ML15159A805

NRR E-mail Capture - V.C. Summer ESEP Clarification Response

ML15159A805
Person / Time
Site:	Summer
Issue date:	06/08/2015
From:	Taylor W South Carolina Electric & Gas Co
To:	Steve Wyman Japan Lessons-Learned Division
References
Download: ML15159A805 (68)

Text

NRR-PMDAPEm Resource From: TAYLOR, WILLIAM L [WILLIAM.TAYLOR@scana.com]

Sent: Monday, June 08, 2015 11:58 AM To: Wyman, Stephen Cc: DiFrancesco, Nicholas; Devlin-Gill, Stephanie; GRAHAM, JEREMY; GARZA, JOHN M; THOMPSON, BRUCE L; MAULDIN, ROBERT D JR

Subject:

RE: V.C. Summer ESEP Clarification Response Attachments: TR00080-005 (REV 0A).pdf

Steve, Please see the attached updated ESEP report for V.C. Summer. Let me know if you have any questions.

Willy Taylor Nuclear Licensing Engineer V.C. Summer Nuclear Station Unit 1 803-931-5661 From: Wyman, Stephen [1]

Sent: Tuesday, April 14, 2015 2:48 PM To: TAYLOR, WILLIAM L Cc: DiFrancesco, Nicholas; Devlin-Gill, Stephanie

Subject:

V.C. Summer ESEP Clarification Response

• • • This is an EXTERNAL email. Please do not click on a link or open any attachments unless you are confident it is from a trusted source.

Mr. Taylor, We appreciate your timely response to the staffs ESEP report clarification questions. In our initial review of your response, the staff noted that V.C. Summer is reviewing additional components for inclusion on the ESEL. Do you have a schedule for that review and a date for email response and/or resubmittal? Assuming an email response can be sent out sooner than the resubmittal, the staff can move forward on their review using an email response that addresses the items proposed in your clarification response. The staff may then complete the review quickly when the resubmittal arrives.

If you have any questions, please feel free to contact me at 301-415-3041.

Thanks, Steve Stephen M. Wyman USNRC/NRR/JLD/HMB Office: O-13G9 MS: O-13C5 301-415-3041 (Voice) 301-415-8333 (Fax)

Stephen.Wyman@nrc.gov 1

Hearing Identifier: NRR_PMDA Email Number: 2141 Mail Envelope Properties (c6ed0be5-aa43-44b3-b0c6-86d890890792)

Subject:

RE: V.C. Summer ESEP Clarification Response Sent Date: 6/8/2015 11:57:47 AM Received Date: 6/8/2015 11:57:57 AM From: TAYLOR, WILLIAM L Created By: WILLIAM.TAYLOR@scana.com Recipients:

"DiFrancesco, Nicholas" <Nicholas.DiFrancesco@nrc.gov>

Tracking Status: None "Devlin-Gill, Stephanie" <Stephanie.Devlin-Gill@nrc.gov>

Tracking Status: None "GRAHAM, JEREMY" <Jeremy.Graham@scana.com>

Tracking Status: None "GARZA, JOHN M" <JGARZA@scana.com>

Tracking Status: None "THOMPSON, BRUCE L" <BTHOMPSON@scana.com>

Tracking Status: None "MAULDIN, ROBERT D JR" <RMauldin@scana.com>

Tracking Status: None "Wyman, Stephen" <Stephen.Wyman@nrc.gov>

Tracking Status: None Post Office: TWMS01.nrc.gov Files Size Date & Time MESSAGE 1486 6/8/2015 11:57:57 AM TR00080-005 (REV 0A).pdf 781362 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

TR00080-005 REVISION 0 Expedited Seismic Evaluation Process Report for V.C. Summer Nuclear Station Table of Contents 1.0 Purpose and Objective ................................................................................................................... 3 2.0 Brief Summary of the FLEX Seismic Implementation Strategies................................................. 3 3.0 Equipment Selection Process and ESEL........................................................................................ 4 3.1 Equipment Selection Process and ESEL............................................................................... 5 3.1.1 ESEL Development................................................................................................... 6 3.1.2 Power Operated Valves ............................................................................................. 7 3.1.3 Pull Boxes ................................................................................................................. 7 3.1.4 Termination Cabinets ................................................................................................ 7 3.1.5 Critical Instrumentation Indicators ........................................................................... 8 3.1.6 Phase 2 and Phase 3 Piping Connections.................................................................. 8 3.2 Justification for Use of Equipment That Is Not The Primary Means for FLEX Implementation ..................................................................................................................... 8 4.0 Ground Motion Response Spectrum (GMRS)............................................................................... 9 4.1 Plot of GMRS Submitted by SCE&G................................................................................... 9 4.2 Comparison to SSE............................................................................................................. 11 5.0 Review Level Ground Motion (RLGM) .................................................................................... 122 5.1 Description of RLGM Selected ........................................................................................ 122 5.2 Method to Estimate ISRS.................................................................................................... 13 6.0 Seismic Margin Evaluation Approach ......................................................................................... 13 6.1 Summary of Methodologies Used ...................................................................................... 14 6.2 HCLPF Screening Process.................................................................................................. 14 6.2.1 Overview................................................................................................................. 14 6.2.2 Generic Screening Results ...................................................................................... 15 6.3 Seismic Walkdown Approach............................................................................................. 17 6.3.1 Walkdown Approach............................................................................................... 17 Page 1 of 65

TR00080-005 REVISION 0 6.3.2 Application of Previous Walkdown Information .................................................... 18 6.3.3 Significant Walkdown Findings.............................................................................. 18 6.4 HCLPF Calculation Process ............................................................................................... 23 6.5 Functional Evaluations of Relays ....................................................................................... 23 6.6 Tabulated ESEL HCLPF Values (Including Key Failure Modes)...................................... 23 7.0 Inaccessible Items ........................................................................................................................ 26 8.0 ESEP Conclusions and Results.................................................................................................... 27 8.1 Supporting Information....................................................................................................... 27 8.2 Identification of Planned Modifications ............................................................................. 28 8.3 Modification Implementation Schedule.............................................................................. 29 8.4 Summary of Regulatory Commitments .............................................................................. 30 9.0 References.................................................................................................................................... 32 Attachments:

Attachment A: VCSNS Unit 1 ESEL........35 Attachment B: ESEP HCLPF Values and Failure Modes Tabulation.......50 Attachment C: Seismic Review Team.......64 Page 2 of 65

TR00080-005 REVISION 0 1.0 Purpose and Objective 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 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. Depending on the comparison between the reevaluated seismic hazard and the current design basis, further risk assessment may be required. Assessment approaches acceptable to the staff include a seismic probabilistic risk assessment (SPRA), or a seismic margin assessment (SMA).

Based upon the assessment results, the NRC staff will determine whether additional regulatory actions are necessary.

This report describes the Expedited Seismic Evaluation Process (ESEP) undertaken for V.C. Summer Nuclear Station Unit 1 (VCSNS). The intent of the ESEP is to perform an interim action in response to the NRCs 50.54(f) letter [1] to demonstrate seismic margin through a review of a subset of the plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events.

The ESEP is implemented using the methodologies in the NRC endorsed guidance in EPRI 3002000704, Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic [2].

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

2.0 Brief Summary of the FLEX Seismic Implementation Strategies The VCSNS FLEX response strategies for reactor core cooling and heat removal, reactor inventory control/long-term subcriticality, core cooling and heat removal (Modes 5 and

6) and containment function are summarized below. This summary is derived from the VCSNS Overall Integrated Plan (OIP) and subsequent updates in Response to the March 12, 2012, Commission Order EA-12-049 [3a-e]. A simplified diagram of the fluid paths can be found in Figure 11 of the latest OIP [3e], FLEX Strategy Conceptual Mechanical Diagram.

Reactor core cooling and heat removal is achieved via steam release from the Steam Generators (SGs) with SG makeup from the Turbine Driven Emergency Feedwater Pump Page 3 of 65

TR00080-005 REVISION 0 (TDEFP) during FLEX Phase 1 with suction from the Condensate Storage Tank (CST).

Maintaining core cooling and heat removal will rely upon the continued operation of the TDEFP, which is capable of feeding the steam generators as long as there is an ample steam supply to drive the TDEFPs turbine.

During Phase 2 and beyond, the reactor core cooling strategy is to connect and repower a Motor Driven Emergency Feedwater Pump (MDEFP) for injection into the steam generators in the event that the TDEFP fails or when ample steam is no longer available to drive the TDEFPs turbine. The Emergency Feed Water flow control valves and Main Steam (MS) Power-Operated Relief Valves (PORVs) are also required to provide reactor core heat-removal capability. The portable Phase 2 reactor core heat removal is achieved via the credited B.5.b connection or via the new FLEX mechanical connections located in the Intermediate Building. The Phase 2 strategy only requires manipulation of manual valves.

Reactor inventory control/long-term subcriticality strategy from normal operation and Modes 5 and 6 conditions consists of a portable reactor coolant system makeup pump taking suction from the Boric Acid Tanks and supplying borated water via Reactor Coolant System (RCS) make-up connections.

RCS inventory control relies upon shrink, passive reactor coolant pump seal leakage, and letdown via head-vents and/or PORVs. The reactor coolant pump seal leak-off is manually isolated to conserve inventory and maintain leak-off flow within the Reactor Building. To ensure SG continued heat removal capability, accumulator isolation valves are electrically closed during the cooldown to prevent nitrogen injection into the reactor coolant system.

There are no Phase 1 or Phase 2 FLEX actions to maintain containment integrity. Phase 3 entails repowering select reactor building cooling unit (RBCU) fans inside of containment using portable generators. Cooling water is provided via a portable pump with suction from the Service Water Pond discharging to new manually operated service water makeup connections to the RBCUs.

Necessary electrical components are outlined in the VCSNS FLEX OIP submittal [3e].

The strategy entails utilizing two portable 1MW generators to repower a 7.2 kV vital bus and subsequently repowering an MDEFP, 480 V motor control centers, an RBCU fan, vital batteries and associated chargers, as well as monitoring instrumentation required for core cooling, reactor coolant inventory, and containment integrity.

3.0 Equipment Selection Process and ESEL The selection of equipment for the Expedited Seismic Equipment List (ESEL) followed the guidelines of EPRI 3002000704 [2]. The ESEL for Unit 1 is presented in Attachment A. Development of the ESEL is documented in Westinghouse correspondence V. C. Summer Unit 1 Expedited Seismic Equipment List [19], whereas the final ESEL is documented in attachment 5 to Westinghouse Correspondence LTR-RAM-I-14-064, Revision 1 [20].

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TR00080-005 REVISION 0 3.1 Equipment Selection Process and ESEL The selection of equipment to be included on the ESEL was based on installed plant equipment credited in the FLEX strategies during Phase 1, 2 and 3 mitigation of a Beyond Design Basis External Event (BDBEE), as outlined in the latest VCSNS OIP [3e]

in Response to the March 12, 2012, Commission Order EA-12-049. The OIP provides the VCSNS FLEX mitigation strategy and serves as the basis for equipment selected for the ESEP.

The scope of installed plant equipment includes equipment relied upon for the FLEX strategies to sustain the critical functions of core cooling and containment integrity consistent with the VCSNS OIP [3e]. FLEX recovery actions are excluded from the ESEP scope per EPRI 3002000704 [2]. The overall list of planned FLEX modifications and the scope for consideration herein is limited to those required to support core cooling, reactor coolant inventory and subcriticality, and containment integrity functions.

Portable and pre-staged FLEX equipment (not permanently installed) are excluded from the ESEL per EPRI 3002000704 [2].

The ESEL component selection followed the EPRI guidance outlined in Section 3.2 of EPRI 3002000704 [2].

1. The scope of components is limited to that required to accomplish the core cooling and containment safety functions identified in Table 3-2 of EPRI 3002000704 [2].

The instrumentation monitoring requirements for core cooling/containment safety functions are limited to those outlined in the EPRI 3002000704 [2] guidance, and are a subset of those outlined in the VCSNS OIP [3e].

2. The scope of components is limited to installed plant equipment and FLEX connections necessary to implement the VCSNS OIP [3e] as described in Section 2.

3. The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either Primary or Back-up/Alternate).

4. The Primary FLEX success path is to be specified. Selection of the Back-up/Alternate FLEX success path must be justified.

5. Phase 3 coping strategies are included in the ESEP scope, whereas recovery strategies are excluded.

6. Structures, systems, and components excluded per the EPRI 3002000704 [2]

guidance are:

x Structures (e.g. containment, reactor building, control building, auxiliary building, etc.)

x Piping, cabling, conduit, Heating, Ventilation, and Air Conditioning (HVAC), and their supports.

x Manual valves, check valves, and rupture disks, except for manual valves that are required to change state as part of the FLEX mitigation strategies and are operated using reach rods.

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TR00080-005 REVISION 0 x Power-operated valves not required to change state as part of the FLEX mitigation strategies.

x Nuclear Steam Supply System (NSSS) components (e.g., Reactor Vessel (RV) and internals, Reactor Coolant Pumps (RCPs) and seals, etc.)

x Very small passive components such as line-mounted strainers, accumulators, and orifices.

x Portions of systems that are not used as transport mechanisms for delivering required flows, such as components beyond boundary valves.

x Electrical equipment not specifically relied upon to perform the FLEX functions, such as power sources and distribution not directly supporting FLEX active components.

x Controls for which plant procedures provide instructions for manual operation (in the event of control system, component, permissive, or interlock failures) that ensure performance of the FLEX function.

x Portions of installed equipment (and FLEX connections) that are not relied upon in the FLEX strategy to sustain the critical functions of core cooling and containment integrity (according to Section 3.2 within Reference 2, and Tables D-1 and D-2 within Reference 21).

7. For cases in which neither train was specified as a primary or back-up strategy, only one train component (generally 'A' train) is included in the ESEL.

3.1.1 ESEL Development The ESEL was developed by reviewing the VCSNS OIP [3a-e] to determine the major equipment involved in the FLEX strategies. Further reviews of plant drawings (e.g.,

Piping and Instrumentation Diagrams (P&IDs) and Electrical One Line Diagrams) were performed to identify the boundaries of the flow paths to be used in the FLEX strategies and to identify specific components in the flow paths needed to support implementation of a single success path for the FLEX strategies supporting the core cooling and containment integrity FLEX functions.

Boundaries were established at an electrical or mechanical isolation device (e.g., isolation amplifier, valve, etc.) in branch circuits/branch lines off the defined strategy electrical or fluid flow path. P&IDs were the primary reference documents used to identify mechanical components and instrumentation. The flow paths used for FLEX strategies were selected and specific components were identified using detailed equipment and instrument drawings, piping isometrics, electrical schematics and one-line drawings, system descriptions, design basis documents, etc., as necessary. The P&IDs were also used to determine the normal position of system valves and the valve positioning required in order to align the system in support of the FLEX functions. Isometric drawings were used to determine if any manual valves required to operate in support of the FLEX functions can be operated using reach rods, since manual valves with reach rods must be included on the ESEL.

