Text

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)
	ML13060A364
Person / Time
Site:	Byron
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-13-018
	Download: ML13060A364 (70)
	v • d • e

1 Exelon Gcncration Order No. EA-12-049 RS-13-018 February 28, 2013 u.s. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

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 25,2012 On March 12, 2012, the 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 0 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 Integrated Plan Report to EA-12-049 February 28, 2013 Page 2 Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29, 2012 which endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Overall Integrated Plan.

Reference 4 provided the EGC initial status report regarding mitigation strategies, as required by Reference 1.

The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1. This letter confirms EGC has received Reference 2 and has an Overall Integrated Plan developed in accordance with the guidance for defining and deploying strategies that will enhance the ability to cope with conditions resulting from beyond-design-basis external events.

The information in the enclosure provides the Byron Station, Units 1 and 2 Overall Integrated Plan for mitigation strategies pursuant to Reference 3. The enclosed Integrated Plan is based on conceptual design information. Final design details and associated procedure guidance, as well as any revisions to the information contained in the Enclosure, will be provided in the 6-month Integrated Plan updates required by Reference 1.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of February 2013.

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

Enclosure:

1.

Byron Station, Units 1 and 2 Mitigation Strategies (MS) Overall Integrated Plan cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Byron Station, Units 1 and 2 NRC Project Manager, NRR - Byron Station, Units 1 and 2 Mr. Robert J. Fretz, Jr, NRRIJLD/PMB, NRC Mr. Robert L. Dennig, NRRIDSS/SCVB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 28,2013 Page 2 Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29,2012 which endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Overall Integrated Plan.

Reference 4 provided the EGC initial status report regarding mitigation strategies, as required by Reference 1.

The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1. This letter confirms EGC has received Reference 2 and has an Overall Integrated Plan developed in accordance with the guidance for defining and deploying strategies that will enhance the ability to cope with conditions resulting from beyond-design-basis external events.

The information in the enclosure provides the Byron Station, Units 1 and 2 Overall Integrated Plan for mitigation strategies pursuant to Reference 3. The enclosed Integrated Plan is based on conceptual design information. Final design details and associated procedure guidance, as well as any revisions to the information contained in the Enclosure, will be provided in the 6-month Integrated Plan updates required by Reference 1.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of February 2013.

Respectfully submitted,

~T7¥ Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Byron Station, Units 1 and 2 Mitigation Strategies (MS) Overall Integrated Plan cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Byron Station, Units 1 and 2 NRC Project Manager, NRR - Byron Station, Units 1 and 2 Mr. Robert J. Fretz, Jr, NRRIJLD/PMB, NRC Mr. Robert L. Dennig, NRRIDSS/SCVB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety Byron Station, Units 1 and 2 Mitigation Strategies (MS)

Overall Integrated Plan (67 pages)

Byron Station, Units 1 and 2 Mitigation Strategies (MS)

Overall Integrated Plan (67 pages)

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Seismic events, except soil liquefaction; flooding from local intense precipitation; severe storms with high winds; snow, and extreme cold; and high temperatures were determined to be applicable Extreme External Hazards for Byron Station per the guidance of NEI 12-06 and are as follows:

Seismic Hazard Assessment:

Byron will address the Beyond Design Basis (BDB) Seismic considerations in the implementation of FLEX strategies consistent NEI 12-06, (Ref. 1). Through test borings performed it was concluded that the soils are not susceptible to liquefaction. (Ref. 2 UFSAR)

External Flood Hazard Assessment:

Byron UFSAR, (Ref. 3), addresses additional flooding mechanisms that are either not critical or not bounding for Byron.

Not applicable per NEI 12-06, (Ref. 4), since Byron is considered a Dry site per Byron UFSAR, (Ref 5), the plant grade elevation is at 869.0 feet and the grade floors of the safety related building are at elevation 870.0 feet. The Probable Maximum Flood (PMF) along the Rock River does not affect the site, since the maximum water surface elevation is 708.3 feet, a minimum of 160.7 feet below the plant grade. The probable maximum precipitation (PMP) falling on the plant area was considered in the analysis of local intense precipitation on the plant site. The maximum water level is elevation 870.90 feet at the plant site due to PMP. To prevent water due to PMP from entering areas where essential equipment/systems are located, reinforced concrete curbs or steel barriers are provided.

