0CAN021302, Units 1 and 2 - Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Units 1 and 2 - Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML13063A151
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/28/2013
From:	Jeremy G. Browning Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN021302, EA-12-049
Download: ML13063A151 (103)

Text

r Entergy Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President, Operations Arkansas Nuclear One OCAN021302 February 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

REFERENCES:

1. NRC Order Number EA-1 2-049, Orderto Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents, dated March 12, 2012 (OCNA031206)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with OrderEA-12-049, OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ML12229A174)

3. Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012

4. Initial Status Report in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA-12-049), dated October 26, 2012, (OCAN 101203)

Dear Sir or Madam:

On March 12, 2012, the NRC issued an order (Reference 1) to Entergy Operations, Inc.

(Entergy). Reference 1 was immediately effective and requires provisions for mitigating strategies for beyond-design-basis external events. Specific requirements are outlined in the Enclosure of Reference 1.

Aj~f "67 f

OCAN021302 Page 2 of 2' Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013.

The NRC Interim Staff Guidance (Reference 2) was issued August 29, 2012, and endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Overall Integrated Plan. The purpose of this letter is to provide that Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1.

Reference 3, Section 13, contains submittal guidance for the Overall Integrated Plan.

The enclosure to this letter provides Arkansas Nuclear One's (ANO's) Overall Integrated Plan pursuant to Reference 3.

Reference 4 provided the ANO initial status report regarding Mitigation Strategies for Beyond-Design-Basis External Events, as required by Reference 1. Entergy has not yet identified any impediments to compliance with the Order, i.e., within two refueling cycles after submittal of the integrated plan. Future status reports will be provided as required by Section IV, Condition C.2, of Reference 1.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Stephenie Pyle at 479.858.4704.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2013.

Sincerely, 9Zr be# M j ' j JGB/nbm

Enclosure:

ANO FLEX Overall Integrated Implementation Plan cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS 0-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852

Enclosure to OCAN021302 Arkansas Nuclear One (ANO) Diverse and Flexible Coping Strategies (FLEX)

Overall Integrated Implementation Plan

Enclosure to OCAN021302 Page 1 of 51 ANO FLEX Overall Integrated Implementation Plan General Integrated Plan Elements Determine Applicable In accordance with Reference 1, the Arkansas Nuclear One Extreme External Hazard (ANO) site has been evaluated, and the following applicable hazards have been identified:

Ref: Nuclear Energy Institute (NEI) 12-06

• Seismic events Section 4.0 -9.0

• External flooding JLD-ISG-2012-01 9 Severe storms with high winds Section 1.0

• Snow, ice, and extreme cold

• Extreme heat Entergy Operations, Inc. (Entergy) has reviewed the NEI Diverse and Flexible Coping Mitigation Strategies (FLEX) guidance and determined the hazards that FLEX equipment should be protected from include seismic; flooding; severe storms with high winds; snow, ice and extreme cold; and extreme high temperatures. Entergy has determined the functional threats from each of these hazards and identified FLEX equipment that may be affected. The FLEX storage locations will provide the protection required from these hazards. Entergy is also developing procedures and processes to further address plant strategies for responding to these various hazards.

Seismic:

Per Safety Analysis Report (SAR) seismic input (Reference 4), the seismic criteria for ANO includes two design basis earthquake spectra: operating basis earthquake (OBE) and design basis earthquake (DBE).

The site-specific design response spectra define the vibratory ground motion of the OBE and DBE. The maximum horizontal acceleration for the DBE is 0.20g and the OBE has a maximum horizontal acceleration of 0.10g.

The seismic hazard applies to ANO. As a result, the credited FLEX equipment will be assessed based on the current ANO seismic licensing basis to ensure that the equipment remains accessible and available after a beyond-design-basis external event (BDBEE) and that the FLEX equipment does not become a target or source of a seismic interaction from other systems, structures, or components. The FLEX strategies developed for ANO will include documentation ensuring that any storage locations and deployment routes meet the FLEX seismic criteria.

Enclosure to 0CAN021302 Page 2 of 51 External Flooding:

The types of events evaluated to determine the worst potential flood included (1) probable maximum flood (PMF) due to flood flow at Dardanelle Dam yielding a water level at 358 feet (ft) mean sea level (MSL), (2) catastrophic failure of the closest dam upstream of Dardanelle Dam yielding a water level of 361 ft MSL, and (3) the effect of wind induced waves.

The maximum plant site flood level from any cause is Elevation 361 ft MSL. A flood of the magnitude of the maximum probable flood will be forecast about five days prior to its arrival at the plant site. The plant will be shut down by the time the flood level reaches 354 ft, which is the elevation where flooding of the turbine building would commence. The plant will be shut down using normal shutdown procedures and, during the flood, the operators will maintain the plant in a safe shutdown condition.

In summary, the ANO site is not considered a "dry" site and the flooding hazard is screened in.

High Wind:

Figures 7-1 and 7-2 from NEI 12-06 (Reference 2) were used for this assessment.

The ANO site is located at 350 - 18' N (References 4a and 4b, Sections 2.2.1 and 2.1.1, respectively); therefore, ANO is not susceptible to hurricanes based on its location in Arkansas. The plant site is north of the final contour line shown in Figure 7-1 of NEI 12-06 (Reference 2).

It was determined that the ANO site has the potential to experience damaging winds caused by a tornado exceeding 130 mph. Figure 7-2 of NEI 12-06 (Reference 2) indicates a maximum wind speed of 200 miles per hour (mph) for Region 1 plants, including ANO, which is located at 350-18' N, 930-13' W (References 4a and 4b, Sections 2.2.1 and 2.1.1, respectively). Therefore, high-wind hazards are applicable to the ANO site.

In summary, (1) based on Figure 7-1 of NEI 12-06 (Reference 2), ANO is not susceptible to hurricanes so the hazard is screened out and (2) based on local data and Figure 7-2 of NEI 12-06 (Reference 2), ANO has the potential to experience damaging winds so the hazard is screened in.

Enclosure to 0CAN021302 Page 3 of 51 Snow, Ice, and Extreme Cold:

Per the FLEX guidance, all sites should consider the temperature ranges and weather conditions for their site in storing and deploying their FLEX equipment. That is, the equipment procured should be suitable for use in the anticipated range of conditions for the site, consistent with normal design practices.

Applicability of snow and extreme cold:

NEI 12-06 (Reference 2) states that plants above the 3 5 th parallel should provide the capability to address the impedances caused by extreme snow and cold. The ANO site is located marginally above the 3 5 th parallel at 350-18' N (References 4a and 4b, Sections 2.2.1 and 2.1.1, respectively); therefore, the FLEX strategies must consider the impedances caused by extreme snowfall with snow removal equipment, as well as the challenges that extreme cold temperature may present.

Applicability of ice storms:

The ANO site, located at 350-18 N, 930-13'W (References 4a and 4b, Sections 2.2.1 and 2.1.1, respectively), is not a Level 1 or 2 region as defined by Figure 8-2 of NEI 12-06 (Reference 2); therefore, the FLEX strategies must consider the hindrances caused by ice storms.

In summary, based on the available local data and Figures 8-1 and 8-2 of NEI 12-06 (Reference 2), the hazards of snow, ice, and extreme cold temperatures are screened in for the ANO site.

Extreme Heat:

Per NEI 12-06 (Reference 2), all sites must address high temperatures. Virtually every state in the lower 48 contiguous United States has experienced temperatures in excess of 110*F. Many states have experienced temperatures in excess of 120°F. All sites will consider the impacts of these conditions on the FLEX equipment and its deployment.

The event considered herein is a loss of all alternating current (AC) power as a result of short extreme high temperatures coincident with high electrical grid demands, resultina in reaional blackout. Durina this type of event,

Enclosure to OCAN021302 Page 4 of 51 with the equipment and water inventories in the units operating within the technical specification (TS) limits, no additional limitations on initial conditions/failures/abnormalities are expected.

In summary, per NEI 12-06, all sites will address high temperatures. Therefore, the extreme heat hazard is screened in for ANO.

Key Site assumptions to Assumptions are consistent with those detailed in implement NEI 12-06 NEI 12-06 (Reference 2, Section 3.2.1) and the Executive strategies. Summary of the Pressurized Water Reactor Owners Group (PWROG) Core Cooling Position Paper (OG-12-482).

Ref: NEI 12-06 Section 3.2.1 ANO Site-Specific Assumptions The following assumptions are specific to the ANO site:

Al. Flood and seismic re-evaluations pursuant to the 10 CFR 50.54(f) letter of March 12, 2012 (Reference 1), are not completed and therefore not assumed in this submittal. As the re-evaluations are completed, appropriate issues will be entered into the corrective action system and addressed on a schedule commensurate with other licensing bases changes.

A2. Exceptions for the site security plan or other (license/site-specific) requirements will be addressed in the Flex Support Guidelines (FSGs).

A3. Deployment resources are assumed to begin arriving at hour 6 after the event and the site is assumed to be fully staffed by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

A4. Hardened connections are assumed to be protected and diverse with respect to the applicable hazards.

A5. A flood of the magnitude of the PMF will be forecast about five days prior to the flood's arrival at the plant site. It is assumed that at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are available for the deployment of FLEX equipment for the preparation for a flooding scenario, and that power is available during this time.

A6. Entergy will declare an extended loss of AC power (ELAP) within sufficient time to take actions to stage equipment and initiate coping strategies.

