L-MT-13-017, 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)

ML13066A066
Person / Time
Site:	Monticello
Issue date:	02/28/2013
From:	Schimmel M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-MT-13-017
Download: ML13066A066 (54)

Text

X celEn~ergy28 Xcel~ ergy2807 7Monticello Nuclear Generating Plant W County Road 75 Monticello, MN 55362 February 28, 2013 L-MT-13-017 10 CFR 2.202 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 Renewed Facility Operating License No. DPR-22 Monticello Nuclear Generating Plant's 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-1 2-049)

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 (ADAMS Accession Number ML12054A736).

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 (ADAMs Accession Number ML12229A174).

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

4. NSPM Letter to NRC, "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 29, 2012 (ADAMs Accession Number ML12305A420).

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to all NRC power reactor licensees and holders of construction permits in active or deferred status. Reference 1 was immediately effective and directs Northern

Document Control Desk Page 2 States Power Company, a Minnesota corporation (NSPM), d/b/a Xcel Energy, to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event for the Monticello Nuclear Generating Plant (MNGP).

Specific requirements are outlined in Attachment 2 of Reference 1.

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 Nuclear Energy Institute (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 NSPM 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. Included in the Overall Integrated Plan is a description of how compliance with the requirements described in Attachment 2 of Reference 1 will be achieved. The enclosed Overall Integrated Plan considers the guidance of References 2 and 3.

The enclosed Overall 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 six-month status reports required by Reference 1.

Please contact Jennie Eckholt, Licensing Engineer, at 612-330-5788, if additional information or clarification is required.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

Document Control Desk Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on February 28, 2013.

Mark A. Schimmel Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC Director of Nuclear Reactor Regulation (NRR), USNRC NRR Project Manager, MNGP, USNRC Senior Resident Inspector, MNGP, USNRC

ENCLOSURE Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan (50 pages to follow)

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan I

)grated Plan Elements (PWR & BWR)

Input the hazards applicable to the site; seismic, externalflood, high winds, snow, ice, cold, high temperatures.

Describe how NEI 12-06, Sections 5 - 9, were appliedand the basisjbr why the plantscreened outJbr certain hazards.

The applicable extreme external hazards for Monticello Nuclear Generating Plant (MNGP) are seismic, flooding, high winds, snow, ice and extreme cold, and high temperatures, as outlined below.

Seismic Hazard Assessment:

Consistent with NEI 12-06, Section 5.2, all sites will address seismic hazards. Seismic hazards are applicable to MNGP. The design basis safe shutdown earthquake (SSE) is 0.12g. The associated spectra are included in MNGP Updated Safety Analysis Report (USAR) Section 2, Figure 2.6-5. MNGP screens in for an assessment of the seismic hazard.

Protection of FLEX eauinment from seismic hazard:

l- F .........................

The MNGP plan for storage locations includes use of the existing onsite storage location for the portable equipment required by 10 Code of Federal Regulations (CFR) 50.54(hh), and a new storage location in a building designed to the standard American Society of Civil Engineers (ASCE) 7-10, Minimum Design Loadsfor Buildings and Other Structures, or an evaluated equivalent so that at least one of the storage locations can be expected to withstand the seismic event.

Large portable Diverse and Flexible Coping Strategy (FLEX) equipment will be secured for a seismic event and located so that it is not damaged by other items in a seismic event.

Deployment of FLEX equipment following seismic event:

As described in the USAR, Section 2.5.5, the site is not considered susceptible to liquefaction based on the soil properties and design basis earthquake accelerations. Site borings used in this evaluation, as shown in USAR Figure Page 1 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan r-i'i egrated Plan Elements (PWR & BWR) 2.5-2, cover the area including expected deployment paths.

Deployment pathways of FLEX equipment from the proposed storage locations include the potential for debris due to non-seismically designed structures. Debris removal equipment onsite will be capable of clearing pathways for deployment.

External Flood Hazard Assessment:

External flooding events are applicable to the MNGP, consistent with NEI 12-06 section 6.2. The design bases flood for the MNGP is a Probable Maximum Flood (PMF) on the Mississippi River. The flood is a relatively slow developing event with actions based on forecasts of river water level. Maximum predicted flood water level is 939.2 ft and there are about 12 days available until the peak stage would be reached. The peak flood is a result of the worst combination of hydrometeorological, hydrological, and climatic conditions. Site grade would be flooded for approximately 11 days. MNGP screens in for the external flood hazard.

Site procedures provide for flood protection of all Class II structures and all Class II structures housing Class I equipment.

Protection of FLEX equipment from external flood hazard:

The MNGP plan for storage locations includes use of the existing onsite storage location for the portable equipment required by 10 CFR 50.54(hh) and a new storage location in a building designed to ASCE 7-10, or an evaluated equivalent. The buildings will not be designed to withstand an external flood because the flood hazard has ample warning time to allow deployment of FLEX equipment. The planned new storage building will be located at an elevation that prevents a flood from impacting access to FLEX equipment during the early stages of the flood.

Deployment of FLEX equipment for flooding event:

There is sufficient time for pre-staging the Phase 2 FLEX equipment within the flood-protected area before the design basis flood level is reached. The main access road Page 2 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan ograted Plan Elements (PWR & BWR) to the site will not be available in the design basis flood.

An alternate access road will be constructed as part of the flood preparations. Phase 3 equipment from the Regional Response Center can be requested prior to flooding of the main access road or can be brought in on the temporary access road and set up on site in advance of the PMF.

Plant procedures require the plant to shut down when the river level is predicted to exceed elevation 92 1'. Backup power supplies and pumps will be pre-staged as part of the plant procedures for construction of flood protection features. No other beyond design basis event is assumed to occur with the flood; therefore makeup from the Condensate Storage Tanks (CST) will be available for makeup functions because the CSTs will be located inside the flood protection features. Portable pumps will be moved as necessary to ensure that they are protected from the flood and also have access to a water supply.

High Wind Hazard Assessment:

Tornado and high wind hazards are applicable to the MNGP. As described in NEI 12-06, Section 7.2.1, tornadoes with the capacity to do significant damage are generally considered to be those with winds above 130 mph. Figure 7-2 in NEI 12-06 provides recommended design wind speeds for probability level of 10-6 per year of 184 mph based on the plant location of 450 20' North latitude and 930 50' West longitude. A tornado event has very little warning to enable anticipatory plant response. MNGP screens in for the tornado hazard. The design bases wind speed for Class I and II structures at the MNGP is 100 mph, and design bases tornado loadings are a differential pressure of 2 psi, rotational wind with tangential velocity of 300 mph, and a torsional moment from the wind speed on half of the structure.

Tornado missiles design parameters are provided in USAR Section 12.2.1.8.

Protection of FLEX equipment from high wind hazard:

The MNGP plan for storage locations includes use of the existing onsite storage location for the portable equipment required by 10 CFR 50.54(hh) and a new storage location in a building designed to ASCE 7-10, or an evaluated equivalent building. Large portable FLEX equipment will Page 3 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan K be secured for a high wind event and located so that it is not damaged by other items in a high wind event. The location of the new building will be selected considering the predominant tornado travel paths from the West or West Southwesterly direction. The FLEX equipment will be stored in diverse locations in a North-South arrangement with sufficient separation distance such that "N" sets of equipment are reasonably protected and deployable after a tornado.

Deployment of FLEX equipment following high wind event:

Following a high wind event, deployment of FLEX equipment could be impaired by large debris. Debris removal equipment will be provided to ensure a clear path for deployment of FLEX equipment is available. The debris removal equipment will be protected to ensure it is available after a tornado.

