JAFP-15-0149, Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying License with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

From kanterella
(Redirected from ML15365A593)
Jump to navigation Jump to search
Phase 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying License with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)
ML15365A593
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 12/29/2015
From: Brian Sullivan
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, JAFP-15-0149
Download: ML15365A593 (51)
v • d • e


Text

{{#Wiki_filter:Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-15-0149 December 29, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

James A. FitzPatrick Phase 2 Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109) James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59

Reference:

1.

NRC Order, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, EA-13-109, dated June 6, 2013

2.

NRC Interim Staff Guidance, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, JLD-ISG-2015-01, dated April 2015

3.

NEI document, Industry Guidance for Compliance with NRC Order EA-13-109, NEI 13-02 Revision 1, dated April 2015

4.

Entergy letter, James A. FitzPatrick Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), JAFP-14-0075, dated June 30, 2014

5.

Entergy letter, Notification of Permanent Cessation of Power Operations, JAFP-15-0133, dated November 18, 2015

Dear Sir or Madam:

On June 6, 2013, the Nuclear Regulatory Commission (NRC or Commission) issued order EA-13-109 [Reference 1] to the James A. FitzPatrick Nuclear Power Plant (JAF). The order was immediately effective and directs JAF to have reliable hardened containment vents capable of operation under severe accident conditions. Specific requirements are outlined in the Enclosure of Reference 1.

JAFP-15-0149 Page 2 of 2 Implementation of order EA-13-109 is divided into two phases. The Overall Integrated Plan for Phase 1 was submitted by letter dated June 30, 2014 [Reference 4], pursuant to EA-13-109 Section IV, Condition D.1. The purpose of this letter is to provide the Phase 2 Overall Integrated Plan, pursuant to EA-13-109 Section IV, Condition D.2, and Section 7.1.4 of Reference 3. Reference 1 requires submission of an Overall Integrated Plan for phase 2 requirements by December 31, 2015. The NRC Interim Staff Guidance (ISG) [Reference 2] was issued in April 2015, which endorses industry guidance document NEI 13-02, Revision 1 [Reference 3], with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Phase 2 Overall Integrated Plan. The Phase 2 Overall Integrated Plan documented in the Enclosure is an accurate description of modifications and/or strategies needed to satisfy the requirements of NRC Order EA-13-109; however, Entergy has announced plans to cease power operation at JAF [Reference 5]. JAF is still executing the implementation plan; however, based upon Entergy's plan to permanently shut down JAF, compliance with the Order will be affected. Future six (6)-month status reports will be provided as required by Section IV, Condition D.3, of Reference 1, and pursuant to 7.1.5 of Reference 3. This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. Chris M. Adner, Regulatory Assurance Manager, at (315) 349-6766. I declare under penalty of perjury that the foregoing is true and correct; executed on December 29, 2015. Sincerely, Brian R. Sullivan BRS/CMA/mh

Enclosure:

Phase 2 Overall Integrated Plan for Hardened Containment Vent: EA-13-109 cc: Mr. Douglas Pickett, Senior Project Manager Regional Administrator, NRC Region 1 NRC Resident Inspectors Office Mr. John B. Rhodes, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ENCLOSURE TO JAFP-15-0149 Phase 2 Overall Integrated Plan for Hardened Containment Vent: EA-13-109 (48 Pages)

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 1 of 48 Table of Contents: Introduction Part 1: General Integrated Plan Elements and Assumptions Part 2: Boundary Conditions for Wet Well Vent Part 3: Boundary Conditions for EA-13-109, Option B.2 Part 3.1 Boundary Conditions for SAWA Part 3.1A Boundary Conditions for SAWA/SAWM Part 3.1B Boundary Conditions for SAWA/SADV Part 4: Programmatic Controls, Training, Drills and Maintenance Part 5: Milestones Schedule : HCVS/SAWA Portable Equipment A: Sequence of Events Timeline - HCVS.1.A: Sequence of Events Timeline - SAWA / SAWM.1.B: Sequence of Events Timeline - SADV.1.C: SAWA / SAWM Plant-Specific Datum.1.D: SAWM SAMG Approved Language : Conceptual Sketches : Failure Evaluation Table : References : Changes/Updates to this Overall Integrated Implementation Plan : List of Overall Integrated Plan Open Items

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 2 of 48 Introduction In 1989, the NRC issued Generic Letter 89-16, Installation of a Hardened Wetwell Vent, to all licensees of BWRs with Mark I containments to encourage licensees to voluntarily install a hardened wetwell vent. In response, licensees installed a hardened vent pipe from the suppression pool to some point outside the secondary containment envelope (usually outside the reactor building). Some licensees also installed a hardened vent branch line from the drywell. On March 19, 2013, the Nuclear Regulatory Commission (NRC) Commissioners directed the staff per Staff Requirements Memorandum (SRM) for SECY-12-0157 to require licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050 with a containment venting system designed and installed to remain functional during severe accident conditions." In response, the NRC issued Order EA-13-109, Issuance of Order to Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accidents, June 6, 2013. The Order (EA-13-109) requires that licensees of BWR facilities with Mark I and Mark II containment designs ensure that these facilities have a reliable hardened vent to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits following events that result in the loss of active containment heat removal capability while maintaining the capability to operate under severe accident (SA) conditions resulting from an Extended Loss of AC Power (ELAP). The Order requirements are applied in a phased approach where: Phase 1 involves upgrading the venting capabilities from the containment wetwell to provide reliable, severe accident capable hardened vents to assist in preventing core damage and, if necessary, to provide venting capability during severe accident conditions. (Completed no later than startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first.) Phase 2 involves providing additional protections for severe accident conditions through installation of a reliable, severe accident capable drywell vent system or the development of a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. (Completed no later than startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first.) The NRC provided an acceptable approach for complying with Order EA-13-109 through Interim Staff Guidance (JLD-ISG-2013-02 issued in November 2013 and JLD-ISG-2015-01 issued in April 2015). The ISG endorses the compliance approach presented in NEI 13-02 Revision 0 and 1, Industry Guidance for Compliance with Order EA-13-109, with clarifications. Except in those cases in which a licensee proposes an acceptable alternative method for complying with Order EA-13-109, the NRC staff will use the methods described in the ISGs to evaluate licensee compliance as presented in submittals required in Order EA-13-109. The Order also requires submittal of an overall integrated plan which will provide a description of how the requirements of the Order will be achieved. This document provides the Overall Integrated Plan (OIP) for complying with Order EA-13-109 using the methods described in NEI 13-02 and endorsed by NRC JLD-ISG-2013-02 and JLD-ISG-2015-01. Six month progress reports will be provided consistent with the requirements of Order EA-13-109. The submittals required are: OIP for Phase 1 of EA-13-109 was required to be submitted by Licensees to the NRC by June 30, 2014. The NRC requires periodic (6 month) updates for the Hardened Containment Vent System (HCVS) actions being taken. The first update for Phase 1, was due December 2014, with the second due June 2015.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 3 of 48 OIP for Phase 2 of EA-13-109 is required to be submitted by Licensees to the NRC by December 31, 2015. It is expected the December 2015 six month update for Phase 1 will be combined with the Phase 2 OIP submittal by means of a combined Phase 1 and 2 OIP. Thereafter, the 6 month updates will be for both the Phase 1 and Phase 2 actions until complete, consistent with the requirements of Order EA-13-109. Note: At the Licensees option, the December 2015 six month update for Phase 1 may be independent of the Phase 2 OIP submittal, but will require separate six month updates for Phase 1 and 2 until each phase is in compliance. The Plant venting actions for the EA-13-109, Phase 1 severe accident capable venting scenario can be summarized by the following: The HCVS will be initiated via manual action from either the Main Control Room (MCR) (some plants have a designated Primary Operating Station (POS) that will be treated as the main operating location for this order) or from a Remote Operating Station (ROS) at the appropriate time based on procedural guidance in response to plant conditions from observed or derived symptoms. The vent will utilize Containment Parameters of Pressure and Level from the MCR instrumentation to monitor effectiveness of the venting actions. The vent operation will be monitored by HCVS valve position, temperature, and effluent radiation levels. The HCVS motive force will be monitored and have the capacity to operate for 24 hours with installed equipment. Replenishment of the motive force will be by use of portable equipment once the installed motive force is exhausted. Venting actions will be capable of being maintained for a sustained period of up to 7 days or a shorter time if justified. The Phase 2 actions can be summarized as follows: Utilization of Severe Accident Water Addition (SAWA) to initially inject water into the Reactor Pressure Vessel (RPV) or Drywell. Utilization of Severe Accident Water Management (SAWM) to control injection and Suppression Pool level to ensure the HCVS (Phase 1) wetwell vent (SAWV) will remain functional for the removal of decay heat from containment. Ensure that the decay heat can be removed from the containment for seven (7) days using the HCVS or describe the alternate method(s) to remove decay heat from the containment from the time the HCVS is no longer functional until alternate means of decay heat removal are established that make it unlikely the drywell vent will be required for DW pressure control. The SAWA and SAWM actions will be manually activated and controlled from areas that are accessible during severe accident conditions. Parameters measured should be Drywell pressure, Suppression Pool level, SAWA flowrate and the HCVS parameters listed above. Alternatively SAWA and a Severe Accident Capable Drywell Vent (SADV) strategy may be implemented to meet Phase 2 of Order EA-13-109.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 4 of 48 Part 1: General Integrated Plan Elements and Assumptions Extent to which the guidance, JLD-ISG-2013-02, JLD-ISG-2015-01 and NEI 13-02 (Revision 1), are being followed. Identify any deviations. Include a description of any alternatives to the guidance. A technical justification and basis for the alternative needs to be provided. This will likely require a pre-meeting with the NRC to review the alternative. Ref: JLD-ISG-2013-02, JLD-ISG-2015-01 Compliance will be attained for JAF with no known deviations to the guidelines in JLD-ISG-2013-02, JLD-ISG-2015-01 and NEI 13-02 for each phase as follows: The Hardened Containment Vent System (HCVS) will be comprised of installed and portable equipment and operating guidance: Severe Accident Wetwell Vent (SAWV) - Permanently installed vent from the Suppression Pool to the top of Reactor Building Severe accident Water Addition (SAWA) - A combination of permanently installed and portable equipment to provide a means to add water to the RPV following a severe accident and monitor system and plant conditions. Severe Accident Water Management (SAWM) guidance for controlling the water addition to the RPV for the sustained operating period. (reference attachment 2.1.D) Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first. Currently scheduled for the fall of 2016 Phase 2 (alternate strategy): by the startup from the first refueling outage that begins after June 30, 2017 or June 30, 2019, whichever comes first. Currently scheduled for the fall of 2018 If deviations are identified at a later date, then the deviations will be communicated in a future 6 month update following identification. Site Applicable Extreme External Hazard from NEI 12-06, Section 4.0-9.0 List resultant determination of screened in hazards from the EA-12-049 Compliance. Ref: NEI 13-02 Section 5.2.3 and D.1.2 The following extreme external hazards screen-in for JAF: Seismic, Extreme Cold (includes snow and ice), High Wind, Extreme High Temperature, External Flood The following extreme external hazards screen out for JAF: None.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 5 of 48 Key Site assumptions to implement NEI 13-02 HCVS, Phase 1 and 2 Actions. Provide key assumptions associated with implementation of HCVS Phase 1 and Phase 2 Actions Ref: NEI 13-02, Revision 1, Section 2 NEI 12-06 Revision 0 Mark I/II Generic EA-13-109 Phase 1 and Phase 2 Related Assumptions: Applicable EA-12-049 assumptions: 049-1. Assumed initial plant conditions are as identified in NEI 12-06 section 3.2.1.2 items 1 and 2. 049-2. Assumed initial conditions are as identified in NEI 12-06 section 3.2.1.3 items 1, 2, 4, 5, 6 and 8 049-3. Assumed reactor transient boundary conditions are as identified in NEI 12-06 section 3.2.1.4 items 1, 2, 3 and 4 049-4. No additional events or failures are assumed to occur immediately prior to or during the event, including security events except for failure of RCIC or HPCI. (Reference NEI 12-06 3.2.1.3 item 9) 049-5. At Time=0 the event is initiated and all rods insert and no other event beyond a common site ELAP is occurring at any or all of the units. (NEI 12-06, section 3.2.1.3 item 9 and 3.2.1.4 item 1-4) 049-6. At 60 minutes (time critical at a time greater than 1 hour) an ELAP is declared and actions begin as defined in EA-12-049 compliance 049-7. DC power and distribution can be credited for the duration determined per the EA-12-049 (FLEX) methodology for battery usage (up to 10 hours). This assumption applies to the water addition capability under SAWA/SAWM. The power supply scheme for the HCVS shall be in accordance with EA-13-109 and the applicable guidance. (NEI 12-06, section 3.2.1.3 item 8) 049-8. Deployment resources are assumed to begin arriving at hour 6 and fully staffed by 24 hours 049-9. All activities associated with plant specific EA-12-049 FLEX strategies that are not specific to implementation of the HCVS, including such items as debris removal, communication, notification, SFP level and makeup, security response, opening doors for cooling, and initiating conditions for the event, can be credited as previously evaluated for FLEX. (Refer to assumption 109-02 below for clarity on SAWA)(HCVS-FAQ-11) Applicable EA-13-109 generic assumptions: 109-01. Site response activities associated with EA-13-109 actions are considered to have no access limitations associated with radiological impacts while RPV level is above 2/3 core height (core damage is not expected). This is further addressed in HCVS-FAQ-12 109-02. Portable equipment can supplement the installed equipment after 24 hours provided the portable equipment credited meets the criteria applicable to the HCVS. An example is use of FLEX portable air supply equipment that is credited to recharge air lines for HCVS components after 24 hours. The FLEX portable air supply used must be demonstrated to meet the SA Capable criteria that are defined in NEI 13-02 Section 4.2.4.2 and Appendix D Section D.1.3. This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment needs to be connected and placed in service within 8 hours from the time of the loss of RPV injection. (reference HCVS-FAQ-

12) 109-03. SFP level is maintained with either on-site or off-site resources such that the SFP does not contribute to the analyzed source term (Reference HCVS-FAQ-07).

