RS-13-018, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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

ML13060A364
Person / Time
Site:	Byron
Issue date:	02/28/2013
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-13-018
Download: ML13060A364 (70)

Text

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

Subject:

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

References:

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

2.

NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August, 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25,2012 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC 0 develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

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

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

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

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

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

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

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

Enclosure:

1.

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

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

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

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

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

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

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

Respectfully submitted,

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

Enclosure:

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

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

Overall Integrated Plan (67 pages)

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

Overall Integrated Plan (67 pages)

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

Seismic Hazard Assessment:

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

External Flood Hazard Assessment:

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

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

High Wind Hazard Assessment:

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

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

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

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

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

UFSAR, (Ref. 3),

flooding mechanisms are either not critical or not bounding Byron.

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

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

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

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

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

severe winds NEI 12-06, (Ref.

7),

to Page 1 of 67

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

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

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

Extreme Cold Hazard Assessment:

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

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

High Temperature Hazard Assessment:

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

References:

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

2.

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

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

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

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

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

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

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

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

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

extreme amount of ice.

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

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

2.

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

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

2.

4.

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

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

6.

12-06

7.

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

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

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

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

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

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

strategies.

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

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

The following conditions exist for the baseline case:

o DC battery banks are available.

o AC and DC electrical distribution is available.

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

o Local manual control of Steam Generator Power Operated Relief Valves, (S/G PORVs) o Plant initial response is the same as Station Black Out, (SBO), WCAP-17601-P (Ref.1).

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

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

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

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

Ref: NEI 12-06 section 3.2.1

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

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

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

Provide key assumptions associated with implementation of FLEX Strategies:

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

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

The following conditions exist for the baseline case:

o DC battery banks are available.

o AC and DC electrical distribution is available.

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

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

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

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

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

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

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

References:

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

Wilcox NSSS Designs, dated August 2012.

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

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

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

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

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

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

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

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

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

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

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

condition where it cannot comply certain

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

References:

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

NSSS Designs, dated August 2012.

Ref 2 -

12-01 0,

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

Full conformance with

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

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

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

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

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

Byron Station timeline is outlined in Attachment 1 A.

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

+

5 to 15 minutes - Based on the plant response and the direction from the Emergency Operating Procedure BCA 0.0, Loss of All AC Power, an operator is dispatched to the B AFW Pump and will ensure that it is properly aligned and low suction pressure is reset if needed. The operators will then verify that the pump is started and running properly.

The one (1) hour time constraint is based on the results of MAAP analysis B-MISC-009 (Ref. 1).

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

+

30 minutes to 3.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - After the Station DGs have been verified to be not available, an operator is dispatched to the Div 2 ESF Switchgear Bus -32X and verifies all breakers are open then will proceed to the FLEX Building and prep and align the FLEX DG to the station connections. Once aligned the FLEX DG will be started and a controlled loading will occur to restore power to the required Div 125 volt DC Battery charger and to the Div 2 125 Volt instrument busses. The 3.6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time constraint is based on the results of EC Evaluation 391872 (Ref.

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

+

1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> - The control room will begin and direct a cooldown of the RCS by local operation of the S/G PORVs and local control of the AF flow control valves to reduce S/C pressure down to at least 300 Asia at a minimum of 75°F/hr, MAAP Analysis (Ref.1)

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

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

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

The results will be provided in a

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

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

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

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

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

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

Page 5 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan

References:

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

WC -17601-P approved August 2012

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

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

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

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

Provide a milestone schedule. This schedule should include:

Modifications timeline o Phase 1 Modifications o

Phase 2 Modifications o

Phase 3 Modifications Procedure guidance development complete o Strategies o

Maintenance Storage plan (reasonable protection)

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

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

See attached milestone schedule (Attachment 2)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Describe training plan List training plans for affected organizations or describe the plan for training development Training materials for FLEX will be developed for all station staff involved in implementing FLEX strategies. For accredited training programs, the Systematic Approach to Training, SAT, will be used to determine training needs. For other station staff, a training overview will be developed and communicated. Closure of this item will be communicated in a future 6-month update.

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

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

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

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

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

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

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

List training plans for affected organizations or describe the plan for training development Training materials for FLEX will be developed for all station staff involved in implementing FLEX strategies. For accredited training programs, the Systematic Approach to Training, SAT, will be used to determine training needs. For other station staff, a training overview will be developed and communicated. Closure of this item will be communicated in a future 6-month update.

Page 7 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Byron Station has contractual agreements in place with the Strategic Alliance for FLEX Emergency Response (SAFER).

The industry will establish two (2) Regional Response Centers, (RRC), located in Tennessee and Arizona to support utilities during beyond design basis events. Each RRC will hold five (5) sets of equipment, four (4) of which will be able to be fully deployed when requested, the fifth set will have equipment in a maintenance cycle. Equipment will be moved from an RRC to a local Assembly Area, established by the Strategic Alliance For Flex Emergency Response (SAFER) team and the utility. Communications will be established between the affected nuclear site and the SAFER team and required equipment moved to the site as needed. First arriving equipment, as established during development of the nuclear site's playbook will be delivered to the site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the initial request Ref. NEI 12-06 (Ref. 1). Reference Nuclear RRC Contract RFP-20480 (Ref.2).

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

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

References:

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

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

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

an to a

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

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

Notes:

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

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

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

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

Attachment B, will be entered when the emergency diesel generators are confirmed unavailable and off-site power cannot be restored and it is confirmed by dispatcher or visual verification of physical damage to infrastructure at site.

Within 90 minutes Operators will cool down the plant at approximately 75°F/hr to 420°F (Tcold).

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

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

During cool down, the Diesel Driven Auxiliary Feedwater (DDAFW) pump will deliver water from the Ultimate Heat Sink (UHS) via Essential Service Water (SX) system to the SGs.

Cold Shutdown and Refueling:

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

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

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

Deploying and implementing portable FLEX pumps to supply injection flow must commence ediately from the time of the event. This should be plausible because more personnel are on site during outages to provide the necessary resources. Strategies for makeup water include 1 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

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

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

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

Loss of AC Power (ELAP),

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

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

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

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

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

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

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

has a

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

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

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

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

resources.

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

Page 9 of 67

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

References:

Ref 1 - MAAP analysis BB-MISC-020 Rev. 0, Approved 2/01/13 Ref 2 - WCAP-17601-P Rev 0, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, & Babcock & Wilcox NSSS Designs, dated August 2012, Section 4 & 5 Ref 3 - OP-AA-108-117-1001 Rev 0, Spent Fuel Storage Pools Heat-up Rate With Loss of Normal Cooling, dated July 22, 2011 Details:

Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

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

These will be an Open item that will be closed and documented in a future 6-month update.

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

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

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

Provide a brief description of Procedures

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

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

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

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

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

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

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

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

future 6-month update.

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

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

3.

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

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

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

SFP Inventory TBD)

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

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

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AFO18A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NR006A/B, NI-36B IR

Reference:

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

Notes:

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

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

Page 11 of 67 Notes:

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

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

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

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

Page 11 of67 8A

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

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

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

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

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

Details:

Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

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

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

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

Provide a brief description of Procedures

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

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

be used to control S/O pressure.

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

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

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

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

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

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

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

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

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

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

( RCS Temperature:

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

TBD)

Byron's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (.. 112-06 Rev. 0 Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

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

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: L1-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06A/B, NI-36B

Reference:

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

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

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

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

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

update identification.

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

a Page 13 of67

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Page 14 of 67 Byron Station, Units 1 and 2 Mitigation Strate ies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 Storage / Protection of Equipment :

Describe stora e I rotection Ian or schedule to determine stora e re uirements Seismic Flooding Note: if stored below cun'ent flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Structures to provide protection of equipment will be constructed to meet the 12-06 Rev. 0, Section

11. Schedule to construct permanent building is contained in will the site compliance date. Temporary U',L1~'U1F-. construction completion.

be developed to address storage path and

~JlUL-,UL;> applicable to protection be constructed to meet the requirements of

11. Schedule to construct permanent is VVJlU.U.JlJlH.,'U Attachment and satisfy site compliance date.

locations used building construction completion.

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

Structures to provide protection of will be constructed to meet 12-06 Rev. 0, Section

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

Procedures programs be developed to address storage structure requirements, haul requirements relative to the external hazards applicable to Station.

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

11. "':r>t'\\t:>riln

,t1"'11f'tTI1"'t::>C to provide constructed to meet Page 14 of 67 vV~"'J.iJJ."'"llv'" date. Temporary completion.

......... ~... L'"'.JU storage

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

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

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

Station, y

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

The required Flex Equipment needed for core cooling will be installed in a Robust Flex building ready for quick hook up and use.

Hoses and Electrical connections that will be completed as needed to support the coping strategy will be stored within the Flex building.

Identify modifications The storage structure conceptual design has not been completed and will be an Open

Item, The closure of this item will be documented in a future 6-month update.

Identify how th e connection is protected FLEX piping, valves, and connections (electrical & fluid) will meet NEI 12-06 Rev.0 protection requirements.

There will be an administrative program created to protect the connections from blockage during outages and non outage times.

Notes:

Secondary cooling capabilities recommend 300 gpm at 300 psia. (WCAP-17601 -P Ref 1)

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

Prior to depletion of the RWST inventory a transition will be made to the UHS.

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

Reference:

Ref 1 - WCAP-17601-P Rev 0, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, & Babcock & Wilcox NSSS Designs, Page 15 of 67 Strategy Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 structure rOr1n""'01T'.ontc requirements relative to the external hazards applicable to Byron Station.

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

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

core cooling a Robust VYJ..* 'UJ,... lr-, ready quick hook use.

Hoses and Electrical connections that will be completed as needed to support the coping strategy will be stored the Flex Notes:

storage structure conceptual design completed will Item.

not been an Open The closure of this item will be documented in a 6-month update.

VLVJL.Uj;;., valves, connections (electrical & fluid) will meet Rev.O protection requirements.

There will be an administrative program to protect the connections from blockage during outages and non outage times.

Secondary cooling capabilities recommend 300 gpm at 300 psia.

