RS-13-017, 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)

ML13060A362
Person / Time
Site:	Braidwood   (NPF-072, NPF-077)
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-13-017
Download: ML13060A362 (71)

Text

1 Exelon Generation Order No. EA-12-049 RS-13-017 February 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457

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 to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-1 2-049 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 Braidwood 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.

Braidwood 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 - Braidwood Station, Units 1 and 2 NRC Project Manager, NRR - Braidwood 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 NEt 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 Braidwood 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, G~T?L~

Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Braidwood 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 - Braidwood Station, Units 1 and 2 NRC Project Manager, NRR - Braidwood 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 Braidwood Station, Units 1 and 2 Mitigation Strategies (MS)

Overall Integrated Plan (68 pages)

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

Overall Integrated Plan (68 pages)

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan E meats PWR Site: Braidwood Seismic events, except soil liquefaction; flooding from local /

intense precipitation; severe storms with high winds; snow, ice and extreme cold; and high temperatures were determined to be applicable Extreme External Hazards for Braidwood Station per the guidance of NEI 12-06 Rev. 0 and are as follows:

Seismic Hazard Assessment:

Braidwood will address Beyond Design Basis (BDB) seismic considerations in the implementation of FLEX strategies consistent with NEI 12-06 Rev. 0 (Ref 1).

External Flood Hazard Assessment:

Braidwood Station UFSAR Rev. 14 (Ref. 2) addresses additional flooding mechanisms that are either not critical or not bounding for Braidwood.

External Flooding is not applicable per NEI 12-06 Rev.0 (Ref.

3), since Braidwood is considered a Dry site. Braidwood UFSAR Rev. 14 (Ref. 4), states that the plant grade elevation is at 600.0 feet and the grade floors of the safety related building are at elevation 601.0 feet. The Probable Maximum Flood (PMF) along the Kankakee River, Mason River and Granary Creek do not affect the site, since the maximum water surface elevations are 561.3, 582 and 576 feet respectively: the peak elevations are a minimum of 18 feet below the plant safety related facilities grade of 600 feet.

The probable maximum precipitation (PIMP) falling on the plant area was considered in the analysis of local intense precipitation on the plant site. The maximum water level is elevation 601.91.

feet (Ref. 11) at the plant safety related facilities due to PIMP.

To prevent water due to PMP from entering areas where essential equipment/systems are located, reinforced concrete curbs or steel barriers are provided (Ref. 4).

Huh Wind Hazard Assessment:

NEI 12-06 Rev. 0 (Ref. 5) identifies Braidwood Station in a region (41 degrees 14' N, 88 degrees 13' W) in which it would not experience severe winds from Hurricanes. However, NEI Determine Applicable Extreme External Hazard Ref: NEI 12-06 Sections 4.0 -9.0 JLD-ISG-2012-01 Section 1.0 Page 1 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Site:

Determine Applicable Extreme External Hazard Ref: NEI 12*06 Sections 4.0.. 9.0 JLD-ISG-2012.. 01 Section 1.0 Page lof68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 12-06 Rev. 0 (Ref. 6) identified Braidwood in Region 1 and susceptible to tornado winds of 200 mph.

Temperature information: From Braidwood's UFSAR Rev. 14 (Ref. 7) The annual average temperature in the Braidwood area as represented by Peoria Illinois is 50.8°F, while extreme temperatures range from a maximum of 102°F to a minimum of

-20°F. Maximum temperatures equal or exceed 90°F nearly 20 times per year, while minimum temperatures are less than or equal to 32°F about 130 times per year.

Braidwood's location is 41 degrees 14' N, 88 degrees 13' W Extreme Cold Hazard Assessment:

I 12-06 Rev, 0 (Ref. 8) identifies Braidwood Station in an area in which it could receive 25 inches of snow over 3 days.

NEI 12-06 Rev. 0 (Ref. 9) identifies Braidwood Station in a region, of Ice Severity Level 5, Catastrophic destruction to power lines and/or existence of extreme amount of ice.

High Temperature Hazard Assessment:

Braidwood Station will address high temperatures considerations in the implementation of FLEX strategies consistent with NEI 12-06 Rev. 0 (Ref. 10)

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, Braidwood Section 2.4.4 through 2.4.7 dated December 2012.

3.

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

4.

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

5.

NEI 12-06 Rev. 0, Diverse and Flexible Coping Page 2 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 12-06 Rev. 0 0.... 0"--'k'... 1U'.LV to T.n.... 'nQrlin.

14 area Braidwood's location is r1Plr1I"PPC' 14' 88 degrees 13' W

region, power 5,

and/or existence of extreme amount of address considerations in implementation of strategies consistent with NEI 12-06 Rev. 0

10)

References:

1.

12-06 Rev. 0, Strategies 5.2 dated August 2012.

2. Byron/Braidwood Nuclear Stations Safety Analysis Report (UFSAR) Revision an Braidwood Section 2.4.4 2.4.7 dated December 2012.

3. NEI12-06 1

5.

Page 20f68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Strategies (FLEX) implementation Guide, Figure 7-1 dated August 2012.

6.

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

7.

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

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

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

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

11. Calculation WR-BR-PF-Rev 14, Effect of Local PIMP at Plant Site, dated November 11, 2012 Provide key assumptions associated with implementation of FLEX Strategies:

Flood and seismic re-evaluations pursuant to the 10 CFR 50.54(f) 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 banks are available.

o AC and DC electrical distribution is available.

o Diesel Driven Auxiliary Feedwater (DDAF) pump is available and will start in auto or manual as needed.

a Local manual control of steam generator (SG) power operated relief valves (PORN).

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-Key Site assumptions to implement NEI 12-06 strategies.

Ref: NEI 12-06 section 3.2.1 Page 3 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Key Site assumptions to implement NEI 12-06 strategies.

Ref: NEI 12-06 section 3.2.1

7.

Safety Analysis Report (UFSAR) Revision 14, Braidwood Section 2.3.1.1 December 2012.

8. NEI and Coping J.vU.lvlJlI..Ut.1VU Guide, 8-1

9.

10 Rev 14, November 11, 2012 8-2 Provide key assumptions associated with implementation of FLEX Strategies:

Flood seismic re-evaluations..... "~C'n,nnt-to 10 50.54(f) 2012 are not i-kr..*r.+,r.""a not assumed sublnittal.

re-evaluations are completed, issues be tracked addressed on a schedule o

o available.

o Diesel Driven licensing bases "'~~"'.Uj:;.,... 'LI.

baseline case:

is available o

o o

Page 3 of68 is

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 06).

Additional staff resources are expected to begin arriving 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 Rev 0 (Ref. 2)

Primary and secondary storage locations have not been selected yet; 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. Storage locations will be chosen in order to support the event timeline.

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 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 EP 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)

(Ref. 3),

References:

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, dated August 2012.

2. NEI 12-01 Rev. 0, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012.

Page 4 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 06).

once.. '--'.......... JA.. '"

routes and will be communicated following Storage locations chosen order to support event "'~'''''''L&.-'.

capable of mitigating a

1.

1"""~'1n<:lr'lnl'r cunent (ac) nA'H""'f"

..... L.......,.... U... J to anticipate the strategies are also ri1'J'A'f"C

a wide range possible conditions.

strategies developed to protect safety be incorporated into operating procedures in accordance change processes, capabilities of the sink 50.59. The Specifications ""'V~...,.u,~~

1L~"'JUl"'JLL conditions for normal to ensure that design safety features are available to to a design basis accident and the actions to be the limiting conditions are not met.

beyond-design-basis event it cannot comply vv.Ul.lUvU.l Specifications, as such, may warrant invocation of 50.54(x) 10 73.55(p)

(Ref. 3).

Page 4of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General ntegrated Plan Elements PWR Task Interface Agreement (TIA) 2004-04, "Acceptability of Proceduralized Departures from Technical Specifications (TSs) Requirements at the Surry Power Station," (TAC Nos. MC4331 and MC4332)," dated September 12, 2006. (Accession No. ML060590273)

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 (for 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.

See attached sequence of events timeline (Attachment 1A).

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

Braidwood Station timeline is outlined in Attachment IA.

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 e 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 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 Page 5 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 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 NEII2.. 0613.1 2.1

3.

Include a description of any alternatives to the guidance, and provide a milestone schedule of planned action.

conformance JLD-ISG-2012-01 Rev. 0 and 12-06 0 is c..'V....,,,.nt-,",-t no 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 (for 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 time line Attachment lAo See attached sequence of events timeline (Attachment lAY.

