Text

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)
	ML13060A362
Person / Time
Site:	Braidwood
Issue date:	02/28/2013
From:	Kaegi G; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, RS-13-017
	Download: ML13060A362 (71)
	v • d • e

1 Exelon Generation Order No. EA-12-049 RS-13-017 February 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457

Subject:

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)

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 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.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-1 2-049 February 28, 2013 Page 2 Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29, 2012 which 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.

Reference 4 provided the EGC initial status report regarding mitigation strategies, as required by Reference 1.

The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1. This letter confirms EGC has received Reference 2 and has an Overall Integrated Plan developed in accordance with the guidance for defining and deploying strategies that will enhance the ability to cope with conditions resulting from beyond-design-basis external events.

The information in the enclosure provides the Braidwood Station, Units 1 and 2 Overall Integrated Plan for mitigation strategies pursuant to Reference 3. The enclosed Integrated Plan is based on conceptual design information. Final design details and associated procedure guidance, as well as any revisions to the information contained in the Enclosure, will be provided in the 6-month Integrated Plan updates required by Reference 1.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of February 2013.

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

Enclosure:

1.

Braidwood Station, Units 1 and 2 Mitigation Strategies (MS) Overall Integrated Plan cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Braidwood Station, Units 1 and 2 NRC Project Manager, NRR - Braidwood Station, Units 1 and 2 Mr. Robert J. Fretz, Jr, NRRIJLD/PMB, NRC Mr. Robert L. Dennig, NRRIDSS/SCVB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28, 2013 Page 2 Reference 1 requires submission of an Overall Integrated Plan by February 28,2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29, 2012 which endorses industry guidance document NEt 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.

Reference 4 provided the EGC initial status report regarding mitigation strategies, as required by Reference 1.

The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1. This letter confirms EGC has received Reference 2 and has an Overall Integrated Plan developed in accordance with the guidance for defining and deploying strategies that will enhance the ability to cope with conditions resulting from beyond-design-basis external events.

The information in the enclosure provides the Braidwood Station, Units 1 and 2 Overall Integrated Plan for mitigation strategies pursuant to Reference 3. The enclosed Integrated Plan is based on conceptual design information. Final design details and associated procedure guidance, as well as any revisions to the information contained in the Enclosure, will be provided in the 6-month Integrated Plan updates required by Reference 1.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of February 2013.

Respectfully submitted, G~T?L~

Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Braidwood Station, Units 1 and 2 Mitigation Strategies (MS) Overall Integrated Plan cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Braidwood Station, Units 1 and 2 NRC Project Manager, NRR - Braidwood Station, Units 1 and 2 Mr. Robert J. Fretz, Jr, NRRIJLD/PMB, NRC Mr. Robert L. Dennig, NRRIDSS/SCVB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety Braidwood Station, Units 1 and 2 Mitigation Strategies (MS)

Overall Integrated Plan (68 pages)

Braidwood Station, Units 1 and 2 Mitigation Strategies (MS)

Overall Integrated Plan (68 pages)

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan E meats PWR Site: Braidwood Seismic events, except soil liquefaction; flooding from local /

intense precipitation; severe storms with high winds; snow, ice and extreme cold; and high temperatures were determined to be applicable Extreme External Hazards for Braidwood Station per the guidance of NEI 12-06 Rev. 0 and are as follows:

Seismic Hazard Assessment:

Braidwood will address Beyond Design Basis (BDB) seismic considerations in the implementation of FLEX strategies consistent with NEI 12-06 Rev. 0 (Ref 1).

External Flood Hazard Assessment:

Braidwood Station UFSAR Rev. 14 (Ref. 2) addresses additional flooding mechanisms that are either not critical or not bounding for Braidwood.

External Flooding is not applicable per NEI 12-06 Rev.0 (Ref.

3), since Braidwood is considered a Dry site. Braidwood UFSAR Rev. 14 (Ref. 4), states that the plant grade elevation is at 600.0 feet and the grade floors of the safety related building are at elevation 601.0 feet. The Probable Maximum Flood (PMF) along the Kankakee River, Mason River and Granary Creek do not affect the site, since the maximum water surface elevations are 561.3, 582 and 576 feet respectively: the peak elevations are a minimum of 18 feet below the plant safety related facilities grade of 600 feet.

The probable maximum precipitation (PIMP) falling on the plant area was considered in the analysis of local intense precipitation on the plant site. The maximum water level is elevation 601.91.

feet (Ref. 11) at the plant safety related facilities due to PIMP.