7601 The inventory is maintained at a minimum of 423,000 gal during normal operation.

a conservative sustained flow rate of 300 gpm, the total inventory would depleted in 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />.

Prior to depletion of RWST inventory a transition be made to A.J"... 'A.'-'Ja....... ""L."......... -'.. " Company, LLC (Exelon) has not finalized the engineering designs for

Reference:

Ref 1 -

Power 12-049.

based on designs Once these "Ov1.LOvUUC1.... 'U 6-month 28, 17601 0,

to AC for Westinghouse, Combustion Engineering, & Babcock & Wilcox NSSS Designs, Page 15 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2 dated August 2012.

Page 16 of 67 B ron Station, Units 1 and 2 Miti ation Strate ies lnte rated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 2

2.

Page 16 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain core cooling. Identify methods and strategy(ies) utilized to achieve this coping time.

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

Phase 3 equipment for Byron includes backup portable FLEX pumps and generators. The portable FLEX pumps will be capable of providing the necessary flow and pressure as outlined in Phase 2 response for Core Cooling & Heat Removal, RCS Inventory Control and Spent Fuel Pool Cooling.

The portable FLEX generators will be capable of providing the necessary 480 volt power requirements as outlined in Phase 2 response for Safety Functions Support.

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

Details:

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Reactor Parameters Confirm that procedure/guidance exists or will be developed to support implementation with a description of the procedure /strategy

/guideline.

Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

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

List instrumentation credited or recovered for this coping evaluation.

Essential Instmentation SG Pressure:

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

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

Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B Safety

`unction RCS pressure boundary and pressure control RCS pressure boundary and pressure control RCS Heat Removal Page 17 of 67 Byron Station, Units 1 and 2 Mitigation Strate ies Inte rated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain core cooling. Identify methods and strategy(ies) utilized to achieve this coping time.

are required.

Phase 3 equipment for Byron includes backup portable portable ULU."UL~ will be capable of providing necessary flow pressure as Phase 2 response for Core Cooling & Heat Removal, RCS Inventory Control and Spent portable generators be capable of providing the necessary 480

... ".'"" *. &.1....... '...... in 2 response Safety Support.

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Reactor Parameters be a vehicle a large diesel oil to Details:

Confirm, that procedure/guidance exists or will be developed to support implementation with a description of the procedure / strategy

/ guideline.

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

procedures and/or guidelines will support the existing symptom based command and control strategies in the current List modifications necessary for phase 3 There are no Phase 3 modifications re uired.

List instrumentation credited or recovered for this coping evaluation.

Page 17 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 RCS Pressure: WR - PI-403 Containment Pressure: PI-PCO05 SFP Level: (component #

TBD)

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

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

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI.951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06A/B, NI-36B IR

Reference:

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

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

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

Modifications Protection of connections Strategy Identify how the connection is protected Byron will utilize Phase 2

connection points.

Identify Strategy including how Identify modifications

( the equipment will be deployed to the point of use.

Equipment will be delivered No modifications are required from the RRC to the staging other than those outlined in area. From there the equipment Phase 2 of this plan.

be transported to the site Page 18 of 67 Strategy Byron Station, Units 1 and 2 Miti ation Strate ies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 TBD) strategy may identify additional parameters order to key actions identified the procedures/guidance or to indicate or actual core damage (NEI 12-06 0 Section 3.2.1 and any difference a

6-month update following use as strategy is developed.

~... 'i*... II communicated in a 6-rnonth update.

be evaluated for of item will Core Thermocouple (CET) Temperature: TI-IT002 Accumulator 1, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 FI-AF014A, FI-AF016A and FI-AF018A Battery Capacity I DC Voltage: EI-DCOO2 Neutron NI-NR006AIB, NI-36B

Reference:

Generic Support Guidelines and Interfaces (Controlling Procedure ALA"""'.. A'.......,....,

Recommendation Instruments)

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

Deployment Conceptual Design (Attachment 3 contains Conce tnal Sketches)

Modifications Protection of connections Identify Strategy including how Identify modifications the equipment will be deployed Identify how the connection is protected to the oint 0 Page 18 of 67 2

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 and hooked up by both RRC personnel and plant personnel per the playbook. Equipment will then be operated per plant procedures.

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

Page 19 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal PWR Portable Equipment Phase 3 Notes:

has not finalized engineering designs for compliance with NRC Order EA-12-049.

designs based on current designs will be developed to plan and associated mitigating strategies. Once these have been fully developed, update integrated for Byron during a scheduled changes to the initial designs as submitted in the February 28, Page 19 of 67

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

Low Leak RCP Seals or RCS makeup required All Plants Provide Means to Provide Borated RCS Makeup PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain core cooling. Identify methods (Low Leak RCP Seals and/or borated high pressure RCS makeup)and strategy(ies) utilized to achieve this coping time.

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

Within 90 minutes operators will cool down the plant at approximately 75°F/hr to 420°F (Tcold).

Steam generator (SC) pressure will be approximately 300 psia. Steam generator pressure of 300 psia corresponds to RCS pressure necessary to inject SI accumulators. This will ensure RCS pressure is above the minimum pressure to preclude injection of accumulator nitrogen into the RCS. WCAP-17601-P (Ref. 2).

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

Cold Shutdown and Refueling:

When in Cold Shutdown and Refueling, many variables exist which impact the ability to cool the core. In the event of an ELAP during these Modes, installed plant systems cannot be relied upon to cool the core, thus transition to Phase 2 will begin immediately. All efforts will be made to control reactor temperature below 212°F to prevent an unplanned mode change. Exelon has a program in place (Ref. 3) to determine the time to boil for all conditions during shutdown periods.

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

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

Deploying and implementing portable FLEX pumps to supply injection flow must commence immediately from the time of the event. This should be plausible because more personnel are on site during outages to provide the necessary resources. Strategies for makeup water include 2 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Page 20 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain RCS Inventory Control Determine Baseline coping capability with installed coping modifications not including FLEX modifications, utilizing methods described in Table 3.. 2 of NEI 12-06:

Low Leak RCP Seals or RCS makeup required All Plants Provide Means to Provide Borated RCS Makeup PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain core cooling. Identify methods (Low Leak RCP Seals and/or borated high pressure RCS makeup)and strategy(ies) utilized to achieve this coping time.

the event operators will enter Emergency Operating Procedure (EOP) 0.0, AC. The Extended Loss of AC (ELAP), BCA 0.0 B, will

"",.. nLV," '.... "V"L.;) are confirmed power

...... ".;)f..'" *. VU.'L or visual verification of physical to rn1.... "1-.',.. " operators will cool down plant at 75°F/hr to 420°F (Tcold).

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

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

During cool down, the accumulators.

Cold Shutdown RCS inventory make-up and boration source will be the SI When in Cold Shutdown and Refueling, many variables exist which impact the ability to cool the core.

the event of an during these Modes, installed plant systems cannot be relied upon to cool the core, thus transition to Phase 2 will begin imnlediately. All efforts will be made to reactor below 212°F to prevent an unplanned mode Exelon has a place (Ref. 3) to determine to boil for all conditions during shutdown periods.

time be used to determine time required to transition to Phase 2.

To accommodate the activities of vessel disassembly and water levels the reactor vessel the reactor cavity are often changed.

most limiting condition is case in which reactor is removed water level in vessel is at or below reactor vessel

...... U.LJULJ.F, this condition on the time shutdown) boiling to supply injection flow must commence I-H"'....... H.V.. "" because more personnel are on resources.

water J.u.V'.LU"

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

Page 20 of 67

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

References:

Ref 1 - MAAP analysis BB-MISC-020 Rev. 0 Approved 2/01/13 Ref 2 - WCAP-17601-P Rev 0, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, & Babcock & Wilcox NSSS Designs, dated August 2012 Ref 3 - OP-AA-108-117-1001 Rev 0, Spent Fuel Storage Pools Heat-up Rate With Loss of Normal Cooling,, date July 22, 2011.

Details:

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Reactor Parameters Confirm that procedure/guidance exists or will be developed to support implementation Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

List modifications There are no Phase 1 modifications required at this time.

List instrumentation credited for this coping evaluation.

Essential Instruentation SG Pressure:

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

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

Cold Leg - TI-413B, TI-42313, TI-433B and T1-443B RCS Pressure: WR - PI-403 Containment Pressure: Pl-PCO05 SFP Level: (component #

TBD)

Safety Function RCS pressure boundary and pressure control RCS pressure boundary and pressure control RCS Heat Removal RCS pressure boundary and pressure control Containment Integrity SFP Inventory Page 21 of 67 Byron Station, Units 1 and 2 Mitigation Strategies lnte rated Plan Maintain RCS Inventory Control

<AJl.U."'V.L~ for

References:

Ref 1 - MAAP analysis BB-MISC-020 Rev. 0 Approved 2/01113 Ref 2 -- WCAP-17601-P 0, Reactor Coolant System Response to Extended Loss AC Power Event for Westinghouse, Combustion Engineering, & Babcock & Wilcox NSSS Designs, dated August 2012 Ref 3 - OP-AA-I08-117-1001 0, Spent Fuel Storage Pools Rate With Loss of Normal 22, 2011.

Provide a brief description of Procedures 1 Strategies / Guidelines Identify modifications Key Reactor Parameters Details:

Confirm that procedure/guidance exists or will be developed to support implementation Owners Groups, Task team to develop procedures or guidelines to address the criteria procedures and/or guidelines will the....... a.. L..... ".. J'JO..

based command and control strategies List modifications are no Phase 1 re uired at this time.

List instrumentation credited for this coping evaluation.

Essential SG Pressure:

PI-5I5, PI-516, PI-545 and PI-546 PI-535, (component #

Page 21 of 67 pressure boundary control

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain RCS Inventory Control Byron's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

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

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

Reference:

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

Notes:

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

Page 22 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain RCS Inventory Control In addition to parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional be evaluated use as the detailed strategy is developed. Closure this will be communicated in a future 6-month update.

