RS-13-017, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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

ML13060A362
Person / Time
Site:	Braidwood
Issue date:	02/28/2013
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-13-017
Download: ML13060A362 (71)

Text

1 Exelon Generation Order No. EA-12-049 RS-13-017 February 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457

Subject:

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

References:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29,2012 3* NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August, 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 20 12 On March 12,2012, th e Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling , containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1 .

U.S. Nuclear Regulatory Commission U.S.

Integrated Plan Report Integrated Report to to EA-1 2-049 EA-12-049 February 28, February 28, 2013 Page 2 Page Reference 1 requires submission of an Overall Reference Overall Integrated Plan by February 28,2013. 28, 2013. The TheNRC NRC InterimStaff Interim StaffGuidance Guidance(ISG) (ISG)(Reference (Reference2) 2)was was issued issued August 29, 29, 2012 which which endorses endorses industry guidance industry guidance document document NEI NEt 12-06, 12-06, Revision Revision 00 (Reference (Reference3)3)with withclarifications clarificationsand and exceptions identified exceptions identified in in Reference Reference 2. 2. Reference Reference33providesprovidesdirection directionregarding regardingthe thecontent contentofof this Overall this Overall Integrated Plan.

Reference 44 provided provided the EGC EGC initial status report initial status report regarding regarding mitigation mitigation strategies, strategies,as asrequired required by Reference 1.

by 1.

The purpose purpose of of this letter isis to provide provide the the Overall Overall Integrated Integrated Plan Plan pursuant pursuanttotoSection SectionIV, IV, ConditionC.1, Condition C.1,ofofReference Reference 1. 1. This letter confirms confirms EGC EGC hashas received received Reference 2 and and has hasan an Overall Integrated Overall Integrated Plan developed developed in in accordance accordancewith with the theguidance guidancefor fordefining definingandanddeploying deploying strategies that strategies thatwill will enhance enhancethe theability ability toto cope copewithwith conditions conditionsresulting resultingfrom from beyond-design-beyond-design-basis external events.

The information information in in the the enclosure enclosure provides the the Braidwood Braidwood Station, Units Units 11 and and 22 Overall Overall Integrated Plan for Integrated for mitigation mitigationstrategies strategiespursuant pursuant to to Reference Reference 3. 3. The The enclosed enclosedIntegrated IntegratedPlan Plan is based on on conceptual conceptual design design information.

information. Final Final design details and associated associatedprocedure procedure guidance, as aswell well as as any anyrevisions revisionsto tothe theinformation information contained containedininthetheEnclosure, Enclosure,will will be be provided in provided in the the 6-month 6-month Integrated Integrated Plan updates updates required required byby Reference Reference1.1.

This letter contains no new regulatory commitments. IfIf you you have have any any questions questionsregarding regardingthis this report, please please contact contactDavid David P. P. Helker Helkerat at610-765-5525.

610-765-5525.

II declare declare under under penalty penalty of of perjury perjury that the foregoing is true and and correct.

correct. Executed Executedon onthe 28th the28th day of February 2013. 2013.

Respectfully submitted, G~T?L~

Glen T. Kaegi Licensing & Regulatory Director -- Licensing Regulatory Affairs Affairs Generation Company, Exelon Generation Exelon Company, LLC LLC

Enclosure:

1.

1. Braidwood Station, Units 1 and and 22 Mitigation Strategies (MS)

Mitigation Strategies (MS) Overall Overall Integrated Integrated Plan Plan cc:

cc: Director, Office Office of of Nuclear Reactor ReactorRegulation Regulation NRC Regional Administrator Administrator -- Region Region III III NRC Senior ResidentResident Inspector Inspector-- Braidwood Braidwood Station, Station, Units Units 11 and and 22 NRC Project Manager, Manager, NRR - Braidwood Station, Units 1 and22 NRR - Braidwood Station, Units 1 and Mr.

Mr. Robert J. J. Fretz, Fretz,Jr,Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr. Robert Robert L. L. Dennig, Dennig, NRRIDSS/SCVB, NRRIDSS/SCVB, NRC NRC Illinois Emergency Management Agency Agency -- Division Division of of Nuclear Nuclear Safety Safety

Enclosure Enclosure 11 Braidwood Station, Units Units 11 and and 22 Mitigation Strategies Strategies (MS)

(MS)

Overall Overall Integrated Plan Integrated Plan (68 pages)

(68

Braidwood Braidwood Station, Station, Units Units 1 1 and and 2 2 Mitigation Strategies Integrated Mitigation Strategies Integrated PlanPlan General General Integrated Integrated Plan Plan E Elements meats PWR PWR Site:

Site: Braidwood Determine Applicable Seismic events, except soil liquefaction; flooding from local /

Extreme Extreme External External intense precipitation; severe storms with high winds; snow, ice Hazard Hazard and extreme cold; and high temperatures were determined to be applicable Extreme External Hazards for Braidwood Station per Ref:

Ref: NEI 12*06 Sections NEI 12-06 Sections the guidance of NEI 12-06 Rev. 0 and are as follows:

4.0 .. 9.0 4.0 -9.0 JLD-ISG-2012 .. 01 JLD-ISG-2012-01 Seismic Hazard Assessment:

Section Section 1.01.0 Braidwood will address Beyond Design Basis (BDB) seismic considerations in the implementation of FLEX strategies consistent with NEI 12-06 Rev. 0 (Ref 1).

External Flood Hazard Assessment:

Braidwood Station UFSAR Rev. 14 (Ref. 2) addresses additional flooding mechanisms that are either not critical or not bounding for Braidwood.

External Flooding is not applicable per NEI 12-06 Rev.0 (Ref.

3), since Braidwood is considered a Dry site. Braidwood UFSAR Rev. 14 (Ref. 4), states that the plant grade elevation is at 600.0 feet and the grade floors of the safety related building are at elevation 601.0 feet. The Probable Maximum Flood (PMF) along the Kankakee River, Mason River and Granary Creek do not affect the site, since the maximum water surface elevations are 561.3, 582 and 576 feet respectively: the peak elevations are a minimum of 18 feet below the plant safety related facilities grade of 600 feet.

The probable maximum precipitation (PIMP) falling on the plant area was considered in the analysis of local intense precipitation on the plant site. The maximum water level is elevation 601.91.

feet (Ref. 11) at the plant safety related facilities due to PIMP.

To prevent water due to PMP from entering areas where essential equipment/systems are located, reinforced concrete curbs or steel barriers are provided (Ref. 4).

Huh Wind Hazard Assessment:

NEI 12-06 Rev. 0 (Ref. 5) identifies Braidwood Station in a region (41 degrees 14' N, 88 degrees 13' W) in which it would not experience severe winds from Hurricanes. However, NEI Page 1lof68 of 68

Station, Units Braidwood Station, Units 1 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Integrated Plan General Integrated Plan Elements Elements PWR PWR 12-06 Rev. 0 (Ref. 6) identified Braidwood in Region 1 and susceptible to tornado winds of 200 mph.

0 .... 0"--'k' ...1U'.LV T.n. ... 'nQrlin.

Temperature information: From Braidwood's UFSAR Rev. 14 14 (Ref. 7) The annual average temperature in the Braidwood area area as represented by Peoria Illinois is 50.8°F, while extreme temperatures range from a maximum of 102°F to a minimum of

-20°F. Maximum temperatures equal or exceed 90°F nearly 20 times per year, while minimum temperatures are less than or equal to 32°F about 130 times per year.

Braidwood's Braidwood's location location is is 41 degrees 14' r1Plr1I"PPC' 14' N, 88 88 degrees degrees 13' W 13' W Extreme Cold Hazard Assessment:

I 12-06 Rev, 0 (Ref. 8) identifies Braidwood Station in an an area in which it could receive 25 inches of snow over 3 days.

NEI 12-06 Rev. 0 (Ref. 9) identifies Braidwood Station in a region, of Ice Severity Level 5,5,Catastrophic destruction to region, power lines and/or existence existence of ofextreme extreme amount amountof ofice.

High Temperature Hazard Assessment:

Braidwood Station will address address high temperatures considerations in the implementation implementation of ofFLEX strategies strategies consistent with NEI 12-06 12-06 Rev.

Rev. 00 (Ref. 10) 10)

References:

1. NEI 12-06 Rev. 0, Diverse and Flexible Coping 1.

Strategies (FLEX) implementation Guide, Section 5.2 dated August 2012.

2. Byron/Braidwood Nuclear Nuclear Stations Stations Updated Final Safety Analysis Report (UFSAR) Safety Analysis Report (UFSAR) Revision Revision 14, Braidwood Braidwood Section 2.4.4 through 2.4.7 dated December 2.4.7 dated December 2012.

3. NEI12-06 NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) i mplementation Guide, Section 6.2.11 dated August 2012.

4. Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Braidwood Section 2.4.2.3 dated December 2012.

5. NEI 12-06 Rev. 0, Diverse and Flexible Coping Page 20f68 Page 2 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Strategies (FLEX) implementation Guide, Figure 7-1 dated August 2012.

6. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Figure 7-2 dated August 2012.

7.

7. Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, 14, Braidwood Section 2.3.1.12.3.1.1 dated December December2012. 2012.

8. NEI 12-06 Rev. 0, Diverse and Flexible Coping Coping Strategies (FLEX) implementation J.vU.lvlJlI..Ut.1VU Guide, Guide, Figure 8-1 8-1 dated August 2012.

9. NEI 12-06 Rev. 0, Diverse and Flexible Coping 9.

Strategies (FLEX) implementation Guide, Figure 8-2 dated August 2012.

10. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Section 9.2 dated August 2012.

11. Calculation WR-BR-PF- 10 Rev 14, Effect of Local PIMP at Plant Site, dated November 11, 2012 Key Site Key Site assumptions to Provide key assumptions associated associated with implementation of of NEI 12-06 implement NEI 12-06 FLEX Strategies:

strategies.

Flood and seismic re-evaluations

• Flood seismic pursuantre-evaluations to ..... "~C'n,nnt-the to 10 10 CFR 50.54(f) letter of March 12, 2012 are not not Ref:

Ref: NEI NEI 12-06 12-06 section section 3.2.1 3.2.1 completed and therefore not i-kr..*r.+,r.""a not assumed assumedin this submittal. sublnittal.

As the re-evaluations are are completed, completed, appropriate issues issues will be tracked and addressed addressed on on aaschedule schedule commensurate with other licensing licensing bases bases changes.

"'~~"'.Uj:;.,...'LI.

The following conditions exist for the baseline baselinecase: case:

o DC banks are available.

o AC and DC electrical distribution isis available.

o Diesel DrivenDriven Auxiliary Feedwater (DDAF) pump is is available available and will start in auto or manual as needed.

ao Local manual control of steam generator (SG) power operated relief valves (PORN).

o Plant initial response is the same as Station Black Out, (SBO), WCAP-17601-P (Ref. 1).

o No additional single failures of any SSC are assumed (beyond the initial failures that define the ELAP/LUHS scenario in NEI 12-Page 33 of 68 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements Elements PWR PWR 06).

• • Additional staff resources are expected to begin arriving at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, Ref: NEI 12-01 Rev 0 (Ref. 2)

• • Primary and secondary storage locations have not been selected yet; once locations .. '--' .......... are finalized implementation JA .. '"

strategies and routes will be assessed for hazard impact, and will be communicated in a future 6 month update following identification. Storage Storage locationslocations will be chosen in order order to support the event event timeline.

"'~'''''''L&.-'.

• This plan defines strategies capable of of mitigating aa simultaneous loss of all alternating cunent(ac) 1"""~'1n<:lr'lnl'r current (ac) powernA'H""'f" and loss of normal access to the ultimate heat sink sink resulting from a beyond-design-basis event by providing adequate capability to maintain or restore core cooling, containment, and SFP cooling capabilities at all units on a site. Though specific strategies are being developed, due to the inabilityJ to anticipate

..... L .... ..., ....U ... anticipate all possible scenarios, the strategies are also also diverse and flexible to encompass ri1'J'A'f"C

a wide range of possible conditions. These pre-planned strategies developed to to protect protect the public health and safety will be incorporated incorporated into into the unit emergency operating procedures in in accordance accordance with established EP change changeprocesses, processes,and their impact to the design basis capabilities of of the the unit evaluated under 10 CFR 50.59. The The plant Technical Specifications Specifications contain ""'V~ .. .,.u,~~ the limiting 1L~"'JUl"'JLL conditions for for normal normal unit operations totoensure ensure that design safety features are are available available to to respond totoaa design basis accident accident and and direct the the required actions actionstoto be taken when the limiting conditions conditions are are not not met. met. The result of the beyond-design-basis beyond-design-basis event eventmay place the plant in a condition where it cannot comply with certain Technical Specifications, and, as such, may warrant vv.Ul.lUvU.l warrant invocation of of 10 CFR 50,54(x) 50.54(x) and/or 10 10CFR 73.55(p) 73.55(p)

(Ref. 3), 3).

References:

1. WCAP-17601-P Rev 0, Reactor Coolant System 1.

Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, & Babcock &

Wilcox NSSS Designs, dated August 2012.

2. NEI 12-01 Rev. 0, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012.

Page 4 of 68 4of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated ntegrated Plan Elements PWR

3. Task Interface Agreement (TIA) 2004-04, "Acceptability of Proceduralized Departures from Technical Specifications (TSs) Requirements at the Surry Power Station," (TAC Nos. MC4331 and MC4332)," dated September 12, 2006. (Accession No. ML060590273)

Extent to Extent to which which thethe Include a description of of any alternatives alternatives to to the the guidance, guidance, JLD-ISG-2012-01 guidance, JLD-ISG-2012 .. 01 and provide a milestone schedule of planned of planned action.

and NEI and NEI 12-06, are being 12.. 06, are being followed. Identify followed. Identify any any Full conformance conformance with JLD-ISG-2012-01 JLD-ISG-2012-01 Rev. Rev. 0 and and NEI deviations to to JLD JLD-ISG-2012-

.. ISG*2012- 12-06 Rev. 0 is expected with no deviations.

c..'V ....,,,.nt-,",-t 01 and 01 and NEI NEI 12-06.

12-06.

Ref: JLD-ISG-2012-01 Ref: JLD .. ISG .. 2012-01 NEI 12-06 NEII2 13.1

.. 0613.1 Provide a sequence of events Strategies that that have have a time constraint to be successful and identify any time should be identified identified with a technical basis and a constraint required for justification provided that the time can reasonably be be met success including the (for example, a walk through of of deployment).

technical basis for the time constraint. Describe in detail in this section the technical basis basis for the the time constraint identified on the sequence of of events time line timeline Ref: NEI 12 -06 section Attachment IA. lAo 3.2.1.7 See attached attached sequence sequenceof ofevents eventstimeline timeline(Attachment (Attachment1A). lAY.

