Text

Revision to Technical Specification 3.6.3, Containment Isolation Valves
	ML042160031
Person / Time
Site:	Wolf Creek
Issue date:	07/23/2004
From:	Jacobs D; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	WO 04-0030
	Download: ML042160031 (109)
	v • d • e

WI~LF CREEK 'NUCLEAR OPERATING CORPORATION Donna Jacobs Vice President Operations and Plant Manager

-JUL 232004 WO 04-0030 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

1) Letter ET 02-0030, dated August 16, 2002, from G. B. Fader, WCNOC, to USNRC

2) Letter WM 04-0016, dated June 4, 2004, from R. A. Muench, WCNOC, to USNRC

Subject:

Docket No. 50-482: Revision to Technical Specification 3.6.3, "Containment Isolation Valves" Gentlemen:

Wolf Creek Nuclear Operating Corporation (WCNOC) herewith transmits an application for amendment to Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS).

This amendment application would revise Technical Specification (TS) 3.6.3, "Containment Isolation Valves," to extend the Completion Times for an inoperable containment isolation valve.

The proposed changes are based on WCAP-15791-P, Revision 1,"Risk-Informed Evaluation of Extensions to Containment Isolation Valve Completion Times." WCNOC is the Westinghouse Owners Group lead plant for this risk-informed program. WCAP-15791-P, Revision 1, was submitted to the NRC by letter WOG-04-0234, dated May 6, 2004. Reference 1 submitted an amendment application to revise TS 3.6.3 based on WCAP-15791-P, Revision 0. As discussed in Reference 2, WCNOC withdrew the amendment application provided by Reference 1 due to the NRC schedule for reviewing WCAP-15791-P.

The WCNOC Plant Safety Review Committee and the Nuclear Safety Review Committee have reviewed this amendment application. Attachments I through VI provide the required Affidavit, Evaluation, Markup of Technical Specifications, Retyped Technical Specifications, Proposed Technical Specification Bases Changes, and List of Commitments, respectively, in support of this amendment request. Attachment V is provided for Information only. Final Bases changes will be implemented pursuant to TS 5.5.14, "Technical Specifications (TS) Bases Control Program.'

P.O. Box 411 I Burlington, KS 66839/ Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNVET t0c I1

WO 04-0030 Page 2 of 2 It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental assessment need be prepared in connection with the issuance of this amendment.

WCNOC requests approval of the proposed license amendment by August 31, 2005. Once approved, this amendment will be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Kansas State Official. If you should have any questions regarding this submittal, please contact me at (620) 364-4246, or Mr. Kevin Moles, Manager Regulatory Affairs, at (620) 364-4126.

Very truly yours, Jacobs DJ/rtg Attachments: I - Affidavit 11 - Evaluation III - Markup of Technical Specification pages IV - Retyped Technical Specification pages V - Proposed Bases Changes (for information only)

VI - List of Commitments cc: V. L. Cooper (KDHE), w/a J. N. Donohew (NRC), w/a D. N. Graves (NRC), w/a B. S. Mallett (NRC), w/a Senior Resident Inspector (NRC), w/a

Attachment I to WO 04-0030 Page 1 of 1 STATE OF KANSAS

) SS COUNTY OF COFFEY Donna Jacobs, of lawful age, being first duly sworn upon oath says that she is Vice President Operations and Plant Manager of Wolf Creek Nuclear Operating Corporation; that she has read the foregoing document and knows the contents thereof; that she has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of her knowledge, information and belief.

Vice and Plant Manager SUBSCRIBED and sworn to before me this 23 day ofWiJly, 2004.

I WIY Pt"& RHONDA L GLEUE STAROFASAS MyApptExP.L-J/-.D Notar Pulic.

Notary Public

-'.1do-ow Expiration Date Ad II A nazll 1to WO 04-0030 Page 1 of 68 ATTACHMENT 11 EVALUATION

Attachment II to WO 04-0030 Page 2 of 68 EVALUATION

1.0 DESCRIPTION

This amendment application would revise Technical Specification (TS) 3.6.3, "Containment Isolation Valves," to extend the Completion Times for an inoperable containment isolation valve.

WCAP-15791-P, Rev. 1, 'Risk-Informed Evaluation of Extensions to Containment Isolation Valve Completion Times," (Reference 1) provides the technical justification for extending the Completion Time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to a maximum of 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months (7 days) for TS 3.6.3. For containment isolation valves where acceptable results could not be demonstrated within 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months , shorter Completion Times were considered, evaluated, and requested. The current Completion Times are generally insufficient to respond to containment isolation valve inoperability and perform preventative maintenance activities at power.

The TS Bases for TS 3.6.3 are modified for consistency with the changes to the technical specifications.

Wolf Creek Nuclear Operating Corporation (WCNOC) is the Westinghouse Owners Group lead plant for this risk-informed program. Letter WOG-04-0234, dated May 6, 2004, transmitted WCAP-15791-P, Rev. 1 (Proprietary) and WCAP-15791-NP, Rev. I (Non-Proprietary), both entitled "Risk-Informed Evaluation of Extensions to Containment Isolation Valve Completion Times," to the NRC for review and approval. References are listed in Section 7 of this evaluation.

2.0 PROPOSED CHANGE

TS 3.6.3, "Containment Isolation Valves," Required Action A.1 of Condition A, requires isolating the affected penetration flow path within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with one or more penetration flow paths with one containment isolation valve inoperable except for purge valve leakage not within limit.

Condition A is only applicable to penetration flow paths with two containment isolation valves.

Required Action C.1 of Condition C, requires isolating the affected penetration flow path within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with one or more penetration flow paths with one containment isolation valve inoperable. Condition C is only applicable to penetration flow paths with one containment isolation valve and a closed system. This amendment application proposes to revise TS 3.6.3 as follows:

Condition A is revised to delete the NOTE indicating that Condition A is only applicable to penetration flow paths with two containment isolation valves.

The Completion Time for Required Action A. 1 is revised to allow Completion Times from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months up to a Completion Time of 7 days.

The existing Condition C is deleted since WCAP-15791-P, Rev. 1, evaluates a Completion Time for each specific valve as opposed to each penetration flow path. A new Condition C is added for two or more penetration flow paths with one containment isolation valve inoperable.

Attachments IlIl and IV provide the TS markups and the retyped TS. Attachment V provides the proposed TS Bases.

Attachment 11to WO 04-0030 Page 3 of 68

3.0 BACKGROUND

The containment isolation valves are used to isolate containment penetration flow paths.

Typically there is one containment isolation valve inside and one containment isolation valve outside each penetration that performs this function. Depending on the purpose of the system, the containment isolation valves may be normally open or closed. Systems can be closed or open inside and outside of containment. An open system inside containment is one that is directly connected to the containment atmosphere. An open system outside containment is one that is directly connected to the outside environment. A closed system inside containment is one that is not directly connected to the containment atmosphere and may consist of only a run of pipe inside containment. A closed system outside containment has no direct connection to the outside environment. Closed systems, either inside or outside containment, may not have an associated containment isolation valve.

The containment isolation valves form part of the containment pressure boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on a containment isolation signal. The isolation devices are either passive or active (automatic). Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured),

blind flanges, and closed systems are considered passive devices. Check valves, or other automatic valves designed to close without operator action following an accident, are considered active devices. Two barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds the limits assumed in the safety analyses. One of these barriers may be a closed system. These barriers (typically containment isolation valves) make up the Containment Isolation System.

Automatic containment isolation signals are produced during accident conditions. Containment Phase 'A' isolation occurs upon receipt of a safety injection signal. A Phase WA" isolation signal isolates nonessential process lines in order to minimize leakage of fission product radioactivity.

Containment Phase "B" isolation occurs upon receipt of a containment pressure High-High signal and isolates the remaining process lines, except systems required for accident mitigation.

In addition to the isolation signals listed above, the purge and exhaust valves receive an isolation signal on a containment high radiation condition. As a result, the Containment Isolation System helps ensure that the containment atmosphere will be isolated from the environment in the event of a release of fission product radioactivity to the containment atmosphere as a result of a Design Basis Accident (DBA).

The OPERABILITY requirements for containment isolation valves help ensure that containment is isolated within the time limits assumed in the safety analysis. Therefore, the OPERABILITY requirements provide assurance that the containment function assumed in the safety analysis will be maintained.

The containment isolation valve Limiting Condition for Operation (LCO) was derived from the assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during major accidents. As part of the containment boundary, containment isolation valve OPERABILITY supports leak tightness of the containment.

Therefore, the safety analysis of any event requiring isolation of containment is applicable to this LCO.

Attachment II to WO 04-0030 Page 4 of 68 The DBAs that result in a release of radioactive material within containment are a loss of coolant accident and a rod ejection accident. In the analysis for each of these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through containment isolation valves are minimized.

As discussed in Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decision-Making: Technical Specifications," acceptable reasons for requesting Technical Specification changes fall into one or more of the following categories:

Improvement to operational safety: A change to the TS can be made due to reductions in the plant risk or a reduction in the occupational exposure of plant personnel in complying with the TS requirements.

Consistency with risk basis in reaulatorv requirements: TS requirements can be changed to reflect improved design features in a plant or to reflect equipment reliability improvements that make a previous requirement unnecessarily stringent or ineffective.

TSs may be changed to establish consistently based requirements across the industry or across an industry group.

Reduce unnecessary burdens: The change may be requested to reduce unnecessary burdens in complying with current TS requirements, based on operating history of the plant or the industry in general. This includes extending Completion Times 1) that are too short to complete repairs when components fail with the plant at-power, 2) to complete additional maintenance activities at-power to reduce plant down time, and 3) provide increased flexibility to plant operators.

The Completion Time extensions are requested primarily to provide an improvement to operational safety, reduce unnecessary burden and provide a more consistent risk basis in regulatory requirements. In addition, the assumption that shutting the plant down is the safest course of action is not always valid and depending on the component or system of interest, it may be safer to complete component repairs at power. During shutdown, the transfer from auxiliary feedwater (AFW) to the residual heat removal (RHR) system represents an increased risk level due to system alignment changes that could lead to loss of inventory events. This transition can be avoided by completing the repair at-power. Potential risks associated with plant shutdown need to be considered when determining an appropriate course of action.

Extended Completion Times enable this shutdown risk to be averted.

With regard to the regulatory basis consistency, containment isolation valves are typically not as risk significant as many other plant safety systems and components. Completion Times should be commensurate with the risk significance of a component. Containment penetrations do not rely on single valves to perform their isolation function, but are designed with multiple isolation valves or involve a closed system. A 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is too restrictive and potentially forces plant operators to focus on containment isolation valve inoperability ahead of other inoperabilities that may be more risk significant, but have longer Completion Times.

Attachment II to WO 04-0030 Page 5 of 68

4.0 TECHNICAL ANALYSIS

4.1 Impact on Defense-In-Depth and Safety Margins In addition to discussing the impact of the changes on plant risk, the traditional engineering considerations need to be addressed. These include defense-in-depth and safety margins.

The fundamental safety principles on which the plant design is based cannot be compromised.

Design basis accidents are used to develop the plant design. These are a combination of postulated challenges and failure events that are used in the plant design to demonstrate safe plant response. Defense-in-depth, the single failure criterion, and adequate safety margins may be impacted by the proposed change and consideration needs to be given to these elements.

Impact on Defense-in Depth The proposed change needs to meet the defense-in-depth principle which consists of a number of elements. These elements and the impact of the proposed change on each follow:

A reasonable balance among prevention of core damage, prevention of containment failure, and consequence mitigation is preserved.

The containment isolation valves are part of the plant design to primarily ensure containment integrity following an accident. By closing the containment isolation valves, inventory required to cool the core is also maintained. Therefore, the proposed Completion Time change for the containment isolation valves has a negligible impact on Core Damage Frequency (CDF), no direct impact on consequence mitigation, and only a small impact on Large Early Release Frequency (LERF). This change does not significantly degrade the ability of one barrier to fission product release and compensate with an improvement of another. The balance between prevention of core damage and prevention of containment failure and consequence mitigation is maintained. Furthermore, no new accident or transients are introduced with the requested change and the likelihood of an accident or transient is not impacted.

Over-reliance on programmatic activities to compensate for weaknesses in plant design.

The plant design will not be modified with this proposed change. All safety systems, including the containment isolation valves, will still function in the same manner with the same reliability, and there will be no additional reliance on additional systems, procedures, or operator actions. The calculated risk increase for the Completion Time changes is very small and additional control processes are not required to be put into place to compensate for any risk increase.

System redundancy, independence, and diversity are maintained commensurate with the expected frequency and consequences of challenges to the system.

There is no impact on the redundancy, independence, or diversity of the containment isolation valves or on the ability of the plant to isolate containment penetrations with diverse systems. The redundant and diverse containment isolation designs will not be changed.

The containment isolation valves are reliable components and will remain reliable after these proposed changes.

Attachment II to WO 04-0030 Page 6 of 68

Defenses against potential common cause failures are maintained and the potential for introduction of new common cause failure mechanisms is assessed.

Defenses against common cause failures are maintained. The Completion Time extensions requested are not significantly increased such that any new common cause failure mechanisms would occur. In addition, the operating environment for these components remains the same; therefore, new common cause failures modes are not expected. The number, design, and types of valves used for containment isolation remain the same with these changes so the containment isolation system maintains the potential against common cause failures.