109-04. Existing containment components design and testing values are governed by existing plant primary containment criteria (e.g., Appendix J) and are not subject to the testing criteria from NEI 13-02 (reference HCVS-FAQ-05 and NEI 13-02 section 6.2.2). 109-05. Classical design basis evaluations and assumptions are not required when assessing the operation of the HCVS. The reason this is not required is that the order postulates an unsuccessful mitigation of an event such that an ELAP progresses to a severe accident with ex-vessel core debris which classical design basis evaluations are intended to

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 6 of 48 prevent. (Reference NEI 13-02 section 2.3.1). 109-06. HCVS manual actions that require minimal operator steps and can be performed in the postulated thermal and radiological environment at the location of the step(s) (e.g., load stripping, control switch manipulation, valving-in nitrogen bottles) are acceptable to obtain HCVS venting dedicated functionality. (reference HCVS-FAQ-01) This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment needs to be connected and placed in service within 8 hours from the time of the loss of RPV injection and will require more than minimal operator action. 109-07. HCVS dedicated equipment is defined as vent process elements that are required for the HCVS to function in an ELAP event that progresses to core melt ex-vessel. (reference HCVS-FAQ-02 and White Paper HCVS-WP-01). This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment is not dedicated to HCVS but shared to support FLEX functions. This is further addressed in HCVS-FAQ-11. 109-08. Use of MAAP Version 4 or higher provides adequate assurance of the plant conditions (e.g., RPV water level, temperatures, etc.) assumed for Order EA-13-109 BDBEE and SA HCVS operation. (reference FLEX MAAP Endorsement ML13190A201) Additional analysis using RELAP5/MOD 3, GOTHIC, PCFLUD, LOCADOSE and SHIELD are acceptable methods for evaluating environmental conditions in areas of the plant provided the specific version utilized is documented in the analysis. MAAP Version 5 was used to develop EPRI Technical Report 3002003301 to support drywell temperature response to SAWA under severe accident conditions. 109-09. NRC Published Accident evaluations (e.g. SOARCA, SECY-12-0157, and NUREG 1465) as related to Order EA-13-109 conditions are acceptable as references. (Reference NEI 13-02 section 8). 109-10. Permanent modifications installed or planned per EA-12-049 are assumed implemented and may be credited for use in EA-13-109 Order response. 109-11. This Overall Integrated Plan is based on Emergency Operating Procedure changes consistent with EPG/SAGs Revision 3 as incorporated per the sites EOP/SAMG procedure change process. This assumption does not apply to Phase 2 SAWM because SAWM is not part of revision 3.(reference to Attachment 2.1.D for SAWM SAMG Changes approved by the BWROG Emergency Procedures Committee) 109-12. Under the postulated scenarios of Order EA-13-109 the Control Room is adequately protected from excessive radiation dose due to its distance and shielding from the reactor (per General Design Criterion (GDC) 19 in 10CFR50 Appendix A) and no further evaluation of its use as the preferred HCVS control location is required provided that the HCVS routing is a sufficient distance away from the MCR or is shielded to minimize impact to the MCR dose. In addition, adequate protective clothing and respiratory protection are available if required to address contamination issues. (reference HCVS-FAQ-01 and HCVS-FAQ-09) 109-13. The suppression pool/wetwell of a BWR Mark I/II containment is considered to be bounded by assuming a saturated environment for the duration of the event response because of the water/steam interactions. 109-14. RPV depressurization is directed by the EPGs in all cases prior to entry into the SAGs. (reference NEI 13-02 Rev 1, §I.1.3) 109-15 The Severe Accident impacts are assumed on one unit only due to the site compliance with NRC Order EA-12-049. However, each BWR Mk I and II under the assumptions of NRC Order EA-13-109 ensure the capability to protect containment exists for each unit. (HCVS-FAQ-1) This is further addressed in HCVS-FAQ-10 Plant Specific HCVS Related Assumptions/Characteristics: None.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 7 of 48 Part 2: Boundary Conditions for Wet Well Vent Provide a sequence of events and identify any time or environmental constraint required for success including the basis for the constraint. HCVS Actions 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, action to open vent valves). HCVS Actions that have an environmental constraint (e.g. actions in areas of High Thermal stress or High Dose areas) should be evaluated per guidance. Describe in detail in this section the technical basis for the constraints identified on the sequence of events timeline attachment. See attached sequence of events timeline (Attachment 2A) Ref: EA-13-109 Section 1.1.1, 1.1.2, 1.1.3 / NEI 13-02 Section 4.2.5, 4.2.6. 6.1.1 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Provide a sequence of events and identify any time or environmental constraint required for success including the basis for the constraint. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Provide Details on the Vent characteristics Provide Details on the Vent characteristics Vent Size and Basis (EA-13-109 Section 1.2.1 / NEI 13-02 Section 4.1.1) What is the plants licensed power? Discuss any plans for possible increases in licensed power (e.g. MUR, EPU). What is the nominal diameter of the vent pipe in inches/ Is the basis determined by venting at containment design pressure, Primary Containment Pressure Limit (PCPL), or some other criteria (e.g. anticipatory venting)? Vent Capacity (EA-13-109 Section 1.2.1 / NEI 13-02 Section 4.1.1) Indicate any exceptions to the 1% decay heat removal criteria, including reasons for the exception. Provide the heat capacity of the suppression pool in terms of time versus pressurization capacity, assuming suppression pool is the injection source. Vent Path and Discharge (EA-13-109 Section 1.1.4, 1.2.2 / NEI 13-02 Section 4.1.3, 4.1.5 and Appendix F/G) Provides a description of Vent path, release path, and impact of vent path on other vent element items. Power and Pneumatic Supply Sources (EA-13-109 Section 1.2.5 & 1.2.6 / NEI 13-02 Section 4.2.3, 2.5, 4.2.2, 4.2.6, 6.1) Provide a discussion of electrical power requirements, including a description of dedicated 24 hour power supply from permanently installed sources. Include a similar discussion as above for the valve motive force requirements. Indicate the area in the plant from where the installed/dedicated power and pneumatic supply sources are coming Indicate the areas where portable equipment will be staged after the 24 hour period, the dose fields in the area, and any shielding that would be necessary in that area. Any shielding that would be provided in those areas

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 8 of 48 Part 2: Boundary Conditions for Wet Well Vent Location of Control Panels (EA-13-109 Section 1.1.1, 1.1.2, 1.1.3, 1.1.4, 1.2.4, 1.2.5 / NEI 13-02 Section 4.1.3, 4.2.2, 4.2.3, 4.2.5, 4.2.6, 6.1.1 and Appendix F/G) Indicate the location of the panels, and the dose fields in the area during severe accidents and any shielding that would be required in the area. This can be a qualitative assessment based on criteria in NEI 13-02. Hydrogen (EA-13-109 Section 1.2.10, 1.2.11, 1.2.12 / NEI 13-02 Section 2.3,2.4, 4.1.1, 4.1.6, 4.1.7, 5.1, & Appendix H) State which approach or combination of approaches the plant will take to address the control of flammable gases, clearly demarcating the segments of vent system to which an approach applies Unintended Cross Flow of Vented Fluids (EA-13-109 Section 1.2.3, 1.2.12 / NEI 13-02 Section 4.1.2, 4.1.4, 4.1.6 and Appendix H) Provide a description to eliminate/minimize unintended cross flow of vented fluids with emphasis on interfacing ventilation systems (e.g. SGTS). What design features are being included to limit leakage through interfacing valves or Appendix J type testing features? Prevention of Inadvertent Actuation (EA-13-109 Section 1.2.7/NEI 13-02 Section 4.2.1) The HCVS shall include means to prevent inadvertent actuation Component Qualifications (EA-13-109 Section 2.1 / NEI 13-02 Section 5.1, 5.3) State qualification criteria based on use of a combination of safety related and augmented quality dependent on the location, function and interconnected system requirements Monitoring of HCVS (Order Elements 1.1.4, 1.2.8, 1.2.9/NEI 13-02 4.1.3, 4.2.2, 4.2.4, and Appendix F/G) Provides a description of instruments used to monitor HCVS operation and effluent. Power for an instrument will require the intrinsically safe equipment installed as part of the power sourcing Component reliable and rugged performance (EA-13-109 Section 2.2 / NEI 13-02 Section 5.2, 5.3) HCVS components including instrumentation should be designed, as a minimum, to meet the seismic design requirements of the plant. Components including instrumentation that are not required to be seismically designed by the design basis of the plant should be designed for reliable and rugged performance that is capable of ensuring HCVS functionality following a seismic event. (reference ISG-JLD-201201 and ISG-JLD-2012-03 for seismic details.) The components including instrumentation external to a seismic category 1 (or equivalent building or enclosure should be designed to meet the external hazards that screen-in for the plant as defined in guidance NEI 12-06 as endorsed by JLD-ISG-12-01 for Order EA-12-049. Use of instruments and supporting components with known operating principles that are supplied by manufacturers with commercial quality assurance programs, such as ISO9001. The procurement specifications shall include the seismic requirements and/or instrument design requirements, and specify the need for commercial design standards and testing under seismic loadings consistent with design basis values at the instrument locations. Demonstration of the seismic reliability of the instrumentation through methods that predict performance by analysis, qualification testing under simulated seismic conditions, a combination of testing and analysis, or the use of experience data. Guidance for these is based on sections 7, 8, 9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, or a substantially similar industrial standard could be used. Demonstration that the instrumentation is substantially similar in design to instrumentation that has been previously tested to seismic loading levels in accordance with the plant design basis at the location where the instrument is to be

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 9 of 48 Part 2: Boundary Conditions for Wet Well Vent installed (g-levels and frequency ranges). Such testing and analysis should be similar to that performed for the plant licensing basis. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 10 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: BDBEE Venting Determine venting capability for BDBEE Venting, such as may be used in an ELAP scenario to mitigate core damage. Ref: EA-13-109 Section 1.1.4 / NEI 13-02 Section 2.2 First 24 Hour Coping Detail Provide a general description of the venting actions for first 24 hours using installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.6 / NEI 13-02 Section 2.5, 4.2.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Greater Than 24 Hour Coping Detail Provide a general description of the venting actions for greater than 24 hours using portable and installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.4, 1.2.8 / NEI 13-02 Section 4.2.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Details: Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. NEI 13-02 §6.1.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Identify modifications: List modifications and describe how they support the HCVS Actions. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Key Venting Parameters: List instrumentation credited for this venting actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order)

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 11 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: BDBEE Venting Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 12 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: Severe Accident Venting Determine venting capability for Severe Accident Venting, such as may be used in an ELAP scenario to mitigate core damage. Ref: EA-13-109 Section 1.2.10 / NEI 13-02 Section 2.3 First 24 Hour Coping Detail Provide a general description of the venting actions for first 24 hours using installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.6 / NEI 13-02 Section 2.5, 4.2.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Details: Provide a general description of the venting actions for greater than 24 hours using portable and installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.4, 1.2.8 / NEI 13-02 Section 4.2.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. First 24 Hour Coping Detail Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Identify modifications: List modifications and describe how they support the HCVS Actions. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Key Venting Parameters: List instrumentation credited for the HCVS Actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order)

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 13 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: Severe Accident Venting Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 14 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: HCVS Support Equipment Functions Determine venting capability support functions needed Ref: EA-13-109 Section 1.2.8, 1.2.9 / NEI 13-02 Section 2.5, 4.2.4, 6.1.2 BDBEE Venting Provide a general description of the BDBEE Venting actions support functions. Identify methods and strategy(ies) utilized to achieve venting results. Ref: EA-13-109 Section 1.2.9 / NEI 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Severe Accident Venting Provide a general description of the Severe Accident Venting actions support functions. Identify methods and strategy(ies) utilized to achieve venting results. Ref: EA-13-109 Section 1.2.8, 1.2.9 / NEI 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Details Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Identify modifications: List modifications and describe how they support the HCVS Actions. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Key Support Equipment Parameters: List instrumentation credited for the support equipment utilized in the venting operation. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order) Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 15 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: HCVS Support Equipment Functions Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 16 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: HCVS Venting Portable Equipment Deployment Provide a general description of the venting actions using portable equipment including modifications that are proposed to maintain and/or support safety functions. Ref: EA-13-109 Section 3.1 / NEI 13-02 Section 6.1.2, D.1.3.1 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Details: Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. HCVS Actions Modifications Protection of connections Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 17 of 48 Part 3: Boundary Conditions for EA-13-109, Option B.2 General: Licensees that use Option B.1 of EA-13-109 (SA Capable DW Vent without SAWA) must develop their own OIP. This template does not provide guidance for that option. Licensees using Option B.2 of EA-13-109 (SAWA and SAWM or 545°F SADW Vent (SADV) with SAWA) may use this template for their OIP submittal. Both SAWM and SADV require the use of SAWA and may not be done independently. The HCVS actions under Part 2 apply to all of the following: This Part is divided into the following sections: 3.1: Severe Accident Water Addition (SAWA) 3.1.A: Severe Accident Water Management (SAWM) 3.1.B: Severe Accident DW Vent (545 deg F) Provide a sequence of events and identify any time constraint required for success including the basis for the time constraint. SAWA and SAWM or SADV Actions supporting SA conditions 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). Actions already identified under the HCVS part of this template need not be repeated here. The time to establish the water addition capability into the RPV or DW should be less than 8 hours from the onset of the loss of all injection sources. Electrical generators satisfying the requirements of EA-12-049 may be credited for powering components and instrumentation needed to establish a flow path. Time Sensitive Actions (TSAs) for the purpose of SAWA are those actions needed to transport, connect and start portable equipment needed to provide SAWA flow or provide power to SAWA components in the flow path between the connection point and the RPV or drywell. Actions needed to establish power to SAWA instrumentation should also be included as TSAs. Ref: NEI 13-02 Section 6.1.1.7.4.1, I.1.4, I.1.5 The operation of the HCVS using SAWA and SAWM/SADV will be designed to minimize the reliance on operator actions in response to hazards listed in Part 1. Initial operator actions will be completed by plant personnel and will include the capability for remote-manual initiation from the HCVS Operating Station and locally at the Screenwell Building. Timelines (see attachments 2.1.A and 2.1.C for SAWA/ SAWM) were developed to identify required operator response times and actions. The timelines are an expansion of Attachment 2A and begin either as core damage occurs (SAWA) or after initial SAWA injection is established and as flowrate is adjusted for option B.2 (SAWM). The timelines do not assume the core is ex-vessel and the actions taken are appropriate for both in-vessel and ex-vessel core damage conditions.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 18 of 48 Part 3.1: Boundary Conditions for SAWA Table 3.1 - SAWA Manual Actions Primary Action Primary Location / Component Notes

1. Establish HCVS capability in accordance with Part 2 of this guidance.

HCVS Operating Station Applicable to SAWA/SAWM strategy

2. Lineup valves appropriate for RPV injection in accordance with EA-12-049 Reactor Building /

Screenwell Building

3. Power SAWA/HCVS components with EA-12-049 (FLEX) generator Electrical Bay
4. Connect SAWA (diesel fire) pump discharge to injection piping RHR Crosstie at Screenwell Building
5. Inject to RPV using SAWA (diesel fire) pump Initial SAWA injection rate is 361 gpm based on ratio of 500 gpm at the reference plant power level of 3514 MW
6. Monitor SAWA indications RHR Crosstie at Screenwell Building MCR Pump Flow
7. Use SAWM to maintain availability of the WW vent (Part 3.1.A)

MCR and Screenwell Building Monitor DW Pressure and Suppression Pool Level in MCR Control SAWA using manual valves in Screenwell Building Discussion of timeline SAWA identified items HCVS operations are discussed under Phase 1 of EA-13-109. 8 Hours - Establish electrical power and other EA-12-049 actions needed to support the strategies for EA-13-109, Phase 1 and Phase 2. Action being taken within the Reactor Building under EA-12-049 conditions after RPV level lowers to 2/3 core height must be evaluated for radiological conditions assuming permanent containment shielding remains intact. (HCVS-FAQ-12) All other actions required are assumed to be in-line with the FLEX timeline submitted in accordance with the EA-12-049 requirements. Less than 8 Hours - Initiate SAWA flow to the RPV. Having the HCVS in service will assist in minimizing the peak DW pressure during the initial cooling conditions provided by SAWA. Severe Accident Operation

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 19 of 48 Part 3.1: Boundary Conditions for SAWA Determine operating requirements for SAWA, such as may be used in an ELAP scenario to mitigate core damage. Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section I.1.6, I.1.4.4 It is anticipated that SAWA will be used in Severe Accident Events based on presumed failure of injection systems or presumed failure to implement an injection system in a timely manner leading to core damage. This does not preclude the use of the SAWA system to supplement or replace the EA-12-049 injection systems if desired. SAWA will consist of both portable and installed equipment. The motive force equipment needed to support the SAWA strategy shall be available prior to t=8 hours from the loss of injection (assumed at T=0). The SAWA flow path includes methods to minimize exposure of personnel to radioactive liquids / gases and potentially flammable conditions by inclusion of backflow prevention. RHR LPCI injection mode has installed ECCS check valves to prevent backflow (10AOV-68A) qualified for accident scenarios. Description of SAWA actions for first 24 hours: T<1 hr: No evaluation required for actions inside the Reactor Building for SAWA. No expected actions inside the Reactor Building for SAWA. T=1 - 8 hr: Evaluation of core gap and early in vessel release impact to Reactor Building access for SAWA actions is required. It is assumed that Reactor Building access is limited due to the source term at this time unless otherwise noted. (Refer to HCVS-FAQ-12 for actions in T=1-7 hr). Manually open and close valves within the Reactor Building to establish flow path to RPV. Table 3.1, Step

2.

