RS-13-021, 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)

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)

ML13060A421
Person / Time
Site:	LaSalle
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-13-021
Download: ML13060A421 (74)

Text

1 Exelon Generation Order No. EA-12-049 RS-13-021 February 28, 2013 U.S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

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 LaSalle County 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:

. LaSalle County 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 - LaSalle County Station, Units 1 and 2 NRC Project Manager, NRR - LaSalle County 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-1 2-049 February 28, 2013 Page 3 bcc: Site Vice President - LaSalle County Station, Units 1 and 2 Vice President Operations Support Plant Manager, LaSalle County Station, Units 1 and 2 Site Engineering Director - LaSalle County Station, Units 1 and 2 Regulatory Affairs Manager Regulatory Assurance Manager - LaSalle County Station, Units 1 and 2 Severe Accident Management Director Site Operations Director - LaSalle County Station, Units 1 and 2 Corporate Licensing Manager - West Corporate Licensing Director - West Exelon Records Management Vinod Aggarwal Steven Pierson Brian Cummings David Schupp

Enclosure 1 LaSalle County Station, Units 1 and 2 Mitigation Strategies (MS)

Overall Integrated Plan (70 pages)

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements BWR Site: LaSalle County Station (LSCS)

Determine Applicable Input the hazards applicable to the site; seismic, external Extreme External Hazard flood, high winds, snow, ice, cold, high temps.

Describe how NEI 12-06 sections S - 9 were applied and Ref: NEI 12-06 section 4.0 -9.0 the basis for why the plant screened out for certain hazards.

JLD-ISG-2012-01 section 1.0 Seismic events; severe storms with high winds; snow, ice and extreme cold; and high temperatures were determined to be applicable Extreme External Hazards for LaSalle County Station (LSCS) per the guidance of NEI 12-06 and are as follows:

The LaSalle County Station, Units 1 and 2 (LSCS) is located in Brookfield Township of LaSalle County in northeastern Illinois. The Illinois River is 5 miles north of the site. The midpoint of the approximate centerline between the two reactors in the Universal Transverse Mercator Coordinate System is 4,567,200 meters north and 360,200 meters east, which corresponds to 41°14'44" north latitude and 88°40'06" west longitude.

The site is subject to typical continental meteorology characterized by high variability and a wide range of temperature extremes. Precipitation at LSCS site area averages approximately 34 inches annually. This includes an annual average of 27 inches of snow. At Peoria, the data show thunderstorms occur on an average of 49 days per year for the period 1944-1976. In the LSCS area, winds are from the south or southwest during the summer months and from the west for five months of winter. The probability of tornado occurrence at the site is 0.016 for any given year, which converts to a recurrence interval of 625 years.

Seismic Hazard Assessment:

Per the Updated Final Safety Analysis Report (UFSAR)

Section 3.7 (Reference 1) the seismic criteria for LaSalle County Nuclear Station (LSCS) include two design basis earthquake spectra: Operating Basis Earthquake (OBE) and the Safe Shutdown Earthquake (SSE), The maximum horizontal ground acceleration at the free field foundation level, corresponding to above site response spectra, is 20%

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LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan gravity for SSE and 10% gravity for OBE. These values constitute the design basis of LSCS. Per Reference 2, all sites will consider the seismic hazard.

External Flood Assessment:

Per the LaSalle Updated Final Safety Analysis Report (UFSAR) Section 2.4: Since there are no large bodies of water in the immediate vicinity of the site, surges, seiches, and tsunami floods are not relevant. A review of the literature has revealed no major dam failures affecting the surrounding region.

Of the following flood events considered, Item 3 is the controlling event: (1) a postulated probable maximum flood (PMF) in the Illinois River, (2) a probable maximum precipitation (PMP) with antecedent standard project storm (SPS) on the cooling lake and its drainage area, and (3) a local PMP at the plant site. The station site is "floodproof" or "dry" with regard to a postulated PMF in the Illinois River, since the plant floor at elevation 710.5 feet MSL is 188 feet higher than the probable maximum flood plus wave runup elevation of 522.5 feet MSL obtained by superimposing the maximum (1%) wave characteristics of sustained 40-mph overland winds on the probable maximum water level. Safety-related structures at the plant site are similarly unaffected by wave runup due to winds coincident with a postulated probable maximum water level in the cooling lake.

In the hydrologic design of the 2058-acre cooling lake, a standard project storm (SPS) is postulated to occur prior to the probable maximum precipitation (PMP), with three rainless days between them. The freeboard and riprap requirements for the peripheral dike are determined by superimposing significant wave characteristics of sustained 40-mph overland winds on the probable maximum water level in the lake. Wave runup elevation at the plant site is obtained by superimposing the maximum (1%) wave characteristics of sustained 40-mph overland winds on the probable maximum water level in the lake. Safety-related facilities at the plant site are unaffected by the probable maximum water level in the lake with coincident wind wave activity.

A conservative estimate of the water surface elevation near the plant buildings due to local intense precipitation at the plant area would 710.3 feet. These elevations are below the Page 2 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan plant grade elevation and would not cause flooding to the plant buildings. Therefore, the LSCS site is "floodproof" or "dry" and the External Flood Hazard is not applicable.

High Wind Hazard Assessment:

LSCS is not susceptible to hurricanes due to location (Reference Figure 7-1 of NEI 12-06). Figure 7-2 from the NET FLEX implementation Guide (Reference 2) was used for this assessment. It was determined that LSCS site is in Region I and will have winds exceeding 200 mph.

Therefore, the high wind hazard is applicable to LSCS.

Snow, Ice and Extreme Cold Assessment.

Figure 8-1 from NEI FLEX implementation Guide (Reference 2) was used for this assessment. Also, Figure 8-2, "Maximum Ice Storm Severity Maps [Ref. 16]," shows LSCS in a Ice Severity Level 5 zone. Therefore, snow, ice and extreme cold are applicable to LSCS.

Extreme High Temperature Assessment:

NEI 12-06 states that all sites must consider high temperatures. Extreme drought and high temperature events are slow meteorological evolutions.

References

1. LaSalle County Power Station Updated Final Safety Analysis Report (UFSAR), Revision 19, April 2012

2. "Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide", NEI 12-06, Revision 0, August 2012 Key Site assumptions to The key assumptions associated with implementation of the implement NEI 12-06 FLEX strategies at LaSalle County Station are:

strategies.

• BWROG EOP Revision EPG/SAG Rev.3, Ref: NEI 12-06 section 3 .2.1 containing items such as guidance to allow early venting and to maintain steam driven injection equipment available during emergency depressurization, is approved and implemented in time to support the compliance date.

• 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 Page 3 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan 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.

• Additional staff resources are assumed to begin arriving at hour six (6) and fully staffed by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

• DC systems are available.

• AC and DC distribution systems are available.

• Plant initial response is the same as Station Black Out (SBO).

• No additional single failures of any SSC are assumed (beyond the initial failures that define the ELAP/LUHS scenario in NEI 12-06).

• Primary and secondary storage locations have not been selected; once locations are finalized implementation routes will be defined.

• 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 EOP 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).

• Maximum environmental room temperatures for habitability or equipment availability is based on NUMARC 87-00 (Reference 1) guidance if other Page 4 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan design basis information or industry guidance is not available.

References:

1. NUMARC 87-00, "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors," Rev. 1 Extent to which the guidance, JLD-ISG-2012-01 Full conformance with JLD-ISG-2012-01 and NEI 12-06 is and NEI 12- 06, are being expected with no deviations.

followed. Identify any deviations to JLD-ISG-2012-01 and NET 12-06.

Ref: JLD-ISG-2012-01 NEI 12-06 13.1 Provide a sequence of events Strategies that have a time constraint to be successful and identify any time should be identified with a technical basis and a constraint required for justification provided that the time can reasonably be met success including the (for example, a walk through of deployment),

technical basis for the time constraint. Describe in detail in this section the technical basis for the time constraint identified on the sequence of events timeline Ref: NEI 12-06 section 3 .2.1.7 Attachment JA.

JLD-ISG-2012- 01 section 2.1 See Attachment IA for the Sequence of Events Timeline.

Discussion of key events, and any applicable technical basis, is provided below.

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

Time Constraints and Technical Basis:

Action Item #3:

Entering the applicable Emergency Operating Procedures Page 5 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan (EOPs) and abnormal procedures for SBO is listed as time critical because there are time critical/sensitive actions required in the SBO procedures (discussed below) and it is important to enter the procedures and initiate the actions in a timely manner.

Action Item #9:

LaSalle has existing time critical actions to take control of the Automatic Depressurization System (ADS)

Safety/Relief Valves (SRVs) from the Aux Building Electric Equipment Room (AEER) within 20 minutes to establish the less than or equal to 20 deg F/hr cooldown rate for the SBO event.

Action Item #10:

Completion of the initial DC load shedding, as specified by the current SBO procedure, within 30 min supports the analyzed coping capability of the batteries.

125 VDC and 250 VDC Battery coping times have been analyzed per engineering evaluation and are documented in LaSalle EC 391795 (Ref 1) with the following results:

125 VDC Systems Unit 1 125 VDC Div 1 Battery 1DC07E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 2) and an extended load shed is completed prior to 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

125 VDC Div 2 Battery 1DC14E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 2) and an extended load shed is completed prior to 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

Unit 2 125 VDC Div 1 Battery 2DC07E Eight (8) hour coping time is demonstrated provided that the Page 6 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan F

existing SBO load shed is completed per the current SBO procedure (Ref. 2) and an extended load shed is completed prior to 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

125 VDC Div 2 Battery 2DC14E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref, 2). An extended load shed is not required for this battery.

250 VDC Systems Unit 1 250 VDC Battery 1DCOIE Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 2). An extended load shed is not required for this battery.

Unit 2 250 VDC Battery 2DCO1E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 2). An extended load shed is not required for this battery.

These battery profiles drive the actions to complete the initial DC load shedding and then to perform the extended DC load shedding (as required) once Extended Loss of AC Power (FLAP) has been declared. These actions collectively support an analyzed coping time of at least eight (8) hrs for each battery. The eight (8) hrs is conservative as a result of the model only being extended to eight (8) hrs to reflect the currently available vendor battery discharge curves.

