FLEX equipment), Section 7.3.1 (severe storms with high winds - protection of FLEX equipment), and Section 8.3.1 (impact of snow, ice and extreme cold -

protection of FLEX equipment). This alternate approach is to store "N" sets of equipment in a fully robust building and selected +1 equipment in a commercial building. Note that for LaSalle, most of the

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

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

Page 3 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX MAINTENANCE AND TESTING The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized.

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

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

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

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

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

For Section 5, seismic hazard, Exelonwill also incorporate these actions:

1. Large portable FLEX equipment such as pumps and power supplies will be secured as appropriate to protect them during a seismic event (i.e., Safe Shutdown Earthquake (SSE) level). 2. Stored equipment and structures will be evaluated and protected from seismic interactions to ensure that unsecured and/or non-seismic components do not damage the equipment.

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

(N+1) of on-site FLEX equipment are required. The plant screens in per Sections 5 through 9 for seismic, wind (both tornado and hurricane), snow, ice and extreme cold, and high temperatures. To meet Section 7.3.1.1.a, either of the following is acceptable:

o All equipment (N+1) in a structure(s) that meets the plant's design basis for high wind hazards, or o (N) equipment in a structure(s) that meets the plant's design basis for high wind hazards and (+1) equipment stored in a location not protected for a high wind hazard.

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

Page 4 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX For Section 8, impact of snow, ice and extreme cold, Exelon will also incorporate this action:

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

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

LaSalle has implemented OU-AA-103, Rev. 16, "Shutdown Safety Management Program." OU-AA-103 incorporates the guidance provided in NEI position paper (Ref. 15) entitled "Shutdown/Refueling Modes".

There are no plant specific issues that require any additional plans or actions to meet the guidance of the position paper.

5 Need for Relief/Relaxation and Basis for the Relief /Relaxation Previously, by letter dated February 27, 2014 (Ref. 3), LaSalle County Station requested relaxation from certain schedule requirements of Order EA-12-049 (Ref. 2) related to installation of the severe accident capable containment vent required by Order EA-13-109 (Ref. 6). The NRC granted that schedule relief via letter dated April 15, 2014 (Ref. 4). No additional need for relief/relaxation relative to Order EA 049 has been identified at this time.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan and the Interim Staff Evaluation (ISE) (Ref. 5), and the status of each item.

NOTE: The "Status" indicated below is as of January 27, 2017. This date was chosen to support the development, review, approval and submittal of this report by the required February 28, 2017 due date.

Section Reference Overall Integrated Plan Open Item Status Sequence of Events (p.5)

The times to complete actions in the COMPLETED Events Timeline are based on operating judgment, conceptual Time validation has been designs, and current supporting completed sufficient to analyses. The final timeline will be demonstrate the ability to time validated once detailed designs execute the FLEX are completed and procedures strategies. Validation developed.

results are documented in "LaSalle CC-LA-118-1004, FLEX (BDBEE) Validation Process. CC-LA-118-1004 has been provided in eportal.

Page 5 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Section Reference Overall Integrated Plan Open Item Status Sequence of Events (p.10)

Initial evaluations were used to COMPLETED determine the fuel pool timelines.

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

cooling strategy detailed design.

EC 392196 Rev. 0 "Spent Fuel Pool Uncovery Time for Outage and Online Scenarios" is provided in the eportal.

Sequence of Events (p.10)

Analysis of deviations between Exelon's COMPLETED engineering analyses and the analyses LaSalle County Station, contained in BWROG Document Units 1 and 2 Second NEDC-33771 P, "GEH Evaluation of Six-Month Status Report FLEX Implementation Guidelines and contains the analysis.

documentation of results on Att. IB, "NSSS Significant Reference Analysis Deviation Table." Planned to be LaSalle County Station, completed and submitted with August Units 1 and 2 Second 2013 Six Month Update.

Six-Month Status Report, has been provided in the eportal.

Page 6 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Section Reference Overall Integrated Plan Open Item Status Strategy Deployment (p.11)

Transportation routes will be developed COMPLETED from the equipment storage area to the FLEX staging areas. An administrative LOA-FSG-012, "FLEX program will be developed to ensure Deployment Path Debris pathways remain clear or Removal," identifies the compensatory actions will be deployment routes for the implemented to ensure all strategies FLEX equipment from the can be deployed during all modes of FLEX storage areas.

operation.

