Text

Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
	ML13079A348
Person / Time
Site:	Indian Point
Issue date:	02/28/2013
From:	Ventosa J; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-13-042
	Download: ML13079A348 (158)
	v • d • e

Enterav Nuclear Northeast a Entergy Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 1051 1-0249 Tel 914 734 6700 John A Ventosa Site Vice President Administration February 28, 2013 NL-13-042 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Indian Point Unit Numbers 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCES:

1. NRC Order Number EA-1 2-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-Basis External Events, dated March 12, 2012 (RA-12-037)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ML12229A174)

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

4. Entergy letter to NRC (NL-1 2-144),Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-BasisExternal Events (OrderNumber EA-12-049), dated October 29, 2012

Dear Sir or Madam:

On March 12, 2012, the NRC issued an order (Reference 1) to Entergy Operations, Inc. (Entergy).

Reference 1 was immediately effective and requires provisions for mitigating

NL-13-042 Dockets 50-247 and 50-286 Page 2 of 2 strategies for beyond-design-basis external events. Specific requirements are outlined in the Enclosure of Reference 1.

Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (Reference 2) was issued August 29, 2012, and endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions. Reference 3 provides direction regarding the content of this Overall Integrated Plan. The purpose of this letter is to provide that Overall Integrated Plan pursuant to Section IV, Condition C.1 .a, of Reference 1.

Reference 3, Section 13, contains submittal guidance for the Overall Integrated Plan. The enclosure to this letter provides Indian Point Energy Center's (IPEC's) Overall Integrated Plan pursuant to Reference 3.

Reference 4 provided IPEC's initial status report regarding Mitigation Strategies for Beyond-Design-Basis External Events, as required by Reference 1. Entergy has not yet identified any impediments to compliance with the Order, i.e., within two refueling cycles after submittal of the integrated plan, or December 31, 2016, whichever comes first. Future status reports will be provided as required by Section IV, Condition C.2, of Reference 1.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. Robert Walpole, Manager, Licensing at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2013.

Sincerely, JAV/sp

Enclosure:

Indian Point Energy Center FLEX Overall Integrated Implementation Plan cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. William M. Dean, Regional Administrator, NRC Region I NRC Resident Inspector's Office Indian Point Ms. Bridget Frymire, New York State Department of Public Service Mr. Francis J. Murray, Jr., President and CEO, NYSERDA

ENCLOSURE TO NL-13-042 INDIAN POINT ENERGY CENTER FLEX OVERALL INTEGRATED IMPLEMENTATION PLAN ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286

General Integrated Plan Elements Indian Point Energy Center Determine Applicable Extreme Input the hazards applicable to the site, seismic, externalflood, high winds, External Hazard snow, ice, cold, high temps. Describe how NEI 12-06 Sections 5 - 9 were applied and the basis for whY the plant screened out/for certainhazards.

Ref: NEI 12-06 Section 4.0 -9.0 JLD-ISG-2012-01 Section 1.0 The Indian Point Energy Center (IPEC) site has been evaluated and the following applicable hazards have been identified:

eSeismic events

.Extemal flooding

Severe storms with high winds eSnow, ice, and extreme cold

Extreme heat IPEC has reviewed the NEI FLEX guidance and determined the hazards that FLEX equipment should be protected from include seismic; external flooding; severe storms with high winds; snow, ice, and extreme cold; and extreme high temperatures. The IPEC has determined the functional threats from each of these hazards and identified the FLEX equipment that may be affected. The FLEX equipment is being purchased as commercial grade and the storage locations will provide the protection required from these hazards. The IPEC is also developing procedures and processes to further address plant strategies for responding to these various hazards.

Seismic:

Per NEI 12-06, seismic hazards must be considered for all nuclear sites. As a result, the credited FLEX equipment will be assessed based on the current IPEC seismic licensing basis to ensure that the equipment remains accessible and available after a BDBEE, and that the FLEX equipment does not become a target or source of a seismic interaction from other systems, structures or components. The FLEX strategies developed for the IPEC will include documentation ensuring that any storage locations and deployment routes meet the FLEX seismic criteria.

External Floodinga:

Per NEI 12-06 Section 6, a three pronged evaluation of external flooding was performed. The IPEC site is not considered a "dry" site and is therefore, susceptible to external flooding. Accordingly, FLEX strategies will be developed for consideration of external flooding hazards.

The types of events evaluated to determine the worst potential flood included (1) runoff generated by a probable maximum precipitation over the entire Hudson River drainage basin upstream of the site, (2) occurrence of any upstream dam failure concurrent with heavy runoff generated by a standard project flood, and (3) the occurrence of a probable maximum hurricane concurrent with a spring high tide in the Hudson River. The maximum flood level from any of the failures listed above was determined to be 15 ft, which would not flood the safety related buildings (References 4 and 5, Section 2.5).

High Wind:

Figures 7-1 and 7-2 from the NEI 12-06 were used for this assessment. The IPEC site is above the 35th parallel (Universal Transverse Mercator Coordinates Latitude 41'-16' North and Longitude 73O-57' West).

It was determined the EPEC site has the potential to experience coastal winds exceeding 130 mph. Figure 7-2 of NEI I

General Integrated Plan Elements Indian Point Energy Center 12-06 indicates a maximum wind speed of 170 mph for the Region 2 plants, including the IPEC. Therefore, high-wind hazards are applicable to the IPEC site.

In summary, based on available local data and Figures 7-1 and 7-2 of NEI 12-06, the IPEC is susceptible to severe storms with high winds, so the hazard is screened in.

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

Applicabilit, of snow and extreme cold:

NEI 12-06 states plants above the 3 5th parallel should provide the capability to address the impedances caused by extreme snow and cold. The IPEC site is above the 35th parallel (Universal Transverse Mercator Coordinates Latitude 41'-16' North and Longitude 730-57' West); therefore, the FLEX strategies must consider the impedances caused by extreme snowfall with snow removal equipment, as well as the challenges that extreme cold temperature may present.

Applicability of ice storms:

The IPEC site is not a Level 1 or 2 region as defined by Figure 8-2 of the NEI FLEX Implementation Guide; therefore, the FLEX strategies must consider the impedances caused by ice storms.

In summary, based on the available local data and Figures 8-1 and 8-2 of NEI 12-6, the IPEC site does experience significant amounts of snow or ice, and extreme cold temperatures; therefore, the hazard is screened in.

Extreme Heat:

Per NEI 12-06, all sites must address high temperatures. Virtually every state in the lower 48 contiguous United States has experienced temperatures in excess of 11 0'F. Many states have experienced temperatures in excess of 120°F.

Peekskill, New York has recorded a high temperature of 11 5'F and a low temperature of -15'F. Sites that should address high temperatures should consider the impacts of these conditions on the FLEX equipment and its deployment.

Based on the available local data and industry estimates the IPEC site does not experience extreme high temperatures.

However, per NEI 12-06, all sites will address high temperatures. Therefore, for FLEX equipment, IPEC will consider the site maximum expected temperatures in their specification, storage, and deployment requirements, including ensuring adequate ventilation or supplementary cooling, if required.

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General Integrated Plan Elements Indian Point Energy Center Key Site assumptions to implement Provide key assumptions associatedwith implementation of FLEX strategies.:

NEI 12-06 strategies.

Ref: NEI 12-06 Section 3.2.1 Assumptions are consistent with those detailed in NEI 12-06, Section 3.2.1 (Reference 2). Analysis has been performed consisted with the recoirmnendations contained within the Executive Summary of the PWROG Core Cooling Position Paper (OG-12-482) and the assumptions from that document are incorporated into the plant-specific analytical bases. Key industry guidance and site-specific assumptions are presented here:

NEI 12-06 Assumptions Initial Plant Conditions The initial plant conditions are assumed to be the following:

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

A2.At the time of the postulated event, the reactor and supporting systems are within normal operating ranges for pressure, temperature, and water level for the appropriate plant condition. All plant equipment is either normally operating or available from the standby state as described in the plant design and licensing basis.

Initial Conditions The following initial conditions are to be applied:

A3.No specific initiating event is used. The initial condition is assumed to be a loss of offsite power (LOOP) at a plant site resulting from an external event that affects the offsite power system either throughout the grid or at the plant with no prospect for recovery of offsite power for an extended period. The LOOP is assumed to affect all units at a plant site.

A4.AII installed sources of emergency onsite ac power and SBO Alternate ac power sources are assumed to be not available and not imminently recoverable.

A5.Cooling and makeup water inventories contained in systems or structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles are available.

A6.Normal access to the UHS is lost, but the water inventory in the UHS remains available and robust piping connecting the UHS to plant systems remains intact. The motive force for the UHS flow, i.e., pumps, is assumed to be lost with no prospect for recovery.

A7.Fuel for FLEX equipment stored in structures with designs, which are robust with respect to seismic events, floods and high winds, and associated missiles, remains available.

A8.Permanent plant equipment that is contained in structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles, are available.

A9.Other equipment, such as portable ac power sources, portable back up dc power supplies, spare Batteries, and equipment for 50.54(hh)(2), may be used provided it is reasonably protected from the applicable external hazards per Sections 5 through 9 and Section 11.3 of NEI 12-06 and has predetermined hookup strategies with 3

General Integrated Plan Elements Indian Point Energy Center appropriate procedures/guidance and the equipment is stored in a relative close vicinity of the site.

A10.Installed electrical distribution system, including inverters and Battery chargers, remains available provided they are protected consistent with current station design.

Al 1.No additional events or failures are assumed to occur immediately prior to or during the event, including security events or fires.

A12.Reliance on the fire protection system ring header as a water source is acceptable only if the header meets the criteria to be considered robust with respect to seismic events, floods, and high winds, and associated missiles.

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

AI 3.Following the loss of all ac power, the reactor automatically trips and all rods are inserted.

A14.The main steam system valves (such as main steam isolation valves, turbine stops, atmospheric dumps, etc.)

necessary to maintain decay heat removal functions operate as designed.

A15.Safety/Relief Valves (S/RVs) or Power Operated Relief Valves (PORVs) initially operate in a normal manner, if conditions in the RCS so require. Normal valve reseating is also assumed.

A16.No independent failures, other than those causing the ELAP/LUHS event, are assumed to occur in the course of the transient.

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

A17.Normal system leakage AI 8.Losses from letdown, unless automatically isolated, or until isolation is procedurally directed A19.Losses due to reactor coolant pump seal leakage (rate is dependent on the RCP seal design)

SFP Conditions The initial SFP conditions are:

A20.All boundaries of the SFP are intact, including the liner, gates, transfer canals, etc.

A21 .Although sloshing may occur during a seismic event, the initial loss of SFP inventory does not preclude access to the refueling deck around the pool.

A22.SFP cooling system is intact, including attached piping.

A23.SFP heat load assumes the maximum design basis heat load for the site.

Containment Isolation Valves A24.It is assumed that the contaimnent isolation actions delineated in the current station blackout coping capabilities is sufficient.

The following assumptions are specific to the IPEC site:

A25.IPEC will be able to declare an ELAP within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in order to enable actions which place the plant outside of the current design and licensing basis.

A26.Flood and seismic re-evaluations pursuant to the 10 CFR 50.54(f) letter of March.12, 2012 are not completed 4

General Integrated Plan Elements Indian Point Energy Center and therefore, not assumed in this submittal. As the re-evaluations are completed, appropriate issues will be entered into the corrective action system.

A27.This plan defines strategies capable of mitigating a simultaneous loss of all alternating current (ac) power and loss of normal access to the UHS resulting from a beyond-design-basis event by providing adequate capability to maintain or restore core cooling, containment, and SFP cooling capabilities at all units on a site. Though specific strategies are being developed, due to the inability to anticipate all possible scenarios, the strategies are also diverse and flexible to encompass a wide range of possible conditions. These pre-planned strategies developed to protect the public health and safety will be incorporated into the unit guidance. The plant Technical Specifications contain the limiting conditions for normal unit operations to ensure that design safety features are available to respond to a design basis accident and direct the required actions to be taken when the limiting conditions are not met. The result of the beyond-design-basis event may place the plant in a condition where it cannot comply with certain Technical Specifications and/or with its Security Plan, and, as such, may warrant invocation of 10 CFR 50.54(x) and/or 10 CFR 73.55(p).

A28.Required staffing levels will be determined consistent with guidance contained in NEI 12-06 for each of the site specific FLEX strategies. Assumed available staffing levels will be determined consistent with NEI 12-06, as described below.

The event impedes site access as follows:

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

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

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

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

A29.The design hardened connections applicable to FLEX strategies are protected against external events or are established at multiple and diverse locations.

A30.Instrumentation on FLEX equipment will be used to confirm continual performance.

S

General Integrated Plan Elements Indian Point Energy Center Extent to which the guidance, JLD- Include a description of any alternatives to the guidance, and provide a ISG-2012-01 and NEI 12-06, are milestone schedule ofplanned action.

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

Ref: JLD-ISG-2012-01 Ref: NEI 12-06 Section 13.1 Entergy plans to fully comply with the guidance in JLD-ISG-2012-01 or NEI 12-06 in implementing FLEX strategies for the IPEC site.

Provide a sequence of events and Strategies that have a time constraint to be successfud should be identified identify any time constraint required with a technical basis and a justification provided that the time can for success including the technical reasonably be met (lbrexample, a ivalkthrough of deplovment.

basis for the time constraint.

Describe in detail in this section the technical basis for the time constraint Ref: NEI 12-06 Section 3.2.1.7 identified on the sequence of events timeline Attachment ]A JLD-ISG-2012-01 Section 2.1 See attachedsequence of events timneline (Attachment IA).

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

The sequence of events and any associated time constraints are identified below for Indian Point Energy Center Modes 1-4 strategies for FLEX Phases 1 through Phase 3 (Reference 10). See attached sequence events timeline (Attachment 1A) for a summary of this information.

1. Control Room Ventilation (Open Room/Cabinet Doors) - 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months

Indian Point Plant procedure ECA-0.0, Loss of All AC Power, directs opening control room doors and/or cabinet doors (References 7 and 8).

2. TDABFP Room Ventilation - 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months

Indian Point Plant procedure ECA-0.0, Loss of All AC Power, directs opening TDABFP room doors within 30 minutes of a loss of all ac power. The temperature in the TDABFP room will be less than 120'F for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if the door is open by the first hour after the event.

3. Declare ELAP - 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 9ELAP entry conditions can be verified by control room staff and it is validated that both emergency diesel generators are not available. This is a reasonable assumption for system operators to perform initial evaluations of the EDGs. Entry into ELAP provides guidance to operators to perform ELAP actions. Time constraint is required to allow taking actions which place the plant SSCs outside License Basis alignments (Reference 10).

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General Integrated Plan Elements Indian Point Energy Center

4. Deep Load Shed- 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months eLoad shedding increases Battery life for duration of Phase 1 (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ). (Reference 10).

5. Perform Plant cooldown - 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months eCooldown commences at 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to minimize RCS leakage prior to capability to initiate RCS makeup as the FLEX RCS Makeup pump has a deployment time of-2 hours. An assumed cooldown rate of 75 +/- 5 'F will place the plant at target temperature of 4007F in -2 hours (3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months after LOAC) (Reference 10).

6. Debris Removal - 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months aBased on earliest need for deployment paths (Reference 10).

7. Perform Damage Assessment - 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months olndian Point will develop a post event damage assessment walkdown procedure. Thepurpose of the damage assessment walkdown is to evaluate and document the condition of plant systems, structures and components (SSCs) after an ELAP event. The damage assessment will be comprehensive enough such that plant management and staff can plan the best recovery strategy. Based on the expected complexity of the task, it is assumed that the damage assessment will take 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , depending on local site conditions. It is assumed that critical plant conditions will be known by the control room coordinator to inform appropriate actions following the completion of this task (Reference 10). This damage assessment will guide FLEX strategies and will be a future FSG requirement.

8. Control Room & Emergency Lighting - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

Phase I lighting is provided by emergency lighting Batteries, but beyond Phase 1 will require new strategies.

Assume control room lighting after 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is addressed per Phase 2 action. (Reference 10).

9. Energize Phase 2 480V Generator - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

This time constraint is dependent upon the earliest need for the generator based on providing power to the Plant Power System (Reference 10).