JLD-ISG-2012-01 section 2.1 Technical Basis Support information, information, see see attached attachedNSSS NSSS Significant Reference Analysis Deviation Deviation Table Table (Attachment (Attachment IB).

lB).

Braidwood Station timeline is outlined in Attachment IA.

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

5 to 15 minutes - Based on the plant response and the direction from the Emergency Operating Page 55 of of6868

Units 1 and 2 Mitigation Strategies Integrated Braidwood Station, Units Integrated PlanPlan General integrated General Integrated Plan Plan Elements Elements PWR PWR Procedures BCA 0.0, Loss of All AC Power, an operator is dispatched to the B AFW Pump and will ensure that it is properly aligned and low suction pressure is reset if needed. Operators will then verify that the pump is started and running properly. The one (1) hour time constraint is based on the results of MAAP analysis BW-MISC-009 (Ref. 1). 1). The MAAP calculation shows SG dryout will occur within 61 minutes without without AFAF flow as as referenced

?<oT'a ..a ..... l"c.ri in the WCAP-17601-P (Ref. (Ref. 2).

2).

• 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s-1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> - The control room will begin to direct a cooldown of the RCS by local operation of the S/G PORVs and local control of the AF flow control valves to reduce S/G pressure down to at least 300 psia at a minimum of 75°F/hr (MAAP Anaysis Ref, 2),

2 30 minutes to 3.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - After the Station DGs have been verified to be L'"''' to

,..n ... be not not available, available, an an operator

""'-'O,"-I,",,r is dispatched dispatched toto the theDiv Div 22 ESF ESF Switchgear Bus _32X and and verifies all breakers are are open, open, and and then then will will proceed to the FLEX Building and prep prep and align align the FLEX DG to the station connections. Once aligned the FLEX. DG will be started and a controlled loading will occur to restore power to the required Div 125 volt DC Battery charger and to the Div 2 125 Volt instrument busses. The 3.6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time constraint is based on the results of EC Evaluation 391834 (Ref. 3). The EC calculation shows the DC bus 1 voltage will be below acceptable values bus 112 after 3.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> without operator action.

References:

1. EC Evaluation 391834, Battery Coping Time For The 1.

125V DC ESF Battery Banks, dated February 12, 2013

2. Byro raidwood MAAP analysis Documentation NO BB-MISC-020 Rev 0 dated February 1, 2013

3. Braidwood Station MAAP analysis Documentation NO.

BW-MISC-009 Rev 1 dated November 1, 2011 Page Page66of68 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General IIntegrated ntegrated Plan Elements PWR Identify how Identify how strategies strategies will will Describe how the strategies strategies will will bebe deployed deployed in all modes. m,odes.

be be deployed deployed in all modes.

Deployment of FLEX is expected for all modes of 12~06 section Ref: NEI 12-06 section 13.1.6 13.1.6 operation. Transportation routes will be developed from the equipment storage area to the FLEX staging areas. Ol.U;::;".lU.;::;" areas. An administrative program will be developed to rln.'TD>"'-"""U:;'ro to ensure ensure pathways remain clear or compensatory actions actions will will be be implemented to ensure all strategies can

.l.I.I.J.,IJJ.'-'.l.U,,",'J..lL'-,U can be deployed deployed during all modes of operation. This This administrative administrative program program will also ensure the strategies strategies can can be implemented in all modes maintaining by .......... "..................Ju .. the portable FLEX equipment available to F,

be deployed during ~~AAAA"" all modes.

Identification of storage and creation of the administrative program are open items. Closure of these items will be communicated in a future 6-month update.

Provide a milestone The The dates dates specifically specifically requiredrequired by by the the order order are obligated obligated oror schedule. This This schedule schedule com,mitted committed dates. dates. Other dates are are planned planned dates dates subject subject to to should include: change. Updates will be provided in the the periodic periodic (six (six

• Modifications timeline month) status reports.

o Phase 1 Modifications o Phase2 Phase 2 See attached milestone schedule (Attachment 2).

Modifications o Phase3 Phase 3 Exelon Generation Company, LLC (Exelon) fully expects to Modifications meet the site implementation/compliance dates provided in

• Procedure guidance Order EA-12-049 with no exceptions. Any changes or development complete additions to the planned interim milestone dates will. be o

o Strategies Strategies provided in a future 6-month update.

o Maintenance

• Storage plan (reasonable protection)

• Staffing analysis completion

• • FLEX FLEX equipment acquisition timeline acquisition timeline

• Training completion for the strategies

• Regional Response Centers operational Page 7 of of 68 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Ref: NEI 12-06 Ref: 12~06 section 13.1 Identify how the Provide a description of of the programnzatic programmatic controls programmatic controls will equipment equipmentprotection, protection, storage and deployment deployment and and be met. equipment equipmentquality.

quality. See section 1111 in NEI 12~06.

in NEI 12-06. Storage of equipment, 11.3, 11.3, will be documented in in later sections of of this Ref: NEI 12-Ref: 12~06 06 section 11 template and template and need not be included in this section.

JLD-ISG-2012 JLD*ISG~2012~01-01 section 6.0 See See section 6.0 ofof JLD-ISG~2012-01.

JLD-ISG-2012-01.

Braidwood Station will implement an administrative program for FLEX to establish responsibilities, and testing

& maintenance requirements. A plant system designation will be assigned to FLEX equipment which requires configuration controls associated with systems. This will establish responsibilities, maintenance and testing requirements for all components associated with FLEX.

Unique identification numbers will be assigned to all components added to the FLEX plant system. Equipment associated with these strategies will be procured as commercial equipment with design, storage, maintenance, testing, and configuration control as outlined in JLD-ISG-2012-01 Rev. 0 section 6 and NEI 12-06 Rev 0 section 11.

Installed structures, systems and components pursuant to 1OC 850.63 (a) will continue to meet the augmented quality guidelines of Regulatory Guide 1.155, Station Blackout. Standard industry PMs will be developed to establish maintenance and testing frequencies based on type of equipment and will be within EPRI guidelines. Testing procedures will be developed based on the industry PM templates and Exelon standards. Braidwood' s administrative program for FLEX responsibilities, and testing &

maintenance are open items. Closure of this item will be communicated in a future 6-month update.

Describe training plan List training plans plans for for affected affected organizations oror describe the the planfor plan training development for training development Training materials for FLEX will be developed for all station staff involved in implementing FLEX strategies. For accredited training programs, the Systematic Approach to Training (SAT) will be used to determine training needs. For other station staff, a training overview will be Page 88 of Page of68 68

Braidwood Station, Units 11 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan General Integrated Plan Elements Elements PWR PWR developed and communicated. Closure of this item will be be communicated in a future 6-month update.

Response

Describe Regional Response Braidwood Station has contractual agreements in place with Center plan the Strategic Alliance for FLEX Emergency Response (SAFER). The industry will establish two (2) Regional Response Centers (RRC) located in Tennessee and Arizona to support utilities during beyond design basis events. Each RRC will hold five (5) sets of equipment, four (4) of which will be able to be fully deployed when requested, the fifth set will have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local Assembly Area, established by the SAFER team and the utility. Communications will be established between the affected nuclear site and the SAFER team and required equipment moved to the site as needed. First arriving equipment, as established during development of the nuclear site's playbook will be delivered to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the initial request (Ref. 1). Development of Braidwood Station's playbook will be communicated in a future 6-month update.

References:

1.

1. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Section 12 dated August 2012.

Notes:

Notes:

Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NR C Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 90f68 9 of 68

Braidwood Station, Braidwood Station, Units Units 1 and 2 1 and Mitigation Strategies 2 Mitigation Strategies Integrated IntegratedPlan Plan Maintain Core Cooling & & Heat Heat Removal Removal Determine Baseline coping coping capability capability with with installed coping1 modifications installedcoping1 modifications not not including including FLEX modifications, FLEX modifications, utilizing methods described described in in Table Table3-2 3-2 ofofNEI NEI12-06:

12-06:

• • AFWIEFW AFW/EFW

• • Depressurize SG SG for for Makeup Makeup withwith Portable Portable Injection Injection Source Source

• Sustained Source of of Water Water I Ref: JLD-ISG-2012-01 lLD-ISG-2012-01 section section 22 and and 33 PWR Installed PWR Installed Equipment Equipment Phase Phase 11 Provide a general general description description of ofthe the coping strategies using using on-site portable equipment equipment including station ntodifications modifications that are proposed to maintain core cooling. cooling. Identify Identify methods methods and and strategy(ies) utilized to to achieve achieve thisthis coping time.

At the initiation of of the event event operators operators will enter enterEmergency EmergencyOperating Procedure (EOP) BwCA 0.0, Loss of All AC. The Extended Loss of of AC Power Power (FLAP), BwCA 0.0 Attachment B, will be entered when the emergency diesel generators are confirmed unavailable and off-site power cannot be restored and it is confirmed by dispatcher or visual verification of physical damage to infrastructure at site.

Within 90 minutes, operators ALLJ. ..............-', operators will cool cool down the plant atatapproximately 75 75 F/hr to 420 420 F (Tcold).

('Told).

Steam generator (SG) pressure pressure will will be be approximately approximately300 300psia atatthis temperature.

temperature.Steam generator pressure of of 300 300 psia psia corresponds correspondstotoRCS RCSpressure pressurenecessary necessarytotoinject injectSI accumulators.

accumulators.

This will ensure RCS pressure is above the minimum pressure to to preclude injection of preclude injection of accumulator nitrogen into the

...." " " " ........................U'.L .. ,UC .... 'V .... """A.L the RCS (MAAP (MAAP Ref. Ref. 1) (WCAP-17601-P (WCAP-17601-PRef.2) Ref.2)

During cool down the Diesel Driven Auxiliary Feedwater (DDAF) pump will deliver water from rI£1'",,,.1r water the Ultimate Heat Sink (UHS) via Essential Service Water (SX) system to the SGs.

Cold Shutdown and Refueling:

When in Cold Shutdown and Refueling, many variables exist which impact the ability to to cool cool the core. In the event of an ELAP during these Modes, installed plant systems cannot be relied upon to cool the core, thus transition to Phase 2 will begin immediately. All efforts will be made to expeditiously provide core cooling and minimize heat-up and repressurization. Exelon has a program in place (Ref. 3) to determine the time to boil for all conditions during shutdown periods. periods.

This time will be used to determine the time required to complete transition to Phase 2.

To accommodate the activities of vessel disassembly and refueling, water levels in the reactor reactor vessel and the reactor cavity are often changed. The most limiting condition is the case in which the reactor head is removed and water level in the vessel is at or below the reactor vessel flange. If an ELAP/LUHS occurs during this condition then (depending on the time after shutdown) boiling in the core may occur quite rapidly.

Deploying and implementing portable FLEX pumps to supply injection flow must must commence commence

'1 Coping modifications consist consist of ofmodifications modificationsinstalled installedtotoincrease increaseinitial initialcoping copingtime, time,i.e.,

i.e.,generators generatorstoto preserve vital instruments instruments or or increase increaseoperating operatingtime timeononbattery batterypowered poweredequipment.

equipment.

Page 1010 of of68 68

Braidwood Station, Units Braidwood Units 11 and and 22 Mitigation Mitigation Strategies Integrated Plan Maintain Core Core Cooling Cooling & & Heat Heat Removal Removal immediately from the time of the event. This should be plausible because more personnel are on site during outages to provide the necessary resources. Strategies for makeup water include deploying a FLEX. pump to take suction from the RWST and /or UHS as described in the Phase 2 Core Cooling section. Guidance will be provided to ensure that sufficient area is available for deployment and that haul paths remain accessible without interference from outage equipment during refueling outages.

Reference:

1. MAAP analysis BB-MISC-20 Rev. 0 dated February 1, 2013 1.

2. WCAP-17601-P Rev 0, Reactor Coolant

2. '--VA .....'I System Response to the Extended Loss of AC Power

'<Tro..,.r1Ic,rw Loss Power Event for Westinghouse, Combustion Engineering,

" - ' ' V .... UJOAu ... r v . . .LJu.r-,:u.J.""V.L.iCU',fO." Babcock

'->n11'IU'" & Wilcox NSSS Designs, dated August 2012.

3. OP-AA-108-117-1001

3. 108-117-1001 Rev 0, Spent Fuel Storage Pools Heat-up Rate With Loss Loss of of Normal Cooling, date July 22, 2011 22,2011 Details:

Details:

Provide aa brief Provide brief Braidwood Station will use the industry developed guidance guidance from description of description Procedures of Procedures the Owners Groups, EPRI and NEI Task team team to to develop site I/ Strategies Strategies /I Guidelines Guidelines specific procedures or guidelines

'-'jJ'-' .......L.JL ..... guidelines to to address address the criteria criteriain NEI 12-06 Rev 0. O. These procedures and/or guidelines guidelines will will support the the existing symptom based command and and control control strategies strategies in in the the current EOPs.

current Identify modifications Identify The following gaps have been identified that prevent operation of the DDAF pump: Braidwood Station will utilize modifications to close these gaps prior to FLEX implementation. Closure of these items will be communicated in a future 6-month update,

1. DDAF pump suction flow path is not available due to CST unavailability and failure of the CST isolation valve to close and the SX suction valve to open on loss of AC power

2. DDAF batteries are drained due to repetitive engine starts with automatic reset of low-low suction pressure trip

3. DDAF pump overheating due to cooling water recirculation flow paths within SX system cycling and overheating the pump within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Key Reactor Parameters Key Reactor Parameters

... ........................ _.__..__..__._..---- _------------ ..........._._.___..__._..._ _..................... _._....... _...r.........

Essential Instrumentation Safet Function I SG Pressure: RCS pressure boundary and P1-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Leve RCS pressure boundary and NR - LI-517 9,a_.. .7Pressure 1 control Page 11 11 of of68 68

Braidwood Station, Units Braidwood Units 1 and and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal

-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B -- ---------------- -------------

RCS Pressure: WR - PI-403 RCS pressure boundary and

.pressure control Containment Pressure: PI- Containment Integrity PCO05 -___..... -- -.....m SFP Level: (component # Inventory TBD)

Braidwood's evaluation of Braidwood's evaluation of the the FLEX strategy may identify additional parameters that are are needed in order to support key U"-'-\'&VU procedures/guidance or actions identified in the plant procedures/guidance orto to indicate L U .... U .............

imminent or actual core damage (NEI 12-06 Rev. 0 Section Section 3.2.1.10) and any difference will be communicated within aafuture 6-month update following identification.

