ML13234A069

McGuire, Units 1 and 2 - Relief Request Serial #13-MN-002, Risk-Informed Inservice Inspection Program Fourth Inservice Inspection Interval

ML13234A069
Person / Time
Site:	Mcguire, McGuire
Issue date:	08/13/2013
From:	Capps S D Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13234A069 (214)

Text

Steven D. CappsVice President ENERGY, 1McGuire Nuclear StationDuke EnergyMG01VP 1 12700 Hagers Ferry RoadHuntersville, NC 28078o: 980.875.4805 f: 980.875.4809 Steven.Capps@du ke-energy.com August 13, 2013 10 CFR 50.55aU. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station, Units 1 and 2Docket Nos. 50-369 and 50-370Relief Request Serial #1 3-MN-002Risk-Informed Inservice Inspection ProgramFourth Inservice Inspection IntervalPursuant to 10 CFR 50.55a(a)(3)(i),

Duke Energy hereby submits Relief Request (RR)13-MN-002 to propose the use of Risk-Informed Inservice Inspection (RI-ISI) program as analternative to the American Society of Mechanical Engineers (ASME) Section Xl, ISI program forClass 1 and 2 (Examination Categories B-F, B-J, C-F-i, and C-F-2) piping welds. The RI-ISIprogram used in this submittal is based on ASME Code Case N-716, "Alternative PipingClassification and Examination Requirements,Section XI, Division 1."Duke Energy requests NRC's approval of this RR by July 31, 2014 to support Unit 1 refueling outage in the fall of 2014.The enclosure to this letter contains this relief request.

If you have any questions or requireadditional information, please contact P.T. Vu at (980) 875-4302.

Sincerely, Steven D. CappsEnclosure

• q7www.duke-energy.com U. S. Nuclear Regulatory Commission August 13, 2013Page 2xc:Victor McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, GA 30303-1257 Jason Paige, Project ManagerU. S. Nuclear Regulatory Commission 11555 Rockville PikeMail Stop O-8G9ARockville, MD 20852-2738 John ZeilerNRC Senior Resident Inspector McGuire Nuclear Station RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Enclosure 1McGuire Nuclear Station Units 1 and 2Request for Alternative 13-MN-002 Request for Approval of Risk-Informed/Safety BasedInservice Inspection Alternative for Class 1 and 2 PipingE1-1 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

McGuire Nuclear Station Units 1 and 2Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Quality and Safety-1. ASME Code Component AffectedCode Class: 1 and 2Examination Categories:

B-F, B-J, C-F-i, C-F-22. Applicable Code Edition and AddendaFor McGuire Unit 1, the 4th Inservice Inspection (ISI) Interval began on December 1, 2011. Theapplicable Code of Record is the ASME Boiler and Pressure Vessel Code,Section XI, 1998Edition with the 2000 Addenda (for Period 1), which was authorized by Relief Request No. 10-MN-001 per NRC SER dated march 3, 2011 (ADAMS ML1105507700).

The applicable Code ofRecord for the second and third periods is the same Code of Record for the McGuire Unit 2, 4thInservice Inspection Interval.

For McGuire Unit 2, the 4th Inservice Inspection Interval is currently scheduled to start onJuly 15, 2014. The applicable Code of Record for the 4th ISI Interval will be the 2007 Editionwith the 2008 Addenda of Section XI.3. Applicable Code Requirement For Unit 1, Period 1, the requirements from which an alternative is requested are specified in theASME Code, Section Xl, 1998 Edition with the 2000 Addenda, IWB-2200, IWB-2420, IWB-2430, and IWB-2500 (Examination Categories B-F and B-J) and in IWC-2200, IWC-2420, IWC-2430, and IWC-2500 (Examination Categories C-F-1 and C-F-2). For Periods 2 and 3, the requirement from which an alternative is requested is the same requirement of Unit 2, the 4th Inservice Inspection Interval.

For Unit 2, the requirement from which an alternative is requested are specified in the ASMECode, Section Xl, 2007 Edition with the 2008 Addenda, IWB-2200, IWB-2420, IWB-2430, andIWB-2500

( Examination Categories B-F and B-J) and in IWC-2200, IWC-2420, IWC-2430, andIWC-2500 (Examination Categories C-F-1 and C-F-2).4. Reason for RequestThe objective of this submittal is to request the use of a risk-informed/safety based (RISB) ISIprocess for the inservice inspection of Class 1 and 2 piping.5. Proposed Alternative and Basis for UseE1-2 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

In lieu of the ASME Code requirements, McGuire proposes to use a RISB process as analternate to the ASME Section X1 ISI program for Class 1 and 2 piping. The RIS_B processused in this submittal is based upon ASME Code Case N-716, Alternative Piping Classification and Examination Requirements,Section XI, Division 1.Code Case N-716 is founded, in large part, on the RI-ISI process described in Electric PowerResearch Institute (EPRI) Topical Report (TR) 112657, Rev. B-A, Revised Risk-Informed Inservice Inspection Evaluation Procedure, December 1999 (ADAMS Accession No.ML01 3470102) which was previously reviewed and approved by the U.S. Nuclear Regulatory Commission (NRC).In general, a risk-informed program replaces the number and locations of nondestructive examination (NDE) inspections based on ASME Code,Section XI requirements with the numberand locations of these inspections based on the risk-informed guidelines.

These processes result in a program consistent with the concept that, by focusing inspections on the most safety-significant welds, the number of inspections can be reduced while at the same time maintaining protection of public health and safety.NRC approved EPRI TR 112657, Rev. B-A includes steps which, when successfully applied,satisfy the guidance provided in Regulatory Guide (RG) 1.174, An Approach for UsingProbabilistic Risk Assessment In Risk-Informed Decisions On Plant-Specific Changes to theLicensing Basis and RG 1.178, An Approach For Plant-Specific Risk-Informed Decision Makingfor Inservice Inspection of Piping. These steps are:Scope definition Consequence evaluation Degradation mechanism evaluation Piping segment definition Risk categorization Inspection/NDE selection Risk impact assessment Implementation monitoring and feedbackThese same steps were also applied to this RIS_B process and it is concluded that this RIS_Bprocess alternative also meets the intent and principles of Regulatory Guides 1.174 and 1.178.In general, the methodology in Code Case N-716 replaces a detailed evaluation of the safetysignificance of each pipe segment required by EPRI TR 112657, Rev. B-A with a genericpopulation of high safety-significant

segments, supplemented with a rigorous flooding analysis toidentify any plant-specific high safety-significant segments (Class 1, 2, 3, or Non-Class).

Theflooding analysis was performed in accordance with Regulatory Guide 1.200 and ASMERA-Sb-2009, Standard for Probabilistic Risk Assessment for Nuclear Plant Applications.

By using risk-insights to focus examinations on more important locations, while meeting theintent and principles of Regulatory Guides 1.174 and 1.178, this proposed RIS_B program willcontinue to maintain an acceptable level of quality and safety. Additionally, all pipingcomponents, regardless of risk classification, will continue to receive ASME Code-required pressure

testing, as part of the current ASME Code, Section Xl program.

Therefore, approvalE1-3 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i) for this alternative to the requirements of IWB-2200, IWB-2420, IWB-2430, and IWB-2500(Examination Categories B-F and B-J) and IWC-2200, IWC-2420, IWC-2430, and IWC-2500(Examination Categories C-F-1 and C-F-2) is requested in accordance with 10 CFR50.55a(a)(3)(i).

A McGuire Nuclear Station specific template for the application of ASME CodeCase N-716 is attached.

All other ASME Code,Section XI requirements for which relief was not specifically requested inthis relief request remain applicable.

6. Duration of Proposed Alternative For McGuire Unit 1, use of the proposed alternative is requested for the duration of the FourthInservice Inspection Interval (currently scheduled from December 1, 2011 to November 30,2021).For McGuire Unit 2, use of the proposed alternative is requested for the Fourth Inservice Inspection Interval (currently scheduled to start on July 15, 2014 to July 14, 2024).7. Precedents Similar alternatives have been approved for Vogtle Electric Generating Plant, Donald C.Cook 1 and 2, Grand Gulf Nuclear Station, Waterford-3.

8. References 8.1 ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition with the 2000Addenda, American Society of Mechanical Engineers, New York.8.2 ASME Boiler and Pressure Vessel Code,Section XI, 2007 Edition with the 2008Addenda, American Society of Mechanical Engineers, New York.8.3 ASME Boiler and Pressure Vessel- Code, Code Case N-716, Alternative PipingClassification and Examination Requirements,Section XI Division 1.8.4 Vogtle Electric Generating Plant Safety Evaluation

-See ADAMS Accession No.ML1-00610470.

8.5 D. C. Cook Safety Evaluation

-See ADAMS Accession No. ML072620553 8.6 Grand Gulf Nuclear Station Safety Evaluation-See ADAMS Accession No. ML072430005 8.7 Waterford-3 Safety Evaluation

-See ADAMS Accession No. ML080980120 E1-4 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

TEMPLATE SUBMITTAL APPLICATION OF ASME CODE CASE N-716RISK-INFORMED/SAFETY-BASED (RISB)INSERVICE INSPECTION PROGRAM PLANE1-5 CAASASEPASMEBERCAFTACCCCCCDPCCFCDFCIVClass 2 LSSCLERPNVDADME-CECSCCEOOSFACF&OFLBFTCFHELBHEPHFEHRHRAHSSIEIFIFIVIGSSCILOCAIPELELERFLOCARR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Technical Acronyms/Definitions Used in the TemplateAuxiliary Feedwater Accident Sequence AnalysisAccident Sequence Evaluation ProgramAmerican Society of Mechanical Engineers Break Exclusion RegionComputer-Aided Fault Tree AnalysisPRA abbreviation for Capacity Category (used in Attachment A)Crevice Corrosion (used in Table 3.2 of Enclosure 1)Conditional Core Damage Probability Common Cause FailureCore Damage Frequency Containment Isolation ValveClass 2 Pipe Break in LSS PipingConditional Large Early Release Probability Chemical Volume and Control SystemData analysisDegradation Mechanism Erosion-Corrosion External Chloride Stress Corrosion CrackingEquipment Out of ServiceFlow-Accelerated Corrosion Facts and Observations Feedwater Line BreakFault treeFeedwater High Energy Line Break (synonymous with BER)Human Error Probability Human Failure EventHuman Reliability Human Reliability AnalysisHigh Safety-Significant Initiating Events AnalysisInternal FloodingInside First Isolation ValveIntergranular Stress Corrosion CrackingIsolable Loss of Coolant AccidentIndividual Plant Evaluation LERF AnalysisLarge Early Release Frequency Loss of Coolant AccidentE11-6 RR 13-MN-002 ENCLOSURE ITemplate Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Technical Acronyms/Definitions Used in the Template (Continued)