High Wind Hazard Assessment:

NEI 12-06, (Ref. 6), identifies Byron Station in a region, (890 16' W x 424' N.) in which it would not experience severe winds from Hurricanes. However, NEI 12-06, (Ref, 7), identified Byron in Region 1 and is susceptible to tornado winds of 200 mph.

Site: Byron Determine Applicable Extreme External Hazard Ref: NEI 12-06 section 4.0 -9.0 JLD-ISG-2012-01 section 1.0 Page 1 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Site:

Determine Applicable Extreme External Hazard Ref: NEI 12-06 section 4.0 -9.0 JLD-ISG-2012-01 section 1.0 Seismic Hazard Assessment:

Byron address Basis (BDB) Seismic considerations in the implementation of consistent 12-06, (Ref. 1).

test IJV.LJ..'VAA,U,"' it was concluded the soils are not susceptible 2

UFSAR, (Ref. 3),

flooding mechanisms are either not critical or not bounding Byron.

Not per 12-06, (Ref. 4), since Byron is considered a site per Byron UFSAR, (Ref 5), the plant grade elevation is at 869.0 feet the grade floors safety related are at elevation 870.0 feet.

Probable Maximum Flood (PM F) along Rock River does not affect the site, since the maximum water surface elevation is 708.3 feet, a minimum of 160.7 below the grade.

probable precIpItation falling on the plant area was considered local intense precipitation on the water is 870.90 To prevent water to areas where essential equipment/systems are located, reinforced concrete curbs or steel are provided.

12-06, (Ref. 6), identifies (89.° 16' x

which it would not "'[1>.. ;'V.I..I."'......,,"-'

severe winds NEI 12-06, (Ref.

7),

to Page 1 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Temperature information from Byron's UFSAR, (Ref 8),

The annual average temperature in the Byron area as represented by Rockford data is 48.1°F, with extreme temperatures having ranged from a maximum of 103°F to a minimum of -22°F. Maximum temperatures equal or exceed 90°F about 13 times per year while minimum temperatures are less than or equal to 0°F about 16 times per year.

Byron Station location is 8 9.'16' W x 42°4' N.

Extreme Cold Hazard Assessment:

NEI 12-06, (Ref. 9), identifies Byron Station in an area in which it could receive 25 inches of snow over 3 days.

NEI 12-06, (Ref. 10), identifies Byron Station as Ice Severity Level 5, Catastrophic destruction to power lines and/or existence of extreme amount of ice.

High Temperature Hazard Assessment:

Byron Station will address high temperatures considerations in the implementation of FLEX strategies consistent with NEI 12-06, (Ref. 11).

References:

1. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Section 5.2 dated August 2012.

2.

Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Byron Section 2.5

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

NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Section 6.2.1 dated August 2012.

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

NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Figure 7-1 dated August 2012.

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

Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Byron Section 2.3.1.1 dated December 2012.

Page 2 of 67 to a 12-06, 9), identifies Byron Station in an area in it could receive 25 inches of snow over 3 days.

10), identifies Byron Station as Ice Severity 5, Catastrophic to power and/or """.,,'to*nne.

extreme amount of ice.

i-,......... "'r... ni-.~"."'l" considerations stnlte~nes ""r.,,,,,",~,,,t-,,,,,... ic with 12-06 Rev. 0, Diverse and

.lv/\\.JlUJ.v Coping Strategies Section 5.2 dated August 2012.

2.

Byron/Braidwood Nuclear Stations Updated Final Analysis Report 14, Byron Section 2.5

3. ByronlBraidwood Nuclear Stations Updated Final Safety Analysis (UFSAR) Revision 14, Byron Section 2.4.4 2.4.7 dated December

2.

4.

12-06 Coping Strategies Guide, Section 6.2.1 dated August 2012.