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

a Page 5 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General integrated Plan Elements PWR Procedures 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. 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 BW-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).

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 to 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/G pressure down to at least 300 psia at a minimum of 75°F/hr (MAAP Anaysis 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, and 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 391834 (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.

References:

1. EC Evaluation 391834, Battery Coping Time For The 125V DC ESF Battery Banks, dated February 12, 2013 2.

Byro raidwood MAAP analysis Documentation NO BB-MISC-020 Rev 0 dated February 1, 2013 3.

Braidwood Station MAAP analysis Documentation NO.

BW-MISC-009 Rev 1 dated November 1, 2011 Page 6of68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR one is on MAAP analysis BW-MISC-009 (Ref. 1).

MAAP calculation shows SG dryout occur within without AF as ?<oT'a.. a..... l"c.ri WCAP-17601-P (Ref. 2).

1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s-2),

,.. n... L'"''' to be not available, an ""'-'O,"-I,",,r dispatched to the Div 2 ESF and are open, and then will prep align bus 1

1.

2.

3.

Page 6 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General I 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

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 Regional Response Centers operational ntegrated Plan Elements PWR 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 communicated in a future 6-month update.

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 implementation/compliance dates provided in Order EA-12-049 with no exceptions. Any changes or additions to the planned interim milestone dates will. be provided in a future 6-month update.

Page 7 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 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 Phase3 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 Regional Response Centers operational Describe how the strategies will be deployed in all m,odes.

Ol.U;::;".lU.;::;" areas.

rln.'TD>"'-"""U:;'ro to ensure clear or compensatory actions will be

.l.I.I.J.,IJJ.'-'.l.U,,",'J..lL'-,U to ensure all strategies can deployed modes of operation. This administrative program also ensure strategies can by.......... ".................. Ju.. F, be deployed ~~AAAA""

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

Page 7 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 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.

Braidwood Station will implement an administrative program for FLEX to establish responsibilities, and testing

& maintenance requirements. A plant system designation will be assigned to FLEX equipment which requires 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 components added to the FLEX plant system. Equipment associated with these strategies will be procured as commercial equipment with design, storage, maintenance, testing, and configuration control as outlined in JLD-ISG-2012-01 Rev. 0 section 6 and NEI 12-06 Rev 0 section 11.

Installed structures, systems and components pursuant to 1OC 850.63 (a) will continue to meet the augmented quality guidelines of Regulatory Guide 1.155, Station Blackout. Standard industry PMs 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. Braidwood' s administrative program for FLEX responsibilities, and testing &

maintenance are open items. Closure of this item will be communicated 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 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 Page 8 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR 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 programnzatic 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.

Braidwood Station List training plans for affected organizations or describe the planfor training development Page 8 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR developed and communicated. Closure of this item will be communicated in a future 6-month update.

Braidwood 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 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. 1). Development of Braidwood Station's playbook will be communicated in a future 6-month update.

References:

1.

NEI 12-06 Rev. 0, Diverse and Flexible Coping Strategies (FLEX) implementation Guide, Section 12 dated August 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 Braidwood 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 9 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan General Integrated Plan Elements PWR Describe Regional Response Center plan Notes:

developed

1.

Page 90f68 be

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal Determine Baseline coping capability with installed coping1 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 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.

At the initiation of the event operators will enter Emergency Operating Procedure (EOP) BwCA 0.0, Loss of All AC. The Extended Loss of AC Power (FLAP), BwCA 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 ('Told).

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 Ref. 1) (WCAP-17601-P Ref.2)

During cool down the Diesel Driven Auxiliary Feedwater (DDAF) 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

' 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 10 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal Determine Baseline coping capability with installed coping1 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 Ref: lLD-ISG-2012-01 section 2 and 3 PWR Installed Equipment Phase 1 Provide a general description of the coping strategies using on-site portable equipment including station ntodifications that are proposed to maintain core cooling. Identify methods and strategy(ies) utilized to achieve this coping time.

of event operators enter Emergency AC. The Loss of Power ALLJ............... -', operators cool at 75 to 420 F (Tcold).

Steam generator (SG) pressure will be approximately 300 at temperature.

generator pressure of 300 psia corresponds to RCS pressure necessary to inject accumulators.

This pressure is above to preclude injection of

.... """"........................ U'.L..,UC.... 'V.... """A.L into the (MAAP Ref.

(WCAP-17601-P Ref.2) rI£1'",,,.1r water to cool periods.

reactor must commence 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 10 of 68

I Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal 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 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.

Reference:

1. MAAP analysis BB-MISC-20 Rev. 0 dated February 1, 2013

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.

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:

Braidwood 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 Rev 0. 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 operation of the DDAF pump: Braidwood Station will utilize modifications to close these gaps prior to FLEX implementation. Closure of these items will be communicated 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 />.

_..................... _._....... _...r.........

Essential Instrumentation Safet Function SG Pressure:

RCS pressure boundary and P1-515, PI-516, PI-525, PI-535, pressure control Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Reactor Parameters PI-545 and PI-546 SG Leve RCS pressure boundary and 9,a_..

.7Pressure1 control NR - LI-517 Page 11 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal

1.

2.

Rev 0, Reactor '--VA..... 'I

'<Tro..,.r1Ic,rw Loss Power for Westinghouse, "-V.... UJOAu... rv...LJu.r-,:u.J.""V.L.iCU',fO."

'->n11'IU'" & Wilcox NSSS Designs, dated 2012.

3.

108-117-1001 Rev Spent Storage Pools Loss of 22,2011 Details:

developed guidance team to Provide a brief description of Procedures I Strategies I Guidelines

'-'jJ'-'....... L.JL..... procedures or guidelines to address criteria O.

and/or guidelines will the existing symptom based command and control strategies in the current Identify modifications Key Reactor Parameters Page 11 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan

-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)

.pressure control Containment Integrity

-- -.....m Inventory RCS Heat Removal RCS pressure boundary and Braidwood'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: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AFOI 8A 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 Braidwood 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 12 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core Cooling & Heat Removal Braidwood's evaluation of the are U"-'-\\'&VU procedures/guidance or to LU.... U.............

12-06 Rev. 0 Section a

addition to the listed in NEI 12-06 3.2.1.10, following additional will use as detailed strategy is developed. Closure of be in a 6-month update.

Core J.AvlUlIcJvlc}'ULJJ.v (CET)

LI951, J.UUlvUIL.1U;::' System (RVLIS):

FI-AF016A and 18A

1.

PSC-096S.

Page 12 of 68

Braidwood 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 SG POR V's. The pump suction will come from the RWST and UHS. The FLEX pump discharge will be into the AFW lines downstream of the containment isolation valves into the SG's. The PORV's will be used to control SG pressure.

In the event that the Unit is in a refueling outage, another portable FLEX pumps will also be able to supply the RCS Boil-off using the modifications outlined in Phase 2 inventory control.

Electrical power to support the FLEX strategy is described in the Safety Function Support section of the document.

Details:

Braidwood 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 MSIV room and terminated with a standard FLEX connection (Primary connection) and the other end will be routed to the A/D MSIV 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 13 of 68 Braidwood 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.

2 be a......-..7"'.-... ""I n suction will come from the R WST and DRS. The downstream of the r>rvrlt<:l1nnnt::>nt Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications

outage, portable FLEX 1J~,ljUIJ\\J will be able to rn.n.r'l11".n"t-.A,nC' outlined in Phase 2 1n.. ;rnnt-Ar~T Details:

Owners team to develop specific procedures or guidelines to address the criteria in NEI 12-06.

flange connections on A,

water SG injection at the test Steam Isolation Valve (MSIV) rooms.

a header.. r. *

• 1'nrl 1'1->...,,,,, ".1->

be.. "".* "".-1 Page 13 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key Reactor Parameters SG Pressure:

PI-515, PI-516, PI-525, PI-53`

PI-545 and PI-546 SG Level:

NR - LI517, LI-519, LI-527, LI-537, LI-547 and LI-549 WR - LI-502 and LI-503 RCS pressure boundary and pressure control RCS pressure boundary and pressure control 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 Containment Pressure: PI-PCO05 pressure control Containment Integrity SFP Level: (component #

SFP Inventory TBD)

Braidwood'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: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 W Flow: FI-AF012A, FI-AF0I4A, FI-AF016A and FI 018A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NRO06

, NI-36B IR

Reference:

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

Page 14 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key Reactor Parameters NR - LI-S17, LI-S19, LI-S27, LI-S37, LI-S47 and LI-S49 WR - LI-S02 LI-S03 (component #

Page 14 of 68 pressure control Res Removal

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan 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 Braidwood 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 Braidwood 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 Braidwood 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 Braidwood Station.