In addition to the parameters listed listed in in NEI NEI 12-06 12-06Rev. 0 Section 3.2.1.10, the following additional additional parameters will will be evaluated for use as the detailed strategy is is developed.

developed. Closure Closure of of this item will be communicated in aa future 6-month 6-month update. update.

Core Core Exit Thermocouple (CET) Temperature: TI-IT002 J.AvlUlIcJvlc}'ULJJ.v RCS Accumulator Level: L1951, LI951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System J.UUlvUIL.1U;::' System (RVLIS):

(RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A FI-AF016Aand andFI-AFOI18A 8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NR006A/B, NI-36B IR.

Reference:

1. PWROG G eneric FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA-PSC-096S.

PSC-0965.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049, Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page Page 12 12 ofof6868

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Core Cooling Cooling & & Heat Removal Removal PWR Portable Equipment Phase 2 Provide a general description of of the coping strategies using on on-site

-site portable equipment including are proposed station modifications that are proposed to maintain core cooling. Identify Identifymethods methodsand andstrategy(ies) strategy(ies) utilized to utilized to achieve achieve this this coping coping time.

time.

Phase 22 Core Cooling will be be achieved with aaportable ......-..7"'.-... ""I n FLEX diesel pump and SG POR V's. The pump suction suction will come from the the R WST and RWST and DRS.

UHS. The The FLEX pump discharge will be into the downstream of the AFW lines downstream of the containment isolation valves into the SG's . The PORV's will be used r>rvrlt<:l1nnnt::>nt to control SG pressure.

In the event that the Unit is in a refueling outage, outage, another portable FLEX pumps 1J~,ljUIJ\J will will also be be able able to to rn.n.r'l11".n"t-.A,nC' outlined supply the RCS Boil-off using the modifications outlined in in Phase 2 Phase 2 inventory control.

1n ..;rnnt-Ar~T Electrical power to support the FLEX strategy is described in the Safety Function Support section of the document.

Details:

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

/ Strategies // Guidelines procedures or guidelines to to address address the the criteria criteria in in NEI NEI 12-06. 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

Identify modifications Identify The following modifications will be installed to support FLEX pump water injection into the SGs:

FLEX pump discharge: Install Pipe flange connections connections on on the A,A, D, B and C Auxiliary feed water (AF) SG SG injection injection lines at at the the test test flanges within the Main Steam Steam Isolation Isolation ValveValve (MSIV) (MSIV) rooms. rooms.

Connect the pipe flanges with aa header headerrouted

..r. *

• through the steam 1'nrl 1'1-> ... ,,,,, ".1->

tunnel. One end of the header will be be ..routed

"" .* to the B/C MSIV room

"".-1 and terminated with a standard FLEX connection (Primary connection) and the other end will be routed to the A/D MSIV room and terminated with a standard FLEX connection (Alternate connection).

FLEX pump suction: A tee will be installed on the B SI pump suction line. A header will be routed from the tee through the RWST tunnel to the RWST tunnel access hatch or alternate path and terminated with a standard FLEX connection. Additionally, hoses could be run from the UHS as suction backup source.

Page 13 13 of of68 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key Reactor Parameters Parameters SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-53` pressure control PI-545 and PI-546 SG Level: RCS pressure boundary and NR - LI517, LI-S17, LI-S19, LI-S27, LI-519, LI-527, pressure control control LI-S37, LI-S47 and LI-537, LI-547 and LI-549 LI-S49 LI-S02 and LI-503 WR - LI-502 LI-S03 RCS Temperature: Res RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR PI 403 RCS pressure boundary and pressure control Containment Pressure: PI- Containment Integrity PCO05 (component ##

SFP Level: (component SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0, Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0, Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 W Flow: FI-AF012A, FI-AF0I4A, FI-AF016A and FI 018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06 , NI-36B IR

Reference:

1. PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA-PSC-0965.

Page 1414 of of 68 68

Braidwood Station, Braidwood Station, Units Units 1 1 andand 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Storage // Protection of Equipment:

Describe storage I/ protection plan or schedule to determine storage requirements requirements Seismic Seismic Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section

11. Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction ..... ,u,'..... ,UJ,i"o, construction completion. completion.

Procedures and programs will be developed developedtotoaddress addressstorage storage structure ..requirements, ar1'n1 ..*0r\""O .... t-" haul path requirements, and FLEX equipment requirements relative to the external external hazards U,"'"',O;..U ...... ...,applicable "1-'1-'.1.1,-,",-".1.,-,to Braidwood Station.

Flooding Structures to provide protection of FLEX equipment will be Note: if if stored below constructed to meet the requirements of NEI 12-06 Rev. 0, Section current flood level, then then 11. Schedule to construct permanent building is contained in ensure procedures exist exist toto Attachment 2, and will satisfy the site compliance date. Temporary move equipment equipment prior prior to to locations will be used until building construction completion.

exceeding flood level.

level. Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment rt:>nlll1f.,-t:>rY\ontC' requirements relative to to the the external external hazards applicable to Braidwood

,UU.LJO;"U ...... "

Station.

Severe Storms Severe Storms with with High High Structures

.... 'V~, ..... Jl .."u to provide protection protection of ofFLEX equipment will be Winds Winds constructed to meet meet the requirements of NEI 12-06 Rev. 0, Section

11. Schedule to construct permanent building is contained in

11. '-"VLA,...., ............ ...,

Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction UA.L",UAJ'F, construction completion. r>r\1'Y\nloh Procedures and programs will be be developed developedtotoaddress addressstorage storage structure requirements, haul path requirements, requirements, and andFLEX equipment requirements relative to to the the external external hazards applicable applicabletotoBraidwood Braidwood Station.

Snow, Ice, and Extreme Extreme Structures to provide protection of FLEX equipment will be Cold Cold constructed to meet the requirements of NEI 12-06 Rev. 0, Section

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

Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Page 15 of of 68

Braidwood Station, Station, Units Units 11 and and 2 Mitigation Strategies Integrated Plan High Temperatures Structures to to provide provide protection of ofFLEX equipment will be constructed to to meet meet the the requirements requirementsof ofNEI NEI12-06, 12-06,Rev.

Rev.0,0,Section Section

11. U"\.,,~.A""UUlv Schedule to construct permanent buildinga is contained in V""'A .........."""'"' ........ ...,,"' .........*....

Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction completion.

Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Deployment Conceptual Design Design (Attachment 3 contains ConceptualConceptual Sketches)

Sketches)

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

The required FLEX equipment The storage structure FLEX piping, valves, and needed for core cooling will be conceptual design has not not been been connections (electrical & fluid) installed in a robust FLEX completed. will meet NEI 12-06 Rev.0 building ready for hookup and The closure of this item will be protection requirements.

use. documented in a future There will be an administrative Hoses and electrical connectors 6-month update. program created to protect the will be completed as needed to connections from blockage support the site coping strategy during outages and non-outage non-outage and will be stored within the times.

FLEX building.

Notes:

Secondary cooling capabilities

.....,'V'"N......lfo-. capabilities recommend 300

-r'Ar"'ATrlrrllnri 300gpm atat300300psia psia(Ref. (Ref.1)1)

The RWST inventory is maintained at a minimum of 423,000 gal during normal operation. With a conservative sustained flow rate of 300 gpm, the total inventory would be depleted in 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />, Prior to depletion of the RWST inventory a transition will be made to the UHS.

Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Reference:

1. WCAP-17601-P Rev 0, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, & Babcock & Wilcox NSSS Designs, dated Page 16 ofof 68

Braidwood Station, Braidwood Units 11 and Station, Units and 22 Mitigation Mitigation Strategies Integrated Plan August August 2012.

Page 17 Page 17 of of68 68

Braidwood Station, Units I1 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated PlanPlan Maintain Core CooHng Cooling & & Heat Heat Removal PWR Portable Equipment Equipment Phase 33 Provide a general general description description of ofthe the coping strategies using using phase 33 equipment equipment including modifications that are modifications are proposed to maintain core cooling. Identify Identify methods methods andand strategy(ies) utilized to to achieve achieve this this coping coping time. time.

Phases 1 and 2 strategy strategy will provide provide sufficientsufficientcapability capabilitysuch suchthat thatthat thatno noadditional additionalPhase Phase3 3 strategies are required.

Phase 3 equipment for Braidwood

"""V,l"l"""U. for Braidwood includes includes backup portable pumps and and generators.

generators. The portable portable pumps will be capable of of providing the necessary flow and pressure as necessary flow and pressure as outlined in Phase 2 2 response response Cooling &

for Core Cooling Heat Removal,

& Heat Removal, RCS RCS Inventory Control Control and and Spent Spent Fuel Fuel Pool Pool Cooling.

Cooling. The portable generators will be capable capable of of providing providing the necessary necessary 480 480 volt voltpower powerrequirements asas outlined in Phase 2 response for VoJlJ',",LH',", for Safety Safety Functions FunctionsSupport.

In addition, a support component would be a portable refuel vehicle with aa large large diesel diesel oil bladderrt"~'H-r to to support refilling the FLEX diesel tanks.

Details:

Provide a brief procedure/guidance exists Confirm that procedure/guidance exists or orwill willbe bedeveloped developedto to description of of Procedures Procedures support implementation implementation with with aa description description of the theprocedure procedure //strategy strategy

// Strategies // Guidelines I/ guideline.

Braidwood Station will use the the industry developed guidance guidance from the Owners Groups, EPRI and NEI Task team to develop develop site specific procedures or guidelines n-rn.ro,;::r.riu-r,:::>C' or guidelines to to address the criteria in NEI 12-06, These

',H lr,rt_><..

procedures and/or guidelines .; ;, .... v,u ....,""' will support the existing symptom based j .....

command and and control

""TIlT'" strategies in the current EOPs.

Identify modifications List modifications necessary for for phase 3 There are no Phase 3 modifications required.

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

evaluation.

Safety Essential Instrumentation Function SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Level: RCS pressure boundary and NR - LI-517, LI-519, LI-527, pressure control LI-537, LI-547 and LI-549 Page 18 18 of of68 68

Station, Units Braidwood Station, Units 1I and and 22 Mitigation Mitigation Strategies Integrated Plan WR - LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: VAR PI 403 RCS pressure boundary and pressure control Containment Pressure: P1- ;Containment Integrity PCOO5 - - ------------ - -----

SFP Level: (component # SFP Inventory p ^

TBD)

Braidwood's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent ororactual 1tTI1Tl1nAnt actual core damage (NEI 12-06 Rev. 0 Section 3,2.1.10) and any any difference difference will be communicated within a future 6-month update UIJ"'~UI.""" following following identification, In addition to the parameters listed in I 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: Fl-AF012A, FT-AF014A, FI-AF016A and FI-AFO18A 8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NROO6 , NI-36B 1R

Reference:

1. PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Rev. 0, Instruments) Rev, 0, Supplement

-.:l1r'.nlt:>rnt:>'nT 14, dated December 2012 PA-PSC-0965.

Page 19 19 of 68 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Deployment Conceptual Design (Attachment 3 contains Conceptual Conceptual Sketches)

Sketches)

Strategy Strategy Modifications Protection of connections Protection Identify Strategy including how Identify n'wdijications modifications Identify how the connection is Identify}

the equipment will be deployed protected to the point point of ofuse.

use.

Equipment will be delivered No No modifications modifications are are required Braidwood will required Braidwood will utilize Phase 22 from the ITC to the staging other than other than those those outlined outlined inin connection points.

area. From there, the equipment Phase 2 of of this plan.

will be transported to the site and hooked up by both RRC and plant personnel per per the the playbook. Equipment will then be operated per plant procedures.

Notes: Exelon Generation Company, LLC (Exelon)

(Exelon) has has not notfinalized finalized the theengineering engineeringdesigns designsfor compliance with NRC Order EA.-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated PI Page 20 of 68 of68

Braidwood Station, Braidwood Station, Units Units 11 andand 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain RCS Maintain RCS Inventory Inventory Control Determine Baseline coping coping capability capability with withinstalled installedcoping2 copinJ? modifications modificationsnot notincluding including FLEX modifications, FLEX modifications, utilizing utilizing methods methods described describedin inTable Table3-2 3-2of ofNEI NEI12-06:

12-06:

• • Low Low Leak Leak Rep RCP Seals Seals oror ReS RCS makeup makeup required required

• • All All Plants Plants Provide Provide Means Means to to Provide Provide Borated Borated RCS ReS Makeup Makeup PWR Installed PWR Installed Equipment Equipment Phase Phase 1: 1:

Provide a general general description description of ofthe the coping coping strategies strategies using using installed installedequipment equipment including including modifications that are proposed proposed to to maintain maintaincorecorecooling.

cooling.Identify Identifymethods methods(Low (LowLeak LeakRCP RCPSeals Seals and/or borated boratedhigh high pressure pressureRCS RCS makeup) makeup) andandstrategy(ies) strategy(ies)utilized utilizedtotoachieve achievethis thiscoping copingtime.time .

At the initiation of

.LL:<.L"U..... H.JLL of the the event event operators operators will enter enterEmergency EmergencyOperating Procedure (EOP) BwCA

'-'!-"V.L .." .... OJ<F, 0.0, Loss of All AC. The Extended Loss of of AC AC Power Power (ELAP), BwCA 0.0 Attachment B, will be be entered when the emergency diesel generators are confirmed unavailable and off-site off-site power power cannot be restored and it is confirmed by dispatcher or visual verification verification of ofphysical physicaldamage damageto to infrastructure at site.

Within 90 minutes operators will cool down the plant plantatatapproximately approximately75°F/hr 75°F/hrtoto420°F 420°F(Tcold).

(Tcold).

Steam generator (SG) pressure will be approximately 300 psia atatthis temperature, Steam generator pressure of 300 psia corresponds to RCS pressure necessary to inject SI accumulators.

This will ensure RCS pressure is above the minimum pressure to preclude injection of accumulator nitrogen into the RCS (MAAP Ref. 1) (WCAP 17601-P Ref. 2).

During cool down the initial RCS inventory source for makeup and boration will be the SI accumulators.

Cold Shutdown and Refueling:

When in Cold Shutdown and Refueling, many variables exist which impact the ability to cool the core. In the event of an FLAP during these Modes, installed plant systems cannot be relied upon to cool the core, thus transition to Phase 2 will begin immediately. All efforts will be made to expeditiously provide core cooling and minimize heat-tip and repressurization. Exelon has a program in place (Ref. 3) to determine the time to boil for all conditions during shutdown periods.

This time will be used to determine the time required to complete transition to Phase 2.