Independence of barriers is not degraded.

The barriers protecting the public and the independence of these barriers are maintained. It is not expected that multiple systems will be out of service simultaneously during the extended Completion Times that could lead to degradation of these barriers, and an increase in risk to the public. In addition, the extended Completion Times do not provide a mechanism that degrades the independence of the fuel cladding, Reactor Coolant System, and containment barriers.

Defenses against human errors are maintained.

No new operator actions related to the Completion Time extensions are required to maintain plant safety. No changes to current operating, maintenance, or test procedures are required due to these changes. The increase in Completion limes provides additional time to complete troubleshooting, test, and repair activities which will lead to improved operator and maintenance personnel performance, and result in reduced system re-alignment and restoration errors.

Impact on Safety Margins The safety analysis acceptance criteria as stated in the Updated Safety Analysis Report are not impacted by this change. Where applicable, redundant and diverse containment isolation valves and closed systems will be maintained. The proposed changes will not allow plant operation in a configuration outside the design basis. Isolation of all containment penetrations will remain single failure proof. Containment isolation valve operation and testing requirements and containment leakage requirements are not impacted by this change. There is no impact on safety margins.

4.2 Assessment of Impact on Risk This section presents the analysis and assumptions used to determine the impact on plant risk of increasing the Completion Times specified in Section 2.0. This section addresses the three tiered approach to the evaluation of risk-informed TS changes. The three tiered approach is defined in Regulatory Guide 1.177. The first tier addresses Probabilistic Safety Assessment (PSA) insights and includes the risk analyses to support the Completion Time change. The second tier addresses avoidance of risk-significant plant configurations. The third tier, which addresses risk-informed plant configuration control and management, is covered by the Maintenance Rule Program.

Attachment II to WO 04-0030 Page 7 of 68 The following types of containment penetration flow paths are evaluated:

Penetration flow paths connected to the containment atmosphere

Penetration flow paths connected to the Reactor Coolant System

Penetration flow paths connected to the Steam Generators Tier 1: Approach to the Evaluation The Tier 1 analysis provides the impact of the Completion Time changes on the incremental conditional large early release probability (ICLERP) and LERF. Since the containment isolation valves are used to maintain containment integrity, any change to their availability will directly impact releases from containment following a core damage event. The impact of these changes on CDF, and as measured by the change in CDF and incremental conditional core damage probability (ICCDP) values, is not important since this impact would be a secondary effect related to a long-term loss of inventory for core cooling or due to a small increase in the probability of flow diversion paths for several safety systems. Potential flow diversion paths are typically small lines not included in PRA models due to the small amount of diverted flow or due to normally closed valves isolating the flow path or multiple valves in series that need to be open for a flow diversion. In addition, inoperable valves in maintenance are not large contributors to fluid safety system unavailability. Therefore, the impact of diversion flow paths on plant risk is not expected to change with this Completion Time extension.

The approach used in WCAP-15791-P applies to both deterministic and probabilistic evaluations. A deterministic approach is used to determine the minimum containment hole size that will result in a large release from the containment atmosphere. Penetration flow paths connected to the containment atmosphere smaller than this size are allowed a Completion Time of 7 days. The minimum hole size is determined for large dry, subatmospheric, and ice condenser containment types. All other penetrations are evaluated on a probabilistic basis to demonstrate if a Completion Time of 7 days is acceptable or to determine an appropriate Completion Time of less than 7 days. The probabilistic evaluation is consistent with the Nuclear Regulatory Commission's (NRC) approach for using PRA in risk-informed decisions on plant-specific changes to the current licensing basis. This approach is discussed in Regulatory Guide 1.174, 'An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and Regulatory Guide 1.177.

Both the deterministic and probabilistic analyses were completed on a generic basis. Input parameters used in the analyses were chosen based on the most conservative plant, that is, the set of design parameters that results in the most conservative results (shortest Completion Time). Application of the generic analysis on a plant specific basis requires each utility implementing this change to demonstrate that their plant is within the bounds of the generic analysis.

The applicability of the WCAP-1 5791-P generic analysis to WCGS is demonstrated in Section 9 of Reference 1. A plant specific analysis was also completed for WCGS and is documented in Section 10 of Reference 1. The plant specific analysis is based on actual plant data and justifies longer plant specific Completion Times.

Attachment II to WO 04-0030 Page 8 of 68 Probabilistic Evaluation of the Containment Penetrations The probabilistic evaluation involves the calculation of the ICLERP and ALERF for each type of containment isolation valve penetration in Sections 8.2.2 through 8.2.4 of Reference 1. Based on the ICLERP and ALERF values (less than 5.OE-08 and 1.OE-07, respectively) per Regulatory Guides 1.177 and 1.174, the maximum Completion Times were determined. For those penetrations where a 7 day Completion Time could not be justified, shorter Completion Times of 72, 48, 24, 12, and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months were evaluated.

The ICLERP is defined in Regulatory Guide 1.177 as:

ICLERP = [(conditional LERF with the subject equipment out of service) - (baseline LERF with nominal expected equipment unavailabilities)] x duration of a single CT under consideration The ICLERP was determined for each penetration with the assumption that one containment isolation valve within the penetration is in maintenance. If there was more than one containment isolation valve within the penetration, the calculation was performed as many times as there are valves because any one of those valves could be in maintenance.

For the ALERF calculations, a fault tree analysis was performed to evaluate all combinations of non-isolated penetration possibilities for each penetration. Non-isolations can be a result of valve failures as well as a valve being in maintenance. This was done for the current 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time and the proposed 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months (7 day) Completion Time or shorter Completion Times as necessary to meet the 1.OE-07/yr ALERF criterion. The increase in the probability of failing to isolate the penetration was then multiplied by the CDF to determine the final ALERF.

The specific calculations for the ICLERPs and ALERFs for the containment isolation valves vary from penetration to penetration. The variations are dependent upon the conditions and configurations of the penetration. Sections 8.2.2 through 8.2.4 of Reference 1 provide the calculations for each penetration and the applicable assumptions.

Deterministic Evaluation of Containment Hole Size A deterministic evaluation was performed in WCAP 15791-P, Rev. 0, to determine the minimum containment hole size that would result in a large release. Penetration flow paths connected to the containment atmosphere (this excludes all Reactor Coolant System and Steam Generator connections) that have piping diameters smaller than this minimum threshold value are assumed to be of insufficient size to result in a large release. These penetrations are assigned a 7 day Completion Time and no detailed probabilistic analysis is required.

A large release was originally defined as a pathway of sufficient size to release the contents of the containment (i.e., one volume change) within one hour. This criterion is provided in the EPRI PSA Applications Guide. The vent diameter, or containment hole size, that met this criteria was calculated. For this evaluation, all releases are considered early.

In Revision 1 to WCAP-15791-P, it is assumed that a hole size of greater than 2 inches in diameter can result in a large release. This assumption was utilized based on discussions with the NRC staff. The Staff did not agree with the definition that was used for a large release (one containment volume per hour) and felt the criteria used in previous studies was more appropriate. In previous studies, a 2 inch containment hole size has been used for screening in the development of containment isolation PRA models.

Attachment II to WO 04-0030 Page 9 of 68 Plant Specific Analysis Plant specific evaluations were performed using WCGS-specific parameters and implementing them into the generic probabilistic evaluation of Section 8.2 of Reference 1 to get actual WCGS-specific results. Consistent with the generic analysis, containment isolation valves not directly connected to the RCS with a pipe diameter of 2 inches or less are assigned a Completion Time of 7 days since these hole sizes are too small to provide a large release.

For the remaining containment penetrations which had a Completion Time of less than 7 days based on the generic analysis, the ICLERP and/or ALERF (depending on which was more limiting) was recalculated with WCGS specific input parameters of Tables 9-1a, 9-1b, 9-1c, and 9-1d of Reference 1. The inputs were used in the appropriate ICLERP and ALERF equations discussed in Sections 8.2.2 through 8.2.4 of Reference 1. The plant specific evaluations resulted in additional Completion Time improvements. Table 1 provides the resulting Completion Times for each containment isolation valve.

Tier 2: Avoidance of Risk-Significant Plant Conditions The objective of the second tier, which is applicable to Completion Time extensions, is to provide reasonable assurance that risk-significant plant equipment outage configurations will not occur when equipment is out of service. If risk-significant configurations do occur, then enhancements to Technical Specifications or procedures, such as limiting unavailability of backup systems, increased surveillance frequencies, or upgrading procedures or training, can be made that avoid, limit, or lessen the importance of these configurations.

The containment isolation valves form part of the containment barrier which limits releases to the environment. Other containment systems, such as the containment cooling system and containment spray system, also function to mitigate releases to the environment, but by different mechanisms. These other systems typically are used to preserve containment integrity by limiting the containment pressure increase or to remove radioactive material from the containment atmosphere during an accident. The containment cooling and containment spray systems are generally not considered backup to the containment isolation function.

Given that containment isolation has failed, releases from containment are independent of the success or failure of containment cooling. The containment is already breached and containment pressure limitation would no longer be an issue. On the other hand, if containment isolation would fail, then containment spray could be a factor in limiting releases via its scrubbing effect. This would be of limited benefit, because a large portion of the core damage sequences in which containment spray would be functional at the time of the initiating event do not have effective scrubbing by containment spray at the time of fission product release to the containment. Thus, efforts taken to assure the availability of containment spray when containment isolation may be impaired, do little to assure that containment spray will be effective in reducing releases if a core damage accident were to occur. Also, when analyzed on a realistic basis, only a small fraction of the core damage sequences with containment isolation failures would result in fission product releases that are risk significant. Therefore, no Tier 2 limitations need to be imposed.

Attachment II to WO 04-0030 Page 10 of 68 Tier 3: Risk-Informed Plant Configuration Control and Management The objective of the third tier is to ensure that the risk impact of out-of-service equipment is evaluated prior to performing any maintenance activity. As stated in Regulatory Guide 1.174, "a viable program would be one that is able to uncover risk-significant plant equipment outage configurations as they evolve during real-time, normal plant operation." The third-tier requirement is an extension of the second-tier requirement, but addresses the limitation of not being able to identify all possible risk-significant plant configurations in the second-tier evaluation.

The risk impact associated with performance of maintenance and testing activities is evaluated in accordance with the Wolf Creek Operational Risk Assessment Program (administrative procedure AP 22C-003). An Operational Risk Assessment is performed for activities within a weekly schedule. Compensatory measures are addressed for activities deemed to be risk significant. The weekly scheduled activities and associated Operational Risk Assessment are reviewed by the WCGS PSA Group and approved by the Plant Manager or designee. The Operational Risk Assessment Program also addresses the impact on the Operational Risk Assessment due to added or emergent activities and activities which have slipped from the scheduled completion time.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration This amendment application would revise Technical Specification (TS) 3.6.3, "Containment Isolation Valves," to extend the Completion Times for an inoperable containment isolation valve.

WCAP-15791-P, 'Risk-informed Evaluation of Extensions to Containment Isolation Valve Completion Times," (Reference 1) provides the technical justification for extending the Completion Time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to a maximum of 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months (7 days) for TS 3.6.3. For containment isolation valves where acceptable results could not be demonstrated for 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months , shorter Completion Times were considered, evaluated, and requested.

The proposed changes do not involve a significant hazards consideration for WCGS based on the three standards set forth in IOCFR50.92(c) as discussed below:

(1) Do the proposed changes Involve a significant Increase In the probability or consequences of an accident previously evaluated?

Response: No The proposed changes to the Completion Times do not change the response of the plant to any accidents and have an insignificant impact on the reliability of the containment isolation valves.

The containment isolation valves will remain highly reliable and the proposed changes will not result in a significant increase in the risk of plant operation. This is demonstrated by showing that the impact on plant safety as measured by the large early release frequency (LERF) and incremental conditional large early release probabilities (ICLERP) is acceptable. These changes are consistent with the acceptance criteria in Regulatory Guides 1.174 and 1.177.

Therefore, since the containment isolation valves will continue to perform their functions with high reliability as originally assumed and the increase in risk as measured by LERF and ICLERP is acceptable, there will not be a significant increase in the consequences of any accidents.

Attachment II to WO 04-0030 Page 11 of 68 The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, or configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed changes do not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed changes are consistent with the safety analysis assumptions and resultant consequences.

Therefore, it is concluded that this change does not increase the probability of occurrence of a malfunction of equipment important to safety.

(2) Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes do not result in a change in the manner in which the containment isolation valves provide plant protection. There are no design changes associated with the proposed changes. The changes to Completion Times do not change any existing accident scenarios, nor create any new or different accident scenarios.

The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements or eliminate any existing requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.

Therefore, the possibility of a new or different malfunction of safety related equipment is not created.

(3) Do the proposed changes involve a significant reduction In a margin of safety?

Response: No The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not impacted by these changes. The proposed changes will not result in plant operation in a configuration outside the design basis. The calculated impact on risk is insignificant and is consistent with the acceptance criteria contained in Regulatory Guides 1.174 and 1.177.

Therefore, it is concluded that this change does not involve a significant reduction in the margin of safety.