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TR00080-005 REVISION 0 The electrical equipment required to support the mechanical components used in the FLEX strategies evaluated for the ESEL was evaluated for its inclusion on the ESEL using electrical drawings and the guidance in [2], Section 3.

3.1.2 Power Operated Valves Page 3-3 of EPRI 3002000704 [2] notes that power operated valves not required to change state are excluded from the ESEL. Page 3-2 of EPRI 3002000704 [2] also notes that functional failure modes of electrical and mechanical portions of the installed Phase 1 equipment should be considered (e.g., RCIC/AFW trips). To address this concern, the following guidance is applied in the VCSNS ESEL for functional failure modes associated with power operated valves:

x Power operated valves that remain energized during the Extended Loss of all AC Power (ELAP) events (such as DC powered valves), were included on the ESEL.

x Power operated valves not required to change state as part of the FLEX mitigation strategies were not included on the ESEL. The seismic event also causes the ELAP event; therefore, the valves are incapable of spurious operation, as they would be de-energized.

x Power operated valves not required to change state as part of the FLEX mitigation strategies during Phase 1, and are re-energized and operated during subsequent Phase 2 and 3 strategies, were not evaluated for spurious valve operation, as the seismic event that caused the ELAP has passed before the valves are re-powered.

3.1.3 Pull Boxes Pull boxes were deemed unnecessary to add to the ESELs, as these components provide completely passive locations for pulling or installing cables. No breaks or connections in the cabling are included in pull boxes. Pull boxes were considered part of conduit and cabling, which are excluded in accordance with EPRI 3002000704 [2].

3.1.4 Termination Cabinets Termination cabinets, including cabinets necessary for FLEX Phase 2 and Phase 3 connections, provide consolidated locations for permanently connecting multiple cables.

The termination cabinets and the internal connections provide a completely passive function; however, the cabinets are included in the ESEL to ensure industry knowledge on panel/anchorage failure vulnerabilities is addressed.

Examples of termination cabinets on the VCSNS ESEL include the XPN-7100 series.

Items #138 and 142-150 within Attachment A are several examples of termination cabinets included on the ESEL.

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TR00080-005 REVISION 0 3.1.5 Critical Instrumentation Indicators Critical indicators and recorders are typically physically located on panels/cabinets and are included as separate components; however, seismic evaluation of the instrument indication may be included in the panel/cabinet seismic evaluation (rule-of-the-box).

All main control board panels (XCP-6100 series) fall in this category and are on the electrical ESEL for VCSNS. Examples within Attachment A include items #59, 61, 62, 66, 67, 177, 178, 179, 180, and 181.

3.1.6 Phase 2 and Phase 3 Piping Connections Item 2 in Section 3.1 above notes that the scope of equipment in the ESEL includes FLEX connections necessary to implement the VCSNS OIP [3e] as described in Section 2. Item 3 in Section 3.1 also notes that The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either Primary or Back-up/Alternate).

Item 6 in Section 3.1 above goes on to explain that Piping, cabling, conduit, HVAC, and their supports are excluded from the ESEL scope in accordance with EPRI 3002000704 [2].

Therefore, piping and pipe supports associated with FLEX Phase 2 and Phase 3 connections are excluded from the scope of the ESEP evaluation. However, any active valves in FLEX Phase 2 and Phase 3 connection flow path are included in the ESEL.

3.2 Justification for Use of Equipment That Is Not the Primary Means for FLEX Implementation The primary flow paths for the Steam Generator (SG) makeup, Emergency Feedwater (EFW) steam supply, and containment integrity FLEX strategies were used for ESEL development, while the alternate flow path for the RCS makeup FLEX strategy was used rather than the primary flow path. The alternate flow path for RCS makeup, a portable makeup pump, meets the requirements of NEI 12-06 for use following a seismic event; however, the electrical supply for the primary flow path for RCS makeup is not seismically qualified and thus cannot be credited.

The VCSNS OIP [3e] provides two redundant primary means for providing RCS Inventory Control. From the VCSNS OIP [3e], RCS inventory and reactivity control involve use of the stations installed Alternate Seal Injection (ASI) positive-displacement (PD) pump or an on-site portable Reactor Makeup FLEX pump, referred to as the FX RCS MU PUMP.

The VCSNS strategy for RCS inventory control and boration strategy is to utilize the ASI pump for RCS injection, if the pump is running immediately after the ELAP. This method allows for minimal operator action and prevents damage to the RCP seals. It could take up to an hour before an ELAP is declared. The Emergency Operating Page 8 of 65

TR00080-005 REVISION 0 Procedures (EOP) have a step to identify if the ASI pump is running. If not, then the RCS makeup pump would be identified as the alternative/preferred method and made ready when manpower is available or before 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. The use of a portable RCS makeup pump to an identified RCS connection point is the VCSNS credited seismic strategy for RCS inventory control and boration.

The complete ESEL for VCSNS is presented in Attachment A.

4.0 Ground Motion Response Spectrum (GMRS) 4.1 Plot of GMRS Submitted by SCE&G The Rock Safe Shutdown Earthquake (SSE) Control Point is defined as top of competent rock at an approximate elevation of 350 feet, which is nominally 85 feet below plant grade elevation of 435 feet [4].

The GMRS plot and tabulated data for VCSNS are provided in Figure 4-1 and Table 4-1, respectively. Development of the VCSNS GMRS is documented in [4] and [25]. In accordance with the 50.54(f) letter and following the guidance in EPRI SPID [18], a Probabilistic Seismic Hazard Analysis (PSHA) was performed using the 2012 CEUS Seismic Source Characterization for Nuclear Facilities [22], a Regional Seismic Catalog Correction [22], and updated EPRI Ground Motion Model for the CEUS [24].

Figure 4-1: GMRS for VCSNS [4]

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TR00080-005 REVISION 0 Table 4-1: GMRS for VCSNS [4]

Freq. (Hz) GMRS (g) 100 3.68E-01 90 3.98E-01 80 4.50E-01 70 5.30E-01 60 6.29E-01 50 7.20E-01 45 7.53E-01 40 7.74E-01 35 7.84E-01 30 7.82E-01 25 7.67E-01 20 7.44E-01 15 6.92E-01 12.5 6.49E-01 10 5.90E-01 9 5.54E-01 8 5.15E-01 7 4.71E-01 6 4.24E-01 5 3.73E-01 4 3.19E-01 3 2.58E-01 2.5 2.22E-01 2 1.91E-01 1.5 1.50E-01 1.25 1.25E-01 1 9.81E-02 0.9 9.30E-02 0.8 8.67E-02 0.7 7.90E-02 0.6 7.01E-02 0.5 5.98E-02 0.4 4.79E-02 0.3 3.59E-02 0.2 2.39E-02 0.167 2.00E-02 0.125 1.50E-02 0.1 1.20E-02 Page 10 of 65

TR00080-005 REVISION 0 4.2 Comparison to SSE The SSE is defined in terms of a Peak Ground Acceleration (PGA) and a design response spectrum. Table 4-2 shows the spectral acceleration values as a function of frequency for the 5% damped horizontal SSE. Figure 4-2 shows a comparison between the GMRS and SSE for VCSNS. In the 1 to 10 Hz part of the response spectrum, the GMRS exceeds the SSE. The GMRS also exceeds the SSE for frequencies above 10 Hz. In both frequency ranges, VCSNS screens in for a risk evaluation.

Table 4-2: SSE for VCSNS [4]

Freq. (Hz) 0.5 1 2.5 5 9 10 25 100 SA (g) 0.08 0.2 0.4 0.4 0.29 0.26 0.15 0.15 Figure 4-2: Comparison of VCSNS GMRS with SSE [4]

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TR00080-005 REVISION 0 5.0 Review Level Ground Motion (RLGM) 5.1 Description of RLGM Selected The RLGM was developed using Option 1 of EPRI Report 3002000704 [2] Section 4.

Under this option, the RLGM is equal to the SSE scaled up by a factor.

Per Section 4 of this report, the maximum GMRS/SSE spectral ratio between 1 and 10 Hertz is equal to 2.3 and occurs at 10 Hertz. Therefore, the RLGM/SSE scale factor is equal to 2.0, which is the upper limit. The SSE and RLGM ground response spectra are plotted in Figure 5-1. The control point for the RLGM is the top of the bedrock. The high confidence of a low probability of failure (HCLPF) values reported herein are for reference to the top of bedrock control point.

For Condensate Storage Tank (CST, equipment ID XTK0008) only, the applied ground motion and HCLPF are based on the GMRS identified in Section 4 of this report. In that case, the GMRS represents the RLGM per EPRI 3002000704 [2] Section 4, Option 2.

The CST is founded on a grade slab in the yard, and a soil-structure interaction analysis (SSI) was performed as part of the HCLPF analysis [11k].

The 5% damping RLGM horizontal GRS is provided in Table 5-1 and plotted in Figure 5-1. Note that the Vertical RLGM is 2/3 of horizontal RLGM.

Table 5-1: VCSNS Review Level Ground Motion Data at 5% Damping

[11b]

Frequency (Hz) Spectral Acceleration (g) 0.13 0.0122 0.55 0.2200 2.00 0.8000 6.00 0.8000 20.00 0.3000 40.00 0.3000 100.00 0.3000 Page 12 of 65

TR00080-005 REVISION 0 VCSNS Unit 1 RLGM and SSE Ground Response Spectra Horizontal Direction - 5% Damping - Applied at Rock 1.0000 Damping: 5%

Sa (g) 0.1000 0.0100 0 1 10 100 Frequency (Hz)

RLGM SSE Figure 5-1: Ground Response Spectra [11b]

5.2 Method to Estimate ISRS Plant design basis in-structure response spectra (ISRS) data are contained in plant specification SP-702-4461-00 [14]. SSE ISRS data in that document were digitized and scaled by a 2.0 factor to produce the RLGM seismic demand.

Generation of the design basis spectra is discussed in FSAR [5] Section 3.7. The SSE design basis ISRS obtained from SP-702-4461-00 are very conservative because they are based on 2% structural damping. This is because the SSE ISRS were obtained by scaling up the OBE ISRS with no credit taken for higher structural damping. A 2% damping level is conservative, but reasonable, for an OBE but is unrealistically low for beyond-SSE seismic loading. Therefore, when appropriate, the equipment HCLPF calculations for ESEP included a procedure to credit the benefit of higher effective structural damping. Further details on this topic are provided in supporting calculations [11].

6.0 Seismic Margin Evaluation Approach The ESEP goal is to demonstrate that ESEL items have sufficient seismic capacity to meet or exceed the demand characterized by the RLGM. The seismic capacity is Page 13 of 65

TR00080-005 REVISION 0 characterized as the PGA for which there is a HCLPF. The PGA is associated with a specific spectral shape, in this case the 5%-damped RLGM spectral shape. The HCLPF capacity must be equal to or greater than the RLGM PGA (= 0.30g). The criteria for seismic capacity determination are given in Section 5 of EPRI 3002000704 [2].

There are two basic approaches for developing HCLPF capacities:

1. Deterministic approach using the conservative deterministic failure margin (CDFM) methodology of EPRI NP-6041, A Methodology for Assessment of Nuclear Power Plant Seismic Margin (Revision 1) [6].

2. Probabilistic approach using the fragility analysis methodology of EPRI TR-103959, Methodology for Developing Seismic Fragilities [7].

6.1 Summary of Methodologies Used The seismic margins methodology of EPRI report NP-6041-SL [6] was applied for this effort. Use of this methodology comports with the EPRI 3002000704 Section 5. The primary tasks performed were:

x Generic seismic screening per NP-6041-SL Table 2-4.

x Performance of seismic walkdowns.

x Item-specific screening via walkdown, review of design data, and performance of screening calculations.

x Performance HCLPF calculations for screened-in equipment.

6.2 HCLPF Screening Process 6.2.1 Overview The seismic margins screening methodology of NP-6041-SL was applied. The primary steps for this screening process are:

1. Apply NP-6041-SL Table 2-4 to determine which equipment items and failure modes may be screened-out on a generic basis.

2. For each equipment item, perform a seismic walkdown to verify generic screening may be applied and to verify the item does not have any specific seismic vulnerabilities.

3. Verify anchorage capacity.

The generic screening criteria of Table 2-4 are dependent on the applied screening level and are applicable to equipment located within 40 feet of plant grade. For VCSNS ESEP project:

x The peak 5% spectral acceleration of the RLGM is 0.80g. This level is on the boundary between the 1st and 2nd screening lanes of NP-6041-SL Table 2-4. As a Page 14 of 65

TR00080-005 REVISION 0 conservative bound the 1.2g screening criteria of Table 2-4 were applied (2nd screening lane).

x A limited number of components in the RB were located above 40 from plant grade; all other equipment was located within 40 of plant grade.

For application to the ESEP, the differences between the 1st and 2nd screening lanes of NP-601-SL Table 2-4 are modest. Table 6-1 below summarizes application of Table 2-4 screening for the ESEP. Applied plant grade was Elevation 435. This grade elevation was also used for screening under the seismic IPEEE [13]. Per the FSAR, this grade elevation is constant throughout the power block area.

After completion of the screening process, an item is either screened-out or screened-in.

The presumptive seismic capacity of a screened-out item exceeds the applied screening level and no further evaluation is needed. An item that is initially screened-in requires a HCLPF analysis to address the failure mode cited by the seismic review team (SRT). The HCLPF capacity may or may not be above the screening level.

6.2.2 Generic Screening Results Table 6-1 summarizes the generic screening results for the ESEL. Only the relevant equipment types are listed. Based on the generic screening:

x HCLPF analyses are required for atmospheric storage tanks x Relay chatter requires evaluation Other generic screening requirements were addressed by walkdown, design review and anchorage verification. These assessments are documented in the screening evaluation work sheets (SEWS) [12].

Table 6-1: Summary of Generic Screening per NP-6041-SL Table 2-4, 1.2g Screening Level Generic Screening Equipment Type Screening Result Criteria Active valves Note (f) applies. There are no extremely large extended operators on 2-inch or smaller piping. There are no MOVs on piping lines of 2 inch diameter or smaller in the scope.

Passive valves No evaluation required.

Heat exchangers Notes (h), (i) apply. There is only one small heat exchanger (TPP0008-Page 15 of 65

TR00080-005 REVISION 0 Table 6-1: Summary of Generic Screening per NP-6041-SL Table 2-4, 1.2g Screening Level Generic Screening Equipment Type Screening Result Criteria HE1) on the ESEL. Anchorage and load path were verified by bounding calculations. Potential failure modes of the heat exchanger body were addressed by walkdown and design review.

