RC-13-0135, Response to NRC Request for Additional Information License Amendment Request - LAR 13-00705, Technical Specification Change to Extend Integrated Leak Rate Test Frequency to 15 Years

Response to NRC Request for Additional Information License Amendment Request - LAR 13-00705, Technical Specification Change to Extend Integrated Leak Rate Test Frequency to 15 Years

ML13252A239
Person / Time
Site:	Summer
Issue date:	09/05/2013
From:	Gatlin T South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 13-00705, RC-13-0135
Download: ML13252A239 (25)

Text

Thomas D. Gatlin Vice President, Nuclear Operations (803) 345-4342 A SCANA COMPANY September 5, 2013 RC-13-0135 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST - LAR 13-00705 TECHNICAL SPECIFICATION CHANGE TO EXTEND INTEGRATED LEAK RATE TEST FREQUENCY TO 15 YEARS

Reference:

1 SCE&G Letter "License Amendment Request - LAR 13-00705 Technical Specification Change to Extend Integrated Leak Rate Test Frequency to 15 Years," dated April 04, 2013 RC-13-0037 [ML130950121]

2 Robert E. Martin, NRC Senior Project Manager, letter to Thomas D. Gatlin letter dated August 6, 2013, "Request for Additional Information Concerning Integrated Leak Rate Testing (TAC NO. MF1385)," [ML13204A145]

South Carolina Electric & Gas Company (SCE&G), acting for itself and as agent for South Carolina Public Service Authority is submitting this response to a request for additional information (RAI). The Nuclear Regulatory Commission (NRC) requested additional information regarding License Amendment Request LAR 13-00705, "Technical Specification Change to Extend Integrated Leak Rate Test Frequency to 15 Years." SCE&G's response is provided in Enclosure I and Attachment I. In addition to the response to RAIs, SCE&G has included Attachment II, an updated table of Type B and C penetrations to be supplemented in Reference 1 Attachment IV.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Mr. Bruce L. Thompson at (803) 931-5042.

Virgil C. Summer Station. Post Office Box 88 -Jenkinsville, SC -29065. F (803) 941-9776

Document Control Desk CR-13-00705 RC-13-0135 Page 2 of 2 I certify under penalty of perjury that the foregoing is true and correct.

Executed on homas b.-Oatlin BQ/TDG/ts

Enclosure:

I.

SCE&G's Response to Request for Additional Information Attachments:

I.

Leak Rate Test Tables for RAI-2 #1(a and b)

II.

Updated Table for Type B and C Penetrations in LAR 13-00705 Attachment IV c:

K. B. Marsh S. A. Byrne J. B. Archie N. S. Carns J. H. Hamilton J. W. Williams W. M. Cherry E. J. Leeds V. M. McCree (w/attachments)

R. E. Martin (w/attachments)

NRC Resident Inspector K. M. Sutton Paulette Ledbetter NSRC RTS (CR-13-00705)

File (813.20)

PRSF (RC-13-0135)

Document Control Desk CR-13-00705 RC-1 3-0135 Enclosure I Page 1 of 11 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT I ENCLOSURE I SCE&G Response to Request for Additional Information

RAI-1

Containment I.

Subsection IWE-1 240, to the American Society of Mechanical Engineers Boiler &

Pressure Vessel Code Section Xl, requires that surface areas likely to experience accelerated degradation and aging require augmented examinations. Describe any identified areas that require performance of augmented inspections in accordance with IWE-1240.

SCE&G Response RAI-1 #1 In addition to the augmented examination for the Moisture Barrier Seal and the containment liner at the Moisture Barrier Seal, the following areas have been identified for detailed visual augmented examination which is performed in accordance with IWE-1240 (further discussed in the response to RAI-2 #2).

The guard pipes that are located around the Residual Heat Removal (RHR) and Spray Piping at penetrations located in the basement of the Auxiliary Building have been exposed to groundwater intrusion at the seismic separation joint between the Reactor Building foundation mat and the Auxiliary Building concrete structure. The groundwater exposure has resulted in degradation of the coating and some corrosion of the exterior of the carbon steel guard pipes over the years. The degradation has been identified and managed under the non-conformance program. Ultrasonic examination has confirmed minimal loss of guard pipe thickness due to corrosion and that the design basis continues to be met. The surfaces have been reworked by prepping and recoating. Due to continued exposure to some groundwater intrusion, the guard pipe inspections remain as augmented examinations. The guard pipes are included in the Type C leak rate testing of the RHR and Spray Piping isolation valve enclosure canisters in the Auxiliary Building and therefore, are not directly impacted by the proposed extension for the Type A leak rate testing.

A location on the interior surface of the outer tendon access gallery reinforced concrete wall has in the past indicated some rust staining at a small shrinkage crack due to groundwater seepage at the crack. The gallery which provides access to the bottom end of the vertical pre-stress tendons is located directly beneath and is tied into the Reactor Building foundation mat. The corrosion was identified and evaluated under the plant nonconformance program and found to have no impact on the structural design of the containment. However, due to the intermittent minor ingress of groundwater, the location remains as an augmented examination although minimal or no change has been observed in the past inspections. Due to the location of this particular augmented examination in the tendon access gallery wall, there is no impact on

Document Control Desk CR-1 3-00705 RC-13-0135 Enclosure I Page 2 of 11 the overall leak tightness capability of containment that is confirmed by Type A leak rate testing.

RAI-2

Mechanical Engineering

1.

In order to assess the implementation of the Type B and Type C local leak rate testing program, the licensee is requested to provide the following:

(a) In the Reference, Attachment V table titled, "VCSNS Failed LLRTs 2003-2012" there are twelve "As Left" Test Types with higher leakage rates than the acceptance criteria. Explain why the "As Left" leakage rates were acceptable.

(b) Attachment V, from the Reference, contains a summary table of local leak rate tests (LLRTs) that did not meet the required acceptance criteria. Describe the causes and corrective actions taken to address the LLRTs that did not demonstrate acceptable performance in accordance with the Containment Leakage Rate Program.

(c) List the length of the test interval for each failed LLRT in the Attachment V table of the Reference. Describe the basis for the length of each failed test interval, as required for the containment leakage rate testing program per the current 10 CFR 50, Appendix J Testing Program Plan using Regulatory Guide (RG) 1.163 (September 1995). In addition, discuss how these intervals will change when NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J" is used.

2.

Consistent with NRC Information Notice 2004-09, "Corrosion of Steel Containment and Containment Liner," discuss any operating experience and evaluation results, regarding the potential for, or presence of, corrosive conditions at the junction of the metal liner and interior concrete floor of the containment, including the potential for stagnant water to have collected behind a degraded floor seal area that could promote pitting corrosion

Document Control Desk CR-13-00705 RC-13-0135 Enclosure I Page 3 of 11 SCE&G Response RAI-2 #1(a)

The twelve "As Left" tests with higher leakage rates than their acceptance criteria are listed below:

Test Test Date Pass/

Equipment ID Leakage Units Acceptance Penetration Type Faii Criteria Number As Left 11/3/2003 FAIL PVA-9312B-SS 2420 SCCM 2015 XRP0407B As Left 5/16/2005 FAIL PVG-6056-HR 2870 SCCM 2720 XRP0103 As Left 11/12/2006 FAIL MVG-3004B-SP 4380 SCCM 3625 XRP0328 As Left 11/9/2006 FAIL PVT-8149A-CS 3220 SCCM 2015 XRP0318 As Left 5/14/2008 FAIL PVT-8149A-CS 3350 SCCM 2015 XRP0318 As Left 5/21/2008 FAIL MVG-7502-AC 3400 SCCM 2720 XRP0208 As Left 5/21/2008 FAIL XVC07541-AC 3400 SCCM 2720 XRP0208 As Left 5/28/2008 FAIL PVT-8149A-CS 3580 SCCM 2015 XRP0318 As Left 11/16/2009 FAIL MVG-7502-AC 3340 SCCM 2720 XRP0208 As Left 11/16/2009 FAIL XVC07541-AC 3340 SCCM 2720 XRP0208 As Left 5/14/2011 FAIL MVG-9568-CC 3830 SCCM 2920 XRP0312 As Left 11/11/2012 FAIL MVB-3110B-SW 7250 SCCM 3626 XRP0403 The acceptance criteria listed in the table are administrative limits. Per VCSNS procedure GTP-315, "Containment Leakage Rate Testing Program," and the individual surveillance test procedures, the station can evaluate leakage values that exceed the acceptance criteria and accept leakage up to 36,456 sccm, as long as the total summation of the leakage from all penetrations remains below 0.6 La. This is in accordance with Section 10.2.3.4 of NEI 94-01 Revision 0 and Revision 3a. Also, in accordance with Section 10.2.3.4, the testing frequency was set at the initial test interval, a cause determination was performed, and corrective actions were identified with appropriate steps to eliminate recurrence (see tables for Response RAI-2

1. 1(b)). The components identified in the tables were not returned to the extended test interval until the corrective actions and two successful tests were completed. Some components remain on the base interval, awaiting either corrective action and/or two consecutive successful tests.