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 Snow, Ice, and Extreme Cold Page 15 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Storage / Protection of Equipment:

Describe storage I 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 Snow, Ice, and Extreme Cold structure.. ar1'n1.. *0r\\""O.... t-"

requirements Station.

structure rt:>nlll1f.,-t:>rY\\ontC'

.....,u,'.....,UJ,i"o, construction completion.

developed to address storage requirements, external U,"'"',O;..U........., "1-'1-'.1.1,-,",-".1.,-,

requirements relative to the external,UU.LJO;"U...... "

Station.

.... 'V~,..... Jl.. "u to provide protection of constructed to meet

11. '-"VLA,....,...............,

UA.L",UAJ'F, construction r>r\\1'Y\\nloh be developed to address storage structure requirements, requirements, and requirements relative to the external applicable to Braidwood Station.

Page 15 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan High Temperatures 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 Braidwood Station.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

S ra egy Modifications Protection of connections 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 hookup and use.

Hoses and electrical connectors will be completed as needed to support the site coping strategy and will be stored within the FLEX building.

Identify modifications The storage structure conceptual design has not been completed.

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:

Secondary cooling capabilities recommend 300 gpm at 300 psia (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 Braidwood 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:

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, dated Page 16 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan High Temperatures Structures to provide of to meet the requirements of NEI 12-06, Rev. 0, Section U"\\.,,~.A""UUlv to construct V""'A.......... """'"'...........,,"'......... *.... a Station.

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.

Notes:

not been Identify how the connection is protected non-outage Secondary.....,'V'"N...... lfo-. capabilities -r'Ar"'ATrlrrllnri 300 at 300 psia (Ref. 1)

Page 16 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan August 2012.

Page 17 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan August 2012.

Page 17 of68

Braidwood Station, Units I 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 that no additional Phase 3 strategies are required.

Phase 3 equipment for Braidwood includes backup portable pumps and generators. The portable 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 Confirm that procedure/guidance exists or will be developed to description of Procedures support implementation with a description of the procedure /strategy

/ Strategies / Guidelines I guideline.

Braidwood 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.

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

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

Essential Instrumentation Safety Function SG Pressure:

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

RCS pressure boundary and NR - LI-517, LI-519, LI-527, pressure control LI-537, LI-547 and LI-549 Page 18 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Core CooHng & 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 strategies are required.

provide sufficient capability such that that no additional Phase 3

"""V,l"l"""U.. for Braidwood includes and generators.

portable capable of providing the necessary flow and pressure as 2 response Cooling & Heat Removal, RCS Control and Spent Fuel Pool Cooling.

be capable of providing necessary 480 volt power as VoJlJ',",LH',", for Safety Functions Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key Reactor Parameters a portable a large diesel rt"~'H-r to Details:

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

/ guideline.

Station will use the guidance Task team to develop n-rn.ro,;::r.riu-r,:::>C' or guidelines to ',H lr,rt_><..

procedures and/or.;;;,.... j..... v,u....,""'

command and ""TIlT'"

List modifications necessary for phase 3 are no List instrun~entation credited or recovered for this coping evaluation.

Page 18 of 68

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

RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: VAR PI 403 RCS pressure boundary and pressure control Containment Pressure: P1-

Containment Integrity PCOO5 SF pP

^Level: (component #

SFP Inventory TBD)

Braidwood'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 I 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: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: Fl-AF012A, FT-AF014A, FI-AF016A and FI-AFO18A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NROO6

, NI-36B 1R

Reference:

1.

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

Page 19 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan

Reference:

1.

(Controlling Procedure SFP Inventory 1tTI1Tl1nAnt or actual any difference UIJ"'~UI.""" following 8A Rev. 0, -.:l1r'.nlt:>rnt:>'nT PSC-0965.

Page 19 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

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

Modifications Identify modifications No modifications are required other than those outlined in Phase 2 of this plan.

Protection of connections Identify} how the connection is protected Braidwood will utilize Phase 2 connection points.

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 Braidwood during a scheduled 6-month update. This update will include any changes to the initial designs as submitted in the February 28, 2013 Integrated PI Page 20 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

personnel per the playbook.

will operated procedures.

No modifications are required Braidwood will other than those outlined in connection points.

Phase 2 of Phase 2 (Exelon) has not finalized the engineering designs Page 20 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain RCS Inventory Control Determine Baseline coping capability with installed coping2 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) BwCA 0.0, Loss of All AC. The Extended Loss of AC Power (ELAP), BwCA 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 (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 Ref. 1) (WCAP 17601-P Ref. 2).

During cool down the initial RCS inventory source for makeup and boration will be the SI 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 FLAP 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-tip 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 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 21 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain RCS Inventory Control Determine Baseline coping capability with installed copinJ? modifications not including FLEX modifications, utilizing methods described in Table 3-2 of NEI 12-06:

Low Leak Rep Seals or ReS makeup required All Plants Provide Means to Provide Borated ReS 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.

.LL:<.L"U..... H.JLL of the event operators enter Emergency '-'!-"V.L.. ".... OJ<F, AC. The Extended Loss of AC Power be off-site power cannot verification of physical damage to plant at approximately 75°F/hr to 420°F (Tcold).

at 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 21 of 68

Braidwood 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.

Reference:

1.

MAAP analysis BB-MISC-20 Rev. 0 dated February 1, 2013 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.

3.

OU-AP-104, Shutdown Safety Management Program Byron /Braidwood Annex, Revision 17, dated September 27, 2012.

Details:

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

/ Strategies / Guidelines Braidwood 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.

Identify modifications List modifications There are no Phase 1 modifications required Key Reactor Parameters List instrumentation credited for this coping evaluation.

Essential Instrumentation Safet Pond up SG Pressure:

RCS pressure boundary and PI-515, PI-516, PI-525, P1-535, pressure control PI-545 and PI-546 SG Level:

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

RCS Heat Removal Cold Leg - TI-413B, TI-423B, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control W..._....

Containment Pressure: PI-Containment Integrity PC005 SFP Level: (component #

SFP Inventory TBD)

Braidwood's evaluation of the FLEX strategy may identify Page 22 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan deploying a FLEX Cooling section.

3

"-""'IJ,-,JlU.>V to

'VU'-j'U.r-,."U~u",,", Combustion Engineering, & Babcock &

dated August 2012.

3.

Shutdown Safety Management Program

!Braidwood Annex,

....... ru"""TT>r"."y-27, Provide a brief description of Procedures I Strategies I Guidelines Identify modifications Key Reactor Parameters Details:

Confirm that procedure/guidance exists or will be developed to support implementation Braidwood Station will use the developed j:::,UJ.\\..HU.J'v'v Task team to P"nD,r>."t"".r>...... r"r\\r>'arH",.c... ' or to nror,...n,'<,

procedures and/or guidelines LU+'VA.AA based command control strategies List ntodifications There are no 1 modifications.. "",..,.........,,,r1 List instrumentation credited for this coping evaluation.

Braidwood's Page 22 of68 boundary and pressure control 17,

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan 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 eters 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: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AFO12A, FI-AFOI4A, FI-AFO16A and FI-AFOI8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-O06

, NI-36B IR

Reference:

1.

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 C 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 Braidwood 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 23 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan

~UU'IU'VJ. \\- key VV""UU.LV~1 E,U.I..ULU.l.vV or to indicate o U.."...,U.V.I..1.

use as strategy is developed.

be communicated in a future 6-month nT"lrl,.,t-o Core RCS Level:

1, LI953, LI955, Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A 8A

• ,.,nar>~T*H /

EI-DC002

Reference:

1.

PSC-0965.

Notes:

Generation Company, LLC (Exelon) has not engineering designs Detailed designs based on the current conceptual and associated strategies.

update plan for Braidwood a

...,v.u.vuu*.....,u 6-month update. This update will include any changes to as 1-1.........,1'1'001"1 in the 28, 2013...... 1'".,.......,'1'01"'1 Page 23 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan M `tain RCS Inventory Contra 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 hrs via a portable pump (Ref. 1). The 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 make up at the expected Xenon peak of 8-10 hrs, from WCAP 17601-P (Ref. 1). A calculation will be required for the timing of the boration and quantity required. Closure of this item will be co mmunicated in a future 6-month update.