LOOP Loss of Off-Site PowerLSS Low Safety-Significant MAAP Modular Accident Analysis ProgramMIC Microbiologically-lnfluenced Corrosion MOV Motor Operated ValveSM Main SteamMU Model UpdateNDE Nondestructive Examination NNS Non-Nuclear SafetyNPS Nominal Pipe SizePBF Pressure Boundary FailurePIT PittingPLOCA Potential Loss of Coolant AccidentPOD Probability of Detection PRA Probabilistic Risk Assessment PSA Probabilistic Safety Assessment PWSCC Primary Water Stress Corrosion CrackingQU Quantification NC Reactor CoolantNCP Reactor Coolant PumpNCPB Reactor Coolant Pressure BoundaryRG Regulatory GuideRHR, ND Residual Heat RemovalRI-BER Risk-Informed Break Exclusion RegionRI-ISI Risk-Informed Inservice Inspection RISB Risk-Informed/Safety Based Inservice Inspection RM Risk Management RPV Reactor Pressure VesselSBO Station BlackoutSC Success CriteriaSDC Shutdown CoolingSLB Steam Line BreakSGTR Steam Generator Tube RuptureSSC Systems, Structures, and Components SR Supporting Requirements RN Nuclear Service WaterSXI Section XISY Systems AnalysisTASCS Thermal Stratification,

Cycling, and StripingTGSCC Transgranular Stress Corrosion CrackingTR Technical ReportTT Thermal Transients Vol Volumetric E1-7 Table of Contents1. Introduction 1.1 Relation to NRC Regulatory Guides 1.174 and 1.1781.2 PSA Quality2. Proposed Alternative to Current Inservice Inspection Programs2.1 ASME Section Xl2.2 Augmented Programs3. Risk-Informed/Safety-Based ISI Process3.1 Safety Significance Determination 3.2 Failure Potential Assessment 3.3 Element and NDE Selection 3.3.1 Current Examinations 3.3.2 Successive Examinations 3.3.3 Scope Expansion 3.3.4 Program Relief Requests3.4 Risk Impact Assessment 3.4.1 Quantitative Analysis3.4.2 Defense-in-Depth

3.5 Implementation

3.6 Feedback (Monitoring)

4. Proposed ISI Plan Change5. References/Documentation Attachment A -McGuire PRA Quality ReviewE1-8

1. INTRODUCTION McGuire Nuclear Station Units 1 and 2 (McGuire) are currently in the fourth and thirdInservice Inspection (ISI) interval, respectively, as defined by the American Society ofMechanical Engineers (ASME) Boiler and Pressure Vessel Section XI Code for Inspection Program B. McGuire plans to implement a risk-informed/safety-based inservice inspection (RISB) program in the fourth ISI interval.

The fourth ISI interval began on December 1,2011 for Unit 1 and it begins July 15, 2014 for Unit 2.The ASME Section XI Code of record for the fourth ISI interval for Examination Category B-F, B-J, C-F-i, and C-F-2 Class 1, 2, 3, or Non-Class piping welds piping is as follows:For McGuire Unit 1, the Code of Record is the ASME Section XI 1998 Edition with the 2000Addenda (for Period 1), which was authorized by Relief Request # 1 0-MN-001 per NRCSER dated march 3, 2011 (ADAMS ML1 105507700).

The Code of Record for the secondand third periods is the same Code of Record for the McGuire Unit 2, 4h Inservice Inspection Interval.

For McGuire Unit 2, the Code of Record will be the 2007 Edition with the 2008 Addenda ofSection XI.The RISB process used in this submittal is based upon ASME Code Case N-716,Alternative Piping Classification and Examination Requirements,Section XI Division 1,which is founded in large part on the RI-ISI process as described in Electric Power ResearchInstitute (EPRI) Topical Report (TR) 112657, Rev. B-A, Revised Risk-Informed Inservice Inspection Evaluation Procedure.

1.1 Relation to NRC Regulatory Guides 1.174 and 1.178As a risk-informed application, this submittal meets the intent and principles of 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 1.178,An Approach for Plant-Specific Risk-Informed Decisionmaking Inservice Inspection ofPiping. Additional information is provided in Section 3.4.2 relative to defense-in-depth.

1.2 Probabilistic Safety Assessment (PSA) QualityThe McGuire PRA model of record is mr3c, which became effective in November 2012. TheMcGuire internal events model (excluding internal flood and LERF) has received a peerreview to NEI 00-02 and a subsequent gap assessment to the ASME/ANS PRA Standard.

The internal flood and LERF models have since received focused peer reviews.Internal EventsThe McGuire PRA received six Fact and Observations (F&Os) with the significance level of"A" and 31 F&Os with the significance level of "B." Since the NEI 00-02 peer review,focused peer reviews have been performed for the internal flood and LERF models, whichsupersede six F&Os.All of the "A" F&Os have been addressed and changes are incorporated into the currentMcGuire internal events PRA model. The remaining "B" F&Os have been reviewed andprioritized for incorporation into the PRA. Twelve of the "B" F&Os have already beenincorporated into the current McGuire internal events PRA model. All F&Os were addressed El-9 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i) without meeting the definition of 'upgrade' per the ASME/ANS Standard and do not require asubsequent peer review. The 31 F&Os from the peer review that have not been superseded are dispositioned for the RI-ISI application in the Technical Adequacy statement included inAttachment A.Internal FloodThe focused-scope internal flood peer review covered a total of 62 Supporting Requirements (SRs) associated with Internal Flood PRA. One of the SRs was determined to be not applicable to the MNS Internal Flood PRA. Of the 61 remaining SRs, 44 SRs wererated as SR Met, Capability Category (CC) 1/11, or greater.

One SR was rated as CC I and16 SRs were not met. The peer review identified 20 Facts and Observations (F&Os) ofwhich 3 were suggestions and 17 were findings.

A subsequent update to the McGuire Internal Flood PRA model was performed to addressthe 16 SRs rated as not met and the one SR rated as CCI. This update did not meet thecriteria defined in the ASME/ANS Standard for a PRA model 'upgrade' and does not requirea subsequent peer review. A discussion of how the 17 Findings were addressed is includedin Attachment A.LERFThe focused-scope LERF peer review covered 41 supporting requirements associated withthe LERF Analyses.

Two of the LERF SRs were determined to be not applicable to theMcGuire LERF PRA. Of the 39 applicable SRs, 26 SRs were rated as SR Met, Capability Category 1/11, or greater.

Only three SRs were not met. However, ten of the SRs wereassessed at Capability Category

1. McGuire uses a LERF model based on the simplified LERF model in NUREG/CR-6595.

The peer review found nine new Facts and Observations (F&Os), including five suggestions and four findings.

The four findings have been dispositioned for the RI-ISI application inAttachment A.External EventsIn accordance with EPRI TR-1021467, external events PRA models are not included withinthe scope of the RI-ISI program.Aggregate ImpactIn addition to the discussion of each individual item in Attachment A, an assessment of theoverall impact of all open F&Os was performed to determine the potential aggregate modelimpact. This assessment determined that the aggregate impact does not significantly impact risk results or the significant accident sequences.

2. PROPOSED ALTERNATIVE TO CURRENT ISI PROGRAMS2.1 ASME Section XIASME Section Xl Examination Categories B-F, B-J, C-F-I, and C-F-2 currently containrequirements for the nondestructive examination (NDE) of Class 1 and 2 pipingcomponents.

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The alternative RIS_B Program for piping is described in Code Case N-716. TheRISB Program will be substituted for the current program for Class 1 and 2 piping(Examination Categories B-F, B-J, C-F-1 and C-F-2) in accordance with 10 CFR50.55a(a)(3)(i) by alternatively providing an acceptable level of quality and safety.Other non-related portions of the ASME Section XI Code will be unaffected.

2.2 Augmented ProgramsThe impact of the RISB application on the various plant augmented inspection programs listed below were considered.

This section documents only those plantaugmented inspection programs that address common piping with the RIS_B application scope (i.e., Class 1, 2 and 3 piping)." The plant augmented inspection program for high energy line breaks,implemented per Table 3-24 of the UFSAR, is not affected or changed by theRISB Program.* The plant augmented inspection program for flow accelerated corrosion perGeneric Letter (GL) 89-08, Erosion/Corrosion-Induced Pipe Wall Thinning, isrelied upon to manage this damage mechanism but is not otherwise affected orchanged by the RISB Program.* The plant augmented inspection program for localized corrosion per GenericLetter 89-13, Service Water System Problems Affecting Safety-Related Equipment, is used to detect localized corrosion damage mechanisms.

Class 3RN (nuclear service water) system piping in the auxiliary feedwater pump roomwas determined to be high safety significant (CDF>1E-6 based on internalflooding results).

While the sampling percentages of Code Case N-716 will beapplied to this piping, it will be inspected under the existing effective localized corrosion

program, per Section 3.6.7 of EPRI TR-1 12657." A plant augmented inspection program has been implemented at McGuire inresponse to Code Case N-770-1(1),

Materials Reliability Program:

PrimarySystem Piping Butt Weld Inspection and Evaluation Guidelines.

Therequirements of Code Case N-770-1 will be used for the inspection andmanagement of PWSCC susceptible welds and will supplement the RIS_BProgram selection process.

The RISB Program will not be used to eliminate any Code Case N-770-1 requirements.

Alloy 82/182 welds susceptible to nodegradation mechanism or PWSCC only per the RIS_B Program failure potential assessment will be removed from the RIS_B population subject to elementselection, and will be inspected and managed per the requirement of Code CaseN-770-1 (1)(2)Notes:(1) Effective July 21, 2011, 10 CFR 50.55a was amended via rulemaking toincorporate by reference Code Case N-770-1, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping andVessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182El-11 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Weld Filler Material With or Without Application of Listed Mitigation Activities, which replaces MRP-139 for the inspection and management of PWSCCsusceptible welds. McGuire is managing Alloy 82/182 welds per therequirements of Code Case N-770-1.(2) Alloy 821182 welds subject to PWSCC and an additional degradation mechanism (or mechanisms) remain in the RISB population subject toelement selection.

McGuire has conducted an evaluation in accordance with MRP-146, Materials Reliability Program:

Management of Thermal Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines, and these results have beenincorporated into the RISB Program.3. RISK-INFORMED/SAFETY-BASED ISI PROCESSThe process used to develop the RISB Program conformed to the methodology described in Code Case N-716 and consisted of the following steps:* Safety Significance Determination (see Section 3.1)* Failure Potential Assessment (see Section 3.2)* Element and NDE Selection (see Section 3.3)" Risk Impact Assessment (see Section 3.4)* Implementation Program (see Section 3.5)* Feedback Loop (see Section 3.6)Each of these six steps is discussed below:3.1 Safety Significance Determination The systems assessed in the RISB Program are provided in Table 3.1a (MNS1) andTable 3.1b (MNS2). The piping and instrumentation diagrams and additional plant.information, including the existing plant ISI Program were used to define the pipingsystem boundaries.

Per Code Case N-716 requirements, piping welds are assignedsafety-significance categories, which are then used to determine the examination treatment requirements.