10. Deploy Miscellaneous Lighting and Ventilation - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

'Additional lighting and ventilation is not easily powered from the 480V bus and will require use of Batteries and/or small portable generators as deemed necessary.

11. Deploy Battery Room Ventilation for Unit 3 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months oUnit 3 Battery room ventilation must occur shortly after Battery charging is initiated to vent hydrogen (Reference 10).

12. Initiate RCS Makeup from BAST - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months oRCS makeup is required for inventory at 5.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months assuming cooldown is commenced at 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Assuming the FLEX RCS pump takes -2 hours to deploy, the cooldown will be commenced at 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (assumption).

Therefore, 5.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months becomes the limiting time. However, further evaluation is expected to extend the current requirement for inventory to justify an eight hour requirement (Reference 10).

13. Establish SFP Area Vent - 8.04 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months oEstablish SFP vent area such as opening the door. Need time based on SFP time to boil without a break. This time to boil is based on an initial SFP temperature of 140'F and assumes all pipe penetrating the SFP remains intact.

14. Deploy SFP Makeup Hose - 8.04 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months oDeploy the FLEX SFP discharge hose. Need time based on SFP time to boil without a break. This time to boil is based on an initial SFP temperature of 140'F and assumes all pipe penetrating the SFP remains intact.

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General Integrated Plan Elements Indian Point Energy Center

15. Switch RCS Makeup from BAST to RWST - 10.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months eThis need time is based on the depletion of the BASTs and the need to maintain RCS inventory (Reference 10).

16. Establish FLEX Equipment Fuel Deployment - 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months eThis is an assumption. Indian Point will provide a more exact basis once all FLEX equipment has been purchased and equipment specifications (fuel consumption rate) are known.

17. Stage FLEX SG Makeup pump - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

Stage as early as possible in event to provide defense in depth (Reference 10).

18. Large Debris Removal -24 hours eNeed time is based on the need for large equipment arriving on-site requiring for additional debris clearing.

Equipment of this size, is not expected to arrive on site until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Reference 10).

19. Initiate SFP Makeup -27.83 hours9.606481e-4 days 0.0231 hours 1.372354e-4 weeks 3.15815e-5 months ePer Reference 10, the time for the SFP to boil is 8.04 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and time for the level to reach 15 ft. above the top of the racks is an additional 19.79 hours9.143519e-4 days 0.0219 hours 1.306217e-4 weeks 3.00595e-5 months .

20. Align FLEX ACS Pump from Available ACS to CST - 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months

Based on current CST credited volume depleting in 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months (Reference 10). The UHS is the assured seismic alternate coolant source (ACS) (Reference 10).

21. Mobile Water Purification System -32 hours eThe current credited CST volume will deplete in 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months . The volume of the UHS can be credited indefinitely.

This mobile purification skid would be aligned as soon as possible to allow processing untreated water for makeup (Reference 10).

22. Phase 3 480V generator - 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months eAssumption based on current plant analysis limited applicability of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Need time is based on eventual loss of capability to support SG feed strategy (Reference 10).

23. Align UHS Pump and Alternate Service Water - 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months eAssumption based on current plant analysis limited applicability of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Need time is based on loss of capability to support SG feed strategy (Reference 10).

24. Establish Large Fuel Truck Delivery Service - 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months eAssumption regarding the depletion of on-site supply and supplying larger equipment. Indian Point will provide a more exact basis once all FLEX equipment has been purchased and equipment specifications are known (Reference 10).

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

Identify how strategies will be Describe how the strategieswill be deployed in all modes.

deployed in all modes.

Ref: NEI 12-06 section 13.1.6 8

General Integrated Plan Elements Indian Point Energy Center Deployment of the FLEX equipment is described for each FLEX function in the subsequent sections below and covers all operating modes. The broad-spectrum deployment strategies do not change for the different operating modes. The deployment strategies from the storage areas to the staging areas are identical and include debris removal, equipment transport, fuel transport, and power sources and requirements. The only difference is the discharge connection location for the FLEX pumps. The primary and secondary connection locations for RCS inventory control when the steam generators are available to provide core cooling will also be the connection locations utilized providing coolant directly to the RCS when the steam generators are not available to provide core cooling. Each of these strategies and the associated connection points are described in detail in the subsequent sections. The electrical coping strategies are the same for all modes.

Provide a milestone schedule. This The dates specificall/ requiredby the order are obligated or committed dates.

schedule should include: Other dates are planned dates subject to change. Updates will be provided in eModifications timeline the periodic (six month) status reports.

o Phase 1 Modifications See attachedmilestone schedule Attachment 2 o Phase 2 Modifications o Phase 3 Modifications o Procedure guidance development complete o Strategies o Maintenance eStorage plan (reasonable protection) eStaffing analysis completion oFLEX equipment acquisition timeline oTraining completion for the strategies oRegional Response Centers operational Ref: NEI 12-06 Section 13.1 The dates specifically required by the order are obligated dates. Other dates are planned dates subject to change.

Updates will be provided in the periodic (six month) status reports.

See attached milestone schedule in Attachment 2.

Identify how the programmatic Provide a description of the programmatic controls equipment protection, controls will be met. storageand deployment and equipment qualitY See Section 11 in NEI 12-06.

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General Integrated Plan Elements Indian Point Energy Center Storage of equipment, 11.3, will be documented in latter sections of this Ref: NEI 12-06 Section 11 temiplaite and need not be included in this section.

J-LD-ISG-2012-01 Section 6.0 See Section 6. 0 of JLD-ISG-2012-O1.

Equipment associated with these strategies will be procured as commercial equipment with design, storage, maintenance, testing, and configuration control in accordance with NEI 12-06 Rev.0 Section 11.0 (Reference 2).

The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy will be managed using plant equipment control guidelines developed in accordance with NEI 12-06 Rev.0 Section 11.5 (Reference 2).

Programs and controls will be established to assure personnel proficiency in the mitigation of beyond-design-basis events is developed and maintained in accordance with NEI 12-06 Rev.0 Section 11.6 (Reference 2).

The FLEX strategies and basis will be maintained in an overall program document. Existing plant configuration control procedures will be modified to ensure that changes to the plant design, physical plant layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies in accordance with NEI 12-06 Rev.0 Section 11.8 (Reference 2).

Procedure Guidance The IPEC is a participant in the Pressurized Water Reactor Owners Group (PWROG) project PA-PSC-0965 and will implement the FLEX Support Guidelines (FSGs) in a timeline to support the implementation of FLEX by Spring 2015 (IP3) and Spring 2016 (IP2). The PWROG has generated these guidelines in order to assist utilities with the development of site-specific procedures to cope with an ELAP in compliance with the requirements of Reference 2.

The proposed implementation strategy aligns with the procedure hierarchy described in NEI 12-06 (Reference 2) in that actions that maneuver the plant are contained within the typical controlling procedure, and the FSGs are implemented as necessary to maintain the key safety functions of Core Cooling, Spent Fuel Cooling, and Containment in parallel with the controlling procedure actions. The overall approach is symptom-based, meaning that the controlling procedure actions and the FSGs are implemented based upon actual plant conditions.

The IPEC will continue participation in PA-PSC-0965 and will update plant procedures upon the completion of the PWROG program. It is expected that the following FSGs will be incorporated into existing plant procedures in order to develop the FSG interface:

Altemate AFW Suction Source eAlternate Low Pressure Feedwater eELAP DC Load Shed/Management

Initial Assessment and FLEX Equipment Staging

Alternate CST Makeup eLoss of DC Power

Altemate RCS Boration 9Long Term RCS Inventory and Temperature Control

Passive RCS Injection Isolation

Altemate SFP Makeup and Cooling 10

General Integrated Plan Elements Indian Point Energy Center eAlternate Containment Cooling eTransition from FLEX Equipment Maintenance and Testing The IPEC intends to maintain and test the FLEX equipment consistent with the requirements of Fire Protection and SBO maintenance. Entergy will review the maintenance and testing template upon issuance by the Electric Power Research Institute (EPRI) to ensure alignment with their Fire Protection and SBO maintenance procedures.

Additionally, the IPEC will ensure that their maintenance and testing procedures meet the FLEX guidelines established in Section 11.5 of Reference 2.

Staffin g The FLEX strategies documented in the event sequence analysis assume:

eOnsite staff are at administrative shift staffing levels eNo independent, concurrent events

All personnel onsite are available to support site response The IPEC will have to address staffing considerations in accordance with NEI 12-06 (Reference 2) to fully implement FLEX at the site.

Configuration Control Per NEI 12-06 (Reference 2) and the Interim Staff Guidance (Reference 3), the FLEX strategies must be maintained to ensure future plant changes do not adversely impact the FLEX stTategies.

Therefore, IPEC will need to maintain the FLEX strategies and basis in an overall program document and will modify existing plant configuration control procedures to ensure changes to the plant design, physical plant layout, roads, buildings, and miscellaneous structures will not adversely impact the approved FLEX strategies.

Describe training plan List trainingplansfor qffected organizationsor describe the plan for training development Training plans will be developed for plant groups such as the ERO, Fire, Security, EP, Operations, Engineering, Mechanical Maintenance, and Electrical Maintenance. The training plan development will be done in accordance with the IPEC procedures using the Systematic Approach to Training, and will be implemented to ensure that the required IPEC staff is trained prior to implementation of FLEX.

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

eSite-specific RR C plan

Identification of the primary and secondary RRC sites eldentification of an' alternateequipment sites (i.e., another nearby site with compatible equipment that can be deployed)

II

General Integrated Plan Elements Indian Point Energy Center eDescribe how delivery to tihe site is acceptable eDescribe how all requirements in NEI 12-06 are identified The industry will establish two Regional Response Centers (RRC) to support utilities during beyond design basis events. Each RRC will hold five sets of equipment, four of which will be able to be fully deployed when requested; the fifth set will have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local Assemble Area, established by the Strategic Alliance for FLEX Emergency Response (SAFER) team and the utility. Communications will be established between the affected nuclear site and the SAFER team and required equipment moved to the site as needed. First arriving equipment, as established during development of the nuclear site's playbook, will be delivered to the site within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the initial request.

Entergy has signed a contract with SAFER to meet the requirements of NEI 12-06, Section 12.

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

sAFW/EFW'

Depressurize SG for Makeup with Portable Injection Source eSustained Source of Water Ref: JLD-ISG-2012-01 Sections 2 and 3 PWR Installed Equipment Phase 1 Provide a generaldescription of the coping strategiesusing installedequipment includingstation modifications that are proposed to maintain core cooling. Identiýf methods (AFW/EFW) and strategv(ies) utilized to achieve this coping time.

Unless otherwise noted, information in this section was obtained from Reference 10.

Core Cooling with Steam Generators Available:

During a SBO, operator actions are currently governed by procedure 2/3 ECA-0.0 for Units 2 and 3. The overall strategy is to isolate the Reactor Coolant System (RCS) to conserve inventory, start the Turbine Driven Auxiliary Boiler Feed Pump (TDABFP), and supply water to the Steam Generator(s) (SG) to remove decay heat and provide RCS cooling by depressurizing the SG(s) via the Atmospheric Dump Valve(s) (ADV), The only exits from this procedure are I. Coping modifications consist of modifications installed to increase the initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

12

Maintain Core Cooling & Heat Removal the restoration of some source of ac Power or the eventual transition to the Severe Accident Management Guidelines (SAMGs) based on high core exit temperatures.

Installed TDABFP Following event initiation, the decay heat removal and SG/RCS depressurization relies on the auxiliary feed water system (AFWS) to draw water from the Condensate Storage Tank (CST) to supply it to the SG(s) using the TDABFP and to depressurize the SG(s) using the ADV(s). Using the existing IPEC PRA/MAAP analyses which assume an available CST volume of 360,000 gallons at the start of the event, the SG(s) can be supplied with water for approximately 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months . With the above strategies and capabilities, the estimated Core Cooling coping time is in excess of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Reference 6).

Ventilation For the TDAFP room, procedure 2/3-ECA-0.0 already contains steps to open ventilation paths to maintain acceptable local temperatures while the pump is in service (References 7 and 8). The procedure background document indicates the doors on cabinets in the control room and the AFW pump room roll-up door are opened to dissipate heat. These actions must be accomplished within 30 minutes of the loss of all AC 480V power event Establish Steam Generator Dump Relief Valves The TDABFP supplies water to the Steam Generator(s) (SG) to remove decay heat and provide RCS cooling by depressurizing the SG(s) via the Atmospheric Dump Valve(s) (ADV). With respect to ADV operation, installed nitrogen supplies will support at least 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months of ADV operation (i.e., two ADVs for IP2 and one ADV for IP3) based on the licensing basis calculations that conservatively assume minimum required N2 bottle pressure and 35 full strokes of the ADV. Per Reference 6, the licensing basis calculation points out that this assumed number of strokes is conservatively high, since plant cool down requires minimal ADV manipulation in the field.

Core Cooling with Steam Generators not Available:

During Modes 5 and 6, core cooling is maintained through heat removal from the RCS via coolant boil-off. During Phase 1, the inventory is maintained in the vessel by ensuring adequate RCS makeup using gravity feed from the RWST. The rate of gravity feed depends upon the RWST fluid height, line losses through the gravity flow path, and developed pressure within the RCS. Pressure is maintained sufficiently low in the RCS by ensuring adequate venting is established prior to entering conditions wherein SG cooling is not available as a part of shutdown risk management.

Details:

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

s Station Blackout (SBO) Emergency Operating Procedure (EOP) ECA-0.0 (Reference 7 and 8) addresses the standard CST alignment strategy. The strategies in ECA-0.0 must be tied to the appropriate FLEX support Guideline (FSG) for this strategy, when the FSG is developed.

Identify modifications List modifications 1.No modifications are necessary.

13

Maintain Core Cooling & Heat Removal Key Reactor Parameters List instrumentationcredited or recoveredfor this coping evaluation.

Steam Generators Available 1.SG Wide Range Level or Narrow Range Level 2.AFW Flow indication 3.SG Pressure 4.CST Level (local level indication only) 5.Subcriticality Steam Generators Not Available l.Core Exit Thermocouple (CET) Temperature 2.Reactor Vessel Level Indicating System IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

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

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

Unless otherwise noted, information in this section was obtained from Reference 10.

Core Cooling with Steam Generators Available:

The transition into Phase 2 will be required once the operating conditions of the TDABFP cannot be maintained. The primary strategy involves staging the portable pump outside the auxiliary building and running hose to a primary or secondary connection point to the auxiliary feedwater system. The storage locations, deployment paths, and staging locations for the FLEX equipment are provided in Figure A3-3, Figure A3-4 and Figure A3-15 through Figure A3-18 in . This strategy involves taking suction first from the CST and then from an alternate water source. The FLEX pump can be staged in an area near the CST as outlined in Figure A3-3 and Figure A3-4 in Attachment 3. The CST contains enough water to maintain core cooling for approximately 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months . After the CST is exhausted, a transition to increasingly impure water sources will occur. A line loss evaluation was performed which shows the expected line losses for both the primary and alternate configurations. The proposed hose routing for the primary AFW FLEX connection and the associated equipment can be seen in Figure A3-5 in Attachment 3. The diesel fuel supply for all FLEX equipment will be from the Emergency Diesel Generator Fuel Oil Storage Tanks.

The primary connection is preferred to be from a system tee at an accessible location. This is preferred because it will decrease the amount of setup time required for operators. Also, it will allow for pre-staging of hose, if a flood warning occurs. This connection will need to be protected from high winds, floods, and seismic events. This connection will be 14

Maintain Core Cooling & Heat Removal just downstream of the TDABFP discharge check valve BFD-31. This location allows for feed to all four steam generators (path to the steam generators shown with green arrows) with a FLEX pump using the same injection path as the previously running TDABFP. Check valves exist between the TDABFP and this connection, preventing flow back through the TDABFP. The Flow Control Valves BFD-FCV-405(A-D) separates this connection point from the steam generators and should be confirmed to be open. These valves may also be operated by their hand wheels. No other valves capable of closing are located downstream of this connection point.

The secondary connections will feed all four steam generators through the 2" drain valves BFD-22 on the AFW system.