5. Byron/Braidwood Nuclear Stations Safety Analysis Report Section 2.4.2.3 dated L-'v'""vJ..l.IUvJ.

6.

12-06

7.

8. Byron/Braidwood Analysis Report 2.3.1.1 dated LJ'\\.A.A... -I.LILJ\\.-.l Page 20f67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan 9.

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

10. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Figure 8-2 dated August 2012.

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

Key Site assumptions to Provide key assumptions associated with implementation of implement NEI 12-06 FLEX Strategies:

strategies.

Flood and seismic re-evaluations pursuant to the 10 CFR 50.54(f) letter of March 12, 2012 are not Ref: NEI 12-06 section 3.2.1 completed and therefore not assumed in this submittal.

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

The following conditions exist for the baseline case:

o DC battery banks are available.

o AC and DC electrical distribution is available.

o Diesel Driven Auxiliary Feedwater Pump, (DDAFW Pp) is available and will start in auto or manual as needed.

o Local manual control of Steam Generator Power Operated Relief Valves, (S/G PORVs) 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 12-06).

Additional staff resources are expected to arrive beginning at 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Ref: NEI 12-01 (Ref. 2)

Primary and secondary storage locations have not been selected yet. Storage locations will be chosen in order to support the event timeline. Once locations are finalized implementation strategies and routes will be assessed for hazard impact, and will be communicated in a future 6 month update following identification.

This plan defines strategies capable of mitigating a simultaneous loss of all alternating current (ac) power and loss of normal access to the ultimate heat sink resulting from a beyond-design-basis event by providing adequate capability to maintain or restore core cooling, containment, and SFP cooling capabilities Page 3 of 67 Byron StatIon, Unlts 1 and 2 Mitigation Strategies Integrated Plan Key Site assumptions to implement NEI 12.. 06 strategies.

Ref: NEI 12-06 section 3.2.1

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

10. NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Figure 8-2 dated August 2012.

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

Provide key assumptions associated with implementation of FLEX Strategies:

Flood and seismic re-evaluations pursuant to the 10 CFR 50.54(0 letter of March 12, 2012 are not completed and therefore not assumed in this submittal.

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

The following conditions exist for the baseline case:

o DC battery banks are available.

o AC and DC electrical distribution is available.

o Diesel Driven Auxiliary Feedwater Pump, (DDAFW Pp) is available and will start in auto or manual as needed.

o Local manual control of Steam Generator Power Operated Relief Valves, (S/G PORVs) o Plant initial response is the same as Station Black Out, (SBO), WCAP-1760l-P (Ref.l).

o No additional single failures of any SSC are assumed (beyond the initial failures that define the ELAPILUHS scenario in NEI 12-06).

Additional staff resources are expected to arrive beginning at 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Ref: NEI 12-01 (Ref. 2)

Primary and secondary storage locations have not been selected yet. Storage locations will be chosen in order to support the event timeline. Once locations are finalized implementation strategies and routes will be assessed for hazard impact, and will be communicated in a future 6 month update following identification.

This plan defines strategies capable of mitigating a simultaneous loss of all alternating current (ac) power and loss of normal access to the ultimate heat sink resulting from a beyond-design-basis event by providing adequate capability to maintain or restore core cooling, containment, and SFP cooling capabilities Page 3 of 67

yron Station, Units 1 and 2 Mitigation Strategies Integrated Plan at all units on a site. Though specific strategies are being developed, due to the inability to anticipate all possible scenarios, the strategies are also diverse and flexible to encompass a wide range of possible conditions. These pre-planned strategies developed to protect the public health and safety will be incorporated into the unit emergency operating procedures in accordance with established EOP change processes, and their impact to the design basis capabilities of the unit evaluated under 10 CFR 50.59. The plant Technical Specifications contain the limiting conditions for normal unit operations to ensure that design safety features are available to respond to a design basis accident and direct the required actions to be taken when the limiting conditions are not met. The result of the beyond-design-basis event may place the plant in a condition where it cannot comply with certain Technical Specifications, and, as such, may warrant invocation of 10 CFR 50.54(x) and/or 10 CFR 73.55(p).

