RS-13-018, 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)

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)

Text

1 Exelon Gcncration Order No. EA-12-049 RS-13-018 February 28, 2013 u.s. Nuclear Regulatory Commission ATIN : 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 Commission Integrated Plan Report Report to EA-12-049 EA-12-049 28, 2013 February 28,2013 Page 2 Reference 11 requires requires submission submission of of an an Overall Overall Integrated Plan Plan by by February February 28, 2013. The TheNRC NRC Interim Staff Interim StaffGuidance Guidance (ISG) (ISG)(Reference (Reference 2) 2) was was issued August 29, 2012 which endorses 29,2012 endorses industry guidance documentdocumentNEI NEI 12-06, 12-06, Revision Revision 00(Reference (Reference3)3)withwithclarifications clarificationsand and exceptions identified identified in in Reference Reference 2. Reference Reference33provides providesdirection directionregarding regardingthethecontent contentofof this Overall Integrated Integrated Plan.Plan.

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

The purpose purpose of of this this letter letter is is to to provide provide the the Overall Overall Integrated Integrated Plan Planpursuant pursuanttotoSection SectionIV,IV, Condition C.1 Condition C.1,, of ofReference Reference 1. 1. This letter confirms confirms EGCEGC has has received Reference 22 and and has hasanan Overall Integrated Plan developed Overall developed in in accordance accordancewith withthe theguidance guidancefor fordefining definingand anddeploying deploying strategies that strategies thatwill will enhance enhancethe theability abilitytotocope copewithwithconditions conditionsresulting resultingfrom from beyond-design-beyond-design-basis external external events.

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

information. Final design details Final design details and and associated associated procedure procedure guidance, guidance, as as well as any revisions to the information contained in the Enclosure, will well as any revisions to the information contained in the Enclosure, will be provided in the be provided in the 6-month Integrated Plan updates 6-month updatesrequired requiredby byReference Reference1.1.

This letter contains no new regulatory commitments. IfIf you have have any any questions questionsregarding regardingthisthis report, please report, 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 foregoing is is true and and correct.

correct. Executed Executedononthethe 28th 28th day of February 2013.

Respectfully submitted,

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

Enclosure:

Byron Station,

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

Mitigation Strategies (MS) Overall Overall Integrated IntegratedPlanPlan cc: Director, Office Director, Office of of Nuclear Nuclear Reactor Reactor Regulation Regulation NRC Regional Administrator Administrator -- Region RegionIII III NRC Senior NRC Senior Resident InspectorInspector -- Byron Byron Station, Units Units 1 and and 22 NRC Project Manager, NRR NRC NRR -- Byron Byron Station, UnitsUnits 1 and and 22 Mr. Robert Mr. Robert J. Fretz, Fretz, Jr, Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr. Robert L. Dennig, NRRIDSS/SCVB, Mr. NRRIDSS/SCVB, NRC NRC IllinoisEmergency Illinois Emergency Management Management Agency Agency -- Division Division of Nuclear Nuclear Safety Safety

Enclosure Enclosure 11 Byron Byron Station, Units 1 and 22 Mitigation Mitigation Strategies (MS)

Strategies (MS)

Overall Integrated Plan Plan (67 pages)

(67

Byron Station, Byron Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan General Integrated Plan General Integrated Plan Elements ElementsPWR PWR Site: Byron Determine Applicable Seismic events, Determine except Applicable soil liquefaction; flooding from local Extreme External Extreme External Hazard Hazard intense precipitation; severe storms with high winds; snow, and extreme cold; and high temperatures were Ref: NEI Ref: NEI 12-06 4.0 -9.0 12-06 section 4.0 -9.0 determined to be applicable Extreme External Hazards for JLD-ISG-2012-JLD-ISG-2012-0101 section 1.0 Byron Station per the guidance of NEI 12-06 and are as follows:

Seismic Hazard Hazard Assessment:

Assessment:

Byron will address the Beyond Design Basis Byron Basis (BDB)

(BDB)Seismic Seismic considerations in the implementation implementation of ofFLEX strategies consistent NEI 12-06, (Ref. (Ref. 1).

1). Through test testborings performed it was concluded IJV.LJ..'VAA,U,"' concluded that the the soils soils are are not notsusceptible susceptible to liquefaction. (Ref. 2 UFSAR)

External Flood Hazard Assessment:

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

Not applicable per NEI 12-06, 12-06, (Ref.

(Ref. 4),

4), since sinceByron Byronisis considered a Dry site per Byron UFSAR, (Ref (Ref 5), the plant plant grade elevation is at at 869.0 869.0 feet feet and the the grade grade floors floorsof the safety related building are at at elevation elevation 870.0 870.0 feet.

feet. The Probable Maximum Flood (PMF) (PM F) along the Rock River does not affect the site, since since the the maximum maximum water watersurface surface elevation is 708.3 feet, aa minimum minimum of of160.7 160.7feet below belowthe the plant grade. The probable maximum precipitation precIpItation(PMP) falling on the plant area was considered in the analysis of local intense precipitation on on the the plant site. The maximum water level is elevation 870.90 870.90 feet at the plant site due to PMP. To prevent prevent water water due to to PMP from entering areas areas where essential equipment/systems equipment/systems are are located, located, reinforced reinforced concrete curbs or steel steel barriers are are provided.

provided.

High Wind Hazard Assessment:

NEI 12-06, (Ref. 6), identifies identifies Byron Station in a region, (890 (89.° 16'16' W x 424' N.) in which it would not not experience

"'[1> ..;'V.I..I."' ......,,"-'

severe winds from Hurricanes. However, NEI NEI 12-06, 12-06,(Ref, (Ref.

7), identified Byron in Region 1 and is susceptible to to tornado winds of 200 mph.

Page 11 of 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 totoaa 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, 12-06, (Ref. 9), 9), identifies identifies Byron Byron Station Station in in an an area area in in which itit could receive receive 25 25 inches inches of ofsnow snowover over33days. days.

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

""".,,'to*nne. extreme amountamountof ofice.ice.

High Temperature Hazard Assessment:

Byron Station will address high temperatures i-,... ...... "'r. .. considerations ni-.~"."'l" considerations in the implementation of FLEX strategies stnlte~nes consistent with

""r.,,,,,",~,,,t-,,,,,... with ic NEI 12-06, (Ref. 11).

References:

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

.lv/\.JlUJ.v Coping Strategies (FLEX) implementation Guide, Section Section5.2 5.2 dated August 2012.

2. Byron/Braidwood Nuclear Stations Updated

2. Updated Final Final Safety Analysis Report (UFSAR) Revision 14, 14, Byron Byron Section 2.5 2.5

3. ByronlBraidwood

3. Byron/Braidwood Nuclear Stations Updated Updated Final Final Safety Analysis Report (UFSAR) Revision 14, 14, Byron Section 2.4.4 through 2.4.7 2.4.7 dated dated December December2012.2.

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

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

L-'v'""vJ..l.IUvJ.

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

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

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

LJ'\.A.A...-I.LILJ\.-.l Page 220f67 of 67

Byron Byron Station, StatIon, Units Unlts 11andand22Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan 9.9. NEI NEI 12-0612-06 Rev.

Rev. 0, 0, Diverse Diverse and and Flexible Flexible Coping Coping Strategies Strategies (FLEX)

(FLEX) implementation implementationGuide, Guide,Figure Figure8-1 8-1 dated dated August August 2012.

2012.

10. NEI

10. NEI 12-0612-06 Rev. 0,0, Diverse Diverse and and Flexible Flexible Coping Coping Strategies (FLEX)

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

2012.

11. NEI 12-06

11. 12-06 Rev.

Rev. 0, 0, Diverse Diverse and and Flexible Flexible Coping Coping Strategies (FLEX)

(FLEX) implementation implementationGuide, Guide,Section Section9.2 9.2 dated August August 2012.

2012 .

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

strategies.

strategies.

• Flood and seismic re-evaluationsre-evaluations pursuant pursuant to to the the 10 10 CFR 50.54(f) 50.54(0 letter of of March 12, 12, 2012 2012 areare not not Ref: NEI NEI 12 12-06 section 3.2.1

-06 section 3.2.1 completed and and therefore therefore not notassumed assumedininthis thissubmittal.

submittal.

As the re-evaluations are are completed, completed, appropriate appropriateissuesissues will be tracked and and addressed addressed on on aaschedule schedule commensurate commensurate with with other other licensing licensingbases baseschanges.

changes.

• The following conditions conditions exist existfor forthethebaseline baselinecase:case:

o DC battery banks banks are are available.

available.

o AC and DC electrical electrical distribution distribution isis available.

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

needed.

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

PORVs) o Plant initial initial response response is the the same same as as Station Station Black Out, (SBO), WCAP-17601-P WCAP-1760l-P (Ref.1). (Ref.l).

o No additional single failures of o of any SSC are are assumed (beyond the initial failures that initial failures that define the ELAP/LUHS ELAPILUHS scenario scenario in in NEI NEI12 06).

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

(Ref. 2) 2)

• • Primary and secondary storage locations locations have have notnotbeen been selected yet.yet. Storage locations will will bebe chosen chosen in in order order to support the event timeline. Once to Once locations locations are are finalized implementation strategies strategies andand routes routes will will be be assessed for hazard impact, and will be assessed be communicated communicated in a future future 6 month update following identification.

identification.

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

yron Station, Units 1 and 2 Mitigation ation Strategies Strategies Integrated Integrated Plan Plan at all units on a site. Though Thoughspecific specific strategies strategies are are being developed, due to to the the inability to to anticipate

..u u............ I-, ........... all possible scenarios, scenarios, the the strategies strategies areare also also diverse diverse and and flexible to encompass aa wide wide range range of of possible possible conditions. These pre-planned strategies strategies developed developed to to protect the public health and safety will be 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 conditions for for normal unit operations operations to to ensure ensurethat design designsafety safety features are available available to to respond respondto toaadesign designbasis basis accident and direct direct the the required required actions actionstotobe betaken taken when the limiting conditions are not met. met. The The result result of of the beyond-design-basis event event may place place the plant in aa condition where it cannot comply with certain certain Technical

""""~'.1U.""" Specifications, and, as as such, such, may may warrant warrant invocation of 10 10 CFR 50.54(x) 50.54(x) and/or and/or10 CFR CFR73.55(p). 73.55(p).

References:

Ref I1- WCAP-17601-P, WCAP-17601 Reactor Coolant System System Response to the Extended Loss of AC Power Power EventEvent for for Westinghouse, Combustion Engineering, & Babcock Babcock & &

Wilcox NSSS Designs, dated August 2012. 2012.

Ref 2 - NEI 12-01 Rev. 0, Guideline for Assessing Assessing Beyond Beyond Design Basis Accident Accident Response Response Staffing Staffingand and Communications Capabilities, Ca abilities, dated May 2012 2012 Extent to which the Include a description description of ofany any alternatives alternatives to to the the guidance, guidance, guidance, JLD-ISG-2012-01 guidance, JLD-ISG ..2012-01 and provide a milestone milestone schedule of planned action.

of planned and NEI and NEI 12-06, 12-06, are are being followed. Identify any followed. any Full conformance conformance with JLD-ISG-2012-01,, Rev Rev 0 and and NEI deviations to JLD-ISG-2012- 12-06 Rev 0 is expected with no deviations no deviations.

deviations.

and NEI 01 and NEI 12-06.

Ref: JLD-ISG-2012-01 JLD~ISG-2012-01 NEI 12-06 12-06 13.1 Provide Provide aa sequence sequence of of events events Strategies that have a time tin1e constraint constraint to to be be successful successful and and identify any time identify any time should be identified with with a technical basis and and aa constraint required for constraint required for justification provided that the the time can reasonably be be met success including success including the the (for or example, example, a a walk walk through through of of deployn1ent).

deployment).

technical technical basis for the basis for the time time constraint.

constraint. Describe in in detail detail inin this this section section the the technical basis for the time constraint identified on the sequence of time of events timeline time line Ref: NEI 12-06 section 3.2.1.7 12~06 section 3.2.1.7 Attachment IA. lAo JLD-ISG-2012-01 section section 2.1 2.1 Page 4 of67 of 67

B ron Station, Units Byron Units 11 and and 22 Mitigation Mitigation Strategies Strate ies Integrated Integrated Plan Plan See attached attached sequence sequenceof events timeline (Attachment IA).

ofevents lAY.

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

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

.... "' **U.L .. ........ '' .. };:;,J.-'-eJ arecompleted and

'-'V .. UI-/Jl ..." .....' .....

procedures are developed. The The results results will will be be provided provided in in aa future 6-month update.

+ 5 to 15 minutes - Based

-'--"-"-" *. .1 ......., " ' ' - ' - Basedon onthe plant response responseand the direction from the Emergency Emergency Operating Operating Procedure BCA 0.0, Loss of ofAll All AC AC Power,Power,an an operator is dispatched to the B 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - After the Station Station DGs have been verified to to be not not available, available, an an operatoroperatorisis dispatched dispatched to to the the Div Div 22 ESF ESF Switchgear Switchgear Bus -32X and verifies all breakers ,-,u.n,,-,,, '" are are open then then will will proceed proceed to the FLEX Building and and prep prep and and alignalign the the FLEX DG toto the the station station connections. connections. Once Once aligned aligned the the FLEX DG will be started and a controlled loading loading will occur to restore power power to to the the required required Div 125 125 volt DC Battery charger and to the Div 2 125 Volt instrument busses. The The 3.6 3.6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> hour time constraint is based on the results of of EC Evaluation 391872 (Ref.

3). The EC calculation shows the DC bus 112 voltage will be below acceptable acceptable values 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. .... VL'l ..J . . .

+ 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 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 Page 55 of67 of 67

Byron Station, Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan

References:

1. MAAP Analysis Document Document NO. NO. BW-MISC-009 BW -MISe-009 Rev Rev 0, 0,

approved 10/20/11 n .......... *......" ""' ..... 1 0/20/11

2. WC WCAP-17601-P -17601-P approved ................" .. ".. riAugust 2012

3. EC Evaluation 391872, Battery Coping Time For The I 125V DC ESF Battery Banks, dated February 8, 2013 Identify Identify how how strategies strategies willwill Describe how how the strategies will be deployed in all modes. modes.

be deployed in in all all modes.

modes.

Deployment of of FLEX is expected expected for for all all modes modes of of Ref: NEINEI 12-06 12-06 section section13.1.6 13.1.6 operation. Transportation Transportationroutes routeswill willbe bedeveloped developedfromfromthe equipment storage area to the FLEX staging areas. areas. An An administrative program program will will be bedeveloped developedtotoensure ensure pathways remain clear or or compensatory compensatory actions actions will will be be implemented to

./../.ullJ.l ..... .lu...,' .........., ...... to ensureensure all strategies strategiescan canbebedeployed during during all modes of operation. This This administrative administrative program program will also ensure the strategies strategies can can be implemented in all modes modes by maintaining the portable FLEX equipment available available toto be deployed during ........... JHJ.F-, all modes.