Procedure LOS-FSG-SR1, "FLEX Equipment Identification of storage areas and Surveillance," contains a creation of the administrative monthly verification that program are open items.

the FLEX equipment deployment paths are unobstructed.

The LaSalle Station Snow Removal Plan has been updated to ensure these paths are cleared in a timely manner. LaSalle has established a once per four (4) year task to validate the snow removal plan. The verification of the snow removal plan is referenced in the LaSalle FLEX Program document, CC-LA-118-1001.

CC-LA-118-1001, LOA-FSG-012 and LOS-FSG-SR1 are provided in the eportal. Page 7 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Irplementation of FLEX Section Reference Overall Integrated Plan Open Item Status Programmatic Controls (p.12)

An administrative program for FLEX to COMPLETED establish responsibilities, and testing &

Procedure CC-LA-118-maintenance requirements will be 1001, "Site implemented.

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

CC-LA-118-1001 is provided in the eportal.

Core Cooling Phase 1 (p.17)

Additional work will be performed during COMPLETED detailed design development to ensure Suppression Pool temperature will The evaluation (EC 399297, support RCIC operation, in accordance Rev 0) shows that RCIC with approved BWROG analysis, can survive for the first 13 throughout the event.

hours of an ELAP with no plant modifications.

EC 399297 Rev. 0 is provided in the eportal.

Fuel Pool Cooling Phase 1 (p.35)

Complete an evaluation of the spent COMPLETED fuel pool area for steam and The evaluation, condensation.

Calculation L-003968, Rev. 0) has been completed showing habitability conditions in the spent fuel pool area.

Rev. 0, Calculation L-003968 Rev. 0 is provided in the eportal.

Page 8 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Section Reference Overall Integrated Plan Open Item Status Safety Functions Support Evaluate the habitability conditions for COMPLETED Phase 1 (p.44) the Main Control Room and develop a The evaluation (Calculation strategy to maintain habitability.

L-003969 Rev 0) has been completed showing habitability maintained with the incorporation of cooling fans per the developed strategy contained in LOA-FSG-005, "Area Ventilation." Calculation L-003969 Rev.

0 and LOA-FSG-005 are provided in the eportal.

Safety Functions Support Evaluate the habitability conditions for COMPLETED Phase 1 (p.44) the Auxiliary Electric Equipment Room The evaluation (Calculation (AEER) and develop a strategy to L-003969 Rev 0) has been maintain habitability.

completed showing habitability maintained with the incorporation of cooling fans per the developed strategy contained in LOA-FSG-005, Area Ventilation." Calculation L-003969 Rev.

0 and LOA-FSG-005 are provided in the eportal.

Page 9 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Section Reference Overall Integrated Plan Open Item Status Safety Functions Support Develop a procedure to prop open COMPLETED Phase 2 (p.48) battery room doors upon energizing the battery chargers to prevent a LOA-FSG-005, "Area buildup of hydrogen in the battery Ventilation," addresses propping open the rooms. applicable battery room doors. LOA-FSG-005 is provided in the eportal.

Page 10 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Interim Staff Evaluation Open and Confirmatory Items Open Items Item Number Description Status 3.2.3.A Verify the modifications associated with Order COMPLETED EA-13-109 on a Hardened Containment Vent System support the sequence of events and actions Item Closed During associated with the LSCS mitigating strategies.

Onsite NRC Audit (Ref.

14). From 8/28/14 update, ML14248A239:

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

Confirmatory Items Item Number Description Status 3.1.1.2.A Confirm that soil liquefaction will not prevent COMPLETED movement of equipment along transportation paths, Item Closed During Onsite NRC Audit (Ref.

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

FLEX Staging Area and Equipment Deployment Paths." The review focused on whether the licensee's planned deployment and storage location are susceptible to seismically-induced soil Page 11 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Interim Staff Evaluation Open and Confirmatory Items Item Number description Status liquefaction to a degree that will adversely affect the implementation of FLEX strategies following a seismic event. The calculation concludes that all haul path areas are not susceptible to liquefaction with the exception of one localized area near the deployment path associated with the 60X90 FLEX building inside the PA. The calculation stated that the vertical settlement resulting from liquefaction would be approximately 2 inches. The licensee stated that the mobile FLEX equipment vehicles have more than sufficient capacity to traverse 2-inch localized roadway depressions, should they appear following a seismic event. The staff had no further questions regarding liquefaction potential of the FLEX deployment paths.

