RS-15-267, Report of Full Compliance with 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)

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Report of Full Compliance with 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)
ML15335A390
Person / Time
Site: Byron Constellation icon.png
Issue date: 11/30/2015
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-15-267
Download: ML15335A390 (11)
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Text

^~= Exeton Generation.,

Order No. EA-12-049 RS-15-267 November 30, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Byron Station, Unit 1 Facility Operating License No. NPF-37 NRC Docket No. STN 50-454

Subject:

Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

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

dated March 12, 2012

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

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 2012
5. Exelon Generation Company, LLC 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), dated February 28, 2013 (RS-13-018)
6. Exelon Generation Company, LLC First Six-Month 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 049), dated August 28, 2013 (RS-13-115)
7. Exelon Generation Company, LLC Second Six-Month 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 049), dated February 28, 2014 (RS-14-008)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 2

8. Exelon Generation Company, LLC Third Six-Month 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 049), dated August 28, 2014 (RS-14-206)
9. Exelon Generation Company, LLC Fourth Six-Month 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 049), dated February 27, 2015 (RS-15-017) 10.Exelon Generation Company, LLC Fifth Six-Month 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 049), dated August 28, 2015 (RS-15-209) 11.NRC letter to Exelon Generation Company, LLC, Byron Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049, (Mitigation Strategies) (TAC Nos. MF0893 and MF0894), dated December 17, 2013 12.NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 13.Exelon Generation Company, LLC letter to USNRC, Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment, dated May 29, 2014 (RS-14-119) 14.NRC letter to Exelon Generation Company, LLC, Byron Station Station, Unit Nos. 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. M170893, MF0894, MF0872, and MF0873), dated December 17, 2014 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed 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 Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Byron Station, Unit 1 OIP.

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 6, 7, 8, 9, and 10 provided the first, second, third, fourth, and fifth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Byron Station, Unit 1.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 3 The purpose of this letter is to provide the report of full compliance with the 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) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Byron Station, Unit 1.

Byron Station, Unit 1 has developed, implemented, and will maintain the 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 in response to Order EA 049. The information provided herein documents full compliance for Byron Station, Unit 1 with Reference 1.

01 P open items have been addressed and closed as documented in References 6, 7, 8, 9, 10, and below, and are considered complete pending NRC closure. EGC's response to the NRC Interim Staff Evaluation (ISE) open and confirmatory items identified in Reference 11 have been addressed and closed as documented in References 7, 8, 9, 10, and below, and are considered closed as documented in Reference 14. EGC's response to the NRC ISE confirmatory items identified as open in Reference 14 are addressed below, and are considered complete pending NRC closure. EGC's response to the NRC audit questions and additional audit open items have been addressed and closed as documented in References 10, 14, and below, and are considered complete pending NRC closure. The following tables provide completion references for each OIP open item and NRC ISE open or confirmatory item, and NRC Audit Report open item.

Overall Integrated Plan Open Items Key Site assumptions (p.4) Primary and secondary storage Reference 9 locations have not been selected yet; once locations are finalized implementation strategies and routes will be assessed for hazard impact.

Sequence of events (p.5) The final timeline will be time validated Reference 9 once detailed designs are completed and procedures are developed.

Identify how strategies will be Identification of storage area and Reference 9 deployed (p.7) creation of the administrative program.

Programmatic controls (p.8) Develop an administrative program for Reference 10 FLEX responsibilities, and testing &

maintenance.

Regional Response Center plan Development of Byron Station's Reference 9 (P-9) la book.

Key Reactor Parameters (p. Identify additional parameters that are Reference 9 multiple) needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 4 Deployment Conceptual Design Develop the storage structure Reference 9 (p. multiple) conceptual design.

Maintain RCS Inventory Control, A calculation will be required for the Reference 10 Phase 2 (p.23) timing of the boration and quantity and updated required. with this submittal as provided below Maintain Containment, Phase 1 Additional calculations will be Reference 10 (p.31) performed to evaluate containment response.

