ML17234A478

Mitigating Strategies Assessment (MSA) Report for the Reevaluated Seismic Hazard Information - NEI 12-06, Appendix H, Revision 2, H.4.4 Path 4: GMRS ≪ 2xSSE

ML17234A478
Person / Time
Site:	Byron
Issue date:	08/22/2017
From:	Gullott D Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-17-089
Download: ML17234A478 (81)

Text

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10 CFR 50.540 RS-17-089 August 22, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Mitigating Strategies Assessment (MSA) Report for the Reevaluated Seismic Hazard Information NEI 12-06, Appendix H, Revision 2, HAA Path 4: GMRS < 2xSSE

References:

1. NEI 12-06, Revision 4, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, December 2016, ADAMS Accession Number ML1635413421

2. JLD-ISG-2012-01, Revision 2, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, February 2017, ADAMS Accession Number ML17005A188

3. EPRI, "Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic", Report Number 3002000704, Palo Alto, CA, April, 2013.

The purpose of this letter is to provide the results of the Mitigating Strategies Assessment (MSA) and Expedited Seismic Evaluation Process (ESEP) reports for Byron Station, Units 1 and 2 (Byron Station), to demonstrate that the FLEX strategies developed, implemented, and maintained in accordance with NRC Order EA-12-049 can be implemented considering the impacts of the re-evaluated seismic hazard. The MSA was performed in accordance with the guidance provided in Appendix H Section HAA of NEI 12-06 Revision 4 [Reference 1] which was endorsed by the NRC

[Reference 2]. The ESEP is implemented using the methodologies in the NRC endorsed guidance in EPRI 3002000704 [Reference 3].

Based upon the MSA and ESEP results provided in Enclosures 1 and 2, respectively, the mitigating strategies for Byron Station, Units 1 and 2, as described in Reference 14 of Enclosure 1, are acceptable considering the impacts of the re-evaluated seismic hazard.

This letter contains no new regulatory commitments and no revision to existing regulatory commitments.

U.S Nuclear Regulatory Commission Mitigating Strategies Seismic Hazard Assessment August 22, 2017 Page 2 Should you have any questions regarding this submittal, please contact David J. Distel at (610)-765-5517.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22nd day of August 2017.

Respectfully Submitted, David M(Gullo'tt Manager - Licensing Exelon Generation Company, LLC

Enclosures:

1. Seismic Mitigating Strategies Assessment for Byron Station, Units 1 and 2

2. Byron Station, Units 1 and 2, Expedited Seismic Evaluation Process (ESEP) Report cc: NRC Regional Administrator - Region III NRC Project Manager, NRR Byron Station NRC Senior Resident Inspector Byron Station Mr. Brett A. Titus, NRR/JLD/JCBB, NRC Mr. Stephen M. Wyman, NRR/JLD/JHMB, NRC Mr. Frankie G. Vega, NRR/JLD/JHMB, NRC Mr. Jason C. Paige, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency Division of Nuclear Safety

ENCLOSURE Seismic Mitigating Strategies Assessment for Byron Station, Units 1 and 2 NEI 12-06 Appendix H Seismic "Path 4" (7 Pages)

U.S Nuclear Regulatory Commission Mitigating Strategies Seismic Hazard Assessment August 22, 2017 Page 1 iJ0000E x A1c i - t'1011 iIm p

Byron Station, Units 1 and 2 (Byron Station or BYR) has completed a mitigating strategies assessment (MSA) [Reference 10] for the impacts of the re-evaluated seismic hazard to determine if the mitigating (FLEX) strategies developed, implemented and maintained in accordance with NRC Order EA-12-049 remain acceptable at the re-evaluated seismic hazard levels. The MSA was performed in accordance with the guidance provided in Appendix H of NEI 12-06 Revision 4

[Reference 1] which was endorsed by the NRC [Reference 2].

The Mitigating Strategies Seismic Hazard Information (MSSHI) is the re-evaluated seismic hazard information at Byron Station, developed using the Probabilistic Seismic Hazard Analysis (PSHA).

The MSSHI includes a performance-based Ground Motion Response Spectrum (GIVIRS), Uniform Hazard Response Spectra (UHRS) at various annual probabilities of exceedance, and a family of seismic hazard curves at various frequencies and fractiles developed at the Byron Station control point elevation. Byron Station submitted the re-evaluated seismic hazard information including the UHRS, GIVIRS and the hazard curves to the NRC on March 31, 2014 [Reference 3]. The NRC staff concluded that the GIVIRS that was submitted adequately characterizes the re-evaluated seismic hazard for the Byron Station site [References 4 and 17]. Section 6.1.1 of Reference 2 identifies the method described in Section HAA of Reference 1 as applicable to Byron Station.

2. ASSESSMENT TO MSSHI Consistent with Section HAA (Path 4) of Reference 1, the Byron Station GIVIRS has spectral accelerations greater than the safe shutdown earthquake (SSE) but no more than 2 times the Safe Shutdown Earthquake (SSE) anywhere in the 1 to 10 Hz frequency range. As described in the Final Implementation Plan (FIP) [Reference 14], the plant equipment relied on for FLEX strategies have previously been evaluated as seismically robust to the SSE levels. This plant equipment is evaluated for the MSSHI by the Expedited Seismic Evaluation Process (ESEP) and/or the MSA report following the guidance of Reference 1. The basic elements within the MSA of Path 4 systems, structures, and components (SSCs) are described in Reference 1. Implementation of each of these basic Path 4 elements for the Byron Station site is summarized in Sections 2.1 through 2.4.

Equipment needed to implement the FLEX strategies that was evaluated by the MSA report includes manual valves, power distribution panels, flow elements, safety injection accumulators, DC bus components, motor control centers, and FLEX neutral connection cabinets. Utilizing walkdowns and reviewing existing calculations for seismic margin, the components were shown to have sufficient Clo% capacity for the GIVIRS in accordance with Section H.5 of Reference 1.

In-structure response spectra are scaled for the GIVIRS by multiplying the existing SSE response spectrum by the ratio between GIVIRS and SSE ground motion curves at the dominant frequency of the building for which the new GIVIRS spectrum is desired.

U.S Nuclear Regulatory Commission Mitigating Strategies Seismic Hazard Assessment August 22, 2017 Page 2 2.1 Step I Scope of MSA Plant Equipment The scope of SSCs considered for the Path 4 MSA [Reference 10] was determined following the guidance used for the expedited seismic evaluation process (ESEP) defined in EPRI 3002000704 [Reference 9]. FLEX SSCs excluded from consideration in the ESEP were added to the MSA equipment scope. In addition, SSC failure modes not addressed in the ESEP that could potentially affect the FLEX strategies were added and evaluated.

SSCs associated with the FLEX strategy that are inherently rugged or sufficiently rugged are discussed in Section 2.3 below and identified in Section HAA (Path 4) of Reference 1.

2.2 Step 2 ESEP Review As stated in Appendix H of NEI 12-06, previous seismic evaluations should be credited to the extent that they apply for the assessment of the MSSHI. This includes the Expedited Seismic Evaluation Process (ESEP) evaluations for the FLEX strategies which were performed in accordance with EPRI 3002000704 [Reference 9]. The ESEP evaluates the plant equipment that is used for the FLEX strategies. The list of equipment is called the Expedited Seismic Equipment List (ESEL). Equipment on the ESEL has been evaluated to demonstrate seismic adequacy following the guidance in Section 5 of NEI 12-06. The ESEP evaluations remain applicable for this MSA since these evaluations directly addressed the most critical 1 Hz to 10 Hz part of the new seismic hazard using seismic responses from the scaling of the design basis analyses. In addition, separate evaluations are performed to address high frequency exceedances under the high frequency (HF) sensitive equipment assessment process, as required, and are documented in Section 4 of this enclosure. The ESEP report is included in Enclosure 2.

2.3 Step 3 Inherently/Sufficiently Rugged Equipment The qualitative assessment of certain SSCs not included in the ESEP was accomplished using (1) a qualitative screening of "inherently rugged" SSCs and (2) evaluation of SSCs to determine if they are "sufficiently rugged." Reference 1 documents the process and the justification for this ruggedness assessment. SSCs that are either inherently rugged or sufficiently rugged are described in Reference 1 and no further evaluations for these rugged SSCs are required under the MSA [Reference 10]

2.4 Step 4 Evaluations Using Section H.5 of Reference I Step four for Path 4 plants includes the evaluations of:

1. FLEX equipment storage buildings and Non-Seismic Category 1 Structures that could impact FLEX implementation

2. Operator Pathways

3. Tie down of FLEX portable equipment

4. Seismic Interactions not included in ESEP that could affect FLEX strategies

5. Haul Paths

U.S Nuclear Regulatory Commission Mitigating Strategies Seismic Hazard Assessment August 22, 2017 Page 3 The results of the reviews of each of these areas are described in the sections below, per Reference 10.

2.4.1a FLEX Equipment Storage Buildings The Robust FLEX Equipment Storage Building consists of 1'-9" thick reinforced concrete walls on a 3'-0" thick nominal reinforced concrete foundation mat. The 1'-9" thick roof slab is supported by W14 beams and girders. The FLEX Building is designed for a horizontal seismic acceleration (Cs) of 0.26g which is calculated using the peak SSE horizontal ground motion acceleration (0.6g). Because the peak GIVIRS horizontal ground motion acceleration (0.583g) is less than the SSE peak acceleration, the FLEX Building is adequate for the GIVIRS.

2.4.1 b Non-Seismic Category 1 Structures Areas of the Turbine Building are utilized for operator haul paths. The Turbine Building is classified as Category 11 but is designed for SSE loading using Category I allowables. Based on the EPRI NP-6041-SL [Reference 12] Table 2-3 screening criteria, the Turbine Building will have sufficient seismic capacity and will be adequate for the GIVIRS.

2.4.2 Operator Pathways Operator paths described in the Final Implementation Plan [Reference 14] pass through the Auxiliary Building (AB), Turbine Building, Main Steam Tunnels, Fuel Handling Building, and Essential Service Cooling Tower which are designed for the SSE and are therefore adequate for the GIVIRS. These operator pathways are required to route hoses and cables and also allow operators to reach equipment required to be locally operated. Byron Station has reviewed the operator pathways and verified that the operator pathways are not impacted by the MSSHI. Considerations for this review included:

• Pathway includes only seismic Category 1 structures (and SSE qualified Turbine Building) with previous reviews for seismic ruggedness.

• Debris removal capabilities for moderate to smaller seismic interactions including cabinets and other items that may tip over and collapse of block walls. Block walls within the Auxiliary Building have adequate capacity to withstand a GIVIRS seismic event. There is adequate room to work around fallen block walls within the Turbine Building. In addition, there are multiple pathways within the Turbine Building.

• Time for operator actions is available. The only actions with time restraints less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are DC bus load shedding (AB 451') and aligning the Service Water system with the Auxiliary Feed Pumps (AB 330'). Operators have clear pathways to perform these actions and, due to location, can easily be completed within the required time frame.

• Operator pathways were reviewed during a walkdown to assess seismic interactions associated with a GMRS-level seismic event.

U.S Nuclear Regulatory Commission Mitigating Strategies Seismic Hazard Assessment August 22, 2017 Page 4 2.4.3 Tie Down of Towable FLEX Equipment Types of large portable equipment used for the Byron Station FLEX strategies include diesel generators, Ford F-750 truck to clear debris, satellite trailer, hose trailers, and towable pumps as described in Attachment 2 of Reference 14. These components are tied down in the Robust FLEX Storage Building.

Stored equipment was evaluated (for stability and restraint as required/necessary) and protected from seismic interactions to the SSE level as part of the FLEX design process to ensure that unsecured and/or non-seismic components do not damage the FLEX equipment.

In addition, large FLEX equipment such as pumps and power supplies were secured as necessary to protect them during a SSE seismic event. These large components in the Robust FLEX Storage Building are tied down with ratchet straps that are secured to the building slab. Because of the low aspect ratios, low GIVIRS accelerations, and the restraints, the towable FLEX equipment was determined to be seismically adequate.

Smaller equipment is stored within storage lockers, boxes, and shelves inside the plant and inside the Robust FLEX Storage Building. These storage components were shown to have adequate capacity as to not tip over during a GIVIRS seismic event.

Byron Station has reviewed the storage requirements (including any tie-down or restraint devices) in effect for FLEX portable equipment and verified that the equipment has no adverse interactions or significant damage that could impair the ability of the equipment to perform its mitigating strategy function during or following the GMRS-level seismic event.

