RS-13-019, 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)

ML13064A274
Person / Time
Site:	Clinton
Issue date:	02/28/2013
From:	Kaegi G Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, RS-13-019
Download: ML13064A274 (62)

Text

Exelon Generation Order No. EA-12-049 RS-13-019 February 28, 2013 u.s. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Overall Integrated Plan in Response to March 12,20 12 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, tCompliance 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 Gene'ration Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

U.S.Nuclear U.S. Nuclear Regulatory Regulatory Commission Commission Integrated Plan Integrated Plan Report Report to to EA-12-049 EA-12-049 February28,2013 February 28, 2013 Page22 Page Reference 11 requires Reference requires submission submission of of an an Overall Overall Integrated Integrated Plan Plan byby February February28,2013.

28, 2013. The NRC InterimStaff Interim StaffGuidance Guidance(ISG) (ISG)(Reference (Reference2)2)was wasissued issued August August 29,29, 2012 2012 which whichendorses endorses industryguidance industry guidance document document NEI NEt 12-06, Revision 0 (Reference (Reference3) 3)with with clarificatio ns and clarifications and exceptions identified exceptions identifiedininReference Reference 2.2. Reference Reference 33 provides provides direction direction regarding regarding thethe content contentof of this Overall Integrated this Overall Integrated Plan. Plan.

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

The purpose The purpose of of this this letter letter is is to to provide provide the Overall Integrated Plan Plan pursuant pursuantto toSection SectionIV,IV, Condition C.1, of Reference 1. This letter Condition C.1 , of Reference 1. This letter confirms EGC confirms EGChas has received received Reference Reference 22 and has has an an Overall Integrated Overall Integrated Plan Plan developed developed in in accordance accordancewith with the theguidance guidancefor fordefining defining and anddeploying deploying strategies that strategies that will enhance the will enhance theability ability to to cope copewith with conditions conditions resulting resulting from from beyond-des ign-beyond-design-basis external events.

basis external events.

The information The information in in the the enclosure enclosure provides provides the theClinton Clinton Power PowerStation, Station,Unit Unit11Overall OverallIntegrated Integrated Plan for Plan for mitigation mitigationstrategies strategiespursuant pursuanttoto Reference Reference 3. 3. The The enclosed enclosed Integrated IntegratedPlanPlanisisbased based on conceptual design informatio n. Final on conceptual design information. Final design details and design details and associated associated procedure guidance, as as well as well as any any revisions revisions to to the the information information contained containedin in the theEnclosure, Enclosure,willwill be beprovided providedininthethe 6-month Integrated 6-month Integrated Plan Plan updates updates required required by by Reference Reference1.1.

This letter This letter contains contains no no new new regulatory commitments. IfIf you have regulatory commitments. have any any questions questionsregarding regardingthisthis report, please contact David P. Helker report, please contact David P. Helker at 610-765-5525.at 610-765-55 25.

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

correct.Executed Executedonon thethe 28 th 28`"

day of day of February February 2013.

2013.

Respectful Respectfully ly submitted, submitted, G~/'/~

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

Enclosure:

1.1. Clinton Clinton Power Power Station, Station, Unit Unit 11Mitigation Mitigation Strategies Strategies(MS) (MS) Overall OverallIntegrated IntegratedPlan Plan cc:

cc: Director, Director, Office Officeof ofNuclear NuclearReactor ReactorRegulation Regulation NRC NRC Regional Regional Administra Administrator tor - -Region RegionIIIIII NRC NRC Senior SeniorResident ResidentInspector Inspector--Clinton ClintonPower PowerStation, Station,Unit Unit1 1 NRC Project Manager, NRR NRC Project Manager, NRR - Clinton -- ClintonPower PowerStation, Station,UnitUnit1 1 Mr.

Mr. Robert RobertJ.J.Fretz, Fretz,Jr, Jr,NRRIJLD/P NRRIJLD/PMB, MB, NRCNRC Mr. Robert Mr. RobertL.L.Dennig, Dennig,NRRIDSS/

NRRIDSS/SCVB, SCVB, NRC NRC Illinois IllinoisEmergency EmergencyManageme Management nt Agency Agency- -Division DivisionofofNuclear NuclearSafety Safety

Enclosure Enclosure 11 Clinton Power Station, Clinton Station, Unit Unit 11 Mitigation Strategies Mitigation Strategies (MS)

(MS)

Overall Integrated Plan (59 pages)

(59 pages)

Clinton Power Clinton Power Station, Station, Unit 1 Mitigation Strategies Integrated Plan General Integrated Plan Elements General ElementsBWR BWR Site:

Site: Clinton Clinton Power Station Determine Applicable Input the the hazards hazards applicable applicable to to the the site; site; seismic, seismic, external external Extreme External Hazard flood, highhigh winds, winds, snow, snow, ice, ice, cold, cold, highhightemps.

temps.

Describe how Describe how NEINEI 12-06 sections sections 55 -- 9 were applied and Ref: NEI 12-06 section Ref: section 4.0 4.0 -9.0

-9.0 the the basis for for why the plant screened out for for certain hazards.

JLD-ISG-2012-01 section 1.0 Seismic events, Seismic events, except except soil soil liquefaction; liquefaction; external flooding; flooding; severe severe storms with high storms high winds; winds; snow, snow, ice ice and and extreme extreme cold;cold; and and high high temperatures were determined to be applicable Extreme External Hazards for Clinton Power Station (CPS) per the per the guidance of of NEI 12-06 and are as NE112-06 as follows:

follows:

Seismic Hazard Assessment:

the Updated Per the Updated Final Final Safety SafetyAnalysis AnalysisReport Report(UFSAR)

(UFSAR) Section Section 3.7.1.1 [Reference 1], the seismic criteria criteria for forCPS include two CPS include earthquake spectra:

design basis earthquake spectra:Operating OperatingBasis Basis Earthquake Earthquake (OBE) and (OBE) and the the Safe Shutdown Shutdown Earthquake Earthquake(SSE). (SSE).

UFSARsection UFSAR section2.5.4.8 2.5.4.8[Reference

[Reference2]2]was was reviewed reviewed to to perform perform aa limited evaluation evaluation of of the liquefaction liquefaction potential potential outside outside the the power block power block area area for foraasafe safe shutdown shutdownearthquake earthquake(SSE) (SSE) event.

event.

There areare no no liquefaction susceptible soils soils within within the area of the principle principlestructures structuresfor foraaSSE SSE event with with aamaximum maximum horizontal acceleration acceleration equalequal to to 0.25 0.25 g. Therefore, Therefore, the the likelihood likelihood of of liquefaction liquefactionatatthe thesitesitefor fora aSSE SSE event with with aa maximum horizontal horizontal acceleration accelerationequal equal toto0.25 0.25ggisis low.

low.

Thus the Clinton Clinton site site screens screens in in for foran anassessment assessment for forseismic seismic hazard hazard except for soil liquefaction.

liquefaction.

External Flood Hazard Assessment:

Hazard Assessment:

The cooling lake is is designed designed to to withstand withstand the the effects effects of ofaa probable maximum maximum storm occurring over the entire entire drainage drainage basin basin upstream of the dam site. Results Results of of the the hydrologic hydrologic analyses discussed in UFSAR sections 2.4.3 UFSAR sections 2.4.3 [Reference 3] and and 2.4.8 [Reference 4] show that aa probable probable maximum maximum flood flood (PMF) runoff into (PMF) runoff into the lake lake routed routedthrough throughthe thespillways spillwayswill will raise the lake waterwater level level toto elevation elevation708.8 708.8feetfeetatatthethedamdam site. The backwater effect effect along along the the North NorthFork Forkfinger fingerwill willraise raise the the PMF water level PMF water level atat the the station station sitesite to to elevation elevation708.9 708.9feet.

feet.

Superimposing the the wind wind wave wave effect effect due due totoaasustained sustained40 40 mph mph windwind acting acting onon the thePMFPMF water waterlevel levelwill will result resultin in wave wave runup elevations elevations of of 711.9 711.9 feetfeet andand 713.8 713.8 feet for for significant significant waves waves and maximum maximum (1%) (1%) waves, respectively, at at the the station station site.

site. The The station's station'sSeismic Seismic Category Category II structures structureswith withgradegrade Page Page 11 of of59 59

Clinton Power Station, Station, Unit Unit 11 Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan elevation of of 736 feet feet will will not notbebeaffected affectedby bythethePMF PMF design design conditions. The conditions. The circulating circulating water waterscreenscreenhouse houseisis designed designed to to withstand the withstand the effects effectsof ofPMF.

PMF. [Reference

[Reference 5] 5]

following protection The following protectionmeasures measuresare are adopted adoptedfor forSeismic Seismic systems and Category I systems and components components located in the the circulating circulating water screen water screen house house and and located located below belowthe thePMFPMF level.level.

• • Water stops are provided in all construction joints joints upup toto the maximum flood level. level.

• Water seal rings rings areare provided provided for for all all penetrations penetrationsinin exterior walls exterior walls below below the the maximum maximum flood floodlevel.level.

Watertight doors

• Watertight doors designed designed to withstand withstand the the hydrostatic hydrostatic head of head of the the maximum flood level level areare provided provided for for all all doorways located on both the the entrance entrance walls walls and and the the internal walls internal walls of ofthetheShutdown ShutdownService ServiceWater Water(SX) (SX) pump pump rooms which are below the maximum maximum flood flood level.

level.

• Hatches are Hatches are provided provided on the the roof roofof ofthe theSX SX pump pump structure (elevation structure (elevation730 730feet) feet)for foraccess accessduring duringPMF. PMF.

accordance with NEI In accordance 12-06 section 6.2.1, Susceptibility to NE112-06 to External Flooding, Flooding, CPS screens in CPS screens in for an assessment for for external flood hazard since the hazard since the site is is IIkept "kept dry" by by the the measures listed measures listed above abovethat that protect protect safety related components in the circulating circulating water waterscreen screen house house below below the thePMF. PMF.

[Reference 6]

Severe Storms Severe Storms withwith High High Winds Winds Hazard Hazard Assessment:

Assessment:

Clinton site is located at 40° 40 0 10' 19.5" north north latitude latitudeand and88°88 0 50'3" 50' 3"west westlongitude longitude[Reference

[Reference7]. 7].NEI NEI12-06 12-06FigureFigure 7-2, 7-2, Recommended Tornado Design Design Wind Speeds Speeds for the 10-6/year the 10.6/year Probability Level Probability Level indicates Clinton is is in in Region Region 1 1- - 200 200 mph mph

[Reference 8]. Thus Thus the the Clinton Clinton site sitescreens screens in in for foran an assessment for assessment for high high winds and tornados, including including missilesmissiles produced by by these events.

Snow,I Ice and Extreme Snow Extreme ColdCold Hazard HazardAssessment:

Assessment:

The guidelines provided in in NEI NEI 12-06 section 8.2.1 generally include the need to consider extreme snowfall at at plant plant sites sites above the 35th parallel,parallel, which which includes includes the the Clinton Clinton site, site, located located at 40° 40 10' 19.5" North North andand 88°88 50'50' 3"3" West West[Reference

[Reference 9]. 9].

0 0 The Clinton site is The Clinton is located located within the the region region characterized characterized by by EPRIas EPRI asice iceseverity severity levelS level 5 (NEI12-06, (NEI 12-06, Figure Figure 8-2,8-2, Maximum Maximum Ice Ice Storm Severity Maps) Maps) [Reference

[Reference 10]. 10]. Consequently, Consequently, the the Clinton site is subject to severe icing conditions that that could could also also cause catastrophic cause catastrophic destruction to to electrical electrical transmission transmission lines. lines.

Thus the Clinton site site screens screens in in for foran an assessment assessment for forsnow, snow, ice, and extreme cold cold hazard.

hazard.

Page 2 of of 59

Clinton Power Clinton Power Station, Station, Unit 1 Mitigation Strategies Integrated Plan High HighTemperatures Temperatures Hazard HazardAssessment:

Assessment:

NEI 12-06section NE112-06 section9.2 9.2 requires requires allall sites sites to to consider the impactimpact of extreme of extreme high temperatures temperatures [Reference

[Reference11]. 11].Central CentralIllinois Illinois summers are warm and humid, summers humid, withwith periods periods of of extremely extremely hot hot weather over weather over 100°F.

100°F. UFSAR UFSAR Section 2.3.2 [Reference 12]

discussesthe discusses the local local meteorology meteorology for forCPS.

CPS.

Thus the Thus the Clinton site screens screens in for an assessment for for extreme extreme high temperature high temperature hazard.hazard.

References References

1. UFSAR

1. UFSARSection Section 3.7.1.1 3.7.1.1 UFSARSection

2. UFSAR Section 2.5.4.8 2.5.4.8

3. U UFSAR sections 2.4.3 FSAR sections

4. U UFSAR sections 2.4.8 FSAR sections UFSARsection

5. UFSAR section 2.4.2.2 2.4.2.2 NEI 12-06 Rev

6. NE112-06 Rev0,0,Section Section 6.2.1, 6.2.1, Susceptibility Susceptibility to to External External Flooding UFSARsection

7. UFSAR section 2.1.1.1 NEI 12-06Rev

8. NE112-06 Rev0,0,Figure Figure7-2, 7-2,Recommended Recommended Tornado Tornado Design Design 6

Wind Speeds for for the the 10-6/year 10- /year Probability ProbabilityLevelLevel

9. NE112-06 NEI 12-06 Rev Rev 0,0, Section Section 8.2.1 8.2.1 Applicability Applicability of ofSnow, Snow, Ice,Ice, and and Extreme Cold

10. NEI 12-06 Rev NEI 12-06 Rev 0,0, Figure Figure 8-2, 8-2, Maximum Ice Storm Severity Severity Maps

11. NEI NEI 12-06 Rev 0, 0, Section 9.2 Approach to to Extreme ExtremeHigh High Temperature Conditions

12. UFSAR Section 2.3.2 UFSAR Section 2.3.2 Key Site assumptions assumptions to to Provide key assumptions associated associated with with implementation implementation of of implement NEI implement NEI 12-06 12.. 06 Strategies:

FLEX Strategies:

strategies.

strategies.

This plan plan defines strategies capable capable of of mitigating mitigating aa simultaneous simultaneous Ref: NEI NEI 12-06 12-06 section section3.2.1 3.2.1 loss of all all alternating alternating current current (ac)

(ac) power powerand andloss lossof ofnormal normal access access toto the the ultimate ultimateheat heatsink sink(ELAP/LUHS) resulting from (ELAP/LUHS) resulting fromaa beyond-design-basis beyond-design-basis event by providing adequate capability capability to to maintain maintain or or restore restore corecorecooling, cooling,containment, containment,and andSFPSFPcooling cooling capabilities at all all units on aa site. Though Though specific specific strategies strategiesare are being developed, due to the inability inabilityto toanticipate anticipateall allpossible possible scenarios, the strategies are are also also diverse and flexible flexible toto encompass a wide range of of possible possible conditions.

conditions. TheseThesepre-pre-planned strategies developed to protect protect the the public publichealth healthand and safety will be be incorporated incorporated into into the theunitunitemergency emergencyoperating operating procedures procedures in in accordance accordance with withestablished establishedEOP EOP change change processes, processes, and and their their impact impact totothe thedesign designbasis basis capabilities capabilitiesof ofthe the unit unit evaluated evaluatedunder under10 10CFR CFR 50.59. The The plant plantTechnical Technical Specifications contain the limiting conditions Specifications contain conditions for for normal normal unitunit operations operations to to ensure ensurethatthatdesign designsafety safetyfeatures featuresare areavailable availableto to Page 33 of Page of5959

Clinton Power Station, Station, Unit Unit 11Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan respond to aa design basis accident and basis accident and direct thethe required required actions toto be taken taken whenwhen the the limiting conditions are not not met.

The result of The of the beyond-design-basis beyond-design-basis event may place the plant in a condition where itit cannot cannot comply comply with withcertain certainTechnical Technical Specifications, and, as such, such, may warrant warrant invocation invocationofof10 10CFR CFR 50.54(x) and/or SO.S4(x) and/or10 10CFR CFR 73.55(p) 73.5S(p) [Reference

[Reference 1]. 1].

Key Assumptions Key Assumptions

• Flood and seismic re-evaluations pursuant pursuantto tothe the10 10CFRCFR 50.54(f) letter SO.S4(f) letter of ofMarch March 12, 12, 2012 2012 areare not not completed completed and and therefore not therefore not assumed assumed in this submittal. As As the the rere--

evaluations are completed, appropriate appropriateissuesissues will will be be entered intointo thethecorrective correctiveaction actionsystem systemand andaddressed addressed on on schedule commensurate with a schedule with other otherlicensing licensingbasesbases changes.

• Additional Additional staffstaffresources resources are are assumed assumed to begin arriving at at hour 6 and fully staffed staffed by by 24 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

hours.

• Plant initial initial response responseisis the thesame sameas as Station StationBlackout Blackout(SBO) (SBO)

• Primary and secondary storage locations have not not been been selected; onceonce locations locations are are finalized finalized implementation implementation routes will be be defined.

defined.

Storage locations will be chosen

• Storage chosen in in order to support support the the event timeline.

• BWROG EOP BWROG EOPRevision Revision EPG/SAG EPG/SAGRev.3,Rev.3,containing containing items items such such as guidance as guidance to to allow allow early venting and to maintain maintain steamsteam driven injection injection equipment equipmentavailable available during during emergency emergency depressurization, is is approved approved and and implemented implemented in time to to support compliance compliance date. date.

• DC battery DC battery banks are available.

• ACAC and and DCDCdistribution distribution systems systems areare available.

available.

• Maximum environmental room temperatures for habitability or habitability orequipment equipmentavailability availabilityarearebased basedon onNUMARC NUMARC 87-00 [Reference 2] guidance if other other design design basis basis or industry guidance industry guidance is is not not available.

available.

• • No additional additional singlesingle failures failures of ofany any Structures, Structures, Systems, Systems, and and Components (SSCs)

Components (SSCs) areareassumed assumed(beyond (beyond the the initial initial failures failures that define that definethe theELAP/LUHS ELAP/LUHS scenario in in NEI 12-06)

NEI12-06)

[Reference 3].

References References Task Interface

1. Task Interface Agreement (TIA) 2004-04, "Acceptability (TIA) 2004-04, "Acceptability of of Proceduralized Departures Departures from fromTechnical Technical Specifications Specifications (TSs)Requirements (TSs) Requirements at the the Surry Surry Power PowerStation,"

Station,"(TAC (TACNos.Nos.

MC4331 and and MC4332)," dated September September 12, 12, 2006.

(Accession No.

(Accession No. ML060590273)

NUMARC87-00,

2. NUMARC 87-00,Revision Revision1,1,Guidelines Guidelines and and Technical Bases Bases for NUMARC Initiatives Addressing NUMARC Initiatives Addressing Station Blackout Blackout at atLight Light Water Reactors Water Reactors Page 440f59of 59

Clinton Power Station, Unit 11 Mitigation Clinton Mitigation Strategies Strategies Integrated IntegratedPlan Plan

3. Diverse

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

. _ - / - - - : , *c* '_----.-

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

andNEI and NEI 12-06, 12-06,are are being followed.

followed. Identify any Full conformance Full conformance with withJLD-ISG-2012-01 JLD-ISG-2012-01 and and NEINEI 12-06 is is deviations to JLD-ISG-2012- expected with expected with no no deviations.

deviations.

01 and 01 and NEI NEI 12-06.

Ref: JLD-ISG-2012-01 NEI 12-06 13.1 NEI12-0613.1 Provide a sequence of events Strategies that have a time constraint to be successful and identify any time should be identified with a technical basis and and a constraint required for justification provided that the time can reasonably be met success including the (for example, a walk (jor walk through through of ofdeployment).

deployment).

technical basis for the time constraint.

Describe in in detail detail inin this this section the technical basis for for the the Ref: NEI NEI 12-06 12-06 section 3.2.1.7 time constraint identified identified on on thethe sequence sequence of ofevents eventstimeline time line JLD-ISG-2012-01 sectionsection 2.1 2.1 Attachment IA.

Attachment lAo The timeline The timeline for the event is is included in Attachment 1A. 1A. The The technical bases bases for time time constraints constraintsare arediscussed discussed below.

below.

Issuance of Issuance of BWROG document NEDC-33771P, BWROG document NEDC-33771P, "GEH flGEH Evaluation of of FLEXImplementation FLEX Implementation Guidelines Rev Rev 1/1 1" [Reference 1] 1] on on 01/31/2013 did did not not allow allow sufficient sufficient time time to toperform performthe theanalysis analysis of of the the deviations deviationsbetweenbetweenExelon's Exelon'sengineering engineeringanalyses analysesand and the the analyses contained in the BWROG analyses contained BWROG document document prior prior toto commencing regulatory regulatory reviews reviews of ofthe theIntegrated IntegratedPlan. Plan.This This analysis analysis is is expected expected to to be be completed, completed, documented documented on on Attachment Attachment113, and prOVided lB, and provided to to the theNRC NRC in the the August August 2013 2013 6-month status status update.

update.

Note 11 Note The times to to complete completeactions actionsininthe theEventsEventsTimeline Timelineare arebased based on operating operating judgment,judgment, the theconceptual conceptualdesigns, designs, and and the current current supporting supporting analyses.

analyses. The final timeline will The final will be be time time validated validated once detailed detailed designsdesigns are are completed completed and and procedures proceduresare are developed. The The results results will be be provided provided in in aa future future 6-month 6-month update.

update.

The items below below provide provide aa technical technical basis basis forfor time timeconstraints constraints listed listed in in Attachment Attachment1A, lA,Sequence Sequence of ofEvents Events Timeline.

Timeline.

1.

1. SpentSpent Fuel Fuel Pool Pool Spent Fuel Fuel Pool (SFP) makeup isisnot (SFP) makeup not aa time time constraint constraint with with the theinitial initialcondition conditionofofMode Mode1 1@@100% 100%power, power, since since the worstworst case case fuel pool pool heat heat load load conditions conditionsonly only Page Page 55 of of5959

ClintonPower Clinton PowerStation, Unit 11Mitigation Station, Unit MitigationStrategies StrategiesIntegrated IntegratedPlan Plan exist during exist during aarefueling refueling outage.

outage.Under Undernon -outage non-outage conditions, the conditions, themaximum maximumSFP SFPheat loadisis --125 heatload ~12.5 million million Btu/hr. Loss Btu/hr. Loss ofofSFP SFP cooling cooling withwith this thisheat heatloadloadand andan an initial SFP temperature of 95-100°F results in a timeto initial 5FP temperature of 95 -100°F results in a time to boil boil of of 16 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, hours, and and -130

-130hourshoursto tothethetop topofofactiveactivefuel.fuel.

Therefore completing Therefore completing the the equipment equipmentline-up line-upfor for initiatingSFP initiating SFP makeup makeupat at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> into the event ensures 12 hours into the event ensures adequate adequatecooling cooling of ofthe thespent spentfuel fuelisismaintained.

maintained.

[Reference 2].

[Reference 2].