Based on the above, WCNOC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

Attachment II to WO 04-0030 Page 12 of 68 5.2 Applicable Regulatorv Requirements/Criteria The regulatory bases and guidance documents associated with the systems discussed in this amendment application include:

General Design Criteria 54 - Piping Systems Penetrating Containment Piping systems penetrating the primary reactor containment shall be provided with leak detection, isolation, and containment capabilities having redundancy, reliability, and performance capabilities which reflect the importance to safety of isolating these piping systems. Such piping systems shall be designed with a capability to test periodically the operability of the isolation valves and associated apparatus and to determine if valve leakage is within acceptable limits.

General Design Criteria 55 - Reactor Coolant Pressure Boundary Penetrating Containment Each line that is part of the reactor coolant pressure boundary and that penetrates primary reactor containment shall be provided with containment isolation valves as follows, unless it can be demonstrated that the containment isolation provisions for a specific class of lines, such as instrument lines, are acceptable on some other defined basis:

(1) One locked closed isolation valve inside and one locked closed isolation valve outside containment; or (2) One automatic isolation valve inside and one locked closed isolation valve outside containment; or (3) One locked closed isolation valve inside and one automatic isolation valve outside containment. A simple check valve may not be used as the automatic isolation valve outside containment; or (4) One automatic isolation valve inside and one automatic isolation valve outside containment. A simple check valve may not be used as the automatic isolation valve outside containment.

Isolation valves outside containment shall be located as close to containment as practical and upon loss of actuating power, automatic isolation valves shall be designed to take the position that provides greater safety.

Other appropriate requirements to minimize the probability or consequences of an accidental rupture of those lines or of lines connected to them shall be provided as necessary to assure adequate safety. Determination of the appropriateness of these requirements, such as higher quality in design, fabrication and testing, additional provisions for inservice inspection, protection against more severe natural phenomena, and additional isolation valves and containment, shall include consideration of the population density, use characteristics, and physical characteristics of the site environs.

Attachment II to WO 04-0030 Page 13 of 68 General Design Criteria 56- Primary Containment Isolation Each line that connects directly to the containment atmosphere and penetrates primary reactor containment shall be provided with containment isolation valves as follows, unless it can be demonstrated that the containment isolation provisions for a specific class of lines, such as instrument lines, are acceptable on some other defined basis:

(1) One locked closed isolation valve inside and one locked closed isolation valve outside containment; or (2) One automatic isolation valve inside and one locked closed isolation valve outside containment; or (3) One locked closed isolation valve inside and one automatic isolation valve outside containment. A simple check valve may not be used as the automatic isolation valve outside containment; or (4) One automatic isolation valve inside and one automatic isolation valve outside containment. A simple check valve may not be used as the automatic isolation valve outside containment.

Isolation valves outside containment shall be located as close to the containment as practical and upon loss of actuating power, automatic isolation valves shall be designed to take the position that provides greater safety.

General Design Criteria 57 - Closed System Isolation Valves Each line that penetrates the primary reactor containment and is neither part of the reactor coolant pressure boundary nor connected directly to the containment atmosphere shall have at least one containment isolation valve which shall be either automatic, or locked closed, or capable of remote manual operation. This valve shall be outside containment and located as close to the containment as practical. A simple check valve may not be used as the automatic isolation valve.

There have been no changes to the containment penetration design such that any of the regulatory requirements and guidance documents in Section 5.0 would come into question.

The evaluation performed by WCNOC in Section 4.0 concludes that WCGS will continue to comply with the applicable regulatory requirements.

In conclusion, based on the considerations discussed above, (1)there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

Attachment II to WO 04-0030 Page 14 of 68

6.0 ENVIRONMENTAL CONSIDERATION

WCNOC has determined that the proposed amendment would change requirements with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. WCNOC has evaluated the proposed amendment and has determined that the amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed amendment is not required.

7.0 REFERENCES

1. WCAP-15791-P, Revision 1, 'Risk-Informed Evaluation of Extensions to Containment Isolation Valve Completion Times," April 2004.

Attachment II to WO 04-0030 Page 15 of 68 Table 1 WCGS Containment Isolation Valve Completion Time Results Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-I to These penetrations are not covered - -

P-12 under LCO 3.6.3 but under their own TS.

P-13 ENHV-07 No direct connection to RCS; I,C #23 System pressure boundary maintained 8 hrs 168 hrs 8 hrs penetration flow path connects open System pressure boundary compromised 4 hrs 168 hrs 4 hrs system IC to closed system outside containment (O); single, normally closed valve OC.

P-14 EJHV-881 lB No direct connection to RCS; I,C #23 System pressure boundary maintained 8 hrs 168 hrs 8 hrs penetration flow path connects open System pressure boundary compromised 4 hrs 168 hrs 4 hrs system inside containment (IC) to closed system OC; single, normally closed valve Oc.

EJHV-24 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 brs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EJHV-26 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

ENV-189 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 bra 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

Attachment II to WO 04-0030 Page 16 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type ( CT: @ CT: CT P-15 EJHV-881 IA No direct connection to RCS; I,C #23 System pressure boundary maintained 8 hrs 168 hrs 8 hrs penetration flow path connects open System pressure boundary compromised 4 hrs 168 hrs 4 hrs system IC to closed system OC; single, normally closed valve OC. _

EJHV-23 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 brs 168 hrs to result in a large release.

EJHV-25 No direct connection to RCS; flow small line System pressure boundary maintained 168 bra 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EJV-187 No direct connection to RCS; flow small line System pressure boundary maintained 168 brs 168 hrs 168 hirs path smaller in size than that required System pressure boundary compromised 168 hrs 168 brs 168 hrs to result in a large release.

P-16 ENHV-01 No direct connection to RCS; I,C #23 System pressure boundary maintained 8 hrs 168 hrs 8 hrs penetration flow path connects open System pressure boundary compromised 4 hrs 168 hrs 4 hrs system IC to closed system OC; single, normally closed valve 0C.

P-21 EJHCV-8825 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system. Flow path is smaller than minimum size required for a large release.

EJHV-8840 RCS connection; standby system; H,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 168 brs 72 hrs with valves EJV-056, EJ-8841A, EJ-8841B.

Attachment II to WO 04-0030 Page 17 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-21 EJV-056 RCS connection; standby system; II,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs (cont) normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 168 hrs 72 hrs with valves EJHV-8840, EJ-8841A, EJ-8841B.

EJV-124 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system. Flow path is smaller than minimum size required for a large release.

EJV-122 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system. Flow path is smaller than minimum size required for a large release.

EJV-l 18,120 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system. Flow path is smaller than minimum size required for a large release.

EJV-175,6,7,8 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system. Flow path is smaller than minimum size required for a large release.

Attachment II to WO 04-0030 Page 18 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-21 EJ-8841A RCS connection; standby system; Hl,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs (cont) check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation.

Assessed with valves EIHV-8840, EJV-056, EJ-8841B.

EJ-8841B RCS connection; standby system; llA #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation.

Assessed with valves EJHV-8840; EJV-056, EJ-8841A.

P-22 BBHV-835 lB RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

BBV-354 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

Attachment II to WO 04-0030 Page 19 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Caoc # Maintenance Activity Type @ CT: @ CT: CT P-22 BBV-246 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

BBV148 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

P-23 BGHV-8160 RCS connection; normally operating f1,B #39 System pressure boundary maintained 24 hrs 168 hrs 24 hrs system; normally open valve IC; System pressure boundary compromised 48 hrs 168 hrs 48 hrs when system pressure boundary is compromised, no longer an RCS connection. Assessed with valves BGHV-8152, BGV-363; Chose CT for an AOV based on guideline B of Section 9.1.

1to WO 04-0030 Page 20 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-23 BGV-363 RCS connection; normally operating II,B #39 System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) system; normally closed valve OC. System pressure boundary compromised 168 hrs 168 hrs 168 hrs Assessed with valves BGHV-8160, BGHV-8152; Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

BGHV-8152 RCS connection; normally operating ll,B #39 System pressure boundary maintained 24 hrs 168 hrs 24 hrs system; normally open valve OC. System pressure boundary compromised 24 hrs 168 hrs 24 hrs Assessed with valves BGHV-8160, BGV-363; Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

P-24 BGHV-8112 Normally operating system; RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection, however b/c of relief System pressure boundary compromised 168 hrs 168 hrs 168 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12BG01, Rev. 10),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to open system OC; given this scenario, flow path is also smaller in size than that required to result in a large release.

Attachment II to WO 04-0030 Page 21 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justifled tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-24 BGV-135 Normally operating system; RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) connection, however b/c of relief System pressure boundary compromised 168 hrs 168 hrs 168 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12BGOI, Rev. 10),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to open system OC; given this scenario, flow path is also smaller in size than that required to result in a large release.

BGHV-8100 Normally operating system; RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection, however b/c of relief System pressure boundary compromised 168 hrs 168 brs 168 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12BGO1, Rev. 10),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to open system OC; given this scenario, flow path is also smaller in size than that required to result in a large release.

BGV457 Normally operating system; RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection, however b/c of relief System pressure boundary compromised 168 hrs 168 hrs 168 hrs valve IC, extremely unlikely to reach RCS pressure, therefore considered as connection from open system IC to open system OC; given this scenario, flow path is also smaller in size than that required to result in a large I

release.

I a. a a a -

1to WO 04-0030 Page 22 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Catc # Maintenance Activity Type @ CT: @ CT: CT P-25 BLHV-8047 No direct connection to RCS; I,A #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration lines normally open IC System pressure boundary compromised 168 hrs 168 hrs 168 hrs and OC.

BLV-054 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

BL-8046 No direct connection to RCS; I,A #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration lines normally open IC System pressure boundary compromised 168 hrs 168 hrs 168 hrs and OC P-26 HBHV-7176 Normally operating system; RCS I,B #20 System pressure boundary maintained 72 hrs 168 hrs 72 brs connection, however b/c of relief System pressure boundary compromised 48 hrs 168 hrs 48 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12HB01, Rev. 8),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to l_ _ _ open system OC.

HBHV-7136 Normally operating system; RCS I,B #20 System pressure boundary maintained 72 hrs 168 hrs 72 hrs connection, however b/c of relief System pressure boundary compromised 72 hrs 168 hrs 72 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12HB01, Rev. 8),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to open system OC.

1to WO 04-0030 Page 23 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: I CT: CT P-26 HBV-419 Normally operating system; RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) connection, however b/c of relief System pressure boundary compromised 168 hrs 168 hrs 168 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12HB01, Rev. 8),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to open system OC; given this scenario, flow path is also smaller in size than that required to result in a large release.

P-27 EJHV-8809B RCS connection; standby system; II,A #33 System pressure boundary maintained 72 hrs 4 hrs 4 hrs normally open valve OC. Assessed System pressure boundary compromised 72 hrs 4 hrs 4 hrs with valves EJV-058, EP-8818C, EP-8818D; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EJV-058 RCS connection; standby system; II,A #33 System pressure boundary maintained 72 hrs 4 hrs 4 hrs normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 4 hrs 4 hrs with valves EJHV-8809B, EP-8818C, EP-8818D; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EJHCV-8890B RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system, flow path is smaller than minimum size required for a large release.

1to WO 04-0030 Page 24 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justifled tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-27 EJV-086 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system; flow path is smaller than minimum size required for a large release.

EJV-088,090 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system, flow path is smaller than minimum size required for a large release.

EP-8818C RCS connection; standby system;, IA #33 System pressure boundary maintained 8 hrs 4 hrs 4 hrs check valve IC; extra check valve System pressure boundary compromised 168 hrs 4 hrs 4 hrs upstream that also provides isolation.

Assessed with valves EJHV-8809B, EJV-058, EP-8818D; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EJV-179, 180, RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs 181,182 release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system, flow path is smaller than minimum size required for a large release.

I I I I ___________________________________ I __________ I ________ .5.

1to WO 04-0030 Page 25 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justifled tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-27 EP-8818D RCS connection; standby system; IIA #33 System pressure boundary maintained 8 hrs 4 hrs 4 hrs (cont) check valve IC; extra check valve System pressure boundary compromised 168 hrs 4 hrs 4 hrs upstream that also provides isolation.

Assessed with valves EJHV-8809B, EJV-058, EP-8818C; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EJV-166 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system, flow path is smaller than minimum size required for a large release.

P-28 EFHV-32 No direct connection to RCS; IB #5 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally open valve OC. Assessed with valve EFHV-34; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EFHV-34 No direct connection to RCS; IB #20 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 72 hrs 168 hrs 72 hrs system IC to open system OC; normally open valve IC. Assessed with valve EFHV-32; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EFV-278 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 brs 168 hrs 168 hra to result in a large release.

1to WO 04-0030 Page 26 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-29 EFHV-46 No direct connection to RCS; I,B #20 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 72 hrs 168 hrs 72 hrs system IC to open system OC; normally open valve IC. Assessed with valve EFHV-32; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EFV-279 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EFHV-50 No direct connection to RCS; I,B #20 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally open valve OC. Assessed with valve EFHV-46; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

P-30 KAFV-29 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

KAV-218 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

KAV-204 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 27 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.) l Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type CT: @ CT: CT P-32 LFFV-95 No direct connection to RCS; I,A #14 or System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open I,A #4 if System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; valve 96 is normally open valve IC. Assessed open with valve LFFV-96, valve 96 opens if sump is running; (get same CT results for both cases). Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

LFFV-96 No direct connection to RCS; IA #14 or System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open I,A #4 if System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; valve 96 is normally closed valve OC, valve open opens if sump is running; (get same CT results for both cases). Assessed with valve LFFV-95; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

LFV-093 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-34 GPV-010 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 28 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT Flanges No direct connection to RCS; I,A #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs penetration flow path connects open System pressure boundary compromised 24 hrs 168 hrs 24 hrs system IC to open system OC; 1 flange IC and I flange OC used to isolate the penetration are analyzed as normally closed valves of the same type.