Extreme Cold Hazard Assessment:

Snow, Ice and Extreme Cold hazards are applicable to the MNGP, consistent with NEI 12-06 section 8.2. Per NEI 12-06 Figure 8-2, MNGP is located in the Level 4 region for ice severity and must consider ice storm impacts. The design bases for the MNGP snow load of 50 pounds per square foot of horizontal projected area is used in the design of structures and components exposed to snow (USAR Section 12.2.1.5). This is a ground snow load. Actual snow load on the structure accounts for roof geometry and features of the surrounding area. USAR Section 2.3.3 includes various return periods for ice thicknesses due to freezing rain. USAR Table 2.3-1 identifies an extreme minimum air temperature of-38°F. MINGP screens in for the extreme cold hazard.

Protection of FLEX equipment from extreme cold hazard:

The MNGP plan for storage locations includes use of the existing onsite storage location for the portable equipment required by 10 CFR 50.54(hh) and a new storage location in a building designed to ASCE 7-10, or an evaluated equivalent. Buildings will be provided with adequate heating to prevent equipment from freezing, and will also Page 4 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan F

be designed to withstand required snow and ice loads.

Backup heating is not required if power is lost because the equipment is expected to be deployed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the initiation of the extended loss of AC power (ELAP).

Deployment of FLEX equipment during extreme cold event:

Snow removal is a normal activity at the plant site because of the climate. Reasonable access to FLEX equipment will be maintained throughout a snow event. Ice management will be performed as required such that large FLEX equipment can be moved by vehicles. Debris removal equipment will be able to move through moderate snow accumulations and can also be used to move portable equipment.

The ultimate heat sink will remain available as the discharge canal is maintained open during normal plant operations due to normal warm water discharge.

Procedures will ensure that following plant shutdown, deployment of the FLEX pump suction piping will not be prevented by any minor ice development on the surface of the discharge canal.

Extreme High Temnerature Hazard Assessment:

Extreme igh Temnerature Hazard Assessment:

Consistent with NEI 12-06, Section 9.2, all sites will address high temperatures. USAR Table 2.3-1 identifies an extreme maximum air temperature of 107°F. MNGP screens in for the extreme high temperature hazard.

Protection of FLEX eguipment from extreme high temperature hazard:

The MNGP plan for storage locations includes use of the existing onsite storage location for the portable equipment required by 10 CFR 50.54(hh) and a new storage location in a building designed to ASCE 7-10, or an evaluated equivalent. Buildings will be provided with adequate ventilation to maintain reasonable storage temperatures.

Backup ventilation cooling is not required if power is lost because the equipment is expected to be deployed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the initiation of the ELAP.

Page 5 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan egrated Plan Elements (PWR & BWR)

Deployment of FLEX equipment during extreme high temperature event:

High temperature does not impact the deployment of FLEX equipment. All FLEX equipment will be procured to be suitable for use in peak temperatures for the region.

Provide key assumptions associatedwith implementation of FLEX Strategies:

" Floodand seismic reevaluationspursuantto the 10 CFR 50.54(l) letter of March 12, 2012 are not completed and therefbre not assumed in this submittal.

" Exceptionsfor the site securityplan or other (license/site specific) requirements of 10 CFR may be required.

• Deployment resources are assumed to begin arrivingat hour 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 />.

NEI 12-06 Section 3.2.1 provides assumptions to be used in establishing the baseline coping capability. These assumptions are utilized at MNGP, as follows:

" General Criteria and Baseline Assumptions outlined in NEI 12-06 Section 3.2.1 for BWRs are assumed.

" 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.

" Exceptions for the site security plan or other site specific regulatory requirements may be required.

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

" While procedures are in place to connect the non-safeguards diesel generator (Diesel Generator 13) to Class I E loads (USAR Section 8.4.2.1), the diesel generator is assumed to be unavailable.

• The Condensate Storage Tank (CST) will be used as a water supply if it is available, but the CST is assumed to be unavailable in this scenario.

" The diesel driven fire pump can be lined up to provide river water makeup to the reactor and will be used if available, but is assumed to be unavailable in this scenario.

• The fire protection piping will be used if available, but the Page 6 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan I egrated Plan Elements (PWR & BWR) equipment is assumed to be unavailable in this scenario.

• MAAP analysis and the resulting timelines were used to establish the strategies and necessary actions described in this FLEX Overall Integrated Plan.

• Debris removal equipment will be reasonably protected from the applicable external events such that it is likely to remain functional and deployable.

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

Page 7 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan F

Include a description of any alternativesto the guidance, andprovide a milestone schedule of plannedaction.

NSPM has no deviations to the guidelines in JLD-ISG-2012-01 and NEI 12-06. If deviations are identified, then the deviations will be communicated in future six-month status reports following identification of the issue.

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

Describe in detail in this section the technical basisfbr the time constraintidentified on the sequence of events timeline Attachment 1.

See attachedsequence of events timeline (Attachment 1).

A Sequence of Events Timeline is provided in Attachment I . The technical bases for any time constraints are provided in this Attachment.

Describe how the strategies will be deployed in all modes.

Strategies will be driven by qualified programs and procedures, including administrative controls to ensure that FLEX portable equipment based on the Mode 1 strategy deployment remains possible to deploy in all modes. Specifically, outage arrangements will not prevent FLEX portable equipment deployment.

The second storage location and access paths will be provided in six-month status reports, once they are identified in the design process.

Page 8 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan F

The dates specifically requiredby the order are obligatedor committed dates. Other dates areplanned dates subject to change. Updates will be provided in the periodic (six month) status reports.

The milestone schedule is included in Attachment 2.

Provide a descriptionof the programmaticcontrols equipment protection,storage and deployment and equipment quality. See section 11 in NEI 12-06. Storage of equipment, Section 11.3, will be documented in later sections of this template and need not be included in this section.

See Section 6.0 ofJLD-ISG-2012-01.

MNGP will implement an administrative program in accordance with NEI 12-06. FLEX strategies and their basis will be maintained in an overall program document, which will contain the basis for the ongoing maintenance and testing chosen for the FLEX equipment. This will include Preventative Maintenance (PM) with scope and frequency established considering EPRI guidelines and manufacturer recommendations.

FLEX equipment will be procured as commercial grade equipment unless credited for other functions, in which case the quality attributes of the other functions apply.

Page 9 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan egrated Plan Elements (PWR & BWR)

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.

List trainingplansfor affected organizationsor describe the plan for training development.

Training for FLEX strategies will be established in accordance with NEI 12-06, Section 11.6. The Systematic Approach to Training (SAT) will be followed.

The industry will establish two (2) Regional Response Centers (RRC) to support utilities during beyond design basis events. NSPM has signed a participation contract with the Strategic Alliance for FLEX Emergency Response (SAFER).

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 assemble 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. Equipment arriving first, as established during development of the nuclear site's playbook, will be delivered to the local assemble area 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.

Page 10 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Core Cooling BWR Installed Equipment Phase 1 Provide a generaldescription of the coping strategies using installedequipment including modifications that areproposedto maintain core cooling. Identify methods (RCIC/HPCI/IC)and strategy(ies) utilized to achieve this coping time.

At the initiation of the event operators will enter existing Station Blackout (SBO) Abnormal Operating Procedure (AOP) and appropriate Emergency Operating Procedures (EOP). FLEX Support Guidelines (FSG) will be entered as directed by the AOP and EOPs.

Initial core cooling during the ELAP will be achieved using the Reactor Core Isolation Cooling System (RCIC) and High Pressure Coolant Injection System (HPCI) to provide high pressure makeup to the reactor, with automatic initiation on low-low reactor water level (-47"). For Reference, top of active fuel is at -126". Both RCIC and HPCI automatically trip on high reactor water level (+48"). For reference, the bottom of the steam lines is at +109". The normal suction supply for both RCIC and HPCI are the non-seismically qualified Condensate Storage Tanks (CST) and are the preferred source, if available. If the CSTs are unavailable, which is assumed, suction automatically transfers to the safety-related Suppression Pool (Torus) on a low CST level signal.