Core Thermocouple (CET) Temperature: TI-IT002 RCS Level: LI-951, LI-953, LI-955, Reactor Indicating System AFW Flow: FI-AF012A, FI-AF016A and FI-AF018A Battery

/

Bus Voltage: EI-DCOO2 Neutron Flux: NI-NR006A/B, NI-36B

Reference:

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

Notes:

Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs be developed to determine and associated mitigating strategies.

these have been fully developed, Exelon will the integrated plan for Byron during a scheduled update. This update will include to as February 28, 2013 Integrated Plan.

Page 22 of 67

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

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

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

The shortened time of 8 hrs for inventory satisfies the borated water makeup at the expected Xenon peak of 8-10 hrs, from WCAP-17601-P (Ref 1). A calculation will be required and tracked as an Open item for the timing of the boration and quantity required. The closure of this item will be documented in a future 6-month update.

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

References:

Ref I - WCAP-17601-P Rev 0, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, & Babcock & Wilcox NSSS Designs, Section 5.8.1 dated August 2012. page 5-206.

Details:

Confirm that procedurelguidance exists or will be developed to support implementation Byron station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

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

FLEX pump discharge: The B CV pump discharge header, downstream of check valve CV8481B, will be modified with a tee. A header will be routed from the tee to the RWST tunnel hatch or alternate path and terminated with a standard FLEX connection (Alternate). The flow path goes through a normally closed MOV S18801A/B which can be manually opened or the B train can be electrically opened after the FLEX DG powers up the Div 2 ESF Bus. The B SI pump discharge header, downstream of SI8921B, will be modified with a tee. A header will be routed from the tee to the RWST tunnel hatch or alternate path and terminated with standard FLEX connection (Primary)_Deployment of the secondary flow path will be Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Page 23 of 67 Byron Station, Units 1 and 2 Miti ation Strategies lnte rated Plan Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

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

come be into the CV/SI pump discharge line downstream of the CV/SI pump.

shortened time of 8 hrs for inventory satisfies borated water makeup at the expected Xenon peak of 8-10 hrs, from WCAP-17601 (Ref 1). A calculation will be and tracked as an Open the timing of the boration and The closure of be documented in a future update.

strategy is

""C',r\\n<'", to

'VTonrl,;:,rI Loss Power for Westinghouse, Combustion Engineering, & Babcock &

NSSS Designs, Section 5.8.1 dated August 2012. page 5-206.

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

Confirm that procedure/guidance exists or will be developed to support implementation Byron Station will use industry developed guidance Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria NEI 12-06.

procedures and/or guidelines support the existing symptom based command and control strategies in the current List modifications following installed to support inventory boraHon.

FLEX pump discharge:

B discharge header, downstream of check valve _CV8481B, will modified with a tee. A will RWST Page 23 of 67

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

contingent on primary pressure conditions less than 1750 prig due to the SI discharge header relief valves. This flow path goes through normally opened MOVs that if closed can be manually realigned to establish flow FLEX pump suction: The SI pump suction line from RWST will be modified with a tee. A header will be routed from the tee to the RWST tunnel hatch or alternate path and terminated with a standard FLEX connection.

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

Essential Instrumentation I SG Pressure:

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

NR - LI-517, LI-S19, LI-527, LI-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS Temperature:

Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: QTR - PI-403 Containment Pressure: PT-PCO05 SFP Level: (component SFP Inventory TBD)

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

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

Safety Function RCS pressure boundary and pressure control RCS pressure boundary and pressure control RCS Heat Removal RCS pressure boundary and pressure control Containment Integrity Page 24 of 67 B ron Station, Units 1 and 2 Mitigation Strate ies Integrated Plan Key Reactor Parameters Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

tunnel hatch or alternate path and terminated connection.

List instrumentation credited or recovered for this coping evaluation.

a standard SG Level:

NR - LI-517, 19, LI-527, RCS pressure boundary and pressure control LI-537, LI-547 and LI-549 LI-503 RCS Temperature:

Cold Leg -

3B, TI-433B and Containment Pressure: PI-PC005 (component #

Page 24 of67 RCS Removal RCS pressure boundary and ressure control Containment Intl'l,n-r11r" SFP

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

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-95 1, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AFO18A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NROO6

, NI-36B IR

Reference:

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

Storage / Protection of Equipment:

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

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

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

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

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

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

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

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

Procedures and programs will be developed to address Storage Seismic Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds Page 25 of 67 Byron Station, Units 1 and 2 Miti ation Strategies lnte rated Plan Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

Reference:

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

Storage I Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

Severe Storms with High Winds List Protection or schedule to protect Structures to provide protection of be constructed to meet the requirements of NEI 12-06 Rev. 0, Section

11. Schedule to construct permanent building is contained in r:U.I.uv.l,AAAAv.lH.. 2, will site Temporary locations will used until building construction completion.

programs will be developed to address storage structure requirements, and FLEX equipment f'"anlll11"'arn.antC' relative to to Byron Station.

List Protection or schedule to protect Structures to provide protection of constructed to meet the requirements of

11.

to construct building is vV'.H.. u..... n,"u,., and the site compliance locations will construction pOlrnn.IPrlon developed to address storage Page 25 of 67

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

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

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

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

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

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

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

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

Snow, Ice, and Extreme Cold High Temperatures Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

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

The required Flex Equipment needed for RCS Inventory will be installed in a Robust Flex building ready for quick hook up and use.

Hoses and Electrical connections that will be completed as needed to support the coping strategy will be stored within the Flex building.

Identify modifications The storage structure conceptual design has not been completed and will be an Open Item.

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

Identify how the connection is protected FLEX piping, valves, and connections (electrical & fluid) will meet NEI 12-06 Rev.0 protection requirements.

There will be an administrative program created to protect the connections from blockage during outages and non-outage s.

Page 26 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Snow, Ice, and Extreme Cold High Temperatures Strategy Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

List Protection or schedule to protect

.....,."f"nf'1*~~.. ":).(, to r>rn... nr.a T'!>... r."""r>"~

r>r... ""t~*nntan to meet

11. Schedule to constnlCt permanent building is contained, and satisfy the site compliance date. Temporary locations be used building construction completion.

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

List Protection or schedule to protect Structures to provide protection of nr>.... "t.*l1ntan to meet the r~nlJl1t*~rrl~ntc.'

to Station.

Deployment Conceptual Modification (Attachment 3 contains Conce tual Sketches)

Modifications Protection of connections Identify modifications The storage structure conceptual design has not been completed and will an be Page 26 of 67 Identify how the connection is protected piping, valves, vV~UAvvLA'JAALI (electrical &

12-06 Rev.O

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

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

Page 27 of 67 Byron Station, Units 1 and 2 Miti ation Strategies Integrated Plan Maintain RCS Inventory Control PWR Portable Equipment Phase 2:

Page 27 of67

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

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain inventory control. Identify methods (Low Leak RCP Seals andlor borated high pressure RCS makeup )and strategy(ies) utilized to achieve this coping time.

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

Phase 3 equipment for Byron includes backup portable FLEX pumps and generators. The portable FLEX pumps will be capable of providing the necessary flow and pressure as outlined in Phase 2 response for Core Cooling & Heat Removal, RCS Inventory Control and Spent Fuel Pool Cooling.

The portable FLEX generators will be capable of providing the necessary 480 volt power requirements as outlined in Phase 2 response for Safety Functions Support.

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

Details:

Confirm that procedure/guidance exists or will be developed to support implementation Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

List modifications There are no Phase 3 modifications required.

List instrumentation credited or recovered for this coping evaluation.

Essential Instrumentation I Safety Function Provide a brief description of Procedures

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

PI-515, PI-516, PI-525, PI-535, PI-545 and PI-546 RCS pressure boundary and pressure control SG Level:

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

RCS Heat Removal Cold Leg - TI-413I3, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Page 28 of 67 Byron Station, Units 1 and 2 Mitigation Strate ies Integrated Plan Maintain ReS Inventory Control PWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain inventory control. Identify methods (Low Leak RCP Seals and/or borated high pressure RCS makeup )and strategy(ies) utilized to achieve this coping time.

Phase 3 equipment for Byron includes backup portable pumps and generators. The portable pumps will be capable providing the necessary flow and pressure as outlined in Phase 2 response Core Cooling &

RCS Inventory and Pool Cooling.

The portable generators be capable of providing necessary 480 volt power requirements as outlined in 2 response for Safety Functions Support.

addition a be a portable a large diesel oil v...... '........ 'v..

to support diesel tanks.

Provide a brief description of Procedures

/ Strategies I Guidelines Identify modifications Key Reactor Parameters Details:

Confirn'l that procedure/guidance exists or will be developed to support implementation Byron Station will use the industry developed guidance from Owners Groups, EPRI and NEI team to develop site specific procedures or guidelines to criteria in NEI 12-06.

procedures and/or guidelines will support the existing symptom based command and control strategies List nwdifications There are no 3 modifications required.

List instrumentation credited or recovered for this coping evaluation.

Page 28 of 67

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

Containment Pressure: PI-PCO05 Containment Integrity SFP Inventory Strategy Byron's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

In addition to the parameters listed in NEI 12-06 Rev. 0 Section 32.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AF W Flow: FI-AFO 12A, Fl-AFO 14A, FI-AFO16A and FI-AFO I 8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06A/B, NI-36B IR

Reference:

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

Deployment Conceptual Modification (Attachment 3 contains Conce ptual Sketches)

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

Equipment will be delivered from the RRC to the staging area. From there the equipment will be transported to the site and hooked up by both RRC personnel and Identify modifications No modifications are required other than those outlined in Phase 2 of this plan.

Identify how the connection is protected Byron will utilize Phase 2 connection points.

Page 29 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Strategy Identify Strategy including how the equipment will be deployed to the point of use.

Maintain RCS Inventory Control PWR Portable Equipment Phase 3:

"'-'v..........,....... u............. Integrity strategy parameters that are needed in order to support key actions identified procedures/guidance or to indicate imminent or actual core damage 12-06 Rev. 0 Section 3.2.1.10) any difference be communicated within a update following identification.

12-06 Rev. 0 Section

... J:vl..*U.Li....,U strategy is developed. Closure

.1-UC'Ll"',....... update.

Reference:

PWROG Generic Support Guidelines (Controlling Procedure Interface and.I.,-v'VV...LUJ.Jl,-",U.'.U.I.I...1VAJ.