Establish electrical power for SAWA systems and indications using EA-12-049, or other systems. Table 3.1, Step 3. Establish flow to the RPV using SAWA systems. Begin injection at a maximum rate, not to exceed 500 gpm. T8 - 12 hr: Continue injection for 4 hours after SAWA injection begins at initial SAWA rate. T 12 hrs: Proceed to SAWM actions (Part 3.1.A). Table 3.1, Step 7. Greater Than 24 Hour Coping Detail Provide a general description of the SAWA actions for greater than 24 hours using portable and installed equipment including station modifications that are proposed. Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3/ NEI 13-02 Section 4.2.2.4.1.3.1, I.1.4,

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 20 of 48 Part 3.1: Boundary Conditions for SAWA SAWA Operation is the same for the full period of sustained operation. If SAWM is employed flow rates will be directed to preserve the availability of the HCVS wetwell vent (see 3.1.A). Details: Details of Design Characteristics/Performance Specifications SAWA shall be capable of providing a RPV injection rate of 361 gpm within 8 hours of a loss of all RPV injection following an ELAP/Severe Accident. SAWA shall meet the design characteristics of the HCVS with the exception of the dedicated 24 hour power source. Hydrogen mitigation is provided by backflow prevention for SAWA. Ref: EA-13-109 Attachment 2, Section B.2.1, B.2.2, B.2.3/ NEI 13-02 Section I.1.4 Equipment Locations/Controls/Instrumentation The locations of the SAWA equipment and controls, as well as ingress and egress paths will be evaluated for the expected severe accident conditions (temperature, humidity, radiation) for the Sustained Operating period. Equipment will be evaluated to remain operational throughout the Sustained Operating period. Personnel exposure and temperature / humidity conditions for operation of SAWA equipment will not exceed the limits for ERO dose and plant safety guidelines for temperature and humidity. The flow path will be from the FLEX (diesel fire) pump suction in Lake Ontario through the FLEX pumps with a common outlet including a flow indicator that will be used for FLEX and HCVS Phase 2. The indicator will be monitoring the flow that is provided to the RHR service water FLEX header. The monitored water flow rate will pass through the RHRSW piping to the Reactor Building where it will connect with the RHR system by opening MOVs from the MCR that interconnect the systems. The flow will then be directed into the RPV via the LPCI injection valves. Cross flow into other portions of the RHR system will be isolated by manually closing the required MOVs using the available handwheels. DW pressure and Suppression Pool level will be monitored and flow rate will be adjusted by use of the FLEX pump control valve at the Screenwell Building. Communication will be established between the MCR and the FLEX pump location. The FLEX DGs are located in either the west side of the DG Building or north side of the Screenwell Building, which is significantly away from the discharge of the HCVS above the Reactor Building. Refueling of the FLEX DG will be accomplished from the EDG fuel oil tanks as described in the EA-12-049 compliance documents. The Screenwell Building is a significant distance from the discharge of the HCVS above the Reactor Building. Evaluations will be performed for projected SA conditions (radiation / temperature) to indicate that personnel can complete the initial and support activities without exceeding the ERO-allowable dose for equipment operation or site safety standards. (reference HCVS-WP-02, Plant-Specific Dose Analysis for the Venting of Containment during the SA Conditions) Electrical equipment and instrumentation will be powered from the existing station batteries, and from AC distribution systems that are powered from the EA-12-049 generator(s). The battery chargers are also powered from the EA-12-049 generator(s) to maintain the battery capacities during the Sustained Operating period. The indications include (*minimum required):

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 21 of 48 Part 3.1: Boundary Conditions for SAWA Parameter Instrument Location Power Source / Notes

  • DW Pressure 27PI-115A1, 2, 27PI-115B1, 2 MCR Station batteries via EA-12-049 generator
  • Torus Level 23LI-202A, B MCR Station batteries via EA-12-049 generator
  • SAWA Flow FLEX Pump Flow indicator Intake Crosstie Self Powered (1 Year Battery)

The instrumentation and equipment being used for SAWA and supporting equipment will be evaluated to perform for the Sustained Operating period under the expected radiological and temperature conditions. Equipment Protection Any SAWA component and connections external to protected buildings have been protected or have site specific evaluations for the screened-in hazards of EA-12-049 for the station. Portable equipment used for SAWA implementation will meet the protection requirements for storage in accordance with the criteria in NEI 12-06 Revision

0.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 5.1.1, 5.4.6, I.1.6 Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. Ref: EA-13-109 Attachment 2, Section A.3.1, B.2.3 / NEI 13-02 Section 1.3, 6.1.2 Hook-up and start FLEX DG to repower Emergency Switchgear 71L25 Manually open 10MOV-148A and 10MOV-149A to cross tie RHR with RHRSW Open 10MOV-25A and 10MOV-27A (normally open) for RHR LPCI injection pathway (manually or from MCR using LPCI batteries) Manually close 10RHR-11A Install FLEX hose and flow indicator between valves 76FPS-720 and 10RHR-432 to crosstie FP with RHRSW Start FLEX (diesel fire) pump Adjust flow rate using Screenwell Building crosstie flow indicator and isolation valve Identify modifications: List modifications and describe how they support the SAWA Actions. Ref: EA-13-109 Attachment 2, Section B.2.2, / NEI 13-02 Section 4.2.4.4, 7.2.1.8, Appendix I None.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 22 of 48 Part 3.1: Boundary Conditions for SAWA Component Qualifications: State the qualification used for equipment supporting SAWA Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section I.1.6 Permanently installed plant equipment shall meet the same qualifications as described in Part 2 of this OIP. Temporary/Portable equipment shall be qualified and stored to the same requirements as FLEX equipment as specified in NEI 12-06 Rev 0. SAWA components are not required to meet NEI 13-02, Table 2-1 design conditions. Notes: None Part 3.1.A: Boundary Conditions for SAWA/SAWM Time periods for the maintaining SAWM actions such that the WW vent remains available SAWM Actions supporting SA conditions 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). Actions already identified under the HCVS part of this template need not be repeated here. There are three time periods for maintaining SAWM actions such that the WW vent remains available to remove decay heat from the containment: SAWM can be maintained for >7 days without the need for a drywell vent to maintain pressure below PCPL or containment design pressure, whichever is lower. o Under this approach, no detail concerning plant modifications or procedures is necessary with respect to how alternate containment heat removal will be provided. SAWM can be maintained for at least 72 hours, but less than 7 days before DW pressure reaches PCPL or design pressure, whichever is lower. o Under this approach, a functional description is required of how alternate containment heat removal might be established before DW pressure reaches PCPL or design pressure whichever is lower. Under this approach, physical plant modifications and detailed procedures are not necessary, but written descriptions of possible approaches for achieving alternate containment heat removal and pressure control will be provided. SAWM can be maintained for <72 hours SAWM strategy can be implemented but for less than 72 hours before DW pressure reaches PCPL or design pressure whichever is lower. o Under this approach, a functional description is required of how alternate containment heat removal might be established before DW pressure reaches PCPL or design pressure whichever is lower. Under this approach, physical plant modifications and detailed procedures are required to be implemented to insure achieving alternate containment heat removal and pressure control will be provided for the sustained operating period. Ref: NEI 13-02 Appendix C.7 SAWM can be maintained for >7 days without the need for a drywell vent to maintain pressure below PCPL.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 23 of 48 Part 3.1: Boundary Conditions for SAWA Basis for SAWM time frame Option 1 - SAWM can be maintained greater than or equal to 7 days: The reference plant is the same containment and RPV design (BRW4, Mark I) and has greater generating capacity. In addition, the available JAF Torus freeboard bounds that of the reference plant. Therefore, James A. FitzPatrick is bounded by the evaluations performed in BWROG TP-2015-008 and representative of the reference plant in NEI 13-02 figures C-2 through C-6. Instrumentation relied upon for SAWM operations is Drywell Pressure, Torus level and SAWA flow. This instrumentation will be initially powered by the station DC batteries and will be repowered by the FLEX (EA-12-049) generator, which is placed in-service prior to RPV breach. The FLEX DG will provide power throughout the Sustained Operation period (7 days). DW Temperature monitoring is not a requirement for compliance with Phase 2 of the Order, but some knowledge of temperature characteristics provides information for the operation staff to evaluate plant conditions under a severe accident and provide confirmation to adjust SAWA flow rates. (C.7.1.4.2, C.8.3.1) Torus level indication is maintained throughout the Sustained Operation period, so the HCVS remains in-service. The time to reach the level at which the WW vent must be secured is >7days using SAWM flowrates (C.6.3, C.7.1.4.3)

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 24 of 48 Table 3.1.B - SAWM Manual Actions Primary Action Primary Location / Component Notes

1. Lower SAWA injection rate to control Torus Level and decay heat removal Screenwell Building Control to maintain containment and Torus parameters to ensure Torus vent remains functional.

73 gpm minimum capability is maintained for greater than 7 days based on ratio of 100 gpm at the reference plant power level of 3514 MW

2. Control to SAWM flowrate for containment control / decay heat removal Screenwell Building SAWM flow rates will be monitored using the following instrumentation:

o SAWA (FLEX diesel fire pump) Flow o Torus Level o DW pressure SAWM flow rates will be controlled using manual valves (FLEX hose splitter isolation valve and 10RHR-432)

3. Establish alternate source of decay heat removal Yard
>7 days
4. Secure SAWA / SAWM Screenwell Building When reliable alternate containment decay heat removal is established.

SAWM Time Sensitive Actions Time Sensitive SAWM Actions: 12 Hours - Initiate actions to maintain the Torus vent capability by lowering injection rate, while maintaining the cooling of the core debris (SAWM). Monitor SAWM critical parameters while ensuring the Torus vent remains available. SAWM Severe Accident Operation Determine operating requirements for SAWM, such as may be used in an ELAP scenario to mitigate core damage. Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Appendix C It is anticipated that SAWM will only be used in Severe Accident Events based on presumed failure of plant injection systems per direction by the plant SAMGs. Refer to attachment 2.1.D for SAWM SAMG language additions.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 25 of 48 First 24 Hour Coping Detail Provide a general description of the SAWM actions for first 24 hours using installed equipment including station modifications that are proposed. Given the initial conditions for EA-13-109: BDBEE occurs with ELAP Failure of all injection systems, including steam-powered injection systems Ref: EA-13-109 Section 1.2.6, Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 2.5, 4.2.2, Appendix C, Section C.7 SAWA will be established as described as stated above. SAWM will use the installed instrumentation to monitor and adjust the flow from SAWA to control the pump discharge to deliver flowrates applicable to the SAWM strategy. Once the SAWA initial flow rate has been established for 4 hours, the flow will be reduced while monitoring DW pressure and Torus level. SAWM flowrate can be lowered to maintain containment parameters and preserve the WW vent path. SAWM will be capable of injection for the period of Sustained Operation. Greater Than 24 Hour Coping Detail Provide a general description of the SAWM actions for greater than 24 hours using portable and installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.4, 1.2.8, Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 4.2.2, Appendix C, Section C.7 SAWM can be maintained >7 days: The SAWM flow strategy will be the same as the first 24 hours until alternate reliable containment heat removal and pressure control is reestablished. SAWM flow strategy uses the SAWA flow path. No additional modifications are being made for SAWM. Details: Details of Design Characteristics/Performance Specifications Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section Appendix C SAWM shall be capable of monitoring the containment parameters (DW pressure and Torus Level) to provide guidance on when injection rates shall be reduced, until alternate containment decay heat/pressure control is established. SAWA will be capable of injection for the period of Sustained Operation. Equipment Locations/Controls/Instrumentation Describe location for SAWM monitoring and control. Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Appendix C, Section C.8, Appendix I The SAWM control location is the same as the SAWA control location. Local indication of SAWM flow rate is provided at the pump discharge hose crosstie by a portable flow instrument qualified to operate under the expected environmental conditions. The SAWA flow instrument is self-powered by two (2) lithium 3.6V D batteries. Communications will be established between the SAWM control location and the MCR. Injection flowrate is controlled by the hose splitter valve located on the FLEX supply hose in the Screenwell Building.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 26 of 48 Torus level and DW pressure are read in the control room using indicators powered by the FLEX DG installed under EA-12-049. These indications are used to control SAWM flowrate to the RPV. Key Parameters: List instrumentation credited for the SAWM Actions. Parameters used for SAWM are: DW Pressure Torus Level SAWM Flowrate The Drywell pressure and Torus level instruments are qualified to RG 1.97 equivalent and are the same as listed in part 2 of this OIP. The SAWM flow instrumentation will be qualified for the expected environmental conditions expected when needed. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 27 of 48 Part 3.1.B: Boundary Conditions for SAWA/SADV Applicability of WW Design Considerations This section is not applicable to JAF. Table 3.1.C - SADV Manual Actions Timeline for SADV Severe Accident Venting First 24 Hour Coping Detail Greater Than 24 Hour Coping Detail Details:

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 28 of 48 Part 4: Programmatic Controls, Training, Drills and Maintenance Identify how the programmatic controls will be met. Provide a description of the programmatic controls equipment protection, storage and deployment and equipment quality addressing the impact of temperature and environment Ref: EA-13-109 Section 1.2.10, 3.1, 3.2 / NEI 13-02 Sections 5, 6.1.2, 6.1.3, 6.2 Program Controls: The HCVS venting actions will include: Site procedures and programs are being developed in accordance with NEI 13-02 to address use and storage of portable equipment relative to the Severe Accident defined in NRC Order EA-13-109 and the hazards applicable to the site per Part 1 of this OIP. Routes for transporting portable equipment from storage location(s) to deployment areas will be developed as the response details are identified and finalized. The identified paths and deployment areas will be analyzed for radiation and temperature to ensure they are accessible during Severe Accidents. Procedures: Procedures will be established for system operations when normal and backup power is available, and during ELAP conditions. The HCVS procedures will be developed and implemented following the plants process for initiating or revising procedures and contain the following details: appropriate conditions and criteria for use of the HCVS when and how to place the HCVS in operation, the location of system components, instrumentation available, normal and backup power supplies, directions for sustained operation, including the storage location of portable equipment, training on operating the portable equipment, and testing of portable equipment James A. FitzPatrick will establish provisions for out-of-service requirements of the HCVS and compensatory measures. The following provisions will be documented in a controlled document: The provisions for out-of-service requirements for HCVS/SAWA functionality are applicable in Modes 1, 2 and 3. If for up to 90 consecutive days, the primary or alternate means of HCVS/SAWA operation are non-functional, no compensatory actions are necessary. If for up to 30 days, the primary and alternate means of HCVS/SAWA operation are nonfunctional, no compensatory actions are necessary. If the out of service times exceed 30 or 90 days as described above, the following actions will be performed through the sites corrective action program: o The cause(s) of the non-functionality o The actions to be taken and the schedule for restoring the system to functional status and prevent recurrence o Initiate action to implement appropriate compensatory actions, and

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 29 of 48 Part 4: Programmatic Controls, Training, Drills and Maintenance o Restore full HCVS functionality at the earliest opportunity not to exceed one full operating cycle. Describe training plan List training plans for affected organizations or describe the plan for training development Ref: EA-13-109 Section 3.2 / NEI 13-02 Section 6.1.3 Personnel expected to perform direct execution of the HCVS/SAWA/SAWM actions will receive necessary training in the use of plant procedures for system operations when normal and backup power is available and during ELAP conditions. The training will be refreshed on a periodic basis and as any changes occur to the HCVS/SAWA/SAWM actions, systems or strategies. Training content and frequency will be established using the Systematic Approach to Training (SAT) process. Identify how the drills and exercise parameters will be met. Alignment with NEI 13-06 and 14-01 as codified in NTTF Recommendation 8 and 9 rulemaking The Licensee should demonstrate use of the HCVS/SAWA/SAWM system in drills, tabletops, or exercises as follows: Hardened containment vent operation on normal power sources (no ELAP). During FLEX demonstrations (as required by EA-12-049: Hardened containment vent operation on backup power and from primary or alternate location during conditions of ELAP/loss of UHS with no core damage. System use is for containment heat removal AND containment pressure control. HCVS operation on backup power and from primary or alternate location during conditions of ELAP/loss of UHS with core damage. System use is for containment heat removal AND containment pressure control with potential for combustible gases (Demonstration may be in conjunction with SAG change). Operation for sustained period with SAWA and SAWM to provide decay heat removal and containment pressure control. Ref: EA-13-109 Section 3.1 / NEI 13-02 Section 6.1.3 The site will utilize the guidance provided in NEI 13-06 and 14-01 for guidance related to drills, tabletops, or exercises for HCVS operation. In addition, the site will integrate these requirements with compliance to any rulemaking resulting from the NTTF Recommendations 8 and 9. Describe maintenance plan: Describe the elements of the maintenance plan The maintenance program should ensure that the HCVS/SAWA/SAWM equipment reliability is being achieved in a manner similar to that required for FLEX equipment. Standard industry templates (e.g., EPRI) and associated bases may be developed to define specific maintenance and testing. o Periodic testing and frequency should be determined based on equipment type, expected use and manufacturers recommendations (further details are provided in Part 6 of this document). o Testing should be done to verify design requirements and/or basis. The basis should be documented and deviations from vendor recommendations and applicable standards should be justified. o Preventive maintenance should be determined based on equipment type and expected use. The basis should be documented and deviations from vendor recommendations and applicable standards should be justified.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 30 of 48 Part 4: Programmatic Controls, Training, Drills and Maintenance o Existing work control processes may be used to control maintenance and testing. HCVS/SAWA permanent installed equipment should be maintained in a manner that is consistent with assuring that it performs its function when required. o HCVS/SAWA permanently installed equipment should be subject to maintenance and testing guidance provided to verify proper function. HCVS/SAWA non-installed equipment should be stored and maintained in a manner that is consistent with assuring that it does not degrade over long periods of storage and that it is accessible for periodic maintenance and testing. Ref: EA-13-109 Section 1.2.13 / NEI 13-02 Section 5.4, 6.2 James A. FitzPatrick will utilize the standard EPRI industry PM process (Similar to the Preventive Maintenance Basis Database) for establishing the maintenance calibration and testing actions for HCVS/SAWA/SAWM components. The control program will include maintenance guidance, testing procedures and frequencies established based on type of equipment and considerations made within the EPRI guidelines. James A. FitzPatrick will implement the following operation, testing and inspection requirements for the HCVS and SAWA to ensure reliable operation of the system. Table 4-1: Testing and Inspection Requirements Description Frequency Cycle the HCVS and installed SAWA valves1 and the interfacing system boundary valves not used to maintain containment integrity during Mode 1, 2 and 3. For HCVS valves, this test may be performed concurrently with the control logic test described below. Once per every2 operating cycle Cycle the HCVS and installed SAWA check valves not used to maintain containment integrity during unit operations3 Once per every other4 operating cycle Perform visual inspections and a walk down of HCVS and installed SAWA components Once per every other4 operating cycle Functionally test the HCVS radiation monitors. Once per operating cycle Leak test the HCVS.