To prevent water due to PMP from entering areas where essential equipment/systems are located, reinforced concrete curbs or steel barriers are provided (Ref. 4).

Huh Wind Hazard Assessment:

NEI 12-06 Rev. 0 (Ref. 5) identifies Braidwood Station in a region (41 degrees 14' N, 88 degrees 13' W) in which it would not experience severe winds from Hurricanes. However, NEI Determine Applicable Extreme External Hazard Ref: NEI 12-06 Sections 4.0 -9.0 JLD-ISG-2012-01 Section 1.0 Page 1 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Site:

Determine Applicable Extreme External Hazard Ref: NEI 12*06 Sections 4.0.. 9.0 JLD-ISG-2012.. 01 Section 1.0 Page lof68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 12-06 Rev. 0 (Ref. 6) identified Braidwood in Region 1 and susceptible to tornado winds of 200 mph.

Temperature information: From Braidwood's UFSAR Rev. 14 (Ref. 7) The annual average temperature in the Braidwood area as represented by Peoria Illinois is 50.8°F, while extreme temperatures range from a maximum of 102°F to a minimum of

-20°F. Maximum temperatures equal or exceed 90°F nearly 20 times per year, while minimum temperatures are less than or equal to 32°F about 130 times per year.

Braidwood's location is 41 degrees 14' N, 88 degrees 13' W Extreme Cold Hazard Assessment:

I 12-06 Rev, 0 (Ref. 8) identifies Braidwood Station in an area in which it could receive 25 inches of snow over 3 days.

NEI 12-06 Rev. 0 (Ref. 9) identifies Braidwood Station in a region, of Ice Severity Level 5, Catastrophic destruction to power lines and/or existence of extreme amount of ice.

High Temperature Hazard Assessment:

Braidwood Station will address high temperatures considerations in the implementation of FLEX strategies consistent with NEI 12-06 Rev. 0 (Ref. 10)

References:

1. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Section 5.2 dated August 2012.

2.

Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Braidwood Section 2.4.4 through 2.4.7 dated December 2012.

3.

NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) i mplementation Guide, Section 6.2.1 dated August 2012.

4.

Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Braidwood Section 2.4.2.3 dated December 2012.

5.

NEI 12-06 Rev. 0, Diverse and Flexible Coping Page 2 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 12-06 Rev. 0 0.... 0"--'k'... 1U'.LV to T.n.... 'nQrlin.

14 area Braidwood's location is r1Plr1I"PPC' 14' 88 degrees 13' W

region, power 5,

and/or existence of extreme amount of address considerations in implementation of strategies consistent with NEI 12-06 Rev. 0

10)

References:

1.

12-06 Rev. 0, Strategies 5.2 dated August 2012.

2. Byron/Braidwood Nuclear Stations Safety Analysis Report (UFSAR) Revision an Braidwood Section 2.4.4 2.4.7 dated December 2012.

3. NEI12-06 1

5.

Page 20f68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Strategies (FLEX) implementation Guide, Figure 7-1 dated August 2012.

6.

NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Figure 7-2 dated August 2012.

7.

Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Braidwood Section 2.3.1.1 dated December 2012.

NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Figure 8-1 dated August 2012.

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

10. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Section 9.2 dated August 2012.

11. Calculation WR-BR-PF-Rev 14, Effect of Local PIMP at Plant Site, dated November 11, 2012 Provide key assumptions associated with implementation of FLEX Strategies:

Flood and seismic re-evaluations pursuant to the 10 CFR 50.54(f) letter of March 12, 2012 are not completed and therefore not assumed in this submittal.

As the re-evaluations are completed, appropriate issues will be tracked and addressed on a schedule commensurate with other licensing bases changes.

The following conditions exist for the baseline case:

o DC banks are available.

o AC and DC electrical distribution is available.

o Diesel Driven Auxiliary Feedwater (DDAF) pump is available and will start in auto or manual as needed.

a Local manual control of steam generator (SG) power operated relief valves (PORN).

o Plant initial response is the same as Station Black Out, (SBO), WCAP-17601-P (Ref. 1).

o No additional single failures of any SSC are assumed (beyond the initial failures that define the ELAP/LUHS scenario in NEI 12-Key Site assumptions to implement NEI 12-06 strategies.

