JAFP-17-0085, High Frequency Confirmation Report for March 12, 2012, Information Request Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1, Seismic

High Frequency Confirmation Report for March 12, 2012, Information Request Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1, Seismic

ML17242A263
Person / Time
Site:	FitzPatrick
Issue date:	08/30/2017
From:	Joseph Pacher Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-17-0085
Download: ML17242A263 (58)

Text

Exelon Generation Company, LLC E xeton G enera t I on JmSAFItZPtflCkNPP

.H:E-Tel 31 5-349-6024 Fax 31 5-349-6480 Joseph E. Pacher Site Vice President JAF 10 CFR 50.54(f)

JAFP-1 7-0085 August 30, 2017 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 James A FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-059 NRC Docket No. 50-333

Subject:

High Frequency Confirmation Report for March 12, 2012, Information Request Pursuantto 10 CFR 50.54(f) Regarding Recommendation 2.1, Seismic

References:

I . NRC letter, Request for Information Pursuant to Title 1 0 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, ML12053A340, dated March 12, 2012

2. NEI letter to NRC, Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations, ML13101A345, dated April 9, 2013

3. Entergy letter, Entergys Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 ofthe Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, JAFP-13-0056, dated April 29, 2013

4. Entergy letter, Follow-up to Request for Information Pursuantto 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2. 1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, JAFP-14-0128, dated December 5, 2014

5. NRC letter, Final Determination of Licensee Seismic Probabilistic Risk Assessments Under the Request for Information Pursuant to Title 1 0 of the Code of Federal Regulations 50.54(f) Regarding Recommendations

2. 1 ccSeismicfl of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, ML15194A015, dated October 27, 2015

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a Request for Information per 10 CFR 50.54(f) [Reference 1] in regard to Recommendation 2.1: Seismic of the Near-Term Task Force review of insights from the Fukushima Dai-ichi Accident. Reference 2 is the Nuclear Energy Institute (NEI) Proposed Path Forward for Recommendation 2.1: Seismic, which James A. FitzPatrick Nuclear Power Plant (JAF) committed to in Reference 3.

JAFP-1 7-0085 Page2 of 2 on October 27, 2015 [Reference 5], the NRC provided a determination for acceptable methods that JAF may respond to the remaining 50.54(f) information requests. This letter is being submitted pursuant to option 2 of Table I b in Reference 5, the completion of the 50.54(f)

Enclosure Recommendation 2.1: Seismic requested information item (4) in Reference 1, and the portion of the Proposed Path Forward risk evaluations, to perform a High Frequency Confirmation evaluation in Reference 2.

The Enclosure to this letter contains the High Frequency Confirmation Report.

In addition, based on the decision to follow option 2 of Table I b in Reference 5, JAF does not need to perform a Relay Chatter Review. The Attachment to this letter summarizes the cancellation of the regulatory commitment made in Reference 4 to perform a Relay Chatter Review.

Should you have any questions regarding this submittal, please contact Mr. William C. Drews, Regulatory Assurance Manager at (31 5) 349-6562.

30th I declare under penalty of perjury that the foregoing is true and correct. Executed on day of August, 2017.

PA 4 Jo ph E. Pacher Site Vice President Exelon Generation Company, LLC J EPIWCD/mh

Attachment:

Regulatory Commitments

Enclosure:

High Frequency Confirmation Report cc: Director, Office of Nuclear Reactor Regulation NRC Region I Administrator NRC Resident Inspector NRC Project Manager NYSPSC President NYSERDA

JAFP-1 7-0085 Attachment Regulatory Commitments (1 Page)

Attachment JAFP-1 7-0085 Regulatory Commitments This table identifies actions discussed in this letter that Exelon commits to perform. Any other actions discussed in this submittal are described for the NRCs information and are not commitments.

Number Text SCHEDULED COMPLETION DATE Original Revised Source: JAFP-14-0128 dated December 5, 2014 I 8482 Perform a Relay Chatter Review to support On the schedule Canceled IPEEE focused scope margin assessment specified in the per SPID in accordance with NEI letter, April 9, 2013, NEI Relay Chatter Reviews for Seismic Hazard letter Screening, dated October 3, 2013 Page 1 of 1

JAFP-1 7-0085 Enclosure High Frequency Confirmation Report (53 Pages)

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Executive Summary The purpose of this report is to provide information as requested by the NRC in its March 12, 2012 50.54(f) letter issued to all power reactor licensees and holders of construction permits in active or deferred status [1]. In particular, this report provides requested information to address the High Frequency Confirmation requirements of Item (4), Enclosure 1, Recommendation 2.1: Seismic, of the March 12, 2012 letter [1].

Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the Nuclear Regulatory Commission (NRC) established a Near Term Task Force (NTTF) to conduct a systematic review of NRC processes and regulations and to determine if the agency should make additional improvements to its regulatory system. The NTFF developed a set of recommendations intended to clarify and strengthen the regulatory framework for protection against natural phenomena. Subsequently, the NRC issued a 50.54(f) letter on March 12, 2012 [1], requesting information to assure that these recommendations are addressed by all U.S. nuclear power plants. The 50.54(f) letter requests that licensees and holders of construction permits under 10 CFR Part 50 reevaluate the seismic hazards at their sites against present-day NRC requirements and guidance. Included in the 50.54(f) letter was a request that licensees perform a confirmation, if necessary, that SSCs, which may be affected by high-frequency ground motion, will maintain their functions important to safety.

EPRI 1025287, Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID) for the resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic [2] provided screening, prioritization, and implementation details to the U.S. nuclear utility industry for responding to the NRC 50.54(f) letter. This report was developed with NRC participation and is endorsed by the NRC.

The SPID included guidance for determining which plants should perform a High Frequency Confirmation and identified the types of components that should be evaluated in the evaluation.

Subsequent guidance for performing a High Frequency Confirmation was provided in EPRI 3002004396, High Frequency Program, Application Guidance for Functional Confirmation and Fragility Evaluation,

[3] and was endorsed by the NRC in a letter dated September 17, 2015 [41. Final screening identifying plants needing to perform a High Frequency Confirmation was provided by NRC in a letter dated October 27, 2015 [5].

This report describes the High Frequency Confirmation evaluation undertaken for James A. FitzPatrick (JAF) using the methodologies in EPRI 3002004396 [3], High Frequency Program, Application Guidance for Functional Confirmation and Fragility Evaluation, as endorsed by the NRC in a letter dated September 17, 2015 [4]. The objective ofthis report is to provide summary information describing the High Frequency Confirmation evaluations and results. The level of detail provided in the report is intended to enable NRC to understand the inputs used, the evaluations performed, and the decisions made as a result ofthe evaluations.

EPRI 3002004396 [3] is used for the JAF engineering evaluations described in this report. In accordance with Reference [3], the following topics are addressed in the subsequent sections of this report:

. Selection of components and a list of specific components for high-frequency confirmation

. JAF SSE and GMRS Information Page 1 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation

. Estimation of seismic demand for subject components

. Estimation of seismic capacity for subject components

. Summary of subject components high-frequency evaluations

. Summary of Results Page 2 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation I Introduction 1.1 PURPOSE The purpose of this report is to provide information as requested by the NRC in its March 12, 2012 50.54(f) letter issued to all power reactor licensees and holders of construction permits in active or deferred status [1]. In particular, this report provides requested information to address the High Frequency Confirmation requirements of Item (4), Enclosure 1, Recommendation 2.1:

Seismic, ofthe March 12, 2012 letter [1].

1.2 BACKGROUND

Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the Nuclear Regulatory Commission (NRC) established a Near Term Task Force (NTTF) to conduct a systematic review of NRC processes and regulations and to determine ifthe agency should make additional improvements to its regulatory system. The NTTF developed a set of recommendations intended to clarify and strengthen the regulatory framework for protection against natural phenomena. Subsequently, the NRC issued a 50.54(f) letter on March 12, 2012 [1], requesting information to assure that these recommendations are addressed by all U.S. nuclear power plants. The 50.54(f) letter requests that licensees and holders of construction permits under 10 CFR Part 50 reevaluate the seismic hazards at their sites against present-day NRC requirements and guidance. Included in the 50.54(f) letter was a request that licensees perform a confirmation, if necessary, that SSCs, which may be affected by high-frequency ground motion, will maintain their functions important to safety.

EPRI 1025287, Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID) for the resolution of Fukushima Near-Term Task Force Recommendation 2.1:

Seismic [21 provided screening, prioritization, and implementation details to the U.S. nuclear utility industry for responding to the NRC 50.54(f) letter. This report was developed with NRC participation and is endorsed by the NRC. The SPID included guidance for determining which plants should perform a High Frequency Confirmation and identified the types of components that should be evaluated in the evaluation.

Subsequent guidance for performing a High Frequency Confirmation was provided in EPRI 3002004396, High Frequency Program, Application Guidance for Functional Confirmation and Fragility Evaluation, [3] and was endorsed by the NRC in a letter dated September 17, 2015 [4].

Final screening identifying plants needing to perform a High Frequency Confirmation was provided by NRC in a letter dated October 27, 2015 [5].

On March 31, 2014, James A. FitzPatrick Nuclear Power Plant (JAF) submitted a reevaluated seismic hazard to the NRC as a part ofthe Seismic Hazard and Screening Report [6]. By letter dated October 27, 2015 [5], the NRC transmitted the results of the screening and prioritization review of the seismic hazards reevaluation.

This report describes the High Frequency Confirmation evaluation undertaken for JAF using the methodologies in EPRI 3002004396 [3], High Frequency Program, Application Guidance for Page 3 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Functional Confirmation and Fragility Evaluation, as endorsed by the NRC in a letter dated September 17, 2015 [4].

The objective of this report is to provide summary information describing the High Frequency Confirmation evaluations and results. The level of detail provided in the report is intended to enable NRC to understand the inputs used, the evaluations performed, and the decisions made as a result ofthe evaluations.

1.3 APPROACH EPRI 3002004396 [31 is used for the JAF engineering evaluations described in this report. Section 4.1 of Reference [3] provided general steps to follow for the high frequency confirmation component evaluation. Accordingly, the following topics are addressed in the subsequent sections ofthis report:

. Selection of components and a list of specific components for high-frequency confirmation

. JAF SSE and GMRS Information

. Estimation of seismic demand for subject components

. Estimation of seismic capacity for subject components

. Summary of subject components high-frequency evaluations

. Summary of Results I .4 PLANT SCREENING JAF submitted reevaluated seismic hazard information including GMRS and seismic hazard information to the NRC on March 31, 2014 [6]. In a letter dated February 18, 2016, the NRC staff concluded that the submitted GMRS adequately characterizes the reevaluated seismic hazard for the JAF site [7].

The NRC final screening determination letter [5] concluded that the JAF GMRS to SSE comparison resulted in a need to perform a High Frequency Confirmation in accordance with the screening criteria in the SPID [2].

Page 4 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation 2 Selection of Components for High-Frequency Screening The fundamental objective of the high frequency confirmation review is to determine whether the occurrence of a seismic event could cause credited equipment to fail to perform as necessary. An optimized evaluation process is applied that focuses on achieving a safe and stable plant state following a seismic event. As described in EPRI 3002004396 [31, this state is achieved by confirming that key plant safety functions critical to immediate plant safety are preserved (reactor trip, reactor vessel inventory and pressure control, and core cooling) and that the plant operators have the necessary power available to achieve and maintain this state immediately following the seismic event (AD/DC power support systems).

Within the applicable functions, the components that would need a high frequency confirmation are contact control devices subject to intermittent states in seal-in or lockout circuits. Accordingly, the objective of the review as stated in Section 4.2.1 of Reference [3] is to determine if seismic induced high frequency relay chatter would prevent the completion of the following key functions.

2.1 REACTOR TRIPISC RAM The reactor trip/SCRAM function is identified as a key function in Reference [3] to be considered in the High Frequency Confirmation. The same report also states that the design requirements preclude the application of seal-in or lockout circuits that prevent reactor trip/SCRAM functions and that No high-frequency review of the reactor trip/SCRAM systems is necessary.

2.2 REACTOR VESSEL INVENTORY CONTROL The reactor coolant system/reactor vessel inventory control systems were reviewed for contact control devices in seal-in and lockout (SILO) circuits that would create a Loss of Coolant Accident (LOCA). The focus ofthe review was contact control devices that could lead to a significant leak path. Check valves in series with active valves would prevent significant leaks due to misoperation of the active valve; therefore, SILO circuit reviews were not required for those active valves.

The process/criteria for assessing potential reactor coolant leak path valves is to review all P&IDs of systems interfacing with the reactor coolant pressure boundary. Success for the inventory control function was taken as the ability to isolate the connections to the reactor coolant pressure boundary with the pressure boundary isolation valve closest to the reactor vessel and a second isolation valve if applicable. To accomplish isolation, normally closed valves need to stay closed and normally open valves need to close or have the ability to close. This includes active isolation valves that are closed during normal operation or are required close upon an initiating event (Loss of Coolant Accident LOCA or Seismic). The control schemes of these valves (and their associated pilot valves, if applicable) were reviewed for SILO circuits that could open a normally closed valve or prevent closure of a normally open valve. If such a SILO circuit is found, the associated contact device is selected for high frequency confirmation.

Page 5 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTTE 2.1 Seismic High Frequency Confirmation As such, the closing circuit of a normally closed valve is not assessed since the valve is in the desired position. Likewise, the opening circuit of a normally open valve is not assessed since it is in its normal position unchanged by chatter.

Manual valves are not part of this assessment since contact chatter would not affect their positions.

Instrumentation lines are typically fitted with orifices and excess flow check valves that are designed to mitigate leakage, and which are immune to chatter. Therefore, instrumentation lines are not considered further.

Table B-2 contains a list of valves that were considered important for the inventory control function. Valves are marked if their control circuitry contains a SILO device. If the SILO device can produce an undesired valve position under chatter then the device is listed for high frequency confirmation (HFC). If the SILO device is not selected a justification is provided in Table 2-2 in Reference [17]. Based on Table B-2 and the analysis detailed below, there are two SILO devices selected for HFC based on the criteria established above.

High Pressure Coolant Injection (HPCI)

Injection Side 34FW5-288 Reactor Feedwater Inboard Isolation Check Valve The HPCI injection line is connected to the B feedwater line. Therefore, this check valve provides isolation to the HPCI injection line. The check valve has no operator and is not affected by contact chatter.