The worst The worst case case SFP load during SFP heat load during an an outage outage is is 40.0 40.0 Btu/hr. Loss of SFP cooling with this heat load and million Btu/hr.

million Loss of SFP cooling with this heat load and an initial an initial SFP SFP temperature temperature of of135° 135°F F results results in in aa time time to to boil of boil of 33.25 hours, and

.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, and 38.65 hours to 38.65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> to the the toptopof ofactive active fuel. With fuel. With thethe entire entire core corebeing beinglocated locatedininthe theSFP,SFP, manpowerresources manpower normally allocated resources normally allocated to to core core cooling cooling along with the along the Operations Operations outage shift manpower outage shift manpower can can be be allocated allocated to to aligning aligning SFP SFP makeup makeup which which ensures ensuresthe the system alignment alignment can can bebe established established withinwithin88hours. hours.

Initiation within Initiation within 88hours hours of event ensures adequate of the event adequate cooling of the spent fuel is is maintained maintained [Reference

[Reference 3]. 3].

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

2. Containment Containment AnalysisAnalysis As part As part of of the the implementation plan plan ofof NEI 12-06, the NE112-06, the BWROG performed BWROG performed evaluations of generic Boiling Boiling WaterWater Reactor (BWR) response to Extended Extended Loss loss of AC Power (ELAP)

(FLAP) events events to to demonstrate demonstrate the the efficacy efficacy of ofthetheFLEX FLEX strategies. BWROG report report NEDC -33771P Rev NEDC-33771P Rev 1, 1, "GEH IIGEH Evaluation of FLEX Evaluation Implementation Guidelines" FLEX Implementation Guidelines"

[Reference 1] provides the

[Reference the results results ofof those those evaluations evaluations for several representative for representative BWR BWR plant plantdesigns.

designs. Based Based upon the upon the initial results results of this evaluation, the BWROG evaluation, the BWROG has initiated has initiated additional analyses [Reference 5]

analyses [Reference 5] for the BWR/6 design BWR/6 design with with Mark III containments to to develop develop additional strategies for additional strategies for containment cooling that cooling that areare not currently included not included in in this this revision revision of of the the report.

These additional These additional strategies strategies specifically specifically address address actions actions necessaryto necessary to mitigate mitigate the suppression suppression pool pool heat-up during ELAP/lUHS during ELAP/ LUHSevents eventsthat that could could challenge challenge containment containment integrity. These strategies integrity. These strategies include suppressionpool suppression poolinventory addition /letdown, alternate inventory addition/letdown, alternate suppressionpool suppression poolcooling coolingmethods, methods, and/orand/or aligning aligning FLEX FLEX equipment to provide AC equipment AC power power to installed installed plant equipment for equipment for containment containment heat removal.

Page Page 66 of of 59 59

Clinton Power Clinton Power Station, Unit 11 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Several Several Clinton Clinton Modular Modular Accident Accident Analysis Analysis Program Program (MAAP)

(MAAP) [Reference

[Reference 4] 4] cases caseswere were run run toto analyze analyze methods methods of of containment containment heat removal, removal, including including containment suppression pool containment venting, suppression pool feed and bleed, and and suppression pool cooling cooling using FLEX strategy.

using aa FLEX strategy. The MAAP MAAP cases casesindicate indicate an an alternate suppression pool alternate suppression pool cooling cooling method method provides provides the the fewest fewest operational challenges challenges while providing margin to the while providing the primary primary containment design pressure limit.

containment design limit. UHSUHStemperature temperature was was conservatively conservatively designated designated at 91.4°F 91.4°F in in the the alternate alternate suppression pool cooling cases. cases.

The The folloWing following time constraints constraints were were used used as as MAAP MAAP input input parameters, parameters, or were were identified in in the the alternate suppression suppression pool cooling MAAP Case Case 14 14 results:

a.

a. RPV RPV pressure pressure is is reduced reduced to a pressure band band of 150-250 psig at a rate of 50 50°Fjhr

°F/hr starting at TO+1 To+1 hr. hr.

b. Suppression Pool Pool Heat Heat Capacity Capacity Temperature Temperature Limit (HCTL) isis reached reached in T4+3. To+3.55 hours6.365741e-4 days <br />0.0153 hours <br />9.093915e-5 weeks <br />2.09275e-5 months <br />. Emergency Depressurization is is not required since not required sinceRCIC RCIC is is being being used for level control during SBO used SBO conditions conditions per perCPSCPS 4402.01, EOP-6 PRIMARY 4402.01, EOP-6 PRIMARY CONTAINMENT CONTAINMENTCONTROL CONTROL

[Reference 6].

c. Suppression Pool Pool Makeup Makeup (SPMU) (SPMU) from from the upper containment containment pool pool is is designated designated to occur occur at at 180°F 180°F suppression pool suppression pooltemperature temperature to extend the time required to to establish establish the the suppression suppression pool pool cooling cooling lineup, and to allow allow timetime for foraaFLEXFLEX generator generator to to provide AC AC power power to to the the SPMU SPMU valves in the containment. This occurs containment. occurs at atTo+5 To+5 hrs.

hrs.

d. The suppression pool cooling lineup is is designated designated'to to occur at occur To+8 atTo+ provide the maximum 8 hrs to provide maximum time for for establishing a suppression pool pool cooling cooling lineuplineupusingusing aa FLEX strategy, while maintainingmaintaining acceptable acceptable containment parameter containment parametervalues. values. The service water water tube side flow fromthe flow from theFLEXFLEX pumppump was designated designated 2000gpm, at 2000 gpm,and andthe theshell shellsidesidesuppression suppression pool pool was designated at 1500 flow was 1500 gpm.gpm. The peak peak suppression pool suppression pool temperature temperature in inthis thiscasecase is is 213°F 213°F at at To+ -24.5 To+ hours. This

-24.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. This value is is well below the the suction temperature acceptable suction temperature established in in the the BWROG feasibility BWROG feasibility studystudy for forRCIC RCIC operation operation in in aa prolonged station blackout blackout [Reference

[Reference 7]. Peak 7]. Peak containmentpressure containment pressure is is 25 25 psia psia at at To+

To+ -41 hours,

-41 hours, compared to compared to containment containmentdesign design pressure pressure of of29.7 29.7 psia.

psia.

e. Suppression Suppression pool makeup from from an an external externalsource source Page Page 77 of of5959

Power Station, Unit Clinton Power Unit 11 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan was designated designated to to maintain maintain level level between between the thevalues values of 19.5 ft. and 22.3 ft. The The first first injection injection of of makeup makeup occurs occurs at atTo+16.8 To+16.8 hrs. hrs.

3. RCIC Room Analysis RCIC Room Analysis The purpose purpose of ofthis thisGOTHIC GOTHIC analysis [Reference [Reference 8] 8] was was toto demonstrate demonstratethe thetransient transient RCIC RCICPump PumpRoom, Room,RCIC RCIC Instrument InstrumentRoom, Room, and and Access Aisle temperature Access Aisle temperature response during during an an ELAP/LUHS.

ELAP/LUHS. The The temperatures temperatures in in these areas were reviewed areas were reviewed both both with and without without compensatory actions actions to to provide additional cooling cooling to the pump pump room.

room.

The analysis shows that analysis shows that with withgland glandseal seal steam steamleakage leakage and no compensatory compensatory actions, actions, the theRCIC Instrument RCIC Instrument Room exceeds its Room exceeds its temperature temperature limit limitofof145°F 145°Fat at4242hours hours while while the theRCIC Pump Room RCIC Pump Room is is maintained maintained below below145°F145°F indefinitely.

indefinitely. Opening Opening the the doors doorsat at4141hours hoursandand30 30 minutes minutes maintains maintainsthe theRCIC RCICPumpPumpRoom Roomand andRCIC RCIC Instrument Room Room within within their their temperature temperature limit limitof of145°F 145°F without the without the need need for for further furthercompensatory compensatoryaction. action. The The timeline timeline reflects reflects aamuch much earlier earliertimetime(To+ (To+ 66 hrs) to to accomplish this simple but but critical critical task.

task.

FLEXwill FLEX willprovide provide aacompensatory compensatory action action to supply supply cooling to the room room usingusing a portable portable blowerblowerand and ducting ducting to move air through the the security security doordoor between between the the Auxiliary and Auxiliary and Turbine Turbine Buildings Buildings and and into intothetheRCIC RCIC room.

room.

The flow rate The rate assumed assumed in in the the analysis analysis was 9500 cfm. The The also show results also show that that when this compensatory compensatory action action isis completed at at To+59.5 To+59.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />,hours, the the room temperature temperature drops sharply and is maintainedmaintained at at an an acceptable acceptable temperature indefinitely.

4. Battery Coping Study The coping study performed The performed by Sargent && Lundy bySargent Lundy

[Reference 9] used used ELMS-DC ELMS-DC to to analyze the the Division Division11 and Division and Division 2 battery battery responses responses to to a station blackout.

The battery The battery of interest in in the event event timeline timeline isis thethe Division 11 battery.

Division battery. The The study concluded that that byby performing the performing the load loadshedding sheddingspecified specifiedininprocedure procedureCPS CPS 4200.01C002 DC LOAD SHEDDING 4200.01C002 DC LOAD SHEDDING DURING A SBO DURING A SBO

[Reference 10],

[Reference 10),the the battery battery can can perform perform its function function for for66 hours. The FLEX strategy for FLEX strategy for ensuring ensuring DC DC power powerto toRCIC, RCIC, SRVsolenoids, SRV solenoids,and andvital vitalinstrumentation instrumentation will willuse use aa55 hour hour required deployment deploymenttime timetotoensure ensureDC DCMCCMCC 1A 1A isis supplied from its battery supplied battery charger charger before before the the Division Division 11 Battery is exhausted.

5. OP-CL-102-106-1001 OPERATOR OP-CL-102-106-1001 OPERATORRESPONSE RESPONSE TIME TIME PROGRAMAT PROGRAM ATCPS, CPS,Attachment Attachment 1, CPS Master List of CPS Master of Page 8 of 59

Clinton Power Station, Unit 1 Mitigation Strategies Integrated Plan Operator Response Response Times Times[Reference

[Reference11]. 11]. Validation Validation of time critical critical and and time time sensitive sensitive tasks tasks listed listed below beloware are pending.

a. Section 2, 2, Time Sensitive Sensitive Actions Actions--TSA TSA 17 - Required Required Action: Bypass Action: Bypasshigh highsteam steam tunnel tunnel isolation before isolation of of RCIC RCIC on on high high Main Main Steam Steam Tunnel temperature occurs.

temperature occurs.

b. Section 1, Time Critical Actions

b. Actions -- TCATCA 3 - Control level level and pressure and pressure per procedures

c. Section 1,

c. 1, Time Time Critical CriticalActions Actions- -TCA TCA44--IfIfSBO SBO isis anticipated to last last greater greater than than one one hour hour then then initiate and initiate and complete complete within within11hour hourCPS CPS 4200.01C002, DC 4200.01C002, DC Load Shedding Shedding During DuringAASBO SBO SRVPneumatic

6. SRV

6. Pneumatic Supply Each SRV Each SRVisisprovided providedwithwith an an air air accumulator accumulator located located in in the drywell capable capable of of providing providing for for a total total of thirty-seven (37) seven (37) lifts lifts without without backup.

backup. Additionally, Additionally, nine nine (9)

(9) ofof the SRVs SRVs are arecapable capableof ofbeing beingsupplied supplied withwith actuating air from backup backup air bottles bottles located located in in the the Auxiliary Auxiliary Building, Building, providing enough air for an additional two-hundred two-hundred(200) (200) lifts [Reference

[Reference 12]. 12]. Since Since the the cooldown cooldownbegins beginsatatTo+ To+ 11 hr, lining up up the the backup backup air airbottles bottlesatatTo+ To+ 22 hrs hrs will will be be needed to ensure a pneumatic supply is maintained for for controlling RPV controlling pressure in RPV pressure in the the specified specified band.

band. Providing Providing FLEXcapability FLEX capability to to recharge ADS ADS backup air bottlesbottlesatatTo+ To+

24 hrs wilt will ensure ensure aa long long term termsupply supplyofofSRV SRV actuating actuating air.

7. Decision to Initiate

7. InitiateELAP/LUHS ELAP/LUHS Actions Actions The one (1) (1) hour time constraint constraint placed placed on on declaring declaring thatthat the the station stationisisininan anELAP/LUHS ELAP/LUHS isisbased based onon the time time needed needed to todeploy deploybeyond beyonddesign designbasisbasisFLEX equipment.

FLEX equipment.

The deployment deploymentof ofthe theFLEX generator and pump FLEX generator pump require require time and resources, resources, and andaadelay delayininbeginning beginning thethe deployment deployment task task could could impact the the timeline.

timeline.

References References

1. BWROG report NEDC-BWROG report NEDC- 33771P 33771P Rev Rev 1,1, "GEH IIGEH Evaluation EvaluationofofFLEX FLEX Implementation Implementation Guidelines Guidelines Rev Rev 1"1"

2. EC EVAL 382149, C1R13 EC EVAL382149, C1R13 Decay Heat Heat

3. USAR Section 9.1.3.3 USAR Section 9.1.3.3

4. CL-MISC-009 CL-MISC-009 Rev Rev 1, 1, MAAP MAAP Analysis Analysis #C467130029-10881

1. C467130029-10881

5. BWROG report NEDC-BWROG report NEDC- 33771P 33771PRev Rev1,1,"GEH IIGEHEvaluation Evaluationofof FLEX FLEX Implementation ImplementationGuidelines GuidelinesRev Rev 1"1" Submittal Submittal Letter, Letter,Dated Dated January January 31,31, 2013 2013 Page 9 of of 5959

Clinton Power Station, Unit Unit 11Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan

6. CPS 4402.01, CPS 4402.01, EOP-6 EOP-6PRIMARY PRIMARYCONTAINMENT CONTAINMENT CONTROL, CONTROL, Rev 29 0000-0143-0382-R1, DRF

7. 0000-0143-0382-R1, DRF 0000-0143-0380, 0000-0143-0380,"BWROG "BWROGRCIC RCIC System Operation System Operation in Prolonged Station Blackout - Feasibility Feasibility Study" S&LCalculation

8. S&L Calculation2013-01301, 2013-01301, Revision Revision 0, "Transient "Transient Analysis Analysis of RCIC Pump Room RCtC Pump Room forfor Extended ExtendedLoss Loss of ofA-C A-C Power" Power"

9. ECEC 391824 391824 FLEX Battery Coping Study FLEX Battery Study CPS 4200.01C002

10. CPS 4200.010002 DC DCLOAD LOADSHEDDING SHEDDING DURINGDURING A 5130, SBO, Rev 5 OP-CL-102-106-1001, Rev

11. OP-CL-l02-106-1001, Rev001, 001,OPERATOR OPERATORRESPONSERESPONSETIME TIME PROGRAM AT AT CPS Calc EPU-T0903

12. Calc EPU-T0903 Rev Rev00(GE-NE-A22-00110-59-01 (GE-NE-A22-00110-59-01 Clinton Power Station Extended Extended Power Power Uprate, Uprate,Task Task T0903:

T0903: Station Station Blackout) strategies will Identify how strategies will Describe how the the strategies strategies willwillbebedeployed deployedininall allmodes.

modes.

be deployed in all modes.

Deployment of Deployment of FLEX FLEX isisexpected expectedfor for all all modes modes of of operation.

Ref: NEI NEI 12-06 12-06 section section 13.1.6 13.1.6 Transportation routes will be be developed from the the equipment equipment storage area to thethe FLEX staging areas.

FLEX staging areas. An administrative administrative program will be be developed developed to to ensure ensure pathways pathways remain remain clear clearor or compensatory actions will be implemented implemented to to ensure ensure allall can be strategies can be deployed deployed during all modes of operation. operation. This This administrative program administrative program will willalso alsoensure ensurethe thestrategies strategiescan can bebe implemented in implemented in all all modes modes by by maintaining maintainingthe theportable portableFLEXFLEX equipment available equipment available to to be be deployed deployed during duringallallmodes.

modes.

Identification of Identification ofstorage storage locations locations andand creation creation of of the the administrative program administrative program are are open open items.

items. Closure Closure of ofthese these items items will be be documented documented in in aa 6-month 6-month update.

update.

Provide a milestone The The dates dates specifically specifically required required by the order are are obligated obligated or or schedule. This schedule schedule. committed committed dates. Other dates dates. Other dates areare planned planned datesdates subject subject to to should include: change.

change. Updates Updates will will be be provided provided in in the the periodic (six periodic (six

• Modifications timeline timeline month) status reports.

month) status reports.

oo Phase Phase 11 Modifications Exelon Generation Company, Exelon Company, LLC (Exelon) fully LLC (Exelon) fully expects to to meet meet oo Phase Phase2 2 the site implementation/compliance implementation/compliancedates datesprovided providedininOrder OrderEA- EA-Modifications12-049 with no exceptions. Any changes changes or or additions additions to the the oo Phase Phase 33 planned interim milestone dates will be planned be provided in a future Modifications 6-month update.

update.

• Procedure Procedure guidance guidance See attached See attached milestone schedule (Attachment (Attachment2). 2).

development complete complete o Strategies Strategies o Maintenance

• Storage plan (reasonable (reasonable protection)

Page 10 of of 59

Clinton Clinton Power PowerStation, Station,Unit Unit11Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlanPlan

• • Staffing Staffinganalysis analysis completion completion

• • FLEX FLEX equipment equipment acquisition timeline acquisition timeline Training completion

• • Training completion for for the strategies the strategies

• • Regional Regional Response

Response

Centers operational Centers operational Ref: NEI Ref: 12R06section NEI12-06 13.1 section13.1 Identify how Identify how the the Provide Provide a description of of the programmatic program,mafic controls programmatic controls programmatic controls will will equipment protection, storage storage and and deployment deploym,ent and and be met.

be met. equipment quality.

quality. See See section section 11 11 in in NEI 12-06. Storage NEI12-06. Storage of of equipment, 11.3, 11.3, will will bebe documented documentedininlater latersections sectionsofofthisthis Ref: NEI 12R06 section NEI12-06 section11 11 template andand needneed notnot be be included includedininthisthissection.

section.

JLD-ISGR2012-01 JLD-ISG-2012- section 6.0 01 section See section See section 6.06.0 ofof JLD-ISG-2012-01.

JLD-ISG-2012-01, Clinton will will implement implementan anadministrative administrativeprogram programfor for FLEX FLEXtoto establish responsibilities, and and testing testing and and maintenance maintenance requirements. AAplant plantsystem systemdesignation designationwillwillbebeassigned assigned to to FLEX equipmentwhich FLEX equipment which requires requires configuration configuration controls associated with systems.

associated with systems. This This will will establish establish responsibilities, responsibilities, maintenance and and testing requirements for for all all components components associated with FLEX.

associated with Unique identification FLEX. Unique identification numbers numbers will willbe be assigned toto all all components componentsadded addedtotothe FLEX the FLEX plant plantsystem.

system.

Equipment associated associated with with these strategies will will be be procured procured as as commercial equipment with design, storage, maintenance, commercial maintenance, testing, and and configuration configurationcontrol controlasasoutlined outlinedininJLD-ISG-2012-01 JLO-ISG-2012-01 section 66 and NEI 12-06 section and NE112-06 section 11. 11. Installed structures, systems systems and components pursuant and pursuant to to 10CFR50.63(a) 10CFR50.63(a) will will continue continue to meet the meet the augmented augmentedquality qualityguidelines gUidelinesofofRegulatory RegulatoryGuide Guide 1.155, Station Blackout.

1.155, Station Blackout. StandardStandard industry preventive maintenance (PM) templates will will be be developed developed to toestablish establish maintenance and and testing frequencies based on type of of equipment and will be within EPRI guidelines. Testing equipment and will be within EPRI guidelines. Testing procedures procedures will be developed based based on the industry industry PMPM templates templates and and Exelon standards.

Exelon standards.

Describe training plan List training plansplans forfor affected organizations or describe the for training development plan for Training materials Training materials for for FLEX willbebedeveloped FLEX will developed forfor all all station station staff staff involved in implementing involved implementing FLEX strategies. For FLEX strategies. For accredited accredited training programs, the training the Systematic Systematic Approach Approach to to Training, Training, SAT, SAT, will be used be usedtoto determine determine training training needs.

needs. ForFor other other station station staff, staft aa training overview training overviewwill willbebedeveloped developedper perchange changemanagement management plan.

plan.

Page Page 11 11 of of 59

Clinton Clinton Power Power Station, Station, Unit 1 Mitigation Strategies Integrated Plan Describe Describe Regional Regional Response Clintonhas Clinton hascontractual contractual agreements agreements in in place with the the Strategic Strategic Center plan Center plan Alliance for FLEX Alliance Emergency Response FLEX Emergency Response(SAFER).

(SAFER).

The industry The industry will willestablish establish two two (2) Regional Response (2) Regional Response Centers (RRC)totosupport (RRC) support utilities utilities during during beyond beyond design design basis basis events. Each events. Each RRC willhold RRC will holdfive five(5)(5)sets sets ofof equipment, equipment, four four (4)

(4) of of which will which will be able able toto be be fully fully deployed deployed when when requested, requested, the the fifth fifth set will set will have have equipment equipment in a maintenance maintenance cycle. cycle. Equipment Equipmentwill will be moved be moved from from anan RRC RRC to to a local Assembly Area, established by by the SAFER the SAFER team teamandandthethe utility.

utility. Communications Communications will will be established between established between the theaffected affectednuclear nuclearsite siteand andthe theSAFER SAFER team and team and required equipment equipment moved moved to to the the site site as as needed. First needed. First arriving equipment, equipment, as as established during development of the nuclear development nuclear site's playbook, will be be delivered delivered toto the site within 24 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the initial initial request.

request.

Notes:

Exelon Generation Exelon Generation Company, LLC (Exelon)has LLC (Exelon) hasnotnotfinalized finalized the the engineering designs for compliance compliance with NRC with NRCOrder OrderEA-12-049.

EA-12-049.Detailed Detaileddesigns designsbased basedon on the the current conceptual conceptual designs designswillwill be be developed to determine determine the the final final plan plan and and associated associated mitigating mitigating strategies.

strategies. Analysis Analysis willwill be be performed toto validate validate that thatthe theplant plantmodifications, modifications,selected selectedequipment, equipment,and andidentified identifiedmitigating mitigating strategy can can satisfy satisfy the the safety safetyfunction functionrequirements requirementsofofNEI 12-06. Once NEI12-06. Oncethesethesedesigns designsand and strategies have mitigating strategies have been beenfully fully developed, developed,ExelonExelon will will update updatethe theintegrated integratedplan planfor forClinton Clinton during a scheduled 6-month 6-month update.

update.This Thisupdate updatewillwillinclude includeany anychanges changestotothe theinitial initialdesigns designsasas submitted in submitted in the the February February28, 28, 2013 2013 Integrated IntegratedPlan.

Plan.