LaSalle has an existing time critical action for SBO to perform a DC load shed with completion times of 30 minutes and 180 minutes. These same SBO actions are reflected in the ELAP Event Timeline. An additional extended DC load shed is included in the Timeline actions to support the eight (8) hr coping times.

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LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Action Items #12 & #13:

Opening all panel doors in the Main Control Room and AEER within 30 minutes is time sensitive because it supports the temperature transient calculations that were performed for SBO conditions and the application of NUMARC 87-00, Rev. 1 requirements.

Action Item #14:

Time period of one (1) hr is selected to ensure that ELAP entry conditions can be verified by control room staff and it is validated that emergency diesel generators (EDGs) are not available. One (1) hour is a reasonable assumption for operators to perform initial evaluation of the EDGs. Entry into ELAP provides guidance to operators to perform ELAP load shedding and FLEX equipment deployment actions.

Action Item #17:

Completion of the 250 VDC load shedding per the existing SBO procedure (Ref. 2) supports the DC coping time evaluations (see discussion above for Action Item #10).

Action Item #18:

Completion of the extended 125 VDC load shedding supports the DC coping analysis for ELAP (see discussion above for Action Item #10).

Action Item #19:

Manual control of the ADS SRVs requires adequate nitrogen supply to the ADS accumulators. Existing SBO nitrogen supply calculation L-003263, Rev. 2, "Volume Requirements for ADS Back-up Compressed Gas System (Bottle Banks) (Ref. 3), states that the 20 degree/hr cooldown rate would require 28 ADS SRV actuations in a four (4) hour period. It also calculates that both ADS nitrogen bottle banks can support 38 actuations. At a rate of

-7 actuations per hour, additional nitrogen supply will be required at -5 hours.

Action Item #21:

Connection of the FLEX 480 VAC generator to supply power to the 125 VDC and 250 VDC battery chargers within six (6) hours supports the DC coping analysis (with Page 8 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan margin). See discussion for Action Item #10.

Action Item #22:

The basic coping strategy being pursued at LaSalle is a cooldown of less than or equal to 20°F/hr coupled with an early containment venting strategy and makeup to the suppression pool via an external source such that RCIC is maintained available for RPV level control. The following timeline events are based on the MAAP analysis (Ref. 4, Case 3.e):

• The conceptual early containment venting trigger of 12 psig wetwell pressure is reached at -5.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

A wetwell pressure of -8 psig is then regulated via the Hardened Containment Vent System (HCVS) to maintain the suppression pool temperature at -234°F for long term RCIC operation.

• Suppression pool makeup via the external source (FLEX pump with UHS suction source) is initiated at -6 hours based on suppression pool level decreasing as a result of the containment venting.

• The HCTL curve is exceeded at -6.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.

• The Pressure Suppression Pressure Limit/Curve is NOT exceeded under this strategy.

• DW airspace temperature does NOT exceed the EOP limit of 340°F (peaks at 261°F under this strategy).

Action Item #24:

Per GOTHIC Analysis (Ref. 5), RCIC Room temperature reaches 169°F (equipment acceptance limit per Ref. 8) at 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. This drives the action to provide external air flow to the RCIC room. The time of 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> to initiate external air flow to the RCIC room is established to provide margin to the calculated value.

Action Item #25:

An evaluation of Spent Fuel Pool scenarios was performed and documented in LaSalle EC 392196 (Ref. 6). Spent Fuel Pool (SFP) makeup is not a time constraint with the initial condition of Mode 1 at 100% power, since the worst case fuel pool heat load conditions only exist during a refueling outage. Under non-outage conditions, the maximum SFP heat load is 27.38 MBtu/hr. Loss of SFP cooling with this heat load and an initial SFP temperature of 140 degrees F results in a time to boil of 12.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and 123 hours0.00142 days <br />0.0342 hours <br />2.03373e-4 weeks <br />4.68015e-5 months <br /> to the Page 9 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan top of active fuel. Therefore, completing the equipment line-up for initiating SFP makeup at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> into the event ensures adequate cooling of the spent fuel is maintained.

The worst case SFP heat load during an outage is 56.03 MBtu/hr. Loss of SFP cooling with this heat load and an initial SFP temperature of 140 degrees F results in a time to boil of 5.86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br />, and 60.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to the top of active fuel.

With the entire core being located in the SFP, manpower resources normally allocated to aligning core cooling along with the Operations outage shift manpower can be allocated to aligning SFP makeup which ensures the system alignment can be established within eight (8) hours.

Initiation at eight (8) hours into the event ensures adequate cooling of the spent fuel is maintained.

Initial evaluations were used to determine the fuel pool timelines. Formal calculations will be performed to validate this information during development of the spent fuel pool cooling strategy detailed design, and will be provided in a future six (6) month update.

BWROG FLEX Document:

Issuance of BWROG document NEDC-33771P, "GEH Evaluation of FLEX Implementation Guidelines" on 1/31/13 (Ref. 7) did not allow sufficient time to perform the analysis of the deviations between Exelon's engineering analyses and the analyses contained in the BWROG document prior to commencing regulatory reviews of the Integrated Plan. This analysis is expected to be completed, documented on Attachment 1B, and provided to the NRC in the August 2013 six (6) month status update.

References:

1. LaSalle Engineering Evaluation EC 391795, Rev.

000, "Battery Coping Times During ELAP with Extended Load Shedding."

2. LaSalle Abnormal Operating Procedure LOA-AP-101, "Unit 1 AC Power System Abnormal," Rev. 42

{Unit 2, LOA-AP-201, Rev. 36}

3. LaSalle Calculation L-003263, Rev. 02, "Volume Requirements for ADS Back-up Compressed Gas System (Bottle Banks)"

4. LS-MISC-017, Rev. 1, "MAAP Analysis to Support Initial FLEX Strategy," LaSalle Units 1 and 2

5. Sargent & Lundy Calculation 2012-11819, Rev. 0, Page 10 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Inte grated Plan "Transient Analysis of RCIC Pump Room for Extended Loss of A-C Power,"

6. LaSalle Engineering Evaluation EC 392196, Rev. 0, "Spent Fuel Pool Uncovery Time for Outage and Online Scenarios,"

7. GE Hitachi Nuclear Energy, NEDC-33771P, "GEH Evaluation of FLEX Implementation Guidelines,"

Rev, 1

8. LaSalle Calculation ATD-035 1, "RCIC Pump Room Temperature Transient Following Station Blackout with Gland Seal Leakage," Rev. 3 Identify how strategies will Deployment of FLEX is expected for all modes of be deployed in all modes. operation. Transportation routes will be developed from the equipment storage area to the FLEX staging areas. An Ref: NEI 12-06 section 13 .1.6 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 areas and creation of the administrative program are open items. Closure of these items will be documented in a six (6) month update.

Provide a milestone See the Milestone Schedule provided in Attachment 2.

schedule. This schedule should include: Exelon Generation Company, LLC (Exelon) fully expects to

• Modifications timeline meet the site implementation/compliance dates provided in o Phase 1 Order EA-12-049 with no exceptions. Any changes or Modifications additions to the planned interim milestone dates will be o Phase 2 provided in a future six (6) month update.

Modifications o Phase 3 Modifications

• Procedure guidance development complete o Strategies o Maintenance

• Storage plan (reasonable protection)

• Staffing analysis completion Page 11 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan

• FLEX equipment acquisition timeline

• Training completion for the strategies

• Regional Response Centers operational Ref: NEI 12-06 section 13.1 Identify how the LaSalle will implement an administrative program for programmatic controls will FLEX to establish responsibilities, and testing &

be met. maintenance requirements. A plant system designation will be assigned to FLEX equipment which requires Ref: NEI 12-06 section 11 configuration controls associated with systems. This will JLD-ISG-2012-01 section 6.0 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 section 6 and NEI 12-06 section 11. Installed structures, systems and components pursuant to IOCFR50.63(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.

Describe training plan 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 developed per change management plan.

Describe Regional Response LSCS has contractual agreements in place with the Strategic Center plan Alliance for FLEX Emergency Response (SAFER).

The industry will establish two (2) Regional Response Centers (RRC) 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 Page 12 of 70

LaSalle County Station, Units I and 2 Mitigation S ategies Integrated Plan 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the initial request.

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

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LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling Determine Baseline coping capability with installed coping' modifications not including FLEX modifications, utilizing methods described in Table 3-1 of NEI 12-06:

• RCIC/HPCI/IC

• Depressurize RPV for injection with portable injection source e Sustained water source BWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain core cooling. Identify methods (RCIC/HPCI/IC}and strategy(ies) utilized to achieve this coping time.

RCIC System Summary The Reactor Core Isolation Cooling (RCIC) system consists of a turbine, pump, piping, valves, accessories, and instrumentation designed to add water inventory to the reactor vessel thus assuring continuity of core cooling. Reactor vessel water is maintained or supplemented by the RCIC system during the following conditions:

a. Should the reactor vessel be isolated and yet maintained in the hot standby condition.

b. Should the reactor vessel by isolated and accompanied by a loss of normal coolant flow from the reactor feedwater system,

c. Should a complete plant shutdown under conditions of loss of normal feedwater system be started before the reactor is depressurized to a level where the reactor shutdown cooling mode of the RHR system can be placed into operation.

RCIC logic is powered from Division 1 and Division 2 125-Vdc. All valves are powered from 250-Vdc Bus 121/221Y, except the following: Inboard isolation valves E51-F063 and E51-F076 are powered from 480-Vac MCC Bus 136Y-2/236Y-2 and outboard isolation valve E51-F008 is powered from 480-Vac MCC, Bus 135X-1/235X-1.

When actuated, the RCIC system pumps water from either the condensate storage tank or the suppression pool to the reactor vessel. The RCIC system includes one turbine-driven pump, one barometric condenser with a d-c vacuum pump, one vacuum d-c condensate pump, automatic valves, control devices for this equipment, sensors, and logic circuitry.