Electrical power to support the FLEX strategy is described in the Safety Function Support section,

Reference:

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, Section 5.8.1 dated August 2012.

Details:

Confirm that procedurelguidance exists or will be developed to support implementation Braidwood 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 Rev 0. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

The following FLEX modifications will be installed to support inventory and boration of the RCS:

FLEX pump discharge: The B CV pump discharge header, down stream of check valve CV8481 B, 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 (Alternate). The flow path goes through a normally closed MOV S18801A/B which can be manually opened or the B train can be Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Page 24 of 68 Braidwood 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 equipn~ent 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 2 RCS inventory control and boration will be achieved 8 hrs via a portable pump (Ref.

The suction corne discharge will be into the CV lSI discharge line of the CV/SI shortened time of 8 for inventory satisfies the borated water at expected of 8-10 hrs, WCAP 17601-P (Ref. 1). A calculation will be required for the

'. r'>..... n... " of in a

'o:u.................. f' section.

1. WCAP-17601-P 0, Reactor Coolant System Response to Loss of AC Llr"TT""'"

Event for Westinghouse, Combustion Engineering, & LJUeU..,,-'VJ.'Io. & Wilcox NSSS Designs, lJV'-"...,,'V.U 5.8.1 dated August 2012.

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

Confirn~ that procedure/guidance exists or will be developed to support implementation Braidwood Station will use the industry developed guidance specific 06 Rev O.

current

Groups, and Task team to develop site or guidelines to address the criteria procedures and/or ;;;,.... JlU'-'lJ.U'""'.:>

",............ 1',...,........ based... """.u..............

Page 24 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan electrically opened after the FLEX DG powers up the Div 2 ESF Bus. The B SI pump discharge header, downstream of 518921B, will be modified with tee. A header will be routed from a tee to the RWST tunnel hatch and terminated with standard FLEX connection (Primary). Deployment of the secondary flow path will be contingent on primary pressure conditions less than 1750 psig 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 the 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 Function SG Pressure:

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

RCS pressure boundary and NR - LI-517, LI-519, LI-527,

pressure control LI-537, LI-547 and LI-549 WR - LT-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)

Braidwood'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 Page 25 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key Reactor Parameters DG powers the y,,a"'............... ;;;;;.v.... ""n,..."".. downstream of SI8921B, be..,,-,..,,1-nri RWST from tee to and terminated with a List instrumentation credited or recovered for this coping evaluation.

Containment U.. ",,,'.,,,,..o.*

PC005

....... 'U'~....L'L'.u to 3.2. L 10, the Page 25 of68 6

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan 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: L1951, LI953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow. FI 012A, PI-AF014A, PI-AFO16A and PI-AFOI8A Battery Capacity / DC Bus Voltage: El-DC002 eutron Flux: N1-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.

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 Braidwood 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 Braidwood 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 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 26 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan use as the strategy is developed.

of this be communicated a future Generic (Controlling Procedure and 0, Supplement dated December 2012 PA-PSC-0965.

Storage / 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 Page 26 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan 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 Braidwood 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 Braidwood Station.

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

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

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

The required FLEX equipment needed for RCS Inventory Control will be installed in a robust FLEX building ready for hookup and use.

Hoses and electrical connectors will be completed as need to support the site coping strategy and will be stored within the FLEX building.

Modifications Identify modifications The storage structure conceptual design has not been completed.

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

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

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

Page 27 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Snow, Ice, and Extreme Cold High Temperatures nr""",hr"nnt-orl to meet

11. Schedule to construct permanent building is contained in to Braidwood Station.

satisfy site compliance Temporary v.......,.".u..l.J,F-, cons truction completion.

developed to address storage requirements, and FLEX to external hazards applicable Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

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

Modifications Identify modifications Page 27 of68 Protection of connections Identify how the connection is protected

Braidwood 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 Braidwood 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 28 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Page 28 of 68

Braidwood Station, Units I 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 and/or 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 Braidwood includes backup portable pumps and generators. The portable 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 Confirm that procedurelguidance exists or will be developed to description of Procedures support implementation f Strategies / Guidelines Braidwood 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 Rev.0. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

Identify modifications List modifications There are no Phase 3 modifications required Key Reactor Parameters List instrumentation credited or recovered for this coping evaluation.

Essential Instrumentation Safety Function SG Pressure:

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

[ RCS pressure boundary and NR - LI-517, LI-519, LI-527, pressure control LI-537, LI-547 and LI-549 SIR - LI-502 and LI-503 Page 29 of 68 Braidwood 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 and/or borated high pressure RCS makeup) and strategy(ies) utilized to achieve this coping time.

2 strategy will Provide a brief description of Procedures I Strategies I Guidelines Identify modifications Key Reactor Parameters sufficient capability such Details:

no additional Phase 3 strategies portable

>oJ..... "'.u.>."".. "'" in Phase 2 Cooling.

'-'.1..1."-.01," as Confirm that procedure/guidance exists or will be developed to support implementation List instrumentation credited or recovered for this coping evaluation.

Page 29 of68 1

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan RCS Temperature:

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

TBD)

Braidwood'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: L1951, L1953, L1955, 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-NRO06

. NI-36B

Reference:

1.

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

Protection of connections Identify how the connection is protected Page 30 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan SFP Inventory Braidwood's FLEX strategy may identify additional parameters are needed order to key actions identified in the plant procedures/guidance or to indicate

.l,L,U.lIU,U,vUl-or actual core damage (NEI 12-06 Rev. 0 Section use as be cOlnmunicated Core Exit Thermocouple (CET) Temperature:

1, LI953, LI955, and LI 957 PSC-0965.

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

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

Modifications Identify ntodifications Page 30 of68 Protection of connections Identify how the connection is protected

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan 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 and plant personnel per the playbook.

Equipment will then be operated per plant procedures.

No modifications are required other than those outlined in Phase 2 of this plan.

Braidwood will utilize Phase 2 connection points.

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 Braidwood 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 31 of 69 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan modifications are 'F".n.nn..... "'rI 2

other those procedures.

Notes: LJL't.VJJ."'AA Generation Company, (Exelon) has not finalized engineering designs for NRC Order EA-12-049. Detailed designs based on the current conceptual and \\4UIJ'V'.,dL.... '-... '~.U,"""'A;",,~"'JJ.U,."" C'Tr~lT"""T1AC' Page 31 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Containmen 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.

There are no Phase 1 actions required.

The limiting case for containment occurs when Auxiliary Feed flow is not established and the TA-F of 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 28 psia and maximum temperature of 218 °F (Ref. 1). This is significantly lower than the Containment Design pressure of 50 psig and the maximum calculated Containment temperature of 280 °F for a LBLOCA and 333 °F for a MSLB (Ref, 2). Additional calculations will be performed to evaluate containment response, Any difference will be communicated within a future 6-month update.

Reference:

1. Braidwood calculation RM Documentation NO. BW-MISC-009, dated November 1, 2011

2. Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Section 6.2, dated December 2012.

Details:

Braidwood 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 Rev. 0. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

Identify modifications There are no Phase 1 modifications required.

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.

Provide a brief description of Procedures

/ Strategies / Guidelines Page 32 of 68 Braidwood 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 equipn1ent including modifications that are proposed to n1,aintain containment. Identify methods (containment spray/Hydrogen igniter) and strategy(ies) utilized to achieve this coping time.

1 actions.-n.rn,,,.. c.ro

Reference:

1.

2.

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

are no 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 32 of 68

Braidwood Station, Units I and 2 Mitigation Strategies Integrated Plan Key Containment Parameters SG Pressure:

RCS pressure boundary and PI-515, PI-516, PI-525, P1 ;pressure control 535, PI-545 and PI-546 SG Level:

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

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

TBD)

RCS pressure boundary and pressure control Containment Integrity SFP Inventory Braidwood'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: L195 1, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFB/ Flow: FI-AFOI2A, FI-AFOI4A, FI-AFOI6A and FI-AFOI8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: N1-NRO06AIB, NI-36B IR Page 33 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key Containment Parameters SG Level:

NR -

17, 19, 527, LI-S37, LI-S47 and LI-S49 WR - LI-S02 and LI-S03 pressure boundary and pressure control may order to support procedures/guidance or to AAA.... '-'."'....... ""

core damage 0 Section any difference a

use as be cornm'unl~::;at(!ct Page 33 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan

Reference:

1.