To accommodate the activities of vessel disassembly and refueling, water levels in the reactor vessel and the reactor cavity are often changed. The most limiting condition is the case in which the reactor head is removed and water level in the vessel is at or below the reactor vessel flange. If an ELAP/LUHS occurs during this condition then (depending on the time after shutdown) boiling in the core may occur quite rapidly.

Deploying and implementing portable FLEX pumps to supply injection flow must commence immediately from the time of the event. This should be plausible because more personnel are on site during outages to provide the necessary resources. Strategies for makeup water include 22 Coping Coping modifications modifications consist of of modifications installed installed to to increase increaseinitial initialcoping copingtime, time,i.e.,

i.e.,generators generatorstoto preserve vital instruments or or increase increase operating operatingtime timeononbattery batterypowered poweredequipment.

equipment.

Page 21 of of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Integrated Plan Plan deploying a FLEX pump to take suction from the RWST and /or UHS as described in the Phase 2 Core Cooling section. Guidance will be provided to'ensure that sufficient area is available for deployment and that haul paths remain accessible without interference from outage equipment during refueling outages.

Reference:

1. MAAP analysis BB-MISC-20 Rev. 0 dated February 1, 20133

2. WCAP-17601-P Rev 0, Reactor Coolant System Response to "-""'IJ,-,JlU.>V to the Extended Loss of AC Power Event for Westinghouse,

'VU'-j'U.r-,."U~u",,", Combustion Engineering, & & Babcock Babcock & & Wilcox NSSS Designs, dated August August 2012. 2012.

3. OU-AP-104, Shutdown Safety Management Program Program Byron /Braidwood !Braidwood Annex, Annex, Revision 17, 17, dated September 27,

....... ru"""TT>r"."y- 27, 2012.

Details:

Provide a brief Confirm that procedure/guidanceprocedure/guidance exists exists or orwill willbe bedeveloped developedto to description of of Procedures Procedures support support implementation implementation I/ Strategies I/ Guidelines Braidwood Station Station will will use use the the industry developed developedguidance from j:::,UJ.\..HU.J'v'v the Owners Groups, EPRI and NEI Task team to develop site specific procedures or P"nD,r>."t"".r> ......r"r\r>'arH",.c...' or guidelines to to address nror, .. .n,'<,

the criteria in NEI 12-

06. These procedures and/or guidelines will support the existing symptom based command LU+'VA.AA command and control control strategiesstrategies in the current EOPs.

Identify modifications List modifications List ntodifications There are no Phase 11 modifications modifications required .."",..,. ........,,,r1 Key Reactor Parameters List instrumentation credited for this coping evaluation.

' Essential Instrumentation Safet Pond up SG Pressure: RCS pressure boundary boundary and and PI-515, PI-516, PI-525, P1-535, pressure control pressure control PI-545 and PI-546 SG Level: RCS pressure boundary and NR - LI-517, LI-519, LI-527, pressure control LI-537, LI-547 and LI-549 WR - LI-502 and LI-503 -------- ----------

RCS Temperature: RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B ..... and TI-443B _......... _..._..._....... ..... _. .......... ............... .............. -_

RCS Pressure: WR - PI-403 RCS pressure boundary and pressure

---

______.......... .... ................................ __..____.__ ------ --- W..._....control .......... _.

Containment Pressure: PI- Containment Integrity PC005 ------- ---- ----- ---

SFP Level: (component # SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may identify Braidwood's Page 22 of of68 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Integrated Plan Plan additional parameters that are needed in order to support ~UU'IU'VJ. key\- key actions identified in the plant procedures/guidance VV""UU.LV~1 E,U.I..ULU.l.vVorortotoindicate indicate imminent or actual core damage (NEI 12-06 Rev. 0oSection U.." ...,U.V.I..1.

3.2.1.10) and any difference will be communicated within a future 6- month update following identification.

In addition to the parameters eters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. developed. Closure of this item will be communicated communicated in in aa future future 6-month 6-monthupdate.

nT"lrl,.,t-o Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: Level:L1951,1,L1953, LI953,L1955, LI955, and LI 957 Reactor Vessel Level Indicating System System (RVLIS):

(RVLIS): LI-RC020LI-RC020 AFW Flow: FI-AFO12A, FI-AF012A, FI-AFOI4A, FI-AF014A, FI-AFO16A FI-AF016A and FI-AFOI8A 8A Battery Capacity *,.,nar>~T*H // DC Bus Voltage: El-DC002 EI-DC002 Neutron Flux: NI- O06 , NI-36B IR

Reference:

1. PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA-PSC-0965, PSC-0965.

Notes: Exelon Generation Company, LLC (Exelon) (Exelon) has has not not finalized the engineering engineeringdesigns designs for compliance with C Order EA-12-049. Detailed Detaileddesigns designsbased basedon onthe thecurrent currentconceptual conceptual designs will be developed to determine the final plan and and associated associated mitigating strategies.strategies. Once these have been fully developed, Exelon will update update the integrated plan plan forfor Braidwood Braidwood during aa scheduled

...,v.u.vuu* .. ...,u 6-month update. This Thisupdate updatewill willinclude includeany anychanges changestotothe initial designs asas submitted in the February 28, 1-1 ......... ,1'1'001"1 28, 2013 2013 Integrated

...... 1'".,..... ..,'1'01"'1 Plan.

Page 23 of Page of 68

Braidwood Station, Braidwood Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan M `tain RCS Maintain RCSInventory Inventory Contra Control PWR Portable Equipment Phase 22::

Provide a general general description description ofofthe the coping coping strategiesstrategies using using on-site on-site portable portable equipment equipn~ent including including modifications that are are proposed proposed to to maintain maintaininventory inventory control. control. Identify Identifymethods methods(Low (Low Leak Leak RCP RCP Seals and/or andlor borated high pressure borated high pressure RCSRCS makeup) makeup) and and strategy(ies) utilized to to achieve achieve this this coping coping time.

Phase 2 RCS inventory control and boration will be be achievedachieved within 88 hrs hrs via via aa portable portable pump pump (Ref. 1). The pump suction will come (Ref. corne from the RWST. The discharge dischargewill willbe beintointothe theCV/SI CVlSI pump discharge line line downstream of ofthe the CV/SI CV/SIpump.

shortened time The shortened of 88 hrs for time of for inventory inventory satisfies satisfiesthe theborated boratedwater water make up at at the expected expected Xenon peak of of 8-10 hrs, from WCAP 17601-8-10 hrs, 17601- P P (Ref. (Ref. 1). 1). A A calculation calculation will willbe berequired required for for the the timing of the boration and quantity required. Closure of ' . r'>. .... n ... " of this item will be co mmunicated in in aa future 6-month update.

Electrical power to support the FLEX strategy is described in the Safety Function Support section, 'o:u ..................f' section.

Reference:

1. WCAP-17601-P Rev 0, Reactor Coolant Coolant System Response Response to to the Extended Loss Loss of of AC AC Power Llr"TT""'"

Event for Westinghouse, Combustion Engineering, & & Babcock &

LJUeU..,,-'VJ.'Io. & WilcoxWilcox NSSS NSSS Designs, Designs, Section 5.8.1 dated August lJV'-" ...,,'V.U August 2012.

2012.

Details:

Details:

Provide aa brief Provide brief Confirn~

Confirm that procedure/guidance procedurelguidance exists exists or orwillwillbe bedeveloped developedtoto description of description of Procedures Procedures support implementation implementation I/ Strategies Strategies // Guidelines Guidelines Braidwood Station will use the industry developed guidance from the Owners Groups, EPRI and and NEI Task Taskteam teamto todevelop developsite site specific procedures or or guidelines guidelines to to address address the thecriteria criteriain NEI 12-06 Rev 0. O. These procedures and/or and/or guidelines ;;;, .... JlU'-'lJ.U'""'.:> will support the

",............ 1',...,. ....... based command existing symptom ... """.u .......... .... and control strategies in the current EOPs.

Identify modifications Identify modifications The following FLEX modifications will be installed to support inventory and boration of the RCS:

FLEX pump discharge: The B CV pump discharge header, down stream of check valve CV8481 B, will be modified with a tee. A header will be routed from the tee to the RWST tunnel hatch or alternate path and terminated with standard FLEX connection (Alternate). The flow path goes through a normally closed MOV S18801A/B which can be manually opened or the B train can be Page 24 of of68 68

Braidwood Station, Braidwood Station, Units Units 1 and 2 Mitigation Strategies Integrated Plan electrically opened after the FLEX DG powers up the Div 2 ESF Bus. The B SI pump discharge y,,a"' ............... ;;;;;.v header,

.... ""n,..."" .. downstream downstreamof of518921B, SI8921B, will be modified with tee. A header will be be routed

..,,-,..,,1-nri from a tee to the RWST tunnel hatch and terminated with standard FLEX connection (Primary). Deployment of the secondary flow path will be contingent on primary pressure conditions less than 1750 psig due to the SI discharge header relief valves. This flow path goes through normally opened MOVs that if closed can be manually realigned to establish flow.

FLEX pump suction: The SI pump suction line from the RWST RWST will be modified with a tee. A header will be routed from the tee tee to to the RWST tunnel hatch or alternate path and terminated terminated with with aa standard FLEX connection.

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

Essential Instrumentation Function SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Level: RCS pressure boundary and NR - LI-517, LI-519, LI-527,  ; pressure control LI-537, LI-547 and LI-549 WR - LT-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and

..... _................... _...... ___............ pressure control Containment Pressure:

Containment U ..",,,'.,,,,..o.* PI- Containment Integrity PC005 PCOO5 SFP Level: (component # SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2. 1.10) and any difference will be communicated within a future 66 month update following identification.

In addition

....... 'U'~ ... .L'L'.u to to the parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, 3.2. L 10, the following additional parameters will be evaluated for the Page Page 25 25 of of68 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan use as the detailed strategyuseisas developed. the strategy is developed.of this of Closure this will item be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1951, LI953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow. FI 012A, PI-AF014A, PI-AFO16A and PI-AFOI8A Battery Capacity / DC Bus Voltage: El-DC002 eutron Flux: N1-NRO06A/B, NI-36B IR

Reference:

PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and and Recommendation Instruments) Rev. 0, Supplement 14, dated December December 2012 2012 PA-PA-PSC-0965.

Storage // Protection of Equipment:

Describe storage // protection plan or schedule to determine storage requirements Seismic Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section

11. Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction completion, Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Flooding Structures to provide protection of FLEX equipment will be Note: if if stored below constructed to meet the requirements of NEI 12-06 Rev. 0, Section current flood level, then 11. Schedule to construct permanent building is contained in procedures exist ensure procedures existto to Attachment 2, and will satisfy the site compliance date. Temporary equipment prior move equipment to prior to locations will be used until building construction completion.

flood level.

exceeding flood level. Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Severe Storms with HighHigh Structures to provide protection of FLEX equipment will be Winds constructed to meet the requirements of NEI 12-06 Rev. 0, Section

11. Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date. Temporary 26 of Page 26 of 68 68

Braidwood Station, Units 1 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan locations will be used until building construction completion.

Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Snow, Ice, and Extreme Structures to provide protection of FLEX equipment will be Cold Cold constructed to meet the requirements of NEI 12-06 Rev. 0, Section nr""",hr"nnt-orl

11. Schedule to construct permanent

11. permanent building building isis contained containedinin Attachment 2, and will satisfy satisfy the site site compliance compliancedate. Temporary Temporary locations will be used until building v ....... ,.".u..l.J,F-, construction cons truction completion.

completion.

Procedures and programs will be developed developed to to address address storage storage structure requirements, haul path requirements, requirements,and andFLEX FLEX equipment requirements relative to to the external externalhazards hazardsapplicable applicable to Braidwood Station.

High Temperatures High Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0,Section I L Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction completion.

Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Deployment Conceptual Modification (Attachment 3 contains Conceptual Conceptual Sketches) Sketches)

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

The required FLEX The storage structure FLEX piping, valves, and equipment needed for RCS conceptual design has not been connections (electrical & fluid)

Inventory Control will be completed. will meet NEI 12-06 Rev.O installed in a robust FLEX The closure of this item will be protection requirements.

building ready for hookup documented in a future There will be an administrative and use. 6-month update. program created to protect the Hoses and electrical connections from blockage connectors will be completed during outages and non-outage as need to support the site times.

coping strategy and will be stored within the FLEX building.

Page 27 27 of 68 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Plan Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 28 of of 68

Braidwood Braidwood Station, Station, Units Units 1I and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Maintain RCS RCS Inventory Inventory Control Control PWR PWR Portable Portable Equipment Equipment Phase 3: 3:

Provide a general description of of the coping strategies using phase 33 equipment using phase equipment including modifications that are proposed modifications proposed toto maintain maintain inventory inventory control control Identify Identifymethods methods(Low (Low Leak Leak RCP RCP Seals and/or borated Seals borated high pressure pressure RCSRCS makeup) and strategy(ies) utilized to to achieve achieve this this coping coping time.

Phases 1 and 2 strategy will will provide sufficient sufficientcapability capabilitysuch suchthat nonoadditional additionalPhase Phase3 3strategies strategies are required.

Phase 3 equipment for Braidwood includes backup portable pumps and generators. The portable portable pumps will be capable of providing the necessary flow and pressure as outlined in >oJ ..... "'.u.>."".."'" in Phase Phase 22 response for Core Cooling Heat Removal, RCS Inventory Control and Spent Fuel Pool Cooling. Cooling.

The portable generators will be capable of providing the necessary 480 volt power requirements asas '-'.1..1."-.01,"

outlined in Phase 2 response for Safety Functions Support.

In addition, a support component would be a portable refuel vehicle with a large diesel oil bladder to support refilling the FLEX diesel tanks.

Details:

Details:

Provide Provide aa brief brief Confirm that procedure/guidance Confirm procedurelguidance exists exists or or will will be be developeddeveloped to description of description of Procedures Procedures support implementation implementation If Strategies Strategies I/ Guidelines Guidelines Braidwood Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12- 1 06 Rev.0. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

Identify modifications modifications List modifications There are no Phase 3 modifications required Key Reactor Key Reactor Parameters Parameters List instrumentation credited credited or or recovered recovered for for this this coping coping evaluation.