Steam Side 23M0V-15 Turbine Steam Supply Inboard Containment Isolation Valve 23M0V-16 Turbine Steam Supply Outboard Containment Isolation Valve 23M0V-60 Turbine Steam Supply Outboard Containment Isolation Bypass Valve HPCI is not required to be isolated upon a LOCA. The inboard isolation valve 23M0V-15 and the outboard 1-inch bypass valve 23M0V-60 are normally open to admit some steam to the steam supply piping in order to keep it warm in anticipation of an actuation of HPCI. The outboard isolation valve 23M0V-16 opens upon HPCI actuation. Both 23M0V-15 and 23M0V-16 have to be open during HPCI operation to supply steam to the HPCI turbine. However, HPCI is not being credited for core cooling in this analysis.

There are SILO devices in the control circuits of these valves that can result in valve closure.

Since Reactor Core Isolation Cooling (RCIC), not HPCI, is credited for core cooling, the SILO devices causing valve closure do not meet a selection criterion. There is no SILO device that could prevent the closure of these valves if closure is needed.

Reactor Core Isolation Cooling (RCIC)

Injection Side 34FWS-28A Reactor Feedwater Inboard Isolation Check Valve Page 6 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation The RCIC injection line is connected to the A feedwater line. Therefore, this check valve provides isolation to the RCIC injection line. The check valve has no operator and is not affected by contact chatter.

Steam Side 13MOV-15 RCIC Steam Supply Inboard Containment Isolation Valve 13MOV-16 RCIC Steam Supply Outboard Containment Isolation Valve RCIC is not required to be isolated upon a LOCA. These MOVs are normally open to admit steam to the steam supply piping in order to keep it warm in anticipation of an actuation of RCIC. Also, 13MOV-15 and 13MOV-16 have to be open during RCIC operation to supply steam to the RCIC turbine.

The closure circuit for 13MOV-15 contains SILO devices:

. Relay 13A-K33 can seal-in itself or cause seal-in of contactor 42/C

. Contactor 42/C can seal-in itself The closure circuit for 13MOV-16 contains SILO devices:

. Relay 13A-K15 can seal-in itself or cause seal-in of contactor 42/2C

. Contactor 42/2C can seal-in itself Chatter can result in valve closure. The impact on the core cooling function of inadvertent closure of these valves will be assessed in Section 2.4. From the perspective of inventory control, RCIC is not required to be isolated for a LOCA; however, there is no SILO device that could prevent the closure of these valves if closure is needed.

Core Spray (CS) 1450V-13A/B Reactor Isolation Testable Check Valves 14AOV-13A/B Reactor Isolation Testable Check Valves The check valves passively open to allow Core Spray pump discharge flow into the reactor vessel. There are two trains of Core Spray. These solenoid- and air-operated valves form an assembly that allows the check valve disc to be opened for testing to ensure it has free movement and will allow flow into the reactor vessel when core spray is actuated. Otherwise, these valves are passively held closed by reactor vessel pressure and disc weight. Actuation of the valves for testing is controlled only by rugged pushbutton switches. Therefore, these valves are not susceptible to chatter.

Residual Heat Removal (RHR)

Injection Side OSOV-68A/B RHR Testable LPCI Check Valves OAOV-68A/B RHR Testable LPCI Check Valves The check valves passively open to allow RHR pump discharge flow into the reactor vessel. There are two trains of RHR. These solenoid- and air-operated valves form an assembly that allows the check valve disc to be opened to ensure it has free movement and will allow flow into the Page 7 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation reactor vessel when RHR is used for shutdown cooling or for Low Pressure Coolant Injection (LPCI). Otherwise, these valves are passively held closed by reactor vessel pressure and disc weight. Actuation of the valves for testing is controlled only by rugged pushbutton switches.

Therefore, these valves are not susceptible to chatter.

Suction Side 1OMOV-18 RHR Shutdown Cooling Inboard Isolation Valve 1QMOV-17 RHR Shutdown Cooling Outboard Isolation Valve These valves are normally closed and need to remain closed for inventory control. They are opened to allow the RHR pumps to take a common suction on the reactor vessel through a recirculation loop during shutdown cooling. However, RHR is not credited for core cooling in this analysis. Power to the valve motor for 1OMOV-18 is disconnected by rugged switches during normal operation preventing any spurious opening. Therefore, chatter cannot result in an open pathway and is acceptable.

Standby Liquid Control (SLC) 11SLC-1 7 Standby Liquid Control Inboard Isolation Check Valve This check valve opens to allow SLC pump discharge flow into the reactor vessel. The check valve has no operator and is not affected by contact chatter.

Reactor Water Clean Up (RWCU)

Injection Side 34FW5-28A Reactor Feedwater Inboard Isolation Check Valve The RWCU injection line is connected to the RCIC injection line which is connected to the A feedwater line. Therefore, this check valve provides isolation to the RWCU injection line. The check valve has no operator and is not affected by contact chatter.

Suction Side 12MOV-15 Suction Inboard Containment Isolation Valve 12MOV-18 Suction Outboard Containment Isolation Valve These MOVs are normally open and need to be able to close for inventory control. They are normally open to allow the RWCU pumps to take suction on a recirculation loop to process the reactor water to maintain it at BWR quality.

The closure circuit for 12MOV-15 contains SILO devices:

. Relay 16A-K26 can cause seal-in of contactor 42/C

. Contactor 42/C can seal-in itself The closure circuit for 12MOV-18 contains SILO devices:

. Relay 16A-K27 can cause seal-in of contactor 42/2C

. Contactor 42/2C can seal-in itself Page 8 of 53

For Information Only James A. FitzPatrick: 50.54(1) NIlE 2.1 Seismic High Frequency Confirmation Chatter can result in valve closure and does not inhibit closure. This behavior is desirable for inventory control and chatter is acceptable.

Safety Relief Valves (SRV)

Electric Lift ofthe SRVs 0250V-71A1/B1/C1/D1/E1/F1/G1/H1/J1/K1/L1 SOVs for Automatic Opening of associated SRVs O2RV-71A/B/C/D/E/F/G/H/i/K/L Safety Relief Valves All eleven of the normally closed SRV5 are equipped with the electric lift feature. Electric lift assists the mechanical lift of the SRVs for pressure relief of the reactor vessel. The assistance is provided to mitigate any disc seat sticking that might be occurring in the SRV. It is an automatic system that employs the SOy to open the SRV at a pressure slightly lower than or at the actual SRV setpoint pressure.

The control circuitry for these SOVs features 2-out-of-2 logic that must be satisfied. The relays implementing this logic are not SILO devices and are not controlled by SILO devices. As a result, this logic enhances the chatter resistance of the control circuitry. Chatter of interposing relays 2E-K114 through 2E-K124 could momentarily energize their associated SOVs. However, the relays do not seal-in to keep the SOVs energized and the SRVs open. Therefore, chatter in the Electric Lift circuitry ofthe SRVs will not result in a LOCA.

Automatic Depressurization System (ADS) 0250V-71A1/B1/C1/D1/E1/G1/H1 SOVs for Automatic Opening of associated SRVs O2RV-71A/B/C/D/E/G/H Safety Relief Valves The ADS uses 7 of the 11 normally closed SRVs to perform its function of backing up HPCI to depressurize the reactor vessel in order to allow injection by Core Spray and RHR if HPCI injection is not sufficient. The ADS opens its associated SRV5 by energizing the SOVs listed above. The SOV must remain energized to keep the SRV open. As such, ADS control circuitry is reviewed for SILO devices that could keep an SRV open causing a LOCA.

The control circuitry for these SOVs features 2-out-of-2 logic that must be satisfied. The relays implementing this logic are not SILO devices and are not controlled by SILO devices. As a result, this logic enhances the chatter resistance ofthe control circuitry. There is a time delay relay controlling some of the logic relays that can seal-in once the delay period has passed. However, time delay relays are not chatter sensitive in the coil circuit because ofthe time delay feature and, therefore, not considered SILO devices. Furthermore, ADS actuation has a permissive that requires an RHR or Core Spray pump to be running. The time delay relay will not seal-in unless this permissive is satisfied. Chatter of interposing relays 2E-K14A/B/C/D/E/G/H could momentarily energize their associated SOVs. However, the relays do not seal-in to keep the SOVs energized and the SRV5 open. Therefore, chatter in the ADS circuitry of the SRVs will not result in a LOCA.

Manual Depressurization O2SOV-71A2/82/C2/D2/E2/F2/G2/H2/i2/K2/L2 SOVs for Manual Opening of associated SRVs O2RV-71A/B/C/D/E/F/G/H/i/K/L Safety Relief Valves Page 9 of 53

For 1nformaton Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation All eleven of the normally closed SRVs have the option for manual opening that utilizes a second soy installed in the SRV. The SOy is controlled by rugged pushbuttons which are not chatter sensitive.

Reactor Feedwater 34FW5-28A Reactor Feedwater Inboard Isolation Check Valve 34FW5-28B Reactor Feedwater Inboard Isolation Check Valve These normally open check valves allow feedwater into the reactor vessel to make up for the generated steam. The A valve also allows RWCU effluent into the reactor during power operation and RCIC injection flow when needed. The B valve also allows HPCI injection flow when needed. The check valves have no operator and are not affected by contact chatter.

Main Steam 2950V-80A1/B1/C1/D1 MSIV Test SOV 2950V-80A2/B2/C2/D2 MSIVAC Closure SOV 2950V-80A3/B3/C3/D3 MSIV DC Closure SOV 29A0V-80A/B/C/D Main Steamline Isolation Valves (MSIV)

The normally open MSIVs allow steam flow to be supplied to the main turbine. The MSIV is a quick acting valve controlled by an AC SOV and a DC SOV. The SOVs are normally energized, normally open to keep the MSIV open. Both SOVs must be de-energized to close the MSIV. The control circuitry utilizes normally energized relays in a fail closed scheme to close the MSIVs.

Therefore, the trip relays are normally sealed-in to maintain power to their own coils during at-power operation. If the seal-in contact is broken, the trip coil will de-energize; it does not re energize automatically which causes a de-energized seal-in. Hence, the closure circuits contain SILO devices:

. Trip relays 16A-K7A/B/C/D can de-energize and seal-in the de-energized state Therefore, chatter can result in valve closure. This behavior is desirable for inventory control and chatter is acceptable.

The Test SOVs are controlled by rugged pushbuttons which are not vulnerable to chatter 29M0V-74 Main Steamline Drain Valve (Inboard) 29M0V-77 Main Steamline Drain Valve (Outboard)

These MOVs are normally closed and need to remain closed for inventory control. These two valves are in series and are used to pass condensate from the main steam lines to be collected and re-used. The contactors in the opening circuit have a seal-in contact that can open the valve if it chatters.

Therefore, 29M0V-74 contains a SILO device:

. Contactor 42/0 can seal-in itself Also, 29M0V-77 contains a SILO device:

. Contactor 42/20 can seal-in itself Page lOaf 53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation Chatter can result in valve opening and the contactors are selected for HFC based on the criteria promulgated in this section. Note that there is no leak path unless both MOVs open.

Nuclear Boiler 0250V-1 7 Reactor Vent Valve O2AOV-17 Reactor Vent Valve (Inboard) 0250V-18 Reactor Vent Valve O2AQV-18 Reactor Vent Valve (Outboard)

These AOVs are normally closed and need to remain closed for inventory control; these two AOVs are in series. Each AOV is controlled by a normally de-energized, normally closed SOy. The AOV is opened to allow venting of the reactor vessel head. Actuation is controlled only by a rugged hand switch. Therefore, these valves are not susceptible to chatter.

Reactor Water Recirculation (RWR)

Recirculation Pump Seal Purge 02-2RWR-13A/B Mini-Purge Check Valves These check valves have no operator and are not affected by contact chatter.

Recirculation Pump Sampling 02-2SOV-39 Recirculation Pump Sampling Line Inboard Containment Isolation Valve 02-2AOV-39 Recirculation Pump Sampling Line Inboard Containment Isolation Valve 02-250V-40 Recirculation Pump Sampling Line Outboard Containment Isolation Valve 02-2AOV-40 Recirculation Pump Sampling Line Outboard Containment Isolation Valve These normally open AOVs are used to isolate flow from the recirculation pump discharge to the Process Sampling System. Each AOV is controlled by an SOV that is normally energized to keep the AOV open. The control circuitry utilizes normally energized relays in a fail closed scheme to close the AOV. Chatter of relays in the Primary Containment Isolation (PCI) circuit can close the AOV. This behavior is desirable for inventory control and chatter is acceptable.

Control Rod Drive (CRD) 0350V-120 Control Rod Withdrawal Valve 0350V-122 Control Rod Withdrawal Valve 0350V-121 Control Rod Insertion Valve 0350V-123 Control Rod Insertion Valve 0350V-11 7 Control Rod Scram Valve O3SOV-118 Control Rod Scram Valve O3AOV-126 Control Rod Scram Valve O3AOV-127 Control Rod Scram Valve O3HCU-138 CRDM Cooling Water Check Valve The CRD system consists of Hydraulic Control Units (HCU) directing the flow from the Drive Water Pumps to the Control Rod Drive Mechanisms (CRDM). An HCU contains SOVs used for normal rod insertion and withdrawal and the scram function. The SOVs used for normal rod Page 11 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation positioning are controlled from the control room and do not have seal-in circuits since such an arrangement could result in unintended rod movement. These SOVs are not considered further.

The scram SOVs are used to insert the rods by opening the scram AOVs. The scram SOVs are controlled by the fail-safe Reactor Protection System and are not considered further. An HCU also directs cooling water into each CRDM which is deposited in the reactor vessel after cooling the CRDM. The check valve installed in this flow path prevents backflow from the CRDM and, by extension, the reactor vessel. In conclusion, the CRD system does not contain any devices for HFC.

2.3 REACTOR VESSEL PRESSURE CONTROL The reactor vessel pressure control function is identified as a key function in Reference [31 to be considered in the High Frequency Confirmation. The same report also states that required post event pressure control is typically provided by passive devices and that no specific high frequency component chatter review is required for this function.

2.4 CORE COOLING James A. FitzPatrick credits their Reactor Core Isolation Cooling (RCIC) system to provide a single train of non-AC powered decay heat removal. RCIC consists of a high pressure pump powered with a steam turbine.

RCIC was reviewed for SILO devices that could prevent system operation and deprive the plant of its core cooling function. A general description of the RCIC system is provided in Section 4.7 of the UFSAR [8] and in reference [91.

Analysis of RCIC revealed several seal-in circuits that could place valves in undesired positions.

However, the RCIC actuation signal will automatically align the system valves into their desired positions and RCIC will successfully actuate unless chatter has produced one ofthe following vulnerabilities:

. false RCIC auto-isolation signal

. false RCIC turbine trip

. premature RCIC turbine start These are described in further detail below. All of the SILO devices selected for HFC are listed in Table B-i.