References:

Ref I - WCAP-17601-P, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, & Babcock &

Wilcox NSSS Designs, dated August 2012.

Ref 2 - NEI 12-01 Rev. 0, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012 Extent to which the guidance, JLD-ISG-2012-01 and NEI 12-06, are being followed. Identify any deviations to JLD-ISG-2012-01 and NEI 12-06.

Ref: JLD-ISG-2012-01 NEI 12-06 13.1 Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint.

Ref: NEI 12-06 section 3.2.1.7 JLD-ISG-2012-01 section 2.1 Include a description of any alternatives to the guidance, and provide a milestone schedule of planned action.

Full conformance with JLD-ISG-2012-01, Rev 0 and NEI 12-06 Rev 0 is expected with no deviations.

Strategies that have a time constraint to be successful should be identified with a technical basis and a justification provided that the time can reasonably be met or example, a walk through of deployment).

Describe in detail in this section the technical basis for the time constraint identified on the sequence of events timeline Attachment IA.

Page 4 of 67 Extent to which the guidance, JLD-ISG.. 2012-01 and NEI 12-06, are being followed. Identify any deviations to JLD-ISG-2012-01 and NEI 12-06.

Ref: JLD~ISG-2012-01 NEI 12-06 13.1 Provide a sequence of events and identify any time constraint required for success including the technical basis for the time constraint.

Ref: NEI 12~06 section 3.2.1.7 JLD-ISG-2012-01 section 2.1 ation Strategies Integrated Plan on a site. Though specific strategies are to the to.. uu............ I-,...........

possible scenarios, the strategies are also diverse and flexible to encompass a wide range of possible conditions.

strategies developed to be Specifications contain the limiting conditions for operations to ensure design safety features are available to respond to a design basis accident and direct the required actions to be taken when the conditions are not met. The result of the beyond-design-basis event may place a

condition where it cannot comply certain

""""~'.1U.""" Specifications, as such, may warrant invocation 10 50.54(x) and/or CFR 73.55(p).

References:

Ref 1 WCAP-17601 System Response to Power Event for Westinghouse, Combustion Babcock &

NSSS Designs, dated August 2012.

Ref 2 -

12-01 0,

for Assessing Beyond Design Basis Accident Response Staffing and Communications Ca abilities, dated 2012 Include a description of any alternatives to the guidance, and provide a milestone schedule of planned action.

Full conformance with

, Rev 0 and 12-06 0 is expected with no deviations.

Strategies that have a tin1e constraint to be successful should be identified with a technical basis and a justification provided that the time can reasonably be met (for example, a walk through of deployn1ent).

Describe in detail in this section the technical basis for the time constraint identified on the sequence of events time line Attachment lAo Page 4 of67

Byron Station, Units 1 and 2 Mitigation Strategies ies Integrated Plan See attached sequence of events timeline (Attachment IA).

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

Byron Station timeline is outlined in Attachment 1 A.

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 time validated once detailed designs are completed and procedures are developed. The results will be provided in a future 6-month update.

+

5 to 15 minutes - Based on the plant response and the direction from the Emergency Operating Procedure 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. The 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 B-MISC-009 (Ref. 1).

The MAAP calculation shows SG dryout will occur within 61 minutes without AF flow as referenced in the WCAP-17601-P (Ref. 2).

+

30 minutes to 3.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - After the Station DGs have been verified to be not available, an operator is dispatched to the Div 2 ESF Switchgear Bus -32X and verifies all breakers are open then will proceed to the FLEX Building and prep and 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time constraint is based on the results of EC Evaluation 391872 (Ref.

3). The EC calculation shows the DC bus 112 voltage will be below acceptable values after 3.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months without operator action.

+

1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months - The control room will begin and 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/C pressure down to at least 300 Asia at a minimum of 75°F/hr, MAAP Analysis (Ref.1)

Page 5 of 67 B ron Station, Units 1 and 2 Mitigation Strate ies Integrated Plan See attached sequence of events timeline (Attachment lAY.