SCE&G Response RAI-2 #1(b)

Attachment I contains tables that list the local leak rate tests not meeting the required acceptance criteria. The causes and corrective actions for each failure have been included in the table. Each LLRT failure listed in the table resulted in the component being placed on the base frequency: 30 months (equivalently 18 months, or 1 refueling outage).

SCE&G Response RAI-2 #1(c)

Regulatory Guide 1.163 specifies that NEI 94-01 Revision 0 should be used to establish test intervals. In accordance with NEI 94-01 Revision 0, Section 10.2.3.4, each failure listed in the Attachment V Table of the original submittal (LAR-1 3-0075) (recreated for Response RAI-2

1. 1(b), with additional information) resulted in the component being reset to the base interval: 30 months (equivalently 18 months, or 1 refueling outage), unless the component was already on the base interval. The components that have successfully completed two consecutive periodic As-found Type C tests, as required in NEI 94-01 Revision 0, Section 10.2.3.2, have been placed

Document Control Desk CR-13-00705 RC-13-0135 Enclosure I Page 4 of 11 on the extended interval of 60 months (equivalently 54 months, or 3 refueling outages), which is the maximum allowed under RG 1.163 item C.2. The Performance Factors of NEI 94-01 Revision 0, Section 11.3.1 are taken into account prior to extending the testing intervals (Past Component Performance, Service, Design, Safety Impact, and Cause Determination). A revised copy of Attachment IV in the original submittal (LAR-1 3-00705) has been included as Attachment II. This updated table now shows the current interval for each penetration in the Appendix J Program.

In the fourth paragraph of Section 4.2, the VCSNS LAR states, "The testing frequency for Type B and C tests is not affected by this requested amendment to permanently extend the Type A test interval from 130 months (10.9 years) to 15 years." Although NEI 94-01 Revision 3A and the associated SER allow plants to extend the Type C intervals to 75 months, VCSNS will continue testing Type C components at a maximum interval of 60 months. VCSNS would have to submit a separate License Amendment Request before changing the maximum Type C frequency from 60 to 75 months. Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995 is still referenced in the VCSNS Technical Specifications; this revision of 1.163 holds VCSNS to a test frequency of 60 months.

SCE&G Response to RAI-2 #2 V. C Summer containment consists of a post-tensioned pre-stressed and reinforced concrete structure with an integral leak tight continuous carbon steel liner plate on the inside surface as described in the UFSAR. The Containment Inservice Inspection Program Plan for V. C. Summer Station addresses the 10CFR50.55a final rule October 1, 2004 and ASME Code Section X1.

Since 2005, the implementing plant surveillance procedure includes an Augmented Inspection (every refueling outage on 18 month cycle) of the Moisture Barrier Seal and adjacent coated containment liner surface at the perimeter joint detail where the basement concrete floor slab in the Reactor Building meets the containment liner plate.

The required inspection consists of 100 percent Detail Visual VT-1 examination. Table 4.2-1 in the original submittal (LAR-1 3-00705) provides an approximate schedule for the containment surface examinations assuming the Type A test frequency is extended to 15 years. The two most recent Type A tests at VCSNS Unit 1 have been successful, so the current Type A test interval requirement is one time in ten years. Operating Experience Evaluation CR-1 0-02513 states that VCSNS has not experienced any events which contributed significant degradation to the containment liner. For additional information use Attachment VI SCE&G ILRT Interval Extension Risk Analysis in the original submittal (LAR-13-00705).

The seal has been inspected and maintained through the VCSNS Corrective Actions Program.

Through these inspections, the seal has been reworked to ensure there is no potential for water to pass through. Limiting the water passage decreases the potential to have collected water behind or below a degraded floor seal area which could promote pitting corrosion of the liner plate. Past inspections have documented some local deterioration of the seal such as local debond from the liner that was reworked at the time to the required design. Rework included, where applicable, locally removing the seal material and backing sufficiently for visual examination to ensure liner corrosion was not occurring down into the joint below the sealant detail. Augmented Inspections will be performed on an 18 month refueling interval to maintain the sealant joint and liner coatings. These inspections ensure that there is no potential for

Document Control Desk CR-13-00705 RC-13-0135 Enclosure I Page 5 of 11 stagnant water to penetrate through the seal, collect behind a degraded floor seal area, and prevent pitting corrosion of the liner below the seal.

RAI-3

Risk Assessment

1.

According to Regulatory Issue Summary 2007-06, "Regulatory Guide 1.200 Implementation," the U.S. Nuclear Regulatory Commission (NRC) staff expects licensees to fully address all scope elements with Revision 2 of Regulatory Guide (RG) 1.200 by the end of its implementation period (i.e., one year after the issuance of Revision 2 of RG 1.200). Revision 2 of RG 1.200 endorses, with exceptions and clarifications, the combined American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) probabilistic risk assessment (PRA) standard (ASME/ANS RA-Sa-2009).

Given that the implementation date of RG 1.200, Revision 2, was April 2010 and the date of the license amendment request (LAR) submittal, April 2013, describe any gaps between the 2007 focused scope peer review of the PRA model used in this application and RG 1.200, Revision 2, that are relevant to this submittal and the impact on this application.

2.

Revision 2 of RG 1.200 endorses, with exceptions and clarifications, ASME/ANS RA-Sa-2009. The ASME/ANS PRA standard provides that PRA upgrades be followed by a focused scope peer review.

Discuss whether the inclusion of the recently developed simplified Level 2 PRA for the internal events model that was referenced in Section 4.5.2 of Attachment I to the LAR is a PRA maintenance or PRA upgrade as defined in the ASME/ANS PRA standard. If the inclusion of the simplified Level 2 PRA for the internal events model is a PRA upgrade, describe the focused scope peer review that was conducted and provide the resolution of the Facts and Observations (F&Os).

Otherwise, explain why the inclusion of the simplified Level 2 PRA model is not considered an "incorporation into a PRA model of a new methodology."

3.

Revision 2 of RG 1.200 endorses, with exceptions and clarifications, ASME/ANS RA-Sa-2009. In Regulatory Position 4.2 of RG 1.200, Revision 2, the NRC staff stated that it expects licensees to submit a discussion of the resolution of the peer review findings that are applicable to the parts of the PRA required for the application.

Provide a list of the F&Os from the focused scope peer review relevant to this submittal and explain how the F&Os were addressed for this application.

SCE&G Response to RAI-3 #1 In November 2011, PRA personnel from South Carolina Electric & Gas Company and Westinghouse Electric Company performed a self assessment to identify gaps between the VCSNS PRA Model and the requirements delineated in Regulatory Guide 1.200, Revision 2, and the ASME/ANS PRA Internal Events Model Standard. (This task was a follow-up to the

Document Control Desk CR-13-00705 RC-13-0135 Enclosure I Page 6 of 11 2007 focused scope review which evaluated the model against the requirements in Revision 1 of the Regulatory Guide. In addition to a general assessment of the internal events PRA model, the self assessment also addressed changes in requirements between the time of the 2007 focused scope review and the implementation date of Revision 2.)

Following the self assessment, VCSNS reviewed the gaps to identify those that could potentially impact the submittal of a LAR to extend the ILRT interval. These include gaps that impact the containment model and potentially have a significant impact on core damage frequency. Two important gaps were identified:

1. Emergency Core Cooling System (ECCS) Sump Blockage: The previous sump blockage model was not based on the latest guidance in WCAP-1 6882-NP, Revision 1 "PRA Modeling of Debris-Induced Failure of Long Term Core Cooling via Recirculation Sumps." To address this gap, the sump blockage model was revised using the guidance in the subject WCAP. Debris-induced loss of cooling basic events were developed and modeled for the range of initiating events where ECCS recirculation is required to achieve a safe and stable plant end state. The revised sump blockage model was utilized in the analysis for the ILRT LAR submittal. Therefore, this gap has no impact on the ILRT extension LAR.