P OG 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 C 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 Braidwood 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 34 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan on current,.".",.",r,t-n<:>

".U.. d.v.LLU.IAj,,,-, the final plan and mitigating strategies.

integrated plan for Braidwood during a changes to designs as Page 34 of 68

Braidwood 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 containment. 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 Confirm that procedure/guidance exists or will be developed to description of Procedures support implementation

/ Strategies / Guidelines Braidwood 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 Rev. 0.

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

Identify modifications List modifications There are no Phase 2 modifications required.

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

Parameters Essential Instentation Safety Punition SG Pressure:

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

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

RCS Heat Removal Cold Leg - TI-41313, TI-423P,TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: PI-Containment Integrity PC005 SFP Level: (component SFP Inventory TBD).___

Braidwood's evaluation of the FLEX strategy may identify additional Page 35 of 68 Braidwood 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 containment. Identify methods (containment spray/hydro gen igniters) and strategy(ies) utilized to achieve this coping time.

There are no Phase 2 actions required.

Provide a brief description of Procedures

/ Strategies I Guidelines Identify modifications Key Containment Parameters Details:

Confirn~ that procedure/guidance exists or will be developed to support in~plementation Braidwood Station will use the industry developed guidance Owners Groups, team to List modifications There are no 2 U.IV".U..1..1.vUl-.1.Vlh:J required.

List instrumentation credited or recovered for this coping evaluation.

Page 35 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan parameters that are needed in order to support key actions identified in the plant procedures/guidance or to indicate imminent or actual core d.age (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: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: EI-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-PSG-0965.

Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic NA Flooding Severe Storms with High Winds NA NA Snow, Ice, and Extreme Cold High Temperatures NA Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Page 36 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan order to support key actions...........,u.............,"'"

procedures/guidance or to indicate or actual o Section 3.2.1.10) use as is ri".TCH,,,,,ru:>,.....

communicated in a future 6-month update.

Core Exit 957 Storage / Protection of Equipment:

Describe storage / protection plan or schedule to determine storage requirements Seismic Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold High Temperatures NA NA Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

Strategy Modifications Protection of connections Page 36 of 68 be

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

No deployment strategy is required.

Identify modifications No modifications are required.

Identify how the connection is protected 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 Braidwood 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 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Identify Strategy including how Identify modifications the equipment will be deployed Identify how the connection is protected to the point of use.

IS are Notes: Exelon Generation _... "O-.. IJ......

(Exelon) has not finalized the engineering designs for NRC EA 049. Detailed designs on the current conceptual designs and associated mitigating strategies.

these have integrated plan for Braidwood a scheduled A.l.J."'Jl"\\..I~'" any changes to the designs as submitted February 28, 2013 Page 37 of 68

Braidwood 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 containment. 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 Confirm that procedure/guidance exists or will be developed to description of Procedures support implementation

/ Strategies / Guidelines There are no Phase 3 required actions.

Identify modifications List modifications There are no Phase 3 modifications required.

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

Parameters Essential Instrumentation Safety Function SG Pressure:

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

ICS pressure boundary and NR - LI°517, LI-51, LI-527, pressure control LI-537, LI-547 and LI-549 VVR - LI-502 and LI-503 RCS Temperature:

RCS Heat Removal Cold Leg - TI-413B, TI-423I3, TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: PI-Containment Integrity PC005........................................ __.____._._._.__.._._.__.._._..._......... _.....

SFP Level: (component SFP Inventory TBD)

Braidwood'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 Page 38 of 68 Braidwood 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 containment. Identify methods (containment spray/hydrogen igniters) and strategy(ies) utilized to achieve this coping time.

There are no 3 actions rann.r".r1 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

.. a"n1T'"£~ri actions.

3 modifications <"'0,",'',..,,,

List instrumentation credited or recovered for this coping evaluation.

Page 38 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan 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: L1951, L1953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and Fl-AFOI 8A Battery Capacity / DC Bus Voltage: El-DC002 Neutron Flux: NI-NR006

, NI-36B IR.

Reference:

1.

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)

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

No deployment strategy is required.

Identify modifications No modifications are required.

Identify how the connection is protected 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 Braidwood 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 39 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Core RCS Accumulator Level: LI951, LI953, LI955, and LI 957 L"v4C1.vL'J~ Vessel Indicating System LI-RC020 Flow: FI-AF012A, FI-AF014A, 6A and 8A Capacity /

Voltage: EI-DCOO2 NI-NR006A/B,

Reference:

1.

Deployment Conceptual Modification (Attachment 3 contains Conceptual Sketches)

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

No deployment strategy is No n'"\\r\\rh"'!~'::!;~!::)!!~ are required.

No new '-VL,ULv.<,"".. ~

required.

Page 39 of 68 are

Braidwood Station, Units I 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 the RWST.

Procedure development 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 S FP 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 S FP makeup at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> into the event ensures 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. With the entire core being located in the SFP, manpower resources normally allocated to aligning core cooling along with the Operations outage shift manpower can be allocated to aligning SFP makeup which ensures the system alignment can be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Initiation at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> event ensures adequate cooling of the spent fuel is maintained.

Initial calculations were 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/Eraidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR) Revision 14, Section 9.1.3.1, Table 9.1-1 and 9.4-1 dated December 2012.

a 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 40 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Determine Baseline coping capability with installed coping4 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 be accomplished with gravity drain from the RWST.

Procedure development will be documented a

6-month condition of both in pool heat load conditions only exist during a load is 38.5 calculations be pool cooling strategy steam strategy, if uv\\',uv'l.l, 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 40 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling Details:

Braidwood 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 Rev. 0. These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOPs.

The Spent Fuel Pool level instrumentation will be installed in accordance with C Order Number EA 12-051 and NEI 12-02 Rev. 0.

Provide a brief description of Procedures

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

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

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

Cold Leg - TI-413IB, TI-42313, TI-43313 and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control RCS Heat Removal RCS pressure boundary and pressure control Safety Function RCS pressure boundary and pressure control Containment Pressure: PI-PC005 SFP Level: (component #

SFP Inventory TB D)

Containment Integrity Braidwood'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.

Per NRC Order Number EA 12-051, "Order Modifying Licenses with regard to Reliable Spent Fuel Pool Instrumentation" and NEI 12-02, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."

1 addition to the parameters listed in NEI 12-06 Rev. 0 Section Page 41 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key SFP Parameter Maintain Spent Fuel Pool Cooling Details:

existing symptom based command and control strategies in the current EOPs.

The J.~A,:)~U..Ll""'Y in 12-02 Page 41 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan ntain Spent Fuel Pool Cooling 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: L1951, LI953, L1955, and LI 957 Reactor Vessel Level Indicating System (RVLIS): LI-RC020 W 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:

1.

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 Braidwood 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 42 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Maintain Spent Fuel Pool Cooling 3.2.1.

use as be,..r...,.,n-\\,.....,.,..'1,1"or!

1, Reactor Vessel Level Indicating System (RVLIS): LI-RC020 AFW Flow: FI-AF012A, FI-AF014A, FI-AF016A and FI-AF018A Battery Capacity / DC Voltage:

Neutron NI-NR006AIB,

Reference:

1.

Generic FLEX Support Guidelines U.. "'I"'nrll".... "" 1.... t-,"".. 1"....,...,a and Kelcornm,enclatlon Instruments) Rev. 0, Supplement 14, dated December 2012 PSC-0965.

Notes: Exelon Generation Company, LLC \\L..Ifl,VA'-fJ.L compliance with Order EA-12-049.

designs will be developed to the final plan and associated mitigating strategies. Once these have fully developed, Exelon will update the integrated plan for Braidwood during a include to designs as 28, 2013 Integrated Page 42 of68

Braidwood 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 pump suction will come from the UHS and/or RWST and will discharge 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 the Safety Function Support Section of the document.

Details:

Confirm that procedure/guidance exists or will be developed to support implementation Braidwood 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 Rev. 0.

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 primary and alternate 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 FIB south wall. The pipe will penetrate the south 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 SFP by the north wall with standard National Standard Tread (NST) connection, A pipe will be routed from the standpipe to the Fuel Handling Building (FHB) north wall on the ground elevation. The pipe will penetrate the north wall of the FHB and have a standard FLEX connection installed that will allow connection of regional response center equipment. The NST Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Page 43 of 68 Braidwood 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 The suction come from the UHS and/or discharge the Evaluation of spent pool area for steam and condensation has not yet been performed.

LV,,".'-'."" of this evaluation the vent path strategy, if needed, be provided a

power required to <'Hr'...... '"'...- the Strategy is described the Safety UU.,"",L-.llw'.l.l Support Section document.