Maintain Spent Fuel Pool Cooling, Procedure development for Initial Reference 9 Phase 1 (p.39) Spent fuel pool make-up with gravity drain from the RWST.

Maintain Spent Fuel Pool Cooling, Initial calculations were used to Reference 9 Phase 1 (p.39) determine the fuel pool timelines.

Formal calculations will be performed to validate this information during development of the spent fuel pool cooling strategy detailed design.

Maintain Spent Fuel Pool Cooling, Evaluation of the spent fuel pool area Reference 9 Phase 1, (p.39 and p.42) for steam and condensation will be performed and used to determine if vent path strategy is needed.

Safety Functions Support, Phase Habitability conditions will be Reference 9 2 (p.51) evaluated and a strategy will be developed to maintain Main Control Room.

Safety Functions Support, Phase Critical ventilation assets may be Reference 9 2 (p.51) required to support DDAF pumps, station battery rooms, miscellaneous electric equipment rooms, and fuel handling building personnel habitability and/or component survivability. Specific analyses of these rooms will be performed, Interim Staff Evaluation Open Items Item No. 3.2.1.8.A References 9 and 10 Interim Staff Evaluation Confirmatory Items Item No. 3.1.1.1.A Reference 9 Item No. 3.1.1.3.A Reference 9 Item No. 3.1.1.4.A Reference 8 Item No. 3.1.5.1.A Reference 9

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 5 Item No. 3.1.5.3.A Reference 9 Item No. 3.2.1.A Reference 9 Item No. 3.2.1.1.A Reference 9 Item No. 3.2.1.1.13 Reference 9 Item No. 3.2.1.1.0 Reference 9 Item No. 3.2.1.1.D Reference 9 Item No. 3.2.1.2.13 Reference 10 and updated with this submittal as provided below Item No. 3.2.1.2.E Reference 8 Item No. 3.2.1.3.A References 9 and 10 Item No. 3.2.1.4.A References 9 and 10 Item No. 3.2.1.4.13 Reference 9 Item No. 3.2.1.5.A Reference 8 Item No. 3.2.1.6.A Reference 10 and updated with this submittal as provided below Item No. 3.2.1.6.13 Reference 9 Item No. 3.2.1.9.A Reference 9 Item No. 3.2.2.A Reference 9 Item No. 3.2.3.A References 9 and 10 Item No. 3.2.3.13 Reference 9 Item No. 3.2.4.1.A Reference 9 Item No. 3.2.4.2.A Reference 9 Item No. 3.2.4.2.13 Reference 9 Item No. 3.2.4.3.A Reference 9 Item No. 3.2.4.4.A Reference 10 and updated with this submittal as provided below Item No. 3.2.4.6.A Reference 8 Item No. 3.2.4.7.A Reference 10 and updated with this submittal asprovided below Item No. 3.2.4.8.A Reference 9 Item No. 3.2.4.9.A Reference 9 Item No. 3.2.4.10.A Reference 9 NRC Audit Report Open Items Audit Open Item Completion Response Reference AQ-27 Reference 10 SE # 10 Reference 10 SE # 12 Reference 10 SE # 13 Reference 10

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 6 The following table documents completion of the final remaining open items. As previously stated, EGC provides the response for the following items and considers them to be complete for Byron Station, Unit 1.

Description Item Reference 011? Open Item Complete Westinghouse Calculation CN-LIS-15-034, Byron Maintain RCS Inventory and Braidwood Stations Reactor Coolant System Control, Phase 2 (pg. 23) ELAP Inventory Control Analysis with SHIELD Reactor Coolant Pump Seal Packages, is A calculation will be complete and provides a minimum time of 58 required for the timing of hours to the end of single-phase natural the boration and quantity circulation and 186 hours0.00215 days <br />0.0517 hours <br />3.075397e-4 weeks <br />7.0773e-5 months <br /> until Core Uncovery required.

occurs.

Westinghouse Calculation CN-LIS-15-039, Byron and Braidwood Stations Reactor Coolant System ELAP Long-Term Subcriticality Analysis with Low-Leakage Reactor Coolant Pump Seal Packages, provides a bounding calculation that determines boration would start by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> into the ELAP with a minimum of 6000 gallons of 2300pprn borated water injected.