2. Inter-System Loss of Coolant Accident (ISLOCA): The self assessment identified that the ISLOCA model was not consistent with the recently developed guidance in WCAP-17154-P, Revision 0, "ISLOCA Risk Model." To address this gap, ISLOCA sequences and frequencies were revised to update the VCSNS model in accordance with the WCAP guidance. As part of this change, the State of Knowledge Correlation (SOKC) was addressed by using correlated data in the CAFTA type code table. The revised ISLOCA model was utilized in the analysis for the ILRT LAR submittal. Therefore, this gap has no impact on the ILRT extension LAR.

Resolution of these gaps involved updating the model to match the most recent guidance available. The structure, scope, and capability of the model remained the same. While frequencies were updated and additional failure sequences were added to the fault tree, the revisions do not consist of incorporation of a new methodology, a change in scope, or a change in capability. Therefore, the changes are considered PRA maintenance activities which do not require a focused peer review.

SCE&G Response to RAI-3 #2 The Level 2 PRA model referenced in Section 4.5.2 of Attachment I in the LAR is an extension of the previous Level 2 Containment Bypass model that has been peer-reviewed. The extended Level 2 assessment expands the VCSNS model beyond a single Large Early Release bin (which has been peer-reviewed) to include additional bins for Small Early Release, Late Release, and sequences where the Containment remains intact. While this expansion utilizes a new methodology and will require a peer review, it does not change the sequences binned as LERF so the peer review is not required to support this Integrated Leak Rate Test Interval Extension LAR which uses LERF metrics. (Note that the simplified Level 2 model was implemented by Westinghouse and then reviewed and accepted by SCE&G, so an independent review of the model was performed.) VCSNS is currently making additional PRA model

Document Control Desk CR-13-00705 RC-13-0135 Enclosure I Page 7 of 11 enhancements and will subject the model to a full-scope peer review once all of the changes are complete.

SCE&G Response to RAI-3 #3 There are three Findings and Observations (F&Os) resulting from the 2007 focused scope review that are relevant to the ILRT LAR. These F&Os and their corresponding resolutions (including how they were addressed for this application) are listed below. The first F&O listed from the 2007 review pertains to the VCSNS ISLOCA analysis. The other two observations relate to documentation of assumptions and uncertainty.

Additionally, VCSNS conducted a gap assessment for Regulatory Guide 1.200, Revision 2, in 2011. As noted in response to RAI Number 1 above, this gap assessment issued findings that were relevant to the ILRT application (findings on ISLOCA and ECCS Sump Blockage). In addition to the findings addressed in RAI Number 1 above, the 2011 assessment included a suggestion regarding the need to document sources of uncertainty in the LERF model. For completeness, the specific F&Os from the 2011 assessment (and how they were addressed for this submittal) are also listed below.

2007 Assessment F&O IE-01 -GA Finding:

In the original peer review, a B level F&O, IE-06, was issued for the ISLOCA analysis. One of the primary items was concern about the variance/polynomial treatment for quantifying the ISLOCA frequency (part of the "state-of-knowledge issue") and the treatment of different valve and component failure modes. A second F&O, AS-01, Significance Level B, raised concerns about the failure to treat large pipe failures and crediting recirculation to mitigate ISLOCAs. The ISLOCA treatment was revised. The ISLOCA frequency was calculated using the variance treatment. While the resulting frequency was a factor of 20 higher than the baseline, it was concluded that this was not significant and could be treated in the uncertainty analysis. It was not used to calculate the error factor and was only used in a sensitivity analysis. Large pipe breaks were addressed by introducing a split fraction that said 1% of ISLOCA initiators resulted in a pipe break. A review of the ISLOCA cutsets showed one cutset with an ISLOCA resulting in a large pipe break outside containment and failure to control ECCS flow. This is not a valid cutset. It is an artifact of the model structure which assumes mitigation even when a pipe break has occurred without fully achieving a safe stable end state.

Mr. R. Lutz was asked to review the ISLOCA supporting analyses to identify the basis for the revised ISLOCA. The results of this review indicated that the accident progression for an ISLOCA involving a pipe break outside containment in the 12 inch RHR suction line is based on the expected plant response as documented in the original IPE Success Criteria Notebook (Reference 15 in CN-RRA-02-81). Since there are no valves in the RHR suction line outside containment, a break in that line would disable the LPI injection function for the pump in the affected train. Thus, RWST drain down would be limited to one LPI pump and two charging pumps. The IPE Success Criteria Notebook indicates that for a completely depressurized RCS, this would drawdown the RWST at a rate of 3930 gpm. At some time into the event, the operators would go through the V. C. Summer Emergency Operating Procedure, EOP-2.4, "Loss of Emergency Coolant Recirculation," and stop all SI pumps and align a single charging pump to take suction from the RWST and discharge through the normal charging pathway that

Document Control Desk CR-13-00705 RC-13-0135 Enclosure I Page 8 of 11 can be throttled (and the flow rate is indicated in the control room). This is detailed in Appendix A of CN-RRA-02-81 and is shown to be able to be completed within 40 minutes. The original IPE success criteria then assumed that the operators would throttle RCS makeup to match the curve in the EOPs. In this case, if ECCS was terminated and throttling started at 44 minutes, the RWST would last for exactly 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. CN-RRA-02-081 references CN-RAS-95-57 for the 40 minute success criteria. CN-RAS-95-57 simply took the original IPE success criteria (44 minutes) and updated it for the power up-rating to show that it is now 41 minutes, which was rounded to 40 minutes in CN-RRA-02-081. Thus, terminating all ECCS flow and initiating normal charging using suction from the RWST is a valid response to the ISLOCA pipe break event.

There are two weaknesses in this success criteria:

1) The assumption that ECCS flow is stopped at 40 minutes and the normal charging pathway, taking suction from the RWST, is used just gets to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the RWST is emptied. This is not a safe stable state. Revising the PRA to model RWST refill at a rate of at least 115 gpm (see table 3.9 of the IPE Success Criteria Notebook adjusted for the 4% power up-rating from CN-RAS-95-57) would resolve this issue.

2) The operator action to terminate SI, re-align a charging pump to the normal charging discharge pathway (but taking suction from the RWST) and then continually throttle the charging pump flow according to the plot in the EOPs is a key modeling assumption that is not modeled in the PRA. Without success in stopping the ECCS pumps and re-aligning a charging pump, RWST refill would have to be started before 100 minutes and at a rate of 3930 gpm. Revising the PRA model to include this operator action would resolve this issue.

The ISLOCA analysis needs to be revisited. First, if mitigation is to be credited, refill of the RWST and the operator action to terminate SI and re-align the charging pump need to be modeled. Alternately, the pipe rupture branch can be taken directly to core damage. Second, once these model changes are made, the variance treatment needs to be revisited, particularly for those sequences that can lead to a large pipe break outside containment. Calculation of rupture probability should consider, at least qualitatively, all low pressure components in the line and where the break is credited as small enough to mitigate, the bases need to be carefully and thoroughly documented.

Resolution/impact on ILRT LAR:

To address this finding initially, the ISLOCA frequency calculation was updated and large leaks and their impacts were included in the model (all large LOCAs were modeled as directly leading to core damage).

Subsequently, during the 2011 Regulatory Guide 1.200, Revision 2, assessment, Large Early Release Supporting Requirement LE-C1 was left ungraded, partially because of concerns with the ISLOCA model not adhering to current industry practice. To address this concern, the ISLOCA model was revised to meet the guidance in WCAP-17154-P, Revision 0, "ISLOCA Risk Model." The updated model meets the requirements of Regulatory Guide 1.200, Revision 2.

Document Control Desk CR-13-00705 RC-1 3-0135 Enclosure I Page 9 of 11 This updated ISLOCA model was used in developing the ILRT Extension LAR, so there is no impact of this finding on the ILRT Extension LAR.