The RCIC system is initiated automatically following a short time delay (not to exceed 3.0 seconds) after the receipt of a reactor vessel low water level signal and produces the design flow rate within 30 seconds. The controls then function to provide design makeup water flow to the reactor vessel until the amount of water delivered to the reactor vessel is adequate to restore vessel level, at which time the RCIC system automatically shuts down. The controls are arranged to allow remote-manual startup, operation, and shutdown.

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 14 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Overpressure Protection - Safety/Relief Valve Summary The nuclear pressure-relief system has been designed:

a. to prevent overpressurization of the nuclear system that could lead to the failure of the reactor coolant pressure boundary;

b. to provide automatic depressurization for small breaks in the nuclear system occurring with malfunction of the high-pressure core spray (HPCS) system, so that low-pressure coolant injection (LPCI-mode of RHR) and low-pressure core spray (LPCS) systems can operate to protect the fuel barrier;

c. to permit verification of its operability; and

d. to withstand adverse combinations of loadings and forces resulting from operation during abnormal, accident, or special event conditions.

The nuclear pressure relief system safety/relief valves have been designed to meet the following power generation bases:

a. discharge to the containment suppression pool, and

b. correctly reclose following operation so that maximum operational continuity can be obtained.

The nuclear pressure relief system consists of safety/relief valves located on the main steamlines between the reactor vessel and the first isolation valve within the drywell. These valves protect against overpressure of the nuclear system. The safety/relief valves provide three main protection functions:

a. Overpressure relief operation - The valves open automatically to limit a pressure rise.

b. Overpressure safety operation - The valves function as safety valves and open (self-actuated operation if not already automatically opened for relief operation) to prevent nuclear system overpressurization.

c. Depressurization operation - The ADS valves open automatically as part of the emergency core cooling system (ECCS) for events involving small breaks in the nuclear system process barrier.

Each of the seven safety/relief valves that make up the Automatic Depressurization System (ADS) is provided with its own ADS accumulator and inlet check valve. These accumulators assure that the valves can be opened to perform their ADS function in the event of a failure of the non-safety related Drywell Pneumatic System. One control switch is available in the control room for each safety/relief valve associated with the ADS. These manual switches backup the automatic depressurization function by activating a separate solenoid control valve on the safety/relief Page 15 of 70

LaSalle County Station, Units I and 2 Mitigation Strategies Integrated Plan valves. The switch is a two-position type OPEN -AUTO. The OPEN position is for manual safety/relief valve operation. Manual opening of the relief valves provides a controlled nuclear system cooldown under conditions where the normal heat sink is not available. ADS valves can be operated from the individual ADS logic relay panels.

Each ADS SRV has an ADS accumulator installed to provide a source of stored compressed gas for SRV operation. These accumulators are supplied by the Drywell Pneumatic System consisting of a safety-related portion and a non safety-related portion. The non safety-related portion is the normal pneumatic supply to the ADS accumulators. The safety-related portion, referred to as the ADS accumulator backup compressed gas system, maintains the ADS accumulators pressurized following a loss of the normal non safety-related pneumatic supply.

The ADS accumulator backup compressed gas system consists of two bottle banks that serve as the safety-related pneumatic supply for the seven ADS SRVs. One bottle bank supplies four of the seven ADS SRVs while the other serves the remaining three ADS SRVs. Each bottle bank consists of four bottles of compressed nitrogen and one reserve bottle at each bottle bank that can be utilized during bottle replacement. The reserve nitrogen bottle is valved in during the replacement of the four bottles installed at each bottle bank to allow for bottle change.

In addition, there is an emergency pressurization station in an accessible area of the auxiliary building at which each ADS gas line can be recharged indefinitely via nitrogen bottles brought to that point, in the event the reactor building becomes inaccessible.

In the SBO/ELAP event scenario, the ADS valves are controlled from the ADS logic relay panels in the Aux Electric Equipment Room (AEER) since the Main Control Room switches are associated with a solenoid that uses non-ADS nitrogen supply. The ADS valve control switches at the ADS logic relay panels are associated with solenoids that use the dedicated ADS nitrogen supply/accumulators.

Event Coping Strategy Using Installed Equipment:

Power Operation, Startup, and Hot Shutdown At the initiation of the event the operators will enter the applicable EOPs and the abnormal operating procedure for SBO (Ref. 1). The ELAP procedures will be entered when there has been a Loss of Offsite Power, including all five (5) on-site Emergency Diesel Generators, with confirmation of no imminent return of any of these power sources to service.

The RCIC System will maintain RPV water inventory using the suppression pool as a suction source, while the ADS SRVs will be used for RPV pressure control.

Venting of the containment will be initiated such that peak Suppression Pool temperature remains below the maximum allowed for RCIC operation. BWROG RCIC System Operation in Prolonged Station Blackout - Feasibility Study (Reference 2) indicates that RCIC will remain functional as long as Suppression Pool temperature can be maintained less than approximately 230° F.

Operation of RCIC above 230°F is currently being evaluated by General Electric and the Page 16 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan BWROG. (Ref. 3). The preliminary MAAP analysis (Ref. 4, Case 3.e) performed for strategy development indicated a maximum Suppression Pool temperature of 234° F. Additional work will be performed during detailed design development to ensure Suppression Pool temperature will support RCIC operation, in accordance with approved BWROG analysis, throughout the event.

The operators will commence a DC load shed to preserve DC power. Subsequently, the operators will reduce RPV pressure to 150-250 psig in order to maintain functionality of RCIC.

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. 5) 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 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 deployment of a FLEX pump to take suction from the UHS (CSCS room source or lake source) 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.

Analysis will be performed during development of the detailed design to validate the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. The results of this analysis will be provided during a scheduled six (6) month update. This update will include any changes to the initial designs and/or strategies as submitted in the February 28, 2013 Integrated Plan.

References:

1. LaSalle Abnormal Operating Procedure LOA-AP-101, "Unit 1 AC Power System Abnormal," Rev. 42 {Unit 2, LOA-AP-201, Rev. 36}

2. GEH/BWROG Project Task Report, "RCIC System Operation in Prolonged Station Blackout - Feasibility Study," 0000-0143-0382-R 1, March 2012

3. BWROG RCIC Pump and Turbine Durability Evaluation - Pinch Point Study, 0000-0155-1545-XX - currently in approval process

4. LS-MISC-017, Rev. 1, "MAAP Analysis to Support Initial FLEX Strategy," LaSalle Units 1 and 2

5. Exelon Nuclear Procedure OU-AA-103, "Shutdown Safety Management Program,"

Revision 12 Page 17 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Details:

Provide a brief Confirm that procedure/guidance exists or will be developed to description of Procedures support implementation.

/ Strategies / Guidelines The existing EOPs (LGA-001) address RPV control via RCIC and SRVs. LaSalle abnormal operating procedure LOA-AP-101 addresses the required actions for response to a SBO, including the initial DC load shedding.

LaSalle 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.

Identify modifications None Key Reactor Parameters List instrumentation credited for this coping evaluation.

1(2)C34-N004B, RPV Level (Control Room indicator is 1(2)C34-R606B)

• Narrow Range, 0-60 inches 1(2)C34-N004C, RPV Level (Control Room indicator is 1(2)C34-R606C)

• Narrow Range, 0-60 inches 1(2)E51-R602, RCIC Turbine Stearn Inlet Pressure (Control Room)

• 0-1500 psig 1(2)C61-8011, RPV Pressure (Remote Shutdown Panel)

• 0-1500 psig 1(2)C61-8010, RPV Level (Remote Shutdown Panel)

• Wide Range, -150 to +60 inches LaSalle'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 differences will be communicated in a future six (6) month update followin identification.

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 18 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain core cooling. Identify methods (RCICIHPCI/IC)and strategy(ies) utilized to achieve this coping time.

See Phase I discussion for RCIC System Summary.

See Phase I discussion for SRV summary.

Residual Heat Removal System

Description:

The RHR system provides several functional configurations generally known as modes of operation. The different modes of RHR operation include:

• Shutdown Cooling and Reactor Vessel Head Spray Mode o `B' RHR loop can be used for Fuel Pool Cooling

• Low-Pressure Coolant Injection Mode

• Containment Cooling Mode o Suppression Pool Cooling o Containment Spray These different modes of operation provide multiple flow paths for injection into the RPV, containment, and the spent fuel pool.

Core Standby Cooling System - E ui ment Cooling Water System

Description:

The CSCS-ECWS for each unit consists of three independent piping subsystems corresponding to the three essential electrical power supply divisions for each unit. All pumps and strainers are located in the basements of the buildings within watertight cubicles to provide separation between divisions and flood protection. The outdoor CSCS-ECWS piping is buried to provide tornado and missile protection.

The CSCS-ECW subsystems take a suction from the service water tunnel located in the basement of the Lake Screen House. The service water tunnel is kept full by six (6) inlet lines which connect to the Circulating Water pump forebays. Prior to entering the service water tunnel inlet pipes, the water is strained by the Lake Screen House travelling screens to prevent large pieces of debris from entering the system and blocking flow or damaging equipment. The travelling screens are not seismically designed nor are they supplied with electrical power from the plant essential power buses. A 54-inch normally closed bypass line is installed to assure access to a continuous supply of CSCS water to the system in the unlikely event that all the travelling screens become blocked.

Page 19 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 2:

One of the pumps in the CSCS-ECW system is the `B' Fuel Pool Cooling (FC) Emergency Makeup (EMU) Pump. This pump provides flow to the following locations:

1) Normally, pump discharge is configured to the "A" DG Strainer backwash line for testing purposes;

2) In an emergency, a spool piece is rotated to connect the pump discharge to the fuel pool make-up flooding hose station on the Refuel Floor;

3) Also in an emergency, alternate reactor and containment injection can be aligned through the `B' RHR loop.

In the strategy described below, the FLEX pump is pre-staged to essentially jumper around this `B' FC EMU pump to use the safety-related water source available in the CSCS pump room (UHS water from Lake Screen House/Lake) and discharge to the path described in item #3 above (RPV and containment). For this Core Cooling function, the path to the suppression pool is used for makeup (RCIC suction source) and the path to the RPV would be used in the event that RCIC becomes unavailable. The Core Cooling strategy conceptual design contains features to expedite and simplify implementation, and may not be required in order to meet the event timeline for maintaining the safety function requirements of NEI 12-06. See attached Conceptual Sketches (Attachment 3).