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

Provide Provide aa milestone milestone The dates The dates specifically specifically required required by by the the order order are obligated or schedule.

schedule. This This schedule schedule committed comm.itted dates. dates. Other dates are planned planned dates dates subject subject to should include:

should include: change. Updates will be provided in the the periodic periodic (six (six

• • Modifications timeline Modifications timeline month) status reports.

oo Phase Phase 11 Modifications Modifications oo Phase2 Phase 2 See attached milestone schedule (Attachment See (Attachment 2)

Modifications Modifications oo Phase Phase 33 Exelon Exelon Generation Generation Company, LLC (Exelon) fully expects expects to to Modifications Modifications meet meet the site site implementationlcompliance implementation/compliance dates dates provided provided in

• • Procedure guidance Procedure guidance Order EA-12-049, EA-12-019, with no no exceptions.

exceptions. Any Any changes changes oror development development complete additions to additions to the planned planned interim milestone milestone dates be dates will be oo Strategies Strategies provided provided in a future 6-month 6-month update update oo Maintenance Maintenance Storage plan

• • Storage (reasonable plan (reasonable protection) protection)

• • Staffing analysis Staffing analysis completion completion

• • FLEX FLEX equipment equipment acquisition timeline acquisition timeline

• • Training completion for Training completion for the the strate ies strategies Page 6 of67 of 67

Byron Station, Units 1 and 2 Mitigation Strategies StrategIes Integrated Integrated PlanPlan

• • Regional Regional Response

Response

Centers Centers operational operational Ref:

Ref: NEI 12-06 section NEI 12-06 13.1 section 13.1 Identify how the how the Provide a description of of the programmatic controls programmatic controls will programmatic controls protection, storage and equipment protection, and deployment deployment and and be met.

be met. equipment quality.

equipment quality. See section 11 See section 11 in in NEI NEI 12-06.

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

section.

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

Byron Station will implement an administrative program program forfor FLEX to establish responsibilities, responsibilities, and andtesting testingand and requirements. A maintenance requirements. A plant plant system system designation designation will will be assigned to FLEX which will require configuration configuration controls associated with systems. systems. This This will will establish establish responsibilities, maintenance maintenance and and testing testingrequirements requirementsfor for components associated all components associated withwith FLEX.

FLEX. Unique Unique identification numbers will will be be assigned assigned to to all all FLEX FLEX components included in the system. (This will be an an open open item) Equipment Equipment associated associated withwith these these strategies strategies will will be be procured as commercial equipment equipmentwith withdesign, design,storage, storage, maintenance, testing, and and configuration configuration control controlas asoutlined outlined JLD-ISG-2012-Olsection 66 and in JLD-ISG-2012-01section and NEI NEI 12-06 12-06section section11. 11.

Installed structures, systems and and components componentspursuant pursuanttoto 10CFR5O.63(a)will 10CFRSO.63(a) willcontinue continue to to meet the augmented augmented qualityquality guidelines of Regulatory Guide Guide 1.155, 1.155, Station StationBlackout.

Blackout.

Standard industry preventive preventive maintenance maintenance (PM) (PM) will willbebe developed to establish maintenance maintenance and and testing testingfrequencies frequencies based on type of equipment and will be within EPRI EPRI guidelines. Testing procedures will be developed based based onon the industry PM Templates and Exelon Templates and Exelon Standards.Standards.

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

Describe training plan Describe training List training plans plans for affected affected organizations organizations or ordescribe describe thethe plan for training training development development Training materials for FLEX FLEX willwill bebe developed developedfor forall all involved in station staff involved in implementing implementing FLEX FLEX strategies.

strategies. ForFor accredited training programs, programs, the the Systematic Systematic Approach Approachtoto Training, SAT, will be used to determine training needs. For Forother otherstation stationstaff, staff,aatraining trainingoverview overviewwill willbebe developed and communicated. Closure of of this itemitem will will bebe communicated in aa future future 6-month 6-month update.

update.

Page 7 ofof67 67

Byron B Units 11 and ron Station, Units and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Describe Regional Response Byron Station has contractual agreements

.... jiio," ........... A'... ..,U""'u in place with the Center plan Strategic Alliance forfor FLEX FLEX Emergency EmergencyResponse 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 to aa local Assembly Area, Area, established by the Strategic Alliance For Flex Emergency Emergency Response (SAFER) team and the utility. utility. Communications Communications will be established established between between thethe affected affectednuclear nuclearsite siteand the SAFER team and required required equipment equipmentmoved movedtotothe thesite asas needed. First arriving arnvlng equipment, as as established established during during development of of the nuclear site's site's playbook will bedelivered 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 request Ref.

Ref. NEI NEI (Ref. 1).

12-06 (Ref. 1). Reference Nuclear RRC Contract ContractRFP-20480 (Ref.2).

Development of Byron Station's playbook playbookisisan anopen openitem.

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

References:

Ref 1 - NEI 12-06 Rev. 0 Diverse and and Flexible Coping Coping Strategies (FLEX) implementation implementation Guide, Guide, Section Section12 Ref 2 -Nuclear

-Nuclear contract contractwith withSAFER SAFERfor forthe theRRC, RRC,dated dated June 8, 2012.

Notes: Exelon Generation Generation Company, Company, LLC (Exelon)

(Exelon)hashasnotnotfinalized finalizedthe theengineering engineeringdesigns designs for compliance with NRC Order EA-12-049, EA-12-049. Detailed Detaileddesigns designsbased basedon onthe thecurrent current conceptual designs will be developed to determine the final final plan plan and and associated associated mitigatingmitigating strategies. Once these have been fully developed, ExelonExelon will will update update the the integrated integrated plan for for Byron during a scheduled 6-month update. This Thisupdate updatewillwininclude includeany anychanges changestotothe initial designs as submitted submitted in the February February28,28,2013 2013Integrated IntegratedPlan.

Page 8 of 67 of67

Byron B ron Station, Units 11 and 2 Mitigation Strategies Strategies IntegratedIntegrated Plan Plan Maintain Core Core Cooling Cooling & & Heat Removal Determine Baseline coping capability with installed coping' coping modifications modifications not not including including FLEX modifications, FLEX modifications, utilizing methods described in Table 33-2 -2 ofof NEI NEI 12-06:

12-06:

• • AFWIEFWAFW/EFW

• Depressurize SG for Makeup with Portable Injection Source

• Sustained Source of of WaterWater I Ret:

Ref; JLD-ISG-2012-01 JLD-ISG-2012- 01 section section 2 2 and and 33 PWR Installed PWR Installed Equipment Equipment Phase Phase 11 Provide aa general generaldescription, description of of the coping strategies using installed installedequipment equipment including including station station modifications that are proposed proposed to to maintain maintain core cooling. Identify Identify methods methods(AFW/EFW)and (AFWIEFW)and strategy(ies) utilized to to achieve achievethis this coping copingtime. time.

At the initiation of the

.L,"Jo," lCU'" ".HJU. the event operators operators will will enter Station Station Blackout Blackout (SBO) (SBO) -- Emergency EmergencyOperatingOperating Procedure (EOP),_BCA 0.0 0.0 Loss of All All AC. AC. The Extended Loss Loss of ofAC ACPowerPower(FLAP), (ELAP),

Attachment B, will be entered when the theemergency emergencydiesel dieselgenerators generatorsare areconfirmed confirmedunavailable unavailable and off-site power cannot be restored restored and and itit isis confirmed confirmed by by dispatcher dispatcher or orvisual visual verification verification of of physical damage to infrastructure "',..... ,"'1"1" .. at 0 atsite.

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

(Tcold).

Steam generator (SG) (SG) pressure pressure will be be approximately approximately300 300psia psiaatatthis thistemperature. Steam Steam generator pressure pressure of of 300 300 psia psia corresponds correspondsto toRCSRCSpressure pressurenecessary necessarytotoinject injectSI accumulators.

accumulators.

This will ensure RCS pressure is above above the the minimum minimum pressurepressure to to preclude preclude injection injection of of accumulator nitrogen accumulator nitrogen intointothe RCS. RCS.MAAP MAAPAnalysis(Ref Analysis(Ref1),1),WCAP- WCAP-17601 17601 -P (Ref. 2). 2).

During cool down, the Diesel Driven Auxiliary Feedwater Feedwater (DDAFW) pump pump will will deliver deliver water water from the Ultimate Heat Sink (UHS) via viaEssential EssentialService ServiceWater Water(SX) (SX)system systemtotothe theSGs.

SGs.

Cold Shutdown and Refueling:

When in Cold Shutdown and Refueling, A"-'.L~V.U.'';~, many many variables variables exist exist which which impact impact thethe ability ability to to cool cool the the core. In the event eventof ofananELAP during duringthese theseModes, Modes,installed installedplantplantsystems systemscannotcannotbeberelied reliedupon upon to cool the core, thus transition to Phase 22 will will begin begin immediately.

immediately. All Allefforts effortswill be bemade madetoto expeditiously provide core cooling and and minimize heat-up and and repressurization.

repressurization. Exelon has has aa program

'.J .... .L~AA in place (Ref. 3) 3) toto determine determine the time timetotoboil boilfor forall allconditions conditionsduring duringshutdown shutdownperiods. periods.

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

To accommodate the activities of vessel disassembly and refueling, water ... ""JU""j",. waterlevels in the thereactor reactor vessel and the reactor cavity are often changed. The most mostlimiting limitingcondition conditionisisthe thecasecaseininwhich the reactor head is removed and water level in the vessel vesselisisatatororbelow belowthe reactor reactorvessel vesselflange.

. . ". . . If uJii-.'....

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

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

equipment.

Page 9 of of 67

Byron Station, Units 1 and 2 Mitigation Miti ation Strategies Strategies Integrated Integrated Plan Plan deploying a FLEX pump to take suction suction from the RWST and and /or lor UHS as as described described in the Phase 2 Core Cooling section. Guidance Guidancewill be provided totoensure ensurethat sufficient area areaisisavailable for for deployment and that haul paths remain accessible without without interference interference from outage outage equipment equipment during refueling outages, 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 Section 44 &

& 55 Ref 3 - OP-AA-108-117-1001 OP-AA-I08-117-1001 Rev 0, 0, Spent Spent FuelFuel Storage Storage Pools Pools Heat-up Heat-up Rate Rate With WithLoss Loss of of Normal Cooling, dated July 22, 2011 July 22, 2011 Details:

Provide a brief Byron Station will use the industry developed guidance guidance from the the description ofof Procedures Owners Groups, EPRI and NEI Task team teatn to to develop develop site site specific specific I/ Strategies I/ Guidelines procedures or guidelines to to address address the criteriacriteria in NEI 12-06. 12-06. These procedures

'-' .......~y. .l.v.., and/or

.... andlor guidelines will support the existing symptom

"-UJIJ'W'.L based command and control strategies strategiesin the current currentEOPs.

Identify modifications The following gaps have been identified identified that that prevent nr"","""1t extended operation of the DDAFW Pump. Byron Station Station will utilize modifications to close these gaps prior to FLEX FLEX implementation.

implementation.

These will be an Open item that that will will bebe closed closed andand documented documented in aa future 6-month 6-month update.

update.

1. DDAF pump suction flow path is not available

1. available due to to CST unavailability and failure of of the CST isolationisolation valve valve to to close close and the SX suction valve valve toto open open on on loss loss of ACACpower.

power.

2. DDAF batteries are are drained drained due due to to repetitive repetitiveengine enginestartsstartswith automatic reset of of low-low low-low suction suction pressure pressuretrip

3. DDAF pump overheating due to cooling water

3. water recirculation recirculation flow paths within SX system cycling and and overheating overheating the 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 Key Reactor Parameters Parameters Essential Essential Instrentation Safety Function SG Pressure: RCS pressure boundary and PI-5I5, PI-515, PI-516, PI-5I6, PI-525, PI-525,P1-535, 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 - LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - T1-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and Page 10 10 of of 67 67

Byron Byron Station, Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan pressure control control Containment Pressure: PI- Containment Containment IntegrityIntegrity PC005 SFP Level: (component # SFP Inventory TBD)

Byron's evaluation of the FLEX strategy strategy may mayidentify

...... V'.... ".LL additional parameters that are needed in order to to support key keyactions actionsidentified

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

.........r.£'orin ....""clo*H1r11<:l-nr'o or to InOlcate in the plant procedures/guidance or to indicate imminent or actual ~rnrnn"lo*nt core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) 3.2.1.10) and any any difference will be communicated communicated within within aafuture future 6-month 6-monthupdate update following identification.

.luv.l..ll..ljLlv(.~l..lVU **

In addition to the parametersparameters listed 3.2.1.10, the following additional listed in NEI 12-06 additional parameters 12-06Rev. Rev.0 Section parameters will be evaluated

° Section evaluatedfor for use as the detailed strategy is developed. Closure Closureofofthis thisitem will be communicated in aa future future 6-month 6-monthupdate. 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 8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NR006A/B, NI-36B IR

Reference:

PWROG Generic FLEX FLEX Support SupportGuidelines Guidelinesand andInterfaces Interfaces (Controlling Procedure Interface Interface and and Recommendation Recommendation Instruments) Rev. 0, Supplement 14, 14, dated datedDecember December2012 2012PA- 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 Page 11 of of6767

Byron Station, Units 11 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated PlanPlan Maintain Core Core Cooling & Heat Removal PWR Portable PWR Portable Equipment Equipment Phase Phase 22 Provide a general general description description of ofthe the coping coping strategies strategies using using on-site on-site portable portable equipment equipment including including station station modifications that modifications that are are proposed proposedto tomaintain maintaincore corecooling. methods and Ident~fy methods cooling. Identify and strategy(ies) strategy(ies) utilized utilized to to achieve this coping coping time. time.

Phase 22 Core cooling will be achieved with aa portable FLEX diesel pump and S/G PORVs. The nn,rTalr-.iQ pump suction will come corne from the RWST R WST and/or andlor the the UHS UHS fed fed from from the the well well water waterpumps pumps powered powered from a portable Flex DG. The Thedischarge dischargewill willbe beinto intothetheAFWAFWlines linesdownstream downstreamofofthe thecontainment containment isolation valves into the S/Gs. S/Os. The PORVs will be be used used to to control control the S/GS/O pressure.

pressure.

In the event the unit is in a refueling outage, another another portable portable FLEX FLEX diesel diesel pump will also alsobe beable abletoto supply the RCS boil off using the modifications outlined in Phase Phase 22 ofof Inventory Control.

c.rn ... 1"*c.t'"t to Electrical power

..... r"' .. required TA .... ....

to support the Flex Strategy is

<:'111"\ ..... n r T 1S described in the Safety Safety Function Support Section of of the document.document.

Details:

Provide a brief Byron Station will use the industry developed developed guidance guidance from the the description of of Procedures Owners Groups, EPRI and NEI Task team team toto develop develop sitesite specific

"'1J"-'vALA ....