High safety-significant (HSS) welds are determined inaccordance with the requirements below. Low safety-significant (LSS) welds includeall other Class 2, 3, or Non-Class welds.(1) Class 1 portions of the reactor coolant pressure boundary (RCPB), except asprovided in 10 CFR 50.55a(c)(2)(i) and (c)(2)(ii)

E1-12 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

(2) Applicable portions of the shutdown cooling pressure boundary function.

That is,Class 1 and 2 welds of systems or portions of systems needed to utilize thenormal shutdown cooling flow path either:(a) As part of the RCPB from the reactor pressure vessel (RPV) to the secondisolation valve (i.e., farthest from the RPV) capable of remote closure or tothe containment penetration, whichever encompasses the larger number ofwelds; or(b) Other systems or portions of systems from the RPV to the second isolation valve (i.e., farthest from the RPV) capable of remote closure or to thecontainment penetration, whichever encompasses the larger number of welds(3) That portion of the Class 2 feedwater system [> 4 inch nominal pipe size (NPS)]of pressurized water reactors (PWRs) from the steam generator to the outercontainment isolation valve,(4) Piping within the break exclusion region (BER) greater than 4" NPS for high-energy piping systems as defined by the Owner. Per Code Case N-716, thismay include Class 3 or Non-Class piping.(5) Any piping segment whose contribution to Core Damage Frequency (CDF) isgreater than 1 E-06 [and per NRC feedback on the Grand Gulf and D. C. CookRISB applications 1E-07 for Large Early Release Frequency (LERF)] basedupon a plant-specific PRA of pressure boundary failures (e.g., pipe whip, jetimpingement, spray, inventory losses).

This may include Class 3 or Non-Class piping. Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room was identified as HSS due to CDF exceeding thesecriteria.

3.2 Failure Potential Assessment Failure potential estimates were generated utilizing industry failure history, plant-specific failure history, and other relevant information.

These failure estimates were determined using the guidance provided in NRC approved EPRI TR-1 12657 (i.e., the EPRI RI-ISImethodology),

with the exception of the deviation discussed below.Table 3.2 summarizes the failure potential assessment by system for each degradation mechanism that was identified as potentially operative.

A deviation to the EPRI RISB methodology has been implemented in the failurepotential assessment for McGuire Nuclear Station (MNS). Table 3-16 of EPRI TR-112657 contains the following criteria for assessing the potential for ThermalStratification,

Cycling, and Striping (TASCS).

Key attributes for horizontal or slightlysloped piping greater than NPS 1 include:1. The potential exists for low flow in a pipe section connected to a component allowing mixing of hot and cold fluids; orEl-13 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

2. The potential exists for leakage flow past a valve, including in-leakage, out-leakage and cross-leakage allowing mixing of hot and cold fluids; or3. The potential exists for convective heating in dead-ended pipe sections connected to a source of hot fluid; or4. The potential exists for two phase (steam/water) flow; or5. The potential exists for turbulent penetration into a relatively colder branch pipeconnected to header piping containing hot fluid with turbulent flow;AND'AT > 500F,AND>Richardson Number > 4 (this value predicts the potential buoyancy of a stratified flow)These criteria, based on meeting a high cycle fatigue endurance limit with the ATassumed equal to the greatest potential AT for the transient, will identify locations where stratification is likely to occur, but allows for no assessment of severity.

Assuch, many locations will be identified as subject to TASCS, where no significant potential for thermal fatigue exists. The critical attribute missing from the existingmethodology, that would allow consideration of fatigue severity, is a criterion thataddresses the potential for fluid cycling.

The impact of this additional consideration onthe existing TASCS susceptibility criteria is presented below.>- Turbulent Penetration TASCSTurbulent penetration is a swirling vertical flow structure in a branch line inducedby high velocity flow in the connected piping. It typically occurs in linesconnected to piping containing hot flowing fluid. In the case of downward slopinglines that then turn horizontal, significant top-to-bottom cyclic ATs can develop inthe horizontal sections if the horizontal section is less than about 25 pipediameters from the reactor coolant piping. Therefore, TASCS is considered forthis configuration.

For upward sloping branch lines connected to the hot fluid source that turnhorizontal or in horizontal branch lines, natural convective effects combined witheffects of turbulence penetration will tend to keep the line filled with hot water. Ifthere is in-leakage of cold water, a cold stratified layer of water may be formedand significant top-to-bottom ATs may occur in the horizontal portion of thebranch line. Interaction with the swirling motion from turbulent penetration maycause a periodic axial motion of the cold layer. Therefore, TASCS is considered for these configurations.

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For similar upward sloping branch lines, if there is no potential for in-leakage, thiswill result in a well-mixed fluid condition where significant top-to-bottom ATs willnot occur. Therefore, TASCS is not considered for these no in-leakage configurations.

Even in fairly long lines, where some heat loss from the outsideof the piping will tend to occur and some fluid stratification may be present, thereis no significant potential for cycling as has been observed for the in-leakage case. The effect of TASCS will not be significant under these conditions and canbe neglected.

SLow flow TASCSIn some situations, the transient startup of a system (e.g., shutdown coolingsuction piping) creates the potential for fluid stratification as flow is established.

In cases where no cold fluid source exists, the hot flowing fluid will fairly rapidlydisplace the cold fluid in stagnant lines, while fluid mixing will occur in the pipingfurther removed from the hot source and stratified conditions will exist only brieflyas the line fills with hot fluid. As such, since the situation is transient in nature, itcan be assumed that the criteria for thermal transients (TT) will govern.Valve leakage TASCSSometimes a very small leakage flow of hot water can occur outward past avalve into a line that is relatively colder, creating a significant temperature difference.

However, since this is generally a "steady-state" phenomenon withno potential for cyclic temperature

changes, the effect of TASOS is not significant and can be neglected.

SConvection Heating TASCSSimilarly, there sometimes exists the potential for heat transfer across a valve toan isolated section beyond the valve, resulting in fluid stratification due to naturalconvection.

However, since there is no potential for cyclic temperature changesin this case, the effect of TASOS is not significant and can be neglected.

In summary, these additional considerations for determining the potential for thermalfatigue as a result of the effects of TASOS provide an allowance for considering cycleseverity.

Consideration of cycle severity was used in previous NRC approved RIS_Bprogram submittals for D. C. Cook, Grand Gulf Nuclear Station, Waterford-3, and theVogtle Electric Generating Plant. The methodology used in the McGuire RIS_Bapplication for assessing TASCS potential conforms to these updated criteria.

Additionally, materials reliability program (MRP) MRP-146 guidance on the subject ofTASCS was also incorporated into the McGuire RIS_B application.

3.3 Element and NDE Selection Code Case N-716 and lessons learned from the Grand Gulf and DC Cook RIS Bapplications provided criteria for identifying the number and location of requiredexaminations.

Ten percent of the HSS welds shall be selected for examination asfollows:E1-15 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

(1) Examinations shall be prorated equally among systems to the extent practical, and each system shall individually meet the following requirements:

(a) A minimum of 25% of the population identified as susceptible to eachdegradation mechanism and degradation mechanism combination shall beselected.

(b) If the examinations selected above exceed 10% of the total number of HSSwelds, the examinations may be reduced by prorating among eachdegradation mechanism and degradation mechanism combination, to theextent practical, such that at least 10% of the HSS population is inspected.

(c) If the examinations selected above are not at least 10% of the HSS weldpopulation, additional welds shall be selected so that the total numberselected for examination is at least 10%.(2) At least 10% of the RCPB welds shall be selected.

(3) For the RCPB, at least two-thirds of the examinations shall be located betweenthe inside first isolation valve (IFIV) (i.e., isolation valve closest to the RPV) andthe RPV.(4) A minimum of 10% of the welds in that portion of the RCPB that lies outsidecontainment (not applicable for McGuire) shall be selected.

(5) A minimum of 10% of the welds within the break exclusion region (BER) shall beselected.

In contrast to a number of traditional RI-ISI program applications, where thepercentage of Class 1 piping locations selected for examination has fallen substantially below 10%, Code Case N-716 mandates that 10% of the HSS welds be chosen. Abrief summary of the number of welds and the number selected is provided below, andthe results of the selections are presented in Table 3.3a (MNS1) and Table 3.3b(MNS2). Section 4 of EPRI TR-1 12657 was used as guidance in determining theexamination requirements for these locations.

Only those RIS_B inspection locations that receive a volumetric examination are included.

Class 1 Welds(1)(5)

Class 2 Welds(2)

All Piping Welds(3)(4)

UnitTotal Selected Total Selected Total Selected1 754 83 3386 14 4140 972 741 80 3621 16 4362 96Notes:(1) Includes all Category B-F and B-J locations except as described in note 5.(2) Includes all Category C-F-1 and C-F-2 locations.

Of the Class 2 piping weld locations, 201are HSS at Unit 1 and 205 are HSS at Unit 2; the remaining are LSS.(3) Regardless of safety significance, Class 1, 2, and 3 ASME Section Xl in-scope pipingcomponents will continue to be pressure tested as required by the ASME Section XlE1-16 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Program.

VT-2 visual examinations are scheduled in accordance with the pressure testprogram that remains unaffected by the RISB Program.(4) Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump roomwas determined to be HSS and is included in the RISB Program although not included inthe total weld count.(5) As described in Section 2.2, Alloy 82/182 welds susceptible to no degradation mechanism or PWSCC only per the RIS B Program failure potential assessment were removed fromthe RISB population totals in the above table prior to element selection.

3.3.1 Current Examinations McGuire Unit 1 is currently using the traditional ASME Section XI inspection methodology for ISI examination of Class 1 and 2 piping welds per the ASME1998 Edition with 2000 Addenda.

However, in anticipation of the approval ofthis RIS-B submittal, welds being examined using the traditional Section XImethodology also meet the examination requirements of Table 1 of Code CaseN-716. Therefore, after approval of the RIS-B submittal, those welds that havealready been examined during the 4th Interval that are selected by the RIS-Bprocess will be credited toward the RIS-B requirements.

McGuire Unit 2 is currently using the NRC previously approved application using WCAP-14572 Revision 1-NP-A and Supplement 2 Revision 1-NP-A forISI examination of piping welds per the ASME 1998 Edition with 2000Addenda.3.3.2 Successive Examinations If indications are detected during RIS_B ultrasonic examinations, they will beevaluated per IWB-3514 (Class 1) or IWC-3514 (Class 2) to determine theiracceptability.

Any unacceptable flaw will be evaluated per the requirements ofASME Code Section XI, IWB-3600 or IWC-3600, as appropriate.

As part ofthis evaluation, the degradation mechanism that is responsible for the flaw willbe determined and accounted for in the evaluation.

If the flaw is acceptable forcontinued

service, successive examinations will be scheduled per Section 6 ofCode Case N-716. If the flaw is found unacceptable for continued operation, itwill be repaired in accordance with IWA-4000, applicable ASME Section XICode Cases, or NRC approved alternatives.