The Condensate Storage Tank (CST) provides the makeup water cooling source to be used as feed water from the onset of the extended loss of all ac power (ELAP) until the CST is exhausted as a water source. For the IPEC, the minimum volume of the CST is exhausted after 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months into the event. Therefore, cooling water will need to be supplied by another source for the remainder of the ELAP event. An evaluation of each alternate coolant source (ACS) has being completed. In this evaluation each ACS is postulated to be used individually as the feedwater source for hours 18 through 72. The ACSs considered for use include: the Primary Water Storage Tanks (PWST), the City Water Tank (CWT), the Fire Water Storage Tanks (FWST), the Refueling Water Storage Tanks (RWST), and the Hudson River.

As previously stated the IPEC would exhaust the available supply of water in the CST in approximately 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months . For the plant to cope for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months would require approximately 600,000 gallons of water for each unit. To provide this volume of water, an additional 240,000 gallons of water would be needed for each to cope for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Regardless of the event scenario, the required coolant to the steam generators, suction could be taken from the Hudson River. The Hudson River is the UHS for the IPEC. The river level may vary depending on the type of event experienced. This source is considered available for this FLEX function, but should be used only if the water sources above are no longer available. Hose will be run from the Hudson River to a booster pump, from the booster pump to the FLEX pump, and then to the CST. The hose will be run through the manway on top of the Unit 2 CST. The staging point for the FLEX pump should be as close to the water as possible to minimize the height difference between the pump and the river. Routing between the Hudson River and the Unit 2 CST is shown in Figure A3-53 with suction routing in green while red represents discharge. Routing between the Hudson River and the Unit 3 CST is shown in Figure A3-58 with suction routing in green while red represents discharge.

Core Cooling with Steam Generators not Available:

During Modes 5 and 6, core cooling is maintained through heat removal from the RCS via coolant boil-off. Since core cooling is ensured by maintaining adequate RCS coolant inventory, core cooling, inventory control and subcriticality issues for conditions where steam generators are not available are addressed in the RCS Inventory Control section of this report.

Details:

Provide a brief description of C'onfirm that procedure/guidance exists or will be developed to support Procedures/Strategies/Guidelines implementation.

Procedures and guidance to support deployment and implementation including interfaces to EOPs, special event procedures, abnormal event procedures, and system operating procedures, will be developed in accordance with NEI 12-06, Revision 0, Section 11.4 (Reference 2). Further, the PWROG is developing generic and NSSS-specific FLEX Support FSGs via PA-PSC-0965. The FSGs developed for IPEC will align with the PWROG guidance.

Identify modifications List modifications 15

Maintain Core Cooling & Heat Removal A description of any modifications required to implement this connection point (per Unit) are documented below. This includes new piping, valves, or adapters.

1. Also, 3 inch or larger suction connection lines will need to be added.

These connections will include a manual isolation valve and a 3"x4" reducer to accommodate a 4 inch STORZ hose connection

2. A tee will be added to the auxiliary feedwater line of both units for the primary connection point. Two isolation valves and a STORZ hose connection will also be added.

3. For the Unit 2 secondary connection, a tee will be added downstream of BFD-22. A 2"x4" reducer will be attached to the branch line along with a 2" manual isolation valve, and a connection for a 4 inch STORZ hose connection. In Unit 3, a threaded cap is installed at this location. This capped end will be replaced with a 2"x4" reducer along with a 4 inch STORZ hose connection.

Key Reactor Parameters List instrumentationcredited or recoveredfor this coping evaluation.

Steam Generators Available I.SG Wide Range Level or Narrow Range Level 2.AFW Flow indication 3.SG Pressure 4.CST Level (local level indication only)

Steam Generators Not Available I.Core Exit Thermocouple (CET) Temperature 2.Reactor Vessel Level Indicating System 3.Neutron Flux IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Storage/Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements The storage location of the IPEC's FLEX equipment is the existing Unit 1 Chemical Systems Building. This location is protected from wind, flood, and seismic events. Access to equipment is possible through multiple roll up doors.

Seismic List how equipment is protected or schedule to protect The storage location is designed equivalent to ASCE 7-10, Minimum Design Loads Jor Buildings and Other Structures. Large portable FLEX equipment will-be 16

Maintain Core Cooling & Heat Removal secured as appropriate during SSE and will be protected from seismic interactions with other components. No components will be stacked or at a raised elevation as to cause interference with the deployment of any of the FLEX equipment.

Flooding List how equipment is protected or schedule to protect Note: if stored below current flood The storage location is located above the maximum flood level of 15 ft mean sea level, then ensure procedures exist to level.

move equipment prior to exceeding flood level.

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

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

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

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

The storage locations, deployment paths, and staging locations for the FLEX equipment are provided in Figure A3-3, Figure A3-4 and Figure A3-15 through Figure A3-18 in Attachment 3. The existing Unit 1 Chemical Systems Building will be used as a storage location. This location is protected from wind, flood, and seismic events. Access to the equipment is possible through multiple roll up door. Deployment from the Unit 1 Chemical Systems Building would necessitate the use of trucks or forklifts capable of pulling the FLEX pumps. The deployment routes are shown in see Figure A3-15 and Figure A3-16. Structures that may present a debris source in a seismic event are shown in red. The paths to the staging locations next to the CSTs are above flood level and no security barriers exist along either path. The deployment paths to the secondary staging location are shown in Figure A3-15 and Figure A3-16 and the primary connection deployment discussion apply to the secondary staging area.

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

17

Maintain Core Cooling & Heat Removal The driveways next to each unit's The connection modifications listed These connections are located in CST provide a level staging location, in the previous table will be made. buildings protected from high winds, well above flood level (-18'), and floods, and seismic events.

near the CST and the alternate water The roll up doors by the AFW sources (PWST, RWST, FWST). primary connection location will be They will be used for the primary evaluated for missile protection.

connection point.

The secondary connections, which are The staging locations for the on the 18' elevation of the turbine secondary connection point are building, will be evaluated for located directly west of the Turbine susceptibility to flooding.

Buildings between the river and each door access point shown on Figure A3-17 and Figure A3-18.

Hose will be run to connect the SG FLEX pump suction to the CST and the pump discharge to the steam generator inlet piping. For both units, flexible hose must be run to connect the FLEX pump to one of the suction sources mentioned.

Hose routings for the primary connection point are shown in Figure A3-5 in Attachment 3. The Flow Control Valves BFD-FCV-405(A-D) for Unit 3 separate this connection point from the steam generators and should be verified to be open. These valves may also be operated by their hand wheels. No other valves capable of closing are located downstream of this connection point.

The proposed hose routing for the secondary AFW FLEX connection runs through the exit door for Unit 3 and through the rollup door on the northwest corner of the Unit 2 Turbine Building for Unit 2 as shown in Figure A3-19 and Figure A3-20 in . Valves BDF-22 for Units 2 and 3 should be verified to be open. These valves may be operated by their hand wheels.

Items requiring fuel include, but are not limited to, debris removal equipment, diesel generators, diesel 18

Maintain Core Cooling & Heat Removal pumps, and FLEX equipment transportation vehicles. The diesel fuel supply for all FLEX equipment will be from the Emergency Diesel Generator Fuel Oil Storage Tanks.

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

19

Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposedto maintain core cooling. Identif, methods and strategv(ies) utilized to achieve this coping time.

Unless otherwise noted, information in this section was obtained from Reference 10.

In Phase 3, core cooling is continued to be maintained through natural circulation heat removal from the RCS via the steam generators. Reactor level and subcriticality is adequately maintained via the Phase 2 strategy, however, borated water sources are limited to some extent. Phase 3 deployment of a unit capable of generating ultra-pure borated coolant can further extend coping times with respect to RCS inventory management. Heat rejection through the steam generators is continued to be maintained via either the TDABFP or the SG FLEX pump; however, use of non-standard coolant in the SG cannot be maintained indefinitely. Phase 3 deployment of a unit capable of generating ultra pure coolant for use in the SGs can extend the coping time further- however, indefinite coping is successfully established once a transition from SG cooling to residual heat removal (RHR) system cooling is established. If the generator power is sufficient to power the CCW system, the Phase 3 deployment of a pump to supply the Ultimate Heat Sink (Hudson River water) flow to the shell side of the CCW Heat Exchanger establishes a portion of this capability. This approach will however require modification to the piping feeding (and returning) cooling water to (and from) the CCW heat exchanger.

Large debris removal equipment will be the first priority. While the Phase 2 FLEX paths will be cleared by onsite debris removal equipment, the regional response center (RRC) could provide debris removal equipment capable of clearing other paths possibly blocked by larger debris.

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

A mobile water purification system would enable water sources such as the Hudson River to be purified. This unit would process the water source and discharge improved quality water which could be used as makeup to the CST, or other components that require non-borated water. This unit would have an internal pump and be self powered. A large diesel generator will also be pursued to repower equipment such as the HVAC, the SFP cooling, the RHR pump, and the CCW pump.

A mobile boration system would enable borated water to be produced using the non-borated water sources that are available at the IPEC. This unit would combine the non-borated water and boron with a mixing mechanism to discharge a desired concentration of borated water, which could be used at makeup to the BASTs or RWSTs. This unit would have an internal pump and be self powered.

Any offsite fuel being provided by the Regional Response Center will be transported to a designated drop-off point outside of the plant site. As a Phase 3 strategy, it is desired to have a fuel truck delivered by the regional response center with the capability to transfer fuel from the designated drop-off point for the regional response center to the onsite fuel storage tanks. A large diesel fuel truck would be an addition to the diesel fuel truck used in the fuel transfer strategies discussed in Phase 2.

Determination of the functional requirements for each of these strategies, equipment and components will be completed at a later time and will be provided in the sixth month updates to the February 28, 2013 submittal.

The IPEC's response to IER 11-4 (Reference 6), provides a sumnmary of agreements and contracts for mutual aid and support to mitigate the consequences of a BDBEE. Each of these contracts should be reviewed to determine applicability and revisions required to incorporate FLEX strategies.

20

Maintain Core Cooling & Heat Removal Details:

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

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

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

The Phase 3 deployment of a pump to supply the Ultimate Heat Sink (Hudson River water) flow to the shell side of the CCW heat exchanger will however require modification to the piping feeding (and returning) cooling water to (and from) the CCW heat exchanger.

Key Reactor Parameters List instrumentation credited or recoveredfor this coping evaluation.

Steam Generators Available 1.SG Wide Range Level or Narrow Range Level 2.AFW Flow indication 3.SG Pressure 4.CST Level (local level indication only) 5.Subcriticality Steam Generators Not Available 1.Core Exit Thermocouple (CET) Temperature 2.Reactor Vessel Level Indicating System IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

The deployment paths for equipment received from the regional response center will be developed after the IPEC and the RRC have agreed upon a location to receive equipment onto the site.

Strategy Modifications Protection of connections Identif', Strategy including how the Identij., modifications Identfr, how the connection is equipment will be deployed to the protected point of use.

Large debris removal equipment will None There are no connection points for be the first priority. While the Phase 2 this strategy. All equipment will be FLEX paths will be cleared by onsite provided by offsite resources.

debris removal equipment, the RRC 21

Maintain Core Cooling & Heat Removal could provide debris removal equipment capable of clearing other paths possibly blocked by larger debris.

A backup to the Phase 2 equipment Each of the Phase 3 strategies will This information is provided in the will be provided from the regional utilize common connections as section for Phase 2.

response centers and will allow all described for the Phase 2 connections Phase 2 functions for coping to to prevent any compatibility issues continue to be utilized in Phase 3, with the offsite equipment.

even when there is a failure of the onsite Phase 2 equipment during the indefinite coping period.

A mobile water purification system Each of the Phase 3 strategies will The connection to the UHS would enable water from the UHS utilize cormnon connections as impoundment will simply be a hose impoundment to be purified. This unit described for the Phase 2 connections dropped into the lake. The discharge would process the water source and to prevent any compatibility issues connections will be identical to the discharge improved quality water with the offsite equipment. ones used for Phase 2. The protection which could be used to make up the of those connection points is CST or other components, which described in the section for Phase 2.

require non-borated water. This unit would have an internal pump and be locally powered. A large diesel generator will also be pursued to repower equipment such as the HVAC, SFP cooling, the RHR pump, and the CCW pump.

A mobile boration system would Each of the Phase 3 strategies will The discharge connections will be enable borated water to be produced utilize common connections as identical to the ones used for Phase 2.

using the non-borated water sources described for the Phase 2 connections The protection of those connection that are available at the IPEC. This to prevent any compatibility issues points is described in the section for unit would combine the purified non- with the offsite equipment. Phase 2 for RCS Inventory Control.

borated water from the mobile water purification system and boron with a mixing mechanism to discharge a desired concentration of borated water, which could be used as makeup to the BASTs or RWST. This unit would have an internal pump and be locally powered.

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

22

Maintain RCS Inventory Control Determine Baseline coping capability with installed coping 2 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Low Leak RCP Seals or RCS makeup required eAll Plants Provide Means to Provide Borated RCS Makeup PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposedto maintain RCS inventoiy control. Identifi, methods (Low Leak RCP Seals and/or boratedhigh pressure RCS makeup) andstrategy(ies) utilized to achieve this coping time.

Unless otherwise noted, information in this section was obtained from Reference 10.

RCS Inventory Control and Sub-Criticality with SG Available The Phase 1 activities involve the plant cooldown, passive injection of the accumulators, and isolation of the accumulators before full depletion. This is done to prevent nitrogen injection into the RCS. The loss of all RCP seal cooling will lead to RCS leakage through the seals into containment from all four RCPs (i.e., 21 gpm per RCP or 84 gpm total at full pressure). The IPEC initial coping strategy evaluation determined the following.

eDue to SG depressurization as directed by 2/3-ECA-0.0, the RCP seal leakage reduces.

Based on SG depressurization and approximately 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months of AFWS cooling, core uncovery is not projected to occur until approximately 237 hours0.00274 days 0.0658 hours 3.918651e-4 weeks 9.01785e-5 months into the event assuming no outside makeup is added to the RCS.

Due to the potential significant RCP seal leakage during Loss of All Seal Cooling, RCS inventory is a significant concern for the ELAP scenario. The ELAP times when a FLEX pump would be required to conservatively ensure that single phase natural circulation or two phase natural circulation is maintained are provided in the table below. Also included is the time when the collapsed liquid level of the RCS volume would begin to drop below the Top of the Active Fuel (TOAF).

IPEC will initiate cooldown immediately upon declaring ELAP. The safety injection accumulators will provide the initial source of inventory in Phase I. By performing an early cooldown, inventory losses are reduced and access to the inventory in the accumulators is established. These actions extend the time frame in which the RCS is maintained in a condition of single phase natural circulation cooling.

Flow Condition IP2 IP3 Single-Phase Natural Circulation 5 hrs 4.5 hrs Two-Phase Natural Circulation 9.2 hrs 9.1 hrs Core Uncovery (Reflux Cooling) 17.6 hrs 17.5 hrs

2. Coping modifications consist of modifications installed to increase initial coping time, i.e. generators to preserve vital instruments or increase operating time on battery powered equipment.

23

Maintain RCS Inventory Control RCS Inventory Control and Sub-Criticality with SG Not Available The main concern for an ELAP during shutdown conditions is to maintain RCS inventory such that core cooling is maintained. During Modes 5 and 6, core cooling is maintained through heat removal from the RCS via coolant boil-off. During Phase 1, the inventory is maintained in the vessel by ensuring adequate RCS makeup using gravity feed from the RWST. The rate of gravity feed depends upon the RWST fluid height, line losses through the gravity flow path, and developed pressure within the RCS. Pressure is maintained sufficiently low in the RCS by ensuring adequate venting is established prior to entering conditions wherein SG cooling is not available as a part of shutdown risk management.

Maintain RCS Inventory Control Details:

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

ECA 0.0 for Loss of All AC Power (References 7 and 8).

Identify modifications List modifications No modifications are required.

Key Reactor Parameters List instrumentationcreditedor recovered for this coping evaluation.

1.Core Exit Thermocouple (CET) Temperature 2.RCS Wide Range Pressure 3.Reactor Vessel Level Indicating System / Pressurizer Level 4.Subcriticality.

IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Notes:

24

Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain RCS inventory control. Identifi. methods (Low Leak RCP Seals and/or boratedhigh pressure RCS makeup) and strategy"(ies) utilized to achieve this coping time.

Unless otherwise noted, information in this section was obtained from Reference 10.

RCS Inventory Control and Sub-Criticality with SG Available The Phase 2 activities for RCS inventory control involve aligning a pump to provide borated coolant for RCS makeup and to maintain the reactor subcritical. The FLEX pump will be deployed at a time consistent with the loss of single phase natural circulation. This pump will provide core make-up such that a limited period of two phase natural circulation cooling occurs maintaining the respective flow conditions desired in order to provide adequate core cooling.

Given the reactor coolant pump characteristics of the Model 93 seal configuration, including the limited leakage expected at reduced inventory conditions , it is reasonable to be in two phase natural circulation for a small period of time.

Without a letdown path, contraction of the RCS inventory during the plant cooldown and depressurization is the only means in which available space is made to borate the RCS. A letdown path can be provided, if required, by opening the head vent to allow for increased boration capabilities. To ensure that the core is maintained subcritical, borated injection into the RCS is provided from the installed, high concentration boric acid tanks via a FLEX pump. This injection also compensates for RCS leakage and contraction, enabling refill of the RCS, and eventually establishing level in the pressurizer.

For Unit 2, valves 7300 or 7302 will be used as a primary connection. For Unit 3, SI-105 will be used as the primary connection. The secondary connection for RCS injection will be through 1.5" vent valve C- 11for Unit 2 and 1.5" vent valve 102 for Unit 3. These valves are directly downstream from charging pump 22 for Unit 2 and charging pump 32 for Unit 3 The BASTs will be used as the primary source for makeup to the RCS through hookups to the newly added 2" source connection off each tank. These tanks are seismically qualified, missile protected (Unit 2 requires evaluation), and well above PMF level. Locations of these drain connections are shown in Figure A3 -23 for Unit 2 and Figure A3 -24 for Unit

3. Suction from the BASTs will be routed through flexible hose to a FLEX pump in the staging area outside of the PAB.

Discharge hose from the FLEX pump will be routed back into the PAB where it will be connected to the primary connections.

The RWST borated inventory will be used as the secondary source for makeup to the RCS through direct hookups with hoses. The source connection points include the 2 inch drain lines. Locations of the connections to the RWST can be found on Figure A3-8 and Figure A3-12.

RCS Inventory Control and Sub-Criticality with SG Not Available At some point initial coping strategies for RCS inventory control will no longer support the requirements and FLEX equipment will be deployed to provide this function. A Mode 5/6 RCS Makeup pump will be deployed to establish make-up for RCS boil-off and maintain RCS inventory. Eventually, due to continuous injection of borated coolant and boil-off, the RCS boric acid concentration will increase. The capability has been provided to increase the flow and establish a forward flushing flow path through the established hot leg vents which will preclude the RCS fluid from reaching the incipient boric acid precipitation point.

It is noted that a higher capacity pump is required for Modes 5 and 6.

25

Maintain RCS Inventory Control Details:

Provide a brief description of FSGs will be developed to dictate these actions during a FLEX event.

Procedures/Strategies/Guidelines Identify modifications List modifications A description of any modifications required to implement this connection point are documented below. This includes new piping, valves, or adapters.

Unit 2 The BAST will require a 2" or greater suction source to be added. This connection will include a 2" or greater manual isolation valve, a 2"x4 " reducer and a connection for a 4" STORZ hose connection. A 2"x4 " reducer and a connection for a 4" STORZ hose connection will be added to the RWST.

The 4" line just downstream of the 7300 valve will be equipped with an additional 4" manual isolation valve and a 4" STORZ hose connection.

Unit 3 The BAST will require a 2" or greater suction source to be added. This connection will include a 2" or greater manual isolation valve, a 2"x4 " reducer, and a connection for a 4" STORZ hose connection. A 2"x4 " reducer, and a connection for a 4" STORZ hose connection will be added to the RWST.

A 6x6x4 inch tee will be installed in the 6 inch line near valve SI-105. The 4-inch branch line will contain two 4-inch manual isolation valves and a 4-inch STORZ hose connection.

For both units, the piping just downstream of the vent valve used for the secondary connection point will need to be modified to include a 1.5"xl.5"x.5" tee. The continuation of the vent line will be reattached to the 0.5" branch and include a 0.5" normally open isolation valve. A 1.5"x4 " reducer will be attached to the remaining 1.5" line. The 4" line will include a 4" manual isolation valve and a 4" STORZ hose connection.

Key Reactor Parameters List instrumentation creditedor recoveredfor this coping evaluation.

1.Core Exit Thermocouple (CET) Temperature 2.RCS Wide Range Pressure 3.Reactor Vessel Level Indicating System / Pressurizer Level 4.Subcriticality.

IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

26

Maintain RCS Inventory Control Storage/Protection of Equipment:

Describe storage/protection plan or schedule to determine storage requirements Seismic List how equipment is protected or schedule to protect The storage locations will be designed or evaluated equivalent to ASCE 7-10, Minimum Design Loads for Buildings and Other Structures. Large portable FLEX equipment will be secured as appropriate during SSE and will be protected from seismic interactions with other components. No components will be stacked or at a raised elevation as to cause interference with the deployment of any of the FLEX equipment.

Flooding List how equipment is protected or schedule to protect Note: if stored below current flood level, then ensure procedures exist to The storage location is located above the maximum flood level of 15 ft mean sea move equipment prior to exceeding level.

flood level.

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

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

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

27

Maintain RCS Inventory Control Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

The equipment storage locations for this connection point will include the Unit I hardened structure as specified for storage of the SG FLEX pump. Deployment from the Unit 1 storage area would necessitate the use of trucks or forklifts capable of pulling the FLEX pumps. Paths to each staging area are shown in green in Figure A3-36 in Attachment 3 of Appendix G. Structures that are possible sources of debris are shown in red. The entire path to each staging location is above flood level and no security barriers exist along either path.

Strategy Modifications Protection of connections Ident*ij Strategy including how the Identijf modifications Identifj' how the connection is equipment will be deployed to the protected point of use.

The primary staging locations for Modifications for the connection The connections are located in a diesel-driven FLEX pumps is the locations are provided in the building which is protected from high pavement just south of the RWST in previous section. winds, missiles, flooding and seismic Unit 2, and the driveway leading to events. The Unit 2 BAST requires the SFP access doors in Unit 3 as evaluation for missile protection.

shown in Figure A3-25 and Figure A3-26 in Attachment 3. These locations are well above the PMF level (zl5 ft) and are close to all outdoor tanks.

The BASTs will be used as the primary source for makeup to the RCS through hookups to the newly added 2" source connection off each tank. These tanks are seismically qualified, missile protected (Unit 2 requires evaluation), and well above PMF level. Locations of these drain connections are shown in Figure A3-23 for Unit 2 and Figure A3-24 for Unit 3. Suction from the BASTs will be routed through flexible hose to a FLEX pump in the staging area outside of the PAB. Discharge hose from the FLEX pump will be routed back into the PAB where it will be connected to the primary connections The RWST borated inventory of will be used as the secondary source for makeup to the RCS through direct hookups with hoses. The source 28

Maintain RCS Inventory Control connection points include the 2 inch drain lines. Locations of the connections to the RWST can be found on Figure A3-8 and Figure A3-12 Flexible piping routes are shown in Figure A3-27 through Figure A3-35 in Attachment 3 from each suction source to the staging locations for each unit. Red lines indicate discharge piping while green lines indicate suction piping. For Unit 2, the 4" valve 7300 or 7302 will need to be opened as well as the added isolation valve to allow flow to RCS.

These valves may be operated by their hand wheels. Similarly, for Unit 3, valves SI-105 will need to be opened as well as the added isolation valve.

The sources of coolant and staging locations for the secondary connection point will be identical to those specified for the primary RCS connection. Piping from both staging locations to the secondary connection points are similar to those in the primary connection. All routing outside of the PAB and the placement of the FLEX pump are the same. The only differences in routing occur between the entry point to the PAB and the charging rooms. Figure A3-37 and Figure A3-38 in Attachment 3 show the different routings. The isolation valve on the 0.5" vent line will need to be manually closed and the 4" and C-11/102 isolation valves will need to be manually opened.

The source and movement of fuel for this alignment will be identical to the strategies identified in the Core Cooling Section.

29

Maintain RCS Inventory Control PWR Portable Equipment Phase 3:

Provide a general description qf the coping strategies using phase 3 equipment including modifications that are proposedto maintain RCS inventory con trol. IdentiA' methods (Low Leak RCP Seals and/or boratedhigh pressure RCS makeup) and strategy(ies) utilized to achieve this coping time.

This section addresses RCS inventory control and subcriticality issues for conditions where steam generators are available. RCS inventory control and subcriticality issues for conditions where steam generators are not available are addressed in the core cooling section of this report.

Unless otherwise noted, the information in this section was obtained from Reference 10.

Reactor level and subcriticality is adequately maintained via the Phase 2 strategy; however, borated water sources are limited to some extent. The BASTs and the RWSTs will be used as the source of borated water for the FLEX strategies.

An analysis was performed that determined that these sources will provide a sufficient supply of borated water until Phase 3 actions are initiated. The strategy for providing makeup to the borated water tanks is addressed as a Phase 3 action. Phase 3 deployment of a unit capable of generating ultra-pure borated coolant will further extend coping times with respect to the RCS inventory management. The specific strategy for providing borated coolant makeup will need to be determined during the detailed design phase.

In Phase 3 with the steam generators unavailable, core cooling continues to be maintained through boil-off and is therefore, an inventory issue, while boron concentration is maintained by continued provision of adequate flushing flow. Phase 3 deployment of a unit that is capable of generating ultra-pure borated coolant can further extend coping times with respect to the RCS inventory management. Indefinite coping is successfully established once a transition from SG cooling to residual heat removal (RHR) system cooling is established.

Details:

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

FSGs will be developed to support the Phase 3 RCS inventory control strategies Identify modifications List modifications Each of the Phase 3 strategies will utilize common connections as described for the Phase 2 connections to prevent any compatibility issues with the offsite equipment.

Key Reactor Parameters List instrumentationcredited or recovered for this coping evaluation.

l.Core Exit Thermocouple (CET) Temperature 2.RCS Wide Range Pressure 3.Reactor Vessel Level Indicating System / Pressurizer Level 4.Subcriticality IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

30

Maintain RCS Inventory Control Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

The deployment paths for equipment received from the regional response center will be developed after the IPEC and the RRC have agreed upon a location to receive equipment onto the site.

Strategy Modifications Protection of Connections Identi/.': Strateg, including how the Identii", modifications Identi.r how the connection is equipment will be deployed to the protected point of use.

Reactor level and subcriticality is Each of the Phase 3 strategies will The connection points are located in adequately maintained via the Phase utilize common connections as buildings which are seismically 2 strategy, however, borated sources described for the Phase 2 connections qualified and missile protected.

are limited. Phase 3 deployment of a to prevent any compatibility issues unit capable of generating pure with the offsite equipment.

water and then borating the pure water can further extend the coping times with respect to RCS inventory management. This is discussed in detail with the other FLEX Phase 3 strategies in the section on maintaining core cooling and heat removal.

Note:

I. This strategy will be finalized once equipment and equipment specifications coming from the RRC are finalized.

31

Maintain Containment Determine Baseline coping capability with the installed coping3 modifications, not including FLEX modifications, and utilizing the methods described in Table 3-2 of NEI 1T-06:

Containment Spray

Hydrogen igniters (ice condenser containments only)

PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain containment. Identi/i.' methods (containmentsprav/Hydrogen igniter) and strateg.(ies) utilized to achieve this coping time.

Containment pressure and temperature are expected to increase during an ELAP due to loss of containment cooling and RCS leakage into containment. By performing an early cooldown, the rate of leakage and heat rejection to containment are reduced and the pressure and temperature are not expected to rise to levels which could challenge the containment structure.

Containment evaluation will be performed based on the boundary conditions described in Section 2 of NEI 12-06.

Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed.

Details:

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

N/A Identify modifications List modifications N/A Key Containment Parameters List instrumentationcreditedor recoveredfor this coping evaluation.

1.Containment Pressure IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Notes:

3. Coping modifications consist of modifications installed to increase initial coping time, i.e. generators to preserve vital instruments or increase operating time on battery powered equipment.

32

Maintain Containment PWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain containment. Identi.f methods (containment spra'/hydrogen igniters) and strategv(ies) utilized to achieve this coping time.

Containment evaluation will be performed based on the boundary conditions described in Section 2 of NEI 12-06.

Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed.

The monitoring of containment conditions will still occur. FSGs will be developed for containment monitoring during a FLEX event.

Details:

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

es FSGs will be developed to dictate these actions during a FLEX event.

Identify modifications List modifications None Key Containment Parameters List instrumentationcreditedor recoveredfor this coping evaluation.

1.Containment Pressure IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Storage/Protection of Equipment:

Describe storage /protection plan or schedule to determine storage requirements Seismic List how equipment is protected or schedule to protect N/A Flooding List how equipment is protected or schedule to protect Note: if stored below current flood level, then N/A ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds List how equipment is protected or schedule to protect N/A Snow, Ice, and Extreme Cold List how equipment is protected or schedule to protect N/A 33

High Temperatures List how equipment is protected or schedule to protect N/A Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Identifr Strateg-' including how the Identi/ modifications Identif.P how the connection is equipment will be deployed to the protected point of use.

N/A N/A N/A Notes:

34

Maintain Containment PWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain containment. Identify methods (containment spray/hydrogen igniters)and strateg,(ies) utilized to achieve this coping time.

Containment evaluation will be performed based on the boundary conditions described in Section 2 of NEI 12-06.

Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed.

Monitoring of containment conditions will still occur. FSGs will be developed for containment monitoring during a FLEX event.

Action taken to support containment integrity may include establishing RHR. Once RHR is realigned, and decay heat is being removed through that system, the containment temperature and pressure will begin to decrease.

Details:

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

N/A Identify modifications List modifications N/A Key Containment Parameters List instrumentation credited or recoveredfor this coping evaluation.

N/A Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of Connections Identify Strategy inchlding how the IdentiP,modifications Identify how the connection is equipment will be deployed to the protected point of use.

N/A N/A N/A Notes:

35

Maintain Spent Fuel Pool Cooling Determine Baseline coping capability with installed coping 4 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Makeup with Portable Injection Source PWR Installed Equipment Phase 1:

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

Unless otherwise indicated, the information in this section was obtained from Reference 10.

Spent Fuel Pool cooling is not challenged early in the event; however, access to the SFP area as part of Phase 2 response could be challenged due to environmental conditions local to the pool, so action is required to establish ventilation in this area and establish any equipment local to the spent fuel pool required to accomplish coping strategies. For these reasons, most of the actions required for Phase 2 occur outside of the Fuel Building. The SFP vent will be established by opening a large roll up door.

Details:

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

FSGs will be developed to dictate these actions during a FLEX event.

Identify modifications List modifications N/A Key SFP Parameter List instrumentationcredited or recoveredfor this coping evaluation.

1.SFP Level IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Notes:

4. Coping modifications consist of modifications installed to. increase initial coping time, i.e. generators to preserve vital instruments or increase operating time on battery powered equipment.

36

Maintain Spent Fuel Pool Cooling PWR Portable Equipment Phase 2:

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

Unless otherwise noted, information in this section was obtained from Reference 10.

Operating, Pre-Fuel Transfer, or Post-Fuel Transfer The Spent Fuel Pool (SFP) sloshing and time-to-boil evaluation determined the volume lost from the SFP due to sloshing to be 2313.15 ft 3 which corresponds to a 2.42 ft loss in the SFP level. Assuming no other reduction in coolant inventory other than the sloshing, results in a time to boil of 12.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for a seismic event in either the North/South or East/West direction assuming the most conservative critical damping and an initial bulk water temperature in the pool of 1007F. This value was calculated using the normal operating decay heat load.