I/ Strategies Strategies /I Guidelines Guidelines procedures or guidelines to to address the criteria criteria in in NEI 12-06.

12-06. These These procedures and/or andlor guidelines will will support support the the existing existing symptom sylnptom based based command and control control strategies strategies in the thecurrent currentEOPs.

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

SOs.

FLEX pump discharge: discharge: Install Pipe flange connections on the A, D, BB and C Auxiliary feed water water (AF)

(AF) SG SO injection injectionlines linesatatthe thetest testflanges flanges within the Main Steam Isolation Valve (MSIV) (MSIV) rooms.

rooms. Connect Connect the the pipe flanges with a header routed through the the steam steam tunnel.

tunnel. One One end end of the header will be routed to the B/C BICMain MainSteam StearnSafety SafetyValve (MSSV) room and terminated terminated with with aastandard standardFLEX FLEXconnection connection (Primary connection) and the the other other end endwill willbe berouted routedtotothe theA/DAID MSSV room and terminated with aa standard 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 12 of of 67

Units 1 and 2 Mitigation Byron Station, Units Mitigation Strategies Strate ies Integrated Integrated Plan Plan Core Cooling Maintain Core Cooling & & Heat Removal PWR Portable PWR Portable Equipment Equipment PhasePhase 22 Key Reactor Parameters Essential Instrumentation Safety Function SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control 1 PI-545 and PI-546 SG Level: RCS pressure boundary boundary and and NR - LI-517, LI-S17, LI-519,19, LI-527, LI-S27, pressure control LI-537. LI-547 LI-S37, LI-S47 and LI-549 LI-S49 WR - LI-502 LI-S02 and and LI-503 LI-S03

( RCS Res Temperature: RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary boundary and and pressure control Containment Pressure: PI- Containment Integrity PCO05 SFP Level: (component # SFP Inventory TBD)

Byron's evaluation Byron's evaluation of ofthe FLEX strategy strategymay identify additional identify..,."""",,, ... 'U, .... w,A parameters that are are needed needed in in order order toto support supportkey keyactions actionsidentified identified in the plant procedures/guidance procedures/guidance or or to to indicate indicateimminent or oractual actual damage (.. 112-06 core damage 12-06Rev.

Rev.00Section Section3.2.1.10) 1.10)and andany difference will be communicated within aa future 6-month update updatefollowing identification.

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

Page 13 of Page 67 of67

Byron Byron Station,Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strate ies Integrated Integrated Plan Plan Maintain Core Core Cooling Cooling & & Heat Removal PWR Portable Equipment Phase 2 Storage // Protection of of Equipment Equipment ::

Describe storagestora e I/ protection rotection plan Ian or schedule to determine storage stora e requirements re uirements Seismic Structures to provide protection protection of ofFLEX equipment equipmentwill willbe be constructed to meet the requirements of NEI 12-06 12-06 Rev. Rev. 0, 0, Section Section

11. Schedule to construct permanent

11. permanent building building isis contained containedinin Attachment 2, and will satisfy the site compliance compliance date. date. Temporary Temporary locations will be used until building construction U',L1~'U1F-. construction completion. completion.

Procedures and programs will be developed to to address address storage storage structure requirements, haul path path requirements, and andFLEX equipment requirements relative to the external hazards ~JlUL-,UL;>applicable applicabletotoByron Station.

Flooding Structures to provide protection protection of FLEX equipment will be be Note: if below current if stored below cun'ent flood flood level, level, constructed to meet the requirements of of NEI 12-06 Rev. 0, Section then ensure procedures procedures exist exist to to move move equipment prior prior to to exceeding exceeding flood flood level.

level. 11. Schedule to construct permanent

11. permanent building isis contained in VVJlU.U.JlJlH.,'U Attachment 2, and will satisfy satisfy the site site compliance compliancedate. date.Temporary locations will be used until building construction construction completion. completion.

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

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

11. Schedule to construct permanent

11. permanent building building isis containedcontainedin Attachment 2, and and will will satisfy satisfy the the site site compliance compliancedate. date.Temporary Temporary locations will be used until building construction construction completion. completion.

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

Snow, Ice, and Extreme Structures to provide protection protection of of FLEX FLEX equipment equipmentwill be be Cold Cold constructed to meet meet the requirements of ofNEI NEI12-06 12-06Rev. Rev.0,0,Section Section 11.

11. Schedule to construct permanent building is contained in

"':r>t'\t:>riln Attachment 2, and will satisfy the site compliance vV~"'J.iJJ."'"llv'"date. date.Temporary Temporary locations will be used until building construction completion. completion .

Procedures and programs will be developed to address ......... ~... L ' " ' . J Ustorage storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Byron Station.

High Temperatures Structures to provide

,t1"'11f'tTI1"'t::>C provide protection of FLEX equipment will be constructed to meet meet the requirements of NEI 12-06 Rev. 0, Section Page 14 Page 14 of of 67 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Integrated Plan Plan Maintain Core Cooling & Heat Maintain Heat Removal Removal PWR Portable Equipment Equipment Phase Phase 22

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

Procedures and programs will be developed to address storage structure requirements, rOr1n""'01T'.ontc haul path requirements, and FLEX equipment requirements relative relative toto the the external external hazards hazardsapplicable applicabletotoByron Byron Station.

Station, Deployment Conceptual Conceptual DesignDesign (Attachment (Attachment 3 3 contains contains Conce Conce ptual tua) Sketches)

Sketches)

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

The required Flex Equipment The storage structure structure FLEX piping, valves, and VLVJL.Uj;;.,

needed for core cooling cooling will be conceptual design has not not been been connections (electrical & & fluid) fluid) installed in a Robust Flex completed and will will be an an Open Open will meet NEI 12-06 Rev.0 Rev.O building ready for quick hook VYJ. .* 'UJ, ...lr-, Item, Item. protection requirements.

up and use.

Hoses and Electrical The closure of this item will be There will be an an administrative administrative connections that will will be be documented in a future program created to to protect protect thethe completed as needed needed to to support support 6- month month update.

update. connections from blockageblockage the coping strategy strategy will will be be during outages and and non non outage outage stored within the Flex building. times.

Notes:

Secondary cooling cooling capabilities capabilitiesrecommend recommend300 300gpm gpmatat300300psia.

psia.(WCAP- 176017601-P Ref 1)

The RWST inventory is maintained at a minimum of of 423,000 gal gal during during normal normal operation.

operation. With aa conservative sustained flow flow rate rate of of300 300 gpm, gpm, thethetotal totalinventory inventorywould wouldbe depleted depletedinin2323hours. hours.

Prior to depletion of of the RWST RWST inventory inventoryaatransition transitionwill be bemade madetotothe UHS.

Exelon A.J"... ""L."......... -' .. " Company, LLC (Exelon)

Generation

'A.'-'Ja ....... has not (Exelon) has not finalized finalized the the engineering engineering designs designs for for compliance with NRC Order EA- 12-049. Detailed designs based basedononthe current conceptual designs designs will be developed to determine the final plan and associated mitigating strategies. Once Oncethese thesehave been fully developed, Exelon will update the integrated plan for Byron during a scheduled 6-month "Ov1.LOvUUC1 ....'U 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 28, 2013 Integrated Plan.

Reference:

Ref 1 - WCAP-17601-P 17601 Rev 0, 0, Reactor Coolant System Response to tothe Extended Loss of AC Power Event for for Westinghouse, Westinghouse, Combustion Engineering, &

Engineering, & Babcock & Wilcox NSSS NSSS Designs, Page 15 of of 67 67

Byron B ron Station, Units 11 and 2 Mitigation Miti ation Strategies Strate ies Integrated lnte rated Plan Plan Core Cooling Maintain Core Cooling & Heat Removal PWR Portable PWR Portable Equipment Phase 2 2.

dated August 2012.

Page 16 of of 67

Byron Byron Station, Station, Units 11 and and 22 Mitigation Mitigation Strategies Strate ies Integrated Inte rated Plan Plan Maintain CoreCore Cooling Cooling & Removal

& Heat Removal PWR Portable PWR Portable Equipment EquipmentPhase Phase 33 Provide a general general description description of ofthe the coping coping strategies strategies using phase 33 equipment using phase equipment including modifications that are proposed proposed to to maintain maintain core core cooling.

cooling. Identify Identify methods methods and andstrategy(ies) strategy(ies) utilized utilized totoachieve achievethis thiscoping coping time.

Phases 1 and 2 strategy will provide sufficient capability such that no additional Phase 3 strategies are required.

Phase 3 equipment for Byron includes backup portable FLEX pumps and generators. The portable portable FLEX pumps ULU."UL~ will be capable of of providing the necessary flow and pressure pressure asas outlined in Phase Phase 22 response for Core Cooling & Heat Removal, RCS Inventory Inventory Control Control andand Spent Spent Fuel Pool Cooling.

The portable FLEX generators will be capable of of providing providing the the necessary necessary 480480 volt power requirements as outlined in

..." . ' " " *.&.1.......' ...... in Phase 22 response responsefor Safety SafetyFunctions Support.

Support.

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

Details:

Provide aa brief Provide brief Confirm, Confirm that procedure/guidance exists or will be developed to to description ofof Procedures Procedures support implementation implementation with description of withaa description of the procedure//strategy theprocedure strategy

// Strategies // Guidelines Guidelines /guideline.

/ guideline.

Byron Station will use the industry developed guidance guidance from from the Owners Groups, EPRI and NEI Task team to develop develop site specific specific procedures or guidelines to address the criteriacriteria in NEI 12-06.

12-06. These procedures and/or guidelines will support support thethe existing existing symptom symptom basedbased command and control control strategies strategies in in the the current currentEOPs.

Identify modifications List modifications necessary for for phase 3 There are no Phase 33 modifications modifications required.

re uired.

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

Essential Instmentation Safety `unction 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 - LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B Page 1717 of of 67 67

Byron Station, Units 11 and Byron Station, and 22 Mitigation Miti ation Strategies Strate iesIntegrated IntegratedPlan Plan Maintain Core Maintain Core Cooling Cooling & & Heat Heat Removal Removal Portable Equipment PWR Portable Equipment Phase Phase 33 RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: PI- Containment Integrity PCO05 SFP Level: (component # SFP Inventory TBD)

Byron's evaluation of the FLEX strategy strategymay mayidentify identifyadditional additional parameters that are needed in order order to to support keykey actionsidentified actions identified in the plant procedures/guidance procedures/guidance or orto to indicate indicateimminent ororactual actual core damage (NEI 12-06 12-06 Rev. 0 Section 0 Section 3.2.1 3.2.1.10) and any difference and any difference will be communicated within aa future 6-month 6-month update update following 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 beevaluated evaluatedfor for use as the detailed strategy is developed. Closure ~ ... 'i*... of II ofthis item itemwill willbe communicated in in aa future 6-month 6-rnonth update. update.

Core Exit Thermocouple Thermocouple (CET) (CET) Temperature: Temperature: TI-IT002 TI-IT002 RCS Accumulator Level: LI.951, 1, LI-953, LI-953, LI-955, LI-955, and and LI LI -957

-957 Reactor Vessel Level Level Indicating Indicating System System(RVLIS): (RVLIS):LI-RC020 LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and and FI-AF018A FI-AF018A Battery Capacity I/ DC Bus Voltage: El-DC002 EI-DCOO2 Neutron Flux: NI-NRO06A/B, NI-NR006AIB, NI-36B NI-36B IR

Reference:

PWROG Generic FLEX Support SupportGuidelines Guidelinesand andInterfaces Interfaces (Controlling Procedure Interface and Recommendation ALA"""' .. A'.......,...., RecommendationInstruments) Instruments)

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

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

Strategy Strategy Modifications Modifications Protection Protection of of connections connections Strategy including how Identify Strategy Identify modifications Identify how the the connection is

( the the equipment will be deployed will be deployed protected to the point oint of 0 use.

Equipment will be delivered No modifications are required Byron will utilize Phase 22 from the RRC to the staging other than those outlined in connection points.

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

be transported to the site Page 18 of of 67

Byron Station, Byron Station, Units Units 11 and and 22 Mitigation Mitigation Strategies StrategiesIntegrated IntegratedPlan Plan Core Cooling Maintain Core Cooling & & Heat Removal PWR Portable Equipment Phase 3 and hooked up by both RRC personnel and plant personnel per the playbook. Equipment will then be operated per plant procedures.

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

strategies. Once Oncethese thesehave have been fully developed, Exelon will update the integrated integrated plan for for Byron Byron during during aa scheduled scheduled 6-month update. This update will include any changes changestotothe theinitial initialdesigns designsasassubmitted submittedininthe theFebruary February28,28, 2013 Integrated Plan.

Page 19 ofof 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Plan Maintain RCS RCS Inventory Inventory Control Control Determine Baseline Baseline coping coping capability capability with with installed installed coping modifications not coping modifications not including including FLEX modifications, utilizing methods described in Table 3-2 3 .. 2 of of NEI 12-06:

12-06:

• Low Leak RCP Seals or RCS makeup required

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

Provide a general general description description of ofthethe coping coping strategies strategiesusing usinginstalled installedequipment equipmentincluding includingmodifications modifications that are proposed proposed to to maintain maintain core core cooling.

cooling. Identify Identify methods methods (Low (Low Leak RCP Seals and/or borated borated high pressure RCS pressure RCS makeup)and makeup)and strategy(ies) utilized utilized totoachieve achievethis thiscoping copingtime. time.

At the initiation of the the event event operators operators will will enter enterEmergencyEmergencyOperating OperatingProcedure Procedure(EOP) (EOP)BCA 0.0, 0.0, Loss of All AC. The Extended Loss of of AC AC Power (ELAP), (ELAP), BCA BCA 0.0 0.0 Attachment B, B, will will be entered when the emergency diesel generators are "",..nLV," ' .... "V"L.;) areconfirmed confirmedunavailable and off-site power power cannot be restored and it is confirmed by dispatcher ...... ".;)f..'" *. VU.'L orvisual or visualverification verificationofofphysical physicaldamage toto infrastructure at site.

Within 90 minutes operators will rn1 .... "1-.',.." operators will coolcool down downthe plant plantatatapproximately 75°F/hr 75°F/hrtoto420°F420°F(Tcold).

(Tcold).

Steam generator (SC) (SG) pressure will be approximately approximately 300 300 psia.

psia. Steam Steam generatorgenerator pressure pressure of of300 300 psia corresponds to RCS pressure necessary to to inject SI accumulators.

accumulators. This will will ensure ensure RCS RCS pressure is above the minimum miniInuln pressure to to precludepreclude injection injection of of accumulator accumulator nitrogen nitrogen into into the the WCAP-17601-P (Ref.

RCS. WCAP-17601-P (Ref. 2). 2).

During cool down, the initial RCS inventory make-up make-up and and boration boration source source will will be be the the SSI accumulators.