Page Page 12 12ofof5959

Clinton Power Clinton Power Station, Station, Unit 1 Mitigation Strategies Integrated Integrated Plan Plan Maintain Core Cooling Maintain Determine Baseline Determine Baseline coping capability with installed coping coping'l modifications not not including including FLEX modifications, utilizing methods described in Table 3-1 of NEI 12-06:

FLEX

• • RCIC/HPCI/IC RCICIHPCI/IC

• • Depressurize RPV for injection with portable Depressurize portable injection injectionsource source

• • Sustained water source Sustained BWR Installed Equipment Phase 1:

BWR 1:

Provide Provide aa general description of general description of the coping strategies strategies using using installed installed equipment including modifications modifications that that are proposed to to maintain core core cooling. (RCICIHPCIIIC) and strategy(ies) utilized Identify methods (RCICIHPCIIIC) cooling. Identify utilized to achieve achieve this coping time.

this coping Mode 1, 2, and 3 At To Station Blackout To in a Station Blackout (SBO)(SBO)eventevent the the reactor will scram on a load reject will scram reject signal.

signal. Following Followingaareactor reactor

scram, scram, steamsteam generation generation will will continue at a reduced rate due due toto core core fission fission product decay heat. Since Since the the reactor vessel is is isolated, isolated,and andthe thefeedwater feedwatersupply supply unavailable, unavailable, Safety Safety Relief ReliefValves Valves (SRVs)

(SRVs)willwill automatically (or remote manually) manually) maintainmaintain vessel vessel pressure within desired limits. The The water water levellevelinin the the reactor vessel will drop due to continued steam steam generation generationby bydecay decayheat heat[Reference

[Reference1]. 1].Upon Uponreaching reaching Reactor Vessel Water Level Vessel Water - Low Low, Level-Low Low, LevelLevel 22 thethe RCtC RCICSystem Systemwill willbe be initiated initiated automatically [Reference automatically [Reference 2). RCIC 2]. RCICcan canalso alsobe beinitiated initiatedmanually manuallyfrom fromthe the Main Main Control Control Room Room or or from from thethe Remote Remote Shutdown ShutdownPanel. Panel.

Sixteen (16) SRVs SRVs are areinstalled installed on on thethe main main steam lines lines inside inside thethedrywell.

drywell. The The valves valves can can be beactuated actuatedinin two ways: they two ways: they will will relieve relievepressure pressureby byaaNuclear NuclearSystem SystemProtection ProtectionSystemSystem(NSPS) (NSPS) pressure pressure transmitter transmitter trip unit actuation with Class and trip Class 1E lE DC DCpower power (relief (relief mode) mode) or by mechanical actuation actuation without withoutpower power (safety mode). In In addition addition to tothe therelief reliefand andsafety safetymodes, modes,seven seven(7) (7)ofofthe theSRVsSRVscancan bebeactuated actuatedby bythe the Automatic Depressurization Depressurization System System (ADS) (ADS) logic through NSPS. NSPS. The suppression suppression pool poolprovides providesaaheat heatsink sink for steam relieved relieved by by these thesevalves.

valves.SRV SRV operation may be controlled controlled manually manually from the control control roomroom to to hold the desired desired reactor reactor pressure pressure [Reference

[Reference 3]. 3]. Each EachSRVSRV can can bebe actuated actuated from fromone oneof oftwo twoinstalled installedDC DC solenoid valves which open to supply supply pneumatic pneumatic pressure pressure to tothe thevalve valveoperating operatingpiston.

piston.

Each Each SRVSRVisisprovided providedwith withan anair airaccumulator accumulator located located in the drywell drywell capable capableof ofproviding providingfor foraatotal totalofof thirty-thirty-seven seven (37) lifts lifts without withoutbackup.

backup. Additionally, Additionally,nine nine(9) (9)ofofthe theSRVs SRVsare arecapable capableofofbeing beingsupplied supplied with actuating actuating air air from one of of two two banks banks of ofbackup backup air air bottles bottleslocated locatedininthe theAuxiliary Auxiliary Building.

Building. TheseThese bottles are are sized to provide for a minimum of of an an additional additional one-hundred one-hundred (100) (100)lifts liftsper perbank bank[Reference

[Reference 4].

4]. The backup backup air air bottles bottles cancan bebe lined lined up upmanually manuallyininPhase Phase1,1,or orremotely remotelyduring duringPhase Phase2 2after after thethe FLEX FLEX generator generatorhas has been beenplaced placedin inservice.

service.

The NSPS The NSPS power supply system system is is designed designed to to provide adequate adequate uninterrupted uninterruptedpower powertotoallallthethe NSPS NSPS loads loads during all modes of operation including including abnormal and accident conditions [Reference 5]. SRV and accident conditions [Reference 5]. SRV actuation actuation instrumentation instrumentationisispowered poweredfrom fromthe theDivision Division11and andDivision Division22NSPS NSPS sub-systems sub-systems[Reference

[Reference6]. 6].

Each sub-system Each SUb-system is is capable capable of of independently independently actuating actuating the thelogic logic that thatsupplies supplies Class Class 1ElE DC DC power to one one of of twosolenoids two solenoids to to each each SRV.SRV. Additionally, Additionally, all all of of the the essential essential parameter parameterinstruments instruments needed neededfor forthethecore core cooling function are cooling are powered powered from fromthe theNSPSNSPS system system and and areare available available in in Phase Phase 11 [Reference

[Reference 7]. 7].

The Class The Class 1E lE DCDC power system system supplies 125 125 VDC VDC power powerto tounit unitClass Class 1E lE loads.

loads. The The primary primarypowerpowersources sources are are battery battery chargers.

chargers. The The system system includes includesbatteries, batteries,battery batterychargers, chargers,motormotorcontrol controlcenters, centers,and and DCDC

' 1Coping Coping modifications modifications consist consist of ofmodifications modifications installed installedto toincrease increaseinitial initialcoping copingtime, time,i.e.,

i.e.,generators generatorstoto preserve preservevitalvitalinstruments instrumentsor orincrease increaseoperating operatingtime timeononbattery batterypowered poweredequipment.

equipment.

Page Page 13 13 of of5959

ClintonPower Clinton Power Station, Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan distribution panels.

distribution panels. The The system system is is divided divided intointo four four divisions, divisions,eacheachwith withitsitsown ownindependent independent distribution network, battery, network, battery, battery charger, and and redundant load group. A swing battery chargerisis also redundant load group. A swing battery charger also part partofofthe the system that system that can be connected connected to tothe the125125VDCVDC buses for supplying backup power during periods when when the the normal battery normal battery charger chargerfor forthe theDivision Division1,1,22or or44bus busisisbeing beingmaintained maintained [Reference

[Reference 81.81.The TheRCICRCICsystem system valves required valves required for automatic automatic and and manual manualoperation, operation,one onesolenoid solenoidfor each for each ofof the the 1616SRVs, SRVs,and andananNSPS NSPS inverter are all inverter all supplied supplied from from thetheDivision Division 11Class Class 1E lE DC power system.

DC power DuringPhase During Phase 1, 1, RPV RPVmakeup makeupisisprovided provided from from RCIC RCICwith withsuction suctionfrom fromthe the suppression suppression pool, poot andandRPVRPV pressure control is pressure is provided by by the the SRVs.

SRVs. Since these these areare loads loadson onthetheDivision Division 11 battery, battery,shedding sheddingofofnon-non-essential loads essential loads on on thethe battery battery is is performed performed to to extend extendthe theDCDC coping coping time to to aa minimum minimum of of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />

[Reference 9].

[Reference 9].

AA gradual gradual cooldown cooldown of ofthe theReactor ReactorPressure PressureVesselVessel(RPV) (RPV) will will be beperformed performedwith with SRVs, SRVs,and andRPVRPVpressure pressure will be controlled between will between approximately approximately150 150andand 250 250 psig.

psig. RPV RPV makeup will continue continue to to be be provided provided from RCIC from until RPV RCIC until RPVpressure pressurerequires requiresaatransition transition to to Phase Phase 22methods.

methods. Guidance Guidance will will bebe provided providedto toopen open the RCIC the RCICpumppumproom roomdoors doorsand andprovide provideair airflow flowto to maintain maintain thethe habitable conditions in in the the room room

[Reference 10].

[Reference 10].

Mode 44 and Mode and 5 5 When in When in Cold ColdShutdown Shutdown or or Refueling, Refueling,many manyvariables variables existexist which which impact impact thethe ability ability toto cool cool the the core. In In the event of an ELAP/UHS during these Modes, installed event of an ELAP/UHS during these Modes, installed plant systems cannot plant systems cannot be relied upon to cool the to cool the core, thus transition transition to to Phase Phase22will will begin begin immediately.

immediately. All All efforts efforts will will be made made to to expeditiously expeditiously provide provide cooling and minimize core cooling minimize heat-upheat-up and repressurization.

repressurization. Exelon Exelonhas hasaaprogram programininplace place[Reference

[Reference11] 11]toto determine the determine the time timeto toboil boil for for all all conditions conditions duringduring shutdown shutdown periods.

periods. ThisThis time timewillwill be used used toto determine the time time required required to tocomplete completetransition transitiontotoPhase Phase 2.2.

To accommodate To accommodate the theactivities activitiesof ofRPV RPV disassembly and refueling, water waterlevels levels inin the the RPV RPV and the the reactor reactor cavity are cavity are often changed. The The most mostlimiting limiting condition is the case case in in which the reactor reactor headheadisis removed removed and water waterlevel levelin in the theRPVRPV is is at at or or below belowthe theflange.

flange.IfIfan anELAP/LUHS ELAP/LUHS occurs occurs during during this this condition condition then then (depending on the the timetime after aftershutdown) shutdown)boiling boilingininthe thecore coremay mayoccur occurquite quiterapidly.

rapidly.

Deploying Deploying and and implementing implementing portable portableFLEX pumps to FLEX pumps to supply injection flow must must commence commenceimmediately immediately from the time of of the the event.

event. This This should should be be plausible plausible because because moremorepersonnel personnelare areon onsite siteduring duringoutages outages to provide provide thethe necessary necessaryresources.

resources.Strategies Strategies forformakeup makeup water water include includedeploying deploying a FLEX a FLEXpumppumpto totake take suction from from the theUHS UHS as described described in in the thePhase Phase22Core CoreCooling Coolingsection.

section.

Guidance will be provided will be provided to ensure that thatsufficient sufficient area areaisisavailable available forfor deployment deploymentand andthat thathaul haulpaths paths remain accessible accessible without without interference interferencefrom from outage outageequipment equipmentduringduringrefueling refuelingoutages.

outages.

References References 1.

1. Clinton Clinton UFSAR Section 5.4.6.1 UFSAR Section 5.4.6.1 2.

2. CPS Technical Specifications Table 3.3.5.2-1, CPS Technical Specifications 3.3.5.2-1, Function Function11 3.

3. Clinton Clinton UFSAR Section 7.3.1.1.1.4.1 UFSAR Section 7.3.1.1.1.4.1 4.

4. Calc Calc EPU-T0903 EPU-T0903 Rev Rev00 (GE-NE-A22-00110-59-01 (GE-NE-A22-00110-59-01Clinton ClintonPower PowerStation Station Extended Power PowerUprate, Uprate,Task Task T0903: Station Blackout)

T0903: Station Blackout)

5. Clinton ClintonUFSAR UFSAR Section Section 8.1.4.1 8.1.4.1

6. CPS Drawing E02-1RP99, CPS Drawing E02-1RP99,Sheet Sheet004, 004,Rev Rev 0, 0, REACTOR REACTOR PROTECTION PROTECTION SYSTEM SYSTEM(RP) (RP)REACTOR REACTOR PROTECTION SYSTEM (NSPS)

PROTECTION SYSTEM (NSPS) (lC71-1050) (1071-1050)

7. CPSCPS Drawing DrawingE02-1LP99, E02-1LP99,Sheet Sheet 004, 004, Rev RevP, LOW P, LOW PRESSURE PRESSURECORE CORESPRAY, SPRAY, E02-1RP99, E02-1RP99,Sheet Sheet013, 013,Rev Rev L, L, REACTOR REACTOR PROTECTION SYSTEM SYSTEM (RP) REACTOR REACTOR PROTECTIONPROTECTION SYSTEMSYSTEM (NSPS)(NSPS) (lC71-1050)

(1C71-1050)

8. Clinton ClintonUFSAR UFSAR Section Section 8.1.3.4 8.1.3.4 9.

9. EC EC 391824, 391824, Rev Rev 0, 0, FLEX FLEX Battery BatteryCopin Coping g Study Study 10.

10. S&L S&L Calculation Calculation 2013-01301, 2013-01301,Revision Revision0, 0,11332-295, 11332-295,Transient TransientAnalysis AnalysisofofRCIC RCICPumpPumpRoom Roomfor for Page Page14 14ofof5959

Clinton Power Power Station, Unit 11 Mitigation Station, Unit Mitigation Strategies StrategiesIntegrated IntegratedPlanPlan Extended Extended Loss Loss of of A-C Power Power

11. OU-AA-103, Shutdown Safety Management OU-AA-l03, Shutdown ManagementProgram, Program,Rev Rev1212 Details:

Details:

Provide a brief brief Confirm that procedure/guidance procedure/guidance exists existsororwill willbebedeveloped developedtoto description of description of Procedures Procedures support support implementation implementation Strategies /I Guidelines

/I Strategies Guidelines Clinton will useuse the industry industry developed developed guidance guidance from the the Owners Owners Groups, EPRI EPRI and and NEINEITask Taskteamteamto to develop develop site specific procedures procedures or or guidelines to to address address the criteria criteria ininNEI NEI 12-06, 12-06. These These procedures procedures and/or and/or guidelines will support supportthe theexisting existingsymptom symptombasedbasedcommand commandand and control control strategies strategies in in the thecurrent currentEOPs.

EOPs.

modifications Identify modifications List List modifications modifications None None Key Reactor Parameters Parameters List instrumentation credited credited for this this coping coping evaluation.

evaluation.

Wide Range Range RPV level Level Division 1 ATMs 1821-N691A, lB21-N691A, 1B21-N691E lB21-N691E RPV Pressure Division 1 ATMs 1621-N697A, 1B21-N697E, ATMs lB21-N697A, 1821-N678A (wide lB21-N697E, lB21-N678A range)

Clinton's evaluation of of the the FLEX strategy may FLEX strategy may identify identify additional additional parameters that are are needed in order order to to support support key key actions actions identified identifiedinin the plant plant procedures/guidance procedures/guidance or to indicate indicate imminent imminentor oractual actual core core damage (NEI 12-06 Rev.

(NEI 12-06 Rev.00Section Section3.2.1.10) 3.2.1.10) and and any any differences differences will bebe provided in in aa future future 6-month update following identification.

identification.

Notes:

Exelon Generation Exelon Generation Company, Company, LLC (Exelon)has LLC (Exelon) hasnot notfinalized finalizedthe the engineering engineering designs for compliance compliance with with NRCOrder NRC OrderEA-12-049.

EA-12-049.Detailed Detaileddesigns designsbased basedon onthe the current current conceptual conceptual designs designs will will be be developed developedto to determine the determine the final final plan plan and and associated associated mitigating mitigating strategies.

strategies. Analysis AnalysiS willwill be performed performed to to validate validate that that the plant plant modifications, modifications, selected selected equipment, equipment,and andidentified identifiedmitigating mitigatingstrategy strategycancansatisfy satisfythe thesafety safety function requirements requirementsof ofNEI 12-06. Once these NEI12-06. these designs designs and andmitigating mitigatingstrategies strategieshave havebeen beenfully fully developed, Exelon willupdate Exelon will update the the integrated integrated planplan for for Clinton Clinton during during aa scheduled scheduled 6-month 6-monthupdate.

update.This This update will include include any any changes changes toto the initial initial designs designs as submitted in in the the February February 28,28, 2013 2013 Integrated Integrated Plan.

Page 15 of 59

Clinton Power Clinton Power Station, Station, Unit Unit 1 Mitigation Mitigation Strategies Integrated Plan Maintain Core Cooling Maintain Cooling BWR Portable BWR Portable Equipment Phase 2:

Provide aa general Provide general description description of of the the coping coping strategies strategies using using on-site on-siteportable portableequipment equipmentincluding including modifications that are proposed modifications proposed to maintain core cooling. Identify Identifymethods methods(RCIC/HPC11lG}

(RC/CIHPC/I/C) and strategy(ies) utilized to strategy(ies) to achieve achieve thisthis coping coping time.

time.

During Phase During Phase 2,2, high high pressure pressure RPV RPVmakeup makeup isis provided provided fromfrom RCIC, RClC, andand RPV RPVpressure pressure control control is provided provided from RCIC from RCIC andandthe the SRVs.

SRVs.AApre-staged pre-staged480 480VAC VACgenerator generatorwill willbe belined linedup uptoto the the Division Division 1 AC ACdistribution distribution system to system to repower repower the theDivision Division11battery batterycharger chargerand andenable enablethe thecontinued continued useuseof of RCIC, RCIC,SRVs, SRVs,and andvital vital instrumentation. AAFLEX instrumentation. FLEX airaircompressor compressor will will be be staged staged to to make make up upto tothe theADSADS backup backup air air bottles, bottles,ififrequired.

required.

Alternatively, aa separate Alternatively, separate generator generatorcan can bebelined linedup uptotothe theswing swingbattery batterycharger chargertotomaintain maintain thetheDivision Division1 1 DC bus.

DC bus. [Reference

[Reference 1]

To accomplish To accomplish low pressure pressure RPV makeup when RPV makeup when RCIC RCIC isisno no longer longer available, available, external water waterconnections connectionswill will be be hard-piped to a location that supports connection to the modified Low Pressure to a location that supports connection to the modified Low Pressure Core Spray (LPCS) Core Spray (LPCS)

[Reference 2] or alternatively alternativelythe theResidual ResidualHeatHeatRemoval Removal(RHR) (RHR) C C [Reference 31 injection header.

3] injection header. AApre- pre-staged section section ofof fire fire hose hose will allow the will allow the final final connection from the the external external water watersupply supplyto tothe theinjection injection header. The header. The injection injection valves valves for these two two systems systems are located outside the primary primary containment containmentand and can can be be operated manually operated manuallywith with the thehandwheel handwheelororelectrically electricallyvia viathe theFLEX generator.

FLEX generator.

RPVpressure RPV pressure will willneed needto to be be further further reduced reduced to toapproximately approximately50 50psig psigwith withSRVs SRVs to achieve the the flow flow rate rate necessary from the the external external water waterconnection.

connection.The Thesupply supply to to the theexternal externalwaterwaterconnections connectionsisisdescribed describedinin the Safety Safety Function Function Support Phase 22 section. section. The Theexternal externalconnection connectionwill willbe becapable capableofofmeeting meetingthe thedecay decay heat boil-off boil-offrate, rate, plus plus the theassumed assumed systemsystem leakage leakage from from reactor reactorrecirculation recirculationpump pumpseals.

seals.

Core cooling Core cooling can can bebe maintained maintained indefinitely indefinitely with withRCIC RCIC first, then then thethe portable portablediesel dieseldriven drivenpump(s) pump(s)with with SRVs controlling RPV SRVs controlling RPV pressure. [Reference

[Reference 4] 4]

References References

1. Clinton Clinton UFSAR UFSAR Section 8.1.3.4 8.1.3.4 2.

2. CPS Drawing DrawingM05-1073, M05-1073, Sheet Sheet001,001, RevRevAG,AG, LOW-PRESSURE LOW-PRESSURE CORECORE SPRAY SPRAY (LPCS)

(LPCS)(LP)

(LP) 3.

3. CPS Drawing Drawing M05-1075, M05-1075,Sheet Sheet 003, RevRev 003, AG,AG, RESIDUAL RESIDUAL HEAT HEATREMOVAL REMOVAL(RH) (RH) 4.

4. CL-MISC-009 CL-MISC-009 Rev Rev 1,1, MAAP MAAP Analysis #C467130029-10881

1. C467130029-10881 Details:

Details:

Provide a briefbrief Confirm that that procedure/guidance procedure/guidanceexists existsor orwill willbe bedeveloped developedtoto description description of of Procedures Procedures support support implementation implementation

/I Strategies Strategies /I Guidelines Guidelines Clinton will will useuse the the industry developed developed guidance guidancefrom fromthetheOwners OwnersGroups, Groups, EPRI and NEI EPRI and NEITask Taskteamteamto to develop develop site specific procedures procedures or orguidelines guidelinestoto address address the criteria criteria ininNEI 12-06. These NEI12-06. These procedures and/or and/orguidelines guidelineswillwill support supportthe theexisting existingsymptom symptombased basedcommand commandand andcontrol controlstrategies strategiesinin the the current currentEOPs. EOPs.

Identify Identify modifications modifications List List modifications modifications

• • Two Two diverse diverse external external connections connections for foraaportable portablediesel dieselpowered poweredpump pump to tosupply supplylow lowpressure pressureRPV RPV makeup makeup water waterininthetheplant.

plant.

Page Page 16 16ofof59 59

Clinton Power Clinton Power Station, Unit 1 Mitigation Strategies Strategies Integrated futegrated Plan Plan Maintain Core Maintain Core Cooling Cooling BWR Portable BWR Portable Equipment Equipment Phase Phase 2: 2:

• • The The LPCS LPCSand andRHR-C RHR-C injection injection header headerflushflushline linewill willbe bemodified modified withwith a connection point connection point for the the lowlow pressure pressure water water supply.

supply.

• • Piping Pipingwill willbebeinstalled installedtotosupport supportthe the connection connection of the the external connections to connections to the theLPCS LPCS and RHR-C RHR-C injection injection headers.

The high

• • The high pressure pressure airair supply supply forfor charging charging ADS ADS air air bottles will will be modified to withstand modified withstand the the applicable applicable external externalhazards.

hazards.

• • The The electrical electrical support support and and cooling/makeup cooling/makeup water support support modifications modifications needed for needed for the core cooling function function are are discussed discussed in the Safety Function Support section.

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

evaluation.

Wide Range Range RPVRPV Level Division 1 ATMs 1621-N691A, lB21-N691A, 1B21-N691E lB21-N691E RPV Pressure Division 1 ATMs ATMs lB21-N697A, 1621-N697A, 1821-N697E, lB21-N697E, lB21-N678A 1821-N678A (wide (wide range) range)

Clinton's evaluation of of the the FLEX FLEX strategy strategy maymay identify identify additional additional parameters that that are are needed in order order toto support supportkey key actions actions identified identifiedinin the plant plant procedures/gu procedures/guidance idance or to indicate indicate imminent imminentor oractual actual core core damage (NEI 12-06 Rev.

(NEI12-06 Rev.00Section Section3.2.1.10) 3.2.1.10) and and anyany differences differences will be be provided in a future future 6-month update following follOWing identification.

identification.

Storage Storage / Protection Protection of of Equipment Equipment:

Describe Describe stora ge /I protection stora~e protection plan or schedule schedule to determine determine storage requirements requirements Seismic Seismic List List how how equipment equipm,ent is is protected protected or or schedule schedule to to protect protect Structures toto provide provide protection protectionofofFLEX FLEX equipment will will be be constructed constructed to to meet the meet the requirements requirementsofofNEI NEt12-06 12-06Section Section11. 11.Schedule Schedule to toconstruct construct permanent permanentbuildings buildings isis contained containedinin Attachment Attachment2,2,and andwill will satisfy satisfy the thesite site compliance date. Temporary locations will be be used used until until building building construction construction completion.

completion. Procedures Proceduresand andprograms programswill will be be developed developedto to address addressstorage storagestructure structurerequirements, requirements, haul haul pathpath requirements, requirements, andandFLEXFLEX equipment equipmentrequirements requirementsrelative relativetotothetheexternal externalhazards hazardsapplicable applicabletoto Clinton Clinton Power PowerStation.