Technical Basis Support information, see attached NSSS Significant Reference Analysis Deviation Table (Attachment lB)

.... "' ** U.L.. ........ ''.. };:;,J.-'-eJ are '-'V.. UI-/Jl... "..... '.....

The results will be provided in a

-'--"-"-" *..1.......,"-' - Based on response Emergency Operating of All AC Power, an B

30 minutes to 3.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months -

Station have been verified to not available, an operator is dispatched to the Div 2 ESF Switchgear Bus

,-,u.n,,-,,, '" are then will proceed Building and prep and align the to the station connections. Once aligned the will be started and a controlled loading occur to restore power to the required 125 DC charger and to 2

busses. The 3.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months based on the of 3).

calculation shows be below acceptable operator.... VL'l.. J...

Page 5 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan

References:

1. MAAP Analysis Document NO. BW-MISC-009 Rev 0, approved 10/20/11 2.

WC -17601-P approved August 2012

3. EC Evaluation 391872, Battery Coping Time For The I

125V DC ESF Battery Banks, dated February 8, 2013 Describe how the strategies will be deployed in all modes.

Deployment of FLEX is expected for all modes of operation. Transportation routes will be developed from the equipment storage area to the FLEX staging areas. An administrative program will be developed to ensure pathways remain clear or compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation. This administrative program will also ensure the strategies can be implemented in all modes by maintaining the portable FLEX equipment available to be deployed during all modes.

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

Provide a milestone schedule. This schedule should include:

Modifications timeline o Phase 1 Modifications o

Phase 2 Modifications o

Phase 3 Modifications Procedure guidance development complete o Strategies o

Maintenance Storage plan (reasonable protection)

Staffing analysis completion FLEX equipment acquisition timeline Training completion for the strategies Identify how strategies will be deployed in all modes.

Ref: NEI 12-06 section 13.1.6 The dates specifically required by the order are obligated or committed dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

See attached milestone schedule (Attachment 2)

Exelon Generation Company, LLC (Exelon) fully expects to meet the site implementationlcompliance dates provided in Order EA-12-019, with no exceptions. Any changes or additions to the planned interim milestone dates will be provided in a future 6-month update Page 6 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Identify how strategies will be deployed in all modes.

Ref: NEI 12-06 section 13.1.6 Provide a milestone schedule. This schedule should include:

Modifications timeline o Phase 1 Modifications o Phase2 Modifications o Phase 3 Modifications Procedure guidance development complete o Strategies o Maintenance Storage plan (reasonable protection)

Staffing analysis completion FLEX equipment acquisition timeline Training completion for the strate ies MAAP Analysis Document NO. BW -MISe-009 Rev 0, n.......... *...... " ""'..... 1 0/20/11 WCAP-17601-P................ ".. ".. ri Describe how the strategies will be deployed in all modes.

Deployment of is expected for all modes of operation. Transportation routes will be developed from equipment storage area to staging areas. An program will be developed to ensure pathways remain or compensatory actions will be

./../.ullJ.l......lu...,'..........,...... to ensure strategies can be during all modes of operation. This administrative program also ensure strategies can modes maintaining the FLEX available to be deployed........... JHJ.F-,

storage program are open items. Closure of documented a future 6-month update.

The dates specifically required by the order are obligated or comm.itted dates. Other dates are planned dates subject to change. Updates will be provided in the periodic (six month) status reports.

See attached milestone schedule (Attachment Exelon Generation expects to meet site implementation/compliance dates provided Order EA-12-049, no exceptions. Any changes or additions to planned milestone dates be provided 6-month update Page 6 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Regional Response Centers operational Ref: NEI 12-06 section 13.1 Identify how the Provide a description of the programmatic controls programmatic controls will equipment protection, storage and deployment and be met.

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

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

Byron Station will implement an administrative program for FLEX to establish responsibilities, and testing and maintenance requirements. A plant system designation will be assigned to FLEX which will require 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 FLEX components included in the system. (This will be an open item) 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-Olsection 6 and NEI 12-06 section 11.