1. Prior to first declaring the system functional;
2. Once every three operating cycles thereafter; and
3. After restoration of any breach of system boundary within the buildings

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 31 of 48 Part 4: Programmatic Controls, Training, Drills and Maintenance Validate the HCVS operating procedures by conducting an open/close test of the HCVS control function from its control location and ensuring that all HCVS vent path and interfacing system boundary valves5 move to their proper (intended) positions. Once per every other operating cycle 1 Not required for HCVS and SAWA check valves. 2 After two consecutive successful performances, the test frequency may be reduced to a maximum of once per every other operating cycle. 3 Not required if integrity of check function (open and closed) is demonstrated by other plant testing requirements. 4 After two consecutive successful performances, the test frequency may be reduced by one operating cycle to a maximum of once per every fourth operating cycle. 5 Interfacing system boundary valves that are normally closed and fail closed under ELAP conditions (loss of power and/or air) do not require control function testing under this part. Performing existing plant design basis function testing or system operation that reposition the valve(s) to the HCVS required position will meet this requirement without the need for additional testing. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 32 of 48 Part 5: Milestone Schedule Provide a milestone schedule 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. Ref: EA-13-109 Section D.1, D.3 / NEI 13-02 Section 7.2.1 The following milestone schedules are 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 6 month status reports. Phase 1 Milestone Schedule: Phase 1 Milestone Schedule: See Phase 1 schedule update issued as part of the 6-month updates. Phase 2 Milestone Schedule: Phase 2 Milestone Schedule Milestone Target Completion Date Activity Status Comments Hold preliminary/conceptual design meeting Oct 2015 Complete Submit Overall Integrated Implementation Plan Dec 2015 Complete Submit 6 Month Status Report Jun 2016 Not Started Submit 6 Month Status Report Dec 2016 Not Started Submit 6 Month Status Report Jun 2017 Not Started Design Engineering On-site/Complete Jun 2017 Not Started Submit 6 Month Status Report Dec 2017 Not Started Operations Procedure Changes Developed Jun 2018 Not Started Site Specific Maintenance Procedure Developed Jun 2018 Not Started Training Complete Jun 2018 Not Started Submit 6 Month Status Report Jun 2018 Not Started Implementation Outage Sep 2018 Not Started Walk Through Demonstration/Functional Test Sep 2018 Not Started Procedure Changes Active Sep 2018 Not Started Submit Completion Report Nov 2018 Not Started Notes: None

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 33 of 48

HCVS/SAWA Portable Equipment List portable equipment BDBEE Venting Severe Accident Venting Performance Criteria Maintenance / PM requirements The portable equipment listed below supports SAWA/SAWM (Phase 2).

For a list of Phase 1 HCVS Equipment, refer to the Phase 1 Overall Integrated Plan and associated 6 month updates FLEX DG (and associated equipment) X X 200 kW Per Response to EA-12-049 4 Hose (5) X X Per Response to EA-12-049 Flow Instrument / Indicator X X 0 - 500 gpm minimum Per Response to EA-12-049

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 A: Sequence of Events Timeline - HCVS This EA-13-109 Phase 1 Overall Integrated Plan timeline is updated to reflect SA WA injection RCIC SBO starts t=Os t" 1 m No Injection t = 5.5 hrs Anticipatory Venting t = 8 hrs Portable generator in place for FLEX. May also be able to power HCVS DC power supply> 23 hours (JAF FLEX OIP) Containment Venting (based on preventing exceeding containment design pressure; anticipatory venting not represented in SOARCA) I I t t" 1 hr t" 8 hr Legend Adequate core cooling maintained Injection Lost t = 23 hrs Begin Monitoring HCVS pneumatic supply and DC power supply status. No replenishment expected to be required for at least 24 hours. t" 18 hrs No Injection Containment Venting (anticipatory venting not Represented in SECY-12-0157) evel at t = 24 hrs Replenishment of HCVS DC power supply and pneumatic supplies. Case 1 FLEX Successful Ref: JAF FLEX OIP L l ~ c-2

  • cmm--------c*t------41---+ RCIC Late Failure t" 23 hrs t" 24 hrs t" 34 hrs Ref: SECY-12-0157

!~ion Begins

References:

Case 1: JAF FLEX Overall Integrated Plan Case 2: SECY-12-0157 - ML12344A030 Case 3: SOARCA-ML13150A053 Case 3 RCIC Early Failure Ref SOARCA Not to Scale Increased shine and leakage of radionuclides primarily from Wetwell HCVS Post Core Damage Dose Evaluation Required Page 34 of 48

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 35 of 48 .1.A: Sequence of Events Timeline - SAWA / SAWM T=8hr T=72hr T=168hr SAWAInjection Flowbegins(<500gpm) SustainedOperationPeriod ControlSAWMflowrate usingdrywellpressure andToruslevel indications T=12hr

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 36 of 48 .1.B: Sequence of Events Timeline - SADV This is not applicable to JAF.

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 37 of 48 .1.C: SAWA / SAWM Plant-Specific Datum NormalTorusLevel(NTL) El.2440(168) LevelInstrumentRange El.2317toEl.2576 (19to330) FreeboardHeight 162(136) AdditionalFreeboardHeight 24(20) DrywellFloor 2566

  • Torus Water Volume:

o 244-0: 810,000 gallons o 256-6: 1,642,000 gallons Estimated injection in 7 days: 769,920 gallons Estimated Torus Water Volume at 7 days: 1,579,920 gallons

  • Gross values without consideration for internal structures BottomofTorus El.2300(0)

SAWVEl.2596 (354) DrywellVentPipeIntersectionwith DrywellShell 25711

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 38 of 48 .1.D: SAWM SAMG Approved Language The following general cautions, priorities and methods will be evaluated for plant specific applicability and incorporated as appropriate into the plant specific SAMGs using administrative procedures for EPG/SAG change control process and implementation. SAMGs are symptom based guidelines and therefore address a wide variety of possible plant conditions and capabilities while these changes are intended to accommodate those specific conditions assumed in Order EA-13-109. The changes will be made in a way that maintains the use of SAMGs in a symptom based mode while at the same time addressing those conditions that may exist under extended loss of AC power (ELAP) conditions with significant core damage including ex-vessel core debris. Actual Approved Language that will be incorporated into site SAMG* Cautions: Addressing the possible plant response associated with adding water to hot core debris and the resulting pressurization of the primary containment by rapid steam generation. Addressing the plant impact that raising Torus water level above the elevation of the suppression chamber vent opening elevation will flood the suppression chamber vent path. Priorities: With significant core damage and RPV breach, SAMGs prioritize the preservation of primary containment integrity while limiting radioactivity releases as follows: Core debris in the primary containment is stabilized by water addition (SAWA) Primary containment pressure is controlled below the Primary Containment Pressure Limit (Wetwell venting) Water addition is managed to preserve the Mark I/II suppression chamber vent paths, thereby retaining the benefits of Torus scrubbing and minimizing the likelihood of radioactivity and hydrogen release into the secondary containment (SAWM) Methods: Identify systems and capabilities to add water to the RPV or drywell, with the following generic guidance: Use controlled injection if possible. Inject into the RPV if possible. Maintain injection from external sources of water as low as possible to preserve suppression chamber vent capability.

  • Actual language may vary by acceptable site procedure standards, but intent and structure should follow this guidance.

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 39 of 48

Conceptual Sketches Refer to the EA-13-109 Phase 1 Overall Integrated Plan for the following sketches:

Electrical Electrical Layout of System - One Line Diagram Electrical Layout of System - Block Diagram Flow and Control Diagrams P&ID Layout of current HCVS Plant Layout ROS Location HCVS Battery System Location Deployment location and haul path (updated as part of Sketch 3 in this Phase 2 OIP) Additional Phase 2 Sketches: Sketch 1: FLEX / SAWA Flow Diagram Sketch 2: FLEX / SAWA Power Distribution Sketch 3: FLEX / SAWA Equipment Location Sketch 4: FLEX / SAWA Ingress/Egress Pathways

OJ " '-,1-*~j,i;;;:;, ~ ** ~L~r~~ ~/,.l*.~t'*~~:,,...-".1 __./. --- ---- n::-; "i~ I I' l~KC:

  • ./ **-- -*~ \\1 *;

',\\' i ~lJ.'.' 1: t ~H

    • -~ l).(/:"I(',

////// /// James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 i IR~~x-1 i \\-~<< ! j '-~re< 'HI'.'£~ :*;iic

l.

1 1'1.:U,t**1Y} ~ I I I ~ _., ~: -~ fii1 fl'"! ~.

  • -------{_~;---~

L __ 1 _________ l~~tm: .~'" T '"

JI/ARY

! :ot-m<rit~E*-T i ~ *'k-@~ T NC i r-..------------------------------------------------J i ! Y>< !L:. NC1' '

l~/----*t;t*----~-+-*~ ---**1

~-~ c i i ~'" T

r~~---**tf**---~i'--L---r;~~ -----J

~ r;
A

,o OfA~ll'.'ATC ~} L_~~~~~~~l__~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~J--t:~* ~~~~~ ld Ii> '8° FLEX SAWA (HCVS PHASE 2) FLOW PATH [1] FLEX/ SAWA (DIESEL FIRE) PUMPS ~ FLEX/ SAWA FLOW METER QJ FLEX/ SAWA 4" HOSE (5') [] FLEX/ SAWA THROTILING VALVE Sketch 1: FLEX I SAWA Flow Diagram Page 40 of 48

I f*~ "~Y f. ) ' - '.KC-62. Ge~*... C~3 James A FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 FLEX PHASE 2 DG, FIXED OR DEPLOYABLE 200 KW/250 KVA, 600V 2 - 410 PER<!> FLEX PHASE 2 DG, FIXED OR DEPLOYABLE 200 KW/250 KVA, 600V Sketch 2: FLEX I SAWA Power Distribution Page 41 of 48

HCVS TH ROUGH ROOF u TRACK BAY James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 TRANSFORMERS ELE CTR ICAL BAY ~ TURBINE BLDG REACTOR ADMIN f-REMOTE PANEL BLDG By f--- EL. 272' NI TR OGEN VALVE PANEL EL.272 ' v--- NITROGEN BOTTLE RACK ~ EL. 272' BOILER CONTR OL ~~ RM I RM I HE ATER BAY BATTERY __) L BATTERY RACK CHARGER Sketch 3: FLEX I SAWA Equipment Location Page 42 of 48 PR IMARY) ~ FLE X DG DIESEL GENER ATOR

,CR EENWEL L FLEX/SAWA DIESEL FIREl PUMPS WA TER TREATING RAD WAS TE 0----

j \\ - FLEX DG ALTERNATE l (

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 43 of 48 This drawing will be provided later. Sketch 4: FLEX / SAWA Ingress / Egress Pathways

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 44 of 48

Failure Evaluation Table Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 45 of 48 : References

1. Generic Letter 89-16, Installation of a Hardened Wetwell Vent, dated September 1, 1989
2. Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012
3. Order EA-12-050, Reliable Hardened Containment Vents, dated March 12, 2012
4. Order EA-12-051, Reliable SFP Level Instrumentation, dated March 12, 2012
5. Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated June 6, 2013
6. JLD-ISG-2012-01, Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated August 29, 2012
7. JLD-ISG-2012-02, Compliance with Order EA-12-050, Reliable Hardened Containment Vents, dated August 29, 2012
8. JLD-ISG-2013-02, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated November 14, 2013
9. NRC Responses to Public Comments, Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-ISG-2012-02: Compliance with Order EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, ADAMS Accession No. ML12229A477, dated August 29, 2012
10. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012
11. NEI 13-02, Industry Guidance for Compliance with Order EA-13-109, Revision 1, Dated April 2015
12. NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, Revision 0, dated March 2014
13. NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision 0, dated March 2014
14. NEI HCVS-FAQ-01, HCVS Primary Controls and Alternate Controls and Monitoring Locations
15. NEI HCVS-FAQ-08, HCVS Instrument Qualifications
16. NEI HCVS-FAQ-09, Use of Toolbox Actions for Personnel
17. NEI White Paper HCVS-WP-02, HCVS Cyclic Operations Approach
18. NEI White Paper HCVS-WP-04, Missile Evaluation for HCVS Components 30 Feet Above Grade

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 46 of 48

19. IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations,
20. James A. FitzPatrick EA-12-049 (FLEX) Overall Integrated Implementation Plan, Rev 0, February 2013
21. James A. FitzPatrick EA-12-050 (HCVS) Overall Integrated Implementation Plan, Rev 0, February 2013
22. James A. FitzPatrick EA-12-051 (SFP LI) Overall Integrated Implementation Plan, Rev 0, February 2013
23. JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, dated March 2015
24. Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments, SECY-12-0157, ML12344A030
25. NUREG/CR-7110, V1, R1, State-of-the-Art Reactor Consequence Analyses (SOARCA) Project: Peach Bottom Integrated Analysis, ML13150A053
26. NEI HCVS-FAQ-10, Severe Accident Multiple Unit Response
27. NEI HCVS-FAQ-11, Plant Response During a Severe Accident
28. NEI HCVS-FAQ-12, Radiological Evaluations on Plant Actions Prior to HCVS Initial Use
29. NEI HCVS-FAQ-13, Severe Accident Venting Actions Validation
30. EC 52736, Fukushima FLEX Basis EC, Rev. 0
31. FM-20A, Flow Diagram Residual Heat Removal System 10, Rev. 72
32. FM-20B, Flow Diagram Residual Heat Removal System 10, Rev. 72
33. 3.11-44, Drywell Shell General Plan, Rev. 2
34. MSK-309C1, System 27 Air Piping from Penetration X-205 to 326-9, Rev. 7
35. ISI-IWE-001, General Arrangement and Details of Drywell and Torus, Rev. 1
36. JAF-CALC-PC-03043, Holdup Volumes for Containment Analyses, Rev. 0
37. ISP-29-3, Post Accident Suppression Pool Water Level Monitor Instrument Calibration, Rev. 12

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 47 of 48 : Changes/Updates to this Overall Integrated Implementation Plan This Overall Integrated Plan includes only content for Phase 2 of Order EA-13-109. Any significant changes to this plan will be communicated to the NRC staff in the 6 Month Status Reports.The Overall Integrated Plan for Phase 1 has been submitted and updated as a separate document.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 48 of 48 : List of Overall Integrated Plan Open Items Phase 1 and ISE Open Items are addressed as part of the Phase 1 OIP updates. Phase 2 Open Item Action Comment 1 Complete hydraulic analysis of diesel fire pump for SAWA / SAWM flowrates 2 Identify and evaluate severe accident conditions for Phase 2 manual actions. 3 The FLEX Engineering Change (EC 52736) has not been completed; therefore, any reference to this information is considered unverified.

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-15-0149 December 29, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

James A. FitzPatrick Phase 2 Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109) James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59

Reference:

1.

NRC Order, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, EA-13-109, dated June 6, 2013

2.

NRC Interim Staff Guidance, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, JLD-ISG-2015-01, dated April 2015

3.

NEI document, Industry Guidance for Compliance with NRC Order EA-13-109, NEI 13-02 Revision 1, dated April 2015

4.

Entergy letter, James A. FitzPatrick Overall Integrated Plan In Response To June 6, 2013 Commission Order Modifying License With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), JAFP-14-0075, dated June 30, 2014

5.

