Text

Transmittal of Callaway Plant NRC FLEX Submittal for February 2013
	ML13063A458
Person / Time
Site:	Callaway
Issue date:	02/22/2013
From:	Retersdorf A; Westinghouse
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML130630597	List: ML13063A458; ULNRC-05962, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events (EA-12-049);
References
	LTR-FSE-13-24, Revision 0
	Download: ML13063A458 (131)
	v • d • e

Westinghouse Non-Proprietary Class 3

Electronically approved records are authenticated in the electronic document management system.

To: Mark Kloock Date: February 22, 2013 cc: Susan Baier From: Alan Retersdorf Ext: 860-731-6184 Our ref: LTR-FSE-13-24, Revision 0 Fax: 860-731-1149

References:

1. Westinghouse Report, TR-FSE-13-4, Revision 0, Callaway Plant FLEX Integrated Plan, February 2013.

Subject:

Transmittal of Callaway Plant NRC FLEX Submittal for February 2013 The purpose of this letter is to transmit a non-proprietary version of Appendix G of Reference 1 for Callaway Plant. This non-proprietary version of this reference is contained in Attachment 1 to this letter.

A word version of this Attachment is electronically attached in EDMS.

It is requested that Callaway Plant review the latest Revision of Reference 1 prior to submittal to the Nuclear Regulatory Commission (NRC) to ensure that the submittal is in alignment with the latest information. Reference 9 (TR-FSE-13-4) of Attachment 1 will need to be updated accordingly.

Please transmit this letter to John Patterson.

Author:

Verifier:

A. F. Retersdorf C. P. Arnold Systems and Equipment Engineering II Systems and Equipment Engineering III Electronically Approved*

Electronically Approved*

Manager:

S. L. Baier Fluid Systems Engineering Electronically Approved*

Enclosure to ULNRC-05962 Page 1 of 131

Callaway Plant FLEX Integrated Plan Submittal Enclosure to ULNRC-05962 Page 2 of 131

1 February 2013 THIS PAGE INTENTIONALLY LEFT BLANK Enclosure to ULNRC-05962 Page 3 of 131

2 February 2013 THIS PAGE INTENTIONALLY LEFT BLANK Enclosure to ULNRC-05962 Page 4 of 131

3 February 2013 General Integrated Plan Elements Callaway Plant Determine Applicable Extreme External Hazard Ref: NEI 12-06 Section 4.0 -9.0 JLD-ISG-2012-01 Section 1.0 Input the hazards applicable to the site; seismic, external flood, high winds, snow, ice, cold, high temps. Describe how NEI 12-06 Sections 5 through 9 were applied and the basis for why the plant screened out for certain hazards.

Callaway Plant has been evaluated and the following applicable hazards have been identified:

Seismic events Storms such as high winds and tornadoes Extreme snow, ice and cold Extreme heat Callaway Plant has determined the functional threats from each of these hazards and identified FLEX equipment that may be needed. The FLEX equipment will provide the protection required from these hazards. Callaway Plant is also developing procedures and processes to further address plant strategies for responding to these various hazards.

Seismic:

Per FSAR seismic input, for Callaway Plant the seismic criteria include two design basis earthquake spectra: Operating Basis Earthquake (OBE) and Safe Shutdown Earthquake (SSE).

The site seismic design response spectra define the vibratory ground motion of the OBE and SSE.

The maximum horizontal acceleration for the SSE is 0.20g, and the OBE has a maximum horizontal acceleration of 0.12g (Reference 4, Section 2.5.2.8).

All safety-related structures are founded on granular structural fill composed mainly of crushed limestone and dolomite or on Graydon chert conglomerate. Neither material is susceptible to liquefaction (Reference 4, Section 2.5.4.8).

In summary, the seismic hazard applies to Callaway Plant. As a result, the credited FLEX equipment will be assessed based on the current Callaway Plant seismic licensing basis to ensure that the equipment remains accessible and available after a beyond design basis external event (BDBEE) scenario as outlined in NEI 12-06 (Reference 2) and that the FLEX equipment does not become a target or source of a seismic interaction from other systems, structures or components. The FLEX strategies developed for Callaway Plant will include documentation ensuring that any storage locations and staging routes and routes from off-site resource support meet the FLEX seismic criteria.

External Flooding:

The types of events evaluated to determine the worst potential flood included (1) potential maximum flood (PMF) due to nearby water sources, and (2) flood due to local intense precipitation equal to the potential maximum precipitation (PMP) at the plant site.

Specific analysis of flood levels resulting from ocean front surges and tsunamis is not required because of the inland location of the plant. Flood waves from landslides into upstream reservoirs Enclosure to ULNRC-05962 Page 5 of 131

4 February 2013 required no specific analysis due to the lack of topographic and geologic features conducive to landslide formation.

The maximum plant site flood level from any cause is Elevation 840.16 ft mean sea level (MSL)

(Reference 9). The grade level for all SSCs (except UHS and RWST) is an elevation of about 840.5 ft MSL (plant elevation 2000 ft) (Reference 9). Per NEI 12-06 (Reference 2), plants that are considered dry (i.e., the plant is built above the design basis flood level) are not susceptible to the external flooding hazard; therefore, the external flood hazard is screened out for Callaway Plant. However, Callaway Plant is developing procedures and strategies for delivery of offsite FLEX equipment during Phase 3 which considers regional impacts from flooding.

High Wind:

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

Callaway Plant is not susceptible to hurricanes based on its location in central Missouri. The plant site is a significant distance from the final contour line shown in Figure 7-1 of NEI 12-06 (Reference 2).

It was determined that the Callaway Plant site has the potential to experience damaging winds caused by a tornado exceeding 130 mph. Figure 7-2 of NEI 12-06 (Reference 2) indicates a maximum wind speed of 200 mph for Region 1 plants, including Callaway Plant. Therefore, high-wind hazards are applicable to the Callaway Plant site.

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

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

Applicability of snow and extreme cold:

NEI 12-06 (Reference 2) states plants above the 35th parallel should provide the capability to address the impedances caused by extreme snow and cold. Callaway Plant site is above the 35th parallel; therefore, the FLEX strategies must consider the impedances caused by extreme snowfall with snow removal equipment, as well as the challenges that extreme cold temperature may present. Callaway Plant is located at Universal Transverse Mercator Coordinates Latitude 38°4540.7 North and Longitude 91°4650.5 (Reference 4, Section 2.1.1.1).

Applicability of ice storms:

Callaway Plant site is not a Level 1 or 2 region as defined by Figure 8-2 of the NEI 12-06 (Reference 2); therefore, the FLEX strategies must consider the impedances caused by ice storms.

In summary, based on Figures 8-1 and 8-2 of NEI 12-06 (Reference 2), Callaway Plant site does experience significant amounts of snow or ice, and extreme cold temperatures; therefore, these hazards are screened in.

Extreme Heat:

Per NEI 12-06 (Reference 2), all sites must address high temperatures. Virtually every state in the lower 48 contiguous United States has experienced temperatures in excess of 110F. Many states have Enclosure to ULNRC-05962 Page 6 of 131

5 February 2013 experienced temperatures in excess of 120F. Sites that should address high temperatures should consider the impacts of these conditions on the FLEX equipment and its deployment.