Enclosure to 0CAN021302 Page 5 of 51 A7. No events or single failures of systems, structures, and components in addition to those presented in NEI 12-06 (Reference 2), are assumed to occur immediately prior to or during the event, including security events.

A8. This plan defines strategies capable of mitigating a simultaneous loss of all AC power and loss of normal access to the ultimate heat sink (UHS) resulting from a BDBEE by providing adequate capability to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities at all units on a site. Though specific strategies are being developed, due to the inability to anticipate all possible scenarios, the strategies are also diverse and flexible to encompass a wide range of possible conditions. These pre-planned strategies developed to protect the public health and safety will be incorporated into the unit guidance.

The plant TSs contain the limiting conditions for normal unit operations to ensure that design safety features are available to respond to a design-basis accident and direct the required actions to be taken when the limiting conditions are not met. The result of the BDBEE may place the plant in a condition where it cannot comply with certain TSs and/or with its Security Plan, and, as such, may warrant invocation of 10 CFR 50.54(x) and/or 10 CFR 73.55(p). See Reference 9.

Extent to which the Entergy expects to comply with the guidance in guidance, JLD-ISG-2012-01 JLD-ISG-2012-01 (Reference 3) and NEI 12-06 and NEI 12-06, are being (Reference 2) in implementing FLEX strategies for the ANO followed. Identify any site. See Attachment 1B.

deviations to JLD-ISG-2012-01 and NEI 12-06.

Ref: JLD-ISG-2012-01 Ref: NEI 12-06 Section 13.1

Enclosure to OCAN021302 Page 6 of 51 Provide a sequence of The sequence of events and any associated time events and identify any time constraints are identified for ANO-1 and ANO-2 for constraint required for Modes 1 through 4. See the attached sequence of events success including the timeline (Attachment 1A) for a summary of this information.

technical basis for the time constraint.

Ref: NEI 12-06 Section 3.2.1.7 JLD-ISG-2012-01 Section 2.1 Identify how strategies will Deployment of FLEX equipment is described for each be deployed in all modes. FLEX function in the subsequent sections below and covers all modes.

Ref: NEI 12-06 section 13.1.6 Provide a milestone See attached milestone schedule in Attachment 2.

schedule. This schedule should include:

" Modifications timeline o Phase 1 o Phase 2 o Phase 3

• Procedure guidance development complete o Strategies o Maintenance

• Storage plan (reasonable protection)

• Staffing analysis completion

• FLEX equipment acquisition timeline

• Training completion for the strategies

• Regional Response Centers operational Ref: NEI 12-06 Section 13.1

Enclosure to OCAN021302 Page 7 of 51 Identify how the Equipment associated with these strategies will be programmatic controls will procured as commercial equipment with design, storage, be met maintenance, testing, and configuration control in accordance with NEI 12-06, (Reference 2, Section 11).

Ref: NEI 12-06 Section 11 JLD-ISG-2012-01 The unavailability of equipment and applicable connections Section 6.0 that directly perform a FLEX mitigation strategy will be managed using plant equipment control guidelines developed in accordance with NEI 12-06, (Reference 2, Section 11.5).

Programs and controls will be established to assure personnel proficiency in the mitigation of beyond-design-basis events is developed and maintained in accordance with NEI 12-06, (Reference 2, Section 11.6).

Existing plant configuration control procedures will be modified to ensure that changes to the plant design, physical plant layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies in accordance with NEI 12-06, (Reference 2, Section 11.8).

Procedure Guidance:

Procedures and guidance to support deployment and FLEX coping strategy implementation, including interfaces with emergency operating procedures (EOPs), special events procedures, abnormal operating procedures (AOPs), and system operating procedures, will be coordinated within the site procedural framework. The procedural documentation will be auditable, consistent with generally accepted engineering principles and practices, and controlled within the Entergy document control system.

Entergy is participating with the PWROG to develop and implement the FSGs at ANO in a timeline to support the implementation of FLEX by Fall of 2014 for ANO-1 and by Fall of 2015 for ANO-2. The PWROG has generated these guidelines in order to assist utilities with the development of site-specific procedures to cope with an ELAP in compliance with the requirements of NEI 12-06 (Reference 2).

Actions that maneuver the plant will remain contained within the typical controlling procedures, and the FSGs will be implemented as necessary to maintain the key safety functions of core cooling, containment, and SFP cooling in

Enclosure to 0CAN021302 Page 8 of 51 parallel with the controlling procedure actions.

Maintenance and Testing:

The FLEX mitigation equipment will be initially tested (or other reasonable means used) to verify performance conforms to the limiting FLEX requirements. It is expected that the testing will include the equipment and the assembled sub-system to meet the planned FLEX performance. Additionally, Entergy plans to use the guidance in the maintenance and testing template upon issuance by the Electric Power Research Institute (EPRI).

The template will be developed to meet the FLEX guidelines established in Section 11.5 of NEI 12-06 (Reference 2).

Staffing:

The FLEX strategies documented in the event sequence analysis assume:

" On-site staff are at minimum shift staffing levels

" No independent, concurrent events

• All personnel on-site are available to support site response Entergy plans to address staffing considerations in accordance with NEI 12-06 (Reference 2) to fully implement FLEX at the site.

Configuration Control:

Per NEI 12-06 (Reference 2) and the Interim Staff Guidance (Reference 3), the FLEX strategies must be maintained to ensure that future plant changes do not adversely impact the FLEX strategies. Therefore, Entergy plans to maintain the FLEX strategies and modify existing plant configuration control procedures to ensure changes to the plant design, physical plant layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies.

Enclosure to OCAN021302 Page 9 of 51 Describe training plan Training plans will be developed for plant groups such as the emergency response organization (ERO), fire, security, emergency planning (EP), operations, engineering, mechanical maintenance, and electrical maintenance. The training plan development will be done in accordance with ANO site procedures using the Systematic Approach to Training and will be implemented to ensure that the required Entergy ANO site staff is trained prior to implementation of FLEX. The training program will comply with the requirements outlined in Section 11.6 of NEI 12-06 (Reference 2).

Describe Regional The industry is expected to establish two Regional Response Center plan Response Centers (RRCs) to support utilities during beyond design basis events. Each RRC is expected to hold five sets of equipment; four of which should be able to be fully deployed when requested; the fifth set would have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local assembly area, established by the Strategic Alliance for FLEX Emergency Response (SAFER) team and the utility. Communications will be established between the affected nuclear site and the SAFER team and required equipment moved to the site as needed. First arriving equipment, as established during development of the nuclear site's playbook, is expected to be delivered to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the initial request.

Entergy will negotiate and execute a contract with the SAFER for the ANO site which will meet the requirements of NEI 12-06 (Reference 2, Section 12).

Notes: N/A

Enclosure to OCAN021302 Page 10 of 51 Maintain Core Cooling and Heat Removal Determine Baseline coping capability with installed coping1 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

• Emergency Feedwater (EFW)

• Depressurize Steam Generator (SG) for Makeup with Portable Injection Source

• Sustained Source of Water Ref: JLD-ISG-2012-01 Sections 2 and 3 PWR-Installed Equipment Phase 1 During a station blackout (SBO), operator actions are currently governed by the applicable SBO procedures. Heat is removed from the core through the SG using the atmospheric dump valves (ADVs)/main steam safety valves, with the SG being fed by the turbine-driven EFW pumps at both units. Following loss of remote control of the ADV and the turbine-driven EFW pump, local manual action is possible and will be used to continue plant control consistent with current procedures. The "Q" condensate storage tank (QCST) will supply inventory for both units but will require modification to assure wind-generated missile protection or be supplemented with a source independent of wind-generated missile effects.

Cooldown for ANO-1 is deferred until the reactor coolant system (RCS) inventory control is assured. This strategy is being confirmed through the planned reanalysis underway with the PWROG, which modifies the current Babcock and Wilcox Nuclear Steam Supply System (NSSS) generic analysis of Reference 7. ANO-2 will initiate an early cooldown consistent with the Reference 7 assumptions.

The turbine-driven EFW pumps will be utilized by both units to provide condensate flow from an event-qualified source to supply the SGs. The turbine-driven EFW pumps are located in the auxiliary building (AB). The building is designed to withstand the effects of earthquakes, tornadoes, floods, external missiles, and other appropriate natural phenomena.

Power supplied to the turbine-driven EFW pump, valve operators, and other necessary support systems is independent of AC power sources.

The QCST (T-41 B; shared by both units) is sufficient for decay heat removal (DHR) without crediting water remaining in the SGs post-trip.

The ADVs need to be opened in order to remove the steam generated from the SGs and support the natural circulation cooling. For ANO-1, each main steam line, between the reactor building penetration and the corresponding main steam isolation valve (MSIV), is provided with spring-loaded safety valves and air-operated dump valves which discharge to atmosphere. This arrangement permits controlled release of steam for RCS cooling when the MSIVs are closed.

1 Coping modifications consist of modifications installed to increase initial coping time, i.e.,

generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to 0CAN021302 Page 11 of 51 This will be accomplished by manual operation either from the control room, or by using local operation.

For ANO-2, two sets of steam dump bypass system ADVs and isolation valves are provided in the main steam lines upstream of the MSIVs, one set in each main steam line. This arrangement permits controlled release of steam for RCS cooling when the MSIVs are closed. This can be accomplished by local operation.