Complete ISE CI 3.2.11.2.13 Byron Station has installed the Westinghouse Reactor Coolant Pump Reactor Coolant Pump (RCP) SHIELD Passive (RCP) Seal Leakage - In Thermal Shutdown Seals (SDS) (Generation 111).

some plant designs, the cold Byron Station has Westinghouse RCP Model legs could experience 93A. Credit for the SHIELD seals has been temperatures as high as 580 endorsed by NRC for Westinghouse Model 93A OF before cooldown RCPs as documented in NRC letter to commences. This is beyond Westinghouse, dated May 28, 2014 the qualification temperature (ML14132A128). The RCP seal leakage (550°F) of the 0-rings used in assumed in Westinghouse calculation CN-LIS-the RCP seals. For those 15-034, Byron and Braidwood Stations Reactor Westinghouse designs, a Coolant System ELAP Inventory Control Analysis discussion should be SHIELD Reactor Coolant Pump Seal Packages, provided to justify that (1) the is consistent with NRC limitation and condition integrity of the associated 0-Number 4 identified in the above reference NRC rings will be maintained at letter to Westinghouse.

the temperature conditions experienced during the ELAP event, and (2) the seal The qualification testing of the shutdown seal leakage rate of 21 gpm/seal was performed at conditions based on a cold leg used in the ELAP is temperature of 571 OF. The maximum shutdown seal temperature remains below the shutdown

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 7 adequate and acceptable. seal temperatures experienced during qualification testing.

Following a loss of AC power, it is possible for the RCS cold leg temperature to exceed 571 OF for short periods of time without the shutdown seal heating up beyond the temperatures experienced during qualification testing. This is due to the significant thermal inertia of the massive reactor coolant pump internals and pressure boundary. The evaluation documented in Westinghouse Letter LTR-CDA- 15-11 concludes that even if the cold leg temperature is 581 OF for the first 3000 seconds (50 minutes) following ELAP initiation, the maximum fluid temperature at the reactor coolant pump seal inlet remains below the temperatures experienced during shutdown seal qualification testing. Auxiliary Feedwater flow to the steam generators will be initiated at approximately 30 minutes into the ELAP event. Following the restoration of Auxiliary Feedwater flow to the steam generators and prior to initiating plant cooldown, cold leg temperature will be dictated by the Main Steam Safety Valves. Cold leg temperature will remain less than 571 OF during this period based on the lowest Main Steam Safety Valve setting of 1175 psig adjusted for setting tolerance and lift setpoint testing uncertainty.

Westinghouse LTR-RES-13-153, Documentation of 7228C Compound O-Rings at ELAP Conditions, concludes with a high level of confidence, that the integrity of the RCS O-rings will be maintained at the temperature conditions experienced during the ELAP event.

Complete ISE CI 3.2.1.6.A There was one change based on the Westinghouse calculation CN-LIS-15-40, Byron Sequence of Events and Braidwood Stations Delayed AFW FLEX Confirm that the final Studies, which resulted in less time to SG dry timeline has been time out. The time to isolate the SG PORVs and to validated after detailed start the "B" AF Pump was shortened. Byron designs are completed and Procedures BCA 0.0, Loss of All AC, and BFSG-procedures are developed. 2, Alternate AFW/EFW Suction Source, steps The results may be and directions have been updated. This change provided in a future 6- was revalidated and updated in the Time

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 8 month update. Sensitive Actions Procedure.

The timeline was updated using the times documented in the Westinghouse calculations.

The revised timeline, previously provided in Attachment A of the 6-month updates, has been validated and the changes required do not impact the time or margins documented for Byron Station Unit 1.

Complete ISE Cl 3.2.4.4.A Communications upgrade is complete.

Communications Confirm Byron Station has completed the NARS Upgrade that upgrades to the site's satellite communications system per NRC RFl 9.3.

communications systems have been completed. Byron Station also has 3 Iridium Satellite phones available for the SM/SED in the MCR area.