2.4.4 Additional Seismic Interactions Seismic interactions that could potentially affect the FLEX strategies and were not previously reviewed as part of the ESEP program (e.g., flooding from non-seismically robust tanks, interactions to distributed systems associated with the ESEP equipment list, etc.) were reviewed for Byron Station. Walkdowns of the areas containing components used for the FLEX strategies were conducted and did not identify any additional seismic interactions. The areas that were not walked down are High Radiation areas or hard-to-access areas. These areas are not anticipated to be used for storage. Also, these areas are Seismic Category I areas with all items designed to Seismic I or Seismic 11/1 requirements.

No underground tanks are relied upon for the FLEX strategies, and therefore, soil failure affecting piping attached to buried tanks is not a concern.

The suspended ceiling in the Work Execution Center (WEC) was identified as a potential seismic interaction during the walkdown. It was determined that the ceiling will not inhibit the execution of the FLEX strategies following a seismic event because of the high tensile capacity of the wire hangers and the lightweight ceiling tiles that can be moved or worked around.

Byron Station has reviewed the additional seismic interactions and verified that the Mitigation Strategy is not adversely impacted by the GIVIRS.

U.S Nuclear Regulatory Commission Mitigating Strategies Seismic Hazard Assessment August 22, 2017 Page 5 2.4.5 Haul Paths Byron Station has reviewed the haul paths and verified that the haul paths are not adversely impacted by the MSSHI.

The FLEX equipment haul paths are used to transport portable FLEX equipment from the Robust FLEX Storage Building to the deployment zones at the Essential Service Cooling Towers, the area near the Refueling Water Storage Tanks (RWSTs), and the Unit 1 and Unit 2 trackway doors. There are no slope stability concerns along the equipment haul paths.

Liquefaction was shown not to be a concern for any haul paths except for the north entrance from German Church Road [Reference 13]. In this case, the south entrance can be utilized.

Walkdowns were performed to verify the adequacy of the equipment haul paths for the GMRS.

It is concluded that debris in the form of metal siding, light posts, and power lines can be removed using the Ford F-750 truck [Reference 10].

3. SPENT FUEL POOL COOLING REVIEW The evaluation of spent fuel pool cooling for Byron Station was performed based on the initial conditions established in NEI 12-06 [Reference 1 ] for spent fuel cooling coping in the event of an extended loss of AC power (FLAP) I loss of normal access to the ultimate heat sink (LUHS). The evaluation also used the results of pool heat-up analyses from the (ELAP) evaluation as input.

The FLEX strategy for spent fuel pool (SFP) cooling utilizes SFP level monitoring and make-up capability as described in the Byron Station Final Integrated Plan (FIP) [Reference 14]. SFP make-up capability is provided using the portable medium head FLEX pump taking suction through a portable flexible hose and discharging through a flexible hose to portable Fuel Pool monitor guns that spray water directly into the pool. The source of make-up water is either the RWST or Deep Well No. 1. Both sources are adequate for the GMRS due to being inherently rugged or being designed to the SSE.

The spent fuel pool integrity evaluations demonstrated inherent margins of the Category I spent fuel pool structure above the SSE to a peak spectral acceleration of 0.8g [Reference 16]. The portable FLEX equipment availability, including its storage and deployment pathways, has subsequently been evaluated considering the GMRS-consistent loading conditions.

The spent fuel pool level indication components remotely display the water level in the spent fuel pool. The MSA report shows that these components have sufficient capacity for the GMRS. No seismic interactions were identified during the walkdowns that would adversely affect the function of the level indication components.

4. HIGH FREQUENCY REVIEW The high frequency review was submitted under separate cover to the NRC [Reference 5]. As discussed in Reference 5, Byron Station has completed the evaluation of potentially sensitive contact devices in accordance with NEI 12-06 [Reference 1], Appendix H Section H.4.2 and EPRI 3002004396 [Reference 7]. The results from the evaluation confirm that the FLEX strategies for Byron Station can be implemented as designed and no further seismic evaluations are necessary.

U.S Nuclear Regulatory Commission Mitigating Strategies Seismic Hazard Assessment August 22, 2017 Page 6

5. CONCLUSION Therefore, the FLEX strategies for Byron Station as described in the FIP [Reference 14] are acceptable as specified and no further seismic evaluations or modifications are necessary.

6. REFERENCES

1. NEI 12-06, Revision 4, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, December 2016, ADAMS Accession Number MI_1635413421

2. JLD-ISG-2012-01, Revision 2, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, February 2017, ADAMS Accession Number ML17005A188

3. Exelon Letter to NRC, Byron Station, Units 1 and 2, Exelon Generation Co., LLC - Seismic Hazard and Screening Report (Central and Eastern United States (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, [March 31, 2014], ML14091A010

4. NRC Letter, Byron Station, Units 1 and 2 - Staff Assessment Of Information Provided Pursuant To Title 10 Of The Code Of Federal Regulations Part 50, Section 50.54(F),

Seismic Hazard Reevaluations For Recommendation 2.1 Of The Near-Term Task Force Review Of Insights From The Fukushima Dai-ichi Accident (Cac Nos. MF3884 And MF3885), [February 17, 2016], ML16027A045

5. Exelon Letter to NRC, Byron Station, Units 1 and 2, Exelon Generation Co., LLC -

Mitigating Strategies Assessment (MSA) Report for the Reevaluated Seismic Hazard Information - NEI 12-06, Appendix H, Revision 2, HAA Path 4: GIVIRS < 2xSSE (Partial Submittal - High Frequency work scope), [November 3, 2016], ML16308A267

6. NRC Letter, Byron Station, Units 1 And 2 - Staff Review of High Frequency Confirmation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1, [January 30, 2017], ML17023A137

7. EPRI 3002004396, Final Report, July 2015, High Frequency Program Application Guidance for Functional Confirmation and Fragility Evaluation, ADAMS Accession Number ML15223A102

8. NRC Letter, Endorsement of Electric Power Research Institute Final Draft Report 3002004396, "High Frequency Program: Application Guidance for Functional Confirmation and Fragility", dated September 17, 2015, ADAMS Accession Number ML15218A569

9. EPRI, "Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic", Report Number 3002000704, Palo Alto, CA, April, 2013.

10. EXBY039-RPT-001, Rev. 0, "Byron MSA Seismic Path 4 Evaluation"

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

Seismic", Report Number 1025287, Palo Alto, CA, November, 2012.

U.S Nuclear Regulatory Commission Mitigating Strategies Seismic Hazard Assessment August 22, 2017 Page 7 12.EPRI, "EPRI NP-6041-SL Revision 1: A Methodology for Assessment of Nuclear Plant Seismic Margin, Revision 1", Palo Alto, CA, August, 1991.

13. Byron Station EC 399165, Rev. 0, "FLEX Haul Path Liquefaction Evaluation" 14.Exelon Letter to NRC, Byron, Unit 2, Exelon Generation Co., LLC -Report of Full Compliance with 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), [July 15, 2016]) ML16197A390, [Contains Final Integration Plan for Units 1 and 2]

15. NRC Letter, Byron Station, Units 1 And 2 - Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (CAC NOS. MFO893, M170894, MF0872, and MF0873), [December 19, 2016] ML16334A504 16.Exelon Letter to NRC, Byron Station, Units 1 and 2, Exelon Generation Co., LLC - Spent Fuel Pool Evaluation Supplemental Report, 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, [August 31, 2016],

ML16244A800

17. NRC Letter, Byron Station, Units 1 and 2-Supplement to Staff Assessment Of Information Provided Pursuant To Title 10 Of The Code Of Federal Regulations Part 50, Section 50.54(F), Seismic Hazard Reevaluations For Recommendation 2.1 Of The Near-Term Task Force Review Of Insights From The Fukushima Dai-ichi Accident (Cac Nos. MF3884 And MF3885), [March 15,2016], ML16070A116

Byron Station, Units 1 and 2 Expedited Seismic Evaluation Process (ESEP) Report (68 Pages)

EXPEDITED SEISMIC EVALUATION PROCESS (ESEP) REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC for the BYRON GENERATING STATION 4450 NORTH GERMAN CHURCH ROAD, BYRON,ILLINOIS 61010-9794 Facility Operating License No. NPF-37 AND NPF-66 NRC Docket No. STN 50-454 and STN 50-455 r4~

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'%,re 10 Exelon Generation Company, LLC(Exelon)

PO Box 805398 Chicago, IL 60680-5398 Prepared by:

Stevenson & Associates 1661 Feehanville Drive, Suite 150 Mount Prospect, IL 60056 Report Number. 1404240-RPT-004, Rev. I Prinjed NaL n2 Signature Date Preparers Alex Breda 21212017 lwaj**

Reviewer. Marlene Delaney 217/2017 Approver. Marlene Delaney 2(7/2017 Lead Wes7xTsible Engineer: SCAN zlevur Branch Manager:

• AA Senior Manager Design Engineering: Q067f 60;1Ucrt- 7 Corporate Acceptance:VSPOJ) A651WOL- 4 1 17

Document

Title:

EXPEDITED SEISMIC EVALUATION PROCESS (ESEP) IN RESPONSE TO THE 50.54(f)

INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC for the BYRON GENERATING STATION Document Type: Report Report Number: 14Q4240-RPT-004 Project Name:

Exelon ESEP for Byron Job No.: 14Q4240 AWWAW Client:

A01r~

Exelon.

This document has been prepared in accordance with the S&A Quality Assurance Program Manual, Revision 18 and project requirements:

Rev. 0 Initial Issue for client record only

,~ ~e`~4 Date: 11 /13/14 re pared by: Marlene Delaney '~ ^

-,~ Date: 11/13/14 Reviewed by: Alex Broda ~

Date: 11/17/14

.l Approved by: Mike Allison Revision Record:

Revision Prepared by/ Reviewed by/ Approved by/ Description of Revision No. Date Date Date 1 A. Broda M. Delaney M. Delaney Complete revision 2/2/2017 2/7/2017 2/7/2017 DOCUMENT CONTRACT NO.

APPROVAL SHEET 14Q4240 Stevenson & Associates Page ii

S&A Report 14Q4240-RPT-004 Revision 1 Contents 1.0 Purpose and Objective .................................................................................................... 4 2.0 Brief Summary of the FLEX Seismic Implementation Strategies ............................. 5 3.0 Equipment Selection Process and ESEL and Alternate Path Justification ............ 6 3.1 Equipment Selection Process and ESEL ...................................................................... 6 3.1.1 ESEL Development ................................................................................................... 7 3.1.2 Power Operated Valves ............................................................................................ 8 3.1.3 Pull Boxes .................................................................................................................. 9 3.1.4 Termination Cabinets ............................................................................................... 9 3.1.5 Critical Instrumentation Indicators .........................................................................9 3.1.6 Phase 2 and Phase 3 Piping Connections ............................................................ 9 3.2 Justification for use of Equipment that is not the primary means for FLEX implementation...............................................................................................................10 4.0 Ground Motion Response Spectrum (GMRS) ............................................................11 4.1 Plot of GMRS submitted by the Licensee ...................................................................11 4.2 Comparison to SSE ........................................................................................................13 5.0 Review Level Ground Motion (RLGM) .........................................................................15 5.1 Description of RLGM selected ......................................................................................15 5.2 Method to estimate ISRS ...............................................................................................18 6.0 Seismic Margin Evaluation Approach .........................................................................19 6.1 Summary of methodologies used ................................................................................19 6.2 HCLPF screening process ............................................................................................ 20 6.3 Seismic walkdown approach ........................................................................................ 20 6.3.1 Walkdown approach ............................................................................................... 20 6.3.2 Application of Previous Walkdown Information ................................................. 21 6.3.3 Significant Walkdown Findings ............................................................................ 22 6.4 HCLPF calculation process ........................................................................................... 22 6.5 Functional evaluation of relays .................................................................................... 24 6.6 Tabulated ESEL HCLPF values (including Key failure modes) ............................... 24 7.0 Inaccessible Items .......................................................................................................... 25 7.1 Identification of ESEL Items inaccessible for walkdowns ....................................... 25 Page 1 of 68

S&A Report 14Q4240-RPT-004 Revision I 7.2 Planned Walkdown I Evaluation Schedule I Close Out ............................................ 25 8.0 ESEP Conclusions and Results ................................................................................... 26 8.1 Supporting Information ................................................................................................. 26 8.2 Summary of ESEP Identified and Identification of Planned Modifications ........... 27 8.3 Modification Implementation Schedule ....................................................................... 28 8.4 Summary of Regulatory Commitments ....................................................................... 28 9.0 References ....................................................................................................................... 29 Attachments A Byron Unit I ESEL (includes common components) ..................................................33 BByron Unit 2 ESEL .......................................................................................................... 41 C ESEP HCLPF Values and Failure Modes Tabulation, Unit 1 ........................................ 49 D ESEP HCLPF Values and Failure Modes Tabulation, Unit 2 ........................................ 60 Page 2 of 68

S&A Report 14Q.4240-RPT-004 Revision 1 List of Tables and Figures Table 3-1 Flow Paths Credited for ESEP Table 4-1 Byron GMRS Table 4-2 Byron GMRS vs SSE Table 5-1 Ratio between GMRS versus SSE Table 5-2 Byron RLGM Figure 4-1 Byron GMRS Plot Figure 4-2 Byron GMRS versus SSE Figure 5-2 Plot of RLGM Page 3 of 68

S&A Report 14Q4240-RPT-004 Revision I 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 Byron Generating Station. The intent of the ESEP is to perform an interim action in response to the N RC's 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 for Byron Generating Station. The level of detail provided in the report is intended to enable NRC to understand the inputs used, the evaluations performed, and the decisions made as a result of the interim evaluations.