Event Coping Strategy Using Portable Equipment:

RCIC will continue to maintain RPV inventory.

SRVs will continue to be used to control RPV pressure.

The primary strategy for providing RPV injection via FLEX equipment (should RCIC become unavailable) will be via 480 VAC pumps installed in a Unit 1 and Unit 2 CSCS pump room (conceptual design is using installation in the Div. 2 CSCS pump room). These pre-staged FLEX pumps will be connected to an UHS water source available in the CSCS pump rooms and the discharge will be connected to the discharge of the existing `B' FC EMU pump. This flow path can provide injection to the RPV via the RHR system. This flow path can also provide makeup to the suppression pool to help maintain RCIC suction. These FLEX pumps will be powered via the existing 480 VAC distribution system that is powered by a portable 480 VAC FLEX generator. See attached Conceptual Sketches (Attachment 3).

The alternate strategy for providing RPV injection via FLEX equipment is to pump water from the UHS (lake location) using a high volume, low pressure pumping system that conceptually consists of a hydraulic submersible pump to be placed in the UHS water source that provides adequate flow/NPSH to a portable diesel driven pump (PDDP). The PDDP provides water to each reactor building where it is attached to a new water piping system that is included in the hardened containment vent chase that goes up the outside wall on the east side of each reactor building. This new water piping system will have penetrations into the reactor buildings at the 761 ft elevation for Page 20 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 2:

connection to the existing B.5.b RHR connections that provide a path for RPV injection. This RHR connection can also provide makeup to the suppression pool to help maintain RCIC suction. See attached Conceptual Sketches (Attachment 3).

Analysis will be performed during development of the detailed design to validate the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. The results of this analysis will be provided during a scheduled six (6) month update. This update will include any changes to the initial designs and/or strategies as submitted in the February 28, 2013 Integrated Plan.

Details:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific procedures

/ Strategies / Guidelines 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.

Identify modifications List modifications

• Pre-stage 480 VAC FLEX pumps in CSCS room

• Install suction and discharge piping for pre-staged FLEX pumps to allow timely connection

• Install electrical supply to pre-staged FLEX pumps to allow timely connection

• For alternate FLEX strategy, install water piping in hardened vent pipe chase on cast side of reactor buildings with external connection at ground elevations and internal connections at 761 feet elevation (for connection to existing B.5.b RHR connection point) and 843 feet elevation for injection to the spent fuel pools (as described in Spent Fuel Pool Cooling section of this Plan).

Key Reactor Parameters List instrumentation credited or recovered for this coping evaluation.

1(2)C34-N004B, RPV Level (Control Room indicator is 1(2)C34-R606B)

• Narrow Range, 0-60 inches 1(2)C34-N004C, RPV Level (Control Room indicator is 1(2)C34-R606C)

• Narrow Range, 0-60 inches 1(2)E51-R602, RCIC Turbine Steam Inlet Pressure (Control Room)

• 0-1500 psig 1(2)C61-RO11, RPV Pressure (Remote Shutdown Panel)

Page 21 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 2:

• 0-1500 prig 1(2)C61-R010, RPV Level (Remote Shutdown Panel)

• Wide Range, -150 to +60 inches LaSalle'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 differences will be communicated in a future six (6) month update following identification.

Storage / Protection of Equipment :

Describe storage i protection plan or schedule to determine stora ge re uirements Seismic Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Flooding Not applicable per NEI 12-06 as outlined within the first section of Note: if stored below current flood level, this integrated plan.

then ensure procedures exist to move equipment prior to exceeding flood level Severe Storms with High Structures to provide protection of FLEX equipment will be Winds constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Snow, Ice, and Extreme Structures to provide protection of FLEX equipment will be Cold constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

High Temperatures Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Page 22 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 2:

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Deployment Conceptual Modification (Attachment 3 contains Conce ptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection is the equipment will be deployed protected to the point of use.

For the primary strategy (for Deployment to use the FLEX FLEX pump piping RPV injection if RCIC pumps for RPV injection will connections will be protected in becomes unavailable), FLEX consist of connecting the the existing CSCS pump room pumps will be pre-staged on suction and discharge piping as structure in the lower elevation each unit in one of the CSCS well as the electrical power of the EDG building.

pump rooms. Pumps will take supply for the 480 VAC motor suction from the UHS source (provided by FLEX portable Electrical connections for the available in the CSCS pump generator through existing 480 FLEX 480 VAC generator are rooms and will be connected to VAC buses). Necessary conceptually planned to be the discharge of the `B' FC modifications for deployment located in the corridor of the EMU pumps on each unit. The include: EDG buildings of each unit.

discharge is connected to the

• Pre-stage 480 VAC RHR system and can provide FLEX pumps in CSCS RPV injection. room

• Install suction and discharge piping for pre-staged FLEX pumps

,to allow timely connection

• Install electrical supply to pre-staged FLEX pumps to allow timely connection For the alternate strategy for Modifications required for New water pipe, and RPV injection (should RCIC deployment of the alternate connections, will be protected become unavailable), a FLEX strategy include: with the new hardened submersible hydraulic pump containment vent chase.

Page 23 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 2:

will be deployed at the UHS

• Installation of water (lake location) to provide pipe in hardened adequate flowINPSH to a high containment vent chase capacity, low pressure portable on each unit.

diesel driven pump (PDDP)

• Installation of that provides flow to each unit. connections at the base The PDDP will be connected to of the water pipe in the a water pipe installed in the chase and connections hardened containment vent at the 761 feet elevation chase on the outside of each to connect to the unit's east reactor building existing B.5.b points on wall. Connection will be RHR.

provided on each unit at the 761 feet elevation to connect to the existing B.5.b RHR locations. This RHR connection can be used to inject to the RPV.

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated plan.

Page 24 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain core cooling. Identify methods (RCIC/HPCI/IC)and strategy(ies) utilized to achieve this coping time.

Phases 1 and 2 strategy will provide sufficient capability such that no additional Phase 3 strategies are required.

Phase 3 equipment for LaSalle includes backup portable pumps and generators. The portable pumps will be capable of providing the necessary flow and pressure as outlined in Phase 2 response for Core Cooling, Containment Cooling and Spent Fuel Pool Cooling. The portable generators will be capable of providing the necessary 480 volt power requirements as outlined in Phase 2 response for Safety Functions Support.

Details:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific procedures

/ Strategies / Guidelines 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.

Identify modifications No additional modification required.

Key Reactor Parameters List instrumentation credited or recovered for this coping evaluation.

LaSalle'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 differences will be communicated in a future six (6) month update following identification.

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection is the equipment will be deployed protected to the point of use.

None. None. None.

Page 25 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 3:

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 26 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment Determine Baseline coping capability with installed coping 2 modifications not including FLEX modifications, utilizing methods described in Table 3-1 of NEI 12-06:

• Containment Venting or Alternate Heat Removal

• Hydrogen Igniters (Mark III containments only)

BWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain containment. Identify methods (containment vent or alternative /Hydrogen Igniters)and strategy(ies) utilized to achieve this coping time.

During Phase 1, containment integrity is maintained by the normal design features of the containment. In accordance with NEI 12-06 (Ref. 1), the containment is assumed to be isolated following the event. As the suppression pool heats up and the water begins to boil, the containment will begin to heat up and pressurize. In order to protect the containment for this scenario, an early containment venting strategy is implemented. In this case, the HCVS is used as implemented per EA-12-050, Reliable Hardened Containment Vents (Reference 2) with control from the main control room (MCR) or remote operating station. Commencing early containment venting (at a conceptual trigger of 12 psig wetwell pressure) will serve to limit the Containment pressure rise and Suppression Pool temperature rise, which will allow for long term operation of the RCIC System for core cooling.

The suppression pool temperature is a limiting factor for implementation of the ELAP strategy.

RCIC suction temperature will be allowed to go as high as -230°F. By opening the HCVS at approximately the 5.4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> point (corresponding to the conceptual trigger of 12 psig wetwell pressure), and maintaining the suppression pool airspace pressure at -8 psig, the suppression pool temperature peaks at - 234°F (Reference 3).

The containment design pressure is 45 psig (UFSAR Table 6.2-1). Containment pressure limits are not expected to be reached during the event as indicated by MAAP analysis (Reference 3),

because the HCVS is opened prior to exceeding any containment pressure limits.

Thus, containment integrity is not challenged and remains functional throughout the event. As indicated by MAAP analysis (Reference 3), the containment will require venting with the HCVS system at approximately 5.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after event initiation (based on the conceptual venting trigger of 12 psig wetwell pressure).

Phase 1 (i.e., the use of permanently installed plant equipment/features) of containment integrity is maintained throughout the duration of the event; no non-permanently installed equipment is required to maintain containment integrity. Therefore, there is no defined end time for the Phase 1 coping period for maintaining containment integrity. An alternative strategy for containment 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.

Page 27 of 70

LaSalle Count Station, Units 1 and 2 Mitigation Strategies Integrated Plan during Phase 1 is not provided, because containment integrity is maintained by the plant's design features.

Analysis will be performed during development of the detailed design to validate the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. The results of this analysis will be provided during a scheduled six (6) month update. This update will include any changes to the initial designs and/or strategies as submitted in the February 28, 2013 Integrated Plan.

References:

1. "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide", NEI 12-06, Revision 0, August 2012

2. NRC Order EA-12-050, "Issuance of Order to Modify Licenses With Regard to Reliable Hardened Containment Vents," March 12, 2012

3. LS-MISC-017, Rev. 1, "MAAP Analysis to Support Initial FLEX Strategy," LaSalle Units 1 and 2 Details:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific

/ Strategies / Guidelines 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.