The IWB-3600 analytical evaluation will be submitted to the NRC. Evaluation of indications attributed toPWSCC and successive examinations of PWSCC indications will be performed in accordance with ASME Code Case N-770-1 or a subsequent NRC rulemaking. Finally, the evaluation will be documented in the corrective actionprogram and the Owner submittals required by Section Xl.3.3.3 Scope Expansion If the nature and type of the flaw is service-induced, then welds subject to thesame type of postulated degradation mechanism will be selected andexamined per Section 6 of Code Case N-716. The evaluation will includewhether other elements in the segment or additional segments are subject tothe same root cause conditions.

Additional examinations will be performed onEl-17 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i) those elements with the same root cause conditions or degradation mechanisms.

The additional examinations will include HSS elements up to anumber equivalent to the number of elements required to be inspected duringthe current outage. If unacceptable flaws or relevant conditions are again foundsimilar to the initial problem, the remaining elements identified as susceptible will be examined during the current outage. No additional examinations needbe performed if there are no additional elements identified as being susceptible to the same root cause conditions.

The need for extensive root cause analysisbeyond that required for the IWB-3600 analytical evaluation will be dependent on practical considerations (i.e., the practicality of performing additional NDE orremoving the flaw for further evaluation during the outage).Scope expansion for flaws characterized as PWSCC will be conducted inaccordance with ASME Code Case N-770-1 or subsequent NRC rule makings.3.3.4 Program Relief RequestsConsistent with previously approved RISB submittals, McGuire will calculate coverage and use additional examinations or techniques in the same manner ithas for traditional Section XI examinations.

Experience has shown this processto be weld-specific (e.g., joint configuration).

As such, the effect on risk, if any,will not be known until the examinations are performed.

Relief requests forthose cases where greater than 90% coverage is not obtained will be submitted per the requirements of 10 CFR 50.55a(g)(5)(iv).

No McGuire relief requests are being withdrawn due to the RIS_B application.

3.4 Risk Impact Assessment The RISB Program development has been conducted in accordance with Regulatory Guide 1.174 and the requirements of Code Case N-716, and the risk fromimplementation of this program is expected to remain neutral or decrease whencompared to that estimated from current requirements.

This evaluation categorized welds as high safety significant or low safety significant inaccordance with Code Case N-716, and then determined what inspection changeswere proposed for each system. The changes included changing the number andlocation of inspections, and in many cases improving the effectiveness of theinspection to account for the findings of the RISB degradation mechanism assessment.

For example, examinations of locations subject to thermal fatigue will beconducted on an expanded volume and will be focused to enhance the probability ofdetection (POD) during the inspection process.3.4.1 Quantitative AnalysisCode Case N-716 has adopted the NRC approved EPRI TR-1 12657 processfor risk impact analyses, whereby limits are imposed to ensure that the change-in-risk of implementing the RISB Program meets the requirements ofRegulatory Guides 1.174 and 1.178. Section 3.7.2 of EPRI TR-112657 requiresEl-18 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i) that the cumulative change in CDF and LERF be less than 1 E-07 and 1 E-08per year per system, respectively.

For LSS welds, Conditional Core Damage Probability (CCDP)/Conditional Large Early Release Probability (CLERP) values of 1 E-4/1 E-5 wereconservatively used. The rationale for using these values is that the change-in-risk evaluation process of Code Case N-716 is similar to that of the EPRI risk-informed ISI (RI-ISI) methodology.

As such, the goal is to determine CCDPs/CLERPs threshold values. For example, the threshold values betweenHigh and Medium consequence categories is 1 E-4 (CCDP)/1 E-5 (CLERP) andbetween Medium and Low consequence categories are 1 E-6 (CCDP)/1 E-7(CLERP) from the EPRI RI-ISI Risk Matrix. Using these threshold valuesstreamlines the change-in-risk evaluation as well as stabilizes the updateprocess.

For example, if a CCDP changes from 1 E-5 to 3E-5 due to an update,it will remain below the 1 E-4 threshold value; the change-in-risk evaluation would not require updating.

The updated internal flooding PRA was also reviewed to ensure that there is noLSS Class 2 piping with a CCDP/CLERP greater than 1 E-4/1 E-5.With respect to assigning failure potentials for LSS piping, the criteria aredefined in Table 3 of Code Case N-716. That is, those locations identified assusceptible to FAC are assigned a high failure potential.

Those locations susceptible to thermal fatigue, erosion-cavitation, corrosion, or stress corrosion cracking are assigned a medium failure potential, unless they have anidentified potential for water hammer loads. In such cases, they will beassigned a high failure potential.

Finally, those locations that are identified asnot susceptible to degradation are assigned a low failure potential.

In order to streamline the risk impact assessment, a review was conducted thatverified that the LSS piping was not susceptible to water hammer. LSS pipingmay be susceptible to FAC; however, the examination for FAC is performed per the FAC program.

This review was conducted similar to that done for atraditional RI-ISI application.

Thus, the high failure potential category is notapplicable to LSS piping. In lieu of conducting a formal degradation mechanism evaluation for all LSS piping (e.g. to determine if thermal fatigue is applicable),

these locations were conservatively assigned to the Medium failure potential

("Assume Medium" in Table 3.4a (MNS1) and Table 3.4b (MNS2)) for use inthe change-in-risk assessment.

Experience with previous industry RIS_Bapplications shows this to be conservative.

McGuire has conducted a risk impact analysis per the requirements of Section5 of Code Case N-716 that is consistent with the "Simplified Risk Quantification Method" described in Section 3.7 of EPRI TR-1 12657. The analysis estimates the net change-in-risk due to the positive and negative influences of adding andremoving locations from the inspection program.The CCDP and CLERP values used to assess risk impact were estimated based on pipe break location.

Based on these estimated values, aE1-19 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i) corresponding consequence rank was assigned per the requirements of EPRITR-1 12657 and upper bound threshold values were used as provided in thetable below. Consistent with the EPRI methodology, the upper bound for allbreak locations that fall within the high consequence rank range was based onthe highest CCDP value obtained (e.g., Medium LOCA CCDP bounds the largeand small LOCA CCDPs).Also, as described in Section 2.2, Alloy 82/182 welds susceptible to nodegradation mechanism or PWSCC only per the RIS_B Program failurepotential assessment were removed from the RISB population prior toelement selection and risk impact assessment.

CCDP and CLERP Values Based on Break LocationBreak Location Estimated Upper BoundDesignation CCDP CLERP CCDP CLERPLOCA 2E-03 2E-04 HIGH 2E-03 2E-04RCPB pipe breaks that result in a loss of coolant accident

-The highest CCDP for Medium LOCA (%ML) wasused (0.1 margin used for CLERP). Unisolable RCPB piping of all sizes.PLOCA' I IE-05 IE-06 MEDIUM IE-04 I E-05Isolable or Potential LOCA (I open valve or I closed valve) inside containment

-RCPB pipe breaks that result inan isolable or potential LOCA -Calculated based on Medium LOCA CCDP of -2E-3 and valve fail to closeprobability of-3E-3 (0.1 margin used for CLERP). Applies to piping between 1st and 2nd RCPB isolation valve.PPLOCA <IE-06 <IE-07 LOW I E-06 IE-07Isolable or Potential LOCA with two valves (2 open valves or 2 closed valves) -RCPB pipe breaks that result inan isolable or potential LOCA beyond 2 valves -Calculated based on Medium LOCA CCDP of-2E-3 and failureof two MOVs to close <IE-4 (0.1 margin used for CLERP). Applies to piping between beyond the 2nd RCPBisolation valve inside containment.

FLB 2E-05 2E-06 MEDIUM I E-04 IE-05Feedwater line breaks -bounding value used that envelopes

%T6 (secondary break inside containment) and %T7(feed line break outside containment)

(0.1 margin used for CLERP).Class 2 LSS IE-04 IE-05 MEDIUM IE-04 IE-05Class 2 pipe breaks that occur in the remaining system piping designated as low safety significant

-Estimated based on upper bound for Medium Consequence.

1. The PRA does not explicitly model potential and isolable LOCA events, because such events are subsumed bythe LOCA initiators in the PRA. That is, the frequency of a LOCA in this limited piping downstream of thefirst RCPB isolation valve times the probability that the valve fails is a small contributor to the total LOCAfrequency.

The N-716 methodology must evaluate these segments individually; thus, it is necessary toestimate their contribution.

This is estimated by taking the LOCA CCDP and multiplying it by the valvefailure probability.

PLOCA is identified and used in the quantification of both ILOCA (isolable LOCA) andPLOCAThe likelihood of pressure boundary failure (PBF) is determined by thepresence of different degradation mechanisms and the rank is based on therelative failure probability.

The basic likelihood of PBF for a piping location withno degradation mechanism present is given as xo and is expected to have avalue less than 1 E-08. Piping locations identified as medium failure potential have a likelihood of 20x0.These PBF likelihoods are consistent withReferences 9 and 14 of EPRI TR-1 12657. In addition, the analysis wasperformed both with and without taking credit for enhanced inspection El-20 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i) effectiveness due to an increased POD from application of the RIS_Bapproach.

Table 3.4a (MNS1) and Table 3.4b (MNS2) present a summary of the RISBProgram versus the second ISI interval (1989 Edition of ASME Section Xl)program requirements on a "per system" basis. The presence of FAC wasadjusted for in the quantitative analysis by excluding its impact on the failurepotential rank. The exclusion of the, impact of FAC on the failure potential rankand therefore in the determination of the change-in-risk, was performed because FAC is a damage mechanism managed by a separate, independent plant augmented inspection program.

The RISB Program credits and reliesupon this plant augmented inspection program to manage this damagemechanism.

The plant FAC program will continue to determine where andwhen examinations shall be performed.

Hence, since the number of FACexamination locations remains the same "before" and "after" (theimplementation of the RISB program) and no delta exists, there is no need toinclude the impact of FAC in the performance of the risk impact analysis.

As indicated in the following tables, this evaluation has demonstrated thatunacceptable risk impacts will not occur from implementation of the RIS_BProgram, and that the acceptance criteria of Regulatory Guide 1.174 and CodeCase N-716 are satisfied.