Cold Shutdown Cold Shutdown and Refueling:

When in When in Cold Cold Shutdown Shutdown and and Refueling, Refueling, many many variables variables exist exist which which impact impact thethe ability ability to to cool cool the the core.

core. In the the event eventof ofan anELAP during during thesethese Modes, Modes,installed installedplant plantsystemssystemscannot cannotbe berelied reliedupon upon to cool to cool thethe core, core, thus thus transition transition to to Phase Phase 22 will will begin begin imnlediately.

immediately. All All efforts efforts will willbe bemade madeto to control reactor reactor temperaturebelow below 212°F 212°F to to preventprevent an an unplanned unplanned mode mode change. Exelon Exelonhas hasaa program in place place (Ref. (Ref. 3)3) to to determine determine the time to to boil boil forfor all all conditions conditionsduring duringshutdown shutdownperiods. periods.

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

To accommodate To accommodate the the activities activities of of vessel vesseldisassembly disassemblyand andrefueling, water waterlevels levelsin the thereactor reactor vessel and the vessel the reactor reactor cavitycavity are are often often changed.

changed. The most mostlimiting limitingcondition conditionisisthe case caseininwhichwhich the reactor reactor head is is removed removed and water water levellevel in in the vessel vessel is at at or or below below the reactor reactor vessel vessel flange. If an ELAP/LUHS occurs during this ...... U.LJULJ.F, this condition condition then (depending on onthe the time time after shutdown) shutdown) boiling boiling in the core may occur quite rapidly.

Deploying and implementing portable FLEX pumps to to supply supply injection injection flow flow must must commence commence immediately from the time of the event. This should be plausible because I-H"' .......H.V .. "" because more more personnel personnel are are on on site during outages to provide the necessary resources. resources. Strategies for makeup water waterinclude J.u.V'.LU"

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

i.e.,generators generatorstoto preserve vitalvital instruments instruments or orincrease increaseoperating operatingtime timeon onbattery batterypowered poweredequipment. equipment.

Page 20 of of 6767

Byron Station, Units 1 and 2 Mitigation Strategies Integrated lnte rated Plan RCS Inventory Maintain RCS Inventory Control Control deploying a FLEX pump to take suction from the RWST and for UHS as described in the Phase 2 Core Cooling section. Guidance will be provided to ensure that sufficient area is available <AJl.U."'V.L~for 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 2/01113

- WCAP-17601-P Ref 2 -- WCAP-17601-P Rev 0, 0, Reactor Reactor Coolant CoolantSystem SystemResponse Responsetotothe Extended ExtendedLoss Lossof AC AC Power Event for Westinghouse, Combustion Engineering, & & Babcock Babcock & & Wilcox Wilcox NSSS NSSS Designs, Designs, dated August 2012 OP-AA-108-117-1001 Rev 0, Spent Fuel Storage Pools Heat-up Rate Ref 3 - OP-AA-I08-117-1001 Rate WithWith Loss Loss of of Normal Cooling, , date July 22, 2011.

Details:

Provide aa brief Provide brief Confirm that procedure/guidance exists or procedure/guidance exists or will will be be developed to description ofof Procedures support implementation support implementation 1/ Strategies // Guidelines Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task Task team team toto develop developsite specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the the existing

....a .. L ..... " .. J'JO.. symptom based command and and control control strategies strategies in the current EOPs.

Identify modifications List modifications There are no Phase Phase 11 modifications required re uiredatat this this time. time.

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

evaluation.

Essential Essential Instruentation Safety Function SG Pressure: RCS pressure boundary and PI-515, PI-5I5, PI-516, PI-516, P1-525, PI-535, PI-535, pressure control PI-545 and PI-546 SG Level: RCS pressure boundary 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-42313, TI-433B and T1-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: Pl- Containment Integrity PCO05 (component ##

SFP Level: (component SFP Inventory TBD)

Page 21 21 of of67 67

Byron Station, Byron Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain RCSRCS Inventory Inventory Control Control 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 12-06 Rev.

Rev. 00 Section Section 3.2.1.10, the following additional parameters will be be evaluated evaluated for use as the detailed strategy is developed.

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

update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 TI-IT002 RCS Accumulator Level:Level: LI-951, LI-951, LI-953, LI-953,LI-955, LI-955,and LI -957 Reactor Vessel Level Indicating Indicating System System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and and FI-AF018A FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 EI-DCOO2 Neutron Flux: NI-NR006A/B, NI-NR006A/B, NI-36B NI-36B IR

Reference:

PWROG Generic FLEX Support Guidelines Guidelines andand Interfaces Interfaces (Controlling Procedure Procedure Interface Interface and and Recommendation Recommendation Instruments) Rev. 0, Supplement Supplement 14, 14, dated dated December December 20122012 PA-PSC-0965.

Notes:

Exelon Generation Company, LLC (Exelon)

(Exelon) has not not finalized finalized the the engineering engineering designs designs for for compliance with NRC Order 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 mitigating strategies.

strategies. Once these have been fully developed, Exelon will will update thethe integrated integrated plan plan for for Byron Byron during during aa scheduled 6-month update. This Thisupdate updatewill willinclude includeany changes totothe initial designs asas submitted in the February 28, 28, 2013 2013 Integrated IntegratedPlan.

Plan.

Page 22 of of 67

Byron Byron Station, Station, Units Units 11 and and 22 Mitigation Miti ation Strategies Strategies Integratedlnte rated Plan Plan Maintain RCSRCS Inventory Inventory Control Control PWR Portable PWR Portable Equipment EquipmentPhase Phase 2: 2:

Provide a general general description of the coping strategies using on-site description of on-site portable portable equipment equipment including including modifications that are proposed to maintain Inventory Control,Control. Identify Identifymethods methods(Low (Low Leak LeakRCP RCP Seals Seals borated high pressure RCS makeup)and strategy(ies) utilized to andlor borated and/or to achieve achievethis thiscoping copingtime.time.

Phase 2 RCS inventory control and boration will be achieved within 8 his via a portable FLEX pump WCAP-17601-P (Ref 1). The FLEX pump suction will come come from the RWST. The discharge will be into into the the CV/SI CV/SI pump pump discharge dischargelinelinedownstream downstreamofofthe theCV/SI CV/SIpump. pump.

The shortened timetime of of 88 hrs hrs for for inventory inventorysatisfies satisfiesthe borated boratedwater watermakeupmakeupatatthe theexpected expected Xenon peak of 8-10 hrs, from WCAP-17601-P WCAP-17601 (Ref (Ref 1).

1). A calculation calculation will will bebe required and and tracked tracked as an Open item for the timing of the boration and quantity required. The The closure closure of ofthis item will be documented in aa future future 6-month update.

update.

Electrical power to support the FLEX strategy is described in the safety Function Support section.

References:

Ref I - WCAP-17601-P Rev 0, Reactor Coolant System Response totothe Extended Loss

""C',r\n<'", 'VTonrl,;:,rI Lossof AC Power Event for Westinghouse, Combustion Combustion Engineering, Engineering, & & Babcock Babcock & & Wilcox NSSS NSSS Designs, Designs, 5.8.1 dated Section 5.8.1 dated August 2012.

2012. page page 5-206.

5-206.

Details:

Provide a brief Confirm that procedure/guidance Confirm procedurelguidance exists exists or or will will bebe developed developed to description ofof Procedures support support implementation implementation I/ Strategies I/ Guidelines Byron station Station will will use use the industry industry developed developedguidance guidancefrom the Owners Groups, EPRI and NEI Task team to to develop site develop site specific specific procedures or guidelines to address the criteria criteria in NEI NEI 12-06.

12-06. These procedures and/or guidelines guidelines will support supportthe theexisting existingsymptom symptom based command and and control control strategies strategies in in the thecurrent currentEOPs.

Identify modifications Identify modifications List modifications The following FLEX modifications will be installed installed to to support support RCS inventory and boration.

boraHon.

pump discharge: The BBCV pump discharge FLEX pump dischargeheader, header,downstream downstream check valve of check CV8481B, will valve_CV8481B, will be modified modified with a tee. A A header will will be routed from the tee to the RWST RWST tunnel hatch or alternate path and terminated with a 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 electrically opened after the FLEX DG powers up the Div 2 ESF Bus. The B SI pump discharge header, downstream of SI8921B, 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 (Primary)_Deployment of the secondary flow path will be Page 23 Page 23 of of 67 67

Byron B ron Station, Station, Units Units I1and and22Mitigation MitigationStrategies Strate iesIntegrated IntegratedPlan Plan Maintain RCSRCS Inventory Inventory Control Control PWR PWR Portable Portable Equipment Phase Phase 2:

2:

contingent on primary pressure conditions less than 1750 prig 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 RWST will be modified with a tee. A header will be routed from the tee to the RWST tunnel hatch or or alternate alternate path path and and terminated terminated with aa standard standard FLEX connection.

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

Essential Instrumentation Safety Function I 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 boundary and and NR - LI-517, LI-S19,19, LI-527, LI-527, pressure control control LI-537, LI-547 and and LI-549 LI-549 WR - LI-502 and LI-503 LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413B, 3B, TI-423B, TI-433B and and TI-443B RCS Pressure: QTR - PI-403 RCS pressure boundary and and pressure ressure control Containment Pressure:PT-Containment Pressure: PI- Containment Integrity Intl'l,n-r11r" PC005 PCO05 SFP Level: (component (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.

24 of67 Page 24 of 67

Byron Station, Units 11 and and 22 Mitigation Miti ation Strategies StrategiesIntegrated lnte ratedPlanPlan Maintain Maintain RCS RCS Inventory Inventory Control Control PWR Portable PWR Portable Equipment Equipment Phase Phase 2: 2:

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-95 1, 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-NROO6 , NI-36B IR

Reference:

PWROG Generic FLEX Support Support Guidelines Guidelines andandInterfaces Interfaces (Controlling Procedure Interface and Recommendation int,:u*'b",.-.o and Instruments) Rev. 0, Supplement 14, 14, dated dated December 2012 2012PA- PA-PSC-0965.

Storage Protection of Storage I/ Protection of Equipment:

Equipment:

Describe storage / protection Describe storage protection plan plan or or schedule schedule to to determine determine storage storage requirements requirements Seismic Seismic List Protection or schedule to protect Structures to provide protection protection of of FLEX equipment will be be constructed to meet meet the the requirements requirements of NEI12-06 ofNEI 12-06Rev.Rev.0,0,Section Section

11. Schedule to construct permanent

11. permanent buildingbuilding is is contained containedin in Attachment 2, and will satisfy the site r:U.I.uv.l,AAAAv.lH.. site compliance date. Temporary Temporary locations will be used until until building building construction constructioncompletion.

completion.

Procedures and programs programs will will be be developed developedto toaddress addressstorage storage structure requirements, haul path requirements, requirements, and andFLEX FLEX equipment requirements relative to f'"anlll11"'arn.antC' relative to the external hazards applicable to Byron Station.

Flooding Flooding List Protection or schedule to protect Note: if stored below current current flood then ensure procedures exist exist to flood level, to move move level, Structures to provide protection protection of ofFLEX equipment will be equipment prior to exceeding exceeding flood flood level.

level. constructed to meet meet the the requirements requirements of ofNEI 12-06 Rev. 0, Section

11. Schedule to construct permanent building building is is contained vV'.H..u .....n,"u,.in Attachment 2, and will satisfy the the site site compliance compliancedate. Temporary locations will be used until building construction constructioncompletion.

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

Severe Severe StormsStorms withwith High High List Protection or schedule to protect Winds 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 Page 25 of of 6767

Byron Station, Byron Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain RCS RCS Inventory Inventory Control Control PWR Portable PWR Portable Equipment Phase Phase 2: 2:

structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Byron Station.

Snow, Ice, and Extreme List Protection or or schedule schedule to to protect protect Cold Cold Structures to

..... ,."f"nf'1*~~ ..":).(, to provide protection of FLEX equipment will be r>rn... n r . a T'!> ... r."""r>"~

constructed r>r. .. ""t~*nntan to meet the requirements of NEI 12-06 Rev. 0, Section

11. Schedule

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

completion.

Procedures and programs will will bebe developed developed to to address address storage storage structure requirements, haul haul path path requirements, requirements,and andFLEX equipment requirements relative relative to to the theexternal externalhazards hazardsapplicable applicable to Byron Station.

High Temperatures List Protection or or schedule to protect Structures to provide protection protection of ofFLEX equipment will be nr> .... "t.*l1ntan to meet constructed meet the the requirements r~nlJl1t*~rrl~ntc.' 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 Byron Station. Station.

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

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

The required Flex Equipment The storage structure structure FLEX piping, valves, and needed for RCS Inventory conceptual design has has not not been been connections vV~UAvvLA'JAALI (electrical &

& fluid) will be installed in a Robust completed and will be an Open will meet NEI 12-06 Rev.0 12-06 Rev.O Flex building ready for quick Item. protection requirements.

hook up and use. There will be an administrative Hoses and Electrical The closure of this item will be be program created to protect the connections that will be documented in a future connections from blockage completed as needed to 6-month update. during outages and non-outage support the coping strategy s.

will be stored within the Flex building.

Page 26 of of 67 67

Byron Station, Units Units 11 and and 22 Mitigation Miti ationStrategies StrategiesIntegrated IntegratedPlan Plan RCS Inventory Maintain RCS Inventory Control Control PWR Portable Equipment Equipment Phase Phase 2:2:

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 27 of 67 of67

Byron Station, Byron Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strate ies Integrated Integrated PlanPlan Maintain ReSRCS Inventory Inventory Control Control Equipment Phase PWR Portable Equipment Phase 3: 3:

Provide a general general description description of ofthe the coping coping strategies strategiesusing phase33equipment usingphase equipmentincluding includingmodifications modifications that are that are proposed proposed to to maintain maintain inventory inventory control.

control. Identify Identifymethods methods (Low (Low Leak Leak RCP RCP Seals Seals andlor and/or borated borated high pressure RCS makeup makeup )and strategy(ies) utilized to to achieve achieve this this coping copingtime.

time.

Phases 1 and 2 strategy will provide sufficient capability such that no additional Phase 3 strategies are required.

Phase 3 equipment for Byron includes backup portable FLEX pumps and and generators.

generators. TheThe portable portable FLEX pumps will be capable of providing the necessary flow and and pressure pressure as as outlined outlined in in Phase Phase 22 response for Core Cooling & & Heat Removal, RCS InventoryInventory Control and and Spent Fuel Pool Pool Cooling.

Cooling.

The portable FLEX generators will be capable of of providing providing the necessary necessary 480 480 volt volt power power requirements as outlined in in Phase 22 response response for forSafety SafetyFunctions FunctionsSupport.

Support.

In addition a support component would be be aa portable portable refuel vehicle with aalarge largediesel dieseloil oilbladder v ......'........ 'v ..

to support refilling the FLEX diesel diesel tanks.

tanks.