Atmospheric storage tanks Evaluation required. HCLPF analyses were performed for the atmospheric storage tanks.

Pressure vessels Notes (h), (i) apply. There is only one small pressure vessel (TPP0008-OR1) on the ESEL. Anchorage and load path were verified by bounding calculations. Potential failure modes of the vessel body were addressed by walkdown and design review.

Batteries and racks Note (k) applies. Batteries are in braced racks designed for seismic loads. A HCLPF analyses was performed for the battery rack anchorage.

Horizontal pumps No evaluation required.

Fans Notes (n), (o) apply. Notes (n), (o) were addressed by walkdown and screening. Vibration isolators are not present for any fans in the scope.

Air handlers Notes (n), (o) apply. Notes (n), (o) were addressed by walkdown and screening. Vibration isolators are not present for any air handlers in the scope.

Active electrical power Notes (s) and (t) apply. Note (s) was addressed by walkdown and design distribution panels review. Items containing in-scope relays are identified on the ESEL and are evaluated for relay chatter.

Passive electrical power Note (s) applies. Note (s) was addressed by walkdown and design distribution panels review.

Transformers Notes (u) and (v) apply. The ESEL includes dry-type transformers. A design review verified coil restraint. Anchorage was verified by bounding calculations.

Battery chargers & inverters Note (w) applies. Per walkdown and design review, the items on the ESEL are solid state units. Anchorage was verified by bounding calculations.

Instrumentation and control Notes (s) and (t) apply. Note (s) was addressed by walkdown and design panels and racks review. Items containing in-scope relays are identified on the ESEL and are evaluated for relay Page 16 of 65

TR00080-005 REVISION 0 Table 6-1: Summary of Generic Screening per NP-6041-SL Table 2-4, 1.2g Screening Level Generic Screening Equipment Type Screening Result Criteria chatter.

Temperature sensors; Note (x) applies. Note (x) was addressed by walkdown and design pressure and level sensors. review. Sensors in the scope were typically mounted in-line on piping.

Relevant notes from NP-6041-SL Table 2-4

f. Evaluation recommended for MOVs in piping lines of 2 inches diameter or less.

h. Margin evaluation only needs to consider anchorage and supports.

i. For vessels designed by dynamic analysis or equivalent static analysis enveloping vessel inertial and piping loading, only the anchorage and supports require evaluation. For vessels not meeting these criteria, all potential failure modes require evaluation.

k. Batteries mounted in braced racks designed for seismic loads or qualified by dynamic testing do not require evaluation. Rigid spacers between batteries and end restraints are required. Batteries should be tightly supported by side rails.

n. All units supported on vibration isolators require evaluation of anchorage.

o. Evaluation should focus on anchorage and supports.

s. Walkdown should be conducted to verify that the instruments are properly attached to the cabinets.

t. Relays, contactors, switches, and breakers must be evaluated for chatter and trip if functionality during strong shaking is required.

u. Anchorage evaluation required.

v. Liquid-filled transformers require evaluation of overpressure safety switches. The transformer coils should be restrained within the cabinet for dry transformers.

w. Solid state units require anchorage checks. Others require evaluation.

x. Insufficient data are available for screening guidelines. Emphasis should be on attachments.

6.3 Seismic Walkdown Approach 6.3.1 Walkdown Approach Walkdowns followed the guidance of NP-6041-SL Section 2. Walkdowns were performed by two-person seismic review teams (SRTs) consisting of engineers with seismic experience. The SRT used NP-6041-SL Appendix F to evaluate item-specific equipment caveats. The SRT also recorded notes and took photographs of the item under review. A number of walkdown sessions were performed as indicated below. Reactor Building items were inspected during the week of April 21, 2014, while the plant was in a refueling outage.

Walkdown Date SRT Plant Support Week of January 13, 2014 John J. OSullivan (S&A) Jeremy Graham (SCE&G)

Stephane Damolini (S&A) Dan Goldston (SCE&G)

Week of February 24, 2014 John J. OSullivan (S&A) Jeremy Graham (SCE&G)

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TR00080-005 REVISION 0 Seth Baker (S&A)

Week of April 21, 2014 John J. OSullivan (S&A) Eric Rumfelt (SCE&G)

Seth Baker (S&A) Courtney Tampas (SCE&G)

Andrew Hall (SCE&G)

Walkdown findings for each item are documented in screening evaluation work sheets (SEWS) [12]. The SEWS notes also identify evaluations and reviews performed to support screening. Brief resumes of SRT members are provided in Attachment C.

6.3.2 Application of Previous Walkdown Information New seismic walkdowns were performed for ESEL equipment. The results of the previous seismic margin evaluation, performed for the Seismic IPEEE program, were reviewed and used for background purposes only.

6.3.3 Significant Walkdown Findings The walkdown and screening results are summarized in the following tables:

x Initially screened-in items selected for HCLPF analysis are listed in Table 6-2.

x Recommended actions to resolve miscellaneous screening issues are listed in Table 6-3.

The actions listed in Table 6-3 are related to issues such as seismic housekeeping, potential seismic interaction, and issues related to equipment caveats. These issues are planned to be resolved through the plant corrective action process (see Section 8.2). For each item, the basis for anchorage screening is identified in the individual SEWS [12].

Project calculations [11] were created to support anchorage screening and contain bounding anchorage calculations for various equipment types.

A select group of ESEL items was initially screened-in based on anchorage. For each of these items, a detailed analysis of the anchorage capacity was performed. The items are identified in Section 6.5.

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TR00080-005 REVISION 0 Table 6-2: Items Selected for HCLPF Analysis No. ID Description Bldg Elev Basis for Selection (ft)

1. XTK0025 REFUELING WATER AB 412 Per NP-6041-SL Table 2-4 seismic capacity cannot be screened and HCLPF STORAGE TANK analysis is required for overall seismic capacity.

2. XPN6004 BOP INSTRUMENT PANEL CB 436 Floor embeds were visible along the front and rear edges of the line-up. The TRAIN A embedments do not extend the full length of XPN6004 and a shim plates were added. Because of the load path thru the shim and unique anchorage, the anchorage is not screened. Perform HCLPF analysis for anchorage.

3. XBA-1A 125V DC DISTRIBUTION IB 412 Because the supported mass is relatively large the anchorage is not screened.

BUS 1A BATTERY Perform HCLPF analysis for anchorage. Analysis should address similar racks in the ESEP scope.

4. XMC1DA2X 480V MCC XCM1DA2X IB 463 The MCC is tall and narrow and is expected to have a low natural frequency.

The base overturning load may be relatively large. Anchorage is not screened.

Perform HCLPF analysis for MCC anchorage. Analysis should address all the MCC's in the ESEP scope (for example, apply bounding loads).

5. XTK0008 CONDENSATE STORAGE YD 435 Per NP-6041-SL Table 2-4 seismic capacity cannot be screened and HCLPF TANK analysis is required for overall seismic capacity.

6. XAA0001A RB COOLING UNIT 1A RB 514 The item is a large custom air handling unit located more than 40 above grade.

NP-6041-SL Table 2-4 screening cannot be directly applied. HCLPF analysis needs to address anchorage, overall structural integrity and functionality.

7. XVT03164-SW DRPI COOLING UNIT RB 518 The item is an air operated valve (AOV) located more than 40 above grade.

INLET HDR ISOL VALVE NP-6041-SL Table 2-4 screening cannot be directly applied. HCLPF analysis is needed to address functionality. Analysis to be performed should address similar items in RB.

8. XVT03169-SW DRPI COOLING UNIT RB 518 Conduit running along the wall is close to the bonnet. The clearance is 1.0".

OUTLET HDR ISOL VLV Because of the relatively high seismic input at high RB elevations and relatively small pipe diameter, analysis is required to verify acceptability of 1.0" clearance.

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TR00080-005 REVISION 0 Table 6-2: Items Selected for HCLPF Analysis No. ID Description Bldg Elev Basis for Selection (ft)

9. XVG03108B-SW RB COOLING UNIT 2A RB 518 The item is a motor operated valve (MOV) located more than 40 above grade.

INLET ISOLATION VLV NP-6041-SL Table 2-4 screening cannot be directly applied. HCLPF analysis is needed to address functionality. Analysis to be performed should address similar items in RB.

Apply results to similar item XVG03109B-SW.

10. DPN1HA BATTERY MAIN IB 412 The cabinet is screened-in for ESEP relay chatter assessment. Evaluation of DISTRIBUTION PANEL chatter/trip of main breaker is required.

1HA Apply results to similar item DPN1HB.

11. XSW1DA1 Class IE 480 V SWGR bus IB 463 The cabinet is screened-in for ESEP relay chatter assessment. Relay chatter XSW1DA1-ES needs to be evaluated for various relay. The HCLPF will be based on design basis seismic qualification testing of a switchgear assembly.

Apply results to similar item XSW1DA2.

12. XSW1DA Class IE 7.2 kV SWGR bus IB 463 The cabinet is screened-in for ESEP relay chatter assessment. Relay chatter XSW1DA-ES needs to be evaluated for various relay. The HCLPF will be based on design basis seismic qualification testing of a switchgear assembly.

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TR00080-005 REVISION 0 Table 6-3: Required Follow-up Actions to Resolve Screening Issues No. ID Description Bldg Elev Issue Actions (ft)

1. XVG01611A-FW MAIN FW TO STM GEN A AB 436 A flexible electrical conduit attached to a Provide slack to preclude unacceptable HDR ISOL pressure tap on north side of operator has stress on attached line. It appears that limited slack. The electrical connection slack is available and a relocation of the may be vulnerable to seismic motion of first support will suffice. VCSNS Work the valve. Order #1414403 has been written to perform rework.

2. IPV02000-MS MAIN STEAM HEADER A AB 436 A small nozzle for a pressure tap on a Modify the handrail to provide sufficient POWER RELIEF VALVE device attached to the valve is very close shake space. ECR 51004 has been issued to the adjacent hand rail. The valve to rework handrail.

motion is limited by nearby pipe support so banging of the rail on the nozzle is primary issue.

3. XBA-1A 125V DC DISTRIBUTION BUS IB 412 Battery rack with two rows and two tiers Modify rack to reduce front rail gaps (for 1A BATTERY per row. Spacers are present on sides of example, install shims behind rail batteries. Gap at front rail varies from 0" attachment points to build out the rail).

to 1/4". ECR51010 has been initiated to resolve It appears that potential seismic the identified condition.

front/back motion of the batteries due to front rail gaps can be accommodated by flexibility of the bus bars. However, NP-6041-SL Appendix F guidance states that batteries should be "encased by rack framework" or shimmed to produced "close-fitting rails".

4. XBA-1B 125V DC DISTRIBUTION BUS IB 412 Battery racks similar to XBA-1A. Refer See actions for XBA-1A 1B BATTERY to notes for that item.

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TR00080-005 REVISION 0 Table 6-3: Required Follow-up Actions to Resolve Screening Issues No. ID Description Bldg Elev Issue Actions (ft)

5. XVT02843B-MS MS HEADER B MOIST IB 436 Clearance to a nearby 3x3 angle post is a It appears the top of the 3x3 post can be COLLECTOR DRAIN VLV potential hazard. It is estimated that trimmed without adverse effects. Trim about 1/2" of motion along the pipe axial the 3x3 angle to preclude interaction.

direction would cause impact of bonnet ECR51010 has been initiated to resolve on corner of post and this is the critical the identified condition clearance.

6. XVG01611C-FW MAIN FW TO STM GEN C IB 436 A flexible electrical conduit attached to a Provide slack to preclude unacceptable HDR ISOL pressure tap on north side of operator has stress on attached line. It appears that minimal slack. The electrical connection slack is available and a minor appears to be vulnerable to seismic modification of the first support will motion of valve. suffice. VCSNS Work Order #1414404 has been written to perform rework.

7. IPT03632 EF PUMP SUCT HDR DB 412 Tubing from pipe to PT is vulnerable to Either restrain the light or move the light PRESSURE TRANSMITTER impact from a hanging light. The impact higher such that impact on tubing is on tubing near root valve IPT03632-HR- precluded. VCSNS Work Order EF appears possible. #1414405 has been written to perform rework.

8. XPN7200A Control Room Evacuation Panel IB 436 A tool locker is located behind the Move and/or restrain the locker such that (CREP A) cabinet, about 10 away. Locker is interaction is precluded. ECR51010 has unanchored and is a potential interaction been initiated to resolve the identified hazard. condition

9. XVT03164-SW DRPI COOLING UNIT INLET RB 518 The hand wheel on the operator is 0.25" Modify the handrail to preclude HDR ISOL VALVE from a hand rail. Seismic shaking may interaction. ECR51010 has been initiated produce interaction. to resolve the identified condition Page 22 of 65

TR00080-005 REVISION 0 6.4 HCLPF Calculation Process All HCLPF values were calculated using the conservative, deterministic failure margin (CDFM) criteria of NP-6041-SL. CDFM analysis criteria are summarized in NP-6041-SL Table 2-5.

For structural failure modes, the HCLPF capacity is equal to the earthquake magnitude at which the strength limit is reached. For equipment functionality failure modes, experience data or available test response spectra (TRS) are typically used to define the HCLPF capacity. The methods of NP-6041-SL Appendix Q were applied for functionality evaluations.

6.5 Functional Evaluations of Relays Verification of functional capacity for equipment mounted within 40 of grade was addressed by application NP-6041-SL Table 2-4 generic screening criteria as described above. For equipment mounted higher than 40 above grade and for in-scope relays, the methods of NP-6041-SL Appendix Q were applied for functionality evaluations. In those cases, the seismic capacity was based upon one of the following:

x Test response spectra (TRS) from plant-specific seismic qualification reports.

x Generic equipment ruggedness spectra (GERS) from EPRI report NP-5223-SL [9].

x Experience based seismic capacity per the guidelines of EPRI TR-1019200 [8].

The ESEP relay functional evaluations are documented in a supporting calculation [11i].

6.6 Tabulated ESEL HCLPF Values (Including Key Failure Modes)

Table 6-4 lists HCLPF analysis results for screened-in items. The failure modes analyzed are identified. Project calculation documents that contain the detailed HCLPF calculations are also identified.

For the following discussion, define an ESEP outlier as an item whose HCLPF capacity is less than the RLGM. There are currently four ESEP outliers:

1. XSW1DA (relay chatter)

2. XSW1DA1 (relay chatter)

3. XSW1DA2 (relay chatter, XSW1DA1 results are applicable)

4. XVT03169-SW (functionality)

Note that for the CST, the applied ground motion and HCLPF are based on the GMRS.

The CST is founded on a slab-on-grade in the yard and a detailed soil-structure interaction analysis (SSI) was performed to develop realistic seismic demand. The GMRS has a horizontal PGA of 0.37g and the CST HCLPF is more than double that level (acceptable with large margin).