Entergy letter, Notification of Permanent Cessation of Power Operations, JAFP-15-0133, dated November 18, 2015

Dear Sir or Madam:

On June 6, 2013, the Nuclear Regulatory Commission (NRC or Commission) issued order EA-13-109 [Reference 1] to the James A. FitzPatrick Nuclear Power Plant (JAF). The order was immediately effective and directs JAF to have reliable hardened containment vents capable of operation under severe accident conditions. Specific requirements are outlined in the Enclosure of Reference 1.

JAFP-15-0149 Page 2 of 2 Implementation of order EA-13-109 is divided into two phases. The Overall Integrated Plan for Phase 1 was submitted by letter dated June 30, 2014 [Reference 4], pursuant to EA-13-109 Section IV, Condition D.1. The purpose of this letter is to provide the Phase 2 Overall Integrated Plan, pursuant to EA-13-109 Section IV, Condition D.2, and Section 7.1.4 of Reference 3. Reference 1 requires submission of an Overall Integrated Plan for phase 2 requirements by December 31, 2015. The NRC Interim Staff Guidance (ISG) [Reference 2] was issued in April 2015, which endorses industry guidance document NEI 13-02, Revision 1 [Reference 3], with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Phase 2 Overall Integrated Plan. The Phase 2 Overall Integrated Plan documented in the Enclosure is an accurate description of modifications and/or strategies needed to satisfy the requirements of NRC Order EA-13-109; however, Entergy has announced plans to cease power operation at JAF [Reference 5]. JAF is still executing the implementation plan; however, based upon Entergy's plan to permanently shut down JAF, compliance with the Order will be affected. Future six (6)-month status reports will be provided as required by Section IV, Condition D.3, of Reference 1, and pursuant to 7.1.5 of Reference 3. This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. Chris M. Adner, Regulatory Assurance Manager, at (315) 349-6766. I declare under penalty of perjury that the foregoing is true and correct; executed on December 29, 2015. Sincerely, Brian R. Sullivan BRS/CMA/mh

Enclosure:

Phase 2 Overall Integrated Plan for Hardened Containment Vent: EA-13-109 cc: Mr. Douglas Pickett, Senior Project Manager Regional Administrator, NRC Region 1 NRC Resident Inspectors Office Mr. John B. Rhodes, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ENCLOSURE TO JAFP-15-0149 Phase 2 Overall Integrated Plan for Hardened Containment Vent: EA-13-109 (48 Pages)

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 1 of 48 Table of Contents: Introduction Part 1: General Integrated Plan Elements and Assumptions Part 2: Boundary Conditions for Wet Well Vent Part 3: Boundary Conditions for EA-13-109, Option B.2 Part 3.1 Boundary Conditions for SAWA Part 3.1A Boundary Conditions for SAWA/SAWM Part 3.1B Boundary Conditions for SAWA/SADV Part 4: Programmatic Controls, Training, Drills and Maintenance Part 5: Milestones Schedule : HCVS/SAWA Portable Equipment A: Sequence of Events Timeline - HCVS.1.A: Sequence of Events Timeline - SAWA / SAWM.1.B: Sequence of Events Timeline - SADV.1.C: SAWA / SAWM Plant-Specific Datum.1.D: SAWM SAMG Approved Language : Conceptual Sketches : Failure Evaluation Table : References : Changes/Updates to this Overall Integrated Implementation Plan : List of Overall Integrated Plan Open Items

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 2 of 48 Introduction In 1989, the NRC issued Generic Letter 89-16, Installation of a Hardened Wetwell Vent, to all licensees of BWRs with Mark I containments to encourage licensees to voluntarily install a hardened wetwell vent. In response, licensees installed a hardened vent pipe from the suppression pool to some point outside the secondary containment envelope (usually outside the reactor building). Some licensees also installed a hardened vent branch line from the drywell. On March 19, 2013, the Nuclear Regulatory Commission (NRC) Commissioners directed the staff per Staff Requirements Memorandum (SRM) for SECY-12-0157 to require licensees with Mark I and Mark II containments to "upgrade or replace the reliable hardened vents required by Order EA-12-050 with a containment venting system designed and installed to remain functional during severe accident conditions." In response, the NRC issued Order EA-13-109, Issuance of Order to Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accidents, June 6, 2013. The Order (EA-13-109) requires that licensees of BWR facilities with Mark I and Mark II containment designs ensure that these facilities have a reliable hardened vent to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits following events that result in the loss of active containment heat removal capability while maintaining the capability to operate under severe accident (SA) conditions resulting from an Extended Loss of AC Power (ELAP). The Order requirements are applied in a phased approach where: Phase 1 involves upgrading the venting capabilities from the containment wetwell to provide reliable, severe accident capable hardened vents to assist in preventing core damage and, if necessary, to provide venting capability during severe accident conditions. (Completed no later than startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first.) Phase 2 involves providing additional protections for severe accident conditions through installation of a reliable, severe accident capable drywell vent system or the development of a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. (Completed no later than startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019, whichever comes first.) The NRC provided an acceptable approach for complying with Order EA-13-109 through Interim Staff Guidance (JLD-ISG-2013-02 issued in November 2013 and JLD-ISG-2015-01 issued in April 2015). The ISG endorses the compliance approach presented in NEI 13-02 Revision 0 and 1, Industry Guidance for Compliance with Order EA-13-109, with clarifications. Except in those cases in which a licensee proposes an acceptable alternative method for complying with Order EA-13-109, the NRC staff will use the methods described in the ISGs to evaluate licensee compliance as presented in submittals required in Order EA-13-109. The Order also requires submittal of an overall integrated plan which will provide a description of how the requirements of the Order will be achieved. This document provides the Overall Integrated Plan (OIP) for complying with Order EA-13-109 using the methods described in NEI 13-02 and endorsed by NRC JLD-ISG-2013-02 and JLD-ISG-2015-01. Six month progress reports will be provided consistent with the requirements of Order EA-13-109. The submittals required are: OIP for Phase 1 of EA-13-109 was required to be submitted by Licensees to the NRC by June 30, 2014. The NRC requires periodic (6 month) updates for the Hardened Containment Vent System (HCVS) actions being taken. The first update for Phase 1, was due December 2014, with the second due June 2015.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 3 of 48 OIP for Phase 2 of EA-13-109 is required to be submitted by Licensees to the NRC by December 31, 2015. It is expected the December 2015 six month update for Phase 1 will be combined with the Phase 2 OIP submittal by means of a combined Phase 1 and 2 OIP. Thereafter, the 6 month updates will be for both the Phase 1 and Phase 2 actions until complete, consistent with the requirements of Order EA-13-109. Note: At the Licensees option, the December 2015 six month update for Phase 1 may be independent of the Phase 2 OIP submittal, but will require separate six month updates for Phase 1 and 2 until each phase is in compliance. The Plant venting actions for the EA-13-109, Phase 1 severe accident capable venting scenario can be summarized by the following: The HCVS will be initiated via manual action from either the Main Control Room (MCR) (some plants have a designated Primary Operating Station (POS) that will be treated as the main operating location for this order) or from a Remote Operating Station (ROS) at the appropriate time based on procedural guidance in response to plant conditions from observed or derived symptoms. The vent will utilize Containment Parameters of Pressure and Level from the MCR instrumentation to monitor effectiveness of the venting actions. The vent operation will be monitored by HCVS valve position, temperature, and effluent radiation levels. The HCVS motive force will be monitored and have the capacity to operate for 24 hours with installed equipment. Replenishment of the motive force will be by use of portable equipment once the installed motive force is exhausted. Venting actions will be capable of being maintained for a sustained period of up to 7 days or a shorter time if justified. The Phase 2 actions can be summarized as follows: Utilization of Severe Accident Water Addition (SAWA) to initially inject water into the Reactor Pressure Vessel (RPV) or Drywell. Utilization of Severe Accident Water Management (SAWM) to control injection and Suppression Pool level to ensure the HCVS (Phase 1) wetwell vent (SAWV) will remain functional for the removal of decay heat from containment. Ensure that the decay heat can be removed from the containment for seven (7) days using the HCVS or describe the alternate method(s) to remove decay heat from the containment from the time the HCVS is no longer functional until alternate means of decay heat removal are established that make it unlikely the drywell vent will be required for DW pressure control. The SAWA and SAWM actions will be manually activated and controlled from areas that are accessible during severe accident conditions. Parameters measured should be Drywell pressure, Suppression Pool level, SAWA flowrate and the HCVS parameters listed above. Alternatively SAWA and a Severe Accident Capable Drywell Vent (SADV) strategy may be implemented to meet Phase 2 of Order EA-13-109.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 4 of 48 Part 1: General Integrated Plan Elements and Assumptions Extent to which the guidance, JLD-ISG-2013-02, JLD-ISG-2015-01 and NEI 13-02 (Revision 1), are being followed. Identify any deviations. Include a description of any alternatives to the guidance. A technical justification and basis for the alternative needs to be provided. This will likely require a pre-meeting with the NRC to review the alternative. Ref: JLD-ISG-2013-02, JLD-ISG-2015-01 Compliance will be attained for JAF with no known deviations to the guidelines in JLD-ISG-2013-02, JLD-ISG-2015-01 and NEI 13-02 for each phase as follows: The Hardened Containment Vent System (HCVS) will be comprised of installed and portable equipment and operating guidance: Severe Accident Wetwell Vent (SAWV) - Permanently installed vent from the Suppression Pool to the top of Reactor Building Severe accident Water Addition (SAWA) - A combination of permanently installed and portable equipment to provide a means to add water to the RPV following a severe accident and monitor system and plant conditions. Severe Accident Water Management (SAWM) guidance for controlling the water addition to the RPV for the sustained operating period. (reference attachment 2.1.D) Phase 1 (wetwell): by the startup from the second refueling outage that begins after June 30, 2014, or June 30, 2018, whichever comes first. Currently scheduled for the fall of 2016 Phase 2 (alternate strategy): by the startup from the first refueling outage that begins after June 30, 2017 or June 30, 2019, whichever comes first. Currently scheduled for the fall of 2018 If deviations are identified at a later date, then the deviations will be communicated in a future 6 month update following identification. Site Applicable Extreme External Hazard from NEI 12-06, Section 4.0-9.0 List resultant determination of screened in hazards from the EA-12-049 Compliance. Ref: NEI 13-02 Section 5.2.3 and D.1.2 The following extreme external hazards screen-in for JAF: Seismic, Extreme Cold (includes snow and ice), High Wind, Extreme High Temperature, External Flood The following extreme external hazards screen out for JAF: None.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 5 of 48 Key Site assumptions to implement NEI 13-02 HCVS, Phase 1 and 2 Actions. Provide key assumptions associated with implementation of HCVS Phase 1 and Phase 2 Actions Ref: NEI 13-02, Revision 1, Section 2 NEI 12-06 Revision 0 Mark I/II Generic EA-13-109 Phase 1 and Phase 2 Related Assumptions: Applicable EA-12-049 assumptions: 049-1. Assumed initial plant conditions are as identified in NEI 12-06 section 3.2.1.2 items 1 and 2. 049-2. Assumed initial conditions are as identified in NEI 12-06 section 3.2.1.3 items 1, 2, 4, 5, 6 and 8 049-3. Assumed reactor transient boundary conditions are as identified in NEI 12-06 section 3.2.1.4 items 1, 2, 3 and 4 049-4. No additional events or failures are assumed to occur immediately prior to or during the event, including security events except for failure of RCIC or HPCI. (Reference NEI 12-06 3.2.1.3 item 9) 049-5. At Time=0 the event is initiated and all rods insert and no other event beyond a common site ELAP is occurring at any or all of the units. (NEI 12-06, section 3.2.1.3 item 9 and 3.2.1.4 item 1-4) 049-6. At 60 minutes (time critical at a time greater than 1 hour) an ELAP is declared and actions begin as defined in EA-12-049 compliance 049-7. DC power and distribution can be credited for the duration determined per the EA-12-049 (FLEX) methodology for battery usage (up to 10 hours). This assumption applies to the water addition capability under SAWA/SAWM. The power supply scheme for the HCVS shall be in accordance with EA-13-109 and the applicable guidance. (NEI 12-06, section 3.2.1.3 item 8) 049-8. Deployment resources are assumed to begin arriving at hour 6 and fully staffed by 24 hours 049-9. All activities associated with plant specific EA-12-049 FLEX strategies that are not specific to implementation of the HCVS, including such items as debris removal, communication, notification, SFP level and makeup, security response, opening doors for cooling, and initiating conditions for the event, can be credited as previously evaluated for FLEX. (Refer to assumption 109-02 below for clarity on SAWA)(HCVS-FAQ-11) Applicable EA-13-109 generic assumptions: 109-01. Site response activities associated with EA-13-109 actions are considered to have no access limitations associated with radiological impacts while RPV level is above 2/3 core height (core damage is not expected). This is further addressed in HCVS-FAQ-12 109-02. Portable equipment can supplement the installed equipment after 24 hours provided the portable equipment credited meets the criteria applicable to the HCVS. An example is use of FLEX portable air supply equipment that is credited to recharge air lines for HCVS components after 24 hours. The FLEX portable air supply used must be demonstrated to meet the SA Capable criteria that are defined in NEI 13-02 Section 4.2.4.2 and Appendix D Section D.1.3. This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment needs to be connected and placed in service within 8 hours from the time of the loss of RPV injection. (reference HCVS-FAQ-

12) 109-03. SFP level is maintained with either on-site or off-site resources such that the SFP does not contribute to the analyzed source term (Reference HCVS-FAQ-07).

109-04. Existing containment components design and testing values are governed by existing plant primary containment criteria (e.g., Appendix J) and are not subject to the testing criteria from NEI 13-02 (reference HCVS-FAQ-05 and NEI 13-02 section 6.2.2). 109-05. Classical design basis evaluations and assumptions are not required when assessing the operation of the HCVS. The reason this is not required is that the order postulates an unsuccessful mitigation of an event such that an ELAP progresses to a severe accident with ex-vessel core debris which classical design basis evaluations are intended to