Additional handheld radios for use on talk-around with batteries are staged in the robust FLEX building. The Site has Sound Powered phones and cords in lockers in the plant with cables as well as Bull Horns for help with notifications.

ISE Cl 3.2.4.7.A Westinghouse Calculation CN-LIS-15-40, Byron and Braidwood Stations Delayed AFW FLEX Complete Water Sources Justify the Studies, provided bounding information that the time at which SG dryout will shorest time to SG dry out would be 2702 occur. seconds, or 45 minutes on Unit 2 and 3777 seconds, or 63 minutes on Unit 1.

MILESTONE SCHEDULE ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall Integrated Plan February 28, 2013 Contract with National SAFER Response Center October 15, 2014 Submit 6 Month Updates:

Update 1 August 28, 2013 Update 2 February 28, 2014 Update 3 August 28, 2014 Update 4 February 27, 2015 Update 5 August 28, 2015 Modification Development:

Phase 1 and 2 modifications October 2, 2015 National SAFER Response Center Operational October 15, 2014

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 9 Milestone Completion Date Procedure Development:

Strategy procedures September 24, 2015 Validate Procedures (NEI 12-06, Sect. 11.4.3) Se tember 24, 2015 Maintenance procedures September 24, 2015 Staffing analysis May 29, 2014 Modification Implementation Phase 1 and 2 modifications October 2, 2015 Storage plan and construction October 20, 2014 FLEX equipment acquisition October 20 2014 Training completion August 21, 2015 Unit 1 implementation date October 2, 2015 ORDER EA-12-049 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Byron Station, Unit 1 as well as the site OIP response submittal (Reference 5), the 6-Month Status Reports (References 6, 7, 8, 9, and 10), and any additional docketed correspondence, demonstrate compliance with Order EA-12-049.

Strategies - Complete Byron Station, Unit 1 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items. The Byron Station, Units 1 and 2, Final Integrated Plan for mitigating strategies will be provided upon full compliance for Byron Station, Unit 2 (Spring 2016).

Modifications - Complete The modifications required to support the FLEX strategies for Byron Station, Unit 1 have been fully implemented in accordance with the station design control process.

Equipment Procured and Maintenance & Testing Complete The equipment required to implement the FLEX strategies for Byron Station, Unit 1 have been procured in accordance with NEI 12-06, Section 11.1 and 11.2, received at Byron Station, Unit 1, initially tested/performance verified as identified in NEI 12-06, Section 11.5, and is available for use.

Maintenance and testing will be conducted through the use of the Byron Station, Unit 1 Preventative Maintenance program such that equipment reliability is achieved.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 10 Protected Storage Complete The storage facilities required to implement the FLEX strategies for Byron Station, Unit 1 have been completed and provide protection from the applicable site hazards. The equipment required to implement the FLEX strategies for Byron Station, Unit 1 is stored in its protected configuration.

Procedures Complete FLEX Support Guidelines (FSGs) for Byron Station, Unit 1 have been developed and integrated with existing procedures. The FSGs and affected existing procedures have been verified and are available for use in accordance with the site procedure control program.

Training Complete Training for Byron Station, Unit 1 has been completed in accordance with an accepted training process as recommended in NEI 12-06, Section 11.6.

Staffing Complete The Phase 2 staffing study for Byron Station has been completed in accordance with 10CFR50.54(f), "Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights from the Fukushima Dai-ichi Accident," Recommendation 9.3, dated March 12, 2012 (Reference 12), as documented in Reference 13.

National SAFER Response Center Complete EGC has established a contract with Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. It has been confirmed that PEICo is ready to support Byron Station, Unit 1 with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

Validation Complete EGC has completed performance of validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the Overall Integrated Plan (OIP) for Order EA-12-049.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 11 FLEX Program Document - Established The Byron Station, Unit 1 FLEX Program Document has been developed in accordance with the requirements of NEI 12-06.

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

1 declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of November 2015.

Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector Byron Station NRC Project Manager, NRR Byron Station Mr. John D. Hughey, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

^~= Exeton Generation.,

Order No. EA-12-049 RS-15-267 November 30, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Byron Station, Unit 1 Facility Operating License No. NPF-37 NRC Docket No. STN 50-454

Subject:

Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

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

dated March 12, 2012

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

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 2012
5. Exelon Generation Company, LLC 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), dated February 28, 2013 (RS-13-018)
6. Exelon Generation Company, LLC First Six-Month 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 049), dated August 28, 2013 (RS-13-115)
7. Exelon Generation Company, LLC Second Six-Month 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 049), dated February 28, 2014 (RS-14-008)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 2

8. Exelon Generation Company, LLC Third Six-Month 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 049), dated August 28, 2014 (RS-14-206)
9. Exelon Generation Company, LLC Fourth Six-Month 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 049), dated February 27, 2015 (RS-15-017) 10.Exelon Generation Company, LLC Fifth Six-Month 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 049), dated August 28, 2015 (RS-15-209) 11.NRC letter to Exelon Generation Company, LLC, Byron Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049, (Mitigation Strategies) (TAC Nos. MF0893 and MF0894), dated December 17, 2013 12.NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 13.Exelon Generation Company, LLC letter to USNRC, Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment, dated May 29, 2014 (RS-14-119) 14.NRC letter to Exelon Generation Company, LLC, Byron Station Station, Unit Nos. 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. M170893, MF0894, MF0872, and MF0873), dated December 17, 2014 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events," (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed 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 Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Byron Station, Unit 1 OIP.

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 6, 7, 8, 9, and 10 provided the first, second, third, fourth, and fifth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Byron Station, Unit 1.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 3 The purpose of this letter is to provide the report of full compliance with the 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) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Byron Station, Unit 1.

Byron Station, Unit 1 has developed, implemented, and will maintain the 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 in response to Order EA 049. The information provided herein documents full compliance for Byron Station, Unit 1 with Reference 1.

01 P open items have been addressed and closed as documented in References 6, 7, 8, 9, 10, and below, and are considered complete pending NRC closure. EGC's response to the NRC Interim Staff Evaluation (ISE) open and confirmatory items identified in Reference 11 have been addressed and closed as documented in References 7, 8, 9, 10, and below, and are considered closed as documented in Reference 14. EGC's response to the NRC ISE confirmatory items identified as open in Reference 14 are addressed below, and are considered complete pending NRC closure. EGC's response to the NRC audit questions and additional audit open items have been addressed and closed as documented in References 10, 14, and below, and are considered complete pending NRC closure. The following tables provide completion references for each OIP open item and NRC ISE open or confirmatory item, and NRC Audit Report open item.

Overall Integrated Plan Open Items Key Site assumptions (p.4) Primary and secondary storage Reference 9 locations have not been selected yet; once locations are finalized implementation strategies and routes will be assessed for hazard impact.

Sequence of events (p.5) The final timeline will be time validated Reference 9 once detailed designs are completed and procedures are developed.

Identify how strategies will be Identification of storage area and Reference 9 deployed (p.7) creation of the administrative program.

Programmatic controls (p.8) Develop an administrative program for Reference 10 FLEX responsibilities, and testing &

maintenance.

Regional Response Center plan Development of Byron Station's Reference 9 (P-9) la book.

Key Reactor Parameters (p. Identify additional parameters that are Reference 9 multiple) needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 4 Deployment Conceptual Design Develop the storage structure Reference 9 (p. multiple) conceptual design.

Maintain RCS Inventory Control, A calculation will be required for the Reference 10 Phase 2 (p.23) timing of the boration and quantity and updated required. with this submittal as provided below Maintain Containment, Phase 1 Additional calculations will be Reference 10 (p.31) performed to evaluate containment response.

Maintain Spent Fuel Pool Cooling, Procedure development for Initial Reference 9 Phase 1 (p.39) Spent fuel pool make-up with gravity drain from the RWST.