McGuire Unit 1With POD Credit Without POD CreditDelta CDF Delta LERF Delta CDF Delta LERFCA -Auxiliary Feedwater 1.30E-10 1.30E-1 1 1.30E-10 1.30E- 1ICF -Feedwater

-1.00E-12

-1.00E-13 3.80E-12 3.80E-13FW -Refueling Water O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00KC -Component Cooling O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00NC -Reactor Coolant -7.68E-09

-7.68E-10

-3.43E-09

-3.43E-10 ND -Residual Heat Removal 5.10E-10 5.10E-11 5.10E-10 5.10E-1 1NF -Ice Condenser Refrig O.OOE+00 O.OOE+00 O.OOE+00 0.00E+00NI -Safety Injection 3.62E-10 3.62E-11 3.62E-10 3.62E-1 1NS -Containment Spray 2.OOE-1 1 2.OOE-12 2.OOE-1 1 2.OOE-12NV -Chemical Volume & Control 3.85E-10 3.85E-1 1 3.87E-10 3.87E- 11RN -Nuclear Service Water (1) O.OOE+00 O.OOE+00 0.00E+00 0.OOE+00RV -Cont Vent Cooling Water 1.00E-1 1 1.00E-12 1.00E-1 1 1.00E-12SA -Auxiliary Steam 2.OOE-11 2.OOE-12 2.OOE-11 2.OOE-12SM -Main Steam 1.60E-10 1.60E-1 1 1.60E-10 1.60E-1 1SV -Main Steam Vent 3.OOE-11 3.OOE-12 3.OOE-11 3.OOE-12VP -Cont Purge Vent 2.00E-1 1 2.OOE-12 2.OOE-1 1 2.00E-12VQ -Cont Air Release & Addition O.OOE+00 O.OOE+00 0.00E+00 0.00E+00WL -Liquid Waste & Recycle 0.00E+00 O.OOE+00 O.OOE+00 O.OOE+00El-21 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

TotalI -6.03E-09 I-6.03E-10 I -1.78E-09 I-1.78E-10 1Note:(1) The risk reduction associated with the HSS Class 3 RN (nuclear service water) system piping inthe auxiliary feedwater pump room is not included in the above tables.McGuire Unit 2With POD Credit Without POD CreditDelta CDF Delta LERF Delta CDF Delta LERFCA -Auxiliary Feedwater 1.40E- 10 1.40E-11 1 .40E-10 1.40E-I 1CF -Feedwater 8.OOE-13 8.OOE-14 5.60E-12 5.60E-13FW -Refueling Water 0.00E+00 O.OOE+00 0.OOE+00 0.OOE+00KC -Component Cooling 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00NC -Reactor Coolant -8. 1OE-09 -8.1OE-10

-3.70E-09

-3.70E-10 ND -Residual Heat Removal 5.30E-10 5.30E-11 5.30E-10 5.30E-1 1NF -Ice Condenser Refrig 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00NI -Safety Injection 4.29E-10 4.29E-1 1 4.29E-10 4.29E-1 1NS -Containment Spray O.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00NV -Chemical Volume & Control 5.05E-10 5.05E- 11 5.07E-10 5.07E- 11RN -Nuclear Service Water (1) 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00RV -Cont Vent Cooling Water 1.00E- 11 1.001E- 12 1.OOE- 11 1.00E-12SA -Auxiliary Steam 2.OOE-1 1 2.OOE-12 2.OOE-1 1 2.OOE-12SM -Main Steam 1.90E-10 1.90E-1 1 1.90E-10 1.90E-I 1SV -Main Steam Vent 3.OOE-I 1 3.00E-12 3.OOE-1 1 3.00E-12VP -Cont Purge Vent 2.00E- 11 2.OOE-12 2.OOE-1 1 2.OOE-12VQ -Cont Air Release & Addition O.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00WL -Liquid Waste & Recycle 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00Total -6.23E-09

-6.23E-10

-1.82E-09

-1.82E-10 Note:(1) The risk reduction associated with the HSS Class 3 RN (nuclear service water) system pipingin the auxiliary feedwater pump room is not included in the above tables.As shown in Table 3.4a (MNS1) and Table 3.4b (MNS2), new RIS_B locations were selected such that the RISB selections exceed the Section XI selections for certain categories (Delta column has a positive number).

To show that theuse of a conservative upper bound CCDP/CLERP does not result in an optimistic calculation with regard to meeting the acceptance

criteria, a conservative sensitivity was conducted where the RISB selections were set equal to theSection Xl selections (Delta changed from positive number to zero). Theacceptance criteria are met when the number of RISB selections is not allowedto exceed Section X1.3.4.2 Defense-in-Depth E1-22 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

The intent of the inspections mandated by 10 CFR 50.55a for piping welds is toidentify conditions such as flaws or indications that may be precursors to leaksor ruptures in a system's pressure boundary.

Currently, the process forselecting inspection locations is based upon terminal end locations, structural discontinuities, and stress analysis results.

As depicted in ASME White Paper92-01-01 Rev. 1, Evaluation of Inservice Inspection Requirements for Class 1,Category B-J Pressure Retaining Welds, this methodology has been ineffective in identifying leaks or failures.

EPRI TR-112657 and Code Case N-716 providea more robust selection process founded on actual service experience withnuclear plant piping failure data.This process has two key independent ingredients; that is, a determination ofeach location's susceptibility to degradation and secondly, an independent assessment of the consequence of the piping failure.

These two ingredients assure defense-in-depth is maintained.

First, by evaluating a location's susceptibility to degradation, the likelihood of finding flaws or indications thatmay be precursors to leak or ruptures is increased.

Secondly, a genericassessment of high-consequence sites has been determined by Code CaseN-716, supplemented by plant-specific evaluations, thereby requiring aminimum threshold of inspection for important piping whose failure would resultin a LOCA or BER break. Finally, Code Case N-716 requires that any piping ona plant-specific basis that has a contribution to CDF of greater than 1 E-06(or 1 E-07 for LERF) be included in the scope of the application.

McGuireidentified Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room as HSS.All locations within the Class 1, 2, and 3 pressure boundaries will continue tobe pressure tested in accordance with the Code, regardless of its safetysignificance.

3.5 Implementation

Upon approval of the RISB Program, procedures that comply with the guidelines described in Code Case N-716 will be prepared to implement and monitor theprogram.

The new program will be implemented during the fourth ISI interval.

Nochanges to the Technical Specifications or Updated Final Safety Analysis Report arenecessary for program implementation.

The applicable aspects of the ASME Code not affected by this change will be retained, such as inspection

methods, acceptance guidelines, pressure

testing, corrective

measures, documentation requirements, and quality control requirements.

ExistingASME Section XI program implementing procedures will be retained and modified toaddress the RISB process, as appropriate.

3.6 Feedback (Monitoring)

The RISB Program is a living program that is required to be monitored continuously for changes that could impact the basis for which welds are selected for examination.

E1-23 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Monitoring encompasses numerous facets, including the review of changes to theplant configuration, changes to operations that could affect the degradation assessment, a review of NDE results, a review of site failure information from thecorrective action program, and a review of industry failure information from industryoperating experience (OE). Also included is a review of PRA changes for their impacton the RISB program.

These reviews provide a feedback loop such that new relevantinformation is obtained that will ensure that the appropriate identification of HSS pipinglocations selected for examination is maintained.

As a minimum, this review will beconducted on an ASME period basis. In addition, more frequent adjustment may berequired as directed by NRC Bulletin or Generic Letter requirements, or by industryand plant-specific feedback.

If an adverse condition, such as an unacceptable flaw is detected during examinations, the adverse condition will be addressed by the corrective action program andprocedures.

The following are appropriate actions to be taken:A. Identify (Examination results conclude there is an unacceptable flaw).B. Characterize (Determine if regulatory reporting is required and assess if animmediate safety or operation impact exists).C. Evaluate (Determine the cause and extent of the condition identified and developa corrective action plan or plans).D. Decide (Make a decision to implement the corrective action plan).E. Implement (Complete the work necessary to correct the problem and preventrecurrence).

F. Monitor (Through the audit process ensure that the RISB program has beenupdated based on the completed corrective action).G. Trend (Identify conditions that are significant based on accumulation of similarissues).For preservice examinations, McGuire will follow the rules contained in Section 3.0 ofN-716. Welds classified HSS require a preservice inspection.

The examination

volumes, techniques, and procedures shall be in accordance with Table 1 of N-716.Welds classified as LSS do not require preservice inspection.

4. PROPOSED ISl PLAN CHANGEMcGuire Unit 1 is currently in the first period of fourth interval and is using the traditional ASME Section XI inspection methodology for ISI examination of piping welds. At least 16%of the ASME Section XI piping examinations will be performed by the end of the first periodof the fourth interval to ensure compliance with the traditional ASME Section XI inspection methodology.

In anticipation of the approval of this RISB submittal, selected welds of McGuire Unit 1 thatwill be examined during the first Period using the traditional ASME Section Xl methodology also meet the examination requirements of Table 1 of Code Case N-716. After approval ofthe RISB submittal, those welds in the RIS_B scope that will be examined during the firstperiod that also meet Table 1 requirements will be credited toward the RISB requirements for the 1st Period.El-24 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

During the second and third ISI periods, the remainder of the inspection locations selectedfor examination per the RIS_B Program will be examined.

Examinations shall be performed such that the period percentage requirements of ASME Section XI are met.McGuire Unit 2 is currently in the third period of the third ISI interval.

The first period offourth interval of McGuire Unit 2 will not begin until July 15, 2014; therefore selected weldsfor examination will be from the RISB scope.As discussed in Section 2.2, implementation of the RISB program will not alter anyPWSCC examination requirements for the Alloy 82/182 examinations.

A comparison between the RISB Program and the 1989 Edition of Section XI programrequirements for second interval in-scope piping is provided in Table 4a (MNS1) and Table4b (MNS2). In addition, Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room was identified as high safety significant and is included in the RIS_BProgram.

Ten percent of the welds will be inspected during the interval.

The degradation mechanisms identified for this piping are MIC and Pitting, and the examination will beperformed in accordance with the Owner's existing Localized Corrosion (MIC/PIT) program.The examination volume shall include base metal, welds, and weld HAZ in the affectedregions of carbon and low-alloy steel, and the welds and weld HAZ of austenitic steel.Examinations shall verify the minimum wall thickness required.

The examination method andexamination region shall be sufficient to characterize the extent of the element degradation.

E1-25 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

5. REFERENCES/DOCUMENTATION EPRI Report 1006937, Extension of EPRI Risk Informed ISI Methodology to BreakExclusion Region Programs.

EPRI TR-1 12657, Revised Risk-Informed Inservice Inspection Evaluation Procedure, Rev. B-A.ASME Code Case N-716, Alternative Piping Classification and Examination Requirements,Section XI Division 1.Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions On Plant-Specific Changes to the Licensing Basis.Regulatory Guide 1.178, An Approach for Plant-Specific Risk-Informed Decisionmaking Inservice Inspection of Piping.Regulatory Guide 1.200, Rev 2 An Approach For Determining The Technical Adequacy OfProbabilistic Risk Assessment Results For Risk-Informed Activities.

USNRC Safety Evaluation for Grand Gulf Nuclear Station Unit 1, Request for Alternative GG-ISI-002-1mplement Risk-Informed ISI based on ASME Code Case N-716, datedSeptember 21, 2007. ADAMS Accession No. ML072430005 USNRC Safety Evaluation for DC Cook Nuclear Plant, Units 1 and 2, Risk-Informed Safety-Based ISI program for Class 1 and 2 Piping Welds, dated September 28, 2007. See ADAMSAccession No. ML072620553.

EPRI Report 1021467 Nondestructive Evaluation:

Probabilistic Risk Assessment Technical Adequacy Guidance for Risk-Informed In-Service Inspection Programs.

Waterford-3 Safety Evaluation

-See ADAMS Accession No. ML080980120.