Station.

Page Page17 17of of5959

Clinton Power Station, Unit 1 Mitigation Strategies Integrated Integrated Plan Plan Maintain Core Cooling BWR Portable Equipment Phase Phase 2:2:

Flooding List how equipment equipment is is protected protected or or schedule schedule to to protect protect below current if stored below Note: if currentflood flood level, level, then ensure procedures exist exist to to move move equipment prior prior to to exceeding exceeding flood flood level level Structures to Structures to provide provide protection protectionofofFLEX equipment will FLEX equipment constructed to will be constructed to meet the requirements requirementsof ofNEI NEI 12-06 12-06 Section Section 11. Schedule Schedule to to construct permanent buildings permanent buildings is is contained contained in in Attachment Attachment2,2,and andwill will satisfy satisfy the the site site compliance date. Temporary locations will be used until building building construction completion.

completion. Procedures Procedures and and programs will be be developed developed to to address storage storage structure structurerequirements, requirements,haulhaulpath pathrequirements, requirements, andandFLEX FLEX equipment requirements equipment requirements relative relativetotothe theexternal externalhazards hazardsapplicable applicable to to Clinton Power Power Station.

Severe Storms with High List how equipment equipment is is protected protected or or schedule schedule to to protect protect Winds Structures to provide protection protectionof ofFLEX equipment will be FLEX equipment be constructed to to meet the meet the requirements requirementsofofNEI 12-06 Section NE112-06 Section 11.

11. Schedule to to construct construct permanent buildings is contained in Attachment Attachment 2, 2, and and will will satisfy satisfy the the site site compliance date.

date. Temporary Temporarylocations locationswill will be be used useduntil untilbuilding building construction completion.

completion. Procedures Procedures and and programs programs will will be be developed developed to to address storage address storage structure requirements, requirements,haulhaulpath pathrequirements, requirements,and andFLEX FLEX equipment requirements equipment requirementsrelative relative to tothe theexternal externalhazards hazardsapplicable applicableto to Clinton Power Power Station.

Snow, Ice, and Extreme Extreme List how equipment is is protected protected or or schedule schedule to to protect protect Cold Structures to Structures to provide provideprotection protectionofofFLEX equipment will FLEX equipment constructed to will be constructed to meet the the requirements requirementsofofNEI NEI 12-06 12-06Section Section 11.

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

completion. Procedures Procedures and programs will be developed to to address storage storage structure structurerequirements, requirements,haulhaulpath pathrequirements, requirements, andandFLEX FLEX equipment requirements equipment requirements relative relativetotothe theexternal externalhazards hazardsapplicable applicable to to Clinton Power Station.

High Temperatures List how equipment equipment is is protected protected or or schedule schedule to to protect protect Structures to Structures to provide provide protection protectionofofFLEX equipment will FLEX equipment be constructed will be constructed to to meet the the requirements requirementsofofNEI 12-06 Section NE112-06 Section 11.

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

completion. Procedures Procedures and programs will be be developed to to address storage address storage structure requirements, requirements,haulhaulpath pathrequirements, requirements,and andFLEX FLEX equipment requirements equipment requirements relative relativetotothe theexternal externalhazards hazardsapplicable applicable to to Clinton Power Station.

Page 18 of of 59

Clinton Power Clinton Power Station, Station, Unit 1 Mitigation Strategies Integrated Integrated PlanPlan Deployment Deployment Conceptual Conceptual Modification Modification (Attachment 33contains (Attachment contains Conceptual ConceptualSketches)

Sketches)

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

use.

The electrical The electrical support support andand The electrical The electrical support support and The The external external connection connection points cooling/makeup water cooling/makeup water support support cooling/makeup water cooling/makeup water support support are common to are common to core core cooling, cooling, deployment strategies deployment strategies are are modifications are modifications are common common to to core core containment, containment, and and spent fuel pool common to core cooling, common cooling, containment, cooling, containment, and and spent spent makeup makeup functions.

functions. TheThe protection protection containment, and containment, spent fuel and spent fuel pool pool fuel pool makeup functions. The fuel discussion isis in discussion in the the Safety makeup functions. The makeup The discussion discussion discussion isis in discussion in the the Safety Function Function Support Support section.

isis in in the the Safety Safety Function Function Support Support Function Support Function Support section.

section.

section.

The The FLEX FLEXair aircompressor compressor will will be be ADS air ADS air charging charg ng station station The The ADS ADSair aircharging chargingstation station will will deployed deployed from from its storage location be be protected protected from applicable applicable to the to the ADS ADS airair charging charging station.

station. external hazards.

Hoses Hoses will will be pre-staged to None None Hoses Hoseswill will be be staged staged in in a structure structure connect piping connect piping from from thethe external external protected from from external external hazards.

hazards.

water connection water connectiontotothe theLPCS LPCS and and RHR-C injection RHR-C injection headers. headers.

Notes:

Notes:

Exelon Generation Exelon Generation Company, Company,LLC (Exelon)has LLC (Exelon) has not not finalized the the engineering engineeringdesigns designsforforcompliance compliance with NRC with NRC Order EA-12-049. Detailed designs EA-12-049. Detailed designs based based on thethe current current conceptual conceptualdesigns designswill will be be developed developedto todetermine determine the final final plan and associated mitigating strategies. Analysis Analysis will be performed will be performed to validate that that the the plant plant modifications, selected equipment, modifications, equipment,and andidentified identifiedmitigating mitigatingstrategy strategycancansatisfy satisfythe thesafety safetyfunction function requirements requirementsof ofNEI 12-06. Once these NEI12-06. these designs designs and and mitigating mitigatingstrategies strategieshave havebeen beenfully fullydeveloped, developed,ExelonExelon will update the will update the integrated integratedplanplanfor forClinton Clinton during during aascheduled scheduled6-month 6-monthupdate.

update.ThisThisupdate update will willinclude includeany any changes to the theinitial initial designs designs as as submitted submittedininthe theFebruary February28, 28,2013 2013Integrated IntegratedPlan.

Plan.

Page Page19 19ofof59 59

Clinton Power Clinton Power Station, Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Core Maintain Core Cooling BWR Portable BWR Equipment Phase Portable Equipment Phase 3:

Provide aa general Provide general description description of of the the coping copingstrategies strategiesusing usingphase phase33equipment equipmentincluding includingmodifications modificationsthat that are proposed are proposed toto maintain maintain core core cooling.

cooling. Identify methods (RCIC/HPCI/IC)

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

achieve Phase1I and Phase and 22 strategy strategy will will provide sufficient sufficient capability capability that thatno noadditional additionalPhase Phase33strategies strategiesare arerequired.

required.

Phase 33 equipment Phase equipment for Clinton includes backup Clinton includes backup portable pumpspumps andand generators.

generators.The Theportable portablepumps pumpswillwillbe be capable of providing capable providing thethe necessary necessary flow flow and pressure pressureas asoutlined outlinedininPhase Phase2 2response responsefor Core for CoreCooling, Cooling, Containment, and Spent Containment, Spent Fuel Fuel Pool PoolCooling.

Cooling.TheTheportable portablegenerators generatorswillwill be be capable capable of of providing providing the necessary480 necessary 480volt volt power power requirements requirements as as outlined outlinedininPhase Phase 22 response response for for Safety Safety Functions Functions Support.

Support.

Details:

Provide a brief procedure/guidance exists or will be developed to Confirm that procedure/guidance Procedures description of Procedures support implementation I/ Strategies I/ Guidelines Clinton will use use the industry industry developed developed guidance guidance fromfromthe theOwners OwnersGroups, Groups, EPRIand EPRI andNEt NEITask Taskteam teamtotodevelop developsitesitespecific specificprocedures procedures or or guidelines guidelines to address the address the criteria criteriainin NEI 12-06. These procedures NEI12-06. procedures and/or and/orguidelines guidelineswillwill support the the existing existing symptom basedbased command command and and control controlstrategies strategiesinin the current the currentEOPs.

EOPs.

Identify modifications List modifications modifications None None Reactor Parameters Key Reactor List instrumentation credited credited or or recovered recovered for for this this coping coping evaluation.

evaluation.

Clinton's evaluation evaluationof ofthe theFLEX strategy may FLEX strategy may identify identify additional additional parameters that that are are needed needed in order order toto support supportkey key actions actions identified identifiedinin the the plant plant procedures/guidance procedures/guidanceor orto toindicate indicateimminent imminentor oractual actualcore core damage damage(NEI 12-06 Rev.

{NE112-06 Rev. 0 Section 3.2.1.10) 3.2.1.10} andand any anydifferences differenceswillwillbe be provided inin a future future 6-month 6-month update updatefollowing followingidentification.

identification.

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

Sketches)

Strategy Strategy Modifications Modifications Protection of Protection of connections connections Identify Identify Strategy Strategyincluding includinghowhow Identify Identify modifications n'wdifications Identify how Identify howthetheconnection connectionisis the equipment will be deployed equipment will be deployed protected protected to the the point pointofofuse.

use.

None None None None None None Page 20 Page 20 of of5959

Clinton Power Clinton Power Station, Unit 1 Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Core Maintain Core Cooling BWR Portable BWR Portable Equipment Equipment Phase Phase 3:

Notes:

Notes:

ExelonGeneration Exelon Generation Company, LLC (Exelon)has LLC (Exelon) hasnot not finalized finalized the the engineering engineering designs designsfor forcompliance compliancewith withNRC NRC Order EA-12-049.

Order EA-12-049. Detailed Detaileddesigns designsbased based onon the the current current conceptual conceptual designs designswill will be developed developed to todetermine determine the final the final plan plan and and associated mitigating strategies.

strategies. Analysis will be Analysis will be performed performed to to validate that that the the plant plant modifications, selected modifications, selected equipment, equipment, andand identified identified mitigating mitigating strategy strategycan cansatisfy satisfythe thesafety safetyfunction function requirements of requirements of NEI 12-06. Once NEI12-0G. Once these these designs and mitigating mitigating strategies strategieshave havebeen beenfully fullydeveloped, developed,Exelon Exelon willupdate will update the the integrated integrated plan plan for for Clinton during aa scheduled Clinton during scheduled G-month 6-month update.

update. This This update updatewill will include include any any changes to the initial initial designs as submitted submitted in in the theFebruary February28,28, 2013 2013 Integrated IntegratedPlan.

Plan.

Page Page 21 21 of of59 59

Clinton Power Clinton Power Station, Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Containment Maintain Containment Determine Baseline coping capability Determine capability with with installed coping 2 modifications installed coping~ modifications not not including including FLEX modifications, utilizing FLEX utilizing methods methods described described in in Table Table 3-13-1 of of NEI NEI 12-06:

12..06:

• • Containment Venting Containment Venting oror Alternate Alternate Heat Removal Removal

• • Hydrogen Igniters Hydrogen Igniters (Mark (Mark IIIIII containments containments only)onl y)

BWR Installed BWR Installed Equipment Equipment Phase Phase 1:

Provide a general description of Provide of the coping strategies using installed installed equipment equipment including including modifications modifications that that are proposed to maintain containment. Identify methods (containment vent or alternative/Hydrogen proposed to maintain containment. Identify methods (containment vent or alternative / Hydrogen Igniters) and strategy(ies) utilized to toachieve achievethis thiscoping copingtime.

time.

During Phase During Phase1,1,containment containment integrity integrity is maintained by by normal normal design design features features ofofthethecontainment, containment,such such asthe as the containment containment isolation valves. valves. In In accordance accordance with NEI 12-06, the NE112-06, the containment isolation isolation actions actions delineated in the the SBO procedure are sufficient.

SBO procedure sufficient.

RPVpressure RPV pressure will willbe begradually graduallyreduced reduced with SRVsSRVstotoapproximately approximately 150 150 psig psig while whilethe the suppression suppression pool pool has sufficient has sufficient heat capacity to absorb a portion portion of ofthe the sensible sensible heat heat inin the thereactor.

reactor.RPV RPVpressure pressurewill willbebe controlled between 150 150 - 250 250 psig.

psig. Decay Decay heat heat will will continue to heat heat upup the the suppression suppression pool pool during during the the initial phase initial phase through RCIC exhaustand RCIC exhaust and SRV SRVoperation.

operation. The The water water inin the the upper upper containment containmentpool poolisis transferred to transferred tothe thesuppression suppressionpool poolonce onceaaFLEX generator has FLEX generator has been lined up up to to the the480480VAC VAC distribution distribution system, and power power is is available available toto the theSPMU SPMU valves.

valves. ThisThisisisaaPhase Phase 2 action action relying relyingon onFLEX equipment, FLEX equipment, expected to occur occur atat 180°F 180°F suppression pool temperature, temperature,atatT0+5 To+5 hours hours [Reference

[Reference 1]. 1].

Suppression Pool Level Leveland andContainment Containment Pressure Pressure instruments instruments remain remain available available during during PhasePhase 11since since they they are powered powered from fromDivision Division11NSPS NSPS [Reference 21. 2]. Suppression Pool Temperature Temperature isis manually manuallyobtained obtained using procedure using procedureCPS CPS4200.010003 4200.01C003 MONITORING MONITORING CNMT CNMT TEMPERATURES TEMPERATURES DURING DURING A A SBO SBO [Reference

[Reference 3]. 3].

The Hydrogen Igniter System (HIS) (HIS) isisdesigned designedto to ignite ignite hydrogen hydrogen in the unlikely unlikely occurrence occurrence of ofaadegraded degraded core event which results in the generation generation of of excessive quantities of hydrogen from aa large excessive quantities large metal-water metal-water reaction in in the the RPV.

RPV. TheThe HIS HISisisdesigned designedtotoburnburnhydrogen hydrogenatatlow lowconcentrations, concentrations, therebythereby maintaining maintaining the the concentration concentration of ofhydrogen hydrogen below belowwhich, which, ifif ignited, ignited, could could lead to to containment containmentoverpressurization overpressurizationfailure failure

[Reference

[Reference 4]. 4].

Containment Containment heat heatremoval removal andand hydrogen hydrogenigniter igniteroperation operationare arenot notpossible possibleduring duringPhase Phase11since sincethey they both both relyrely onon the the availability availabilityof of480 480 VAC VAC power. These These functions functions relyrely on on deployment deploymentof ofportable portable equipment equipment to to meet meetthe thewater waterand andpower powerrequirements.

requirements.These Theserequirements requirementsare aremetmet ininPhase Phase2.2.

References References 1.

1. CL-MISC-009 CL-MISC-009 Rev Rev 1,1, MAAP Analysis #C467130029-10881

1. C467130029-10881 2.

2. CPS Drawing E02-1RI99, CPS Drawing E02-1RI99/Sheet Sheet010,010,Rev RevF, F, REACTOR REACTORCORE COREISOLATION ISOLATIONCOOLING COOLINGSYS SYS(RI)(RI)NSPS NSPS 1E51-lE51-1050 SCHEMATIC DIAGRAM, E02-1RH99, Sheet 010, Rev L, SCHEMATIC 1050 SCHEMATIC DIAGRAM, E02-1RH99, Sheet 010, Rev L, SCHEMATIC DIAGRAM RESIDUAL HEAT DIAGRAM RESIDUAL HEAT REMOVAL REMOVALSYS SYS (RH) 1E12-1050 lE12-1050NSPS NSPS 3.

3. CPS 4200.01C003 MONITORING CPS 4200.01C003 MONITORINGCNMT CNMTTEMPERATURES TEMPERATURES DURING DURING A A SBO, SBO, Rev la la

4. Clinton

4. Clinton UFSAR UFSAR Section 6.2.5.2.1 6.2.5.2.1 22 Coping modifications consist consist of ofmodifications modificationsinstalled installedtotoincrease increaseinitial initialcoping copingtime, time,i.e.,

i.e.,generators generatorstoto preserve preserve vital vitalinstruments instrumentsor orincrease increaseoperating operatingtime timeononbattery batterypowered poweredequipment.

equipment.

Page Page 22 22 ofof5959

Clinton Power Clinton Power Station, Station, UnitUnit 1 Mitigation Mitigation Strategies Integrated Plan Details:

Details:

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

// Strategies Strategies / Guidelines

• • Clinton will Clinton will use use thethe industry developed guidance guidance fromfrom the Owners Groups, EPRI Groups, EPRIand andNEI NEITask Taskteamteamtotodevelop developsitesite specific specific procedures procedures or guidelines or guidelines to address the the criteria criteria in in NEI NEI 12-06. These These procedures and/or guidelines will and/or will support support thethe existing symptom based command existing symptom and control and control strategies in in the the current currentEOPs.

EOPs.

Identify modifications Identify List modifications modifications None None Key Containment Key Containment List instrumentation credited for this coping evaluation.

Parameters Suppression Pool Suppression PoolTemperature Temperature Manually obtained Manually obtainedusing usingprocedure procedureCPS CPS4200.01C003 4200.01C003 MONITORING MONITORING CNMT TEMPERATURES DURING A SBO Suppression Pool Pool Level Level 1E51-N636A/E 1E51-N636A/E Containment Pressure Containment Pressure 1E12-N662A/C 1E12-N662A/C Clinton's evaluation of of the the FLEX strategy may FLEX strategy may identify identify additional parameters that are needed in order to that are needed order to support key support key actions actions identified identifiedinin the plant plant procedures/guidance procedures/guidanceor orto toindicate indicateimminent imminentor oractual actualcore core damage (NEI(NEI 12-06 Rev. Rev. 00 Section Section 3.2.1.10) and any differences differences will willbe be provided in a future future 6-month update following identification.

identification.

Notes:

Exelon Generation Company, Exelon Generation Company, LLC (Exelon)has LLC (Exelon) hasnot notfinalized finalizedthethe engineering engineering designs designs for for compliance compliancewith with NRC Order EA-12-049.

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

strategies.Analysis Analysiswill will be be performed performed to tovalidate validate that that the the plant plant modifications, modifications,selected selectedequipment, equipment,and andidentified identifiedmitigating mitigatingstrategy strategycan cansatisfy satisfythe thesafety safety function requirements requirementsofofNEI 12-06. Once NEI12-06. Once these thesedesigns designsand andmitigating mitigatingstrategies strategieshavehavebeen beenfully fully developed, Exelon Exelon will update the integrated integrated plan plan for forClinton Clintonduring duringaascheduled scheduled 6-month 6-month update.

update.This This update updatewill will include include any changes toto the the initial initial designs designs as as submitted submittedinin the theFebruary February28, 28,2013 2013Integrated Integrated Plan.

Plan.

Page 23 Page 23 of of59 59

Clinton Power Station, Clinton Station, UnitUnit 1 MitigatIon Mitigation StrategIes Strategies Integrated Plan Maintain Containment Maintain BWR Portable BWR Portable Equipment Phase Phase 2:

Provide aa general Provide general description description of of the the coping coping strategies strategies using using on-site on-siteportable portableequipment equipment including including modifications that are proposed to maintain modifications that are proposed to maintain containment. containment. Identify methods (containment vent or alternative /

Hydrogen Igniters) and strategy(ies) utilized totoachieve achievethis thiscoping copingtime.time.

During Phase During Phase2,2,aapre-staged pre-staged480 480VAC VACgenerator generatorwill willbe belined lined up up to to the the Division 1, or alternatively alternativelyDivision Division22 ACdistribution AC distribution to to repower repower1SM001A lSM001A and and 1SM002A, lSM002A, or alternatively alternatively 1SM001BlSM001B and and 1SM002B lSM002B Upper Upper Containment Pool Makeup to Suppression Pool Valves Valves [Reference

[Reference 1]. 1]. The The added added inventory from the the upper upper pools will pools willextend extend thethe time before suppression suppression pool pool cooling cooling is is required required to to avoid avoid significant significant containment containment pressurization. Suppression pressurization. Suppressionpool poolcooling coolingwillwillbebeaccomplished accomplishedusing using a 480 a 480VACVACFLEX pump lined up to FLEX pump to suppression pool circulate suppression pool water waterthrough throughthe theshell shellside sideofofananRHR RHR heat heatexchanger exchangerusingusingabandoned abandoned RHR RHR Steam Condensing Mode Piping, Piping, and and water water from from the external external connections connectionswill will supply the the heat heatexchanger exchanger tube side. TheThe proposed proposedSX SX connection connection pointspointsare arediscussed discussedin inthe theSafety SafetyFunctions FunctionsSupport SupportPhase Phase22 section.

section.

Either RHR RHRheatheatexchanger exchangercan can be be used used for the alternate alternatesuppression suppressionpool poolcooling coolingstrategy.

strategy.The TheRHRRHR heat heat exchanger chosen exchanger chosen willwill depend depend on on thethe SX SXdivision divisionsupplied supplied fromfrom thethe external connection connection and and the the electrical electrical division aligned division aligned to to the the FLEX generator. This FLEX generator. Thisstrategy strategy will willprovide provide an an unlimited unlimited coping coping period for the the containment [Reference containment [Reference 2].

Suppression pool Suppression pool water water addition addition is is required required to tomaintain maintainRCIC RCIC pump NPSH, makeupfor NPSH, makeup for reactor reactor recirculation pump seal leakage into into the the drywell, drywell, and and makeup makeup for for evaporative evaporativelosses. losses.The Theexternal externalwater water connection connection will will supply the the LPCS injection header LPCS injection header or or alternatively alternativelythe theRHR-C RHR-C injection header. header. Water can be added added as as needed to needed tothe thesuppression suppressionpool poolusing using1E21-F012 lE21-F012LPCS LPCSTest TestReturn ReturnTo To Suppression SuppressionPool PoolValve Valve [Reference

[Reference3] 3]

or 1E12-F021 or lE12-F021 RHR RHRCCTest TestValve ValveTo ToSuppression SuppressionPool Pool[Reference

[Reference4]. 4]. These These twotwo valves are located located outside outsidethethe primary containment primary containmentand and can can bebe operated operatedmanually manuallywith withthe thehandwheel handwheelororelectrically electricallyviaviathe theFLEX FLEX generator.

generator.

The pre-staged 480 VAC VAC FLEX FLEXgenerator generatorwill willalso alsorepower repowerthe the Division Division 1, 1, or or alternatively alternatively the the Division Division 2,2, hydrogen hydrogen igniter igniterdistribution distributionpanelpanel from fromAux Aux Building BuildingMCC MCC1A1, lAl,ororalternatively alternatively AuxAuxBuilding BuildingMCC MCC181,lBl,toto allow allow igniter igniteroperation operationas asprescribed prescribedby bythetheEOPs EOPs [Reference

[Reference 5]. 5].

References References 1.