The Torus will be used as the heat sink for Safety Relief Valve (SRV) discharge, heat sink for RCIC and HPCI exhaust, and makeup water to the reactor.

After the initial automatic initiation and trip of RCIC and HPCI, RCIC will be used as the primary strategy to provide makeup water to the reactor. RCIC will be manually started and operated to maintain reactor level in the normal range above -47" and below +48". HPCI equipment will be secured to extend the Division II battery life. The RCIC trip signals and isolation signals that could possibly prevent RCIC operation when needed during the ELAP will be overridden in accordance with procedural direction. MAAP analysis will be used to confirm that RCIC maintains adequate net positive suction head (NPSH) during the event, taking into account conditions in the Torus.

Reactor depressurization will be initiated to reduce reactor pressure to approximately 100 psig using SRVs. SRVs will be manually cycled per procedure to control reactor pressure, but it will be maintained high enough such that RCIC can operate.

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 11 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Core Cooling BWR Installed Equipment Phase 1 The Torus performs as the heat sink for core cooling. The Hardened Containment Vent System (HCVS) line for the Torus will be opened to remove heat from the Torus per the EOPs based on the pressure suppression pressure limit (a range of 17 to 33 psig, depending on Torus level). Based on MAAP analysis, this is expected to be approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after the initiation of the event, and will be confirmed by analysis. If the completed analysis results in a change in strategy, this will be provided in a six-month status report.

Load shedding will be performed on the Division I and Division II station batteries to extend the time station batteries can be used to operate equipment and instruments used to provide core cooling. RCIC operates using the Division I station batteries. Instruments, SRVs, and the HCVS will be operated using Division II station batteries. Additional discussion of the load shedding strategy is provided in the section for Safety Functions Support - BWR Installed Equipment Phase 1.

Nitrogen gas requirements for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are expected to be supplied by the installed capacity of the Alternate Nitrogen Supply System, and will be confirmed by analysis, so no changeout of bottles is required during Phase 1. If the completed analysis results in a change in strategy, this will be provided in a six-month status report.

The applicable FLEX portable equipment, such as the diesel-driven pump or generator, will be staged as soon as possible during Phase 1.

tonjtrm tnatproceaureigutaanceexists or win ve aeveiopea to support implementation.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, Electric Power Research Institute (EPRI) and Nuclear Energy Institute (NEI) 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.

List modifications.

None.

Page 12 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Core Cooling BWR Installed Equipment Phase 1 List instrumentationcreditedfor this coping evaluation.

Containment Essential Safety Function Instrumentation Drywell Pressure (PT-725 IA,B) Containment integrity Drywell Air Temperature (TE- Containment integrity 4247A/B/C/D/E/F/G/H)

Torus Water Temperature (TE-4073A Containment integrity through 4080A (Division I) and TE-4073B through 4080B (Division II))

Torus Water Level (LT-7338A,B) Containment integrity Reactor Vessel Essential Safety Function Instrumentation RPV Level - (LT-2-3-85A/B, LT-2 Reactor vessel 112A/B, LT-2-3-61) inventory and core heat removal RPV Pressure (PT-6-53A/B) Reactor vessel pressure boundary and pressure control Notes:

Drywell Air Temperature Instruments TE-4247A/B/C/D/E/F/G/H are not DC powered, but will be able to be read from the Main Control Room using a hand held device.

Division I and II instruments are both listed in the Key Reactor Parameters table above, but Division I instrumentation will be load shed as part of the deep load shed. See a further discussion on this topic in the Safety Function Support Section.

Page 13 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall 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 proposedto maintain core cooling. Identify methods (RCIC/HPCI/IC)and strategy(ies) utilized to achieve this coping time.

In summary, the strategy for Phase 2 Core Cooling will rely on RCIC and the Torus with venting through the HCVS for as long as possible. Once RCIC operation is no longer possible, the reactor will be fully depressurized using SRVs, and core cooling makeup will be provided by a FLEX portable diesel driven pump. DC powered equipment will be supported by a FLEX portable diesel-driven generator. Details of this strategy are outlined below.

A FLEX portable diesel driven pump will be used during Phase 2 to supply water from the discharge canal that empties to the Mississippi River in all events except the beyond design basis flooding event. The Mississippi River is the ultimate makeup water source, and will be available in all scenarios. The FLEX portable pump will be deployed near the discharge canal and take suction directly from the canal, with a strainer installed at the suction to prevent large debris from entering the pump. Water in the canal is less likely to have large debris because the water has already passed through plant equipment. For the flood hazard, the plant will be shutdown. The discharge canal will be flooded therefore the FLEX portable pump will be deployed inside the berm near the intake structure, and take suction directly from the river outside the berm. It will rely on its suction strainer to prevent large debris from entering the pump. The use of raw water is acceptable because the water level is maintained above the top of the fuel throughout the ELAP so cooling of the fuel does not rely solely on flow up from the bottom of the fuel assembly.

The FLEX pump will discharge through a hose into a connection point in the Division I RHR Service Water (RHRSW) piping in the Reactor Building. From this point, the water will utilize the seismically qualified cross tie connection between RHR and RHRSW to provide makeup water to the Reactor via RHR Low Pressure Coolant Injection (LPCI) lines. An alternate connection point for the makeup supply for LPCI will be in the Division I RHR pump discharge piping. The portable pump and temporary connection will be staged and available for use no later than eight hours after the initiation of the event. Valves required to align this injection path are all accessible and can be manually operated. The RHR to RHRSW cross tie valves are accessible via a dedicated, labeled ladder.

In Phase 2, a FLEX portable diesel generator is used to provide power to 250 VDC and 125 VDC system battery chargers, to maintain sufficient battery power to maintain the Phase I coping strategy. This deployment will occur no later than eight hours after event initiation. The FLEX portable diesel generator will use a primary connection point to a 480V load center, with an alternate connection point available at the battery chargers themselves.

Page 14 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 2 tonjirm thatproceaure/guiaanceexists or will be aevelopea to support implementation.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, EPRI and NEI 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.

List modifications.

The following modifications are planned:

Add connection points to connect 480 V portable diesel generators to the 480 V load centers (primary strategy). A breaker will be modified for connection to the 480 V portable diesel generators. The breaker will be racked into the 480 V load center in a spare location or in place of an existing breaker not required for the event.

• Add connection points to connect 480 V portable diesel generators directly to the battery chargers (alternate strategy).

Add new connection point to RHRSW piping in Reactor Building with a fitting for hose connection. This connection provides a path to RHR using the cross tie piping between Division I RHR and RHRSW. The cross tie is intended to provide a path for an inexhaustible source of river water to the reactor core.

List instrumentationcreditedor recoveredfbrthis coping evaluation.

See instrumentation listed in Phase I Core Cooling; note that Division I instruments may be repowered after the FLEX portable diesel generator is connected.

Local instrumentation (e.g., flow meter, pressure gauge) will be available where required to operate the Phase 2 FLEX equipment.

Page 15 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Core Cooling BWR Portable Equipment Phase 2 Storage/ Protection of Equipmnt Des~bestoage/ rotectio pa or schedule to detrnidesoa g reuitmnt See discussion under "Determine Applicable Extreme External Hazard" for storage and protection attributes to address each hazard.

Seismic List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from seismic events.

Fi List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from external flooding.

Severe Stormus with High List how equipment is protected or schedule to protect.

Winds, See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from high winds.

Snow, and Ex e List how equipment is protected or schedule to protect.

Cold See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from snow, ice and extreme cold.

empertures. List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from high temperatures.

Page 16 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan MaJintain Core Cooling BWR Portable Equipment Phase 2 Strategy Modifications Protection of connections Identify Strategy including how Identify modifications. Identify how the connection is the equipment will be deployed to protected the point of use.