Phase 1 core heat removal during Modes 5 and 6 will follow existing procedural guidance for loss of DHR/shutdown coolinc (SDC) system capability.

Details:

Provide a brief Existing procedures/strategies/guidelines will be revised to description of Procedures consider FSGs.

/ Strategies / Guidelines Identify modifications 1. None Key Reactor Parameters 1. SG Level

2. SG Pressure

3. QOCST Level

4. RCS Pressure

5. Core Exit Thermocouples (CETs)

6. RCS Temperature Notes: The key parameters will either be monitored from the control room or taken locally.

Enclosure to OCAN021302 Page 12 of 51 Maintain Core Cooling and Heat Removal PWR Portable Equipment Phase 2 The transition into Phase 2 for core heat removal will only be required if the operating conditions of the turbine-driven EFW pump cannot be maintained. In preparation of this postulated occurrence, the primary strategy involves staging a FLEX pump to deliver coolant to both SGs. The seismically-qualified QCST is available for several hours.

As the QCST depletes, portable diesel-driven pumps will be staged to transfer inventory to the QCST. Preferred sources of inventory include the ANO-1 and ANO-2 condensate storage tanks (CSTs), the ANO-2 reactor water makeup tank (RMWT), and the ANO-1 raw water hold-up tank (RWHT), which each are non-seismically-qualified and are not assured of availability in all event cases. Suction from the emergency cooling pond (ECP), the Dardanelle Reservoir, and the cooling tower will provide an indefinite source of inventory via an inventory transfer pump.

Support of core heat removal during conditions without SGs available will follow existing procedural guidance (References 8a, 8b, and 8c) for loss of DHR/SDC system capability. During conditions without SGs available, SG feed pumps would be utilized as RCS makeup pumps due to the higher flow demand required.

Diesel fuel required for FLEX equipment will be sourced from available onsite diesel fuel storage tanks for both ANO-1 and ANO-2.

Conceptual routings for reactor core cooling and heat removal strategies with SGs available (Modes 1 through 4) are contained in Attachment 3.

Conceptual routings for transfer of inventory to the QCST are contained in Attachment 3.

Conceptual routings for core heat removal with SGs not available (Modes 5 and 6) are contained in .

Details:

Provide a brief Procedures and guidance to support deployment and description of Procedures implementation including interfaces to existing site

/ Strategies / Guidelines procedures/strategies/guidelines will be developed in accordance with NEI 12-06 (Reference 2, Section 11.4). Further, the PWROG is developing generic and NSSS-specific FSGs. The FSGs developed for ANO will align with the PWROG guidance.

Identify modifications 1. The ANO-1 and ANO-2 primary and secondary connection points for the FLEX SG feed pump discharge during Modes 1 through 4 would be accessible locations on the EFW system.

2. The ANO-1 and ANO-2 primary and secondary FLEX SG feed pump suction for Modes 1 through 4 would require connections from the QCST piping to the pump.

Enclosure to OCAN021302 Page 13 of 51 Maintain Core Cooling and Heat Removal PWR Portable Equipment Phase 2

3. Missile protection beyond the current barrier of the QCST or connection to a wind-generated missile independent source.

4. Hose and/or piping connection(s) between alternate water sources and the QCST or QCST piping.

Key Reactor Parameters 1. SG Level

2. SG Pressure

3. QCST Level

4. RCS Pressure

5. CETs

6. RCS Temperature Notes: The key parameters will either be powered from batteries and monitored from the control room or taken locally.

Enclosure to OCAN021302 Page 14 of 51 Storage Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic The FLEX equipment storage location(s) will withstand the NEI 12-06 (Reference 2) hazards as applicable to ANO.

Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Design In all external events, a deployment strategy is planned that will deliver FLEX equipment to the appropriate event-determined staging area.

In the specific case of a flooding event, it is expected that several days' notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of portable FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location to the primary staging locations via the train bay.

All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will be utilized for deploying any portable FLEX equipment.

Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A strategy to clear debris for FLEX coping strategies will be implemented.

Strategy Modifications Protection of connections The ANO-1 and ANO-2 event ANO-1 and ANO-2 primary The primary and secondary strategies are to rely upon the and secondary connections piping connections are installed turbine-driven EFW are required to the EFW /located to be protected from pumps with inventory from the system and the QCST piping. the event specific conditions.

QCST;

Enclosure to 0CAN021302 Page 15 of 51 The plant will steam through the Potential use of the FLEX SG The FLEX connections will be ADV with either remote or local feed pump for Modes 5 and 6 constructed to withstand the manual control of the valves and would require discharge NEI 12-06 (Reference 2) the turbine-driven EFW pump; connections to ANO-1 high hazards as applicable to pressure injection (HPI) and ANO.

Transition to FLEX SG feed pump ANO-2 high pressure safety is possible; injection (HPSI)/charging piping.

The FLEX SG feed pumps will feed the SG through connection into normal EFW piping; Primary and secondary staging locations address all external event possibilities; Primary staging is located in the AB at the end of the train bay. The ANO-1 secondary staging location will be outside the southwest corner of the AB on ground level. The ANO-2 secondary staging location will be outside the northwest corner of the AB on ground level.

The strategy, previously described, is used for Modes 1 through 4, but for Modes 5 and 6 (SGs not available), the SG FLEX feed pump is used for RCS makeuo.

If any other alternate water source Hose and/or piping The FLEX connections will survives the event (such as the connection(s) will be made be constructed to withstand ANO-1 and ANO-2 CSTs, the between alternate water the NEI 12-06 (Reference 2)

ANO-2 RMWT, and the ANO-1 sources and the QOCST or hazards as applicable to the RWHT, the ECP, the Dardanelle QCST piping. (It should be specific water source.

Reservoir, and the cooling tower), noted that no modifications it can provide additional inventory will be required for the ECP, to the QCST. Dardanelle Reservoir, or the cooling tower.)

Notes: N/A

Enclosure to OCAN021302 Page 16 of 51 Maintain Core Cooling and Heat Removal PWR Portable Equipment Phase 3 It is calculated that the decay heat is able to maintain the required steam pressure to the turbine-driven EFW pump for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if provided acceptable sources of SG feed. Because condensate-grade water sources, diesel fuel supplies, and other large equipment cannot be assured to be on site, strategies for delivery of off-site equipment from the RRC must be developed. This strategy credits that back-ups to the Phase 2 equipment will be delivered from the RRC to be on-site during Phase 3 should any Phase 2 equipment fail during the indefinite coping period.

Alternate water sources were evaluated for their capability to extend SG feed time after plant trip.

The primary water source is the QCST. Site alternate water sources include the CSTs for ANO-1 and ANO-2, the ANO-1 RWHT, the ANO-2 RMWT, Dardanelle Reservoir, and ECP.

Phase 3 strategies and the equipment necessary are independent of operational mode at the start of the event. The strategy will involve accessing the UHS with inventory through the service water system (SWS) to one of the DHR/SDC system heat exchangers, combined with re-powering one of the DHR/SDC system pumps.

Details:

Provide a brief FSGs will be developed to support the Phase 3 core cooling and description of Procedures heat removal strategies.

/ Strategies / Guidelines Identify modifications A hose connection for an RRC pump will be installed in order to supply water from the UHS through the installed SWS piping, and discharging back into the UHS.

Key Reactor Parameters 1. SG Level

2. SG Pressure

3. QCST Level

4. RCS Pressure

5. CETs

6. RCS Temperature Notes: N/A Deployment Conceptual Design Deployment strategies for Phase 3 equipment will be determined during detailed design.

Strategy Modifications Protection of connections A hose connection for an RRC A hose connection to the UHS The FLEX connections will be pump will be used to supply for an RRC pump will be constructed to withstand the water from the UHS through installed. NEI 12-06 (Reference 2) the installed SWS piping and hazards as applicable to ANO.

discharge back into the UHS.

Enclosure to OCAN021302 Page 17 of 51 Maintain Core Cooling and Heat Removal PWR Portable Equipment Phase 3 The RRC will provide debris None N/A removal equipment capable of clearing paths blocked by large debris. Any further level of design of this equipment will not be completed during the conceptual design phase, and will need to be completed during detailed design.

Notes: N/A

Enclosure to OCAN021302 Page 18 of 51 Maintain RCS Inventory Control Determine Baseline coping capability with installed coping2 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

• Low Leak reactor coolant pump (RCP) Seals or RCS makeup required

• All Plants Provide Means to Provide Borated RCS Makeup PWR-Installed Equipment Phase 1:

Based on the current conditions and performance of the RCP seals, RCP seal leakage is not anticipated to be an immediate concern. Under scenario conditions, it is not currently possible to add RCS inventory for either unit. This issue arises days into the event since ANO plans to cool down post-event; however, the capability to provide RCS makeup remains a Phase 2 action. The FLEX-phased approach will provide a means to add inventory to the RCS, but it will occur in Phase 2.

On loss of DHR for Modes 5 and 6 (no SGs available), ANO will seal containment and let the RCS heat up and eventually start boiling. A strategy for RCS makeup will be specified in Phase 2.

The WCAP-17601 (Reference 7) methodology is used to investigate limiting plant-specific scenarios for RCS inventory control, shutdown margin, and Modes 5 and 6 boric acid precipitation control with respect to the guidelines set forth in the NEI FLEX 12-06 (Reference 2) strategies.

RCS Inventory Control:

For ANO-1 RCS inventory control is not required until Phase 2.