Implementation of the Hardened Containment Vent System (HCVS) required moving the pre-planned staging area for the FLEX generators due to anticipated dose rates from the HCVS.

Calculation L-004000 documents that the new staging areas are acceptable.

Calculation L-004000 Rev. 0 is provided in the eportal Page 12 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX TV Interim Staff Evaluation Open and Confirmatory Items Item Dumber Description Status 3.1.1.2.B Confirm that the egress path for personnel to reach the COMPLETED FLEX storage building is seismically robust, or multiple Item Closed During egress paths that are not seismically robust are Onsite NRC Audit (Ref.

identified.

14). While on site the NRC staff reviewed and walked down egress and ingress paths for personnel to reach the FLEX storage buildings. The review focused on whether ingress/egress paths are seismically robust and, if not, are multiple paths available. The licensee stated that paths for personnel responding to FLEX equipment storage buildings are partially seismically robust (portions inside seismic structures) and there are multiple paths available for personnel to leave the power block. The staff had no further questions regarding ingress or egress paths for FLEX implementation.

Page 13 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Interim Staff Evaluation Open and Confirmatory Items Item Number Description Status 3.1.1.4.A Confirm that the logistics for equipment transportation, area set up, and other needs for ensuring the equipment and commodities to sustain the site's coping strategies are available from offsite resources.

COMPLETED Item Closed During Onsite NRC Audit (Ref. 14).

AREVA Document No. 51-9233422, "LaSalle County Nuclear Generating Station SAFER Response Plan," Rev. 0, 12/19/14, showed that Staging Area C is the Pontiac Municipal Airport, Pontiac, IL, and the alternate to that (Staging Area D) was the Illinois Valley Regional Airport. LaSalle specific procedure CC-LA-118-1002, "SAFER Response Plan for LaSalle County Generating Station 38-9233758, Revision 1 has changed the Staging Area D to the Braidwood Station owner controlled area. Staging Area B is the plant contractor parking lot.

Exelon Procedure EP-AA-112-400-F-04, "EOF Logistics Manager Checklist," Rev. L, Section 3.7, includes coordination for the SAFER Response Plan, including notifying the facility managers for Staging Areas C and D, obtaining road conditions, becoming the single point of contact for SAFER, and preparing for the arrival of SAFER personnel.

Page 14 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Interim Staff Evaluation Open and Confirmatory Description Iterns Status Item Number Croman Corporation has filed a helicopter flight plan for the route from Pontiac airport to LaSalle. The State of Illinois Plan for Radiological Accidents (IPRA) shows that the State will cooperate with Exelon to provide law enforcement escorts for SAFER vehicles and provide helicopters (if available).

AREVA Document No. 51-9233422, CC-LA-118-1002, and EP-AA-112-400-F-04 are provided in the eportal.

3.1.3.1.A If the licensee credits separation of storage sites to COMPLETED address tornado threats, confirm that the axis of Per Ref. 14 this ISE/Audit separation and distance between storage locations will Item remains open as it provide assurance that a single tornado would not relates to use of a commercial impact all locations if the licensee relies on NEI 12-06, (non- robust) FLEX building Section 7.3.1, configurations I.b or I.c for protection for storage of the N+1 of the portable equipment from the high winds hazard.

equipment. Exelon/LaSalle is proposing the use of an alternate approach in Section 4 of this document.

Therefore, response to this item is complete.

Page 15 of 29 LaSalle County Station, Units 1 and 2 Eighth Six Month Status Report for the Implementation of FLEX Interim Staff Evaluation Open and Confirmatory Items Item Number Description Status 3.2.1.1.A Confirm that benchmarks are identified and discussed COMPLETED that demonstrate that the Modular Accident Analysis Item Closed During Program (MAAP) is an appropriate code for the Onsite NRC Audit (Ref. 14).

simulation of an ELAP event at LSCS.

LS-MISC-025 Rev. 1 was referenced for item closure during the NRC Audit.