Identify modifications

• EA-12-050, Hardened Containment Vent Modification

• Modification(s) needed to have suitable instrument(s) for Drywell Pressure and/or Suppression Chamber (Pool)

Pressure indication

• Modification needed to have suitable instrument for Suppression Pool level indication

• Modification needed to expand the range for Suppression Pool water temperature Key Containment List instrumentation credited for this coping evaluation.

Parameters Drywell temperature - 1(2)TI-CM045 (Remote Shutdown Panel)

• 0-600 Deg F Drywell pressure -1(2)C71-N004 (Local Rx Bldg 761 Elev.)

• Narrow range, -20 to +60 inches water o Equates to ---0.75 to +2.25 psig Suppression Pool water temperature - 1(2)TI-CM037 (Remote Shutdown Panel)

• 0-225 Deg F Suppression Pool level - I (2)CM02M (Local Rx Bldg 694 Elev)

• Narrow range, approximately +/-1 ft of 699'11" Suppression Pool air temperature - 1(2)TI-CM040 (Remote Shutdown Panel)

• 0-275 Deg F Page 28 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan LaSalle'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 differences will be communicated in a future six (6) month update following identification.

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update, This update will include changes to the initial designs as submitted i n the February 28, 2013 Integrated Plan.

Page 29 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment BWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain containment. Identify methods (containment vent or alternative /

Hydrogen Igniters)and strategy(ies) utilized to achieve this coping time.

Containment venting via the use of the installed HCVS will continue in Phase 2.

Inventory will be made up to the Suppression Pool with the FLEX Pump via the RHR System, which will maintain Suppression Pool level and also provide some cooling of the Suppression Pool.

Analysis will be performed during development of the detailed design to validate the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. The results of this analysis will be provided during a scheduled six (6) month update. This update will include any changes to the initial designs and/or strategies as submitted in the February 28, 2013 Integrated Plan.

Details:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific procedures

/ Strategies / Guidelines 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.

Identify modifications Identified in Phase 1 discussion.

Additionally, the modifications below provide the water source and flow paths for injection to the suppression pool:

• Pre-stage 480 VAC FLEX pumps in CSCS room

• Install suction and discharge piping for pre-staged FLEX pumps to allow timely connection

• Install electrical supply to pre-staged FLEX pumps to allow timely connection

• For alternate FLEX strategy, install water piping in hardened vent pipe chase on east side of reactor buildings with external connection at ground elevations and internal connections at 761 feet elevation (for connection to existing B.5.b RHR connection point) and 843 feet elevation for injection to the spent fuel pools (as described in Spent Fuel Pool Cooling section of this Plan).

Key Containment List instrumentation credited or recovered for this coping evaluation.

Parameters Drywell temperature - 1(2)TI-CM045 (Remote Shutdown Panel)

• 0-600 Deg F Page 30 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment BWR Portable Equipment Phase 2:

Drywell pressure - 1(2)C7 I -NO04 (Local Rx Bldg 761 Elev.)

• Narrow range, -20 to +60 inches water o Equates to --0.75 to +2.25 psig Suppression Pool water temperature - 1(2)TI-CM037 (Remote Shutdown Panel)

• 0-225 Deg F Suppression Pool level -1(2)CM02M (Local Rx Bldg 694 Elev)

• Narrow range, approximately +/-1 ft of 699' 11" Suppression Pool air temperature -1(2)TI-CM040 (Remote Shutdown Panel)

• 0-275 Deg F LaSalle'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 differences will be communicated in a future six (6) month update following identification.

Storage / Protection of Equipment :

Describe stora ge / protection plan or schedule to determine storage re q uirements Seismic Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Flooding Not applicable per NEI 12-06 as outlined within the first section of Note: if stored below current flood level, this integrated plan.

then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Structures to provide protection of FLEX equipment will be Winds constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Snow, Ice, and Extreme Structures to provide protection of FLEX equipment will be Cold constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment Page 31 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment BWR Portable Equipment Phase 2:

2, 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 LaSalle.

High Temperatures Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Deployment Conceptual Design (Attachment 3 contains Conce ptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection is the equipment will be deployed protected to the point o use.

Same as Core Cooling Same as Core Cooling Same as Core Cooling discussion. Connected to RHR discussion. discussion.

and will be implemented via different valve lineups.

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 32 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment BWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain containment, Identify' methods (containment vent or alternative / Hydrogen Igniters)and strategy(ies) utilized to achieve this coping time.

Phases 1 and 2 strategy will provide sufficient capability such that no additional Phase 3 strategies are required.

Phase 3 equipment for LaSalle includes backup portable pumps and generators. The portable pumps will be capable of providing the necessary flow and pressure as outlined in Phase 2 response for Core Cooling, Containment Cooling and Spent Fuel Pool Cooling. The portable generators will be capable of providing the necessary 480 volt power requirements as outlined in Phase 2 response for Safety Functions Support.

Details:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific procedures 1 Strategies / Guidelines 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.

Identify modifications No additional modification required.

Key Containment List instrumentation credited or recovered for this coping evaluation.

Parameters LaSalle'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 differences will be communicated in a future six (6) month update following identification.

Deployment Conceptual Design (Attachment 3 contains Conce ptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection is the equipment will be deployed protected to the point of use.

None. None. None.

Page 33 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment BWR Portable Equipment Phase 3:

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 34 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Determine Baseline coping capability with installed coping 3 modifications not including FLEX modifications, utilizing methods described in Table 3 - 1 of NEI 12-06:

• Makeup with Portable Injection Source BWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain spent, fuel pool cooling. Identify methods (makeup with portable injection source)and strategy(ies) utilized to achieve this coping time.

There are no Phase 1 actions required at this time that need to be addressed.

An evaluation of Spent Fuel Pool scenarios was performed and documented in LaSalle EC 392196 (Ref. 1). Spent Fuel Pool (SFP) makeup is not a time constraint with the initial condition of Mode 1 at 100% power, since the worst case fuel pool heat load conditions only exist during a refueling outage. Under non-outage conditions, the maximum SFP heat load is 27.38 MBtu/hr. Loss of SFP cooling with this heat load and an initial SFP temperature of 140 degrees F results in a time to boil of 12.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and 123 hours0.00142 days <br />0.0342 hours <br />2.03373e-4 weeks <br />4.68015e-5 months <br /> to the top of active fuel. Therefore, completing the equipment line-up for initiating SFP makeup at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> into the event ensures adequate cooling of the spent fuel is maintained.

The worst case SFP heat load during an outage is 56.03 MBtu/hr. Loss of SFP cooling with this heat load and an initial SFP temperature of 140 degrees F results in a time to boil of 5.86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br />, and 60.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to the top of active fuel. With the entire core being located in the SFP, manpower resources normally allocated to aligning core cooling along with the Operations outage shift manpower can be allocated to aligning SFP makeup which ensures the system alignment can be established within eight (8) hours. Initiation at eight (8) hours into the event ensures adequate cooling of the spent fuel is maintained.

Evaluation of the spent fuel pool area for steam and condensation has not yet been performed. The results of this evaluation and the vent path strategy, if needed, will be provided in a future six (6) month update.

Analysis will be performed during development of the detailed design to validate the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. The results of this analysis will be provided during a scheduled six (6) month update. This update will include any changes to the initial designs and/or strategies as submitted in the February 28, 2013 Integrated Plan.

s 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 35 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan

References:

1. LaSalle Engineering Evaluation EC 392196, Rev. 0, "Spent Fuel Pool Uncovery Time for Outage and Online Scenarios,"

Details:

Provide a brief N/A description of Procedures

/ Strategies / Guidelines Identify any equipment Per EA 12-051 (SFP Level) modifications Key SFP Parameter Per EA 12-051 (SFP Level)

LaSalle'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 differences will be communicated in a future six (6) month update following identification.

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 36 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling BWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain spent fuel pool cooling. Identify methods (makeup with portable injection source)and strategy(ies) utilized to achieve this coping time.

The primary and alternate strategies for connection of the FLEX pumps for Core Cooling and Containment Cooling also provide connection to a dedicated hose station on the refuel floor that can be used for SFP filling and spray. The primary and alternate strategy connections also provide a path through `B' RHR for SFP water addition without accessing the refuel floor. An additional spool piece will require installation to provide SFP fill via the RHR line.

Evaluation of the spent fuel pool area for steam and condensation has not yet been performed. The results of this evaluation and the vent path strategy, if needed, will be provided in a future six (6) month update.

Analysis will be performed during development of the detailed design to validate the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. The results of this analysis will be provided during a scheduled six (6) month update. This update will include any changes to the initial designs and/or strategies as submitted in the February 28, 2013 Integrated Plan.

References:

1. LaSalle Engineering Evaluation EC 392196, Rev. 0, "Spent Fuel Pool Uncovery Time for Outage and Online Scenarios,"

Schedule:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific procedures

/ Strategies / Guidelines 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.

Identify modifications Per EA 12-051 (SFP Level)

Additionally, the modifications below provide the water source and flow paths for injection to the spent fuel pool:

• Pre-stage 480 VAC FLEX pumps in CSCS room

• Install suction and discharge piping for pre-staged FLEX pumps to allow timely connection

• Install electrical supply to pre-staged FLEX pumps to allow timely connection

• For alternate FLEX strategy, install water i in in hardened Page 37 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling BWR Portable Equipment Phase 2:

vent pipe chase on east side of reactor buildings with external connection at ground elevations and internal connections at 761 feet elevation (for connection to existing B.5.b RHR connection point) and 843 feet elevation for injection to the spent fuel pools (as described in Spent Fuel Pool Cooling section of this Plan).

Key SFP Parameter Per EA 12-051 (SFP Level)

LaSalle'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 differences will be communicated in a future six (6) month update following identification.

Storage / Protection of Equipment :

Describe stora gee / protection plan or schedule to determine stora ge requirements Seismic Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Flooding Not applicable per NEI 12-06 as outlined within the first section of Note: if stored below current flood level, this integrated plan.

then ensure procedures exist to move eq uipment prior to exceedin flood level.

Severe Storms with High Structures to provide protection of FLEX equipment will be Winds constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Snow, Ice, and Extreme Structures to provide protection of FLEX equipment will be Cold constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction completion. Procedures and Page 38 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling BWR Portable Equipment Phase 2:

programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards a licable to LaSalle.