Details:

Provide aa brief Provide brief Confirm that procedure/guidance Confirn'l procedure/guidance exists exists oror will will bebe developed developed to description of description Procedures of Procedures support implementation implementation

// Strategies Strategies /I Guidelines Guidelines Byron Station will use the industry developed guidance guidance from from the Owners Groups, EPRI and NEI Task team team to to develop develop site site specific specific procedures or guidelines to address the criteria criteria inin NEI NEI 12-06.

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

Identify modifications Identify List modifications nwdifications There are no Phase 33 modifications modificationsrequired.

required.

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

Essential Instrumentation I 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 WR - LI-502 and LI-503 RCS Temperature: RCS Heat Removal Cold Leg - TI-413I3, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Page 2828 of of 67 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Plan Maintain RCS Inventory Control PWR Portable PWR Portable Equipment Phase Phase 3: 3:

Containment Pressure: PI- Containment Integrity

"'-'v .........., ....... u .............

PCO05 SFP Inventory Byron's evaluation of the FLEX strategy maystrategy identify additional parameters that are needed needed in in order order to to support supportkey keyactions actionsidentified identified procedures/guidance or in the plant procedures/guidance or to to indicate indicate imminent imminentor oractual actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and any any difference will be communicated communicated within within aa future 6-month update update following identification.

In addition to the parameters listed in NEI12-06 12-06 Rev. Rev. 00 Section Section 32.1.10, the following additional parameters will be evaluated for use as the detailed strategy

...J:vl..*U.Li ....,U strategy isis developed.

developed. Closure Closure of this item will be communicated in a future 6-month update. .1-UC'Ll"', ....... 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 AF W Flow: FI-AFO 12A, Fl-AFO 14A, FI-AFO16A and FI-AFO I 8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06A/B, NI-36B IR

Reference:

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

.I.,-v'VV .. .LUJ.Jl,-",U.'.U.I.I...1VAJ.

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

Deployment Conceptual Modification (Attachment 33 contains (Attachment contains Conce Conceptual tual Sketches)

Sketches)

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

use.

Equipment will be delivered No modifications are required Byron will utilize Phase 22 from the RRC to the staging other than 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 personnel and Page 29 29 of of67 67

Byron.

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

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

Notes: Exelon Generation Company, LLC (Exelon)

(Exelon) has notnot finalized the engineering engineering designs designs for compliance with. NRC Order with NRC Order EA-12-049.

EA-12-049. Detailed Detailed designs designs based based onon the the current current conceptual conceptual designs will be developed to determine the final plan andand associated associated mitigating mitigating strategies.

strategies. Once Once these have been fully developed, Exelon will update the the integrated plan plan for for Byron Byron during during aa scheduled 6-month update. This Thisupdate updatewill willinclude includeany anychanges changestotothe theinitial initialdesigns designsasas submitted in the February 28, 2013 2013 Integrated Integrated Plan.

Page 30 of of 67 67

Byron Station, Units 1 and 2 Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Containment Determine Baseline coping capability capability with installed coping 3 modifications not including FLEX modifications, FLEX modifications, utilizing methods described in Table 33-2 of NEI

..2 of NEI 12-06:

12..06:

• • Containment Spray

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

PWR Installed PWR Installed Equipment Phase Phase 1: 1:

Provide a generalgeneral description description of ofthe the coping coping strategies strategiesusing usinginstalled installedequipmentequipmentincluding includingmodifications modifications that that are proposed proposed to to maintain maintain containment.

containment. Identify methods (containment spray/Hydrogen igniter) and strategy(ies) utilized to to achieve achievethis this coping copingtime. time.

There are no Phase Phase 1 actions ",or required.

.. , .,.. £)ort The ......

limiting U,A""A,.,..., case for containment occurs when Auxiliary Feed flow flow is is not not established established and and the the TAF is 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 calculated "'"'v.,." containment pressure is

.........."'"',u., pressure is 27 27 psia.

psia. (Ref (Ref 1) 1) This is below the Containment Design pressure of of 50 psig. psig. (Ref 2) The Containment maximum temperature is 218 °F. This is below the maximum calculatedContainment rn"..v1,..... U,'"'Y\calculated Containmenttemperatureta.,," ...... a, .. £}t'l1 . . a of 280 °F for a LBLOCA and 333 °F for a MSLB. UFSAR (Ref (Ref 2) 2)

Additional calculations will be performed to evaluate containment response. This r>r1il"lT<:llnrnt:>l'T response. This will will be be an an open item. The closure of this item will be documented in aafuture 6-month 6-monthupdate. update.

References:

Ref I1 -- MAAP MAAP Analysis Analysis BW-MISC-009, BW-MISC-009,dated datedNovember November1,1,2011 2011 Ref 2 - Byron/Braidwood ByronlBraidwood Nuclear Stations Stations Updated Updated Final Safety Safety Analysis Analysis Report Report (UFSAR)

Revision 14, Section 6.2 dated December December 2012 2012 Details:

Provide a brief Byron Station will use the industry developed guidance guidance from the description of of Procedures Procedures Owners Groups, EPRI and NEI Task team teamto todevelop developsite sitespecific specific

/I Strategies I/ Guidelines procedures or or guidelines guidelinestotoaddress addressthe thecriteria in z 112-06. 12-06. These procedures and/or and/or guidelines guidelines will support supportthe theexisting existingsymptom symptom based command and and control control strategies strategiesin inthe thecurrent currentEOPs.

Identify modifications There are no phase hase 11 modifications modifications required. required.

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

Essential Instrumentation Safes Function SG Pressure: RCS pressure boundary and P1-515, PI-516, PI-525, P1-535, pressure control P1-545 and PI-546 SG Level: RCS pressure boundary and NR - LI-517, LI-519, L1-527, pressure control LI-537, LI-547 and LI-549 s

3 Coping modifications consist consist ofof modifications modifications installed installed to to increase increase initialinitial coping coping time, time, i.e.,

i.e.,generators generatorsto to preserve vital vital instruments instruments or orincrease increaseoperatingoperatingtime timeon onbattery batterypowered poweredequipment.

equipment.

Page 31 31 of of 67 67

Byron B Station, Units ron Station, Units I1and and 22 Mitigation MitigationStrategies Strategies Integrated Inte ratedPlan Plan Maintain Containment 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 PCOO5 SFP Level: (component (component # SFP Inventory TBD)

Byron's evaluation Byron's evaluation of ofthe FLEX strategy strategy may mayidentify additional additional parameters that that are are needed needed in order ordertoto support key keyactions actionsidentified identified in the plant procedures/guidance procedures/guidance or or to to indicate indicateimminent ororactual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and and any any difference will be communicated within aa future 6-month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0 Section Section 3.2.1.10, the following additional parameters will be evaluated evaluated forfor use as the detailed strategy is developed. Closure Closureofofthis thisitem will will be communicated in in aa future future 6-month 6-month update.

update.

Core Exit Thermocouple Thermocouple (CET) (CET) Temperature: TI-IT002 RCS Accumulator Level:Level: LI-951, 1, LI-953, LI-955, and andLI -957 -957 Reactor Vessel Level Indicating Indicating System System (RVLIS):

(RVLIS): LI-RC020 LI-RC020 AFW Flow: FI-AF012A, FI-AFO14A,FI-AF014A, FI-AF016A and and FI-AF018A 8A Battery Capacity / DC Bus Bus Voltage:

Voltage: El-DC002 EI-DC002 Neutron Flux:

Flux: NI-NROO6A/B, NI-NR006NB, NI-36B IR

Reference:

PWROG Generic FLEX Support Guidelines and Interfaces (Controlling Procedure Procedure Interface Interface and and Recommendation JL'-v'vv ........ .uv ***.,.u.l..* vJ..L Instruments) Rev. 0, Supplement 14, dated datedDecember

!L.JvvvJJ.HJ'v.i 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 32 of Page 67 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Strate ies Integrated Integrated Plan Plan Maintain Containment Maintain Containment PWR Portable PWR Portable Equipment EquipmentPhase Phase2: 2:

Provide a general description of of the coping strategies using using on-site on-site portable portable equipment equipment including modifications that are proposed proposed to maintain core cooling.

cooling. Identify Identify methods (containment spray/hydrogen igniters) and strategy(ies) strategy(ies) utilized toto achieve achievethis thiscoping copingtime.

time.

There are no Phase 2 actions required.

Details:

Details:

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

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

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

Identify modifications Identify modifications List modifications There are no Phase 2 modifications required Key Containment Key Containment List instrumentation credited credited or or recovered recovered for for this this coping coping evaluation.

evaluation.

Parameters Essential Instruentation Safety nction SG Pressure: RCS pressure boundary and PI-515,15, PI-516, 16, PI-525, PI-525, PI-535, PI-535, pressure control PI-545 and PI-546 PI-546 SG Level: RCS pressure boundary and NR - LI-517, LI-519, 19, LI-527, pressure control LI-537, LI-547 and and LI-549 LI-549 WR - LI-502 and LI-503LJ'- ..HLJ 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 PC005 SFP Level: (component (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.

Page 33 Page 33 of 67

Byron B ron Station, Units 1 and 2 Mitigation Miti ation Strategies Integrated Integrated Plan Plan Maintain Maintain Containment Containment 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-951, LI-953, LI-953, LI-955, LI-955,and andLILI-957

-957 Reactor Vessel Level Indicating Indicating System System(RVLIS): (RVLIS): LI-RC020 LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and and FI-AF018A8A Battery Capacity /I DC DC BusBus Voltage:

Voltage: El-DC002 EI-DC002 Neutron Flux: NI-NR006A/B, NI-NR006 , NI-36B IR

Reference:

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

"'-'A Storage I/ Protection Storage Protection of of Equipment:

Equipment:

Describe Describe stora storagee // protection rotection plan Ian or or schedule schedule to to determine determine stora storagee requirements re uirements Seismic Seismic List Protection or schedule to protect NA Flooding Flooding List Protection or schedule schedule to to protect protect NA Severe Storms with Severe Storms with High High List Protection or schedule schedule to to protect protect Winds NA

Snow, Snow, Ice, and Extreme Ice, and Extreme List Protection or or schedule schedule to to protect protect Cold NA NA High Temperatures High Temperatures List Protection or schedule to protect NA NA Deployment Conceptual Modification Deployment Conceptual Modification (Attachment (Attachment 3 contains Conceptual 3 contains Conce tual Sketches)

Sketches)

Strategy Modifications Modifications Protection of connections of connections Identify Strategy including how how Identify modifications Identify how the the connection is the equipment will be deployed protected to the point oint of 0 use.

use.

No deployment strategy is No modifications are required.

V U 1 . l l .... U U ' J U 0 required. No new connection points are are required. required.

Page Page 34 of67 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Strate ies Integrated lnte rated Plan Plan Maintain Containment 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 2 2013 Integrated Plan.

Page 35 of of 67

Byron Station, Units 11 and and 22 Mitigation Miti ation Strategies Strategies Integrated Inte rated Plan Plan Maintain Containment Containment PWR PWR Portable Portable Equipment EquipmentPhase Phase3: 3:

Provide aa general general description descriptionof ofthe the coping coping strategies strategiesusing using phase phase33equipment equipment including including modifications modifications that are are proposed proposed toto maintain maintain core core cooling.

cooling. Identify Identifymethods methods(containment (containment spray/hydrogen spray/hydrogen igniters) and and strategy(ies) strategy(ies) utilized utilizedtotoachieve achievethis thiscoping copingtime. time.

There are no Phase 3 actions required.

Details:

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

/I Strategies /I Guidelines Guidelines There are no Phase Phase 33 actions actions required.

re"n1 .. an Identify modifications modifications List modifications modifications There are no Phase Phase 33 modifications modifications required. re uired.

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

Parameters Essential Instentation Safety Function SG Pressure:

SG Pressure- RCS pressure boundary and PI-515, IS, PI-516,16, PI-525, PI-535, pressure control PI-545 PI-S4S and PI-546 PI-S46 SG Level: RRCS CS pressure boundary boundary and and NR - LI-517, LI-519, LI-S19, LI-527, LI-S27, pressure control LI-537, LI-547 LI-S37, LI-S47 and and LI-549 LI-S49 WR - LI-502 LI-S02 and LI-503 LI-503 RCS Temperature:

Temperature: RCS Heat Removal Cold Leg Leg-- TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary boundary and pressure res sure control Containment Containment Pressure:

1-101,('('11'' PI- Containment ..... Integrity rr.l>ty . ."T ..

PC005 PCODS SFP Level: (component (component # SFP Inventory TB D)

Byron's evaluation evaluation of of the FLEX strategy strategy may may identify identify additional .......n ... AL-L"-Ju'.......

parameters that are needed in order order to to support key keyactions

"'''AVU..,identifiedidentified in the plant procedures/guidance or to n ...n,r>arnl"'<~C """1.(1<3nl'' or to indicate indicate imminent or oractual actual core damage (NEI 12-06 Rev. 0oSection Section 3.2.1.10) 3.2.1. and any anydifference will be communicated within a future 6-month .u'"""' ..... update UIJ,,"lU\-v 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.

Page 36 of 67

Byron B ron Station, Units 1 and 2 Mitigation Strategies Integrated lnte rated Plan Plan Maintain Maintain Containment Containment 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- 016A and FI-AF018A 8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI- 006 , NI-36B IR

Reference:

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

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

Deployment Conceptual Modification Deployment Conceptual Modification (Attachment (Attachment 33 contains Conceptual contains Conce tual Sketches)

Sketches)

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

use.

No deployment strategy is is No modifications areare required.

required. No new connection connection points points are are required. required.

Notes: Exelon Generation Company, Notes: Com.pany, LLC (Exelon)

(Exelon) has not finalized the engineering engineering designs designs for for compliance with NRC Order EA-12-049.

NRC Order 12-049. Detailed designs designsbased basedononthe thecurrent currentconceptual conceptualdesigns designs will be developed to determine the final plan and associated mitigating mitigating strategies.

strategies. Once these have been fully developed, Exelon Exelon will will update updatethe theintegrated integratedplan planforforByron Byronduring duringa ascheduled scheduled6-month update. ThisThis update will will include any anychanges changestotothe initial initialdesigns designsasassubmitted

~U.~J~.LL.l"'''''U-in the February 28, 2013 Integrated Inh~,fTT'<:Itl"rt Plan.