Maintain Spent Fuel Pool Cooling, Initial calculations were used to Reference 9 Phase 1 (p.39) determine the fuel pool timelines.

Formal calculations will be performed to validate this information during development of the spent fuel pool cooling strategy detailed design.

Maintain Spent Fuel Pool Cooling, Evaluation of the spent fuel pool area Reference 9 Phase 1, (p.39 and p.42) for steam and condensation will be performed and used to determine if vent path strategy is needed.

Safety Functions Support, Phase Habitability conditions will be Reference 9 2 (p.51) evaluated and a strategy will be developed to maintain Main Control Room.

Safety Functions Support, Phase Critical ventilation assets may be Reference 9 2 (p.51) required to support DDAF pumps, station battery rooms, miscellaneous electric equipment rooms, and fuel handling building personnel habitability and/or component survivability. Specific analyses of these rooms will be performed, Interim Staff Evaluation Open Items Item No. 3.2.1.8.A References 9 and 10 Interim Staff Evaluation Confirmatory Items Item No. 3.1.1.1.A Reference 9 Item No. 3.1.1.3.A Reference 9 Item No. 3.1.1.4.A Reference 8 Item No. 3.1.5.1.A Reference 9

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 5 Item No. 3.1.5.3.A Reference 9 Item No. 3.2.1.A Reference 9 Item No. 3.2.1.1.A Reference 9 Item No. 3.2.1.1.13 Reference 9 Item No. 3.2.1.1.0 Reference 9 Item No. 3.2.1.1.D Reference 9 Item No. 3.2.1.2.13 Reference 10 and updated with this submittal as provided below Item No. 3.2.1.2.E Reference 8 Item No. 3.2.1.3.A References 9 and 10 Item No. 3.2.1.4.A References 9 and 10 Item No. 3.2.1.4.13 Reference 9 Item No. 3.2.1.5.A Reference 8 Item No. 3.2.1.6.A Reference 10 and updated with this submittal as provided below Item No. 3.2.1.6.13 Reference 9 Item No. 3.2.1.9.A Reference 9 Item No. 3.2.2.A Reference 9 Item No. 3.2.3.A References 9 and 10 Item No. 3.2.3.13 Reference 9 Item No. 3.2.4.1.A Reference 9 Item No. 3.2.4.2.A Reference 9 Item No. 3.2.4.2.13 Reference 9 Item No. 3.2.4.3.A Reference 9 Item No. 3.2.4.4.A Reference 10 and updated with this submittal as provided below Item No. 3.2.4.6.A Reference 8 Item No. 3.2.4.7.A Reference 10 and updated with this submittal asprovided below Item No. 3.2.4.8.A Reference 9 Item No. 3.2.4.9.A Reference 9 Item No. 3.2.4.10.A Reference 9 NRC Audit Report Open Items Audit Open Item Completion Response Reference AQ-27 Reference 10 SE # 10 Reference 10 SE # 12 Reference 10 SE # 13 Reference 10

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 6 The following table documents completion of the final remaining open items. As previously stated, EGC provides the response for the following items and considers them to be complete for Byron Station, Unit 1.

Description Item Reference 011? Open Item Complete Westinghouse Calculation CN-LIS-15-034, Byron Maintain RCS Inventory and Braidwood Stations Reactor Coolant System Control, Phase 2 (pg. 23) ELAP Inventory Control Analysis with SHIELD Reactor Coolant Pump Seal Packages, is A calculation will be complete and provides a minimum time of 58 required for the timing of hours to the end of single-phase natural the boration and quantity circulation and 186 hours0.00215 days <br />0.0517 hours <br />3.075397e-4 weeks <br />7.0773e-5 months <br /> until Core Uncovery required.

occurs.

Westinghouse Calculation CN-LIS-15-039, Byron and Braidwood Stations Reactor Coolant System ELAP Long-Term Subcriticality Analysis with Low-Leakage Reactor Coolant Pump Seal Packages, provides a bounding calculation that determines boration would start by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> into the ELAP with a minimum of 6000 gallons of 2300pprn borated water injected.