1. E02-1AP49, E02-1AP49, SheetSheet001, AUXILIARY 001, AUXILIARY BUILDING BUILDING MCC MCClA3,1A3,Rev Rev Z,Z,and and E02-1AP50, E02-1APsO, Sheet Sheet001, 001, KEY KEYDIAGRAM DIAGRAM AUX BUILDING BUILDING MCC MCC 1A4 lA4 ANDAND 1B4 lB4(1AP93E)

(lAP93E)(1AP94E),

(lAP94E),Rev RevRR

2. CL-MISC-009 CL-MISC-009 Rev Rev 1,1, MAAP MAAP Analysis Analysis #C467130029-10881

1. C467130029-10881 3.

3. CPS Drawing DrawingM05-1073, MOs-l073, Sheet Sheet001,001, RevRevAG,AG, LOW-PRESSURE LOW-PRESSURE CORE CORE SPRAY SPRAY (LPCS)

(LPCS)(LP)

(LP)

4. CPS Drawing M05-1075, CPS Drawing MOs-l07s,Sheet Sheet003, 003,RevRevAG,AG,RESIDUAL RESIDUALHEAT HEATREMOVAL REMOVAL (RH) (RH)

5. CPS Drawing DrawingE02-1AP47, E02-1AP47,Sheet Sheet001, RevRev 001, AF,AF,KEYKEY DIAGRAM DIAGRAM AUXILIARY AUXILIARYBLDG BLDG MCC MCC 1A1lAl (1AP72E),

(lAP72E),E02-E02-1AP51, lAPsl,Sheet Sheet002,002, Rev M,M, Rev KEYKEYDIAGRAM DIAGRAMAUX AUXBLDG BLDGMCC MCC1B1 lBl Details:

Details:

Provide a briefbrief Confirm that that procedure/guidance procedure/guidanceexists existsor orwill willbebedeveloped developedtoto description description of Procedures Procedures support support implementation implementation Strategies I Guidelines

/I Strategies / Guidelines

• • Clinton Clinton willwill use use the the industry developed developed guidance guidancefrom fromthe theOwners Owners Page Page 24 24 ofof59 59

Clinton Power Clinton Power Station, Unit 1 Mitigation Strategies Integrated Plan Maintain Containment Maintain Containment BWR Portable BWR Portable Equipment Phase 2:

Groups, EPRI Groups, EPRIand andNEI NEITask Taskteam teamtotodevelop develop site site specific specific procedures or or guidelines to address address thethecriteria criteriaininNEI 12-06. These procedures NEI12-06. procedures and/or guidelines will and/or support the will support the existing symptom symptom based command and control and control strategies strategies inin the the current currentEOPs.EOPs.

• • EOPsprovide EOPs provideguidance guidanceon on hydrogen hydrogen igniter operation.

Identify modifications List modifications modifications

• • diverse external Two diverse external connections connections for for a portable diesel powered pump to supply cooling cooling water to an RHR heat exchanger.

water to an RHR heat exchanger.

• • Piping will Piping will be be installed installed toto support support the the connection of the external water connection to to the the Unit Unit11Shutdown ShutdownService ServiceWater Water(SX)

(SX) system system using using the Unit Unit 22 SX supply to SX supply to the Division Division 11 or or Division Division 22 Control Control Room Room Ventilation (VC)

Ventilation (VC) Chillers Chillers (currently blind-flanged).

blind-flanged).

• • Modify an Modify an ECCS pump suction ECCS pump suction spool spool piece to provide provide suppression suppression pool pool suction for suction for aa480 480VACVAC pump.

• • Adapt the RHR Steam Condensing RHR Steam Condensing Mode Mode (currently (currently abandoned) abandoned) heat heat exchanger supply exchanger supply piping piping toto provide provide aadischarge dischargepath pathfor forthe the480 480VAC VAC pump.

• The The electrical support and cooling/makeup cooling/makeup water water support support modifications needed needed forfor the the containment containmentfunction functionarearediscussed discussed in in the Safety Safety Function Support Support section.

section.

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

evaluation.

Parameters Suppression Suppression Pool Pool Temperature Temperature Manually Manually obtained obtainedusing usingprocedure procedureCPS CPS4200.01C003 4200.01C003MONITORING MONITORING CNMT CNMT TEMPERATURES TEMPERATURES DURING DURING AASBO SSO Suppression Pool Level Level 1E51-N636A/E 1E51-N636A/E Containment ContainmentPressure Pressure 1E12-N662A/C 1E12-N662A/C Clinton's evaluation evaluationof ofthe theFLEX strategy may identify FLEX strategy identify additional additional parameters thatthat are are needed needed in in order order toto support supportkey key actions actions identified identifiedinin the the plant plant procedures/guidance procedures/guidance or or to to indicate indicate imminent imminentor oractual actualcore core damage (NEI(NEI 12-06 Rev.Rev. 0 Section 3.2.1.10) and any any differences differenceswill willbe be provided in in a future 6-month update update following following identification.

identification.

Storage Storage / Protection Protection of of Equipment Equipment::

Describe Describe storage / protection plan or protection plan or schedule schedule to to determine determinestorastorage requirements ge requirements Seismic Seismic List List how how equipment equipment isis protected protectedor orschedule schedule to to protect protect Page Page 25 25 ofof 59 59

Clinton Power Clinton Power Station, Unit Unit 1 Mitigation Mitigation Strategies Integrated Integrated Plan Plan Maintain Containment Maintain BWR Portable BWR Portable Equipment Equipment Phase Phase 2: 2:

Structures to provide Structures provide protection protectionof ofFLEX equipment will FLEX equipment will be be constructed constructed to to meet the meet the requirements requirementsofofNEI 12-06 Section 11. Schedule NE112-06 Schedule to construct construct permanent buildings permanent buildings is is contained contained in in Attachment 2, and will satisfy the site site compliance date.

compliance date. Temporary Temporary locations locations will will be be used used until until building construction completion, completion. Procedures Procedures and programs will be developed to address storage address storage structure structure requirements, requirements, haulhaulpath pathrequirements, requirements,and andFLEX FLEX equipment requirements requirements relative relative to to the theexternal externalhazards hazardsapplicable applicable to to Clinton Power Station.

Flooding List how equipn'lent equipment is protected or schedule to protect Note: if stored below current Note: current flood flood level, level, then ensure procedures exist exist to to move move equipment prior to exceeding exceeding flood flood level.

level. Structures to provide protection protection ofof FLEX FLEXequipment equipmentwillwillbebeconstructed constructed to to meet the requirements requirementsofofNEI 12-06 Section NE112-06 Section 11.

11. Schedule Schedule to to construct construct permanent buildings is is contained in Attachment Attachment 2, 2, and and will will satisfy satisfy the the site site compliance date.

compliance date. Temporary Temporary locations locations will will be used used until until building construction completion.

completion. Procedures Procedures and programs will be developed to to address storage storage structure structurerequirements, requirements,haul haulpath pathrequirements, requirements, and and FLEX FLEX equipment requirements requirements relative relative to tothe theexternal externalhazards hazards applicable applicable to to Clinton Power Station.

Severe Storms with High List how equipment is protected or schedule to to protect protect Winds Structures to provide protection protection ofofFLEX equipment will be constructed to FLEX equipment to meet the requirements of NEI 12-06 Section 11. Schedule the requirements of NEI 12-06 Section 11. Schedule to construct to construct permanent buildings is contained in Attachment Attachment 2, 2, and and will will satisfy satisfy the the site site date. Temporary locations will be used compliance date. used until building construction completion.

completion. Procedures Procedures and and programs will be be developed developed to to address address storage storage structure structurerequirements, requirements,haul haulpath pathrequirements, requirements, andandFLEX FLEX equipment equipment requirements requirements relative relativetotothe theexternal externalhazards hazardsapplicable applicable to to Clinton Power Station.

Power Station.

Snow, lee, Ice, and and Extreme equipment isis protected List how equipment protectedor orschedule scheduletotoprotect protect Cold Structures Structures to to provide provideprotection protectionofofFLEX equipment will FLEX equipment will be constructed constructed to to meet meet the the requirements requirementsofofNEI 12-06 Section NE112-06 Section11.

11.Schedule Schedule to to construct construct permanent permanentbuildings buildings is is contained contained in in Attachment Attachment2,2,and andwill will satisfy satisfy the the site site compliance date. Temporary locations will be be used until building building construction completion.

completion. Procedures Procedures and and programs programswillwill be be developed developed to to address address storage storagestructure structurerequirements, requirements,haul haulpath pathrequirements, requirements, andandFLEX FLEX equipment equipment requirements requirementsrelative relativetotothe theexternal externalhazards hazardsapplicable applicableto to Clinton Power Power Station.

Station.

High High Temperatures Temperatures List how List how equipment equipment is is protected protected or or schedule schedule to to protect protect Structures to provide provide protection protectionofofFLEXFLEX equipment will will be be constructed constructed to to meet meet the therequirements requirementsofofNEI 12-06 Section NE112-06 Section 11.

11. Schedule Schedule to to construct construct permanent permanentbuildings buildings isis contained containedin in Attachment Attachment2,2,and andwill will satisfy satisfy the thesite site Page Page 26 26 of of5959

Clinton Power Station, Unit 1 Mitigation Strategies Strategles Integrated Integrated PlanPlan Maintain Containment BWR Portable Equipment Equipment Phase Phase 2: 2:

compliance date.

date. Temporary Temporarylocations locationswill will be be used useduntil untilbuilding building construction completion. Procedures Procedures and and programs programswill will be developed developed to to address storage storage structure structurerequirements, requirements,haul haulpath pathrequirements, requirements, and FLEX and FLEX equipment requirements requirements relative relative to to the theexternal externalhazards hazardsapplicable applicable to to Clinton Power Station.

Clinton Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

use.

The electrical support and and The electrical support The support and and The The external connection points cooling/makeup water support support cooling/makeup water water support support are common to core core cooling, cooling, deployment strategies deployment strategies are modifications are are common to to core core containment, and and spent fuel pool pool common to to core core cooling, cooling, cooling, containment, and cooling, and spent makeup functions. The The protection protection containment, and and spent spent fuel fuel pool pool fuel pool makeup functions. The The discussion is in the Safety Safety makeup functions.

makeup functions. TheThediscussion discussion discussion is discussion is in in the Safety Function Support section.

is in is in the the Safety Function Support Support Function Support section.

section.

Hoses will Hoses will be pre-staged to to None None Hoses will Hoses will be staged in a structure structure connect the connect the FLEX alternate FLEX alternate protected protected fromfrom external externalhazards.

hazards.

suppression pool cooling pump to suppression to the suppression suppression pool pooland andRHR RHR heat exchanger connections.

connections.

Hoses will Hoses will be pre-staged to to None None Hoses will Hoses will be staged in a structure structure connect piping from the the external external protected from protected from external externalhazards.

hazards.

water water connection connection to tothe theUnit Unit22SX SX supply to to the the VC VC chillers.

Notes:

Notes:

Exelon Generation Exelon Generation Company, Company,LLC (Exelon) has LLC (Exelon) has not not finalized the the engineering engineeringdesigns designsforforcompliance compliance with withNRC NRC Order EA-12-049. Detailed designs EA-12-049. Detailed designs based based on the the current currentconceptual conceptualdesigns designswill will be bedeveloped developedtotodetermine determine the final final plan and associated mitigating strategies. Analysis mitigating strategies. Analysis will be performed to validate that will be that the theplant plant modifications, selected equipment, equipment,and andidentified identifiedmitigating mitigatingstrategy strategycancansatisfy satisfythe thesafety safetyfunction function requirements requirementsof ofNEI 12-06. Once these NEI12-06. these designs designs and andmitigating mitigatingstrategies strategieshave havebeen beenfully fullydeveloped, developed,ExelonExelon will update the will update the integrated integratedplan planfor forClinton Clinton during during aascheduled scheduled6-month 6-monthupdate.

update.ThisThisupdate update will willinclude includeany any changes to to the the initial initial designs designs as as submitted submittedininthe theFebruary February28,28,2013 2013Integrated IntegratedPlan.

Plan.

Page 2727 of of5959

Clinton Power Station, Unit 11 Mitigation Clinton Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Containment Maintain Containment BWR Portable BWR Portable Equipment Equipment Phase Phase 3: 3:

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

containment. Identify methods (containment vent or alternative //Hydrogen Hydrogen Igniters) and strategy(ies) utilized to toachieve achievethisthiscoping copingtime.

time.

Phases11and Phases and22strategy strategywill will provide provide sufficient sufficient capability capability such such that thatnonoadditional additionalPhase Phase33strategies strategiesare are required.

Phase33equipment Phase equipment forfor Clinton Clinton includes includes backup backup portable portable pumps and generators. The The portable pumps will will be be capable of providing capable providing the thenecessary necessary flowflowand andpressure pressureas as outlined outlinedininPhase Phase22response responsefor forCore CoreCooling, Cooling, Containment, andand Spent Spent Fuel Fuel Pool Pool Cooling.

Cooling. TheThe portable portable generators generators will will be be capable capable of ofproviding providing the the necessary 480 volt power requirements requirementsas asoutlined outlinedininPhase Phase22response responsefor forSafety SafetyFunctions FunctionsSupport.

Support.

Details:

Provide a brief Confirm that procedure/guidance exists exists oror will will be be developed developedtoto description of Procedures Procedures support implementation II Strategies /I Guidelines Clinton will useuse the industry industry developed developed guidance guidance from from the theOwners OwnersGroups, Groups, EPRIand EPRI andNEINEITask Taskteam teamtotodevelop develop site site specific specific procedures or or guidelines guidelinesto to address the address the criteria inin NEI 12-06. These NEI12-06. These procedures procedures and/or and/or guidelines guidelines will will support the support the existing existing symptom based based command command and andcontrol controlstrategies strategiesinin the current the currentEOPs.

EOPs.

Identify modifications List List modifications modifications None None Key Containment Containment List instrumentation creditedcredited or or recovered recovered for this this coping coping evaluation.

evaluation.

Parameters Clinton's evaluation evaluation of of the the FLEX strategy may FLEX strategy may identify identify additional additional parameters that that are are needed needed in order order toto support supportkeykey actions actions identified identifiedinin the the plant plant procedures/guidance procedures/guidanceor ortotoindicate indicateimminent imminentor oractual actualcore core damage (NEI (NEI 12-06 Rev.

Rev. 00 Section Section 3.2.1.10) 3.2.1.10) and any differences differences will willbe be provided in a future 66 monthmonth update updatefollowing following identification.

identification.

Deployment Deployment Conceptual ConceptualDesign Design (Attachment 33 contains (Attachment contains Conceptual Conceptual Sketches)

Sketches)

Strategy Strategy Modifications Modifications Protection of Protection of connections connections Identify Identify Strategy Strategyincluding includinghow how Identify Identify modifications n1.odifications Identify Identify how how the theconnection connectionisis the equipment will be deployed equipment will be deployed protected protected to the the point pointofofuse.

use.

None None None None None None Page 28 Page 28 ofof59 59

Clinton Power Clinton Power Station, Station, Unit 1 Mitigation Strategies Integrated Plan Maintain Containment Maintain BWR Portable BWR Portable Equipment Equipment Phase Phase 3:3:

Notes:

Exelon Generation Exelon Generation Company, LLC (Exelon)has LLC (Exelon) hasnot notfinalized finalizedthe the engineering engineering designs designs for for compliance compliancewithwithNRC NRC Order EA-12-049.

Order EA-12-049. Detailed Detailed designs designs based based on on the the current current conceptual conceptualdesigns designswill will be be developed developedto todetermine determine the final plan and associated mitigating strategies. Analysis final plan will be Analysis will be performed performed to validate that that the the plant plant modifications, selected modifications, selected equipment, equipment, and and identified identifiedmitigating mitigating strategy strategycancansatisfy satisfythe thesafety safetyfunction function requirements of requirements ofNEI 12-06. Once NEI12-06. Once these these designs and and mitigating mitigating strategies strategieshave havebeen beenfully fullydeveloped, developed,Exelon Exelon will update will update the integrated plan for Clinton integrated plan for Clinton during a scheduled 6-month update.

update. This update will include any This update will include any changes to the initial initial designs as submitted submitted inin the the February February28, 28, 2013 2013 Integrated IntegratedPlan.

Plan.

Page 29 Page 29 of of59 59

Clinton Power Clinton Power Station, Unit 1 Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Spent Maintain Spent Fuel Pool Cooling Determine Baseline Determine Baseline coping capability capability with with installed installed coping modifications j

modifications not not including FLEX modifications, FLEX modifications, utilizing methods methods described described in in Table Table 3-1 3-1 of of NEI NEI 12-06:

12-06:

• • Makeup with Makeup with Portable Portable Injection Source BWR Installed BWR Installed EquipmentEquipment Phase Phase 1:

Provide a general description of Provide of the coping strategies using installed installed equipment equipment including including modifications modifications that are that are proposed proposed to maintain spent fuel fuel pool cooling. Identify Identifymethods methods(makeup (makeupwith withportable portableinjection injection source)and strategy(ies) utilized source)and strategy(ies) utilized to achieve to achieve this coping coping time There are There are no no Phase Phase11actions actionsrequired.

required. Below Below is is aa description description of ofthe theSFP SFP and the decay heat loading loading forfor the pool. Effects from loss of cooling Effects from loss of cooling are also are also included which indicate no operator action indicate no operator action is required for is required for 38.65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> (time to to boil boil off off to the the toptopofoffuel fuelracks) racks) afterafterloss lossof ofcooling coolingusing using the theMaximum MaximumAbnormal Abnormal Load (MAHl)

Heat load (MAHL) from Reference Reference 2. 2.

The CPS The CPSspent spentfuelfuel pool pool has has aa capacity capacity of 3796 fuel storage storage cells.

cells. OnOn an an as-needed as-needed basis basis the the cask cask storage storage pool may be utilized for for storage storage of ofup up to to22racks racks with with264 264cells cells capacity capacity which which increases increases the pool pool total total storage capacity to 4060 fuel assemblies. assemblies. CPS CPS is is licensed licensedto to store store 3,796 3,796 fuel assemblies assemblies in in the the spent fuel pool and an additional additional 363 363 inin thethefuel fuelcask caskstorage storagepool, pool,asas needed.

needed.

Reference 1 discusses the peak peak fuel fuel pool pool temperature temperaturefor fortwo twodecaydecayheat heatloadloadcases caseswithwiththe the Fuel FuelPool Pool Cooling and Cleanup System (FC) (FC) in in service service and and alsoalso withwith aa sudden loss loss of of the the FC FC system. The Thebasis basis for forthe the UFSAR discussion UFSAR discussion is contained is contained in Reference 2.

2.

Case 1 Maximum Normal Heat Heat Load Load (MNHL)

(MNHL) --This Thisnormal normalbatchbatch discharge discharge case conservatively conservatively assumes assumes more fuel cells cells are are occupied than than available.

available. The TheMNHL MNHLcase case assumes assumes that that the the spent spentfuel fuelpool pooland andcask cask storage pool has has a combined total total of of4159 4159cells cellsto tostore storespent spentfuel fuelbundles bundlesand and40564056cells cellshave havealready already been been filled with with spent spent fuel fuel bundles bundles from from 13 13previous previous 18 18 month monthlong longoperating operatingcycles.

cycles. The Thenormal normalbatchbatch discharge of 312 bundles with an an average exposure of 43.0 GWd/MT is initiated initiated 24 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hours after afterreactor reactor shutdown shutdown from from aa24 24 month monthlong longoperating operatingcycle.cycle. So Sothe thespent spentfuel fuelstorage storageisis conservatively conservatively overfilled overfilled after after this this batch batch discharge.

discharge. The The MNHL MNHL is calculated calculated to to be 27.7 27.7 million million Btu/hr.

Btu/hr.

Case Case 22 Maximum Maximum AbnormalAbnormal Heat HeatLoad load (MAHL)

(MAHl) -- This This full-core full-core discharge discharge case case isis an extension extension from fromthe the MNHL case case afterafter 24 24 months months of full power power operation operationfrom fromthe thelastlastoutage.

outage.This Thiscase caseassumes assumesthat thataafull-full-core discharge of 624 fuel bundles with with anan average average exposure of of 43.0 GWd/MTGWd/MT is is initiated initiated 24 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hours after after shutdown.

shutdown. The Theprevious previousbatchbatchof of312 312fuel fuel bundles bundlesdischarged discharged in in the thespentspentfuelfuelstorage storagepool poolmentioned mentionedinin Case Case 11 hashasjust justdecayed decayedfor for2424months.

months. So the spent fuel storage is So the is conservatively conservatively overfilled after after this this full-full-core core discharge. The The MAHL MAHL is calculated to be 40.0 million million Btu/hr.

Btu/hr.

The The analysis of Case Case 11shows showsthat that the the spent fuel pool and and cask cask storage pool bulk bulk temperature temperaturewill willpeak peakatat 125.8°F if the the batch discharge discharge of of 312 312 bundles bundles isisinitiated initiated 24 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hours afterafter reactor shutdown with with oneone train train of of FC FC ininoperation.

operation. The The highest highest evaporation evaporationheat heatloss lossrate ratereaches reaches0.4 0.4million millionBtu/hr.

Btu/hr.Additionally Additionallyfor for Case Case 1, 1, itit is is assumed assumedthat that all all pool pool cooling cooling isis lost lost when when spentspent fuel fuel pool temperature temperature isis at at its its peak.

peak. ItItwould would take 5.3 hours for the pool temperature to reach boiling, and the take 5.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for the pool temperature to reach boiling, and the peak boil-off rate at about 60 gpm, peak boil-off rate at about 60 gpm, which which isis less less than than the the Seismic Seismic Category I spent fuel pool pool emergency emergency water watermakeup makeupsystem systemcapability capabilityofof 100 100 gpm. Calculation Calculation 01FC43 01FC43 shows that for Case 1 the time to to reach reach the thetop topofofthethefuel fuelracks rackswith withno no 33 Coping Coping modifications modificationsconsist consistof ofmodifications modificationsinstalledinstalledtotoincrease increaseinitialinitialcoping copingtime, time,i.e.,

i.e.,generators generatorstoto preserve preservevital vitalinstruments instrumentsororincreaseincreaseoperating operatingtime timeon onbattery batterypowered poweredequipment.

equipment.

Page Page30 30of of5959

Clinton Power Clinton Power Station, Station, Unit Unit 1 Mitigation Mitigation Strategies Integrated Plan makeup is makeup is 55.81 55.81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br />.

The analysis The analysisofofCase Case22shows showsthat thatthe thespent spentfuel fuel pool pool andand cask caskstorage storagepoolpool bulk bulk temperature temperature reachesreaches aa maximum of maximum of 134.9°F 134.9°Fwith with only onlyone one train train of FCFCoperating operating (both trains trains available) available) ifif aa full full core discharge discharge 624 624 bundles(after bundles (after 24 24 months months ofof full full power power operation) operation) is initiated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reactor is initiated reactor shutdown.

shutdown. The The worst worst evaporation heat loss evaporation loss rate rate isisabout about 0.60.6 million million Btu/hr. Additionally Additionallyfor forCase Case2,2, ititisis also also assumed assumed that all pool cooling pool coolingisislost lostwhen whenspent spentfuel fuelpool pooltemperature temperature is at its is at its peak.

peak. The The pool temperature temperaturerises risestotoboiling boiling in 3.2 in 3.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

hours. The peak boil-off boil-offraterateisisabout about86 86gpm, gpm,which whichisisless less than thanthetheSeismic SeismicCategory CategoryIIspentspentfuel fuel pool emergency water pool water makeup makeup systemsystem capability capability ofof100100gpm.

gpm.Calculation Calculation01FC43 01FC43shows showsthatthatfor forCase Case22 the time to reach the reach the top top of of thethe fuel fuelracks racks with withno nomakeup makeup isis 38.65 38.65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br />.

hours.