Ref: NEI 12-06 section 3.2.1 Page 3 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Key Site assumptions to implement NEI 12-06 strategies.

Ref: NEI 12-06 section 3.2.1

7.

Safety Analysis Report (UFSAR) Revision 14, Braidwood Section 2.3.1.1 December 2012.

8. NEI and Coping J.vU.lvlJlI..Ut.1VU Guide, 8-1

9.

10 Rev 14, November 11, 2012 8-2 Provide key assumptions associated with implementation of FLEX Strategies:

Flood seismic re-evaluations..... "~C'n,nnt-to 10 50.54(f) 2012 are not i-kr..*r.+,r.""a not assumed sublnittal.

re-evaluations are completed, issues be tracked addressed on a schedule o

o available.

o Diesel Driven licensing bases "'~~"'.Uj:;.,... 'LI.

baseline case:

is available o

o o

Page 3 of68 is

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 06).

Additional staff resources are expected to begin arriving at 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Ref: NEI 12-01 Rev 0 (Ref. 2)

Primary and secondary storage locations have not been selected yet; once locations are finalized implementation strategies and routes will be assessed for hazard impact, and will be communicated in a future 6 month update following identification. Storage locations will be chosen in order to support the event timeline.

This plan defines strategies capable of mitigating a simultaneous loss of all alternating current (ac) power and loss of normal access to the ultimate heat sink resulting from a beyond-design-basis event by providing adequate capability to maintain or restore core cooling, containment, and 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 emergency operating procedures in accordance with established EP change processes, and their impact to the design basis capabilities of the unit evaluated under 10 CFR 50.59. The plant Technical Specifications 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 beyond-design-basis event may place the plant in a condition where it cannot comply with certain Technical Specifications, and, as such, may warrant invocation of 10 CFR 50,54(x) and/or 10 CFR 73.55(p)

(Ref. 3),

References:

1. WCAP-17601-P Rev 0, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, & Babcock &

Wilcox NSSS Designs, dated August 2012.

2. NEI 12-01 Rev. 0, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012.

Page 4 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 06).

once.. '--'.......... JA.. '"

routes and will be communicated following Storage locations chosen order to support event "'~'''''''L&.-'.

capable of mitigating a

1.

1"""~'1n<:lr'lnl'r cunent (ac) nA'H""'f"

..... L.......,.... U... J to anticipate the strategies are also ri1'J'A'f"C

a wide range possible conditions.

strategies developed to protect safety be incorporated into operating procedures in accordance change processes, capabilities of the sink 50.59. The Specifications ""'V~...,.u,~~

1L~"'JUl"'JLL conditions for normal to ensure that design safety features are available to to a design basis accident and the actions to be the limiting conditions are not met.

beyond-design-basis event it cannot comply vv.Ul.lUvU.l Specifications, as such, may warrant invocation of 50.54(x) 10 73.55(p)

(Ref. 3).

Page 4of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General ntegrated Plan Elements PWR Task Interface Agreement (TIA) 2004-04, "Acceptability of Proceduralized Departures from Technical Specifications (TSs) Requirements at the Surry Power Station," (TAC Nos. MC4331 and MC4332)," dated September 12, 2006. (Accession No. ML060590273)

Include a description of any alternatives to the guidance, and provide a milestone schedule of planned action.

Full conformance with JLD-ISG-2012-01 Rev. 0 and NEI 12-06 Rev. 0 is expected with no deviations.

Strategies that have a time constraint to be successful should be identified with a technical basis and a justification provided that the time can reasonably be met (for example, a walk through of deployment).

Describe in detail in this section the technical basis for the time constraint identified on the sequence of events timeline Attachment IA.

See attached sequence of events timeline (Attachment 1A).

Technical Basis Support information, see attached NSSS Significant Reference Analysis Deviation Table (Attachment IB).

Braidwood Station timeline is outlined in Attachment IA.

The times to complete actions in the Events Timeline are based on operating judgment, the conceptual designs, and the current supporting analyses. The final timeline will be e validated once detailed designs are completed and procedures are developed, The results will be provided in a future 6-month update.

5 to 15 minutes - Based on the plant response and the direction from the Emergency Operating Extent to which the guidance, JLD-ISG-2012-01 and NEI 12-06, are being followed. Identify any deviations to JLD-ISG-2012-01 and NEI 12-06.

Ref: JLD-ISG-2012-01 NEI 12-06 13.1 Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint.