Page 4 of 68

S&A Report 14Q4240-RPT-004 Revision I 2.0 Brief Summary of the FLEX Seismic Implementation Strategies The BYR FLEX strategies for Reactor Core Cooling and Heat Removal, Reactor Inventory Control/Long-term Sub-criticality and Containment Function are summarized below. This strategy is described in the Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049, including 6 month updates through August 2014 [3].

FLEX Phase 1, strategy relies on installed plant equipment. Reactor core cooling and heat removal is achieved via manual/local operation of the steam generator (SG) power operated relief valves (PORV). The safety injection (SI) accumulator will provide the initial boration for reactivity control and the Diesel Driven Auxiliary Feedwater (DDAF) pump will provide inventory to the SG via the condensate storage tank (CST) or Ultimate Heat Sink (UHS). Reactor coolant system (RCS) inventory and control is achieved by maintaining RCS temperature by controlling SG pressure with the PORVs. This ensures maximum SI accumulator injection. Containment temperature and pressure limits are not expected to challenged, but will be monitored.

Instrumentation will be maintained available by performing DC and AC bus load shedding.

Batteries are expected to last 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after load shedding.

FLEX Phase 2, strategy relies on installed plant equipment and portable on-site equipment.

Inventory to the SGs will continue to be provided by the DDAF pump or the medium head FLEX pump with inventory from the Essential Service Water Cooling (SXCT) which is maintained by well water backup. The FLEX diesel generator (DG) will provide power to the diesel oil (DO) transfer pumps to maintain oil inventory for the DDAF pump. The FLEX DG will also reenergize the DDAF pump battery chargers and the Div 2 instrumentation bus battery chargers. The high head FLEX pump will provide borated water from the RWST to the reactor through the FLEX connections to CV and/or SI.

FLEX Phase 3, strategy relies on installed plant equipment and portable on-site and off-site equipment. The portable equipment and connections used in phase 2 will continue to be used as the primary strategy with National SAFER Response Center (NSRC) equipment as spares.

Page 5 of 68

S&A Report 14Q4240-RPT-004 Revision I 3.0 Equipment Selection Process and ESEL and Alternate Path Justification The selection of equipment for the ESEL followed the guidelines of EPRI 3002000704 [2]. The ESEL was validated in Report 14Q4240-RPT-003 [21.1]. The ESELs for Unit 1 and Unit 2 are presented in Attachments A and B, respectively. Items associated with both units (common) are identified on the Unit 1 ESEL in Attachment A.

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 Byron Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049 [3]. The OIP provides the Byron 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 Byron OIP [3]. 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 sub-criticality, 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. The instrumentation monitoring requirements for core cooling/containment safety functions are limited to those outlined in the EPRI 3002000704 guidance, and are a subset of those outlined in the Byron OIP [3].

2. The scope of components is limited to installed plant equipment, and FLEX connections necessary to implement the Byron OIP [3] 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:

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

• Piping, cabling, conduit, HVAC, and their supports.

• Manual valves and rupture disks.

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S&A Report 14Q4240-RPT-004 Revision 1

• Power-operated valves not required to change state as part of the FLEX mitigation strategies.

• Nuclear steam supply system components (e.g. reactor pressure vessel and internals, reactor coolant pumps and seals, etc.)

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

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

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 flow paths credited for ESEP for Byron are discussed in the table below.

Table 3-1 Flow Paths Credited for ESEP P&IDs Flow Path Unit I Unit 2 M-120 sh. 1 RCS Heat Removal: Discharge of Main Steam M-35 sh. 1 M-120 sh. 2A from the Steam Generators to the Atmosphere M-35 sh. 2 M-120 sh. 2B via Main Steam Power Operated Relief Valves M-35 sh. 8 M-120 sh. 9 M-121 sh. 1A M-36 sh. 1A M-121 sh. 1 B RCS Heat Removal: Feedwater from the M-36 sh. 1 B M-121 Sh. 1C Essential Service Water Cooling Tower Basin to M-36 sh. 1 C M-121 sh. 1D the Steam Generators via the Diesel Driven M-36 sh. 1 D M-122 Auxiliary Feedwater Pump M-37 M-126 sh. 1 M-42 sh. 3 M-42 sh. 2A Page 7 of 68

S&A Report 14Q4240-RPT-004 Revision I P&lDs Flow Path Unit I Unit 2 M-61 sh. 5 M-135 sh. 1 B M-61 sh. 6 M-135 sh. 2 RCS Inventory Control: Passive injection from M-61 sh. 1A M-135 sh. 3 the Safety Injection Accumulators; and active M-61 sh. 3 M-135 sh. 4 injection from the RWST to the RCS at the M-61 sh. 1 B M-136 sh. 5 CV/Sl Pump discharge piping, via a FLEX pump M-60 sh. 2 M-136 sh. 6 and FLEX connections. M-60 sh. 3 M-136 sh. 4 M-60 sh. 4 M-136 sh. 1 M-62 M-137 Fuel Oil Supply: From the Diesel Fuel Oil M-50 sh. 1A M-130 sh. 1A Storage Tank to the FLEX Connection Point (for M-50 sh. 1 B M-130 sh. 1 B fueling FLEX Equipment) and the Diesel Driven M-50 sh. 1 D M-130 sheet 2 Auxiliary Feedwater Pump M-50 sh. 3 M-42 sh. 1A M-42 sh. 1A RCS Heat Removal and Equipment Cooling:

M-42 sh. 2A M-42 sh. 2A Essential Service Water make-up from the M-42 sh. 2B M-42 sh. 2B Deep Well to the Essential Service Water M-42 sh. 6 M-42 sh. 6 Cooling Tower Basin and cooling for the Diesel M-42 sh. 7 M-42 sh. 7 Driven Auxiliary Feedwater Pump M-83 M-83 RCS Pressure Control: Discharge of reactor M-60 sh. 5 M-135 sh. 5 coolant from the Pressurizer via Power M-60 sh. 8 M-135 sh. 8 Operated Relief Valves Equipment Cooling and Ventilation: Battery Room HVAC for environment and hydrogen M-115 sh. M-116 sh. 1 control 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 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 Byron ESEL for functional failure modes associated with power operated valves:

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

Page 8 of 68

S&A Report 14Q4240-RPT-004 Revision I 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.

• 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 FLAP 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.

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).

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 Byron OIP [3] 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].

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S&A Report 14Q4240-RPT-004 Revision 1 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 No equipment that is not the primary means for FLEX implementation is specified on the Byron ESEL.

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S&A Report 14Q4240-RPT-004 Revision I 4.0 Ground Motion Response Spectrum (GMRS) 4.1 Plot of GMRS submitted by the Licensee In accordance with Section 2.4.2 of the SPID [15], the licensing design basis definition of the SSE control point for Byron Station is used for comparison to the GMRS. Section 2.5.2.6 and 3.7.1.1 of the Byron UFSAR [18], states that the 0.208 Reg. Guide 1.60 site response spectra is defined at the bedrock-soil interface elevation of 869 feet mean sea level.

The GMRS per the March submittal report [4] is tabulated and graphed below:

TABLE 4-1 BYRON GMRS (5% Damping)

Freq. (Hz) GMRS (unscaled, g) 1 0.070 1.25 0.081 1.5 0.090 2 0.113 2.5 0.129 3 0.172 3.5 0.218 4 0.269 5 0.385 6 0.477 7 0.551 8 0.583 9 0.581 10 0.568 12.5 0.508 15 0.488 20 0.514 25 0.508 30 0.497 35 0.467 40 0.435 50 0.365 60 0.307 70 0.284 80 0.275 90 0.272 100 0.270 El Page 11 of 68

S&A Report 14Q4240-RPT-004 Revision 1 FIGURE 4-1 BYRON GMRS PLOT 1.0 0.9 0.8 i

0.7 to 0.6 0.5 a

a u

u a 0.4 0.3 l

0.2 0.1 0.0 1 10 100 Frequency (Hz)

GMRS Page 12 of 68

S&A Report 1484240-RPT-004 Revision I 4.2 Comparison to SSE As identified in the Byron March submittal report [4], the GIVIRS exceeds the SSE in the 1-10 hz range as shown in Table 4-2 and Figure 4.2.

TABLE 4-2 BYRON GIVIRS vs. SSE G\ARS Horizontal

~g)__

II Q; MewRf-,

,ie s m on ai Page 13 of 68

S&A Report 14Q4240-RPT-004 Revision 1 FIGURE 4-2 BYRON GMRS vs. SSE PLOT 1.0 0.9 0.8 0.7 n

0.6 0.3 0.2 0.1 0.0 1 10 Frequency (Hz)

GMRS ----- Horizontal SSE Page 14 of 68

S&A Report 14Q4240-RPT-004 Revision 1 5.0 Review Level Ground Motion (RLGM) 5.1 Description of RLGM selected The RLGM for Byron was determined in accordance with Section 4 of EPRI 3002000704 [2] as being derived by linearly scaling the Byron SSE by the maximum ratio of the GMRS/SSE between the 1 and 10 hertz range. This calculation is shown in Table 5-1.

The ratio between the GIVIRS and SSE at 5% damping is tabulated.

TABLE 5-1 RATIO BETWEEN GIVIRS AND SSE Freq. GIVIRS Horizontal SSE SF =

(Hz) (unscaled, (g) GMRS/SSE 1 0.070 0.295 0.24 1.25 0.081 0.354 0.23 1.5 0.090 0.410 0.22 2 0.113 0.521 0.22 2.5 0.129 0.626 0.21 3 0.172 0.610 0.28 3.5 0.218 0.598 0.36 4 0.269 0.586 0.46 5 0.385 0.567 0.68 6 0.477 0.553 0.86 7 0.551 0.541 1.02 8 0.583 0.531 1.10 9 0.581 0.522 1.11 10 0.568 0.483 1.18 As shown above, the maximum ratio between the 5% damping GIVIRS and horizontal SSE occurs at 10 Hz and equals 1.18.

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S&A Report 14Q4240-RPT-004 Revision I The resulting 5% damped RLGM, based on increasing the horizontal SSE by the maximum GMRS/SSE ratio of 1.18 is shown in Table 5-2 and Figure 5-2, the Byron Horizontal SSE is obtained from reference [4] Table 3.1-1. Note the RLGM PGA is 0.24.

TABLE 5-2 Byron RLGM (5% Damping)

K.

MIKE" INOMI Page 16 of 68

S&A Report 14Q4240-RPT-004 Revision 1 FIGURE 5-2 PLOT OF RLGM 1.0 0.9 0.8 0.7

,-0.6 a 0.4 0.3 i

0.2 f

0.1 i

0.0 1 10 100 Frequency (Hz)

-RLGM Page 17 of 68

S&A Report 14Q4240-RPT-004 Revision I 5.2 Method to estimate ISRS The method used to derive the ESEP in-structure response spectra (ISRS) was to uniformly scale the existing SSE-based ISRS obtained from DC-ST-04-BB, Revision 2, "Development of Seismic Subsystem (or Equipment) Design Criteria (Horizontal and Vertical Earthquake) and Response Spectra" [22] by the maximum ratio of 1.18. The scaled ISRS was determined for all buildings and elevations where ESEL items are located at Byron and are documented in 14Q4240-CAL-001 [10.5].