High Temperatures Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Deployment Conceptual Design (Attachment 3 contains Conce ptual tual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection is the equipment will be deployed protected to the point of use.

FLEX pump and generator Same as previously described Same as previously described.

deployment same as previously for Core Cooling and described for Core Cooling and Containment Cooling. An RHR spool piece that requires Containment Cooling. additional spool piece will installation for SFP fill is in Connections are the same. require installation to provide protected structure (reactor Different flow path will be SFP fill via the RHR line, building).

utilized to provide flow to the SFP either via the hose station

-flow path or the RHR flow path, 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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 39 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling BWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain spent fuel pool cooling. Identify methods (makeup with portable injection source)and strategy(ies) utilized to achieve this coping time.

Phases 1 and 2 strategy will provide sufficient capability such that no additional Phase 3 strategies are required.

Phase 3 equipment for LaSalle includes backup portable pumps and generators. The portable pumps will be capable of providing the necessary flow and pressure as outlined in Phase 2 response for Core Cooling, Containment Cooling and Spent Fuel Pool Cooling. The portable generators will be capable of providing the necessary 480 volt power requirements as outlined in Phase 2 response for Safety Functions Support.

Schedule:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific procedures I Strategies I Guidelines 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.

Identify modifications No additional modification required.

Key SFP Parameter LaSalle'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 differences will be communicated in a future six (6) month update following identification.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection is the equipment will be deployed protected to the point o use.

None. None. None.

Page 40 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling BWR Portable Equipment Phase 3:

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 41 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support Determine Baseline coping capability with installed coping 4 modifications not including FLEX modifications.

BWR Installed Equipment Phase 1 Provide a general description of the coping strategies using installed equipment including station modifications that are proposed to maintain andlor support safety functions. Identify methods and strategy(ies) utilized to achieve coping times.

Electrical Support The primary electrical power strategy is to connect a portable FLEX 480VAC generator to each unit to supply power to select 480 VAC buses (Division 1 and Division 2) so the 125 VDC Battery Chargers, 250VDC Battery Chargers, and 480 VAC FLEX pumps are powered up. See attached Conceptual Sketch (Attachment 3).

The alternate electrical power strategy is to connect a portable FLEX 480 VAC generator to a portable power distribution panel on each unit and then directly power each load individually (i.e.,

each battery charger and FLEX pump). See attached Conceptual Sketch (Attachment 3).

Safety Related 250VDC and 125VDC Bus voltage will be maintained by their associated batteries until the portable 480V generators are placed in service to re-energize the battery chargers.

DC Load shedding will be accomplished in accordance with the existing SBO response procedure (Ref. 1) as well as an extended DC load shed procedure to be developed.

125 VDC and 250 VDC Battery coping times have been analyzed per EC 391795 (Ref 2) with the following results:

125 VDC Unit 1 125 VDC Div 1 Battery 1DC07E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1) and an extended load shed is completed prior to 4. 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

125 VDC Div 2 Battery 1DC14E Eight (8) hour cop ing time is demonstrated provided that the existing SBO load shed is completed 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.

Page 42 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan per the current SBO procedure (Ref. 1) and an extended load shed is completed prior to 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

Unit 2 125 VDC Div 1 Battery 2DC07E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1) and an extended load shed is completed prior to 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

125 VDC Div 2 Battery 2DC14E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1). An extended load shed is not required for this battery.

250 VDC Unit 1 250 VDC Battery 1DC01E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1). An extended load shed is not required for this battery.

Unit 2 250 VDC Battery 2DCO1E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1). An extended load shed is not required for this battery.

These battery profiles drive the actions to complete the initial DC load shedding and then to perform the extended DC load shedding (as required) once ELAP has been declared. These actions collectively support an analyzed coping time of at least eight (8) hrs for each battery. The eight (8) hrs is conservative as a result of the model only being extended to eight (8) hrs to reflect the currently available vendor battery discharge curves.

RCIC Room Habitability Per GOTHIC Analysis (Ref. 4), RCIC Room temperature reaches 169°F (equipment acceptance limit per Ref. 3) at 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. This drives the action to provide external air flow to the RCIC Room. The time of 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> to initiate external air flow to the RCIC Room is established to provide margin to the calculated value.

Main Control Room Habitability Exelon Generation Company, LLC (Exelon) intends on maintaining the O perational command and Page 43 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan control function within the Main Control Room. Habitability conditions will be evaluated and a strategy will be developed to maintain Main Control Room habitability. The strategy and associated support analyses will be submitted in a future six (6) month update.

AEER Habitability Exelon Generation Company, LLC (Exelon) intends on maintaining the functions/actions that occur in the AEER for the SBO/ELAP scenario. Habitability conditions will be evaluated and a strategy will be developed to maintain AEER habitability. The strategy and associated support analyses will be submitted in a future six (6) month update, Battery Room Ventilation It is expected that the rise in temperature in the Safety Related Battery Rooms due to the loss of ventilation will not adversely affect the functionality of the batteries. However, hydrogen generation upon re-energizing the battery chargers will be addressed in Phase 2.

Spent Fuel Pool Area Ventilation Evaluation of the spent fuel pool area for steam and condensation has not yet been performed. The results of this evaluation and the vent path strategy, if needed, will be provided in a future six (6) month update.

Analysis will be performed during development of the detailed design to validate the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. The results of this analysis will be provided during a scheduled six (6) month update. This update will include any changes to the initial designs and/or strategies as submitted in the February 28, 2013 Integrated Plan.

References:

1, LaSalle Abnormal Operating Procedure LOA-AP-101, "Unit 1 AC Power System Abnormal," Rev. 42 {Unit 2, LOA-AP-201, Rev. 36}

2. LaSalle Engineering Evaluation EC 391795, Rev. 000, "Battery Coping Times During ELAP with Extended Load Shedding."

3. LaSalle Calculation ATD-0351, "RCIC Pump Room Temperature Transient Following Station Blackout with Gland Seal Leakage," Rev. 3

4. Sargent & Lundy Calculation 2012-11819, Rev. 0, "Transient Analysis of RCIC Pump Room for Extended Loss of A-C Power,"

Details:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Groups, EPRI and NEI Task team to develop site specific procedures Procedures / Strategies / or guidelines to address the criteria in NEI 12-06. These procedures Guidelines and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

Page 44 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Identify modifications Modifications described under the Core Cooling, Containment Cooling and SFP Cooling sections.

Key Parameters Described under Core Cooling, Containment Cooling and SFP Cooling sections.

LaSalle'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 differences will be communicated in a future six (6) month update following identification.

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 45 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support BWR 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 andlor support safety functions. Identify methods and strategy(ies) utilized to achieve coping times.

Electrical Support The primary electrical power strategy is to connect a portable FLEX 480VAC generator to each unit to supply power to select 480 VAC buses (Division 1 and Division 2) so the 125 VDC Battery Chargers, 250VDC Battery Chargers, and 480 VAC FLEX pumps are powered up. See attached conceptual sketch (Attachment 3).

The alternate electrical power strategy is to connect a portable FLEX 480 VAC generator to a portable power distribution panel on each unit and then directly power each load individually (i.e.,

each battery charger and FLEX pump). See attached conceptual sketch (Attachment 3).

Safety Related 250VDC and 125VDC Bus voltage will be maintained by their associated batteries until the portable 480V generators are placed in service to re-energize the battery chargers.

DC Load shedding will be accomplished in accordance with the existing SBO response procedure (Ref. 1) as well as an extended DC load shed procedure to be developed.

125 VDC and 250 VDC Battery coping times have been analyzed per EC 391795 (Ref 2) with the following results:

125 VDC Unit 1 125 VDC Div I Battery 1DC07E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1) and an extended load shed is completed prior to 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

125 VDC Div 2 Battery 1DC14E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1) and an extended load shed is completed prior to 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

Page 46 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 Unit 2 125 VDC Div 1 Battery 2DC07E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1) and an extended load shed is completed prior to 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

125 VDC Div 2 Battery 2DC14E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1). An extended load shed is not required for this battery.

250 VDC Unit 1 250 VDC Battery 1DCO1E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1). An extended load shed is not required for this battery.

Unit 2 250 VDC Battery 2DCO1E Eight (8) hour coping time is demonstrated provided that the existing SBO load shed is completed per the current SBO procedure (Ref. 1). An extended load shed is not required for this battery.

These battery profiles drive the actions to complete the initial DC load shedding and then to perform the extended DC load shedding (as required) once ELAP has been declared. These actions collectively support an analyzed coping time of at least eight (8) his for each battery. The eight (8) his is conservative as a result of the model only being extended to eight (8) hrs to reflect the currently available vendor battery discharge curves.

RCIC Room Habitability Per GOTHIC Analysis (Ref. 4), RCIC Room temperature reaches 169°F (equipment acceptance limit per Ref. 3) at 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. This drives the action to provide external air flow to the RCIC Room.

The time of 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> to initiate external air flow to the RCIC Room is established to provide margin to the calculated value.

Page 47 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 Main Control Room Habitability Exelon Generation Company, LLC (Exelon) intends on maintaining the Operational command and control function within the Main Control Room. Habitability conditions will be evaluated and a strategy will be developed to maintain Main Control Room habitability. The strategy and associated support analyses will be submitted in a future six (6) month update.

AEER Habitability Exelon Generation Company, LLC (Exelon) intends on maintaining the functions/actions that occur in the AEER for the SBO/ELAP scenario. Habitability conditions will be evaluated and a strategy will be developed to maintain AEER habitability. The strategy and associated support analyses will be submitted in a future six (6) month update.

Battery Room Ventilation It is expected that the rise in temperature in the Safety Related Battery Rooms due to the loss of ventilation will not adversely affect the functionality of the batteries. To address hydrogen generation upon re-energizing the battery chargers, the battery room doors will be propped open to prevent a buildup of hydrogen in the battery rooms.

Spent Fuel Pool Area Ventilation Evaluation of the spent fuel pool area for steam and condensation has not yet been performed. The results of this evaluation and the vent path strategy, if needed, will be provided in a future six (6) month update.