P-39 BBHV-8351C RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

BBV-356 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

1to WO 04-0030 Page 29 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-39 BBV-247 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

BBV-178 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

P-40 BBHV-8351D RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

1to WO 04-0030 Page 30 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-40 BBV-358 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

BBV-248 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

BBV-208 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

Attachment II to WO 04-0030 Page 31 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P.41 BBHV-8351A RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

BBV-352 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

BBV-245 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

1to WO 04-0030 Page 32 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-41 BBV-1 18 RCS connection; normally operating small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) system; continues to operate during System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.

P43 HDV-016 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

HDV-023 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

HDV-017 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-44 HBHV-7126 Normally operating system; RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection, however b/c of relief System pressure boundary compromised 168 hrs 168 hrs 168 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12HBOI, Rev. 8),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to open system OC; given this scenario, flow path is also smaller in size than that required to result in a large release.

1to WO 04-0030 Page 33 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justifled tion # Valve Grouping Explanation Calc # Maintenance Activity Type CT: @ CT: CT P-44 HBHV-7150 Normally operating system; RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) connection, however b/c of relief System pressure boundary compromised 168 hrs 168 hrs 168 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12HBO1, Rev. 8),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to open system OC; given this scenario, flow path is also smaller in size than that required to result in a large release.

HBV-420 Normally operating system; RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection, however b/c of relief System pressure boundary compromised 168 hrs 168 hrs 168 hrs valve on RC drain tank IC (WCGS P&ID drawing M-12HBOI, Rev. 8),

extremely unlikely to reach RCS pressure, therefore considered as connection from closed system IC to open system OC; given this scenario, flow path is also smaller in size than that required to result in a large release.

P-45 EPV-046 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EPV-043 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 34 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type 1 CT: CT: CT P-45 EPHV-8880 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-48 EMHV-8802B RCS connection; standby system; II,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 168 hrs 72 hrs with valves EMV-059, EMV-003, EMV-004.

EMHV-8824 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SI system; flow path is smaller than minimum size required for a large release.

EMV-003 RCS connection; standby system; II,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation; when system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMHV-8802B, EMV-059, EMV-004.

1to WO 04-0030 Page 35 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP jLERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: j CT: CT P48 EMV-004 RCS connection; standby system; HA #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs (cont) check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation; when system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMHV-8802B, EMV-059, EMV-003.

EMV-060, 061, RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs 063,064 release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs EMV-217, 169 atmosphere to environment via the SI system; flow path is smaller than minimum size required for a large release.

EMV-170,172 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SI system; flow path is smaller than minimum size required for a large release.

EMV-059 RCS connection; standby system; H,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 168 hrs 72 hrs with valves EMHV-8802B, EMV-003, EMV-004.

1to WO 04-0030 Page 36 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justifled tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: ( CT: CT P-49 EMHV-8835 RCS connection; standby system; II,A #34 System pressure boundary maintained 72 hrs 4 hrs 4 hrs normally open valve OC. Assessed System pressure boundary compromised 72 hrs 4 hrs 4 hrs with valves EPV-067, EPV-020, EPV-010, EPV-040, EPV-030; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EMHV-8823 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SI system; flow path is smaller than minimum size required for a large release.

EPV-020 RCS connection; standby system; llA #34 System pressure boundary maintained 8 hrs 4 hrs 4 hrs check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation; when system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMHV-8835, EPV-067, EPV-010, EPV-040, EPV-030; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1. _

1to WO 04-0030 Page 37 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ITCLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: [ CT: CT P.49 EPV-010 RCS connection; standby system; II,A #34 System pressure boundary maintained 8 hrs 4 hrs 4 hrs (cont) check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation; when system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMHV-8835, EPV-067, EPV-020, EPV-040, EPV-030; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

.4 1 4 .4 4 EPV-040 RCS connection; standby system; II,A #34 System pressure boundary maintained 8 hrs 4 hrs 4 hrs check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation; when system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMHV-8835, EPV-067, EPV-020, EPV-010, EPV-030; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

1to WO 04-0030 Page 38 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-49 EPV-030 RCS connection; standby system; II,A #34 System pressure boundary maintained 8 hrs 4 hrs 4 hrs (cont) check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation; when system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMHV-8835, EPV-067, EPV-020, EPV-020, EPV-040; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EMV-067 RCS connection; standby system; H,A #34 System pressure boundary maintained 72 hrs 4 hrs 4 hrs normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 4 hrs 4 hrs with valves EMHV-8835, EPV-020, EPV-010, EPV-040, EPV-030; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EMV-068 thru RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs EMV-075 release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SI system; flow path is smaller than minimum size required for a large release.

1to WO 04-0030 Page 39 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P49 EMV-218 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) EMV-162 thru release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs EMV-168 atmosphere to environment via the SI system; flow path is smaller than minimum size required for a large release.

P-51 GPV-O1 I No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GPV-012 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

Flanges No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-52 EJHV-8701B RCS connection; standby system; llA #35 & System pressure boundary maintained 4 hrs 4 hrs 4 hrs normally closed valve IC; for 1,C #23 System pressure boundary compromised 8 hrs 168 hrs 8 hrs boundary maintained, extra valve upstream that also provides isolation; for boundary compromised, ECCS is considered a closed system and I,C

23 is applicable.

EJ-8708B RCS connection; but no direct RCS I,C #23 System pressure boundary maintained 8 hrs 168 hrs 8 hrs to environment connection via this System pressure boundary compromised 8 hrs 168 hrs 8 hrs CIV; valve is IC; analyze as single CIV IC to closed system OC, ECCS is considered a closed system and I,C

23 is applicable.

1to WO 04-0030 Page 40 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-53 ECV-084 No direct connection to RCS; IA #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs penetration flow path connects to System pressure boundary compromised 24 hrs 168 hrs 24 hrs open system IC to open system OC; normally closed valve IC. Assessed with valve ECV-083.

ECV-085 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

ECV-083 No direct connection to RCS; IA, #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs penetration flow path connects open System pressure boundary compromised 24 hrs 168 brs 24 hrs system IC to open system OC; normally closed valve OC. Assessed with valve ECV-084.

P-54 ECV-087 No direct connection to RCS; IA, #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs penetration flow path connects open System pressure boundary compromised 24 hrs 168 brs 24 hrs system IC to open system OC; normally closed valve IC. Assessed with valve ECV-088.

ECV-086 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

ECV-088 No direct connection to RCS; IA, #1 System pressure boundary maintained 24 brs 168 hrs 24 hrs penetration flow path connects open System pressure boundary compromised 24 hrs 168 brs 24 hrs system IC to open system OC; normally closed valve OC. Assessed with valve ECV-087.

Attachment II to WO 04-0030 Page 41 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justifled tion # Valve Grouping Explanation CaIc # Maintenance Activity Type CT: CT: CT P-55 ECV-095 No direct connection to RCS; IA, #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs penetration flow path connects open System pressure boundary compromised 24 hrs 168 hrs 24 hrs system IC to open system OC; normally closed valve IC. Assessed with valve ECV-096.

ECV-094 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

ECV-096 No direct connection to RCS; IA, #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs penetration flow path connects open System pressure boundary compromised 24 hrs 168 hrs 24 hrs system IC to open system OC; normally closed valve IC. Assessed with valve ECV-095.

P-56 GSHV-9 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-8 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 Irs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSV-032 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-38 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 Irs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 brs 168 hrs to result in a large release.

GSHV-39 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 42 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-56 GSV-058 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-57 SJHV-131 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

SJHV-132 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

SJV-i 11 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

SlV-1 14 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-58 EMV-006 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EMV-182 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EMV-123 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EMHV-8888 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 43 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type CT: @ CT: CT P-59 N/A 2 lines within one penetration; II,A #9 System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection to RCS; standby system; System pressure boundary compromised 168 hrs 168 hrs 168 hrs hydraulic sensor IC, LIS OC per line; 3/16" line.

P-62 BBHV-8026 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

BBHV-8027 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-63 KAV-l 18 No direct connection to RCS; IA #2 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally closed valve OC. Assessed with valve KAV-039.

KAV-163 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

KAV-039 No direct connection to RCS; IA #2 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally closed valve IC. Assessed with valve KAV-1 18.

1to WO 04-0030 Page 44 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Cale # Maintenance Activity Type @ CT: @ CT: CT P-64 SJHV-128 RCS connection; standby system; IIA #31 System pressure boundary maintained 12 hrs 168 hrs 12 hrs normally closed valve IC; when System pressure boundary compromised 168 hrs 168 hrs 168 hrs system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves SJHV-129, SJHV-130, SJV-106.

SJHV-129 RCS connection; standby system; II,A #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve OC. Assessed System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves SJHV-128, SJHV-130, SJV-106.

SJHV-130 RCS connection; standby system; II,A #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve OC. Assessed System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves SJHV-128, SlHV-129, SJV-106.

SJV-106 RCS connection; standby system; II,A #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve OC. Assessed System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves SJHV-128, SJHV-129, SJV-130.

P-65 GSHV-20 No direct connection to RCS; IA #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs penetration flow path connects open System pressure boundary compromised 24 hrs 168 hrs 24 hrs system IC to open system OC; normally closed valve IC. Assessed with valve GSHV-2 1.

1to WO 04-0030 Page 45 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-65 GSHV-21 No direct connection to RCS; I,A #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs (cont) penetration flow path connects open System pressure boundary compromised 24 hrs 168 hrs 24 hrs system IC to open system OC; normally closed valve OC. Assessed with valve GSHV-20.

GSV-041 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-66 ENHV-12 No direct connection to RCS; 1,C #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to closed system OC; normally closed valve OC. Assessed with valve ENV-0 17.

ENV-080 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

ENV-017 No direct connection to RCS; I,C #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to closed system OC; normally closed valve IC. Assessed with valve ENHV-12.

P-67 KCHV-253 No direct connection to RCS; IA #2 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally closed valve OC. Assessed with valve KCV-478.

1to WO 04-0030 Page 46 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-67 KCV478 No direct connection to RCS; I,A #2 System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) penetration flow path connects open System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally closed valve IC. Assessed with valve KCV-253.

lKCV431 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 brs 168 hrs to result in a large release.

P-69 SJHV-12 RCS connection; standby system; ll,A #30a System pressure boundary maintained 24hrs 168 hrs 24 hrs normally closed valve IC; when System pressure boundary compromised 168 hrs 168 hrs 168 hrs system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves SJHV-13, SJV-071.

SJHV-13 RCS connection; standby system; H,A #30a System pressure boundary maintained 24 hrs 168 bra 24 hrs normally closed valve OC. Assessed System pressure boundary compromised 24 hrs 168 brs 24 hrs with valves SJHV-12, SJV-071.

SJV-071 RCS connection; standby system; II,A #2 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve OC. Assessed System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves SJHV-12, SJHV-13.

1to WO 04-0030 Page 47 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type CT: @ CT: CT P-71 EFHV-31 No direct connection to RCS; IB #20 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally open valve OC. Assessed with valve EFHV-33; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EFV-276 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EFHV-33 No direct connection to RCS; IB #20 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 72 hrs 168 hrs 72 hrs system IC to open system OC; normally open valve IC. Assessed with valve EFHV-3 1; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

P-73 EFHV45 No direct connection to RCS; IB #20 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 72 hrs 168 hrs 72 hrs system IC to open system OC; normally open valve IC. Assessed with valve EFHV-49; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EFV-277 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 48 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-73 EFHV49 No direct connection to RCS; I,B #20 System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally open valve OC. Assessed with valve EFHV-45; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

P-74 EGHV-58 No direct connection to RCS; I,B #7 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally open valve OC. Assessed with valves EGV-204, EGHV-127; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EGV-090 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EGV-204 No direct connection to RCS; I,B #7 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally open valve IC. Assessed with valves EGHV-58, EGHV-127; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

1to WO 04-0030 Page 49 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-74 EGHV-127 No direct connection to RCS; I,B #7 System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally closed valve OC. Assessed with valves EGHV-58, EGV-204; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

P-75 EGHV-60 No direct connection to RCS; I,B #22a System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 72 hrs 168 hrs 72 hrs system IC to open system OC; normally open valve IC. Assessed with valves EGHV-59, EGHV-131, EGHV-130; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EG-V372 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EGHV-59 No direct connection to RCS; I,B #22a System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally open valve OC. Assessed with valves EGHV-60, EGHV-1 31, EGHV-130; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

1to WO 04-0030 Page 50 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-75 EGHV-131 No direct connection to RCS; I,B #22a System pressure boundary maintained 72 hrs 168 hrs 72 hrs (cont) penetration flow path connects closed System pressure boundary compromised 72 hrs 168 hrs 72 hrs system IC to open system OC; normally closed valve OC. Assessed with valves EGHV-60, EGHV-59, EGHV-130; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EGHV-130 No direct connection to RCS; I,B #22a System pressure boundary maintained 72 hrs 168 hrs 72 hrs penetration flow path connects closed System pressure boundary compromised 24 hrs 168 hrs 24 hrs system IC to open system OC; normally closed valve IC. Assessed with valves EGHV-60, EGHV-59, EGHV-131; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

P-76 EGHV-62 No direct connection to RCS; I,B #22a System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects closed System pressure boundary compromised 72 hrs 168 hrs 72 hrs system IC to open system OC; normally open valve IC. Assessed with valves EGHV-61, EGHV-132, EGHV-133; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EGV-371 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 brs 168 hrs to result in a large release.