2007 Assessment F&O AS-02-GA Finding:

VCSNS does not have a stand-alone database or document identifying all of the assumptions or sources of uncertainty included in their PRA. The VCSNS practice is to capture the assumptions associated when each element of the PRA in the documentation associated with that element or in the PRA update documentation. DC00300-146 contained a small set of assumptions, but there is no indication they had been reviewed for significance. A review of the updated success criteria report indicated that there was no compilation of assumptions used but assumptions could be identified by a careful reading of the individual tasks. In the event tree notebook, DC00300-130, the assumptions section states that the assumptions are contained in the individual event tree sections. The assumptions could be identified through a careful reading of the text, but there was no assessment of the importance of the assumptions and there was no compilation of the assumptions. A review of the HRA Documentation also shows that it is difficult to identify the assumptions and there appears to be no assessment of the significance of assumptions. The Systems Notebooks were also reviewed and they have a fairly good set of assumptions for each of the systems analyses. Again, there appears to be neither an assessment of the significance of the assumptions nor an assessment of the uncertainty.

VCSNS should consider establishing a compilation of the assumptions used in their PRA model. As a minimum, VCSNS should identify and track key sources of uncertainty, in particular, epistemic uncertainty. The assumptions should be identified by PRA Element and include at least a qualitative assessment of the importance of each assumption.

Note that no problems were identified with respect to specific assumptions or the ability to ascertain the validity of any specific analysis. This is primarily a documentation issue.

Resolution/Impact on ILRT LAR:

This item dealt with documentation of assumptions and their impacts/uncertainties on the model. To resolve the issue, VCSNS improved the method of documenting assumptions as changes are made to the model.

VCSNS utilizes a simplified Level 2 PRA model. Assumptions and uncertainties for the simplified Level 2 model are thoroughly documented in the analysis supporting the model. The simplified Level 2 model was utilized in the analysis to support the ILRT Extension LAR, so there is no impact of this finding on the ILRT Extension LAR.

2007 Assessment F&O QU-02-GA Finding:

The discussion of key sources of model uncertainty is somewhat limited. A quantitative parametric uncertainty analysis was performed and there was a limited set of sensitivity analyses linked to some specific changes in the update. However, the overall discussion of key sources of uncertainty seemed somewhat limited. VCSNS may want to consider developing a list of key sources of uncertainty and providing a discussion of the overall potential impact of these assumptions on the robustness of the model.

Document Control Desk CR-13-00705 RC-13-0135 Enclosure I Page 10 of 11 Resolution/lImpact on ILRT LAR:

This comment noted that the discussion concerning key sources of uncertainty in VCSNS modeling was limited. Similar to AS-02-GA above, VCSNS documented the key sources of uncertainty and discussed their impact.

Additionally, as noted above, the key sources of model uncertainty in the simplified Level 2 model (utilized to support the ILRT LAR) are specifically addressed in the documentation for development of the model. Therefore, there is no impact of this finding on the ILRT Extension LAR.

2011 Assessment F&O 1-49 (SR LE-Cl)

Finding:

Supporting Requirement Ungraded. Concerns over ISLOCA model exist. Is catastrophic failure of RCP seals considered (or just leakage)? (This F&O originated from SR LE-C1) Basis for Significance: Issues with treatment of ISLOCA and RCP seal leaks. Possible Resolution:

Treatment of State of Knowledge Correlation should be reviewed with respect to WCAP-17154-P "ISLOCA Risk Model", April 2010. Induced SGTR is written off based on a review of physical phenomena. However, the present treatment does not consider large RCP seal leakage.

Consideration of these leaks would result in a potential for thermally induced SGTRs. Larger leaks should be considered, as applicable and assessment re-evaluated.

ResolutionlImpact on ILRT LAR:

To address this concern, the ISLOCA model was revised to meet the guidance in WCAP-17154-P, Revision 0, "ISLOCA Risk Model." In addition, the Level 2 model was revised to be consistent with WCAP-16341-P, Revision 0, "Simplified Level 2 Modeling Guidelines," which addressed thermally induced SG tube ruptures. The updated model meets the requirements of Regulatory Guide 1.200, Revision 2. This updated ISLOCA model and Level 2 model were used in developing the ILRT Extension LAR, so there is no impact of this finding on the ILRT Extension LAR.

2011 Assessment F&O 1-50 (LE-F3)

Suggestion:

No treatment of uncertainty. Over reliance on Zero. (This F&O originated from SR LE-F3)

Basis for Significance: Uncertainty treatment lacking. Possible Resolution: LERF model needs to consider both parameter and model uncertainty. Parameter uncertainty is associated with selection of values used in the PRA model including uncertainties with the containment fragility curve. Model uncertainty includes consideration of the impact of the neglect of human actions. And the treatment of DCH, H2, induced SGTR, and other low potential failure modes.

Resolution/Impact on ILRT LAR:

Both parameter and model uncertainty are thoroughly addressed in the documentation of the simplified Level 2 model used to support the analysis of the ILRT Extension LAR. There is no impact of this suggestion on the ILRT Extension LAR.

2011 Assessment F&O 7-3 (AS-B3)

Finding:

Sump blockage was not based on the latest PWROG information from WCAP-16882. (This F&O originated from SR AS-B3) Basis for Significance: The VCSNS model for sump

Document Control Desk CR-1 3-00705 RC-13-0135 Enclosure I Page 11 of 11 blockage is from IPE days and does not address GSI-191 concerns. The current model only includes CCF of sump screens due to blockage for %LLO and %MLO based on a generic data based for different conditions. Sump blockage is not modeled in other initiators that go to ECC recirc and does not follow the latest PWROG recommendations in WCAP-16882. Possible Resolution: Revise the sump blockage model for failure of ECC recirc to be consistent with the recommendations of WCAP-16882.

Resolution/Impact on ILRT LAR To address this gap, the ECCS Sump blockage model was revised using the guidance in the subject WCAP-16882. Debris-induced loss of cooling basic events were developed and modeled for the range of initiating events where ECCS recirculation is required to achieve a safe and stable plant end state. The revised sump blockage model was utilized in the analysis for the ILRT Extension LAR submittal. Therefore, there is no impact of this F&O on the ILRT Extension LAR.

Document Control Desk CR-13-00705 RC-13-0135 Attachment I Page 1 of 7 Local Leak Rate Tests Not Meeting the Required Acceptance Criteria Test Type Date Equipment Leakage Isccm]

Acceptance Criteria

[sccml Penetration Number Condition Report Causes/Corrective Action 0

Valve marginally exceeded acceptance criteria. No work As Found 10/16/2003 PVA-9312B-SS 2240 2015 XRP0407B CR-03-03801 performed.

eaaeewas accepte as-is.

performed. AL Leakage was accepted as-is.

Could not pressurize valve. The Outside Reactor Containment As Found 10/24/2003 XVC08861-SI 99999 2015 XRP0317 CR-03-03599 (ORC) valve leakage was used for the As-Found MNPLR. Valve was disassembled and cleaned. Valve passed the AL test.

Leakage was accepted as-is. Work Order generated to clean the As Found 10/25/2003 XVC06799-FS 2320 2015 XRP0427 CR-03-03624 valve in RF-15 if needed, but canceled due to valve passing AF and AL.

As Found 10/26/2003 MVG-9605-CC 3140 2920 Parallel Path Penetration: Check Valve and MOV. The Check As Found 10/26/2003 XVC09689-CC 3140 2920 XRP0330 CR-03-03647 Valve was removed, cleaned, and reinstalled. The valve passed the AL Test.

Could not pressurize check valve. The Outside Reactor Containment (ORC) valve leakage was used for the As-Found As Found 10/27/2003 XVC09602-CC 99999 2015 XRP0204 CR-03-03671 MNPLR. Valve was disassembled, inspected, and cleaned. Seat and disc required lapping. The valve passed the AL Test.

Valve marginally exceeded acceptance criteria. No work As Left 11/3/2003 PVA-9312B-SS 2420 2015 XRP0407B CR-03-03801 performed. Leakage was accepted as-is.

As Found 11/4/2003 MVB-3106B-SW 0

0 XRP0403 N/A False record, 3106B removed from program.

Parallel valves 8149A/B/C-CS: Valve failed the As-Found test.

As Found 11/9/2003 PVT-8149C-CS 2380 2015 XRP0318 CR-03-03903 Leakage was accepted as-is. Work Order generated to rework valve in an upcoming outage. See following outages.