Steam Supply Isolation RCIC is vulnerable to isolation of the steam supply line to the RCIC turbine Isolation of this line will result in the loss ofthe credited core cooling function. Therefore, any relays that could cause this isolation must be selected for HFC.

The vulnerability centers on the RCIC Steam Supply Containment Isolation Valves and their control relays:

. i3A-Ki5 (controls i3MOV-i6 Outboard Containment Isolation Valve)

. i3A-K33 (controls i3MOV-i5 Inboard Containment Isolation Valve)

The valves are in series and, as such, the closure of only one of them will isolate steam flow.

These relays can be sealed in by upstream relays, can seal-in themselves, and will disable the Page 12of53

For Information Only James A. FitzPatrick: 50.54(1) NTTE 2.1 Seismic High Frequency Confirmation opening circuit once sealed in. They also require a manual reset once sealed in. They will drive their respective isolation valves closed and the valves will not re-open upon a RCIC actuation signal until these relays are reset.

Upstream relays of 13A-K15 and -K33 are also selected for HFC since they could cause a seal-in of 13A-K15 or -K33. Most of the SILO devices listed for RCIC in Table B-i are listed there for this reason.

RCIC Turbine Trip Any energization of the turbine trip solenoid is assumed to trip the turbine which requires operator intervention to reset the trip valves.

The RCIC turbine trip solenoid is energized by the following signal chain:

. Logic relay i3A-K8 > logic relay i3A-K49 > trip solenoid i3TS-i Relay i3A-K8 is the signal funnel receiving input from i3A-K6, -K7, -K15 or -K33. These relays provide signals to trip the turbine on auto-isolation, low RCIC pump suction pressure, or high turbine exhaust pressure. These relays, along with their upstream contact devices, are selected for HFC. The applicable pressure switches and logic relays are listed for HFC in Table B-i.

Premature Steam Admission to RCIC Turbine i3MOV-i3i is a normally closed valve used to block steam from the turbine stop and throttle valves while allowing reactor steam to keep the steam supply line. Opening of this valve before a RCIC actuation signal could damage RCIC functionality because the rest of the system is not necessarily aligned for operation. Namely, the RCIC pump has no discharge path, potentially leading to pump damage, and there is no cooling flow to the turbine lube oil cooler or the barometric condenser. The SILO device that can lead to this situation is:

. Contactor 42/0 in motor control center 7iBMCC-3-OBi(MC)

This device is selected for HFC.

2.5 ACIDC POWER SUPPORT SYSTEMS The AC and DC power support systems were reviewed for contact control devices in seal-in and lockout circuits that prevent the availability of DC and AC power sources. The following AC and DC power support systems were reviewed:

. Emergency Diesel Generators,

. Battery Chargers,

. Emergency i2OV AC (Inverters / Uninterruptable Power Supplies),

. EDG Ancillary Systems, and

. Switchgear, Load Centers, and MCCs.

Electrical power, especially DC, is necessary to support achieving and maintaining a stable plant condition following a seismic event. DC power relies on the availability of AC power to recharge the batteries. The availability of AC power is dependent upon the Emergency Diesel Generators and their ancillary support systems. EPRI 3002004396 [31 requires confirmation that the supply Page 13of53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation of emergency power is not challenged by a SILO device. The tripping of lockout devices or circuit breakers is expected to require some level of diagnosis to determine if the trip was spurious due to contact chatter or in response to an actual system fault. The actions taken to diagnose the fault condition could substantially delay the restoration of emergency power.

In order to ensure contact chatter cannot compromise the emergency power system, control circuits were analyzed for the Emergency Diesel Generators (EDG), Battery Chargers, Emergency 120V AC (Inverters/uninterruptible power), and Switchgear/Load Centers/MCCs as necessary to distribute power from the EDGs to the Battery Chargers and EDG Ancillary Systems. General information on the arrangement of safety-related AC and DC systems, as well as operation of the EDGs, was obtained from JA Fitzpatricks UFSAR. Fitzpatrick has two divisions of Class 1E loads with two EDGs per division. The two EDGs supplying each 4KV emergency bus operate in parallel. The 4KV buses provide power to the redundant 600V AC emergency buses, which in turn are a power source for 125V DC and emergency 120V AC. A general description of the class 1E AC distribution scheme is described in UFSAR sections 8.5 and 8.6, and shown on 4KV one-line drawings and 600V AC one-line drawings. The Class 1E DC distribution scheme is described in UFSAR section 8.7 and shown on one-line drawings. The 120V AC is described in UFSAR section 8.9 and shown on one-line drawings.

The analysis necessary to identify contact devices in this category relies on conservative worst case initial conditions and presumptions regarding event progression. The analysis considers the reactor is operating at power with no equipment failures or LOCA prior to the seismic event. The Emergency Diesel Generators are not operating but are available. The seismic event is presumed to cause a Loss of Offsite Power (LOOP) and a normal reactor SCRAM. In response to bus undervoltage relaying detecting the LOOP, the Class 1E control systems must automatically shed loads, start the EDGs, and sequentially load the diesel generators as designed. Ancillary systems required for EDG operation as well as Class 1E battery chargers and emergency AC must function as necessary. The goal of this analysis is to identify any vulnerable contact devices that could chatter during the seismic event, seal-in or lock-out, and prevent these systems from performing their intended safety-related function of supplying electrical power during the LOOP.

The following sections contain a description of the analysis for each element of the AC/DC support systems. Contact devices are identified by description in this narrative and apply to all four EDGs. The selected contact devices for both divisions appear in Table B-i.

Emergency Diesel Generators The analysis of the four EDGs (EDG A and C on 4KV bus 10500, and EDG B and D on 4KV bus i0600) is broken down into the generator protective relaying and diesel engine control. General descriptions ofthese systems and controls appear in the UFSAR Section 8.6. The contact devices are identified by description in this narrative and apply to all four EDGs. Full relay identification for the relays selected for HFC is in Table B-i.

Generator Protective Relaying The control circuits for the EDG output breakers (e.g., 4KV breaker i0502 for EDG A) include several relays whose chatter could trip and/or lockout the EDG output breaker. These include the phased high speed differential relays (87-A, $7-B, $7-C), the phased time-overcurrent relays (27/5i-A, 21/57-B, 21/57-C) and the generator fault relay ($6X1). There are relays in the static exciter and voltage regulator circuit that can also trip the output breaker. These include the exciter-regulator voltage shutdown relay (K1VR), and the engine failure and generator field Page f4of53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation shorted relay (Kb). Also in this circuit are the diesel generator exciter-regulator sensing relay (K3VR) and the diesel generator exciter-regulator reset relay (K4VR), which can interrupt automatic field flashing if they chatter.

Chatter in the anti-motoring circuit could actuate the EDG shutdown relay (SDR) and trip the output breaker. This includes the high circulating current power relay (32), the high circulating current seal in relay (32/SI), and the high circulating current shutdown relay (32X1). Also, chatter of the contacts on the high circulating current interlock time delay relay (62-1EDG_12) could enable the anti-motoring circuit prematurely, which could possibly result in trip of the circuit.

Diesel Engine Control Chatter analysis for the diesel engine control was performed on the start and shutdown circuits of each EDG. The start circuit is blocked by seal-in of the shutdown relay (SDR), which signifies engine trouble. Chatter of the seal-in contact of this relay, its auxiliary relay arranged in parallel (SDRX), or of the contacts of relays within the coil circuits of SDR or SDRX may prevent EDG start.

The SDR/SDRX coils can be energized by chatter ofthe contacts ofthe diesel fail to start relay (TD5). This is a time-delay relay that shuts down the engine if it fails to start within 10 seconds.

Other contact devices whose chatter can trip SDR/SDRX include the jacket water high temperature shutdown switch (TS-3A) and the engine start bypass interlock relay (TD6). TD6 is a time delay relay that is used as a permissive for the low lube oil pressure trip. Its contacts close after engine speed reaches 200 RPM; if it chatters before lube oil pressure is up, then the SDR will trip.

The SDR/SDRX coils can also be actuated by chatter of the generator field failure relay (40X1).

The coil circuit of 40X1 has an open contact from a time-delay relay (TD1O, loss of field relay),

whose chatter can seal-in the circuit if the diesel engine reaches a speed of 400 RPM before the strong shaking stops. Circuits on the coil side of ID1O are immune from chatter because of the buffering effect ofthe time delay.

The EDG is started by the auto start relay (Ki), which is a latching relay. Chatter of the operate coil contacts is acceptable because it will cause the relay to latch to the EDG start position.

However, the EDG must start in ten seconds, and the seismic shaking is assumed to last 30 seconds. Therefore, this relay is included for HFC to ensure that strong shaking will not cause the reset coil to unlatch the circuit.

There is an electronic speed switch tESS), which has three sets of contacts (SPSW4O, SPSW200, and SPSW400) to signal increasing engine speeds of4O RPM, 200 RPM, and 400 RPM, respectively. These correspond to engine speed sensing relays ESR4O, ESR200 and ESR400, which each have a seal in and a different control function. ESR4O and ESR200 are used in the air start logic, and chatter prior to the engine reaching the indicated speed can prevent the air start system from operating. ESR200 also signals the start of forced-paralleling for the two EDGs on the same 4KV bus (see below). For successful paralleling the two diesel engines must reach 200 RPM within 3 seconds of each other. Therefore, premature actuation of an ESR200 relay due to chatter could defeat the operation. ESR400 is used to initiate generator field flashing (as well as start of emergency service water flow through the water jackets). Two paralleled EDGs must reach 400 RPM within 3 seconds of each other. Therefore, chatter of the seal-in contact prior to 400 RPM can cause the generator field to flash early or may defeat paralleling.

Page 15 of 53

For inforrnaton Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Once the EDGs are started, the two EDGs that operate on each 4KV emergency bus are paralleled via a tie breaker (breaker 10504 for EDG A and C, breaker 10604 for EDG B and D).

This is controlled by the force paralleling and tie breaker control circuits. There are relays in these circuits that can trip the tie breaker, including: the force parallel loss of l25vdc control voltage relay (74C), tie breaker open control relay (K9), force parallel logic relays (TD9X, TD9M, TD8M), and fail to synch relays (FTS1A, FTS2A). In addition, chatter of the tie breaker closing control relay (K8) can cause the tie breaker to close prematurely. The EDG output breakers (e.g.,

breaker 10502 for EDG A) also have interlock relays on the close circuit whose chatter may cause the output breaker to close prematurely. These include the output breaker voltage check close interlock relay (62-1EDG_O1), output breakers (e.g., A and C) close interlock relay (62-1EDGO2), and tie (e.g., A and C) auxiliary time delay relay (62X-1EDG_02).

There are other contact devices in the above-described circuits that are excluded from HFC because they are inherently rugged (e.g., mechanical switches [3]), do not seal in because the contact is upstream of a time-delay coil, or are blocked by a normally-open switch contact. A complete accounting of these devices is contained in Reference [17].

Battery Chargers The 125V DC power system consists of two redundant and independent trains. Each train includes a lead-calcium battery and a static battery charger operating in parallel. The output power from each battery/charger train is supplied to its own battery control board. The battery control board supplies power to 125V DC distribution panels, motor control centers, UPS Static Inverter, and emergency lighting panels.

There is protective relaying associated with the battery charger (71BC-1A and 1B). Each charger includes ground detect relays, AC power failure relays, charger failure relays, and low DC voltage sensing relay. These relays provide contact outputs for external annunciators only; they have no SILO function.

Emergency 12OVAC (Inverters I Uninterruptable Power Supplies)

The emergency 120V AC power system consists of two redundant and independent divisions, which supply all ofthe safety-related loads associated with safeguard control and instrument power. The power to the 120V AC panels is from single phase distribution transformers supplied from the 600V AC emergency buses and backed by the EDGs. The only contact devices of interest in this distribution are the protective relays associated with the 4KV supply breakers that distribute power via stepdown transformers from the 4KV safeguards buses to their associated 600V load centers; these are covered in the section below on Switchgear, Load Centers and MCCs.

There are dedicated inverters (71INV-1A and 1B) that provide power for LPCI valves. One of these inverters also supplies a backup power source for one ofthe RCIC pump enclosure exhaust fans in case of EDG failure. Since LPCI is not a flow path that is credited for this analysis, and station blackout is not assumed, chatter in these circuits is not of interest.

There is an uninterruptible power system (UPS) that supplies power to vital non-safety related loads such as the control rod drives and process radiation monitoring. This non-safety related UPS system consists oftwo redundant motor-generator sets and a static inverter (71UPP). These are not required for the functions that are in the scope of this analysis, so chatter analysis is not necessary.

Page 16 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation The RCIC system (credited for core cooling in Section 2.4) has a small inverter (13INV-152) that provides power to the instrumentation, specifically the RCIC pump discharge flow indication and control. Flow indication is used by the control room operator to evaluate pump performance and is also used by the RCIC turbine control system to automatically adjust turbine speed to match the flow demand. Investigation shows this to be a solid state inverter with no contact devices that require circuit analysis.

RCIC also has steam leak detection logic that is powered by inverters (B21B-K8O1A and K8O1B).

However, circuit analysis of these inverters is unnecessary because loss of power is fail safe with respect to RCIC function (i.e., isolation logic is energize to trip).

EDG Ancillary Systems In order to start and operate the Emergency Diesel Generators, a number of components and systems are required. For the purpose of identifying electrical contact devices, only systems and components which are electrically controlled are analyzed.

Starting Air Based on Diesel Generator availability as an initial condition, the passive air reservoirs are presumed pressurized and the only active components in this system required to operate are the air start solenoids. The control circuit for the air start solenoids includes SILO devices consisting of the EDG auto start relay (Ki), the EDG electronic speed switch (ESS), and the engine speed sensing relays (ESR-40, ESR-200), which are covered under the EDG engine control analysis discussed above.

Combustion Air Intake and Exhaust The combustion air subsystem for the Diesel Generators is passive, which does not rely on electrical control.

Lube Oil The Diesel Generators utilize engine-driven mechanical lubrication oil pumps, which do not rely on electrical control. (There are also pre-lube pumps that keep the EDGs lubricated during standby, which are not needed after the postulated event begins.)

Fuel Oil The Diesel Generator Fuel Oil System is described in section 8.6 ofthe UFSAR and shown on flow diagrams. Each diesel generator unit is provided with an independent fuel oil system consisting of a main fuel storage tank, a day tank and pumps. Two full-capacity motor-driven transfer pumps are provided for filling the day tank from the storage tank. An engine-driven prime pump and a DC motor-driven prime pump are provided to pump fuel from the day tank to the fuel injectors and are arranged so as to provide two redundant engine fuel pumping systems.