Vogtle Electric Generating Plant Safety Evaluation

-See ADAMS Accession No.ML100610470.

Supporting Onsite Documentation Structural Integrity Calculation 0801613.302 "N716 Evaluation for McGuire Unit 1"Structural Integrity Calculation 0801613.304 "N716 Evaluation for McGuire Unit 2"Structural Integrity Calculation 0801613.301 "Degradation Mechanism Evaluation forMcGuire Unit 1"Structural Integrity Calculation 0801613.303 "Degradation Mechanism Evaluation forMcGuire Unit 2"E1-26 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 3.1aUnit 1 Code Case N-716 Safety Significance Determination Weld N-716 Safety Significance Determination Safety Significance Systen (I) Count RCPB SDC PWR: FW BER CDF > IE-6 (2) High LowCA 159119 v ,CF 1313 V"FW 136 VKC 8347 VNC 24 V V V8 V" V" V V"15 V V VND 2 v V485 ,/NF 2 V138 / V105 V V VNI80 V V553 VNS 443 V117 V VNV1031 ,(2) ..... VRV 9 VSA 22 VSM 164 "Sv 37 VVP 20 VVQ 78 VWL 8 V602 V V144 V V VSummary 82 V "Results 8for allSystems 119 V V3 8(2)5 .. .3185 ______(1) System Scope:CA -Auxiliary Feedwater CF -Feedwater FW -Refueling WaterKC -Component CoolingNC -Reactor CoolantND -Residual Heat RemovalNF -Ice Condenser Refrigeration El-27 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

NI -Safety Injection NS -Containment SprayNV -Chemical Volume & ControlRN -Nuclear Service WaterRV -Cont Vent Cooling WaterSA -Auxiliary SteamSM -Main SteamSV -Main Steam VentVP -Cont Purge VentVQ -Cont Air Release & AdditionWL -Liquid Waste & Recycle(2) HSS Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room is notincluded in the Weld Count or Summary Results.E1-28 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 3.1bUnit 2 Code Case N-716 Safety Significance Determination System Weld N-716 Safety Significance Determination Safety Significance (I) Cunt CPB DC PVR:(F) count RCPB SDC BER CDF > 1E-6 (2) High LowCA 121 V/129 V VCF 13FW 154 VKC 6 V341 V VNC 20 V V '8 " V" V" V17 V V VND 2 V V520 VNF 2 V132 V V97 V" V V"NI V74 V573 VNS 464 V126 V VNV____1188 VRN (2) V V22 VRV 10 VSA 22 __SM 185 VSv 35 VVp 20 VVQ 73 VWL 8 V599 V V134 V" V V"Summary 76 V VResults 8Vfor all_ _ _ _Systems 129 V V(2) V V3416 V(1) System Scope:CA -Auxiliary Feedwater CF -Feedwater FW -Refueling WaterKC -Component CoolingNC -Reactor CoolantND -Residual Heat RemovalE1-29 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

NF -Ice Condenser Refrigeration NI -Safety Injection NS -Containment SprayNV -Chemical Volume & ControlRN -Nuclear Service WaterRV -Cont Vent Cooling WaterSA -Auxiliary SteamSM -Main SteamSV -Main Steam VentVP -Cont Purge VentVQ -Cont Air Release & AdditionWL -Liquid Waste & Recycle(2) HSS Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room is notincluded in the Weld Count or Summary Results.El-30 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 3.2Failure Potential Assessment SummaryThermal Localized FlowFatigue Stress Corrosion Cracking Corrosion Sensitive System(1)(

2) TASCS TT IGSCC TGSCC ECSCC PWSCC MIC PIT CC E-C FACCACF V"FWKCNC V V "NDNFNI V V VNSNV "RN V VRVSASMSVVPVQWLNotes:1. Systems are described in Table 3.1a, Table 3.1b2. A degradation mechanism assessment was not performed on low safety significant piping segments.

This includesthe CA, FW, KC, NF, NS, RV, SA, SM, SV, VP, VQ and WL systems in their entirety, as well as portions of the ND, NI,NV and RN systems.E1-31 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 3.3a: Unit 1 Code Case N716 Selections System Weld Count N716 Selection Considerations Selections (1) HSS LSS DMs RCPB RCPB (IFIV) RCPB (OC) BERCA 159 None 08 TT 2CF 111 None 1013 None 0FW 136 None 0KC 8 None 054 TT V / 1413 IT V 327 TASCS,TT V V 9NC 2 TASCS 1 /8 None , V V 5248 None V , 2327 None V 215 None V 0ND 2 None 0485 None 0NF 2 None 08 TT,IGSCC V 230 IGSCC V 8NI 205 None V 480 None 2553 None 0NS 443 None 0II TT v, 320 None v V 9NV86 None V, 01031 None 0RN (2) 17 None 0RV 9 None 0SA 22 None 0SM 164 None 0SV 37 None 0VP 20 None 0VQ 78 None 0WL 8 None 08TT2SummaryResultsAllSystems54 TT V V 1424 IT T 627 TT.,TASCS V V 92 TASCS 1 V8 TT,IGSCC V 230 IGSCC v 88 None V V V 5268 None V V 32333 None V 6193 None 123185 None 0El-32 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

[ System Weld Count N716 Selection Considerations Selections (1) HSS LSS DMs I RCPB RCPB (IFIV) RCPB (OC) BERTotals 955 3185 None 97Notes:(1) Systems are described in Table 3.1(2) HSS Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room isnot included in the Weld Count or Summary ResultsE1-33 RR 13-MN-002 ENCLOSURE ITemplate Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 3.3b: Unit 2 Code Case N716 Selections System Weld Count N716 Selection Considerations Selections (1) HSS LSS DMs RCPB RCPB (IFIV) RCPB (OC) BERCA 121 None 08 TT 2CF 121 None II13 None 0kFW 154 None 0KC 6 None 060 TT V V 1531 TASCS,TT V / 82 TASCS 2 28 None V " V 6245 None " , 2423 None " 017 None V 0ND 2 None 0520 None 0NF 2 None 08 TT,1GSCC

, 238 IGSCC " 10NI 183 None V 074 None 3573 None 0NS 464 None 010 TT " 320 None V V 9NV96 None 11188 None 0RN (2) 22 None 0RV 10 None 0SA 22 None 0SM 185 None 0SV 35 None 0VP 20 None 0VQ 73 None 0WL 8 None 08 TT 260 TT I V 1510 TT T 331 TT,TASCS V V 8Summary 2 TASCS V V 2Results 8 TTIGSCC V 2All 38 IGSCC V 10Systems 8 None V V" 6265 None V V 33319 None 1197 None 143416 None 0Totals 946 3416 None 96E1-34 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Notes:(1) Systems are described in Table 3.1(2) HSS Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room isnot included in the Weld Count or Summary ResultsE1-35 RR 13-MN-002 ENCLOSURE ITemplate Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 3.4a Unit 1 Risk Impact Analysis ResultsSystem (I) Safety Break Failure Potential Inspections CDF Impact LERF ImpactSystem Significance Location DMs Rank SXI RIS B Delta w/POD w/o POD w/POD w/o PODCA Total Low Class 2 LSS Assume Medium 13 0 -13 1.30E-10 1.30E-10 1.30E-11 1.30E-11CF High FLB TT Medium 2 2 0 -2.40E-11 0.00E+00

-2.40E-12 0.OOE+00CF High FLB None Low 8 10 2 -1.00E-12

-1.00E-12

-1.00E-13

-1.00E-13 CF Low Class 2 LSS Assume Medium 2 0 -2 2.00E-1 I 2.OOE-I 1 2.00E-12 2.00E-12CF Total -5.OOE-12 1.90E-11

-5.OOE-13 1.90E-12FW Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00KC Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 0.O0E+00 O.00E+00 O.OOE+00NC High LOCA TT Medium 1 14 13 -4.92E-09

-2.60E-09

-4.92E-10

-2.60E-10 NC High PLOCA TT Medium 0 3 3 -5.40E-1I

-3.OOE-11

-5.40E-12

-3.OOE- 12NC High LOCA TASCS,TT Medium 4 9 5 -2.76E-09

-1.00E-09

-2.76E-10

-1.00E-10 NC High LOCA TASCS Medium 0 1 1 -3.60E-10

-2.OOE-10

-3.60E- 11 -2.OOE-I 1NC High LOCA None Low 56 19 -37 3.70E-10 3.70E-10 3.70E-l 1 3.70E-1INC High PLOCA None Low 0 0 0 0.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00NC High PPLOCA None Low 0 0 0 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00NC Total -7.72E-09

-3.46E-09

-7.72E-10

-3.46E-10 ND High PLOCA None Low 5 0 -5 2.50E-12 2.50E-12 2.50E-13 2.50E-13ND High PPLOCA None Low 1 0 -1 5.OOE-15 5.OOE-15 5.OOE-16 5.OOE-16ND Low Class 2 LSS Assume Medium 51 0 -51 5.10E-10 5.10E-10 5.10E-l1

5. OE-1 IND Total 5.13E-10 5.13E-10 5.13E-11 5.13E-11NF Total Low Class 2 LSS Assume Medium 0 0 0 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00NI High PLOCA TTIGSCC Medium 0 2 2 -2.OOE-1I

-2.OOE-II

-2.OOE-12

-2.OOE-12 NI High PLOCA IGSCC Medium 11 8 -3 3.OOE-1 I 3.OOE- I 3.OOE-12 3.OOE-12NI High PLOCA None Low 26 4 -22 1.10E-1I 1.10E-I1 1.10E-12 1.10E-12NI High PPLOCA None Low 48 2 -46 2.30E-13 2.30E-13 2.30E-14 2.30E-14NI Low Class 2 LSS Assume Medium 36 0 -36 3.60E-10 3.60E-10 3.60E-1 I 3.60E-I 1NI Total 3.81E-10 3.81E-10 3.81E-11 3.81E-1INS Total Low Class 2 LSS Assume Medium 2 0 -2 2.00E-I 1 2.OOE-I1 2.OOE-12 2.OOE-12NV High PLOCA TT Medium 0 3 3 -5.40E-I I -3.OOE-I 1 -5.40E-12

-3.OOE-12 NV High LOCA None Low 0 0 0 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00NV High PLOCA None Low 0 0 0 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00E1-36 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

System (1) Safety Break Failure Potential Inspections CDF Impact LERF ImpactSignificance Location DMs Rank SXI RISB Delta w/POD w/o POD w/POD w/o PODNV Low Class 2 LSS Assume Medium 39 0 -39 3.90E-10 3.90E-10 3.90E- I1 3.90E-I 1NV Total 3.36E-10 3.60E-10 3.36E-1I 3.60E-11RN Total (7) Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00RV Total Low Class 2 LSS Assume Medium 1 0 -1 1.00E-11 1.00E-11 1.OOE-12 1.OOE-12SA Total Low Class 2 LSS Assume Medium 2 0 -2 2.00E-1I 2.OOE-11 2.OOE-12 2.OOE-12SM Total Low Class 2 LSS Assume Medium 16 0 -16 1.60E-10 1.60E-10 1.60E-11 1.60E-11SV Total Low Class 2 LSS Assume Medium 3 0 -3 3.OOE-1 1 3.OOE-11 3.OOE-12 3.OOE-12VP Total Low Class 2 LSS Assume Medium 2 0 -2 2.00E-I 1 2.0OE-11 2.OOE-12 2.OOE-12VQ Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00WL Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00Grand Total 329 77 -252 -6.11E-09

-1.80E-09

-6.11E-10

-1.80E-10 Notes1. Systems are described in Table 3.12. Only those ASME Section Xl Code inspection locations that received a volumetric examination are included in the count. Inspection locations previously subjected to a surface examination only were not considered in accordance with Section 3.7.1 of EPRI TR-1 12657.3. Only those RIS_B inspection locations that receive a volumetric examination are included in the count. Locations subjected to VT2 only arenot credited in the count for risk impact assessment.