Essential Instrumentation Safety Function SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Level: [ RCS pressure boundary and NR - LI-517, LI-519, LI-527, pressure control LI-537, LI-547 and LI-549 SIR - LI-502 and LI-503 Page 29 29 of 68 of68

Braidwood Station, Units Units 1 and 2 Mitigation Strategies Integrated Integrated PlanPlan RCS Temperature: RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary pressure control Containment Pressure: P1- Containment Integrity PCO05 SFP Level: (component # SFP Inventory TBD)

Braidwood's Braidwood's evaluation of the FLEX FLEXstrategy strategymay mayidentify identify additional parameters that are are needed needed in order orderto tosupport keykey actions identified in the plant plant procedures/guidance procedures/guidanceor ortotoindicate indicate imminent or actual

.l,L,U.lIU,U,vUl- actual core damage damage (NEI (NEI 12-06 12-06Rev.

Rev. 00Section Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use use as as the detailed strategy is developed. Closure of this item will be communicated cOlnmunicated in a future 6-month update.

Core Exit Thermocouple Thermocouple (CET)

(CET) Temperature:

Temperature: TI-IT002 RCS Accumulator Level: L1951,1,L1953, LI953, L1955, LI955, and andLI LI957957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06 . NI-36B

Reference:

1. PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA-PSC-0965.

Deployment Conceptual Modification (Attachment 3 contains ConceptualConceptual Sketches)

Sketches)

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

use.

Page 30 of 68 of68

Braidwood Station, Braidwood Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Equipment will be delivered modifications are No modifications are required

'F".n.nn ....."'rI Braidwood will utilize Phase 22 from the RRC to the staging other than those other those outlined in connection points.

area. From there, the Phase 2 of this plan.

equipment will be transported to the site and hooked up by both RRC and plant personnel per the playbook.

Equipment will then be operated per plant procedures.

procedures.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering Notes: LJL't.VJJ."'AA engineering designs designs for for compliance with NRC Order EA-12-049.

EA-12-049. Detailed designs based on the Detailed designs based on the current conceptual current conceptual designs will be developed to determine the final plan and associated

\4UIJ'V'.,dL .... '-...'~ mitigating

.U,"""'A;",,~"'JJ.U,."" strategies.

C'Tr~lT"""T1AC' Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page Page 31 31 of 69 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Containmen Maintain Containment Determine Baseline coping capability with installed coping coping3 modifications not including FLEX modifications, utilizing methods described in Table 3-2 of FLEX NEI 12-06:

of NEI 12-06:

• • Containment Spray

• • Hydrogen igniters (ice condenser condenser containments containmentsonly) only)

PWR Installed Equipment Equipment Phase Phase 1: 1:

Provide a general general description description of ofthe the coping coping strategies strategies using using installed installed equipment equipn1ent including including modifications that modifications that are are proposed to n1,aintain maintain containment.

containment. IdentifyIdentify methods methods (containment spray/Hydrogen igniter) and and strategy(ies) strategy(ies) utilized utilized totoachieve achievethis thiscoping copingtime.

time.

There are no Phase 11 actions actions required.

.-n.rn,,,..c.ro The limiting case for containment occurs when Auxiliary Feed flow is not established and the TA-F of 2.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> results in the maximum calculated containment pressure is 28 psia and maximum temperature of 218 °F (Ref. 1). This is significantly lower than the Containment Design pressure of 50 psig and the maximum calculated Containment temperature of 280 °F for a LBLOCA and 333 °F for a MSLB (Ref, 2). Additional calculations will be performed to evaluate containment response, Any difference will be communicated within a future 6-month update.

Reference:

1. Braidwood calculation RM Documentation NO. BW-MISC-009, dated November 1, 2011 1.

2. Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Section 6.2, dated December 2012.

Details:

Provide a brief Braidwood Station will use the industry developed guidance from description of of Procedures Procedures the Owners Groups, EPRI and NEI Task team to develop site I/ Strategies /I Guidelines specific procedures or guidelines to address the criteria in NEI 12-06 Rev. 0. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

Identify modifications modifications There are no no Phase 1 modifications required.

33 Coping modifications consist consist of of modifications modifications installed installed to to increase increase initial initial coping coping time, time, i.e.,

i.e., generators generatorsto to preserve vital instruments instruments or or increase increaseoperating operatingtime timeononbattery batterypowered poweredequipment.

equipment.

Page 32 of of 6868

Braidwood Station, Units I1 and and 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Key Containment Parameters SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, P1 ;pressure control 535, PI-545 and PI-546 SG Level: RCS pressure boundary and and NR - LI-517, 17, LI-519,19, LI- pressure control 527, 527, LI-S37, LI-S47 and LI-537, LI-547 and LI-S49 LI-549 WR R - LI-S02 LI-502 andand LI-503 LI-S03 RCS Temperature:

Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS pressure boundary and pressure control Containment Pressure: PI- Containment Integrity PCO05 SFP Level: (component # SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may mayidentify additional parameters that are needed in order order to support key actions identified in the plant procedures/guidance procedures/guidanceor ortotoindicate AAA .... '-'."'.......""

imminent or actual core core damage damage ( 112-06 Rev. 00 Section Section 3.2.1.10) and any difference difference will be communicated within aafuture 6- month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated cornm'unl~::;at(!ct in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L195 1, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFB/ Flow: FI-AFOI2A, FI-AFOI4A, FI-AFOI6A and FI-AFOI8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: N1-NRO06AIB, NI-36B IR Page 33 of of 68 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan

Reference:

1. P OG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA-PSC-0965.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with C Order EA-12-049. Detailed designs based on onthe current currentconceptual

,.".",.",r,t-n<:>

designs will be developed to determine

".U..d.v.LLU.IAj,,,-, the the final final plan and and associated mitigating mitigating strategies.

strategies. Once these have been fully developed, Exelon will update the integrated integrated plan plan for for Braidwood Braidwood during during aa scheduled 6-month update. This update will include any changes changestotothe initial designs designsasas submitted in the February 28, 2013 Integrated Plan.

Page 34 ofof 68

Braidwood Braidwood Station, Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Maintain MaintainContainment Containment PWR PWR Portable Portable Equipment EquipmentPhase Phase2: 2:

Provide Provide aa general generaldescription descriptionofofthe the coping strategies using coping strategies on-site portable using on-site portableequipment equipment including including proposed to maintain modifications that are proposed containment. Identify maintain containment. Identify methods (containment spray/hydrogen spray/hydrogen igniters) and and strategy(ies) strategy(ies) utilized utilized totoachieve achievethis thiscoping copingtime. time.

There are are no no Phase Phase 22 actions actionsrequired.

required.

Details:

Provide a brief brief Confirm Confirn~ that procedure/guidance procedure/guidanceexists existsor orwill willbe bedevelopeddevelopedtoto description ofof Procedures Procedures support support implementation in~plementation Strategies /I Guidelines

/ Strategies Braidwood Station will use use thethe industry industry developed developed guidance guidance from the Owners Groups, EPRI and NEI Task team team to to develop site specific procedures or guidelines to address the criteria in NEI 12-06 Rev. 0.

These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

Identify modifications List modifications modifications There are no Phase 22 modifications required.

U.IV".U. .1..1.vUl-.1.Vlh:J required.

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

Parameters . . _.

Essenti al Instentation Safety Punition SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Level: RCS pressure boundary and NR - LI-517, LI 519, LI-527, pressure control LI-537, LI-547 and LI-549 LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-41313, TI-

....423P,TI-433B

.... and TI-443B_............................

RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: PI- Containment Integrity

---

PC005 SFP Level: (component SFP Inventory TBD).___

Braidwood's evaluation of the FLEX strategy may identify additional Page 35 Page 35 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Integrated Plan Plan parameters that are needed in order order to to support supportkey keyactions actions identified

. . . . ...,u .......... ...,"'"

in the plant procedures/guidance procedures/guidanceor orto toindicate indicateimminent ororactual actual core d.age (NEI 12-06 Rev. 0 o Section Section3.2.1.10) 3.2.1.10)and any difference will be communicated within a future 6-month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be ri".TCH ,,,,,ru:>,.....

be communicated communicated in in aa future future 6-month 6-monthupdate.update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1951, L1953, L1955, and LI 957 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: EI-AF012A, FI. AF014A, FI-AF016A and FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06A/B, NI-36B IR

Reference:

PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments)

Rev. 0, Supplement 14, dated December 2012 PA-PSG-0965.

Storage // Protection of of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic NA NA Flooding NA NA with High Severe Storms with High NA Winds Winds Snow, Ice, and Extreme

Snow, Cold Cold High Temperatures NA Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Strategy Modifications Protection of Protection of connections connections Page 36 of 68

Station, Units Braidwood Station, Braidwood Units 11 and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated PlanPlan Identify Identify Strategy Strategy including includinghow how Identify Identify modifications modifications Identify Identify how thethe connection connection isis the the equipment equipment will will be be deployed deployed protected protected to to the the point pointof ofuse.

use.

No deployment strategy isIS No modifications are required. No new connection points are are required. required.

Notes:

Notes: Exelon Exelon Generation GenerationCompany,

_ .."O-.. IJ ...... LLC (Exelon) (Exelon)has hasnot notfinalized finalizedthetheengineering engineeringdesigns designsfor for compliance with NRC Order EA-12-049.

EA 049. Detailed Detaileddesigns designsbased on onthe thecurrent currentconceptual conceptualdesigns designs will be developed to determine the final plan and and associated associated mitigating mitigating strategies.

strategies. Once these thesehave have been fully developed, Exelon will update the integrated integrated plan planfor for Braidwood Braidwoodduring aascheduled scheduled 6-month update. This update will include A.l.J."'Jl"\..I~'"any anychanges changestotothe theinitial designs designsasassubmitted submittedin the February 28,28, 2013 2013 Integrated Plan.

Page 37 Page 37 of 68

Braidwood Braidwood Station, Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Maintain Maintain Containment Containment PWR PWR Portable Portable Equipment EquipmentPhase Phase3: 3:

Provide aa general generaldescription description of ofthe the coping coping strategies strategies using using phase phase 33equipment equipment including including maintain containment. Identify proposed to maintain modifications that are proposed Identify methods methods (containment (containment spray/hydrogen spray/hydrogen igniters) and and strategy(ies) strategy(ies) utilized utilized totoachieve achievethis thiscoping copingtime. time.

no Phase 33 actions are no There are actions required.

rann.r".r1 Details:

Details:

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

// Strategies // Guidelines There are no Phase 3 required .. a"n1T'"£~ri actions. actions.

modifications Identify modifications List modifications There are no Phase 33 modifications modificationsrequired. <"'0,",'',..,,,

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

evaluation.

Parameters - ._.,

Essential Instrumentation Safety Function SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Level: ICS pressure boundary and NR - LI°517, LI-51, LI-527, pressure control LI-537, LI-547 and LI-549 VVR - LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413B, TI-423I3, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: PI- Containment Integrity PC005. ...... ...................... ....... ..... __.____._._._.__.._._.__.._._..._......... _..... ................... ...... ............ .......... _..............

SFP Level: (component SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and any difference Page Page 38 38 of of 68

Braidwood Station, Units Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan will be communicated within a future 6 month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator AccumulatorLevel: Level:L1951, LI951,L1953, LI953,L1955, LI955, andandLI LI957 957 Reactor L"v4C1.vL'J~ Vessel Level Indicating IndicatingSystem System(RVLIS): LI-RC020 LI-RC020 AFW Flow: FI-AF012A, FI-AF012A, FI-AF014A, FI-AF014A,FI-AF016A 6Aand andFl-AFOI 8A 8A Battery Capacity / DC Bus Voltage: Voltage: El-DC002 EI-DCOO2 Neutron Flux: NI-NR006 NI-NR006A/B,, NI-36B IR.

Reference:

1. PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA-PSC-0965.

Deployment Conceptual Deployment Conceptual Modification (Attachment 3 contains Conceptual (Attachment Conceptual Sketches)

Sketches)

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

No deployment strategy is No modifications n'"\r\rh"'!~'::!;~!::)!!~ are are required.

required. No new connection~ points are

'-VL,ULv.<,"". . are required. required.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 39 of 68

Braidwood BraidwoodStation, Station,Units UnitsI1and and22Mitigation MitigationStrategies StrategiesIntegratedIntegratedPlan Plan Maintain MaintainSpentSpentFuelFuel Pool Pool Cooling Cooling Determine Determine Baseline Baseline coping copingcapability capabilitywith installed coping withinstalled coping4 modifications modifications not notincluding including FLEX FLEX modifications, modifications,utilizing utilizingmethods methodsdescribed describedin inTable Table3-2 3 .. 2of ofNEI NEI12-06:

12..06:

• • Makeup with Makeup withPortable PortableInjection InjectionSource Source PWR PWR Installed Installed Equipment EquipmentPhase Phase1: 1:

Initial Initial Spent Spent FuelFuel Pool Pool makeup makeup will be be accomplished accomplishedwith withgravity gravitydrain drainfrom fromthe theRWST.

RWST.

Procedure development Procedure developmentwill willbebedocumented documentedin aafuture 6-month 6-monthupdate.

Spent Fuel Pool (S FP) makeup is not a time constraint with the initial condition condition of ofboth bothunits in in Mode 1 at 100% power, since the worst case fuel pool pool heat heatload load conditions conditionsonly onlyexist existduring duringaa refueling outage. Under non-outage conditions, the maximum S FP heat load is is 38.5 38.5 Mbtu/hr. Loss of SFP cooling with this heat load and an initial SFP temperature of 141 degrees F results in a time to boil of 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, and 81.96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to the top of active fuel. Therefore, completing the equipment line-up for initiating S FP makeup at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> into the event ensures adequate cooling of the spent fuel is maintained.

The worst case SFP heat load during an outage is 61.4 Mbtu/hr. Loss of SFP cooling with this heat load and an initial S FP` temperature of 163 degrees F results in a time to boil of 3.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and 50.16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to the top of active fuel. With the entire core being located in the SFP, manpower resources normally allocated to aligning core cooling along with the Operations outage shift manpower can be allocated to aligning SFP makeup which ensures the system alignment can be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Initiation at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> event ensures adequate cooling of the spent fuel is maintained.

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

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

References:

1. Byron/Eraidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Section 9.1.3.1, Table 9.1-1 and 9.4-1 dated December 2012.

4aCoping Copingmodifications modificationsconsist consist of of modifications modifications installed to increase initial coping coping time, time, i.e.,

i.e., generators generatorsto to preserve vital preserve vital instruments instruments or increase operating time on battery powered powered equipment.

equipment.

Page 40 Page 40 of68 of 68

Braidwood Braidwood Station, Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Maintain Spent SpentFuel Fuel Pool Pool Cooling Cooling Details:

Details:

Provide Provide a brief brief Braidwood Station will use the industry developed guidance from description description ofofProcedures Procedures the Owners Groups, EPRI and NEI Task team to develop site

// Strategies Strategies // Guidelines Guidelines specific procedures or guidelines to address the criteria in NEI 12-06 Rev. 0. These procedures and/or guidelines will support the existing symptom symptom based based command command and and control control strategies strategiesin inthethe current current EOPs.