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S&A Report 14Q4240-RPT-004 Revision I 6.0 Seismic Margin Evaluation Approach It is necessary to demonstrate that ESEL items have sufficient seismic capacity to meet or exceed the demand characterized by the RLGM. The seismic capacity is characterized as the peak ground acceleration (PGA) for which there is a high confidence of a low probability of failure (HCLPF). The PGA is associated with a specific spectral shape, in this case the 5%-

damped RLGM spectral shape. The calculated HCLPF capacity must be equal to or greater than the RLGM PGA (0.24g from Table 5-2). 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) [7].

2. Probabilistic approach using the fragility analysis methodology of EPRI TR-1 03959, Methodology for Developing Seismic Fragilities [8].

For Byron, the deterministic approach using the CDFM methodology of EPRI NP-6041 [7] was used to determine HCLPFs.

6.1 Summary of methodologies used Byron performed a seismic margin assessment (SMA) in 1998 in accordance with Nuclear Regulatory Commission, NUREG-1407, Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, June 1991 [5]

and Nuclear Regulatory Commission, Generic Letter No. 88-20 Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities - 1 OCFR 50.54(f),

June 1991 [6]. Byron submitted the results of this SMA to the NRC per ComEd (now Exelon)

Letter BY: 96-0323, Transmittal of Byron Station Individual Plant Examination of External Events Submittal Report", December 23, 1996 [9]. The SMA was based on the IPEEE RLE, which was anchored to 0.3g peak ground acceleration. The SMA consisted of screening walkdowns and HCLPF calculations in accordance with EPRI NP-6041 [7]. HCLPF calculations were based on the CDFM methodology of EPRI NP-6041 [7].

For ESEP, Byron conservatively applied the methodology of EPRI NP-6041 [7] to all items on the ESEL. The screening walkdowns used the'screening tables from Chapter 2 of EPRI NP-6041 [7]. The walkdowns were conducted by engineers who as a minimum attended the SQUG Walkdown Screening and Seismic Evaluation Training Course. The walkdowns were documented on Screening Evaluation Work Sheets from EPRI NP-6041 [7] which are included in Report 14Q4240-RPT-005 [21.2]. Anchorage capacity calculations used the CDFM criteria from EPRI NP-6041 [7] with Byron specific allowables and material strengths used as applicable. The input seismic demand was the RLGM provided in Table 5-2 and Figure 5-2.

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S&A Report 14Q4240-RPT-004 Revision 1 6.2 HCLPF screening process From Table 5-2 the spectral peak of the RLGM (amplified PGA) for Byron equals 0.739. The screening tables in EPRI NP-6041 [7] are based on ground peak spectral accelerations of 0.8g and 1.2g. These both exceed the RLGM peak spectral acceleration. The Byron ESEL components were screened against the 0.8g column of Table 2-4 of NP-6041 [7]. Note that the 0.8g corresponds to a PGA of 0.3g.

Per Report 14Q4240-RPT-003 [21.1], the Unit 1 and Unit 2 ESEL contain 111 and 104 items respectively. Of these, 16 are valves in Unit 0 and Unit 1 and 15 in Unit 2, both power-operated and relief. In accordance with Table 2-4 of EPRI NP-6041 [7], active valves may be assigned a functional capacity of 0.8g peak spectral acceleration without any review other than looking for valves with large extended operators on small diameter piping, and anchorage is not a failure mode. Therefore, valves on the ESEL may be screened out from ESEP seismic capacity determination, subject to the caveat regarding large extended operators on small diameter piping. The non-valve components in the ESEL were evaluated to the EPRI NP-6041 [7]

caveats.

6.3 Seismic walkdown approach 6.3.1 Walkdown approach Walkdowns for Byron were performed in accordance with the criteria provided in Section 5 of EPRI 3002000704 [2], which refers to EPRI NP-6041 [7] for the Seismic Margin Assessment process. Pages 2-26 through 2-30 of EPRI NP-6041 [7] describe the seismic walkdown criteria, including the following key criteria.

"The SR [Seismic Review Team] should "walk by" 100% of all components which are reasonably accessible and in non-radioactive or low radioactive environments. Seismic capability assessment of components which are inaccessible, in high-radioactive environments, or possibly within contaminated containment, will have to rely more on alternate means such as photographic inspection, more reliance on seismic reanalysis, and possibly, smaller inspection teams and more hurried inspections. A 100% "walk by" does not mean complete inspection of each component, nor does it mean requiring an electrician or other technician to de-energize and open cabinets or panels for detailed inspection of all components. This walkdown is not intended to be a QA or QC review or a review of the adequacy of the component at the SSE level.

If the SRT has a reasonable basis for assuming that the group of components are similar and are similarly anchored, then it is only necessary to inspect one component out of this group. The "similarity-basis" should be developed before the walkdown during the seismic capability preparatory work (Step 3) by reference to drawings, calculations or specifications. The one component or each type which is selected should be thoroughly Page 20 of 68

S&A Report 14Q4240-RPT-004 Revision I inspected which probably does mean de-energizing and opening cabinets or panels for this very limited sample. Generally, a spare representative component can be found so as to enable the inspection to be performed while the plant is in operation. At least for the one component of each type which is selected, anchorage should be thoroughly inspected.

The walkdown procedure should be performed in an ad hoc manner. For each class of components the SRT should look closely at the first items and compare the field configurations with the construction drawings and/or specifications. If a one-to-one correspondence is found, then subsequent items do not have to be inspected in as great a detail. Ultimately the walkdown becomes a "walk by" of the component class as the SRT becomes confident that the construction pattern is typical. This procedure for inspection should be repeated for each component class; although, during the actual walkdown the SRT may be inspecting several classes of components in parallel. If serious exceptions to the drawings or questionable construction practices are found then the system or component class must be inspected in closer detail until the systematic deficiency is defined.

The 100% "walk by" is to look for outliers, lack of similarity, anchorage which is different from that shown on drawings or prescribed in criteria for that component, potential S1

[Seismic Interaction ] problems, situations that are at odds with the team members' past experience, and any other areas of serious seismic concern. If any such concerns surface, then the limited sample size of one component of each type for thorough inspection will have to be increased. The increase in sample size which should be inspected will depend upon the number of outliers and different anchorages, etc., which are observed. It is up to the SRT to ultimately select the sample size since they are the ones who are responsible for the seismic adequacy of all elements which they screen from the margin review. Appendix D gives guidance for sampling selection.

The Byron walkdowns included as a minimum a 100% walk-by of the existing items on the ESEL except as noted in Section 7.0. Any previous walkdown information that was relied upon for SRT judgment is documented in Section 6.3.2.

6.3.2 Application of Previous Walkdown Information The seismic walkdowns for Byron included as a minimum a walk-by of all the components on the ESEL with the exception of OWWO1 PA (deep well pump) which is discussed in Section 7.0.

All non-energized cabinets were opened when specialized tools were not needed to operate the cabinet doors. For the switchgear (1/2AP12E), the photos taken during the NTTF R2.3 walkdowns (17] were utilized for SRT judgment.

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S&A Report 14Q4240-RPT-004 Revision I 6.3.3 Significant Walkdown Findings Consistent with the guidance from NP-6041 [7], no significant outliers or anchorage concerns were identified during the Byron seismic walkdowns. The following findings were noted during the walkdowns.

Several block walls were identified in the proximity of ESEL equipment. These block walls were assessed for their structural adequacy to withstand the seismic loads resulting from the RLGM. For these cases, the block wall is noted on the ESEL HCLPF tables in Attachments C and D.

6.4 HCLPF calculation process ESEL items were evaluated using the criteria in EPRI NP-6041 [7]. Those evaluations included the following steps:

Performing seismic capability walkdowns for equipment to evaluate the equipment installed plant conditions Performing screening evaluations using the screening tables in EPRI NP-6041[7] as described in Section 6.2 and Performing HCLPF calculations considering various failure modes that include both structural failure modes (e.g. anchorage, load path etc.) and functional failure modes.

All HCLPF calculations were performed using the CDFM methodology and are documented in Byron calculations [10].

Anchorage for non-valve components was evaluated either by SRT judgment, large margins in existing design basis calculations, or CDFM HCLPF calculations [10]. This is documented in Attachments C and D.

A number of components were located above 40 feet from grade. For components located 40 feet above grade, screening based on ground peak spectral acceleration is not applicable and additional consideration is required. In accordance with Appendix B of EPRI 1019200 [19],

spectral acceleration of the ground can be converted to 5% damper spectral acceleration at the base of the component. Therefore, components that are above 40 feet from grade and have corresponding ISRS at the base of component not in exceedance of 1.8g (1.5 times 1.2g) in the component frequency range of interest may be screened using the caveats of the 2nd screening column. Per Calculation 14Q4240-CAL-001 [10.5], the acceleration values at elevations above 40 feet are significantly larger than 1.8g. In order to determine the equipment capacity of these components, existing Byron design basis seismic test qualification reports were utilized by increasing the Required Response Spectra by the ratio of GMRS/SSE to determine their acceptability and the HCLPFs for these components.

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S&A Report 14Q4240-RPT-004 Revision 1 In addition, potential seismic interactions such as block walls were identified during the walkdowns and the CDFIVI HCLPFs were determined for these interactions as noted in Attachment C and D.

As described in Section 6.0, for HCLPF calculations the conservative, deterministic failure margin (CDFM) analysis criteria established in Section 6 of EPRI NP-6041 [7] are used for a detailed analysis of components. The relevant CDFIVI criteria from EPRI NP-6041 [7] are summarized in Table 6-1.

Table 6-1: HCLPF Calculation Summary Load combination: Normal + Ec Conservatively specified (84% non-exceedance Ground response spectrum:

probability)

Damping: Conservative estimate of median damping.

Best estimate (median) + uncertainty variation in Structural model:

frequency.

Soil-structure Interaction Best estimate (median) + parameter variation Code specified minimum strength or 95% exceedance of Material strength:

actual strength if test data is available.

Code ultimate strength (ACI), maximum strength (AISC),

Service Level D (ASM E) or functional limits. If test data Static capacity equations: is available to demonstrate excessive conservatism of code equations then use 84% exceedance of test data for capacity equations.

For non-brittle failure modes and linear analysis, use 80% of computed seismic stress in capacity evaluation Inelastic energy absorption:

to account for ductility benefits or perform nonlinear analysis and use 95% exceedance ductility levels.

In-structure (floor) spectra Use frequency shifting rather than peak broadening to generation: account for uncertainty and use median damping.

The HCLPF capacity is equal to the PGA at which the strength limit is reached. The HCLPF earthquake load is calculated as follows:

U = Normal + Ec Where:

• U = Ultimate strength per Section 6 of EPRI NP-6041 [7]

• Ec = HCLPF earthquake load

• Normal = Normal operating loads (dead and live load expected to be present, etc.)

For this calculation, the HCLPF earthquake load is related to a fixed reference earthquake:

Ec = SFc*Eref Where:

• Eref = reference earthquake from the relevant in-structure response spectrum (ISRS)

• SFc = component-specific scale factor that satisfies U = Normal +Ec Page 23 of 68

S&A Report 14Q4240-RPT-004 Revision I The HCLPF will be defined as the PGA produced by Ec. Because the Byron RLGM PGA is 0.24g:

HCLPF = 0.24g *SFc 6.5 Functional evaluation of relays Per Report 14Q4240-RPT-003 [21.1], twenty-six relays in the ESEL associated with the FLEX Phase 1 response required functional evaluations. Each relay was evaluated using the SMA relay evaluation criteria of Section 3 of NP-6041 [7].

Twelve relays were evaluated using Generic Equipment Ruggedness Spectra in accordance with NP-6041 [7].

Specific seismic qualification test-based capacities were available for the remaining relays in Byron documentation. In-cabinet capacity to demand evaluations were performed using the Byron relay seismic capacities and the ESEP ISRS scaled with the NP-6041 in-cabinet amplification factors.

The ESEP relay functional evaluations are documented in a Byron calculation 14Q4240-CAL-005 [10.4].

6.6 Tabulated ESEL HCLPF values (including Key failure modes)

Tabulated ESEL HCLPF values including the key failure modes are included in Attachment C for Unit 1 and common items and in Attachment D for Unit 2 items.

For items screened out using NP 6041 [7] screening tables, the screening level can be provided as >RLGM (0.24g) and the failure mode can be listed as "Screened",

(unless the controlling HCLPF value is governed by anchorage).

For items where anchorage controls the HCLPF value, the HCLPF value is listed in the table and the failure mode is noted as "anchorage."