Chatter analysis ofthe control circuits for the electrically powered transfer and prime pumps concluded they do not include SILO devices.

Cooling Water The EDG Jacket Cooling Water System is a closed-loop system, one for each EDG, consisting of a temperature control valve, engine-driven cooling water pump, jacket water heat exchanger, and coolant expansion tank. The only SILO device in this cooling loop is the jacket water high Page 17of53

For information Only James A. FitzPatrick: 50.54(1) NTTE 2.1 Seismic High Frequency Confirmation temperature shutdown switch (TS-3A), which is covered above in the section on diesel engine control.

The jacket water heat exchangers are cooled by the emergency service water (ESW) system. A general description ofthe ESW system is in section 9.7.1 ofthe UFSAR. As described above in the section on diesel engine control, the ESW pumps are started on a signal from the 400 RPM engine speed sensing relays (ESR400). Examination of the control circuits for the ESW pumps and associated valves indicates that there are no SILO devices that can prevent the system from operating.

Ventilation The EDG Building ventilation during accidents is provided by one supply fan per diesel engine.

These fans are started via the EDG Start Signal. Chatter analysis of the EDG start signal is included in the section above. Other than SILO devices identified for the EDG start signal, chatter analysis of the control circuits for these fans and their associated dampers concluded they do not include SILO devices that can impede system operation.

The ESW pump rooms have supply and exhaust fans that are required for ventilation. Other than the SILO devices identified for the EDG and ESW start signals describe above, chatter analysis of the control circuits for these fans and their associated dampers concluded they do not include SILO devices that can impede system operation.

The battery and battery charger rooms also have a ventilation system that consists of exhaust fans, recirculation/exhaust fans, and air handling units. Chatter analysis for control circuits for this equipment concluded that there are no SILO devices that can impede system operation.

The RCIC pump enclosure also has two exhaust fans 13FN-1A and 2A. Chatter analysis of the control circuits for these fans and their associated dampers concluded they do not include SILO devices that can impede system operation.

Switchgear, Load Centers, and MCCs Power distribution from the EDGs to the necessary electrical loads (Battery Chargers, Emergency AC, Fuel Oil Pumps, and EDG Ventilation Fans) was traced to identify any SILO devices that could lead to a circuit breaker trip and interruption in power. This effort excluded the EDG circuit breakers, which are covered in the sections above, as well as component-specific contactors and their control devices, which are covered in the analysis of each component above.

The loads described in this section are supplied via motor control centers (MCC) in the 600V AC load centers. This includes the ESW pumps, fuel oil transfer pumps, battery chargers, and the ventilation fans for the diesel engines, ESW pump rooms, and battery rooms. The motive power for AC-powered components credited in the previous sections on RCS inventory control and core cooling is also supplied by 600V MCCs. This includes normally-open MOVs in the RCS pressure boundary that are credited with closing, and MOVs in RCIC that are credited to open.

The 600V MCCs are also the source of power for DC-powered components. The 125VDC loads are powered from the 600V AC MCCs via the battery chargers (see discussion in section on battery chargers). This includes the DC-powered MOVs in RCIC, the DC fuel prime pump, and the various component control circuits. Individual 125V DC circuits are protected by molded case circuit breakers, which are not vulnerable to chatter [3], or by fuses.

Page 18of53

For information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation The 120V AC emergency loads are also powered from the 600V MCCs via transformers, as discussed in the section above on emergency 120V AC. Individual 120V AC circuits are protected by molded case circuit breakers, which are not vulnerable to chatter, or by fuses.

Each 600V MCC bus is protected from phase and ground faults by long time adjustable and short time adjustable solid state trip devices, which are installed on each 600V load center breaker supplying the MCC. Solid state trip devices are not vulnerable to chatter [3]. There are no contact devices in the protective circuitry for the power distribution that are vulnerable to chatter, except as noted below.

The only circuit breakers affected by protective relaying (not already covered) are those that distribute power via stepdown transformers from the 4KV safeguards buses to their associated 600V load centers. A chatter analysis of the control circuits for these circuit breakers (breakers 10560, 10660) indicates that chatter in the 50/51 Phase Overcurrent Relays or the 50G5 Ground Overcurrent Relay in the trip circuits of these breakers could cause breaker tripping following the seismic event.

2.6

SUMMARY

OF SELECTED COMPONENTS The investigation of high-frequency contact devices as described above was performed in accordance with the EPRI guidance [31. Reference [17] provides a more detailed accounting of the relay chatter analysis. A list of the contact devices requiring a high frequency confirmation is provided in Table B-i.

Page 19 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation 3 Seismic Evaluation 3.1 HORIZONTAL SEISMIC DEMAND Per Reference [3], Sect. 4.3, the basis for calculating high-frequency seismic demand on the subject components in the horizontal direction is the JAF horizontal ground motion response spectrum (GMRS), which was generated as part of the JAF Seismic Hazard and Screening Report

[6] submitted to the NRC on March 31, 2014 and accepted by the NRC on February 18, 2016 [7].

It is noted in Reference [3] that a Foundation Input Response Spectrum (FIRS) may be necessary to evaluate buildings whose foundations are supported at elevations different than the Control Point elevation. Section 3.2 of Reference [6] notes that the control point elevation is defined at a depth of 12 ft, which is the top of the Oswego sandstone where all plant structures are founded. Combining this condition with the justification provided in section 3.3 of Reference [3]

on when a FIRS would normally be defined, the GMRS is judged appropriate for use as the site review level ground motion for high frequency evaluations.

The horizontal GMRS values are provided in Table 3-2.

3.2 VERTICAL SEISMIC DEMAND As described in Section 3.2 of Reference [3], the horizontal GMRS and site soil conditions are used to calculate the vertical GMRS (VGMRS), which is the basis for calculating high-frequency seismic demand on the subject components in the vertical direction.

The sites soil mean shear wave velocity vs. depth profile is provided in Reference [6], Table 2.3.2-1 (Profile 1) and partially reproduced below in Table 3-1 below.

Page 20 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation Table 3-1: Soil Mean Shear Wave Velocity Vs. Depth Profile Depth Depth Thickness, Vs Vs30 Layer (ft) (m) d1 fft) (ft/sec) d1 I Vs1  ! t d1 I Vs1 I (ft/s) 1 6.00 1.23 6.0 7,500 0.0008 0.0008 2 12.00 3.66 6.0 7,500 0.0008 0.0016 3 20.00 6.10 8.0 7,500 0.0011 0.0027 4 30.90 9.42 10.9 7,500 0.0015 0.0042 500 5 49.80 15.18 18.9 7,500 0.0025 0.0067 6 68.70 20.94 18.9 7,500 0.0025 0.0092 7 87.60 26.70 18.9 7,500 0.0025 0.0117 30.00 10.8 0.0014 0.0131 8 500 106.50 32.46 8.1 Using the shear wave velocity vs. depth profile, the velocity of a shear wave traveling from a depth of 30m (98.4ft) to the surface of the site (Vs30) is calculated per the methodology of Reference [3], Section 3.5.

. The time for a shear wave to travel through each soil layer is calculated by dividing the layer depth (d1) by the shear wave velocity of the layer (Vsj.

. The total time for a wave to travel from a depth of 30m to the surface is calculated by adding the travel time through each layer from depths of Om to 30m ([d1/Vs]).

. The velocity of a shear wave traveling from a depth of 30m to the surface is therefore the total distance (30m) divided by the total time; i.e., Vs30 = (30m)/>[d1/Vs1].

The sites soil class is determined by using the sites shear wave velocity (Vs30) and the peak ground acceleration (PGA) of the GMRS and comparing them to the values within Reference [3],

Table 3-1. Based on the PGA of 0.12g and the shear wave velocity of 7,500ft/s, the site soil class is Class A-Hard.

Once a site soil class is determined, the mean vertical vs. horizontal GMRS ratios (V/H) at each frequency are determined by using the site soil class and its associated V/H values in Reference

[3], Table 3-2.

The vertical GMRS is then calculated by multiplying the mean V/H ratio at each frequency by the horizontal GMRS acceleration at the corresponding frequency. It is noted that Reference [3],

Table 3-2 values are constant between 0.1Hz and 20Hz for Class A-Hard sites.

The V/H ratios and VGMRS values are provided in Table 3-2 ofthis report.

Figure 3-1 below provides a plot of the horizontal GMRS, V/H ratios, and vertical GMRS for JAF.

Page2f of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Table 3-2: Horizontal and Vertical Ground Motions Response Spectra Frequency (Hz) HGMRS (g) V/H Ratio VGMRS (g) 0.10 0.008 0.67 0.005 0.13 0.009 0.67 0.006 0.15 0.011 0.67 0.008 0.20 0.015 0.67 0.010 0.25 0.019 0.67 0.013 0.30 0.023 0.67 0.015 0.35 0.026 0.67 0.018 0.40 0.030 0.67 0.020 0.50 0.038 0.67 0.025 0.60 0.045 0.67 0.030 0.70 0.051 0.67 0.034 0.80 0.057 0.67 0.038 0.90 0.061 0.67 0.041 1.00 0.064 0.67 0.043 1.25 0.071 0.67 0.048 1.50 0.075 0.67 0.050 2.00 0.085 0.67 0.057 2.50 0.094 0.67 0.063 3.00 0.114 0.67 0.076 3.50 0.127 0.67 0.085 4.00 0.144 0.67 0.096 5.00 0.170 0.67 0.114 6.00 0.188 0.67 0.126 7.00 0.204 0.67 0.137 8.00 0.215 0.67 0.144 9.00 0.226 0.67 0.151 10.00 0.233 0.67 0.156 12.50 0.239 0.67 0.160 15.00 0.241 0.67 0.161 20.00 0.231 0.67 0.155 25.00 0.216 0.69 0.149 30.00 0.209 0.74 0.155 35.00 0.199 0.79 0.157 40.00 0.187 0.84 0.157 50.00 0.155 0.88 0.136 60.00 0.133 0.90 0.120 70.00 0.125 0.89 0.111 80.00 0.122 0.85 0.104 90.00 0.120 0.81 0.097 100.00 0.120 0.78 0.094 Page 22 of 53

For nforrnation Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation 0.30 too

o.

C 0.80 0

0 I-w Q

U

=

0.10 0.60 0.00 0.40 0.1 1.0 10.0 100.0 Frequency (Hz)

Figure 3-1 Plot of the Horizontal and Vertical Ground Motions Response Spectra and V/H Ratios 3.3 COMPONENT HORIZONTAL SEISMIC DEMAND Per Reference [3] the peak horizontal acceleration is amplified using the following two factors to determine the horizontal in-cabinet response spectrum:

. Horizontal in-structure amplification factor AFSH to account for seismic amplification at floor elevations above the host buildings foundation

. Horizontal in-cabinet amplification factor AFCH to account for seismic amplification within the host equipment (cabinet, switchgear, motor control center, etc.)

The in-structure amplification factor AFSH is derived from Figure 4-3 in Reference [3]. The in-cabinet amplification factor, AFCH is associated with a given type of cabinet construction. The three general cabinet types are identified in Reference [3] and Appendix I of EPRI NP-7248 [14]

assuming 5% in-cabinet response spectrum damping. EPRI NP-7148 [14] classified the cabinet types as high amplification structures such as switchgear panels and other similar large flexible panels, medium amplification structures such as control panels and control room benchboard panels and low amplification structures such as motor control centers.

All of the electrical cabinets containing the components subject to high frequency confirmation (see Table B-i in Appendix B) can be categorized into one of the in-cabinet amplification categories in Reference [31 as follows:

Page 23 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation

. Motor Control Centers are identified during walkdowns and typically consist of a lineup of several interconnected sections. Each section is a relatively narrow cabinet structure with height-to-depth ratios of about 4.5 that allow the cabinet framing to be efficiently used in flexure for the dynamic response loading, primarily in the front-to-back direction. This results in higher frame stresses and hence more damping which lowers the cabinet response. In addition, the subject components are not located on large unstiffened panels that could exhibit high local amplifications. These cabinets qualify as low amplification cabinets and receive an in-cabinet amplification factor of 3.6.

. Switchgear cabinets are large cabinets consisting of a lineup of several interconnected sections typical ofthe high amplification cabinet category. Each section is a wide box-type structure with height-to-depth ratios of about 1.5 and may include wide stiffened panels. This results in lower stresses and hence less damping which increases the enclosure response. Components can be mounted on the wide panels, which results in the higher in-cabinet amplification factors and receive an in-cabinet amplification factor of 7.2. The switchgear amplification factor is used when uncertainty exists in the applicability of lower amplification cabinet categories.

. Control cabinets are in a lineup of several interconnected sections with moderate width.

Each section consists of structures with height-to-depth ratios of about 3 which results in moderate frame stresses and damping. The response levels are mid-range between MCCs and switchgear and therefore these cabinets can be considered in the medium amplification category and receive an in-cabinet amplification factor of 4.5.

3.4 COMPONENT VERTICAL SEISMIC DEMAND The component vertical demand is determined using the peak acceleration of the VGMRS between 15 Hz and 40 Hz and amplifying it using the following two factors:

. Vertical in-structure amplification factor AF5 to account for seismic amplification at floor elevations above the host buildings foundation

. Vertical in-cabinet amplification factor AF to account for seismic amplification within the host equipment (cabinet, switchgear, motor control center, etc.)

The in-structure amplification factor AF5is derived from Figure 4-4 in Reference [3]. The in-cabinet amplification factor, AF is derived in Reference [3] and is 4.7 for all cabinet types.

Page 24 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation 4 Contact Device Evaluations Per Reference [3], seismic capacities (the highest seismic test level reached by the contact device without chatter or other malfunction) for each subject contact device are determined by the following procedures:

(1) If a contact device was tested as part ofthe EPRI High Frequency Testing program [10],

then the component seismic capacity from this program is used.

(2) If a contact device was not tested as part of [10], then one or more of the following means to determine the component capacity were used:

(a) Device-specific seismic test reports (either from JAF or from the SQURTS testing program).

(b) Generic Equipment Ruggedness Spectra (GERS) capacities per [11], [12], [13], and

[15].

(c) Assembly (e.g. electrical cabinet) tests where the component functional performance was monitored.

The high-frequency capacity of each device was evaluated in Reference [18] with the component mounting point demand from Section 3 using the criteria in Section 4.5 of Reference

[3].

A summary of the high-frequency evaluation conclusions is provided in Table B-i in Appendix B.