ANO-2 has a large accessible volume in the safety injection tanks (SITs) and is implementing a cooldown and depressurization strategy consistent with the PWROG Core Cooling recommendations for the ELAP scenario.

RCS Shutdown Margin:

For ANO-1 cooldown is not anticipated during Phase 1; therefore, shutdown margin is not applicable.

ANO-2 has adequate shutdown margin and therefore, does not need to take actions to provide additional negative reactivity during an ELAP event for RCS temperatures in excess of 3500 F.

For temperatures less than this value, or conditions outside the constraints of NEI 12-06 (Reference 2), such as a failure to insert control rods, additional boration may be required.

2 Coping modifications consist of modifications installed to increase initial coping time, i.e.,

generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to OCAN021302 Page 19 of 51 Maintain RCS Inventory Control Details:

Provide a brief Existing procedures/strategies/guidelines will be revised to description of Procedures consider FSGs.

/ Strategies / Guidelines Identify modifications ANO-2 SIT level power supply will need to be added to the batteries.

Key Reactor Parameters 1. RCS Pressure

2. ANO-2 SIT Level

3. Pressurizer Level (Modes 1 - 4)

4. Reactor Vessel Level (Modes 5 and 6)

Notes: The key parameters will either be powered from batteries and monitored from the control room or taken locally.

Enclosure to 0CAN021302 Page 20 of 51 Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

RCS inventory control and boration in Modes 1 through 4 will be provided by using a FLEX RCS makeup pump to inject borated water into the HPI or makeup system for ANO-1 and the HPSI or charging system for ANO-2 in Phase 2 of the FLEX strategies. The strategy to facilitate cool down is to pump boric acid solution from the ANO-1 boric acid addition tank (BAAT) and the ANO-2 boric acid makeup tank (BAMT) to the FLEX suction piping that feeds the FLEX RCS makeup pumps. This FLEX supply piping allows the FLEX pumps to draw from the ANO-1 Borated Water Storage Tank (BWST) and ANO-2 Refueling Water Tank (RWT) from both the primary and the secondary staging areas. The FLEX RCS makeup pump will be deployed to maintain RCS inventory to maintain Natural Circulation Cooling (NCC). The primary and secondary RCS makeup strategies share a common injection connection into the RCS.

ANO-2 is capable of re-powering the charging pumps since they are 480V-powered components once the FLEX generator is installed. ANO-2 can supply RCS makeup utilizing these pumps with suction from the RWT.

During Modes 5 and 6 with SGs not available, the FLEX SG feed pumps will be utilized for RCS makeup due to their higher volume capacity with like connections.

Conceptual routings for RCS inventory control are contained in Attachment 3.

Conceptual routings for RCS inventory control with SGs not available (Modes 5 and 6) are contained in Attachment 3.

RCS Shutdown Margin:

For ANO-1 existing analyses indicates that the minimum BWST volume and concentration, required by TS 3.5.4, is sufficient to borate from hot full power critical boron concentration to cold shutdown (2000 F) without letdown and thus, satisfy the 10CFR50 Appendix R requirement concerning boration without RCS letdown. The intended FLEX makeup capability supports the inventory makeup capability in existing analyses.

For ANO-2 this was discussed in Phase 1.

RCS Mode 5 and Mode 6 Boric Acid Precipitation Control The first concern for an ELAP during shutdown conditions is the selection of a makeup pump with sufficient capacity to match the expected steaming rate. The second concern is when to provide flushing flow in order to prevent the precipitation of boric acid. The capacity of the makeup provided during these modes addresses these concerns.

Details:

Provide a brief FSGs will be developed to support the Phase 2 strategies for RCS description of Procedures inventory control.

/ Strategies / Guidelines

Enclosure to 0CAN021302 Page 21 of 51 Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

Identify modifications 1. The ANO-1 primary and secondary FLEX RCS makeup pump suction requires a connection to BWST/BAAT piping.

2. The ANO-1 primary and secondary FLEX RCS makeup pump discharge requires a connection to RCS HPI/makeup piping.

3. The ANO-2 primary and secondary FLEX RCS makeup pump suction location requires a connection to RWT/BAMT piping.

4. The ANO-2 primary and secondary FLEX RCS makeup pump discharge requires a connection to HPSI/charging piping.

5. For Modes 5 and 6 use of the FLEX SG feed pump would require discharge connections to ANO-1 HPI and ANO-2 HPSI/charging piping.

6. ANO-2 SIT level power supply will need to be added to the batteries.

7. Missile protection for BWST and RWT (potential modification required based on analysis).

Key Reactor Parameters 1. RCS Pressure

2. ANO-2 SIT Level

3. Pressurizer Level (Modes 1 - 4)

4. Reactor Vessel Level (Modes 5 and 6)

Notes: The key parameters will either be powered from batteries and monitored from the control room or taken locally.

Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic The FLEX equipment storage location(s) will withstand the NEI 12-06 (Reference 2) hazards as applicable to ANO.

Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures

Enclosure to OCAN021302 Page 22 of 51 Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

Deployment Conceptual Modification In all external events, a deployment strategy is planned that will deliver any required FLEX equipment to the appropriate event-determined staging area.

In the specific case of a flooding event, it is expected that several days' notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the primary staging locations via the train bay.

All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will all be utilized for deploying any portable FLEX equipment.

Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A ~trnt~nv tn nI~r r1~hri~ fnr Fl FX r~.nninri ~trntpnip~ will ~ imnk~m~nt~d Strategy Modifications Protection of connections For ANO-1, a FLEX RCS ANO-1 primary and secondary The FLEX connections will be makeup pump would inject connections are required to the constructed to withstand the borated water into the RCS HPI/makeup piping and NEI 12-06 (Reference 2)

HPI/makeup system with the BWST/BAAT piping. hazards as applicable to ANO.

suction from the BWST/BAAT. The primary ANO-2 primary and secondary and secondary discharge connections are required to the connections are to be HPSI/charging piping and the hard-piped as much as RWT/BAMT piping.

practical to minimize the required length of high Potential use of the FLEX SG pressure hose. feed pump for Modes 5 and 6 would require discharge connections to ANO-1 HPI and ANO-2 HPSI/charging piping.

ANO-2 SIT level power supply will need to be added to the batteries.

Enclosure to OCAN021302 Page 23 of 51 Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

For ANO-2, a FLEX RCS Missile protection for BWST makeup pump would inject and RWT (potential borated water into the modification required based on HPSI/charging system with analysis).

suction from the RWT/BAMT.

The primary discharge connection is to be hard-piped as much as practical to minimize the required length of high pressure hose.

Primary staging is located in the AB at the end of the train bay. The secondary staging location will be outside the Post Accident Sampling System (PASS) building on ground level.

Modes 5 and 6 (with SGs not available) may require a higher capacity pump, e.g.,

the FLEX SG feed pump.

Notes: N/A

Enclosure to OCAN021302 Page 24 of 51 Maintain RCS Inventory Control PWR Portable Equipment Phase 3:

For Phase 3, Entergy intends to continue with the Phase 2 strategies with additional support and equipment provided by offsite resources. Phase 3 design will be completed during the detailed design phase. If it is determined in the detailed design phase that a mobile boration unit or a mobile water purification system is required these items will be obtained from the RRC.

Details:

Provide a brief FSGs will be developed to support the Phase 3 RCS inventory description of Procedures control strategies.

/ Strategies / Guidelines Identify modifications No modifications are currently identified for Phase 3.

Key Reactor Parameters 1. RCS Pressure

2. ANO-2 SIT Level

3. Pressurizer Level (Modes 1 - 4)

4. Reactor Vessel Level (Modes 5 and 6)

Notes: N/A Deployment Conceptual Modification Deployment strategies for Phase 3 equipment will be determined during detailed design.

Strategy Modifications Protection of connections N/A N/A N/A Notes: N/A

Enclosure to OCAN021302 Page 25 of 51 Maintain Containment Determine Baseline coping capability with installed coping 3 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

" Containment Spray

• Hydrogen igniters (ice condenser containments only)

PWR-Installed Equipment Phase 1:

Containment function is not challenged early in the event; therefore, no actions are required in Phase 1 in support of containment function.

For Modes 5 and 6, containment function will be addressed using current procedural actions of References 8a, 8b, and 8c.

Details:

Provide a brief N/A description of Procedures

/ Strategies / Guidelines Identify modifications N/A Key Containment Containment Pressure Parameters Notes: N/A 3 Coping modifications consist of modifications installed to increase initial coping time, i.e.,

generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to OCAN021302 Page 26 of 51 Maintain Containment PWR Portable Equipment Phase 2:

Containment function is not challenged early in the event; therefore, no actions are required in Phase 2 in support of containment function.

Per the analysis supporting Reference 5, containment is not expected to be challenged for the duration of Phase 2.

For Modes 5 and 6, containment closure will be addressed using current procedural actions of References 8a, 8b, and 8c.

Details:

Provide a brief N/A description of Procedures

/ Strategies / Guidelines Identify modifications N/A Key Containment Containment Pressure Parameters Notes: N/A Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic N/A Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Modification N/A Strategy Modifications Protection of connections N/A N/A N/A Notes: N/A

Enclosure to OCAN021302 Page 27 of 51 Maintain Containment PWR Portable Equipment Phase 3:

Using RRC equipment for restoration of SW to containment cooling, containment function will not be challenged even later in the event; therefore, no further actions are required in Phase 3 in support of containment function.