Attachment II to WO 04-0030 Page 51 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-76 EGHV-61 No direct connection to RCS; I,B #22a System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) penetration flow path connects closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to open system OC; normally open valve IC. Assessed with valves EGHV-62, EGHV-132, EGHV-133; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EGHV-132 No direct connection to RCS; I,B #22a System pressure boundary maintained 72 hrs 168 hrs 72 hrs penetration flow path connects closed System pressure boundary compromised 24 hrs 168 hrs 24 hrs system IC to open system OC; normally closed valve IC. Assessed with valves EGHV-62, EGHV-61, EGHV-133; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

EGHV-133 No direct connection to RCS; I,B #22a System pressure boundary maintained 72 hrs 168 hrs 72 hrs penetration flow path connects closed System pressure boundary compromised 72 hrs 168 hrs 72 hrs system IC to open system OC; normally closed valve OC. Assessed with valves EGHV-62, EGHV-61, EGHV-132; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

1to WO 04-0030 Page 52 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-78 BMV-045 No direct connection to RCS; B/c of IA #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs multiple closed valves between the System pressure boundary compromised 24 hrs 168 hrs 24 hrs IC CIV and the SG (WCGS P&ID drawing M-12BM1OI, Rev. 13), not considered a SG connection; therefore considered a connection from open system IC to open system OC.

BMV-302 No direct connection to RCS; B/c of small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs multiple closed valves between the System pressure boundary compromised 168 hrs 168 hrs 168 hrs IC CIV and the SG (WCGS P&ID drawing M-12BMOl, Rev. 13), not considered a SG connection; therefore considered a connection from open system IC to open system OC; flow path smaller in size than that required to result in a large release.

BMV-046 No direct connection to RCS; B/c of I,A #1 System pressure boundary maintained 24 hrs 168 hrs 24 hrs multiple closed valves between the System pressure boundary compromised 24 hrs 168 hrs 24 hrs IC CIV and the SG (WCGS P&ID drawing M-I2BMO1, Rev. 13), not considered a SG connection; therefore considered a connection from open system IC to open system OC.

1to WO 04-0030 Page 53 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-79 EJHV-8701A RCS connection; standby systemn; HA #35 & System pressure boundary maintained 4 hrs 4 hrs 4 hrs normally closed valve IC; extra valve I #23 System pressure boundary compromised 8 hrs 168 hrs 8 hrs upstream that also provides isolation; for boundary compromised, ECCS is considered a closed system and I,C

23 is applicable.

EJ8708A RCS connection; but no direct RCS I,C #23 System pressure boundary maintained 8 hrs 168 hrs 8 hrs to environment connection via this System pressure boundary compromised 8 hrs 168 hrs 8 hrs CIV, valve is IC; analyze as single CIV IC to closed system OC. ECCS is considered a closed system and I,C

23 is applicable.

EJV-154 RCS connection, but no direct RCS small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs to environment connection via this System pressure boundary compromised 168 hrs 168 hrs 168 hrs CIV; valve is IC; analyze as single CIV IC to closed system OC, flow path smaller in size that that required to result in a large release..

P-80 BGHV-8105 RCS connection; normally operating 11,B #3 System pressure boundary maintained 168 hrs 168 hrs 168 hrs system; normally open valve OC; 1 System pressure boundary compromised 168 hrs 168 hrs 168 hrs extra valve between MOV 8105 and charging pumps that also provide isolation; line isolated during accident. Assessed with valve BG8381; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

BGV-342 RCS connection; valve is IC; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size and small release System pressure boundary compromised 168 hrs 168 hrs 168 hrs would occur only within containment.

1to WO 04-0030 Page 54 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-80 BG8381 RCS connection; normally operating II,B #3 System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) system; check valve IC; extra check System pressure boundary compromised 168 hrs 168 hrs 168 hrs valve upstream that also provides isolation; line isolated during accident; when system pressure boundary is compromised, no longer an RCS connection. Assessed with valve BGHV-8105; Chose CT for an MOV based on guideline B of Section 9.1 of Reference 1.

P-82 EJHV-8809A RCS connection; standby system; HA #33 System pressure boundary maintained 72 hrs 4 hrs 4 hrs normally open valve OC. Assessed System pressure boundary compromised 72 hrs 4 hrs 4 hrs with valves EJV-054, EP8818A, EP8818B; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EJV-054 RCS connection; standby system; IlA #33 System pressure boundary maintained 72 hrs 4 hrs 4 hrs normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 4 hrs 4 hrs with valves EJHV-8809A, EP8818A, EP8818B; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EP8818A RCS connection; standby system; II,A #33 System pressure boundary maintained 8 hrs 4 hrs 4 hrs check valve IC; extra check valve System pressure boundary compromised 168 hrs 4 hrs 4 hrs upstream that also provides isolation.

Assessed with valves EJHV-8809A, EJV-054, EP8818B; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

1to WO 04-0030 Page 55 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc #_I Maintenance Activity Type @ CT: @ CT: CT P-82 EP8818B RCS connection; standby system; ll,A #33 System pressure boundary maintained 8 hrs 4 hrs 4 hrs (cont) check valve IC; extra check valve System pressure boundary compromised 168 hrs 4 hrs 4 hrs upstream that also provides isolation.

Assessed with valves EJHV-8809A, EJV-054, EP8818A; Chose CT for an MOV based on guideline A of Section 9.1 of Reference 1.

EJHCV-8890A RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR systern, flow path is smaller than minimum size required for a large release.

ENV-134, RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs V-136 release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system, flow path is smaller than minimum size required for a large release.

EJV-132 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system, flow path is smaller than minimum size required for a large release.

______________ J __________________________________________________ 2 ______________ 2 ___________ ______________

1to WO 04-0030 Page 56 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: CT: CT P-82 EJV-171, RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) EJV-172, release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs EJV-173, atmosphere to environment via the EJV-174 RHR system, flow path is smaller than mininmm size required for a large release.

P-83 to These penetrations are not covered -

P-86 under LCO 3.6.3 but under their own TS.

P-87 EMHV-8802A RCS connection; standby system; llA #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 168 hrs 72 hrs with valves EMV-001, EMV-002, EMV-051.

EMHV-8881 RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SI system, flow path is smaller than minimum size required for a large release.

EMV-001 RCS connection; standby system; II,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation; when system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMHV-8802A, EMV-002, EMV-051.

1to WO 04-0030 Page 57 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Vav GxGroup &I ICLERP I ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type CT: CT: CT P-87 EMV-002 RCS connection; standby system; ll,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs (cont) check valve IC; extra check valve System pressure boundary compromised 168 hrs 168 hrs 168 hrs upstream that also provides isolation; when system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMHV-8802A, EMV-001, EMV-051.

EMV-052, RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs V-053, V-055, release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs V-056, V-184, atmosphere to environment via the SI V-185 system, flow path is smaller than minimum size required for a large release.

EMV-051 RCS connection; standby system; II,A #32 System pressure boundary maintained 72 hrs 168 hrs 72 hrs normally closed valve OC. Assessed System pressure boundary compromised 72 hrs 168 hrs 72 hrs with valves EMHV-8802A, EMV-OO1, EMV-002.

EMV-186, RCS connection; valve is IC; only small line System pressure boundary maintained 168 hrs 168 hrs 168 hrn V-187 release path is from containment System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SI system, flow path is smaller than minimum size required for a large release.

1to WO 04-0030 Page 58 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Caic # Maintenance Activity Type @ CT: @ CT: CT P-88 EMHV-8801A RCS connection; standby system; ll,A #11 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve OC. Assessed System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves EMHV-8801B, EMV-8815.

EMHV-8801B RCS connection; standby system; HA #11 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve OC. Assessed System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves EMHV-8801A, EMV-8815.

EMV-077 RCS connection; standby system; small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs piping rated for RCS pressure; System pressure boundary compromised 168 hrs 168 hrs 168 hrs dominating flow path through valves EMHV-8801A, EMHV-8801B; large number of normally closed valves available to isolate; indirect RCS connection; given this scenario, flow path is also smaller in size than that required to result in a large release.

EMHV-8843 Indirect connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EMV-8815 RCS connection; standby system; II,A #11 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve IC; when System pressure boundary compromised 168 hrs 168 hrs 168 hrs system pressure boundary is compromised, no longer an RCS connection. Assessed with valves EMHV-8801A, EMHV-8801B.

1to WO 04-0030 Page 59 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justifled tion # Valve Grouping Explanation Caoc # Maintenance Activity Type @ CT: @ CT: CT P-88 EMV-151 RCS connection; standby system; small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) piping rated for RCS pressure; System pressure boundary compromised 168 hrs 168 hrs 168 hrs dominating flow path through valves EMHV-8801A, EMHV-8801B; large number of normally closed valves available to isolate; indirect RCS connection; given this scenario, flow path is also smaller in size than that required to result in a large release.

P-89 ENHV-06 No direct connection to RCS; I,C #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to closed system OC; normally closed valve OC. Assessed with valve ENV-013.

ENV-076 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

ENV-013 No direct connection to RCS; 1,C #4 System pressure boundary maintained 168 hrs 168 hrs 168 hrs penetration flow path connects open System pressure boundary compromised 168 hrs 168 hrs 168 hrs system IC to closed system OC; normally closed valve IC. Assessed with valve ENHV-06.

P-91N/A 2 lines within one penetration; ll,A #9 System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection to RCS; hydraulic sensor System pressure boundary compromised 168 hrs 168 hrs 168 hrs IC, LIS OC per line; 3/16" line.

1to WO 04-0030 Page 60 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-92 EMHV-8964 RCS connection; standby system; II,A #1 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve O; multiple System pressure boundary compromised 168 hrs 168 hrs 168 hrs extra valves upstream that also provide isolation (WCGS P&ID drawing M-12EMO1, Rev. 23).

Assessed with valves EMHV-8871, EMV-038.

4 4. 4 .4 EMV-153 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

EMHV-8871 RCS connection; standby system; ll,A #1 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve IC; when System pressure boundary compromised 168 hrs 168 hrs 168 hrs system pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT.

Assessed with valves EMIHV-8964, EMV-038.

EMV-038 RCS connection; standby system; II,A #1 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve OC. Assessed System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves EMHV-8964, EMHV-8871.

Attachment II to WO 04-0030 Page 61 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-93 SJHV-5 RCS connection; standby system; II,A #30b System pressure boundary maintained 48 hrs 168 hrs 48 hrs normally open valve IC; when system System pressure boundary compromised 168 hrs 168 hrs 168 hrs pressure boundary is compromised, no longer an RCS connection, flow path is smaller in size than that required to result in a large release, therefore is considered a 'small line' and given 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT. Assessed with valves SJHV-6, SJV-069, SJHV-127; Chose CT for an SOV based on guideline B of Section 9.1 of Reference 1.

4 1 *I. 4 4 4 SJHV-6 RCS connection; standby system; ll,A #30b System pressure boundary maintained 48 hrs 168 hrs 48 hrs normally open valve OC. Assessed System pressure boundary compromised 48 hrs 168 hrs 48 hrs with valves SJHV-5, SJV-069, SJHV-127; Chose CT for an SOV based on guideline B of Section 9.1 of Reference 1.

SJV-069 RCS connection; standby system; II,A #3 System pressure boundary maintained 168 hrs 168 hrs 168 hrs normally closed valve OC. Assessed I System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves SJHV-5, SJHV-6, SJHV-127; Chose CT for an SOV based on guideline B of Section 9.1 of Reference 1.

SJHV-127 RCS connection; standby system; ll,A #3 System pressure boundary maintained 168 hrs 168 brs 168 hrs normally closed valve OC. Assessed System pressure boundary compromised 168 hrs 168 hrs 168 hrs with valves SJHV-5, SJHV-6, SJV-069; Chose CT for an SOV based on guideline B of Section 9.1 of Reference 1.