Fuel in Transfer or Full Core Off-Load The Spent Fuel Pool (SFP) sloshing and time-to-boil evaluation determined the volume lost from the SFP due to sloshing to be 2313.15 ft 3 which corresponds to a 2.42 ft loss in the SFP level. Assuming no other reduction in coolant inventory other than the sloshing, results in a time to boil of 4.04 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for a seismic event in either the North/South or East/West direction assuming the most conservative critical damping and an initial bulk water temperature in the pool of 1407F. This value was calculated using the maximum credible heat load.

Makeup for Boil-Off Applicable to all Conditions An analysis was performed to determine the pump requirements for supplying SFP makeup. A flow rate of 114 gpm is conservative. In addition, all sites that have spent fuel pools that are capable of being drained must have provisions for SFP spray.

For the primary SFP makeup connection, a hose will be routed from the RWST suction source to the FLEX pump on the staging area outside the SFP building. The discharge hose will be routed through the side door of the SFP building and up to the floor of the SFP. This connection will need to be anchored to keep the hose stationary once deployed. The CST will be used as a secondary source of makeup for the SFP with a similar routing.

A secondary connection on the outlet piping from the SFP heat exchanger is required for both units. For both units, a tee will be installed in the 8"-#328 line.

For events occurring with the steam generators available and during a full core offload the RWST is the primary makeup source for the SFP FLEX pump. For events occurring when the steam generators are not available the CST is the primary makeup source for the SFP FLEX pump. This is dictated by the timing and deployment evaluation.

An analysis was performed indicating NPSH concerns when using the 2" drain line as a source connection for this strategy for both units. This analysis shows that a 3" drain line would allow for sufficient NPSH. Therefore, IPEC will modify the RWSTs to include a 3" connection.

A secondary source of coolant is coolant is the CST. The CSTs for both plants will also be modified to include a 3" or greater suction source connection.

A device to anchor the hose at the edge of the SFP must be installed to keep the hose stationary once deployed.

All sites that do not have spent fuel pools that are capable of being drained must have provisions for SFP spray. This means that in addition to the provision for 114 gpm makeup to the SFP discussed above, a 250 gpm SFP spray capability will be required as part of FLEX. The connection point, staging area, and hose routing are almost identical to 37

Maintain Spent Fuel Pool Cooling those described for SFP Cooling above. The exception being that the discharge hose will not be placed in the pool, but attached to a nozzle placed on the walkways surrounding the pool.

An oscillating nozzle monitor would need to be stored along with the discharge hose for this alignment. The monitor has a 2.5" hose inlet requiring a 4"x 2.5" reducing fitting for the discharge hose.

Details:

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

FSGs will be developed to support the Phase 2 Spent Fuel Pool Cooling strategies.

Identify modifications List modifications IPEC will modify the RWSTs to include a 3" connection. This 3" drain connection will include a manual isolation valve, a 3"x4" reducer, and a 4" STORZ hose connection.

A secondary source of coolant is the CST.

The CSTs for both plants will also be modified to include a 3" or greater suction source connection. This 3" drain connection will include a manual isolation valve, a 3"x4" reducer, and a 4" STORZ hose connection.

An 8"x8"x4" tee will be added to 8"-#328 line for both units for the secondary connection point. Two manual isolation valves and a 4" STORZ hose connection will be added to the end of the piping.

A device to anchor the hose at the edge of the SFP must be installed to keep the hose stationary once deployed.

Key SFP Parameter List instrumentation creditedor recoveredfor this coping evaluation.

1.SFP Level IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Storage/Protection of Equipment:

Describe storage/protection plan or schedule to determine storage requirements Seismic List how equipment is protectedor schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

Flooding List how equipment is protected or schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

Maintain Spent Fuel Pool Cooling Severe Storms with High Winds List how equipment is protected or schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

Snow, Ice, and Extreme Cold List how equipment is protected or schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

High Temperatures List how equipment is protected or schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

The equipment storage locations for this connection point will include the Unit I hardened structure as specified for storage of the SG FLEX pump. Deployment from the Unit I Storage area would necessitate the use of trucks or forklifts capable of pulling the FLEX pumps. The entire path to each staging location is above flood level and no security barriers exist along either path. Deployment paths are shown in Figure A3-46 and Figure A3-47 in Attachinent

3. Paths to each staging area are shown in green. Structures that are possible sources of debris are shown in red.

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

Staging locations for the SFP cooling Modifications for the connection The connections are located in will be the driveways to the SFP points are described in the previous buildings that are protected against Building garage doors. These are section. missiles, floods, high winds, and shown in Figure A3-39 and seismic events or are established at Figure A3-40. multiple and diverse locations.

For events occurring with the steam generators available (Modes 1-4) and during a full core offload the RWST is the primary makeup source for the SFP FLEX pump. For events occurring when the steam generators are not available (Modes 5-6) the CST is the primary makeup source for the SFP FLEX pump. This is dictated by the timing and deployment evaluation.

For this connection, a hose will be routed from the RWST 3" source connection.

39

Maintain Spent Fuel Pool Cooling The CST inventory may also be used for makeup to the spent fuel pool by drawing suction through a hose connected to a 3" or greater suction source connection.

Suction hose will be run from the RWST (or the CST if the RWST is not available) to the staging areas outside the SFP buildings. Discharge hose will be run from the staging areas in the driveways to the SFP building through the side door and up to the SFP floor level. Routings are shown in Figure A3-41 through Figure A3-45 in Attachment 3. There are no valve manipulations required in the existing plant system to align this FLEX strategy.

For the secondary connection, hose will be run from the staging areas in the driveways to the SFP building where it will be attached to the connections outside of the building.

The hard piping and tee connections are shown in purple in Figure A3-48 and Figure A3-49 in Attachment 3.

The four isolation valves need to be opened during the event to allow for coolant to pass to SFP.

The source and movement of fuel for this alignment will be identical to the strategies identical to those identified for the Core Cooling Section.

Notes:

40

Maintain Spent Fuel Pool Cooling PWR Portable Equipment Phase 3:

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

In Phase 3, the spent fuel pool is initially cooled via continued boil-off and makeup or via spray. Alignment of a portable SFP cooling system from the RRC (backup to Phase 2 equipment) provides indefinite coping capability following the event.

Details:

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

FSGs will be developed for implementation of the Phase 3 FLEX strategies Identify modifications List modifications None Key SFP Parameter List instrumentationcreditedor recoveredfor this coping evaluation.

1.SFP Level IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

The deployment paths for equipment received from the regional response center will be developed after the IPEC and the RRC have agreed upon a location to receive equipment onto the site.

Strategy Modifications Protection of connections Identif, Strategy including how the Identi .v modifications Identifi, how the connection is equipment will be deployed to the point of protected use.

The SFP cooling system pumps will be None Connections will be made either repowered using a larger generator from inside of the Fuel Building or on the RRC or a mobile heat exchanger the exterior of the wall.

system from the RRC will be used to reestablish SFP cooling.

Notes:

41

Safety Functions Support Determine Baseline coping capability with installed coping 5 modifications not including FLEX modifications.

PWR Installed Equipment Phase 1 Provide a general description of the coping strategies using installed equipment including station modifications that are proposed to maintain and/or support safet fimctions. Identify methods and strategy(ies),utilized to achieve coping times.

Unless otherwise noted, the information in this section was obtained from Reference 10.

All essential instrumentation required to monitor core, containment, and spent fuel parameters is powered from the Station batteries 21/31, 22/32, 23/33, and 24/34 via the 125 Vdc buses for Units 2/3. The Loss of All AC Procedure (References 7 and 8) directs operators to shed dc loads in Steps 15/17 for Unfits 2/3. This strategy will extend Battery life into the 2.4/3.8 to 5.2/5.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months range depending on the Battery bank for Units 2/3 (Reference 6).

Once the ELAP is announced, the operators will establish a deeper dc load shed. These actions will extend the life of the Batteries for the remainder of the Phase 1 coping period. These further dc loads to shed will be identified and included in the FLEX procedures. Additional actions include opening control room cabinet doors on a loss of ventilation (Step 5 of Loss of All AC Procedure) to provide cooling to control room and its components.

Onsite portable equipment must be deployed, staged, and able to power essential instrumentation before Battery depletion. Given the IPEC's existing calculations for Battery life on an ELAP, the time to establish temporary power is very short. Additional measures may need to be implemented to ensure vital indication and dc loads are available until the Battery chargers can be restored in Phase 2.

Details:

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

2/3-ECA-0.0 - Loss of All AC Power (References 7 and 8) directs operators at Step 15/17 (U2/U3) to strip dc loads per 2/3-AOP-DC-I and 2/3-AOP-IB-1. A requirement to begin load shedding, if power will not be restored to the 480 V vital buses by 30 minutes after the event start should be added. A similar requirement to begin deep load shedding should be added, if power will not be restored by 45 minutes after the event start. Additionally, 2-ECA-0.0 should include a notice to provide temporary control room ventilation within 30 minutes by opening doors similar to Step 7 and Attachment 2 of 3-ECA-0.0.

Identify modifications List modifications None Key Parameters List instrumentation creditedfor this coping evaluationphase.

5. Coping modifications consist of modifications installed to increase initial coping time, i.e. generators to preserve vital instruments or increase operating time on battery powered equipment.

42

Safety Functions Support The dc bus voltage is required so the operators can ensure that the dc bus voltage remains above 105 volts.

IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

43

Safety Functions Support PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain and/or support safe,.fiunctions. Identif, methods and strategy(ies) utilized to achieve coping times.

Unless otherwise noted, the information in the section was obtained from Reference 10.

Electrical Safety Function Support The electrical portion of the Units 2/3 Phase 2 coping strategy has the main goal of repowering the vital 480 Vac buses 2A, 3A, 5A, and 6A. This will be achieved through spare breaker connection points in Bus 2A or 6A. After repowering from one of these locations, buses may be cross-tied through operator manipulation of breakers to allow powering of any Battery charger or other loads as discussed below. A single FLEX generator will be designated to achieve this goal.

Repowering essential instrumentation will be achieved by repowering Battery chargers 21/31, 22/32, 23/33 and 24/34 for Units 2/3. These chargers are connected to the 480 Vac vital buses through the MCCs as shown in the following tables. The 480 Vac buses are also necessary to power fuel oil transfer pumps (FOTPs) and Battery rooms exhaust fans.

The FLEX generator will power Bus 2A or 6A via flexible cable to be run from either of the staging locations. The ends of the cable will have male connections that can be quickly connected to the generator on one end and the bus on the other end. Four cables must be run (three phases and ground) the entire route shown in the conduit /cable routing description below. On the bus end, the cables will plug into a modified breaker with quick-connect contacts on the face, installed in a spare breaker slot, or be connected to a junction box with similar quick-connect contacts. This breaker will be normally open, and then closed once the FLEX generator has been started. Spare Breaker 23A/31B (U2/U3) on Bus 2A was identified as a preferred spare to be permanently replaced with the modified breaker, as shown in Figure A3-60/101 (U2/U3) in Attachment 3. A secondary option for the installation of a modified breaker is by replacing the EDG Breaker 13C/15B,C (U2/U3) on Bus 6A once entering an ELAP as shown in Figure A3-61/102 (U2/U3) in Attachment 3.

The use of this modified breaker allows for an easy cable connection to the bus. By utilizing color-coded cables and connectors, operators would be able to perform this action without requiring additional personnel, such as an electrician.

For Unit 3, several of the Battery room fans may not survive all events due to their location on non-vital bus panels.

Portable fans and generators to exhaust the Unit 3 Battery rooms will be used.

Additional equipment may be required to be powered during this event such as portable lighting and ventilation fans.

These are not conveniently powered via the FLEX generator. Small portable generators are available onsite if this additional lighting and ventilation is deemed necessary. Small Battery packs for these items are also a possibility.

Alternate Coolant Source Safety Function Support The following coolant sources may be available for makeup to the CST:

The City Water Tank is currently capable of supplying coolant to the AFW system. The CWT is not missile protected, and the piping for this coolant supply is not seismically qualified. Therefore, it cannot be relied upon. However, if the CWT is available, and the piping is capable of supplying coolant, this source would be the preferred choice and could supply the required inventory needed for removing decay heat.

The PWST and the FWST are seismically qualified, but not missile protected. Therefore, they may not be available to supply makeup. If they are available, they would be the 2nd and 3rd choices and could supply the remaining volume needed to reach 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This tank would be the 4th choice, since it is a borated source, which would have a negative impact on the AFW system.

44

Safety Functions Support Also, the RWST is used for other FLEX strategies and may not have enough inventory when needed.

The Unit 2/3 PWST is a potential makeup source to the Unit 2 CST. Each tank provides 165,000 gallons of water. The tank is not missile protected. Hose will be run from the PWST to a booster pump, from the booster pump to the FLEX pump, and then to the CST. The hose will be run through the manway on top of the CST. The routing between the Unit 2 PWST and Unit 2 CST is shown in Figure A3-52 in Attachment 3 with suction routing in green while red represents discharge. The booster pump should be placed within 50 ft of the PWST. The routing between the Unit 3 PWST and Unit 3 CST is shown in Figure A3-57 with suction routing in green while red represents discharge. The booster pump should be placed within 50 ft of the PWST.

The Units 2/3 FWST is a potential makeup source to the Unit 2 CST. Each tank (U2 FWST, U3 FWST3 1, and U3 FWST32) provides 300,000 gallons of water. The tank is not missile protected and is not seismically qualified. Hose will be run from the FWST to a booster pump, from the booster pump to the FLEX pump, and then to the CST. The hose will be run through the manway on top of the CST. Routing between the Unit 2 FWST and Unit 2 CST is shown in Figure A3-51 with suction routing in green while red represents discharge. The booster pump should be placed within 50 ft of the FWST. Routing between the Unit FWST31 and Unit 3 CST is shown in Figure A3-55 with suction routing in green while red represents discharge. Routing between the Unit FWST32 and Unit 3 CST is shown in Figure A3-56 with suction routing in green while red represents discharge. The booster pump should be placed within 50 ft of the source tank.

The Unit 2/3 RWST is a potential makeup source to the Unit 2 CST. Each tank provides 345,000 gallons of borated water. Hose will be run from the RWST to a booster pump, from the booster pump to the FLEX pump, and then to the CST. The hose will be run through the manway on top of the CST. Routing between the Unit 2 RWST and Unit 2 CST is shown in Figure A3-50 with suction routing in green while red represents discharge. The booster pump should be placed within 50 ft of the RWST. The routing between the Unit 3 RWST and Unit 3 CST is shown in Figure A3-54 with suction routing in green while red represents discharge. The booster pump should be placed within 50 ft of the RWST.

The condenser hotwell was evaluated as a potential alternate water source; however, it is not seismically designed.

Details:

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

FLEX Generator Deployment:

eDeploy the generator to the staging area and connect

Align switchgear to Battery chargers Restoring Normal Power to the Class I E 480V Buses. This guideline will be required when the FLEX generator is connected or a normal power sources is restored and is not time-critical.

New Procedures/Guidelines:

ePlant personnel must be trained on all new procedures eAligning Buses 2A, 3A, 5A, and 6A and associated MCCs for FLEX Generator - 2 operators to operate -50 breakers, no special skills, 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . This would include opening all breakers and breakers on the downstream MCCs that will be repowered for FLEX strategies; specifically MCCs 24A, 26B, 26C, 27A, and 29A (Unit 2) and MCCs 32, 36C, 36D, 36E, 37, and 39 (Unit 3).

45

Safety Functions Support Identify modifications List modifications Phase 2 electrical design requires the following modifications:

elnstallation of modified breaker, connection through a tie breaker and test breaker or equivalent in Bus 2A, replacing the spare breaker 23A/31 B (U2/U3) in an ELAP elnstallation of a housing for two temporary modified breakers or equivalent near Bus 6A, for replacement of the EDG Breaker 13C/1 5B,C (U2/U3) in an ELAP eModification to the EDG intake grating and louvers or the EDG exhaust fan screen to allow for a cable to be routed from the roof to elevation 15' of the EDG building in an ELAP (U3).