Fuel Oil Supply to Portable Equipment Fuel oil to portable FLEX Pumps and Generators will be supplied by the quantity of fuel in the tanks located on the skids of the portable equipment. This initial fuel will then be supplemented by fuel tanks contained on the back of the FLEX Truck. When required, fuel can then be pumped from the Emergency Diesel Generator Day Tanks.

Analysis will be performed during development of the detailed design to validate the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. The results of this analysis will be provided during a scheduled six (6) month update. This update will include any changes to the initial designs and/or strategies as submitted in the February 28, 2013 Integrated Plan.

Page 48 of 70

LaSalle Count Station, Units 1 and 2 Mitigation Strategies egrated Plan Safety Functions Support BWR Portable Equipment Phase 2

References:

1. LaSalle Abnormal Operating Procedure LOA-AP-101, "Unit 1 AC Power System Abnormal," Rev. 42 { Unit 2, LOA-AP-201, Rev. 361

2. LaSalle Engineering Evaluation EC 391795, Rev. 000, "Battery Coping Times During ELAP with Extended Load Shedding."

3. LaSalle Calculation ATD-0351, "RCIC Pump Room Temperature Transient Following Station Blackout with Gland Seal Leakage," Rev. 3

4. Sargent & Lundy Calculation 2012-11819, Rev. 0, "Transient Analysis of RCIC Pump Room for Extended Loss of A-C Power,"

Details:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific procedures

/ Strategies / Guidelines 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.

Identify modifications 1. The primary electrical power strategy is to connect a portable FLEX 480VAC generator to each unit to supply power to select 480 VAC buses (Division 1 and Division 2) so the 125 VDC Battery Chargers, 250VDC Battery Chargers, and 480 VAC FLEX pumps are powered up. See attached conceptual sketch (Attachment 3). This modification will involve providing connections to the selected buses as well as connections to the portable 480VAC generator.

2. The alternate electrical power strategy is to connect a portable FLEX 480 VAC generator to a portable power distribution panel on each unit and then directly power each load individually (i.e., each battery charger and FLEX pump). See attached conceptual sketch (Attachment 3). This modification will involve providing connections directly to the supported loads from the mobile distribution panel as well as a connection from the portable 480VAC generator to the mobile distribution panel.

Key Parameters LaSalle'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 differences will be communicated in a future six (6) month update following identification.

Page 49 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 Storage / Protection of Equipment Describe storage / rotection plan or schedule to determine stora ge requirements Seismic Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Flooding Not applicable per NEI 12-06 as outlined within the first section Note: if stored below current flood level, then of this integrated plan.

ensure procedures exist to move equipment p rior to exceeding flood level.

Severe Storms with High Structures to provide protection of FLEX equipment will be Winds constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Snow, Ice, and Extreme Cold Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

High Temperatures Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Section 11.

Schedule to construct permanent building is contained in Attachment 2, 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 LaSalle.

Page 50 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 Deployment Conceptual Design (Attachment 3 contains Conce ptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection is the equipment will be deployed protected to the point of use.

For the primary strategy, the For the primary strategy, For both the primary and 480VAC generator will be modifications will be required alternate strategies, all moved from the storage to the selected 480VAC buses connection points will be inside location to outside the EDG to provide a pre-wired protected structures (either the building (each unit). connection capability for the EDG or Aux Buildings).

Conceptually, it is envisioned FLEX 480VAC generator that the connection to the power supply. This 480VAC generator will occur modification would also in the hallway of the EDG involve running cable/conduit building at ground elevation. to the EDG building (both Permanently installed units) hallway on the ground cabling/conduit would be run elevation for the 480VAC from that location to the generator connection point.

selected 480VAC buses.

For the alternate strategy, For the alternate strategy, the modification to the supported 480VAC generator will be loads would be required to moved from the storage accommodate a direct location to outside the EDG connection from the mobile building (each unit). Cabling distribution panel.

would be run to the mobile distribution panel that is pre-staged in a protected structure (EDG or Aux Bldg). Cabling would then be run from the mobile distribution panel to the selected loads.

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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06. Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS Page 51 of 70

LaSalle County Station, Units 1 and 2 _Mitigation Strategies Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 52 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support BWR Portable Equipment Phase 3 Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain and/or support safety functions. Identify methods and strategy(ies) utilized to achieve coping times.

Phases 1 and 2 strategy will provide sufficient capability such that no additional Phase 3 strategies are required.

Phase 3 equipment for LaSalle includes backup portable pumps and generators. The portable pumps will be capable of providing the necessary flow and pressure as outlined in Phase 2 response for Core Cooling, Containment Cooling and Spent Fuel Pool Cooling. The portable generators will be capable of providing the necessary 480 volt power requirements as outlined in Phase 2 response for Safety Functions Support.

Details:

Provide a brief LaSalle will use the industry developed guidance from the Owners description of Procedures Groups, EPRI and NEI Task team to develop site specific procedures

/ Strategies / Guidelines 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.

Identify modifications No additional modification required.

Key Parameters LaSalle'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 differences will be communicated in a future six (6) month update following identification.

Deployment Conceptual Design (Attachment 3 contains Conce ptual Sketches)

Strategy Modifications Protection of connections Identify Strategy including how Identify modifications Identify how the connection is the equipment will be deployed protected to the point o use.

None. None. None.

Page 53 of 70

LaSalle County Station, Units I and 2 Mitigation Strategies Integrated Plan Safety Functions Support BWR Portable Equipment Phase 3 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. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06, Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for LSCS during a scheduled six (6) month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 54 of 70

LaSalle County Station, Units I and 2 Mitigation Strategies Integrated Plan BWR Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance I PM requirements equipment Three (3) X X X To be determined as part Equipment maintenance large self of detailed design and testing will be prime pumps process. performed i n accordance (Support with the industry Alternate templates, as outlined in Strategy) JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Three (3) 480 X X X X X To be determined as part Equipment maintenance VAC of detailed design and testing will be Generators process. performed in accordance (Support with the industry Primary templates, as outlined in Strategy) JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Two (2) 480 X X X To be determined as part Equipment maintenance VAC of detailed design and testing will be Pumps process. performed in accordance (Support with the industry Primary templates, as outlined in Strategy) JLD-ISG-2012-01 section 6 and NEI 12-06 Page 55 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan BWR Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM requirements equipment section 11.

Three (3) X X X To provide suction to Equipment maintenance Submersible portable large self prime and testing will be Hydraulic pumps from UHS. performed in accordance Pumps Actual number and size with the industry (Support of submersible hydraulic templates, as outlined in Alternate pumps to be determined JLD-ISG-2012-01 Strategy) as part of detailed design section 6 and NEI 12-06 process. section 11.

Ford F750 X Tow vehicle, portable Equipment maintenance Truck w/snow equipment refueling and testing will be plow and vehicle, and debris performed in accordance diesel fuel removal vehicle with the industry tanks templates, as outlined in JLD-ISG-201.2-01 section 6 and NEI 12-06 section 11.

Three (3) X X X Capable of hauling Equipment maintenance Tandem Axle hoses, fittings, tools and and testing will be Hose Trailers spray monitors performed in accordance (Support with the industry Alternate templates, as outlined in Strategy) JLD-ISG-2012-01 Page 56 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan BWR Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM requirements equipment section 6 and NEI 12-06 section 11.

Six (6) 5.5 X Diesel, 5.5 kW Equipment maintenance kW portable and testing will be diesel performed in accordance generators with the industry (Support templates, as outlined in powering fans JLD-ISG-2012-01 for RCIC section 6 and NEI 12-06 room cooling) section 11.

Ten (10) X 115 VAC, 5,000 SCFM Equipment maintenance portable fans and testing will be with ducting performed in accordance (Support with the industry RCIC room templates, as outlined in cooling) JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Two (2) X 250 gpm Equipment maintenance Oscillating and testing will be Spray Fire performed in accordance Monitors with the industry Page 57 of 70

LaSalle County Station, Units I and 2 Mitigation Strategies Integrated Plan BWR Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM e q uip ment requirements (Support SFP templates, as outlined in Spray) JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Miscellaneous x X X Various Equipment maintenance fire hose and and testing will be fittings performed in accordance (Support with the industry Alternate templates, as outlined in Strategy and JLD-ISG-2012-01 SFP Spray) section 6 and NEI 12-06 section 11.

Page 58 of 70

LaSalle County Station, Units I and 2 Mitigation Strategies Integrated Plan BWR Portable Equipment Phase 3 Note: The RRC equipment has not been procured at the time of this submittal. Once the SAFER committee determines the equipment specifications for bid, updates will be made as necessary to this table. The Phase 3 portable equipment table will be updated once all of the e quipment has been procured and laced in inventor y.

Use and (potential /flexibility) diverse uses Performance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment Medium x X X X X 2 MW output at 4160

• Generator must be Voltage Vac, three phase common Diesel commercially Generator available.

• Must run on diesel fuel.

Low Voltage x X X X X 500 kW output at 480

• Generator must be Diesel Vac, three phase common Generator commercially available.

• Must run on diesel fuel.

Low Pressure x X X 300 psi shutoff head, Pum 2500 g pm max flow Low Pressure x X 500 psi shutoff head, Pump 500 g 2m max flow Low Pressure x 110 psi shutoff head, Pump 400 gpm max flow submersible Page 59 of 70

LaSalle County Station, Units I and 2 Mitigation Strategies Integrated Plan Low Pressure X X 150 psi shutoff head, Pump 5000 gpm max flow Air I I X 120 psi minimum Compressor I pressure, 2000 scfm Page 60 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Phase 3 Response Equipment/Commodities Item Notes Radiation Protection Equipment The RRC will not stock this type of equipment but this equipment will be requested

• Survey instruments from site-to-site and utility-to-utility on an as required basis.

• Dosimetry

• Off-site monitoring/sampling Commodities The RRC will not stock these commodities but they will be requested from site-to-

• Food site and utility-to-utility on an as required basis.

• Potable water Fuel Requirements 300 - 500 gallon bladders that can be delivered by air.