4. The failure potential rank for high safety significant (HSS) locations is assigned as "High", "Medium",

or "Low" depending upon potential susceptibly to the various types of degradation.

[Note: Low Safety Significant (LSS) locations were conservatively assumed to be a rank ofMedium (i.e., "Assume Medium")5. The "LSS" designation is used to identify those Code Class 2 locations that are not HSS because they do not meet any of the five HSS criteriaof Section 2(a) of N-716 (e.g., not part of the BER scope).6. As described in Section 2.2, Alloy 82/182 welds susceptible to no degradation mechanism or PWSCC only per the RIS_B Program failurepotential assessment are not included in the table.7. The risk reduction associated with the HSS Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room is notincluded in the above table.E1-37 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 3.4b Unit 2 Risk Impact Analysis ResultsSystem (1) Safety Break Failure Potential Inspections CDF Impact LERF ImpactSystem_(1)

Significance Location DMs Rank SXI RIS B Delta w/POD w/o POD w/POD w/o PODCA Total Low Class 2 LSS Assume Medium 14 0 -14 1.40E-10 1.40E-10 1.40E-11 1.40E-11CF High FLB TT Medium 2 2 0 -2.40E-11 0.OOE+00

-2.40E-12 0.OOE+00CF High FLB None Low 7 11 4 -2.OOE-12

-2.OOE-12

-2.OOE-13

-2.OOE-13 CF Low Class 2 LSS Assume Medium 3 0 -3 3.00E-1 I 3.00E-1 1 3.OOE-12 3.00E-12CF Total 4.OOE-12 2.80E-11 4.OOE-13 2.80E-12FW Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00KC Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00NC High LOCA TT Medium 0 15 15 -5.40E-09

-3.00E-09

-5.40E-10

-3.00E-10 NC High LOCA TASCS.TT Medium 5 8 3 -2.28E-09

-6.OOE-10

-2.28E-10

-6.OOE-I INC High LOCA TASCS Medium 0 2 2 -7.20E-10

-4.OOE-10

-7.20E-11

-4.OOE- 1NC High LOCA None Low 49 19 -30 3.OOE-10 3.OOE-10 3.00E-11 3.00E-I 1NC High PLOCA None Low 0 0 0 0.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00NC High PPLOCA None Low 0 0 0 0.00E+00 0.OOE+00 0.OOE+00 0.00E+00NC Total -8.10E-09

-3.70E-09

-8.19E-10

-3.70E-10 ND High PLOCA None Low 5 0 -5 2.50E-12 2.50E-12 2.50E-13 2.50E-13ND High PPLOCA None Low 1 0 -1 5.00E-15 5.00E-15 5.00E-16 5.00E-16ND Low Class 2 LSS Assume Medium 53 0 -53 5.30E-10 5.30E-10 5.30E-11 5.30E-1IND Total I 5.33E-10 5.33E-10 5.33E-11 5.33E-11NF Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00NI High PLOCA TT,IGSCC Medium 0 2 2 -2.OOE-1I

-2.00E-11

-2.OOE-12

-2.00E-12 NI High PLOCA IGSCC Medium 8 8 0 0.OOE+00 0.OOE+00 0.00E+00 O.OOE+00NI High PLOCA None Low 18 0 -18 9.OOE-12 9.OOE-12 9.OOE-13 9.00E-13NI High PPLOCA None Low 53 3 -50 2.50E-13 2.50E-13 2.50E-14 2.50E-14NI Low Class 2 LSS Assume Medium 43 0 -43 4.30E-10 4.30E-10 4.30E-1 1 4.30E-1 1NI Total 4.19E-10 4.19E-10 4.19E-11 4.19E-11NS Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.0OE+00NV High PLOCA TT Medium 0 3 3 -5.40E-1I

-3.OOE-I 1 -5.40E-12

-3.00E-12 NV High LOCA None Low 0 0 0 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00NV High PLOCA None Low 1 0 0 0 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00NV Low Class 2 LSS Assume Medium 51 0 -51 5.10E-10 5.10E-10 5.10E-I 1 5.1OE- 1E1-38 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Safety Break Failure Potential Inspections CDF Impact LERF ImpactSystem (1) Significance Location DMs Rank SXI RIS B Delta wfPOD w/o POD w/POD w/o PODNV Total 4.56E-10 4.80E-10 4.56E-11 4.80E-1IRN Total (7) Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00RV Total Low Class 2 LSS Assume Medium 1 0 -1 I.OOE-1I 1.00E-I 1 1.00E-12 1.OOE-12SA Total Low Class 2 LSS Assume Medium 2 0 -2 2.OOE-11 2.OOE-11 2.0OE-12 2.OOE-12SM Total Low Class 2 LSS Assume Medium 19 0 -19 1.90E-10 1.90E-10 1.90E-11 1.90E-11SV Total Low Class 2 LSS Assume Medium 3 0 -3 3.00E-I I 3.OOE-1I 3.OOE-12 3.OOE-12VP Total Low Class 2 LSS Assume Medium 2 0 -2 2.00E-I 1 2.OOE-11 2.OOE-12 2.OOE-12VQ Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00WL Total Low Class 2 LSS Assume Medium 0 0 0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00Grand Total 339 73 -266 -6.28E-09

-1.83E-09

-6.28E-10

-1.83E-10 Notes1. Systems are described in Table 3.12. Only those ASME Section Xl Code inspection locations that received a volumetric examination are included in the count. Inspection locations previously subjected to a surface examination only were not considered in accordance with Section 3.7.1 of EPRI TR-1 12657.3. Only those RISB inspection locations that receive a volumetric examination are included in the count. Locations subjected to VT2 only arenot credited in the count for risk impact assessment.

4. The failure potential rank for high safety significant (HSS) locations is assigned as "High", "Medium",

or "Low" depending upon potential susceptibly to the various types of degradation.

[Note: Low Safety Significant (LSS) locations were conservatively assumed to be a rank ofMedium (i.e., "Assume Medium")5. The "LSS" designation is used to identify those Code Class 2 locations that are not HSS because they do not meet any of the five HSScriteria of Section 2(a) of N-716 (e.g., not part of the BER scope).6. As described in Section 2.2, Alloy 82/182 welds susceptible to no degradation mechanism or PWSCC only per the RISB Program failurepotential assessment are not included in the table.7. The risk reduction associated with the HSS Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room is notincluded in the above table.E1-39 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 4a: Unit 1 Inspection Location Selections Com parisonSystem Safety Significance Break Failure Potential Code Weld Section XI Code Case N716(1) High Low Location DMs Rank Category Count Vol Surface RISB OtherCA Class 2 LSS Assume Medium C-F-I, C-F-2 159 13 0 0 NACF / FLB TT Medium C-F-2 8 2 0 2 NACF FLB None Low C-F-2 111 8 0 10 NACF Class 2 LSS Assume Medium C-F-2 13 2 0 0 NAFW " Class 2 LSS Assume Medium C-F-I 136 0 0 0 NAKC Class 2 LSS Assume Medium C-F-2 8 0 0 0 NANC " LOCA TT Medium B-J 54 1 15 14 NANC " PLOCA TT Medium B-J 13 0 2 3 NANC V LOCA TASCS,TT Medium B-J 27 4 6 9 NANC " LOCA TASCS Medium B-J 2 0 0 1 NANC " LOCA. None Low B-F, B-i 256 56 32 19 9NC " PLOCA None Low B-J 22 0 I 0 2NC " PPLOCA None Low B-1 5 0 3 0 NAND " PLOCA None Low B-i 15 5 0 0 NAND PPLOCA None Low C-F-I 2 1 0 0 NAND _ _ Class 2 LSS Assume Medium C-F- 1 485 51 0 0 NANF Class 2 LSS Assume Medium C-F-1 2 0 0 0 NANI V PLOCA TT,IGSCC Medium B-i 8 0 8 2 NANI / PLOCA IGSCC Medium B-i 30 11 0 8 NANI " PLOCA None Low B-J 171 26 12. 4 NANI " PPLOCA None Low C-F- 1 114 48 0 2 NANI Class 2 LSS Assume Medium C-F-1 553 36 16 0 NANS " Class 2 LSS Assume Medium C-F-I 443 2 0 0 NANV " PLOCA TT Medium B-J 11 0 4 3 NANV " LOCA None Low B-J 20 0 7 0 9NV " PLOCA None Low B-J 86 0 23 0 NANV Class 2 LSS Assume Medium C-F-i 1031 39 40 0 NARN (5) / Class 2 LSS Assume Medium C-F-2 17 0 0 0 NARV / Class 2 LSS Assume Medium C-F-2 9 1 0 0 NASA / Class 2 LSS Assume Medium C-F-2 22 2 0 0 NAEl-40 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

System Safety Significance Break Failure Potential Code Weld Section XI Code Case N716(1) High Low Location DMs Rank Category Count Vol Surface RISB OtherSM V Class 2 LSS Assume Medium C-F-2 164 16 0 0 NASV Class 2 LSS Assume Medium C-F-2 37 3 0 0 NAVP Class 2 LSS Assume Medium C-F-2 20 2 0 0 NAVQ ___Class 2 LSS Assume Medium C-F-I 78 06 0 0 NAWL _" Class 2 LSS Assume Medium C-F-1 8 0 0 0 NATotals 4140 329 169 77 20Notes1. Systems are described in Table 3.12. The column labeled "Other" is generally used to identify plant augmented inspection program locations credited per Section 4 of Code CaseN-716. Code Case N-716 allows the existing plant augmented inspection program for IGSCC (Categories B through G) in a BWR to becredited toward the 10% requirement.

This option is not applicable for the McGuire RISB application.

The "Other" column has been retainedin this table solely for uniformity purposes with other RISB application template submittals and to indicate when RIS_B selections will receivea VT-2 examination (these are not credited in risk impact assessment).

3. The failure potential rank for high safety significant (HSS) locations is assigned as "High", "Medium",

or "Low" depending upon potential susceptibly to the various types of degradation.

[Note: Low safety significant (LSS) locations were conservatively assumed to be a rank ofMedium (i.e., "Assume Medium").