Complete ISE CI 3.2.11.2.13 Byron Station has installed the Westinghouse Reactor Coolant Pump Reactor Coolant Pump (RCP) SHIELD Passive (RCP) Seal Leakage - In Thermal Shutdown Seals (SDS) (Generation 111).

some plant designs, the cold Byron Station has Westinghouse RCP Model legs could experience 93A. Credit for the SHIELD seals has been temperatures as high as 580 endorsed by NRC for Westinghouse Model 93A OF before cooldown RCPs as documented in NRC letter to commences. This is beyond Westinghouse, dated May 28, 2014 the qualification temperature (ML14132A128). The RCP seal leakage (550°F) of the 0-rings used in assumed in Westinghouse calculation CN-LIS-the RCP seals. For those 15-034, Byron and Braidwood Stations Reactor Westinghouse designs, a Coolant System ELAP Inventory Control Analysis discussion should be SHIELD Reactor Coolant Pump Seal Packages, provided to justify that (1) the is consistent with NRC limitation and condition integrity of the associated 0-Number 4 identified in the above reference NRC rings will be maintained at letter to Westinghouse.

the temperature conditions experienced during the ELAP event, and (2) the seal The qualification testing of the shutdown seal leakage rate of 21 gpm/seal was performed at conditions based on a cold leg used in the ELAP is temperature of 571 OF. The maximum shutdown seal temperature remains below the shutdown

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 7 adequate and acceptable. seal temperatures experienced during qualification testing.

Following a loss of AC power, it is possible for the RCS cold leg temperature to exceed 571 OF for short periods of time without the shutdown seal heating up beyond the temperatures experienced during qualification testing. This is due to the significant thermal inertia of the massive reactor coolant pump internals and pressure boundary. The evaluation documented in Westinghouse Letter LTR-CDA- 15-11 concludes that even if the cold leg temperature is 581 OF for the first 3000 seconds (50 minutes) following ELAP initiation, the maximum fluid temperature at the reactor coolant pump seal inlet remains below the temperatures experienced during shutdown seal qualification testing. Auxiliary Feedwater flow to the steam generators will be initiated at approximately 30 minutes into the ELAP event. Following the restoration of Auxiliary Feedwater flow to the steam generators and prior to initiating plant cooldown, cold leg temperature will be dictated by the Main Steam Safety Valves. Cold leg temperature will remain less than 571 OF during this period based on the lowest Main Steam Safety Valve setting of 1175 psig adjusted for setting tolerance and lift setpoint testing uncertainty.

Westinghouse LTR-RES-13-153, Documentation of 7228C Compound O-Rings at ELAP Conditions, concludes with a high level of confidence, that the integrity of the RCS O-rings will be maintained at the temperature conditions experienced during the ELAP event.

Complete ISE CI 3.2.1.6.A There was one change based on the Westinghouse calculation CN-LIS-15-40, Byron Sequence of Events and Braidwood Stations Delayed AFW FLEX Confirm that the final Studies, which resulted in less time to SG dry timeline has been time out. The time to isolate the SG PORVs and to validated after detailed start the "B" AF Pump was shortened. Byron designs are completed and Procedures BCA 0.0, Loss of All AC, and BFSG-procedures are developed. 2, Alternate AFW/EFW Suction Source, steps The results may be and directions have been updated. This change provided in a future 6- was revalidated and updated in the Time

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 8 month update. Sensitive Actions Procedure.

The timeline was updated using the times documented in the Westinghouse calculations.

The revised timeline, previously provided in Attachment A of the 6-month updates, has been validated and the changes required do not impact the time or margins documented for Byron Station Unit 1.

Complete ISE Cl 3.2.4.4.A Communications upgrade is complete.

Communications Confirm Byron Station has completed the NARS Upgrade that upgrades to the site's satellite communications system per NRC RFl 9.3.

communications systems have been completed. Byron Station also has 3 Iridium Satellite phones available for the SM/SED in the MCR area.

Additional handheld radios for use on talk-around with batteries are staged in the robust FLEX building. The Site has Sound Powered phones and cords in lockers in the plant with cables as well as Bull Horns for help with notifications.