Phase 2 alternate coolant source requires the following modifications; eOne 4 inch STORZ connection (suction) will be added to the PWST of each unit along with two isolation valves.

eOne 4 inch STORZ connection (suction) and two isolation valves will be added to the Unit 2 FWST and to the Unit 3 FWST31 and FWST32.

eOne 4 inch STORZ connection (suction) and two isolation valves will be added to the RWST of each unit.

Key Parameters List instrumentationcredited for this coping evaluationphase.

dc bus voltage is required so operators can ensure that the dc bus voltage remains above 105 volts.

IPEC will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI 12-06.

Storage/Protection of Equipment:

Describe storage/protection plan or schedule to determine storage requirements Seismic List how equipment is protectedor schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

Flooding List how equipment is protectedor schedule to protect Note: if stored below current flood level, then ensure procedures exist to move This information is identical to what is provided for Core Cooling and Heat equipment prior to exceeding flood level. Removal.

Severe Storms with High Winds List how equipment is protected or schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

46

Safety Functions Support Snow, Ice, and Extreme Cold List how equipment is protected or schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

High Temperatures List how equipment is protected or schedule to protect This information is identical to what is provided for Core Cooling and Heat Removal.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

Onsite portable. equipment will be deployed from the FLEX equipment storage location, staged in the designated staging areas, connected to the applicable cables (electrical) or hoses (coolant), and begin performing the FLEX functions.

Strategy Modifications Protection of connections Identif, Strategy including how the Identifj' modifications Identfif how the connection is equipment will be deployed to the protected point of use.

Electrical Modifications are described in The connections will be located in From the Primary and Secondary previous section. buildings that are protected from Staging Locations are shown in external hazards.

Figure A3-59.

Unit 2 Primary Staging Location Cable Routing From the Primary Staging location cables will be routed around the northern wall of the Unit 2 Containment, through the Transformer Yard, and into the 480V Switchgear Room. This route is illustrated in Figure A3-62 and Figure A3-63 in Attachment 3.

47

Safety Functions Support Routing down the slope from the Unit 2 CST to the Unit 2 Transformer Yard should be done in a cautious manner by two operators. The length of cable needed for this routing is 1075 ft.

Unit 2 Secondary Staging Location Cable Routing From the secondary staging location for Unit 2 cables will be run from the generator, past the Unit 2 EDG Building and into the Unit 2 Control Building at elevation 72'. This is illustrated in Figure A3-64 in . The length of cable needed for this routing is 700 ft.

The cables will enter the Unit 2 Control Building at elevation 72' and then travel down Stair #4 to elevation 15'. This path is shown in Figure A3-65 through Figure A3-68.

Unit 3 Primary Staging Location Staging Routing From the Primary Staging Location shown in Figure A3-59, cables will be routed along the northern wall of the Unit 3 containment using the stairs on the steep side or the gentler slope to the north. The cables will then be taken through the Unit 3 Transformer Yard and into the 480V Switchgear Room. This route is illustrated in Figure A3-73 and Figure A3-74 in .

Unit 3 Secondary Staging Location Routing From the secondary staging location for Unit 3 as shown in Figure A3-59, cables will be run southwest from the generator to the grated roof over the Unit 3 EDG Rooms. Cables will be dropped to the floor of the EDG Rooms, through one of the EDG exhaust fans, or through the EDG room air intakes. Both options have louvers and screens that may need to 48

Safety Functions Support be modified to feed cable through the opening. Once at the 15' level of the EDG Rooms, the 480V Switchgear is accessed through a door in the room containing EDG 31. This path is illustrated in Figure A3-75 through Figure A3-80 in Attachment 3.

Coolant The storage locations, deployment paths, and staging locations for the FLEX equipment are provided in Figure A3-3, Figure A3-4 and Figure A3-15 through Figure A3-18 in . The existing Unit 1 Chemical Systems Building will be used as a storage location. The deployment routes are shown in see Figure A3-15 and Figure A3-16. The deployment paths to the secondary staging location are shown in Figure A3-15 and Figure A3-16 and the primary connection deployment discussion apply to the secondary staging area.

Notes:

49

Safety Functions Support PWR Portable Equipment Phase 3 Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain and/or support sa/eO.fiunctions. Identif methods and strategy(ies) utilized to achieve coping times.

Unless otherwise noted, the information in this section was obtained from Reference 10.

The electrical portion of the Phase 3 coping strategy has the main goal of repowering the 480 Vac equipment to aid in cooling down the plant to a stable, Mode 5 condition. This will be achieved through the same spare breaker connection points in Bus 2A or 6A as presented for Phase 2. However, new breakers with a larger amp capacity rating will need to be used in the same breaker slot. After repowering from one of these locations, buses may be cross-tied through operator manipulation of breakers to allow powering of any of the RHR or CCW pumps in addition to the Phase 2 loads.

A single, large generator deployed from the Regional Response Center will be placed in the Unit 2 staging area shown in order to achieve this goal. Repowering the RHR and the CCW pumps will be achieved by powering the 480 Vac vital buses. Locations to tie into will be identical to those shown in Figure A3-60 and Figure A3-61 in Attachment 3.

Details:

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

The IPEC will utilize industry developed guidance from the PWROG, EPRI, and NEI to develop site-specific guidelines for the deployment and implementation of the FLEX strategies, as well as the interfaces for the FLEX strategies with existing plant procedures. This strategy will require procedures to deploy and connect the 480V diesel generator, and restore power to the required vital buses.

Identify modifications List modifications Phase 3 electrical design requires the following modifications:

Installation of a housing for two modified breakers, connection through a tie breaker and test breaker, connection through a tie breaker and test breaker or the equivalent near Bus 2A, for replacement of spare breaker 23A/31B (U2/U3) in an ELAP

Installation of a housing for two temporary modified breakers, connection through a tie breaker and test breaker or the equivalent near Bus 6A, for replacement of EDG Breaker 13C/15B, C (U2/U3) in an ELAP.

Key Parameters List instrumentationcreditedfor this coping evaluationphase.

No instrumentation is required to support the Phase 3 electrical coping strategies.

50

Safety Functions Support Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

The deployment paths for equipment received from the regional response center will be developed after the IPEC and the RRC have agreed upon a location to receive equipment onto the site.

Strategy Modifications Protection of connections Identif. Strategy including how the Identp inodifications Identif. how the connection is equipment will be deploYed to the protected point of use.

The cable route for Phase 3 will be Modifications for connections are The connections are located in identical to the routing chosen in identified in the previous section. buildings which are protected from Phase 2. However, new larger cables external hazards.

will need to be run along this identical route.

Notes:

51

PWR Portable Equipment Phase 2 Use and (potential/flexibility)diverse uses Performance Criteria Maintenance List portable Maintenance/PM equipment Core Containment SFP Instrumentation Accessibility Requirements Three (3) X 327 gpm, 1180.3 ft Will follow EPRI template AFW/Modes requirements 5&6 Pumps Three (3) RCS X 40 gpm, 3537 ft Will follow EPRI template Pumps requirements Three (3) SI X 137 gpm, 898.8 ft Will follow EPRI template Pumps requirements Three (3) SFP X 114 gpm, 75.6 ft Will follow EPRI template Pumps requirements Three (3) SFP X 250 gpm, 1067.4 ft Will follow EPRI template Spray Pumps requirements Three (3) 480 X X 300 kW Will follow EPRI template Vac Generators requirements Debris X Will follow EPRI template Removal requirements Equipment Pickup Trucks X X X X Will follow EPRI template or forklifts requirements Small X Will follow EPRI template Generators and requirements Portable Fans Fuel X X X X Will follow EPRI template Transportation requirements Equipment 52

PWR Portable Equipment Phase 2 Use and (potential/flexibility)diverse uses Performance Criteria Maintenance List portable Maintenance/PM equipment Core Containment SFP Instrumentation Accessibility Requirements Hose X X Will follow EPRI template requirements Cable X X Will follow EPRI template requirements 53

PWR Portable Equipment Phase 3 Use and (potential/flexibilit.') diverse uses Pert brmance Criteria Notes List portable equipment Core Containment SFP Instrumentation Accessibility Two (2) UHS X X 4000 gpm, 139 ft Will follow EPRI template Pumps requirements AFW Back X X 327 gpm, 1432 ft Will follow EPRI template Pump requirements Water Transfer X 327 gpm, 400 ft Will follow EPRI template Pump requirements Booster Pump X 327 gpm, 55 ft Will follow EPRI template requirements RCS Backup X 40 gpm, 4004 ft Will follow EPRI template Pump requirements SFP Backup X 250 gpm,. 1218 ft Will follow EPRI template Pump requirements Two (2) 480 X X X X X 2 MW Will follow EPRI template Vac Generators requirements Mobile X X Will follow EPRI template Boration Unit requirements Mobile Water X Will follow EPRI template Purification requirements Unit Mobile Heat X Will follow EPRI template Exchanger requirements Unit 54

PWR Portable Equipment Phase 3 Use and (potential/flexibilit,)diverse uses Performance Criteria Notes List portable equipment Core Containment SFP Instrumentation Accessibility Mobile Chiller X Will follow EPRI template Unit requirements Diesel-Driven X X X Will follow EPRI template Air requirements Compressor Large Fuel X X X X X Will follow EPRI template Trucks requirements Large Debris X Will follow EPRI template Removal requirements Equipment Hose X X X Will follow EPRI template requirements Cable X X X X X Will follow EPRI template I I_ I_ I I Irequirements 55

Phase 3 Response Equipment/Commodities Item Notes Radiation Protection Equipment

" Survey instruments

Dosimetry

Offsite monitoring/sampling

Radiological counting equipment

Radiation protection supplies

" Equipment decontamination supplies

Respiratory protection Commodities

Food oMeals ready to eat (MREs) oMicrowavable meals

Potable water Fuel Requirements

1. 2 Diesel fuel

Diesel fuel bladders Heavy Equipment

Transportation equipment o4WD tow vehicle

Debris clearing equipment Communications Equipment eSatellite phones ePortable radios Portable Lighting eFlashlights

Headlamps

Batteries

@Exterior light units with diesel generators 56

References

1. NRC EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," March 12, 2012. [ADAMS Accession Number MLI2056A045]

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

3. NRC JLD-ISG-2012-01, Revision 0, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," August 2012.

4. IPEC Report, "Indian Point 2 UFSAR," Revision 22, 2010.

5. IPEC Report, "Indian Point 3 UFSAR," Revision 4, 2011.

6. Indian Point Report CR-IP2-2011-3909, "IER 11-4 Near Term Actions to Address the Effects of an Extended Loss of All AC Power in Response to the Fukushima Daiichi Event," October 27, 2011.

7. 2-ECA-0.0, Revision 12, "Loss of All AC Power."

8. 3-ECA-0.0, Revision 8, "Loss of All AC Power."

9. IPEC Drawings

a. 502450 Rev. 1 Sh. 1: Indian Point Energy Center Overall Plot Plan Civil (Sht. 1)

b. A208088 Rev. 44: One Line Diag. of 480 VAC. SWGRS. 21 & 22. Bus 2A, 3A, 5A & 6A - UFSAR Figure No. 8.2-6

c. A249955, Rev. 21: One Line Diagram 480V AC MCC 29 & 29A

d. 9321-F-3005, Rev. 110: One Line Diagram 480V Motor Control Center 27 & 27A

e. A249956, Rev. 18: One Line Diagram 480V MCC 24 & 24A

f. B248513, Rev. 12: Single Line Diagram 480V MCC 26C & CCR Vent. Dist. Panel 21

g. 9321-01-20346, Rev. 6: Condensate Storage Tank. General Plan

h. 9321-f-1381, Rev. 25: Control Building Floor Plans & Sections

i. PFP-251, Rev. 8: IPEC Pre-Fire Plans

j. A216386, Rev. 2: Indian Point 1 & 2 300,000 Gal Water Storage Tank and Foundation for Backup Fire Protection. Sections, Plans, and Details

k. PFP-156, Rev. 13: IPEC Pre-Fire Plans 57

1. PFP-253, Rev. 13: IPEC Pre-Fire Plans

m. PFP-252, Rev. 11: IPEC Pre-Fire Plans

n. 617F644, Rev. 33: 480V One Line Diagram

o. 9321-F-30063 Shl, Rev. 77: Single Line Diagram 480V Motor Control Center No.'s 36A, 36B &

36C

p. 9321-F-30063 Sh2, Rev. 10: Single Line Diagram 480V Motor Control Center No.'s 36D & 36E

q. 9321 -F-30053, Rev. 72: Single Line Diagram 480V Motor Control Centers 37, 38, 39 & 311

r. 932 1-F-30043 Sh2, Rev. 20: Single Line Diagram 480V Motor Control Centers No's 32 & 35

s. IP3V-91-0058, Rev. 3: General Plan (Condensate Storage Tank)

t. 9321 -f- 10543, Rev. 10: Control and Diesel Generator Buildings Concrete Plan El. 15'-01"

u. PFP-351, Rev. 5: IPEC Pre-Fire Plans

v. IP3V-91-14.6-0085, Rev. 2: Unit 3 General Plan 30'-0 DIAx 35'-3 High Dome Roof Tank- Primary Water Storage Tank

w. 932 1-F-40483, Rev. 9: Diesel Generator Building Heating & Ventilation Plan & Sections

x. PFP-354A, Rev. 0: IPEC Pre-Fire Plans

y. PFP-354, Rev. 0: IPEC Pre-Fire Plans

z. 9321-F-2019-116, Rev. 116: Flow Diagram Boiler Feedwater - UFSAR Figure No. 10.2-7 aa. 932 I-F-20193, Rev. 60: Flow Diagram Boiler Feedwater bb. 9321-2018-140, Rev. 140: Flow Diagram Condensate & Boiler Feed Pump Suction - UFSAR Figure No. 10.2-5 (Sht. 1) cc. 932 1-F-20183, Rev. 58: Flow Diagram Condensate & Boiler Feed Pump Suction (Sht. 1) dd. B216214-5 Rev. 5: Unit 2 FWST Drawing ee. 9321-01 20339-4 Rev. 1: Unit 2 RWST Drawing ff. 9321-01 20352-1 Rev. 2: Unit 2 PWST Drawing gg. IP3V-0245-0002 Rev. 3: Unit 3 FWST Drawing 58

hh. IP3V-0091-0068 Rev. 2: Unit 3 RWST Drawing ii. IP3V-91-14.6-0085 Rev. 2: Unit 3 PWST Drawing jj. 932 1-F-2735, Rev. 140: Flow Diagram Safety Injection System - UFSAR Figure No. 6.2-1 (Sht. 1) kk. 932 1-F-27503, Rev. 53: Flow Diagram Safety Injection System Sheet No. 2 it. 9321-F-2736, Rev. 129 Sh. 1: Flow Diagram Chemical and Volume Control System Unit-2 mm. 9321-F-27363, Rev. 51: Flow Diagram Chemical and Volume Control System Unit-3 tin. PFP-308 Rev. 5: IPEC Pre-Fire Plans Unit 3

00. PFP-2 11 Rev. 11: IPEC Pre-Fire Plans Unit.

pp. PFP-113 Rev. 5: IPEC Pre-Fire Plans Unit qq. PFP-207 Rev. 0: IPEC Pre-Fire Plans Unit rr. PFP-212 Rev. 11: IPEC Pre-Fire Plans Unit ss. PFP-318 Rev. 12: IPEC Pre-Fire Plans Unit tt. PFP-307 Rev. 12: IPEC Pre-Fire Plans Unit uu. PFP-305 Rev. 0: IPEC Pre-Fire Plans Unit vv. PFP-217 Rev. 12: IPEC Pre-Fire Plans Unit wwI PFP-315 Rev. 0: IPEC Pre-Fire Plans Unit xx. PFP-316 Rev. 12: IPEC Pre-Fire Plans Unit

10. TR-FSE-13-11, Revision 0, "Indian Point FLEX Integrated Plan," February 2013.

11. WCAP-17601-P, Revision 1, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs," January 2013.

59

List of Acronyms ac alternating current ACS alternate coolant source ADV atmospheric dump valve AFW auxiliary feedwater AOP abnormal operating procedure ASCE American Society of Civil Engineers BAST boric acid storage tank BDB beyond-design-basis BDBEE beyond-design-basis external events CCW component cooling water CET core exit thermocouple CFR Code of Federal Regulations CST condensate storage tank CWT city water tank dc direct current DG diesel generator EDG emergency diesel generator ELAP extended loss of ac power EOP emergency operating procedure EPRI Electric Power Research Institute FLEX Flexible and Diverse Coping Mitigation Strategies FOTP fuel oil transfer pump FSG FLEX support guideline FWST fire water storage tank HVAC heating, ventilation, and air conditioning IER Industry Event Report INPO Institute of Nuclear Power Operations IPEC Indian Point Energy Center ISG Interim Staff Guidance LOOP loss of offsite power LUHS loss of normal access to the ultimate heat sink MAAP modular accident analysis program NEI Nuclear Energy Institute NPSH net positive suction head NRC Nuclear Regulatory Commission NSSS nuclear steam supply system PORV power operated relief valve PMF probable maximum flood PMH probable maximum hurricane PORV power operated relief valve PRA probabilistic risk assessment PWR pressurized water reactor 60

PWROG Pressurized Water Reactor Owners Group PWST primary water storage tank RCP reactor coolant pump RCS reactor coolant system RHR residual heat removal RRC Regional Response Center RWST refueling water storage tank SAFER Strategic Alliance for FLEX Emergency Response SAMG severe accident management guideline SBO station blackout SSCs systems, structures and components SFP spent fuel pool SG steam generator S/RV safety/relief valve SSC systems, structures and components SSE safe shutdown earthquake TDABF turbine driven auxiliary boiler feed UFSAR updated final safety analysis report UHS ultimate heat sink 61

Attachment 1A Sequence of Events Timeline New ELAP Elapsed Time Time Action Time Constraint Constraint Item (hours)' Action (Y/N)2 (hours) 3 Remarks /Applicability 0 N/A Event Starts N/A N/A Plant at 100% Power Perform SBO SBO actions are proceduralized 0 N/A Coping Action N/A N/A SBO Procedures ECA 0.0 Ventilation is created by opening control room door(s). Evaluation should be performed to determine if this action is Control Room adequate for the duration of ELAP Currently, for Unit 2 only the control room 0.5 0.5 Ventilation(Open Room/Cabinet y 0.5 cabinet doors are opened with no time Doors) specified; and for Unit 3 both control room doors and cabinets are opened within 30 minutes.