Ref: NEI 12-06 section 3.2.1.7 JLD-ISG-2012-01 section 2.1 Page 5 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Extent to which the guidance, JLD-ISG-2012.. 01 and NEI 12.. 06, are being followed. Identify any deviations to JLD.. ISG*2012-01 and NEI 12-06.

Ref: JLD.. ISG.. 2012-01 NEII2.. 0613.1 2.1

3.

Include a description of any alternatives to the guidance, and provide a milestone schedule of planned action.

conformance JLD-ISG-2012-01 Rev. 0 and 12-06 0 is c..'V....,,,.nt-,",-t no Strategies that have a time constraint to be successful should be identified with a technical basis and a justification provided that the time can reasonably be met (for example, a walk through of deployment).

Describe in detail in this section the technical basis for the time constraint identified on the sequence of events time line Attachment lAo See attached sequence of events timeline (Attachment lAY.

Technical Basis Support information, see attached NSSS Significant Reference Analysis Deviation Table (Attachment lB).

a Page 5 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General integrated Plan Elements PWR Procedures BCA 0.0, Loss of All AC Power, an operator is dispatched to the B AFW Pump and will ensure that it is properly aligned and low suction pressure is reset if needed. Operators will then verify that the pump is started and running properly. The one (1) hour time constraint is based on the results of MAAP analysis BW-MISC-009 (Ref. 1). The MAAP calculation shows SG dryout will occur within 61 minutes without AF flow as referenced in the WCAP-17601-P (Ref. 2).

1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months - The control room will begin to direct a cooldown of the RCS by local operation of the S/G PORVs and local control of the AF flow control valves to reduce S/G pressure down to at least 300 psia at a minimum of 75°F/hr (MAAP Anaysis Ref, 2

30 minutes to 3.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - After the Station DGs have been verified to be not available, an operator is dispatched to the Div 2 ESF Switchgear Bus _32X and verifies all breakers are open, and then will proceed to the FLEX Building and prep and align the FLEX DG to the station connections. Once aligned the FLEX. DG will be started and a controlled loading will occur to restore power to the required Div 125 volt DC Battery charger and to the Div 2 125 Volt instrument busses. The 3.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time constraint is based on the results of EC Evaluation 391834 (Ref. 3). The EC calculation shows the DC bus 112 voltage will be below acceptable values after 3.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months without operator action.

References:

1. EC Evaluation 391834, Battery Coping Time For The 125V DC ESF Battery Banks, dated February 12, 2013 2.

Byro raidwood MAAP analysis Documentation NO BB-MISC-020 Rev 0 dated February 1, 2013 3.

Braidwood Station MAAP analysis Documentation NO.

BW-MISC-009 Rev 1 dated November 1, 2011 Page 6of68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR one is on MAAP analysis BW-MISC-009 (Ref. 1).

MAAP calculation shows SG dryout occur within without AF as ?<oT'a.. a..... l"c.ri WCAP-17601-P (Ref. 2).

1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months s-2),

,.. n... L'"''' to be not available, an ""'-'O,"-I,",,r dispatched to the Div 2 ESF and are open, and then will prep align bus 1

1.

2.

3.

Page 6 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General I Identify how strategies will be deployed in all modes.

Ref: NEI 12-06 section 13.1.6 Provide a milestone schedule. This schedule should include:

Modifications timeline o

Phase 1 Modifications o

Phase 2 Modifications o

Phase 3 Modifications 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 ntegrated Plan Elements PWR Describe how the strategies will be deployed in all modes.

Deployment of FLEX is expected for all modes of operation. Transportation routes will be developed from the equipment storage area to the FLEX staging areas. An administrative program will be developed to ensure pathways remain clear or compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation. This administrative program will also ensure the strategies can be implemented in all modes by maintaining the portable FLEX equipment available to be deployed during all modes.

Identification of storage and creation of the administrative program are open items. Closure of these items will be communicated in a future 6-month update.

The dates specifically required by the order are obligated or committed dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

See attached milestone schedule (Attachment 2).

Exelon Generation Company, LLC (Exelon) fully expects to meet the site implementation/compliance dates provided in Order EA-12-049 with no exceptions. Any changes or additions to the planned interim milestone dates will. be provided in a future 6-month update.

Page 7 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Identify how strategies will be deployed in all modes.