The climate at Callaway Plant site is temperate-continental with cold, snowy winters and warm, humid summers. Based on climatological data from nearby weather stations, the normal average temperature is 55°F in Columbia, Missouri. Extreme temperatures are 116°F and -26°F in Fulton, Missouri Reference 4, Section 2.3).

In summary, based on the available local data and industry estimates, the Callaway Plant site does not experience extreme high temperatures. However, per NEI 12-06 (Reference 2), all sites will address high temperatures. Therefore, for FLEX equipment Callaway Plant will consider the site maximum expected temperatures in their specification, storage, and deployment requirements, including ensuring adequate ventilation or supplementary cooling, if required.

Key Site assumptions to implement NEI 12-06 strategies.

Ref: NEI 12-06 Section 3.2.1 Provide key assumptions associated with implementation of FLEX strategies:

Assumptions are consistent with those detailed in NEI 12-06, Section 3.2.1. Analysis has been performed consistent with the recommendations contained within the Executive Summary of the Pressurized Water Reactors Owners Group (PWROG) Core Cooling Position Paper (Reference 10) and assumptions from that document are incorporated into the plant-specific analytical bases. Key industry guidance and site-specific assumptions are presented here:

NEI 12-06 Assumptions Section 3.2.1 of NEI 12-06 (Reference 2) provides the following assumptions:

Initial Plant Conditions The initial plant conditions are assumed to be the following:

A1.

Prior to the event the reactor has been operating at 100 percent rated thermal power for at least 100 days or has just been shut down from such a power history as required by plant procedures in advance of the impending event.

A2.

At the time of the postulated event, the reactor and supporting systems are within normal operating ranges for pressure, temperature, and water level for the appropriate plant condition. All plant equipment is either normally operating or available from the standby state as described in the plant design and licensing basis.

Enclosure to ULNRC-05962 Page 7 of 131

6 February 2013 Initial Conditions The following initial conditions are to be applied:

A3.

No specific initiating event is used. The initial condition is assumed to be a loss of offsite power (LOOP) at a plant site resulting from an external event that affects the off-site power system either throughout the grid or at the plant with no prospect for recovery of off-site power for an extended period. The LOOP is assumed to affect all units at a plant site.

A4.

All installed sources of emergency on-site ac power and SBO Alternate ac power sources are assumed to be not available and not imminently recoverable.

A5.

Cooling and makeup water inventories contained in systems or structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles are available.

A6.

Normal access to the ultimate heat sink is lost, but the water inventory in the UHS remains available and robust piping connecting the UHS to plant systems remains intact.

The motive force for UHS flow, i.e., pumps, is assumed to be lost with no prospect for recovery.

A7.

Fuel for FLEX equipment stored in structures with designs that are robust with respect to seismic events, floods and high winds and associated missiles, remains available.

A8.

Permanent plant equipment that is contained in structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles, are available.

A9.

Other equipment, such as portable ac power sources, portable backup dc power supplies, spare batteries, and equipment for 10 CFR 50.54(hh)(2), may be used provided it is reasonably protected from the applicable external hazards per Sections 5 through 9 and Section 11.3 of NEI 12-06 (Reference 2) and has predetermined hookup strategies with appropriate procedures/guidance and the equipment is stored in a relative close vicinity of the site.

A10.

Installed electrical distribution system, including inverters and battery chargers, remain available provided they are protected consistent with current station design.

A11.

No additional events or failures are assumed to occur immediately prior to or during the event, including security events.

A12.

Reliance on the fire protection system ring header as a water source is acceptable only if the header meets the criteria to be considered robust with respect to seismic events, floods, and high winds, and associated missiles.

Reactor Transient The following additional boundary conditions are applied for the reactor transient:

A13.

Following the loss of all ac power, the reactor automatically trips and all rods are inserted.

A14.

The main steam system valves (such as main steam isolation valves, turbine stops, atmospheric dumps, etc.), necessary to maintain decay heat removal functions operate as designed.

A15.

Safety/Relief Valves (S/RVs) or Power Operated Relief Valves (PORVs) initially operate Enclosure to ULNRC-05962 Page 8 of 131

7 February 2013 in a normal manner if conditions in the RCS so require. Normal valve reseating is also assumed.

A16.

No independent failures, other than those causing the ELAP/LUHS event, are assumed to occur in the course of the transient.

Reactor Coolant Inventory Loss Sources of expected PWR reactor coolant inventory loss include:

A17.

Normal system leakage A18.

Losses from letdown unless automatically isolated or until isolation is procedurally directed A19.

Losses due to reactor coolant pump seal leakage (rate is dependent on the RCP seal design)

SFP Conditions The initial SFP conditions are:

A20.

All boundaries of the SFP are intact, including the liner, gates, transfer canals, etc.

A21.

Although sloshing may occur during a seismic event, the initial loss of SFP inventory does not preclude access to the refueling deck around the pool.

A22.

SFP cooling system is intact, including attached piping.

A23.

SFP heat load assumes the maximum design basis heat load for the site.

Containment Isolation Valves A24.

It is assumed that the containment isolation actions delineated in current station blackout coping capabilities are sufficient.

The following assumptions are specific to Callaway Plant:

A25.

Callaway Plant will be able to identify an ELAP condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to enable actions that place the plant outside the current design and licensing basis.

A26.

From Reference 11: 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 Enclosure to ULNRC-05962 Page 9 of 131

8 February 2013 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/or with its Security Plan, and, as such, may warrant invocation of 10 CFR 50.54(x) and/or 10 CFR 73.55(p).

A27.

Required staffing levels will be determined consistent with guidance contained in NEI 12-06 for each of the site specific FLEX strategies. Assumed available staffing levels will be determined consistent with NEI 12-01, as described below.

The event impedes site access as follows:

A. Post event time: 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

B. Post event time: 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g.,

private resource providers or public sector support).

C. Post event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

These results will be compared to confirm this assumption, or adjustments will be made to plant staffing or FLEX design to meet this requirement.

A28.

Flood and seismic re-evaluations pursuant to the 10 CFR 50.54(f) letter of March 12, 2012 are not completed and therefore not assumed in this submittal. As the re-evaluations are completed, appropriate issues will be entered into the corrective action system.

A29.

It is assumed that each FLEX component can store a minimum supply of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months of fuel at constant operation. This forms the basis for deployment of the refueling strategies.

This will be confirmed as more detailed design information becomes available.

A30.

The designed hardened connections applicable to FLEX strategies are protected against external events or are established at multiple and diverse locations.

A31.

Callaway Plant will be installing the Westinghouse Spent Fuel Pool Level Instrumentation System.

A32.

Callaway Plant will be installing Westinghouse Low Leak RCP seals (SHIELD1) prior to FLEX implementation.

A33.

The location of the Primary Storage bunker will be located within the protected area prior to FLEX implementation.