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

Confirnt that procedure/guidance exists or will be developed to support intplementation Braidwood Station will use the industry developed guidance Owners Groups, team to procedures or guidelines to address These procedures and/or Fo...,'.... ""..... "-H..;'"

symptom command and List modifications Spent fuel pool cooling be achieved alternate l"UU.r>i"1r,,,,, connections.

Page 43 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan connection will have a staged fire hose with a spray nozzle, Key SFP Parameter Essential Instrumentation Safety Function SO Pressure:

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

RCS pressure boundary and

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

RCS Heat Removal Cold Leg - TI-413B, TI-423B,

}

I TI-433B and TI-443B RCS Pressure: WR - PI-403 RCS pressure boundary and pressure control Containment Pressure: PI-Containment Integrity PC005 SFP Level: (component #

SFP Inventory TBD)

Braidwood'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.

Per NRC Order Number EA 12-051, "Order Modifying Licenses with regard to Reliable Spent Fuel Pool Instrumentation" and NEI 12-02, "To Modify Licenses with Regard to Reliable Spent Fuel Pool:

Instrumentation."

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: L1951, L1953, L1955, 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-006A/B, NI-36B IR Page 44 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Key SFP Parameter connection SG Level:

NR -

17, LI-S37, WR - LI-S02 a staged LI-S27, and LI-S49 LI-S03 Temperature:

Cold Leg-TI-433B and TI-443B Res Pressure:

- PI-403 Per NRC Order Number regard to Spent "To Modify Licenses with Page 44 of68 a

RCS pressure boundary and pressure...,.... "'....... 'VA RCS Heat Removal RCS pressure boundary and Tu'pccn'rp control 11"';:;>1"1C';;:>C' with 12-02, Pool:

Braidwood Station, Units I and 2 Mitigation Strategies Integrated Plan

Reference:

1.

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 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 Braidwood Station.

Structures to provide protection of FLEX equipment will be constructed to meet the requirements of 112-06 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 Braidwood 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 Braidwood 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 Braidwood Seismic Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold Page 45 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan

Reference:

1.

PA-Storage I Protection of Equipment:

Describe storage I protection plan or schedule to determine storage requirements Seismic Flooding Severe Storms with High Winds Snow, Ice, and Extreme Cold Structures to provide protection of constructed to meet requirements of 0, Section

11. Schedule to construct permanent building is in,

satisfy the site compliance date. Temporary JlV....,".. ~'vu.1J will be used building construction completion.

be developed to address storage Structures to provide protection constructed to meet 0, Section

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

be developed to storage

""AAJV.U""', and hazards applicable to Braidwood Station.

Structures to provide be constructed to meet the 0, Section

11. Schedule to construct permanent building is contained

""''.......,AU.U.... 2, Temporary locations will Page 45 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Station.

High Temperatures 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 Braidwood Station.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

The required FLEX equipment needed for Spent Fuel Pool Cooling will be installed in a robust FLEX building ready for hookup and use.

Hoses and electrical connectors will be completed as needed to support the site coping strategy and will be stored within the FLEX building.

Modifications Identify modifications The storage structure conceptual design has not been completed.

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

Protection of connections 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 Braidwood 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 46 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan High Temperatures VL'VIIJ"".... to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

.... 'V... JL.V".'--..,..... as needed to support the site coping strategy and will be stored within FLEX building.

compliance The storage structure conceptual has not completed.

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

an "'........ u.J.u..J...,.....

program created to protect the connections from blockage during outages and non-outage times.

has not finalized designs for Detailed designs on current conceptual designs will be developed to determine the associated mitigating C1\\-.L\\-.L\\-'-'j;~.L""'" Once have plan Braidwood

.... Jlv*........ "" any changes to the Page 46 of68

Braidwood 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 Braidwood includes backup portable pumps and generators. The portable pumps will be capable of providing the necessary flow and pressure as outlined in the 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 Confirm that procedure/guidance exists or will be developed to support implementation Braidwood 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 Rev. 0.

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.

Key SFP Parameter Essential Instrumentation SG Pressure:

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

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

Cold Leg - TI-413E, T1-423E, TI-433E 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 47 of 68 Braidwood 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 Phase 3 equipment for Braidwood includes backup portable pumps and generators. The portable pumps will capable of providing the necessary and pressure as outlined the Phase 2 response for Core Cooling &

Removal, RCS Inventory Control, and Spent Fuel Pool Cooling.

generators be capable of necessary 480 volt power as

..... """u'...... in Phase 2 response for Safety Functions Support.

Provide a brief description of Procedures

/ Strategies / Guidelines Identify modifications Key SFP Parameter a large oil ri'*-'f1".. ~r to Details:

Confirm, that procedure/guidance exists or will be developed to support implementation Braidwood Station industry developed guidance from the Task team to develop site specific nll1,rtaI1naC' to address 12-06 ressure boundar Page 47 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan pressure control Containment Pressure: PI-Containment Integrity PC005 S

Level: (component #

SFP Inventory TBD)

Braidwood'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.

Per NRC Order Number EA 12-051, "Order Modifying Licenses with regard to Reliable Spent Fuel Pool Instrumentation" and NEI 12-02, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."

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: L1951, L1953, L1955, 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:

1.

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

Protection of connections Identify how the connection is protected Equipment will be delivered I No modifications are required I Braidwood will utilize Phase 2 Page 48 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan parameters are to support key actions......... VL............LV.....

the plant procedures/guidance or to indicate imminent or actual core damage (NEI 12-06 Rev. 0 Section 3.2.1.10) any difference will be communicated within a 6-month update following identification.

Per NRC Order Number EA 12-051, "Order Modifying Licenses regard to Reliable Spent Fuel Pool Instrumentation" and 12-02, "To with Regard to Reliable Spent Fuel Pool Instrumentation. "

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

Core Exit Thermocouple (CET) Temperature:

RCS Accumulator Level: LI951, LI953, LI955, and Reactor System Flow: FI-AF012A, FI-AF014A, FI-AF016A Battery Capacity / DC Voltage: EI-DC002 NI-NR006A1B,

Reference:

1.

Generic FLEX Support Guidelines (Controlling Procedure Instruments) 0, Supplement PSC-0965.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches) 8A Strategy Modifications Protection of connections Identify Strategy including how Identify modifications the equiplnent will be deployed to the point of use.

are Page 48 of68 Identify how the connection is protected 2

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan connection points.

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

other than those outlined in Phase 2 of this plan.

Notes: Exelon Generation Company, L LC (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 Braidwood 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 49 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan other than those In connection points.

2 of this plan.

Notes: Exelon Generation Company, (Exelon) has not finalized the engineering designs 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 developed, will update integrated plan for Braidwood a scheduled This update include any changes to designs as sublnitted February 28, 2013 Int""0>1'jJ,tt:>1"i Page 49 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support Determine Baseline coping capability with installed copings 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 andlor 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 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 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 BwCA 0.0. Loss of all AC Power.

Reference:

1.

EC Evaluation 391834, Battery Coping Time For The 125v DC ESF Battery Banks, dated February 12, 2013.

Details:

Provide a brief description of Procedures / Strategies /

Guidelines Identify modifications Key Parameters Confirm that procedure/guidance exists or will be developed to support implementation.

Braidwood 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 Rev.0.

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.

No identified key parameters.

Braidwood'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.

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 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 50 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support Determine Baseline coping capability with installed copingS modifications not including FLEX modifications.

PWR Installed Equipment Phase 1 Provide a general description of the coping strategies using installed equipm,ent 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 to control of vital Battery chargers are de-energized during a to loss of DC and associated functions.

The present 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 40 with deep shedding (Ref. 1) consistent procedure BwCA 0.0. Loss of

1.

Provide a brief description of Procedures I Strategies I Guidelines Identify modifications Key Parameters 125v Details:

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

Braidwood Station use industry developed guidance from Owners Groups, and Task team to develop procedures or guidelines to address the criteria 12-06 Rev.O.

procedures andlor support the existing

.UAI->JJ:.U based and control strategies the current 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 50 of68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support these have been fully developed, Exelon will update the integrated plan for Braidwood 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 51 of 68 Braidwood Station, Units 1 and 2 Miti ation Strate ies Inte rated Plan Safety Functions Support developed, Exelon will update integrated h_n"'Anrn update. This include any changes to 3

Page 51 of 68 Braidwood during a designs as

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PR 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 portable diesel generator will provide power to one (1) division of the 480V ESF busses. Repowering at this level will permit the recovery of one division of station battery chargers, DDAFP battery chargers, 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 Operational command and control 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. Closure of these items will be documented in a future 6-month update.