1to WO 04-0030 Page 62 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-95 SJHV-1 8 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

SJHV-19 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

SJV-066 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-97 GSHV-18 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-17 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSV-036 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-33 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-34 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSV-052 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 63 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-98 KBV-OOl No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

KBV-002 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-99 GSHV-3 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV4 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-5 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSV-029 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-36 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-37 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSV-056 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 brs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 64 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: CT: CT P-101 GSHV-12 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-13 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-14 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSV-033 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-31 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSHV-32 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

GSV-050 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

P-103 Pressure No isolation valves involved in small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs Transmitter penetration; flow path smaller in size System pressure boundary compromised 168 hrs 168 hrs 168 hrs than that required to result in a large release 1to WO 04-0030 Page 65 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT P-104 Pressure No isolation valves involved in small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs Transmitter penetration; flow path smaller in size System pressure boundary compromised 168 hrs 168 hrs 168 hrs than that required to result in a large release E-256 Pressure No isolation valves involved in small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs Transmitter penetration; flow path smaller in size System pressure boundary compromised 168 hrs 168 brs 168 hrs than that required to result in a large release V-160 GTHZ-9 These penetrations have additional I,A #15 System pressure boundary maintained 12 hrs 168 hrs 12 hrs specs under 3.6.3. Normally closed or System pressure boundary compromised 12 hrs 168 hrs 12 hrs valve OC; valves 11 and 12 are I,A #15a if or if valve is open: or: or: or:

intermittently opened to provide for valves are System pressure boundary maintained 24 hrs 168 hrs 24 hrs containment min-purge during power open System pressure boundary compromised 24 hrs 168 hrs 24 hrs operation. Assessed with valves GTHZ-8, GTHZ-12, GTHZ-ll.

Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

GTHZ-8 These penetrations have additional I,A #15 System pressure boundary maintained 12 hrs 168 hrs 12 hrs specs under 3.6.3. Normally closed or System pressure boundary compromised 12 hrs 168 hrs 12 hrs valve IC; valves 11 and 12 are I,A #15a if or if valve is open: or: or: or:

intermittently opened to provide for valves are System pressure boundary maintained 24 hrs 168 hrs 24 hrs containment min-purge during power open System pressure boundary compromised 24 hrs 168 hrs 24 hrs operation. Assessed with valves GTHZ-9, GTHZ-12, GTHZ-ll.

Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

1to WO 04-0030 Page 66 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justifiled tion # Valve Grouping Explanation CaIc # Maintenance Activity Type @ CT: @ CT: CT V-1 60 GTHZ-12 These penetrations have additional IA #15 System pressure boundary maintained 12 hrs 168 brs 12 hrs (cont) specs under 3.6.3. Normally closed or System pressure boundary compromised 12 hrs 168 hrs 12 hrs valve OC; this valve is intermittently I,A #15a if or if valve is open: or: or: or:

opened to provide for containment valves are System pressure boundary maintained 48 hrs 168 hrs 48 hrs min-purge during power operation. open System pressure boundary compromised 48 hrs 168 hrs 48 hrs Assessed with valves GTHZ-9, GTHZ-8, GTHZ-1 1. Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

GTHZ-11 These penetrations have additional IA #15 System pressure boundary maintained 12 hrs 168 hrs 12 hrs specs under 3.6.3. Normally closed or System pressure boundary compromised 12 hrs 168 hrs 12 hrs valve IC; this valve is intermittently I,A #15a if or if valve is open: or: or: or:

opened to provide for containment valves are System pressure boundary maintained 48 hrs 168 hrs 48 hrs min-purge during power operation. open System pressure boundary compromised 48 hrs 168 hrs 48 hrs Assessed with valves GTHZ-9, GTHZ-8, GTHZ-12. Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

GTV0223 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hrs to result in a large release.

1to WO 04-0030 Page 67 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: @ CT: CT V-161 GTHZ-7 These penetrations have additional I,A #15 System pressure boundary maintained 12 hrs 168 hrs 12 hrs specs under 3.6.3. Normally closed or System pressure boundary compromised 12 hrs 168 hrs 12 hrs valve IC; valves 5 and 4 are I,A #15a if or if valve is open: or: or: or:

intermittently opened to provide for valves are System pressure boundary maintained 24 hrs 168 hrs 24 hrs containment min-purge during power open System pressure boundary compromised 24 hrs 168 hrs 24 hrs operation. Assessed with valves GTHZ-5, GTHZ-4, GTHZ-6. Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

GTHZ-5 These penetrations have additional I,A #15 System pressure boundary maintained 12 hrs 168 brs 12 hrs specs under 3.6.3. Normally closed or System pressure boundary compromised 12 hrs 168 hrs 12 hrs valve IC; this valve is intermittently I,A #15a if or if valve is open: or: or: or:

opened to provide for containment valves are System pressure boundary maintained 48 hrs 168 hrs 48 hrs min-purge during power operation. open System pressure boundary compromised 48 hrs 168 hrs 48 hrs Assessed with valves GTHZ-7, GTHZ-4, GTHZ-6. Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

GTHZ-4 These penetrations have additional I,A #15 System pressure boundary maintained 12 hrs 168 hrs 12 hrs specs under 3.6.3. Normally closed or System pressure boundary compromised 12 hrs 168 hrs 12 hrs valve OC; this valve is intermittently I,A #15a if or if valve is open: or: or: or:

opened to provide for containment valves are System pressure boundary maintained 48 hrs 168 hrs 48 hrs min-purge during power operation. open System pressure boundary compromised 48 hrs 168 hrs 48 hrs Assessed with valves GTHZ-7, GTHZ-5, GTHZ-6. Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

1to WO 04-0030 Page 68 of 68 WCGS Containment Isolation Valve Completion Time Results (cont.)

Penetra- Group & ICLERP ALERF Justified tion # Valve Grouping Explanation Calc # Maintenance Activity Type @ CT: ( CT: CT V-161 GTHZ-6 These penetrations have additional I,A #15 System pressure boundary maintained 12 hrs 168 hrs 12 hrs (cont) specs under 3.6.3. Normally closed or System pressure boundary compromised 12 hrs 168 hrs 12 hrs valve OC; valves 5 and 4 are IA #15a if or if valve is open: or: or: or:

intermittently opened to provide for valves are System pressure boundary maintained 24 hrs 168 hrs 24 hrs containment min-purge during power open System pressure boundary compromised 24 hrs 168 hrs 24 hrs operation. Assessed with valves GTHZ-7, GTHZ-5, GTHZ-4. Chose CT for an AOV based on guideline B of Section 9.1 of Reference 1.

GTV0222 No direct connection to RCS; flow small line System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required System pressure boundary compromised 168 hrs 168 hrs 168 hra to result in a large release.

Attachment III to WO 04-0030 Page 1 of 6 ATTACHMENT III MARKUP OF TECHNICAL SPECIFICATION PAGES

Attachment IlIl to WO 04-0030 Containment Isolation Valves Page 2 of 6 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE.

APPLICABILITY: MODES 1,2, 3, and 4.

ACTIONS LIT

_ _ __ __ __ _ _ _ _ _ _ _ _ t I I- - - -- - __

1. Penetration flow path(s) except for containment shutdown purge valve flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION I REQUIRED ACTION COMPLETION TIME A. -- A.1 Isolate the affected O yappli le to penetration flow path by enetra n flow ths use of at least one closed two c tainme isola n and de-activated valy s. / / automatic valve, closed manual valve, blind flange, or check valve with One 4penetration flow through the valve flow path with one secured.

,-f A containment isolation valve Wctv) ) inoperable except for AND E 2 purge valve leakage not within limit.

(continued)

Wolf Creek - Unit 1 3.6-7 Amendment No. 423,131

Attachment III to WO 04-0030 Page 3 of 6 INSERT 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Category I CIVs AND 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for Category 2 CIVs AND 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Category 3 ClVs AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Category 4 CIVs AND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for Category 5 CIVs AND 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for Category 6 CIVs AND 7 days for Category 7 CIVs

Attachment III to WO 04-0030 Page 4 of 6 Containment Isolation Valves 3.6.3 tfuloc &ckia~ylonsesto. 'S ACTIONS (continued)

CONDITION I REQUIRED ACTION I COMPLETION TIME A. (continued) A.2 --- NOTES--

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

Verify the affected Once per 31 days penetration flow path is for isolation isolated. devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment L a (continued)

Wolf Creek - Unit 1 3.6-8 Amendment No. 123

Attachment III to WO 04-0030 Containment Isolation Valves Page 5 of 6 3.6.3 ACTIONS (crntinued)

CONDITION REQUIRED ACTION COMPLETION TIME B. ----------NOTE-B.1 Isolate the affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to penetration flow path by penetration flow paths with use of at least one closed two containment isolation and de-activated valves. automatic valve, closed manual valve, or blind flange.

One or more penetration flow paths with two containment isolation valves inoperable except for containment purge valve leakage not within limit.