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 6 of 48 prevent. (Reference NEI 13-02 section 2.3.1). 109-06. HCVS manual actions that require minimal operator steps and can be performed in the postulated thermal and radiological environment at the location of the step(s) (e.g., load stripping, control switch manipulation, valving-in nitrogen bottles) are acceptable to obtain HCVS venting dedicated functionality. (reference HCVS-FAQ-01) This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment needs to be connected and placed in service within 8 hours from the time of the loss of RPV injection and will require more than minimal operator action. 109-07. HCVS dedicated equipment is defined as vent process elements that are required for the HCVS to function in an ELAP event that progresses to core melt ex-vessel. (reference HCVS-FAQ-02 and White Paper HCVS-WP-01). This assumption does not apply to Phase 2 SAWA/SAWM because SAWA equipment is not dedicated to HCVS but shared to support FLEX functions. This is further addressed in HCVS-FAQ-11. 109-08. Use of MAAP Version 4 or higher provides adequate assurance of the plant conditions (e.g., RPV water level, temperatures, etc.) assumed for Order EA-13-109 BDBEE and SA HCVS operation. (reference FLEX MAAP Endorsement ML13190A201) Additional analysis using RELAP5/MOD 3, GOTHIC, PCFLUD, LOCADOSE and SHIELD are acceptable methods for evaluating environmental conditions in areas of the plant provided the specific version utilized is documented in the analysis. MAAP Version 5 was used to develop EPRI Technical Report 3002003301 to support drywell temperature response to SAWA under severe accident conditions. 109-09. NRC Published Accident evaluations (e.g. SOARCA, SECY-12-0157, and NUREG 1465) as related to Order EA-13-109 conditions are acceptable as references. (Reference NEI 13-02 section 8). 109-10. Permanent modifications installed or planned per EA-12-049 are assumed implemented and may be credited for use in EA-13-109 Order response. 109-11. This Overall Integrated Plan is based on Emergency Operating Procedure changes consistent with EPG/SAGs Revision 3 as incorporated per the sites EOP/SAMG procedure change process. This assumption does not apply to Phase 2 SAWM because SAWM is not part of revision 3.(reference to Attachment 2.1.D for SAWM SAMG Changes approved by the BWROG Emergency Procedures Committee) 109-12. Under the postulated scenarios of Order EA-13-109 the Control Room is adequately protected from excessive radiation dose due to its distance and shielding from the reactor (per General Design Criterion (GDC) 19 in 10CFR50 Appendix A) and no further evaluation of its use as the preferred HCVS control location is required provided that the HCVS routing is a sufficient distance away from the MCR or is shielded to minimize impact to the MCR dose. In addition, adequate protective clothing and respiratory protection are available if required to address contamination issues. (reference HCVS-FAQ-01 and HCVS-FAQ-09) 109-13. The suppression pool/wetwell of a BWR Mark I/II containment is considered to be bounded by assuming a saturated environment for the duration of the event response because of the water/steam interactions. 109-14. RPV depressurization is directed by the EPGs in all cases prior to entry into the SAGs. (reference NEI 13-02 Rev 1, §I.1.3) 109-15 The Severe Accident impacts are assumed on one unit only due to the site compliance with NRC Order EA-12-049. However, each BWR Mk I and II under the assumptions of NRC Order EA-13-109 ensure the capability to protect containment exists for each unit. (HCVS-FAQ-1) This is further addressed in HCVS-FAQ-10 Plant Specific HCVS Related Assumptions/Characteristics: None.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 7 of 48 Part 2: Boundary Conditions for Wet Well Vent Provide a sequence of events and identify any time or environmental constraint required for success including the basis for the constraint. HCVS Actions 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, action to open vent valves). HCVS Actions that have an environmental constraint (e.g. actions in areas of High Thermal stress or High Dose areas) should be evaluated per guidance. Describe in detail in this section the technical basis for the constraints identified on the sequence of events timeline attachment. See attached sequence of events timeline (Attachment 2A) Ref: EA-13-109 Section 1.1.1, 1.1.2, 1.1.3 / NEI 13-02 Section 4.2.5, 4.2.6. 6.1.1 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Provide a sequence of events and identify any time or environmental constraint required for success including the basis for the constraint. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Provide Details on the Vent characteristics Provide Details on the Vent characteristics Vent Size and Basis (EA-13-109 Section 1.2.1 / NEI 13-02 Section 4.1.1) What is the plants licensed power? Discuss any plans for possible increases in licensed power (e.g. MUR, EPU). What is the nominal diameter of the vent pipe in inches/ Is the basis determined by venting at containment design pressure, Primary Containment Pressure Limit (PCPL), or some other criteria (e.g. anticipatory venting)? Vent Capacity (EA-13-109 Section 1.2.1 / NEI 13-02 Section 4.1.1) Indicate any exceptions to the 1% decay heat removal criteria, including reasons for the exception. Provide the heat capacity of the suppression pool in terms of time versus pressurization capacity, assuming suppression pool is the injection source. Vent Path and Discharge (EA-13-109 Section 1.1.4, 1.2.2 / NEI 13-02 Section 4.1.3, 4.1.5 and Appendix F/G) Provides a description of Vent path, release path, and impact of vent path on other vent element items. Power and Pneumatic Supply Sources (EA-13-109 Section 1.2.5 & 1.2.6 / NEI 13-02 Section 4.2.3, 2.5, 4.2.2, 4.2.6, 6.1) Provide a discussion of electrical power requirements, including a description of dedicated 24 hour power supply from permanently installed sources. Include a similar discussion as above for the valve motive force requirements. Indicate the area in the plant from where the installed/dedicated power and pneumatic supply sources are coming Indicate the areas where portable equipment will be staged after the 24 hour period, the dose fields in the area, and any shielding that would be necessary in that area. Any shielding that would be provided in those areas

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 8 of 48 Part 2: Boundary Conditions for Wet Well Vent Location of Control Panels (EA-13-109 Section 1.1.1, 1.1.2, 1.1.3, 1.1.4, 1.2.4, 1.2.5 / NEI 13-02 Section 4.1.3, 4.2.2, 4.2.3, 4.2.5, 4.2.6, 6.1.1 and Appendix F/G) Indicate the location of the panels, and the dose fields in the area during severe accidents and any shielding that would be required in the area. This can be a qualitative assessment based on criteria in NEI 13-02. Hydrogen (EA-13-109 Section 1.2.10, 1.2.11, 1.2.12 / NEI 13-02 Section 2.3,2.4, 4.1.1, 4.1.6, 4.1.7, 5.1, & Appendix H) State which approach or combination of approaches the plant will take to address the control of flammable gases, clearly demarcating the segments of vent system to which an approach applies Unintended Cross Flow of Vented Fluids (EA-13-109 Section 1.2.3, 1.2.12 / NEI 13-02 Section 4.1.2, 4.1.4, 4.1.6 and Appendix H) Provide a description to eliminate/minimize unintended cross flow of vented fluids with emphasis on interfacing ventilation systems (e.g. SGTS). What design features are being included to limit leakage through interfacing valves or Appendix J type testing features? Prevention of Inadvertent Actuation (EA-13-109 Section 1.2.7/NEI 13-02 Section 4.2.1) The HCVS shall include means to prevent inadvertent actuation Component Qualifications (EA-13-109 Section 2.1 / NEI 13-02 Section 5.1, 5.3) State qualification criteria based on use of a combination of safety related and augmented quality dependent on the location, function and interconnected system requirements Monitoring of HCVS (Order Elements 1.1.4, 1.2.8, 1.2.9/NEI 13-02 4.1.3, 4.2.2, 4.2.4, and Appendix F/G) Provides a description of instruments used to monitor HCVS operation and effluent. Power for an instrument will require the intrinsically safe equipment installed as part of the power sourcing Component reliable and rugged performance (EA-13-109 Section 2.2 / NEI 13-02 Section 5.2, 5.3) HCVS components including instrumentation should be designed, as a minimum, to meet the seismic design requirements of the plant. Components including instrumentation that are not required to be seismically designed by the design basis of the plant should be designed for reliable and rugged performance that is capable of ensuring HCVS functionality following a seismic event. (reference ISG-JLD-201201 and ISG-JLD-2012-03 for seismic details.) The components including instrumentation external to a seismic category 1 (or equivalent building or enclosure should be designed to meet the external hazards that screen-in for the plant as defined in guidance NEI 12-06 as endorsed by JLD-ISG-12-01 for Order EA-12-049. Use of instruments and supporting components with known operating principles that are supplied by manufacturers with commercial quality assurance programs, such as ISO9001. The procurement specifications shall include the seismic requirements and/or instrument design requirements, and specify the need for commercial design standards and testing under seismic loadings consistent with design basis values at the instrument locations. Demonstration of the seismic reliability of the instrumentation through methods that predict performance by analysis, qualification testing under simulated seismic conditions, a combination of testing and analysis, or the use of experience data. Guidance for these is based on sections 7, 8, 9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, or a substantially similar industrial standard could be used. Demonstration that the instrumentation is substantially similar in design to instrumentation that has been previously tested to seismic loading levels in accordance with the plant design basis at the location where the instrument is to be

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 9 of 48 Part 2: Boundary Conditions for Wet Well Vent installed (g-levels and frequency ranges). Such testing and analysis should be similar to that performed for the plant licensing basis. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 10 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: BDBEE Venting Determine venting capability for BDBEE Venting, such as may be used in an ELAP scenario to mitigate core damage. Ref: EA-13-109 Section 1.1.4 / NEI 13-02 Section 2.2 First 24 Hour Coping Detail Provide a general description of the venting actions for first 24 hours using installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.6 / NEI 13-02 Section 2.5, 4.2.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Greater Than 24 Hour Coping Detail Provide a general description of the venting actions for greater than 24 hours using portable and installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.4, 1.2.8 / NEI 13-02 Section 4.2.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Details: Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. NEI 13-02 §6.1.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Identify modifications: List modifications and describe how they support the HCVS Actions. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Key Venting Parameters: List instrumentation credited for this venting actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order)

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 11 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: BDBEE Venting Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 12 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: Severe Accident Venting Determine venting capability for Severe Accident Venting, such as may be used in an ELAP scenario to mitigate core damage. Ref: EA-13-109 Section 1.2.10 / NEI 13-02 Section 2.3 First 24 Hour Coping Detail Provide a general description of the venting actions for first 24 hours using installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.6 / NEI 13-02 Section 2.5, 4.2.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Details: Provide a general description of the venting actions for greater than 24 hours using portable and installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.4, 1.2.8 / NEI 13-02 Section 4.2.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. First 24 Hour Coping Detail Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Identify modifications: List modifications and describe how they support the HCVS Actions. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Key Venting Parameters: List instrumentation credited for the HCVS Actions. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order)

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 13 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: Severe Accident Venting Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 14 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: HCVS Support Equipment Functions Determine venting capability support functions needed Ref: EA-13-109 Section 1.2.8, 1.2.9 / NEI 13-02 Section 2.5, 4.2.4, 6.1.2 BDBEE Venting Provide a general description of the BDBEE Venting actions support functions. Identify methods and strategy(ies) utilized to achieve venting results. Ref: EA-13-109 Section 1.2.9 / NEI 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Severe Accident Venting Provide a general description of the Severe Accident Venting actions support functions. Identify methods and strategy(ies) utilized to achieve venting results. Ref: EA-13-109 Section 1.2.8, 1.2.9 / NEI 13-02 Section 2.5, 4.2.2, 4.2.4, 6.1.2 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Details Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Identify modifications: List modifications and describe how they support the HCVS Actions. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Key Support Equipment Parameters: List instrumentation credited for the support equipment utilized in the venting operation. Clearly indicate which of those already exist in the plant and what others will be newly installed (to comply with the vent order) Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 15 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: HCVS Support Equipment Functions Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 16 of 48 Part 2: Boundary Conditions for Wet Well Vent Part 2 Boundary Conditions for WW Vent: HCVS Venting Portable Equipment Deployment Provide a general description of the venting actions using portable equipment including modifications that are proposed to maintain and/or support safety functions. Ref: EA-13-109 Section 3.1 / NEI 13-02 Section 6.1.2, D.1.3.1 Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Details: Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. HCVS Actions Modifications Protection of connections Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 17 of 48 Part 3: Boundary Conditions for EA-13-109, Option B.2 General: Licensees that use Option B.1 of EA-13-109 (SA Capable DW Vent without SAWA) must develop their own OIP. This template does not provide guidance for that option. Licensees using Option B.2 of EA-13-109 (SAWA and SAWM or 545°F SADW Vent (SADV) with SAWA) may use this template for their OIP submittal. Both SAWM and SADV require the use of SAWA and may not be done independently. The HCVS actions under Part 2 apply to all of the following: This Part is divided into the following sections: 3.1: Severe Accident Water Addition (SAWA) 3.1.A: Severe Accident Water Management (SAWM) 3.1.B: Severe Accident DW Vent (545 deg F) Provide a sequence of events and identify any time constraint required for success including the basis for the time constraint. SAWA and SAWM or SADV Actions supporting SA conditions 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). Actions already identified under the HCVS part of this template need not be repeated here. The time to establish the water addition capability into the RPV or DW should be less than 8 hours from the onset of the loss of all injection sources. Electrical generators satisfying the requirements of EA-12-049 may be credited for powering components and instrumentation needed to establish a flow path. Time Sensitive Actions (TSAs) for the purpose of SAWA are those actions needed to transport, connect and start portable equipment needed to provide SAWA flow or provide power to SAWA components in the flow path between the connection point and the RPV or drywell. Actions needed to establish power to SAWA instrumentation should also be included as TSAs. Ref: NEI 13-02 Section 6.1.1.7.4.1, I.1.4, I.1.5 The operation of the HCVS using SAWA and SAWM/SADV will be designed to minimize the reliance on operator actions in response to hazards listed in Part 1. Initial operator actions will be completed by plant personnel and will include the capability for remote-manual initiation from the HCVS Operating Station and locally at the Screenwell Building. Timelines (see attachments 2.1.A and 2.1.C for SAWA/ SAWM) were developed to identify required operator response times and actions. The timelines are an expansion of Attachment 2A and begin either as core damage occurs (SAWA) or after initial SAWA injection is established and as flowrate is adjusted for option B.2 (SAWM). The timelines do not assume the core is ex-vessel and the actions taken are appropriate for both in-vessel and ex-vessel core damage conditions.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 18 of 48 Part 3.1: Boundary Conditions for SAWA Table 3.1 - SAWA Manual Actions Primary Action Primary Location / Component Notes

1. Establish HCVS capability in accordance with Part 2 of this guidance.

HCVS Operating Station Applicable to SAWA/SAWM strategy

2. Lineup valves appropriate for RPV injection in accordance with EA-12-049 Reactor Building /

Screenwell Building

3. Power SAWA/HCVS components with EA-12-049 (FLEX) generator Electrical Bay
4. Connect SAWA (diesel fire) pump discharge to injection piping RHR Crosstie at Screenwell Building
5. Inject to RPV using SAWA (diesel fire) pump Initial SAWA injection rate is 361 gpm based on ratio of 500 gpm at the reference plant power level of 3514 MW
6. Monitor SAWA indications RHR Crosstie at Screenwell Building MCR Pump Flow
7. Use SAWM to maintain availability of the WW vent (Part 3.1.A)

MCR and Screenwell Building Monitor DW Pressure and Suppression Pool Level in MCR Control SAWA using manual valves in Screenwell Building Discussion of timeline SAWA identified items HCVS operations are discussed under Phase 1 of EA-13-109. 8 Hours - Establish electrical power and other EA-12-049 actions needed to support the strategies for EA-13-109, Phase 1 and Phase 2. Action being taken within the Reactor Building under EA-12-049 conditions after RPV level lowers to 2/3 core height must be evaluated for radiological conditions assuming permanent containment shielding remains intact. (HCVS-FAQ-12) All other actions required are assumed to be in-line with the FLEX timeline submitted in accordance with the EA-12-049 requirements. Less than 8 Hours - Initiate SAWA flow to the RPV. Having the HCVS in service will assist in minimizing the peak DW pressure during the initial cooling conditions provided by SAWA. Severe Accident Operation

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 19 of 48 Part 3.1: Boundary Conditions for SAWA Determine operating requirements for SAWA, such as may be used in an ELAP scenario to mitigate core damage. Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section I.1.6, I.1.4.4 It is anticipated that SAWA will be used in Severe Accident Events based on presumed failure of injection systems or presumed failure to implement an injection system in a timely manner leading to core damage. This does not preclude the use of the SAWA system to supplement or replace the EA-12-049 injection systems if desired. SAWA will consist of both portable and installed equipment. The motive force equipment needed to support the SAWA strategy shall be available prior to t=8 hours from the loss of injection (assumed at T=0). The SAWA flow path includes methods to minimize exposure of personnel to radioactive liquids / gases and potentially flammable conditions by inclusion of backflow prevention. RHR LPCI injection mode has installed ECCS check valves to prevent backflow (10AOV-68A) qualified for accident scenarios. Description of SAWA actions for first 24 hours: T<1 hr: No evaluation required for actions inside the Reactor Building for SAWA. No expected actions inside the Reactor Building for SAWA. T=1 - 8 hr: Evaluation of core gap and early in vessel release impact to Reactor Building access for SAWA actions is required. It is assumed that Reactor Building access is limited due to the source term at this time unless otherwise noted. (Refer to HCVS-FAQ-12 for actions in T=1-7 hr). Manually open and close valves within the Reactor Building to establish flow path to RPV. Table 3.1, Step

2.