Identification of storage None. Connection points will be locations are still in located inside protected (Class development. Debris removal I) areas of the Reactor equipment will be available to Building, Emergency Filtration clear debris from the Trains Building, and Turbine deployment path. Building. Multiple access pathways exist for hose and Deployment of portable cable routing to connection equipment and hoses will be points.

performed using vehicles and trailers from the storage locations.

Hoses and cables will be laid out to connect portable equipment. Hoses may be routed through plant security fences.

Notes:

None.

Page 17 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Mainta.n Core Cooling Provide a generaldescription of the coping strategies usingphase 3 equipment including modifications that are proposedto maintain core cooling. Identify methods (RCIC/HPCI/IC)andstrategy(ies) utilized to achieve this coping time.

The Phase 3 strategy is to use equipment from the Regional Response Center to restore power to one RHR pump and restore cooling water flow on the RHR Service Water (RHRSW) side of one RHR heat exchanger.

The Regional Response Center will provide a 4160 V diesel generator that can be connected to an essential bus to provide power to an RHR pump, and will have additional capacity to supply other necessary loads such as motor operated valves or additional support equipment as discussed in the Safety Function Support - BWR Portable Equipment Phase 3 section. Appropriate actions will be developed to prevent pipe damage due to water hammer prior to an RHR pump being started.

The Regional Response Center will also provide a diesel driven pump to provide the motive force for cooling water on the RHRSW side of the RHR heat exchanger. The HCVS will be closed when cooling through the RHR heat exchanger is sufficient to remove the decay heat.

In addition to the 4160 V diesel generator and diesel driven pump, the Regional Response Center will provide backups for active Phase 2 FLEX equipment that will continue to be used in Phase 3 and will provide consumables such as fuel and compressed gas supplies to support continued operation of equipment in Phase 3.

Alternate connection points are provided in Divisions I and II of RHRSW by removal of valve bonnets in the intake structure and installation of a flange with a hose connection.

Suction strainers will be provided for the pumps supplied by the Regional Response Center. Water in the discharge canal is unlikely to have large debris because it would have passed through the traveling screens and plant equipment. The suction strainers provided with the pumps will ensure that debris is not likely to clog heat exchanger tubes.

DetaIds:

PConfirm thatprocedure/guidanceexists or will be developed to support p ono . roeimplementation.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, EPRI and NEI to develop site specific procedures or guidelines to address the criteria in NEI 12-06.

These procedures and/or guidelines will support the existing svmptom based command and control strateizies.

Page 18 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan I 7 List modifications.

The following modifications are planned:

- Add connection points to connect 4160 V diesel generators to the Division I or Division II 4160 V bus. Two breakers will be modified for connection to the 4160V portable diesel generators, one for each division. The breaker can be racked into the 4160 V load center in a spare location or in place of an existing breaker not required for the event.

- A flange will be fabricated for the alternate connection point in the intake structure to one of the four RHRSW lines.

List instrumentationcreditedor recoveredfor this coping evaluation.

The instrumentation is the same as the Phase 1 Core Cooling. See discussion in previous section on Phase 1.

Local instrumentation (e.g., flow meter, pressure gauge) will be available where required to operate the Phase 3 FLEX equipment ategy 1VIVu S of connections Identify Strategy including how Identify modifications. Identift how the connection is the equipment will be deployed to protected the point of use.

Phase 3 equipment will be No modifications identified for Connection points will be provided by the Regional Phase 3 deployment issues. located inside protected (Class Response Center (RRC) which I) areas of the Reactor will be located in Memphis, Building, Emergency Filtration TN. Trains Building, Intake Structure, and Turbine Building.

Notes:

None.

Page 19 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Containment BWR Installed Equipment Phase 1 Determine,*Baeiecpn apbltihIstalled~ copig moiications notincuding FLEX Hylfdrogen iltuhtrs (Mark Mcontafinments only)

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

The primary strategy for maintaining containment is through the use of the Hardened Containment Vent System (HCVS) to remove heat from the Suppression Pool (Torus).

Torus temperature increases as the result of operation of the SRVs and RCIC exhaust. Heat removal from the Torus in the event of Extended Loss of AC Power (ELAP) will be accomplished by venting from the Torus through the Hardened Containment Vent System (HCVS). Venting of the Torus through HCVS will be initiated manually per the EOPs based on the pressure suppression pressure limit (a range of 17 to 33 psig, depending on Torus level).

The HCVS can be operated using Train B of the alternate nitrogen system and Division II DC power. Operation of the HCVS limits the pressure and temperature reached in the Torus and drywell. Thus, containment integrity is not challenged and remains functional throughout the event.

Phase 1 (i.e., the use of permanently installed plant equipment/features) strategies to maintain containment will be relied upon throughout the duration of the event. Continued operation of the permanently installed plant equipment and features is supported in Phase 2 and 3 by supplemental electrical power and nitrogen gas.

DC battery life to support SRV, HCVS, and associated instrumentation will be extended as discussed in the Maintain Core Cooling - BWR Installed Equipment Phase 1 section.

Confirm thatprocedure/guidanceexists or will be developed to support implementation.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, EPRI and NEI 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.

List modifications.

Modifications associated with the HCVS are addressed in response to NRC Order EA-12-050.

Page 20 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Containment BWR Installed Equipment Phase 1 List instrumentationcreditedfor this coping evaluation.

Containment Essential Instrumentation Safety Function Drywell Pressure (PT-725 1A,B) Containment integrity Drywell Air Temperature (TE- Containment integrity 4247A/B/C/D/E/F/G/H)

Torus Water Temperature (TE-4073A Containment integrity through 4080A (Division I) and TE-4073B through 4080B (Division II)

Torus Water Level (LT-7338A, B) Containment integrity HCVS Rad Monitor (RE/RM-4544) HCVS effluent radioactivity HCVS system valve position indication HCVS operability (Component No. AO-4539, AO-4540) iNores:

Drywell Air Temperature Instruments TE-4247A/B/C/D/E/F/G/H are not DC powered, but will be read from the Main Control Room using a hand held device.

Division I and II instruments are both listed in the Key Reactor Parameters table above, but Division I instrumentation will be load shed as part of the deep load shed. See further discussion in the Safety Function Support Section.

Page 21 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Containment BWR Portable Equipment Phase 2 Provide a generaldescription of the coping strategies using on-site portable equipment including modifications that areproposedto maintain containment. Identify methods (containmentvent or alternative/

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

The Phase 2 strategy to maintain containment uses Torus venting through the HCVS to maintain drywell and Torus temperatures and pressures within allowable limits. This is a continuation of the Phase 1 strategy, with the addition of the portable diesel-driven generator to support DC electrical system functions as discussed in the Maintain Core Cooling - BWR Portable Equipment Phase 2 section.

The HCVS system is powered from the Division II 250 VDC system. As described in the Maintain Core Cooling - BWR Portable Equipment Phase 2 section, a FLEX portable diesel generator will be deployed to provide power to 250 VDC and 125 VDC system battery chargers, to maintain sufficient battery power to operate the HCVS nitrogen supply solenoids.

Confirm that procedure/guidanceexists or will be developed to support implementation.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, EPRI and NEI 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.

List modifications.

Modifications associated with the HCVS are addressed in response to NRC Order EA-12-050.

List instrumentationcreditedor recoveredfor this coping evaluation.See instrumentation listed in the Phase 1 Maintain Containment section; note that Division I instruments may be repowered after the FLEX portable diesel generator is connected.

Local instrumentation (e.g., flow meter, pressure gauge) will be available where required to operate the Phase 2 FLEX equipment.

Page 22 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Containment BWR Portable Equipment Phase 2 List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from seismic events.