For Modes 5 and 6, containment closure will be addressed using current procedural actions of References 8a, 8b, and 8c.

Details:

Provide a brief FSGs will be developed to support the Phase 3 containment description of Procedures strategies as needed.

/ Strategies / Guidelines Identify modifications N/A Key Containment Containment Pressure Parameters Deployment Conceptual Modification Strategy Modifications Protection of connections The large UHS pump delivered No additional modification. N/A from the RRC will utilize the same SWS connections to establish flow to the containment coolers; the large generator will support loads of the containment cooler fans.

The RRC will provide debris None N/A removal equipment capable of clearing paths blocked by large debris. Any further level of design of this equipment will not be completed during the conceptual design phase, and will need to be completed during detailed design.

Notes: N/A

Enclosure to OCAN021302 Page 28 of 51 Maintain SFP Cooling Determine Baseline coping capability with installed coping 4 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Makeup with Portable Injection Source PWR-Installed Equipment Phase 1:

SFP cooling is not challenged early in the event for either unit.

During phase 1, SFP cooling will be by boil-off of inventory in the pool. SFP makeup will be addressed in phase 2, but during phase 1 a makeup hose will be staged to ensure that makeup capability is available for phase 2.

For ANO-1, for the maximum credible heat load, the time to boil is 3.87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br />. The boil-off rates of 28.10 gpm and 66.50 gpm were determined for normal and maximum decay heat in the SFP, respectively. These values correspond to a required volumetric flow rate of 27.32 gpm and 64.66 gpm, respectively, to replace any boil-off losses in the SFP using water with coolant properties at 1300F.

For ANO-2, for the maximum credible heat load, the time to boil is 2.19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />. ANO-2 SFP has a smaller volume and a higher decay heat load than the ANO-1 SFP. The boil-off rates of 42.92 gpm and 81.73 gpm were determined for normal and maximum decay heat in the SFP, respectively. These values correspond to a required volumetric flow rate of 41.73 gpm and 79.46 gpm, respectively, to replace any boil-off losses in the SFP using water with coolant properties at 130 0 F.

Details:

Provide a brief Procedures/strategies/guidelines will be revised, as necessary, to description of Procedures consider timing of requirements for access to the SFP.

/ Strategies / Guidelines Identify modifications No modifications are required for Phase 1.

Key SFP Parameter SFP Level Notes: The key parameters will either be monitored from the control room or taken locally.

4 Coping modifications consist of modifications installed to increase initial coping time, i.e.,

generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to OCAN021302 Page 29 of 51 Maintain SFP Cooling PWR Portable Equipment Phase 2:

SFP cooling in the ELAP condition is accomplished by local pool boiling and evaporation supported by coolant makeup. SFP cooling is not challenged early in the event (Phase 1) for either unit due to the limited inventory loss due to boiling. However, access to the SFP area as a part of Phase 2 response could be challenged due to environmental conditions local to the pool. Thus, actions that require access to the SFP deck will be completed prior to Phase 2.

Makeup will be provided using the FLEX SG feed pump that is in use (either from the primary or secondary staging location) or separate FLEX SFP makeup pump.

The strategies for the discharge connection to the SFP are to:

" install branch connection to the SFP deck to accommodate a hose connection or oscillating spray fire nozzle

• provide makeup via connection into existing SFP Cooling system piping (only available from primary staging location)

Both SFPs are located in a structure that does not require additional ventilation.

Conceptual routings for makeup to the SFP are contained in Attachment 3.

Details:

Provide a brief FSGs will be developed to support the Phase 2 SFP cooling description of Procedures strategies.

/ Strategies / Guidelines Identify modifications 1. A branch connection from the ANO-1 FLEX SG feed pump discharge line(s) to the ANO-1 SFP would be required for both primary and secondary staging locations.

2. A branch connection from the ANO-2 FLEX SG feed pump discharge line(s) to the ANO-2 SFP would be required for both primary and secondary staging locations.

3. A connection into existing SFP cooling system piping would be required.

Key SFP Parameter SFP Level Notes: The key parameters will be monitored from the control room or taken locally.

Enclosure to OCAN021302 Page 30 of 51 Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic The FLEX equipment storage location(s) will withstand the NEI 12-06 (Reference 2) hazards as applicable to ANO.

Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Design In all external events, a deployment strategy is planned that will deliver any required FLEX equipment to the appropriate event-determined staging area.

In the specific case of a flooding event, it is expected that several days' notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the primary staging locations via the train bay. All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will all be utilized for deploying any portable FLEX equipment.

Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A strategy to clear debris for FLEX coping strategies will be implemented.

Strategy Modifications Protection of connections The FLEX SG feed pumps will See Core Cooling The FLEX connections will be be used to supply water via modifications for suction constructed to withstand the branch connections from their source. NEI 12-06 (Reference 2) discharge lines to either a hose hazards as applicable to ANO.

or oscillating fire monitor A branch connection from the nozzle. ANO-1 FLEX SG feed pump or the FLEX SFP makeup pump discharge line(s) to the ANO-1 SFP would be required.

Enclosure to OCAN021302 Page 31 of 51 Primary and secondary staging A branch connection from the locations address all external ANO-2 FLEX SG feed pump or event possibilities; Primary the FLEX SFP makeup pump staging for the FLEX SG feed discharge line(s) to the ANO-2 pump or the FLEX SEP SFP would be required.

makeup pump is located in the AB at the end of the train bay. A connection into existing SFP The secondary staging location cooling system piping would be will be outside the southwest required.

corner of the AB on ground level (ANO-1). The secondary staging location will be outside the northwest corner of the AB on ground level (ANO-2).

Hose or piping will be routed from the SEP deck to the applicable staging area.

If the connection into existing SEP cooling system piping from the primary staging area is used, a hose will be connected at the primary staging area.

!Notes: N/A

Enclosure to 0CAN021302 Page 32 of 51 Maintain SFP Cooling PWR Portable Equipment Phase 3:

For Phase 3, Entergy intends to continue with the Phase 2 strategies (boil-off) with additional support and equipment provided by off-site resources. RRC equipment can be installed into the existing SWS piping to provide makeup indefinitely.

This strategy credits that back-ups to the Phase 2 equipment will be delivered from the RRC to be on-site during Phase 3 should any Phase 2 equipment fail during the indefinite coping period.

Details:

Provide a brief FSGs will be developed to support the Phase 3 SFP cooling description of Procedures strategies.

I Strategies / Guidelines Identify modifications A hose connection for an RRC pump will be installed in order to supply water from the UHS through the installed SWS piping.

Key SFP Parameter SFP Level Notes: The key parameters will either be monitored from the control room or taken locally.

Deployment Conceptual Design Deployment strategies for Phase 3 equipment will be determined during detailed design.

Strategy Modifications Protection of connections A hose connection for an RRC A hose connection to the UHS The FLEX connections will be pump will be used to supply for an RRC pump will be constructed to withstand the water from the UHS through installed. NEI 12-06 (Reference 2) the installed SWS piping. hazards as applicable to ANO.

The RRC will provide debris None N/A removal equipment capable of clearing paths blocked by large debris. Any further level of design of this equipment will not be completed during the conceptual design phase, and will need to be completed during detailed design.

Notes: N/A

Enclosure to 0CAN021302 Page 33 of 51 Safety Functions Support Determine baseline coping capability with installed coping5 modifications not including FLEX modifications PWR-Installed Equipment Phase 1 Support for the safety functions is provided by continued observation of plant conditions by site personnel in the control room or taken locally. During Phase 1, the installed vital batteries are used to maintain the critical instrumentation, and some control systems (ANO-1 only), available to the site personnel.

The time which vital power will be available can be extended by performing a load shed of all loads which are not considered to be critical for monitoring the conditions of the plant during an ELAP.

DC load shed will be required in order to extend battery life until installed battery chargers can be re-powered via the FLEX portable diesel generators (PDGs).

Details:

Provide a brief Procedures/strategies/guidelines will be revised to consider the description of FSGs.

Procedures / Strategies

/ Guidelines Identify modifications No modifications are required for Phase 1.

Key Parameters DC Bus Voltage Notes: N/A 5 Coping modifications consist of modifications installed to increase initial coping time, i.e.,

generators to preserve vital instruments or increase operating time on battery powered equipment.

Enclosure to OCAN021302 Page 34 of 51 Safety Functions Support PWR Portable Equipment Phase 2 The electrical portion of the ANO-1 and ANO-2 Phase 2 coping strategy consists of two main goals:

• Maintain power to essential instrumentation by powering the battery charger.

" Provide electric power to FLEX pumps and other equipment.

In a non-seismic BDBEE, the primary staging location will be used. All FLEX pumps are located inside the AB, and the FLEX PDG location will depend on if the event is a flood event or a non-flood event. In a flood event, the FLEX PDG will be staged on the turbine deck, as there is ample warning time and available power to lift the PDGs to an elevation above the PMF elevation (361'). In a high wind or extreme temperature event, the FLEX PDG will be staged in the train bay outside the primary staging location.

In a seismic BDBEE, the secondary staging location will be used.

Maintaining power to essential instrumentation will be achieved by re-powering an installed battery charger via the FLEX PDG. Powering the FLEX pumps will be achieved by connecting the FLEX PDG to electrical connections either on the turbine deck or in the train bay.

Additional installed equipment may be required to be powered by the FLEX generators. This will include fuel oil transfer pumps. Additional equipment that may be required to be powered include portable fans/lighting, pressurizer heaters, and other essential equipment.