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

Deployment Conceptual Modification (Attachment 3 contains Conce tual Sketches)

Modifications Protection of connections Identify modifications Page 29 of 67 Identify how the connection is protected 2

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

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

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

Page 30 of 67 B ron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain RCS Inventory Control PWR Portable Equipment Phase 3:

Notes: Exelon Generation Company, (Exelon) not finalized engineering designs compliance with NRC Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to final plan and associated mitigating strategies. Once have been fully developed, Exelon will update the integrated plan for Byron during a scheduled 6-month This update will include any changes to the initial designs as the February 28, 2013 Integrated Page 30 of 67

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

Containment Spray Hydrogen igniters (ice condenser containments only)

PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain containment. Identify methods (containment spray/Hydrogen igniter) and strategy(ies) utilized to achieve this coping time.

There are no Phase 1 actions required.

The limiting case for containment occurs when Auxiliary Feed flow is not established and the TAF is 2.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> results in the maximum calculated containment pressure is 27 psia. (Ref 1) This is below the Containment Design pressure of 50 psig. (Ref 2) The Containment maximum temperature is 218 °F. This is below the maximum calculated Containment temperature of 280 °F for a LBLOCA and 333 °F for a MSLB. UFSAR (Ref 2)

Additional calculations will be performed to evaluate containment response. This will be an open item. The closure of this item will be documented in a future 6-month update.

References:

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

Revision 14, Section 6.2 dated December 2012 Details:

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Containment Parameters Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in z 112-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

There are no phase 1 modifications required.

List instrumentation credited or recovered for this coping evaluation.

Essential Instrumentation SG Pressure:

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

NR - LI-517, LI-519, L1-527, LI-537, LI-547 and LI-549 s Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Safes Function RCS pressure boundary and pressure control RCS pressure boundary and pressure control Page 31 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment Determine Baseline coping capability with installed coping modifications not including FLEX modifications, utilizing methods described in Table 3.. 2 of NEI 12.. 06:

Containment Spray Hydrogen igniters (ice condenser containments only)

PWR Installed Equipment Phase 1:

Provide a general description of the coping strategies using installed equipment including modifications that are proposed to maintain containment. Identify methods (containment spray/Hydrogen igniter) and strategy(ies) utilized to achieve this coping time.

are no Phase 1 actions ",or..,.,.. £)ort

...... U,A""A,.,..., case for containment occurs when flow is not established and the results in the calculated "'"'v.,.".......... "'"',u., pressure is 27 psia. (Ref 1) of 50 psig.

rn".. v1,..... U,'"'Y\\ calculated Containment ta.,,"...... a,.. £}t'l1.. a (Ref 2) r>r1il"lT<:llnrnt:>l'T response. This will be an a

6-month update.

References:

Ref 1 - MAAP Analysis BW-MISC-009, dated November 1,2011 Ref 2 - ByronlBraidwood Nuclear Stations Updated Safety Analysis Report Revision 14, Section 6.2 dated December 2012 Provide a brief description of Procedures I Strategies I Guidelines Identify modifications Key Containment Parameters Details:

Byron Station will use the industry developed guidance

Groups, team to develop site specific procedures or guidelines to address the 12-06. These procedures and/or guidelines support the existing symptom based command and control strategies in the current There are no hase 1 modifications required.

List instruntentation credited or recovered for this coping evaluation.

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

Page 31 of 67

Byron Station, Units I and 2 Mitigation Strategies Integrated Plan Maintain Containment WR - LI-502 and LI-503 RCS Temperature:

RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: PI-Containment Integrity PCOO5 SFP Level: (component #

SFP Inventory TBD)

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

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

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AFO14A, FI-AF016A and FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NROO6A/B, NI-36B IR

Reference:

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

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

Page 32 of 67 B ron Station, Units 1 and 2 Mitigation Strategies Inte rated Plan Maintain Containment (component #

SFP Byron's evaluation of strategy may additional parameters that are needed order to key actions identified in plant procedures/guidance or to indicate or core damage 12-06 0 Section 3.2.1.10) and any a

following identification.

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

Core Exit Thermocouple (CET)

RCS Accumulator Level:

1, and

-957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and 8A Battery Capacity /

Bus Voltage: EI-DC002 Neutron Flux: NI-NR006NB, NI-36B

Reference:

(Controlling Procedure Interface and JL'-v'vv.........uv ***.,.u.l..* vJ..L Instruments) Rev. 0, dated !L.JvvvJJ.HJ'v.i PSC-0965.

Page 32 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment PWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain core cooling. Identify methods (containment spray/hydrogen igniters) and strategy(ies) utilized to achieve this coping time.

There are no Phase 2 actions required.

Details:

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Containment Parameters Confirm that procedure/guidance exists or will be developed to support implementation Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

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

Essential Instruentation SG Pressure:

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

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

Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 Containment Pressure: PI-PC005 SFP Level: (component ##

TBD)

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

Page 33 of 67 Byron Station, Units 1 and 2 Mitigation Strate ies Integrated Plan Maintain Containment PWR Portable Equipment Phase 2:

Provide a general description of the coping strategies using on-site portable equipment including modifications that are proposed to maintain core cooling. Identify methods (containment spray/hydrogen igniters) and strategy( ies) utilized to achieve this coping time.

are no Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Containment Parameters Details:

Confirm that procedure/guidance exists or will be developed to support implementation Byron Station will use the industry developed guidance from the Owners Groups, EPRI and Task team to develop site specific procedures or guidelines to address criteria in 12-06. These procedures the symptom command and control strate ies List modifications are no List instrumentation credited or recovered for this coping evaluation.

SG Pressure:

15, 16, PI-525, PI-535, PI-545 and PI-546 SG Level:

NR - LI-517, 19, LI-527, LI-537, and LI-549

- LI-502 and LJ'-.. HLJ SFP Level: (component #

TBD)

Page 33 of 67

Seismic Flooding Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment In addition to the parameters listed in NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this item will be communicated in a future 6-month update.

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NR006

, NI-36B IR

Reference:

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

Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine stora ge requirements List Protection or schedule to protect NA List Protection or schedule to protect NA List Protection or schedule to protect NA List Protection or schedule to protect NA List Protection or schedule to protect NA Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Strategy Identify Strategy including how the equipment will be deployed to the point of use.

No deployment strategy is required.

Modifications Identify modifications No modifications are required.

Protection of connections Identify how the connection is protected No new connection points are required.

Page 34 of 67 B ron Station, Units 1 and 2 Miti ation Strategies Integrated Plan Maintain Containment RCS Accumulator Level: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and 8A Battery Capacity I DC Bus Voltage: EI-DC002 Neutron Flux: NI-NR006A/B, NI-36B

Reference:

Generic (Controlling Rev. 0, Supplement 14, dated L/....,,-'...,~.. '.... "'-'A Storage I Protection of Equipment:

Describe stora e / rotection Ian or schedule to determine stora e re uirements Seismic Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Strategy List Protection or schedule to protect List Protection or schedule to protect NA List Protection or schedule to protect NA List Protection or schedule to protect NA List Protection or schedule to protect NA Deployment Conceptual Modification (Attachment 3 contains Conce tual Sketches)

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

VU1.ll.... UU'JU0 are required.

are Page 34 of67

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

Page 35 of 67 Byron Station, Units 1 and 2 Mitigation Strate ies lnte rated Plan Maintain Containment Page 35 of 67

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

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain core cooling. Identify methods (containment spray/hydrogen igniters) and strategy(ies) utilized to achieve this coping time.

There are no Phase 3 actions required.

Details:

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Containment Parameters Confirm that procedure/guidance exists or will be developed to support implementation There are no Phase 3 actions required.

List modifications There are no Phase 3 modifications required.

List instrumentation credited or recovered for this coping evaluation.

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

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

Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 Containment Pressure: PI-PC005 SFP Level: (component #

TB D)

Safety Function RCS pressure boundary and pressure control RCS pressure boundary and pressure control RCS Heat Removal RCS pressure boundary and pressure control Containment Integrity SFP Inventory Essential Instentation Byron's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

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

Page 36 of 67 Byron Station, Units 1 and 2 Miti ation Strategies Inte rated Plan Maintain Containment PWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain core cooling. Identify methods (containment spray/hydrogen igniters) and strategy( ies) utilized to achieve this coping time.

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

Confirm that procedure/guidance exists or will be developed to support implementation There are no Phase 3 actions re"n1.. an List modifications are no Phase 3 modifications re uired.

List instrumentation credited or recovered for this coping evaluation.

SG Pressure:

IS, 16, PI-S4S and PI-S46 SG Level:

NR - LI-517, LI-S19, LI-S27, LI-S37, LI-S47 and LI-S49 WR - LI-S02 and LI-503 Temperature:

Cold Leg-TI-433B and RCS Containment 1-101,('('11''

PCODS (component #

R CS pressure boundary and pressure control RCS pressure boundary res sure control Containment..... rr.l>ty.. "T..

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

parameters order to key "'''AVU.., identified in plant n...n,r>arnl"'<~C """1.(1<3nl'' or to indicate or actual o Section 3.2.1.

any

.u'"""'..... UIJ,,"lU\\-v following Page 36 of 67

Strategy Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Containment Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-016A and FI-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-006

, NI-36B IR

Reference:

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

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

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

No deployment strategy is required.

Identify modifications Identify how the connection is protected No modifications are required.

No new connection points are required.

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

Page 37 of 67 B ron Station, Units 1 and 2 Mitigation Strategies lnte rated Plan Maintain Containment Core Exit Thermocouple RCS 8A

Reference:

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

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

Deployment Conceptual Modification (Attachment 3 contains Conce tual Sketches)

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

No strategy is No modifications are required.

required.

No new connection points are required.