For items where equipment capacity based upon the screening lane values of Table 2-4 of EPRI NP-6041 [7] controls the HCLPF value (e.g. anchorage HCLPF capacity exceeds the equipment capacity derived from screening lanes), the HCLPF value is listed in the table and the failure mode is noted as "equipment capacity."

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S&A Report 14Q4240-RPT-004 Revision I 7.0 Inaccessible Items 7.1 Identification of ESEL Items inaccessible for walkdowns There are no inaccessible items for the Byron ESEP with the exception of the deep well pump OWWO1 PA and low suction pressure switch 1/2PSL-AF055. This pump is incased in a concrete vault and is not accessible. However, this pump undergoes frequent surveillance for functionality per Byron procedure BVP 800-27 [20]. The pump is not anchored to any concrete elements but is grouted in place therefore no anchorage calculation is required. Similarly, seismic interactions with components such as block walls are not a feasible concern. The pressure switch is located in panel 1/2PA34J which was walked down. The switch is located within a Westinghouse unit and cannot be visually inspected.

Twelve components in the Unit 2 containment were not walked down. Based on the results of the Unit 1 ESEP walkdowns, these components would be qualified by comparison to their counterpart in the other unit. Based on the location of the items and with regard to seismic interactions, there would be no block walls or attached piping.

2PL60JB 2PL60JD 2PL61JA 2PL61JC 2PL69J 2PL75J 2RY32MB 2RY456 2SI8808A 2SI8808B 2SI8808C 2SI8808D 1/2PIS-0403 in the Auxiliary Building were not walked down, due to radiation and safety concerns. 1/2PIS-0403 are located in a high radiation area of the plant a few feet from 1/2PT-0403. 1/2PT-0403 were walked down the week of April 28th, 2014, and systems interactions were not noted in that area of the plant. 1/2PIS-0403 are acceptable by engineering judgement for seismic interactions due to their proximity to 1/2PT-0403 and the walkdown performed the week of April 28th, 2014.

7.2 Planned Walkdown / Evaluation Schedule / Close Out No additional walkdowns are required.

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S&A Report 14Q4240-RPT-004 Revision 1 8.0 ESEP Conclusions and Results 8.1 Supporting Information Byron Generating Station has performed the ESEP as an interim action in response to the NRC's 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 Byron response to the NRC's 50.54(f) letter [1]. On March 12, 20141 NEI submitted to the NRC results of a study [12] 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 NRC's May 9, 2014 NTTF 2.1 Screening and Prioritization letter [14] concluded that the "fleetwide seismic risk estimates are consistent with the approach and results used in the GI-199 safety/risk assessment." The letter also stated that "As a result, the staff has confirmed that the conclusions reached in GI-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 Byron was included in the fleet risk evaluation submitted in the March 12, 2014 NEI letter [12] therefore, the conclusions in the NRC's May 9 letter [14] also apply to Byron.

In addition, the March 12, 2014 NEI letter [12] 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:

Page 26 of 68

S&A Report 14Q4240-RPT-004 Revision I

• Safety factors applied in design calculations

• Damping values used in dynamic analysis of SSCs

• Bounding synthetic time histories for in-structure response spectra calculations

• Broadening criteria for in-structure response spectra

• Response spectra enveloping criteria typically used in SSC analysis and testing applications

• Response spectra based frequency domain analysis rather than explicit time history based time domain analysis

• Bounding requirements in codes and standards

• Use of minimum strength requirements of structural components (concrete and steel)

• Bounding testing requirements, and

• 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 NRC's 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 plant's SSE rather than the actual GIVIRS. To more fully characterize the risk impacts of the seismic ground motion represented by the GIVIRS 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 [15]. Per the NRC May 9, 2014 letter [14], it is not necessary for Byron to perform a risk evaluation. The completion of the ESEP satisfies the regulatory commitment.

8.2 Summary of ESEP Identified and Identification of Planned Modifications Page 27 of 68

S&A Report 14Q4240-RPT-004 Revision I The results of the Byron ESEP performed as an interim action in response to the NRC's 50.54(f) letter [1] using the methodologies in the NRC endorsed guidance in EPRI 3002000704 [2] show that all equipment evaluated are adequate in resisting the seismic loads expected to result from the site RLGM. Therefore, no plant modifications are required as a result of the Byron ESEP.

8.3 Modification Implementation Schedule No modification implementation schedule is required since no modifications are required.

8.4 Summary of Regulatory Commitments No regulatory commitments are required.

Page 28 of 68

S&A Report 14Q4240-RPT-004 Revision 1 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) Order Number EA-12-049 responses:

3.1) NRC Letter RS-13-018 from Byron (ML13060A364), "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)", February 28, 2013 3.2) NRC Letter RS-13-115 from Byron (ML13241A279), "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)", August 28, 2013 3.3) NRC Letter RS-14-008 from Byron (ML14059A425)'(I 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)", February 28, 2014 3.4) NRC Letter RS-14-206 from Byron (ML14248A229)'I[ 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)", August 28, 2014

4) Seismic Hazard and Screening Report in Response to the 50.54(f) Information Request Regarding Fukushima Near-Term Task Force Recommendation 2.1: Seismic for Byron Generating Station dated 3/17/14, Correspondence No. RS-14-065 (S&L Report SL-012185, Revision 0).

5) Nuclear Regulatory Commission, NUREG-1407, Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, June 1991

6) Nuclear Regulatory Commission, Generic Letter No. 88-20 Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities -

10CFR 50.54(f), June 1991 Page 29 of 68

S&A Report 14Q4240-RPT-004 Revision I

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

8) Methodology for Developing Seismic Fragilities, August 1991, EPRI, Palo Alto, CA.

1994, TR-103959

9) ComEd, K. L. Graesuar, Letter By: 96-0323 to the USNRC, "Transmittal of Byron Station Individual Plant Examination of External Events Submittal Report", December 23, 1996

10) Byron HCLPF Calculations for the ESEP project 10.1) 14Q4240-CAL-002, Revision 1, HCLPF Evaluations of Equipment and Anchorage for Byron ESEP 10.2) 14Q4240-CAL-003, Revision 1, HCLPF Evaluations of Masonry Block Walls for Byron ESEP 10.3) 14Q4240-CAL-004, Revision 1, HCLPF Evaluation of the Diesel Oil Storage Tanks for Byron ESEP 10.4) 14Q4240-CAL-005, Revision 1, HCLPF Evaluations of Relays for Byron ESEP 10.5) 14Q4240-CAL-001, Revision 1, Generation of In-Structure Response Spectra for Byron ESEP

11) Nuclear Regulatory Commission, NUREG/CR-0098, Development of Criteria for Seismic Review of Selected Nuclear Power Plants, published May 1978

12) 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

13) 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

14) 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.

15) Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPI D) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1:

Seismic. EPRI, Palo Alto, CA: February 2013. 1025287.

16) NRC (E Leeds) Letter to NEI (J Pollock), "Electric Power Research Institute Final Draft Report XXXXXX, "Seismic Evaluation Guidance: Augmented Approach for the Page 30 of 68

S&A Report 14Q4240-RPT-004 Revision I Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic," as an Acceptable Alternative to the March 12, 2012, Information Request for Seismic Reevaluations," May 7, 2013 ADAMS Accession No. MI-1 3106A331

17) NTTF 2.3 Seismic Walkdown Submittals 17.1) Correspondence RS-12-161, Report 12Q0108.20-R-001, Revision 1, Unit 1 17.2) Correspondence RS-12-161, Report 12Q0108.20-R-002, Revision 1, Unit 2 17.3) Correspondence RS-13-218, Updated Transmittal #1 (Annex A), Unit 1 17.4) Correspondence RS-13-218, Updated Transmittal #1 (Annex A), Unit 2

18) Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR),

Revision 13

19) EPRI Technical Report JR) 1019200, "Seismic Fragility Applications Guide Update,"

December 2009.

20) BVP 800-27, Revision 4, "Seismic Requirements for Deep Well Pumps"

21) Byron ESEP Reports 21.1) 14Q4240-RPT-003, Revision 3, Validation of Expedited Seismic Equipment List 21.2) 14Q4240-RPT-005, Revision 1, Byron ESEP SEWS

22) DC-ST-04-BB, Revision 2, "Development of Seismic Subsystem (Or Equipment) Design Criteria (Horizontal and Vertical Earthquake) and Response Spectra" Page 31 of 68

Attachment A Byron Unit 1 ESEL Page 32 of 68

U Equipment Equipment Equipment ID Description Notes W Normal State Desired State 1 1SX04P 113 AF PP ENG DRV CLG WTR PP In Service In Service 2 1SX01K 1B AF PP ENG CLSD CYCLE HX In Service In Service Passive Component 1B AF PP RHT ANGLE GEAR LUBE OIL 3 1SX02K In Service In Service Passive Component CLR 4 1AF01AB 113 DSL DRV AF PP OIL CLR In Service In Service Passive Component 5 1AF02A 1B DSL DRV AF PP GEAR OIL CLR In Service In Service Passive Component 6 1VA08S 1B DSL DRV AF PP CUB CLR In Service In Service Passive Component 13 1AF017B MOV 1B AF PP SX SUCT UPST ISOL VLV Closed Open 14 1AF006B MOV 16 AF PP SX SUCT DWST ISOL VLV Closed Open 15 OCC01A Unit 0 CC Heat Exchanger In Service In Service Passive Component (Common to Both Units) 16 1CC01A Unit 1 CC Heat Exchanger In Service In Service Passive Component 18 1AF01PB 113 AF DSL Pump Assembly Stand By In Service Diesel Engine and Pump on a single skid 19 1AF01J 113 DSL DRV AF PP STARTUP CONT PNL In Service In Service 1B DSL DRV AF PP EMERGENCY 20 1AF03J Normal Normal Control Panel STARTUP CONT PNL AOV Manual operation only Control via 21 1AF005E AOV 1B AF PP DSCH TO 1A S/G FCV Open Throttled Hand wheel after Air fails AOV Manual operation only Control via 22 1AF005F AOV 1B AF PP DSCH TO 1B S/G FCV Open Throttled Hand wheel after Air fails AOV Manual operation only Control via 23 1AF005G AOV 113 AF PP DSCH TO 1C S/G FCV Open Throttled Hand wheel after Air fails AOV Manual operation only Control via 24 1AF005H AOV 1B AF PP DSCH TO 1D S/G FCV Open Throttled Hand wheel after Air fails Panel containing separately powered and 25 1PL84JB Local Instrument Panel In Service In Service separately listed instrumentation transmitters Page 33 of 68

Equipment Equipment E Equipment ID Description Notes

~. Normal State Desired State PANEL CONT MAIN BOARD ENG SAFETY 27 1PM06J In Service In Service Control Panel 0-3378 MCR Panel containing separately powered and 41 1PL85JB Local Instrument Panel In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 43 1PL79JB 1A SAFETY VLV RM LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 44 1PL77JC 1B SAFETY VLV RM LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 49 1PL69J RX1 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 50 1PL75J RX1 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters PANEL CONT MAIN BOARD 51 1PM04J In Service In Service Control Panel FEEDWATER 0-3378 MCR 52 1MS018A 1A SG PORV Closed Throttled Valve 53 1MS018A-HFK 1A S/G MS PORV HANDPUMP Stand By In Service Hand pump 54 1MS018B 113 SG PORV Closed Throttled Valve 55 1MS018B-HFK 113 S/G MS PORV HANDPUMP Stand By In Service Hand pump Valve Includes manual hand pump and 56 1MS018C 1C SG PORV Closed Throttled controls 57 1MS018C-HFK 1C S/G MS PORV HANDPUMP Stand By In Service Hand Pump and indications Page 34 of 68

U Equipment Equipment j Equipment ID Description Notes E Normal State Desired State

=

58 lMS018JCE-BAT 1C MS PORV Controller Battery Bank Energized Energized Valve 59 lMS018JCE 1C PORV CONTROLLER UPS In Service In Service UPS 60 lMS018JC 1C MS PORV Control Panel In Service In Service Control Panel Valve Includes manual hand pump and 61 1MS018D 1D SG PORV Closed Throttled controls 62 1MS018D-HFK 1D S/G MS PORV HANDPUMP Stand By In Service Hand Pump and indications 63 lMS018JD 1D MS PORV Control Panel In Service In Service Control Panel Battery is not recharged during the FLEX 64 lMS018JDE-BAT 1D MS PORV Controller Battery Bank Energized Energized