Ref: NEI 12~06 section 13.1.6 Provide a milestone schedule. This schedule should include:

Modifications timeline o Phase 1 Modifications o Phase2 Modifications o Phase3 Modifications 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 Describe how the strategies will be deployed in all m,odes.

Ol.U;::;".lU.;::;" areas.

rln.'TD>"'-"""U:;'ro to ensure clear or compensatory actions will be

.l.I.I.J.,IJJ.'-'.l.U,,",'J..lL'-,U to ensure all strategies can deployed modes of operation. This administrative program also ensure strategies can by.......... ".................. Ju.. F, be deployed ~~AAAA""

The dates specifically required by the order are obligated or com,mitted dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

Page 7 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Provide a description of the programmatic controls equipment protection, storage and deployment and equipment quality. See section 11 in NEI 12-06. Storage of equipment, 11.3, will be documented in later sections of this template and need not be included in this section.

See section 6.0 of JLD-ISG-2012-01.

Braidwood Station will implement an administrative program for FLEX to establish responsibilities, and testing

& maintenance requirements. A plant system designation will be assigned to FLEX equipment which requires configuration controls associated with systems. This will establish responsibilities, maintenance and testing requirements for all components associated with FLEX.

Unique identification numbers will be assigned to all components added to the FLEX plant system. Equipment associated with these strategies will be procured as commercial equipment with design, storage, maintenance, testing, and configuration control as outlined in JLD-ISG-2012-01 Rev. 0 section 6 and NEI 12-06 Rev 0 section 11.

Installed structures, systems and components pursuant to 1OC 850.63 (a) will continue to meet the augmented quality guidelines of Regulatory Guide 1.155, Station Blackout. Standard industry PMs will be developed to establish maintenance and testing frequencies based on type of equipment and will be within EPRI guidelines. Testing procedures will be developed based on the industry PM templates and Exelon standards. Braidwood' s administrative program for FLEX responsibilities, and testing &

maintenance are open items. Closure of this item will be communicated in a future 6-month update.

List training plans for affected organizations or describe the plan for training development Training materials for FLEX will be developed for all station staff involved in implementing FLEX strategies. For accredited training programs, the Systematic Approach to Training (SAT) will be used to determine training needs. For other station staff, a training overview will be Ref: NEI 12-06 section 13.1 Identify how the programmatic controls will be met.

Ref: NEI 12-06 section 11 JLD-ISG-2012 -01 section 6.0 Describe training plan Page 8 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Ref: NEI 12~06 section 13.1 Identify how the programmatic controls will be met.

Ref: NEI 12~06 section 11 JLD*ISG~2012~01 section 6.0 Describe training plan Provide a description of the programnzatic controls equipment protection, storage and deployment and equipment quality. See section 11 in NEI 12~06. Storage of equipment, 11.3, will be documented in later sections of this template and need not be included in this section.

See section 6.0 of JLD-ISG~2012-01.

Braidwood Station List training plans for affected organizations or describe the planfor training development Page 8 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR developed and communicated. Closure of this item will be communicated in a future 6-month update.

Braidwood Station has contractual agreements in place with the Strategic Alliance for FLEX Emergency Response (SAFER). The industry will establish two (2) Regional Response Centers (RRC) located in Tennessee and Arizona to support utilities during beyond design basis events. Each RRC will hold five (5) sets of equipment, four (4) of which will be able to be fully deployed when requested, the fifth set will have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local Assembly Area, established by the 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 will be delivered to the site within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the initial request (Ref. 1). Development of Braidwood Station's playbook will be communicated in a future 6-month update.

References:

1.

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

Notes:

Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Describe Regional Response Center plan Page 9 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Describe Regional Response Center plan Notes:

developed

1.

Page 90f68 be

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & 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:

AFW/EFW Depressurize SG for Makeup with Portable Injection Source Sustained Source of Water I Ref: JLD-ISG-2012-01 section 2 and 3 PWR Installed Equipment Phase 1 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain core cooling. Identify methods and strategy(ies) utilized to achieve this coping time.

At the initiation of the event operators will enter Emergency Operating Procedure (EOP) BwCA 0.0, Loss of All AC. The Extended Loss of AC Power (FLAP), BwCA 0.0 Attachment B, will be entered when the emergency diesel generators are confirmed unavailable and off-site power cannot be restored and it is confirmed by dispatcher or visual verification of physical damage to infrastructure at site.

Within 90 minutes, operators will cool down the plant at approximately 75 F/hr to 420 F ('Told).