References References

1. CPS

1. CPSUFSAR UFSARsection section9.1.3.3.1 9.1.3.3.1

2. Calculation

2. Calculation 01FC43, 01FC43, Rev Rev 11 Details:

Provide a brief N/A N/A description of Procedures I/ Strategies /I Guidelines Guidelines Identify any equipment equipment SFP Level SFP LevelModification Modification as required required by byEA-12-051 EA-12-051 modifications Key SFP Key SFP Parameter Parameter SFP Level SFP Levelprovided provided by by modification modification required requiredby byEA-12-051 EA-12-051 Clinton's evaluation of of the the FLEX strategy may FLEX strategy may identify identify additional additional parameters that are are needed in order order toto support supportkey key actions actions identified identifiedinin the plant plant procedures/guidance procedures/guidance or or to indicate indicate imminent imminentor oractual actual core core damage (NEI 12-06 Rev.

(NEI 12-06 Rev.00Section Section3.2.1.10) 3.2.1.10) and and any any differences differences will be be future 6-month update following identification.

provided in a future identification.

Notes:

Exelon Generation Company, Exelon Generation Company, LLC (Exelon)has LLC (Exelon) hasnot notfinalized finalizedthe the engineering engineering designs designsfor forcompliance compliancewith with NRC OrderEA-12-049.

NRC Order EA-12-049.Detailed Detaileddesigns designsbased based on on the the current current conceptual conceptualdesigns designswill will be bedeveloped developedtoto determine determine the thefinal final plan plan and and associated associated mitigating mitigating strategies.

strategies.Analysis Analysis will will be performed performed to to validate validate that that the the plant plant modifications, modifications, selected selected equipment, equipment,and andidentified identifiedmitigating mitigatingstrategy strategycan cansatisfy satisfythe thesafety safety function requirements requirementsofofNEI 12-06. Once NE112-06. Once these thesedesigns designsand andmitigating mitigatingstrategies strategieshave havebeen been fully fully developed, Exelon will update the integrated Exelon will integrated plan plan for forClinton Clinton during duringaascheduled scheduled 6-month6-month update.

update.This This update update will will include any changes to the the initial initial designs designs as as submitted submittedin in the theFebruary February28, 28,2013 2013integrated Integrated Plan.

Plan.

Page Page 31 31 ofof59 59

Clinton Clinton Power Power Station, Station, UnitUnit 11Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Maintain Spent Maintain SpentFuel FuelPool Pool Cooling Cooling Portable Equipment BWR Portable EquipmentPhase Phase2:2:

Provide Provide aa general general description description of ofthe the coping coping strategies using on-site portable equipment including modifications modifications thatthat areare proposed proposedto to maintain maintainspent spentfuel fuel pool poolcooling.

cooling. Identify Identifymethods metlwds(makeup(makeupwith withportable portable injection source) injection source) and and strategy(ies) utilizedtotoachieve strategy(ies) utilized achievethis thiscoping copingtime.

time.

After After the the SFP SFP reaches the the boiling boiling point aa source source of of makeup makeup water waterwill will need needto tobebeprovided providedtotoensure ensurethe thefuel fuel in the SFP remains cool SFP remains cool and radiological radiological conditions on the the fuel fuel handling handling floor floor dodo notnotdegrade.

degrade.The The seismically seismically qualified qualifiedemergency emergencySFP SFP makeup makeup supplysupply from fromthe theSX SX system system will willbe beused usedto tosupply supply>86>86gpmgpmtoto the the SFP.

SFP. Motor Motoroperated operatedvalvevalve1SX016A lSX016A[Reference

[Reference1]1]and and1SX016B lSX016B[Reference

[Reference2]2]SX SXToToFuel FuelPool PoolMake-Up Make-Up Valves can be operated operatedmanually manuallywith withthe thehandwheel, handwheel, oror with with ACACpower power supplied supplied from from thethe FLEX FLEXDiesel Diesel Generator.

Generator. The The valve used will will depend depend on on which whichSX SX division division the the external externalwater waterconnection connectionisissupplying.

supplying.

The supply to the the SX system from SX system from the external water water connections connections isis described described in in the the Safety Safety Function Function Phase 2 section.

Support Phase Support section.

Alternatively, Alternatively, a firefire hose can be connected connected to tothe theexternal externalwater waterconnection connectionand and routed routed upup thethe Fuel Building Fuel Building east east or or west weststairwell stairwellto tothe thefuel fuelhandling handlingfloor, floor,utilizing utilizingaanozzle nozzlerestrained restrainedatatthe theSFP SFPhandrail.

handrail.

By To+12hours By To+12 hoursthe theSXSXsupply supplyheader headerwill willbebepressurized pressurizedfrom fromthetheexternal external water water connection, and and makeup makeup flow flow can can then then bebe established established via via 1SX016A lSX016A or or lSX016B.

1SX016B. IfIf needed, needed, aafirefire hose hoseon onthethe fuel fuel handling handling floor floor will also be available as as an alternate alternateSFP SFP makeup supply.supply.

Evaluation of Evaluation of the the spent spent fuel pool area for steam steam and and condensation condensationhas hasnotnotyetyetbeen beenperformed.

performed.The Theresults results of this evaluation and the the vent vent path path strategy, strategy,ififneeded, needed,will will bebeprovided provided in in aafuture future6-month 6-monthupdate.

update.

SFP Spray SFP A fire hose A fire hose will willbe beconnected connected to the external external water waterconnection connectionand androuted routedupupthe the Fuel FuelBuilding Buildingeasteastororwest west stairwell to the the fuel fuel handling handling floor. This This fire fire hose hose can can supply supply aa monitor monitor nozzle nozzle staged staged on on the thefuel fuelhandling handling floor to floor to provide providethe theSFP with 250 SFP with 250 gpm gpm ofof spray.

spray.

References References

1. CPSCPS Drawing Drawing M05-1052, M05-1052,Sheet Sheet 001, RevRev DOl, AX,AX, SHUTDOWN SHUTDOWN SERVICE SERVICEWATER WATER(SX) (SX)

2. CPSCPS Drawing Drawing M05-1052, MOS-l052,Sheet Sheet 002, RevRev 002, ACl,AQ P AND P AND ID IDSHUTDOWN SHUTDOWN SERVICE SERVICEWATER WATER(SX) (SX)

Schedule:

Provide a brief Confirm that procedure/guidance procedure/guidance exists exists oror will will be be developed developedtoto description of Procedures support implementation II Strategies I/ Guidelines Clinton will Clinton willuse usethe the industry industry developed developed guidance from from thethe Owners OwnersGroups, Groups, EPRIand EPRI andNEINEITask Taskteamteamtotodevelop developsite site specific specific procedures procedures or or guidelines guidelines to to address thethe criteria criteria inin NEI 12-06. These NEI12-06. These procedures procedures and/or and/orguidelines guidelineswillwill support thethe existing existing symptom based command command and and control control strategies strategiesinin the current current EOPs.

EOPs. Procedural changes changes willwill include reference to level level indication that indication that will will be beprovided providedininaccordance accordancewith withEA-12-051.

EA-12-051.

Identify modifications modifications List modifications modifications The electrical The electrical support support and and cooling/makeup cooling/makeup water support support modifications modifications Page 32 of 59 Page

Clinton Power Clinton Power Station, Station, Unit 1 Mitigation Strategies Integrated Plan Maintain Spent Fuel Maintain Fuel Pool Cooling BWR Portable BWR Equipment Phase 2:

Portable Equipment required to provide required provide UHS water for SFP UHS water makeup are SFP makeup are discussed in the the Safety Safety Function Support section.

Function Key Key SFP SFP Parameter Parameter SFPLevel SFP Levelprovided provided by by modification modification required required by byEA-12-051 EA-12-0S1 Clinton's evaluation of of the the FLEX strategy may FLEX strategy may identify identify additional parameters that parameters that are needed in order to supportsupport keykey actions actions identified identifiedinin the plant procedures/guidance or to indicate imminent imminent or or actual actual core core damage (NEI damage (NEI 12-06 12-06 Rev.

Rev.00Section Section3.2.1.10) 3.2.1.10)and andanyanydifferences differences willwill be provided in provided in aa future future 6-month 6-month update following identification.

identification.

Storage I/ Protection of Equipment :

stora ge / protection plan .or Describe storage or schedule to determine storastorage ge requirements Seismic List how equipment is protected or schedule to to protect protect Structures to provide protection protectionof ofFLEX equipment will be constructed to FLEX equipment to meet the meet the requirements requirementsofofNEI NEI 12-06 12-06 Section 11. Schedule to construct construct permanent buildings permanent buildings is is contained contained inin Attachment Attachment2, 2, and andwill will satisfy satisfy the the site site compliance date. Temporary locations will be used used until building building construction completion.

completion. Procedures Procedures and programs will be be developed developed to to address storage storage structure structurerequirements, requirements,haulhaulpath pathrequirements, requirements, and and FLEX FLEX equipment requirements equipment requirements relative relativeto tothe theexternal externalhazards hazardsapplicable applicableto to Clinton Power Power Station.

Station.

Flooding List List how equipment equipment is is protected protected or or schedule schedule to to protect protect Note: if if stored stored below below current current flood flood level, level, then then ensure ensure procedures procedures exist existto to move move equipment equipment prior prior to to exceeding exceeding flood flood level.

level. Structures Structures to to provide provideprotection protectionofofFLEX equipment will FLEX equipment will be constructed constructed to to meet the meet the requirements requirementsofofNEI NEI 12-06 12-06Section Section 11.

11.Schedule Schedule to to construct construct permanent permanentbuildings buildings is is contained contained inin Attachment Attachment2,2,and andwill will satisfy satisfy the the site site compliance date. Temporary locations will be used until building building construction construction completion.

completion.Procedures Procedures and and programs programs will will be be developed developed to to address storage structure structure requirements, requirements,haulhaulpath pathrequirements, requirements,and andFLEX FLEX equipment equipment requirements requirementsrelative relativeto tothe theexternal externalhazards hazardsapplicable applicableto to Clinton Power Power Station.

Station.

Severe StormsStorms with High High List List how equipment equipment is is protected protected or or schedule schedule to to protect protect Winds Structures to provide provide protection protectionofofFLEX FLEX equipment will will be be constructed constructed to to meet meet the the requirements requirementsofofNEI NEI12-06 12-06Section Section11.

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

completion.Procedures Procedures and and programs programs will will be be developed developed to to address address storage structure structure requirements, requirements,haulhaulpath pathrequirements, requirements, and and FLEX FLEX equipment equipment requirements requirementsrelative relativeto tothe theexternal externalhazards hazardsapplicable applicableto to Clinton Power Station.

Clinton Power Station.

Page Page 33 33 of of5959

ClintonPower Clinton PowerStation, Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain Spent Maintain Spent Fuel Fuel Pool Pool Cooling Cooling BWRPortable BWR Portable Equipment Equipment Phase 2: 2:

Snow, Ice, Snow, Ice, and and Extreme Extreme List how List how equipment isis protected protected or or schedule schedule toto protect protect Cold Cold Structuresto Structures to provide provide protection protection of FLEXFLEX equipment equipment will will be be constructed constructed to to meet meet the the requirements of NEI of NEI 12-06 12-06 Section Section 11.

11. Schedule Schedule to construct to construct permanent buildings permanent buildings isis contained contained in in Attachment Attachment 2, and will will satisfy satisfy the site the site compliance date.

compliance date. Temporary locations will be used Temporary locations used until building building construction completion.

construction completion. Procedures Procedures and and programs programs will will be be developed developed to to addressstorage address storagestructure structure requirements, requirements, haul path requirements requirements,, and and FLEX FLEX equipment requirements relative equipment relative to to the theexternal externalhazards hazards applicable applicable to to Clinton Power Clinton Power Station.

High Temperatures High Temperatures List how equipment is protected or schedule to protect Structures to Structures to provide provide protection protectionofofFLEX equipment will FLEX equipment will bebe constructed constructed to to meet the meet the requirements requirementsofofNEI 12-06 Section 11. Schedule to construct NE112-06 construct permanent buildings permanent buildings isis contained contained in in Attachment Attachment 2, 2, and and willwill satisfy the site site compliance date.

compliance date. Temporary Temporary locations locationswillwill be be used used until until building building construction completion. Procedures and construction and programs programs will will be developed to to address address storage storage structure structurerequirements requirements, , haul haulpath pathrequirements requirements, , andand FLEX FLEX equipment requirements equipment requirements relative relative to to the theexternal externalhazards hazardsapplicable applicable to to Clinton Power Clinton Power Station.

Station.

Deploymentt Conceptual Deploymen Conceptual DesignDesign Attachment 33 contains (Attachment contains Conceptual ConceptualSketches)

Sketches)

Strategy Strategy Modificatio Modifications ns Protection of Protection ofconnections connections Identify Identify Strategy Strategy including including howhow dentify modification Identify modifications s Identify how Identify how the the connection connection is is the equipment will be deployed the equipment deployed protected protected to to the the point pointof ofuse.

use.

The The electrical electrical support support and and The electrical support support andand connection points The external connection points cooling/make cooling/makeup up water water support support cooling/make cooling/makeup water support up water support are common to are to core core cooling, cooling, deployment strategies deployment strategies are are modifications modifications are common to are common tocore core containment, and containment, and spent spent fuel fuel pool pool common common to to core core cooling, cooling, cooling, cooling, containment, containment, and and spent spent makeup functions.

makeup functions. The The protection protection containment, containment, and and spent spent fuel fuel pool pool fuel fuel pool pool makeup makeup functions. The functions. The discussion is discussion is in in the the Safety Safety makeup functions. The discussion makeup functions. The discussion discussion discussion is in the Safety is in the Safety Function Support Function Supportsection.

section.

is is in in the the Safety Safety Function Function Support Support Function Function Support Support section.

section.

section.

section.

Hoses will be Hoses will be pre-staged pre-staged to to supply supply None None Hoses will Hoses will be be staged staged inin aastructure structure makeup makeup waterwaterto tothe theSpent SpentFuelFuel protected from protected from external externalhazards.

hazards.

Pool.

Pool.

Page Page34 34ofof59 59

Clinton Power Station, Unit Unit 11 Mitigation Mitigation Strategies StrategiesIntegrated IntegratedPlan Plan Maintain Maintain SpentSpent Fuel Fuel Pool Pool Cooling Cooling BWR Portable Equipment EquipmentPhase Phase2: 2:

Notes:

Exelon Generation Exelon Generation Company, Company, LLC (Exelon)has LLC (Exelon) hasnot not finalized finalized the the engineering engineeringdesigns designsfor forcompliance compliancewith withNRC NRC Order EA-12-049. Detaileddesigns EA-12-049. Detailed designsbased based on on thethe current current conceptual designs designs will be developed to determine will be determine the final final plan and associated mitigating mitigating strategies. Analysis Analysis will be performed to validate that will be that the theplant plant modifications, selected equipment, modifications, equipment,and andidentified identifiedmitigating mitigatingstrategy strategycan cansatisfy satisfythe thesafety safetyfunction function requirements of requirements ofNEI Once these NEI 12-06. Once these designs designs andand mitigating mitigating strategies strategieshave havebeen beenfully fullydeveloped, developed,Exelon Exelon will update the integrated will update integrated plan plan for for Clinton Clinton during a scheduled 6-month update. update. This Thisupdate updatewill will include include any any changes to thethe initial initial designs as submitted submitted inin the theFebruary February28, 28, 2013 2013 Integrated IntegratedPlan.

Plan.

Page 35 of of 59

Clinton Power Station, Unit 1 Mitigation Strategies Strategies Integrated Integrated Plan Plan Maintain SpentSpent Fuel Pool Cooling Cooling BWR Portable Equipment Equipment Phase Phase3: 3:

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

cooling. Identify Identifymethods methods(makeup (makeupwith withportable portableinjection injection source)and strategy(ies) utilized to to achieve achieve this this coping coping time.

time.

Phase Phase 11 and and 2 strategy will provide provide sufficient sufficientcapability capabilitysuch such that thatnonoadditional additionalPhase Phase33strategies strategiesareare required.

Phase Phase 33 equipment Clinton includes equipment for Clinton includes backup portable pumps pumps and and generators.

generators. TheThe portable portablepumps pumpswill willbebe capable of providing providing the the necessary necessary flow flow and and pressure pressure asas outlined outlinedin inPhase Phase 22response response for forCore CoreCooling, Cooling, Containment, and and Spent Spent Fuel Fuel Pool Pool Cooling. generators will Cooling. The portable generators will be be capable capable ofofproviding providing the the necessary 480 480 volt volt power power requirements requirementsas asoutlined outlinedininPhase Phase22response responsefor forSafety SafetyFunctions FunctionsSupport.

Support.

Schedule:

Provide a brief Confirm that procedure/guidance procedure/guidance exists exists or orwill willbe bedeveloped developedtoto description ofof Procedures Procedures support implementation implementation I/ Strategies I/ Guidelines Clinton will use the industry developed guidance guidance from the the Owners OwnersGroups, Groups, EPRI and EPRI and NEI NEI Task team to develop developsitesitespecific specificprocedures proceduresor orguidelines guidelines to to address the criteria in address in NEI NEI12-06.

12 -06. These procedures and/or and/or guidelines guidelines will will support the existing existing symptom symptom basedbasedcommand commandand andcontrol controlstrategies strategiesinin the current currentEOPs.

EOPs.

Identify modifications List modifications modifications None None Key SFP Parameter Clinton's evaluation of the FLEX strategy may Clinton's evaluation may identify identify additional additional parameters thatthat are are needed needed in in order orderto tosupport supportkey keyactions actions identified identifiedinin plant procedures the plant procedures/guidance

/guidance or to indicate imminent imminent or oractual actual core core damage (NEI(NEI12-06 Rev. 0 Section 33.2.1.10) 12 -06 Rev. .2.1.10) and any differences will be be provided in a future 66 month month update updatefollowing followingidentification.

identification.

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

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

use.

None None None None None None Page 36 of of 59

Clinton Power StatIon, Unit 11 Mitigation Power Station, MitigatIon Strategies StrategIes Int Integrateded Plan Plan Maintain Maintain Spent Spent Fuel Fuel Pool Pool Cooling Cooling BWR Portable Portable Equipment EquipmentPhase Phase3: 3:

Notes:

Notes:

Exelon Generation Company, Exelon Generation Company,LLC (Exelon)has LLC (Exelon) has not not finalized finalized the engineering engineeringdesigns designsfor forcompliance compliancewith NRC with NRC Order EA-12-049. Detailed designs EA-12-049. Detailed designs based based on on the the current conceptual conceptual designs designs will will be developed to determine determine the the final final plan and associated associated mitigating mitigating strategies.

strategies. Analysis Analysis will be performed to validate that will be thatthe theplant plant modifications, selected equipment, equipment,and andidentified identifiedmitigating mitigatingstrategy strategycan cansatisfy satisfythe thesafety safetyfunction function requirements requirementsof ofNEI 12-06. Once these NEI12-06. these designs designs and and mitigating mitigating strategies strategieshave havebeen beenfully fullydeveloped, developed,Exelon Exelon will update the integrated will update integrated plan plan for for Clinton Clinton during a scheduled 6-month update. update.This Thisupdate updatewill will include include any any changes to to the the initial initial designs designs as as submitted submittedin in the theFebruary February28,28,2013 2013Integrated IntegratedPlan, Plan.

Page 37 of 59

Clinton Power Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Safety Functions Safety Functions Support Support Determine Baseline coping capability with installed coping Determine coping4 modifications not including modifications.

FLEX modifications.

BWR Installed Installed Equipment EquipmentPhase Phase11 Provide Provide a general general description description of of the the coping coping strategies strategies using usinginstalled installedequipment equipment including including station station modifications that modifications proposed totomaintain that are proposed maintainand/orand/orsupport supportsafety safetyfunctions.

functions. Identify methods methods and ana utilized totoachieve strategy(ies) utilized strategy(ies) achievecoping copingtimes.

times.

DC Power SupportSupport 125 VDC VDC powerpower will willbe be available available from station station batteries batteriesduring during Phase 1. 1.

Phase Division Division1 DC1 DCMCC MCC1A 1A will will continue continue to to supply supply the theRCIC system controls RCIC system controls and and indications, indications,SRV SRV solenoid solenoid power, power,and andNSPS NSPS Inverter Inverterfor forvital vital instrumentation.

RCIC Room RCIC Room Ventilation Ventilation The RCIC RCIC pump pumproom roomwillwillheat heatupupduring duringPhase Phase11fromfromthethe steam piping and suppression suppression pool poolpiping piping inside the room.room. GOTHIC analysis [Reference GOTHIC analysis [Reference 1] has shown that thatopening openingthe theRCIC RCIC room room doorsdoorsandand supplying supplying air air to to the the room will maintain habitable conditions.

will maintain conditions. Compensatory Compensatoryactions actionsare aredescribed describedinin Phase 2.2.

Main Control Room Habitability Main Control Habitability CPS 4200.01C001, CPS 4200.010001, MCR MCR COOLING COOLING DURING DURINGA A SBOSBO [Reference2]21

[Reference providesa amethod provides method for for maintaining maintaining control control room habitability during a station blackout for the station's designed four (4) hour coping blackout for the station's designed four (4) hour coping period. The period. The method utilizes a portable fan fan and and establishes establishesaaflowpath flowpath to to bring bring outside outside airair into into the the control room. The The for further need for furtheranalysis analysisisisdiscussed discussedininPhase Phase2. 2.

Battery RoomRoom Ventilation Hydrogen buildup in Hydrogen in the the battery battery rooms roomswill will not not begin begin until until aa480 480VAC generator is used to VAC generator to charge charge batteries in in Phase Phase 2. 2. The The need need forfor further furtheranalysis analysisofofbattery batteryroomroomconditions conditions during during anan ELAP/LUHS ElAP/lUHSisisan an open item. Closure open Closure of of this this item item will be documented in a future future 6-month update.update.

Inverter Room Ventilation Division11NSPS The Division NSPSinverter inverterwill willbebeenergized energizedduring duringPhase Phase 11without without normal cooling from the the room room cooler. The cooler. The inverter inverter room room doordoorwillwill be propped propped open openduring during Phase Phase 11to toprevent preventoverheating overheatingthe theinverter.

inverter.

need for The need for further furtheranalysis analysisof ofinverter inverterroomroomheatup heatup during during ananELAP/LUHS ElAP/lUHS is is an open open item.

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

update.