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TR00080-005 REVISION 0 Relay Chatter Failure Modes Switchgear XSW1DA, XSW1DA1 and XSW1DA2 are ESEP-outliers with respect to relay chatter. Credit for operator action may resolve the relay chatter failure modes. The approach for resolution is discussed in Section 8.2.

Items with Functional or Structural Failure Modes The valve XVT03169-SW is located at a high elevation of the RB and application of a relatively large lateral seismic load was required. The failure mode is related to lateral seismic displacement of the valve. A modification for XVT03169-SW would involve providing more side-side shake space (currently 1 is available between the valve and a wall conduit). Alternatively, the supporting piping could be locally stiffened.

Tabulated HCLPF Values The HCLPF values for all ESEL items are tabulated in Attachment B. In general, the HCLPF for a screened-out item equals or exceeds the RLGM.

+&/3)J HCLPF for screened-out items and failure modes Unless justified by calculations, the above HCLPF is applicable for screened-out items and covers all relevant failure modes.

For the items listed in Table 6-4, the listed HCLPF values and failure modes are controlling except for those items cited in Note 5. For those items, the functionality limit is lower than the anchorage HCLPF and is controlling.

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TR00080-005 REVISION 0 Table 6-4: HCLPF Analysis Results ID Description Bldg Elev (ft) HCLPF (g) Failure Mode Analyzed Reference (see [11])

XTK0025 REFUELING WATER AB 412 0.32 Anchorage, due to overturning moment. 13C4188-ESEP-CAL-005 STORAGE TANK XPN6004 BOP INSTRUMENT CB 436 1.07 Anchorage, load path (see Note 5). 13C4188-ESEP-CAL-006 PANEL TRAIN A XBA-1A 125V DC IB 412 1.16 Anchorage, concrete breakout (see Note 5). 13C4188-ESEP-CAL-006 DISTRIBUTION BUS 1A BATTERY DPN1HA BATTERY MAIN DISTR IB 412 0.35 Functionality, including main breaker trip. 13C4188-ESEP-CAL-009 PANEL 1HA XSW1DA CLASS IE 7.2 KV SWGR IB 463 0.20 Relay chatter. 13C4188-ESEP-CAL-009 BUS XSW1DA-ES XSW1DA1 CLASS IE 480 V SWGR IB 463 0.24 Relay chatter. 13C4188-ESEP-CAL-009 BUS XSW1DA1-ES XMC1DA2X 480V MCC XCM1DA2X IB 463 0.38 Anchorage, embedment steel stress (see 13C4188-ESEP-CAL-006 Note 5).

XAA0001A RB COOLING UNIT 1A RB 514 0.35 Overall structural integrity. 13C4188-ESEP-CAL-008 XVT03164-SW DRPI COOLING UNIT RB 518 0.44 Functionality. 13C4188-ESEP-CAL-010 INLET HDR ISOL VLV XVT03169-SW DRPI COOLING UNIT RB 518 0.24 Impaired functionality due to seismic 13C4188-ESEP-CAL-010 OUTLET HDR ISOL VLV interaction (impact with wall conduit).

XVG03108B-SW RB COOLING UNIT 2A RB 518 0.82 Functionality. 13C4188-ESEP-CAL-010 INLET ISOLATION VLV XTK0008 CONDENSATE YD 435 0.88 Sliding due to exceedance of base shear 13C4188-ESEP-CAL-004 (See Note 4)

STORAGE TANK capacity.

Table 6-4 Notes

1. The listed HCLPF value is for comparison to the horizontal PGA at the bedrock surface.

2. The listed Reference is an S&A project calculation document.

3. Results for XSW1DA1 are applicable to XSW1DA2; results for DPN1HA are applicable to DPN1HB.

4. For CST only, the applied ground motion and HCLPF are based on the GMRS; the GMRS has a 0.37g horizontal PGA at rock.

5. Where Note 5 is cited, the screening limit for functionality is lower than the listed anchorage HCLPF.

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TR00080-005 REVISION 0 7.0 Inaccessible Items The items in Table 7.1 are inside containment and currently inaccessible. The station will perform walkdowns of the items in Table 7.1 during the fall 2015 refueling outage. The station proposes to have an updated ESEP with a complete ESEL list submitted by February 1, 2015.

TABLE 7.1 - INACCESSIBLE ITEMS TO BE ADDED TO ESEL ESEL Equipment Operating State1 Item Normal Desired Notes/Comments Num ID Description State State SG A WD RGE 219 ILI00477 N/A N/A LEVEL INDICATOR SG B WD RGE 220 ILI00487 N/A N/A LEVEL INDICATOR SG C WD RANGE 221 ILI00497 N/A N/A LEVEL INDICATOR SG A WIDE RANGE A 222 ILT00477 N/A N/A LEVEL XMTR SG B WIDE RANGE 223 ILT00487 N/A N/A LEVEL XMTR SG C WIDE RANGE 224 ILT00497 N/A N/A LEVEL XMTR RCS WIDE RANGE 225 IPI00402B PRESSURE N/A N/A INDICATOR PT-402 RC WIDE 226 IPT00402 RNG. PRESS. N/A N/A TRANSMITTER RC LOOP A COLD LEG 227 ITE00410 N/A N/A TEMPERATURE ELEMENT RC LOOP A COLD 228 ITI00410 LEG TEMP N/A N/A INDICATOR Page 26 of 65

TR00080-005 REVISION 0 8.0 ESEP Conclusions and Results 8.1 Supporting Information VCSNS has performed the ESEP as an interim action in response to the NRCs 50.54(f) letter [1]. It was performed using the methodologies in the NRC endorsed guidance in EPRI 3002000704 [2].

The ESEP provides an important demonstration of seismic margin and expedites plant safety enhancements through evaluations and potential near-term modifications of plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events.

The ESEP is part of the overall VCSNS response to the NRCs 50.54(f) letter [1]. On March 12, 2014, the Nuclear Energy Institute (NEI) submitted to the NRC results of a study [15] of seismic core damage risk estimates based on updated seismic hazard information as it applies to operating nuclear reactors in the Central and Eastern United States (CEUS). The study concluded that "site-specific seismic hazards show that there

[...] has not been an overall increase in seismic risk for the fleet of U.S. plants" based on the re-evaluated seismic hazards. As such, the "current seismic design of operating reactors continues to provide a safety margin to withstand potential earthquakes exceeding the seismic design basis."

The NRCs May 9, 2014 NTTF 2.1 Screening and Prioritization letter [17] concluded that the fleetwide seismic risk estimates are consistent with the approach and results used in the Gl-199 safety/risk assessment. The letter also stated that As a result, the staff has confirmed that the conclusions reached in Gl-199 safety/risk assessment remain valid and that the plants can continue to operate while additional evaluations are conducted.

An assessment of the change in seismic risk for VCSNS was included in the fleet risk evaluation submitted in the March 12, 2014 NEI letter [15] therefore, the conclusions in the NRCs May 9 letter [17] also apply to VCSNS.

In addition, the March 12, 2014 NEI letter [15] provided an attached "Perspectives on the Seismic Capacity of Operating Plants," which (1) assessed a number of qualitative reasons why the design of SSCs inherently contain margin beyond their design level, (2) discussed industrial seismic experience databases of performance of industry facility components similar to nuclear SSCs, and (3) discussed earthquake experience at operating plants.

The fleet of currently operating nuclear power plants was designed using conservative practices, such that the plants have significant margin to withstand large ground motions safely. This has been borne out for those plants that have actually experienced significant earthquakes. The seismic design process has inherent (and intentional) conservatisms, which result in significant seismic margins within structures, systems and components (SSCs). These conservatisms are reflected in several key aspects of the seismic design process, including:

x Safety factors applied in design calculations x Damping values used in dynamic analysis of SSCs Page 27 of 65

TR00080-005 REVISION 0 x Bounding synthetic time histories for in-structure response spectra calculations x Broadening criteria for in-structure response spectra x Response spectra enveloping criteria typically used in SSC analysis and testing applications x Response spectra based frequency domain analysis rather than explicit time history based time domain analysis x Bounding requirements in codes and standards x Use of minimum strength requirements of structural components (concrete and steel) x Bounding testing requirements, and x Ductile behavior of the primary materials (that is, not crediting the additional capacity of materials such as steel and reinforced concrete beyond the essentially elastic range, etc.).

These design practices combine to result in margins such that the SSCs will continue to fulfill their functions at ground motions well above the SSE.

The intent of the ESEP is to perform an interim action in response to the NRCs 50.54(f) letter [1] to demonstrate seismic margin through a review of a subset of the plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events. In order to complete the ESEP in an expedited amount of time, the RLGM used for the ESEP evaluation is a scaled version of the plants SSE rather than the actual GMRS. To more fully characterize the risk impacts of the seismic ground motion represented by the GMRS on a plant specific basis, a more detailed seismic risk assessment (SPRA or risk-based SMA) is to be performed in accordance with EPRI 1025287 [18]. As identified in the VCSNS Seismic Hazard and GMRS submittal [4],

VCSNS screens in for a risk evaluation. The complete risk evaluation will more completely characterize the probabilistic seismic ground motion input into the plant, the plant response to that probabilistic seismic ground motion input, and the resulting plant risk characterization. VCSNS will complete that evaluation in accordance with the schedule identified in the NRCs May 9, 2014 letter [17].

8.2 Identification of Planned Modifications Insights from the ESEP identified the following four items where the HCLPF is below the RLGM and plant modifications will be made in accordance with EPRI 3002000704 [2] to enhance the seismic capacity of the plant.

1. 7.2KV Switchgear XSW1DA had a functional failure mode HCLPF for relay chatter below the RLGM. Modification of the FLEX Support Procedures to explicitly direct the operator(s) to reset the relays is planned.

2. 480V Switchgear XSW1DA1 had a functional failure mode HCLPF for relay chatter below the RLGM. Modification of the FLEX Support Procedures to explicitly direct the operator(s) to reset the relays is planned.

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TR00080-005 REVISION 0

3. 480V Switchgear XSW1DA2 had a functional failure mode HCLPF for relay chatter below the RLGM. Modification of the FLEX Support Procedures to explicitly direct the operator(s) to reset the relays is planned.

4. Service Water isolation valve XVT03169-SW had a functional failure mode due to seismic spatial interaction with nearby conduit resulting in a HCLPF capacity below the RLGM. A modification is planned to provide additional seismic margin by either modifying the conduit or modifying piping system supports.

Additionally, during the screening process, the following five follow-up actions requiring modifications to resolve screening issues were identified. The screening issues are related to items such as seismic housekeeping, potential seismic interaction, and issues related to equipment caveats.

1. Main Steam Header Relief valve IPV02000-MS has a small nozzle for pressure tap located very close to adjacent handrail. A modification is planned to provide sufficient shake space.

2. 125V DC Distribution bus battery XBA-1A has a small gap between the battery cells and front rail of the rack. EPRI NP-6041 Appendix F recommends shimming all rails to a very close fit. A modification is planned to modify rack to reduce gaps.

3. 125V DC Distribution bus battery XBA-1B has a small gap between the battery cells and front rail of the rack. EPRI NP-6041 Appendix F recommends shimming all rails to a very close fit. A modification is planned to modify rack to reduce gaps.

4. Main Steam Header drain valve XVT02843B-MS has potential for seismic interaction with nearby steel angle pipe support. A modification is planned to trim the top of the nearby steel angle support to preclude potential seismic interaction.

5. Service water isolation valve XVT03164-SW has potential for seismic interaction with the hand wheel operator and nearby hand rail. A modification is planned to modify handrail to preclude seismic interaction.

8.3 Modification Implementation Schedule Plant modifications will be performed in accordance with the schedule identified in NEI letter dated April 9, 2013 [16], which states that plant modifications not requiring a planned refueling outage will be completed by December 2016, and modifications requiring a refueling outage will be completed within two planned refueling outages after December 31, 2014. Section 8.4 contains the regulatory commitment dates to complete planned plant modifications as a result of ESEP. Referencing Section 8.4, Action Items 1, 2, 3, and 5 are expected to be complete by December 2015 to support FLEX Program Implementation. Action Items 4, 6, 7, and 9 are required to be performed during a refueling outage and are therefore expected to be completed by spring 2017. Action Item 8 is not required to be performed during a refueling outage, with the expected completion date being prior to December 2016.

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TR00080-005 REVISION 0 8.4 Summary of Regulatory Commitments The following actions have been added to VCSNS Corrective Action Program as CR 01097, and will be performed as a result of the ESEP.

Action Equipment Equipment Completion Action Description

1. ID Description Date 1 XSW1DA 7.2KV Modify FLEX Support December 2016 Switchgear Procedures to include operator actions to reset relays with HCLPF values less than the RLGM.

2 XSW1DA1 480V Modify FLEX Support December 2016 Switchgear Procedures to include operator actions to reset relays with HCLPF values less than the RLGM.

3 XSW1DA2 480V Modify FLEX Support December 2016 Switchgear Procedures to include operator actions to reset relays with HCLPF values less than the RLGM.

4 XVT03169-SW DRPI Cooling Modify the seismic No later than the Unit Outlet interaction to provide end of the second Header sufficient shake space, or Unit 1 refueling Isolation Valve modify piping system outage after supports such that HCLPF > December 31, GMRS. 2014 (Tentative Spring 2017) 5 IPV02000-MS Main Steam Modify valve or handrail to December 2016 Header Power provide sufficient shake Relief Valve space.

6 XBA-1A 125V DC Modify rack to reduce front No later than the Distribution rail gaps. end of the second Bus Battery Unit 1 refueling outage after December 31, 2014 (Tentative Spring 2017)

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TR00080-005 REVISION 0 Action Equipment Equipment Completion Action Description

1. ID Description Date 7 XBA-1B 125V DC Modify rack to reduce front No later than the Distribution rail gaps. end of the second Bus Battery Unit 1 refueling outage after December 31, 2014 (Tentative Spring 2017) 8 XVT02843B-MS Main Steam Trim the steel angle post to December 2016 Header Drain mitigate potential seismic Valve interaction.

9 XVT03164-SW DRPI Cooling Modify the handrail to No later than the Unit Inlet mitigate potential seismic end of the second Header interaction. Unit 1 refueling Isolation Valve outage after December 31, 2014 (Tentative Spring 2017)

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TR00080-005 REVISION 0 9.0 References

1. NRC (E Leeds and M Johnson) Letter to All Power Reactor Licensees et al.,

Request for Information Pursuant to Title 10 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, March 12, 2012.

2. Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1 - Seismic. EPRI, Palo Alto, CA: May 2013. 3002000704.