Refueling strategies will be evaluated as part of the detailed design phase.

Conceptual routings for safety function support are contained in Attachment 3. The portable equipment is listed in the following table.

Details:

Provide a brief FSGs will be developed to support the Phase 2 safety functions description of Procedures strategies.

/ Strategies / Guidelines Identify modifications Installation of spare breaker in applicable existing switchgear and raceway from PDG staging location to tie-in points Key Parameters DC Bus Voltage Notes: N/A

Enclosure to OCAN021302 Page 35 of 51 Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic The FLEX equipment storage location(s) will withstand the NEI 12-06 (Reference 2) hazards as applicable to ANO.

Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Design In all external events, a deployment strategy is planned that will deliver any required FLEX equipment to the appropriate event-determined staging area.

In the specific case of a flooding event, it is expected that several days' notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the primary staging locations via the train bay. All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will all be utilized for deploying any portable FLEX equipment.

Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

A strategy to clear debris for FLEX coping strategies will be implemented.

Strategy Modifications Protection of connections For ANO-1 and ANO-2, a PDG Conduit will be run from the The FLEX connections will be will be used to maintain power PDG staging locations to both constructed to withstand the to essential instrumentation by the FLEX pumps and the tie-in NEI 12-06 (Reference 2) re-powering an existing battery point for the battery charger hazards as applicable to ANO.

charger that feeds vital DC that feeds vital DC buses.

buses and provide electric power to the FLEX pumps for SG feed and RCS makeup as necessary.

Enclosure to 0CAN021302 Page 36 of 51 Staging location of PDG is event-dependent.

Notes: N/A

Enclosure to OCAN021302 Page 37 of 51 Safety Functions Support PWR Portable Equipment Phase 3 Similar Phase 3 coping strategies will be employed for both ANO-1 and ANO-2. Off-site equipment from the RRC will arrive on-site to supply Phase 3 coping capabilities.

Electrically, this includes 4160V generators capable of re-powering 4160V buses. In turn, the 4160V buses will feed the 480V Engineered Safeguards buses so the Phase 2 PDGs are no longer required for this function. There will be a single connection point on each unit for the 4160V generators that will be protected from the applicable BDBEEs (seismic, flooding, high wind, and extreme temperatures) for both ANO-1 and ANO-2.

The RRC equipment will be capable of floating the 4160V generator to the connection point.

Conceptual routings for safety function support are contained in Attachment 3. The portable equipment and commodities are listed in the following tables.

Details:

Provide a brief FSGs will be developed to support the Phase 3 safety functions description of Procedures strategies.

I Strategies / Guidelines Identify modifications Installation of a tie-in to the installed ANO-1 and ANO-2 4160V Engineered Safeguards buses Key Parameters DC Bus Voltage Notes: N/A Deployment Conceptual Design In all external events, a deployment strategy is planned that will deliver any required FLEX equipment to the appropriate event-determined staging area.

In the specific case of a flooding event, it is expected that several days' notice will be given before a flood level will approach either plant grade and/or the magnitude of the PMF. Therefore, it is assumed that at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is available for the deployment of the FLEX equipment for the flooding scenario (i.e., primary connection). It is also assumed that power is available during this time. Deployment of FLEX equipment for the flooding scenario consists of transporting all required equipment from the storage location(s) to the primary staging locations via the train bay. All paths and roads on-site are assumed to be maintained as unobstructed in this scenario, so the easiest path will used.

Any portable FLEX equipment will be trailer-mounted or on wheels for ease of deployment. This will give the current vehicles at ANO the capability to move any portable FLEX equipment.

Available forklifts or pickup trucks will all be utilized for deploying any portable FLEX equipment.

Most of this equipment will be utilized for both the movement of any portable FLEX equipment and debris removal.

Enclosure to 0CAN021302 Page 38 of 51 Safety Functions Support PWR Portable Equipment Phase 3 A strategy to clear debris for FLEX coping strategies will be implemented.

Strategy Modifications Protection of connections The ANO-1 and ANO-2 Installation of a tie-in to the The FLEX connections will be Phase 3 electrical coping installed ANO-1 and ANO-2 constructed to withstand the strategy is to re-power 4160V 4160V Engineered Safeguards NEI 12-06 (Reference 2)

Engineered Safeguards buses. buses. hazards as applicable to ANO.

Notes: N/A

Enclosure to OCAN021302 Page 39 of 51 PWR Portable Equipment Phase 2 Use and (potential/ flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Flow Rate and Maintenance / PM equipment Required Head requirements (Quantity)

ANO-1 SG X X 600 gpm Will follow EPRI Feed Pump 1 2827 ft template requirements

• ANO-1/2 Feed PumpSG SX2 600 gpm Will follow EPRI FN+I) 2827 ft template requirements ANO-2 SG X X 600 gpm Will follow EPRI Feed Pump 3 2827 ft template requirements ANO-1 RCS 40 gpm Will follow EPRI Inje n1 3537 ft template requirements Pump 1

• ANO-1/2 RCS Injection X 40 gpm Will follow EPRI RS 2Injetio X3537 ft template requirements ANO-2 RCS Injection X 40 gpm Will follow EPRI Pump 3 3537 ft template requirements Inventory 650 gpm Will follow EPRI Transfer X X 225 ft template requirements Pump_1_____

• Inventory 60Wl Transfer X650 gpm Will follow EPRI Pump 2 (N+I) 225 ft template requirements Inventory 650 gpm Will follow EPRI Transfer X X 225 ft template requirements Pump_3 1___1__ __ __ __ ___1___1__ __

Enclosure to 0CAN021302 Page 40 of 51 PWR Portable Equipment Phase 2 Use and (potential/ flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Flow Rate and Maintenance/ PM equipment Required Head requirements (Quantity)

Pick Up X To be determined Will follow EPRI Truck(s) (TBD) template requirements Debris Removal X TBD Will follow EPRI Equipment template requirements Trailer X TBD Will follow EPRI template requirements SG Feed Will follow EPRI Suction Hose template requirements SG Feed Discharge X TBD Will follow EPRI Hose template requirements RCS injection X TBD Will follow EPRI Suction Hose template requirements RCS injection Discharge X TBD Will follow EPRI Hose template requirements SEP Discharge X TBD Will follow EPRI Hose template requirements Inventory Transfer Suction Hose TBD Will follow EPRI template requirements

Enclosure to 0CAN021302 Page 41 of 51 PWR Portable Equipment Phase 2 Use and (potential/ flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Flow Rate and Maintenance/ PM equipment Required Head requirements (Quantity)

Inventory Transfer Will follow EPRI Discharge template requirements Hose ANO-1 480V X X X TBD Will follow EPRI DG template requirements

• ANO-1/2 480V Diesel TBD Will follow EPRI Generator template requirements (DG) (N+1)

ANO-2 480V X X X TBD Will follow EPRI DG I I I template requirements

• N+1 is based upon N units. ANO only needs three items so long as the "swing" item can function for both units. See NEI 12-06 (Reference 2, p. 23).

Enclosure to OCAN021302 Page 42 of 51 PWR Portable Equipment Phase 3 Use and (potential/flexibility)diverse uses Performance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility Flow Rate and equipment Required Head ANO-1 SW 2500 gpm 9.8 gph fuel required RRC Pump 52.15 ft ANO-1/2 SW 2500 m RRC Pump X X X 25 gpm 9.8 gph fuel required (N+1) 52.15 ft ANO-2 SW 2500 gpm 9.8 gph fuel required RRC Pump 52.15 ft Large Fuel x x X X TBD Fuel Replenish/Transfer Truck Large Debris Removal X TBD Equipment SW Suction TBD Hose SW Discharge X X X TBD Hose Large 4160V TBD DG Large 4160V TBD DG (N+1) I I II

Enclosure to OCAN021302 Page 43 of 51 Phase 3 Response Equipment/Commodities Item Notes i

Radiation Protection Equipment N/A 0 Survey instruments 0 Dosimetry 0 Off-site monitoring/sampling 0 Radiological counting equipment 0 Radiation protection supplies 0 Equipment decontamination supplies 0 Respiratory protection Commodities N/A

• Food o Meals ready to eat o Microwavable meals

• Potable water Fuel Requirements N/A

• #2 Diesel Fuel

• Diesel fuel bladders Heavy Equipment N/A

• 4 wheel-drive transportation equipment (tow vehicle)

• Debris clearing equipment (skid steer type)

Enclosure to 0CAN021302 Page 44 of 51

References:

1. NRC EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for BDBEE," March 12, 2012 [ADAMS Accession Number ML12056A045]

2. NEI 12-06, Revision 0, "Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide," August 2012

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

4. ANO SARs

a. ANO-1 SAR, Amendment 25, Facility Operating License Number DPR-51, Docket Number 50-313

b. ANO-2 SAR, Amendment 24, Facility Operating License Number NPF-6, Docket Number 50-368

5. Entergy Document, "Arkansas Nuclear One Station Response to INPO IER 11-4,

'Near-Term Actions to Address the Effects of an Extended Loss of All AC Power in Response to the Fukushima Daiichi Event'," Attached in EDMS as 'ANO IER 11-4 Responses.zip'

6. ANO Procedures

a. ANO-1 Procedure 1202.008, "Blackout"

b. ANO-2 Procedure 2202.008, "Station Blackout"