As Found 11/10/2003 XVD06671-SF 5290 2015 XRP0419 CR-03-03915 Leakage due to diaphragms. Valves were rebuilt and passed the As-Left test.

As Found 11/10/2003 XVD06672-SF 5290 2015

Document Control Desk CR-13-00705 RC-1 3-0135 Attachment I Page 2 of 7 Test Type Date Equipment Leakage

[seem]

Acceptance Criteria Fsccml Penetration Number Condition Report Causes/Corrective Action 0

Check Valve stuck open and pen could not be pressurized. Valve was removed and cleaned. The Outside Reactor Containment As Found 4/24/2005 XVC02913-SA 99999 2015 XRP0310 CR-05-01387 waC valve leak e wue Orthe as-Founde (ORC) valve leakage was used for the As-Found MvNPLR. The AL Test was SAT.

Parallel valves 8149A/B/C-CS: Valve failed the As-Found test.

As Found 4/26/2005 PVT-8149C-CS 2150 2015 XRP0318 CR-05-01448 Leakage was accepted as-is. All three valves were reworked in RF-I 5 and the penetration passed the AL Test.

Leakage was accepted as-is. Contingency work order generated As Found 5/10/2005 MVG-3004B-SP 4310 3625 XRP0328 CR-05-01798 to clean the valve internals in RF-16, if the valve failed the AF, but was canceled since the valve passed its AF test in RF-16.

Leakage was slightly above the acceptance criteria. Work Order As Left 5/16/2005 PVG-6056-HR 2870 2720 XRP0103 CR-05-01998 generated to clean the valve internals in RF-16, but was canceled, since the valve passed its AF and AL test in RF-16.

As Found 5/18/2005 PVA-93 12B-SS 2160 2015 XRP0407B CR-05-02062 Leakage was slightly above the acceptance criteria. Work Order generated to repack the valve in the next outage. Valve passed its AF test in RF-16, the valve was reworked, and the valve passed its AL test.

Document Control Desk CR-13-00705 RC-1 3-0135 Attachment I Page 3 of 7 Test Type Date Equipment Leakage

[sccm]

Acceptance Criteria

[sccml Penetration Number Condition Report Causes/Corrective Action 0

'4-Parallel valves 8149A/B/C-CS: Leakage was marginally above As Found 10/17/2006 PVT-8149A-CS 3990 2015 XRP0318 CR-06-03462 the acceptance criteria.

Valves were repacked and rebuilt, but failed their AL test.

MOV was disassembled, cleaned, and inspected. The MOV was As Found 10/19/2006 MVG-9568-CC 5120 2920 XRP0312 CR-06-03512 reas dipassed theaseft test.

reassembled and passed the As-Left test.

As Found 10/27/2006 MVG-9605-CC 99999 2920 Parallel Path Penetration: Check Valve and MOV. Could not pressurize valves. The Outside Reactor Containment (ORC)

As Found 10/27/2006 XVC09689-CC 99999 2920 XRP0330 CR-06-03837 valve leakage was used for the As-Found MNPLR. The MOV internals were reworked and the penetration passed the As-Left test.

The leakage was accepted as-is. A Work Order was written for As Found 11/1/2006 MVG-8886-SI 2480 2015 XRP0412 CR-06-03821 the valve operator to be adjusted in RF-17, but was canceled since the valve passed its AF and AL tests.

Parallel valves 8149A/B/C-CS: New internals were installed in 8149B-CS during RF-16. Leakage accepted as-is, since it was marginally above the acceptance criteria. Work Orders were As Left 11/9/2006 PVT-8149A-CS 3220 2015 XRP03 18 CR-06-04027 tageneate toew aceAtand critCrin Wrk but were gaenerated to rework 8149A and 8149C in RF-17, but were canceled due to dose considerations and because 8149B required reworking to correct a body to bonnet leak.

As Left 11/12/2006 MVG-3 004B-SP 4380 3625 XRP0328 CR-06-04079 Valve passed AF, but failed AL. Work Order generated to rework valve internals in RF-17, but was canceled since the valve passed its AF and AL tests in RF-17.

Document Control Desk CR-1 3-00705 RC-13-0135 Attachment I Page 4 of 7 Test Type Date Equipment Leakage

[sccml Acceptance Criteria lsccml Penetration Number Condition Report Causes/Corrective Action N

Cu 0

Parallel valves 8149A/B/C-CS: During RF-16, Work Orders were generated to rework 8149A and 8149C in RF-17, but were As8149A-CS 3860 2015 XRP318 CR-08-01686 canceled due to dose considerations and because 8149B required reworking to correct a body to bonnet leak. The leakage was close to the leakage measured in RF-17, which showed that the valves were not degrading.

As Found 5/6/2008 MVG-8885-SI 2251 2015 XRP0222 CR-08-01858 Packing Adjustment and MOVAT testing was performed to improve leakage. Valve passed its AL test.

As Found 5/6/2008 MVG-8884-SI 2462 2015 XRP0415 CR-08-01858 Packing Adjustment and MOVAT testing was performed to improve leakage. Valve passed its AL test.

As Left 5/14/2008 PVT-8149A-CS 3350 2015 XRP0318 CR-08-01686 Parallel valves 8149A/B/C-CS: See 5/28/2008 AL test.

As Found 5/18/2008 MVG-9605-CC 7500 2920 Parallel Path Penetration: Check Valve and MOV. The Check As Found 5/18/2008 XVC09689-CC 7500 2920 XRP0330 CR-08-02176 Valve was removed, cleaned, and reinstalled. The penetration passed the AL Test.

As Found 5/20/2008 MVG-7502-AC 7954 2720 XRP0208 CR-08-02206 Parallel Path Penetration: Check Valve and MOV. Failed AF As Found 5/20/2008 XVC07541-AC 7954 2720 and AL: The Check Valve was removed, cleaned, and reinstalled.

As Left 5/21/2008 MVG-7502-AC 3400 2720 During the AL test, the leakage did not significantly exceed the As Left 5/21/2008 XVC07541-AC 3400 2720 XRP0208 CR-08-02206 acceptance criteria and was accepted.

Parallel valves 8149A/B/C-CS: During RF-16, Work Orders were generated to rework 8149A and 8149C in RF-17, but were As Left 5/28/2008 PVT-8149A-CS 3580 2015 XRP0318 CR-08-01686 canceled due to dose considerations and because 8149B required reworking to correct a body to bonnet leak. The leakage was close to the leakage measured in RF-17, which showed that the valves were not degrading. Leakage accepted as-is. See RF-18.

As Found 6/1/2008 MVB-3106B-SW 0

0 XRP0403 N/A False record, 3106B removed from the program As Left 11/16/2009 XVC07541I-AC 3340 2720 As Left 11/16/2009 XVCO7S4 1-AC 3340 2720

Document Control Desk CR-13-00705 RC-13-0135 Attachment I Page 5 of 7 Test Type Date Equipment Leakage Isccm]

Acceptance Criteria

[sceml Penetration Number Condition Report Causes/Corrective Action 0l The valve was disassembled and inspected. Buildup on the As Found 10/20/2009 XVG06773-FS 8290 2015 XRP0404 CR-09-04161 wedge and stem was reported. The valve internals were cleaned and the valve reassembled. The valve passed the As-Left test.

As Found 10/21/2009 MVG-9605-CC 99999 2920 Parallel Path Penetration: Check Valve and MOV. Could not pressurize valves. The Outside Reactor Containment (ORC)

XRP0330 CR-09-04194 valve leakage was used for the As-Found MNPLR. Check Valve As Found 10/21/2009 XVC09689-CC 99999 2920 was removed, cleaned, and reinstalled. The penetration passed the AL Test.

Parallel valves 8149A/B/C-CS: The valve internals for 8149C As Found 10/22/2009 PVT-8149A-CS 6350 2015 XRP0318 CR-09-04221 were replaced. After repairs, the valves passed their AL test and have had satisfactory performance since.

Work Order generated to repair valve during the next outage, but As Found 10/30/2009 PVT-8880-SI 2400 2015 XRP0320 CR-09-04485 w scnee i c h

av asdisA et

_______was canceled since the valve passed its AF test.

As Found 10/30/2009 MVG-8801A-SI 3010 2015 Test was declared "Failed" prior to troubleshooting:

XRP0426 CR-09-04474 Troubleshooting reveal leakage was due to a leaking boundary As Found 10/30/2009 MVG-880IB-SI 3010 2015 valve. The penetration was retested @ 3.67 sccm.