Notes:

Generation Com.pany, (Exelon) has not engineering designs for compliance with NRC Order 12-049.

designs based on the current conceptual designs will be developed to final plan and associated mitigating strategies.

been developed, Exelon will update the integrated plan for Byron during a scheduled update. This will any changes to initial designs as ~U.~J~.LL.l"'''''U-2013 Inh~,fTT'<:Itl"rt Page 37 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Determine Baseline coping capability with installed coping" modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Makeup with Portable Injection Source PWR Installed Equipment Phase 1:

Initial Spent Fuel Pool makeup will be accomplished with gravity drain from RWST. Procedure development will be tracked as an open item. The closure of this item will be documented in a future 6-month update.

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

The worst case SFP heat load during an outage is 61.4 Mbtu/hr. Loss of SFP cooling with this heat load and an initial SFP temperature of 163 degrees F results in a time to boil of 3.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and 50.16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to the top of active fuel. Therefore, completing the equipment line-up for initiating SFP make-up within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> into the event ensures adequate cooling of the spent fuel is maintained.

Operator judgment was used to 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, and will be provided in a future 6-month update.

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

References:

1.

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

Details:

Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

4 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment, Provide a brief description of Procedures

/ Strategies / Guidelines Page 38 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Determine Baseline coping capability with installed coping modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

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

Spent be accomplished gravity drain from Procedure development will be tracked as an open item. The closure of this item will be documented in a future 6-month nnrl... f-o Spent Pool (SFP) makeup is not a constraint with initial condition of both units in Mode 1 at 100% power, since the worst case fuel pool heat load conditions only exist during a refueling outage. Under non-outage conditions, the maximum SFP heat load is 38.5 Mbtu/hr. Loss of cooling load and an of degrees F results a

7 Therefore, completing equipment the event ensures cooling of Loss of cooling with a time to boil of 3.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, top of active completing the for ~~L.L'".L"""U.LF>

make-up within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> into the event ensures adequate cooling of the spent fuel is calculations will be pool cooling strategy spent fuel pool area for steam and condensation has not yet been Provide a brief description of Procedures I Strategies I Guidelines the vent strategy, if needed, provided Analysis Report (UFSAR) Revision Details:

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

Page 38 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan The Spent Fuel Pool level instrumentation will be installed in accordance with NRC Order Number BA 12-051 and NEI 12-02.

Identify modifications Key SFP Parameter Essential Instrumentation SG Pressure:

PI-515, PI-516, PI-525, PI-535, PI-545 and PI-546 Safety Function RCS pressure boundary and pressure control SG Level:

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

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

TBD)

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

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

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AFO12A, FI-AFO I 4A, Fl-AF016A and Fl-AF018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NROO6AIB, NI-36B lR

Reference:

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

PSC-0965, Page 39 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Identify modifications The Spent Fuel Pool be...... '.. H"u..L.n."'~

Key SFP Parameter accordance with NRC Order Number EA 12-051 NR -

17, LI-519, LI-527, LI-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS RCS Pressure: WR - PI-403 RCS Heat Removal RCS pressure boundary and Byron's evaluation of the strategy may identify additional parameters that are needed order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage 12-06 Rev. 0 Section 3.2.1.10) and any

'.. ""..LA.VA.V."""' will be communicated within a 6-month update iAnJ'1n...... identification.

In to listed in 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters be evaluated use as detailed strategy is developed. Closure of communicated in a update.

Page 39 of 67

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

Page 40 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for v'V~... tJ,~,""."""'-' with EA-12-049.

designs based on current "",,-,Ln""""I,.,"'-.''

associated mitigating strategies. Once Page 40 of67

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

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

Spent Fuel Pool cooling will be achieved with a portable FLEX diesel pump. The FLEX pump suction will come from the RWST and/or UHS with make-up from Well Water. The discharge will be into the SFP.

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

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

Details:

Confirm that procedure/guidance exists or will be developed to support implementation Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

List modifications Spent fuel pool cooling will be achieved with a portable FLEX diesel pump via a primary and secondary FLEX injection connections.

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

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

The alternate injection path will be provided by installation of a standpipe adjacent to the S FP` by the south wall with standard National Standard Tread (NST) connection. A pipe will be routed from the standpipe to the FHB south wall on the ground elevation.

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

Provide a brief description of Procedures I Strategies / Guidelines Identify modifications Page 41 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling PWR Portable Equipment Phase 2:

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

Spent Fuel Pool cooling will be achieved with a portable diesel pump. The FLEX pump suction will come from RWST and/or URS with make-up from Well Water.

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

results of evaluation the vent path strategy, if needed, be provided a

6-month update.

Electrical power required to 0UIJIJV~

Strategy is described Safety U.U'I._L.l.V'.U Support Section Provide a brief description of Procedures I Strategies I Guidelines Identify modifications Details:

Confirm that procedure/guidance exists or will be developed to support implem,entation Byron Station will use the industry developed guidance the Owners Groups, team to develop site UIJ... 'v....lI.... v procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies the current EOPs.

List modifications Spent pool cooling will be achieved a portable diesel via a primary and secondary injection connections.

Page 41 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Key SFP Parameter Essential Instruentation Safe Function SG Pressure:

RCS pressure boundary and PI-515, PI-516, PI-525, PI-535, pressure control PI-545 and PI-546 SG Level:

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

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

TBD)

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

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

Core Exit Thermocouple (CET) Temperature: TI-IT002 RCS Accumulator Level: LI-951, LI-953, LI-955, and LI -957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AFO12A, FI-AFOI4A, FI-AFOI6A and FI-AFO18A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NROO6A/B, NI-36B IR

Reference:

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

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

Page 42 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key SFP Parameter Maintain Spent Fuel Pool Cooling SO Level:

NR - LI-S17, LI-S27, LI-S37, LI-S47 LI-S49 WR - LI-S02 and LI-503 RCS Temperature:

Cold Leg-I--r_LJI.-' and RCS pressure boundary and pressure control RCS Removal RCS pressure boundary ressure control Byron's evaluation of the strategy additional parameters that are needed in order to support actions identified in the plant procedures/guidance or to indicate imminent or core damage 12-06 Rev. 0 Section 3.2.1.10) difference will be communicated a

6-month update following identification.

In addition to the listed 12-06 Rev. 0 Section 3.2.1.10, following additional parameters will be use as the detailed strategy is developed. Closure of vV.lUC.l.lC.U.lA... vU.. vl...& in a future update.

Page 42 of 67

Seismic Flooding Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Storage / Protection of Equipment:

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

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

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

List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NET 12-06 Rev. 0, Section

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

List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section 1.1. Schedule to construct permanent building is contained in, and will satisfy the site compliance date. Temporary locations will be used until building construction completion.

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

List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NET 12-06 Rev, 0, Section

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

Severe Storms with High Winds Snow, Ice, and Extreme Cold Page 43 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Storage I Protection of Equipment:

Describe stora e / rotection Ian or schedule to determine stora e re uirements Seismic Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold List Protection or schedule to protect Structures to provide protection of equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section

11.

to construct permanent building is contained in, and satisfy site compliance date. Temporary locations be used until building construction completion.

programs will developed to address storage List Protection or schedule to protect

......,.,.... JL....,u to provide protection will constructed to meet the requirements of NEI 12-06 Rev. 0, Section

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

Procedures programs will be developed to address storage

....,'-f,~JlJl,..,JlJl~'..,1Jl"\\3, haul path requirements, and FLEX equipment to hazards applicable to Byron List Protection or schedule to protect Structures to provide protection of be constructed to meet the requirements of

11.

to construct VVL.LAH"l.JJ.VIL<-

OJYAL'UCLUlF,, and satisfy the locations used construction completion.

v....,.....,u.... Jv\\3 and programs will be developed to address..,,,'V'L,,,}o,"'"

structure requirements, requirements relative to Station.

List Protection or schedule to protect

.......",......... "J to Page 43 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Byron Station.

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

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

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

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

The required Flex Equipment needed for SFP cooling will be installed in a Robust Flex building ready for quick hook up and use.

Hoses and Electrical connections that will be completed as needed to support the coping strategy will be stored within the Flex building.

Identify modifications The storage structure conceptual design has not been completed and will be an Open Item.

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

Identify how the connection is protected FLEX piping, valves, and connections (electrical & fluid) will meet NEI 12-06 Rev.0 protection requirements.

There will be an administrative program created to protect the connections from blockage during outages and non-outage times.

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

Page 44 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling High Temperatures List Protection or schedule to protect Structures to provide protection of equipment will be constructed to meet requirements of 12-06 Rev. 0, Section

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

Procedures and programs be developed to address storage

'V"-!..,U...... 'A..

,.. ',U,.. '" relative to the external hazards applicable to Byron Deployment Conceptual Design (Attachment 3 contains Co nee tnal Sketches)

Strategy Identify Strategy including how the equipment will be deployed to the oint of use.

The required needed for cooling will installed a Robust Flex building ready for quick hook up and use.

Hoses and Electrical connections that will be completed as needed to ""'l.H,JA, the coping will be stored Flex building.

Notes:

Modifications Protection of connections Identify modifications The storage structure conceptual design not been completed and will be an r>ln,CH1!"'t:> of this item will be rlnd"llfl,,,,,.... t,,,,rI in a future 6-month.... u,.. u,u.,....,.

Identify how the connection is protected FLEX valves, and connections (electrical & fluid) meet NEI 12-06 Rev.O protection requirements.