Installed structures, systems and components pursuant to 10CFR5O.63(a) will continue to meet the augmented quality guidelines of Regulatory Guide 1.155, Station Blackout.

Standard industry preventive maintenance (PM) 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.

Byron's administrative program for FLEX responsibilities, and testing & maintenance are open items. Closure of these items will be documented in a future 6-month update.

Describe training plan List training plans for affected organizations or describe the plan 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 developed and communicated. Closure of this item will be communicated in a future 6-month update.

Page 7 of 67 Byron Station, Units 1 and 2 Mitigation StrategIes Integrated Plan Regional Response Centers operational Ref: NEI 12-06 section 13.1 Identify how the programmatic controls will be met.

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

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

Byron Station will implement an administrative program for FLEX to establish responsibilities, and testing and maintenance requirements. A plant system designation will be assigned to FLEX which will require 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 FLEX components included in the system. (This will be an open item) Equipment associated with these strategies will be procured as commercial equipment with design, storage, maintenance, testing, and configuration control as outlined in JLD-ISG-2012-01section 6 and NEI 12-06 section 11.

Installed structures, systems and components pursuant to 10CFRSO.63(a) will continue to meet the augmented quality guidelines of Regulatory Guide 1.155, Station Blackout.

Standard industry preventive maintenance (PM) 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.

Byron's administrative program for FLEX responsibilities, and testing & maintenance are open items. Closure of these items will be documented in a future 6-month update.

List training plans for affected organizations or describe the plan 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 developed and communicated. Closure of this item will be communicated in a future 6-month update.

Page 7 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Byron Station has contractual agreements in place with 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 Strategic Alliance For Flex Emergency Response (SAFER) team and the utility. Communications will be established between the affected nuclear site and the SAFER team and required equipment moved to the site as needed. First arriving equipment, as established during development of the nuclear site's playbook will be delivered to the site within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the initial request Ref. NEI 12-06 (Ref. 1). Reference Nuclear RRC Contract RFP-20480 (Ref.2).

Development of Byron Station's playbook is an open item.

Closure of this item will be documented in a future 6-month update.

References:

Ref 1 - NEI 12-06 Rev. 0 Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Section 12 Ref 2 -Nuclear contract with SAFER for the RRC, dated June 8, 2012.

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 Byron 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.

Describe Regional Response Center plan Page 8 of 67 B ron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Describe Regional Response Station has contractual.... jiio,"........... A'.....,U""'u Center plan Strategic for FLEX Emergency Response (SAFER).

an to a

Area, established by Strategic Alliance For Flex Emergency Response (SAFER) team and utility. Communications will established between the affected nuclear site SAFER team and required equipment moved to the as arnvlng as established during development of the nuclear site's playbook will be delivered to site 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the request Ref. NEI 12-06 (Ref. 1).

Contract 20480 playbook is an open documented a future 6-month 12-06 Rev. 0 Diverse and Flexible Coping Strategies implementation Guide, Section 2 -Nuclear contract with SAFER for the RRC, dated June 8, 2012.

Notes:

Generation Company, (Exelon) has not finalized the engineering designs for compliance with Order EA-12-049. Detailed designs based on the current conceptual designs be developed to final plan and associated mitigating strategies. Once these have been developed, Exelon will update the integrated for during a scheduled 6-month update. This update win include any changes to initial designs as submitted February 28, 2013 Integrated Page 8 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal Determine Baseline coping capability with installed coping' modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

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

At the initiation of the event operators will enter Station Blackout (SBO) - Emergency Operating Procedure (EOP),_BCA 0.0 Loss of All AC. The Extended Loss of AC Power (FLAP),

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 will cool down the plant at approximately 75°F/hr to 420°F (Tcold).

Steam generator (SG) pressure will be approximately 300 psia at this 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 Analysis(Ref 1), WCAP-17601 -P (Ref. 2).

During cool down, the Diesel Driven Auxiliary Feedwater (DDAFW) pump will deliver water from 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 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.