37 of Page 37 of 67 67

Byron Station, Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated PlanPlan Maintain Spent Fuel Pool Cooling Determine Baseline coping capability Determine capability with with installed modifications not including coping" modifications installed coping FLEX modifications, FLEX modifications, utilizing methods methods described describedin inTable Table3-2 3-2of ofNEI NEI12-06:

12-06:

• with Portable Makeup with Makeu Portable In'Injection ection Source PWR Installed Equipment Equipment Phase Phase 1: 1:

Initial Spent Fuel Pool makeup will be be accomplished accomplished with gravity gravity drain drain from from RWST. Procedure Procedure development will be tracked as an open item. item. The Theclosure closureofofthis thisitem itemwill willbebedocumented documentedinina a future 6-month 6-month update.

nnrl ... f-o Spent Fuel Pool (SFP) makeup is not aa time constraint constraint withwith the initial initial condition condition of ofboth bothunits units in in Mode 1 at 100% power, since the worst worst case case fuel fuel pool pool heat heat load load conditions conditions onlyonly exist existduring duringaa refueling outage, outage. Under non-outage conditions, the the maximum maximum SFP SFP heat heat load load isis 38.5 38.5 Mbtu/hr.

Mbtu/hr. Loss Loss of SFP cooling with this heat load and and anan initial SFP temperature of of141 degrees degrees FF results results in aatime 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, Therefore, completing completing the equipment equipment line-up for initiating SFP makeup within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> into the the event event ensures ensures adequate cooling coolingof ofthe spent fuel is maintained.

The worst case SFP heat load during an outage is 61.4 Mbtu/hr. Loss Loss of ofSFP cooling cooling withwiththis heat load and an initial SFP temperature of 163 degrees F results in aa time time to to boil boil of of3.1 3.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, hours, 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 of active fuel. Therefore, completing completing the the equipment line-up for for initiating

~~L.L'".L"""U.LF>

SFP make-up within 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> hours into into the the event eventensures ensuresadequate adequatecoolingcoolingofofthe thespent spentfuelfuelisis maintained.

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

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

References:

1. Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Analysis Report Report (UFSAR) Revision Revision 14, Table 9.1-1, dated December 2012.

Details:

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

44 Coping Coping modifications consist of of modifications modifications installed installed to to increase increaseinitial initialcoping copingtime, time,i.e.,

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

Page Page 3838 ofof 67

Byron Byron Station, Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Identify Identify modifications modifications The The Spent Spent Fuel Fuel Pool Pool level instrumentation will be beinstalled

...... '.H"u..L.n."'~in accordance accordance with with NRC NRC Order OrderNumber NumberBA EA12-051 12-051and NEI 12-02.

Key Key SFP SFP Parameter Parameter 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, 17, LI-519, LI-519, LI-527, LI-527, pressure control LI-537, LI-547 LI-547 and and LI-549 LI-549 WR -- LI-502 LI-502 and and LI-503 LI-503 RCS Temperature: RCS HeatHeat Removal Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure:

RCS Pressure: WIZ WR -- PI-403 PI-403 RCS pressure pressure boundary boundary and and pressure control Containment Pressure: PI- Containment Integrity PCO05 SFP Level: (component # SFP Inventory TBD)

Byron's Byron's evaluation evaluation of ofthe the FLEX strategy strategymaymayidentify identifyadditionaladditional parameters that that are needed order to support key actionsidentified are needed in order to support key actions identified in the plant procedures/guidance procedures/guidance or or to to indicate indicateimminent imminentororactual actual core damage (NEI 12-06 12-06 Rev. 0 Section Section 3.2.1.10) 3.2.1.10) and and any any difference will be communicated within aa future 6-month

' .."". .LA.VA.V."""' 6-month update update following identification.

iAnJ'1n ......

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

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

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-AFO12A, FI-AFO I 4A, Fl-AF016A and Fl-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NROO6AIB, NI-36B lR

Reference:

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

PSC-0965, Page 39 of 67 Page

Byron Station, Byron Station, Units Units 11and and22Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Notes:Exelon Notes: ExelonGeneration GenerationCompany, Company,LLCLLC(Exelon)

(Exelon)has hasnot notfinalized finalizedthe theengineering engineeringdesignsdesignsfor for v'V~with compliance ... tJ,~,""."""'-'

NRC with EA-12-049.

Order EA-12-049. Detailed designs designs basedbased on the current on current conceptual

"",,-,Ln""""I,.,"'-.''

designs will be developed to determine the final plan and associated associated mitigating mitigating strategies.

strategies. Once 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 Page 40 40 of67 of 67

Byron Station, Units 11 and Byron Station, and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain SpentSpent Fuel Fuel PoolPool Cooling Cooling PWR Portable PWR Portable Equipment Equipment Phase Phase 2: 2:

Provide a general description of of the coping strategies using on-siteon-site portable portable equipment equipment including including modifications that are proposed to maintain spent fuel pool cooling.cooling. Identify methods (makeup via portable portable injection source) and strategy(ies) strategy(ies) utilized utilized totoachieve achievethis thiscoping copingtime.

time.

Spent Fuel Pool cooling will be achieved with with a portable portable FLEX diesel diesel pump.

pump. TheThe FLEX FLEX pump pump suction will come from the RWST and/or UHS URS with with make-up make-up from from Well Well Water.

Water. The discharge dischargewill will be into the SFP.

Evaluation of of the spent fuel pool area area for steam steam and and condensation condensation has has not not yet yet been been performed.

performed. The results of this evaluation and the vent vent path strategy, strategy, ifif needed, needed, will be be provided provided in aafuture 6-month 6-month update.

Electrical power required to support 0UIJIJV~ the Flex Strategy Strategy is is described described in Safety Safety Function Support U.U'I._L.l.V'.U Support Section of the document.

Details:

Provide aa brief Provide brief procedure/guidance exists Confirm that procedure/guidance exists or orwill willbebedeveloped developedto to description of description of Procedures Procedures support implementation support implem,entation II Strategies Strategies /I Guidelines Guidelines Byron Station will use use thethe industry industry developed developedguidance guidancefrom the the Owners Groups, EPRI and NEI Task team to develop site site specific UIJ ...'v ... .lI. ... v procedures or guidelines to address the criteria criteria in NEINEI 12-06. 12-06. TheseThese procedures and/or guidelines will support support thethe existing existing symptom symptom based based command and control strategies strategies in the the current currentEOPs.

EOPs.

Identify modifications Identify modifications List modifications List Spent fuel pool cooling will Spent be achievedpool coolingwith will be aachieved portable a portable FLEX diesel diesel pump via aa primary primary and and secondary secondary FLEX injection injectionconnections.

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 FHB north wall. The pipe will penetrate the north 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 S FP` by the south wall with standard National Standard Tread (NST) connection. A pipe will be routed from the standpipe to the FHB south wall on the ground elevation.

The pipe will penetrate the south wall of the FHB and have a standard FLEX connection installed. The NST connection will have a staged fire hose with a spray nozzle.

41 of 67 Page 41 67

Byron Byron Station, Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Spent Spent Fuel Fuel Pool Pool Cooling Cooling Key SFP Parameter Key SFP Parameter Essential Instruentation Safe Function SG Pressure: RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG SO Level: RCS pressure boundary and and LI-S17, LI-519, LI-527, NR - LI-517, LI-S27, pressure control control LI-S37, LI-547 LI-537, LI-S47 and LI-549 LI-S49 WR - LI-502LI-S02 and LI-503 and LI-503 RCS Temperature:

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

RCS Pressure: WR - PI-403 RCS pressure boundary boundary and pressure ressure control control Containment Pressure: PI- Containment Integrity PCO05 SFP Level: (component # SFP Inventory TBD)

Byron's Byron's evaluation evaluation of ofthe the FLEX strategy strategymay identify additional additional parameters that that are are needed needed in in order ordertotosupport supportkey actions actionsidentified identified in the plant procedures/guidance procedures/guidance or or to to indicate indicateimminent imminentororactual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) 3.2.1.10) and any difference difference will be communicated within a future 6-month update following update following identification.

In addition to the parameters listed in NEI 12-06 12-06 Rev.

Rev. 0 Section Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure Closureofofthis item will be communicated in a future 6-month update.

vV.lUC.l.lC.U.lA ... v U ..vl...& 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-AFO12A, FI-AFOI4A, FI-AFOI6A and FI-AFO18A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NROO6A/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.

Page 42 of 67

Byron Station, Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Maintain Spent Spent Fuel Fuel Pool Pool Cooling Cooling Storage Storage I/ Protection Protection of of Equipment:

Equipment:

Describe stora e / protection Describe storage rotection plan Ian or or schedule schedule to to determine determine storage stora e requirements re uirements Seismic Seismic List Protection or or schedule to protect Structures to provide protection protection of ofFLEX equipment equipmentwillwillbe be constructed to meet meet the the requirements requirements of ofNEI NEI12-0612-06Rev.

Rev.0,0,Section Section

11. Schedule to construct permanent

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

completion.

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

Flooding Flooding List Protection or or schedule to protect Structures

. . . ...,., .... JL ....,u to provide protection protection of FLEX equipment will willbe constructed to constructed to meetmeet the the requirements requirementsofofNET NEI 12-06 12-06Rev.

Rev.0,0,SectionSection

11. Schedule to construct permanent

11. permanent building building isis contained containedin Attachment 2, and and will will satisfy satisfy the the sitesite compliance compliancedate, date.Temporary Temporary locations will be used until building construction construction completion, completion.

Procedures and programs programs will will be be developed developedtotoaddress addressstorage storage structure requirements, ....,'-f,~JlJl,..,JlJl~'..,1Jl"\3, haul haul path path requirements, requirements, and andFLEX FLEXequipment equipment requirements relative to to the external hazards hazardsapplicable applicabletotoByron Byron Station.

Severe Storms with Severe Storms with High High List Protection or or schedule to protect Winds Winds Structures to provide protection protection of ofFLEX equipment will be be constructed to meet meet the the requirements requirements of ofNEI 12-06 Rev. 0, Section 1.1. Schedule to construct

11. construct permanent building is contained in VVL.LAH"l.JJ.VIL<- OJYAL'UCLUlF, Attachment 2, and and will satisfy satisfy thethe site compliance date. Temporary locations will be used used until building construction constructioncompletion.

completion.

Procedures v...., .....,u .... Jv\3 and programs programs will will be be developed developedto toaddress addressstorage

..,,,'V'L,,,}o,"'"

structure requirements, haul path requirements, and FLEX equipment requirements relative to to the external hazards applicable to Byron Station.

Snow, Ice, and Snow, Ice, and Extreme Extreme List Protection or or schedule schedule to protect Cold Structures to provide protection of FLEX equipment will be

... ....", ........." J constructed to meet the requirements of NET 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.

Page 43 of of 6767

Byron Station, Units 1 and 2 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Maintain Spent Fuel Pool Cooling Maintain 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.

High Temperatures List Protection or schedule to protect Structures to provide protection protection of of FLEX equipment equipmentwill willbe be constructed to meet the requirements of of NEI 12-06 12-06 Rev.

Rev. 0,0, Section Section

11. Schedule to construct permanent

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

'V"-! ..,U ......'A . ., . .',U, .. ' " to the the external external hazards hazardsapplicable applicabletotoByron Byron Station.

Deployment Deployment Conceptual Conceptual Design Design (Attachment (Attachment 33 contains contains Conceptual Co nee tnal Sketches)

Sketches)

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

use.

The required Flex Equipment The storage structure FLEX piping, valves, and and needed for SFP cooling cooling will will be conceptual design has not not been been connections connections (electrical (electrical & fluid)

& fluid) installed in a Robust Flex completed and will will be be an an Open meet NEI will meet NEI 12-06 Rev.O Rev.0 building ready for quick hook Item. requirements.

protection requirements.

up and use.

use. There will be be anan administrative administrative Hoses and Electrical Electrical The closure ofr>ln,CH1!"'t:> of thisthis item item will will be be program created program created to to protect protect the the connections that will will be be documented a rlnd"llfl,,,,, .... t,,,,rI in a future connections from connections blockage from blockage completed as needed to to support

""'l.H,JA, 6-month update. .... u,..u,u.,....,. ~~~AAJ"'" outages during non-outage outages and non-outage the coping strategy will will be be times.

stored within the Flex building.

building.

Notes: Exelon Generation Company, LLC (Exelon)

Notes: has not

.L..I""""".LVJ'~I has not finalized finalized the the engineering designs for pnCT1n'::'I"rln 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 44 of of 67 67

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

Provide of the coping strategies using phase 33 equipment Provide a general description of equipment including modifications that that are proposed to maintain spent fuel pool cooling.

spentjueZ cooling. Identify Identify methods (makeup (makeup viavia portable portable injection source)and strategy(ies) utilized toto achieve achieve this this coping coping time.

time.

Phase 2 strategy will provide sufficient capability such that no additional Phase 3 strategies are required.

Phase 3 equipment for Byron includes Phase includes backup backup portable portable FLEX FLEX pumps and andgenerators.

generators.TheTheportable portable FLEX pumps FLEX pumps will be capable of of providing providing thethe necessary necessary flow and andpressure pressureas asoutlined outlinedin Phase Phase22 response for Core Cooling & Heat Removal, response Removal, RCS RCS Inventory Inventory Control and and Spent Spent Fuel Fuel Pool PoolCooling.

Cooling.

The portable generators will be capable of providingproviding the necessary necessary 480 480 volt voltpower powerrequirements as as outlined in Phase 2 response for Safety Safety Functions FunctionsSupport.

Support.

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

Details:

Provide a brief Confirm that procedure/guidance Confirm procedure/guidance exists exists or or will will be developed to description ofof Procedures support implementation support implementation I/ Strategies I/ Guidelines Byron Station will use the the industry developed developedguidance guidancefrom fromthe Owners Groups, EPRI and NEI Task team team toto develop develop site site specific specific procedures or guidelines to address the the criteria criteria in in NEI NEI 12-06.

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

EOPs.

Identify modifications modifications There are no phase phase 33 modifications modificationsrequired.

Key SFP Parameter Key SFP Parameter Essential Essential Instentation Safet Function Safety SG Pressure: RCS Res pressure boundary boundary andand PI-515, PI-516, 16, PI-525, PI-525, PI-535, pressure control control PI-545 and PI-546 SG Level: RCS pressure pressure boundary boundary and

- LI-517, LI-519, LT-527, pressure control 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 I RCS Pressure: WR - PI-403 RCS pressure boundary and and pressure control Containment Pressure: P1- Containment Integrity PCO05 SFP Level: (component # SFP Inventory TBD)

Page Page 45 45 of of6767

Byron Station, Units 11 and 2 Mitigation Strategies Strategies Integrated Integrated Plan Plan Spent Fuel Maintain Spent Fuel Pool Pool Cooling Cooling 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 12-0612-06 Rev.

Rev. 00 Section Section 3.2.1.10, the following additional parameters will will be be evaluated evaluated for for detailed strategy is use as the detailed is developed.

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

update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 TI-IT002 RCS Accumulator Level: LI-951, 1, LI-953, LI-955, and LI -957 -957 Reactor Vessel Level Indicating System (RVLIS):(RVLIS): LI-RC020 LI-RC020 AFW Flow: FI-AFOI2A, FI-AFOI4A, FI-AFOI6A FI-AF016A and and FI-AFOI8A FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06AIB, NI-36B IR

Reference:

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

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

PA-PSC-0965.