There be an administrative program created to protect the connections from blockage

~~~AAJ"'" outages non-outage

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

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

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain spent fuel pool cooling. Identify methods (makeup via portable injection source)and strategy(ies) utilized to achieve this coping time.

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

Phase 3 equipment for Byron includes backup portable FLEX pumps and generators. The portable FLEX pumps will be capable of providing the necessary flow and pressure as outlined in Phase 2 response for Core Cooling & Heat Removal, RCS Inventory Control and Spent Fuel Pool Cooling.

The portable generators will be capable of providing the necessary 480 volt power requirements as outlined in Phase 2 response for Safety Functions Support.

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

Details:

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key SFP Parameter Essential Instentation SG Pressure:

PI-515, PI-516, PI-525, PI-535, PI-545 and PI-546 Safety Function RCS pressure boundary and pressure control Confirm that procedure/guidance exists or will be developed to support implementation Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

There are no phase 3 modifications required.

SG Level:

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

Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B Containment Pressure: P1-PCO05 RCS pressure boundary and pressure control RCS Heat Removal RCS pressure boundary and pressure control Containment Integrity I RCS Pressure: WR - PI-403 SFP Level: (component #

SFP Inventory TBD)

Page 45 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Inte rated Plan Maintain Spent Fuel Pool Cooling PWR Portable Equipment Phase 3:

Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain spentjueZ pool cooling. Identify methods (makeup via portable injection source)and strategy(ies) utilized to achieve this coping time.

Phase 3 includes backup portable FLEX and generators. The portable FLEX pumps will capable of providing the necessary and pressure as outlined Phase 2 response Core Cooling &

Removal, RCS Inventory and Spent Fuel Pool Cooling.

The portable generators be capable providing necessary 480 volt power as Phase 2 response Safety Functions Support.

Provide a brief description of Procedures I Strategies I Guidelines Identify modifications Key SFP Parameter a

oil bladder to Details:

Confirm that procedure/guidance exists or will be developed to support implementation Byron Station use the developed guidance from Owners Groups, EPRI and Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures andlor guidelines will support the existing symptom based command and control strategies current EOPs.

There are no phase 3 modifications Essential SG Pressure:

PI-515, 16, PI-525, PI-546 Page 45 of 67 Safet Res pressure boundary and pressure control RCS pressure boundary pressure control and

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Byron's evaluation of the FLEX strategy may identify additional parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) and any difference will be communicated within a future 6-month update following identification.

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

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

Reference:

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

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

Equipment will be delivered from the RRC to the staging area. From there the equipment will be transported to the site and hooked up by both RRC personnel and plant personnel per the playbook. Equipment will then be operated per plant procedures.

Identify how the connection is protected No modifications are required Byron will utilize Phase 2 other than those outlined in connection points.

Phase 2 of this plan.

Page 46 of 67 Strategy Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling addition to the parameters listed NEI 12-06 Rev. 0 Section 3.2.1.10, the following additional parameters will be evaluated for use as the detailed strategy is developed. Closure of this be communicated a future 6-month update.

Core Thermocouple (CET) Temperature: TI-IT002 RCS 1,

-957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 FI-AF016A and FI-AF018A

Reference:

PWROG Support Guidelines and Interfaces (Controlling Procedure and Recommendation Instruments)

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

Deployment Conceptual Design (Attachment 3 contains Conce tual Sketches)

Modifications Protection of connections Identify modifications modifications are required other than those outlined 2 of this plan.

Page 46 of 67 Identify how the connection is protected Byron connection points.

2

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

Page 47 of 67 Byron Station, Units 1 and 2 Miti ation Strate ies Integrated Plan Maintain Spent Fuel Pool Cooling Page 47 of 67

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

PWR Installed Equipment Phase 1 Provide a general description of the coping strategies using installed equipment including station modifications that are proposed to maintain and/or support safety functions.

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

DC power is required to maintain control of ESF equipment and vital instrumentation. Battery chargers are de-energized during a BDBEE leading to loss of DC and associated functions.

The present 125'VDC battery coping time is approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 36 minutes, without load shedding and can be extended to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 40 minutes with deep load shedding (Ref. 1) consistent with procedure _BCA 0.0. Loss of all AC Power.

References:

Ref 1-Byron EC Evaluation 391872, Battery Coping Time For The 1 25v DC ESF Battery Banks, dated 2/8/13 Details:

Confirm that procedure/guidance exists or will be developed to support implementation.

Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in 112-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

There are no Phase I modifications required.

No identified key parameters.

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

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

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

Provide a brief description of Procedures / Strategies /

Guidelines Identify modifications Key Parameters Page 48 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support Determine Baseline coping capability with installed coping modifications not including FLEX modifications.

PWR Installed Equipment Phase 1 Provide a general description of the coping strategies using installed equipment including station modifications that are proposed to maintain and/or support safety functions.

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

power is required to maintain control of ESF equipment vital instrumentation. Battery chargers are de-energized during a leading to loss associated functions.

present 125VDC battery coping time is approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 36 without load shedding and can be extended to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 40 minutes deep load shedding (Ref. 1) consistent procedure _BCA 0.0. Loss of all AC Power.

References:

1-2/8/13

<'u'UU.L.cVAA 391872, Coping Time 125v DC Provide a brief description of Procedures / Strategies /

Guidelines Identif modifications Key Parameters Details:

Confirm that procedure/guidance exists or will be developed to support implementation.

Byron Station will use the industry developed guidance from the Owners Groups, and NEI Task team to develop site specific procedures or guidelines to address the criteria in 12-06. These procedures and/or guidelines support existing symptom based command and control strate ies in the current There are no Phase 1 modifications re uired.

No identified key parameters.

Byron's evaluation of the FLEX strategy may identify parameters that are needed order to actions identified in plant procedures/guidance or to indicate imminent or core dmnage 12-06 Rev. 0 Section 3.2.1.10) and any be communicated within a future 6-month update following has not finalized the engineering ~_k'~_"~

Detailed designs based on the current V'VA.i.vVI,,"'UC'LU final associated.. "L.. 'L-LF,.......... JlF, 01'r<::;,'..... 0 update integrated plan for Byron a

changes to designs as 5 Coping modifications consist of modifications installed to increase initial coping time, i.e., generators to preserve vital instruments or increase operating time on battery powered equipment.

Page 48 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain andlor support safety functions. Identify methods and strategy(ies) utilized to achieve coping times.

A portable diesel generator will provide power to one division of the 480V ESF busses. Repowering at this level will permit the recovery of one division of station battery chargers, DDAFP battery chargers, and MCC's powering critical equipment such as Diesel fuel oil transfer pumps, and other ESF equipment beneficial to mitigate the event.

Exelon Generation Company, LLC (Exelon) intends on maintaining the Operational Command and Control function within the Main Control Room. Habitability conditions will be evaluated and a strategy will be developed to maintain Main Control Room habitability. The strategy and associated support analyses will be provided in a future 6-month update, Critical ventilation assets may be 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 are open items and will be addressed as part of the detailed engineering design phase. The closure of these items will be documented in a future 6-month update.

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

Details:

Confirm that procedure/guidance exists or will be developed to support implementation with a description of the procedure / strategy

/guideline.

Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

List modifications necessary for phase 2 The following modifications will be installed to support FLEX generator repowering station DC batteries:

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

The alternate FLEX connection will consist of a patch panel mounted Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Page 49 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 2 Provide a general description of the coping strategies using on-site portable equipment including station modifications that are proposed to maintain and/or support safety functions. Identify methods and strategy( ies) utilized to achieve coping times.

A generator power to one of 480V busses. Repowering at this level will permit the recovery of one division of station battery chargers, battery chargers, and MCC's powering critical equipment such as Diesel fuel oil transfer pumps, and other equipment beneficial to mitigate the event.

Exelon Generation Company, (Exelon) intends on the Operational Command and Control function within Main Control Room.

conditions be evaluated and a strategy will be developed to maintain Control Room habitability. The strategy and associated analyses provided in a

"'-'..............4>.. ventilation assets may be to,::"-"LJ'iL1~H

,LUJ.I~'-.l.lu.UV'..'kJ electric rooms, and fuel handling building jJVJlkJV,lU,'"' *. d

......... uJ.... UU..,LH..

component survivability.

these rooms are as part the detailed engineering design phase.

closure of a

future 6-month update.

Additionally, a backup water source for core cooling, inventory, and SFP Lu..... n.v.. !'1J established a

diesel and ton... r.r......... *"',

be installed at to support this strategy.

Details:

Provide a brief description of Procedures

/ Strategies / Guidelines Confirm, that procedure/guidance exists or will be developed to support implementation with a description of the procedure / strategy Identify modifications

/ guideline.

Byron Station will use Owners Groups, and procedures or j::,UJlU,""A.\\,lA'",kJ procedures and/or Jiio,.... "........,u,.,,""u developed guidance Task team to develop r>Alrnn"l<::i"f1,ri and control strategies in the current List modifications necessary for phase 2 The following modifications installed to u.... U

.. ""JL t'r",rl"""'JiTAr repowering Page 49 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 2 directly to the 480 V ESF bus. Cables and a portable generator will be staged supporting timely re-powering of the bus consistent with the site's timeline.

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

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

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

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

No identified key parameters.

Byron's evaluation of the FLEX strategy may identify parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage.