C.. TE C more. ?CAA* C.l IS all btone- 4 hS

~~~~~ecvV'flout Cte.w1XO FhSon -x0 t' XLeatnoRolnah* %t& L

&Lr*Drruf L. valve Go.sa reonayA or.1W

nasvv, C~fi*Wr D. artwe.

Wolf Creek - Unit 1 3.6-9 Amendment No. 123

Attachment IlIl to WO 04-0030 Containment Isolation Valves Page 6 of 6 3.6.3 Wolf Creek - Unit 1 3.6-1 0 Amendment No. 123

Attachment IV to WO 04-0030 Page 1 of 18 ATTACHMENT IV RETYPED TECHNICAL SPECIFICATION PAGES

TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.6 Containment Purge Isolation Instrumentation ................... ............... 3.3-46 3.3.7 Control Room Emergency Ventilation System (CREVS)

Actuation Instrumentation .. 3.3-50 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation ........................... 3.3-55 3.4 REACTOR COOLANT SYSTEM (RCS) ........................... 3.4-1 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits ................................................... 3.4-1 3.4.2 RCS Minimum Temperature for Criticality ........................................ 3.4-5 3.4.3 RCS Pressure and Temperature (PIT) Limits ................... ............... 3.4-6 3.4.4 RCS Loops - MODES 1 and 2.......................................................... 3.4-8 3.4.5 RCS Loops - MODE 3................................................... 3.4-9 3.4.6 RCS Loops - MODE 4................................................... 3.4-12 3.4.7 RCS Loops - MODE 5, Loops Filled ................................................. 3.4-14 3.4.8 RCS Loops - MODE 5, Loops Not Filled ................................. ......... 3.4-17 3.4.9 Pressurizer ................................................... 3.4-19 3.4.10 Pressurizer Safety Valves ................................................... 3.4-21 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) ....................... 3.4-23 3.4.12 Low Temperature Overpressure Protection (LTOP) System ......... .. 3.4-26 3.4.13 RCS Operational LEAKAGE ................................................... 3.4-31 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage .................................. 3.4-33 3.4.15 RCS Leakage Detection Instrumentation ......................................... 3.4-37 3.4.16 RCS Specific Activity ................................................... 3.4-41 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) .............................. 3.5-1 3.5.1 Accumulators ................................................... 3.5-1 3.5.2 ECCS - Operating ................................................... 3.5-3 3.5.3 ECCS - Shutdown ................................................... 3.5-6 3.5.4 Refueling Water Storage Tank (RWST) ........................................... 3.5-8 3.5.5 Seal Injection Flow ................................................... 3.5-10 3.6 CONTAINMENT SYSTEMS ..................... .............................. 3.6-1 3.6.1 Containment ................................................... 3.6-1 3.6.2 Containment Air Locks................................................... 3.6-2 3.6.3 Containment Isolation Valves .................................................... 3.6-7 3.6.4 Containment Pressure .................... ............................... 3.6-14 3.6.5 Containment Air Temperature ................................................... 3.6-15 3.6.6 Containment Spray and Cooling Systems ............................ ............ 3.6-16 3.6.7 Spray Additive System .................... ............................... 3.6-19 3.6.8 Hydrogen Recombiners ................................................... 3.6-21 Wolf Creek - Unit 1 ii Amendment No. 123,131,

Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE.

APPLICABILITY: MODES 1, 2,3, and 4.

ACTIONS NOTES

1. Penetration flow path(s) except for containment shutdown purge valve flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment,' when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A. One penetration flow path A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for with one containment penetration flow path by Category I CIVs isolation valve (CIV) use of at least one closed inoperable except for and de-activated AND purge valve leakage not automatic valve, closed within limit. manual valve, blind 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for flange, or check valve with Category 2 CIVs flow through the valve secured. AND AND 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Category 3 CIVs AND (continued)

Wolf Creek - Unit 1 3.6-7 Amendment No. 123, 131,

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Category 4 CIVs AND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for Category 5 CIVs AND 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for Category 6 CIVs AND 7 days for Category 7 CIVs A.2 -ONOTES

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

Verify the affected Once per 31 days penetration flow path is for isolation isolated. devices outside containment AND (continued) l Wolf Creek - Unit 1 3.6-8 Amendment No. 423,

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION IME A. (continued) Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment B. - NOTE B.1 Isolate the affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to penetration flow path by penetration flow paths with use of at least one closed two containment isolation and de-activated valves. automatic valve, closed manual valve, or blind flange.

One or more penetration flow paths with two containment isolation valves inoperable except for containment purge valve leakage not within limit.

C. Two or more penetration C.1 Isolate all but one 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with one penetration flow path by containment isolation valve use of at least one closed inoperable for reasons and de-activated other than Condition D. automatic valve, closed manual valve, or blind flange.

(continued)

Wolf Creek - Unit 1 3.6-9 Amendment No. A,

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more D.1 Isolate the affected 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months penetration flow penetration flow paths by paths with one or use of at least one closed more containment and de-activated purge valves not automatic valve, closed within leakage limits. manual valve, or blind flange.

AND D.2 NOTES

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

Verify the affected Once per 31 days penetration flow path is for isolation isolated. devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment AND (continued) l Wolf Creek - Unit 1 3.6-1 0 Amendment No. 423,

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.3 Perform SR 3.6.3.6 or Once per 92 days SR 3.6.3.7 for the resilient seal purge valves closed to comply with Required Action D.1.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND E.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each containment shutdown purge valve is Once per 31 days sealed closed or closed and blind flange installed for isolation except for one purge valve in a penetration flow path devices outside while in Condition D of this LCO. containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment (continued)

Wolf Creek - Unit I 3.6-1 1 Amendment No. 123,1 31-, l

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.2 Verify each containment mini-purge valve is closed, 31 days except when the containment mini-purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open.

SR 3.6.3.3 NOTE Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve and 31 days blind flange that is located outside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

SR 3.6.3.4 NOTE Valves and blind flanges in high radiation areas may be verified by use of administrative means.

Verify each containment isolation manual valve and Prior to entering blind flange that is located inside containment and not MODE 4 from locked, sealed, or otherwise secured and required to MODE 5 if not be closed during accident conditions is closed, except performed within for containment isolation valves that are open under the previous administrative controls. 92 days SR 3.6.3.5 Verify the isolation time of each automatic power In accordance with operated containment isolation valve is within limits. the Inservice Testing Program (continued)

Wolf Creek - Unit 1 3.6-12 Amendment No. 423, 1

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued) T SURVEILLANCE FREQUENCY 4.

& IT-SR 3.6.3.6 IV& i I I- ______

Only required to be peiformed when containment shutdown purge valve blind flanges are installed.

Perform leakage rate testing for containment 24 months shutdown purge valves with resilient seals and associated blind flanges. AND Following each reinstallation of the blind flange SR 3.6.3.7 -NOTE-Only required to be performed for the containment shutdown purge valves when associated blind flanges are removed.

Perform leakage rate testing for containment 184 days mini-purge and shutdown purge valves with resilient seals. AND Within 92 days after opening the valve SR 3.6.3.8 Verify each automatic containment isolation valve 18.months that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

Wolf Creek - Unit 1 3.6-1 3 Amendment No. A29, 1

Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment pressure shall be 2 -0.3 psig and < + 1.5 psig.

APPLICABILITY: MODES 1, 2,3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure not A.1 Restore containment 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within limits. pressure to within limits.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Wolf Creek - Unit 1 3.6-14 Amendment No. A24, 1

Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature L00 3.6.5 Containment average air temperature shall be

1200F.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment average air A.1 Restore containment 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within average air temperature limit. to within limit.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit.

Wolf Creek - Unit 1 3.6-15 Amendment No. 423, 1

Containment Spray and Cooling Systems 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2,3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable. spray train to OPERABLE status. AND 10 days from discovery of failure to meet the LCO B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months C. One containment cooling C.1 Restore containment 7 days train inoperable. cooling train to OPERABLE status. AND 10 days from discovery of failure to meet the LCO (continued)

Wolf Creek - Unit 1 3.6-16 Amendment No. 423, 1

Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two containment cooling D.1 Restore one containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months trains inoperable. cooling train to OPERABLE status.

E. Required Action and E.i Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C or D AND not met.

E.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two containment spray F.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more trains inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power 31 day operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

SR 3.6.6.2 Operate each containment cooling train fan unit for 31 days 2 15 minutes.

(continued)

Wolf Creek - Unit 1 3.6-1 7 Amendment No. 423, l

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.3 Not Used.

SR 3.6.6.4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equal to the Inservice the required developed head. Testing Program SR 3.6.6.5 Verify each automatic containment spray valve in the 18 months flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.6.6.6 Verify each containment spray pump starts 18 months automatically on an actual or simulated actuation signal.

SR 3.6.6.7 Verify each containment cooling train starts 18 months automatically and minimum cooling water flow rate is established on an actual or simulated actuation signal.

SR 3.6.6.8 Verify each spray nozzle is unobstructed. 10 years Wolf Creek - Unit 1 3.6-18 Amendment No. Q43, I

Spray Additive System 3.6.7 3.6 CONTAINMENT SYSTEMS 3.6.7 Spray Additive System LCO 3.6.7 The Spray Additive System shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Spray Additive System A.1 Restore Spray Additive 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. System to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify each spray additive manual, power operated, 31 days and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

(continued)

Wolf Creek - Unit 1 3.6-1 9 Amendment No. 423, l

Spray Additive System 3.6.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.7.2 Verify spray additive tank solution volume Is 2 4340 184 days gal and

4540 gal.

SR 3.6.7.3 Verify spray additive tank solution concentration is 184 days

Ž 28% and

31% by weight.

SR 3.6.7.4 Verify each spray additive automatic valve in the flow 18 months path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.6.7.5 Verify spray additive flow rate from each solution's 5 years flow path.

Wolf Creek - Unit 1 3.6-20 Amendment No. 423, I

Hydrogen Recombiners 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen Recombiners LCO 3.6.8 Two hydrogen recombiners shall be OPERABLE.

APPLICABILITY: MODES I and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen recombiner A.1 - NOTE inoperable. LCO 3.0.4 is not applicable.

Restore hydrogen 30 days recombiner to OPERABLE status.

B. Two hydrogen B.1 Verify by administrative 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months recombiners inoperable. means that the hydrogen control function is AND maintained.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Restore one hydrogen 7 days recombiner to OPERABLE status.

(continued)

Wolf Creek - Unit 1 3.6-21 Amendment No. 423, l

Hydrogen Recombiners 3.6.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.8.1 Perform a system functional test for each hydrogen 18 months recombiner.

SR 3.6.8.2 Visually examine each hydrogen recombiner 18 months enclosure and verify there is no evidence of abnormal conditions.

SR 3.6.8.3 Perform a resistance to ground test for each heater 18 months phase.

Wolf Creek - Unit 1 3.6-22 Amendment No. 423, l

Attachment V to WO 04-0030 Page 1 of 13 ATTACHMENT V PROPOSED BASES CHANGES (for Information only)

Attachment V to WO 04-0030 Containment Isolation Valves Page 2 of 13 B 3.6.3 BASES ACTIONS In the event the containment isolation valve leakage results in exceeding (continued) the overall containment leakage rate acceptance criteria, Note 4 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1.

A.1 and A.2 In the event one containment isolation valve in one penetration flow pathois inoperable except for purge valve leakage not within limit, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve (this includes power operated valves with power removed),

a blind flange, or a check valve with flow through the valve secured. For a penetration flow path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one spiici-e ,Spfiftl.

c to containment. The isolation barrier utilized to satisfy Required Action XCt4,meet A.1 must have been demonstrated to meet the leakage requirements of ientli4

^ vaws 3.6.1.1. Required Action A.1 must be completed within KT n /SR ka~e 1 B Tvk3-Sc Cp^\4h~{Om,>to is W s i e r~Irdo,

\i~te th~eegto a9lh eaiemo~c spon twY11s or onta- entERB IT ig OD 1,2 nd >

@ eaffected penetration flow path that cannot be restored to OPERABLE status within th Completion Time and that have been isolated in aere d Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification, through a system walkdown (which may include the use of local or remote indicators), that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

Condition A ea ic t is.cgd' iis ip pplicable to 0penetration flow paths with two containment Wolf Creek - Unit 1 B 3.6.3-5 Revision 8

Attachment V to WO 04-0030 Containment Isolation Valves Page 3 of 13 B 3.6.3 BASES ACTIONS A.1 and A.2 (contin ,

isolation valves6Z penetration flow paths with only one containment isolation valve and a closed s Required Action A.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. Therefore, the probability of misalignment of these devices once they have been verified to be in the proper position, is small.

B.1 With two containment isolation valves in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve (this includes power operated valves with power removed), and a blind flange. For a penetration flow path isolated in accordance with Required Action B.1, the device used to isolate the penetration should be the closest available one to containment. The isolation barrier utilized to satisfy Required Action B.1 must have been demonstrated to meet the leakage requirements of SR 3.6.1.1. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1. In the event the affected penetration Is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative control and the probability of their misalignment is low.

Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two containment isolation valves.

MotWne~ionJ16 puswjkron~lobneqofita~in_ fit isptaffontava D 9'aprrrai' Wolf Creek - Unit 1 B 3.6.3-6 Revision 8

Attachment V to WO 04-0030 Containment Isolation Valves Page 4 of 13 B 3.6.3 BASES ACTIONS C.1r6.2_

( nith ondor mor penetratio flow paths one cont ment isol n valve* opera , the ino rable valve w path mu be restore o OP BL status or t affected p etration flb path must e isolated.

e met d of isola in must inclu e the use o t least one solation arrie at canno e adversely ected by single activ failure.