(Current SBO Procedure Guidance).

When the temperature in the TDAFW pump room is above 120'F, the reliability of the pump may be affected. This occurs 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months after the start of the event if the door to the Ensure TDAFW TDAFW pump room remains shut. The 2 0.5 Pump Room Door y 0.5 temperature in the TDAFW pump room will Open for be less than 1207F for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if the Ventilation door is left open by the first hour after the event. Currently required within 30 minutes of loss of power for IP3.

(Current SBO Procedure Guidance).

ELAP Declaration Time Line 3 1 Declare ELAP Y I (IPEC assumption).

Load shedding increases Battery life for 4 2 Deep Load Shed Y2 duration of Phase 1 (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ). This requires verification.

62

New ELAP Elapsed Time Time Action Time Constraint Constraint Item (hours)' Action (YIN) 2 (hours) 3 Remarks / Applicability This analysis assumes cooldown commences at 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to minimize RCS leakage prior to capability to initiate RCS makeup as the FLEX RCS Makeup pump has a deployment 5 3Coplete Plant y3 time of-2 hours. A cooldown from 547'F to cooldown 400 'F at an assumed cooldown rate of 75 +/-

5'F; will be completed in -2 hours (3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months after LOAC).

6 6 Perform Damage 6 Future FSG Requirement Assessment Phase 1 lighting is provided by emergency Control Room & lighting Batteries, but beyond Phase 1 will 7 8 Emergency Y require new strategies. Assume control room Lighting lighting after 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is addressed per Phase 2, Item 3.

Establish SFP vent area such as opening the door. Need time based on SFP time to boil Establish SFP Area without a break. This time to boil is based on 8 8.04 Vent Y 8.04 an initial SFP temperature of 140'F and assumes pipe penetrating the SFP remains intact.

Earliest need for FLEX equipment or Debris Removal y3 deployment paths. This is needed to deploy

(.Access) the RCS Makeup pump.

Earliest need for a 300 kW 480 Vac generator based on Battery capacity of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Deployment includes staging, making connections, starting & repowering equipment. Deployment of sandbags or 10 8 Deploy Phase 2 y8 other flood mitigation system must be pre-Generator staged prior to flood conditions to protect the entrances to the 480V Switchgear Room.

Assumes the results from future load shed calculations will result in 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Battery life.

This requires verification.

63

New ELAP Elapsed Time Time Action Time Constraint Constraint Item (hours)' Action (Y/N) 2 (hours) 3 Remarks / Applicability Additional lighting and ventilation is not easily powered from the 480V bus and will Deploy Misc. require use of Batteries and/or small portable Lighting & generators as deemed necessary. New 11 Ventilation (small Y 8 strategies will need to be developed.

portable Assumed 1 man-hour to setup adequate generators) portable equipment (e.g., portable generators, fans, lights).

For U2, Battery room exhaust fans and fuel oil transfer pumps are powered from the 480V re-powered bus. Time and manpower for U2 is included in Item 1. For U3 fuel oil transfer pumps are powered from the 480V Deploy Battery re-powered bus but the Battery room exhaust 12 8 Room Ventilation Y fans are not. An evaluation of hydrogen for Unit 3 buildup without ventilation (except open door) is required for Unit 3 to determine if portable ventilation equipment needs to be staged. Time and manpower for U3 portable Battery room ventilation equipment is included in Item 3.

RCS boration is required for shutdown margin at 23.3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months (i.e., 1785/40/60).

RCS makeup is required for inventory at 5.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months assuming cooldown is commenced at 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or 2.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months assuming cooldown is commenced at 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Since the FLEX RCS pump takes -2 hours to deploy, the cooldown will be commenced at 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 13 8 Makeup Pump 8 (assumption). Therefore, 5.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months becomes from BAST the limiting time. However, further evaluation is expected to extend the current requirement for inventory. It is assumed the accumulators are isolated. Controlling the RCS makeup pump is a continuous action.

The BAST may require heat tracing due to high boric acid concentration (requires evaluation).

64

New ELAP Elapsed Time Time Action Time Constraint Constraint Item (hours)' Action (Y/N) 2 (hours) 3 Remarks / Applicability Deployment of FLEX SFP pump discharge hose to SFP needs to occur before boiling.

14 8.04 Deploy SFP y 8.04 This time to boil is based on an initial SFP Makeup Hose temperature of 140'F and assumes all pipe penetrating the SFP remains intact.

Based on a BAST volume of 6000 gallons (IPEC U2 TRM 3.1.B.1) and 6100 gallons (IPEC U3 TRM TRS 3.1.C.1.4) starting at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and a flow rate of 40 gpm, the BAST will become depleted after 2.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months for a total elapsed time of 10.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . The RWST Align FLEX RCS may be used for makeup following depletion 15 10.5 Boration/Makeup Y 10.5 of the BAST. Switching the FLEX RCS Pump from RWST pump suction source from the BAST to the RWST involves re-routing the pump suction hose from the BAST to the RWST (time assumed is the same as for the BAST suction hose deployment (18 minutes) using the same 2 Plant Operators as for the BAST.

Depletion of FLEX fuel supplies (10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months of on-board fuel tank assumed + equipment Establish Alternate deployment time). A detailed fuel strategy 16 13 Fuel Supply Y 13 has not yet been developed. This is considered a continuous action to support periodic re-fueling of all FLEX equipment.

Steam pressure will not be decreased enough to compromise TDABFP performance, however, back-up should be staged as soon 17 24 Stage FLEX SG y 24 resources allow in the event of TDABFP Makeup Pump failure. Coping time of the TDABFP is expected past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Controlling the SG makeup pump is a continuous action.

Supporting evaluations demonstrate a time to 18 18 27.83 Makeup Align FLEXPump SFP Y 27.83 makeup of 27.83 hr (Reference 10).

65

New ELAP Elapsed Time Time Action Time Constraint Constraint Item (hours)' Action (Y/N) 2 (hours) 3 Remarks / Applicability Depletion of previous source (360,000 gal CST) based Reference 10. Use of CST inventory for SFP makeup occurs after 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months when the CST makeup is aligned from the UHS. Assumes the TDABFP recirculation line returning to the CST is intact. Other preferred water sources may be Align FLEX ACS used prior to using the UHS as a source if 19 32 Pump From y 32 available; however, the UHS is used here as Available ACS to the limiting scenario since this source will be

.the CST available during all seismic and natural phenomena events. It is noted that the same manpower resources will be available regardless of the selection of ACSs to move from source to source. The sources that may be available after CST depletion include CWT, PWST, FWST, Hotwell.

The earliest need time to support deployment of Phase 3 equipment. The earliest expected 20 24 Perform Debris Large Removal Y 24 arrival of RRC equipment at the site is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (NEI 12-06).

Time is based on supporting makeup to the CST and/or RWST (via mobile boration system) when other ultra-pure sources are depleted or not available; thus avoiding use Align Mobile of Hudson River water (UHS). The CST 21 32 Water Purification 32 inventory is expected to be depleted after System 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months . The RWST inventory is expected to be depleted after 93.9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months for U3 and 93.3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months for U2. If IPEC would like makeup sources to the CST and/or RWST, this water source should be made available.

66

New ELAP Elapsed Time Time Action Time Constraint Constraint Item (hours)' Action (Y/N)2 (hours) 3 Remarks / Applicability A 2 MW 480 Vac generator from the RRC will be brought in to support powering a 480 Vac bus to supply power for one RHR pump, one CCW pump RHR and the Phase 2 loads.

This will provide capability to place plant in 22 72 Deploy Phase 3 y 72 cold shutdown for indefinite coping Generator (Reference 10). Deployment includes stopping running generator, opening breakers, staging, making connections, starting & repowering equipment (closing breakers).

Align UHS Pump / UHS pump will be needed to move from SG 23 72 Alternate Service Y 72 cooling to RHR for achieving/maintaining Water cold shutdown.

Three 7700 gallon tanks of diesel fuel capable of withstanding seismic, flood and wind events are available at each site. This Establish Large supply represents an allowable usage of 320 24 72 Fuel Truck Y 72 gallons/hour for the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ELAP duration.

Delivery Service Therefore, on-site fuel supplies are expected to last >72 hours. IPEC should coordinate replenishment of diesel fuel at that time.

Notes:

(1) Elapsed time is defined as estimated time required to complete action. Following completion of staffing studies (A28),

operator action times will be provided for each time sensitive action. All actions will be completed prior to time constraint.

(2) Instructions: Provide justification if No or NA is selected in the remark column. If yes include technical basis discussion as required by NEI 12-06 Section 3.2.1.7 (Reference 2).

(3) Time constraints based on Reference 10. Additional refinements may be provided in subsequent updates.

67

Attachment 1B NSSS Significant Reference Analysis Deviation Table Entergy has evaluated WCAP-17601 (Reference 11) considering IPEC 2 and 3 site-specific parameters and determined that the conclusions of that document are applicable to IPEC 2 and 3. Entergy has performed analysis consistent with recommendations of the core cooling position paper, provided as an attachment to LTR-PCSA-12-92. The following deviations were identified as part of this evaluation and justification is provided based on the direction contained in NEI 12-06. No other deviations have been identified with respect to the PWROG recommendations for the FLEX program.

WCAP Value WCAP Item Parameter of Interest (WCAP-17601-P January 2013 Rev. 1) Page Plant Applied Value Gap and Discussion I Time initiating cooldown 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Table 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months The earlier cooldown time 5.2.2-1 reduces reactor coolant pump seal leakage which improves the plant response relative to Reference 11; it will be incorporated into plant procedures for loss of all AC power events. This approach is consistent with Reference 11 and represents an acceptable deviation to the generic approach.

68

Attachment 2 Milestone Schedule The following milestone schedule is provided. The dates are planming dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent six month status reports.

Indian Point Milestone Schedule Status Original Target (Will be updated Activity Completion Date every 6 months)

Submit Overall Integrated Implementation Plan February-2013 6 Month Status Updates Update 1 August-2013 Update 2 February-2014 Update 3 August-2014 Update 4 February-2015 Update 5 August-2015 Update 6 February-2016 Update 7 August-2016 Perform Staffing Analysis December-2013 Modifications Engineering and Implementation N-1 Walkdown (Unit 2) Spring-2014 Design Engineering December-2014 Unit 2 Implementation Outage April-2016 Unit 3 Implementation Outage April-2015 On-site FLEX Equipment Purchase June-2013 Procure December-2013 Off-site FLEX Equipment Develop Strategies with RRC November-2013 Procedures PWROG issues NSSS-specific guidelines June-2013 Create Indian Point FSG October-2014 Create MaintenanceProcedures October-2014 Training Develop TrainingPlan May-2015 Implement Training November-2015 Submit Completion Report June-2016 69

Attachment 3 Conceptual Sketches Figure A3-1: Unit 2 CST Connections (Reference 9-bb) 70

/NN NNE 455 4 5

~ ll VN f1232 m

- 149 ISOl CS-148 B..F 3 1 V3NTNTCD- 129 3/-- OVERLO.W

" 1 8"le CONDEiNSATIE 8 -

i , STORAC[ TAWK

-- (CLASS I tow)

... -.- _--_-.... _- qj-CTT-99 ftr-57 2"

---. NO. 38 I-Figure A3-2: Unit 3 CST Connections (Reference 9-cc) 71

Figure A3-3: Staging Area Unit 2 (Reference 9-a) 72

Figure A3-4: Staging Area Unit 3 (Reference 9-a) 73

Figure A3-5: Primary AFW Routing for Unit 2 & Unit 3 (Reference 9-a) 74

- , =-.r~-~-,,- *I*

I z

z

-J FL A'j] STACK q

5:)

\

1 SUPERHEATER BUILDING 0>

UNIT 3 C UI T --I I EI L)ING 8"::ILD ING Ry STORAGE

- ~

TANI 4J STORAGE AUXIUARY JBUILDING _ -- =__;__BUILDING__

CL I S LD i.. 2 STORAr TANK .

....- . PROTECTET AREARE/

-- =- .. "... . " . . . . . ./

CATED SOU FrN--j F< °" " .... . ..

,~ 'A, ,DELTA GATE H*DRAULIC I kLV-FORT"!i11 "

TYPICAL --3--PbVAES-SEE-

// / VE Figure A3-6: Site Plan with Tanks (Reference 9-a) 75

TM

- L Oý-0" Eu-rTM(

Figure A3-7: Unit 2 FWST (Reference 9-dd) 76

LcF_ F Figure A3-8: Unit 2 RWST Connections (Reference 9-ee_))

77

--~~~-*

e,-*. 15-.

e LA2 VA3-9N "oJec Figure A3-9: Unit 2 PWST Connection Locations (Reference g-if) 78

- -- - 4.

Figure A3-10: Unit 3 FWST 32 (Reference 9-gg) 79

(Reference 9-gg___)

31 3FWST Unit A3-11:

Figure Figure A3-11: Unit 3 FWST 31 (Reference 9-gg) 80 80

Figure A3-12: Unit 3 RWST (Reference 9-hh) 81

/ .. 'EV.

If-P`Y::WM -

Figure A3-13: Unit 3 PWST (Reference 9-ii) 82

Figure A3-14: Proposed Equipment Storage Location (Reference 9-pp) 83

Figure A3-15: Unit 2 Deployment Path (Reference 9-a) 84

U. -

OWGI502458 SH. I ý 11ýý.k IItSR.

0WG1502458 ZZZ1Z _

ý III - - I V.

[

SCREEN STRUC SEWAGE TREýhENT Z' -F9 HEATER BAY J ~ ~ ,.