Fuel Building Fuel Building Habitability Habitability Environmental conditions in the fuel fuel building building will remain acceptable will remain acceptable during during Phase Phase 11since since boiling boiling in in the the SFPwill SFP will not not occur occur for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> [Reference

[Reference 3]. 3].

4 Coping modifications consist of 4 of modifications modifications installed installedtotoincrease increaseinitial initialcoping copingtime, time,i.e.,

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

equipment.

Page 38 of 59

Clinton Power Power Station, StatIon, UnitUnit11Mitigation MitigatIonStrategies StrategIesIntegrated IntegratedPlan Plan References References

1. S&L Calculation 2013-01301,

1. 2013-01301, Revision Revision 0, 0, 11332-295, 11332-295,"Transient "TransientAnalysis AnalysisofofRCIC RCIC Pump PumpRoomRoom for for Extended Extended Loss Loss of of A-C A-C Power" Power" CPS 4200.01C001

2. CPS 4200.01C001, MCR1 MCRCOOLING COOLING DURINGDURINGAASBO, SBO, RevRev4c4c

3. EC EVAL382149 EC EVAL Rev00, C1R13 382149 Rev 1 CSR13 Decay Decay Heat Heat Details:

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

support implementation.

Procedures /I Strategies Procedures Strategies I Guidelines Clinton willuse Clinton will use the the industry industry developed developed guidance guidance fromfrom the theOwners OwnersGroups, Groups, EPRI EPRI andandNEINEITask Taskteam teamtotodevelop develop site site specific specific procedures or or guidelines guidelinesto to address the criteria criteria inin NEI 12-06. These NEI12-06. These procedures and/or and/or guidelines guidelines willwill support support the the existing existing symptom symptombasedbased command command and and control controlstrategies strategiesinin the the current currentEOPs.EOPs.

Identify modifications Identify modifications List List modifications modifications and and describe describe howhowthey theysupport supportcoping copingtime.

time.

None None Key Parameters Parameters List instrumentation credited credited for thisthis coping coping evaluation evaluation phase.

phase.

None None Clinton's evaluation Clinton/s evaluation of ofthe theFLEX strategy may identify additional FLEX strategy additional parameters that are are needed in order to to support support key key actions actions identified identifiedinin the plant plant procedures/guidance procedures/guidance or to indicate indicate imminent imminentor oractual actual core core damage (NEI 12-06 Rev.

(NEI12-06 Rev. 00 Section Section 3.2.1.10) 3.2.1.10) and any differences differences will willbe be future 6-month update following identification.

provided in a future identification.

Notes:

Exelon Generation Exelon Generation Company, Company, LLC (Exelon)has LLC (Exelon) hasnot notfinalized finalizedthethe engineering engineering designs for for compliance compliance with with NRCOrder NRC OrderEA-12-049.

EA-12-049.Detailed Detaileddesigns designsbasedbasedon onthe the current conceptual conceptual designs designswill will be be developed developedto to determine the determine the final final plan plan and and associated mitigating strategies.

associated mitigating strategies. Analysis Analysis will will be be performed performedto tovalidate validatethat that the plant plant modifications, modifications, selected selected equipment, equipment,and andidentified identifiedmitigating mitigatingstrategy strategycancansatisfy satisfythe thesafety safety function requirements function requirementsofofNEI 12-06. Once NEI12-06. Oncethese thesedesigns designs andand mitigating mitigatingstrategies strategieshave havebeen beenfully fully Exelon will developed, Exelon will update the integrated plan plan for for Clinton Clinton during during aa scheduled scheduled 6-month 6-month update.

update. ThisThis update will include any changes include any changes to the initial designs as submitted in the February 28, 2013 initial designs as submitted in the February 28, 2013 Integrated Integrated Plan.

Page 39 of 59

Clinton Power Station, Station, Unit Unit 11Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Safety Functions Support Support BWR PortablePortable Equipment Equipment Phase Phase 22 Provide aa general generaldescription descriptionof ofthe the coping coping strategies strategiesusingusingon-site on-siteportable portableequipment equipmentincluding includingstation station modifications that that are proposedtotomaintain are proposed maintainand/or and/orsupport supportsafety functions. Identify safetyfunctions. Identify methods and strategy(ies) strategy(ies) utilized utilized totoachieve achievecoping copingtimes.

times.

Electrical Support Key portions of Key portions of the the Division Division 1, 11 Division Division 2/ 2, and non-divisional non-divisional 480 480VAC distribution system VAC distribution system willwill be beable abletotobe be re-energized from from aapre-staged pre-stagedprimary primaryFLEX generator or aa portable FLEX generator portablealternate alternateFLEX generator. Either FLEX generator. Either generator generatorindependently independentlywill willenable enablemaintaining maintaining DCDCpower powerfor forRCIC, RCICI SRV controls and SRV controls and vital vital instrumentation instrumentation, l and provide provideAC AC power power for forhydrogen hydrogenigniters, ignitersSPMUl SPMUvalves valvesand andsuppression suppression pool poolcooling cooling FLEX FLEXpump.

pump .

• The The primary primary FLEX generator and FLEX generator and switchgear switchgear will will bebe permanently permanently housed housed in in the theUnit Unit22sidesideofofthe theControl Control and Diesel Generator buildings; Diesel Generator therefore, deployment buildings; therefore l deploymentwill will not notbe beimpeded impededby byaabeyond beyonddesign designbasisbasis external event external event(BDBEE).

(BDBEE). The The connecting connecting cabling will be pre-routed pre-routedfrom fromthe thevicinity vicinityofofthe theprimary primary FLEX FLEX switchgear switchgear to to the thevicinity vicinity ofof the theDivision Division 14801480VAC substations which VAC unit substations which will will have have connection connectionpoints pointsfor for an external source source of of power.

power .

• The The alternate alternate(N+1)(N+1) portable portableFLEX generator will FLEX generator able to will able to be deployed deployed to to an anexternal externalelectrical electricalconnection connection point. AA heavy heavy duty duty truck truck capable capable of of clearing clearing debris debris from from the the travel travel path pathwill will be be stored storedininthe thesame same location. The switchgear for the alternate alternategenerator generatorwill willbebehoused housedininthe theUnitUnit22sidesideofofthe theDiesel Diesel Generator Building.

Generator Building. The The connecting connectingcablingcablingwill will be be pre-routed pre-routedfrom fromthe thevicinity vicinityofofthe thealternate alternate FLEX FLEX switchgear to switchgear to the thevicinity vicinity ofof the theDivision Division 22480 480 VAC VAC unitunitsubstations substations and the the swing swing battery batterycharger.

charger.The The substations will unit substations will have connection points points for for an an external externalsourcesourceof ofpower.

power.

Once the event eventisis identified identifiedas asananELAP/LUHS, ElAP/lUHS/ operationsoperations personnel personnel will line up and start will line start the theprimary primaryoror alternate FLEX alternate generator and perform FLEX generator perform aalineup lineupthat thatenables enableskey key480 480VACVAC components, components including l includingthe theDivision Division battery charger, 1 battery charger/ to tobe bere-energized re-energizedbybyTo+5 To+5 hrs.hrs.

Cooling/Makeup Cooling/ Makeup Water Water Support Support A portable A portable diesel driven driven pump pump willwill be be able able totobe bedeployed deployedtotothe Ultimate the Ultimate Heat Heat Sink Sink(UHS)

(UHS)atatthe theCirculating Circulating Water Screen House (699' (699 1 elevation). The The pump pumpwill will take take itsits suction suction from from the theUHS UHS and discharge to to the the second portable diesel driven suction of a second driven pump pump storedstored inin the same storage storage structure structureand anddeployed deployedatatgradegrade elevation (736' (736/ elevation) in in the the vicinity external water vicinity of external water connections.

connections. The Thesecond secondpump pumpwill willdischarge dischargeto to one of two external water water connections.

connections.

Provisions will Provisions willbebemade made forfor accessing accessing the the UHS UHSshouldshouldthe the downstream downstream main main dam dam fail fail during aa seismic seismic event.

event.

In this event In this event the surface of the lake could drop from approximately 690' elevation of the lake could drop from approximately 690 elevation to 675/ elevation.

1 to 675' elevation.

The external water water connections con nectionswill will be be hard-piped hard-pipedtotoboth boththe theDivision Division11and andDivision Division22Shutdown ShutdownService Service Water (SX)

Water System. The (SX) System. The Control Control Room Room Ventilation Ventilation(VC) (VC) chillers werewere designed designedfor foraaUnit Unit11ororUnit Unit2 2SX SX supply, and the supplYI the Unit Unit 22 supply (currently blind-flanged) is the proposed proposedconnection connectionpoint pointforforcross-tying cross-tyingtoto Unit 1 SX. The Division SX. The Division 11 VC VCchiller chillerwill willenable enable the the supply supply to toDivision Division11SX, SX, andandthe theDivision Division22VC VCchiller chillerwill will enable thethe supply supplyto toDivision Division 22 SX.SX. The SX SXsystem systemwill willallow allowcooling coolingwater waterto to be be supplied supplied to the the associated associated RHRHeat RHR HeatExchanger Exchangerfor forsuppression suppression pool pool cooling coolingand and to to supply makeup water waterto tothe theSpent SpentFuelFuelPool.

Pool.

The external connections The connectionswill will also also supply supply makeup makeupwater watertotothe theRPV RPVand andsuppression suppressionpool poolusing usingthetheLPCS lPCSandand RHR-Cmodifications RHR-C modificationsdescribed described in Core Cooling Phase Phase 2. 2.

Page 40 of 59

Clinton Power Station, Unit 11 Mitigation Strategies Strategies Integrated Integrated PlanPlan Safety Functions Support BWR Portable Equipment Phase 2 RCIC Room RCIC Room Ventilation Ventilation The RCIC RCIC pumppumproomroom will willreach reach 145°F 145°Fwithin within 42 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> hours if no action is taken.taken. ToTo improve improve conditions conditionsininthe the pump room for for equipment equipmentprotection protectionand andpersonnel personnelaccess, access, the the doors doors between betweenthe thepump pumproom roomand andthethe access aisle willwill be be opened opened and a portable portable blowerblower will inject air will inject air into into the the room. The The security security door door between between the Auxiliary and Turbine Turbine Building Building basement basement will will be be opened opened to to provide provide aa source sourceof ofair airfor forthe the blower.

blower. With With these actions taken, the temperature temperature in in the theroomroomwillwillremain remainbelowbelow145°F 145°F[Reference

[Reference 1]. 1].

Main Control Room Main Control Room Habitability Habitability Exelon Generation Exelon Generation Company, Company, LLC LLC(Exelon)

(Exelon)intendsintendstotomaintain maintainOperational Operationalcommand command and andcontrol control within within thethe Main Control Main Control Room.Room. Habitability Habitabilityconditions conditions will willbebeevaluated evaluated and and a strategy strategy will will be developed developed to to maintain maintain Main Control Main Control RoomRoom habitability.

habitability.The Thestrategy strategy and and associated associated support support analyses analyses will submitted in will be submitted in aa future future 6-month update.

update.

Battery Room Ventilation Ventilation Battery room doors doors will will be blocked open when when battery batterycharging chargingcommences commencesto tominimize minimizethe thepotential potentialfor for an explosive hydrogen concentration concentration to tobuild build up upinside inside the therooms.

rooms.Battery Batteryroomroomconditions conditionswill willbebe evaluated and a strategy will be be developed developed to to maintain maintainacceptable acceptableconditions.

conditions.The Thestrategy strategyand andassociated associated support analyses support analyses willwill be submitted in in aa future future 6-month 6-monthupdate.

update.

Inverter Room Ventilation The Division Division 11 NSPS NSPSinverter inverterwill willbebeenergized energizedduring duringPhase Phase 22 without without room cooling. InverterInverter roomroom conditions will will be be evaluated evaluated and and a strategy will be be developed developed to to maintain maintain acceptable acceptable conditions.

conditions. The The strategy and associated support analyses associated support analyses will will be submitted in in aa future future 6-month 6-monthupdate.

update.

Fuel Building Fuel Building Habitability Habitability Evaluation of the spent fuel pool Evaluation pool area area forfor steam steam and and condensation condensation has has not not yet yetbeen been performed.

performed.The Theneedneed for further furtheranalysis analysisof offuel fuelbuilding buildingconditions conditionsduring duringananELAP/LUHS ELAP/LUHS and and mitigating mitigating actions is is an open open item.

item.

Closure of Closure of this this item will bebe documented documented in in aa future future 6-month 6-monthupdate.

update.

Fuel Oil Supply Fuel oil Fuel oil to to diesel diesel driven driven pumps pumps and and generators generators will will be be supplied supplied by by the the quantity quantity ofof fuel in in the the tanks tanks located located the skids on the skids of the portable portable equipment equipmentand andby byfuel fueltanks tankscontained containedononthe theback backofofthe theFLEX FLEX truck.

truck. WhenWhen required, fuel required, fuel oil oil will will be obtained obtainedfrom fromthe theDivision Division1,1,ororalternatively alternativelythe theDivision Division2 2DG DGFuel FuelOilOil Storage Storage Tank. The The 480 480VAC FLEXgenerator VAC FLEX generator willwillsupply supply power power to the theDGDG Fuel Fuel Oil Transfer Pump Oil Transfer Pump which whichwill will provide provide the DG DG Day Tank with Day Tank with a continuous supply supply of of fuel fuel oil.

oil.The The DGDG Day TankTank drain drain line will be be used used to to supply supply aa portable 120 portable 120 VAC pump via VAC pump via aa flexible flexible hose hose connected connected to to the drain line.

line.

References:

1. S&L Calculation 2013-01301, Revision Revision 0, 0, 11332-295, 11332-295, Transient TransientAnalysis Analysis of ofRCIC RCIC Pump Room for for Extended Extended Loss of Loss of A-C A-C Power Details:

Provide a brief Confirm that procedure/guidance procedure/guidance exists exists ororwill willbebedeveloped developedtoto description of of Procedures Procedures support implementation with a description of ofthe the procedure / strategy strategy Page 41 of of 59 59

Clinton Power Station, Unit 11 Mitigation Mitigation Strategies StrategIes Integrated IntegratedPlan Plan Safety Safety Functions Functions SupportSupport BWR Portable EquipmentEquipment Phase Phase 2

/ Strategies / Guidelines //guideline.

guideline.

Clinton will Clinton willuse usethe the industry industry developed developed guidance guidance from from the theOwners OwnersGroups, Groups, EPRIand EPRI andNEINEITask Taskteam teamtotodevelop developsitesite specific specific procedures procedures or or guidelines guidelinesto to address thethe criteria criteria inin NEI 12-06. These NEI12-06. These procedures procedures and/or and/orguidelines guidelineswill will support the existing existing symptom symptom based based command command and and control controlstrategies strategiesinin the current currentEOPs.

EOPs.

Identify modifications List modifications necessary for Phase 2 Electrical Support Electrical

• • AA 480 480 VAC VACprimary primaryFLEX FLEX generatorwill generator willbebepre-staged pre-staged in the the Unit Unit 22 side side of the diesel diesel generator generatorbuilding.

building.An Analternate alternate (N+1)

(N+l)portable portable FLEX FLEX generator will generator will be be housed housed separately separately in in aa storage storage structure.

structure.

Electrical switchgear

• Electrical switchgear will will be be installed installed for the primary primary andand the the alternate alternate FLEXgenerators.

FLEX generators.

Cabling will

• Cabling will be be installed for connecting connecting the the generators generators to tothe the480480VAC VAC distribution system.

distribution system.

• Unit Substations Substations will will be modified to to enable enable cabling cabling from the the generators generators to supply power power to to the thebus busandand feed feed the theMotor MotorControl ControlCenters Centers(MCCs)

(MCCs) supplying the required required480 480VAC components.

VAC components.

• An connection point for An external electrical connection for the the alternate alternate generator generatorwill wi" be installed on the south side be side of of the the Diesel Diesel Generator Generator Building.

Building.

Cooling/Makeup Water Support

• A suction source for a portable diesel diesel powered powered pump pumpfromfromthe theUHS UHSwillwi" be installed atat the the Screen Screen House, House, including includingUHS UHS access modifications.

access modifications.

• Two external connections for for aa portable portable diesel diesel powered powered pumppump to to supply supply low pressure makeup makeup and and cooling cooling water water in the plant will will be be installed.

installed.

• A connection to the the Division Division 11 and and Division Division 22 Shutdown Service Service Water (SX) systemsfrom (SX) systems fromthe the external external water water connections will be be installed.

installed.

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

evaluation.

None None Clinton's evaluation evaluation of of the the FLEX strategy may FLEX strategy may identify identify additional additional parameters thatthat are are needed needed in orderorder toto support supportkey key actions actions identified identifiedinin the plant plant procedures/guidance procedures/guidance or or to to indicate indicate imminent imminentor oractual actual core core damage (NEI 12-06 Rev.

(NEI12-06 Rev. 00 Section Section 3.2.1.10) 3.2.1.10) andand anyany differences differences will be be provided in a future 6-month 6-month update updatefollowing following identification.

identification.

Storage Storage / Protection Protection of of Equipment Equipment:

Describe Describe storage storagee 1/ protection plan or protection plan or schedule to determine determine stora stora~ege requirements Seismic IList List how equipment equipment is is protected protected or or schedule schedule to to protect protect Page 42 of of 59 59

Clinton Power Station, Unit 1 Mitigation Strategies Strategies Integrated Integrated Plan Plan Safety Functions Support Equipment Phase 2 BWR Portable Equipment Structures to provide provide protection protectionofofFLEXFLEX equipment equipment will be constructed constructed to meet meetthetherequirements requirementsofofNEI NE112-06 12 -06 Section 11. Schedule to construct permanent permanentbuildings buildings isis contained containedininAttachment Attachment2,2,and andwill will site compliance date.

satisfy the site compliance date. Temporary locations will be used until used until building construction completion.

completion. Procedures Procedures and and programs programs willwill be be developed developed to to address addressstorage storagestructure structurerequirements, requirements,haul haulpath path requirements, requirements, and and FLEX FLEX equipment equipment requirements requirements relative to to the the hazards applicable to Clinton Power external hazards Power Station.

Station.

Flooding equipment is List how equipment is protected protected or or schedule schedule toto protect protect if stored below current flood level, then Note: if move equipment ensure procedures exist to move equipment prior to prior to exceeding flood level, level. Structures to provide provide protection protectionof ofFLEX FLEX equipment equipmentwillwillbe beconstructed constructed to meet meet the the requirements requirements of ofNEI NE112-06 11. Schedule 12 -06 Section 11. Schedule to to construct permanent permanentbuildings buildings isis contained containedininAttachment Attachment2,2,and andwill will satisfy the site site compliance compliance date.

date. Temporary locations will be used used until until building construction completion.

completion. Procedures Procedures and and programs programs willwill be be developed to to address address storage structure requirements, requirements, haul haul path path requirements, and FLEX equipment requirements requirements, and FLEX equipment requirements relative to the to the external hazards hazards applicable applicable to to Clinton Clinton Power PowerStation.

Station.

Severe Storms with High protected or List how equipment is protected or schedule to to protect protect Winds Structures to provide provide protection protectionof ofFLEX FLEX equipment equipmentwillwillbe beconstructed constructed meet the to meet the requirements requirementsof ofNEI NE112-06 Section 11.

12-06 Section 11. Schedule Schedule to construct construct permanent buildings is permanent buildings is contained contained in in Attachment Attachment 2, 2, and and will will satisfy satisfy the date. Temporary the site compliance date. Temporarylocations locationswill willbebeused useduntil until building construction completion. Procedures Procedures and and programs programs willwill be be developed to address address storage structure requirements, requirements, haul haul path path requirements, requirements, and FLEX equipment and FLEX equipment requirements requirements relative to to the the external hazards hazards applicable applicable to to Clinton Clinton Power PowerStation.

Station.

Snow, Ice, and Extreme Cold equipment is List how equipment is protected protected or or schedule to to protect protect Structures to provide provide protection protectionof ofFLEX FLEX equipment equipmentwillwillbe beconstructed constructed to meet meetthetherequirements requirementsofofNEI NE112-06 Schedule to 12 -06 Section 11. Schedule to construct permanent permanentbuildings buildings isis contained containedininAttachment Attachment2,2,and andwill will satisfy the date. Temporary the site compliance date. Temporarylocations locationswill willbebeused useduntil until building construction completion. Procedures Procedures and and programs programs willwill be be address storage structure requirements, developed to address requirements, haul haul path path requirements, requirements, and and FLEX FLEX equipment equipment requirements requirements relative to to the the external hazards hazards applicable to to Clinton Clinton Power PowerStation.

Station.

High Temperatures List how equipment is protected or schedule to to protect protect Structures to provide provide protection protectionofofFLEX FLEX equipment equipment will will be constructed constructed to meet meet the the requirements requirements of ofNEI NE112-06 11. Schedule 12 -06 Section 11. Schedule to to construct permanent permanentbuildings buildings isis contained containedinin Attachment Attachment2,2,and andwill will Page 43 of of 59

Clinton Power Station, Unit Unit 11 Mitigation Mitigation Strategies StrategiesIntegrated IntegratedPlan Plan Safety Functions Support BWR Portable Equipment Phase Phase 22 satisfy the site compliance date. TemporaryTemporary locations locations will willbebeused used until until building construction building construction completion. Procedures Procedures and andprograms programswillwill be be developed to address storage structure structure requirements, requirements, haul haul path path requirements, and requirements, andFLEX equipment requirements FLEX equipment requirements relative relative to to the the external hazards hazards applicable to Clinton Clinton Power PowerStation.

Station.

Deployment Conceptual Design (Attachment 33 contains contains Conceptual Sketches)

Conceptual Sketches)

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

use.

Electrical Support (Attachment (Attachment 33 Figure Figure 1) 1)

The primary primaryFLEX generator will FLEX generator will ** A permanently staged 480 A permanently The internal electrical connections The connections permanently staged be permanently staged and and does does VAC generator VAC generator ableable to supply are inside the station's station's seismically seismically not require deployment. necessary portions portions of of the the 480 480 robust Control, robust Control, Auxiliary, Auxiliary, and VAC distribution system to VAC distribution Diesel Generator Diesel Generator buildings and repower thethe Division Division 11 are protected against against external battery charger and other battery hazards.

needed AC AC loads.

• • Pre-routed cabling with with cam-cam-lock connectors

• An An external external electrical electrical FLEXpiping, FLEX piping, valves, and and alternate FLEX The alternate generator will FLEX generator connection ableable to to supply supply 480480 connections (electrical & fluid) be housed in a nearby storage VAC power VAC power to switchgear switchgear inside meet NEI inside will meet 12-06 Rev.0 NE112-06 Rev.O structure and will be and will be ableable to be be the Control/DG Control/DG building.

building. The The protection requirements.

requirements.

deployed to the vicinity of of the the switchgear will be able to external electrical connection connection supply necessary portions of necessary portions of point. A A heavy duty duty truck truck capable capable the 480 VAC VAC distribution distribution of clearing debris from the travel system system to repower repower the the swing swing path will bebe stored stored in in the the same same battery charger battery charger toto supply supplyDC DC location. MCC lA, and other needed AC MCC 1A, and other needed AC loads..

loads

• Pre-routed Pre-routed cabling cabling with with cam-cam-lock connectors Cooling/Makeup Water Water Support Support (Attachment (Attachment 33 Figure Figure 2) 2)

The portable diesel driven driven pumps Two external Two external water connections.

connections. FLEXpiping, FLEX piping,valves, valves, and and will be be housed housed in in aa storage storage connections (electrical & fluid) structure and and will will be be able able to bebe meet NEI will meet 12-06 Rev.0 NE112-06 Rev.O deployed to to the the UHS UHS and to the the protection requirements.

requirements.

vicinity of of the external water connection points. AA heavy heavy duty truck capable truck capable of of clearing clearing debris debris Page 44 of of 59

Clinton Power Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated Integrated PlanPlan Safety Functions Support Support BWR Portable Equipment Equipment Phase Phase 22 from the the travel travel path path will will be be stored in the same location the same location (Attachment 33 Figure (Attachment Figure 3).