Deployment Conceptual Design (Attachment (Attachment 33 contains Conce tual Sketches) contains Conceptual Sketches)

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

Equipment will be delivered No modifications are are required required Byron Byron will utilize Phase 22 from the RRC to the staging other than than those those outlined outlined in connection points.

connection points.

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

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

Page 46 ofof 67

Byron Station, Units 11 and Byron Station, and 22 Mitigation Miti ation Strategies Strate ies Integrated Integrated Plan Plan Maintain Spent Maintain Spent Fuel Fuel Pool Pool Cooling Cooling 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 e 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 47 ofof 67 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Integrated Plan Plan Safety Functions Support Determine Baseline coping capability capability with with installed installed coping coping modifications modifications not not including including FLEX modifications.

modifications.

PWR Installed Equipment PWR Installed EquipmentPhase Phase11 Provide Provide a general general description description of ofthe thecoping copingstrategies strategiesusing usinginstalled installedequipment equipmentincluding including station station modifications modifications thatthat are proposed proposed to to maintain maintain and/or and/orsupport supportsafety safetyfunctions.

functions. Identify methods methods and strategy(ies) strategy( ies) utilized to to achieve achievecoping copingtimes.

times.

DC power is required to maintain control of of ESF equipment equipment and vital vital instrumentation.

instrumentation. Battery Battery chargers are de-energized de-energized during during aa BDBEE leading leadingtotoloss lossof DC and associated associatedfunctions. functions.

The present 125'VDC 125VDC battery coping time 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, without withoutload load 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 minutes with deep load load shedding shedding (Ref. (Ref. 1) 1) consistent consistent with procedure _BCA 0.0. 0.0. Loss Loss of ofall all AC AC Power.

Power.

References:

1-Byron EC Evaluation 391872, Ref 1- <'u'UU.L.cVAA 391872,Battery Coping Time For The 1125v Coping Time 25v DC DC ESF Battery Banks, dated 2/8/13 2/8/13 Details:

Provide a brief procedure/guidance exists Confirm that procedure/guidance exists or orwill willbe bedeveloped developedtoto description of support support implementation.

implementation.

Procedures // Strategies // Byron Station will use the the industry industry developed developedguidance guidancefrom fromthe the Guidelines Owners Groups, EPRI and NEI Task team to develop site site specific specific procedures or guidelines guidelines to to address address thethecriteria criteriainin 112-06.

12-06. These procedures and/or guidelines will support support the existing existing symptom symptom based command and and control control strategies strate iesin inthe thecurrent currentEOPs.

Identify modifications Identif modifications There are no Phase I1modifications modifications required.

re uired.

Key Parameters Key Parameters identifiedkey No identified keyparameters.

parameters.

Byron's evaluation Byron's evaluation of ofthe the FLEX FLEX strategy strategymay mayidentify identifyparameters parameters that are needed in order to to support key actions actions identified identifiedininthe plant plant procedures/guidance or or to to indicate indicate imminent imminentor oractual core coredamage dmnage (NEI 12-06 Rev. Rev. 0 Section Section 3.2.1.10) 3.2.1.10) andand any difference will be be communicated within a future 6-month update following identification.

Notes: Exelon Generation Company, LLC (Exelon) has has not not finalized finalized the the engineering engineering designs ~_k'~_"~ for compliance with NRC Order EA- 12-049. Detailed designs designs based based on on the the current current conceptual V'VA.i.vVI,,"'UC'LU designs will be developed to determine the final plan and associated associated mitigating

.. "L .. 'L-LF, .......... JlF, strategies.

01'r<::;,' .....0 Once these have been fully developed, Exelon will update the integrated plan plan for for Byron Byron during aa scheduled 6-month update. This update will include any changes changestotothe initial designs designsasas submitted in the February 28, 2013 Integrated Plan.

55 Coping modifications consist of of modifications installed to increase increase initial initial coping coping time, time, i.e., i.e., generators generators to to preserve vital instruments or or increase increase operating operatingtime timeon onbattery batterypowered poweredequipment.

equipment.

Page 48 ofof 67 67

Byron Station, Units 11 and 2 Mitigation Strategies Strategies Integrated Integrated Plan Plan Safety Functions Support PWR Portable PWR Portable Equipment EquipmentPhase Phase 22 Provide Provide aa general generaldescription descriptionof ofthe thecoping copingstrategies strategiesusing usingon-site on-siteportable portableequipment equipmentincluding includingstation station modifications that are proposed proposed to to maintain maintain andlor and/orsupport supportsafety safety functions. Identify Identify methods methods and and strategy(ies) strategy( ies) utilized utilized totoachieve achievecoping copingtimes. times.

A portable diesel generator will provide power power to to one one division of ofthe 480V 480V ESF busses. Repowering at at this this level level willwill permit permitthe therecovery recoveryofofone onedivision divisionofofstationstationbattery batterychargers,chargers, DDAFP battery chargers, and MCC's MCC'spowering poweringcritical criticalequipment equipmentsuch suchasasDiesel Dieselfuel fueloil oiltransfer transfer pumps, and other ESF equipment equipment beneficial beneficial to to mitigate mitigate the the event.

event.

Exelon Generation Company, LLC (Exelon) (Exelon) intends intends on onmaintaining the theOperational OperationalCommand Commandand and Control function Control function within the Main Main ControlControl Room. Room. Habitability conditions conditions will be be evaluated evaluated and and aa strategy will be developed to maintain maintain Main Control Control Room Room habitability.

habitability. The The strategystrategy and and associated associated support analyses will be provided provided in in aa future 6-month update, Critical ventilation assets may be required to

" ' - '..............4> .. to support

,::"-"LJ'iL1~H DDAF pumps, station battery rooms, miscellaneous

,LUJ.I~'-.l.lu.UV'..'kJ electric equipment rooms, rooms, and and fuel fuel handling handling building building personnel habitability jJVJlkJV,lU,'"'*.d ......... uJ. ... UU .. ,LH.. and/or component survivability. Specific analyses of these these rooms rooms are are open items and will be addressed as as part of the detailed engineering engineering designdesign phase. phase. The closure closureofofthese items will be documented in a a future 6-month 6-month update.update.

Additionally, aa backup backup water water source sourcefor forcorecorecooling, cooling,inventory, inventory,and andSSFPF . makeup will be Lu .....n.v ..!'1J established with aa portable FLEX diesel diesel pump and and temporaryton... r.r.........*"', hoses from the UHS. A Dry Hydrant will be installed at at the UHS to to support supportthis thisstrategy.

strategy.

Details:

Provide a brief Confirm that procedure/guidance Confirm, procedure/guidance exists exists ororwill willbe bedeveloped developedto to description of Procedures support implementation implementation with a description of of the procedure // strategy the procedure strategy

// Strategies // Guidelines / guideline.

/guideline.

Byron Station will will use use the industry developed developedguidance guidancefrom the Owners Groups, EPRI and NEI Task team to to develop develop site specific procedures or guidelines to address the criteria in NEI 12-06. These j::,UJlU,""A.\,lA'",kJ procedures and/or guidelines Jiio, .... " ........ ,u,.,,""u will support the existing symptom based command r>Alrnn"l<::i"f1,ri and control control strategies in strategies in the thecurrent currentEOPs.

Identify Identify modifications modifications List modifications necessary for for phase 2 The following modifications will be installed installed to to support FLEX u .... U ..""JL generator repowering t'r",rl"""'JiTAr repowering 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 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 Page 49 of of 67

Byron Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Safety Functions Safety Functions Support Support PWR Portable PWR Portable Equipment Equipment Phase Phase 22 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.

A dry hydrant will be installed in the IRIS with a Flex Connection on it as a source of makeup water for use with a portable FLEX diesel pump.

The well water pump will have aa Flex Connection Connection added added to to the discharge as a source of clean makeup water.

Electrical connection Electrical connection via viasparesparebreaker breaker forfor UI-IS UHS 480v Substation for 480v Substation for aa FLEX DG to to repower the UHS 480 Substation for aa deep deep well pump.

Key Parameters Key Parameters List instrumentation credited or or recovered recovered forfor this this coping coping evaluation.

evaluation.

identified key No identified key parameters.

parameters.

Byron's evaluation Byron's evaluation of of the the FLEX strategy strategymay may identify identifyparameters T'H11r'<:lT'li"""r""T'C' that are needed in order order to to support support key key actions actions identified identifiedininthe plant plant procedures/guidance or or to to indicate indicate imminent imlninentor oractual actualcore coredamage. damage.

Reference NEI 12-06 Rev. 0, Section 3.2.1.10 and any any difference

~LJLL,",L''''''',", will be communicated within a future 6-month update update following following identification.

Storage Storage / Protection Protection of of Equipment Equipment::

Describe Describe storastoragee I/ protection rotection plan Ian oror schedule schedule to to determine determine storage stora erequirements re uirements Seismic Seismic List Protection or schedule to protect Structures to provide protection protection of of FLEX equipment will be constructed to meet the requirements requirements of ofNEI 12-06 Rev. 0, Section 11. Schedule to construct construct permanent building permanent buildingisiscontained contained in Attachment 2, and will satisfy satisfy the site compliance compliancedate. date.

Temporary locations will be used until building construction pfl"'Iinn.rQ'I""!J completion. Procedures and programs will be developed to to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Byron Station.

Flooding Flooding Protection or schedule to protect List Protection protect Note: if stored below current Note: current flood flood level, level, then then Structures to Structures to provide protection of FLEX equipment will be

...... ,-,,~,.r.'" .... ' .. "'TL:-.nT.

ensure procedures exist to move equipment prior to exceeding exceeding flood flood level, level. 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.

Page 50 50 of of 67 67

Byron B ron Station, Units 11 and and 22 Mitigation Mitigation Strategies Strate ies Integrated IntegratedPlan Plan Safety Functions Support Support PWR Portable Equipment Equipment Phase Phase 2 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.

Severe Storms with with High High List Protection or or schedule schedule to to protect protect Winds Structures to provide provide protection protection ofofFLEX FLEXequipment equipmentwill willbe be constructed to to meetmeet the the requirements requirementsof ofNEI 12-06 12-06Rev.Rev.0,0, Section 11. 11. Schedule to construct construct permanent permanent building building isis contained contained in Attachment "t.\..\..u."" ... u, ...... ""J'L\.. 2, 2, and and will will satisfy satisfythe site sitecompliance date. date.

Temporary locations will be used used until until building building construction construction completion. Procedures and programs will be developed to """-Vi;.; ..... to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Byron Station.

Snow, Ice, and Extreme Cold List Protection or or schedule schedule to protect Structures to provide provide protection protection ofofFLEX FLEXequipment equipmentwill be be constructed to meet meet the the requirements requirements of ofNEI NEI12-06 12-06Rev.Rev.0,0, Section 11. Schedule Schedule to to construct construct permanent permanentbuilding buildingisiscontained contained in Attachment Attachnlent 2, 2, and and will will satisfy satisfy the the site sitecompliance compliancedate. date.

Temporary locations will be used until building building construction construction completion. Procedures and programs will be developed developed to to address storage structure structure requirements, requirements, haulhaulpath pathrequirements, and FLEX equipment requirements requirements relative relativetotothe external hazards applicable to to Byron Station, Station.

High Temperatures List Protection or schedule to protect Structures

""""~,,,,,, ..,u to provide protection protection of FLEX equipment will be be constructed to meet meet the the requirements requirements of ofNEI 12-06 Rev. 0,0, Section 11. Schedule to to construct construct permanent building buildingisiscontained contained in Attachment 2, and will will satisfy satisfy the the site compliance compliancedate. date.

Temporary locations will be used until building construction construction completion. Procedures and programs will be developed developed to to address storage structure requirements, haul haul path requirements, requirements, and FLEX equipment requirements relative to to the the external external hazards applicable to Byron Station.

Page 51 51 of 67

Byron B ron Station, Units Units 11 andand 22 Mitigation Mitigation Strategies Strate ies Integrated Inte rated Plan Plan Safety Functions Safety Functions Support Support PWR Portable PWR Portable Equipment Equipment Phase Phase 22 Deployment Conceptual Deployment Conceptual Design Design (Attachment 33 contains (Attachment contains Conceptual Conce tnal Sketches)

Sketches)

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

use.

The required Support The storage structure structure FLEX piping, valves, valves, and and Equipment ro,,~ ............. ...,. .... i- needed for AC AC conceptual design has has not not been connections (electrical been connections (electrical &

& fluid) 11'Y1r.lo'1'YIt:>nT*,>T.,{"\n will be Phase 2 implementation will be completed and and will will be be an an Open Open will meet T 112-06 will meet 12-06 Rev.0 Rev.O installed in a Robust Flex Item. protection protection requirements.

requirements.

building ready for quick hook up and use. The closure of this item will be be There will be be anan administrative administrative Hoses and Electrical documented in a future program created to protect the connections that will be 6-month update. connections from blockage completed as needed to support

,...,..,.' ...... Iai-':lo..-; " .... I.)'I.IV.l during outages and non-outage non-outage the coping strategy strategy will will be be times.

stored within the Flex building. building.

Equipment for the UHS FLEX J..J\..I \..UIJHl"-'!H.

support will be staged in aa robust building and will be deployed to a pre-identified pre-identified staging location with aa debris debris removal tool like the the F-750 F-750 with snowplow or equivalent machine. Hoses and and electrical electrical connections will be completed as needed to support the site site coping co ing strategy.

Notes: Exelon Generation Company, LLC (Exelon) has not Notes: L.JL'LV.lV'.lA ......,'VAAV.lUAVAA ' - ' V . l l U J ...'A.l not finalized the the engineering engineering designs designs for for compliance with NRC Order EA-12-049. Detailed Detaileddesigns designsbased basedononthe thecurrent currentconceptual conceptualdesigns designs will be developed to determine the final plan and associated 'U-VI.VA LALAA"[V associated mitigating mitigating strategies.

strategies. Once these thesehave have been fully developed, Exelon will update the integrated .L.fI'\.VAV'J.l integrated plan for for Byron Byron during during aa scheduled scheduled 6-month 6-month update. This update will include any changes _AA~UA"""~~to tothe initial designs asassubmitted in the theFebruary February28,28, 2013 Integrated Integrated Plan. Plan.

Page Page 5252 of67 of 67

Byron Station, Units 11 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Safety Functions Support PWR Portable Equipment Phase 3 Provide a general general description description of ofthe the coping strategies strategies using phase 33 equipment using phase equipment including including modifications that are proposed to maintain and/or andlor support support safety Identify methods and strategy(ies) utilized functions. Identify safety functions. utilized toto achieve coping times.

times.

Phase 2 strategy will provide sufficient capability such such that that no no additional additional Phase Phase 33 strategies strategies are are required.