Iso ion barrie hat meet thi criterion ar a closed a de-activ d omatic va e, a closed nual valve nd a blind nge. For penetratio flow path iso ed in acco ance with equired A ion C.1, t device ed to isolateie penetrati should bhe close available ne to co ainment. Trisolation b ier utilizedo satisfy quired A on C.must have b n demonstr ed to me the leaka require nts of 3.6.1.1. eckvalve aynot be edtoisol the affed penetration ow path. R uired Actn C.1 mu e compeed withi he 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ompletion T e. The s ecified tim period is asona considing the rela e stabili f the cbs systemIence, r ability act a a penetrati isolation oundary d the rel ive impance m taining co inment ERABILIT durin DES 1 3 a 4.

rhe closed system must meet the reurmn of Reeec 5T Containment Spray System and ECCS are closed ESF-grade systems B 3.6.3 - outside tcontainment, which meetrthe requirementsof Reference 5,and serve as the second containment isolation barrier (Rep 1td rif te pe ieted tration fi accordtis lae with quired Acta ethe al esed penr tionnowd a must feveroliad te onditio C ies odifdc basy his peaidic vet ich is neiinis ton assupplic clItmeh enetratioflo p requirinh ol ation tin an acdin a isolate sphe Comaytion Times once aIon dats.

opfyineat eac flop d pepwtration ampath is lat v e riate eca ti e va s aa r ovpeMe undtrop inist fve ns t Re ired Ac ir misa mo ent is ot t l d nbitiond as modice bn i r icati ion at athis ls dithe ices obvricf to thos enetratiofAw pativ meh only ow invercti byadmi sratIve in a close s temr is Note isince a sssto thi areastyicalls yg n spectd.ly to appress thesolenetration ice aths bc d, sealed, o thewishecured in p isolation devc CodtosA and B~poie th aprritReuired Ats Re red Actiopd ism mo ;d by twotes Note,1ppies to v;s Hdblind flag es locatepi higjh radi~fo aes ai alows the devices; Aobe verifit closed bhuse of ad mistrative me fs . Allowin vrificatig by admip srative m~asis consi rd acceptle, since a ksst te aesityial stitd. Ng~ 2 applies tpioaindvces thaar ler doherisecued n piton ndfwsthe device Wolf Creek - Unit 1 B 3.6.3-7 Revision 8

Attachment V to WO 04-0030 Page 5 of 13 INSERT B-1 C.I In the event one containment isolation valve in two or more penetration flow paths is inoperable, except for purge valve or shield building bypass leakage not within limit, all but one of the affected penetration flow path(s) must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured. For a penetration flow path isolated in accordance with C. 1, the device used to isolate the penetration should be the closest available one to containment. Required Action C.1 must be completed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . For the penetration flow paths isolated in accordance with Required Action C.1, the affected penetration(s) must be verified to be isolated on a periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure that the penetrations requiring isolation following an accident are isolated. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting Containment OPERABILITY during MODES 1, 2, 3, and 4.

Attachment V to WO 04-0030 Containment Isolation Valves Page 6 of 13 B 3.6.3 BASES ACTIONS an (cont to e verifie osed by us of administrve mean.Aowing ye ation iyadmin tftve meas cosdracceptab esince h yzino lockin sealing, or curing com

, ents is t nsure that t se devices arenot inadvert ly repositio d. Theref e, the proba ity of vlonc ISainenShs en Chae to be ie

_ffe D.1. D.2. and D.3 In the event one or more containment shutdown or mini-purge valves in one or more penetration flow paths are not within the leakage limits, leakage must be restored to within limits, or the affected penetration flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve (this includes power operated valves with power removed), or blind flange. A containment shutdown purge or mini-purge valve with resilient seals utilized to satisfy Required Action D.1 must have been demonstrated to meet the leakage requirements of SR 3.6.3.6 or SR 3.6.3.7. The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containment does not exist.

In accordance with Required Action D.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or valve manipulation.

Rather, it involves verification, through a system walkdown (which may include the use of local or remote indicators), that those isolation devices outside containment capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

For the containment purge valve with resilient seal that is isolated in accordance with Required Action D.1, SR 3.6.3.6 or SR 3.6.3.7 must be performed at least once every 92 days. This assures that degradation of the resilient seal is detected and confirms that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated. The normal Frequency for SR 3.6.3.7, 184 days, is based on an NRC initiative, Multi-Plant Action No. B-20 (Ref. 3). Since more reliance is placed on a single valve while in this Condition, it is Wolf Creek - Unit 1 B 3.6.3-8 Revision 8 1

Attachment V to WO 04-0030 Containment Isolation Valves Page 7 of 13 B 3.6.3 BASES REFERENCES 6. NUREG-0881, 'Safety Evaluation Report related to the operation of (continued) Wolf Creek Generating Station, Unit No. 1,0 Section 6.2.3, April 1982.

7. NRC letter dated March 29, 2001, "Relief Request from the Requirements of ASME Code, Section Xl, Related to Code Case OMN-1 for Wolf Creek Generating Station (TAC NO. MB0982)."

of Extnsons t& rrtinnexr 1s0tafun alev C&DplsetA J S S-ace"A 2it0t4.v Wolf Creek - Unit I B 3.6.3-14 Revision 9

Attachment V to WO 04-0030 Page 8 of 13 INSERT B-2 TABLE B 3.6.3-1 (Page 1 of 6)

CONTAINMENT ISOLATION VALVES - COMPLETION TIMES VALVE PENETRATION NO. CATEGORYICOMPLETION TIME BBHV-8026 P-62 Category 7 7 days BBHV-8027 P-62 Category 7 7 days BBHV-8351A P-41 Category 7 7 days BBHV-8351 B P-22 Category 7 7 days BBHV-8351C P-39 Category 7 7 days BBHV-8351 D P-40 Category 7 7 days BBV-1 18 P-41 Category 7 7 days BBV-148 P-22 Category 7 7 days BBV-178 P-39 Category 7 7 days BBV-208 P-40 Category 7 7 days BBV-245 P-41 Category 7 7 days BBV-246 P-22 Category 7 7 days BBV-247 P-39 Category 7 7 days BBV-248 P-40 Category 7 7 days BBV-352 P-41 Category 7 7 days BBV-354 P-22 Category 7 7 days BBV-356 P-39 Category 7 7 days BBV-358 P40 Category 7 7 days BG-8381 P-80 Category 7 7 days BGHV-8100 P-24 Category 7 7 days BGHV-8105 P-80 Category 7 7 days BGHV-8112 P-24 Category 7 7 davs BGHV-8152 P-23 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months BGHV-8160 P-23 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months BGV-135 P-24 Category 7 7 days BGV-342 P-80 Category 7 7 days BGV-363 P-23 Category 7 7 days BGV-457 P-24 Category 7 7 days BL-8046 P-25 Category 7 7 days BLHV-8047 P-25 Category 7 7 days BLV-054 P-25 Category 7 7 days BMV-045 P-78 Categor 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months BMV-046 P-78 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months BMV-302 P-78 Category 7 7 days ECV-083 P-53 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ECV-084 P-53 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ECV-085 P-53 Category 7 7 days ECV-086 P-54 Category 7 7 days ECV-087 P-54 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ECV-088 P-54 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ECV-094 P-55 Category 7 7 days ECV-095 P-55 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ECV-096 P-55 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EFHV-31 P-71 Category 7 7 days

Attachment V to WO 04-0030 Page 9 of 13 TABLE B 3.6.3-1 (Page 2 of 6)

CONTAINMENT ISOLATION VALVES - COMPLETION TIMES VALVE PENETRATION NO. CATEGORY/COMPLETION TIME EFHV-32 P-28 Category 7 7 days EFHV-33 P-71 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EFHV-34 P-28 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EFHV-45 P-73 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EFHV-46 P-29 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EFHV-49 P-73 Category 7 7 days EFHV-50 P-29 Category 7 7 days EFV-276 P-71 Category 7 7 days EFV-277 P-73 Category 7 7 days EFV-278 P-28 Category 7 7 days EFV-279 P-29 Category 7 7 days EGHV-127 P-74 Category 7 7 days EGHV-130 P-75 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EGHV-131 P-75 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EGHV-132 P-76 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EGHV-133 P-76 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EGHV-58 P-74 Category 7 7 days EGHV-59 P-75 Category 7 7 days EGHV-60 P-75 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EGHV-61 P-76 Category 7 7 days EGHV-62 P-76 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EGV-090 P-74 Category 7 7 days EGV-204 P-74 Category 7 7 days EGV-371 P-76 Category 7 7 days EGV-372 P-75 Category 7 7 days EJ-8708A P-79 Category 2 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months EJ-8708B P-52 Category 2 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months EJ-8841A P-21 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EJ-8841 B P-21 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EJHCV-8825 P-21 Category 7 7 days EJHCV-8890A P-82 Category 7 7 days EJHCV-8890B P-27 Category 7 7 days EJHV-23 P-1 5 Category 7 7 days EJHV-24 P-14 Category 7 7 days EJHV-25 P-15 Category 7 7 days EJHV-26 P-14 Category 7 7 days EJHV-8701A P-79 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EJHV-8701 B P-52 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EJHV-8809A P-82 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EJHV-8809B P-27 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EJHV-8811A P-15 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EJHV-881 I B P-14 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EJHV-8840 P-21 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EJV-054 P-82 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EJV-056 P-21 Category 6 72 hours EJV-058 P-27 Category 1 4 hours

Attachment V to WO 04-0030 Page 10 of 13 TABLE B 3.6.3-1 (Page 3 of 6)

CONTAINMENT ISOLATION VALVES - COMPLETION TIMES VALVE PENETRATION NO. CATEGORY/COMPLETION TIME EJV-086

_ P-27 Category 7 7 days EJV-088, -090 P-27 Category 7 7 days EJV-118, 120 P-21 Category 7 7 days EJV-122 P-21 Category 7 7 days EJV-124 P-21 Category 7 7 days EJV-132 P-82 Category 7 7 days EJV-134,-136 P-82 Category 7 7 days EJV-154 P-79 Category 7 7 days EJV-166 P-27 Category 7 7 days EJV-171, -172, -173, -174 P-82 Category 7 7 days EJV-175, -176, -177, -178 P-21 Category 7 7 days EJV-179, -180, -181, -182 P-27 Category 7 7 days EJV-187 P-15 Category 7 7 days EJV-189 P-14 Category 7 7 davs EMHV-8801A P-88 Category 7 7 days EMHV-8801 B P-88 Category 7 7 days EMHV-8802A P-87 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EMHV-8802B P-48 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EMHV-8823 P-49 Category 7 7 days EMHV-8824 P-48 Category 7 7 days EMHV-8835 P-49 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EMHV-8843 P-88 Category 7 7 days EMHV-8871 P-92 Category 7 7 days EMHV-8881 P-87 Category 7 7 days EMHV-8888 P-58 Category 7 7 days EMHV-8964 P-92 Category 7 7 days EMV-001 P-87 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EMV-002 P-87 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EMV-003 P48 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EMV-004 P48 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EMV-006 P-58 Category 7 7 days EMV-038 P-92 Category 7 7 days EMV-051 P-87 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EMV-052, -053, -055, -056, P-87 Category 7 7 days

-184, -185 EMV-059 P-48 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months EMV-060, -061, -063, -064, P48 Category 7 7 days EMV-067 P49 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EMV-068, -069, -070, -071, P-49 Category 7 7 days

-072, -073, -074, -075 EMV-077 P-88 Category 7 7 days EMV-123 P-58 Category 7 7 days EMV-151 P-88 Category 7 7 davs EMV-153 P-92 Category 7 7 days EMV-1 62, -163, -164, -165, P49 Category 7 7 days

-166, -167, -168

Attachment V to WO 04-0030 Page 11 of 13 TABLE B 3.6.3-1 (Page 4 of 6)

CONTAINMENT ISOLATION VALVES - COMPLETION TIMES VALVE PENETRATION NO. CATEGORYICOMPLETION TIME EMV-169, -217 P-48 Category 7 7 days EMV-170, -172 P-48 Category 7 7 days EMV-182 P-58 Category 7 7 days EMV-186, -187 P-87 Category 7 7 days EMV-218 P-49 Category 7 7 days EMV-8815 P-88 Category 7 7 days ENHV-06 P-89 Category 7 7 days ENHV-01 P-16 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ENHV-07 P-1 3 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ENHV-12 P-66 Category 7 7 days ENV-013 P-89 Category 7 7 days ENV-017 P-66 Category 7 7 days ENV-076 P-89 Category 7 7 days ENV-080 P-66 Category 7 7 days EP-8818A P-82 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EP-8818B P-82 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EP-8818C P-27 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EP-8818D P-27 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EPHV-8880 P-45 Category 7 7 days EPV-010 P49 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EPV-020 P.49 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EPV-030 P-49 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EPV-040 P-49 Category 1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EPV-043 P-45 Category 7 7 days EPV-046 P.45 Category 7 7 days GPV-010 P-34 Category 7 7 davs GPV-011 P-51 Category 7 7 days GPV-012 P-51 Category 7 7 days GSHV-12 P-101 Category 7 7 days GSHV-13 P-101 Category 7 7 days GSHV-14 P-101 Category 7 7 days GSHV-17 P-97 Category 7 7 days GSHV-18 P-97 Category 7 7 days GSHV-20 P-65 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months GSHV-21 P-65 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months GSHV-3 P-99 Category 7 7 days GSHV-31 P-101 Category 7 7 days GSHV-32 P-101 Category 7 7 days GSHV-33 P-97 Category 7 7 days GSHV-34 P-97 Category 7 7 days GSHV-36 P-99 Category 7 7 days GSHV-37 P-99 Category 7 7 days GSHV-38 P-56 Category 7 7 days GSHV-39 P-56 Category 7 7 days GSHV-4 P-99 Category 7 7 days GSHV-5 P-99 Category 7 7 days

Attachment V to WO 04-0030 Page 12 of 13 TABLE B 3.6.3-1 (Page 5 of 6)

CONTAINMENT ISOLATION VALVES - COMPLETION TIMES VALVE PENETRATION NO. CATEGORYICOMPLETION TIME GSHV-8 P-56 Category 7 7 days GSHV-9 P-56 Category 7 7 days GSV-029 P-99 Category 7 7 days GSV-032 P-56 Category 7 7 days GSV-033 P-99 Category 7 7 days GSV-036 P-97 Category 7 7 days GSV-041 P-65 Category 7 7 days GSV-050 P-101 Category 7 7 days GSV-052 P-97 Category 7 7 days GSV-056 P-101 Category 7 7 days GSV-058 P-56 Category 7 7 days GTHZ-1 I V-160 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GTHZ-12 V-160 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GTHZ-4 V-161 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GTHZ-5 V-161 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GTHZ-6 V-161 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GTHZ-7 V-161 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GTHZ-8 V-160 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GTHZ-9 V-160 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GTV-222 V-161 Category 7 7 days GTV-223 V-160 Category 7 7 days HBHV-7126 P-44 Category 7 7 days HBHV-7136 P-26 Category 6 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months HBHV-7150 P-44 Category 7 7 days HBHV-7176 P-26 Category 5 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months HBV-419 P-26 Category 7 7 days HBV-420 P-44 Category 7 7 days HDV-016 P-43 Category 7 7 days HDV-017 P-43 Category 7 7 days HDV-023 P43 Category 7 7 days KAFV-29 - P-30 Category 7 7 days KAV-039 P-63 Category 7 7 days KAV-1_18 P-63 Category 7 7 days KAV-163 P-63 Category 7 7 days KAV-204 P-30 Category 7 7 days KAV-218 P-30 Category 7 7 days KBV-001 P-98 Category 7 7 days KBV-002 P-98 Category 7 7 days KCHV-253 P-67 Category 7 7 days KCV-431 P-67 Category 7 7 days KCV-478 P-67 Category 7 7 days LFFV-95 P-32 Category 7 7 days LFFV-96 P-32 Category 7 7 days LFV-093 P-32 Category 7 7 days SJHV-12 P-69 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SJHV-127 P-93 Category 7 7 days

Attachment V to WO 04-0030 Page 13 of 13 TABLE B 3.6.3-1 (Page 6 of 6)

CONTAINMENT ISOLATION VALVES - COMPLETION TIMES VALVE PENETRATION NO. CATEGORYICOMPLETION TIME SJHV-128 P-64 Category 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SJHV-129 P-64 Category 7 7 days SJHV-13 P-69 Category 4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SJHV-130 P-64 Category 7 7 days SJHV-131 P-57 Category 7 7 days SJHV-132 P-57 Category 7 7 days SJHV-18 P-95 Category 7 7 days SJHV-19 P-95 Category 7 7 days SJHV-5 P-93 Category 5 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months SJHV-6 P-93 Category 5 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months SJV-066 P-95 Category 7 7 days SJV-069 P-93 Category 7 7 days SJV-071 P-69 Category 7 7 days SJV-106 P-64 Category 7 7 days SJV-111 P-57 Category 7 7 days SJV-1 14 P-57 Category 7 7 days

Attachment VI to WO 04-0030 Page 1 of 1 LIST OF COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation (WCNOC) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Kevin Moles, Manager Regulatory Affairs at Wolf Creek Generating Station, (620) 364-4126.

COMMITMENT Due Date/Event WCNOC requests approval of the proposed license amendment Within 90 days of by August 31, 2005. Once approved, this amendment will be NRC approval.

implemented within 90 days.

WO 04-0030, Revision to Technical Specification 3.6.3, Containment Isolation Valves

Contents

Text

References:

Subject:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

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WO 04-0030, Revision to Technical Specification 3.6.3, Containment Isolation Valves

Text

References:

Subject:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

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