3. Virgil C. Summer Nuclear Station Unit 1 OIPs

a. SCE&G Correspondence RC-13-0028, Virgil C. Summer Nuclear Station Unit 1 Docket No. 50-285 Operating License No. NPF-12 South Carolina Electric & Gas Companys Overall Integrated Plan as Required by March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), Attachment, South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Unit 1 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan, Revision 0, February 28, 2013. (ADAMS Accession Number ML13063A150)

b. SCE&G's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2013.

c. SCE&G's Second Six-Month Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2014.

d. SCE&G's Third Six-Month Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2014.

e. SCE&G Technical Report TR00080-002, FLEX Overall Integrated Plan (OIP), Revision 1, October 2, 2014.

4. SCE&G Correspondence RC-14-0048, Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Docket No. 50-395 Operating License No. NPF-12 South Carolina Electric & Gas (SCE&G) Seismic Hazard and Screening Report (CEUS sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)

Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident RC-14-0048, March 26, 2014. (ADAMS Accession Number ML14092A250)

5. Virgil C. Summer Nuclear Station, Final Safety Analysis Report, dated May 2013.

Page 32 of 65

TR00080-005 REVISION 0

6. A Methodology for Assessment of Nuclear Power Plant Seismic Margin, Rev. 1, August 1991, Electric Power Research Institute, Palo Alto, CA. EPRI NP 6041

7. Methodology for Developing Seismic Fragilities, August 1991, EPRI, Palo Alto, CA. 1994, TR-103959

8. EPRI Report TR-1019200, Seismic Fragility Applications Guide Update, December 2009.

9. EPRI Report NP-5223-SL Rev. 1, Generic Seismic Ruggedness of Power Plant Equipment, August 1991.

10. Seismic Qualification Utility Group, Generic Implementation Procedure (GIP) for Verification of Nuclear Plant Equipment (SQUG-GIP), Revision 3.

11. Stevenson & Associates Calculations

a. 13C4188-ESEP-CAL-001 Rev. 2, In-structure RS Data for ESEP.

b. 13C4188-ESEP-CAL-002 Rev. 2, Review Level Ground Motion for ESEP.

c. 13C4188-ESEP-CAL-003 Rev. 1, Procedure to Determine RLGM In-Structure Seismic Demand for Equipment.

d. 13C4188-ESEP-CAL-004 Rev. 1, HCLPF Seismic Capacity of Condensate Storage Tank.

e. 13C4188-ESEP-CAL-005 Rev. 1, HCLPF Seismic Capacity of Refueling Water Storage Tank.

f. 13C4188-ESEP-CAL-006 Rev. 0, HCLPF Seismic Capacity Evaluations for Selected Equipment.

g. 13C4188-ESEP-CAL-007 Rev. 0, Anchorage Screening for ESEP.

h. 13C4188-ESEP-CAL-008 Rev. 0, HCLPF Seismic Capacity Evaluation for Reactor Building Cooling Unit XAA0001A.

i. 13C4188-ESEP-CAL-009 Rev. 0, Seismic Analysis of Relays for ESEP.

j. 13C4188-ESEP-CAL-010 Rev. 0, HCLPF Seismic Analysis of Selected RB Equipment.

k. 13C4188-ESEP-CAL-011 Rev. 1, SSI Analysis of CST for GMRS.

12. Stevenson & Associates Letter, 13C4188-LSC-016 Rev. 0, V.C. Summer Nuclear Station Unit 1 ESEP - Transmittal of NP-6041-SL SEWS, September 2, 2014.

13. Virgil C. Summer Nuclear Station Engineering Services Technical Report TR00310-001, Individual Plant Examination for External Events, December 1998.

14. Specification Seismic Analysis, Testing And Documentation Virgil C. Summer Nuclear Station - Unit 1, SP-702-4461-00 Rev. 5, May 17, 1972.

15. Nuclear Energy Institute (NEI), A. Pietrangelo, Letter to D. Skeen of the USNRC, "Seismic Core Damage Risk Estimates Using the Updated Seismic Hazards for the Operating Nuclear Plants in the Central and Eastern United States",

March 12, 2014.

Page 33 of 65

TR00080-005 REVISION 0

16. Nuclear Energy Institute (NEI), A. Pietrangelo, Letter to D. Skeen of the USNRC, "Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations", April 9, 2013.

17. NRC (E Leeds) Letter to All Power Reactor Licensees et al., Screening and Prioritization Results Regarding Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(F) Regarding Seismic Hazard Re-Evaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-Ichi Accident, May 9, 2014.

18. Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic. EPRI, Palo Alto, CA: February 2013. 1025287.

19. Westinghouse Correspondence LTR-SEE-II-13-95, Revision 1, V. C. Summer Unit 1 Expedited Seismic Equipment List, October 2, 2014.

20. Westinghouse Correspondence LTR-RAM-I-14-064, Revision 1, V.C. Summer Unit 1 Expedited Seismic Evaluation Process Report & Finalized Expedited Seismic Equipment List, December 4, 2014.

21. Nuclear Energy Institute (NEI) Document NEI 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, August 2012.

(ADAMS Accession Number ML12242A378)

22. NRC, EPRI, DOE (2012). Central and Eastern United States Seismic Source Characterization for Nuclear Facilities, NRC Report NUREG-2115, EPRI Report 1021097, 6 Volumes.

23. EPRI (2014). Review of EPRI 1021097 Earthquake Catalog for RIS Earthquakes in the Southeastern U. S. and Earthquakes in South Carolina Near the Time of the 1886 Charleston Earthquake Sequence, transmitted by letter from J. Richards to NRC on August 28, 2014, ADAMS Accession No. [ML14260A209].

24. EPRI (2013). EPRI (2004, 2006) Ground-Motion Model (GMM) Review Project, EPRI, Palo Alto, CA, Rept. 3002000717, June, 2 volumes.

25. SCE&G Letter, SOUTH CAROLINA ELECTRIC & GAS (SCE&G) RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 2.1, SEISMIC RE-EVALUATIONS dated November 12, 2014, RC-14-0182.

Page 34 of 65

TR00080-005 REVISION 0 Attachment A VCSNS Unit 1 ESEL 1 1

The complete list of equipment investigated for inclusion in the ESEL is documented in Reference 20. Reference 20 includes the valve operating states, as well as rationales for exclusion for any component which was determined to be appropriate to exclude from the ESEL. A summary list of the components, which were ultimately determined to be appropriate for inclusion in the ESEL, is provided herein.

Page 35 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State TURB DRIVEN EF 1 IFE03525 PUMP DISCH FLOW N/A N/A OIP, Page 14, D-302-085 ELEMENT SG A MTR DR EF 2 IFT03531 PUMP DISCH HDR N/A N/A OIP, D-302-085 FLOW XMTR SG B MTR DR EF 3 IFT03541 PUMP DISCH HDR N/A N/A OIP, D-302-085 FLOW XMTR SG C MTR DR EF 4 IFT03551 PUMP DISCH HDR N/A N/A OIP, D-302-085 FLOW XMTR STEAM GEN A EF 5 IFT03561 SUPPLY HEADER N/A N/A OIP, D-302-085 FLOW XMTR STEAM GEN B EF 6 IFT03571 SUPPLY HEADER N/A N/A OIP, D-302-085 FLOW XMTR STEAM GEN C EF 7 IFT03581 SUPPLY HEADER N/A N/A OIP, D-302-085 FLOW XMTR EF PUMP TURB Open /

8 IFV02030-MS STEAM SUPPLY FLOW Closed OIP, Page 14, D-302-011 Closed CONT VLV OPER-EF PP TURB 9 IFV02030-O-MS STM SUP FLOW CONT N/A N/A OIP, Page 14, D-302-011 VLV SG A MTR DR EF Open /

10 IFV03531-EF PUMP FLOW Open OIP, D-302-085 Closed CONTROL VALVE OPER-SG A MTR DR EF 11 IFV03531-O-EF PUMP FLOW CONT N/A N/A OIP, D-302-085 VLV SG A TURB DR EF Open /

12 IFV03536-EF PUMP FLOW Open OIP, Page 14, D-302-085 Closed CONTROL VALVE OPER-SG A TURB DR 13 IFV03536-O-EF EF PUMP FLOW CONT N/A N/A OIP, Page 14, D-302-085 VLV SG B MTR DR EF Open /

14 IFV03541-EF PUMP FLOW Open OIP, D-302-085 Closed CONTROL VALVE Page 36 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State OPER-SG B MTR DR EF 15 IFV03541-O-EF PUMP FLOW CONT N/A N/A OIP, D-302-085 VLV SG B TURB DR EF Open /

16 IFV03546-EF PUMP FLOW Open OIP, Page 14, D-302-085 Closed CONTROL VALVE OPER-SG B TURB DR 17 IFV03546-O-EF EF PUMP FLOW CONT N/A N/A OIP, Page 14, D-302-085 VLV SG C MTR DR EF Open /

18 IFV03551-EF PUMP FLOW Open OIP, D-302-085 Closed CONTROL VALVE OPER-SG C MTR DR EF 19 IFV03551-O-EF PUMP FLOW CONT N/A N/A OIP, D-302-085 VLV SG C TURB DR EF Open /