EOPs.

modifications Identify modifications The Spent Fuel Pool level instrumentation will be installed J.~A,:)~U..Ll""'Yin in accordance with C Order Number EA 12-051 and NEI 12-02 12-02 Rev. 0.

Key Key SFP SFP Parameter Essential Instru mentation Safety Function SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, P1-535, pressure control PI-545 and PI-546 SG Level: RCS pressure boundary and NR - LI-517, LT-519, LI-527, pressure control LI-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413IB, TI-42313, TI-43313 and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: PI- Containment Integrity PC005 SFP Level: (component # SFP Inventory TB D)

Braidwood's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3,2.1.10) and any difference will be communicated within a future 6-month update following identification.

Per NRC Order Number EA 12-051, "Order Modifying Licenses with regard to Reliable Spent Fuel Pool Instrumentation" and NEI 12-02, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."

1 addition to the parameters listed in NEI 12-06 Rev. 0 Section Page 41 Page 41 of 68

Braidwood Braidwood Station, Station, Units Units 11 andand 22Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlanPlan ntain Spent Maintain SpentFuel FuelPool PoolCooling Cooling 3.2.1.10, 3.2.1. the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will use as be be communicated in a future 6-month update.

,..r...,.,n-\,. ....,.,..'1,1"or!

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1951,1,LI953, L1955, and LI 957 Reactor Reactor VesselVessel Level Level Indicating IndicatingSystem System(RVLIS): (RVLIS):LI-RC020 LI-RC020 AFWW Flow:Flow: FI-AF012A,FI-AF012A, FI-AF014A, FI-AF014A, FI-AF016A FI-AF016A and and FI-AF018A FI-AF018A Battery Battery Capacity Capacity // DC DC Bus Voltage: Voltage: El-DC002 Neutron Neutron Flux: NI-NRO06A/B, NI-NR006AIB, NI-36B IR

Reference:

1. PWROG Generic

1. Generic FLEX FLEX Support SupportGuidelines Guidelinesand Interfaces (Controlling Procedure Interface U .."'I"'nrll" .... "" 1 .... t-,"" ..1" .... ,...,a andRecommendation and Kelcornm,enclatlon Instruments) Rev. Rev. 0, 0, Supplement Supplement14, 14,dated datedDecember December2012 2012PA-PSC-0965.

PSC-0965.

Notes: Exelon Generation Company, Company, LLC LLC (Exelon) has not finalized the engineering designs for

\L..Ifl,VA'-fJ.L compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the the final plan plan and and associated associated mitigating mitigating strategies.

strategies. Once Once these have been fully developed, Exelon will will update update the the integrated integrated plan plan for for Braidwood Braidwood during during aa scheduled 6-month update. This update will include includeany changes totothe initial designs designsasas 28, 2013 submitted in the February 28, 2013 Integrated IntegratedPlan.

Page 42 Page 42 of68of 68

Braidwood Station, Units Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling PWR Portable PWR Portable Equipment Phase Phase 2: 2:

Provide Provide aa general generaldescription description ofofthe the coping coping strategies strategiesusing usingon-site on-site portable portableequipment equipmentincluding including modifications that modifications that are are proposed proposedto to maintain maintainspent spentfuel fuelpool poolcooling. cooling. Identify Identifymethodsmethods(makeup (makeupvia via portable portable injection injection source) source) and and strategy(ies) strategy(ies) utilized utilized totoachieve achievethis this coping copingtime. time.

Spent Fuel Pool cooling will be achieved with a portable FLEX diesel pump. The Thepump suction suctionwill come from the UHS and/or RWST and will discharge discharge into the the S FP.

Evaluation of of the spent spent fuel pool pool area area for for steam steamandandcondensation condensationhas hasnot notyetyetbeen beenperformed.

performed.The results of this evaluation and the vent path strategy, if LV,,".'-'."" if needed, needed, will be be provided provided in aa future 6-month update.

Electrical power required to support the Flex Strategy is

<'Hr' ...... '"' .. .- is described described in the the Safety Safety Function Support UU.,"",L-.llw'.l.l Support Section of the document.

document.

Details:

Provide aa brief Provide brief Confirm that procedure/guidance Confirnt procedure/guidance exists exists or orwill willbe bedeveloped developedtoto description of description of Procedures Procedures support implementation support intplementation I/ Strategies Strategies // Guidelines Guidelines Braidwood Station will use the industry developed guidance guidance from the Owners Groups, EPRI and NEI Task team to to develop site specific procedures or guidelines to to address address the criteria in NEI 12-06 Rev. 0.

These procedures and/or guidelines Fo ... ,' ...."" ..... "-H..;'" will support the existing symptom based command command and and control strategies in the current EOPs.

Identify modifications Identify modifications List modifications Spent fuel pool cooling will be Spentachieved fuel pool cooling withbeaachieved portable FLEX diesel pump via primary and alternate alternate FLEX injection connections. l"UU.r>i"1r,,,,, connections.

The primary injection path will be through the SFP skimmer system.

A tee connection will be installed on line OFC29B upstream of OFC8751. The pipe will be routed from this tee in the spent fuel pool skimmer room to the FIB south wall. The pipe will penetrate the south wall of the FHB and have a standard FLEX connection installed.

The alternate injection path will be provided by installation of a standpipe adjacent to the SFP by the north wall with standard National Standard Tread (NST) connection, A pipe will be routed from the standpipe to the Fuel Handling Building (FHB) north wall on the ground elevation. The pipe will penetrate the north wall of the FHB and have a standard FLEX connection installed that will allow connection of regional response center equipment. The NST Page 43 of 68 of68

Braidwood Station, Braidwood Station, Units Units 1 and 2 Mitigation Strategies Integrated Plan connection connection will have a staged fire hose with aa spray nozzle, Key SFP Parameter Key Essential Instrumentation Safety Function SO Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Level: RCS pressure boundary and and NR - LI-517, 17, LI-519, LI-527, LI-S27, pressure .control pressure ., . . "' ....... 'VA LI-S37, LI-537, LI-547 and LI-S49 LI-549 WR - LI-S02 LI-502 and LI-503 LI-S03 - ---------------------- - -

RCS Temperature: RCS Heat Removal Cold Leg- Leg - TI-413B, TI-423B, }

I TI-433B

- - --------- ----------- - and TI-433B and TI-443B TI-443B --------------

Res RCS Pressure: WR -- PI-403 PI-403 RCS pressure boundary and and control pressure control Tu'pccn'rp Containment Pressure: PI- Containment Integrity PC005 SFP Level: (component # SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

Per NRC Order Number EA 12-051, "Order Modifying Licenses with 11"';:;>1"1C';;:>C' with regard to Reliable Spent Spent Fuel Pool Instrumentation" and NEI 12-02, 12-02, "To ModifyModify Licenses Licenses with with Regard to Reliable Spent Fuel Pool: Pool:

Instrumentation."

In addition to the parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI- 006A/B, NI-36B IR Page 44 Page 44 of 68 of68

Braidwood Station, Braidwood Station, Units Units 1I and 2 Mitigation Strategies Integrated Plan

Reference:

1.1. PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Interface and Recommendation Instruments) Rev. 0, Supplement 14, dated December 2012 PA- PA-PSC-0965.

Storage I/ Protection Storage Protection of Equipment:

Describe storage I/ protection plan or schedule to determine storage requirements Describe requirements Seismic Seismic Structures to provide protection of Structures of FLEX equipment will be constructed to meet the requirements of ofNEI 12-06 Rev. 0, 0,Section Section

11. Schedule

11. Schedule to to construct permanent building is is contained inin Attachment 2, and will satisfy the the site site compliance compliance date.date. Temporary Temporary locations JlV....," .. ~'vu.1J will be used until building building construction construction completion.

completion.

Procedures and programs will be be developed developed to to address addressstorage storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Flooding Structures to provide protection protection of FLEX equipment will be constructed to meet the requirements of 112-06 Rev. 0, Section

11. Schedule to construct permanent

11. permanent building building isis contained containedin Attachment 2, and will satisfy the site site compliance date, date. Temporary Temporary locations will be used used until building buildingconstruction constructioncompletion.

completion.

Procedures and programs will be be developed developedtotoaddress storagestorage structure requirements, haul path requirements, and ""AAJV.U""', andFLEX equipment requirements relative to the external hazards hazardsapplicable applicabletotoBraidwood Braidwood Station.

Station.

Severe Severe Storms Storms with with High High Structures to provide provide protection of FLEX equipment will be be Winds Winds constructed constructed to to meet meet the the requirements of NEI 12-06 Rev. 0,0,Section Section

11. Schedule to construct construct permanent permanentbuilding buildingisis contained containedin Attachment 2,

""'' .... ...,AU.U. . . . 2, and will satisfy the site compliance date. Temporary Temporary locations will will be used until building construction completion.

Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Snow, Snow, Ice, Ice, and and Extreme Extreme Structures to provide protection of FLEX equipment will be Cold Cold constructed to meet the requirements of NEI 12-06 Rev. 0, Section

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

Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Page Page45 45 of of68 68

Braidwood Station, Units Units 1 and and 2 Mitigation Strategies Integrated Integrated Plan Plan Station.

High Temperatures Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section

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

Procedures and programs will be developed to VL'VIIJ"" .... to address addressstorage storage structure requirements, haul path path requirements, requirements, and andFLEX FLEXequipment equipment requirements relative to to the the external external hazards hazards applicableapplicabletotoBraidwood Braidwood Station.

Deployment Conceptual Design (Attachment 3 contains Conceptual Conceptual Sketches)

Sketches)

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

use.

The required FLEX equipment The storage structure structure FLEX piping, valves, and needed for Spent Fuel Pool conceptual design has not not been connections (electrical & fluid)

Cooling will be installed in a completed. will meet NEI 12-06 Rev.0 robust FLEX building ready for The closure of this item will be protection requirements.

hookup and use. documented in a future There will be an an administrative

"'. . . . .J..., .....

u.J.u.

6-month update. program program created created to protect protect the the Hoses and electrical connectors connections from blockage will be completed as needed

.... 'V ... JL.V".'--.., ..... needed toto during outages and during and non-outage non-outage support the site coping coping strategy strategy times.

and will be stored within within the FLEX building.

Notes: Exelon Generation Company, LLC (Exelon) has has not not finalized finalized the engineering designs designs for for compliance with NRC Order EA-12-049. Detailed Detaileddesigns designsbased on onthe current currentconceptual conceptualdesigns designs will be developed to determine the final plan and associated associated mitigating mitigating strategies.

C1\-.L\-.L\-'-'j;~.L""'" Once Oncethese have have been fully developed, Exelon will update the integrated plan planfor Braidwood Braidwoodduring a scheduled 6-month update. This update will include any .... Jlv* ........ "" anychanges changestotothetheinitial designs as submitted in the February 28, 2013 Integrated Plan.

Page 46 of 68 of68

Braidwood Station, Units 1 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Spent Fuel Maintain Spent Fuel Pool Pool Cooling Cooling PWR. Portable PWR Portable Equipment Equipment Phase 3:

Provide a general general description description of ofthe the coping coping strategies strategies using phase 33 equipment using phase equipment including including modifications that are are proposed proposed toto maintain maintain spent spentfuelfuel pool poolcooling.

cooling. Identify Identifymethods methods(makeup (makeup via via portable portable injection injection source) source) and andstrategy(ies) strategy(ies) utilized utilized totoachieve achievethis thiscoping copingtime.

time.

Phase 2 strategy will will provide provide sufficient sufficientcapability capabilitysuch suchthat thatno noadditional additionalPhase Phase3 3strategies strategiesareare required.

Phase 3 equipment equipment for for Braidwood Braidwood includes includes backup backup portable portable pumps pumpsand andgenerators.

generators.TheTheportable portable pumps will pumps will be capable capable ofof providing providing the the necessary necessary flow and and pressure pressure as as outlined outlined in thethe Phase Phase 22 response for Core Cooling Cooling & & Heat Removal, Removal, RCS RCS Inventory InventoryControl, Control,andandSpent SpentFuel FuelPool PoolCooling.

Cooling.

The portable generators will be capable capable ofof providing the necessary necessary 480 480 volt voltpower powerrequirements as as outlined

..... """u' ...... in Phase 2 2 response response for for Safety Safety Functions FunctionsSupport.

Support.

In addition, a support component would be a portable refuel vehicle with aa large oil bladder~rto large diesel oil ri'*-'f1" .. to support refilling the FLEX diesel tanks.

Details:

Provide aa brief Provide brief Confirm that procedure/guidance Confirm, procedure/guidance exists exists or orwill willbe bedeveloped developedto to description of of Procedures support implementation implementation

/ Strategies // Guidelines Braidwood Station will use the industry developed guidance guidance from from the the Owners Groups, EPRI and NEI Task team to develop develop site site specific specific procedures or guidelines to nll1,rtaI1naC' to address address the criteria in NEI 12-0612-06Rev. 0.

These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

Identify modifications Identify modifications There are no Phase 3 modifications required.

Key SFP Parameter Essential Instrumentation Safety Function SG Pressure: RCS pressure boundary and PI-515, P1-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Level: RCS pressure boundary and NR - LI-517, L,I-519, LI-527, pressure control LI-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413E, T1-423E, TI-433E and TI-443B RCS Pressure: WR - PI-403 RCS pressure ressure boundary boundar and Page 47 of of6868

Braidwood Station, UnitsUnits 1 and 2 Mitigation Strategies Integrated Plan pressure control Containment Pressure: PI- Containment Integrity PC005 S Level: (component # SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may identify additional parameters that are are needed in order toto support supportkey keyactions actionsidentified

..... VL ........... .LV .....

in the plant procedures/guidance procedures/guidance or ortoto indicate indicateimminent imminentororactual actual core damage (NEI 12-06 12-06 Rev. 0 Section 3.2.1.10) 3.2.1.10) and any difference any difference will be communicated within a future 6-month 6-month update update following following identification.

Per NRC Order Number EA 12-051,12-051, "Order "Order Modifying Modifying Licenses Licenses with regard to Reliable Spent Fuel Pool Instrumentation" Instrumentation" and and NEI 12-02, 12-02, "To Modify Licenses with RegardRegard to to Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation."

Instrumentation. "

In addition to the parameters listed in NEI 12-06 Rev. 00 Section Section 3.2.1.10, the following additional parameters will be evaluated evaluated for for use as the detailed strategy is developed.

developed. Closure Closure of ofthis this item will be be communicated in aa future 6-month comtnunicated 6-monthupdate.

update.