1 SHIELD is a registered trademark of Westinghouse Electric Company LLC, its subsidiaries and/or affiliates in the United States of America and may be registered in other countries throughout the world.

Enclosure to ULNRC-05962 Page 10 of 131

9 February 2013 Extent to which the guidance, JLD-ISG-2012-01 and NEI 12-06, are being followed.

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

Ref: JLD-ISG-2012-01 Ref: NEI 12-06 Section 13.1 Include a description of any alternatives to the guidance, and provide a milestone schedule of planned action.

Ameren will fully comply with the guidance in JLD-ISG-2012-01 (Reference 3) and NEI 12-06 (Reference 2) in implementing FLEX strategies for Callaway Plant.

Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint.

Ref: NEI 12-06 Section 3.2.1.7 JLD-ISG-2012-01 Section 2.1 Strategies that have a time constraint to be successful should be identified with a technical basis and a justification provided that the time can reasonably be met (for example, a walkthrough of deployment).

Describe in detail in this section the technical basis for the time constraint identified on the sequence of events timeline A See attached sequence of events timeline (Attachment 1A).

Technical Basis Support information, see attached NSSS Significant Reference Analysis Reconciliation Table (Attachment 1B)

The sequence of events and any associated time constraints are identified below for Callaway Plant Modes 1-4 strategies for FLEX Phases 1 through Phase 3 (Reference 9). See attached sequence events timeline (Attachment 1A) for a summary of this information.

1. Declare ELAP - 0.75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months ELAP entry conditions can be verified by control room staff and it is validated that both emergency diesel generators are not available. This is a reasonable assumption for system operators to perform initial evaluations of the EDGs. Entry into ELAP provides guidance to operators to perform ELAP actions. Time constraint is required to allow taking actions which place the plant SSCs outside License Basis alignments (Reference 9).

2. Control Room Lighting - 0.75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months Lighting in the control room will initially be powered by plant batteries (Reference 9).

Portable lighting systems will be used once load shed procedures are implemented. Lighting strategies in Phase 2 are the same as in Phase 1. Existing plant circuits are not expected to be directly repowered using the 480V FLEX generators.

3. Control Room Ventilation - 0.75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months Enclosure to ULNRC-05962 Page 11 of 131

10 February 2013 Callaway Plant procedure ECA-0.0, Loss of All AC Power, directs opening control room cabinet doors (Reference 6.a). Strategies for providing temporary ventilation are still being developed, which include propping open doors and possibly using small generators to power mobile fans.

4. NK Power Load Shed - 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Load shed should be initiated no later than 0.75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months after the event to complete no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (Reference 9).

5. Vent SFP Area-5.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months This constraint time is based on the SFP time to boil, assuming sloshing occurs and the initial temperature of the SFP is 140°F (Reference 9).

6. Perform Damage Assessment - 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Callaway Plant will develop a post event damage assessment walkdown procedure. The purpose of the damage assessment walkdown is to evaluate and document the condition of plant systems, structures and components (SSCs) after an ELAP event. The damage assessment will be comprehensive enough such that plant management and staff can plan the best recovery strategy. Based on the expected complexity of the task, it is assumed that the damage assessment will take 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , depending on local site conditions. It is assumed that critical plant conditions will be known by the control room coordinator to inform appropriate actions following the completion of this task (Reference 9). This damage assessment will guide FLEX strategies and will be a future FSG requirement.

7. Debris Removal - 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months Based on earliest need for deployment paths (Reference 9).

8. Deploy FLEX SG Makeup pump (FLEX Core Cooling Pump) - 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months Stage as early as possible in event to provide defense in depth (Reference 9).

9. Perform Plant Cooldown - 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Based on Reference 9, a plant cooldown will begin within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and will have a duration of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The ARVs and the TDAFWP will be used to ensure a symmetric plant cooldown.

Actual cooldown time is projected to be approximately 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months but 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is assumed because local AFW and ARV control is required (Reference 9).

10. Energize NK Power 480V Generator - 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months This time constraint is dependent upon the earliest need for the generator based on providing power to the NK Power System (Reference 9).

11. Establish Battery Room Ventilation - 14.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Battery room ventilation must occur shortly after battery charging is initiated to vent hydrogen (Reference 9).

12. Align CST Makeup from the UHS - 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months Based on current CST credited volume depleting in 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months (Reference 9). The UHS is the preferred seismic alternate coolant source (ACS) (Reference 9).

13. Initiate RCS Makeup (boration) from BAT - 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months This time constraint was calculated by dividing the total volume of boron injected by the volumetric flow rate of the injection stream (Reference 9).

14. FLEX Fuel Deployment - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months This is an assumption. Callaway Plant will provide a more exact basis once all FLEX equipment has been purchased and equipment specifications (fuel consumption rate) are known.

15. TDAFWP Room Ventilation - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Callaway Plant will perform analysis to prove indefinite coping or provide actions necessary to maintain EQ requirements for the TDAFWP.

Enclosure to ULNRC-05962 Page 12 of 131

11 February 2013

16. Initiate SFP Makeup - 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months Per Reference 9, the time for the SFP to boil is 5.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and the time for the level to reach 15 ft. above the top of the racks is 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

17. Switch RCS Makeup from BATs to RWST - 46 hours5.324074e-4 days 0.0128 hours 7.60582e-5 weeks 1.7503e-5 months This need time is based on the depletion of the BATs and the need to maintain RCS inventory (Reference 9).

18. Large Debris Removal -72 hours Need time is based on the need for large equipment arriving on-site requiring for additional debris clearing. Equipment of this size is not expected to arrive on site until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Reference 9).

19. Mobile Water Purification System -72 hours The current credited CST volume will deplete in 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months . The volume of the UHS Retention Pond can be credited indefinitely. This mobile purification skid would be aligned as soon as possible to prevent continued injection with untreated water (Reference 9).

20. Ultimate Heat Sink Pump - 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Assumption based on current plant analysis limited applicability of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Need time is based on loss of capability to support SG feed strategy (Reference 9).

21. 4160V generator - 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Assumption based on current plant analysis limited applicability of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Need time is based on eventual loss of capability to support SG feed strategy (Reference 9).

22. Mobile Boration Unit - 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months This time constraint is based on on-site borated sources depleting (Reference 9).

23. Establish Large Fuel Truck Service - 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Assumption regarding the depletion of on-site supply and supplying larger equipment.

Callaway Plant will provide a more exact basis once all FLEX equipment has been purchased and equipment specifications are known (Reference 9).

To confirm the times given, Callaway Plant will prepare procedures for each task, perform time study walkthroughs for each of the tasks under simulated ELAP conditions, and account for equipment and tagging and other administrative procedures required to perform the task.

Identify how strategies will be deployed in all modes.

Ref: NEI 12-06 section 13.1.6 Describe how the strategies will be deployed in all modes.