Page 25 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation 5 Conclusions 5.1 GENERAL CONCLUSIONS JAF has performed a High Frequency Confirmation evaluation in response to the NRCs 50.54(f) letter [1] using the methods in EPRI report 3002004396 [3].

The evaluation, References [17, 18], identified a total of 174 components that required seismic high frequency evaluation. As summarized in Table B-i in Appendix B, i62 ofthe devices have adequate seismic capacity. The i2 devices that have seismic capacity less than seismic demand can be resolved by JAF operator actions.

5.2 IDENTIFICATION OF FOLLOW-UP ACTIONS Twelve EDG high speed differential relays are installed with GE model CFD12B and have been determined to have capacity to demand ratio of 0.19 under HFE approach.

These relays have been determined to be in the $6 lockout relay circuits [16]. If a seismic event were to occur with a magnitude high enough to cause these relay contacts to chatter, the lockout relays would trip. If the EDG lockout relays were to trip the diesel generator will trip if running and would not start if the diesel generator was in standby. An operator action to reset the $6 lockout relays would be required prior to being able to re-start the diesel generator.

Procedural guidance for the above actions can be found in the following JAF procedures.

Procedure Revision Title OP-22 6i Diesel Generator Emergency Power ARP-93ECP-A-i6 1 EDG A Prot Relay ARP-93ECP-B-i6 i EDG B Prot Relay ARP-93ECP-C-i6 i EDG C Prot Relay ARP-93ECP-D-i6 i EDG D Prot Relay ARP-93EGP-A-5 1 EDG A Prot Relay ARP-93EGP-B-5 1 EDG B Prot Relay ARP-93EGP-C-5 i EDG C Prot Relay ARP-93EGP-D-5 1 EDG D Prot Relay No additional follow up actions are required.

Page 26 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation 6 References 1 NRC (E. Leeds and M. Johnson) Letter to All Power Reactor Licensees et al., Request for Information Pursuant to Title 10 ofthe Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3 and 9.3 ofthe Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident, March 12, 2012, ADAMS Accession Number M L12053A340 2 EPRI 1025287. Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic. February 2013 3 EPRI 3002004396. High Frequency Program: Application Guidance for Functional Confirmation and Fragility Evaluation. July 2015 4 NRC (J. Davis) Letter to Nuclear Energy Institute (A. Mauer). Endorsement of Electric Power Research Institute Final Draft Report 3002004396, High Frequency Program:

Application Guidance for Functional Confirmation and Fragility. September 17, 2015, ADAMS Accession Number ML15218A569 5 NRC (W. Dean) Letter to the Power Reactor Licensees on the Enclosed List. Final Determination of Licensee Seismic Probabilistic Risk Assessments Under the Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1 Seismic ofthe Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident. October 27, 2015, ADAMS Accession Number M L15194A015 6 Entergy Letter to U.S. NRC, letter number JAFP-14-0039, Entergys Seismic Hazard and Screening Report (CEUS Sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 ofthe Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, March 31, 2014, NRC ADAMS Accession No. ML14090A243.

7 NRC letter to James A. FitzPatrick Nuclear Power Plant, James A FitzPatrick Nuclear Power Plant Staff Assessment of Information Provided Pursuant to Title 10 of the Code of Federal Regulations Part 50, Section 50.54(f), Seismic Hazard Reevaluations for Recommendation 2.1 ofthe Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, February 18, 2016, ADAMS Accession Number M L16043A41 1 8 JAF Report, Updated Final Safety Analysis Report (UFSAR), Revision 6, April 2017 9 JAF Design Basis Document DBD-013, Revision 11, Reactor Core Isolation Cooling System.

10 EPRI 3002002997. High Frequency Program: High Frequency Testing Summary.

September 2014 11 EPRI NP-5223-SLR1. Generic Seismic Ruggedness of Power Plant Equipment. Revision 1, Final Report, August 1991 Page 27 o153

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For nformaton Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation A Representative Sample Component Evaluations A.1 Demand The CDFM Mounting Point Demand values (ICRSCH and lCRS) for 3 typical components (cabinet, switchgear, motor control center) at JAF for Elevations 242, 272, 284, and 300 are computed and summarized in Table A-i below:

Table A-i: JAF High Frequency Acceleration Demand for Relays ISRS(GMRS)(g) ISRS(@EIev.)(g) AFcH ICRScH fg) ICRScV fg)

Component HT. above Control Control Elevation Foundation AFSH AFSV HGMRS VGMRS SAH SAV MCC Switchgear Cab. AFV MCC Switchgear Cab. All Cabinet 242 0 120 1.00 0.241 0.162 0289 0.162 3.6 7.2 4.5 4.7 1.041 2.082 1301 0.759 272 0.162 3.6 7.2 4.5 4.7 1.041 2.082 1.301 0.759 1.20 1.00 0.241 0.162 0.289 (Foundation) 284 12 1.47 1.20 0.241 0.162 0.354 0.194 3.6 7.2 4.5 4.7 1.275 2.551 1.594 0.914 300 28 1.83 1.48 0.241 0.162 0.441 0.238 3.6 7.2 4.5 4.7 1.588 3.175 1.985 1.120 It should be noted, for the horizontal direction, the demand is dependent on the type of equipment in which the relay is mounted (i.e. MCC, switchgear, or control cabinet). There is one elevation below the main foundation elevation. This elevation is conservatively given the same in-structure amplification factor as the foundation since there would be no additional amplification below grade.

A.2 Square D KPD-13 Relay Evaluation The Generic Equipment Ruggedness Spectrum (GERS) for the Square D KPD-i3 series relays are presented in Table 3-i of Reference [i5J. For the KPD-i3 relay, a high frequency capacity of i4.2g is used along with an FK = i.5 (the capacity knockdown factor, FK, is determined based on the test source as provided in Table 4-2 of Reference [3]).

Table A-2 below contains the complete list of Square D KPD-i3 relays along with their respective capacity to demand ratios. The minimum capacity to demand ratio is 4.55 for the horizontal and i2.47 for the vertical checks.

A.3 GE 12PJC11A4 Code 11 Relay Evaluation The Generic Equipment Ruggedness Spectrum (GERS) for the GE i2PJC series relays are presented starting on page B-87 of Reference [i2]. EPRIs high frequency program tested a GE i2PJCiiA (Table 5-io of Reference [iO]) and obtained a high frequency capacity of 6.5g prior to relay chatter for D/NO (De Energized Normally Open). As the GERS grouped all PJC1i together, it is considered acceptable to use a high frequency capacity of 7.i25g (=6.5g + O.625g) with an FK = i.56 (the capacity knockdown factor, FK, is determined based on the test source as provided in Table 4-2 of Reference [3]).

Table A-3 below contains the complete list of GE PJC series relays along with their respective capacity to demand ratios. The minimum capacity to demand ratio is 2.i9 for the horizontal and 6.02 for the vertical checks.

Page 29 of 53

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For information Only James A. FitzPatrick: 50.54(f) NTTE 2.1 Seismic High Frequency Confirmation B Components Identified for High Frequency Confirmation Page3J of 53

For Information Only James A. FitzPatrick: 50.54(f) NIlE 2.1 Seismic High Frequency Confirmation Table B-i: Components Identified for High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit System Relay ID Component Description 71BMCC C28001607,AF3H per 1/26/2017 71BMCC-3 RB 242 EPRI NP-5223-SLR Confirmed 1 1 125VDC OB1fMC), DC Contactor for 3MOV-131 ELECTRCO Relay 42/20 walkdown finding 71BMCC GENERAL EPRI NP-5223-SLR1 Confirmed 2 125VDC OA1(MC) DC Contactor for 29M0V-77 1C2$OO 71BMCC-2 RB 242 1 ELECTRIC CO Relay 42/20 600V EMERG SWGR TO 71T-71-50/51-A- GENERAL 272 EPR13002002997 Confirmed 3 4.16KV 13&71T-15INST/TIME IAC51B 71-10560 EG 1 ELECTRIC CO 1HOEAO2 OVERCURRENT PH A REL 600V EMERG SWGRTO 71T-71-50/51-A- GENERAL EPR13002002997 Confirmed 4 416KV 14&71T-16INST/TIME IAC51B 7140660 EG 272 1 ELECTRIC CO 1HOEBO2 OVERCURRENT PH A REL 600V EMERG SWGR 10 711-71-50/51-B- GENERAL 272 EPR13002002997 Confirmed 5 4.16KV 13&71T-15INST/TIME IAC51B 71-10560 EG 1 ELECTRIC CO 1HOEAO2 OVERCURRENT PH B REL 600V EMERG SWGR TO 711-71-50/51-B- GENERAL 272 EPRI 3002002997 Confirmed 6 4.16KV 14 & 711-16 INST/TIME IAC51B 71-10660 EG 1 ELECTRIC CO 1HOEBO2 OVERCURRENT PH B REL 600V EMERG SWGR TO 711-71-50/51-C- GENERAL EPR13002002997 Confirmed 7 13&71T-151N51/TIME IACS1B 71-10560 EG 272 1 4.16KV ELECTRIC CO 1HOEAO2 OVERCURRENT PH C REL 600V EMERG SWGRTO 71T-71-50/51-C- GENERAL EPRI 3002002997 Confirmed 8 4.16KV 14 & 711-16 INST/TIME IAC51B 71-10660 EG 272 1 ELECTRIC CO 1HOEBO2 OVERCURRENT PH C REL 1 All of the mechanical All of the relays on this table are normally de-energized (ND) and the applicable Contact is normally open (NO) unless otherwise stated.

sensor switches (process switches) on this table are normally open (NO) unless otherwise stated.

2 All relay model numbers are from the JAF Equipment Database unless otherwise noted.

Page 32 of 53

For Information Only James A. FitzPatrick: 50.54(f) NIlE 2.1 Seismic High Frequency Confirmation component Enclosure component Evaluation Cab/Rack? Evaluation Relay ID Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit System AUX POWER TO 600V UNIT 71-50G5- GENERAL Confirmed 9 4.16KV SUB INST GROUND PJC 71-10560 EG 272 EPRI 3002002997 1 ELECTRIC CO 1HOEAO2 OVERCURRENT RELAY 600 V EMERG SWGR TO 711-71-5OGS- GENERAL EPRI 3002002997 Confirmed 10 1 4.16KV 14 & 711-16 GROUND 12P]C11AV1A 71-10660 EG 272 1HOEBO2 ELECTRIC CO OVERCURRENT RELAY 71MCC-152- CR1O9CO G ENERAL EPRI NP-5223-SLR1 Confirmed 11 1 600VAC 0B4(MC), AC Contactor 29M0V-74 71MCC-152 RB 272 ELECTRIC CO Relay 42/0 93-27/51-A- EDG A PHASE A TIME- GENERAL Confirmed 12 1 EDG IJCV51A 71-10502 EG 272 EPRI NP-7147-SL-V2 1EDGAO8 OVERCURRENT RELAY ELECTRIC CO 93-27/51-A- EDG B PHASE A TIME- GENERAL EPRI NP-7147-SL-V2 Confirmed 13 1 EDG IJCV51A 71-10602 EG 272 1EDGBO2 OVERCURRENT RELAY ELECTRIC CO 93-27/51-A- EDG C PHASE A TIME- GENERAL Confirmed 14 EDG IJCVS1A 71-10512 EG 272 EPRI NP-7147-SL-V2 1 ELECTRIC CO 1EDGCO8 OVERCURRENT RELAY 93-27/51-A- EDG D PHASE A TIME- GENERAL Confirmed 15 EDG IJCVS1A 71-10612 EG 272 EPRI NP-7147-SL-V2 1 ELECTRIC CO 1EDGDO8 OVERCURRENT RELAY 93-27/51-B- EDG A PHASE B TIME- GENERAL EPRI NP-7147-SL-V2 Confirmed 16 1 EDG IJCVS1A 71-10502 EG 272 1EDGAO8 OVERCURRENT RELAY ELECTRIC 93-27/51-B- EDG B PHASE B TIME- GENERAL EPRI NP-7147-SL-V2 Confirmed 17 1 EDG IJCVS1A 71-10602 EG 272 1EDGBO8 OVERCURRENT RELAY ELECTRIC 93-27/51-B- EDG C PHASE B TIME- GENERAL Confirmed 18 EDG IJCVS1A 71-10512 EG 272 EPRI NP-7147-SL-V2 1 ELECTRIC 1EDGCO8 OVERCURRENT RELAY 93-27/51-B- EDG D PHASE B TIME- GENERAL Confirmed 19 EDG IJCV51A 71-10612 EG 272 EPRI NP-7147-SL-V2 1 ELECTRIC 1EDGDO8 OVERCURRENT RELAY 93-27/51-C- EDG A PHASE CTIME- GENERAL 272 EPRI NP-7147-SL-V2 Confirmed 20 1 EDG IJCV51A 71-10502 EG 1EDGAO8 OVERCURRENT RELAY ELECTRIC Page 33 of 53