Core Exit Thermocouple Thermocouple (CET)

(CET) Temperature:

Temperature:TI-IT002 RCS Accumulator Accumulator Level:

Level: L1951, LI951 ,L1953, LI953, L1955, LI955, and LI 957 Reactor Vessel Level Indicating System System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A FI-AF016A and FI-AF018A 8A Battery Capacity / DC Bus Voltage: El-DC002 EI-DC002 Neutron Flux: NI-NR006A/B, NI-NR006A1B, NI-36B IR

Reference:

1. PWROG Generic FLEX Support Support Guidelines and Interfaces (Controlling Procedure Procedure Interface and Recommendation Instruments) Rev. 0, Instruments) Supplement 14, dated December 2012 PA-0, Supplement PSC-0965.

Deployment Conceptual Design (Attachment 3 contains Conceptual Conceptual Sketches)

Sketches)

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

use.

Equipment will be delivered I No modifications are are required I Braidwood will utilize Phase 22 Page 48 of 68 of68

Station, Units Braidwood Station, Units 1 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan from the RRC to the staging other other than than those those outlined in In connection connection points.

points.

area. From there, the equipment Phase 22 of of this this plan.

plan.

will be transported to the site and hooked up by both RRC and plant personnel per the playbook. Equipment will then be operated per plant procedures.

Notes: Exelon Generation Generation Company,Company, L LC (Exelon) has not not finalized finalized the the engineering engineeringdesigns designsfor compliance with NRC Order EA-12-049. Detailed Detaileddesigns designsbased basedon onthe thecurrent currentconceptual conceptualdesigns designs will be developed to determine the final final plan plan and and associated associated mitigating mitigating strategies.

strategies. Once Oncethese thesehave have been fully developed, Exelon will will update update the integrated integrated plan plan for for Braidwood Braidwood during aascheduled scheduled 6-month update. This Thisupdate updatewill include includeany anychanges changestotothe initial designs designsasassubmitted sublnittedin the 2013 Integrated February 28, 2013 Int""0>1'jJ,tt:>1"i Plan.

Page 49 Page 49 ofof 68 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Strategies Integrated Integrated PlanPlan Functions Support Safety Functions Support Determine Baseline Determine Baseline coping coping capability capability with with installed installed copings copingS modifications modifications not not including including FLEX modifications.

FLEX modifications.

PWR PWR InstalledInstalled Equipment Equipment Phase Phase 11 Provide Provide aa general generaldescription description of ofthe the coping coping strategies strategiesusingusinginstalled installedequipment equipm,entincluding includingstation station modifications that are proposed proposed to maintain andlor and/orsupport supportsafety safety functions. IdentifyIdentify methods methods andand strategy(ies) utilized to to achieve achieve coping coping times.times.

DC power is required to to maintain control control ofofESF equipment and vital vitalinstrumentation. Battery Battery chargers are de-energized de-energized during during aa BDBEE leading totoloss lossofofDC DCand andassociated associatedfunctions.

functions.

The present 125VDC battery The battery coping coping time is is approximately approximately 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> hours 36 36minutes, minutes, without withoutload load shedding and shedding and can be extended to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 40 40 minutes with with deep deep load shedding shedding (Ref.(Ref. 1)1) consistent consistent with procedure BwCA BwCA 0.0.0.0. Loss Loss ofofall AC Power.

Reference:

1. EC Evaluation 391834, Battery Coping Time For The 125v 125v DC ESF Battery Banks, dated February 12, 2013.

Details:

Details:

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

support implententation.

Procedures Procedures /I Strategies Strategies /I Braidwood Station will use the industry industry developed developed guidance guidance from from the Guidelines Guidelines Owners Groups, EPRI and NEI Task team team toto develop develop site specific procedures or guidelines guidelines to to address address the thecriteria criteriain NEI 12-06 12-06Rev.0.

Rev.O.

These procedures and/or andlor guidelines will support support the the existing existing symptom based command and

.UAI->JJ:.U and control control strategies strategiesin the thecurrent currentEOPs.

Identify modifications Identify modifications There are no Phase 1 modifications required.

Key Parameters Key No identified key parameters.

Braidwood's evaluation of the FLEX strategy may identify parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage. Reference NEI 12-06 Rev. 0 Section 3.2.1.10 and any difference will be communicated within a future 6-month update following identification.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once 55 Coping modifications consist of of modifications installed to to increase increase initial initial coping coping time, time, i.e.,

i.e., generators generators to to preserve vital instruments instruments or or increase increase operating operatingtime timeon onbattery batterypowered poweredequipment.

equipment.

Page 50 of of6868

Units 1 and 2 Mitigation Braidwood Station, Units Miti ation Strategies Strate ies Integrated Inte rated Plan Plan Safety Functions Support Support these have been fully developed, Exelon Exelon will will update update the integrated integrated plan for Braidwood Braidwood during during aa scheduled 6-month Thisupdate will include h_n"'Anrn update. This includeany anychanges changestotothe initial designs designsasas submitted in the February 28, 20133 Integrated Plan.

Page 51 Page 51 of of 68 68

Braidwood Station, UnitsUnits 11 andand 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Safety Functions Safety Support Functions Support PR PWRPortable Portable Equipment Equipment Phase Phase 22 Provide aa general general description description ofofthe the coping coping strategies strategies using using on-site on-site portable portable equipment equipment including including station station modifications that are proposed proposed to to maintain maintain and/or and/orsupport supportsafety safety functions.

functions. Identify Identify methods methods and and strategy(ies) strategy(ies) utilized to to achieve achieve coping coping times.

times.

A portable diesel generator will provide power to one (1) division of the 480V ESF busses. Repowering atatthis level will permit the recovery of one onedivision of station battery chargers, chargers, DDAFP battery battery chargers, chargers, MCC's MCC'spowering poweringcritical criticalequipment equipmentsuch suchasasDiesel.

Dieselfuel fueloil oiltransfer transferpumps, pumps, and other ESF equipment equipment beneficial beneficial toto mitigate mitigatethe theevent.

event.

Exelon Generation Company, LLC (Exelon) (Exelon) intends intends onon maintaining maintaining Operational commandcommandand control control within the Main Control Room. Habitability conditions conditions will will be be evaluated evaluated andand aastrategy strategy will will be be developed to maintain Main Control Room habitability. habitability. The The strategy strategy and associated associated support analyses analyses will be provided in a future 6-month update. Critical ventilation ventilation assets assets may may be required required to to support DDAF pumps, station battery rooms, miscellaneous miscellaneous electric electric equipment rooms, rooms, and fuel handling building personnel habitability and/or

......... " ......... u.J'-, and/or component component survivability.

survivability. Specific Specific analyses analyses ofofthese theserooms roomsare are open items and will be addressed as part of the detailed engineering engineering design design phase. Closure Closureofofthese these items will be documented in aa future 6-month update.

Additionally, a backup water source for core cooling, inventory, and and SFP makeup will be established with a portable FLEX diesel driven pump and and temporary temporary hoses hoses from the UHS. Dry Hydrant will be installed at the UHS to to support support this strategy.

strategy.

Details:

Details:

Provide a brief description procedure/guidance exists Confirm that procedure/guidance exists or orwill willbe bedeveloped developedto to of Procedures I/ Strategies of Procedures Strategies I/ support implementation with with aa description description of the procedure // strategy the procedure strategy //

Guidelines Guidelines guideline.

Braidwood Station will use the industry developed guidance from the n-ll1r1<::l1nI"'P Owners Groups, EPRI and NEI Task team to to develop site site specific specific procedures or guidelines to address the the criteria criteria in NEI 12-06 12-06 Rev. Rev. 0.O.

These procedures and/or guidelines will support the support the existing symptom symptom based command and control strategies strategies in the thecurrent currentEOPs.

Identify Identify modifications modifications List modifications necessary for Phase 2 The following modifications will be installed to support the FLEX generator for repowering one division of station DC batteries:

One 480V ESF bus on each unit will be re-powered with a portable FLEX generator. The primary FLEX connection will be at the FLEX building outside of the Fuel Handling Building (FHB) outer wall. From the FLEX connection installed cables will be routed through the FHB and AUX building to the 480V ESF bus. At the bus, a spare breaker will be modified to function as a feed breaker.

The alternate FLEX connection will consist of a patch panel mounted directly to the 480 V ESF bus. Cables and a portable generator will be staged supporting timely re-powering of the bus consistent with the site's timeline.

Page 52 of 68

Braid ood Station, Units Braidwood Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan A dry hydrant will be installed installed in the UHS UHS with with aa Flex Connection Connection on on it as a source source of ofmakeup water waterfor foruse usewith aaportable portablepump.

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

evaluation.

No No identified key parameters.

1rt"'.-nh,-t-1..-.'rt Braidwood's evaluation of the FLEX strategy may identify parameters that are needed in order to support key actions identified in the plant procedures/guidance fo:"UJ.UCUJ. .l...,..., or or toto indicate imminent ororactual core coredamage.

UU-JlU."fo:"V.

Reference NEI NEI 12-06 12-06 Rev. Rev. 0, 0, Section Section3.2.1.10 3.2.1.10and andanyanydifference differencewill will be communicated within aa future 6-month 6-month update following update following identification.

Storage Storage // Protection Protection of of Equipment Equipment: :

Describe storage // protection Describe storage protection plan plan or orschedule scheduleto to determine determinestorage storagerequirements requirements Seismic Seismic Structures to provide provide protection protection of ofFLEX FLEXequipment will be be constructed

,.,....,. .."C't~'lHyh:"rl to meet meet the requirements of ofNEI 12-06 12-06Rev.Rev.0,0,Section Section11. 11.

Schedule to construct permanent building is contained p""LJU$ ....' .... ...", .... '-" ....... JL .......... [O-, contained in Attachment 2, and will satisfy satisfy the site site compliance date. date. TemporaryTemporarylocations locationswill be used until building construction completion. completion. Procedures Procedures andand programs will be be developed developed to to address address storage storagestructure structurerequirements, haul path requirements, and and FLEX FLEX equipment equipmentrequirements relative to the external hazards applicable applicable to to Braidwood BraidwoodStation. Station.

Flooding Structures to provide protection of FLEX equipment U-vl.LU'-J," equipmentwill willbebe Note: if stored below current constructed to meet the the requirements l'prnllt'PfY1Pntc of NEI 12-06 12-06Rev.Rev.0,0,Section Section11. 11.

flood level, then ensure ensure Schedule to construct permanent building T\PT"T"n'J,npl1T building isis contained containedin Attachment procedures exist to move 2, and will satisfy the site site compliance date. date. TemporaryTemporarylocations locationswill equipment prior to exceeding be used until building building constructionconstruction completion. completion. Procedures Proceduresand and flood level. programs will be developed developed to to address address storage storagestructure structurerequirements, haul path requirements, and FLEX equipment requirements requirementsrelative relativetoto the external hazards applicable to to Braidwood BraidwoodStation. Station.

Severe Storms Severe Storms with with High High Structures to provide protection of FLEX equipment will be Winds Winds constructed to meet the requirements of NEI 12-06 Rev. 0, Section 11.

Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction completion. Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Snow, Ice, Snow, Ice, and and Extreme Extreme Structures to provide protection of FLEX equipment will be Cold Cold constructed to meet the requirements of NEI 12-06 Rev. 0, Section 111.

Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction completion. Procedures and programs will be developed to address storage structure requirements, Page Page 53 53 ofof 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

High Temperatures Temperatures Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section 11.

Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date. Temporary locations will be used until building construction completion. Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards hazards applicable applicable to to Braidwood BraidwoodStation.

Station.

Deployment Conceptual Design (Attachment 3 contains Conceptual Conceptual Sketches)

Sketches)

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

The required FLEX support support structure The storage structure FLEX piping, valves, and equipment needed for AC Phase 22 pr'l111nl"nPIt- needed conceptual design design has has not not been connections (electrical fluid) implementation will be installed

""1'\'\on1"n1".r' ..... will installed completed. will meet NEI 12-06 Rev.0 in a robust FLEX building building ready ready The closure of this item will be protection requirements.

for hookup and use. Hoses and and documented in aa future There will be an administrative electrical connectors will will bebe 6-month update. program created to protect the completed

...,.~AALiJ'jl'V ...'"' ..... as needed to support connections from blockage the site coping strategy strategy and and willwill during outages and non-outage be stored within the FLEX times.

building.

The UHS FLEX support equipment will be staged in a robust building and and transported transported to to pre-identified a pre .. identified staging location location with a debris removal tool like the F750 with snow plow or equivalent, Hoses will be be completed as need to support cOlnpleted L~I.AUV,"JL the site coping strategy.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

54 of Page 54 68 of68

Braidwood Braidwood Station, Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Safety Functions SupportSupport PWR Portable Equipment Equipment Phase Phase 3 Provide aa general general descriptiondescription of ofthethe coping coping strategies strategies using using phase phase 33 equipment equipment including including modifications that are proposed to maintain andlor and/or support supportsafety safety functions. Identify Identify methods methods and and strategy(ies) utilized toto achieve achieve coping copingtimes. times.

Phase 2 strategy strategy will will provide provide sufficient sufficientcapabilitycapabilitysuch suchthat thatnonoadditional additionalPhase Phase3 3strategies strategiesareare required.

Phase 3 equipment ... ... IJ,u~ "',u. for

.. for Braidwood Braidwood includes includes backup backupportable portablepumps pumpsand andgenerators.

generators.The portable portable pumps will be capable capable of of providing providing the necessary necessary flow flow and and pressure pressure as as outlined outlinedininPhase Phase22response response for for Core Core Cooling Cooling & & Heat Heat Removal,Removal, RCS RCS Inventory Inventory Control Control andand Spent Fuel Pool PoolCooling.

Cooling.The portable portable generators generators will be capable capable of of providing providing the necessary necessary 480 480 volt voltpower powerrequirements requirements as as outlined

£'U""'YU.'" in In Phase 22 response for for Safety Safety Functions FunctionsSupport.

Support.

In addition, a supportr component C'l1r\T"\r\ ... v . u .. u,uvu....,J,u. would be a a portable portable refuel refuel vehicle vehicle with with aa large large diesel diesel oil bladder bladderto to support refilling

""',L,&J..u.~J'M the FLEX FLEX diesel diesel tanks.

Details:

Provide Provide aa brief brief Braidwood Station will use the the industry developed developed guidance guidance fromfrom the the description of of Procedures Procedures Owners Groups, EPRI and NEI Task team team toto develop develop site site specific specific

/ Strategies I/ Guidelines Guidelines procedures or guidelinesguidelines toto address address the thecriteria criteriain NEI 12-06 12-06Rev.