Callaway Plant has differentiated between the route from a storage location to its staging location, which is the staging route, and the path from a staging location to the source and/or supply plant connection, which is the deployment path. Staging routes are shown in Figure A3-1 and Figure A3-32. Deployment paths are shown in Figure A3-4, Figure A3-5, Figure A3-10, Figure A3-11, Figure A3-12, Figure A3-13, Figure A3-14, Figure A3-15, Figure A3-17, Figure A3-18, Figure A3-19, and Figure A3-20. Staging routes will be followed to transport the FLEX equipment to the required staging locations. The deployment paths will be followed to connect the associated plant SSCs to Enclosure to ULNRC-05962 Page 13 of 131

12 February 2013 allow the strategies to be implemented. Deployment paths with respect to the applicable plant mode will be maintained clear. Evaluations will need to be performed to demonstrate the integrity of the staging and deployment paths with regard to a BDBEE scenario as outlined in NEI 12-06 (Reference 2). For Phase 3, the deployment routes from the staging area will be evaluated based on an assessment of the damage in the affected area; the equipment will be deployed to the site in accordance with that assessment. These requirements will be included in an administrative program. Updates on these activities will be included in the appropriate six month status updates required by Reference 1.

Provide a milestone schedule.

This schedule should include:

Modifications timeline o Phase 1 Modifications o Phase 2 Modifications o Phase 3 Modifications Procedure guidance development complete o Strategies o Maintenance Storage plan (reasonable protection)

Staffing analysis completion FLEX equipment acquisition timeline Training completion for the strategies Regional Response Centers operational Ref: NEI 12-06 Section 13.1 The dates specifically required by the order are obligated or committed dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

See attached milestone schedule Attachment 2 See attached milestone schedule Attachment 2 Identify how the programmatic controls will be met.

Ref: NEI 12-06 Section 11 JLD-ISG-2012-01 Section 6.0 Provide a description of the programmatic controls equipment protection, storage and deployment and equipment quality. See Section 11 in NEI 12-06. Storage of equipment, 11.3, will be documented in latter sections of this template and need not be included in this section.

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

Enclosure to ULNRC-05962 Page 14 of 131

13 February 2013 Equipment associated with these strategies will be procured as commercial equipment with design, storage, maintenance, testing, and configuration control in accordance with NEI 12-06, Section 11.0 (Reference 2).

The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy will be managed using plant equipment control guidelines developed in accordance with NEI 12-06, Section 11.5 (Reference 2).

Programs and controls will be established to assure personnel proficiency in the mitigation of a BDBEE scenario as outlined in NEI 12-06 (Reference 2).

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

Describe training plan List training plans for affected organizations or describe the plan for training development Training plans will be developed for plant groups such as the emergency response organization (ERO), Fire, Security, emergency planning (EP), Operations, Engineering, Maintenance, and Instrumentation and Controls. The training plan development will be done in accordance with Callaway Plant procedures using the Systematic Approach to Training, and will be implemented to ensure that the required Callaway Plant staff is trained prior to implementation of FLEX. The training program will comply with the requirements outlined in Section 11.6 of NEI 12-06 (Reference

2)

Describe Regional Response Center plan Discussion in this section may include the following information and will be further developed as the Regional Response Center development is completed.

Site-specific RRC plan Identification of the primary and secondary RRC sites Identification of any alternate equipment sites (i.e., another nearby site with compatible equipment that can be deployed)

Describe how delivery to the site is acceptable Describe how all requirements in NEI 12-06 are identified The industry will establish two (2) Regional Response Centers (RRCs) to support utilities during a BDBEE scenario as outlined in NEI 12-06 (Reference 2). Each RRC will hold five (5) sets of equipment, four (4) of which will be able to be fully deployed when requested; the fifth set will have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local Assembly Area, established by the Strategic Alliance for FLEX Emergency Response (SAFER) team and the utility.

Communications will be established between the affected nuclear site and the SAFER team and Enclosure to ULNRC-05962 Page 15 of 131

14 February 2013 required equipment moved to the site as needed. First arriving equipment, as established during development of the nuclear sites playbook, will be delivered to the site within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the initial request.

Callaway Plant will negotiate and execute an automatically renewing contract with the vendor of the RRC to establish and maintain a facility which will meet the requirements of NEI 12-06, Section 12 (Reference 2).

Notes:

None Enclosure to ULNRC-05962 Page 16 of 131

15 February 2013 Maintain Core Cooling & Heat Removal Determine Baseline coping capability with installed coping2 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

AFW/EFW

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

Core Cooling with Steam Generators Available:

During a station blackout (SBO), operator actions are currently governed by procedure ECA-0.0 (Reference 6.a). Per Callaway Plant IER 11-4 response (Reference 5), the site has evaluated core cooling, containment integrity, and spent fuel pool (SFP) inventory based on this current procedure and protected equipment.

Analysis shows that approximately 660,000 gallons of secondary makeup water is required to maintain core cooling for a minimum of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Reference 9). Based on the Technical Specification (TS) minimum CST volume of 281,000 gallons and Reference 9, the CST volume will be available for 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months . The seismically qualified alternate coolant source is the ultimate heat sink (UHS) retention pond with a volume of 38 acre feet (Reference 4, Section 9.2.5.3). Using a combination of the CST and UHS, there is sufficient seismically protected inventory to provide AFW for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after the BDBEE scenario as outlined in NEI 12-06 (Reference 2), assuming the CST is modified to be made seismically qualified and missile protected. Per Section 10.4.9.2.3 of Reference 4, the Turbine Driven Auxiliary Feedwater Pump (TDAFWP) will automatically start on a loss of offsite power signal. The current plant procedures provide for the capability to manually restart the TDAFWP within 50 minutes, if required (Reference 6.b, Attachment R).

The strategy in the current procedures (ECA-0.0; Reference 6.a) includes load shedding to conserve battery life, depressurizing to reduce potential RCS leakage through RCP seals, and removing heat through the steam generators using the atmospheric relief valves (ARVs) with the SGs being fed by the TDAFWP.

The CST is non-seismic and non-missile protected and, therefore, is not creditable for FLEX (Reference 9).

The volume available in this CST is sufficient for core decay heat removal for 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months . The site has contracted an engineering firm to conduct a seismic and missile protection evaluation of the CST. Callaway Plant is also evaluating installation of a new, seismically qualified and hardened CST that will hold approximately 670,000 gallons of creditable volume. This volume would be sufficient for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of 2 Coping modifications consist of modifications installed to increase initial coping time, i.e. generators to preserve NK instruments or increase operating time on battery powered equipment.

Enclosure to ULNRC-05962 Page 17 of 131

16 February 2013 coping.

The TDAFWP is a horizontal centrifugal pump. The pump bearings are cooled by the pumped fluid. The pump design capacity includes continuous minimum flow recirculation. Power for all controls, valve operators, and other support systems is independent from ac power sources. Steam supply is taken from two of the four main steam lines between the containment penetrations and the main steam isolation valves.

Each of the steam supply lines to the turbine is equipped with a locked-open gate valve, normally closed air-operated globe valve with air-operated globe bypass to keep the line warm, and two non-return valves.