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 ediately 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 1 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Page 9 of 67 B ron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal Determine Baseline coping capability with installed coping modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

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

.L,"Jo," lCU'" ".HJU. of the event operators will enter Station Blackout (SBO) - Emergency Operating 0.0 of All AC.

Loss of AC Power (ELAP),

the emergency diesel generators are confirmed unavailable restored and it is confirmed by dispatcher or visual verification of

"',.....,"'1"1".. 0 at 90 minutes Operators will cool down the plant at approximately 75°F/hr to 420°F (Tcold).

Steam generator (SG) pressure be approximately 300 psia at this Steam pressure of 300 psia corresponds to RCS pressure necessary to inject accumulators.

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

Auxiliary Feedwater pump will deliver water via Essential Service Water (SX) system to the SGs.

A"-'.L~V.U.'';~, many variables exist which impact the ability to cool the core.

event of an during these Modes, installed plant systems cannot be relied upon to cool the core, thus transition to Phase 2 will begin immediately. All efforts be made to provide core cooling and and repressurization.

has a

'.J.....L~AA in place

3) to determine time to boil for all conditions during shutdown periods.

will be to determine time required to complete transition to 2.

... ""JU""j",. water the reactor most limiting condition is the case in vessel is at or below reactor vessel.... "..... uJii-.'....

resources.

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

Page 9 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated 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,

References:

Ref 1 - MAAP analysis BB-MISC-020 Rev. 0, Approved 2/01/13 Ref 2 - 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 August 2012, Section 4 & 5 Ref 3 - OP-AA-108-117-1001 Rev 0, Spent Fuel Storage Pools Heat-up Rate With Loss of Normal Cooling, dated July 22, 2011 Details:

Byron 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 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

The following gaps have been identified that prevent extended operation of the DDAFW Pump. Byron Station will utilize modifications to close these gaps prior to FLEX implementation.

These will be an Open item that will be closed and documented 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Reactor Parameters Essential Instrentation SG Pressure:

PI-515, PI-516, PI-525, P1-535, PI-545 and PI-546 SG Level:

NR - LI-517, LI-519, LI-527, LI-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS Temperature:

Cold Leg - T1-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control RCS Heat Removal RCS pressure boundary and Safety Function RCS pressure boundary and pressure control Page 10 of 67 Byron Station, Units 1 and 2 Miti ation Strategies Integrated Plan a FLEX to take suction and lor as described Core Cooling section. Guidance to ensure area is for deployment and that haul paths remain accessible without interference outage equipment during refueling outages.

August 2012, Section 4 & 5 Ref 3 - OP-AA-I08-117-1001 Rev 0, Spent Fuel Storage Pools Heat-up Rate With Loss of Normal Cooling, dated July 22, 2011 Provide a brief description of Procedures I Strategies I Guidelines Identify modifications Key Reactor Parameters Details:

Byron Station Owners Groups, industry developed guidance the teatn to develop site specific procedures or guidelines to address criteria 12-06.

'-'....... ~y......l.v.., andlor guidelines will "-UJIJ'W'.L based strategies current The following gaps have been identified that nr"","""1t operation of the Byron Station modifications to close these gaps prior to FLEX implementation.

These will be an Open that will be closed and documented a

future 6-month update.

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

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

3.

overheating due to cooling water recirculation system cycling and overheating the Essential SG Pressure:

PI-5I5, PI-5I6, PI-525, Page 10 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan pressure control Containment Pressure: PI-Containment Integrity PC005 SFP Level: (component #

SFP Inventory TBD)

Byron'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: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AFO18A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NR006A/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-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 Byron 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 11 of 67 Notes:

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan pressure control Containment Integrity strategy may...... V'.... ".LL to key actions...........,..u........ '""~

......... r.£'orin.... ""clo*H1r11<:l-nr'o or to InOlcate ~rnrnn"lo*nt core damage 12-06 Rev. 0 Section 3.2.1.10) any difference will be communicated within a future 6-month update following.luv.l..ll..ljLlv(.~l..lVU **

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

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

Page 11 of67 8A

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain core cooling.

Identify methods and strategy(ies) utilized to achieve this coping time.