For information Only JarnesA. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation No. Unit System Relay ID Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result 93-27/51-C- EDG B PHASE C TIME- GENERAL 21 1 EDG IJCV51A 71-10602 EG 272 EPRI NP-7147-SL-V2 Confirmed 1EDGBO8 OVERCURRENT RELAY ELECTRIC 93-27/51-C- EDG C PHASE CTIME- GENERAL Confirmed 22 1 EDG IJCV51A 71-10512 EG 272 EPRI NP-7147-SL-V2 1EDGCO8 OVERCURRENT RELAY ELECTRIC 93-27/51-C- EDG D PHASE C TIME- GENERAL 23 1 EDG IJCV51A 71-10612 EG 272 EPRI NP-7147-SL-V2 Confirmed 1EDGDOB OVERCURRENT RELAY ELECTRIC 93-32/SI- EDGA HIGH CIRC CURRENT 272 EPRI TR-105988-V2 Confirmed 24 1 EDG SQUARE D KPD-13 93EGP-A EG 1EDGA12 SEAL IN RELAY 93-32/SI- EDG B HIGH CIRC CURRENT EG 272 EPRI TR-105988-V2 Confirmed 25 1 EDG SQUARE D KPD-13 93EGP-B 1EDGB12 SEAL IN RELAY 93-32/SI- EDGC HIGH CIRC CURRENT EG 272 EPRI TR-1059$8-V2 Confirmed 26 1 EDG SQUARE D KPD-13 93EGP-C 1EDGC12 SEAL IN RELAY 93-32/SI- EDGD HIGH CIRC CURRENT EG 272 EPRI TR-105988-V2 Confirmed 27 1 EDG SQUARE D KPD-13 93EGP-D 1EDGD12 SEAL IN RELAY 93 EDG A HIGH CIRC CURRENT GENERAL 28 1 EDG ICWS1A 93EGP-A EG 272 SQURTS Confirmed 1EDGAO9 POWER RELAY ELECTRIC 93 EDG B HIGH CIRC CURRENT GENERAL Confirmed 29 1 EDG ICW51A 93EGP-B EG 272 SQURTS 1EDGBO9 POWER RELAY ELECTRIC CO 93 EDG C HIGH CIRC CURRENT GENERAL Confirmed 30 1 EDG ICWS1A 93EGP-C EG 272 SQURTS 1EDGCO9 POWER RELAY ELECTRIC CO 93 EDG D HIGH CIRC CURRENT GENERAL Confirmed 31 1 EDG ICW51A 93EGP-D EG 272 SQURTS 1EDGDO9 POWER RELAY ELECTRIC CO 93-32X1- HIGH CIRCULATING CURRENT EG 272 EPRI TR-105988-V2 Confirmed 32 1 EDG SQUARE D KPD-13 93ECP-A 1EDGA12 SHUTDOWN RELAY EDG B HIGH CIRCULATING 93-32X1- 93ECP-B EG 272 EPRI TR-105988-V2 Confirmed 33 1 EDG CURRENT ENG SHUTDOWN SQUARE D KPD-13 1EDGB12 RELAY Page 34 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Relay ID Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit System EDG C HIGH CIRCULATING 93-32X1- 93ECP-C EG 272 EPRI TR-105988-V2 Confirmed 34 1 EDG CURRENT ENGINE SQUARE D KPD43 1EDGC12 SHUTDOWN RELAY EDG 0 HIGH CIRCULATING 3 2X 93ECP-D EG 272 EPRI TR-105988-V2 Confirmed 35 1 EDG CURRENT ENG SHUTDOWN SQUARE D KPD-13 1EDGD12 RELAY 93-40X1- KPD-13 93ECP-B EG 272 EPRI TR-105988-V2 Confirmed 36 1 EDG EDG A FIELD FAILURE RELAY SQUARE D 1EDGA12 37 EDG B FIELD FAILURE RELAY SQUARE D KPD-13 93ECP-B EG 272 EPRI TR-105988-V2 Confirmed 1 EDG 93-40X1- 93ECP-C EG 272 EPRI TR-1059$8-V2 Confirmed 38 1 EDG EDG C FIELD FAILURE RELAY SQUARE D KPD-13 1EDGC12 93-40X1- KPD-13 93ECP-D EG 272 EPRI TR-105988-V2 Confirmed 39 1 EDG EDG D FIELD FAILURE RELAY SQUARE D 1EDGD1 2 EDG A OUTPUT BREAKER 93 AMERACE Confirmed 40 EDG VOLTAGE CHECK CLOSE E7O12PB 71-10502 EG 272 EPRI NP-7147-SL 1 CORP 1EDGAD1 INTERLOCK RELAY EDG A & EDG C OUTPUT 93 AMERACE EPRI NP-7147-SL Confirmed 41 EDG BREAKERS CLOSE INTERLOCK E7O12PB 71-10504 EG 272 1 CORP 1EDGAO2 RELAY 93 EDG A HIGH CIRCULATING AMERACE EPRI NP-7147-SL Confirmed EDG E7O12PC 71-10502 EG 272 1EDGA12 CURRENT INTERLOCK RELAY CORP EDG B OUTPUT BREAKER 93 AMERACE EPRI NP-7147-SL Confirmed 43 EDG VOLTAGE CHECK CLOSE E7012PB004 71-10602 EG 272 1 CORP 1EDGBO1 INTERLOCK RELAY EDG B & EDG D OUTPUT 93 AMERACE E7O12PB Confirmed 44 EDG BREAKERCLOSEINTERLOCK 71-10604 EG 272 EPRINP-7147-SL 1 CORP E7012PB004 1EDGBO2 RELAY Page 35 of 53

For Information Only James A. FitzPatrick: 50.54(f) NIlE 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation System Relay ID Component Description Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit 93 EDG B HIGH CIRCULATING AMERACE Confirmed 45 1 EDG E7012PC004 71-10602 EG 272 EPRI NP-7147-SL 1EDGB12 CURRENT INTERLOCK RELAY CORP EDG C OUTPUT BREAKER 93 AMERACE Confirmed 46 1 EDG VOLTAGE CHECK CLOSE E7O12PB 71-10512 EG 272 EPRI NP-7147-SL 1EDGCO1 CORP INTERLOCK RELAY 93 EDG C HIGH CIRCULATING AMERACE Confirmed 47 EDG E7O12PC 71-10512 EG 272 EPRI NP-7147-SL 1 CORP 1EDGC12 CURRENT INTERLOCK RELAY EDG D OUTPUT BREAKER 93 AMERACE Confirmed 48 1 EDG VOLTAGE CHECK CLOSE E7O12PB 71-10612 EG 272 EPRI NP-7147-SL 1EDGDO1 CORP INTERLOCK RELAY 93 EDG 0 HIGH CIRCULATING AMERACE Confirmed 49 EDG E7O12PC 71-10612 EG 272 EPRI NP-7147-SL 1 CORP 1EDGD12 CURRENT INTERLOCKS RELAY 93-62X- BUS1O500EDGA&EDGC GENERAL Confirmed 50 EDG HLA 71-10504 EG 272 EPRI NP-7147-SL 1

1EDGAO2 TIE AUX TIME DELAY RELAY ELECTRIC CO 93-62X- BUS 10600 EDG B & EDG D GENERAL EPRI NP-7147-SL Confirmed 51 1 EDG HLA 71-10604 EG 272 1EDGBO2 TIE AUX TIME DELAY RELAY ELECTRIC CO FORCE PARALLEL LOSS OF 125VDC CONTROL VOLTAGE CR2811 EPRI TR-105988-V2 Confirmed GENERAL RELAY 93-74C- ELECTRIC CO 52 1 EDG 93FPAC EG 272 1EDGA13 Note: Relay is normally 8501XUDO26V63Y4 SQUARE D EPRI 3002002997 Confirmed energized and Contact is 14 normally open (NE/NO)

FORCE PARALLEL LOSS OF 125VDC CONTROL VOLTAGE CR2811 EPRI TR405988-V2 Confirmed GENERAL RELAY ELECTRIC CO 93-74C- 93FPBD EG 272 53 1 EDG 1EDGB13 Note: Relay is normally 8501XUD026V63Y4 SQUARE D EPRI 3002002997 Confirmed energized and Contact is ;4 normally open (NE/NO)

Page 36 of 53

For Information Only James A. FitzPatrick: 50.54(1) NIlE 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack? Evaluation Relay ID Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit System 93-86X1- KPD-13 93ECP-A EG 272 EPRI TR-105988-V2 Confirmed 54 1 EDG GEN FAULT RELAY SQUARE D 1EDGA12 93-86X1- KPD-13 93ECP-B EG 272 EPRI TR-105988-V2 Confirmed 55 1 EDG EDG B GEN FAULT RELAY SQUARE D 1EDGB12 56 EDG C GEN PROJ RELAY SQUARE D KPD-13 93ECP-C EG 272 EPRI TR-105988-V2 Confirmed 1 EDG 93-86X1- KPD-13 93ECP-D EG 272 EPRI TR-105988-V2 Confirmed 57 1 EDG EDG D GEN PROTECT RELAY SQUARE D 1EDGD12 93-87-A- EDG A PHASE A HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier 58 EDG CFD12B 71-10502 EG 272 1

1EDGAO7 DIFFERENTIAL RELAY ELECTRIC CO 93-87-A- EDG B PHASE A HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier 59 EDG CFD12B 71-10602 EG 272 1 ELECTRIC CO 1EDGBO7 DIFFERENTIAL RELAY 93-87-A- EDG C PHASE A HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier 60 EDG CFD12B 71-10512 EG 272 1 ELECTRIC CO 1EDGCO7 DIFFERENTIAL RELAY 93-87-A- EDG D PHASE A HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier 61 EDG CFD12B 71-10612 EG 272 1 ELECTRIC CO 1EDGDO7 DIFFERENTIAL RELAY 93-87-B- EDG A PHASE B HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier 62 EDG CFD12B 71-10502 EG 272 1 ELECTRIC 1EDGAO7 DIFFERENTIAL RELAY 93-87-B- EDG B PHASE B HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier 63 EDG CFD12B 71-10602 EG 272 1 ELECTRIC 1EDGBO7 DIFFERENTIAL RELAY 93-87-B- EDG C PHASE B HIGHSPEED GENERAL Outlier 64 EDG CFD12B 71-10512 EG 272 EPRI TR-105988-V2 1 ELECTRIC 1EDGCO7 DIFFERENTIAL RELAY 93-87-B- EDG D PHASE B HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier

1 EDG CFD12B 71-10612 EG 272 1EDGDO7 DIFFERENTIAL RELAY ELECTRIC 93-87-C- EDG A PHASE C HIGH-SPEED GENERAL EPRI TR-105988-V2 Outlier 66 EDG CFD12B 71-10502 EG 272 1 ELECTRIC 1EDGAO7 DIFFERENTIAL RELAY Page 37 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack? Evaluation Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit System Relay ID 93-87-C- EDG B PHASE C HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier 67 EDG CFD12B 71-10602 EG 272 1 ELECTRIC 1EDGBO7 DIFFERENTIALRELAY 93-87-C- EDG C PHASE C HIGHSPEED GENERAL EPRI TR-105988-V2 Outlier 68 EDG CFD12B 71-10512 EG 272 1 ELECTRIC 1EDGCO7 DIFFERENTIAL RELAY 93-87-C- EDG D PHASE C HIGHSPEED GENERAL Outlier 69 CFD12B 71-10612 EG 272 EPRI TR-105988-V2 1 EDG ELECTRIC 1EDGDO7 DIFFERENTIAL RELAY 8501XUD00408V63 93-ESR200- EDG A ENG SPEED SENSING 93ECP-A EG 272 EPRI 3002002997 Confirmed 7D 1 EDG SQUARE D per EC 16492 (WO 1EDGA12 RELAY 51203289) 8501XUD00408V63 93-ESR200- EDG B ENG SPEED SENSING 93ECP-B EG 272 EPRI 3002002997 Confirmed 71 1 EDG SQUARE D per EC 13522 (WO 1EDGB12 RELAY 51204938) 8501XUD00408V63 93-ESR200- EDG C ENG SPEED SENSING 93ECP-C EG 272 EPR13002002997 Confirmed 72 1 EDG SQUARED perECl4796(WO 1EDGC12 RELAY 51192196) 8501XUD00408V63 93-ESR200- EDG D ENGINE SPEED 93ECP-D EG 272 EPRI 3002002997 Confirmed 73 1 EDG SQUARE D per EC 16218 (WO 1EDGD12 SENSING RELAY 51201711)

CR2811 EPRITR-105988-V2 Confirmed G ENERAL 93-ESR400- EDG A ENG SPEED SENSING ELECTRIC CO 74 93ECP-A EG 272 1 EDG 1EDGA12 RELAY 8501XUD00804V63 SQUARE D EPRI 3002002997 Confirmed Y414 EPRITR-105988-V2 Confirmed GENERAL CR2811 93-ESR400- EDG B ENG SPEED SENSING ELECTRIC CO 75 EDG 93ECP-B EG 272 1

1EDGB12 RELAY SQUARE D 8501XUD00408V63 EPRI 3002002997 Confirmed Page 38 o153

For Information Only James A. FitzPatrick: 50.54(1) NIlE 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Unit System Relay ID Component Description1 Manufacturer Model Panel Bldg Elev Basis for Capacity Result No.

CR2811 EPRITR-105988-V2 Confirmed G ENERAL 93-ESR400- EDG C ENG SPEED SENSING ELECTRIC CO 76 1 EDG 93ECP-C EG 272 1EDGC12 RELAY 8501XUD00804V63 SQUARE D EPRI 3002002997 Confirmed Y414 GENERAL CR2811 EPRITR-105988-V2 Confirmed 93-ESR400- EDG D ENG SPEED SENSING ELECTRIC CO 77 1 EDG 93ECP-D EG 272 1EDGD12 RELAY 8501XUD00408V63 EPRI 3002002997 Confirmed SQUARE D 8501XU D00408V63 93-ESR4O- EDG A ENG SPEED SENSING 93ECP-A EG 272 EPRI 3002002997 Confirmed 78 1 EDG SQUARE D per EC 16492 (WO 1EDGA12 RELAY 51203288) 8501XU D00408V63 93-ESR4O- EDG B ENG SPEED SENSING EG 272 EPR13002002997 Confirmed 79 1 EDG SQUARED perECl3522(WO 93ECP-B 1EDGB12 RELAY 1204937) 8501XUD00408V63 93-ESR4O- EDG C ENG SPEED SENSING EG 272 EPRI 3002002997 Confirmed 80 1 EDG SQUARE D per EC 14796 tWO 93ECP-C 1EDGC12 RELAY 51192197) 8501xu D00408V63 93-ESR4O- EDG D ENG SPEED SENSING 93ECP-D EG 272 EPRI 3002002997 Confirmed 81 1 EDG SQUARE D per EC 16218 (WO 1EDGD12 RELAY 51201710)

EDG A ELECTRONIC SPEED WOODWARD JAF Documentation 82 93E5S-A SST-2400A-8 93ECSP-A EG 284 Confirmed 1 EDG [19]

SWITCH GOVERNOR EDG B ELECTRONIC SPEED WOODWARD JAF Documentation 83 93ESS-B SST-2400A-8 93ECSP-B EG 272 Confirmed 1 EDG [19]

SWITCH GOVERNOR EDG C ELECTRONIC SPEED JAF Documentation 84 93ES5-C DYNALCO CORP SST-2400A-8 93ECSP-C EG 272 Confirmed 1 EDG [19]

SWITCH EDG D ELECTRONIC SPEED WOODWARD JAF Documentation

$5 EDG 93ESS-D SST-2400A-$ 93ECSP-D EG 272 Confirmed 1 [19]

SWITCH GOVERNOR Page 39 of 53

For Information Ony James A. FitzPatrick: 50.54(f) NTIF 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation System Relay ID Component Description Manufacturer Model Panel Bldg Elev Basis for Capacity Result No. Unit 93FTS1A- 93FPAC EG 272 EPRI TR-105988-V2 Confirmed 1 EDG TIE A/C FAIL TO SYNCH RELAY SQUARE D KPD-13 1EDGA13 93FTSA- 93FPBD EG 272 EPRI TR-1059$2-V2 Confirmed 87 1 EDG TIE B/D FAIL TO SYNCH RELAY SQUARE D KPD43 1EDGB13 88 EDG TIE A/C FAIL TO SYNCH RELAY SQUARE D KPD-13 93FPAC EG 272 EPRI TR-10598$-V2 Confirmed 1

93FT52A- EG 272 EPRI TR-1059$8-V2 Confirmed 89 1 EDG TIE BID FAIL TO SYNCH RELAY SQUARE D KPD-13 93FPBD 1EDGB13

$5O1XU D00408V63 93-Kb- EDG A ENG FAILURE AND 272 EPR13002002997 Confirmed 90 1 EDG SQUARED perECl6492(WO 93ECP-A EG 1EDGAO1 GEN FIELD SHORTED RELAY 51203292) 8501XU D0040$V63 93-Kb- EDG B ENG FAILURE AND EG 272 EPRI 3002002997 Confirmed 91 1 EDG SQUARE D per EC 13662 (WO 93ECP-B 1EDGBO1 GEN FIELD SHORTED RELAY 1204941) 8501XU D00408V63 93-Kb- EDG C ENG FAILURE AND GEN EG 272 EPRI 3002002997 Confirmed 92 1 EDG SQUARE D per EC 14318 (WO 93ECP-C 1EDGCO1 FIELD SHORTED RELAY 51192205) 85O1XU D00408V63 93-KiD- EDG D ENG FAILURE AND EG 272 EPRI 3002002997 Confirmed 93 1 EDG SQUARE D per EC 16218 (WO 93ECP-D 1EDGDO1 GEN FIELD SHORTED RELAY 51201714)

ES150224 (ES150224 is a combination of two Allen Bradley relays: models 93-K1- ENGINE 700DC-PL and JAF Documentation 94 EDGAAUTOSTARTRELAY 93ECP-A EG 272 Confirmed 1 EDG 700DC-PK; the [201 1EDGA12 SYSTEMS, INC.

pertinent chatter for this analysis is of the reset coil/contacts.)