7. WCAP-17601-P, Revision 1, "RCS Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs," January 2013

8. ANO Procedures

a. ANO-1 Procedure 1203.028, "Loss of Decay Heat Removal"

b. ANO-2 Procedure 2203.029, "Loss of Shutdown Cooling"

c. ANO-2 Procedure 2202.011, "Lower Mode Functional Recovery

9. Task Interface Agreement 2004-04, "Acceptability of Proceduralized Departures from TSs Requirements at the Surry Power Station," (TAC Nos. MC4331 and MC4332)," dated September 12, 2006. (Accession No. ML060590273)

Enclosure to OCAN021302 Page 45 of 51 Attachment 1A - ANO-1 Sequence of Events Timeline Action Elapsed Action Time Remarks / Applicability Item Time Constraint Y/N (hours) 0 Event Starts N/A Plant at 100% power 0 Perform Actions Consistent with Station N/A Actions performed per EOP Blackout Procedure (Reference 6a) 1 1 Declare ELAP Y ELAP declared when power sources cannot be restored 2 3 Perform Battery Load Shed Y Extended battery load shedding performed to extend life to Phase 2 3 5 Clear Debris Y Debris cleared for deployment paths for equipment 4 6 Perform Damage Assessment Y FSG requirement to devise coping strategies 5 6 Deploy and Connect FLEX 480V Y Electrically-powered RCS Generator makeup pump staged 6 6 Align FLEX RCS Makeup Pump from Y A makeup flow rate of 35 gpm suction source is used assumed a 20°F/hr cooldown. BWST volume should last throughout the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ELAP event.

7 6 Align FLEX Pump suction to additional Y The required time for QCST sources as needed for RCS heat makeup is based on the removal credited TS QCST volume and the assumed cooldown strategy at ANO-1, which starts at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

8 8 Commence Plant Cooldown Y Pending outcome of PWROG analysis 9 12 Deploy hose for SFP makeup Y Prior to onset of boiling 10 16 Refuel Diesel Equipment Y Assuming 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of fuel is available in all diesel equipment, the RCS makeup pump and 480V generator need to be refueled at ANO-1 starting at 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. The QCST makeup pump needs to be refueled at 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

11 24 Prepare site for receipt of RRC Y RRC equipment expected to be equipment able to arrive 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event 12 24 Align SG Feed Pump to SFP Y Assuming 15 feet of water is needed above the fuel racks for shielding, makeup to the ANO-1 SFP is not required until 47.67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br /> after the event.

Enclosure to 0CAN021302 Page 46 of 51 13 N/A Establish any required ventilation N The need for ventilation through 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> has not been determined.

14 N/A Align FLEX SG Feed Pump N Steam pressure is expected to be sufficient to operate the turbine-driven EFW pumps throughout the 72-hour ELAP event. The backup FLEX SG feed pumps should be deployed when time/resources permit.

15 N/A Align 4160V Generators N The 4160V generator aligned when possible 16 N/A Establish Large Fuel Truck Service N On-site fuel resources expected to last for over 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 17 N/A Establish FLEX SW RRC Pump N The final details of this equipment will be finalized in the detailed design phase.

Enclosure to 0CAN021302 Page 47 of 51 Attachment 1A - ANO-2 Sequence of Events Timeline Action Elapsed Action Time Remarks / Applicability item Time Constraint Y/N (hours) 0 Event Starts N/A Plant at 100% power 0 Perform Actions Consistent with Station N/A Actions performed per EOP Blackout Procedure (Reference 6b) 1 1 Declare ELAP Y ELAP declared when power sources cannot be restored 2 3 Perform Battery Load Shed Y Extended battery load shedding performed to extend life to Phase 2 3 5 Commence Plant Cooldown to a Cold Y Assuming an initial cold leg Leg Temperature of 350°F temperature of 550°F cooled to a temperature of 3500 F, this cooldown will take 2.67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br /> with a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> hold.

4 5 Clear Debris Y Debris cleared for deployment paths for equipment 5 6 Perform Damage Assessment Y FSG requirement to devise coping strategies 6 8 Align FLEX Pump suction to additional Y The required time for QCST sources as needed for RCS heat makeup is based on the removal credited TS QCST volume and the assumed cooldown strategy at ANO-1, which starts at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The QOCST is a shared resource for both units. The exact need time for makeup to this water source is unknown until the cooldown strategy has been finalized.

7 12 Deploy hose for SFP makeup Y Prior to onset of boiling 8 16 Refuel Diesel Equipment Y Assuming 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of fuel is available in all diesel equipment, the QCST makeup pump needs to be refueled at 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

9 18 Align FLEX RCS Makeup Pump from Y RCS makeup is to be supplied suction source at 17.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> at a flow rate of 20 gpm.

10 18 Deploy and Connect FLEX 480V Y Electrically-powered RCS Generator makeup pump staged.

11 24 Prepare site for receipt of RRC Y RRC equipment expected to be equipment able to arrive 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event

Enclosure to 0CAN021302 Page 48 of 51 12 24 Align SG Feed to SFP Y Assuming 15 feet of water is needed above the fuel racks for shielding, makeup to the ANO-2 SFP is not required until 24.74 hours8.564815e-4 days <br />0.0206 hours <br />1.223545e-4 weeks <br />2.8157e-5 months <br /> after the event.

13 N/A Establish any required ventilation N The need for ventilation through 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> has not been determined.

14 N/A Align FLEX SG Feed Pump N Steam pressure is expected to be sufficient to operate the turbine-driven EFW pumps throughout the 72-hour ELAP event. The backup FLEX SG feed pumps should be deployed when time/resources permit.

15 N/A Align 4160V Generators N The 4160V generator aligned when possible 16 N/A Establish Large Fuel Truck Service N On-site fuel resources expected to last for over 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 17 N/A Establish FLEX SW RRC Pump N The final details of this equipment will be finalized in the detailed design phase.

Enclosure to OCAN021302 Page 49 of 51 Attachment 1 B - NSSS Significant Reference Analysis Deviation Table There are currently no identified deviations in the ANU-1 FLEX conceptual design with respect to the All PWROG guidance pending completion of PWROG-sponsored revision to WCAP-17601 (Reference 7) that ic in nrnnrin fnr tho i inrtnfort KI.c..* cztrntfnx/ fnr RAW KIJ .q~rip-inni T

Entergy has evaluated WCAP-1 7601 (Reference 7) considering ANO-2 site-specific parameters and All determined that the conclusions of that document are generally applicable to ANO-2. There are currently no identified deviations in the ANO-2 FLEX conceptual design with respect to the PWROG guidance.

Enclosure to 0CAN021302 Page 50 of 51 Attachment 2 - Milestone Schedule The following milestone schedule is provided. The dates are planning dates that are subject to change as the FLEX program design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent six-month status reports.

.-. NO M ileston e Schedule Status Original Target (Will be updated Activity Completion Date every 6 months)

Submit Overall Integrated Implementation Plan February-2013 Complete Update 1 August-2013 Update 2 February-2014 Update 3 August-2014 Update 4 February-2015 Update 5 August-2015 Perform Staffing Analysis December-2013 Modifications Modifications Evaluation June-2013 Engineeringand Implementation June-2013 - October2015 ANO- 1 Implementation Outage November-2014 ANO-2 Implementation Outage October-2015 On-site FLEX Equipment Purchase June-2014 Procure November-2014 Off-site FLEX Equipment Develop Strategies with RRC November-2013 Install Off-site Delivery Station (if necessary) October-2014 Procedures PWROG issues NSSS-specific guidelines June-2013 CreateANO FSG November-2014 Create Maintenance Procedures November-2014 Training Develop Training Plan June-2014 Implement Training November-2014 Submit Completion Report December-2015

Enclosure to 0CAN021302 Page 51 of 51 Attachment 3 - Conceptual Drawing Mark-ups Please see enclosed drawings.

Attachment 3 Conceptual Sketches TR-FSE-I 3-10-Appendix G-NP G-85 February 2013 Revision 0

Q-~ '\ G) C> (D (D G) (D (D 0 ~

0 0>TC >~'

'-N N--'

K>

6>

Figure G3.1.1-1 Reactor Core Cooling and Heat Removal (Steam Generators Available)

Conceptual Routings TR-FSE-13-10-Appcndix G-NP G-86 February 2013 Revision 0

TR-FSE-13-I0-Appendix G-NP G-87 February 2013 Revision 0

!?AN Figre G31.1-3 Reactor andHeatRerrmal (SteamCwgerwm CoreCcOWmg ConepWnd Available) Abgnnwu TR-FSE-13-I0-Appendix G-NP G-88 February 2013 Revision 0

-. D Avbbe Coae AhZmvr TR-FSE-13-1O-Appeiidix G-NP G-89 February 2013 Revision 0

'D Gk* 2 00 GK (D (D (_ (D h (Th',ý0 '

'-V

---V

'U

'-V

• • 2ystfiM sxxrc~ ~

t*N ~~~CVC~N A 2"~V~M*

N Figure G3.2. 1-1 RCS Inventory Control Conceptual Routings u-w TR-FSE-13-10-Appmdix G-NP onrolCocetuaGRutng nvetoy RS FigreG32A- . -- J,2013 Revision 0

K) K7> K> K)

C>

(71.