ISE Cl 3.2.4.7.A Westinghouse Calculation CN-LIS-15-40, Byron and Braidwood Stations Delayed AFW FLEX Complete Water Sources Justify the Studies, provided bounding information that the time at which SG dryout will shorest time to SG dry out would be 2702 occur. seconds, or 45 minutes on Unit 2 and 3777 seconds, or 63 minutes on Unit 1.

MILESTONE SCHEDULE ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall Integrated Plan February 28, 2013 Contract with National SAFER Response Center October 15, 2014 Submit 6 Month Updates:

Update 1 August 28, 2013 Update 2 February 28, 2014 Update 3 August 28, 2014 Update 4 February 27, 2015 Update 5 August 28, 2015 Modification Development:

Phase 1 and 2 modifications October 2, 2015 National SAFER Response Center Operational October 15, 2014

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 9 Milestone Completion Date Procedure Development:

Strategy procedures September 24, 2015 Validate Procedures (NEI 12-06, Sect. 11.4.3) Se tember 24, 2015 Maintenance procedures September 24, 2015 Staffing analysis May 29, 2014 Modification Implementation Phase 1 and 2 modifications October 2, 2015 Storage plan and construction October 20, 2014 FLEX equipment acquisition October 20 2014 Training completion August 21, 2015 Unit 1 implementation date October 2, 2015 ORDER EA-12-049 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Byron Station, Unit 1 as well as the site OIP response submittal (Reference 5), the 6-Month Status Reports (References 6, 7, 8, 9, and 10), and any additional docketed correspondence, demonstrate compliance with Order EA-12-049.

Strategies - Complete Byron Station, Unit 1 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items. The Byron Station, Units 1 and 2, Final Integrated Plan for mitigating strategies will be provided upon full compliance for Byron Station, Unit 2 (Spring 2016).

Modifications - Complete The modifications required to support the FLEX strategies for Byron Station, Unit 1 have been fully implemented in accordance with the station design control process.

Equipment Procured and Maintenance & Testing Complete The equipment required to implement the FLEX strategies for Byron Station, Unit 1 have been procured in accordance with NEI 12-06, Section 11.1 and 11.2, received at Byron Station, Unit 1, initially tested/performance verified as identified in NEI 12-06, Section 11.5, and is available for use.

Maintenance and testing will be conducted through the use of the Byron Station, Unit 1 Preventative Maintenance program such that equipment reliability is achieved.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 10 Protected Storage Complete The storage facilities required to implement the FLEX strategies for Byron Station, Unit 1 have been completed and provide protection from the applicable site hazards. The equipment required to implement the FLEX strategies for Byron Station, Unit 1 is stored in its protected configuration.

Procedures Complete FLEX Support Guidelines (FSGs) for Byron Station, Unit 1 have been developed and integrated with existing procedures. The FSGs and affected existing procedures have been verified and are available for use in accordance with the site procedure control program.

Training Complete Training for Byron Station, Unit 1 has been completed in accordance with an accepted training process as recommended in NEI 12-06, Section 11.6.

Staffing Complete The Phase 2 staffing study for Byron Station has been completed in accordance with 10CFR50.54(f), "Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force review of Insights from the Fukushima Dai-ichi Accident," Recommendation 9.3, dated March 12, 2012 (Reference 12), as documented in Reference 13.

National SAFER Response Center Complete EGC has established a contract with Pooled Equipment Inventory Company (PEICo) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. It has been confirmed that PEICo is ready to support Byron Station, Unit 1 with Phase 3 equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

Validation Complete EGC has completed performance of validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the Overall Integrated Plan (OIP) for Order EA-12-049.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-049 November 30, 2015 Page 11 FLEX Program Document - Established The Byron Station, Unit 1 FLEX Program Document has been developed in accordance with the requirements of NEI 12-06.

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

1 declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of November 2015.

Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector Byron Station NRC Project Manager, NRR Byron Station Mr. John D. Hughey, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

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