Page4O of 53

For information Only James A. FitzPatrick: 50.54(f) NIlE 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit System Relay ID 93-Ki- ENGINE JAF Documentation E5I50224 93ECP-B EG 272 Confirmed

1 EDG EDG B AUTO START RELAY [20]

1EDGB12 SYSTEMS, INC.

93-Ki- ENGINE JAF Documentation E5I50224 93ECP-C EG 272 Confirmed

1 EDG EDG C AUTO START RELAY [20]

1EDGC12 SYSTEMS, INC.

93-Ki- ENGINE JAF Documentation ES150224 93ECP-D EG 272 Confirmed 97 1 EDG EDG D AUTO START RELAY [20]

1EDGD12 SYSTEMS, INC.

DIESEL GEN EXCITER-WESTINGHOUS 272 EPRI NP-5223-SLR1 Confirmed 98 EDG 93-K1VR-A REGULATOR VOLTAGE MD11O 93EGP-A EG 1 E SHUTDOWN RELAY DIESEL GEN EXCITER-WESTINGHOUS EG 272 EPRI NP-5223-SLR1 Confirmed 99 1 EDG 93-K1VR-B REGULATOR VOLTAGE MD11O 93EGP-B E

SHUTDOWN RELAY DIESEL GEN EXCITER-WESTINGHOUS EPRI NP-5223-SLR1 Confirmed 100 93-K1VR-C REGULATOR VOLTAGE MD11O 93EGP-C EG 272 1 EDG E SHUTDOWN RELAY DIESEL GEN EXCITER-WESTINGHOUS 272 EPRI NP-5223-SLR1 Confirmed 101 EDG 93-K1VR-D REGULATOR VOLTAGE MD11O 93EGP-D EG 1 E SHUTDOWN RELAY DIESEL GEN EXCITER- POTTER & EPRI 3002002997 Confirmed 102 93-K3VR-A PRD11AYO 93EGP-A EG 272 1 EDG BRUMFIELD REGULATOR SENSING RELAY DIESEL GEN EXCITER- POTTER & 272 EPRI 3002002997 Confirmed

- 1 EDG 93-K3VR-B PRD11AYO 93EGP-B EG REGULATOR SENSING RELAY BRUMFIELD PRD11 per Mod Dl-DIESEL GEN EXCITER- POTTER & EPRI 3002002997 Confirmed 104 EDG 93-K3VR-C 98-023 (WO 93EGP-C EG 272 1 BRUMFIELD REGULATOR SENSING RELAY 52161266)

DIESEL GEN EXCITER- POTTER & EPRI 3002002997 Confirmed 93-K3VR-D PRD11AYO 93EGP-D EG 272

- ;- EDG BRUMFIELD REGULATOR SENSING RELAY DIESEL GEN EXCITER- POTTER & 272 EPRI 3002002997 Confirmed

;

- EDG 93-K4VR-A PRD11DYO 93EGP-A EG REGULATOR RESET RELAY BRUMFIELD Page4l of 53

For information Only James A. FitzPatrick: 50.54(f) NIlE 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Relay ID Component Description Manufacturer Model Panel Bldg Elev Basis for Capacity Result No. Unit System DIESEL GEN EXCITER- POTTER & Confirmed 107 1 EDG 93-K4VR-B PRD11DYO 93EGP-B EG 272 EPRI3002002997 REGULATOR RESET RELAY BRUMFIELD PRD11 per mod Dl-DIESEL GEN EXCITER- POTTER & Confirmed 108 1 EDG 93-K4VR-C 98-023 (WO 93EGP-C EG 272 EPRI 3002002997 REGULATOR RESET RELAY BRUMFIELD 52161266)

DIESEL GEN EXCITER- POTTER & Confirmed 109 1 EDG 93-K4VR-D PRD11DYO 93EGP-D EG 272 EPRI 3002002997 REGULATOR RESET RELAY BRUMFIELD CR2811 GENERAL EPRI TR-105988-V2 Confirmed ELECTRIC CO 93-Ks- EDG-A AND C TIE BKR 10504 EG 272 110 1 EDG 8501XUD031V63 93FPAC EPRI 3002002997 1EDGAO2 CLOSING CONTROL RELAY SQUARE D Confirmed 8501XU D031V63Y4 EPRI 3002002997 Confirmed SQUARE D 14 CR2811 EPRI TR-105988-V2 Confirmed GENERAL ELECTRIC CO 93-K8- EDG B-D TIE BKR 71-10604 93FPBD EG 272 EPRI 3002002997 Confirmed 111 1 EDG 85D1XUD031V63 1EDGBO2 CLOSE CONTROL RELAY SQUARE D 8501XU D031V63Y4 SQUARE D EPRI 3002002997 Confirmed 14 CR2811 EPRITR-105988-V2 Confirmed G ENERAL ELECTRIC CO 93-K9- EDG-A AND C TIE BKR 10504 EG 272 EPRI 3002002997 Confirmed 112 1 EDG 8501XUD031V63 93FPAC 1EDGAO2 OPENING CONTROL RELAY SQUARE D 8501XU D031V63Y4 SQUARE D EPRI 3002002997 Confirmed 14 Page42 of 53

For Informafion Only JarnesA.FitzPatrick: 50.54(f) NIlE 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit System Relay ID CR2811 EPRITR-105988-V2 Confirmed GENERAL ELECTRIC CO 93-K9- EDG B-D TIE BKR 71-10604 93FPBD EG 272 EPRI 3002002997 Confirmed 113 1 EDG 8501XUD031V63 1EDGBO2 OPEN CONTROL RELAY SQUARE D 8501XUD031V63Y4 SQUARE D EPRI 3002002997 Confirmed 14 CR2811 EPRITR-105988-V2 Confirmed GENERAL 93SDR- ELECTRIC CO 114 EDG EDG A SHUTDOWN RELAY 93ECP-A EG 272 1

1EDGA12 8501XU D00705V63 SQUARE D EPRI 3002002997 Confirmed Y414 CR2811 EPRITR-105988-V2 Confirmed GENERAL 935DR- ELECTRIC CO 115 EDG B SHUTDOWN RELAY 93ECP-B EG 272 1 EDG 1EDGB12 8501XU D00705V63 SQUARE D EPRI 3002002997 Confirmed Y414 935DR- 8501XU000705V63 Confirmed 116 EDG C SHUTDOWN RELAY SQUARE 0 93ECP-C EG 272 EPRI 3002002997 1 EDG Y414 1EDGC12 CR2811 EPRITR-105988-V2 Confirmed GENERAL 935DR- ELECTRIC CO 117 EDG EDG D SHUTDOWN RELAY 93ECP-D EG 272 1

1EDGD12 8501XUD00705V63 SQUARE D EPRI 3002002997 Confirmed Y414 93-SDRX- EDGA SHUTDOWN AUXILIARY 93ECP-A EG 272 EPRI TR-105988-V2 Confirmed 118 1 EDG SQUARE D KPD-13 1EDGA12 RELAY 93-SDRX- EDGB SHUTDOWN AUXILIARY 93ECP-B EG 272 EPRI TR-105988-V2 Confirmed 119 1 EDG SQUARE D KPD-13 1EDGB12 RELAY 93-SDRX- EDGC SHUTDOWN AUXILIARY 93ECP-C EG 272 EPRI TR405988-V2 Confirmed 120 1 EDG SQUARE D KPD-13 1EDGC12 RELAY Page43 o153

For InformatIon Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No. Unit System Relay ID Component Description 93-SDRX- EDGD SHUTDOWN AUXILIARY 93ECP-D EG 272 EPRI TR-105988-V2 Confirmed 121 1 EDG SQUARE D KPD-13 1EDGD12 RELAY 93TD10- AMERACE 272 EPRI NP-7147-SL Confirmed 122 EDG EDG A LOSS OF FIELD RELAY E7O12PD 93ECP-A EG 1 CORP 1EDGA12 93TD10- AMERACE EPRI NP-7147-SL Confirmed 123 EDG B LOSS OF FIELD RELAY E7012PD004 93ECP-B EG 272 1 EDG CORP 1EDGB12 93TD10- AMERACE EPRI NP-7147-SL Confirmed 124 EDG C LOSS OF FIELD RELAY E7O12PD 93ECP-C EG 272 1 EDG CORP 1EDGC12 93TD10- AMERACE 272 EPRI NP-7147-SL Confirmed 125 EDG D LOSS OF FIELD RELAY E7012PD004 93ECP-D EG 1 EDG CORP 1EDGD12 93TD5- EDG A DIESEL FAIL TO START AMERACE 272 EPRI 3002002997 Confirmed 126 E7O14PC 93ECP-A EG 1 EDG CORP 1EDGA12 RELAY 93TD5- EDG B DIESEL FAIL TO START AMERACE 272 EPRI 3002002997 Confirmed 127 E7014PC004 93ECP-B EG 1 EDG CORP 1EDGB12 RELAY 93TDS- EDG C DIESEL FAIL TO START AMERACE 272 EPRI3002002997 Confirmed 128 E7O14PC 93ECP-C EG 1 EDG CORP 1EDGC12 RELAY 93TD5- EDG D DIESEL FAIL TO START AMERACE 272 EPRI 3002002997 Confirmed 129 E7014PC004 93ECP-D EG 1 EDG CORP 1EDGD12 RELAY 93TD6- EDG A ENGINE START BYPASS AMERACE 272 EPRI NP-7147-SL Confirmed 130 E7O12PD 93ECP-A EG 1 EDG CORP 1EDGA12 INTERLOCK RELAY 93TD6- EDG B ENGINE START BYPASS AMERACE EPRI NP-7147-SL Confirmed 131 E7012PD004 93ECP-B EG 272 1 EDG CORP 1EDGB12 INTERLOCK RELAY 93TD6- EDG C ENGINE START BYPASS AMERACE 272 EPRI NP-7147-SL Confirmed 132 E7O12PD 93ECP-C EG 1 EDG 1EDGC12 INTERLOCK RELAY CORP 93TD6- EDG D ENGINE START BYPASS AMERACE EPR13002002997 Confirmed 133 E7014PC004 93ECP-D EG 272 1 EDG CORP 1EDGD12 INTERLOCK RELAY Page44 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTIF2.lSeismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Component Description Manufacturer Model Panel Bldg Elev Basis for Capacity Result No. Unit System Relay ID 93TD8M- EDG A & EDG C FORCE AMERACE Confirmed 134 EDG E7O14PC 93FPAC EG 272 EPR13002002997 1 CORP 1EDGA13 PARALLEL LOGIC RELAY 93TD8M- EDG B & EDG D FORCE AMERACE Confirmed 135 EDG E7O14PC 93FPBD EG 272 EPRI 3002002997 1

1EDGB13 PARALLEL LOGIC RELAY CORP 93TD9M EDG B & EDG D FORCE AMERACE 136 E7O14PC 93FPBD EG 272 EPRI 3002002997 Confirmed 1 EDG PARALLEL LOGIC RELAY CORP

-1EDGB13 93TD9M- FOG A & EDG C FORCE AMERACE Confirmed 137 EDG E7O14PC 93FPAC EG 272 EPR13002002997 1 CORP 1EDGA13 PARALLEL LOGIC RELAY CR2811 EPRITR-105988-V2 Confirmed GENERAL 931D9X- EDG A AND C FORCE ELECTRIC CO 138 1 EDG 93FPAC EG 272 1EDGA13 PARALLEL LOGIC RELAY 8501XUD00705V63 SQUARE D EPRI 3002002997 Confirmed Y414 EPRI TR-105988-V2 Confirmed GENERAL CR2811 93TD9X- EDG B AND D FORCE ELECTRIC CO 139 1 EDG 93FPBD EG 272 1EDGB13 PARALLEL LOGIC RELAY SQUARE D 85O1XUDO EPRI 3002002997 Confirmed SQUARE D 9025 SQURTS Confirmed ENGINE 9544836 EPRI NP-5223-SLR1 Confirmed EDG A JACKET WATER HIGH N/A EG 272 140 1 EDG 93T5-3A SYSTEMS, INC 8/12/2009 TEMP SHUTDOWN SWITCH ENGINE E5150415 EPRI NP-5223-SLR1 SYSTEMS, INC 12/10/2010 Confirmed SQUARE D 9025 SQURTS Confirmed EDG B JACKET WATER HIGH N/A EG 272 141 1 EDG 93T5-3B TEMP SHUTDOWN SWITCH ENGINE 9544836 EPRI NP-5223-SLR1 Confirmed SYSTEMS, INC 8/12/2009 Page45 of 53