Additionally, a backup water source for core cooling, inventory, and SFP makeup will be established with a portable FLEX diesel driven pump and temporary hoses from the UHS. 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.

Braidwood 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 Rev. 0.

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 the FLEX generator for repowering one division of 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 Fuel Handling Building (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 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.

Provide a brief description of Procedures / Strategies /

Guidelines Identify modifications Page 52 of 68 Braidwood 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.

busses.

at one

chargers, DDAFP battery chargers, MCC's powering critical equipment such as Diesel fuel oil transfer pumps, and other ESF equipment beneficial to mitigate the event.

Generation Company, (Exelon) intends on maintaining command control the Main Control Room. Habitability conditions will be evaluated and a strategy will be developed to maintain Main Control Room habitability. The strategy associated analyses be provided a future 6-month update. Critical ventilation assets may required to DDAF pumps, station battery rooms, miscellaneous electric

rooms,

......... "......... u.J'-, personnel habitability and/or component survivability. Specific analyses of these rooms are and will be addressed as part engineering design Closure of these be a

Additionally, a backup water source for core cooling, inventory, and with a portable FLEX diesel driven and temporary hoses installed at the to support strategy.

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 with a description of the procedure / strategy /

guideline.

Braidwood Station use industry developed n-ll1r1<::l1nI"'P Owners Groups, and NEI Task team to develop site specific procedures or guidelines to address the criteria 12-06 Rev. O.

procedures and/or guidelines will support the symptom control strategies the current Page 52 of 68

Braid ood Station, Units 1 and 2 Mitigation Strategies Integrated Plan A dry hydrant will be installed in the UHS with a Flex Connection on it as a source of makeup water for use with a portable pump.

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

No identified key parameters.

Braidwood'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 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 Braidwood 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 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 Braidwood 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 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 Braidwood 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 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, 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 Snow, Ice, and Extreme Cold Page 53 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan dry be installed UHS with a Connection on it as a source of water for use a portable Key Parameters List instrumentation credited or recovered for this coping evaluation.

No 1rt"'.-nh,-t-1..-.'rt fo:"UJ.UCUJ..l...,..., or to or core UU-JlU."fo:"V.

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

Storage / Protection of Equipment :

Describe storage / protection plan or schedule to determine storage requirements Seismic Structures to provide protection of FLEX be 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

,.,....,... "C't~'lHyh:"rl to meet of 12-06 Rev. 0, Section 11.

p""LJU$.... '.......",.... '-"....... JL.......... [O-, is contained satisfy site date. Temporary locations building construction completion. Procedures and be developed to address storage structure haul path and FLEX equipment the external hazards applicable to Braidwood Station.

U-vl.LU'-J," to provide equipment will be constructed to meet the l'prnllt'PfY1Pntc 12-06 Rev. 0, Section 11.

T\\PT"T"n'J,npl1T building is contained 2,

satisfy site date. Temporary locations be building construction completion. Procedures and programs will be developed to address storage structure path requirements relative to external hazards to Braidwood Station.

1.

Page 53 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Braidwood Station.

High Temperatures 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 Braidwood Station.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

The required FLEX support equipment needed for AC Phase 2 implementation will be installed in a robust FLEX building ready for hookup and use. Hoses and electrical connectors will be completed as needed to support the site coping strategy and will be stored within the FLEX building.

The UHS FLEX support equipment will be staged in a robust building and transported to a pre-identified staging location with a debris removal tool like the F750 with snow plow or equivalent, Hoses will be completed as need to support the site coping strategy.

Modifications Identify modifications The storage structure conceptual design has not been completed.

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

Protection of connections 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 Braidwood 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 68 High Temperatures the external hazards applicable to Braidwood Station.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

Modifications Identify modifications The required support storage structure pr'l111nl"nPIt-needed 2

conceptual design has not

""1'\\'\\on1"n1".r'..... will installed in a robust building ready for hookup and use.

and electrical connectors will be

...,.~AALiJ'jl'V... '"'..... as to support the site coping strategy and will be building.

The support equipment be staged in a robust building and transported to a pre.. identified staging location a debris removal tool F750 with snow plow or Hoses be cOlnpleted as need to L~I.AUV,"JL coping strategy.

Notes:

documented a future 6-month update.

Page 54 of68 Protection of connections Identify how the connection is protected times.

Braidwood 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 Braidwood includes backup portable pumps and generators. The portable 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 Parameters Braidwood 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 Rev. 0.

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.

Strategy Braidwood'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.

Deployment Conceptual Design (Attachment 3 contains Conceptual Sketches)

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

Equipment and consumables Identify modifications No modifications are required Identify how the connection is protected Braidwood will utilize Phase 2 Page 55 of 68 Braidwood 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.

...... IJ,u~.. "',u. for Braidwood includes backup portable pumps and generators.

portable pumps be capable of providing necessary flow and pressure as outlined in Phase 2 response for Core Cooling & Heat Removal, RCS Inventory Control and Pool Cooling.

portable generators be capable of providing necessary 480 volt power requirements as

£'U""'YU.'" In 2 response for Safety Functions Support.

addition, a C'l1r\\T"\\r\\... r v.u.. u,uvu....,J,u. would be a portable refuel vehicle with a large diesel support

""',L,&J.. u.~J'M the FLEX diesel bladder to Details:

Provide a brief description of Procedures

/ Strategies I Guidelines Braidwood Station will use the developed guidance from the Identify modifications Key Parameters Strategy Owners Groups, EPRI and Task team to develop site specific procedures or guidelines to address the criteria 12-06 Rev. O.

These and/or guidelines support

.l,Lll-"AJJlAA based command and strategies There are no 3 modifications required.

No identified key parameters.

Braidwood's evaluation the strategy identify parameters are needed order to support key actions identified procedures/guidance or to imminent or actual core damage. Reference 12-06 0 Section 3.2.1.

any a

following identification.

Deployment Conceptual Design (Attachment 3 contains Conce tual Sketches)

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

Page 55 of68 2

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Safety Functions Support PWR Portable Equipment Phase 3 connection points.

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

other than those outlined in Phase 2 of this plan.

Notes: Exelon Generation Company, LLC (Exelon) has not finalized the engineering designs for compliance with NRC Order EA-12049. 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 Braidwood 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 56 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan transported to the site and hooked up by both and plant nt:>y*cnl"lnf>.

playbook.

be operated per procedures.

Notes: LJn.'-,.IC\\JU.

Safety Functions Support PWR Portable Equipment Phase 3 Page 56 of68

Braidwood Station, Units I and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Use and (potential /,flexibility) diverse uses Core Containment SFP Instrumentation X

1 500kW Per conceptual design Three (3) 480 VAC Generator List portable equipment Pekfiwmance O-iteiwi x

Three (3)

High Head Flex Pump Three (3)

Medium Head FLEX Pump Two (2) Self Prime 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 SG per WCAP-17601 -P 1100 gpm at 500 ft head General Usage

L3ain(cliance uintenance / 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.

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 Page 57 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 uses n_~~_

C f;lJU' Core I Containment 1

at ft General Page 57 of 68 I\\JlOUI'\\t'A1'1H!lnl"'A I PM

..,"",....t-.,......... 6

,.,,,...,....11-.......... 11.

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase Use and (potential /j lc.cihilit °) diverse uses P ij rtnancc Criteria

^%^1ctt-nte:nance Core 11ontainment SFP Instrumentation Accessibility x

x X

x x

x x

,ist portable equipment Six (6)

Portable 120/240 12VDC One F-750 Ford Truck Three (3)

Diesel Trash Pumps 5500 watt General Usage Debris Removal and Refuel delivery capability General Usage General Usage Maintenance / PM requirements 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.

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 58 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR. Portable Equipment Phase 2 Core Containment IPM Page 58 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Use and (potential /exi hi l i r y) diverse uses A-lainten.ance Accessibility List portable I Core I Containment Inslromentation equipment PWR Portable Equipment Phase 2 Three (3)

Satellite Phones General Usage x

x x

x x

Six (6) 42" Box Fans General Usage x

x X

Ten (10) 20" portable vent fans General Usage x

x x

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.

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 59 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 2 Core Containment General General General Page 59 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 3 Use and (potential /flexibility) clii'erse uses Per~ rrrn once Criteria Note:

The RRC equipment has not been procured at the time of this submittal. The equipment listed is a generic list provided by the RRC and even though Braidwood 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.