I~4~

EXISTIN,' 7XRAtINL Ltocation forIT E GDERATOR 4-' 13ELC-W ~ T:URBINEG-ENERAUTO7UMj3 I LOING i fl~

BUILDING#3 CON, ýETETHL, AREA I I TAC K fTNG (ATCH HASNTO JE~UrL 3ANDONED AN ýL CGEG IrT1 ~1K .~o L~ for Unit3TRBLN rr X)NCPETE 3 R BUIU NTH IZE N 3 itU

">~~ __F__

PRIMARY -

AUXIUARY B T

IN-UIIN ~l' 14',

F.UNI 1 I-

\

BUILDIN N

K

'I mA rEnA 4 ____

S

~

CTED AREA N

- RELOCATED SOU H F`0NCE PEI1 EC-16536 3/4 ~y j RE/ /

A, PAREA"TAY Figure A3-16: Unit 3 Deployment Path (Reference 9-a) 85

NLY ONLY GRATENLY SEE ThPICA

ONCRErE GRATE DETAIL PVC PIPE AT SHEET PILING DWG 502458 SH. 2 -- 7 K

C T#AE) '1->

Figure A3-17: Unit 2 Secondary AFW Staging (Reference 9-a) 86

SEE -GRATE- AiiTl~lMENT COP DWG 502458 SH. 2

-OR 4E SEE HEATER BAY TURBINE GENERATOR BUILDING #3 ft~

Figure A3-18: Unit 3 Secondary AFW Staging (Reference 9-a) 87

Figure A3-19: Unit 2 Secondary AEW Connection Routing (Reference 9-a) 88

Figure A3-20: Unit 3 Secondary AFW Connection Routing (Reference 9-a) 89

S. DLLATI'N

.WI W[NO1UTU*AT Pno. WI[. CAP.-eau7 Amy. I

4. A 4cr C N9 F"TThM pAL LL. E UMW IMV. a AM

9. OPEC MOM/l MqLY. 0 Storz ConnectionRC I*llTANK sdVav L

y IURtP*~ l lP , im

,*toB NKTO jr-"U pit .=

0M q O M s cMr ~ "IawA i

Figure A3-21: Unit 2 Primary RCS Inventory Connections (Reference 9-j j) 90

Figure A3-22: Unit 3 Primary RCS Inventory Connections (Reference 9-kk) 91

Figure A3-23: Unit 2 BAST Connections (Reference 9-11) 92

Figure A3-24: Unit 3 BAST Connections (Reference 9-mm) 93

g REFUELING WAI STORAGE TANK Figure A3-25: Unit 2 RCS Staging Location (Reference 9-a)

ý111+

Figure A3-26: Unit 3 RCS Staging Location (Reference 9-a) 95

Figure A3-27: Unit 2 RCS Inventory Routing-I (Reference 9-a) 96

Unit 2 Primary Auxiliary Building Elev. 80'-0" N

I . . . . -1 Figure A3-28: Unit 2 RCS Inventory Routing-2 (Reference 9-oo) 97

Unit 2 Primary Auxiliary Building 4 -rw Insta'ab I Elev. 59'-o"

~~17300 andS 7Wr*

'V Figure A3-29: Unit 2 RCS Inventory Routing-3 (Reference 9-qq) 98

Unit 2 Primary Auxiliary Building Elev. 80'-0" Q (D PA~n. A,.*

Figure A3-30: Unit 2 RCS Inventory Routing-2 (Reference 9-oo) 99

Unit 2 P r;mn rir A,,yv;1; nr I",;I1lA i P

I II%.I7 J~~\I%.I7 4I'.. jE Elev. 59'-0"

- 173oo ancl 7'3o2I CABLESSF 2ASUALTY ANO CONNECTir#4 Box Figure A3-31: Unit 2 RCS Inventory Routing-3 (Reference 9-qq__)

100

Figure A3-32: Unit 3 RCS Inventory Routing-i (Reference 9-a) 101

Unit 3 RAMS Bldg. - General Floor Plan Elev. 54'-0" HP Storage Area -

Figure A3-33: Unit 3 RCS Inventory Routing-2 (Reference 9-ss) 102

Unit 3 Primary Aux. Bldg. - General Floor Plan

-A,_ - Elev. 55'-0" ft -- To EL. 411IA Figure A3-34: Unit 3 RCS Inventory Routing-3 (Reference 9-tt) 103

Unit 3 Primary Aux. Bldg. -

Safety Injection Pumps/Main Corridor Elev. 34'-0" Figure A3-35: Unit 3 RCS Inventory Routing-4 (Reference 9-uu) 104

Unit 3 Outdoor Deployment Figure A3-36: Units 2 & 3 RCS Inventory Deployment (Reference 9-a) 105

Unit 2 Primary Auxiliary Building Elev. 80'-0" Figure A3-37: Unit 2 Secondary RCS Routing (Reference 9-oo) 106

Unit 3 Primary Aux. Bldg. - General Floor Plan Figure A3-38: Unit 3 Secondary RCS Inventory Routing (Reference 9-tt) 107

Figure A3-39: Unit 2 SFP Staging (Reference 9-a) 108

Figure A3-40: Unit 3 SFP Staging (Reference 9-a) 109

Figure A3-41: Unit 2 SFP Routing (Reference 9-a) 110

Unit 2 Nt Fuel Storage Building i Elevs. 80'-0" k 95'-0" I

Figure A3-42: Unit-2 SFP Primary Routing (Reference 9-vv) 111

Figure A3-43: Unit 3 SFP Routing (Reference 9-a) 112

Unit 3 Fuel Storage Bldg. - Fuel Storage Bay Area Elev. 55'-0" 1/1 P1 2

U ~

C P1 Figure A3-44: Unit-3 SFP Primary Routing (Reference 9-ww) 113

Unit 3 Fuel Storage Bldg. - General Floor Plan Elev. 95'-0" Skimmer New Fuel --

Filter .. Elevator Drive 1 Grating t

ol El 105' Sampling Spent Fuel P;t System Skimmer Pump I -.

Door LM.

320 F Nev. e~J~

I

.~nliP I T o El. 55'~

Neva Fuel_

Elevator New Fuel Spent Fuel Pool Cells I

FS8 Truck Bey at U~ 55' B~b.

Gangbox 0

LIF 7~. -'

7q5Fllatlorrm

,I. Z I

- .1 r Fon House Comfro* Panin-- ot El 92' 114 Figure A3-45: Unit-3 SFP Primary Routing (Reference 9-xx) 114

Figure A3-46: Unit-2 Outdoor SFP Deployment (Reference 9-a) 115

Figure A3-47: Unit-3 Outdoor SFP Deployment (Reference 9-a) 116

Unit 2 i Fuel Storage Building Elevs. 80'-0" & 95'-0" Figure A3-48: Unit 2 SFP Secondary Routing (Reference 9-vv) 117

Unit 3 Fuel Storage Bldg. - Fuel Storage Bay Area Elev. 55'-0" SOverheadYARD SteeloDoo AREA Flo o r E Lt 5 7TD o - 0 Fuel Building l Truck Buy "r C~mfection, Pent and Hard Piping PExch(

Spent Fuel Cosk Cr- Decontaminaotion Figure A349: Unit 3 SFP Secondary Routing 55' (Reference 9-ww) 118

Figure A3-50: Unit 2 RWST to CST Makeup (Reference 9-a) 119

Figure A3-51: Unit 2 FWST to CST Makeup (Reference 9-a) 120

Figure A3-52: Unit 2 PWST to CST Makeup (Reference 9-a) 121

Figure A3-53: Hudson River to Unit 2 CST (Reference 9-a) 122

p Figure A3-54: Unit 3 RWST to CST Makeup (Reference 9-a) 123

12f4Staging Location F Figure A3-55: Unit 3 FWST31 to CST Makeup (Reference 9-a) 124

125A Figure A3-56: Unit 3 FWST32 to CST Makeup (Reference 9-a) 125

I Figure A3-57: Unit 3 PWST to CST Makeup (Reference 9-a) 126

SIM RITY UPGRADE FOR W9IsJNG72* DWDUNEE,4~

SECU'RITY IGRtr UPGRADE.

SEEGRATEELEYATIO DOGS502454H s-I 4

ONLY iýrj SiMiJTURE LVIt

'lim EXCISTINGDRAP~rDE IPEN VHSTJRB1N-S ELOW L W4, GEERAIORpa VITH WN. 300 PSIBUILDIG #3 flTN;- ATCHWA~t7) 8j"RLEý ý ANDONED AND~ i..JGGED

'H RVAQ COiL PRMAY um PRai Figure A3-58: Hudson River to Unit 3 CST Makeup (Reference 9-a) 127

,xt.

, /

EM o C1 I

, L.,.

Lm-'I

I I L~-I 2 --

HEATERBAY L HEATER BAY l TURENNE OEERATOR Uit,2sl0me TURBINE GENERATOR TURBINEGENE RATORATO 3UILDGING~ BUILDING02 BUILDNG j3

...-*..... -4...

Un LkMIt TrrEtr Svc, STACK A T JN Aas RHEA WILDIN AtL )ING BU )IG III I

I I PRIAY AUIUARY tilIN FUEL STORAGE IBUILDING I I

ý ,- L I 1i Iý) D hn i STORAGE I

I t7

__ UNI 1 j ~TRAE CRA BUIWIN N Unit 2 Wkt2

' J:CV,;,,<r PIT PnrnaY LW3 Aleý

-~ $4 Atagi~e -fl tpK Staong I I m N Area

\~'

/

N,~ PRO ECTEDAREA I, /

A ACC :SS BUILOING tUN1j- - 7 A

Figure A3-59: Staging Locations for Electrical Equipment (Reference 9-a) 128

5.;

~ A C-

.4 -$~R 1ý -. 0 Figure A3-60: Spare breaker 23A on Bus 2A (Reference 9-b) 129

£ Figure A3-61: Replace Breaker 13C on Bus 6A (Reference 9-b) 130

Figure A3-62: Unit 2 Primary Electrical Routing Outdoors (Reference 9-a) 131

Unit 2 Control Building - 480V Switchgeor Room Elev. 15'-0" 0, jtL~A I.,OflWUtOr A o~

A"-flU ~- ~- ES dj- r--,dp ci: ~

PFP-251 Figure A3-63: Unit 2 Primary Routing in 15'480V Switchgear Room (Reference 94) 132

Figure A3-64: Unit 2 Secondary Outdoor Cable Route (Reference 9-a) 133

Unit 1 Superheater Building Elev. 72'-0" 30 "04. 1C k*S 1 09. O

'kn.

Sr.3 I

-rp --

I M-i ')

Figure A3-65: Unit 2 Secondary Cable Routing at 72' (Reference 9-k) 134

cx i-~. c~ F Figure A3-66: Unit 2 Secondary Cable Routing at 53' (Reference 9-1) 135

Unit 2 Control Building - Cable Spreading Room Elev. 33'-0" h

MANI ACIDA 0 WAY4 ARr~n OAT~ wHk ISE RMWXPAL R HEnAO U19iW AM ~

%4 *.M SW A

EE~,t 'Pec p n~. Po,..

PFP-252 Figure A3-67: Unit 2 Secondary Cable Routing at 33' (Reference 9-r) 136

Unit 2 Control Building - 480V Switchgeor Room Elev. 15'-0"

? V~C7~

LW~4 A E3-

- :~~'~-

m ~-"

,- -- .~#-

PFP-251 Figure A3-68: Unit 2 Secondary Cable Routing at 15' (Reference 9-)

137

if' WW W-1 Figure A3-69: Unit 2 Phase 2 Bus 2A Replacement Breaker (Reference 9-b) 138

6.91<V SWITCHGEAR (A23 1592)

-r --- -I(AC-4) 2-1fC 10 I1200A )I~

TO 125V DC PWR.- .BA6I1 .

125V DC SL%'PLY ST A. SERV . ANS .6 PhL. 22 C4T. 6 M*FOR CiIRC. BKR. 2.OO12,67MlVA C0NTPOL WAJ&A 6Hz 6900/480V 3o TO Oc PA.

625V

.PL 24 cKd. 5 2-$/'C to 2-i4C*'0 TRANSF. -

FANS 15A 2 424OV) 13OPT-TCF BUS 6A

'ARN REFERENCE OWGSt Figure A3-70: Unit 2 Phase 2 6A Replacement Breaker (Reference 9-b) 139

31C 310 wt12 3mU I

I~ ~; ~ ~1

~I Figure A3-71: Spare breaker 31B on Bus 2A (Reference 9-n) 140

f Figure A3-72: Replace Breaker 15B, C on Bus 6A (Reference 9-n) 141

Figure A3-73: Unit 3 Primary Routing Outdoors (Reference 9-a) 142

Figure A3-74: Unit 3 Primary Routing in 15' 480V Switchgear Room (Reference 9-u) 143

Figure A3-75: Unit 3 Secondary Routing Outside (Reference 9-a) 144

Figure A3-76: Unit 3 Secondary Routing EDG Building Roof (Reference 9-x) 145

Exhaust Fan BETDjVN XH A R~OOM with Louvers ~ ~ O P.~[ A;:l C) ~~~j.$ (r P Cq#)COJxPA.SA Y-t-

&'m~owccvER td. 3--,- PLATFEL9'O MRATIN*

S-. 3 I~~~~X KDLSACI(

57~

AIR 5.UPPLY TC CcbNTROLLUE AcAkL VE-S,(2 j (300' SECO roAt;-4

93IMSM448&

& CA 4 E / " -, 0' Figure A3-77: Unit 3 Secondary Routing EDG Exhaust Fan Access (Reference 9-w) 146

I I)~., i Figure A3-78: Unit 3 Secondary Routing EDG Intake Access (Reference 9-w) 147

Figure A3-79: Unit 3 Secondary Routing EDG Building 15' (Reference 9-y) 148

Figure A3-80: Unit 3 Secondary Routing 480V Switchgear Room (Reference 9-u) 149

E NOTE 5 JIE MMLF CA 32 480V-30-60-. BUS 2A 29D 30B 30C 30D 318 iC 31D 32B 32C 32D 0t00 A1 15C4A 02 35 400 (nn.., Ip I. SrA IP OPI 0

1UlO ato C4 LOM -

Figure A3-81: Unit 3 Phase 2 Bus 2A Replacement Breaker (Reference 9-n) 150

48OV-30-60,, BUS 6A z I 0 I I')I (Kin~

CL CL wJ a<0.

Figure A3-82: Unit 3 Phase 2 Bus 6A Replacement Breaker (Reference 9-n) 151

~4ZY 6 a

-~ U N N L.J W Js. ~ a.

~ 4--

Figure A3-83: Unit 2 Phase 3 Bus 2A Replacement Breaker (Reference 9-b) 152

6.9KV SWITCHGEAR (A23 1592) 2- /C 10 I12-O0A )521 TO 125V DMR . 'BA6I L.. -------

PNL. 22 CK.T. 6- 125V DC SLP)PLY STA.Sd 1AS.

FOR CIRC. WIR. 2. 0267M4VA CONTROL BUS 6A 3o. 60$4z. 6900/400.'

TO 125V DC WR

-P1L. 24 CXr. 5 2-i/C 10 AA/AF.

TRA-3 Z-6.2X H

FANS 15A 2A4 1240V .0, 13DPT-TCF -. - 3PT -

BUS 6A OA to$ ~II o l ie C 12A 125 -2C 13A

-7 ICdJ\CFI T REFERENCE OWGS:

Figure A3-84: Unit 2 Phase 3 Bus 6A Replacement Breaker (Reference 9-b) 153

E NOTE 5 JAM OR PAN c2 4.80V-30-60 -. BUS 2A 29D 30B 30C

-- 30D 318 1C 31D e -e 32B 32C 32D 33B 0 4 C IsN~ (4 0ooL Oj 0400 15095 0

!I in ,t*l'"

r-.

, ot, _.C%_,,.~

CI4 7E Figur A385 I~nt3Phs }s:A 9 Relaemn Bree (Rfrene9nA 6 N 0jo; -z aY-0 LAJ 0 Fiur A3.5 Unt3Pae3Bs2ARpaeetBeke4Rfrne9n 154

480V-30-60 %BUS 6A 11D 128 12C 12D 13B 13C 13D 00

-< 0 Figure A3-86: Unit 3 Phase 3 Bus 6A Replacement Breaker (Reference 9-n) 155

NL-13-042, Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Contents

Text

SUBJECT:

REFERENCES:

Dear Sir or Madam:

Enclosure:

Navigation menu

NL-13-042, Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Text

SUBJECT:

REFERENCES:

Dear Sir or Madam:

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