Establish electrical power for SAWA systems and indications using EA-12-049, or other systems. Table 3.1, Step 3. Establish flow to the RPV using SAWA systems. Begin injection at a maximum rate, not to exceed 500 gpm. T8 - 12 hr: Continue injection for 4 hours after SAWA injection begins at initial SAWA rate. T 12 hrs: Proceed to SAWM actions (Part 3.1.A). Table 3.1, Step 7. Greater Than 24 Hour Coping Detail Provide a general description of the SAWA actions for greater than 24 hours using portable and installed equipment including station modifications that are proposed. Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3/ NEI 13-02 Section 4.2.2.4.1.3.1, I.1.4,

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 20 of 48 Part 3.1: Boundary Conditions for SAWA SAWA Operation is the same for the full period of sustained operation. If SAWM is employed flow rates will be directed to preserve the availability of the HCVS wetwell vent (see 3.1.A). Details: Details of Design Characteristics/Performance Specifications SAWA shall be capable of providing a RPV injection rate of 361 gpm within 8 hours of a loss of all RPV injection following an ELAP/Severe Accident. SAWA shall meet the design characteristics of the HCVS with the exception of the dedicated 24 hour power source. Hydrogen mitigation is provided by backflow prevention for SAWA. Ref: EA-13-109 Attachment 2, Section B.2.1, B.2.2, B.2.3/ NEI 13-02 Section I.1.4 Equipment Locations/Controls/Instrumentation The locations of the SAWA equipment and controls, as well as ingress and egress paths will be evaluated for the expected severe accident conditions (temperature, humidity, radiation) for the Sustained Operating period. Equipment will be evaluated to remain operational throughout the Sustained Operating period. Personnel exposure and temperature / humidity conditions for operation of SAWA equipment will not exceed the limits for ERO dose and plant safety guidelines for temperature and humidity. The flow path will be from the FLEX (diesel fire) pump suction in Lake Ontario through the FLEX pumps with a common outlet including a flow indicator that will be used for FLEX and HCVS Phase 2. The indicator will be monitoring the flow that is provided to the RHR service water FLEX header. The monitored water flow rate will pass through the RHRSW piping to the Reactor Building where it will connect with the RHR system by opening MOVs from the MCR that interconnect the systems. The flow will then be directed into the RPV via the LPCI injection valves. Cross flow into other portions of the RHR system will be isolated by manually closing the required MOVs using the available handwheels. DW pressure and Suppression Pool level will be monitored and flow rate will be adjusted by use of the FLEX pump control valve at the Screenwell Building. Communication will be established between the MCR and the FLEX pump location. The FLEX DGs are located in either the west side of the DG Building or north side of the Screenwell Building, which is significantly away from the discharge of the HCVS above the Reactor Building. Refueling of the FLEX DG will be accomplished from the EDG fuel oil tanks as described in the EA-12-049 compliance documents. The Screenwell Building is a significant distance from the discharge of the HCVS above the Reactor Building. Evaluations will be performed for projected SA conditions (radiation / temperature) to indicate that personnel can complete the initial and support activities without exceeding the ERO-allowable dose for equipment operation or site safety standards. (reference HCVS-WP-02, Plant-Specific Dose Analysis for the Venting of Containment during the SA Conditions) Electrical equipment and instrumentation will be powered from the existing station batteries, and from AC distribution systems that are powered from the EA-12-049 generator(s). The battery chargers are also powered from the EA-12-049 generator(s) to maintain the battery capacities during the Sustained Operating period. The indications include (*minimum required):

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 21 of 48 Part 3.1: Boundary Conditions for SAWA Parameter Instrument Location Power Source / Notes

  • DW Pressure 27PI-115A1, 2, 27PI-115B1, 2 MCR Station batteries via EA-12-049 generator
  • Torus Level 23LI-202A, B MCR Station batteries via EA-12-049 generator
  • SAWA Flow FLEX Pump Flow indicator Intake Crosstie Self Powered (1 Year Battery)

The instrumentation and equipment being used for SAWA and supporting equipment will be evaluated to perform for the Sustained Operating period under the expected radiological and temperature conditions. Equipment Protection Any SAWA component and connections external to protected buildings have been protected or have site specific evaluations for the screened-in hazards of EA-12-049 for the station. Portable equipment used for SAWA implementation will meet the protection requirements for storage in accordance with the criteria in NEI 12-06 Revision

0.

Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 5.1.1, 5.4.6, I.1.6 Provide a brief description of Procedures / Guidelines: Confirm that procedure/guidance exists or will be developed to support implementation. Ref: EA-13-109 Attachment 2, Section A.3.1, B.2.3 / NEI 13-02 Section 1.3, 6.1.2 Hook-up and start FLEX DG to repower Emergency Switchgear 71L25 Manually open 10MOV-148A and 10MOV-149A to cross tie RHR with RHRSW Open 10MOV-25A and 10MOV-27A (normally open) for RHR LPCI injection pathway (manually or from MCR using LPCI batteries) Manually close 10RHR-11A Install FLEX hose and flow indicator between valves 76FPS-720 and 10RHR-432 to crosstie FP with RHRSW Start FLEX (diesel fire) pump Adjust flow rate using Screenwell Building crosstie flow indicator and isolation valve Identify modifications: List modifications and describe how they support the SAWA Actions. Ref: EA-13-109 Attachment 2, Section B.2.2, / NEI 13-02 Section 4.2.4.4, 7.2.1.8, Appendix I None.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 22 of 48 Part 3.1: Boundary Conditions for SAWA Component Qualifications: State the qualification used for equipment supporting SAWA Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section I.1.6 Permanently installed plant equipment shall meet the same qualifications as described in Part 2 of this OIP. Temporary/Portable equipment shall be qualified and stored to the same requirements as FLEX equipment as specified in NEI 12-06 Rev 0. SAWA components are not required to meet NEI 13-02, Table 2-1 design conditions. Notes: None Part 3.1.A: Boundary Conditions for SAWA/SAWM Time periods for the maintaining SAWM actions such that the WW vent remains available SAWM Actions supporting SA conditions 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). Actions already identified under the HCVS part of this template need not be repeated here. There are three time periods for maintaining SAWM actions such that the WW vent remains available to remove decay heat from the containment: SAWM can be maintained for >7 days without the need for a drywell vent to maintain pressure below PCPL or containment design pressure, whichever is lower. o Under this approach, no detail concerning plant modifications or procedures is necessary with respect to how alternate containment heat removal will be provided. SAWM can be maintained for at least 72 hours, but less than 7 days before DW pressure reaches PCPL or design pressure, whichever is lower. o Under this approach, a functional description is required of how alternate containment heat removal might be established before DW pressure reaches PCPL or design pressure whichever is lower. Under this approach, physical plant modifications and detailed procedures are not necessary, but written descriptions of possible approaches for achieving alternate containment heat removal and pressure control will be provided. SAWM can be maintained for <72 hours SAWM strategy can be implemented but for less than 72 hours before DW pressure reaches PCPL or design pressure whichever is lower. o Under this approach, a functional description is required of how alternate containment heat removal might be established before DW pressure reaches PCPL or design pressure whichever is lower. Under this approach, physical plant modifications and detailed procedures are required to be implemented to insure achieving alternate containment heat removal and pressure control will be provided for the sustained operating period. Ref: NEI 13-02 Appendix C.7 SAWM can be maintained for >7 days without the need for a drywell vent to maintain pressure below PCPL.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 23 of 48 Part 3.1: Boundary Conditions for SAWA Basis for SAWM time frame Option 1 - SAWM can be maintained greater than or equal to 7 days: The reference plant is the same containment and RPV design (BRW4, Mark I) and has greater generating capacity. In addition, the available JAF Torus freeboard bounds that of the reference plant. Therefore, James A. FitzPatrick is bounded by the evaluations performed in BWROG TP-2015-008 and representative of the reference plant in NEI 13-02 figures C-2 through C-6. Instrumentation relied upon for SAWM operations is Drywell Pressure, Torus level and SAWA flow. This instrumentation will be initially powered by the station DC batteries and will be repowered by the FLEX (EA-12-049) generator, which is placed in-service prior to RPV breach. The FLEX DG will provide power throughout the Sustained Operation period (7 days). DW Temperature monitoring is not a requirement for compliance with Phase 2 of the Order, but some knowledge of temperature characteristics provides information for the operation staff to evaluate plant conditions under a severe accident and provide confirmation to adjust SAWA flow rates. (C.7.1.4.2, C.8.3.1) Torus level indication is maintained throughout the Sustained Operation period, so the HCVS remains in-service. The time to reach the level at which the WW vent must be secured is >7days using SAWM flowrates (C.6.3, C.7.1.4.3)

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 24 of 48 Table 3.1.B - SAWM Manual Actions Primary Action Primary Location / Component Notes

1. Lower SAWA injection rate to control Torus Level and decay heat removal Screenwell Building Control to maintain containment and Torus parameters to ensure Torus vent remains functional.

73 gpm minimum capability is maintained for greater than 7 days based on ratio of 100 gpm at the reference plant power level of 3514 MW

2. Control to SAWM flowrate for containment control / decay heat removal Screenwell Building SAWM flow rates will be monitored using the following instrumentation:

o SAWA (FLEX diesel fire pump) Flow o Torus Level o DW pressure SAWM flow rates will be controlled using manual valves (FLEX hose splitter isolation valve and 10RHR-432)

3. Establish alternate source of decay heat removal Yard
>7 days
4. Secure SAWA / SAWM Screenwell Building When reliable alternate containment decay heat removal is established.

SAWM Time Sensitive Actions Time Sensitive SAWM Actions: 12 Hours - Initiate actions to maintain the Torus vent capability by lowering injection rate, while maintaining the cooling of the core debris (SAWM). Monitor SAWM critical parameters while ensuring the Torus vent remains available. SAWM Severe Accident Operation Determine operating requirements for SAWM, such as may be used in an ELAP scenario to mitigate core damage. Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Appendix C It is anticipated that SAWM will only be used in Severe Accident Events based on presumed failure of plant injection systems per direction by the plant SAMGs. Refer to attachment 2.1.D for SAWM SAMG language additions.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 25 of 48 First 24 Hour Coping Detail Provide a general description of the SAWM actions for first 24 hours using installed equipment including station modifications that are proposed. Given the initial conditions for EA-13-109: BDBEE occurs with ELAP Failure of all injection systems, including steam-powered injection systems Ref: EA-13-109 Section 1.2.6, Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 2.5, 4.2.2, Appendix C, Section C.7 SAWA will be established as described as stated above. SAWM will use the installed instrumentation to monitor and adjust the flow from SAWA to control the pump discharge to deliver flowrates applicable to the SAWM strategy. Once the SAWA initial flow rate has been established for 4 hours, the flow will be reduced while monitoring DW pressure and Torus level. SAWM flowrate can be lowered to maintain containment parameters and preserve the WW vent path. SAWM will be capable of injection for the period of Sustained Operation. Greater Than 24 Hour Coping Detail Provide a general description of the SAWM actions for greater than 24 hours using portable and installed equipment including station modifications that are proposed. Ref: EA-13-109 Section 1.2.4, 1.2.8, Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section 4.2.2, Appendix C, Section C.7 SAWM can be maintained >7 days: The SAWM flow strategy will be the same as the first 24 hours until alternate reliable containment heat removal and pressure control is reestablished. SAWM flow strategy uses the SAWA flow path. No additional modifications are being made for SAWM. Details: Details of Design Characteristics/Performance Specifications Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Section Appendix C SAWM shall be capable of monitoring the containment parameters (DW pressure and Torus Level) to provide guidance on when injection rates shall be reduced, until alternate containment decay heat/pressure control is established. SAWA will be capable of injection for the period of Sustained Operation. Equipment Locations/Controls/Instrumentation Describe location for SAWM monitoring and control. Ref: EA-13-109 Attachment 2, Section B.2.2, B.2.3 / NEI 13-02 Appendix C, Section C.8, Appendix I The SAWM control location is the same as the SAWA control location. Local indication of SAWM flow rate is provided at the pump discharge hose crosstie by a portable flow instrument qualified to operate under the expected environmental conditions. The SAWA flow instrument is self-powered by two (2) lithium 3.6V D batteries. Communications will be established between the SAWM control location and the MCR. Injection flowrate is controlled by the hose splitter valve located on the FLEX supply hose in the Screenwell Building.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 26 of 48 Torus level and DW pressure are read in the control room using indicators powered by the FLEX DG installed under EA-12-049. These indications are used to control SAWM flowrate to the RPV. Key Parameters: List instrumentation credited for the SAWM Actions. Parameters used for SAWM are: DW Pressure Torus Level SAWM Flowrate The Drywell pressure and Torus level instruments are qualified to RG 1.97 equivalent and are the same as listed in part 2 of this OIP. The SAWM flow instrumentation will be qualified for the expected environmental conditions expected when needed. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 27 of 48 Part 3.1.B: Boundary Conditions for SAWA/SADV Applicability of WW Design Considerations This section is not applicable to JAF. Table 3.1.C - SADV Manual Actions Timeline for SADV Severe Accident Venting First 24 Hour Coping Detail Greater Than 24 Hour Coping Detail Details:

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 28 of 48 Part 4: Programmatic Controls, Training, Drills and Maintenance Identify how the programmatic controls will be met. Provide a description of the programmatic controls equipment protection, storage and deployment and equipment quality addressing the impact of temperature and environment Ref: EA-13-109 Section 1.2.10, 3.1, 3.2 / NEI 13-02 Sections 5, 6.1.2, 6.1.3, 6.2 Program Controls: The HCVS venting actions will include: Site procedures and programs are being developed in accordance with NEI 13-02 to address use and storage of portable equipment relative to the Severe Accident defined in NRC Order EA-13-109 and the hazards applicable to the site per Part 1 of this OIP. Routes for transporting portable equipment from storage location(s) to deployment areas will be developed as the response details are identified and finalized. The identified paths and deployment areas will be analyzed for radiation and temperature to ensure they are accessible during Severe Accidents. Procedures: Procedures will be established for system operations when normal and backup power is available, and during ELAP conditions. The HCVS procedures will be developed and implemented following the plants process for initiating or revising procedures and contain the following details: appropriate conditions and criteria for use of the HCVS when and how to place the HCVS in operation, the location of system components, instrumentation available, normal and backup power supplies, directions for sustained operation, including the storage location of portable equipment, training on operating the portable equipment, and testing of portable equipment James A. FitzPatrick will establish provisions for out-of-service requirements of the HCVS and compensatory measures. The following provisions will be documented in a controlled document: The provisions for out-of-service requirements for HCVS/SAWA functionality are applicable in Modes 1, 2 and 3. If for up to 90 consecutive days, the primary or alternate means of HCVS/SAWA operation are non-functional, no compensatory actions are necessary. If for up to 30 days, the primary and alternate means of HCVS/SAWA operation are nonfunctional, no compensatory actions are necessary. If the out of service times exceed 30 or 90 days as described above, the following actions will be performed through the sites corrective action program: o The cause(s) of the non-functionality o The actions to be taken and the schedule for restoring the system to functional status and prevent recurrence o Initiate action to implement appropriate compensatory actions, and

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 29 of 48 Part 4: Programmatic Controls, Training, Drills and Maintenance o Restore full HCVS functionality at the earliest opportunity not to exceed one full operating cycle. Describe training plan List training plans for affected organizations or describe the plan for training development Ref: EA-13-109 Section 3.2 / NEI 13-02 Section 6.1.3 Personnel expected to perform direct execution of the HCVS/SAWA/SAWM actions will receive necessary training in the use of plant procedures for system operations when normal and backup power is available and during ELAP conditions. The training will be refreshed on a periodic basis and as any changes occur to the HCVS/SAWA/SAWM actions, systems or strategies. Training content and frequency will be established using the Systematic Approach to Training (SAT) process. Identify how the drills and exercise parameters will be met. Alignment with NEI 13-06 and 14-01 as codified in NTTF Recommendation 8 and 9 rulemaking The Licensee should demonstrate use of the HCVS/SAWA/SAWM system in drills, tabletops, or exercises as follows: Hardened containment vent operation on normal power sources (no ELAP). During FLEX demonstrations (as required by EA-12-049: Hardened containment vent operation on backup power and from primary or alternate location during conditions of ELAP/loss of UHS with no core damage. System use is for containment heat removal AND containment pressure control. HCVS operation on backup power and from primary or alternate location during conditions of ELAP/loss of UHS with core damage. System use is for containment heat removal AND containment pressure control with potential for combustible gases (Demonstration may be in conjunction with SAG change). Operation for sustained period with SAWA and SAWM to provide decay heat removal and containment pressure control. Ref: EA-13-109 Section 3.1 / NEI 13-02 Section 6.1.3 The site will utilize the guidance provided in NEI 13-06 and 14-01 for guidance related to drills, tabletops, or exercises for HCVS operation. In addition, the site will integrate these requirements with compliance to any rulemaking resulting from the NTTF Recommendations 8 and 9. Describe maintenance plan: Describe the elements of the maintenance plan The maintenance program should ensure that the HCVS/SAWA/SAWM equipment reliability is being achieved in a manner similar to that required for FLEX equipment. Standard industry templates (e.g., EPRI) and associated bases may be developed to define specific maintenance and testing. o Periodic testing and frequency should be determined based on equipment type, expected use and manufacturers recommendations (further details are provided in Part 6 of this document). o Testing should be done to verify design requirements and/or basis. The basis should be documented and deviations from vendor recommendations and applicable standards should be justified. o Preventive maintenance should be determined based on equipment type and expected use. The basis should be documented and deviations from vendor recommendations and applicable standards should be justified.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 30 of 48 Part 4: Programmatic Controls, Training, Drills and Maintenance o Existing work control processes may be used to control maintenance and testing. HCVS/SAWA permanent installed equipment should be maintained in a manner that is consistent with assuring that it performs its function when required. o HCVS/SAWA permanently installed equipment should be subject to maintenance and testing guidance provided to verify proper function. HCVS/SAWA non-installed equipment should be stored and maintained in a manner that is consistent with assuring that it does not degrade over long periods of storage and that it is accessible for periodic maintenance and testing. Ref: EA-13-109 Section 1.2.13 / NEI 13-02 Section 5.4, 6.2 James A. FitzPatrick will utilize the standard EPRI industry PM process (Similar to the Preventive Maintenance Basis Database) for establishing the maintenance calibration and testing actions for HCVS/SAWA/SAWM components. The control program will include maintenance guidance, testing procedures and frequencies established based on type of equipment and considerations made within the EPRI guidelines. James A. FitzPatrick will implement the following operation, testing and inspection requirements for the HCVS and SAWA to ensure reliable operation of the system. Table 4-1: Testing and Inspection Requirements Description Frequency Cycle the HCVS and installed SAWA valves1 and the interfacing system boundary valves not used to maintain containment integrity during Mode 1, 2 and 3. For HCVS valves, this test may be performed concurrently with the control logic test described below. Once per every2 operating cycle Cycle the HCVS and installed SAWA check valves not used to maintain containment integrity during unit operations3 Once per every other4 operating cycle Perform visual inspections and a walk down of HCVS and installed SAWA components Once per every other4 operating cycle Functionally test the HCVS radiation monitors. Once per operating cycle Leak test the HCVS.