20 IFV03556-EF PUMP FLOW Open OIP, Page 14, D-302-085 Closed CONTROL VALVE OPER-SG C TURB DR 21 IFV03556-O-EF EF PUMP FLOW CONT N/A N/A OIP, Page 14, D-302-085 VLV CONDENSATE 22 ILT03631 STORAGE TANK N/A N/A OIP, Page 14, D-302-085 LEVEL XMTR MDEFP A SUCT PRESS 23 IPS03504 N/A N/A OIP, D-302-085 SW LO PRESS ALARM TURB DR EF PUMP 24 IPS03524 SUCT LP ALARM N/A N/A OIP, Page 17, D-302-085 SWITCH SG A MAIN STEAM 25 IPT00474 HDR PRESS N/A N/A D-302-011 TRANSMITTER SG A MAIN STEAM 26 IPT00475 HDR PRESS N/A N/A D-302-011 TRANSMITTER SG A MAIN STEAM 27 IPT00476 HDR PRESS N/A N/A D-302-011 TRANSMITTER SG B MAIN STEAM 28 IPT00484 HDR PRESS N/A N/A D-302-011 TRANSMITTER Page 37 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State SG B MAIN STEAM 29 IPT00485 HDR PRESS N/A N/A D-302-011 TRANSMITTER SG B MAIN STEAM 30 IPT00486 HDR PRESS N/A N/A D-302-011 TRANSMITTER SG C MAIN STEAM 31 IPT00494 HDR PRESS N/A N/A D-302-011 TRANSMITTER SG C MAIN STEAM 32 IPT00495 HDR PRESS N/A N/A D-302-011 TRANSMITTER SG C MAIN STEAM 33 IPT00496 HDR PRESS N/A N/A D-302-011 TRANSMITTER STEAM GENERATOR 34 IPT02000 A OUTLET PRESSURE N/A N/A D-302-011 XMTR STEAM GENERATOR 35 IPT02000A A OUTLET PRESSURE N/A N/A D-302-011 XMTR STEAM GENERATOR B 36 IPT02010 OUTLET PRESSURE N/A N/A D-302-011 XMTR STEAM GENERATOR B 37 IPT02010A OUTLET PRESSURE N/A N/A D-302-011 XMTR STEAM GENERATOR C 38 IPT02020 OUTLET PRESSURE N/A N/A D-302-011 XMTR STEAM GENERATOR C 39 IPT02020A OUTLET PRESSURE N/A N/A D-302-011 XMTR EF PUMP TURBINE MS 40 IPT02032 N/A N/A OIP, Page 17, D-302-011 SUP HDR PRESS XMTR STEAM GEN A EF 41 IPT03563 SUPPLY HEADER N/A N/A D-302-085 PRESS XMTR STEAM GEN B EF 42 IPT03573 SUPPLY HEADER N/A N/A D-302-085 PRESS XMTR Page 38 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State STEAM GEN C EF 43 IPT03583 SUPPLY HEADER N/A N/A D-302-085 PRESS XMTR EF PUMP SUCT HDR 44 IPT03632 PRESSURE N/A N/A D-302-085 TRANSMITTER EF PUMP SUCT HDR 45 IPT03633 PRESSURE N/A N/A D-302-085 TRANSMITTER EF PUMP SUCT HDR 46 IPT03634 PRESSURE N/A N/A D-302-085 TRANSMITTER EF PUMP SUCT HDR 47 IPT03635 PRESSURE N/A N/A D-302-085 TRANSMITTER MAIN STEAM HEADER Closed, 48 IPV02000-MS A POWER RELIEF Closed Open, or OIP, Page 14, D-302-011 VALVE Throttled OPER-MAIN STEAM 49 IPV02000-O-MS HDR A POWER RELIEF N/A N/A OIP, Page 14, D-302-011 VLV MAIN STEAM HEADER Closed, 50 IPV02010-MS B POWER RELIEF Closed Open, or OIP, Page 14, D-302-011 VALVE Throttled OPER-MAIN STEAM 51 IPV02010-O-MS HDR B POWER RELIEF N/A N/A OIP, Page 14, D-302-011 VLV MAIN STEAM HEADER Closed, 52 IPV02020-MS C POWER RELIEF Closed Open, or OIP, Page 14, D-302-011 VALVE Throttled OPER-MAIN STEAM 53 IPV02020-O-MS HDR C POWER RELIEF N/A N/A OIP, Page 14, D-302-011 VLV EMERGENCY 54 TPP0008 FEEDWATER PUMP N/A N/A OIP, Page 17, D-302-085 TURBINE EF PUMP TURBINE 55 TPP0008-HE1 LUBE OIL HEAT N/A N/A OIP, Page 17, D-302-085 EXCHANGER EF PUMP TURBINE 56 TPP0008-OR1 N/A N/A OIP, Page 17, D-302-085 LUBE OIL RESERVOIR Page 39 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State EF PUMP TURBINE 57 TPP0008-PP1 LUBE OIL ROTARY N/A N/A OIP, Page 17, D-302-085 PUMP EF PUMP TURBINE 58 TPP0008-SC1 SPEED CONTROL N/A N/A OIP, Page 17, D-302-085 GOVERNOR EMERG FEEDWATER 59 XPP0008 TURBINE DRIVEN N/A N/A OIP, Page 14, D-302-085 PUMP EMERGENCY 60 XPP0021A N/A N/A OIP, D-302-085 FEEDWATER PUMP A CONDENSATE OIP, Page 14, D-302-085, D-61 XTK0008 N/A N/A STORAGE TANK 302-101 REFUELING WATER 62 XTK0025 N/A N/A OIP, Page 22, D-302-651 STORAGE TANK MAIN FW TO STM GEN 63 XVG01611A-FW Open Closed D-302-083 A HDR ISOL OPER-MAIN FW TO 64 XVG01611A-O-FW N/A N/A D-302-083 STM GEN A HDR ISOL MAIN FW TO STM GEN 65 XVG01611B-FW Open Closed D-302-083 B HDR ISOL OPER-MAIN FW TO 66 XVG01611B-O-FW N/A N/A D-302-083 STM GEN B HDR ISOL MAIN FW TO STM GEN 67 XVG01611C-FW Open Closed D-302-083 C HDR ISOL OPER-MAIN FW TO 68 XVG01611C-O-FW N/A N/A D-302-083 STM GEN C HDR ISOL MAIN STEAM HEADER Open or 69 XVM02801A-MS Open D-302-011 A ISOLATION VALVE Throttled OPER-MAIN STEAM 70 XVM02801A-O-MS HEADER A STOP N/A N/A D-302-011 VALVE MAIN STEAM HEADER Open or 71 XVM02801B-MS Open D-302-011 B ISOLATION VALVE Throttled OPER-MAIN STEAM 72 XVM02801B-O-MS HEADER B STOP N/A N/A D-302-011 VALVE MAIN STEAM HEADER Open or 73 XVM02801C-MS Open D-302-011 C ISOLATION VALVE Throttled Page 40 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State OPER-MAIN STEAM 74 XVM02801C-O-MS HEADER C STOP N/A N/A D-302-011 VALVE EF PUMP TURBINE Open or 75 XVM11025-EF SPEED CONT Open OIP, Page 14, D-302-011 Throttled GOVERNOR VLV MAIN STEAM HEADER Closed or 76 XVS02806A-MS Closed D-302-011 A SAFETY VALVE Open MAIN STEAM HEADER Closed or 77 XVS02806B-MS Closed D-302-011 A SAFETY VALVE Open MAIN STEAM HEADER Closed or 78 XVS02806C-MS Closed D-302-011 A SAFETY VALVE Open MAIN STEAM HEADER Closed or 79 XVS02806D-MS Closed D-302-011 A SAFETY VALVE Open MAIN STEAM HEADER Closed or 80 XVS02806E-MS Closed D-302-011 A SAFETY VALVE Open MAIN STEAM HEADER Closed or 81 XVS02806F-MS Closed D-302-011 B SAFETY VALVE Open MAIN STEAM HEADER Closed or 82 XVS02806G-MS Closed D-302-011 B SAFETY VALVE Open MAIN STEAM HEADER Closed or 83 XVS02806H-MS Closed D-302-011 B SAFETY VALVE Open MAIN STEAM HEADER Closed or 84 XVS02806I-MS Closed D-302-011 B SAFETY VALVE Open MAIN STEAM HEADER Closed or 85 XVS02806J-MS Closed D-302-011 B SAFETY VALVE Open MAIN STEAM HEADER Closed or 86 XVS02806K-MS Closed D-302-011 C SAFETY VALVE Open MAIN STEAM HEADER Closed or 87 XVS02806L-MS Closed D-302-011 C SAFETY VALVE Open MAIN STEAM HEADER Closed or 88 XVS02806M-MS Closed D-302-011 C SAFETY VALVE Open MAIN STEAM HEADER Closed or 89 XVS02806N-MS Closed D-302-011 C SAFETY VALVE Open MAIN STEAM HEADER Closed or 90 XVS02806P-MS Closed D-302-011 C SAFETY VALVE Open MS HEADER A MOIST Closed, 91 XVT02843A-MS COLLECTOR DRAIN Open Open, or D-302-011 VLV Throttled Page 41 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State OPER-MS HDR A 92 XVT02843A-O-MS MOIST COLLECTOR N/A N/A D-302-011 DRN VLV MS HEADER B MOIST Closed, 93 XVT02843B-MS COLLECTOR DRAIN Open Open, or D-302-011 VLV Throttled OPER-MS HDR B 94 XVT02843B-O-MS MOIST COLLECTOR N/A N/A D-302-011 DRN VLV MS HEADER C MOIST Closed, 95 XVT02843C-MS COLLECTOR DRAIN Open Open, or D-302-011 VLV Throttled OPER-MS HDR C 96 XVT02843C-O-MS MOIST COLLECTOR N/A N/A D-302-011 DRN VLV EF PUMP TURB MAIN 97 XVT02865-MS STEAM THROTTLE Throttled Throttled OIP, Page 14, D-302-011 VALVE OPER-EF PP TURB 98 XVT02865-O-MS MAIN STEAM N/A N/A OIP, Page 14, D-302-011 THROTTLE VLV MS HEADER A MOIST Closed, 99 XVT02877A-MS COLLECTOR DRAIN Open Open, or D-302-011 VLV Throttled MS HEADER C MOIST Closed, 100 XVT02877B-MS COLLECTOR DRAIN Open Open, or D-302-011 VLV Throttled SG A STEAM FLOW DP 101 IFT00475 N/A N/A D-302-011 XMTR NARROW RANGE 102 IFT00475A N/A N/A D-302-011 STEAM FLOW SG B STEAM FLOW DP 103 IFT00485 N/A N/A D-302-011 XMTR NARROW RANGE 104 IFT00485A N/A N/A D-302-011 STEAM FLOW SG C STEAM FLOW DP 105 IFT00495 N/A N/A D-302-011 XMTR NARROW RANGE 106 IFT00495A N/A N/A D-302-011 STEAM FLOW TURB DR EF PP EF SUP 107 IPI03521 N/A N/A E-302-085 HDR SUCT PRESS IND Page 42 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State TURBINE DR EF PUMP 108 IFT03525 DISCHARGE FLOW N/A N/A E-302-085 XMTR TURBINE DR EF PUMP 109 IPI03527 DISCHARGE PRESS N/A N/A E-302-085 IND SG A MTR DR EF 110 IFE03531 PUMP DISCH HDR N/A N/A E-302-085 FLOW ELEM STEAM GEN A EF 111 IFE03561 SUPPLY HEADER N/A N/A E-302-085 FLOW ELEM SG B MTR DR EF 112 IFE03541 PUMP DISCH HDR N/A N/A E-302-085 FLOW ELEM STEAM GEN B EF 113 IFE03571 SUPPLY HEADER N/A N/A E-302-085 FLOW ELEM SG C MTR DR EF 114 IFE03551 PUMP DISCH HDR N/A N/A E-302-085 FLOW ELEM STEAM GEN C EF 115 IFE03581 SUPPLY HEADER N/A N/A E-302-085 FLOW ELEM CONTAINMENT 116 IPI00950 PRESSURE, PRESSURE N/A N/A OIP, Page 27 IND I REACTOR BLDG 117 ITI09201A AMBIENT TEMP N/A N/A OIP, Page 27 INDICATOR MOTOR DRIVEN EF 118 IPI03512 PUMP A SUCT PRESS N/A N/A D-302-085 IND TDEFP DISCHARGE 119 IFI03525 N/A N/A OIP, Page 14, D-302-085 FLOW INDICATOR REACTOR 120 IPT00950 CONTAINMENT N/A N/A OIP, Page 27 PRESSURE XMTR REACTOR BLDG TEMP 121 ITE09201 N/A N/A OIP, Page 27 ELEM 122 XAA0001A RB COOLING UNIT 1A N/A N/A OIP, Page 30, D-302-222 Page 43 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State BATT & CHG ROOM 123 XAH0024A AIR HANDLING UNIT N/A N/A OIP, Page 46 A

BATT&CHG RM AIR 124 XFN0038A HANDLING UNIT A N/A N/A OIP, Page 46 SUP FAN BATT&CHG RM AH 125 XFN0038A-M UNIT A SUPPLY FAN N/A N/A OIP, Page 46 MOTOR BATTERY ROOM 126 XFN0039A N/A N/A OIP, Page 46 EXHAUST FAN A BATTERY ROOM 127 XFN0039A-M EXHAUST FAN A N/A N/A OIP, Page 46 MOTOR REACTOR BLDG 128 XFN0064A COOLING UNIT 1A N/A N/A OIP, Page 30, D-302-222 EMERG FAN RBCU FAN XFN0064A 129 IYE40000 N/A N/A OIP, Page 30, D-302-222 VIBRATION SENSOR SW PIPING RELIEF Closed or 130 XVR13142A-SW Closed OIP, Page 30, D-302-222 VALVE Open SW BOOSTER PUMP A 131 IFE04466 DISCHARGE FLOW N/A N/A OIP, Page 30, D-302-222 ELEM SW BOOSTER PUMP A 132 IFT04466 DISCHARGE FLOW N/A N/A OIP, Page 30, D-302-222 XMTR SW BOOSTER PUMP A 133 IFI04466 DISCHARGE FLOW N/A N/A OIP, Page 30, D-302-222 IND RBCU 1A&2A CI SYS 134 XVB03110A-SW SUPPLY ISOLATION Open Closed OIP, Page 30, D-302-222 VLV OPER-RBCU 1A&2A CI 135 XVB03110A-O-SW N/A N/A OIP, Page 30, D-302-222 SYS SUPPLY ISOL VLV RB CLG UNIT 1A Closed or 136 XVR03146A-SW OUTLET HDR RELIEF Closed OIP, Page 30, D-302-222 Open VALVE DRPI COOLING UNIT 137 XVT03164-SW INLET HDR ISOL Open Closed OIP, Page 30, D-302-222 VALVE Page 44 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State OPER-DRPI CLG UNIT 138 XVT03164-O-SW INLET HDR ISOL N/A N/A OIP, Page 30, D-302-222 VALVE RB COOLING UNIT 2A 139 XVG03108B-SW INLET ISOLATION Open Closed OIP, Page 30, D-302-222 VLV OPER-RB COOLING 140 XVG03108B-O-SW UNIT 2A INLET ISOL N/A N/A OIP, Page 30, D-302-222 VLV RB COOLING UNIT 2A 141 XVG03109B-SW OUTLET ISOLATION Open Closed OIP, Page 30, D-302-222 VLV OPER-RB COOLING 142 XVG03109B-O-SW UNIT 2A OUTLET ISOL N/A N/A OIP, Page 30, D-302-222 VLV DRPI COOLING UNIT 143 XVT03169-SW OUTLET HDR ISOL Open Closed OIP, Page 30, D-302-222 VLV OPER-DRPI CLG UNIT 144 XVT03169-O-SW OUTLET HDR ISOL N/A N/A OIP, Page 30, D-302-222 VLV RBCU 1A&2A CI SYS 145 XVG03111A-SW RETURN ISOLATION Open Closed OIP, Page 30, D-302-222 VLV OPER-RBCU 1A&2A CI 146 XVG03111A-O-SW SYS RETURN ISOL N/A N/A OIP, Page 30, D-302-222 VLV RBCU SW RETURN 147 ITE04467 HEADER A TEMP N/A N/A OIP, Page 30, D-302-222 ELEMENT RBCU RETURN HDR A 148 ITI04467 N/A N/A OIP, Page 30, D-302-222 TEMP INDICATOR SW POND RBCU RET 149 IFE04468 HDR A INLET FLOW N/A N/A OIP, Page 30, D-302-222 ELEM SW POND RBCU RET 150 IFT04468 HDR A INLET FLOW N/A N/A OIP, Page 30, D-302-222 XMTR RBCU RETURN HDR A 151 IFI04468 N/A N/A OIP, Page 30, D-302-222 FLOW INDICATOR SW POND RBCU RET 152 IPT04528 HDR A INLET PRESS N/A N/A OIP, Page 30, D-302-222 XMTR Page 45 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State SW FROM RBCU LOOP 153 IPI04528 N/A N/A OIP, Page 30, D-302-222 A PRESS INDICATOR LOOP A COLD LEG 154 IFE00975 N/A N/A E-302-691 FLOW ELEMENT LOOP B COLD LEG 155 IFE00976 N/A N/A E-302-691 FLOW ELEMENT LOOP C COLD LEG 156 IFE00977 N/A N/A E-302-691 FLOW ELEMENT 120 VOLT VITAL AC E-206-005, E-206-054, E-206-157 APN5901 N/A N/A DISTR PANEL 1, NSSS 062-SH 1 120 VOLT VITAL AC E-206-005, E-206-054, E-206-158 APN5902 N/A N/A DISTR PANEL 2, NSSS 062-SH 1 120 VOLT VITAL AC E-206-005, E-206-054, E-206-159 APN5903 N/A N/A DISTR PANEL 3, NSSS 062-SH 2 120 VOLT VITAL AC E-206-005, E-206-054, E-206-160 APN5904 N/A N/A DISTR PANEL 4, NSSS 062-SH 2 120 VOLT VITAL AC E-206-005, E-206-054, E-206-161 APN5907 N/A N/A DISTR PANEL 7, NSSS 062-SH 1 120 VOLT VITAL AC E-206-005, E-206-054, E-206-162 APN5908 N/A N/A DISTR PANEL 8, NSSS 062-SH 1 BATTERY MAIN 163 DPN1HA2 DISTRIBUTION PANEL N/A N/A E-206-005, E-206-062-SH 3 1HA 125V DC 164 DPN1HA1 DISTRIBUTION PANEL N/A N/A E-206-005, E-206-062-SH 3 1HA1 BATTERY MAIN 165 DPN1HB2 DISTRIBUTION PANEL N/A N/A E-206-005, E-206-062-SH 4 1HB DC DISTRIBUTION 166 DPN1HB1 N/A N/A E-206-005, E-206-062-SH 4 PANEL 1HB1 125V DC 167 XBA-1A2 DISTRIBUTION BUS N/A N/A E-206-005 1A BATTERY 125V DC 168 XBA-1B2 DISTRIBUTION BUS 1B N/A N/A E-206-005 BATTERY 125V DC DISTRI BUS 169 XBC-1A 1A BATTERY N/A N/A E-206-005 CHARGER Page 46 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State 125V DC DISTRI BUS 1A-1B BACKUP 170 XBC-1A-1B N/A N/A E-206-005 BATTERY CHARGER

("Swing charger")

E-206-080, 1MS-28-026, Sh.

171 XCP6103 MCB XCP-6103 N/A N/A 3, 1MS-28-026, Sh. 4 E-206-080, 1MS-28-026, Sh.

172 XCP6104 MCB XCP-6104 N/A N/A 3, 1MS-28-026, Sh. 4 E-206-080, 1MS-28-026, Sh.

173 XCP6106 MCB XCP-6106 N/A N/A 5, 1MS-28-026, Sh. 6 E-206-080, 1MS-28-026, Sh.

174 XCP6107 MCB XCP-6107 N/A N/A 5, 1MS-28-026, Sh. 6 1MS-28-026, Sh. 7, E-206-175 XCP6108 MCB XCP-6108 N/A N/A 022 1MS-28-026, Sh. 17, 1MS 176 XCP6110 MCB XCP-6110 N/A N/A 026, Sh. 18, E-206-022 E-206-080, 1MS-28-026, Sh.