As Found 11/1/2009 MVT-8102C-CS 8450 2015 XRP0221 CR-09-04502 The valve was disassembled and repaired: a new disc was installed. The valve passed the AL test.

As Found 11/2/2009 XVCO3009A-SP 4300 3225 XRP0401 CR-09-0453)4 The valve was disassembled and inspected. The valve internals were cleaned. The valve passed the AL test.

Parallel Path Penetration: Check Valve and MOV. Could not As Found 11/14/2009 MVG-7503-AC 99999 2720 pressurize valve. The ORC valve leakage was used for the As-XRP0209 CR-09-04880 Found MNPLR. The Check Valve was removed, cleaned, and As Found 11/14/2009 XVC07544-AC 99999 2720 reinstalled. The penetration passed the AL Test.

As Found 11/15/2009 MVG-7502-AC 99999 2720 Parallel Path Penetration: Check Valve and MOV. Could not XRP0208 CR-09-04894 pressurize valve. The ORC valve leakage was used for the As-As Found 11/15/2009 XVC07541-AC 99999 2720 Found MNPLR. The Check Valve was removed, cleaned, and reinstalled.

As Left 11/16/2009 MVG-7502-AC 3340 2720 XRP0208 CR-09-04923 Parallel Path Penetration: Check Valve and MOV. The Check Valve was removed, cleaned, and reinstalled. The penetration did not pass the AL Test, but was accepted as-is, since the leakagze marginally exceeded the acceptance criteria.

As Left 11 /16/2009 XVC07541-AC 3340 2720 As Left 11/16/2009 XVC07541-AC 3340

Document Control Desk CR-1 3-00705 RC-13-0135 Attachment I Page 6 of 7 Test Type Date Equipment Leakage

[sem]

Acceptance Criteria Isccml Penetration Number Condition Report Causes/Corrective Action 0N Could not pressurize the pen. The Outside Reactor Containment (ORC) valve leakage was used for the As-Found MNPLR. The As Found 4/17/2011 XVC02913-SA 99999 2015 XRP03 10 CR-1 1-01760 check valve was disassembled and rust particles were found on the seating surface. The valve was cleaned and passed the AL Test.

Containment Sump Valve "Mini Containment Chamber: The chamber was disassembled/opened for work on the valve inside of the Chamber. After reassembly, the Chamber passed the AL Test.

As Found 5/2/2011 MVG-7502-AC 6600 2720 Parallel Path Penetration: Check Valve and MOV. The Check XRP0208 CR-I 1-02289 Valve was removed, cleaned, and reinstalled. The penetration As Found 5/2/2011 XVC07541-AC 6600 2720 passed the AL Test.

As Left 5/14/2011 MVG-9568-CC 3830 2920 XRP0312 CR-11-02676 Leakage attributed to newly installed packing. Leakage was accepted as-is, since it did not significantly exceed the acceptance criteria. The valve passed its AF test during RF-20.

Document Control Desk CR-13-00705 RC-13-0135 Attachment I Page 7 of 7 Test Type Date Equipment Leakage

[scem]

Acceptance Criteria Iscecml Penetration Number Condition Report Causes/Corrective Action 0

Parallel Path Penetration: Check Valve and MOV. The Check As Found 10/22/2012 MVG-7502-AC 6300 2720 Valve was removed, cleaned, and reinstalled. The penetration XRP0208 CR-12-04732 passed the AL Test. Design Change (ECR50845) initiated to As Found 10/22/2012 XVC07541-AC 6300 2720 address failures of Parallel Path Penetrations (Check Valve and MOV).

Since the valve failed the normal 30 Day Water Seal Test, an As Found 10/31/2012 MVG-8701B-RH 15600 3625 XRP0226 CR-12-05037 LLRT was required. The As-Found LLRT also failed. The valve was repacked and passed the AL Test.

As Left 11/11/2012 MVB-310 OB-SW 7250 3626 XRP0403 CR-12-05334 The valve passed the as-found, but failed the as-left test. This was attributed to work performed on the operator and not a problem with the valve itself The leakage was accepted as-is.

Work Order generated to repair operator in RF-2 1.

RC-13-0135 (RC-13-0037, Revised Attachment IV)

Page 1 of 5 Attachment II VCSNS Type B and C Frequencies Penetration Interval Equipment ID Description Type Comments Number (Months)

FUEL-XFERTUBE Fuel Transfer Tube XRP0107 Flange 18 Manually set to 18 months to meet every outage commitment HATCH-EQUIP Containment Equipment Hatch HATCH-01 Hatch 18 Manually set to 18 months to meet I

every outage commitment HATCH-ESCAPE Personnel Escape Airlock HATCH-02 Hatch 30 Manually set to 30 months to meet GTP-315 requirements HATCH-PERSON Personnel Airlock HATCH-03 Hatch 30 Manually set to 30 months to meet GTP-315 requirements MVB-3106A-SW SWBP A Discharge XRP0304 Butterfly 60 MVB-3106B-SW SWBP B Discharge XRP0403 Butterfly 60 MVB-3110A-SW Ind Cig To RBCU 64A/65A XRP0304 Butterfly 60 Manually set to base interval Post LLRT MVB-3110B-SW Ind Cooling To RBCU 64B/65B XRP0403 Butterfly 30 exceeded Surveillance limit (RF-20) CR-12-05319 MVG-3003A-SP Spray Header Isolation Loop A XRP0401 Gate 60 MVG-3003B-SP Spray Header Isol Loop B XRP0303 Gate 60 Manually set to base interval, Post LLRT MVG-3004A-SP Sump Isolation Loop A XRP0327 Gate 30 exceeded Surveillance limit (RF-19) CR-11-02700 MVG-3004B-SP Sump Isolation Loop B XRP0328 Gate 60 MVG-3103A-SW RBCU 64A/65A Out Hdr Isol XRP0305 Gate 60 MVG-3103B-SW RBCU 64B/65B Out Hdr Isol XRP0102 Gate 60 MVG-6797-FS Fire Service Cntmt Isol XRP0427 Gate 60 MVG-7501-AC TO CRDM Cooler Isolation XRP0208 Gate 60 Auto set to base interval, Pre LLRT MVG-7502-AC TO CRDM Cooler Isolation (IRB)

XRP0208 Gate 30 exceeded Surveillance limit (RF-20) CR-12-04732 MVG-7503-AC From CRDM Cooler Isol (IRB)

XRP0209 Gate 60 MVG-7504-AC From CRDM Cooler Isol (ORB)

XRP0209 Gate 30 Manually set to base interval, could not perform LLRT (RF-19) CR-11-02192 MVG-8107-CS Charging Line Isolation XRP0409 Gate 60 MVG-8701A-RH RCS Loop A To Pump A XRP0316 Gate 60 30 Day Water Seal (Auto set to base interval) Failed PRE MVG-8701B-RH RCS Loop C To Pump B XRP0226 Gate 30 LLRT (RF-20) CR-12-04956 (30 Day Water Seal)

MVG-8801A-SI Hi Head To Cold Leg Injection XRP0426 Gate N/A Removed from program (LAR-11-04821)

MVG-8801B-SI Hi Head To Cold LegInjection XRP0426 Gate N/A Removed from program (LAR-11-04821)

MVG-8811A-SI RHR Sump A to RHR Pump A XRP0329 Gate 30 Manually set to base interval Pre LLRT not performed (RF-20) CR-12-12-04858 MVG-8811B-SI RHR Sump B to RHR Pump B XRP0425 Gate 30 Manually set to base interval, PRE LLRT not performed (RF-20) CR-12-04825 MVG-8884-SI Charging Loop A To Hot Legs XRP0415 Gate N/A Removed from program (LAR-11-04821)

MVG-8885-SI Charging Loop A To Cold Legs XRP0222 Gate N/A Removed from program (LAR-11-04821)

MVG-8886-SI Charging Loop B To Hot Legs XRP0412 Gate N/A Removed from program (LAR-11-04821)

MVG-8888A-SI RHR LP A to Cold Legs XRP0322 Gate 60 MVG-8888B-SI RHR LP B to Cold Legs XRP0227 Gate 60 MVG-8889-Sl RHR LP A&B to Hot Legs XRP0325 Gate 60