Phase 3 equipment equipment for Byron Byron includes includes backup backup portable portable FLEX pumps pumpsand generators.

generators.The portable portable FLEX pumps pumps will be capable capable ofof providing providing thethe necessary necessary flowflow and pressure pressureasasoutlined outlinedininPhase Phase2 2 response for Core Cooling & & Heat Heat Removal, Removal, RCS RCS Inventory Control and Spent SpentFuel FuelPool PoolCooling.

Cooling.

The portable portable FLEX generators generators willwill be be capable capable of of providing the necessarynecessary 480480 voltvolt power power requirements as outlined outlined in Phase Phase 22 response responsefor forSafety SafetyFunctions FunctionsSupport.

Support.

In addition, a support component would be aa portable refuel vehicle with aalarge diesel dieseloil bladder toto support refilling the FLEX diesel tanks.

Details:

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

// Strategies // Guidelines procedures or guidelines to address address thethe criteria criteria in in NEI 12-06.

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

EOPs.

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

required.

Key Parameters Key Parameters No identified key parameters.

parameters.

Byron's evaluation Byron's evaluation ofofthe FLEX strategy strategymaymayidentify identifyparameters parameters that are needed in order to support key actions actions identified in in the plant procedures/guidance or or to to indicate indicate imminent or oractual actualcore coredamage.

V"JlI.",~V.

Reference NEI 12-06 Rev. Rev. 0 Section 3.2.1.10 and any difference difference w will be communicated within a future 6-month update update following following identification.

Page 53 of of 6767

Byron Station, Units 11 and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Safety Functions Support Safety Functions Support PWR Portable Equipment Equipment Phase Phase 33 Deployment Conceptual Deployment Conceptual Design Design (Attachment (Attachment 33 contains contains Conceptual Conce tual Sketches)

Sketches)

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

Equipment and consumables No modifications are are required required Byron will utilize Phase 2 will be delivered from the RRC other than those outlined outlined in connection points.

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

plan.

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

.LJ ..... ,u.J.IJJUJ.'VJiJ.l.

will then be operated per plant procedures.

Notes: Exelon Generation Company, LLC (Exelon)

Notes: (Exelon) has has not not finalized the the engineering engineering designs designs for for compliance with NRC Order Order EA12-049.

EA-12-049. Detailed Detailed designs designs based basedon onthe thecurrent currentconceptual conceptualdesigns designs will be developed to determine the final 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 Byron Byron during during aa scheduled scheduled 6-month 6-month update. This update updatewill include includeany changes changestotothe theinitial designs designsasassubmitted submittedininthetheFebruary 28,28, 2013 Integrated Plan.

Page 54 of of 67

Byron Station, Units Byron Station, Units 11and and 22Mitigation MitigationStrategies StrategiesIntegrated Integrated Plan Plan PWR Portable PWR Portable Equipment Phase 2 Use and (potential (potential/flexibility)

/flexibility) diverse uses I Performance Perfonnance Criteria Maintenance Core Containment Containment SFP S Instrumentation Instrumentation Accessibility Accessibility Maintenance // PM Maintenance PM List portable portable requirements requirements equipment Four (4) 480 x x 500kW Equipment maintenance VAC and testing will be Generator Per conceptual design Per performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section H.

Three (3) 40 gpm at 1500 psia Equipment maintenance High Head and testing will be Flex Pump to the At the injection point to the performed in accordance perWCAP RCS per 17601-P WCAP 17601-P with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Three (3) 300 gpm at 300 psia Equipment maintenance Medium and testing will be Head FLEX At the At the injection point point to to the the performed i n accordance Steam Generators Steam Generators per WCAP WCAP pump with the industry 17601-P 17601-P templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11, Page 55 of of 67

Byron Station, Station, Units Units 11 and and 22 Mitigation Mitigation Strategies StrategiesIntegrated IntegratedPlan Plan PWR PWR Portable Portable Equipment EquipmentPhasePhase22 Use and (potential (potential/flexibility) diverse uses

/flexibility) diverse uses I Performance Peiformance Criteria Maintenance List portable Core Containment SFP SFP Instrumentation Instrumentation Accessibility Accessibility Maintenance Maintenance I/ PM PM List portable requirements requirements equipment equipment Two (2) X x 1100 gpm at 500 ft head Equipment maintenance Portable and testing will be diesel FLEX General Usage General performed in accordance pumps with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

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

One (1) F- x X X X Debris Removal and Equipment maintenance 750 Ford Refuel delivery and testing will be Truck capability performed in accordance with the industry General General Usage templates, as outlined in JLD-ISG-2012-01 section 6 and NET 12-06 section 11.

Page 56 ofof6767

Byron Station, Station, Units Units 11 and and 22 Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan PWR Portable Portable Equipment Equipment Phase Phase 22 Use and (potential (potential/flexibility)

Iflexibility) diverse uses Performance Peiformance Criteria Criteria Maintenance List portable Core Containment SFP SFP Instrumentation Instrumentation Accessibility Accessibility Maintenance Maintenance // PM PM List portable requirements requirements equipment equipment Three (3) X X x x x General Usage Equipment maintenance Diesel Trash and testing will be Pumps performed in 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 x x Iridium 9555 Equipment maintenance Satellite and testing will be phones General Usage performed in accordance with the industry templates, as outlined in JI D-ISG-2012-01 section 6 and NEI 12-06 section 11.

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

Page 57 ofof 67

Byron Station, Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan PWR Portable Equipment Phase 2 Use Use and (potential/flexibility) diverse uses (potential /flexibility) diverse uses Performance Criteria Maintenance Core Containment Containment SFP SFP Instrumentation Instrumentation Accessibility Maintenance /I PM PM List portable portable requirements requirements equipment Ten (10) 20" x x x Equipment maintenance portable and testing will be is vent General Usage performed in accordance s with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Page 58 ofof 67

Byron Station, Units 11 and 22 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan PWR Portable PWR Portable Equipment Equipment Phase Phase 33 Use Use and and (potential/flexibility) diverse uses (potential /flexibility) diverse uses Performance Criteria Notes Note: The RRC equipment has not been procured at the time of this submittal. The equipment listed is a generic list provided by the C and even though Byron 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 SFP Instrumentation Accessibility equipment 2 Medium MW x x output x x atx 4160 must be Generator must Voltage Vac, three phase common common Diesel commercially Generator available.

Must run on diesel

" fuel.

Low Voltage x x x 500 kW output at 480 Generator must be Diesel Vac, three phase common Generator commercially available,

• Must run on diesel fuel.

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

Low Pressure x 300 psi shutoff head, Pump 2500 gpm max flow Low Pressure x 500 psi shutoff head, Pump 500 gpm max flow Page 59 ofof 67

Byron Station, Units I1and Station, Units and 22Mitigation MitigationStrategies StrategiesIntegrated Integrated Plan Plan Low Pressure x 1 10 psi shutoff head, Pump 400 gpm max flow submersible Low Pressure 150 psi shutoff head, Pump 5000 gpm max flow Air 120 psi minimum Compressor pressure, 2000 scfm Industry Standard C Order

---

.~-

Page 60 of of 67

Byron Station, Byron Station, Units Units 11and and 22 Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Phase 33 Response Phase Response Equipment/Commodities Equipment/Commodities Item Item Notes Notes Radiation Protection Radiation Protection Equipment Equipment The C will not stock this type of equipment but this equipment will be requested

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

• • Dosimetry

• • Off-site monitoring/sampling monitoring/sampling Commodities Commodities The RRC 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 water Fuel Requirements Fuel Requirements 300 - 500 gallon bladders that can be delivered by air Heavy Heavy Equipment Equipment ** TBD during site specific playbook development

1. Transportation equipment ** Redundant Phase 2 equipment to be located at RRC

2. Debris clearing equipment 61 of 67 Page 61

Byron Station, Byron Station, Units Units 11 and and 22 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Attachment 1A Attachment lA Sequence of Sequence Events Timeline of Events Timeline Time Remarks Remarks //

Elapsed Elapsed Constraint Applicability 6

Action item Time Action V/N Y/N6 The times to complete actions in the Events Timeline are are based based on on operating operating judgment, judgment, thethe co nceptual designs, conceptual and the current supporting analyses. The Thefinal finaltimeline timelinewill willbe betime timevalidated validatedonce oncedetailed detailedddesigns are esigns are completed, procedures are developed, and and the results will be be provided in aa future 6-month up update.

date.

1 o0 Event Starts, BDBEE occurs, occurs, Unit 11and andUnit Unit22 NA NA Plant @100%

Plant @100%

reactors automatically automatically trip trip and and all rods rods are areinserted.

inserted. power Loss of off-site power power (LOOP) affecting affectingboth units occurs.

22 1 min 1 Emergency Operating Procedures VvvuuJ. *...,'" (EOPs)

(EOPs)and and NA A _BCA

_BCA 0,0,0.0, Loss Loss Out (SBO),

Station Black Out (SBO), Procedures Procedures are areentered.

a ..... t*o .."".ri of All AC ACPower, Power, action.

action, 3 5-15 mins 5-15 mins Verify DDAF Pp iiss operating properly.

operating properly. Y-1-1 _BCA 0.0, Loss hour hour of All AC Power, Power, action.

4 10-30 minx Attempt starting Emergency Emergency D/Gs. DIGs. NA NA _BCA 0.0, Loss

-BCA 0.0, Loss All AC Power, of All AC Power, action.

5 30 mins ELAP condition recognized recognized and and ELAP Procedures Procedures NA A _BCA 0.0, Loss are entered. of All AC Power, attachment attachment B for B for ELAP 6 30 mins to 30 minx Connect FLEX 480V AC AC generators generators to to ESF bus bus Y-3.6

Reference:

EC-3.6 hrs -32X and

_32X and verify verify they they are are supplying supplying power power to Div 2 hrs EVAL # 391872

- 125V DC battery chargers. Battery Battery Coping Coping Time For The 125V DC ESF Battery Banks, Battery Banks, dated February 8, dated February 8, 2013 7 1.5 hrs Start depressurization depressurization of ofSGsSGstoto300300Asia psia at ataa Y - 1.5 _BCA 0.0, Loss minimum of 75°F/hr 75°P/hr cooldown with SG PORV hrs of All AC Power, local/manual operation. SG feed is controlled with action.

Local/Manual operation

..... v"'u.l-n..'u. of ofAFW flow control control valves.

66 Instructions:

Instructions: Provide justification justification ifif No No or or NA NA is is selected selectedin inthe theremarks relnarkscolumn column If yes, include technical basis discussion as required by by NEI NEI 12-06 12-06 section section 3.2.1.7 3.2.1.7 Page 62 of of6767

Byron Station, Station, Units Units 11and and22Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan 8 2.25 hrs I SISIAccumulator 2.25 hrs Accumulatorborated boratedwater water begins begins to inject into into I NANA Operator Operator the RCS ReS I I Judgment 9 3-6 hrs 3-6 hrs Connect Connect high pressure FLEX Pumps Pumps and and ensure ensure they are available to supplying borated I-\n.'-:.1-",,,'imake-up to IIlaKe-UtDto the RCS.

10 10 3 hrs Maintain RCS 300 psia /-420°F with SG PORV Operator operation. WCAP- section 5.2.1 page 5-4 Judgment Maintain SG level.

11 11 6 - 12 hrs Connect FLEX Pump and ensure it is available to 6-12hrs NA NA supplying makeup to the SFP.

12 12 12 hrs Connect FLEX Pumps and ensure they are NA NA available to supplying makeup to the SGs.

13 24 hrs Set up FLEX pump suction from UIIS. NA NA 14 24 hrs Regional Response Center (RRC) resources begin NA NA arriving on site.

155 24 - 72 hrs Continue to maintain critical functions of Core NA A End of analytical Cooling (via DDAF), RSC Inventory Control (via simulation FLEX pump injection to RCS) and S FP Cooling (via FLEX pump injection to S FP). Utilize initial RRC equipment ment and and resources resources as as aaspare s arecapacity.

capacity.

Page 63 Page of 67 63 of 67

Byron Byron Station, Station, Units Units 11and and 22Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Attachment Attachment lB IB NSSS Significant Reference NSSS Reference Analysis Analysis Deviation Deviation Table Table Item Item of interest Parameter of interest WCAPvalue WCAP value WCAP WCAP Plant applied applied value value Gap Gap and anddiscussion discussion (WCAP-17601-P August 2012 Revision August 2012 Revision 0)

0) page page From the MAAP Analysis BB-MISC-020 the cooldown begins early due to the 1

1 Time to begin the cooldown WCAP has aa delay of 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> 4-144 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> secondary inventory available in the Original Steam Generators, (OSGs) on U-2 of 67 Page 64 of67

Station, Units Byron Station, Units 1 and 2 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Attachment 22 Milestone Schedule Site: Byron Orlsnnal Target Original Activity

. ell vay

,~ - ~

Status rl II '-'.1II .4-~ Date Completion { T.llH.dUUC elude

.1 el date chanQ'es date changes

'-' in

-r column this column Submit 60 Day Status Report Report rrmn1*4-Complete Overall Integrated Submit Overall Integrated Complete Implementation Plan Implementation Plan Contract with RRC ~C Complete Recurring action, Submit 66 month Submit updates IUJi t1 updates Ongoing Aug and Feb IUnit 1 Unit 2 Development Modification Development Aug 2014 Dec (Aug 2013

                     ~ec 2013

• Phase 11 modifications Phase modifications Conceptual Design Design UPIfP Aug 2014 Dec 2013
• Phase 22 Inudifkatl()n~

Phase

                                       ., Phase modifications                  Conceptual rt          r i~1 Design   IJP ne~lgn I/P Aug 2014 Dec 20133                            Phase 33 modifications modifications                                   fote 1 Note IUnit 1                Unit 2       Modification           111 ,1;1 If'-ta+;!on M~ Jd'f~rlil III Implementation Sept Sent 2015 Oct         Oct 2014          *.,   Phase I1 modifications modifications                                  Note 11 Note Sept 2015 Oct 2014                            Phase 22 modifications Phase             modifications                                  Note I1 Sept 2015 Oct 2014

~ep

• Phase 33 modifications Phase modifications Note 11 Note Procedure development Oct 2014 ., Strategy Strategy proceduresprocedures Note I1 Oct 2014 ., Maintenance Maintenance procedures procedures Note 11 Note Jun 2014 Jun 2014 Staffing analysis Staffing analysis Note 11 Oct 2014 Storage Plan and construction construction Note 1 I Oct 2014 FLEX equipment acquisition Note 1 I Oct 2014 Trainl1uI Training completion Note Note 11 Aug 2014 Regional Response Center Regional Response Center (will (will be be aa standard standard date date Operational from RRC)

Sept 2015 Unit I1 Implementation Implementation date date Note 1I Oct 2014 Unit 2 IImplementation i l i l ,h: iI date 11i:-if1' HI date Note Note 1I No

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

Page Page 65 65 of of 6767

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment 3 Conceptual Sketches (Byron Mechanical)

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Page 66 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment 3 Conceptual Sketches (Byron Electrical)

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