List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from external flooding.

List how equipment is protectedor schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from high winds.

List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from snow, ice and extreme cold.

List how equipment is protectedor schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from high temperatures.

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

the point of use.

See discussion in Phase 2 of Core See discussion in Phase 2 of Core See discussion in Phase 2 of Core Cooling. Cooling. Cooling.

Notes:

None.

Page 23 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposedto maintain containment. Identify methods (containmentvent or alternative/ Hydrogen Igniters) and strategy(ies) utilized to achieve this coping time.

No additional equipment is needed beyond what is described in Phase 2. See the Maintain Core Cooling - BWR Portable Equipment Phase 3 section for discussion of Phase 3 strategies for decay heat removal.

konjirm mat proceaure/gutaanceexists or win ye aevetopea to support implementation.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, EPRI and NEI 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.

List modifications.

Modifications associated with the HCVS are addressed in response to NRC Order EA-12-050.

List instrumentationcreditedor recoveredfor this coping evaluation.

The instrumentation is the same as the Phase 1 Maintain Containment.

See discussion in previous section on Phase 1.

Local instrumentation (e.g., flow meter, pressure gauge) will be available where required to operate the Phase 3 FLEX equipment obtained from the RRC.

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

See discussion in Phase 3 of Core See discussion in Phase 3 of Core See discussion in Phase 3 of Core Cooling. Cooling. Cooling.

Page 24 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Page 25 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Spent Fuel Pool Cooling BWR Installed Equipment Phase 1 Providea generaldescription of the coping strategies using installedequipment including modifications that areproposed to maintainspentfuel pool cooling. Identifi' methods (makeup with portable injection source)andstrategy(ies) utilized to achieve this coping time The only Phase 1 action is to monitor the Spent Fuel Pool level. The following paragraphs provide justification for the Phase 1 action.

The emergency heat load assumes a full core discharge is required 30 days following startup from the last refueling discharge. The full core discharge fills the last 484 spaces, with the full core discharge complete 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> after shutdown. In this scenario, there is no fuel in the core, therefore the entire site focus would be on maintaining cooling in the Spent Fuel Pool. Under this condition, the Spent Fuel Pool will reach a boiling temperature no earlier than 8.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and have a maximum evaporation rate of 53 gpm after bulk boiling commences. The Spent Fuel Pool has 7,769 gallons per foot of depth. Once boiling begins, Spent Fuel Pool level would drop less than two feet in four hours. Four hours is adequate to stage a FLEX portable pump to inject water into the Spent Fuel Pool. Therefore, assuming event initiation under these conditions, no actions are required for Spent Fuel Pool cooling or makeup during Phase 1.

The normal heat load for the Spent Fuel Pool is 5.55 x 106 Btu/hr (USAR Section 10.2.2.3).

Conservatively assuming that the reactor is at 100% rated power after the discharge is completed, the time to boil for the Spent Fuel Pool after AC power is lost would be no earlier than 36.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, and the evaporation rate would be 11.9 gpm (715 gal/hr), based on scaling the time to boil and evaporation rate of the emergency heat load with the normal heat load. The Spent Fuel Pool has 7,769 gallons per foot of depth. Once boiling begins, the Spent Fuel Pool level would drop by less than two feet in twenty hours. The FLEX portable pump staged for providing water to the reactor to maintain core cooling will be shown to have the capacity to maintain core cooling and maintain Spent Fuel Pool level. Assuming event initiation under normal operating conditions, no actions are required for Spent Fuel Pool cooling or makeup during Phase 1.

As the spent fuel pool temperature increases, additional moisture will enter the atmosphere in the reactor building The roof vent on the Spent Fuel Pool floor and the reactor building railroad doors will be able to be opened to allow venting of the area.

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 26 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Confirm thatprocedure/guidanceexists or will be developed to support implementation.

Procedures will be revised to include Spent Fuel Pool level monitoring, consistent with the Order EA- 12-051.

Spent Fuel Pool level instrumentation will be provided in accordance with EA- 12-051 and associated guidance.

List instrumentationcredited or recoveredfor this coping evaluation.

Spent Fuel Pool level instrumentation will be provided in accordance with EA- 12-051 and associated guidance.

Notes:

None.

Page 27 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Spent Fuel Pool Coong BWR Portable Equipment Phase 2 Provide a generaldescription of the coping strategies using on-siteportable equipment including modifications that areproposedto maintain spentJuelpool cooling. Identify methods (makeup with portable injection source) and strategy(ies) utilized to achieve this coping time.

In Phase 2, the Spent Fuel Pool level monitoring will continue under all scenarios and modes, as long as there is fuel in the pool.

For the emergency heat load case, the full core has been moved to the Spent Fuel Pool. There is no need to meet core cooling or containment functions. Therefore, the portable diesel-driven FLEX pump staged as described in the Maintain Core Cooling - BWR Portable Equipment Phase 2 section would be relied upon to provide makeup to the Spent Fuel Pool to maintain Spent Fuel Pool Cooling. The FLEX pump could provide makeup either via RHR spent fuel pool cooling piping or via hoses that would be staged directly into the pool.

For the normal heat load case, the event is assumed to occur with the reactor at 100% rated power, and the Phase 2 actions will be to pre-stage hoses for makeup, and open the roof vent. As noted in the Maintain Spent Fuel Pool Cooling - BWR Installed Equipment Phase 1 section, the pool level would drop by less than two feet in no less than 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> (36.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> to boiling plus 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to drop less than two feet). Therefore, makeup is not necessary for the spent fuel pool in Phase 2.

Schedule:

I support implementation.

Procedures will be revised to include Spent Fuel Pool level monitoring.

1de Ufify mdfc io List modifications.

Spent Fuel Pool level instrumentation will be provided in accordance with EA- 12-051 and associated guidance.

List instrumentationcreditedor recoveredfor this coping evaluation.

Spent Fuel Pool level instrumentation will be provided in accordance with EA- 12-051 and associated guidance.

Page 28 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Maintain Spent Fuel Pool Cooling BWR Portable Equipment Phase 2 List now equipment is protecteaor scneauie to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from seismic events.

List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from external flooding.

List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from high winds.

List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from snow, ice and extreme cold.

List how equipment is protected or schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from high temperatures.

strategy lvlocutications rrotecton ot connections Identify Strategy including how the Identify modifications. Identify how the connection equipment will be deployed to the point is protected of use.

See discussion in Phase 2 of Core See discussion in Phase 2 of Core See discussion in Phase 2 Cooling. Cooling. of Core Cooling.

Page 29 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan M*aintain Sp ent Fuel Pool Cooling BWR Portable Equipment Phase 2 Notes:

None.

Page 30 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan rroviae a generai aescriptton oj me coping strategies using pnase o equipment inciuamng moaticationsmat areproposedto maintainspent fuel pool cooling. Identify methods (makeup with portable injection source) and strategy(ies) utilized to achieve this coping time.

For Phase 3, the Regional Response Center will provide a diesel driven pump that will be used to backup the FLEX pump, or will be used as the primary pump for makeup water to the Spent Fuel Pool. The 4160 V diesel generator provided by the Regional Response Center will be used to provide power to the Spent Fuel Pool level instruments that will be installed per NRC Order EA 051.

Confirm that procedure/guidanceexists or will be developed to support implementation.

Procedures will be revised to include Spent Fuel Pool level monitoring.

List modifications.

Spent Fuel Pool level instrumentation will be provided in accordance with EA- 12-051 and associated guidance.

List instrumentationcreditedor recoveredfor this coping evaluation.

Spent Fuel Pool level instrumentation will be provided in accordance with EA- 12-051 and associated guidance.

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

of use.

See discussion in Phase 3 of Core See discussion in Phase 3 of Core See discussion in Phase 3 Cooling. Cooling. of Core Cooling.