Air-operated globe valves are equipped with dc-powered solenoid valves. Callaway Plant will be installing a secondary nitrogen source for these air-operated valves so they can be repositioned remotely or locally following the event. These steam supply lines join to form a header that leads to the turbine through a normally closed, dc motor-operated, mechanical trip and throttle valve. The steam lines contain provisions to prevent the accumulation of condensate. The turbine driver is designed to operate with steam inlet pressures ranging from 92 psia to 1,290 psia (Reference 4, Section 10.4.9.2.2).

The Auxiliary Feedwater System (AFS) is located in the Auxiliary Building, except for the TDAFWP exhaust pipe and the section of pump recirculation piping mentioned below. Exhaust steam from the turbine driver is routed from the Auxiliary Building wall through the Auxiliary Boiler Building, which is designed to UBC seismic requirements. If the Auxiliary Boiler Building were to catastrophically fail and the exhaust line were sheared off completely, the TDAFWP would operate properly (Section 10.4.9.3 of Reference 4).

This building is designed to withstand the effects of earthquakes, tornadoes, hurricanes, floods, external missiles, and other appropriate natural phenomena (Reference 4).

In Callaway Plants IER 11-4 response (Reference 5) the site recognized that because the condensate storage tank (CST) was neither seismic or missile protected and the ESW (which is the safety grade backup) would be unavailable due to a simultaneous BDBEE scenario as outlined in NEI 12-06 (Reference

2) and ELAP, the site would be unable to establish auxiliary feed, and consequently, core damage was estimated to occur within 2.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . Subsequent to the response, the site has contracted an engineering firm to conduct a seismic evaluation of the CST. Callaway Plant is also evaluating installation of a new, seismically qualified and hardened CST that will hold approximately 670,000 gallons of creditable volume.

This volume would be sufficient for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of coping. All of the current AFW makeup strategies rely on the integrity of the CST. Should Callaway Plant install a new CST, the strategies will change to draw water from the new CST, but the discharge connection points and staging location will remain the same. A future action is required to resolve this issue (Open Item OI5).

To avoid pump damage due to overheating while operating with no delivered flow, the TDAFWP requires a minimum flow of 120 gpm (Reference 9). To satisfy this requirement, the TDAFWP has a recirculation line off the discharge line, AL-029-DBC-3 which becomes AL-045-DBC-3, that returns to the CST. The recirculation line transitions from safety-related to non-safety related/non-seismic at the AFS to CST pipe chase boundary, becoming line AL-046-DBD-3. The CST pipe chase and the CST are not seismically qualified. If a hazard (i.e., tornadoes, floods, missiles, pipe breaks, fires, and seismic events) resulted in the non-safety related portion of the recirculation header becoming crimped such that the recirculation flow was restricted in conjunction with an AFS actuation signal, the potential for pump damage would exist.

Callaway Plant will evaluate options to analyze this piping or protect it. A future action is required to resolve this issue (Open Item OI5).

An assessment of room environmental conditions and effects on key equipment was also performed.

Reference 5 documents that temperatures in the TDAFWP Room, equipment cabinets, and the control room Enclosure to ULNRC-05962 Page 18 of 131

17 February 2013 are considered acceptable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following a BDBEE scenario as outlined in NEI 12-06 (Reference 2). Callaway Plant will evaluate ventilation coping times beyond 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . A future action is required to resolve this issue.

Per Reference 5, DC control power for the TDAFWP will be available for a minimum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months without load shedding. The Emergency Coordinator Supplemental Guidelines provide guidance to operate the TDAFWP and control flow manually without DC control power (Reference 6.b).

An atmospheric relief valve (ARV) is installed on the outlet piping from each steam generator. The four valves are installed to provide for controlled removal of reactor decay heat during normal reactor cooldown when the main steam isolation valves are closed or the turbine bypass system is not available. The total capacity of the four valves is 15 percent of rated main steam flow at steam generator no-load pressure. The maximum actual capacity of the relief valve at design pressure is limited to reduce the magnitude of a reactor transient if one valve would inadvertently open and remain open (Reference 4).

The ARVs are air-operated carbon steel, 8-inch 1,500-pound globe valves, supplied by a safety-related air supply (Section 9.3.1 of Reference 4), and controlled from Class 1E sources. A non-safety related air source is available during normal operating conditions. The capability for remote manual valve operation is provided in the main control room, the auxiliary shutdown panel, and locally at the valves for ABPV0002 and ABPV0003. The valves are opened by pneumatic pressure and closed by spring action. These valves are designed to withstand the effects of earthquakes, flooding, and a high wind/missile hazard (Reference 5). Future FLEX Support Guideline procedures will address specific actions for operating the ARVs in a BDBEE scenario as outlined in NEI 12-06 (Reference 2).

Callaway Plant is designing a modification that will supplement the existing backup nitrogen capacity. This modification will provide nitrogen for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Reference 9). A future action is required to resolve this issue.

Core Cooling with Steam Generators not Available:

Reactor core cooling and heat removal with steam generators not available is provided during Phase 1 by heating up and boiling of the RCS coolant inventory. RCS inventory during Phase 1 may be maintained by gravity feed from the RWST. The ability of the RWST to provide gravity feed to the RCS is limited by the RWST fluid height, line losses through the gravity feed path, and pressure within the RCS.

If it is determined that gravity feed is not effective to cool the RCS and prevent fuel damage, Callaway Plant will take actions to proceduralize administrative controls to pre-stage FLEX equipment prior to entering a condition where the steam generators cannot provide adequate core cooling.

Details:

Provide a brief description of procedures, strategies, and guidelines Confirm that procedure/guidance exists or will be developed to support implementation.

Station Blackout (SBO) Emergency Operating Procedure (EOP) ECA-0.0 addresses the standard CST alignment strategy. The strategies in ECA-0.0 must be tied to the appropriate FLEX Support Guideline (FSG) for this Enclosure to ULNRC-05962 Page 19 of 131

18 February 2013 strategy when the FSG is developed.

Identify modifications List modifications

1. In order to credit the CST, the tank and the attached valve house need to be seismically qualified and missile protected. Callaway Plant is also evaluating installation of a new, seismically qualified and hardened CST that will hold approximately 670,000 gallons of creditable volume. This volume would be sufficient for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of coping (Reference 9).

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

1. SG Level - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

2. AFW Flow indication (downstream of connection points) - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

3. SG Pressure - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

4. CST Level - Normal Power Source: Non-Class 1-E; a temporary battery will be used to repower the non-Class 1E racks (Open Item OI4)

5. RCS Hot Leg Temperature (if CETs not available)- Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

6. RCS Cold Leg Temperature - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

7. Core Exit Thermocouple - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

8. RCS Pressure - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

9. Pressurizer Level - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG Callaway Plant will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Notes:

Core cooling strategies are provided for conditions where steam generators are available or where steam generators are not available but a sufficient RCS vent has been established to support core cooling. This assumption is per the guidance of NEI 12-06 FAQ 2012-19. Other configurations are not considered as these occur for short durations that are exempted per NEI 12-06 Table D.

After NK load shedding, only ABPV0001 and ABPV0002 will have DC power available for operation and the Control Room will only be able to remotely control AFW to SG A and SG D.

Enclosure to ULNRC-05962 Page 20 of 131

19 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain core cooling. Identify methods and strategy(ies) utilized to achieve this coping time.