RC-13-0135 (RC-13-0037, Revised Attachment IV)

Page 2 of 5 Attachment II VCSNS Type B and C Frequencies Penetration Interval Equipment ID Description Type Comments Number (Months)

MVG-9568-CC TO RB Load XRP0312 Gate 30 Manually set to base interval, Pre LLRT not performed (RF-20) CR-12-04859 MVG-9600-CC TO Thermal Barrier Isolation XRP0204 Gate 60 MVG-9605-CC From RB Load Isolation (IRB)

XRP0330 Gate 60 MVG-9606-CC From RB Load Isolation (ORB)

XRP0330 Gate 60 MVT-8100-CS Seal Water Rtn Isol XRP0410 Globe 60 MVT-8102A-CS A Seal Water Injection Isol XRP0408 Globe 60 MVT-8102B-CS B Seal Water Injection Isol XRP0229 Globe 60 MVT-8102C-CS C Seal Water Injection Isol XRP0221 Globe 60 MVT-8112-CS Seal Water Rtn Isol XRP0410 Globe 60 NOZZLE: 0211 RB Leak Rate Test Blowdown XRP0211 Flange 120 NOZZLE: 0212 RB Leak Rate Test Blowdown XRP0212 Flange 120 NOZZLE: 0216 RB Leak Rate Test Pressurize XRP0216 Flange 120 NOZZLE: 0327 Prot Chamb RB Recirc Smp 3004A XSMOOO4A Flange 120 Auto set to base interval, exceeded NOZZLE: 0328 Prot Chamb RB Recirc Smp 3004B XSMOOO4B Flange 30 Surveillance limit (RF-19) CR-11-01932 NOZZLE: 0329 Prot Chamb RB Recirc Smp 8811A XSMOOO5A Flange 120 NOZZLE: 0425 Prot Chamb RB Recirc Smp 8811B XSMOOO5B Flange 120 NOZZLE: 0501 Channel B XRPOO07 O-Ring Seal 120 NOZZLE: 0502 Electrical Penetration XRPO052 O-Ring Seal 120 NOZZLE: 0503 Misc. 480V Power XRPOO16 O-Ring Seal 120 NOZZLE: 0504 Reactor Coolant Pump C XRPOO01 O-Ring Seal 120 NOZZLE: 0601 Reactor Coolant Pump B XRPOO03 O-Ring Seal 120 NOZZLE: 0604 Instrument Group 3 XRPO048 O-Ring Seal 120 NOZZLE: 0605 Instrument Channel 1 XRPO043 O-Ring Seal 120 NOZZLE: 0606 Instrument Channel Ill XRPO044 O-Ring Seal 120 NOZZLE: 0607 Instrument Misc.

XRPO042 O-Ring Seal 120 NOZZLE: 0700 Control Rod Drive Power XRPO023 O-Ring Seal 120 NOZZLE: 0701 Control Rod Drive Power XRPO024 O-Ring Seal 120 NOZZLE: 0702 Instrument Group 1 XRPO051 O-Ring Seal 120 NOZZLE: 0704 MPWR XRPOO17 O-Ring Seal 120 NOZZLE: 0705 MPWR/Control (Channel A)

XRPO028 O-Ring Seal 120 NOZZLE: 0706 Control Rod Drive Power XRPOOS4 O-Ring Seal 120 NOZZLE: 0707 Control Rod Drive Power XRPO025 O-Ring Seal 120 NOZZLE: 0708 Control Rod Drive Power XRPO026 O-Ring Seal 120 NOZZLE: 0710 Reactor Coolant Pump A XRPOO06 O-Ring Seal 120 NOZZLE: 0711 Ctrl Rod Pos. & Incore Temp.

XRPO037 O-Ring Seal 120 NOZZLE: 0712 Incore Detector Drive XRPO031 O-Ring Seal 120 NOZZLE: 0714 Incore Detector Position Ind.

XRPO032 O-Ring Seal 120 NOZZLE: 0715 Instrument Group 4 XRPO036 O-Ring Seal 120 NOZZLE: 0716 Instrument Misc.

XRPO039 O-Ring Seal 120 NOZZLE: 0717 Misc. 480V Power XRPOO19 O-Ring Seal 120 NOZZLE: 0718 Instrument Misc.

XRPO040 O-Ring Seal 120 NOZZLE: 0720 Thermocouple Elect. Pen.

XRP0104 O-Ring Seal 120 Pressurize with dry nitrogen only.

NOZZLE: 0721 Instrument Channel II XRPO045 O-Ring Seal 120 NOZZLE: 0722 Misc. 480V Power XRPOO18 O-Ring Seal 120 NOZZLE: 0723 MPWR/Control (Channel B)

XRPO030 O-Ring Seal 120 NOZZLE: 0725 Misc. Control & Comm.

XRPO033 O-Ring Seal 120 NOZZLE: 0726 Channel A XRPO010 O-Ring Seal 120 NOZZLE: 0727 Channel A XRPO011 O-Ring Seal 120 NOZZLE: 0728 Control Rod Drive Power XRPOO55 O-Ring Seal 120 NOZZLE: 0800 Instrument Group 2 XRPO035 O-Ring Seal 120 NOZZLE: 0802 Electrical Penetration XRPO053 O-Ring Seal 120 NOZZLE: 0803 Control Rod Drive Power XRPO056 O-Ring Seal 120

RC-13-0135 (RC-13-0037, Revised Attachment IV)

Page 3 of 5 Attachment II VCSNS Type B and C Frequencies Penetration Interval Equipment ID Description Type Comments Number (Months)

NOZZLE: 0804 Control Rod Drive Power XRPOO57 O-Ring Seal 120 NOZZLE: 0805 RB Polar Crane 480V Panel XRPOO15 O-Ring Seal 120 NOZZLE: 0806 Thermocouple Elect. Pen.

XRP0106 O-Ring Seal 120 Pressurize with dry nitrogen only.

NOZZLE: 0808 Channel B XRPO014 O-Ring Seal 120 NOZZLE: 0809 Presurizer Heaters XRP0020 O-Ring Seal 120 NOZZLE: 0810 Presurizer Heaters XRP0021 O-Ring Seal 120 NOZZLE: 0812 Misc. Control & Comm.

XRP0034 O-Ring Seal 120 NOZZLE: 0814 Instrument Channel IV XRP0046 O-Ring Seal 120 NOZZLE: 0815 Presurizer Heaters XRPO022 O-Ring Seal 120 NOZZLE: 505-18 Outage Penetration XRP0505 Flange 18 Manually set to perform every outage (outage pen)

Manually set to perform every outage NOZZLE: 600-12 Outage Penetration XRP0600 Flange 18 (outage (outage pen)

NOZZLE: 602-12 Outage Penetration XRP0602 Flange 18 Manually set to perform every outage (outage pen)

PVA-9311A-SS Inlet To RM-A2 (IRB)

XRPO407A Ball 60 PVA-9311B-SS Inlet To RM-A2 (ORB)

XRPO407A Ball 60 PVA-9312A-SS RM-A2 To RB (IRB)

XRP0407B Ball 60 PVA-9312B-SS RM-A2 To RB (ORB)

XRP0407B Ball 60 PVD-6242A-ND RB Sumps Discharge Hdr Drn Vlv XRP0424 Diaphragm 60 PVD-6242B-ND RB Sumps Discharge Hdr Drn Vlv XRP0424 Diaphragm 60 PVG-6056-HR Alt Pur Supp Isol Viv XRP0103 Gate 60 PVG-6057-HR Alt Pur Supp Isol VIv XRP0103 Gate 60 PVG-6066-HR Cntmt Purge Exh Isol Viv XRP0302 Gate 60 PVG-6067-HR Cntmt Purge Exh Isol VIv XRP0302 Gate 60 PVT-2660-IA Instrument Air Supply To RB XRP0311 Globe 60 PVT-2662A-IA RB Air Cmpr Suct Isol (ORB)

XRP0319 Globe 18 Manually set to 18 to meet every outage commitment.