SFP List portable equipment Containment Instrumentation Accessibility Core x

2 MVO output at 4160 Vac, three phase Medium Voltage Diesel Generator Generator must be common commercially available.

Must run on diesel fuel.

x x

Low Voltage Diesel Generator Positive x

displacement High Pressure Pumps (PWR only) 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.

Must run on diesel fuel x

x x

x Low Pressure X

X X

300 psi shutoff head, 2500 Pump gpm max flow Page 60 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 3 uses List portable Core Containment SFP Instrumentation Accessibili ty equipment 2

Page 60 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable quipment Phase 3 Use and potential /f exibility) di verve uses Pe^fiOT'7Yi(ZITCL' C1"TT`C'I"!.C!

Af1te,1 Note:

The RRC equipment has not been procured at the time of this submittal. The equipment listed is a generic list provided by the RRC and even though Braidwood may not require this equipment in its plan it will be available and could be utilized in the Phase 3 time period. Once the SAFER committee determines the equipment specifications for bid, updates will be made as necessary to this table. The Phase 3 portable equipment table will be updated once all of the equipment has been procured and placed in inventory.

List portable equipment Containment I SFP Instrumentation Accessibility Core Low Pressure Pump 500 psi shutoff head, 500 gpm rnax flow x

Low Pressure Pump 110 psi shutoff head, 400 gpm max flow submersible x

Low Pressure Pump 150 psi shutoff head, 5000 gpm max flow x

x Air Compressor 120 psi minimum pressure, 2000 scfm X

Page 61 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan PWR Portable Equipment Phase 3 uses Page 61 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan esponse Equipment/Commodities Radiation Protection Equipment Survey instruments Dosimetry Off-site monitoring/sampling (EP input for Personnel FLEX list)

Commodities Food Potable water (EP input for Personnel FLEX list)

Fuel Requirements Heavy Equipment Transportation equipment Debris clearing equipment The RRC 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.

The 12.RC 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 To be developed during site specific playbook development Redundant Phase 2 equipment to be located at RRC Page 62 of 68 Item Radiation Protection Equipment Survey instruments Dosimetry Off-site monitoring/sampling (EP input for Personnel FLEX list)

Commodities Food Potable water (EP input for Personnel FLEX list)

Fuel Requirements Heavy Equipment Transportation equipment Debris clearing equipment Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Phase 3 Response Equipment/Commodities Notes be can be 2

to at Page 62 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan A Sequence of Events Timeline Action item Time Constraint YIN6 Remarks Applicability 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, procedures are developed, and the results will be provided in a future 6-month update.

0 2

1 1 minutes 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 Emergency Operating Procedures (EOPs) and Station Black Out (SBO) Procedures are entered.

NA I

Plant @ 100%

power NA BwCA 0.0, Loss of All AC Power, 5-15 minutes Verify DDAF Pp is operating properly.

Y - 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

Reference:

Braidwood Station MAAP analysis Documentation NO. BW-MISC-009 Rev 1 dated November 1, 2011 4

1 10-30 minutes Attempt starting Emergency D/Gs BwCA 0.0, Loss of All. AC Power.

NA 6

30 minutes ELAP condition recognized and ELAP Procedures NA Operator are entered.

judgment Y-3.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 7

30 minutes to 3.6 Connect FLEX 480V AC generators to ESF bus hours

_32X and verify they are supplying power to Div I -

125V DC battery chargers 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 63 of 68

Reference:

EC Evaluation 391834, Battery Action item Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Elapsed Time Attachment lA Sequence of Events Timeline Action Time Constraint YIN 6

Remarks I Applicability The times to complete actions the Events Timeline are based on operating judgment, the conceptual designs, and current analyses.

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

1 2

3 4

6 7

o 5-15 minutes

.1UJ,,1,",,,,'' to Event Starts,

occurs, 1 and Unit 2 reactors automatically trip and rods are inserted.

Loss off-site power affecting both occurs Procedures Station (SBO) Procedures are entered.

Verify is operating properly.

L......,,l,U~J\\- starting lI-<fl1arn'onr',:r DIGs are entereo.

1 NA Y -1 hour NA 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 63 of 68

@100%

power

Reference:

Braidwood Station analysis Documentation NO. BW-MISC-009 Rev 1 dated November 1, 2011

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> 3 hours 3-6 hours 6-12 hours 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Start depressurization of S/Gs to 300 psia at 75°F/hr Y 1.5 cooldown with SG PORV local/manual operation. SG hours feed is controlled with LocallManual operation of AFW flow control valves.

SI Accumulator borated water begins to inject into the NA RCS.

Maintain RCS 300 psial-420"F with SG PORV NA operation. Maintain SG level.

Connect high pressure FLEX Pumps and ensure they NA are available to supplying borated makeup to the RCS.

Connect FLEX Pump and ensure it is available to NA supplying makeup to the SFP.

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

Set up FLEX pump suction from UHS.

NA Regional Response Center (RRC) resources begin NA arriving on site.

Continue to maintain critical functions of Core NA Cooling (via DDAF), RSC Inventory Control (via FLEX pump injection to RCS) and SFP Cooling (via FLEX pump injection to SFP). Utilize initial RRC equipment and resources as a spare capacity.

Page 64 of 68 9

10 11 12 Action Time Constraint Y/N6 Remarks /

Applicability Coping Time For The 125V DC ESF Battery Banks, dated February 12, 2013 WCAP-17601-P Rev 0 and Byron/Braidwood MAAP analysis Documentation NO BB-MISC-020 Rev 0 dated February 1, 2013 Operator Judgment WCAP-Rev 0 End of analytical simulation Action item 8

9 10 11 12 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Elapsed Time 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 2.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> 3 hours 3-6 hours 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action Time Constraint YIN 6 Start depressurization of S/Gs to 300 psia at 75°F/hr Y 1.5 cooldown with SG PORV local/manual operation. SG hours feed is controlled with LocallManual operation of AFW flow control valves.

SI Accumulator borated water begins to inject RCS.

Maintain RCS 300 psia!~420°F operation. Maintain SG level.

Connect pressure FLEX SGPORV are available to supplying borated -">....... n.'""".""

Page 64 of68 NA Remarks I Applicability Operator Judgment WCAP-17601 Rev 0

Braidwood Station, Units I and 2 Mitigation Strategies Integrated Plan B NSSS Significant Reference Analysis Deviation Table Item I Parameter of interest WCAP value WCAP (WCAP-17601-P August 2012 Revision 0) page Plant applied value 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 /> 4-14 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Cap and discussion From the MAAP Analysis BB-MISC-020 the cooldown begins early due to the secondary inventory available in the original Steam Generators on U-2 Page 65 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Attachment IB NSSS Significant Reference Analysis Deviation Table Item Parameter of interest WCAPvalue WCAP (WCAp.. 17601.. PAugust 2012 Revision 0)

Plant applied value Gap and discussion 1

2 Page 65 of 68

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan :

Milestone Schedule Site: Braidwood Original Target Completion Date Activity Submit 60 Day Status Report Submit Overall Integrated Implementation Plan Contract with RRC Recurring action, Submit 6 month updates Aug and Feb Unit 1 Unit 2 Modification Development Status

{ Include date changes in this column}

Complete Complete Feb 2014 Sept 2014 Feb 2014 p

Apr 2015 Dec 2014 Apr 2015 Oct 2015 Note(s):

Regional Response Center Operational Unit 1 Implementation date Unit 2 Implementation date 1.

Exelon will update the status of ongoing and future milestones in the Integrated Plan for BRW 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 66 of 68 Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Site: Braidwood Recurring action, Aug and Feb 1

2 1

Apr 2015 Apr 2015 Apr 2015 Apr 2015 Apr 2015 Jan 2015 Apr 2015 Apr 2015 A r 2015 2014 A r 2015 Oct 2015 Note(s):

1.

Sept 2014 Unit 2 Oct 2015 Oct 2015 Oct 2015 :

Milestone Schedule Submit Overall Integrated Implementation Plan Contract RRC Submit 6 updates Modification Development 1 modifications 2 modifications Phase 3 modifications NI A Modification lementation Phase 1 modifications 2 modifications Phase 3 modifications cedure Develo ment Strategy procedures Page 66 of68 N/A N/A N/A milestones update February 28, 2013

Braidwood Station, Units 1 and 2 Mitigation Strategies Integrated Plan Conceptual Sketches (Conceptual sketches, as necessary to indicate equipment which is installed or equipment hookups necessary for the strategies.)

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