Response

65 lMS018JDE 1D PORV CONTROLLER UPS In Service In Service UPS 66 1RY456 U1 PZR PORV Closed Closed Valve 67 1RY32MB 1B PZR PORV Accumulator In Service In Service Passive Component 68 1DC11J 125V DC ESF 12 Fuse Panel Energized Energized Panel Pump common to both units, circuit breaker 86 OWW0IPA PUMP DEEP WELL M-83 M-3 GL In Service In Service controlled manually per OBFSG-5 Air Operated Valve (common to both units)

AOV OB DEEP WELL PP OWW01PB TO 87 OWW019A Throttled Throttled will be manually operated per procedure OA SXCT LCV OBFSG-5 88 1AP99E Bus 131Z Energized Energized 480VAC Bus 89 1LT-0933 REF WTR STG TK LVL D/P XMTTR In Service In Service Instrument 91 1S101T U-1 RWST In Service In Service Passive Component 93 1DO01TB 113 DO STO TK, 25,000 GAL In Service In Service Passive Component 94 1DO01TD 1D DO STO TK, 25,000 GAL In Service In Service Passive Component 95 1DO01PB 1B DG 1B FO XFER PP In Service In Service Pump 96 1PL08J ASSY - 1B DG 1DG01KB CONT PNL In Service In Service Control Panel Page 35 of 68

M Equipment Equipment E Equipment ID Description Notes 1W Normal State Desired State 97 1DO10T 113 AF DO DAY TK, 500 GAL In Service In Service Passive Component 98 1LI-DO032 113 AF DO Day Tank Level Site Glass In Service In Service Passive Component 99 1AP27E MCC 132X2 Energized Energized MCC 106 1SI8808A A SI Accum Isolation Valve Open Closed Valve 108 1S18808B B Sl Accum Isolation Valve Open Closed Valve 109 1AP27E-A MCC 132X2A Energized Energized MCC 110 1SI8808C C SI Accum Isolation Valve Open Closed Valve 111 IS18808D D SI Accum Isolation Valve Open Closed Valve Panel containing separately powered and 112 1PL61JA RX1 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 113 1PL60JB RX1 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 114 1PL61JC RX1 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 115 1PL60JD RX1 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Instrument Rack containing separately 116 1PA06J U-1 PROC I&C RACK CONT GRP 2 CAB 6 In Service In Service powered and separately listed instrumentation transmitters Instrument Rack containing separately 117 1PA08J U-1 PROC I&C RACK In Service In Service powered and separately listed instrumentation transmitters Page 36 of 68

U Equipment Equipment Equipment ID Description Notes E Normal State Desired State 130 1PIS-403 W-RNG LP 1A HOT LEG ISOLATOR In Service In Service Instrument Instrument Rack containing separately 131 1PA04J U-1 PROC I&C RACK PROTECT CH 4 In Service In Service powered and separately listed instrumentation transmitters PANEL CONT MAIN BOARD RX/CV 0-132 1PM05J In Service In Service Control Panel 3378 MCR Instrument Rack containing separately 133 1PA02J U-1 PROC I&C RACK PROTECT CH 2 In Service In Service powered and separately listed instrumentation transmitters Panel containing separately powered and CAB HJTC RX VESSEL LEVEL CH B 0-134 1PA52J In Service In Service separately listed instrumentation 33716 transmitters CNMT PRESSURE CHANNEL B PRESSURE 135 1PI-PC005 In Service In Service Instrument INDICATOR CNMT PRESSURE CHANNEL B PRESSURE 136 1PT-PC005 In Service In Service Instrument TRANSMITTER Panel containing separately powered and 137 1PA34J CAB CONT SYSTEM ESF 12 0-3371B In Service In Service separately listed instrumentation transmitters 146 1NR13EB Wide Range Amp In Service In Service Instrument 147 1NR13EC Signal Processor In Service In Service Instrument 148 1NR13ED Optical Signal Isolator In Service In Service Instrument Control Panel (Common to Both Units) 149 OPM02J MCR at Center Desk In Service In Service containing separately powered and separately listed instrument indicators Page 37 of 68

U Equipment Equipment Equipment ID Description Notes W

41 Normal State Desired State Panel containing separately powered and 150 1PM07J U1 NI panels In Service In Service separately listed instrumentation transmitters 156 1AP12E Bus 132X Energized Energized 480VAC Bus 157 1DCO2E 125V DC Battery 112 Energized Energized Battery 158 1DC04E 125V DC BATT CHGR 112 Energized Energized Battery Charger 159 11P06E 112 Inverter Energized Energized Inverter 160 11P08E 114 Inverter Energized Energized Inverter 161 11P02J Instrument Bus 112 Energized Energized 120VAC Bus 162 11 PO4 Instrument Bus 114 Energized Energized 120VAC Bus 170 1AF01EA-A 1B DSL DRV AF PP BANK A BATT A Energized Energized Battery 171 1AF01EA-B 1B DSL DRV AF PP BANK A BATT B Energized Energized Battery 172 1AF01EB-1 1B DSL DRV AF PP 1B BATT CHGR Energized Energized Battery Charger 173 1AF01EA-1 1B DSL DRV AF PP 1A BATT CHGR Energized Energized Battery Charger 174 1AP24E MCC 132X3 Energized Energized MCC 175 1AP23E MCC132X1 Energized Energized MCC 182 1VE02C BATT RM-112 EXH FAN In Service In Service Fan 184 1AP28E MCC 132X4 Energized Energized MCC 186 1AP32E MCC 132X5 Energized Energized MCC 190 1RH02AA-1A RHR HX 1A Available Available Passive Component 191 1RH02AB-1B RHR HX 1B Available Available Passive Component 192 1SX01FB-2 SX Strainer Available Available Passive Component 193 OVA413Y Fire Damper In Service In Service Damper 194 K7 @ 1AF01J OVERCRANK RELAY In Service In Service Relay 195 K4 @ 1AF01J OVERCRANK TIMER RELAY In Service In Service Relay Page 38 of 68

U Equipment Equipment Equipment ID Notes

..,E Description Normal State Desired State 196 S1 @ 1AF01J Speed Switch 1SS-AF8002 In Service In Service Relay 197 K9 @ 1AF01J OVERSPEED RELAY In Service In Service Relay 198 1PSL-AF143 LUBE OIL PRESSURE In Service In Service Pressure Switch 199 K10 @ 1AF01J LOW LUBE Oil PRESSURE RELAY In Service In Service Relay 200 K8 @ 1AF01J HIGH WATER TEMPERATURE RELAY In Service In Service Relay 201 1PSL-AF055 LOW SUCTION PRESSURE In Service In Service Relay 202 K12 @ 1AF01J ENGINE FAILURE LOCKOUT RELAY In Service In Service Relay 203 1DC04E-K1-1 OVERVOLTAGE RELAY In Service In Service Relay 204 1DC04E-K1-2 OVERVOLTAGE RELAY In Service In Service Relay 205 1PM01J PANEL CONT MAIN BOARD MCR In Service In Service Panel with bus voltage indicators 206 1VE01J CONTROL PANEL In Service In Service Control Panel Page 39 of 68

Attachment B Byron Unit 2 ESEL Page 40 of 68

Equipment Equipment E Equipment ID Description Notes

.r Normal State Desired State 7 2SX04P 2B AF PP ENG DRV CLG WTR PP In Service In Service 8 2SX01K 2B AF PP ENG CLSD CYCLE HX In Service In Service Passive Component 2B AF PP RHT ANGLE GEAR LUBE OIL 9 2SX02K In Service In Service Passive Component CLR 10 2AF01AB 2B DSL DRV AF PP OIL CLR In Service In Service Passive Component 11 2AF02A 2B DSL DRV AF PP GEAR OIL CLR In Service In Service Passive Component 12 2VA08S 2B DSL DRV AF PP CUB CLR In Service In Service Passive Component 17 2CC01A Unit 2 CC Heat Exchanger In Service In Service Passive Component 28 2AF017B MOV 2B AF PP SX SUCT UPST ISOL VLV Closed Open MOV 29 2AF006B MOV 2B AF PP SX SUCT DWST ISOL VLV Closed Open MOV 30 2AF01PB 2B AF DSL Pump Assembly Stand By In Service Diesel Engine and Pump on a single skid 31 2AF01J 2B DSL DRV AF PP STARTUP CONT PNL In Service In Service 32 2AF03J AF PUMP 2B EMERGENCY CONT PNL Normal Normal Control Panel AOV Manual operation only Control via 33 2AF005E AOV 2B AF PP DSCH TO 2A S/G FCV Open Throttled Hand wheel after Air fails AOV Manual operation only Control via 34 2AF005F AOV 2B AF PP DSCH TO 2B S/G FCV Open Throttled Hand wheel after Air fails AOV Manual operation only Control via 35 2AF005G AOV 2B AF PP DSCH TO 2C S/G FCV Open Throttled Hand wheel after Air fails AOV Manual operation only Control via 36 2AF005H AOV 2B AF PP DSCH TO 21) S/G FCV Open Throttled Hand wheel after Air fails Panel containing separately powered and 37 2PL84JB Local Instrument Panel In Service In Service separately listed instrumentation transmitters Page 41 of 68

Equipment Equipment Equipment ID Description Notes

` W Normal State Desired State PANEL CONT MAIN BOARD ENG 39 2PM061 In Service In Service Control Panel SAFETY 0-3378 MCR Panel containing separately powered and 40 2PL85JB Local Instrument Panel In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 42 2PL69J RX2 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 45 2PL79JB 2A SAFETY VLV RM LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 46 2PL77JC 213 SAFETY VLV RM LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 47 2PL75J RX2 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters PANEL CONT MAIN BOARD 48 2PM04J In Service In Service Control Panel FEEDWATER 0-3378 MCR Valve Includes manual hand pump and 69 2MS018A 2A SG PORV Closed Throttled controls 70 2MS018A-HFK 2A S/G MS PORV HANDPUMP Stand By In Service Hand Pump and indications Valve Includes manual hand pump and 71 2MS018B 2B SG PORV Closed Throttled controls 72 2MS018B-HFK 2B S/G MS PORV HANDPUMP Stand By In Service Hand Pump and indications Valve Includes manual hand pump and 73 2MS018C 2C SG PORV Closed Throttled controls Page 42 of 68

4 Equipment Equipment Equipment ID Description I Notes E Normal State Desired State 74 2MS018C-HFK 2C S/G MS PORV HANDPUMP Stand By In Service Hand Pump and indications 75 2MS018JC 2C MS PORV Control Panel In Service In Service Control Panel 76 2MS018JCE 2C PORV CONTROLLER UPS Energized Energized UPS 77 2MS018JCE-BAT 2C PORV CONTROLLER BATTERY BANK Energized Energized Battery Valve Includes manual hand pump and 78 2MS018D 2D SG PORV Closed Throttled controls 79 2MS018D-HFK 2D S/G MS PORV HANDPUMP Stand By In Service Hand Pump and indications 80 2MS018JD 2D MS PORV Control Panel In Service In Service Control Panel 81 2MS018JDE 2D PORV CONTROLLER UPS Energized Energized UPS Battery is not recharged during the FLEX 82 2MS018JDE-BAT 2D PORV CONTROLLER BATTERY BANK Energized Energized

Response

83 2RY456 U2 PZR PORV Closed Closed Valve 84 2RY32MB 2B PZR PORV Accumulator In Service In Service Passive Component 85 2DC11J 125V DC FUSE PNL ESF 22 Energized Energized Panel 90 2LT-0933 REF WTR STG TK LVL D/P XMTTR In Service In Service Instrument 92 2S101T U-2 RWST In Service In Service Passive Component 100 2DO01TB 2B DO STO TK, 50,000 GAL In Service In Service Passive Component 101 2DO01PB 2B DG 213 FO XFER PP In Service In Service Pump 102 2PL08J 2B DG control panel In Service In Service Control Panel 103 2DO10T U-2 B AF DO Day Tank In Service In Service Passive Component 104 2LI-DO032 2B AF DO Day Tank Level Site Glass In Service In Service Passive Component 105 2AP27E MCC 232X2 Energized Energized MCC 118 2SI8808A A SI Accum Isolation Valve Open Closed Valve 120 2SI8808B B SI Accum Isolation Valve Open Closed Valve 121 2AP27E-A MCC232X2A Energized Energized MCC Page 43 of 68