Heavy Equipment

• TBD during site specific playbook development

• Transportation equipment

• Redundant Phase 2 equipment to be located at RRC

• Debris clearing equipment Page 61 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment 1A Sequence of Events Timeline Time Remarks I Constraint Applicability Action Elapsed Action Y/N 5 item Time 0 Event Starts NA Plant @ 100% power 1 0 Reactor Scram and SBO.

2 RCIC starts on to-lo RPV water level and injects N Automatic equipment

-2 min at 600 m function 3 Y LOA-AP-101, Att. K (time to direct initial SBO critical response (Ref. 1) activities in Operating crew enters applicable EOPs and LOA-AP-0-5 mins abnormal procedures for SBO. 101) 4 N LOA-AP-101, Att. K, Step 2. Initiation of load shedding is not time critical -

completion of load shedding is time 5 mins DC load shedding initiated critical.

5 Attempt to start emergency diesel generators (3 N LOA-AP-101, Att. K, 5 mins for Unit 1, 2 for Unit 2) Step 3.

6 Equipment Operator dispatched to Aux Electric N LOA-AP-101, Att. K, Equipment Room (AEER) to: Step 4. Dispatch of

• Control the ADS SRVs to support EO is not time critical cooldown within 20 mins - completion of the

• Open all panel doors in AEER within 30 tasks is time sensitive mins and discussed below.

• Monitor and report critical parameters at Remote Shutdown Panel & 1H13-5 mins P629/1H13-P631 panels 7 N LOA-AP-101, Att. K, Step 5 5 mins Reactor Operator control RPV level with RCIC For events in which 5 Instructions: Provide justification if No or NA is selected in the remarks column If yes, include technical basis discussion as requires by NEI 12-06 section 3.2.13 Page 62 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan CST is not available, suction path swapped to sup ression pool.

8 N Not time critical since not depressurizing RPV at this time.

Defeat RCIC Low Steam Line Pressure Isolation LGA-RI-101, E.2 15 mins (RO Control Room portion) (Ref. 2) 9 Y LOP-AP-101, Att. K, Step 6.

Time sensitive portions are Control of ADS SRVs to support cooldown establishing control established and an RPV depressurization at less within 20 mins and than or equal to 20 deg F per hour is depressurizing/cooling 20 mins commenced. down slow enough.

10 Y LOA-AP-101, Att. K, 30 mins Partial Initial DC load shedding completed Step 2, 30 min loads 11 N Not time critical since not depressurizing Defeat RCIC Low Pressure Isolation Logic (EO RPV at this time.

30 mins AEER portion) LGA-RI-101, Att. A 12 Y Time sensitive for AEER temperature 30 mins All anel doors in AEER opened. evaluation.

13 Y LOA-AP-101, Att. K, Step 11. Time sensitive for Control Room temperature 30 mins All panel doors in Main Control Room opened evaluation.

14 Y Time is reasonable approximation based Control Room crew has assessed SBO and plant on operating crew conditions and declares an Extended Loss of AC assessment of plant

-60 mins Power (ELAP) event. conditions.

15 N DC coping analysis (Ref. 3) shows the 125VDC and 250VDC batteries have a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping capability with initial Equipment Operators dispatched to begin and deep load setup/connection of FLEX equipment (480VAC shedding completed generators to power battery chargers and FLEX (as applicable to

-60 mins um ). articular battery).

Page 63 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan 16 N DC coping analysis (Ref. 3) shows that extended DC load shedding needs to be completed within 4.5 hrs for U1 Div. 1, 5.5 hrs for U 1 Div. 2, 5.5 hrs for U2 Div. 1 and deep load shedding is not required for U2 Div. 2. Initiation of extended (deep) load shedding is shown in

-180 Initiate Extended DC load shedding to prolong the timeline to allow rains 125 VDC battery life to -8 hrs -1.5 hrs to complete.

17 Y LOA-AP-101, Att. K, Step 2, 180 minute 180 mins Initial DC load shedding completed loads 18 Y Timing of completion of extended DC load shedding is important to extending coping time to 8 hrs as Complete Extended DC load shedding for described earlier in 4.5 hrs applicable 125VDC batteries. timeline.

19 Y Per LOA-IN-101 (Ref. 4) & LOP-IN-05 (Ref. 5). Time sensitive per Provide additional nitrogen supply for ADS calculation L-003263 5 hrs SRVs (Ref. 6).

20 N MAAP analysis (Ref.

7) indicates that the conceptual early containment venting strategy trigger of 12 Initiate early containment venting strategy at a psig in the wetwell wetwell pressure of -12 psig. Open hardened will occur at -5.4 hrs

-5.4 hrs containment vent with path from the wetwell. with this strategy.

21 Y Restore AC power to battery chargers prior 480VAC generators connected to supply battery to loss of each battery chargers for 125VDC (Div. 1 and 2) and at the analyzed value 6 hrs 250VDC buses of -8 hrs.

22 FLEX pumps connected (electrical and water Y MAAP analysis (Ref.

6 hrs I suction/discharge path) and alignment for 7) is showing Page 64 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan suppression pool makeup established. suppression pool Suppression pool makeup begins. makeup at 6.2 his based on the suppression pool level reduction from implementation of the early containment venting strategy at

-5.4 hrs. This MAAP analysis also shows a required makeup flowrate of -95 gpm for the first 4 hrs after the vent is opened.

23 N MAAP analysis (Ref.

7) indicates that the HCTL curve will be exceeded at -6.7 hrs based on this strategy.

RPV depressurization stops at -200 psig (pressure band of 150-250 psig used) in RPV to preserve RCIC operation. Modified Heat Capacity Temperature Limit (HCTL) curve depressurization exceeded, RPV depressurization to -200 psig approach supported by required. RPV pressure now maintained 150- BWROG changes to

-6.7 hrs 250 psig range to support RCIC operation. EPGs.

24 Y GOTHIC analysis (Ref. 8) shows that external air flow needs to be provided within 13 hrs to prevent room temps from exceeding 169 deg F which is the maximum allowable value from the current

-11 his Provide external air flow to RCIC room SBO analysis (Ref. 9).

25 Y EC 392196 (Ref. 10) indicates that SFP boiling begins at -12 Begin SFP injection based on FLEX "normal" hrs with TAF being scenario that begins with both units on-line at reached at -1.23 his.

12 his 100% power. Beginning SFP inject Page 65 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan by -12 hrs provides margin to degraded radiological conditions and TAF.

26 Continue to maintain critical functions of core N Not time cooling (via RCIC), containment (via hardened critical/sensitive since vent opening and FLEX pump injection to Phase 2 actions result suppression pool) and SFP cooling (FLEX pump in indefinite coping injection to SFP). Utilize initial RRC equipment times for all safety 24 -72 hrs in spare capacity. functions.

References:

1. LaSalle Abnormal Operating Procedure LOA-AP-101, "Unit 1 AC Power System Abnormal," Rev. 42 { Unit 2, LOA-AP-201, Rev. 36}

2. LaSalle LGA Support Procedure LGA-RI-101, "Unit 1 Alternate Vessel Injection Using RCIC Including Defeat of RCIC Isolations," Rev. 005 (Unit 2, LGA-RI-201, Rev. 0031

3. LaSalle Engineering Evaluation EC 391795, Rev. 000, "Battery Coping Times During ELAP with Extended Load Shedding."

4. LaSalle Abnormal Operating Procedure LOA-IN-101, "Loss Of Drywell Pneumatic Air Supply," Rev. 007 {Unit 2, LOA-IN-201, Rev. 007}

5. LaSalle Normal Operating Procedure LOP-IN-05, "Replacing Nitrogen Bottles on Instrument Nitrogen System Supporting Op Eval OE06-00," Rev. 023

6. LaSalle Calculation L-003263, Rev. 02, "Volume Requirements for ADS Back-up Compressed Gas System (Bottle Banks)"

7. LS-MISC-017, Rev. 1, "MAAP Analysis to Support Initial FLEX Strategy,"

LaSalle Units 1 and 2

8. Sargent & Lundy Calculation 2012-11819, Rev. 0, "Transient Analysis of RCIC Pump Room for Extended Loss of A-C Power,"

9. LaSalle Calculation ATD-0351, "RCIC Pump Room Temperature Transient Following Station Blackout with Gland Seal Leakage," Rev. 3 Page 66 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan

10. LaSalle Engineering Evaluation EC 392196, Rev. 0, "Spent Fuel Pool Uncovery Time for Outage and Online Scenarios,"

Page 67 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment 2 Milestone Schedule Site: LaSalle Original Target Activity Status Completion Date {Include date changes in this column}

Submit 60 Day Status Report Complete Submit Overall Integrated Complete Implementation Plan Contract with RRC Complete Recurring action, Submit six (6) month updates Ongoing Aug and Feb Unit 1 Unit 2 Modification Development an 2015 Jan 2014

• Phase 1 modifications Note 1 an 2015 an 2014

• Phase 2 modifications Note 1 an 2015 an 2014

• Phase 3 modifications Note 1 Unit 1 Unit 2 Modification Implementation Mar 2016 Feb 2015

• Phase 1 modifications Note 1 Mar 2016 Feb 2015

• Phase 2 modifications Note 1 Mar 2016 Feb 2015

• Phase 3 modifications Note 1 Procedure development Feb 2015

• Strategy procedures Note 1 Feb 2015

• Maintenance procedures Note 1 Oct 2014 Staffing analysis Note 1 Feb 2015 Storage Plan and construction Note 1 Feb 2015 FLEX equipment acquisition Note 1 Feb 2015 Training completion Note 1 Dec 2014 Regional Response Center (will be a standard date from Operational RRC)

Mar 2016 Unit 1 Implementation date Note 1 Feb 2015 Unit 2 Implementation date Note 1 Note(s):

1. Exelon will update the status of ongoing and future milestones in the Integrated Plan for LSCS during a scheduled six (6) month update. This update will include any changes to the milestone schedule as submitted in the February 28, 2013 Integrated Plan.

Page 68 of 70

LaSalle County Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment 3 Conceptual Sketches

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