177 XCP6111 MCB XCP-6111 N/A N/A 19, 1MS-28-026, Sh. 20 E-206-080, 1MS-28-026, Sh.

178 XCP6112 MCB XCP-6112 N/A N/A 21, 1MS-28-026, Sh. 22 E-206-080, 1MS-28-026, Sh.

179 XCP6113 MCB XCP-6113 N/A N/A 23, 1MS-28-026, Sh. 24 1MS-28-026, Sh. 30, 1MS 180 XCP6114 MCB XCP-6114 N/A N/A 026, Sh. 31 120 VAC VITAL BUS 10 E-206-005, E-206-054, E-206-181 XIT5901 N/A N/A KVA UPS XIT5901 062-SH 1 120 VAC VITAL BUS 10 E-206-005, E-206-054, E-206-182 XIT5902 N/A N/A KVA UPS XIT5902 062-SH 1 120 VAC VITAL BUS 10 E-206-005, E-206-054, E-206-183 XIT5903 N/A N/A KVA UPS XIT5903 062-SH 2 120 VAC VITAL BUS 10 E-206-005, E-206-054, E-206-184 XIT5904 N/A N/A KVA UPS XIT5904 062-SH 2 E-206-005, E-206-034, E-206-185 XMC1DA2X 480V MCC XMC1DA2X N/A N/A 047 E-206-005, E-206-034, E-206-186 XMC1DA2Y 480V MCC XMC1DA2Y N/A N/A 047, E-206-054 BOP Instrument Panel 187 XPN6001 N/A N/A E-206-062-SH 1 Train A BOP Instrument Panel 188 XPN6002 N/A N/A E-206-062-SH 2 Train B Page 47 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State BOP Instrument Panel 189 XPN6004 N/A N/A E-206-062-SH 1 Train A BOP Instrument Panel 190 XPN6005 N/A N/A E-206-062-SH 2 Train B ESF Load Sequence 191 XPN6020 N/A N/A E-206-062-SH 1 Panel, Train A Process I&C Rack 192 XPN7001 N/A N/A E-206-062-SH 1 Protection Set I Process I&C Rack 193 XPN7002 N/A N/A E-206-062-SH 1 Protection Set II Process I&C Rack 194 XPN7003 N/A N/A E-206-062-SH 2 Protection Set III Process I&C Rack 195 XPN7004 N/A N/A E-206-062-SH 2 Protection Set IV Process I&C Rack Cont 196 XPN7005 N/A N/A E-206-062-SH 1 Group 1 Process I&C Rack Cont 197 XPN7006 N/A N/A E-206-062-SH 1 Group 2 Process I&C Rack Cont 198 XPN7007 N/A N/A E-206-062-SH 2 Group 3 Solid State Protection E-206-062-SH 1 & 2, B-208-199 XPN7010 N/A N/A System Cabinet Train A 094 Solid State Protection E-206-062-SH 1 & 2, B-208-200 XPN7020 System (SSPS) Cabinet N/A N/A 094 Train B Aux Safeguards Cabinet 201 XPN7034 N/A N/A E-206-062-SH 3 Train A Aux Safeguards Cabinet 202 XPN7035 N/A N/A E-206-062-SH 4 Train B MAIN CONTROL BOARD 203 XPN7106 N/A N/A E-206-062-SH 3, E-206-080 TERMINATION CABINET XPN7106 MAIN CONTROL BOARD 204 XPN7107 N/A N/A B-208-032-EF54 TERMINATION CABINET XPN7107 MAIN CONTROL BOARD 205 XPN7108 N/A N/A B-208-032-EF54 TERMINATION CABINET XPN7108 Page 48 of 65

TR00080-005 REVISION 0 Equipment Operating State1 ESEL Item Normal Desired Notes/Comments Num ID Description State State Main Control Board 206 XPN7113 Instrument Bus 2 Channel N/A N/A E-206-062-SH 1 D

MAIN CONTROL B-208-032-EF37A,B, B-208-BOARD 207 XPN7114 N/A N/A 032-EF38A,B, E-811-017, B-TERMINATION 208-032-EF39A,B CABINET XPN7114 MAIN CONTROL BOARD B-208-032-EF34A,B, B-208-208 XPN7119 N/A N/A TERMINATION 032-EF36A,B CABINET XPN7119 MAIN CONTROL BOARD 209 XPN7120 N/A N/A E-811-017, B-208-032-EF54 TERMINATION CABINET XPN7120 MAIN CONTROL BOARD 210 XPN7121 N/A N/A B-208-032-EF35A,B TERMINATION CABINET XPN7121 MAIN CONTROL B-208-032-EF34A,B, B-208-BOARD 211 XPN7124 N/A N/A 032-EF35A,B, B-208-032-TERMINATION EF36A,B, E-811-019 CABINET XPN7124 MAIN CONTROL BOARD 212 XPN7130 N/A N/A E-206-062-SH 4, E-206-080 TERMINATION CABINET XPN7130 Control Room Evacuation E-206-062-SH 3, E-206-042-213 XPN7200A N/A N/A Panel (CREP A) SH 1 Control Room Evacuation E-206-062-SH 4, E-206-042 214 XPN7200B N/A N/A Panel (CREP B) SH 1 Control Room Evacuation 215 XPN7213 Panel (CREP) Process N/A N/A E-206-062-SH 4 Cabinet Class IE 7.2 kV SWGR 216 XSW1DA2 N/A N/A E-206-005, E-206-022 bus XSW1DA-ES Class IE 480 V SWGR E-206-005, E-206-034, E-206-217 XSW1DA12 N/A N/A bus XSW1DA1-ES 047 Class IE 480 V SWGR E-206-005, E-206-034, E-206-218 XSW1DA22 N/A N/A bus XSW1DA2-ES 047 Notes

1. The operating states for the equipment selected for inclusion on the ESEL can be found in Attachment 5 of Reference 20.

2. These components were identified to have lockout relays, which were considered in this analysis. For more information regarding the identification of these lockout relays, see tab VCSNS U1 Elec ESEL Relay List within Attachment 5 of Reference 20.

Page 49 of 65

TR00080-005 REVISION 0 Attachment B ESEP HCLPF Values and Failure Modes Tabulation Page 50 of 65

TR00080-005 REVISION 0 HCLPF values are listed in Table B-1. These notes are applicable:

1. The listed HCLPF value is for comparison to the horizontal PGA at the bedrock surface.

2. Items covered by the NP-6041-SL rule of the box are identified in Table B-2. In each case, the HCLPF value for the parent item applies.

3. Results take credit for planned resolution of screening issues cited in Table 6-3.

4. For the CST only (XTK0008), the applied ground motion was based on the GMRS.

5. The Class value for each item refers to the equipment class per the SQUG-GIP [10].

Page 51 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 1 IFE03561 STEAM GEN A EF SUPPLY HEADER FLOW ELEM AB 412 0  Screened 2 XMC1DA2Y 480V MCC XMC1DA2Y AB 412 1  Screened 3 IFT03561 STEAM GEN A EF SUPPLY HEADER FLOW XMTR AB 412 18  Screened 4 IPT03563 STEAM GEN A EF SUPPLY HEADER PRESS XMTR AB 412 18  Screened 5 XTK0025 REFUELING WATER STORAGE TANK AB 412 21 0.32 Overturning moment capacity.

6 IFE04466 SW BOOSTER PUMP A DISCHARGE FLOW ELEM AB 436 0  Screened 7 IFE04468 SW POND RBCU RET HDR A INLET FLOW ELEM AB 436 0  Screened 8 IPV02000-MS MAIN STEAM HEADER A POWER RELIEF VALVE AB 436 7  Screened 9 XVG01611A-FW MAIN FW TO STM GEN A HDR ISOL AB 436 7  Screened 10 XVS02806A-MS MAIN STEAM HEADER A SAFETY VALVE AB 436 7  Screened 11 XVS02806B-MS MAIN STEAM HEADER A SAFETY VALVE AB 436 7  Screened 12 XVS02806C-MS MAIN STEAM HEADER A SAFETY VALVE AB 436 7  Screened 13 XVS02806D-MS MAIN STEAM HEADER A SAFETY VALVE AB 436 7  Screened 14 XVS02806E-MS MAIN STEAM HEADER A SAFETY VALVE AB 436 7  Screened 15 XVT02877A-MS MS HEADER A MOIST COLLECTOR DRAIN VLV AB 436 7  Screened 16 IFT04466 SW BOOSTER PUMP A DISCHARGE FLOW XMTR AB 436 18  Screened 17 IFT04468 SW POND RBCU RET HDR A INLET FLOW XMTR AB 436 18  Screened Page 52 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 18 IPT00474 SG A MAIN STEAM HDR PRESS TRANSMITTER AB 436 18  Screened 19 IPT00475 SG A MAIN STEAM HDR PRESS TRANSMITTER AB 436 18  Screened 20 IPT00476 SG A MAIN STEAM HDR PRESS TRANSMITTER AB 436 18  Screened 21 IPT02000 STEAM GENERATOR A OUTLET PRESSURE XMTR AB 436 18  Screened 22 IPT02000A STEAM GENERATOR A OUTLET PRESSURE XMTR AB 436 18  Screened 23 IPT04528 SW POND RBCU RET HDR A INLET PRESS XMTR AB 436 18  Screened 24 XVB03110A-SW RBCU 1A&2A CI SYS SUPPLY ISOLATION VLV AB 463 8  Screened 25 XVG03111A-SW RBCU 1A&2A CI SYS RETURN ISOLATION VLV AB 463 8  Screened 26 IPT00950 REACTOR CONTAINMENT PRESSURE XMTR AB 463 18  Screened 27 ITE04467 RBCU SW RETURN HEADER A TEMP ELEMENT AB 463 19 0.30 Screened 28 APN5901 120 VOLT VITAL AC DISTR PANEL 1, NSSS CB 436 14  Screened 29 APN5902 120 VOLT VITAL AC DISTR PANEL 2, NSSS CB 436 14  Screened 30 APN5903 120 VOLT VITAL AC DISTR PANEL 3, NSSS CB 436 14  Screened 31 APN5904 120 VOLT VITAL AC DISTR PANEL 4, NSSS CB 436 14  Screened 32 APN5907 120 VOLT VITAL AC DISTR PANEL 7, NSSS CB 436 14  Screened 33 APN5908 120 VOLT VITAL AC DISTR PANEL 8, NSSS CB 436 14  Screened 34 XIT5901 120 VAC VITAL BUS 10 KVA UPS XIT5901 CB 436 16  Screened Page 53 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 35 XIT5902 120 VAC VITAL BUS 10 KVA UPS XIT5902 CB 436 16  Screened 36 XIT5903 120 VAC VITAL BUS 10 KVA UPS XIT5903 CB 436 16  Screened 37 XIT5904 120 VAC VITAL BUS 10 KVA UPS XIT5904 CB 436 16  Screened 38 XPN6001 BOP Instrument Panel Train A CB 436 20  Screened 39 XPN6002 BOP Instrument Panel Train B CB 436 20  Screened 40 XPN6004 BOP Instrument Panel Train A CB 436 20  Screened 41 XPN6005 BOP Instrument Panel Train B CB 436 20  Screened 42 XPN6020 ESF Load Sequence Panel, Train A CB 436 20  Screened 43 XPN7001 Process I&C Rack Protection Set I CB 436 20  Screened 44 XPN7002 Process I&C Rack Protection Set II CB 436 20  Screened 45 XPN7003 Process I&C Rack Protection Set III CB 436 20  Screened 46 XPN7004 Process I&C Rack Protection Set IV CB 436 20  Screened 47 XPN7005 Process I&C Rack Cont Group 1 CB 436 20  Screened 48 XPN7006 Process I&C Rack Cont Group 2 CB 436 20 0.30 Screened 49 XPN7007 Process I&C Rack Cont Group 3 CB 436 20  Screened 50 XPN7010 Solid State Protection System Cabinet Train A CB 436 20  Screened 51 XPN7020 Solid State Protection System (SSPS) Cabinet Train B CB 436 20  Screened Page 54 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 52 XPN7034 Aux Safeguards Cabinet Train A CB 436 20  Screened 53 XPN7035 Aux Safeguards Cabinet Train B CB 436 20  Screened 54 XPN7106 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7106 55 XPN7107 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7107 56 XPN7108 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7108 57 XPN7113 Main Control Board Instrument Bus 2 Channel D CB 448 20  Screened 58 XPN7114 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7114 59 XPN7119 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7119 60 XPN7120 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7120 61 XPN7121 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7121 62 XPN7124 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7124 63 XPN7130 MAIN CONTROL BOARD TERMINATION CABINET CB 448 20  Screened XPN7130 64 XCP6103 MCB XCP-6103 CB 463 20  Screened 65 XCP6104 MCB XCP-6104 CB 463 20  Screened 66 XCP6106 MCB XCP-6106 CB 463 20  Screened Page 55 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 67 XCP6107 MCB XCP-6107 CB 463 20  Screened 68 XCP6108 MCB XCP-6108 CB 463 20  Screened 69 XCP6110 MCB XCP-6110 CB 463 20  Screened 70 XCP6111 MCB XCP-6111 CB 463 20  Screened 71 XCP6112 MCB XCP-6112 CB 463 20  Screened 72 XCP6113 MCB XCP-6113 CB 463 20  Screened 73 XCP6114 MCB XCP-6114 CB 463 20  Screened 74 IPT03632 EF PUMP SUCT HDR PRESSURE TRANSMITTER DB 412 18  Screened 75 IPT03633 EF PUMP SUCT HDR PRESSURE TRANSMITTER DB 412 18  Screened 76 IPT03634 EF PUMP SUCT HDR PRESSURE TRANSMITTER DB 412 18  Screened 77 IPT03635 EF PUMP SUCT HDR PRESSURE TRANSMITTER DB 412 18  Screened 78 IFE03525 TURB DRIVEN EF PUMP DISCH FLOW ELEMENT IB 412 0  Screened 79 IFE03541 SG B MTR DR EF PUMP DISCH HDR FLOW ELEM IB 412 0  Screened 80 IFE03571 STEAM GEN B EF SUPPLY HEADER FLOW ELEM IB 412 0  Screened 81 IFE03581 STEAM GEN C EF SUPPLY HEADER FLOW ELEM IB 412 0  Screened 82 TPP0008 EMERGENCY FEEDWATER PUMP TURBINE IB 412 5  Screened 83 XPP0008 EMERG FEEDWATER TURBINE DRIVEN PUMP IB 412 5  Screened Page 56 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 84 XPP0021A EMERGENCY FEEDWATER PUMP A IB 412 5  Screened 85 IFV02030-MS EF PUMP TURB STEAM SUPPLY FLOW CONT VLV IB 412 7  Screened 86 XVM11025-EF EF PUMP TURBINE SPEED CONT GOVERNOR VLV IB 412 7  Screened 87 XVR13142A-SW SW PIPING RELIEF VALVE IB 412 7 0.30 Screened 88 XVT02865-MS EF PUMP TURB MAIN STEAM THROTTLE VALVE IB 412 7  Screened 89 DPN1HA BATTERY MAIN DISTRIBUTION PANEL 1HA IB 412 14 0.35 Functionality, including breaker trip.