Rev.0.O.

These procedures and/or guidelines will support support the existing symptom based command

.l,Lll-"AJJlAA command and and control strategies strategiesin the current EOPs.

Identify modifications Identify There are no Phase 33 modifications modifications required.

required.

Key Parameters No identified key parameters.

parameters.

Braidwood's evaluation Braidwood's evaluation of thethe FLEX strategy strategymay identify identify parameters that are are needed needed in order ordertoto support supportkeykeyactions actionsidentified identified in the plant procedures/guidance procedures/guidance or or to to indicate imminent imminentororactual actual core damage. Reference NEI 12-06 12-06 Rev. 0 Section Section 3.2.1.10 3.2.1. and any any difference will be communicated within a future 6-month update following identification.

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

Sketches)

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

Equipment and consumables No modifications are required Braidwood will utilize Phase 2 Page 55 55 of68 of 68

Braidwood Braidwood Station, Station, Units Units 11and and22Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Safety Safety Functions Functions Support Support PWR PWR Portable Portable Equipment EquipmentPhase Phase33 will be delivered from the RRC other than those outlined in connection points.

to the staging area. From there, Phase 2 of this plan.

the equipment will be transported to transported to the the site site and and hooked up up by both RRC and and plant plant personnel per the nt:>y*cnl"lnf>.

playbook. Equipment will then be operated operated per per plant procedures.

procedures.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for LJn.'-,.IC\JU.

compliance with NRC Order EA-12049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 56 of68 Page 56 of 68

Station, Units Braidwood Station, Braidwood Units I1and and 22 Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan PWR Portable Portable Equipment Equipment Phase Phase 22 n_~~_

uses Use and (potential /,flexibility) diverse uses Pekfiwmance C f;lJU' O-iteiwi ;L3ain(cliance List portable uintenance /I PM I\JlOUI'\t'A1'1H!lnl"'A PM Core I Containment Core Containment SFP Instrumentation requirements equipment Three (3) 480 X 1 500kW Equipment maintenance and VAC Per conceptual design testing will be performed in Generator accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Three (3) 40 gpm at 1500 psia at the Equipment maintenance and High Head injection point to the RCS testing will be performed in Flex Pump per WCAP- 17601 -P accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6

..,"",....t-.,.... ..... 6 and NEI 12-06 section 11.

,.,,,...,....11-.......... 11.

Three (3) 300 gpm at 300 psia at Equipment maintenance and Medium the injection point to the testing will be performed in Head FLEX SG per WCAP- 17601 -P accordance with, the industry Pump templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Two (2) Self x 1100 gpm at 500 ft head 1 Equipment maintenance and Prime Pump General Usage testing will be performed in accordance with the industry 57 of 68 Page 57 Page

Braidwood Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan PWR. Portable PWR Equipment Phase Portable Equipment Phase 2 Use and (potential /jlc.cihilit °) diverse uses P ij rtnancc Criteria ^%^1ctt-nte:nance Maintenance

,ist portable Core Containment

/ PM IPM 11ontainment SFP Instrumentation Accessibility equipment requirements templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Six (6) 5500 watt Equipment maintenance and Portable General Usage testing will be performed in 120/240 accordance with the industry 12VDC templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

One F-750 x x X x Debris Removal and Equipment maintenance and Ford Truck Refuel delivery capability testing will be performed in General Usage accordance with the industry templates, as outlined in JLD-ISG-2012 -01 section 6 and NEI 12-06 section 11.

Three (3) x x x General Usage Equipment maintenance and Diesel Trash testing will be performed in Pumps accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Page 58 ofof 68 68

Braidwood Station, Braidwood Station, Units Units 11and and 22 Mitigation Mitigation Strategies StrategiesIntegrated IntegratedPlan Plan PWR Portable Portable Equipment Phase 22 EquipmentPhase Use and (potential /exi hi l i r y) diverse uses A-lainten.ance List portable I Core I Containment Containment Inslromentation Accessibility equipment Three (3) x x x x x General Usage Equipment maintenance and Satellite testing will be performed in Phones accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Six (6) 42" x x X General Usage Equipment maintenance and Box Fans testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Ten (10) 20" x x x General Usage Equipment maintenance and portable vent testing will be performed in fans accordance with the industry templates, as outlined in JLD-IS G-2012-01 section 6 and NEI 12-06 section 11.

Page 59 ofof 68

Braidwood Station, Braidwood Station, Units Units11and and22Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan PWR Portable PWR Portable Equipment Equipment Phase Phase 33 uses Use and (potential /flexibility) clii'erse uses Per~ rrrn once Criteria Note: The RRC equipment has not been procured at the time of this submittal. The equipment listed is a generic list provided by the RRC and even though Braidwood may not require this equipment in its plan it will be available and could be utilized in the Phase 3 time period. Once the SAFER committee determines the equipment specifications for bid, updates will be made as necessary to this table. The Phase 3 portable equipment table will be updated once all of the equipment has been procured and placed in inventory.

List portable List portable Core Core Containment Containment SFP SFP Instrumentation Instrumentation Accessibili ty Accessibility equipment equipment Medium x x x 2 MVO output at 4160 Vac,

• Generator must be common Voltage three phase commercially available.

Diesel

• Must run on diesel fuel.

Generator Low Voltage x x x x 500 kW output at 480 Vac,

• Generator must be common Diesel three phase commercially available.

Generator

• Must run on diesel fuel.

Positive x 1000-3000 psi shutoff head, Must run on diesel fuel displacement 60 gpm capacity High Pressure Pumps (PWR only)

Low Pressure X X X 300 psi shutoff head, 2500 Pump gpm max flow Page 60 of Page 60 of 68 68

Braidwood Station, Units Braidwood Station, Units 11and and 22Mitigation MitigationStrategies StrategiesIntegrated Integrated PlanPlan PWR Portable PWR Portable Equipment Phase 33 quipment Phase uses Use and potential /f exibility) di verve uses Pe^fiOT'7Yi(ZITCL' C1"TT`C'I"!.C! Af1te,1 Note: The RRC equipment has not been procured at the time of this submittal. The equipment listed is a generic list provided by the RRC and even though Braidwood may not require this equipment in its plan it will be available and could be utilized in the Phase 3 time period. Once the SAFER committee determines the equipment specifications for bid, updates will be made as necessary to this table. The Phase 3 portable equipment table will be updated once all of the equipment has been procured and placed in inventory.

List portable Core Containment I SFP Instrumentation Accessibility equipment Low Pressure x 500 psi shutoff head, 500 Pump gpm rnax flow Low Pressure x 110 psi shutoff head, 400 Pump gpm max flow submersible Low Pressure x x 150 psi shutoff head, 5000 Pump gpm max flow Air X 120 psi minimum pressure, Compressor 2000 scfm Page 61 Page of 68 61 of 68

Braidwood Station, Braidwood Station, Units Units 11and and 22 Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Phase 3 Response Equipment/Commodities esponse Equipment/Commodities Item Notes Radiation Protection Radiation Protection Equipment Equipment The RRC will not stock this type of equipment but this equipment will be berequested

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

• Dosimetry monitoring/sampling

• Off-site monitoring/sampling (EP input (EP input for for Personnel Personnel FLEX FLEX list) list)

Commodities Commodities The 12 .RC will not stock these commodities but they will be requested from site-to-

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

• Potable water (EP (EP input for Personnel input for Personnel FLEX FLEX list)

Fuel Requirements Fuel Requirements 300 - 500 gallon bladders that can canbe delivered by air Heavy Equipment Heavy Equipment To be developed during site specific playbook development

• Transportation equipment

• Debris clearing equipment Redundant Phase 2 equipment to be located at at RRC Page 62 of 68

Braidwood Braidwood Station, Station, UnitsUnits 11andand 22 Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Attachment Attachment1A lA Sequence Sequence of of Events Events TimelineTimeline Time ion Time Act Action Elapsed Time Action Constraint Constraint Remarks I Remarks item Applicability Applicability item YIN6 YIN 6

The times to to complete complete actions actions in the the Events Events Timeline Timeline are are based based on onoperating operatingjudgment, judgment,the theconceptual conceptualdesigns, designs,and and the current current supporting analyses. analyses. The final timeline timelinewill be betimetimevalidated validatedonce oncedetailed detaileddesigns designsare arecompleted, completed, procedures areare developed, developed, and andthe theresults resultswill willbebeprovided providedin a afuturefuture6-month 6-monthupdate.

update.

1 0o Event Event Starts, Starts, BDBEE occurs, occurs, Unit 11and andUnit Unit22 NA Plant @@100%

100%

reactors automatically automatically trip trip and andall rodsrodsare areinserted.

inserted. I power Loss of off-site off-site power power (LOOP) affecting affectingboth bothunits occurs occurs 2 1 1 minutes Emergency Operating Procedures (EOPs) and Station Station NA BwCA 0.0, Loss Black Out (SBO) (SBO) Procedures Procedures are areentered.

entered. of All AC Power, 3 5-15 minutes Verify DDAF Pp is is operating operating properly.

properly. Y --11 Y

Reference:

hour hour Braidwood Station MAAP analysis Documentation NO. BW-MISC-BW-MISC -

009 Rev 009 Rev 1 dated November 1, 1, 2011 4 1 10-30 minutes Attempt

L ...... starting Emergency D/Gs

,,l,U~J\- starting lI-<fl1arn'onr',:r DIGs NA NA BwCA 0.0, Loss of All. AC Power.

6 30 minutes ELAP condition recognized and ELAP Procedures NA Operator entered.

are entereo. judgment 7 30 minutes to 3.6

.1UJ,,1,",,,,'' Connect FLEX 480V AC generators to ESF bus Y-3.6

Reference:

EC hours _32X and verify they are supplying power to Div I1- hours Evaluation 125V DC battery chargers 391834, Battery 66 Instructions:

Instructions: Provide Provide justification justification if if No No or NA is is selected in the selected in the remarks remarks column column If If yes, yes, include technical basis include technical basis discussion discussion as as required required by by NEI 12-06 section NEI 12-06 3.2.1.7 section 3.2.1.7 Page 63 of 68 Page

Braidwood Station, Braidwood Station, Units Units 11 and and 22 Mitigation MitigationStrategiesStrategiesIntegrated Integrated Plan Plan Time Time Remarks Action Remarks I/

Elapsed Time Action Constraint Constraint item Action Applicability Applicability YIN 6 Y/N6 Coping Time For The 125V DC ESF Battery Banks, dated February 12, 2013 8 hours 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Start Start depressurization depressurization ofofS/Gs S/Gstoto300 300psia psiaatat75°F/hr 75°F/hr Y 1.5 1.5 WCAP-17601-P cooldown with SG cooldown with SG PORV PORV local/manual local/manualoperation. operation.SG SG hours hours Rev 0 and feed is controlled controlled with with LocallManual LocallManual operation operation of of Byron/Braidwood AFW flow AFW flowcontrol controlvalves.

valves. MAAP analysis Documentation NO BB-MISC-020 Rev 0 dated February 1, 2013 9 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> SI Accumulator borated borated water water begins begins to to inject injectinto the NA Operator RCS. Judgment 10 10 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Maintain RCS Maintain 300 psial-RCS 300 420"F with SG psia!~420°F SGPORV PORV NA WCAP-WCAP-17601 Maintain SG level.

operation. Maintain operation. Rev 0 11 11 3-6 hours Connect high pressure FLEX Pumps and ensure they NA are available to supplying supplying borated borated makeup

-">. ......n.'"""."" to the RCS.

12 12 6-12 hours Connect FLEX Pump and ensure it is available to NA supplying makeup to the SFP.

12 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Connect FLEX Pumps and ensure they are available NA to supplying makeup to the SGs.

Set up FLEX pump suction from UHS. NA Regional Response Center (RRC) resources begin NA arriving on site.

End ofContinue to maintain critical functions of Core analytical NA Cooling (via DDAF), RSC Inventory Control (via simulation FLEX pump injection to RCS) and SFP Cooling (via FLEX pump injection to SFP). Utilize initial RRC equipment and resources as a spare capacity.

Page Page 64 64 of68 of 68

Braidwood Station, Units I1and and22Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Attachment Attachment 1B IB NSSS Significant Reference NSSS Significant Reference Analysis Analysis Deviation Deviation TableTable WCAP WCAPvalue value WCAP Cap Gap and and discussion discussion Item Item I Parameter of Parameter interest of interest applied value Plant applied value (WCAp..17601.. PAugust (WCAP-17601-P August 2012 Revision 0) 2012 Revision 0) page 1 Time to begin the cooldown WCAP has a delay of 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> 4-14 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> From the MAAP Analysis BB-MISC-020 the cooldown begins early due to the secondary inventory available in the original Steam Generators on U-2 Page 65 of of 68

Braidwood Station, Units Braidwood Station, Units 11 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Attachment Attachment 2: 2:

Milestone ScheduleSchedule Site: Braidwood Site: Braidwood Original Target Activity Status Completion Date { Include date changes in this column}

Submit 60 Day Status Report Complete Submit Overall Integrated Integrated Complete Implementation Implementation PlanPlan Contract with RRC RRC Recurring action, action, Submit 6 month updates updates Aug and Feb Unit 11 2 Unit 2 Modification Development Modification Development Feb 2014 Sept Sept 1 modifications 2014 2014 Feb 2014 2 modifications

• Phase 3 modifications NIA 1 Unit 2 Modification lementation Apr 2015 Oct 2015

• Phase 1 modifications N/A Apr 2015 Oct 2015

• 2 modifications N/A Apr 2015 Oct 2015

• Phase 3 modifications N/A cedure Develop ment Apr 2015

• Strategy procedures Apr 2015 Jan 2015 Apr 2015 Apr 2015 Aprr 2015 A 2015 Dec 2014 Regional Response Center Operational A

Aprr 2015 2015 Unit 1 Implementation date Oct 2015 Unit 2 Implementation date Note(s):

1. Exelon will update the status of ongoing and future milestones in the Integrated Plan for BRW during a scheduled 6-month update. This update update will include any changes to the milestone schedule as submitted in the February February28,28,2013 2013 Integrated Plan.

of 68 Page 66 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment 3 Conceptual Sketches (Conceptual sketches, as necessary to indicate equipment which is installed or equipment hookups necessary for the strategies. )

Mechanical sketch

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Braidwood Station , Units 1 and 2 Mitigation Strategies Integrated Plan Electrical Sketch UNT1 UNIT 2 r-------------------------------------------i r------------------------------ -------------il I I I .....,---~

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