MflE. YT.,-O-ti Figure G3.2.1-2 RCS Inventory Control Conceptual Routings T N February 2013 TR-FSE-13-10-Appendix (i-NP (i-91 U-91 Februry 2013 Revisioni 0

8 I H I .32 P,_ f tC ;Q F_

z W1 I ~~ ~ ~ ~ ~ ~ ~ _________________

E; ......

.; .. [

J G-92 Februar 2013 TR-FSF-13-1O-Appendix G-NP Revision 0

i.-______,_

T J Alk Fý T Qa F

J.

mg-A pw" WWI r2 A E E I ýe . 9 94 JL c

Axlr

---

n B w Flom G3.2,14 RCS k"MM ca" C--PkWAlw-nts A

A; G-NP G-93 February 2013 Revision 0

i i!Il 4Q

~ley Ap.

If "N 1

>~9W ym i I*~ 7-E E AKii IV~

7

~ ~ Ktl-D cý FqvK G1.- RC ne"Cnro oeI-Or B

B, ba i A

AY~

TR-FSE-13-lO-Appendix 0-NP .__J, G1-94 Revisioni 0

0~l ( 0DG I

TR-FSE-13-10-Appendix G-NP G-95 February 2013 Revision 0

TR-FSE-13-10-Appcndix G-NP G-96 February 2013 Revision 0

I I lit

~P?I ?I iIi.iiI~i:~i

+

--- 0

-0

-0

--- 0

• ~

cziMM Figure G33.1-3 Spent Fuel Pool Cooling Conceptual Routings rvwwiiyy-,41,13 TR-FSE 1O-Appendix G-NP G-97 Revision 0

0'~ 0 K) '-, 0-

\"D (D~ 0 0 (Dx~i0.

0: 0

,-S 0 0 09 C-' 0q 0 00 0 O 0 / ~1/22 Figure G3.3.1-4 Spent Fuel Pool Cooling Conceptual Routings February 2013 TR-FSE I10-Appendix G-NP 0-98 G-98 February 2013 Revision 0

TR-FSE-13-10-Appendix G-NP G-99 February 2013 Revision 0

Hi 14"a=4 I

e=

0.

7,11

.~~I E .

mttMe4t T-R-FSE-13-l(J-Appendix G-NP GJ-100I FebruaI 2013 Revision 0

H c,

E A

Februaiy 2013 TR-FSE-13-10-Appendix Ui-NP G-I0I G-101 February 2013 Revision 0

H F

FQ 3.4.2-1 Und I CWndrWM StMq. Tank CMn AMgiwd I~eOruaryii.Jij TR-FSE-13-I0-Appendix G-NP 0-102 G3-102 F*ebruary 2013.

Revision 0

H F

4ti~i 0

0

~ U.~2 Cndm~l.

G3 3-Mq0ra torge ToksConepO~

C Cý B B:

Iebruary 2013 TR-FSE-13-10-Appeidix G-NP U-103 G-103 Feb~ruary 2013 Revision 0

I~sI T~rw ft.

7~

Fj 7V 4 -

Akiv 4

- -X A5 p ; CA ---

TR-FE-I3IO- ppa~ix -NP -104FebU2Jy201 RevisionA

N

.L

" A , , -;-f','ý GI I.

V.

K I~1 K

~i,. I ffi~..

I - .4

~ J P~' f~j +/-:

.~ AK Y

Ac

.. J-'

CMMcPhW F"ur G3,46-1 RMCtmMakeUpWOWTM*8~ M~gn-el UIU)

TR-FSE-I 3-10-Appendix G-NP Gl-105 2013 Revision 0

A lpl F _ ]

E L2......

c B

Ak~Delt FouesG3.4.6ýSwr~wWaW{Da riaft~Rfieivok Cancaptua February 2013 TR-FSE-13-10-Appendix a-NP G-106 Revision 0

H A F

E1 Il/

B A

Agnmard

!jga03.47.1 Emei~ency Cook* Paid Ce~tcepuW G-107 February 2013 TR-FSE-13-1O-Appendix 0-NP Revision 0

A H A

.. 9...

1/1 E - iP1 o e B

G3. 9-1Coolng lo~e BasinCsoeeftuaJ A#Vnnwtt Fmgjre TR-FSE-13-1O-Appendix 0-NP G-108 February 2013 Revision 0

4 I H

S;~

if

~ -A -. -- W y ;V W G

IT,,

---

1 i r~

a I

to.I~%I 0 c

8 0FtoseG3.$11 BeraedWaterStrage TatatCp&MoAb0vwt ros.uui~ LU,,

TR-FSE-13-lO-Appeadix G-NP (G-1U9 r *u*s*y *um*

Revisioni 0

G-110 Febraary 2013 TR-FSE-13-10-Appadix G-NP Revision 0

"~ H IRA:

EL

-cw ~

~ NPciiiFebuary201 Revision 0

C7 H

- ~IBal

~BZaM IK

-InOL~

- nr E

D J

~Th

~-~t I~

D ISO' c

B Figts G3$.531Unit I 5amtAcidjAdftmi TankCocepuat Amvnrlt lemuary 1013 1 K-1FSE-I3-iU-Appendix U-NP G-112 U-Ill February 2013 Revision 0

H H nor I~n G

t F

I ~ li l jai "I fw

~~-

12W E

D J Aplwh n_

US C

ArgrAVM.

a E

Foae G3.5.4-1 Urit 2 Bodc Acid Make LP Tank CWooI A

I

~> 11 I

revruaryzua.~

TR-FSE-13-1O-Appadix G-NP G-113 February 2013 Revision 0

I E IE

-W 8~ Figure G3.6.1-1 Unit I Conceptual Routing for Jumper Between Buses D01 and D02 TR-FSE-I 3-IO-Appemdix G-NP G-114 February 2013 Revisioni 0

4 TR-FSE-13-10-Appmdix G-NP G-115 February 2013 Revision 0

-I -1

• 2 K,

L Junýction ýbox I

r

<1/4

= ~~1/4* 2!

p Figure G3.6.2-2 Unit .

Conceptual I ___

Primary Cable/Conduit Route, 386' v^

February 2013 (i-I 16 G-II16 February 2U013 TR-FSE-13-10-Appmdix U-NIP Revision 0

/ I IiIi i II I / /

>1'

--I-. i i~w t L

b~d jiu ~,,II From ~386' TUý,m CI j

Tr 0"ý'

1 7

1l, L

.1ELS

-RY:

I H c o eL-5C ,~,AR A~-~A 1L~

.2~I 4, 7-l'. =4P 7 FiL IW t4ý I 54h LL- +t C3ý i

,71 3,

CA&W-AdWO.&

SI I Figure G3.6.2-3 Unit 1 Conceptual V I! Primary Cable/Conduit Route to Unit I TR-IFSE-13-10-Appdalx (i-NF Revision 0 372" 6L 57 6-117 G-117 HFebruaxy 2013 February 2013

TR-FSE-I 3-I0-Appendix G-NP G-I I8 February 2013 Revision 0

TR-FSE-13-10-Appendix G-NP G-119 February 2013 Revision 0

Figure 03.6.2-6 Unit 2 Conceptual Primary Cable/Conduit Route, 386' IL HTC 467 E

rtl-imlpl .

DR%<Ga ýýAj- Aw" PLATR~tN1S

-7 1

t CD

.)E 4t I*

-, t' t~of 1` 5-CflO OV1.

Aý It" _ _

CHKR

£ iTl CON7ZOi F1 7jgI, Ri3OFK~t Junction box near handrail TR-FSE-I 3-I0-Appendix G-NP G-120 ~ebruaey ~UI3 Fetbruary 2013 Revision 0

TR-FSE-13-10-Appaudix G-NP G-121 February 2013 Revision 0

I -

CIPrimary Cable/Conduit Route to TR-FSE- 13-1 O-Appendix CG-NP G- 122 February 2013 Revision 0

TR-FSE 10-Appendix G-NP G-123 February 2013 Revision 0

TR-FSE-13-lO-Appaidix G-NP G-124 Febuary 2013 Revision 0

SL4PG P~LAN

/

.\ i . . . . .......

4 s* Figure G3.6.2-11 Unit 1 Conceptual Jna_ i onu.tJ*Fig-teL ,.S(

"CndiRot toSut withgar RoomI TR-FSE-13-1O-Appendix G-NP G-125 February 2013 Revision 0

TR-FSE- 13-10-Appendix G-NP G-126 February 20t3 Revision 0

~ck. From 354k' 7-

" '% .... .* J rk T° *- *:>° '*'Figure

• '*=* *G3.6.2-13 Unit 2 Conceptual t Secondary Cable/Conduit Route, 372' TR-FSF-1 3-1 0-Annondix 0-NP G-127 February 2013 Revision 0

G-128 February 2013 TR-FSE-I 3-IO-Appendix G-NP Revision 0

C~~~F #- AL~L~

q,-

ES-Uit&A 372 Upfrom 36 P-1Ta i44

~J ~JL. 144U "J 44U 7- >4 Figure G3.6.3-2 Unit 2 Conceptual Phase 3 Conduit Routing, 372' i

TR-FSE-13-I0-Appendix G-NP G-129 Febru-y 2o013 Revision 0

TR-FSE-13-I0-Appendix G-NP G-130 February 2013 Revision 0

TR-FSE-1 3-1O-Appendix G-NP G-131 February 2013 Revision 0

TR-FSE-13-10-Appendix cl-NP G-132 Febmruay 2013 Revision 0

TR-FSE-13-10-Appendix G-NP G-133 February 2013 Revision 0