Steam generator (SG) pressure will be approximately 300 psia at this temperature. Steam generator pressure of 300 psia corresponds to RCS pressure necessary to inject SI accumulators.

This will ensure RCS pressure is above the minimum pressure to preclude injection of accumulator nitrogen into the RCS (MAAP Ref. 1) (WCAP-17601-P Ref.2)

During cool down the Diesel Driven Auxiliary Feedwater (DDAF) pump will deliver water from the Ultimate Heat Sink (UHS) via Essential Service Water (SX) system to the SGs.

Cold Shutdown and Refueling:

When in Cold Shutdown and Refueling, many variables exist which impact the ability to cool the core. In the event of an ELAP during these Modes, installed plant systems cannot be relied upon to cool the core, thus transition to Phase 2 will begin immediately. All efforts will be made to expeditiously provide core cooling and minimize heat-up and repressurization. Exelon has a program in place (Ref. 3) to determine the time to boil for all conditions during shutdown periods.

This time will be used to determine the time required to complete transition to Phase 2.

To accommodate the activities of vessel disassembly and refueling, water levels in the reactor vessel and the reactor cavity are often changed. The most limiting condition is the case in which the reactor head is removed and water level in the vessel is at or below the reactor vessel flange. If an ELAP/LUHS occurs during this condition then (depending on the time after shutdown) boiling in the core may occur quite rapidly.

Deploying and implementing portable FLEX pumps to supply injection flow must commence

' 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.

Page 10 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & 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:

AFWIEFW Depressurize SG for Makeup with Portable Injection Source Sustained Source of Water Ref: lLD-ISG-2012-01 section 2 and 3 PWR Installed Equipment Phase 1 Provide a general description of the coping strategies using on-site portable equipment including station ntodifications that are proposed to maintain core cooling. Identify methods and strategy(ies) utilized to achieve this coping time.

of event operators enter Emergency AC. The Loss of Power ALLJ............... -', operators cool at 75 to 420 F (Tcold).

Steam generator (SG) pressure will be approximately 300 at temperature.

generator pressure of 300 psia corresponds to RCS pressure necessary to inject accumulators.

This pressure is above to preclude injection of

.... """"........................ U'.L..,UC.... 'V.... """A.L into the (MAAP Ref.

(WCAP-17601-P Ref.2) rI£1'",,,.1r water to cool periods.

reactor must commence 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.

Page 10 of 68

I Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal immediately from the time of the event. This should be plausible because more personnel are on site during outages to provide the necessary resources. Strategies for makeup water include deploying a FLEX. pump to take suction from the RWST and /or UHS as described in the Phase 2 Core Cooling section. Guidance will be provided to ensure that sufficient area is available for deployment and that haul paths remain accessible without interference from outage equipment during refueling outages.

Reference:

1. MAAP analysis BB-MISC-20 Rev. 0 dated February 1, 2013

2. WCAP-17601-P Rev 0, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, Babcock Wilcox NSSS Designs, dated August 2012.

3. OP-AA-108-117-1001 Rev 0, Spent Fuel Storage Pools Heat-up Rate With Loss of Normal Cooling, date July 22, 2011 Details:

Braidwood Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06 Rev 0. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

The following gaps have been identified that prevent operation of the DDAF pump: Braidwood Station will utilize modifications to close these gaps prior to FLEX implementation. Closure of these items will be communicated in a future 6-month update,

1. DDAF pump suction flow path is not available due to CST unavailability and failure of the CST isolation valve to close and the SX suction valve to open on loss of AC power

2. DDAF batteries are drained due to repetitive engine starts with automatic reset of low-low suction pressure trip

3. DDAF pump overheating due to cooling water recirculation flow paths within SX system cycling and overheating the pump within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

_..................... _._....... _...r.........

Essential Instrumentation Safet Function SG Pressure:

RCS pressure boundary and P1-515, PI-516, PI-525, PI-535, pressure control Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Reactor Parameters PI-545 and PI-546 SG Leve RCS pressure boundary and 9,a_..

.7Pressure1 control NR - LI-517 Page 11 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal

1.

2.

Rev 0, Reactor '--VA..... 'I

'<Tro..,.r1Ic,rw Loss Power for Westinghouse, "-V.... UJOAu... rv...LJu.r-,:u.J.""V.L.iCU',fO."

'->n11'IU'" & Wilcox NSSS Designs, dated 2012.

3.