Core Cooling with Steam Generators Available:

The transition into Phase 2 will be required once the operating conditions of the TDAFWP cannot be maintained. As the event proceeds, the decay heat will decrease and as a result the steam output from the SG will decrease. Eventually, the steam output will not be sufficient to run the TDAFWP. Prior to that point the transition to the Phase 2 strategy will occur. The primary and secondary strategies involve staging the FLEX Core Cooling Pump on the other side of Road J from the CST. The FLEX Core Cooling Pump will draw from the CST through the currently available hose connection downstream of APV0043 on the Plant South side of the tank. The FLEX Core Cooling Pump discharge will be connected with hose to a hard pipe connection in the CST valve house. Two intermediate pipes (one for either connection) will run from the CST valve house through the pipe chase into the Auxiliary Building where a flexible spool will be used in either Room 1330 or 1326 to make the final connection to the AFW system. For both strategies, suction will be taken from the CST. It is estimated that this source will be available for 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months . The next qualified source available is the UHS Retention Pond. There is a large amount of fuel available on site that should be sufficient for all Phase 2 strategies (Reference 9).

The ARVs continue to be used during Phase 2 and the details provided in the Phase 1 description apply in Phase 2. Should the AFW flow control valves need to be adjusted, the same details provided in the Phase 1 description apply in Phase 2.

Core Cooling with Steam Generators not Available:

For an event that occurs when the steam generators are not available to provide core cooling, the transition to Phase 2 strategies will be required as inventory is lost from the RCS. Reactor core cooling and heat removal with steam generators not available will be provided by using the FLEX Core Cooling Pump to inject water into the High Pressure Coolant Injection system. Existing piping will feed the RCS through normal safety injection paths into the cold legs.

A flushing flow of approximately 127 gpm at atmospheric conditions is required at 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months in order to preclude the RCS fluid from reaching the incipient boric acid precipitation point (Reference 9).

Suction will be taken from the RWST through a new connection. The FLEX Core Cooling Pump will be located in Staging Area 2 and will provide discharge through a mix of flexible hose and hard piping. The flexible hose will be run from the portable pump to the Tendon Gallery access hatch. A penetration just beside the hatch will allow external access to permanently installed hard piping which will run along the outer wall of the Tendon Gallery. This piping will terminate at the Tendon Gallery access door to the Auxiliary Building. For the primary connection, flexible hose will be run from this access door to the base of the installed hard pipe on the outer Plant South wall of the BIT Room. Flexible hose will then run the short distance to the Storz connection in the piping penetration room. For the secondary connection, the flexible Enclosure to ULNRC-05962 Page 21 of 131

20 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 hose from the Tendon Gallery access door will run to a short piping penetration/sleeve on the Plant South wall of the BIT room. A flexible pipe will connect this pipe to the Storz connection in the BIT room. The proposed routes for these connections are shown in Figure A3-12 and Figure A3-13.

Details:

Provide a brief description of procedures, strategies, and guidelines Confirm that procedure/guidance exists or will be developed to support implementation.

Procedures and guidance to support deployment and implementation including interfaces to EOPs, special event procedures, abnormal event procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Section 11.4 (Reference 2). Further, the PWROG is developing generic and NSSS-specific FLEX Support FSGs via PA-PSC-0965. Callaway Plant will align with the PWROG guidance once the FSGs are developed.

Identify modifications List modifications

1. In order to credit the CST, the tank and the attached valve house need to be seismically qualified and missile protected. Callaway Plant is also evaluating installation of a new, seismically qualified and hardened CST that will hold approximately 670,000 gallons of creditable volume.

This volume would be sufficient for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of coping (Reference 9).

2. A reducing tee will be installed into the discharge line of the Non-Safety Auxiliary Feedwater Pump (NSAFWP) downstream of ALV0200 in Room 1330 for the primary connection and into the discharge of the A MDAFWP downstream of ALFV0042 in Room 1326 for the secondary connection. Both tees will have two isolation valves and terminate in a Storz connection.

3. Two intermediate runs of pipe will be installed from the CST valve house, through the pipe chase, and into the Auxiliary Building. The primary connection intermediate pipe will terminate in Room 1330; the secondary connection intermediate pipe will terminate in Room 1326.

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

1. SG Level - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

2. AFW Flow indication (downstream of connection points) - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

3. SG Pressure - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG Enclosure to ULNRC-05962 Page 22 of 131

21 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2

4. CST Level - Normal Power Source: Non-Class 1E, a temporary battery will be used to repower the non-Class 1E racks (Open Item OI4)

5. RCS Hot Leg Temperature - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

6. RCS Cold Leg Temperature - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

7. Core Exit Thermocouple - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

8. RCS Pressure - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG

9. Pressurizer Level - Normal Power Source: Class 1E; Long-Term Power Source: Temporary DG Callaway Plant will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Storage/Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements The maximum plant site flood level from any cause is elevation 840.16 ft mean sea level (Reference 9). The site sits at an elevation of about 840.5 ft mean sea level (Reference 9). The site is considered dry and thus none of the storage locations will be affected by a flood.

Two locations have been determined for storage of Callaway Plant FLEX equipment. These locations are shown in Attachment 3, Figure A3-1. The primary storage location will be a new FLEX storage bunker. The secondary storage location will be the Unit 2 ESW Pumphouse. Each of the buildings will have a common set of equipment capable of supporting each FLEX function/strategy. At this time it is estimated that the primary storage location will be approximately 6,000 ft2 and will be sufficient to store the N set of FLEX equipment and any FLEX vehicles. A conceptual evaluation has been performed (Reference 9) and will be reevaluated once the equipment list is final. A future action is required to resolve this issue. The secondary storage location is significantly smaller but still expected to be capable of storing all of the N+1 FLEX equipment. If all of the N+1 equipment cannot fit in the secondary storage location, there will be sufficient space in the primary storage location to store it. Priority for storage of N+1 equipment in the secondary storage location will be given to equipment that might be staged at Staging Area 3.

Enclosure to ULNRC-05962 Page 23 of 131

22 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Seismic List how equipment is protected or schedule to protect The storage locations will be designed or evaluated equivalent to ASCE 7-10, Minimum Design Loads for Buildings and Other Structures. Large portable FLEX equipment will be secured as appropriate during SSE and will be protected from seismic interactions with other components. No components will be stacked or at a raised elevation as to cause interference with the deployment of any of the FLEX equipment.

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

List how equipment is protected or schedule to protect The Callaway Plant is currently considered a dry site; however, Phase 2 equipment will be protected from flooding.

Severe Storms with High Winds List how equipment is protected or schedule to protect Portable equipment to implement FLEX strategies will be maintained in storage locations that are protected from high winds, i.e., hardened structures designed and built to ASCE 7-10.

Snow, Ice, and Extreme Cold List how equipment is protected or schedule to protect Portable equipment required to implement FLEX strategies will be maintained heated in storage locations.