4 Equipment Equipment Equipment ID Description Notes E

,.. Normal State Desired State 122 2SI8808C C SI Accum Isolation Valve Open Closed Valve 123 2SI8808D D SI Accum Isolation Valve Open Closed Valve Panel containing separately powered and 124 2PL61JA RX2 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 125 2PL60JB RX2 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 126 2PL61JC RX2 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Panel containing separately powered and 127 2PL60JD RX2 CNMT LOC INST PNL In Service In Service separately listed instrumentation transmitters Instrument Rack containing separately 128 2PA06J U-2 PROC I&C RACK CONT GRP 2 In Service In Service powered and separately listed instrumentation transmitters Instrument Rack containing separately 129 2PA08J U-2 PROC I&C RACK In Service In Service powered and separately listed instrumentation transmitters 138 2PIS-403 W-RNG LP 2A HOT LEG ISOLATOR In Service In Service Instrument Instrument Rack containing separately 139 2PA04J U-2 PROC I&C RACK PROTECT CH 4 In Service In Service powered and separately listed instrumentation transmitters PANEL CONT MAIN BOARD RX/CV 0-140 2PMOSJ In Service In Service Control Panel 3378 MCR Page 44 of 68

~* Equipment Equipment E Equipment ID Description Notes 1 Normal State Desired State Instrument Rack containing separately 141 2PA02J U-2 PROC I&C RACK PROTECT CH 2 In Service In Service powered and separately listed instrumentation transmitters Panel containing separately powered and CAB HJTC RX VESSEL LEVEL CH B 0-142 2PA52J In Service In Service separately listed instrumentation 33716 transmitters CNMT PRESSURE CHANNEL B 143 2P1-PCO05 In Service In Service Instrument PRESSURE INDICATOR Panel containing separately powered and 144 2PA34J CAB CONT SYSTEM ESF 12 0-3371B In Service In Service separately listed instrumentation transmitters CNMT PRESSURE CHANNEL B 145 2PT-PCO05 In Service In Service Instrument PRESSURE TRANSMITTER 151 2NR13EB JUNCT BOX NTRN DET 90 AMP 2NR257 In Service In Service Instrument JUNCT BOX NTRN DET 90 PROC 152 2NR13EC In Service In Service Instrument 2N R248 Panel containing separately powered and 154 2PM07J U2 NI panels In Service In Service separately listed instrumentation transmitters NEUTRON MONITOR OPTICAL 155 2NR13ED In Service In Service Instrument ISOLATOR, CHANNEL 2 163 2AP12E Bus 232X Energized Energized 480VAC Bus 164 2DCO2E 125V DC Battery 212 Energized Energized Battery 165 2DC04E 125V DC BATT CHGR 212 Energized Energized Battery Charger 166 21P06E 212 Inverter Energized Energized Inverter 167 21P08E 214 Inverter Energized Energized Inverter Page 45 of 68

I

'x Equipment Equipment Equipment ID Description Notes EW 41, Normal State Desired State 168 21 P02 Instrument Bus 212 Energized Energized 120VAC Bus 169 21 PO4 Instrument Bus 214 Energized Energized 120VAC Bus 176 2AF01EA-A 2B DSL DRV AF PP BANK A BATT A In Service In Service Battery 177 2AF01EA-B 2B DSL DRV AF PP BANK A BATT B In Service In Service Battery 178 2AF01EB-1 2B DSL DRV AF PP 1B BATT CHGR In Service In Service Battery Charger 179 2AF01EA-1 2B DSL DRV AF PP 1A BATT CHGR In Service In Service Battery Charger 180 2AP24E MCC 232X3 Energized Energized MCC 181 2AP23E MCC 232X1 Energized Energized MCC 183 2VE02C BATT RM-212 EXH FAN In Service In Service Fan 185 2AP28E MCC 232X4 Energized Energized MCC 187 2AP32E MCC 232X5 Energized Energized MCC 207 2RH02AA-2A RHR HX 2A N/A N/A Passive Component 208 2RH02AB-2B RHR HX 2B N/A N/A Passive Component 209 2SX01FB-2 SX Strainer N/A N/A Passive Component 210 K7 @ 2AF01J OVERCRANK RELAY In Service In Service Relay 211 K4 @ 2AF01J OVERCRANK TIMER RELAY In Service In Service Relay 212 S1 @ 2AF01J Speed Switch 1SS-AF8002 In Service In Service Relay 213 K9 @ 2AF01J OVERSPEED RELAY In Service In Service Relay 214 2PSL-AF143 LUBE OIL PRESSURE In Service In Service Pressure Switch 215 K10 @ 2AF01J LOW LUBE OIE PRESSURE RELAY In Service In Service Relay 216 K8 @ 2AF01J HIGH WATER TEMPERATURE RELAY In Service In Service Relay 217 2PSL-AF055 LOW SUCTION PRESSURE In Service In Service Relay 218 K12 @ 2AF011 ENGINE FAILURE LOCKOUT RELAY In Service In Service Relay 219 2DC04E-K1-1 OVERVOLTAGE RELAY In Service In Service Relay 220 2DC04E-K1-2 OVERVOLTAGE In Service In Service Relay Page 46 of 68

U Equipment Equipment Equipment ID Description Notes E

40 Normal State Desired State 221 2PM01J PANEL CONT MAIN BOARD MCR In Service In Service Panel with bus voltage indicators 222 2VE01J CONTROL PANEL In Service In Service Control Panel Page 47 of 68

Attachment C ESEP HCLPF Values and Failure Modes Tabulation, Unit 1 Page 48 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number ID Equipment Component evaluated in Calculation 14Q4240-15 OCC01A 0.33g Capacity CAL-002 Component evaluated in Calculation 14Q4240-CAL-002 Control room ceiling seismic interaction 149 OPM02J Anchorage 0.24g HCLPF determined > 0.24g in Calculation 14Q4240-CAL-002 Block wall seismic interaction HCLPF determined 193 OVA413Y Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g 87 OWWO19A Screened > 0.24g Equipment Component evaluated in Calculation 14Q4240-86 OWW0IPA 0.24g capacity CAL-002 Block wall seismic interaction HCLPF determined 21 1AF005E Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g Block wall seismic interaction HCLPF determined 22 1AF005F Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g Block wall seismic interaction HCLPF determined 23 1AF005G Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 24 1AF005H Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g Block wall seismic interaction HCLPF determined 14 1AF006B Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g Block wall seismic interaction HCLPF determined 13 1AF017B Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g Block wall seismic interaction HCLPF determined 4 1AF01AB Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g Page 49 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number ID Anchorage Screened by large available margin in existing design basis calculation. Block wall 173 1AF01EA-1 Screened > 0.24g seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Anchorage Screened by large available margin in existing design basis calculation. Block wall 170 1AF01EA-A Screened > 0.24g seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Equipment CAL-002 171 1AF01EA-B 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Anchorage Screened by large available margin in existing design basis calculation. Block wall 172 1AF01EB-1 Screened > 0.24g seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 19 1AF01J Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-K10 @

199 Functional 0.38g CAL-005 1AF01J Host component is 1AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-K12 @ Functional 202 0.38g CAL-005 1AF01J Host component is 1AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-195 K4 @ Functional 0.54g CAL-005 1AF01J Host component is 1AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-194 K7 @ Functional 0.38g CAL-005 1AF01J Host component is 1AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-200 K8 @ Functional 0.38g CAL-005 1AF01J Host component is 1AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-197 K9 @ Functional 0.38g CAL-005 1AF01J Host component is 1AF01J with HCLPF = 0.24g Page 50 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number ID S1 @

Component evaluated in Calculation 14Q4240-1AF01J Functional 0.25g 196 CAL-005 (1SS-Host component is 1AF01J with HCLPF = 0.24g AF8002)

Anchorage Screened by large available margin in existing design basis calculation. Block wall 18 1AF01PB Screened > 0.24g seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 5 1AF02A Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-20 1AF03J Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-CAL-002 156 1AP12E Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 175 1AP23E Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-174 1AP24E Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-99 1AP27E Anchorage 0.24g CAL-002 109 1AP27E-A Anchorage 0.24g See 1AP27E Component evaluated in Calculation 14Q4240-184 1AP28E Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-CAL-002 186 1AP32E Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Page 51 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number p ID Component evaluated in Calculation 14Q4240-88 1AP99E Anchorage 0.248 CAL-002 Equipment Component evaluated in Calculation 14Q4240-16 1CC01A 0.338 Capacity CAL-002 Component evaluated in Calculation 14Q4240-Equipment CAL-002 157 1DCO2E 0.248 Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Anchorage /

CAL-002 158 lDC04E Equipment 0.24g Block wall seismic interaction HCLPF determined Capacity in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-K1-1 @

203 Functional 0.31g CAL-005 1DC04E Host component is 1DC04E with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-K1-2 @

204 Functional 0.31g CAL-005 1 DC04E Host component is 1DC04E with HCLPF = 0.24g Anchorage /

Component evaluated in Calculation 14Q4240-68 1DC11J Equipment 0.24g CAL-002 Capacity Component evaluated in Calculation 14Q4240-95 1DO01PB Anchorage 0.24g CAL-002 Anchorage /

Component evaluated in Calculation 14Q4240-93 1DO01TB Equipment 0.24g CAL-004 Capacity Anchorage /

Component evaluated in Calculation 14Q4240-94 1DO01TD Equipment 0.24g CAL-004 Capacity Equipment Component evaluated in Calculation 14Q4240-97 1DO10T 0.31g Capacity CAL-002 Component evaluated in Calculation 14Q4240-Equipment CAL-002 161 11 P02J 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Page 52 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number ID Component evaluated in Calculation 14Q4240-Equipment CAL-002 162 11 PO4J 0.248 Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Equipment CAL-002 159 11 P06E 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Equipment CAL-002 160 11 P08E 0.248 Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Anchorage Screened by SRT judgment. Block 98 1LI-DO032 Screened > 0.24g wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

89 1LT-0933 Screened > 0.24g Anchorage Screened by SRT judgment.

Equipment Component evaluated in Calculation 14Q4240-52 1MS018A 0.24g Capacity CAL-002 1MS8A-01 53 Screened > 0.24g Anchorage Screened by SRT judgment.

S01 HFK Equipment Component evaluated in Calculation 14Q4240-54 1MS018B 0.24g capacity CAL-002 1MS018B-55 Screened > 0.24g Anchorage Screened by SRT judgment.

HFK Equipment Component evaluated in Calculation 14Q4240-56 1MS018C 0.24g Capacity CAL-002 1MS018C-Screened > 0.24g Anchorage Screened by SRT judgment.

57 HFK Equipment Component evaluated in Calculation 14Q4240-61 1MS018D 0.24g Capacity CAL-002 Page 53 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number ID 1MS8D-01 62 Screened > 0.24g Anchorage Screened by SRT judgment.

S01 HFK Component evaluated in Calculation 14Q4240-60 1MS018JC Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-CAL-002 59 lMS018JCE Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 lMS018JCE 58 Anchorage 0.24g Chain link fence seismic interaction HCLPF

-BAT determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 63 1MS018JD Anchorage 0.248 Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

1MS018JD Component evaluated in Calculation 14Q4240-65 Anchorage 0.24g E CAL-002 Component evaluated in Calculation 14Q4240-1 MS018J D CAL-002 64 Anchorage 0.24g E-BAT Chain link fence seismic interaction HCLPF determined > 0.24g.

146 1NR13EB Screened > 0.24g Anchorage Screened by SRT judgment.

147 1NR13EC Screened > 0.24g Anchorage Screened by SRT judgment.

148 1NR13ED Screened > 0.24g Anchorage Screened by SRT judgment.

Equipment Component evaluated in Calculation 14Q4240-133 1PA02J 0.24g Capacity CAL-002 Page 54 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number ID Equipment Component evaluated in Calculation 14Q4240-131 1PA04J 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-116 1PA06J 0.24g Capacity CAL-002 Component evaluated in Calculation 14Q4240-Equipment CAL-002 117 1 PA08J 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Equipment Component evaluated in Calculation 14Q4240-137 1PA34J 0.24g Capacity CAL-002 Component evaluated in Calculation 14Q4240-Equipment CAL-002 134 1PA52J 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall and control ceiling seismic interaction 135 1PI-PCO05 Screened > 0.24g HCLPF determined > 0.24g. Anchorage Screened by SRT judgment.

Component evaluated in Calculation 14Q4240-CAL-002 96 1PL08J Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Anchorage Screened by large available margin in 113 1PL60JB Screened > 0.24g existing design basis calculation.

Anchorage Screened by large available margin in 115 1PL60JD Screened > 0.24g existing design basis calculation.

Anchorage Screened by large available margin in 112 1PL61JA Screened > 0.24g existing design basis calculation.

Equipment Component evaluated in Calculation 14Q4240-114 1PL61JC 0.24g Capacity CAL-002 Anchorage Screened by large available margin in 49 1PL69J Screened > 0.24g existing design basis calculation.