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

Storage / Protection of Equipment :

Describe storage / protection plan or schedule to determine storage requirements List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section 11. Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date.

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

List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev, 0, Section 11. Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date.

Seismic Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level, Page 50 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key Parameters Safety Functions Support PWR Portable Equipment Phase 2 will have a Connection added to Electrical connection via spare breaker for UHS 480v Substation for a to 480 a deep List instrumentation credited or recovered for this coping evaluation.

No identified key parameters.

Byron's evaluation of the strategy may identify T'H11r'<:lT'li"""r""T'C' that are needed in order to support key actions identified in plant procedures/guidance or to indicate imlninent or actual core damage.

Reference NEI 12-06 0, Section 3.2.1.10 and any ~LJLL,",L''''''',",

be communicated within a future 6-month update following identification.

Storage / Protection of Equipment:

Describe stora e I rotection Ian or schedule to determine stora e re uirements Seismic Flooding Note: if stored below current flood level, then ensure procedures exist to move equipment prior to exceeding flood level.

List Protection or schedule to protect Structures to provide protection of constructed to meet the requirements of Section 11. Schedule to construct permanent building is contained, and satisfy compliance date.

pfl"'Iinn.rQ'I""!J locations will Procedures and programs will be developed to address storage structure List Protection or schedule to protect Structures to......,-,,~,.r.'".... '.. "'TL:-.nT.

Page 50 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 2 Temporary locations will be used until building construction completion. Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Byron Station.

List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section 11. Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date.

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

Snow, Ice, and Extreme Cold List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section 11. Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date.

Temporary locations will be used until building construction completion. Procedures and programs will be developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Byron Station, High Temperatures List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of NEI 12-06 Rev. 0, Section 11. Schedule to construct permanent building is contained in Attachment 2, and will satisfy the site compliance date.

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

Severe Storms with High Winds Page 51 of 67 B ron Station, Units 1 and 2 Mitigation Strate ies Integrated Plan Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures Safety Functions Support PWR Portable Equipment Phase 2 List Protection or schedule to protect Structures to provide protection of FLEX equipment will be constructed to meet the requirements of 12-06 Rev. 0, Section 11. Schedule to construct permanent building is contained "t.\\..\\..u.""... u,...... ""J'L\\.. 2, and will satisfy site date.

locations used until building construction

"""-Vi;.;..... to List Protection or schedule to protect Structures to provide protection of FLEX equipment be constructed to meet the requirements of NEI 12-06 Rev. 0, Section 11. Schedule to construct permanent building is contained in Attachnlent 2, and will satisfy the site compliance date.

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

List Protection or schedule to protect

""""~,,,,,,..,u to provide protection be to meet the requirements of 0,

Section 11. Schedule to construct building is contained,

will satisfy the compliance date.

Temporary locations will be used construction completion. Procedures and programs will be developed to address storage structure haul requirements, to the external Page 51 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 2 Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

The required Support Equipment needed for AC Phase 2 implementation will be installed in a Robust Flex building ready for quick hook up and use.

Hoses and Electrical connections that will be completed as needed to support the coping strategy will be stored within the Flex building.

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

Identify modifications The storage structure conceptual design has not been completed and will be an Open Item.

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

Identify how the connection is protected FLEX piping, valves, and connections (electrical & fluid) will meet T 112-06 Rev.0 protection requirements.

There will be an administrative program created to protect the connections from blockage during outages and non-outage times.

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

Page 52 of 67 B ron Station, Units 1 and 2 Mitigation Strate ies Inte rated Plan Safety Functions Support PWR Portable Equipment Phase 2 Deployment Conceptual Design (Attachment 3 contains Conce tnal Sketches)

Strategy Identify Strategy including how the equipm.ent will be deployed to the oint of use.

The Support ro,,~................,..... i-needed for AC 11'Y1r.lo'1'YIt:>nT*,>T.,{"\\n will be

,...,..,.'...... Iai-':lo..-; as needed to ".... I.)'I.IV.l the coping strategy will be stored the Flex building.

J..J\\..I \\..UIJHl"-'!H. for UHS FLEX support will be staged in a robust building and will be deployed to a pre-identified staging location with a debris removal tool the F-750 with snowplow or equivalent machine. Hoses and electrical connections will be completed as needed to support the site co ing strategy.

Modifications Protection of connections Identify modifications storage structure conceptual design has not been completed and will be an Open Item.

be Identify how the connection is protected piping, valves, and connections (electrical & fluid) will meet 12-06 Rev.O protection requirements.

will be an administrative non-outage Notes: L.JL'LV.lV'.lA......,'VAAV.lUAVAA '-'V.llUJ... 'A.l (Exelon) has not finalized the engineering designs for Detailed designs based on the current conceptual designs compliance with NRC Order EA-12-049.

will be developed to 'U-VI.VA LALAA"[V and associated mitigating strategies.

these have developed,.L.fI'\\.VAV'J.l update the integrated for Byron during a scheduled 6-month

_AA~UA"""~~ to as the February 28, 2013 Integrated Plan.

Page 52 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 3 Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain andlor support safety functions. Identify methods and strategy(ies) utilized to achieve coping times.

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

Phase 3 equipment for Byron includes backup portable FLEX pumps and generators. The portable FLEX pumps will be capable of providing the necessary flow and pressure as outlined in Phase 2 response for Core Cooling & Heat Removal, RCS Inventory Control and Spent Fuel Pool Cooling.

The portable FLEX generators will be capable of providing the necessary 480 volt power requirements as outlined in Phase 2 response for Safety Functions Support.

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

Details:

Byron Station will use the industry developed guidance from the Owners Groups, EPRI and NEI Task team to develop site specific procedures or guidelines to address the criteria in NEI 12-06. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

There are no phase 3 modifications required.

No identified key parameters.

Byron's evaluation of the FLEX strategy may identify parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core damage.

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

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Parameters Page 53 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 3 Provide a general description of the coping strategies using phase 3 equipment including modifications that are proposed to maintain and/or support safety functions. Identify methods and strategy(ies) utilized to achieve coping times.

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

Phase 3 equipment for Byron includes backup portable pumps generators.

portable pumps be capable of providing the necessary flow pressure as outlined in Phase 2 response Core Cooling & Heat Removal, RCS Spent Fuel Pool Cooling.

portable generators will be capable of necessary 480 volt power requirements as outlined Phase 2 response for Safety Functions Support.

addition, a be a a

diesel to support Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Parameters Details:

Byron Station will use the industry developed guidance from the Owners Groups, and NEI team to develop site specific procedures or guidelines to address the criteria in 12-06. These procedures and/or guidelines will support existing symptom based command and control strategies in the current EOPs.

are no phase 3 modifications required.

No identified parameters.

Byron's evaluation of strategy may identify parameters that are needed order to key actions in procedures/guidance or to indicate or actual core V"JlI.",~V.

Reference 12-06 Rev. 0 Section 3.2.1.10 any difference will be within a update following identification.

Page 53 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 3 Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

Equipment and consumables will be delivered from the RRC to the staging area. From there the equipment will be transported to the site and hooked up by both RRC personnel and plant personnel per the playbook. Equipment will then be operated per plant procedures.

Identify modifications No modifications are required other than those outlined in Phase 2 of this plan.

Identify how the connection is protected Byron will utilize Phase connection points.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update the integrated plan for Byron during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated Plan.

Page 54 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 3 Deployment Conceptual Design (Attachment 3 contains Conce tual Sketches)

Strategy Identify Strategy including how the equipment will be deployed to the oint of use.

per the playbook..LJ.....,u.J.IJJUJ.'VJiJ.l.

will then be operated per procedures.

Modifications Protection of connections Identify modifications No modifications are required other than those outlined Phase 2 of plan.

Identify how the connection is protected Byron will utilize Phase 2 connection points.

Notes: Exelon Generation Company, (Exelon) has not the engineering designs for compliance with Order EA-12-049. Detailed designs based on the current conceptual designs will be developed to determine the final plan and associated mitigating strategies. Once these have been fully developed, Exelon will update integrated plan for Byron during a scheduled 6-month update.

update include changes to the designs as submitted in the 28, 2013 Page 54 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses I

Performance Criteria Maintenance Containment Instrumentation x

Accessibility x

List portable equipment Core S

Four (4) 480 VAC Generator 500kW Per conceptual design Maintenance / PM requirements Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section H.

Three (3)

High Head Flex Pump Three (3)

Medium Head FLEX pump 40 gpm at 1500 psia At the injection point to the RCS per WCAP 17601-P 300 gpm at 300 psia At the injection point to the Steam Generators per WCAP 17601-P Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11, Page 55 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential/flexibility) diverse uses Perfonnance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements Per At the to the RCS perWCAP 17601-P At the point to the Steam Generators per WCAP 17601-P Page 55 of 67

List portable equipment Two (2)

Portable diesel FLEX pumps Six (6)

Portable 5500 watt DGs One (1) F-750 Ford Truck Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses I

Performance Criteria Maintenance Maintenance I PM requirements Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

x X

X X

Debris Removal and Equipment maintenance Refuel delivery and testing will be capability performed in accordance with the industry General Usage templates, as outlined in JLD-ISG-2012-01 section 6 and NET 12-06 section 11.

Accessibility 1100 gpm at 500 ft head General Usage 5500 watt General Usage x

X Core Containment SFP Instrumentation X

x Page 56 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential/flexibility) diverse uses Peiformance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements General 5500 watt General General Page 56 of67