Page 31 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan r"oyes:

Strategies used in Phase 2 to maintain the water inventory in the Spent Fuel Pool can be used indefinitely.

Page 32 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Provide a general description of the coping strategies using installed equipment including station modifications that are proposed to maintain and/or support safety functions. Identify methods and strategy(ies) utilized to achieve coping times.

Safety functions support can include DC power, ventilation, lighting, air/gas supplies for operation of valves, communication equipment, and fuel. Each of these supports is discussed below relative to the Phase 1 coping time.

DC Power DC power is supplied to RCIC, SRVs, Hardened Containment Vent System (HCVS), critical instrumentation, and emergency lighting.

DC power is provided by two divisions of batteries and each division includes 125 VDC and 250 VDC sources. Battery life will be extended through deep load shedding on each battery. A high-level, preliminary summary of the major loads to remain and examples of those to be shed are provided below.

Battery Major Loads to Remain Examples of Loads to be Shed Powered Division 1 125 RCIC Controls Emergency Lighting VDC (#11) Secondary-Side Panels/ Benchboards Division I power supply to A, B, C, D SRVs Emergency Diesel Generator (EDG) Control Panels 4KV Switchgear Controls Division 1 250 RCIC Valves, Support Pumps, Division I SRV solenoids to E, F, G, H SRVs VDC (#13) AC Controls (Y-71 Inverter) Outboard Isolation Valves Non-RCIC Y-71 Inverter Loads Division 11 125 Essential Instrumentation HPCI Controls VDC (#12) (Panels) Secondary-Side Panels/ Benchboards Division II SRV solenoids to EDG Control Panels A, B, C, D SRVs 4KV Switchgear Controls Division I1 250 HCVS HPCI VDC (#16) Division II SRV solenoids to Non-Essential Y-81 Inverter Loads E, F, G, H SRVs Essential Instrumentation With this deep load shedding strategy, it is expected that the station batteries can be extended 3 Coping modifications consist of modifications installed to increase initial coping time, i.e. generators to preserve vital instruments or increase operating time on battery powered equipment.

Page 33 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Safety Functions Support BWR Installed Equipment Phase 1 through Phase 1 and do not require portable supplemental charging before eight hours for the most limiting battery. Additional formal analysis will be performed to support this. If analysis results require a change in strategy, that change will be communicated in a six-month status report. This approach will reduce critical instrument diversity as only Division II of essential instrumentation will remain powered after load shedding.

Nitrogen Supply for Pneumatic Valves The alternate nitrogen system is expected to have the capacity to provide nitrogen to the inboard Main Steam Isolation Valves (MSIV), T-ring seals on the containment purge and vent valves, SRVs, and the HCVS. HCVS usage includes breaking the rupture disc and actuation of air-operated valves. The SRVs and HCVS use the alternate nitrogen gas supply for valve actuation. Additional formal analysis of the nitrogen supply will be performed to assure that it is adequate. If changes to the Phase 1 strategy are required as a result of the analysis, they will be provided in a six-month status report.

MCR Environmental Conditions The primary strategy for maintaining the environment of the Main Control Room (MCR) during Phase I is to open doors. The MCR temperature is not expected to exceed 11 0°F within eight hours of the event.

RCIC Room Environmental Conditions The primary strategy for maintaining the environment of the RCIC Room during Phase 1 is to open doors. The existing SBO procedure directs operators to open room doors and panel doors supporting RCIC functions to promote heat removal.

RCIC room temperatures are not expected to exceed the equipment limitations during Phase 1.

Additional formal analysis of the RCIC room will be performed to assure that these areas remain accessible and temperatures are within the equipment functional limitations. If changes to the Phase 1 strategy are required as a result of the analysis, they will be provided in a six-month status report.

Torus Room Environmental Conditions The primary strategy for maintaining the environment of the Torus Room during Phase I is to open doors. Torus area room temperatures are not expected to exceed the equipment limitations during Phase 1. Additional formal analysis of the Torus room will be performed to assure that temperatures are within the equipment functional limitations. If changes to the Phase 1 strategy are required as a result of the analysis, they will be provided in a six-month status report. Other than opening the doors as mentioned above, personnel access to the Torus area during Phase 1 is not required.

Battery Rooms Environmental Conditions The primary strategy for maintaining the environment of the Battery Rooms during Phase 1 is to Page 34 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Safety Functions Support BWR Installed Equipment Phase 1 open doors. Battery room temperatures and hydrogen levels are not expected to exceed the equipment limitations during Phase 1. Hydrogen generation is only a concern when batteries are charging, and therefore hydrogen generation will not occur during Phase 1. Additional formal analysis of the battery rooms will be performed to assure that these areas remain accessible and temperatures are within the equipment functional limitations. If changes to the Phase 1 strategy are required as a result of the analysis, they will be provided in a six-month status report.

RHR Rooms Environmental Conditions The primary strategy for maintaining the environment of the RHR Rooms during Phase 1 is to open doors. RHR room temperatures are not expected to exceed the equipment limitations during Phase 1.

Additional formal analysis of the RHR room will be performed to assure that these areas remain accessible and temperatures are within the equipment functional limitations. If changes to the Phase 1 strategy are required as a result of the analysis they will be provided in a six-month status report.

Personnel access to the RHR room during Phase 1 is not required.

Ventilation No forced ventilation is expected to be required during Phase 1 as described above for each area.

Plant doors may be opened as necessary to provide additional ventilation.

Li2htin2 Lighting is required for operator actions and access in the plant to implement actions associated with the SBO procedure. Emergency lighting is provided by local battery-powered emergency lighting and the lighting is available for at least eight hours.

Communications A Communications Assessment was performed as a result of the information requested for NTTF Recommendation 9.3 in the March 12, 2012 NRC's 10 CFR 50.54(f) letter. This Communications Assessment was provided by NSPM to the NRC in a letter dated October 29, 2012, and supplemented on February 21, 2013. NSPM will implement recommendations from the Communications Assessment in coordination with development of FLEX mitigating strategies four months prior to the beginning of the MNGP R27 refueling outage or December 31, 2016, whichever comes first.

Diesel Fuel No portable equipment is used in Phase 1; therefore no refueling is needed.

Page 35 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan ed Equipment.

t-unlrlrm inut pruccure/g-umurIIce exISts ur w Ve ULVCL-oPeU [a support implementation.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, EPRI and NEI 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. Existing procedures will be reviewed with the industry generic FSGs and modified as appropriate.

List modifications and describe how they support coping time.

Necessary local battery-powered emergency lighting will be modified to use light emitting diode (LED) bulbs to extend the emergency lighting capability to beyond eight hours.

List instrumentationcreditedfor this coping evaluationphase.

There is no instrumentation.

Notes:

None.

Page 36 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 Provide a generaldescription of the coping strategies using on-site portable equipment includingstation modifications that are proposedto maintainand/or supportsafety Junctions. Identify methods and strategy(ies) utilized to achieve coping times.

Portable equipment in Phase 2 is required to support continued strategies from Phase 1 and includes DC power, ventilation, lighting, air/gas supplies for operation of valves, communication equipment, and fuel. These supports are discussed below relative to the Phase 2 coping time.

DC Power As discussed in the portable equipment section of Phase 2 for core cooling, a 480 V FLEX portable diesel generator will be connected to recharge the batteries and provide continuous DC power for RCIC operation, SRV operation, Hardened Containment Vent System operation, and critical instrumentation. Depending on conditions, loads shed in Phase 1 will be restored as needed when the FLEX portable diesel generator is supplying the power.