3).

The proposed means The means of of routing

• Connection Connection to to the theUnit Unit22SX SX the water water from from the the UHS UHS to the supply piping fromfrom the theUHS UHS plant is is via seismically robust robust FLEXpump FLEX pump (proposed).

(proposed).

unused Unit22SX unused Unit SX piping.

A means means will will be provided to to

• Security Security fence fence modifications access UHS access UHSwater water at 675' MSL MSL will be be installed to facilitate elevation with elevation withaaFLEX pump in the FLEX pump the access toto the theUHS.

UHS.

event ofof the the loss loss ofof the the main main dam.

Notes:

Exelon Generation Exelon Generation Company, Company,LLC (Exelon)has LLC (Exelon) has not not finalized finalized the the engineering engineeringdesigns designsforforcompliance compliancewith NRC with NRC Order EA-12-049. Detailed designs EA-12-049. Detailed designs based based on the the current currentconceptual conceptualdesigns designswill will be be developed developedto todetermine determine the final final plan and associated mitigating mitigating strategies.

strategies. Analysis Analysis will be performed to validate that will be that the theplant plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety equipment, and identified mitigating strategy can satisfy the safety function function requirements of requirements ofNEI 12-06. Once these NEI12-06. these designs designs and andmitigating mitigatingstrategies strategieshave havebeen beenfully fullydeveloped, developed,Exelon Exelon will update will update the the integrated integratedplan planfor forClinton Clinton during during aascheduled scheduled6-month 6-monthupdate.

update.ThisThisupdate update will willinclude includeany any changes to to the the initial initial designs designs as as submitted submittedininthe theFebruary February28, 28,2013 2013Integrated IntegratedPlan.

Plan.

Page 45 of of 59

Clinton Power Station, Unit Unit 11 Mitigation Mitigation Strategies StrategiesIntegrated IntegratedPlanPlan Safety Functions Support BWR Portable Equipment Equipment Phase Phase 33 Provide a general description of of the the coping coping strategies strategies using using phase phase 33 equipment equipment including including modifications that proposed to are proposed to maintain functions. Identify maintain and/or support safety functions. Identify methods methods and and strategy(ies) strategy(ies) utilized utilized toto achieve coping coping times.

times.

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

required.

Phase Phase 33 equipment for Clinton Clinton includes includes backup backup portable pumps and portable pumps and generators. The portable pumps pumps will will be be capable of providing capable providing thethe necessary flow and necessary flow and pressure pressure as outlined outlined in in Phase Phase 22response response for CoreCore Cooling, Cooling, Containment, Containment, and and Spent Fuel Pool Spent Fuel Pool Cooling.

Cooling. The portable generators The portable generators will will be be capable capable of ofproviding providing thethe necessary 480 volt necessary 480 volt power powerrequirements requirementsas asoutlined outlinedininPhase Phase22response responsefor forSafety SafetyFunctions FunctionsSupport.

Support.

Details:

Provide a brief Confirm that procedure/guidance exists or will be developed Confirm. developed to to description ofof Procedures Procedures support implementation with a description of ofthe the procedure procedure / strategy strategy

/ Strategies / Guidelines I/ guideline.

Clinton will use use the industry developed guidance from the the Owners Owners Groups, Groups]

EPRI EPRI and NEI Task team to develop develop sitesite specific specific procedures or or guidelines guidelines toto address address thethe criteria in NEI NEI12-06. These procedures 12-06. These procedures and/or and/orguidelines guidelineswillwill the existing support the existing symptom symptom based based command command and andcontrol controlstrategies strategiesinin the current currentEOPs.

EOPs.

Identify modifications List modifications necessary for Phase 33 None None Key Parameters List instrumentation credited or recovered recovered for this this coping coping evaluation.

evaluation.

None None Clinton's Clinton's evaluation evaluation of the FLEX strategy may identify additional parameters thatthat are are needed needed in in order orderto tosupport supportkey keyactions actions identified identifiedinin procedures/guidance or plant procedures/guidance the plant or to to indicate imminent imminent or or actual actual core core damage (NEI 12-06 12-06 Rev.

Rev. 00 Section Section 33.2.1.10)

.2.1.10) and any differences will be provided provided inin a future following identification.

future 6 month update following identification.

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

Strategy Modifications Protection of of connections connections Identify Strategy Strategy including includinghowhow Identify modifications modifications Identify how the the connection connection isis the equipment equipment willwill be be deployed deployed protected to the point point of ofuse.

use.

None None None None None None Page 46 ofof 59

Clinton Power Station, Unit Unit 11 Mitigation Strategies Strategies Integrated Integrated Plan Plan Safety Functions Support BWR Portable Equipment Equipment PhasePhase 33 Notes:

Exelon Generation Exelon Generation Company, Company, LLC (Exelon)has LLC (Exelon) has not not finalized finalized the engineering engineeringdesigns designsfor forcompliance compliancewith withNRC NRC Order EA-12-049. Detailed designs EA-12-049. Detailed designsbased based onon the the current conceptual conceptual designs designs will will be developed to determine determine the final final plan and associated mitigating mitigating strategies.

strategies. Analysis Analysis will will be performed toto validate validate that thatthe theplant plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety equipment, and identified mitigating strategy can satisfy the safety function function requirements of requirements ofNEI 12-06. Once these NEll2-0G. these designs designs and and mitigating mitigating strategies strategieshave havebeen beenfully fullydeveloped, developed,Exelon Exelon will update will update the integrated integrated plan plan for for Clinton Clinton during a scheduled 6-month G-month update.

update.ThisThisupdate updatewill will include include any any changes to thethe initial initial designs designs as submitted submittedin in the theFebruary February28,28,2013 2013Integrated IntegratedPlan.

Plan.

Page 47 of of 59

Clinton Power Station, Unit 1I Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan BWR Portable Equipment Equipment Phase 22 Use Use and (potential/flexibility) diverseuses (potential /flexibility) diverse uses Peiformance Criteria Performance Criteria Maintenance List portable List portable Core Containment SFP Instrumentation Instrumentation Accessibility Accessibili ty Maintenance Maintenance // PM equipment equipment requirements requirements Four (4) Diesel X x X X XX 150 psig gpm, 150 2700 gpm, psig Equipment maintenance maintenance Driven self prime Driven and testing testing will will be be pumps performed in accordance accordance with the industry industry templates, templates, asas outlined outlined in in JLD-ISG-2012-01 section section 66 NEI 12 and NEI 12-06 section 11.

-06 section 1I.

Two (2) 480 480VAC VAC X X X X XX X X X X 750 kW 750kW Equipment maintenance Equipment maintenance Generators (one Generators (one isis and testing will will be be pre-staged) performed in accordance accordance with the industry industry templates, templates, asas outlined outlined in in JLD-ISG-2012-JLD-ISG-2012-01 01 section 66 and NEI 12-06 section 11.

NEI 12-06 11.

Diesel powered Diesel powered air X x 2800 2800 psig psig Equipment maintenance maintenance compressors (2)(2) for and testing will bebe ADS backup ADS backup air performed performed in in accordance accordance bottles with the the industry industry templates, tem plates, as as outlined outlined in in JLD-ISG-2012-01 section 66 NE112-06 and NEI 1I.

12 -06 section 11.

Portable blower X x X X X X 9500 9500dmcfm Equipment maintenance Equipment maintenance and ducting for and testing will bebe RCIC room RCIC room cooling performed in accordance (2) with the the industry industry templates, templates, asas outlined outlined in in JLD-ISG-2012-01 section 66 NE112-06 and NEI 12-06 section 11.1!.~~

Page 48 of of 59 59

Clinton Power Clinton Power Station, Station, Unit Unit I1Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan BWR Portable BWR Portable Equipment Equipment Phase Phase 22 Use and (potential (potential/flexibility) diverseuses

/flexibility) diverse uses Performance Peiformance Criteria Maintenance Maintenance List portable List portable Core Core Containment Containment SFP SFP Instrumentation Instrumentation Accessibility Accessibili ty Maintenance Maintenance // PMPM equipment requirements requirements equipment Hose trailers Hose trailers (2) XX XX XX XX XX N/A N/A Equipment maintenance maintenance equipped with equipped with and testing testing will will be be hoses, fittings, and hoses, fittings, and performed performed in in accordance accordance tools need tools need forfor the the with with the the industry industry FLEX pumps FLEX pumps templates, templates, asas outlined outlinedinin JLD-ISG-2012-JLD-ISG-2012-01 01 section 66 and NEI NEI 12-06 12-06 section section 11.

11.

A heavy duty truck A heavy truck XX XX XX XX XX N/A Equipment maintenance maintenance capable of debris capable of debris and testing will will be be removal andand performed performed in in accordance accordance hauling FLEX hauling FLEX with the industry industry equipment templates, templates, asas outlined outlined in in JLD-ISG-2012 JLD-ISG-2012-01 -01 section 66 and NEI 12-06 section 11.

NE112-06 11.

Page 49 of 59

Power Station, Clinton Power Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Portable Equipment BWR Portable EquipmentPhase Phase33 Use Use and (potential/flexibility) diverseuses (potential /flexibility) diverse uses Performance Peiformance Criteria Notes Notes List portable List portable Core Core Containment SFP SFP Instrumentation Instrumentation Accessibility Accessibility equipment eq ui ment -1 Note: The RRC RRCequipment equipmenthas has not not been been procured at the the time timeof ofthis thissubmittal.

submittal.Once Once the SAFER committee determines the SAFER the the equipment equipment specifications specifications for bid, updates will be made made as as necessary necessaryto tothis table. The Phase 3 portable equipment thistable. equipment table will be table will beupdated updated once all all of of the the equipment equipmenthas hasbeen beenprocured procuredand andplaced placedin ininventory.

inventory.

Medium X X X X XX X X XX 2 MW output outputatat4160 4160VAC, VAe, ** Generator Generator must must be be Diesel Voltage Diesel three three phase phase common common commercially commercially Generator available.

• • Must Must run run on on diesel diesel fuel.

Low Low Voltage Voltage X X X X X X X X XX 500 kW output at kW output at 480 480 ** Generator Generator must must be be Diesel VAC, three phase VAC, three phase common commercially commercially Generator available.

• • Must Must run run on on diesel diesel fuel.

Low Pressure X X X X X X 300 psi shutoff shutoff head, head, 2500 2500 Pump gpm max max flow Low Pressure X XX 500 psi shutoff head, psi shutoff head, 500 500 Pump gpm max flow Low Pressure X X psi shutoff 110 psi shutoff head, head, 400 400 i I

Pump gpm max flow flow submersible submersible Low Pressure X X X 150 psi psi shutoff shutoff head, head, 5000 5000 Pump gpm max flow Air X psi minimum 120 psi minimum Compressor Comp~c:ss()r_ pressure, 2000 scfm Page 50 ofof 59

Clinton Power Power Station, Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated IntegratedPlan Plan Equipment/Commodities Phase 3 Response Equipment/Commodities Item Notes Notes Equipment Radiation Protection Equipment The RRC willnot RRC will notstock stockthis thistype typeofofequipment equipment but this equipment equipmentwill will be be requested requestedfrom from

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

basis.

• • Dosimetry

• • Off-site monitoring/sampling monitoring/sampling Commodities The RRC willnot RRC will notstock stockthis thistype typeofofequipment equipment but this equipment equipmentwill will be be requested requestedfrom from

• • Food site-to-site and utility-to-utility utility-to-utilityon onananasasrequired requiredbasis.

basis.

• • Potable water water Fuel Requirements Requirements 300 -- 500 500 gallon bladders thatthat can can be be delivered delivered by by air air Heavy Heavy Equipment ** TBDduring TBO duringsite site specific specific playbook playbook development development

• • Transpo rtation equipment Transportation equ ipm ent ** Redundant Phase 22 equipment equipmentto tobe belocated locatedatatRRC RRC

• • Debris clearing equipment Page 5151 of 59

Clinton Power Station, Unit 11 Mitigation MitigationStrategies StrategiesIntegrated Integrated Plan Plan Attachment 1A lA Sequence of of Events Timeline Timeline (insert site specific time line line to to support supportsubmittal) submittal)

Time Action Elapsed Action Constraint Remarks /I Applicability item Time v/N 5 YIN Calc EPU-T0903 Calc EPU-T0903Clinton Clinton Power Power Station 0 Event starts/

EVent starts, Scram, Scram/ Recirc Recirc Pumps Pumps Trip NA Extended Power Uprate, Uprate, Task Task T0903:

T0903:

Station Blackout Calc EPU-T0903 Calc EPU-T0903Clinton Clinton Power Power Station Lev 2 Level 1 RCIChas RCIC hasstarted started and and begins to to inject inject NA Extended PowerPower Uprate, Uprate,Task Task T0903:

T0903:

1 Le v sec

+30 Station Blackout SBOprocedure SBO procedure action action 2 10 min 10min Control level andand pressure pressure perper procedures procedures Y Y SeeItem See Item 5.b 5.b inin "General Integrated Integrated Plan" Plan" section.

SBOprocedure SBO procedure action action 3 29 min Bypass RCtC Bypass RCICleakleakdetection detection isolation isolation logic logic y Y See Item See Item 5.a 5.a inin "General "General Integrated Plan" Plan" section.

Defeat Low Defeat Low RCIC Steam Supply RCtC Steam Supply Pressure Pressure SBOprocedure SBO procedure action drivendriven by by aa 4 1 hr Isolation per Isolation perCPS 4410.01CO01, Defeating CPS 4410.01C001, Defeating N N

parameter value parameter value RCICInterlocks RCIC Interlocks SBO procedure action SBO procedure Initiate CPS 4200,01C003, Monitoring CPS 4200.01C003, MonitoringCNMT CNMT N KeyParameter Key Parameter for monitoring monitoring 5 1 hr N Temperatures Temperatures During DuringAASBO SBO containment conditions, but but does does not drive a time critical action action SBO procedure action SBO procedure action Complete CPS Complete 4200.010002, DC CPS 4200.01C002, DC Load Load 6 1 hr Y Y See Item Item 5.c5.c in " General Integrated in "General Plan""

Integrated Plan Shedding During Shedding DuringAASBO SBO section.

See item Item 7 in "General Integrated IntegratedPlan" Plan" 7 1 hr Initiate Beyond Initiate BeyondDesign DesignBasis BasisFLEX Strategies FLEX Strategies Y Y

section.

Begin RPV Begin RPVdepressurization depressurization to to 150 prig psig with Input assumption assumption for for MAAP analysis. See MAAP analysis.

8 1 hr SRVsatat50°Fjhr.

SRVs 50°F/hr. Control Control RPV RPV pressure YY Item 2.a in "General Integrated 2.a in Integrated Plan" Plan" between 150 between 150 and and 250 250 psig.

psig. section.

Time selected selected to to meet completion 9 1 hr Commence LiningLining UpUp FLEX generator FLEX generator N N

timeline.

timeline. (Line (Line 13) 13)

Time selected to meet Time selected meet completion completion 10 2 hr Commence UHS Pump Deployment UHS Pump N N

timeline. (Line (Line 20) 20)

Place ADS Place ADSBackup BackupAirAir Bottles Bottles in service per per Y See Item See Item 66 inin "General Integrated Integrated Plan" Plan" 11 2 hr y CPS3101.01/

CPS 3101.01, Main SteamSteam (MS, (MS, IS IS &

& ADS).

ADS). section.

Needed for for Div Div 11 Battery BatteryCharger.

Charger. (Line (Line 12 5 hr Energize MCC 1A1 lAl N N

13,14) 13/ 14)

Startup Div Startup Div 1 Battery Battery Charger Chargerand andsupply supplyDC DC y See Item 4 in "General Integrated Plan" in IIGenerallntegrated Plan" 13 5 hr y MCC 1A MCC1A section.

55 Instructions:

Instructions: Provide justification if if No No oror NA NA isis selected selectedin in the theremarks remarkscolumn column If yes, include technical basis basis discussion discussion as as required requiredby byNEI NEI12-06 12-06section section3.2.1.73.2.1.7 Page 52 of of 59

Clinton Power Power Station, Station, Unit Unit11 Mitigation Strategies Strategies Integrated Integrated Plan Plan Energize Hydrogen Igniter Distribution Panel Panel NEI 12-06 Table NE112-06 Table C-2 requirement, driven C-2 requirement, driven 14 5 hr N N

(MCC 1A1) lAl) by EOP)

EOP)

Needed forfor SPMU SPMU valves valves andand Standby Standby 15 5 hr Energize MCC 1A3 lA3 N N

Lighting Cabinet Cabinet 1LL70EA lLL70EA (Line(Line 19, 19, 22) 22)

See See Item 2.c in "General "Generallntegrated Plan" Integrated Plan" 16 5 hr Open the SPMU SPMU valves valves Y Y

section.

Provide receptacle power for Provide receptacle for DG DG fuel oil oil Energize DGDG MCC 1A and Standby LightingLighting 17 5 hr N N transfer pump and portable portable fuel fuel oil oil pump pump Cabinet lLL70EA Cabinet 1LL70EA (Line 19) 19)

See Item 3 in See in "General "Generallntegrated Plan Integrated Plan" lJ 18 6 hr Open RCIC RCIC room doors Y Y

section. Time Time critical criticalatatTQ+42 To+42 hours.

hours.

Provide Provide fuel oil transfer transfer capability. Fuel capability. Fuel Connect Div 1 Day Tank 120 120 VAC VAC portable portable consumption rate is consumption is not not yet determined.

19 8 hr yy pump See Note 1 in "General See "Generallntegrated Plan Integrated Plan" lJ section.

Place FLEX suppressionpool FLEX suppression pool cooling cooling strategy Y See Item Item 2.d 2.d inin "General Integrated Plan" "Generallntegrated Plan" 20 8 hr y in service section.

The need for for further furtheranalysis analysis of ofcontrol control Initiate supplemental MCR MCR ventilation ventilation per per room habitability habitabilityduring duringan anELAP ELAP/LUHS

/LUHS is is 21 12 hr N N

CPS 4200.01COOl, CPS 4200.010001, MCRMCR Cooling CoolingDuring DuringAASBOSBO an open item.

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

See See Item Item 2.e in in "General "Generallntegrated Integrated Plan"Plan" 22 12 hr Makeup Makeup to to Suppression Suppression PoolPool as needed Y Y section. Bottom of section. Bottom ofoperating operating band band expected at To+16.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

at To+16.8 hours.

See See item 1 lin "Generallntegrated in "General Plan Integrated Plan" lJ Commence Spent Fuel Fuel Pool Pool makeup (>86 23 12 hr Y Y section. Top of section. Top of fuel fuel racks racks expected at at gpm) as needed To+130 Ta+130 hours.

The The need need forfor further analysis of fuel further analysis building heatup heatup duringduringan anELAP/LUHS ELAP/LUHS is is 24 12 hr Establish Establish Fuel Fuel Bldg Bldg steam steam vent path path N N

an an open item. ClosureClosure of this item will will bebe documented in a future 6-month 6-month update.

update.

Commence recharging recharging the theADS ADS backup backup air air y

,, See Item Item 66in in "General Integrated Plan" "Generallntegrated Plan" 25 24 hr hr with aaFLEX bottles with FLEX air compressor section.

First First piece piece of RRC RRCequipment equipment arrives arrives at the 26 24 hr N N Assumption Assumption from NEI NEI12-06.

12-06.

staging area Establish Establish RCtC RCICPump Pump Room Room compensatory compensatory See See item 3 in "General "Generallntegrated Plan Integrated Plan" lJ 27 30 hr yY action (portable (portable fan) fan) section. Time Time critical criticalatatTo+59.5 To+59.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> hours Continue to maintain maintain critical critical functions functions ofof core cooling (via RCIC),

RClC), containment (via containment (via 28 24-72 hr alternate suppression pool alternate suppression pool cooling) cooling) and andSFPSFP N N General General comment cooling (FLEX pump injection to SFP).

cooling (FLEX pump injection to SFP). Utilize RRC equipment initial RRC equipment in in spare spare capacity.

capacity.

Page 53 Page 53 of 59

Clinton Power Station, Unit Unit 11 Mitigation Mitigation Strategies Strategies Integrated Integrated Plan Plan Attachment 2 Schedule Milestone Schedule Original Target Target Activity Status Date Completion Date {Include date date changes changes inin this this column}

Submit Submit 60 Day Status Report 60 Day Complete Overall Integrated Submit Overall Complete Implementation ImplementationPlan Plan Contract Contract with withRRC RRC Complete Recurring action, action, Submit 6-month updates updates Ongoing Aug and Feb Aug Modification Development Mar Mar 2014 2014 *

• PhasePhase 2 modifications Note 1 Modification Implementation Implementation May 2015 ** Phase Phase 2 modifications Note 11 Procedure Procedure development May 2015 May 2015 ** Strategy procedures Note 1 May 2015 ** Maintenance procedures Note 1 May 2015 Staffing analysis Note 1 May 2015 Plan and construction Storage Plan Note 11 May 2015 FLEX equipment acquisition FLEX equipment Note 1 May 2015 Training completion Note 1 Dec 2014 Dec Regional Response Response Center (will be aa standard date from Operational RRC)

May 2015 Unit 1 Implementation date Note 1 Note(s):

1. Exelon will Exelon will update update the the status ofof ongoing ongoing and and future future milestones milestonesininthe theIntegrated IntegratedPlan Planfor forClinton Clinton during aa scheduled during scheduled 6-month 6-month update. This This update will include include any any changes changes toto the milestone milestone schedule schedule as submitted in the February February 28/28, 2013 2013 Integrated Integrated Plan.

Plan.

Page 54 of 59

Clinton Power Clinton Power Station, Station, Unit Unit11 Mitigation MitigationStrategies StrategiesIntegrated IntegratedPlan Plan Attachment 33 Attachment Sketches Conceptual Sketches Page Page 55 55 of of 59

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February 2013 FLEX February FLEX Integrated Plan Plan Figure 33 -- FLEX Figure FLEX Deployment Conceptual Sketch Deployment Conceptual Sketch Page 58 of 59

February 2013 February 2013 FLEX FLEX Integrated Integrated Plan Plan Figure 4 - RRC Figure RRC Equipment EquipmentDeployment Conceptual Sketch Deployment Conceptual Sketch Page 59 of 59