The industry response to the Nuclear Regulatory Commission (NRC) Order EA-12-049 is based on a set of Diverse and Flexible Coping Strategies (commonly referred to as FLEX) for beyond design basis external events as described in NEI 12-06. The Pressurized Water Reactors Owners Group (PWROG) developed generic guidance for response to these Beyond Design Basis External Events (BDBEE), called FLEX Support Guidelines (FSGs). These guidelines are referenced from the plant Emergency Operating Procedures (EOPs) when it is determined that an event exhibits certain beyond design basis characteristics such as an Extended Loss of all AC Power (ELAP). These generic FLEX Support Guidelines provide a uniform basis for all PWRs to implement the FLEX guidance in NEI 12-06 that was endorsed by the NRC to maintain core, containment and spent fuel cooling.

The PWROG generic FSGs include guidance in FSG-7, “Loss of Vital Instrumentation or Control Power” for obtaining information for key plant parameters in an ELAP event. The key parameters were selected based on industry guidance and plant specific implementation. This set of key parameters will allow the licensed operators to have vital instrumentation to safely shutdown the core and maintain the core in a shutdown condition, including core, containment and spent fuel pool cooling. These parameters are used in the EOPs as well as the FSGs that are designed to mitigate a beyond design basis event. The requirements of NEI 12-06, as implemented through the FSGs, enhance both availability and reliability of instrumentation by requiring diverse methods of providing DC power for instrumentation and control as well as protection of instrumentation from the beyond design basis event.

The subsequent implementation of this guidance at the Byron Station has proven to also be beneficial for diagnosis of severe accident conditions (where core cooling could not be maintained). The same parameter values that are needed to verify core, containment and spent fuel cooling prior to core damage are also needed to diagnose severe accident conditions. Guidance provided within FSG-7, as implemented at the Byron Station, contains several layers of diverse methods to obtain parametric values for key variables that can be especially useful when the environmental qualification is exceeded for the primary instrumentation that provides this information. The methods range from the use of self-powered portable monitoring equipment to the use of local mechanical instrumentation. The FSG-7 guidance is referenced from the Byron Severe Accident Management Guidance (SAMG) to either obtain parameter information during a severe accident or to validate the information that is available from the primary instrumentation.

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