High Temperatures List how equipment is protected or schedule to protect All of the storage locations will be evaluated for high temperature effects and ventilation will be provided as required to assure no adverse effects on the FLEX equipment. Active cooling systems are not required as normal ventilation will be utilized.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

Figure A3-1 and Figure A3-32 in Attachment 3 show the staging paths from each of the storage locations to the staging locations. The staging strategies will utilize the roadway that travels the perimeter of the plant inside the PA to get from storage to staging. It is the intent for Callaway Plant FLEX coping strategies to have the shortest distance traveled from storage location to staging location.

The four staging areas for Callaway Plant FLEX strategies are shown in Figure A3-1 and Figure A3-32 in Enclosure to ULNRC-05962 Page 24 of 131

23 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2. There is an abundance of space in each of these staging areas for FLEX equipment and space will not be a concern (Reference 9). Flooding is not a concern for the staging areas as the site is a dry site.

Normal plant maintenance will mitigate deployment concerns in icy and/or snow conditions. Staging Areas 1 through 3 will be used for mechanical/fluid systems functions (Figure A3-1). Figure A3-32 shows the staging routes and staging location for electrical components, which is Staging Area 4.

The distance from the primary storage area to Staging Area 1 is approximately 525 ft., following the green path shown in Figure A3-1 (Reference 9). Initially, the primary storage area will be outside the PA. Prior to FLEX implementation, the security fence will be moved and the primary storage area will be within the PA.

The Plant Support Facility and Maintenance Storage Facility (950 and 952 in Figure A3-1) could be potential sources of debris due to both seismic and high wind events. All generated debris that impacts the FLEX strategy will be cleared with a Pettibone forklift or similar purposed vehicle.

The distance from the secondary storage area to Staging Area 1 is approximately 1,550 ft., following the blue path shown in Figure A3-1 (Reference 9). This location is within the PA. The Outage Maintenance Facility and the Turbine Building (884 and 400 in Figure A3-1) could be potential sources of debris due to both seismic and high wind events. An alternate path to avoid the Turbine Building would follow the road between the Fuel Building and the Radwaste Building. The distance along this path would be slightly shorter, but security gates would have to be opened. All generated debris that impacts the FLEX strategy will be cleared with Pettibone forklift or similar purposed vehicle.

All FLEX equipment will be trailer mounted or on wheels for ease of deployment. Vehicles with approximately 16,000lb towing capacity will be used to move the pumps and/or generators as well as the hoses and fittings needed for the connection point.

Core Cooling with Steam Generators Available Strategy Modifications Protection of Connections Identify Strategy including how the equipment will be deployed to the point of use.

Identify modifications Identify how the connection is protected Primary Connection The FLEX Core Cooling Pump will be staged in Staging Area 1 (Figure A3-1). The suction connection on the CST is located on the Plant South side of the CST (approximately 2000 elevation) and is 70 ft. from the staged pump Primary Connection For this strategy to be successful the CST must be modified; the tank is a non-seismic and non-missile protected tank. The tank will need to be seismically qualified and missile protected to credit it for any plant strategies Primary Connection The primary connection point is located in the Auxiliary Building, which is seismically qualified and missile protected. Access is available through the Tendon gallery, which is seismically qualified and protected from a Enclosure to ULNRC-05962 Page 25 of 131

24 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 location. The suction piping will consist entirely of flexible hose.

The discharge connection will be located in the CST valve house, 200 ft. from the staged FLEX Core Cooling Pump. The flexible hose will run from the FLEX Core Cooling Pump to this external discharge connection. About 150 ft. of piping will be run from inside the CST valve house through the piping chase at 1989-6 into Room 1207 in the Auxiliary Building. From Room 1207 the pipe will be run up through a core drilled hole into Room 1330 near the primary connection point. The piping would be stubbed off here with a Storz connector and cap. When required, the final connection to the reducing tee would be made via a flexible spool piece.

Figure A3-4 shows the pipe and hose routing for the primary AFW connection.

(Open Item OI5). The proposed routing also requires that the CST valve house be seismically qualified and confirmed to be missile protected. Callaway Plant is also evaluating installation of a new, seismically qualified and hardened CST that will hold approximately 670,000 gallons of creditable volume. This volume would be sufficient for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of coping.

The reducing tee will be installed into the discharge line of the NSAFWP downstream of ALV0200 and upstream of ALV0198. The connection is located in Room 1330 and will be equipped with a Storz connection.

This connection will be double isolated and new piping will be seismically qualified. This will be the primary connection point and can provide makeup to all four steam generators.

An intermediate run of hard piping will be installed and will run directly into Room 1330 where the NSAFWP discharge pipe ties into the TDAFWP discharge piping and where the primary connection will be located. This intermediate piping will run from the CST valve house to Room 1330 and will terminate on either end with a Storz connection. A short flexible spool piece will connect the intermediate pipe in Room 1330 to the primary connection point.

high wind/missile hazard.

The suction and makeup connections to the CST will be seismically qualified and missile protected. This includes seismically qualifying the CST valve house.

Enclosure to ULNRC-05962 Page 26 of 131

25 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Secondary Connection The FLEX Core Cooling Pump will be staged in Staging Area 1 (Figure A3-1). The suction connection on the CST is located on the Plant South side of the CST (approximately 2000 elevation) and is 70 ft. from the staged pump location. The suction piping will consist entirely of flexible hose.

The discharge connection will be located in the CST valve house, 200 ft. from the staged FLEX Core Cooling Pump. The flexible hose will run from the FLEX Core Cooling Pump to this external discharge connection. About 155 ft. of piping will be run from inside the CST valve house through the piping chase at 1989-6 into Room 1207 in the Auxiliary Building. From Room 1207 the pipe will be run up through a core drilled hole into Room 1326 near the secondary connection point. The piping would be stubbed off here with a Storz connector and cap. When required, the final connection to the reducing tee would be made via a flexible spool piece.

Figure A3-5 shows the pipe and hose routing for the secondary AFW connection.

Secondary Connection For this strategy to be successful the CST must be modified; the tank is a non-seismic and non-missile protected tank. The tank will be seismically qualified and missile protected to credit it for any plant strategies (Open Item OI5). The proposed routing also requires that the CST valve house be seismically qualified and confirmed to be missile protected.

Callaway Plant is also evaluating installation of a new, seismically qualified and hardened CST that will hold approximately 670,000 gallons of creditable volume. This volume would be sufficient for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of coping (Reference 9).

The reducing tee will be installed into the discharge line of the A MDAFWP downstream of ALFV0042 and upstream of ALV0043. The connection is located in Room 1326 and will be equipped with a Storz connection.

This connection will be double isolated and new piping will be seismically qualified. This will be the secondary connection point and can provide makeup to all four steam generators.

An intermediate run of hard piping will be installed and will run directly into Room 1326 where the A MDAFWP is located and where the secondary connection will be located. This intermediate piping will run from the CST valve house to the secondary connection.

Secondary Connection The secondary connection point is located in the Auxiliary Building, which is seismically qualified and missile protected. Access is available through the Tendon gallery which is seismically qualified and protected from a high wind/missile hazard.

The suction and makeup connections to the CST will be seismically qualified and missile protected. This includes seismically qualifying the CST valve house.