108-117-1001 Rev Spent Storage Pools Loss of 22,2011 Details:

developed guidance team to Provide a brief description of Procedures I Strategies I Guidelines

'-'jJ'-'....... L.JL..... procedures or guidelines to address criteria O.

and/or guidelines will the existing symptom based command and control strategies in the current Identify modifications Key Reactor Parameters Page 11 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan

-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS Temperature:

Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 Containment Pressure: PI-PCO05 SFP Level: (component #

TBD)

.pressure control Containment Integrity

-- -.....m Inventory RCS Heat Removal RCS pressure boundary and Braidwood's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AFOI 8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NR006A/B, NI-36B IR.

Reference:

PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA-PSC-0965.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049, Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 12 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal Braidwood's evaluation of the are U"-'-\\'&VU procedures/guidance or to LU.... U.............

12-06 Rev. 0 Section a

addition to the listed in NEI 12-06 3.2.1.10, following additional will use as detailed strategy is developed. Closure of be in a 6-month update.

Core J.AvlUlIcJvlc}'ULJJ.v (CET)

LI951, J.UUlvUIL.1U;::' System (RVLIS):

FI-AF016A and 18A

1.

PSC-096S.

Page 12 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on -site portable equipment including station modifications that are proposed to maintain core cooling. Identify methods and strategy(ies) utilized to achieve this coping time.

Phase 2 Core Cooling will be achieved with a portable FLEX diesel pump and SG POR V's. The pump suction will come from the RWST and UHS. The FLEX pump discharge will be into the AFW lines downstream of the containment isolation valves into the SG's. The PORV's will be used to control SG pressure.

In the event that the Unit is in a refueling outage, another portable FLEX pumps will also be able to supply the RCS Boil-off using the modifications outlined in Phase 2 inventory control.

Electrical power to support the FLEX strategy is described in the Safety Function Support section of the document.

Details:

Braidwood Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

The following modifications will be installed to support FLEX pump water injection into the SGs:

FLEX pump discharge: Install Pipe flange connections on the A, D, B and C Auxiliary feed water (AF) SG injection lines at the test flanges within the Main Steam Isolation Valve (MSIV) rooms.

Connect the pipe flanges with a header routed through the steam tunnel. One end of the header will be routed to the B/C MSIV room and terminated with a standard FLEX connection (Primary connection) and the other end will be routed to the A/D MSIV room and terminated with a standard FLEX connection (Alternate connection).

FLEX pump suction: A tee will be installed on the B SI pump suction line. A header will be routed from the tee through the RWST tunnel to the RWST tunnel access hatch or alternate path and terminated with a standard FLEX connection. Additionally, hoses could be run from the UHS as suction backup source.

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Page 13 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain core cooling. Identify methods and strategy(ies) utilized to achieve this coping time.

2 be a......-..7"'.-... ""I n suction will come from the R WST and DRS. The downstream of the r>rvrlt<:l1nnnt::>nt Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications

outage, portable FLEX 1J~,ljUIJ\\J will be able to rn.n.r'l11".n"t-.A,nC' outlined in Phase 2 1n.. ;rnnt-Ar~T Details:

Owners team to develop specific procedures or guidelines to address the criteria in NEI 12-06.

flange connections on A,

water SG injection at the test Steam Isolation Valve (MSIV) rooms.

a header.. r. *

1'nrl 1'1->...,,,,, ".1->

be.. "".* "".-1 Page 13 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key Reactor Parameters SG Pressure:

PI-515, PI-516, PI-525, PI-53`

PI-545 and PI-546 SG Level:

NR - LI517, LI-519, LI-527, LI-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS pressure boundary and pressure control RCS pressure boundary and pressure control RCS Temperature:

RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR PI 403 RCS pressure boundary and Containment Pressure: PI-PCO05 pressure control Containment Integrity SFP Level: (component #

SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0, Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0, Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 W Flow: FI-AF012A, FI-AF0I4A, FI-AF016A and FI 018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06

, NI-36B IR

Reference:

1. PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA-PSC-0965.

Page 14 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key Reactor Parameters NR - LI-S17, LI-S19, LI-S27, LI-S37, LI-S47 and LI-S49 WR - LI-S02 LI-S03 (component #

Page 14 of 68 pressure control Res Removal

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section

11. Schedule to construct permanent building is contained in, and will satisfy the site compliance date. Temporary locations will be used until building construction completion.

Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section