1. Prior to first declaring the system functional;
2. Once every three operating cycles thereafter; and
3. After restoration of any breach of system boundary within the buildings

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 31 of 48 Part 4: Programmatic Controls, Training, Drills and Maintenance Validate the HCVS operating procedures by conducting an open/close test of the HCVS control function from its control location and ensuring that all HCVS vent path and interfacing system boundary valves5 move to their proper (intended) positions. Once per every other operating cycle 1 Not required for HCVS and SAWA check valves. 2 After two consecutive successful performances, the test frequency may be reduced to a maximum of once per every other operating cycle. 3 Not required if integrity of check function (open and closed) is demonstrated by other plant testing requirements. 4 After two consecutive successful performances, the test frequency may be reduced by one operating cycle to a maximum of once per every fourth operating cycle. 5 Interfacing system boundary valves that are normally closed and fail closed under ELAP conditions (loss of power and/or air) do not require control function testing under this part. Performing existing plant design basis function testing or system operation that reposition the valve(s) to the HCVS required position will meet this requirement without the need for additional testing. Notes: None

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 32 of 48 Part 5: Milestone Schedule Provide a milestone schedule 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. Ref: EA-13-109 Section D.1, D.3 / NEI 13-02 Section 7.2.1 The following milestone schedules are 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 6 month status reports. Phase 1 Milestone Schedule: Phase 1 Milestone Schedule: See Phase 1 schedule update issued as part of the 6-month updates. Phase 2 Milestone Schedule: Phase 2 Milestone Schedule Milestone Target Completion Date Activity Status Comments Hold preliminary/conceptual design meeting Oct 2015 Complete Submit Overall Integrated Implementation Plan Dec 2015 Complete Submit 6 Month Status Report Jun 2016 Not Started Submit 6 Month Status Report Dec 2016 Not Started Submit 6 Month Status Report Jun 2017 Not Started Design Engineering On-site/Complete Jun 2017 Not Started Submit 6 Month Status Report Dec 2017 Not Started Operations Procedure Changes Developed Jun 2018 Not Started Site Specific Maintenance Procedure Developed Jun 2018 Not Started Training Complete Jun 2018 Not Started Submit 6 Month Status Report Jun 2018 Not Started Implementation Outage Sep 2018 Not Started Walk Through Demonstration/Functional Test Sep 2018 Not Started Procedure Changes Active Sep 2018 Not Started Submit Completion Report Nov 2018 Not Started Notes: None

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 33 of 48

HCVS/SAWA Portable Equipment List portable equipment BDBEE Venting Severe Accident Venting Performance Criteria Maintenance / PM requirements The portable equipment listed below supports SAWA/SAWM (Phase 2).

For a list of Phase 1 HCVS Equipment, refer to the Phase 1 Overall Integrated Plan and associated 6 month updates FLEX DG (and associated equipment) X X 200 kW Per Response to EA-12-049 4 Hose (5) X X Per Response to EA-12-049 Flow Instrument / Indicator X X 0 - 500 gpm minimum Per Response to EA-12-049

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 A: Sequence of Events Timeline - HCVS This EA-13-109 Phase 1 Overall Integrated Plan timeline is updated to reflect SA WA injection RCIC SBO starts t=Os t" 1 m No Injection t = 5.5 hrs Anticipatory Venting t = 8 hrs Portable generator in place for FLEX. May also be able to power HCVS DC power supply> 23 hours (JAF FLEX OIP) Containment Venting (based on preventing exceeding containment design pressure; anticipatory venting not represented in SOARCA) I I t t" 1 hr t" 8 hr Legend Adequate core cooling maintained Injection Lost t = 23 hrs Begin Monitoring HCVS pneumatic supply and DC power supply status. No replenishment expected to be required for at least 24 hours. t" 18 hrs No Injection Containment Venting (anticipatory venting not Represented in SECY-12-0157) evel at t = 24 hrs Replenishment of HCVS DC power supply and pneumatic supplies. Case 1 FLEX Successful Ref: JAF FLEX OIP L l ~ c-2

  • cmm--------c*t------41---+ RCIC Late Failure t" 23 hrs t" 24 hrs t" 34 hrs Ref: SECY-12-0157

!~ion Begins

References:

Case 1: JAF FLEX Overall Integrated Plan Case 2: SECY-12-0157 - ML12344A030 Case 3: SOARCA-ML13150A053 Case 3 RCIC Early Failure Ref SOARCA Not to Scale Increased shine and leakage of radionuclides primarily from Wetwell HCVS Post Core Damage Dose Evaluation Required Page 34 of 48

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 35 of 48 .1.A: Sequence of Events Timeline - SAWA / SAWM T=8hr T=72hr T=168hr SAWAInjection Flowbegins(<500gpm) SustainedOperationPeriod ControlSAWMflowrate usingdrywellpressure andToruslevel indications T=12hr

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 36 of 48 .1.B: Sequence of Events Timeline - SADV This is not applicable to JAF.

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 37 of 48 .1.C: SAWA / SAWM Plant-Specific Datum NormalTorusLevel(NTL) El.2440(168) LevelInstrumentRange El.2317toEl.2576 (19to330) FreeboardHeight 162(136) AdditionalFreeboardHeight 24(20) DrywellFloor 2566

  • Torus Water Volume:

o 244-0: 810,000 gallons o 256-6: 1,642,000 gallons Estimated injection in 7 days: 769,920 gallons Estimated Torus Water Volume at 7 days: 1,579,920 gallons

  • Gross values without consideration for internal structures BottomofTorus El.2300(0)

SAWVEl.2596 (354) DrywellVentPipeIntersectionwith DrywellShell 25711

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 38 of 48 .1.D: SAWM SAMG Approved Language The following general cautions, priorities and methods will be evaluated for plant specific applicability and incorporated as appropriate into the plant specific SAMGs using administrative procedures for EPG/SAG change control process and implementation. SAMGs are symptom based guidelines and therefore address a wide variety of possible plant conditions and capabilities while these changes are intended to accommodate those specific conditions assumed in Order EA-13-109. The changes will be made in a way that maintains the use of SAMGs in a symptom based mode while at the same time addressing those conditions that may exist under extended loss of AC power (ELAP) conditions with significant core damage including ex-vessel core debris. Actual Approved Language that will be incorporated into site SAMG* Cautions: Addressing the possible plant response associated with adding water to hot core debris and the resulting pressurization of the primary containment by rapid steam generation. Addressing the plant impact that raising Torus water level above the elevation of the suppression chamber vent opening elevation will flood the suppression chamber vent path. Priorities: With significant core damage and RPV breach, SAMGs prioritize the preservation of primary containment integrity while limiting radioactivity releases as follows: Core debris in the primary containment is stabilized by water addition (SAWA) Primary containment pressure is controlled below the Primary Containment Pressure Limit (Wetwell venting) Water addition is managed to preserve the Mark I/II suppression chamber vent paths, thereby retaining the benefits of Torus scrubbing and minimizing the likelihood of radioactivity and hydrogen release into the secondary containment (SAWM) Methods: Identify systems and capabilities to add water to the RPV or drywell, with the following generic guidance: Use controlled injection if possible. Inject into the RPV if possible. Maintain injection from external sources of water as low as possible to preserve suppression chamber vent capability.

  • Actual language may vary by acceptable site procedure standards, but intent and structure should follow this guidance.

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 39 of 48

Conceptual Sketches Refer to the EA-13-109 Phase 1 Overall Integrated Plan for the following sketches:

Electrical Electrical Layout of System - One Line Diagram Electrical Layout of System - Block Diagram Flow and Control Diagrams P&ID Layout of current HCVS Plant Layout ROS Location HCVS Battery System Location Deployment location and haul path (updated as part of Sketch 3 in this Phase 2 OIP) Additional Phase 2 Sketches: Sketch 1: FLEX / SAWA Flow Diagram Sketch 2: FLEX / SAWA Power Distribution Sketch 3: FLEX / SAWA Equipment Location Sketch 4: FLEX / SAWA Ingress/Egress Pathways

OJ " '-,1-*~j,i;;;:;, ~ ** ~L~r~~ ~/,.l*.~t'*~~:,,...-".1 __./. --- ---- n::-; "i~ I I' l~KC:

  • ./ **-- -*~ \\1 *;

',\\' i ~lJ.'.' 1: t ~H

    • -~ l).(/:"I(',

////// /// James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 i IR~~x-1 i \\-~<< ! j '-~re< 'HI'.'£~ :*;iic

l.

1 1'1.:U,t**1Y} ~ I I I ~ _., ~: -~ fii1 fl'"! ~.

  • -------{_~;---~

L __ 1 _________ l~~tm: .~'" T '"

JI/ARY

! :ot-m<rit~E*-T i ~ *'k-@~ T NC i r-..------------------------------------------------J i ! Y>< !L:. NC1' '

l~/----*t;t*----~-+-*~ ---**1

~-~ c i i ~'" T

r~~---**tf**---~i'--L---r;~~ -----J

~ r;
A

,o OfA~ll'.'ATC ~} L_~~~~~~~l__~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~J--t:~* ~~~~~ ld Ii> '8° FLEX SAWA (HCVS PHASE 2) FLOW PATH [1] FLEX/ SAWA (DIESEL FIRE) PUMPS ~ FLEX/ SAWA FLOW METER QJ FLEX/ SAWA 4" HOSE (5') [] FLEX/ SAWA THROTILING VALVE Sketch 1: FLEX I SAWA Flow Diagram Page 40 of 48

I f*~ "~Y f. ) ' - '.KC-62. Ge~*... C~3 James A FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 FLEX PHASE 2 DG, FIXED OR DEPLOYABLE 200 KW/250 KVA, 600V 2 - 410 PER<!> FLEX PHASE 2 DG, FIXED OR DEPLOYABLE 200 KW/250 KVA, 600V Sketch 2: FLEX I SAWA Power Distribution Page 41 of 48

HCVS TH ROUGH ROOF u TRACK BAY James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 TRANSFORMERS ELE CTR ICAL BAY ~ TURBINE BLDG REACTOR ADMIN f-REMOTE PANEL BLDG By f--- EL. 272' NI TR OGEN VALVE PANEL EL.272 ' v--- NITROGEN BOTTLE RACK ~ EL. 272' BOILER CONTR OL ~~ RM I RM I HE ATER BAY BATTERY __) L BATTERY RACK CHARGER Sketch 3: FLEX I SAWA Equipment Location Page 42 of 48 PR IMARY) ~ FLE X DG DIESEL GENER ATOR

,CR EENWEL L FLEX/SAWA DIESEL FIREl PUMPS WA TER TREATING RAD WAS TE 0----

j \\ - FLEX DG ALTERNATE l (

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 43 of 48 This drawing will be provided later. Sketch 4: FLEX / SAWA Ingress / Egress Pathways

James A. FitzPatrick Nuclear Power Station (JAF) Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan - December 2015 Page 44 of 48

Failure Evaluation Table Refer to the EA-13-109 Phase 1 Overall Integrated Plan and associated 6-month updates

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 45 of 48 : References

1. Generic Letter 89-16, Installation of a Hardened Wetwell Vent, dated September 1, 1989
2. Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012
3. Order EA-12-050, Reliable Hardened Containment Vents, dated March 12, 2012
4. Order EA-12-051, Reliable SFP Level Instrumentation, dated March 12, 2012
5. Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated June 6, 2013
6. JLD-ISG-2012-01, Compliance with Order EA-12-049, Mitigation Strategies for Beyond-Design-Basis External Events, dated August 29, 2012
7. JLD-ISG-2012-02, Compliance with Order EA-12-050, Reliable Hardened Containment Vents, dated August 29, 2012
8. JLD-ISG-2013-02, Compliance with Order EA-13-109, Severe Accident Reliable Hardened Containment Vents, dated November 14, 2013
9. NRC Responses to Public Comments, Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-ISG-2012-02: Compliance with Order EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, ADAMS Accession No. ML12229A477, dated August 29, 2012
10. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012
11. NEI 13-02, Industry Guidance for Compliance with Order EA-13-109, Revision 1, Dated April 2015
12. NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, Revision 0, dated March 2014
13. NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Revision 0, dated March 2014
14. NEI HCVS-FAQ-01, HCVS Primary Controls and Alternate Controls and Monitoring Locations
15. NEI HCVS-FAQ-08, HCVS Instrument Qualifications
16. NEI HCVS-FAQ-09, Use of Toolbox Actions for Personnel
17. NEI White Paper HCVS-WP-02, HCVS Cyclic Operations Approach
18. NEI White Paper HCVS-WP-04, Missile Evaluation for HCVS Components 30 Feet Above Grade

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 46 of 48

19. IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations,
20. James A. FitzPatrick EA-12-049 (FLEX) Overall Integrated Implementation Plan, Rev 0, February 2013
21. James A. FitzPatrick EA-12-050 (HCVS) Overall Integrated Implementation Plan, Rev 0, February 2013
22. James A. FitzPatrick EA-12-051 (SFP LI) Overall Integrated Implementation Plan, Rev 0, February 2013
23. JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, dated March 2015
24. Consideration of Additional Requirements for Containment Venting Systems for Boiling Water Reactors with Mark I and Mark II Containments, SECY-12-0157, ML12344A030
25. NUREG/CR-7110, V1, R1, State-of-the-Art Reactor Consequence Analyses (SOARCA) Project: Peach Bottom Integrated Analysis, ML13150A053
26. NEI HCVS-FAQ-10, Severe Accident Multiple Unit Response
27. NEI HCVS-FAQ-11, Plant Response During a Severe Accident
28. NEI HCVS-FAQ-12, Radiological Evaluations on Plant Actions Prior to HCVS Initial Use
29. NEI HCVS-FAQ-13, Severe Accident Venting Actions Validation
30. EC 52736, Fukushima FLEX Basis EC, Rev. 0
31. FM-20A, Flow Diagram Residual Heat Removal System 10, Rev. 72
32. FM-20B, Flow Diagram Residual Heat Removal System 10, Rev. 72
33. 3.11-44, Drywell Shell General Plan, Rev. 2
34. MSK-309C1, System 27 Air Piping from Penetration X-205 to 326-9, Rev. 7
35. ISI-IWE-001, General Arrangement and Details of Drywell and Torus, Rev. 1
36. JAF-CALC-PC-03043, Holdup Volumes for Containment Analyses, Rev. 0
37. ISP-29-3, Post Accident Suppression Pool Water Level Monitor Instrument Calibration, Rev. 12

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 47 of 48 : Changes/Updates to this Overall Integrated Implementation Plan This Overall Integrated Plan includes only content for Phase 2 of Order EA-13-109. Any significant changes to this plan will be communicated to the NRC staff in the 6 Month Status Reports.The Overall Integrated Plan for Phase 1 has been submitted and updated as a separate document.

James A. FitzPatrick Nuclear Power Plant Hardened Containment Vent System (HCVS) Phase 2 Overall Integrated Plan December 2015 Page 48 of 48 : List of Overall Integrated Plan Open Items Phase 1 and ISE Open Items are addressed as part of the Phase 1 OIP updates. Phase 2 Open Item Action Comment 1 Complete hydraulic analysis of diesel fire pump for SAWA / SAWM flowrates 2 Identify and evaluate severe accident conditions for Phase 2 manual actions. 3 The FLEX Engineering Change (EC 52736) has not been completed; therefore, any reference to this information is considered unverified.}}

Retrieved from "https://kanterella.com/w/index.php?title=JAFP-15-0149,_Phase_2_Overall_Integrated_Plan_in_Response_to_June_6,_2013_Commission_Order_Modifying_License_with_Regard_to_Reliable_Hardened_Containment_Vents_Capable_of_Operation_Under_Severe_Accident_Conditions_(Order_Number_EA-13-109)&oldid=5178162"