Phase 2 Core cooling will be achieved with a portable FLEX diesel pump and S/G PORVs. The pump suction will come from the RWST and/or the UHS fed from the well water pumps powered from a portable Flex DG. The discharge will be into the AFW lines downstream of the containment isolation valves into the S/Gs. The PORVs will be used to control the S/G pressure.

In the event the unit is in a refueling outage, another portable FLEX diesel pump will also be able to supply the RCS boil off using the modifications outlined in Phase 2 of Inventory Control.

Electrical power required to support the Flex Strategy is described in the Safety Function Support Section of the document.

Details:

Byron 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 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

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

FLEX pump discharge: Install Pipe flange connections on the A, D, B and C Auxiliary feed water (AF) SG injection lines at the test flanges within the Main Steam Isolation Valve (MSIV) rooms. Connect the pipe flanges with a header routed through the steam tunnel. One end of the header will be routed to the B/C Main Steam Safety Valve (MSSV) room and terminated with a standard FLEX connection (Primary connection) and the other end will be routed to the A/D MSSV 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.

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Page 12 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain core cooling. Ident~fy methods and strategy(ies) utilized to achieve this coping time.

2 a nn,rTalr-.iQ pump suction will corne from R WST andlor the UHS fed from the well water pumps powered from a portable Flex DG. The discharge will be into the AFW lines downstream of the containment isolation valves into the S/Os.

be used to control S/O pressure.

is a refueling outage, another portable FLEX diesel also be able to off using the modifications Phase 2 of

..... r"'.. TA........ c.rn... 1"*c.t'"t to <:'111"\\..... nrT 1S Safety Section of the document.

Provide a brief description of Procedures I Strategies I Guidelines Identify modifications Details:

Byron Station will use developed guidance the Owners Groups, and team to develop site "'1J"-'vALA....

procedures or guidelines to criteria in 12-06. These procedures andlor guidelines will support the existing sylnptom based command control strategies the current following modifications will installed to support pump water injection into the SOs.

FLEX discharge: Install Pipe flange connections on the A, B

and C Auxiliary feed water (AF) SO injection lines at the test flanges the Steam Isolation Valve (MSIV) rooms. Connect the flanges with a header routed the steam tunnel. One end of the header will be routed to the BIC Main Stearn Safety room and terminated with a standard FLEX connection the other end will be routed to the AID a standard Page 12 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Key Reactor Parameters Essential Instrumentation SG Pressure:

PI-515, PI-516, PI-525, PI-535, 1 PI-545 and PI-546 SG Level:

NR - LI-517, LI-519, LI-527, LI-537. LI-547 and LI-549 WR - LI-502 and LI-503

( RCS Temperature:

Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 Containment Pressure: PI-PCO05 SFP Level: (component #

TBD)

Byron'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 (.. 112-06 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: L1-951, LI-953, LI-955, 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-NRO06A/B, NI-36B

Reference:

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

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

Safety Function RCS pressure boundary and pressure control RCS pressure boundary and pressure control RCS Heat Removal RCS pressure boundary and pressure control Containment Integrity SFP Inventory Page 13 of 67 Byron Station, Units 1 and 2 Mitigation Strate ies Integrated Plan Key Reactor Parameters Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 SG Level:

NR - LI-S17, 19, LI-S27, LI-S37, LI-S47 LI-S49 WR - LI-S02 and LI-S03 Res Temperature:

Cold Leg - TI-413B, TI-423B, RCS pressure boundary and pressure control RCS Heat Removal RCS pressure boundary and Byron's evaluation of strategy identify..,."""",,,..... 'U,.... w,A parameters are needed in order to support key actions identified in the procedures/guidance or to indicate or actual core damage 12-06 Rev. 0 Section 1.10) and will be communicated a

update identification.

addition to the parameters listed 3.2.1.10, the following additional parameters use as detailed strategy is developed.

a Page 13 of67

Seismic Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Storage / Protection of Equipment :

Describe storage / protection plan or schedule to determine storage requirements 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, 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 Byron Station.

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