Page 55 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number ID Equipment Component evaluated in Calculation 14Q4240-50 1 P L75J 0.24g Capacity CAL-002 Anchorage Screened by large available margin in 44 1PL77JC Screened > 0.24g existing design basis calculation.

Anchorage Screened by large available margin in 43 1PL79JB Screened > 0.24g existing design basis calculation.

Anchorage Screened by large available margin in existing design basis calculation. Block wall 25 1PL84J6 Screened > 0.24g seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Anchorage Screened by large available margin in existing design basis calculation. Block wall 41 1PL85JB Screened > 0.24g seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 205 113M01J Anchorage 0.248 Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 51 1PM04J Anchorage 0.249 Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 132 1PM05J Anchorage 0.249 Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 27 1PM06J Anchorage 0.248 Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 150 1PM07J Anchorage 0.24g Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Page 56 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number ID Component evaluated in Calculation 14Q4240-1PSL-201 Functional 1.47g CAL-005 AF055 Host component is 1PA34J with HCLPF = 0.24g.

Component evaluated in Calculation 14Q4240-1PSL-198 Functional 0.32g CAL-005 AF143 Host component is 1AF01PB with HCLPF = 0.24g.

Equipment Component evaluated in Calculation 14Q4240-136 1PT-PC005 0.24g capacity CAL-002 Component evaluated in Calculation 14Q4240-0.24g CAL-002 190 1RH02AA Anchorage Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-0.24g CAL-002 191 1RH02AB Anchorage Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Equipment Component evaluated in Calculation 14Q4240-67 1RY32MB 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-66 1RY456 0.24g Capacity CAL-002 91 1S101T Screened > 0.24g Anchorage Screened by SRT judgment.

Equipment Component evaluated in Calculation 14Q4240-106 1S18808A 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-108 1S18808B 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-110 1S18808C 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-111 1S18808D 0.24g Capacity CAL-002 Page 57 of 68

ESEL Equipment Failure Mode HCLPF Additional Discussion Number p ID Anchorage Screened by large available margin in 192 1SX01FB Screened > 0.24g existing design basis calculation.

Block wall seismic interaction HCLPF determined 2 1SX01K Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 3 1SX02K Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 1 1SX04P Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 6 1VA08S Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Anchorage /

Component evaluated in Calculation 14Q4240-206 1VE01J Equipment 0.24g CAL-002 Capacity Component evaluated in Calculation 14Q4240-CAL-002 182 1VE02C Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Page 58 of 68

Attachment D ESEP HGLPF Values and Failure Modes Tabulation, Unit 2 Page 59 of 68

ESEL Equipment ID Failure Mode HCLPF Additional discussion Number 33 2AF005E Screened > 0.24g 34 2AF005F Screened > 0.24g 35 2AF005G Screened > 0.24g 36 2AF005H Screened > 0.24g Block wall seismic interaction HCLPF determined 29 2AF006B Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 28 2AF017B Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 10 2AF01AB Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 179 2AF01EA-1 Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Equipment CAL-002 176 2AF01EA-A 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Anchorage Screened by large available margin in existing design basis calculation. Block wall 177 2AF01EA-B Screened > 0.24g seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 178 2AF01EB-1 Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Page 60 of 68

ESEL Equipment ID Failure Mode HCLPF Additional discussion Number Component evaluated in Calculation 14Q4240-CAL-002 31 2AF01J Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-0.51g 215 K10 @ 2AF01J Functional CAL-005 Host component is 2AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-Functional 0.51g CAL-005 218 K12 @ 2AF01J Host component is 2AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-Functional 0.54g CAL-005 211 K4 @ 2AF01J Host component is 2AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-Functional 0.51g CAL-005 210 K7 @ 2AF01J Host component is 2AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-Functional 0.51g CAL-005 216 K8 @ 2AF01J Host component is 2AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-Functional 0.51g CAL-005 213 K9 @ 2AF01J Host component is 2AF01J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-S1 @ 2AF01J Functional 0.27g CAL-005 212 (2SS-AF8002) Host component is 2AF01J with HCLPF = 0.24g Anchorage Screened by large available margin in existing design basis calculation. Block wall 30 2AF01PB Screened > 0.24g seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 11 2AF02A Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-32 2AF03J Anchorage 0.24g CAL-002 Page 61 of 68

ESEL Equipment ID Failure Mode HCLPF Additional discussion Number Component evaluated in Calculation 14Q4240-CAL-002 163 2AP12E Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 181 2AP23E Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-180 2AP24E Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-CAL-002 105 2AP27E Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

See 2AP27E.

121 2AP27E-A Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-185 2AP28E Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-187 2AP32E Anchorage 0.24g CAL-002 Equipment Component evaluated in Calculation 14Q4240-17 2CC01A 0.33g Capacity CAL-002 Component evaluated in Calculation 14Q4240-Equipment CAL-002 164 2 DCO2 E 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Anchorage /

CAL-002 165 2DC04E Equipment 0.24g Block wall seismic interaction HCLPF determined Capacity in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-K1-1 @

219 Functional 0.31g CAL-005 2DC04E Host component is 2DC04E with HCLPF = 0.24g Page 62 of 68

ESEL Equipment ID Failure Mode HCLPF Additional discussion Number Component evaluated in Calculation 14Q4240-K1-2 @

220 Functional 0.318 CAL-005 2DC04E Host component is 2DC04E with HCLPF = 0.24g Anchorage /

Component evaluated in Calculation 14Q4240-85 2DC11J Equipment 0.24g CAL-002 Capacity Component evaluated in Calculation 14Q4240-101 2DO01PB Anchorage 0.24g CAL-002 Anchorage /

Component evaluated in Calculation 14Q4240-100 2DO01TB Equipment 0.248 CAL-004 Capacity Component evaluated in Calculation 14Q4240-Equipment CAL-002 103 2DO10T 0.318 Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Equipment CAL-002 168 21 P02J 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Equipment CAL-002 169 21 PO4J 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Equipment CAL-002 166 21 P06 E 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-Equipment CAL-002 167 21P08E 0.24g Capacity Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

104 2LI-DO032 Screened > 0.24g Anchorage screened by SRT judgment.

90 2LT-0933 Screened > 0.24g Anchorage screened by SRT judgment.

Page 63 of 68

ESEL Equipment ID Failure Mode HCLPF Additional discussion Number Equipment Component evaluated in Calculation 14Q4240-69 2MS018A 0.24g Capacity CAL-002 70 2MS018A-HFK Screened > 0.24g Anchorage screened by SRT judgment.

Equipment Component evaluated in Calculation 14Q4240-71 2MS018B 0.24g Capacity CAL-002 72 2MS018B-HFK Screened > 0.24g Anchorage screened by SRT judgment.

Equipment Component evaluated in Calculation 14Q4240-73 2MS018C 0.24g Capacity CAL-002 74 2MS018C-HFK Screened > 0.24g Anchorage screened by SRT judgment.

Equipment Component evaluated in Calculation 14Q4240-78 2MS018D 0.24g Capacity CAL-002 79 2MS018D-HFK Screened > 0.24g Anchorage screened by SRT judgment.

Component evaluated in Calculation 14Q4240-CAL-002 75 2MS018JC Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-76 2MS018JCE Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-2 MS018JCE- CAL-002 77 Anchorage 0.24g BAT Chain link fence seismic interaction HCLPF >

0.248.

Component evaluated in Calculation 14Q4240-80 2MS018JD Anchorage 0.24g CAL-002 Block wall seismic interaction HCLPF > 0.24g.

Page 64 of 68

ESEL Equipment ID Failure Mode HCLPF Additional discussion Number Component evaluated in Calculation 14Q4240-81 2MS018JDE Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-2 MS018J D E- CAL-002 82 Anchorage 0.24g BAT Chain link fence seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-151 2NR13EB Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-152 2NR13EC Anchorage 0.24g CAL-002 Component evaluated in Calculation 14Q4240-155 2NR13ED Anchorage 0.24g CAL-002 Equipment Component evaluated in Calculation 14Q4240-141 2 PA02J 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-139 2PA04J 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-128 2PA06J 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-129 2PA08J 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-144 2 PA34J 0.24g Capacity CAL-002 Equipment Component evaluated in Calculation 14Q4240-142 2PA52J 0.24g Capacity CAL-002 Block wall and Control room ceiling seismic 143 2PI-PCO05 Screened > 0.24g interaction HCLPF determined > 0.24g.

Anchorage Screened by SRT judgment.

Component evaluated in Calculation 14Q4240-102 2PL08J Anchorage 0.24g CAL-002 Page 65 of 68

ESEL Equipment ID Failure Mode HCLPF Additional discussion Number 125 2PL60JB Screened >0.24g Component acceptable compared to 1PL60JB 127 2PL60JD Screened >0.24g Component acceptable compared to 1PL60JD 124 2PL61JA Screened >0.24g Component acceptable compared to 1PL61JA Component acceptable compared to 1PL61JC Equipment 126 2PL61JC 0.24g (1PL61JC evaluated in Calculation 14Q4240-CAL-Capacity 002) 42 2PL69J Screened >0.24g Component acceptable compared to 1PL69J Component acceptable compared to 1PL75J Equipment 47 2PL75J 0.24 (1PL75J evaluated in Calculation 14Q4240-CAL-Capacity 002)

Anchorage screened by large available margin in 46 2PL77JC Screened > 0.24g existing design basis calculations.

Anchorage screened by large available margin in 45 2PL79JB Screened > 0.24g existing design basis calculations.

Anchorage screened by large available margin in 37 2PL84JB Screened > 0.24g existing design basis calculations.

Anchorage screened by large available margin in 40 2PL85JB Screened > 0.24g existing design basis calculation. Block wall seismic interaction HCLPF > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 221 2PM01J Anchorage 0.24g Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 48 2PM04J Anchorage 0.24g Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

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ESEL Equipment ID Failure Mode HCLPF Additional discussion Number Component evaluated in Calculation 14Q4240-CAL-002 140 2PM05J Anchorage 0.248 Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 39 2PM06J Anchorage 0.248 Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 154 2PM07J Anchorage 0.248 Block wall and control room ceiling seismic interaction HCLPF determined > 0.24g.

Component evaluated in Calculation 14Q4240-217 2PSL-AF055 Functional 1.478 CAL-005 Host component is 2PA34J with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-214 2PSL-AF143 Functional 0.32g CAL-005 Host component is 2AF01PB with HCLPF = 0.24g Component evaluated in Calculation 14Q4240-Equipment 145 2PT-PCO05 0.24g CAL-002 Capacity Anchorage screened by SRT judgment.

Component evaluated in Calculation 14Q4240-CAL-002 207 2RH02AA Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 208 2RH02AB Anchorage 0.248 Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

84 2RY32MB Screened 0.248 Component acceptable compared to 1RY32MB Component acceptable compared to 1RY456 Equipment 83 2RY456 0.24g (1RY456 evaluated in Calculation 14Q4240-CAL-Capacity 002) 92 2S101T Screened > 0.24g Anchorage screened by SRT judgment.

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ESEL Equipment ID Failure Mode HCLPF Additional discussion Number Component acceptable compared to 1SI8808A Equipment 118 2SI8808A 0.24 (1S19908A evaluated in Calculation 14Q4240-Capacity CAL-002)

Component acceptable compared to 1S18808B Equipment 120 2SI8808B 0.24 (1S19908B evaluated in Calculation 14Q4240-Capacity CAL-002)

Component acceptable compared to 1SI8808C Equipment 122 2SI8808C 0.24 (1S19908C evaluated in Calculation 14Q4240-Capacity CAL-002)

Component acceptable compared to 1SI8808D Equipment 123 2SI8808D 0.24 (1S199081) evaluated in Calculation 14Q4240-Capacity CAL-002)

Anchorage screened by large available margin in 209 2SX01FB Screened > 0.24g existing design basis calculation.

Block wall seismic interaction HCLPF determined 8 2SX01K Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 9 2SX02K Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Block wall seismic interaction HCLPF determined 7 2SX04P Screened > 0.24g in Calculation 14Q4240-CAL-002 to be > 0.24g.

Component evaluated in Calculation 14Q4240-CAL-002 12 2VA08S Anchorage 0.248 Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

Anchorage /

Component evaluated in Calculation 14Q4240-222 2VE01J Equipment 0.248 CAL-002 Capacity Component evaluated in Calculation 14Q4240-CAL-002 183 2VE02C Anchorage 0.24g Block wall seismic interaction HCLPF determined in Calculation 14Q4240-CAL-002 to be > 0.24g.

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