Enclosure to ULNRC-05962 Page 27 of 131

26 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 There will be a Storz connection that will be connected with the final spool piece.

Core Cooling with Steam Generators not Available Strategy Modifications Protection of Connections Identify Strategy including how the equipment will be deployed to the point of use.

Identify modifications Identify how the connection is protected Primary Connection The primary strategy for providing adequate cooling during Modes 5 and 6 will take suction from the new RWST connection on the RWST drain line.

The FLEX Core Cooling Pump will be located in Staging Area 2 and will provide discharge through a mix of flexible hose and hard piping. The flexible hose will be run from the FLEX Core Cooling Pump to the Tendon Gallery access hatch. A Storz connector will be available exterior to the Tendon Gallery near the access hatch. The intermediate pipe will run down to an elevation of about 1980 and run along the outer wall of the Tendon Gallery to the Auxiliary Building access door.

Flexible hose will be run from this access door to the base of the installed hard pipe on the Plant South exterior wall of the BIT Room. Flexible hose will connect this pipe to the Storz connector on the fabricated manifold in the A piping penetration room, Room Primary Connection A short run of piping containing two isolation valves will be fabricated and installed on the existing blind flange in the A piping penetration room, Room 1323. This piping will be seismically qualified and supported.

The primary makeup source will be the RWST, which is seismically qualified, but not missile protected. The RWST will be missile protected to credit its use in core cooling with SGs not available strategies (Open Item OI1). A tee will be installed on the RWST drain line with two isolation valves. This piping will be seismically supported and terminate in a Storz connection.

Primary Connection With the exception of the RWST suction connection which is inside the RWST valve house, all of the other connections are located within the Auxiliary Building or Tendon Gallery. Therefore, the connections are protected from all applicable BDBEE scenarios as outlined in NEI 12-06 (Reference 2). Access is available through the Tendon Gallery which is seismically qualified and protected from a high wind/missile hazard.

The suction connection point will be in the RWST valve house, which is seismically qualified and will be modified to be protected from a high wind/missile hazard.

Access is available directly into the RWST valve house.

Enclosure to ULNRC-05962 Page 28 of 131

27 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 1323.

Secondary Connection The secondary strategy for providing adequate cooling during Modes 5 and 6 will take suction from the new RWST connection on the RWST drain line.

The FLEX Core Cooling Pump will be located in Staging Area 2 and will provide discharge through a mix of flexible hose and hard piping. The flexible hose will be run from the FLEX Core Cooling Pump to the Tendon Gallery access hatch. A Storz connector will be available exterior to the Tendon Gallery near the access hatch. The intermediate pipe will run down to an elevation of about 1980 and run along the outer wall of the Tendon Gallery to the Auxiliary Building access door.

Flexible hose will be run from this access door to the Storz connector on the new hard pipe penetration through the Plant South wall of the BIT Room. A short length of hose will connect to this hard pipe from inside the BIT Room and to the Storz connection on the fabricated manifold.

Secondary Connection A short run of piping containing two manual isolation valves will be fabricated to provide the connections in the BIT Room. The piping will be seismically qualified and supported.

The primary makeup source will be the RWST, which is seismically qualified, but not missile protected. The RWST will be missile protected to credit its use in core cooling with SGs not available strategies (Open Item OI1). A tee will be installed on the RWST drain line with two isolation valves. This piping will be seismically supported and terminate in a Storz connection.

Secondary Connection With the exception of the RWST suction connection which is inside the RWST valve house, all of the other connections are located within the Auxiliary Building or Tendon Gallery. Therefore, the connections are protected from all applicable BDBEE scenarios as outlined in NEI 12-06 (Reference 2). Access is available through the Tendon Gallery which is seismically qualified and protected from a high wind/missile hazard.

The suction connection point will be in the RWST valve house, which is seismically qualified and will be modified to be protected from a high wind/missile hazard.

Access is available directly into the RWST valve house.

Notes:

Core cooling strategies are provided for conditions where steam generators are available or where steam generators are not available but a sufficient RCS vent has been established to support core cooling. This assumption is per the guidance of NEI 12-06 FAQ 2012-19. Other configurations are not considered as these occur for short durations that are exempted per NEI 12-06 Table D.

Enclosure to ULNRC-05962 Page 29 of 131

28 February 2013 Maintain Core Cooling & Heat Removal PWR 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 and strategy(ies) utilized to achieve this coping time.

For Phase 3, Callaway Plant will continue the Phase 2 coping strategies with additional assistance provided from offsite equipment/resources. Each of the Phase 3 strategies will utilize common connections to prevent any compatibility issues with offsite equipment. The pathways and areas utilized for Phase 2 deployment and staging will also be used for Phase 3. A list of equipment expected for Phase 3 is provided below in order of prioritization. For this equipment and the FLEX strategies, the specific timing is discussed in Attachment 1A.

In addition to the regional response centers (RRCs), Callaway Plant has established agreements and contracts with local, state, and federal government organizations and suppliers for mutual aid and support. Current procedures are also in place for assisting and interfacing with these offsite resources.

In Phase 3, core cooling is maintained through natural circulation heat removal from the RCS via the steam generators. Heat rejection through the steam generators is maintained via the TDAFWP or the FLEX Core Cooling Pump. Use of a non-condensate grade coolant in the SG cannot be maintained indefinitely. Phase 3 deployment of a unit capable of generating clean coolant for use in the SGs can extend the coping time.

Indefinite coping is successfully established once a transition from SG cooling to residual heat removal (RHR) cooling is established. Phase 3 deployments of the alternate essential service water system for cooling the component cooling water (CCW) system and subsequently the RHR system establishes a portion of this capability. Callaway Plant is currently evaluating installing a new CST with an increased volume. The current coping time with the credited volume of the CST is 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months (Reference 9). Per Reference 9, approximately 660,000 gallons of CST volume is needed for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of coping time. The new CST being evaluated by Callaway Plant would have a minimum creditable volume of at least 670,000 gallons.

A backup to the Phase 2 equipment will be provided from the regional response centers and will allow all Phase 2 functions for coping to continue to be utilized in Phase 3, even when there is a failure of the onsite Phase 2 equipment during the indefinite coping period.

Strategy Safety Function Large Debris Removal Safety Function Support Mobile Water Purification System Core Cooling, RCS Inventory &

Reactivity Mobile Boration Unit Core Cooling, RCS Inventory &

Reactivity Backup to Phase 2 Equipment All Large Generator Core Cooling, SFP Cooling Align UHS to ESW Core Cooling Large Fuel Truck Safety Function Support Details:

Enclosure to ULNRC-05962 Page 30 of 131

29 February 2013 Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 Provide a brief description of procedures, strategies, and guidelines Confirm that procedure/guidance exists or will be developed to support implementation.

FLEX Support Guidelines (FSGs) will be developed to support the Phase 3 strategies described for Core Cooling and Heat Removal.

Identify modifications List modifications Each of the Phase 3 strategies will utilize common connections as described for the Phase 2 connections to prevent any compatibility issues with the offsite equipment.