90 DPN1HA1 125V DC DISTRIBUTION PANEL 1HA1 IB 412 14  Screened 91 DPN1HB BATTERY MAIN DISTRIBUTION PANEL 1HB IB 412 14 0.35 Functionality, including breaker trip.

92 DPN1HB1 DC DISTRIBUTION PANEL 1HB1 IB 412 14  Screened 93 XBA-1A 125V DC DISTRIBUTION BUS 1A BATTERY IB 412 15  Screened 94 XBA-1B 125V DC DISTRIBUTION BUS 1B BATTERY IB 412 15  Screened 95 XBC-1A 125V DC DISTRI BUS 1A BATTERY CHARGER IB 412 16  Screened 96 XBC-1A-1B 125V DC DISTRI BUS 1A-1B BACKUP BATTERY IB 412 16  Screened CHARGER ("Swing charger")

97 IFT03525 TURBINE DR EF PUMP DISCHARGE FLOW XMTR IB 412 18  Screened 98 IFT03531 SG A MTR DR EF PUMP DISCH HDR FLOW XMTR IB 412 18  Screened 99 IFT03541 SG B MTR DR EF PUMP DISCH HDR FLOW XMTR IB 412 18  Screened 100 IFT03551 SG C MTR DR EF PUMP DISCH HDR FLOW XMTR IB 412 18  Screened Page 57 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 101 IFT03571 STEAM GEN B EF SUPPLY HEADER FLOW XMTR IB 412 18  Screened 102 IFT03581 STEAM GEN C EF SUPPLY HEADER FLOW XMTR IB 412 18  Screened 103 IPI03512 MOTOR DRIVEN EF PUMP A SUCT PRESS IND IB 412 18  Screened 104 IPI03521 TURB DR EF PP EF SUP HDR SUCT PRESS IND IB 412 18  Screened 105 IPI03527 TURBINE DR EF PUMP DISCHARGE PRESS IND IB 412 18  Screened 106 IPS03504 MDEFP A SUCT PRESS SW LO PRESS ALARM IB 412 18  Screened 107 IPS03524 TURB DR EF PUMP SUCT LP ALARM SWITCH IB 412 18  Screened 108 IPT02032 EF PUMP TURBINE MS SUP HDR PRESS XMTR IB 412 18  Screened 109 IPT03573 STEAM GEN B EF SUPPLY HEADER PRESS XMTR IB 412 18  Screened 110 IPT03583 STEAM GEN C EF SUPPLY HEADER PRESS XMTR IB 412 18  Screened 111 TPP0008-HE1 EF PUMP TURBINE LUBE OIL HEAT EXCHANGER IB 412 21  Screened 112 TPP0008-OR1 EF PUMP TURBINE LUBE OIL RESERVOIR IB 412 21  Screened 113 IFE03531 SG A MTR DR EF PUMP DISCH HDR FLOW ELEM IB 423 0  Screened 114 IFV03531-EF SG A MTR DR EF PUMP FLOW CONTROL VALVE IB 423 7  Screened 115 IFV03536-EF SG A TURB DR EF PUMP FLOW CONTROL VALVE IB 423 7  Screened 116 IFV03541-EF SG B MTR DR EF PUMP FLOW CONTROL VALVE IB 423 7  Screened 117 IFV03546-EF SG B TURB DR EF PUMP FLOW CONTROL VALVE IB 423 7  Screened Page 58 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 118 IFV03551-EF SG C MTR DR EF PUMP FLOW CONTROL VALVE IB 423 7  Screened 119 IFV03556-EF SG C TURB DR EF PUMP FLOW CONTROL VALVE IB 423 7  Screened 120 XFN0039A BATTERY ROOM EXHAUST FAN A IB 423 9  Screened 121 XAH0024A BATT & CHG ROOM AIR HANDLING UNIT A IB 423 10  Screened 122 IFE03551 SG C MTR DR EF PUMP DISCH HDR FLOW ELEM IB 424 0  Screened 123 IPV02010-MS MAIN STEAM HEADER B POWER RELIEF VALVE IB 436 7  Screened 124 IPV02020-MS MAIN STEAM HEADER C POWER RELIEF VALVE IB 436 7  Screened 125 XVG01611B-FW MAIN FW TO STM GEN B HDR ISOL IB 436 7  Screened 126 XVG01611C-FW MAIN FW TO STM GEN C HDR ISOL IB 436 7  Screened 127 XVM02801A-MS MAIN STEAM HEADER A ISOLATION VALVE IB 436 7  Screened 128 XVM02801B-MS MAIN STEAM HEADER B ISOLATION VALVE IB 436 7  Screened 129 XVM02801C-MS MAIN STEAM HEADER C ISOLATION VALVE IB 436 7  Screened 130 XVS02806F-MS MAIN STEAM HEADER B SAFETY VALVE IB 436 7  Screened 131 XVS02806G-MS MAIN STEAM HEADER B SAFETY VALVE IB 436 7  Screened 132 XVS02806H-MS MAIN STEAM HEADER B SAFETY VALVE IB 436 7  Screened 133 XVS02806I-MS MAIN STEAM HEADER B SAFETY VALVE IB 436 7  Screened 134 XVS02806J-MS MAIN STEAM HEADER B SAFETY VALVE IB 436 7  Screened Page 59 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 135 XVS02806K-MS MAIN STEAM HEADER C SAFETY VALVE IB 436 7  Screened 136 XVS02806L-MS MAIN STEAM HEADER C SAFETY VALVE IB 436 7  Screened 137 XVS02806M-MS MAIN STEAM HEADER C SAFETY VALVE IB 436 7  Screened 138 XVS02806N-MS MAIN STEAM HEADER C SAFETY VALVE IB 436 7  Screened 139 XVS02806P-MS MAIN STEAM HEADER C SAFETY VALVE IB 436 7  Screened 140 XVT02843A-MS MS HEADER A MOIST COLLECTOR DRAIN VLV IB 436 7  Screened 141 XVT02843B-MS MS HEADER B MOIST COLLECTOR DRAIN VLV IB 436 7  Screened 142 XVT02843C-MS MS HEADER C MOIST COLLECTOR DRAIN VLV IB 436 7  Screened 143 XVT02877B-MS MS HEADER C MOIST COLLECTOR DRAIN VLV IB 436 7  Screened 144 IPT00484 SG B MAIN STEAM HDR PRESS TRANSMITTER IB 436 18  Screened 145 IPT00485 SG B MAIN STEAM HDR PRESS TRANSMITTER IB 436 18  Screened 146 IPT00486 SG B MAIN STEAM HDR PRESS TRANSMITTER IB 436 18  Screened 147 IPT00494 SG C MAIN STEAM HDR PRESS TRANSMITTER IB 436 18  Screened 148 IPT00495 SG C MAIN STEAM HDR PRESS TRANSMITTER IB 436 18  Screened 149 IPT00496 SG C MAIN STEAM HDR PRESS TRANSMITTER IB 436 18  Screened 150 IPT02010 STEAM GENERATOR B OUTLET PRESSURE XMTR IB 436 18  Screened 151 IPT02010A STEAM GENERATOR B OUTLET PRESSURE XMTR IB 436 18  Screened Page 60 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 152 IPT02020 STEAM GENERATOR C OUTLET PRESSURE XMTR IB 436 18  Screened 153 IPT02020A STEAM GENERATOR C OUTLET PRESSURE XMTR IB 436 18  Screened 154 XPN7200A Control Room Evacuation Panel (CREP A) IB 436 20  Screened 155 XPN7200B Control Room Evacuation Panel (CREP B) IB 436 20  Screened 156 XPN7213 Control Room Evacuation Panel (CREP) Process Cabinet IB 436 20  Screened 157 XMC1DA2X 480V MCC XMC1DA2X IB 463 1  Screened 158 XSW1DA1 Class IE 480 V SWGR bus XSW1DA1-ES IB 463 2 0.24 Cited HCLPF is for relay chatter failure mode; other IDLOXUHPRGHVDUHVFUHHQHGDQG+&/3)J

159 XSW1DA2 Class IE 480 V SWGR bus XSW1DA2-ES IB 463 2 0.24 Cited HCLPF is for relay chatter failure mode; other IDLOXUHPRGHVDUHVFUHHQHGDQG+&/3)0.30g.

160 XSW1DA Class IE 7.2 kV SWGR bus XSW1DA-ES IB 463 3 0.20 Cited HCLPF is for relay chatter failure mode; other IDLOXUHPRGHVDUHVFUHHQHGDQG+&/3)J

161 IFE00975 LOOP A COLD LEG FLOW ELEMENT RB 412 0  Screened 162 IFE00976 LOOP B COLD LEG FLOW ELEMENT RB 412 0  Screened 163 IFE00977 LOOP C COLD LEG FLOW ELEMENT RB 412 0  Screened 164 IFT00475 SG A STEAM FLOW DP XMTR RB 463 18  Screened 165 IFT00475A NARROW RANGE STEAM FLOW RB 463 18  Screened 166 IFT00485 SG B STEAM FLOW DP XMTR RB 463 18  Screened 167 IFT00485A NARROW RANGE STEAM FLOW RB 463 18  Screened Page 61 of 65

TR00080-005 REVISION 0 Table B-1: ESEL HCLPF Values No. ID Description Bldg Elev Class HCLPF (g) Controlling Failure Mode (ft) 168 IFT00495 SG C STEAM FLOW DP XMTR RB 463 18  Screened 169 IFT00495A NARROW RANGE STEAM FLOW RB 463 18  Screened 170 XAA0001A RB COOLING UNIT 1A RB 514 10 0.35 Overall structural integrity.

171 IYE40000 RBCU FAN XFN0064A VIBRATION SENSOR RB 514 0  Screened 172 XVR03146A-SW RB CLG UNIT 1A OUTLET HDR RELIEF VALVE RB 518 7  Screened 173 XVT03164-SW DRPI COOLING UNIT INLET HDR ISOL VALVE RB 518 7 0.44 Functionality 174 XVT03169-SW DRPI COOLING UNIT OUTLET HDR ISOL VLV RB 518 7 0.24 Seismic interaction.

175 XVG03108B-SW RB COOLING UNIT 2A INLET ISOLATION VLV RB 518 8 0.82 Functionality 176 XVG03109B-SW RB COOLING UNIT 2A OUTLET ISOLATION VLV RB 518 8 0.82 Functionality 177 ITE09201 REACTOR BLDG TEMP ELEM RB 518 19  Screened 178 ILT03631 CONDENSATE STORAGE TANK LEVEL XMTR YD 435 18  Screened 179 XTK0008 CONDENSATE STORAGE TANK YD 435 21 0.88 Sliding due to exceedance of base shear capacity.

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TR00080-005 REVISION 0 Table B-2: ESEL Rule-of-Box Items ID Description Bdlg Elev Parent (ft)

IFI03525 TDEFP DISCHARGE FLOW INDICATOR CB 463 XCP6103 IFI04466 SW BOOSTER PUMP A DISCHARGE CB 463 XCP6103 FLOW IND IFI04468 RBCU RETURN HDR A FLOW CB 463 XCP6103 INDICATOR IPI00950 CONTAINMENT PRESSURE, PRESSURE CB 463 XCP6103 IND I IPI04528 SW FROM RBCU LOOP A PRESS CB 463 XCP6103 INDICATOR ITI04467 RBCU RETURN HDR A TEMP CB 463 XCP6103 INDICATOR ITI09201A REACTOR BLDG AMBIENT TEMP CB 463 XCP6103 INDICATOR TPP0008-PP1 EF PUMP TURBINE LUBE OIL ROTARY IB 412 TPP0008 PUMP TPP0008-SC1 EF PUMP TURBINE SPEED CONTROL IB 412 TPP0008 GOVERNOR XFN0038A-M BATT&CHG RM AH UNIT A SUPPLY IB 423 XAH0024A FAN MOTOR XFN0039A-M BATTERY ROOM EXHAUST FAN A IB 423 XFN0039A MOTOR XFN0038A BATT&CHG RM AIR HANDLING UNIT A IB 423 XAH0024A SUP FAN XFN0064A REACTOR BLDG COOLING UNIT 1A RB 514 XAA0001A EMERG FAN Notes Valve operators on the ESEL are not listed above. The parent for each valve operator is the corresponding valve.

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TR00080-005 REVISION 0 Attachment C Seismic Review Team Page 64 of 65

TR00080-005 REVISION 0 The SRT consisted of seismic engineers from Stevenson & Associates. Brief resumes for team members are provided below.

John J. OSullivan, P.E.

Mr. OSullivan is a Senior Consultant in the S&A Boston office. He has managed and led seismic walkdowns and fragility analyses of structures and components for use in probabilistic risk assessments.

Mr. OSullivan has 25 years of seismic experience serving the nuclear industry. Mr. OSullivan has participated in numerous USI A-46 and IPEEE projects in response to the requirements of Generic Letters 87-02 and 88-20. He recently led the seismic fragility analysis effort for the Palo Verde station to industry standard ASME/ANS RA-Sa-2009. Mr. OSullivan is a registered professional engineer (Massachusetts) and has a Master of Science in Structural Engineering from the Massachusetts Institute of Technology. He has received industry training as Seismic Capability Engineer (EPRI 5-day SQUG training), EPRI IPEEE Add-on, and Seismic Fragility training.

Stephane Damolini Mr. Damolini is a Senior Engineer in the S&A Boston office. In his five years at Stevenson &

Associates, he has performed multiple finite element analyses (including 3D building models and piping models) along with seismic fragility and HCLPF generation for structures, systems, and components. He also completed seismic walkdowns for the Seabrook and V.C. Summer nuclear stations. Mr. Damolini has a Master of Engineer in Civil/Structural Engineering from the Massachusetts Institute of Technology and a Master of Science in Civil Engineering and Construction from the École Spéciale des Travaux Publics (the number one Civil Engineering school in France). Mr. Damolini has been a SQUG Qualified Seismic Capability Engineer since 2011.

Seth Baker Mr. Baker is a Senior Engineer in the S&A Boston office. He has performed structural engineering analysis & design, finite element analysis, structural mechanics evaluations, seismic qualification managed and seismic walkdowns. Mr. Baker has a Master of Science in Civil/Structural Engineering from Stanford University. He has received industry training as Seismic Capability Engineer (EPRI 5-day SQUG training) and completed the EPRI training for NTTF 2.3 plant seismic walkdowns.

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