For nforrnation Only James A. FitzPatrick: 50.54(f) NIlE 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack/ Evaluation No. Unit System Relay ID Component Description Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result SQUARE D 9025 SQURTS Confirmed EDG C JACKET WATER HIGH 272 142 1 EDG 93TS-3C N/A EG TEMP SHUTDOWN SWITCH ENGINE 9544836 EPRI NP-5223-SLR1 Confirmed SYSTEMS, INC 8/12/2009 SQUARE 0 9025 SQURTS Confirmed EDG 0 JACKET WATER HIGH 143 1 EDG 93TS-3D N/A EG 272 TEMP SHUTDOWN SWITCH ENGINE 9544836 EPRI NP-5223-SLR1 Confirmed SYSTEMS, INC 8/12/2009 RCIC STEAM LEAK DETECTION GENERAL 144 1 RCIC 02F-K3A 12HGA11J7O 09-21 CR 300 EPRI 3002002997 Confirmed HIGH TEMP TRIP RELAY ELECTRIC CO RCIC STEAM LEAK DETECTION GENERAL

- RCIC 02F-K3B 12HGA11J7O 09-21 CR 300 EPRI 3002002997 Confirmed HIGH TEMP TRIP RELAY ELECTRIC CO AGASTAT 146 1 RCIC 13A-K113A LOGICRELAY RELAY EGPBC2004003 09-95 RR 284 EPR13002002997 Confirmed (AM ERACE)

AGASTAT 147 1 RCIC 13A-K13B LOGICRELAY RELAY EGPBC2004003 09-96 RR 284 EPR13002002997 Confirmed (AM ERACE)

AGASTAT 148 1 RCIC 13A-K114A LOGIC RELAY RELAY EGPBC2004003 09-95 RR 284 EPRI 3002002997 Confirmed (AM ERACE)

AGASTAT 149 1 RCIC 13A-K114B LOGIC RELAY RELAY EGPBC2004003 09-96 RR 284 EPRI 3002002997 Confirmed (AMERACE)

AGASTAT 150 1 RCIC 13A-K115A LOGIC RELAY RELAY EGPBC2004003 09-95 RR 284 EPRI 3002002997 Confirmed (AM ERACE)

AGASTAT 151 1 RCIC 13A-K115B LOGICRELAY RELAY EGPBC2004003 09-96 RR 284 EPR13002002997 Confirmed (AM ERACE)

Page46 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation Unit System Relay ID Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result No.

AGASTAT 152 RCIC 13A-K116A LOGICRELAY RELAY EGPBC2004003 09-95 RR 284 EPR13002002997 Confirmed 1

(AMERACE)

AGASTAT 153 RCIC 13A-K116B LOGIC RELAY RELAY EGPBC2004003 09-96 RR 284 EPRI 3002002997 Confirmed 1

(AMERACE)

GENERAL Confirmed 154 1 RCIC 13A-K12 LOGIC RELAY 12HGA11A52F 09-30 RR 284 EPRI NP-7147-SL ELECTRIC CO AGASTAT 155 13A-K125A LOGICRELAY RELAY EGPBC2004003 09-95 RR 284 EPRl3002002997 Confirmed 1 RCIC (AM ERACE)

AGASTAT 156 13A-K125B LOGICRELAY RELAY EGPBC2004003 09-96 RR 284 EPR13002002997 Confirmed 1 RCIC (AMERACE)

AGASTAT 157 13A-K126A LOGIC RELAY RELAY EGPBC2004003 09-95 RR 284 EPRI 3002002997 Confirmed 1 RCIC (AMERACE)

AGASTAT 158 LOGIC RELAY RELAY EGPBC2004003 09-96 RR 284 EPRI 3002002997 Confirmed 1 RCIC 13A-K126B (AM ERACE) 159 13A-K15 LOGIC RELAY 12HFA151A2F 09-30 RR 284 EPRI 3002002997 Confirmed 1 RCIC ELECTrnCCO GENERAL EPRI NP-7147-SL Confirmed 160 1 RCIC 13A-K29 LOGIC RELAY 12HGA11A52F 09-30 RR 284 ELECTRIC CO GENERAL Confirmed 161 1 RCIC 13A-K32 LOGIC RELAY 12HGA11A52F 09-33 RR 284 EPRI NP7147-SL ELECTRIC CO G ENERAL Confirmed 162 RCIC 13A-K33 LOGIC RELAY 12HFA1S1A2F 09-33 RR 284 EPRI 3002002997 1 ELECTRIC CO Page4Z of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Component Enclosure Component Evaluation Cab/Rack! Evaluation No. Unit System Relay ID Component Description1 Manufacturer Model2 Panel Bldg Elev Basis for Capacity Result GENERAL 163 1 RCIC 13A-K39 LOGIC RELAY 12HGA11A52F 09-33 RR 284 EPRI NP-7147-SL Confirmed ELECTRIC CO GENERAL Confirmed 164 1 RCIC 13A-K49 LOGIC RELAY 1C2800-1607AD 09-30 RR 284 EPRI NP-5223-SLR1 ELECTRIC GENERAL 165 RCIC 13A-K6 LOGIC RELAY 12HGA11A52F 09-30 RR 284 EPRI NP-7147-SL Confirmed 1 ELECTRIC CO G ENERAL Confirmed 166 1 RCIC 13A-K7 LOGIC RELAY 12HGA11A52F 09-30 RR 284 EPRI NP-7147-SL ELECTRIC CO GENERAL Confirmed 167 1 RCIC 13A-K8 LOGIC RELAY 12HGA11A52F 09-30 RR 284 EPRI NP-7147-SL ELECTRIC CO RCIC PUMP INLET LOW PRESS STATIC-O-RING 54N6-B118-M9-16$ RCIC 13PS-67A 25-5$ RB 242 SQURTS Confirmed 1

SWITCH (SOR) C1A-JJUNQ RCIC TURB EXH DISCH TO STATIC-O-RING 6N6-B3-U$-C1A-169 RCIC 13P5-72A 25-5$ RB 242 SQURTS Confirmed 1

SUPPR POOL PRESS SWITCH (SOR) JJHNQ RCIC TURB EXH DISCH TO STATIC-O-RING 6N6-B3-U$-C1A-170 RCIC 13P5-72B 25-58 RB 242 SQURTS Confirmed 1

SUPPR POOL PRESS SWITCH (SOR) JJTTNQ RCIC TURB EXH RUPTURE STATIC-O-RING 4N6-B5-NX-C1A-171 RCIC 13PS-7$A 25-5$ RB 242 SQURTS Confirmed 1 iiUX6 DISC PRESS SWITCH (SOR)

RCIC TURB EXH RUPTURE STATIC-O-RING 4N6-B5-NX-C1A-172 13P5-7$B 25-5$ RB 242 SQURTS Confirmed 1 RCIC JJUX6 DISC PRESS SWITCH (SOR)

RCIC TURB EXH RUPTURE STATIC-O-RING 4N6B5-NX-C1A-173 13PS-7$C 25-5$ RB 242 SQURTS Confirmed 1 RCIC JJTTX6 DISC PRESS SWITCH (SOR)

RCIC TURB EXH RUPTURE STATIC-O-RING 4N6-B5-NX-C1A-174 RCIC 13PS-7$D 25-5$ RB 242 SQURTS Confirmed 1 JJTTX6 DISC PRESS SWITCH (SOR)

Page 48 of 53

For Information Only James A. FitzPatrick: 50.54(1) NTTF 2.1 Seismic High Frequency Confirmation Table B-2: Reactor Coolant Leak Path Valve Identification for High Frequency Confirmation RELAY SYSTEM VALVE DESCRIPTION FOR HFC HPCI 23M0V-15 HPCI Turbine Steam Supply Inboard Containment Isolation Valve NONE HPCI 23M0V-16 HPCI Turbine Steam Supply Outboard Containment Isolation Valve NONE HPCI 23M0V-60 HPCI Turbine Steam Supply Outboard Containment Isolation Bypass Valve NONE RCIC 13MOV-15 RCIC Steam Supply Inboard Containment Isolation Valve NONE RCIC 13MOV-16 RCIC Steam Supply Outboard Containment Isolation Valve NONE CS 1450V-13A CS Reactor Isolation Testable Check Valve NONE CS 4AOV-13A CS Reactor Isolation Testable Check Valve N/A CS 14S0V43B CS Reactor Isolation Testable Check Valve NONE CS 14AOV-13B CS Reactor Isolation Testable Check Valve N/A RHR 1OSOV-62A RHR Testable LPCI Check Valve NONE RHR 1OAOV-6$A RHR Testable LPCI Check Valve N/A RHR 1OSOV-68B RHR Testable LPCI Check Valve NONE RHR 1OAOV-68B RHR Testable LPCI Check Valve N/A RHR 1OMOV-18 RHR Shutdown Cooling Inboard Isolation Valve NONE RHR 1OMOV-17 RHR Shutdown Cooling Outboard Isolation Valve NONE SLC 1SLC-17 Standby Liquid Control Inboard Isolation Check Valve N/A RWCU 12MOV-15 RWCU suction Inboard Containment Isolation Valve NONE RWCU 12MOV-18 RWCU suction Outboard Containment Isolation Valve NONE SRV/ADS 0250V-71A1 Automatic opening SOV for SRV NONE SRV 0250V-71A2 ManualopeningSOVforSRV NONE SRV O2RV-71A Safety ReliefValve N/A Page49 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTIF 2.1 Seismic High Frequency Confirmation RELAY SYSTEM VALVE DESCRIPTION FOR HFC SRV/ADS 0250V-71B1 Automatic opening SOy for SRV NONE SRV 0250V-71B2 Manual opening SOV for SRV NONE SRV O2RV-71B Safety Relief Valve N/A SRV/ADS 0250V-71C1 Automatic opening SOy for SRV NONE SRV 0250V-71C2 Manual opening SOV for SRV NONE SRV O2RV-71C Safety ReliefValve N/A SRV/ADS O2SOV-71D1 Automatic opening SOV for SRV NONE SRV 0250V-71D2 Manual opening SOV for SRV NONE SRV O2RV-71D Safety Relief Valve N/A SRV/ADS 0250V-71E1 Automatic opening SOV for SRV NONE SRV O2SOV-71E2 Manual opening SOV for SRV NONE SRV O2RV-71E Safety Relief Valve N/A SRV O2SOV-71F1 Automatic opening SOV for SRV NONE SRV 0250V-71F2 Manual opening SOV for SRV NONE SRV O2RV-71F Safety Relief Valve N/A SRV/ADS O2SOV-71G1 Automatic opening SOV for SRV NONE SRV O2SOV-71G2 Manual opening SOV for SRV NONE SRV O2RV-71G Safety Relief Valve N/A SRV/ADS O2SOV-71H1 Automatic opening SOV for SRV NONE SRV 0250V-71H2 Manual opening SOV for SRV NONE SRV O2RV-71H Safety Relief Valve N/A SRV O2SOV-71J1 Automatic opening SOV for SRV NONE Page 50 of 53

For Information Only James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation RELAY VALVE DESCRIPTION FOR HFC SYSTEM Manual opening SOV for SRV NONE SRV O2SOV-71J2 Safety Relief Valve N/A SRV O2RV-71J AutomaticopeningSOVforSRV NONE SRV 0250V-71K1 Manual opening SOy for SRV NONE SRV 0250V-71K2 Safety ReliefValve N/A SRV O2RV-71K Automatic opening SOV for SRV NONE SRV 0250V-71L1 Manual opening SOV for SRV NONE SRV 0250V-71L2 Safety Relief Valve N/A SRV O2RV-71L Feedwater A Line Inboard Isolation Check Valve N/A FW 34FW5-28A Feedwater B Line Inboard Isolation Check Valve N/A EW 34FW5-28B MSIVTestSOV NONE MS 2950V-80A1 MSIV AC Closure SOV NONE MS 2950V-80A2 MSIV DC Closure SOV NONE MS 2950V-80A3 Main Steamline Isolation Valve N/A MS 29A0V-80A MSIV Test SOV NONE MS 29SOV-80B1 MSIV AC Closure SOV NONE MS 2950V-80B2 MS(V DC Closure SOV NONE MS 2950V-80B3 Main Steamline Isolation Valve N/A MS 29A0V-80B MSIV Test SOV NONE MS 29S0V-80C1 MSIV AC Closure SOV NONE MS 2950V-$0C2 MSIV DC Closure SOV NONE MS 2950V-80C3 Main Steamline Isolation Valve N/A MS 29A0V-80C Page5l of 53

For Information Only James A. FitzPatrick: 50.54(f) NIlE 2.1 Seismic High Frequency Confirmation RELAY SYSTEM VALVE DESCRIPTION FOR HFC 29S0V-8OD1 MSIV Test SOV NONE MS MS 2950V-$0D2 MSIV AC Closure SOV NONE MS 2950V-80D3 MSIV DC Closure SOV NONE MS 29A0V-80D Main Steamline Isolation Valve N/A MS 29M0V-74 Main Steamline Drain Inboard Valve 42/0 29M0V-77 Main Steamline Drain Outboard Valve 42/20 MS NB 0250V-17 Reactor Vent Valve SOV NONE O2AOV-17 Reactor Vent Valve N/A NB 0250V48 Reactor Vent Valve SOV NONE NB NB O2AOV-18 Reactor Vent Valve N/A RWR 02-2RWR-13A Mini-Purge Check Valve N/A 02-2RWR-13B Mini-PurgeCheckValve N/A RWR 02-250V-39 Recirculation Pump Sampling Line Inboard Containment Isolation Valve NONE RWR 02-2AOV-39 Recirculation Pump Sampling Line Inboard Containment Isolation Valve N/A RWR RWR 02-250V-40 Recirculation Pump Sampling Line Outboard Containment Isolation Valve NONE 02-2AOV-40 Recirculation Pump Sampling Line Outboard Containment Isolation Valve N/A RWR O3SOV-120 HCU Control Rod Withdrawal Valve NONE CRD O3SOV-122 HCU Control Rod Withdrawal Valve NONE CRD O3SOV-121 HCU Control Rod Insertion Valve NONE CRD 0350V-123 HCU Control Rod Insertion Valve NONE CRD 0350V-117 HCU Control Rod Scram Valve NONE CRD O3SOV-118 HCU Control Rod Scram Valve NONE CRD Page 52 of 53

James A. FitzPatrick: 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation RELAY SYSTEM VALVE DESCRIPTION FOR HFC CRD O3AOV-126 HCU Control Rod Scram Valve N/A CRD 03A0V427 HCU Control Rod Scram Valve N/A CRD O3HCU-138 HCU CRDM Cooling Water Check Valve N/A Page 53 of 53