Nitro2en Supply for Pneumatic Valves The Alternate Nitrogen Supply System will continue to supply nitrogen gas for SRVs and Hardened Containment Vent System valve actuation. In Phase 2, the nitrogen bottles will be changed out with replacement bottles, if required. The system design allows for replacement of nitrogen bottles without interruption to the nitrogen supply. It is expected that there are sufficient quantities of nitrogen stored on site to supply alternate nitrogen gas system usage for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Additional formal analysis of the nitrogen quantities required for Phase 1 and 2 operations will be performed to assure that on site quantities are sufficient for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If changes are required to the Phase 2 strategy as a result of the analysis, they will be provided in a six-month status report.

MCR Environmental Conditions In Phase 2, supplemental ventilation will be provided for the operators in the Main Control Room using portable ducting and fans for air circulation as necessary to maintain a temperature below 110 F. Portable fans will be powered by the FLEX portable diesel generator. Additional formal analysis will be performed to determine the timing and scope of the supplemental cooling, or heating required, and the results of this analysis will be provided in a six-month status report.

RCIC Room Environmental Conditions To maintain equipment qualification, the RCIC room is provided with supplemental ventilation using portable ducting and fans to lower the room temperature, if required. The RCIC room is open to a large area above. Natural convection will result in cooler air falling to the RCIC room, and warmer air rising to the space above. Portable fans will be powered by the FLEX portable diesel generator. Additional formal analysis will be performed to determine the timing and scope of the supplemental cooling required, and the results of this analysis will be provided in a six-month status report.

Page 37 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 Torus Room Environmental Conditions The Torus room temperature is not expected to exceed 160'F. Additional formal analysis will be performed to confirm the temperature does not result in equipment failures, and the results of this analysis will be provided in a six-month status report.

Personnel access to the Torus room is not required to accomplish the FLEX strategies in Phase 2.

Battery Rooms Environmental Conditions In Phase 2, the battery room cooling and hydrogen ventilation may be required. Portable fans, if required, will be placed outside the battery room doors to circulate air through the rooms for cooling and to mitigate hydrogen buildup. An increase in room temperature may impact the battery capacity; however, a reduction in the battery capacity in Phase 2 is not significant because the batteries are being recharged by the FLEX diesel generator. Additional formal analysis will be performed to determine the timing and scope of the supplemental cooling or hydrogen ventilation required, and the results of this analysis will be provided in a six-month status report.

RHR Rooms Environmental Conditions Without AC power, RHR rooms will not have any equipment in operation. Therefore, RHR room temperatures are not expected to exceed the equipment limitations during Phase 2. Additional formal analysis of the RHR room will be performed to assure that these areas remain accessible and temperatures are within the equipment functional limitations. If changes are required to the Phase 2 strategy as a result of the analysis, they will be provided in a six-month status report. Personnel access to the RHR room during Phase 2 is required.

Ventilation Ventilation for the RCIC Room, Battery Rooms, and Main Control Room will be provided, if required, from portable fans that are powered from the FLEX diesel generator. Plant doors may be opened as necessary to provide additional ventilation.

Li2htin2 Control Room emergency lighting will be available because the 125 VDC system will have power supplied to the battery chargers from the FLEX diesel generator.

Portable lights will be available for use in areas that require operator access to perform Phase 2 equipment connections. These lights will either be battery powered, or will be capable of being powered by the FLEX diesel generator.

Communications See discussion in the Safety Functions Support - BWR Portable Equipment Phase 1 section for Page 38 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 communication strategies.

Diesel Fuel Portable equipment used in Phase 2 will be equipped with fuel storage tanks sufficient for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation without refueling to minimize actions required to keep equipment running.

Portable fuel containers can be used to refuel equipment, and the fuel stored in day tanks for the Emergency Diesel Generators will be available. At least 3,000 gallons of fuel will be available in the day tanks.

onrytrrn nut pruc'uure/gumuutnc' tt., or witi oe utvetopeu to .upport implementation with a description of the procedure /strategy/ guideline.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, EPRI and NEI 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. Existing procedures will be reviewed with the industry generic FSGs and modified as appropriate.

List modifications necessaryfor phase 2.

None.

List instrumentationcredited or recoveredfor this coping evaluation.

See discussion under Phase 2 for core cooling modifications.

List how equipment is protectedor schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from seismic events.

List how equipment is protectedor schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from external flooding.

Page 39 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Safety Functions Support BWR Portable Equipment Phase 2 List how equipment is protectedor schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from high winds.

List how equipment is protectedor schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from snow, ice and extreme cold.

List how equipment is protectedor schedule to protect.

See discussion under "Determine Applicable Extreme External Hazard" section for protection of equipment from high temperatures.

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

the point of use.

Portable ventilation equipment No modifications are required Portable ventilation does not will be deployed within the to deploy portable ventilation require a hard connection.

Reactor Building and equipment.

Emergency Filtration Train Building.

Nitrogen bottles are deployed No modifications are required The nitrogen connections are when system pressure is to deploy the nitrogen bottles. located in the Class I area of required. Bottles are moved the Turbine Building.

from the FLEX storage areas to the connection point.

Diesel fuel will be gravity No modifications are required The Day Tanks and associated drained, when required, from to drain fuel oil from the Day drain lines are located in Class I the Emergency Diesel Tanks. structures.

Generator Day Tanks to fuel canisters.

Page 40 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Safety Funcicfons Support BWR Portable Equipment Phase 2 Notes:

None.

Page 41 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Safety Functions Support Provide a generaldescription of the coping strategies using phase 3 equipment including modifications that are proposed to maintain and/orsupport safelyJunctions. Identifj methods and strategy(ies) utilized to achieve coping times.

Phase 3 portable equipment will be supplied by the Regional Response Center. The Phase 3 portable equipment requirements will be a 4160 V diesel generator, an additional diesel driven pump comparable in size to those on site, and backups for any active Phase 2 FLEX equipment that will continue to be used in Phase 3. The 4160 V diesel generator will be used to power one division of essential power to support continued core cooling functions. The onsite FLEX diesel driven pump and the additional diesel driven pump will be used to support cooling functions by providing makeup to the reactor, makeup to the Spent Fuel Pool, cooling water to the RHR heat exchanger, and cooling water for necessary room and equipment cooling normally supplied by the Emergency Service Water System.

As part of Phase 3 portable equipment, consumables such as fuel and nitrogen will also be provided.

tonjirm tnatproceaureiguiaanceexists or witi ve aeveiopea to support implementation with a descriptionof the procedure /strategy /guideline.

NSPM will utilize the industry developed guidance from the Boiling Water Reactor Owners Groups, EPRI and NEI 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. Existing procedures will be reviewed with the industry generic FSGs and modified as appropriate.

List modificationsnecessaryfor phase 3.

None.

List instrumentationcreditedor recoveredfor this coping evaluation.

See Phase 3 descriptions for core cooling and spent fuel pool for permanently installed instruments.

Page 42 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan yr'ategy ivioulicanons rrorecuon oi connecuons Identify Strategy including how Identify modifications. Identify how the connection is the equipment will be deployed to protected the point of use.

Installed diesel fuel oil transfer None. Installed pumps and pumps will be used to move connections are located inside fuel from the fuel storage tanks Class I areas.

to portable tanks.

RRC equipment will be used to deliver diesel fuel to the portable diesel-driven equipment.

Notes:

None.

Page 43 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall 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 equipmentm') requirements Two (2) Self- X X X Adequate for core cooling Will follow EPRI template Priming Pumps makeup / spent fuel pool makeup requirements Two (2) Vehicles X Vehicles that can tow the pumps Will follow EPRI template and generators. requirements Two (2) 480VAC x X X 500 kW Will follow EPRI template Diesel Generators Cables - #1 per Phase. requirements Two (2) Flatbed X Means to store and transport Will follow EPRI template Trailers hoses, strainers, cables, and requirements miscellaneous equipment.