List portable equipment Three (3)

Diesel Trash Pumps Three (3)

Satellite phones Six (6) 42" Electric Box Fans Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential Iflexibility) diverse uses Performance Criteria Maintenance Maintenance / PM requirements Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JI D-ISG-2012-01 section 6 and NEI 12-06 section 11.

Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Core Containment SFP Instrumentation Accessibility General Usage Iridium 9555 General Usage General Usage X

x X

x x

x x

X x

x x

x x

Page 57 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential/flexibility) diverse uses Peiformance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance / PM equipment requirements Page 57 of 67

List portable equipment Ten (10) 20" portable is vent s

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance Maintenance / PM requirements Equipment maintenance and testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Core Containment SFP Instrumentation Accessibility x

x x

General Usage Page 58 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential/flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance I PM equipment requirements General Page 58 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 3 Use and (potential /flexibility) diverse uses Performance Criteria Notes Note:

The RRC equipment has not been procured at the time of this submittal. The equipment listed is a generic list provided by the C and even though Byron may not require this equipment in its plan it will be available and could be utilized in the Phase 3 time period. Once the SAFER committee determines the equipment specifications for bid, updates will be made as necessary to this table. The Phase 3 portable equipment table will be updated once all. of the equipment has been procured and placed in inventory.

Instrumentation x

Containment x

x x

x Accessibility x

Core x

SFP x

x x

List portable equipment Medium Voltage Diesel Generator Low Voltage Diesel Generator Positive displacement High Pressure Pumps (PWR only)

Low Pressure Pump Low Pressure Pump 2 MW output at 4160 Vac, three phase 500 kW output at 480 Vac, three phase 1000-3000 psi shutoff head, 60 gpm capacity

Generator must be common commercially available.

Must run on diesel fuel.

Generator must be common commercially available, Must run on diesel fuel.

Must run on diesel fuel 300 psi shutoff head, 2500 gpm max flow 500 psi shutoff head, 500 gpm max flow Page 59 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 3 Use and (potential/flexibility) diverse uses Core Containment Instrumentation Accessibility must common common 1000-3000 Page 59 of 67

Byron Station, Units I and 2 Mitigation Strategies Integrated Plan Low Pressure Pump Low Pressure Pump Air Compressor x

Industry Standard C Order 1 10 psi shutoff head, 400 gpm max flow submersible 150 psi shutoff head, 5000 gpm max flow 120 psi minimum pressure, 2000 scfm Page 60 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan

---

.~-

Page 60 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Phase 3 Response Equipment/Commodities Item Radiation Protection Equipment Survey instruments Dosimetry Off-site monitoring/sampling Notes The C will not stock this type of equipment but this equipment will be requested from site-to-site and utility-to-utility on an as required basis.

Commodities Food Potable water Fuel Requirements Heavy Equipment

1. Transportation equipment 2.

Debris clearing equipment The RRC will not stock these commodities but they will be requested from site-to-site and utility-to-utility on an as required basis.

300 - 500 gallon bladders that can be delivered by air TBD during site specific playbook development Redundant Phase 2 equipment to be located at RRC Page 61 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Phase 3 Response Equipment/Commodities Item Notes Radiation Protection Equipment

• Survey instruments

• Dosimetry

• Off-site monitoring/sampling Commodities

• Food

• Potable water Fuel Requirements Heavy Equipment

1. Transportation equipment

2. Debris clearing equipment Page 61 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan A Sequence of Events Timeline Action item Elapsed Time Action Time Constraint Y/N6 Remarks /

Applicability The times to complete actions in the Events Timeline are based on operating judgment, the co and the current supporting analyses. The final timeline will be time validated once detailed d completed, procedures are developed, and the results will be provided in a future 6-month up 0

Event Starts, BDBEE occurs, Unit 1 and Unit 2 reactors automatically trip and all rods are inserted.

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

1 min Emergency Operating Procedures (EOPs) and Station Black Out (SBO), Procedures are entered.

5-15 mins Verify DDAF Pp i s operating properly.

10-30 minx Attempt starting Emergency D/Gs.

30 mins ELAP condition recognized and ELAP Procedures are entered.

30 minx to Connect FLEX 480V AC generators to ESF bus 3.6 hrs

-32X and verify they are supplying power to Div 2

- 125V DC battery chargers.

_BCA 0,0, Loss of All AC Power,

action,

_BCA 0.0, Loss of All AC Power, action.

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

_BCA 0.0, Loss of All AC Power, attachment B for ELAP

Reference:

EC-EVAL # 391872 Battery Coping Time For The 125V DC ESF Battery Banks, dated February 8, 2013 2

4 5

6 NA A

Y-1 hour NA A

Y-3.6 hrs nceptual designs, esigns are date.

Plant @100%

power 1.5 hrs Start depressurization of SGs to 300 Asia at a Y - 1.5

_BCA 0.0, Loss minimum of 75°F/hr cooldown with SG PORV hrs of All AC Power, local/manual operation. SG feed is controlled with action.

Local/Manual operation of AFW flow control valves.

6 Instructions: Provide justification if No or NA is selected in the remarks column If yes, include technical basis discussion as required by NEI 12-06 section 3.2.1.7 Page 62 of 67 Action item Elapsed Time Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Action Attachment lA Sequence of Events Timeline Time Remarks /

Constraint Applicability V/N 6

The times to complete actions in the Events are based on operating judgment, the conceptual designs, and the current supporting analyses. The final timeline will be time validated once detailed designs are completed, procedures are developed, and the results be a

update.

1 2

3 4

5 6

7 o

Event Starts, BDBEE occurs, 1 and Unit 2 NA reactors automatically trip and rods are inserted.

Loss of power affecting 1

VvvuuJ. *...,'" (EOPs) and NA Out (SBO), Procedures are a..... t*o.. "".ri 5-15 mins Verify is operating properly.

-1 hour 10-30 30 mins 30 mins to 3.6 1.5 Attempt starting Emergency DIGs.

NA ELAP condition recognized and are entered.

Procedures NA Connect FLEX 480V AC generators to bus

_32X and verify they are supplying power to 2

hrs

- 125V battery chargers.

Start depressurization of SGs to 300 psia at a Y - 1.5 minimum 75°P/hr cooldown with SG local/manual operation. SG

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

6 Instructions: Provide justification if No or NA is selected in the relnarks column If yes, include technical basis discussion as required by NEI 12-06 section 3.2.1.7 Page 62 of67 Plant @100%

power

_BCA 0.0, Loss of AC Power, action.

_BCA 0.0, Loss of All AC Power, action.

_BCA 0.0, Loss of All AC Power, action.

_BCA 0.0, Loss of All

Power, attachment B for Battery Coping Time For 125V DC ESF Battery Banks, dated February 8, 2013

10 11 12 13 14 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan 2.25 hrs I SI Accumulator borated water begins to inject into I NA Operator the RCS I

I Judgment 5

24 - 72 hrs Continue to maintain critical functions of Core Cooling (via DDAF), RSC Inventory Control (via FLEX pump injection to RCS) and SFP Cooling (via FLEX pump injection to S FP). Utilize initial RRC equipment and resources as a spare capacity.

3-6 hrs 3 hrs 6-12hrs 12 hrs 24 hrs 24 hrs Connect high pressure FLEX Pumps and ensure they are available to supplying borated make-up to the RCS.

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

Connect FLEX Pump and ensure it is available to supplying makeup to the SFP.

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

Set up FLEX pump suction from UIIS.

Regional Response Center (RRC) resources begin arriving on site.

Operator Judgment NA NA NA NA End of analytical simulation A

Page 63 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan 8

2.25 hrs SI Accumulator borated water begins to inject into NA Operator the ReS 9

3-6 hrs Connect Pumps and ensure I-\\n.'-:.1-",,,'i IIlaKe-UtD to 10 11 6 - 12 hrs NA 12 12 hrs NA NA NA 15 NA ment and resources as a s are capacity.

Page 63 of 67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment lB NSSS Significant Reference Analysis Deviation Table WCAP value (WCAP-17601-P August 2012 Revision 0)

WCAP page Item Parameter of interest Plant applied value Gap and discussion 1

4-14 Time to begin the cooldown WCAP has a delay of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> From the MAAP Analysis BB-MISC-020 the cooldown begins early due to the secondary inventory available in the Original Steam Generators, (OSGs) on U-2 Page 64 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment IB NSSS Significant Reference Analysis Deviation Table Item Parameter of interest WCAPvalue WCAP Plant applied value Gap and discussion (WCAP-17601-P August 2012 Revision 0) page 1

to a

2 4

1.5 Page 64 of67

Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Milestone Schedule Site: Byron Original Target Completion Date Status elude date changes in this column }

{

Activity Submit 60 Day Status Report Submit Overall Integrated Implementation Plan Contract with RRC Submit 6 month updates Complete Complete Complete Ongoing (Aug 2014 Aug 2014 Aug 2014 Dec 2013 Dec 2013 Dec 2013 Sept 2015 Sent 2015 Oct 2014 Oct 2014 Sept 2015 Oct 2014 Oct 2014 Oct 2014 Jun 2014 Oct 2014 Oct 2014 Oct 2014 Aug 2014 Sept 2015 Oct 2014 Modification Development Phase 1 modifications Phase 2 modifications Phase 3 modifications Modification Implementation Phase I modifications Phase 2 modifications Phase 3 modifications Procedure development Strategy procedures Maintenance procedures Staffing analysis Storage Plan and construction FLEX equipment acquisition Training completion Regional Response Center Operational Unit I Implementation date Unit 2 Implementation date Conceptual Design UP Conceptual Design I/P Note Note 1 Note I Note 1 Note I Note 1 Note 1 Note I Note I Note 1 (will be a standard date from RRC)

Note I Note I No 1.

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

Page 65 of 67 Byron Station, Units 1 and 2 Mitigation Strategies Integrated Plan Site: Byron Orlsnnal rl '-'.1.4-~

II II

-r Recurring action, Aug and Feb IUnit 1 Unit 2 Aug 2014

~ec 2013 Aug 2014 Dec 2013 Aug 2014 Dec 3

IUnit 1 Unit 2 Sept 2015 Oct 2014 Sept 2015 Oct 2014

~ep 2015 Oct 2014 Oct 2014 Oct 2014 Jun 2014 Oct 2014 Oct 2014 Oct 2014 Aug 2014 Sept 2015 Oct 2014

1.

Milestone Schedule

,~ - ~

.. ell vay Submit 60 Day Status Report Submit Overall Integrated Implementation Plan Contract with

~C Submit 6 IUJi t1 updates Modification Development

• Phase 1 modifications

• Phase 2 Inudifkatl()n~

Phase 3 modifications M~ Jd'f~rlil III 111,1;1 If'-ta+;!on

• Phase 1 modifications Phase 2 modifications

• Phase 3 modifications Procedure development Strategy procedures Maintenance procedures Staffing analysis Storage Plan and construction FLEX equipment acquisition Trainl1uI completion Regional Response Center Operational Unit 1 Implementation date Unit 2 Iilil,h: iI 11i:-if1' HI date Page 65 of 67 T.

.1 el date chanQ'es llH.dUUC this column}

rrmn1*4-Complete Complete Ongoing Conceptual Design IfP rt i~1 ne~lgn IJP r

fote 1 Note 1 Note 1 Note 1 Note 1 Note 1 Note 1 Note 1 Note 1 Note 1 (will be a standard date from RRC)

Note 1 Note 1

f '

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

- -I -

t- -

---a..,-:;r---

"""1Uisrz:.........r---.rt"- --..,

I I

I I

I I

I I

- ~I -l.

~

-fI.-.-----l R

,~~ ~,

~'E I Page 66 of67

.:.."'........ c:=-..r

_...-..w...-..

HI- --:-"'"'

'~"'

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

~::i£-:..c:_

UN IT I

\\.N112 f-------------------------------------------,r-------------------------------------------

~ I L

I*-.. ~~

I I

Il Ii I! ~

~I :

II

,I

~i

~~.

~

.:"Exelon "it JC'~ JC'-~' l

'!

rI~:~~~

r:... NU l r:.

"0 f r~.....

I..-

~

(

~

1 1

'I" T

u~~

~

t

~

.d I

.1,_

1 i ~

r:--

~.. -

sa 1-I I

R, d(

~r :

f L __ ~ __ J l_~~J I - ~

I

! II n~.a:"

1,,~

~ II I

I"A-...a

' ~II I

I -

.. ~,-~ I tl-------------------------------------------~L------------------------------------------- J,;:~~~~

2f loIllJ I...... ' ~

'.I.

Page 67 of67