PVT-2662B-IA RB Air Cmpr Suct Isol (IRB)

XRP0319 Globe 18 Manually set to 18 to meet every outage commitment PVT-8149A-CS Letdown Orifice "A" Isolation XRP0318 Globe 60 PVT-8149B-CS Letdown Orifice "B" Isolation XRP0318 Globe 60 PVT-8149C-CS Letdown Orifice "C" Isolation XRP0318 Globe 60 PVT-8152-CS Letdown Line Isolation XRP0318 Globe 60 PVT-8860-Sl Hydro Pump Disharge XRP0317 Globe 60 PVT-8871-Sl SI Test Line To RWST (IRC)

XRP0321 Globe 60 PVT-8880-Sl SI Accumulator N2 Supply XRP0320 Globe 60 PVT-8961-Sl SI Test Line To RWST (ORC)

XRP0321 Globe 60 RBLEAKRATEPRES RB Leak Rate Press Sense Line XRP0210 Flange 120 RBLEAKRATETEST RB Leak Rate Test Flow Test Ln XRP0201 Flange 120 SVX-605OA-HR Post Accid H2 Loop A (IRB)

XRP0301B Globe 60 SVX-605OB-HR Post Accid H2 Loop B (IRB)

XRP0105B Globe 60 SVX-6051A-HR Post Accid H2 Loop A (IRB)

XRPO3O1A Globe 60 SVX-6051B-HR Post Accid H2 Loop B (IRB)

XRPOO5A Globe 60 SVX-6051C-HR Post Accid H2 Loop A (DOME)

XRPO301A Globe 60 SVX-6052A-HR Post Accid H2 Loop A (ORB)

XRP0301B Globe 60 SVX-6052B-HR Post Accid H2 Loop B (ORB)

XRP0105B Globe 60 SVX-6053A-HR Post Accid H2 Loop A (ORB)

XRPO301A Globe 60 SVX-6053B-HR Post Accid H2 Loop B (ORB)

XRPOO5A Globe 60 SVX-6054-HR RB NR Press Cntmt Isol XRP0301B Globe 60 SVX-9339-SS PRT Sample Isolation VIv XRP0417 Globe 60 SVX-9341-SS PRT Sample Isolation VIv XRP0417 Globe 60 SVX-9356A-SS Pzr Steam Sample Isol XRP0405 Globe 60 SVX-9356B-SS Pzr Liquid Sample Isol XRP0405 Globe 60 SVX-9357-SS Pzr Sample Isol XRP0405 Globe 60 SVX-9364B-SS RCS Loop B Sample Isol XRP0314 Globe 60

RC-13-0135 (RC-13-0037, Revised Attachment IV)

Page 4 of 5 Attachment II VCSNS Type B and C Frequencies Penetration Interval Equipment ID Description Type Comments Number (Months)

SVX-9364C-SS RCS Loop C Sample Isol XRP0223 Globe 60 SVX-9365B-SS RCS Loop B Sample Isol XRP0314 Globe 60 SVX-9365C-SS RCS Loop C Sample Isol XRP0223 Globe 60 SVX-9387-SS Accumulator Sample Isol XRP0323 Globe 60 XVBOOOO1A-AH RB Purge Sup Hdr Vlv XRP0402 Butterfly 18 Manually set to 18 to meet every outage commitment XVBOOOO1B-AH RB Purge Supply Isol Vlv (IRC)

XRP0402 Butterfly 18 Manually set to 18 to meet every outage commitment XVBOOOO2A-AH Reactor Bldg Purge Exh Valve XRP0101 Butterfly 18 Manually set to 18 months to meet every outage commitment XVBOOOO2B-AH RB Purge Exh Isol VIv (IRC)

XRP0101 Butterfly 18 Manually set to 18 months to meet every outage commitment ASME Check Valve - Manual Set to 18 XVC02661-IA RB Instr Sup Hdr Chk Vlv (IRC)

XRP0311 Check 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVC02913-SA Reactor Bldg SA Hdr Chk (IRC)

XRP0310 Check 18 Mo (Refuel) Could not pressurize (RF-19)

CR-11-01760 ASME Check Valve - Manual Set to 18 XVCO3009A-SP RB Spray Nozzle Inlet Hdr Chk XRP0431 Check 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVCO3OO9B-SP RB Spray Nozzle Inlet Hdr Chk XRP0303 Check 18 Months (Refuel)

XVC06588-NG S/G N2 Sup Hdr Check (IRC)

XRP0313 Check 18 ASME Check Valve - Manual Set to 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVCO6799-FS Fire Service Header Chk (IRC)

XRP0427 Check 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVCO7541-AC AC Sup Hdr Cntmt Isol Byp Chk XRP0208 Check 18 Months (Refuel)

XVC07544-AC AC Ret Hdr Cntmt isol Byp Chk XRP0229 Check 18 ASME Check Valve - Manual Set to 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVC08046-RC PRT Spray Header Check Valve XRP0422 Check 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVC08103-CS RCP Seal Wtr Ret Isol Bypass C XRP0410 Check 18 Months (Refuel)

XVC08368A-CS RC Pump A Seal Sup Hdr Chk Vlv XRP0428 Check 18 ASME Check Valve - Manual Set to 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVCO8368B-CS RC Pump B Seal Sup Hdr Chk Vlv XRP0229 Check 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVC08368C-CS RC Pump C Seal Sup Hdr Chk XRP0221 Check 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVC08381-CS CVCS Charging Hdr Chk Vlv XRP0409 Check 18 Months (Refuel)

ASME Check Valve - Manual Set to 18 XVC08861-Sl SI Accum Fill Line Chk Vlv XRP0317 Check 18 Months (Refuel)

XVC08947-SI SI Accum N2 Supply Check Vlv XRP0320 Check 18 ASME Check Valve - Manual Set to 18 Months (Refuel)

XVCD9571-CC Excess Letdown Hx CC Sup Hdr XRP0312 Check 18 AM

___________________________Months (Refuel)

XVC09602-CC RC Pumps CC Sup Hdr Chk Vlv XRP0204 Check 18 AMECekVle-anlStto1

__________________________Months (Refuel)

XVC09689-CC RB CC Ret Hdr Isol Vlv Byp Chk XRP0330 Check 18 AMECekVle-anlStto1 Months (Refuel)

XVD06671-SF Refuel Cavity SF Pur Suct Isol XRP0419 Diaphragm 60 XVD06672-SF Refuel Cavity SF Pur Suct Isol XRP0419 Diaphragm 60 XVD06697-SF SF Pur Hdr Refuel Cavity Isol XRP0421 Diaphragm 60 XVD06698-SF Refuel Cavity SF Pur Hdr Isol XRP0421 Diaphragm 60 XVDO7126-WL RCDT Vent To WGPS XRP0418 Diaphragm 60

RC-13-0135 (RC-13-0037, Revised Attachment IV)

Page 5 of 5 Attachment II VCSNS Type B and C Frequencies Penetration Interval Equipment ID Description Type Comments Number (Months)

XVD07136-WL RCDT To WPS (ORC)

XRP0423 Diaphragm 60 XVDO7150-WL RCDT Vent To WGPS XRP0418 Diaphragm 60 XVDO7170-WL RCDT To WPS (IRC)

XRP0423 Diaphragm 60 XVD08028-RC PRT RMWST Makeup XRP0422 Diaphragm 60 XVD08033-RC PRT N2 Vent XRP0420 Diaphragm 60 Manually set to base interval, Diaphragm XVD08047-RC PRT N2 & Vent XRP0420 Diaphragm 30 replaced without Pre LLRT (RF-19) CR 02214 XVD08767-DN Demin Water Hdr Sup Isol (ORC)

XRP0231 Diaphragm 60 XVD08768-DN Demin Water Sup Isol VIv (IRC)

XRP0231 Diaphragm 60 XVG06772-FS Fire Service Sup Hdr to RB iso XRP0404 Gate 60 XVG06773-FS Reactor Bldg FS Hdr Isol (IRC)

XRP0404 Gate 60 XVR08117-CS Letdown Flow Ctrl Hdr Relief XRP0318 Relief 60 XVT02679-1A Out Cntmt Breathing Air Isol XRP0324 Globe 60 XVT02680-IA RB Breathing Air Sup Hdr Isol XRPO324 Globe 60 XVT02912-SA Reactor Bldg SA Hdr Iso Vlv XRP0310 Globe 60 XVT06587-NG S/G Hi Press N2 Hdr Sup Isol XRP0313 Globe 60