Two (2) Monitor X Sized for 250 gpm Will follow EPRI template Spray Nozzles for requirements SFP Spray and required hoses 4 Portable fans X X X X N/A and ducting Front loader X Debris removal and alternate for equipment placement Forklift X Debris removal and alternate for equipment placement (1) Represents quantity to meet "N+ 1" criteria Page 44 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Use and (potential/flexibility)diverse uses Performance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment Two (2) Self- X X X Adequate for core cooling Same as Phase 2 Priming Pumps makeup / spent fuel pool makeup One (1) 4160VAC X X X X 4160 VAC To power RHR, etc.

Diesel Generator One (1) set of X X X N/A Supply as required cables for connecting portable generators One (1) Diesel X X X X N/A Supply as required.

Generator fuel To ensure transfer capability of transfer pump and site fuel to portable equipment hoses Page 45 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Attachment 1 Sequence of Events Timeline Action Elapsed Tim Action ELAP Event Remarks! Applicability item Time Constraint Y/N4 0 Event Starts NA Plant @100% power Per SBO HPCI placed in NA HPCI must be placed in pull-to-lock prior to procedure Pull-to-Lock its second automatic initiation such that it does not start. This is to preserve the Division II 250 VDC battery for other Phase 1 functions, including SRV and Hardened Containment Vent System operation. NA as the action occurs per the SBO procedure.

2 Per SBO RCIC manually NA NA as the action occurs per the SBO procedure initiated to control procedure.

reactor level 3 1 hr ELAP Y In order to ensure that follow-on actions are Determination completed consistent with the timelines made identified, a timely decision must be made that the Station Blackout (SBO) condition is an Extended Loss of AC Power (ELAP).

From event initiation, operations will have one hour to attempt to restart the Emergency Diesel Generators and evaluate site conditions prior to making the determination that the condition is an ELAP and entering appropriate procedures and FLEX strategies. This is a reasonable amount of time to allow operations to execute the initial SBO actions per procedure and make sufficient evaluation to determine an ELAP is likely.

4 Instructions: Provide justification if No or NA is selected in the remark column If yes include technical basis discussion as requires by NEI 12-06 section 3.2.1.7 Page 46 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Action Elapsed Time Action ELAP Event Remarks / Applicability item Time Constraint 4

____ ~~~~~Y/N _ _ _ _ _ _ _ _ _ _ _

4 2 hr DC load shed Y This is a necessary action to ensure safety-(preliminary) complete related battery power can be extended through Phase 1. This will be a deep load shed driven by a new procedure for the Division I and Division 11125 VDC and 250 VDC batteries.

Loads will be shed by manipulating individual circuit breakers at the distribution panels. A specific sequence of loads to shed will be proceduralized based on priority and efficiency of execution. Individual circuits to be shed will be labeled with reflective FLEX labels so they are easy for operators to identify. DC panels are readily accessible and familiar to operators. The time is shown as preliminary as the supporting load-shed analysis is not yet complete. Changes will be provided in a six-month status report.

5 Following Depressurize N Reactor depressurization to approximately Action 4 Reactor using 100 psig will enable continued RCIC SRVs to operation. Reactor depressurization is not approximately 100 time critical. Depressurization is required psig. prior to venting the Torus.

6 6 hr Initiate use of Y The Hardened Containment Vent System Hardened (HCVS) must be opened per the EOPs.

Containment Vent Opening the vent provides a path for heat System removal from the Torus which extends time that the Torus is able to function as a heat sink and makeup water source. The vent is powered by an available battery and supplied with Nitrogen from the Alternate Nitrogen System. Controls for the HCVS are on the Alternate Shutdown System panel outside of the control room but are readily accessible and familiar to operators. HCVS controls will be labeled with reflective FLEX labels so they are easy for operators to identify.

7 6 hr Off-site staffing NA NA because not a time constraint; included resources begin to for reference.

arrive 8 8 hr Batteries are being Y Necessary for continued DC power. Portable (preliminary) repowered using FLEX 480VAC Diesel Generator and portable FLEX necessary deployment equipment will be 480VAC Diesel stored in a protected structure. The time is Generator shown as preliminary as the supporting load-shed analysis is not yet complete. Changes will be provided in a six-month status report.

Page 47 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Actio Ela Ipsed Time Action ELAP Event Rema~rks / Applicability item Time Constraint Y/N 4 9 8 hr Portable diesel N Strategy for core cooling relies on a portable driven FLEX diesel driven FLEX pump in Phase 2. The pumps staged for pump and necessary deployment equipment use will be stored in a protected structure. Pumps will be staged with suction lined up to the discharge canal and discharge hose connections aligned to the RHRSW system or Spent Fuel Pool as necessary.

10 After 8 hr Provide RCIC N Necessary for continued qualification and (preliminary) room cooling operation of RCIC equipment. Portable FLEX fans will be available and powered by either the FLEX 480V generator or other small portable generator and will maintain the room within required limits. The time is shown as preliminary as the supporting analysis is not yet complete. Changes will be provided in a six-month status report.

11 After 8 hr Provide Main N Necessary for continued Main Control Room (preliminary) Control Room habitability. Portable FLEX fans will be cooling available and powered by the FLEX 480 V generator and will maintain the room within required limits. The time is shown as preliminary as the supporting analysis is not yet complete. Changes will be provided in a six-month status report.

12 After 8 hr Provide Battery Y Necessary for continued qualification and (preliminary) Room ventilation operation of batteries and equipment. Portable FLEX fans will be available and powered by the FLEX 480V generator and will maintain the room within required limits. The time is shown as preliminary as the supporting analysis is not yet complete. Changes will be provided in a six-month status report.

13 12 hr For emergency Y For the SFP emergency heat load, provide heat load, provide makeup to the SFP using portable FLEX makeup to SFP pump to at least meet the boil off rate (53 gpm for emergency heat load) 14 After 24 hr Supplement Y Provide additional nitrogen supply to the (preliminary) Alternate Nitrogen Alternate Nitrogen System to support continued SRV and Hardened Containment Vent System operation. Bottles will be staged in accessible areas. The time is shown as preliminary as the supporting analysis is not yet complete. Changes will be provided in a six-month status report.

Page 48 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Action~ Elapsed Time. Action ELAP Event Remarks / AppIcabiUty item Time Constraint 15 After 24 hr Refuel portable Y Phase 2 portable equipment will require equipment refueling no earlier than 24 hrs. All Phase 2 portable equipment will have fuel tanks with a minimum 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capacity. Fuel and fuel containers will be available on site and can be transported by hand.

16 24-72 hr Supplement on-site Y The Regional Response Center equipment equipment with will provide a reliable backup to the on-site equipment from the portable equipment for extended operation. It Regional Response will replenish consumables, and restore power Center to a 4160 V AC bus and restore water make up from the UHS.

Page 49 of 50

Enclosure Monticello Nuclear Generating Plant NRC Order EA-12-049 Overall Integrated Plan Attachment 2 Milestone Schedule The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent six-month status reports.

Original Activity Status Target Daite (Include date changes inthis October 2012 Submit 60 Day status report Complete February 2013 Submit Overall Integrated Complete with this Implementation Plan submittal August 2013 Submit six-month status report January 2014 Commence Engineering Modification Design - Phase 2 & 3 February 2014 Submit six-month status report (TBD) Regional Response Center Operational June 2014 Procure Equipment August 2014 Submit six-month status report August 2014 Commence Installation for Online Modifications - Phase 2 and 3 December 2014 Implement Storage December 2014 Issue Maintenance Procedures February 2015 Implement Training February 2015 Submit six-month status report Four months Submit Staffing Assessment prior to R27 Four months Complete Communication prior to R27 Recommendations April 2015 Issue Procedures updated for FLEX strategies April 2015 Implementation Outage August 2015 Submit Completion Report Page 50 of 50