4. As described in Section 2.2, Alloy 82/182 welds susceptible to no degradation mechanism or PWSCC only per the RIS_B Program failurepotential assessment are not included in the table.5. Inspection locations associated with the HSS Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room are notincluded in the above table.E1-41 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

Table 4b: Unit 2 Inspection Location Selections Comparison System Safety Significance Break Location Failure Potential Code Weld Section XI Code Case N716(1) High Low DMs Rank Category Count Vol Surface RISB OtherCA __ _Class 2 LSS Assume Medium C-F-I, C-F-2 121 14 0 0 NACF V FLB TT Medium C-F-2 8 2 0 2 NACF / FLB None Low C-F-2 121 7 0 11 NACF " Class 2 LSS Assume Medium C-F-2 13 3 0 0 NAFW V Class 2 LSS Assume Medium C-F-1 154 0 0 0 NAKC V Class 2 LSS Assume Medium C-F-2 6 0 0 0 NANC / LOCA TT Medium B-J 60 0 12 15 NANC V LOCA TASCS,TT Medium B-F, B-J 31 5 8 8 NANC V LOCA TASCS Medium B-1 2 0 2 2 NANC / LOCA None Low B-F B-J 253 49 20 19 11NC _ _ PLOCA None Low B-J 18 0 3 0 NANC V PPLOCA None Low B-J 5 0 0 0 NAND " PLOCA None Low B-J 17 5 0 0 NAND V PPLOCA None Low C-F-i 2 1 0 0 NAND " Class 2 LSS Assume Medium C-F-1 520 53 1 0 NANF Class 2 LSS Assume Medium C-F-1 2 0 0 0 NANI " PLOCA TT.,IGSCC Medium B-J 8 0 7 2 NANI V PLOCA,PPLOCA IGSCC Medium B-J 38 8 1 8 2NI PLOCA None Low B-4 114 18 8 0 NANI " PPLOCA None Low C-F-1 143 53 6 3 NANI " Class 2 LSS Assume Medium C-F-1 573 43 14 0 NANS Class 2 LSS Assume Medium C-F-i 464 0 0 0 NANV V PLOCA TT Medium B-J 10 0 4 3 NANV V LOCA None Low B-J 20 0 4 0 9NV / PLOCA None Low B-1 96 0 26 0 1NV V Class 2 LSS Assume Medium C-F-I 1188 51 39 0 NARN (5) " Class 2 LSS Assume Medium C-F-2 22 0 0 0 NARV V Class 2 LSS Assume Medium C-F-2 10 1 0 0 NASA V Class 2 LSS Assume Medium C-F-2 22 2 0 0 NASM __ Class 2 LSS Assume Medium C-F-2 185 19 0 0 NAEl-42 RR 13-MN-002 ENCLOSURE 1Template Submittal McGuire Nuclear StationPROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

System Safety Significance Failure Potential Code Weld Section XI Code Case N716Break Location

____ _____(1) High Low DMs Rank Category Count Vol Surface RISB OtherSV " Class 2 LSS Assume Medium C-F-2 35 3 0 0 NAVP " Class 2 LSS Assume Medium C-F-2 20 2 0 0 NAVQ v/ Class 2 LSS Assume Medium C-F-1 73 0 0 0 NAWL __ Class 2 LSS Assume Medium C-F-I 8 0 0 0 NATotals 4362 339 155 73 23Notes1. Systems are described in Table 3.12. The column labeled "Other" is generally used to identify plant augmented inspection program locations credited per Section 4 of Code CaseN-716. Code Case N-716 allows the existing plant augmented inspection program for IGSCC (Categories B through G) in a BWR to becredited toward the 10% requirement.

This option is not applicable for the McGuire RIS_1B application.

The "Other" column has been retainedin this table solely for uniformity purposes with other RISB application template submittals and to indicate when RIS_B selections will receivea VT-2 examination (these are not credited in risk impact assessment).

3. The failure potential rank for high safety significant (HSS) locations is assigned as "High", "Medium",

or "Low" depending upon potential susceptibly to the various types of degradation.

[Note: Low safety significant (LSS) locations were conservatively assumed to be a rank ofMedium (i.e., "Assume Medium").

4. As described in Section 2.2, Alloy 82/182 welds susceptible to no degradation mechanism or PWSCC only per the RIS_B Program failurepotential assessment are not included in the table.5. Inspection locations associated with the HSS Class 3 RN (nuclear service water) system piping in the auxiliary feedwater pump room are notincluded in the above table.El-43

.Attachment A to McGuire N-716 TemplateConsideration of the Adequacy ofProbabilistic Risk Assessment Model forApplication of ASME Code Case N-716A-i Attachment AEvaluation of Technical Adequacy1 Introduction The purpose of this attachment is to document an assessment of the technical adequacy of the McGuirePRA model of record for use in the Risk-Informed In-Service Inspection (RI-ISI) submittal to the NuclearRegulatory Commission (NRC). Any discrepancies between the model of record and the technical adequacy assessment will be supported using sensitivity studies.2 Description of MethodA qualitative discussion is provided for the disposition of each finding and observation (F&O) from theinternal gap assessment to the ASME/ANS PRA Standard and peer review to NEI 00-02." Regulatory Guide 1.174 (Reference 8.1) provides guidance on the use of PRA findings and riskinsights to support licensee requests for changes to a plant's Licensing Basis, as in requests forlicense amendments and technical specification changes.* Regulatory Guide 1.177 (Reference 8.2) provides guidance on the use of PRA in support ofdecisions to modify an individual plant's Technical Specifications (TS)." EPRI report TR 1021467-A (Reference 8.6) provides guidance on determining the technical adequacy of PRAs used to develop a RI-ISI program.* NEI 05-04 (Reference 8.8) provides guidance on the peer review process, including the originalpeer reviews to NEI 00-02 and a subsequent gap assessment to the ASME/ANS PRA Standard.

3 Sensitivity StudiesSensitivity cases were performed where applicable for open PRA model F&Os and gap assessment items.A sensitivity study was also performed for outstanding PRA model changes.The results of the sensitivity studies were evaluated against the model of record importance measuresto determine the final scope of pressure boundary pipe break failures that scope into the RI-ISI program.4 Assessment of Technical Adequacy for the Internal Events ModelThe McGuire PRA model of record is mr3c, which became effective in November 2012. The McGuireinternal events model (excluding internal flood and LERF) has received a peer review to NEI 00-02(Reference 8.12) and a subsequent gap assessment to the ASME/ANS PRA Standard (Reference 8.14).The internal flood and LERF models have since received focused peer reviews are discussed in Sections4.3 and 4.4.Page A-1 of A-168 4.1 Internal Events Peer Review to NEI 00-02In October 2000, the internal events PRA model received a peer review to certify the acceptability ofPRAs before a consensus PRA Standard was available.

McGuire participated in the Westinghouse Owners Group (WOG) PRA Certification Program.

The industry-developed process and methodology outlined in NEI 00-02 (Reference 8.7) was used for the peer review. The review process was originally developed and used by the Boiling Water Reactor Owners Group (BWROG) and subsequently broadened to be an industry-applicable process through the Nuclear Energy Institute (NEI) Risk Applications TaskForce. The resulting industry

document, NEI-00-02, describes the overall PRA peer review process.The results of the review provided strengths, weaknesses, and areas for improvement.

Overall, the peerreview indicated the process used and technical adequacy was satisfactory and acceptable for use inapplications.

A summary of some of the McGuire PRA strengths and recommended areas forimprovement from the peer review are as follows:Strengths

• Good Summary Report write-up with insights* Good system notebooks

• Rigorous Level 2 & 3 PRA Model* Integrated internal and external events model" Up-to-date plant database using Maintenance Rule* Ongoing PRA staff interaction with plant staff, plant staff reviews" PRA personnel knowledge of plant goodRecommended Areas for Improvement

" Better integration of sequences and recoveries within quantification process needed* Need to review treatment of events requiring time-phasing in the modeling* Better approach to closing the loop on PRA update items (tracking of errors/mods) needed* More thorough, systematic approach to Human Reliability Analysis (HRA) screening values andcommon cause modeling needed" Need an approach for reconciling realistic LERF model with NRC expectations from simplistic LERF modeling" Need to update the PRA model to be more in line with current practices and expectations forstate-of-the-art PRAThe significance levels of the WOG Peer Review Certification process have the following definitions:

A. Extremely important and necessary to address to ensure the technical adequacy of the PRA, thequality of the PRA, or the quality of the PRA update process.B. Important and necessary to address but may be deferred until the next PRA update.Based on the PRA peer review report, the McGuire PRA received six Fact and Observations (F&Os) withthe significance level of "A" and 31 F&Os with the significance level of "B." Since the NEI 00-02 peerreview, focused peer reviews have been performed for the internal flood and large early release (LERF)Page A-2 of A-168 models, which supersede six F&Os: "A" level F&O L2-7 and "B" level F&Os L2-5, [2-9, L2-10, DE-1 andDE-2.All of the "A" F&Os have been addressed and changes are incorporated into the current McGuireinternal events PRA model. The remaining "B" F&Os have been reviewed and prioritized forincorporation into the PRA. Twelve of the "B" F&Os have already been incorporated into the currentMcGuire internal events PRA model. The 31 F&Os from the peer review that have not been superseded are dispositioned for the RI-ISI application as follows.Page A-3 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element.:

Related Elements:

Level of Significance:

IE-2 IE-5 BPeer Review F&O:Loss of HVAC initiator was removed, because operators may shut down the plant from remote locations (the Auxiliary Shutdown Panel and the SSF) if the Control Room is incapable of maintaining inventory control.

Not only the control room, but also the switch gear room may be affected by the failed HVAC.A particular example of interest is the possibility that the switch gear room AHU might fail but the HVACchiller is working, in which case operators may not realize the situation in time. CDF may be affected bysuch an initiator.

Justification for Level of Significance CDF may be affected by such an initiator Possible Resolution:

........Perform/document additional evaluation of loss of switchgear room HVAC and, if appropriate, develop anew event tree to analyze the sequence of loss of switch gear room cooling.Disposition of the Peer Review Finding:This F&O is under evaluation as part of the in-progress McGuire PRA model update. Equipment roomsthat have not been screened or previously modeled will be modeled as part of the update, including the4160 V Switchgear Room (refer to the screening study performed in F&O TH-6). A sensitivity study wasperformed in Section 7.1 to determine the impacts of this F&O on the RI-ISI application.

This studyfound that for initiating event sequences that impact the RI-ISI application, the impact from ControlRoom Area Ventilation is insignificant with respect to risk. Therefore, this sensitivity study shows thatthis F&O has an insignificant impact on the results or conclusions of the RI-ISI application.

Page A-4 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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Level of Significance:

IE-5 IE-10 IE-17 BPeer Review F&O:SAAG File 594 lists those support systems for which failure is included as an initiating event but does notclearly document the basis for exclusion of other support system failures such as Vital AC. A morestructured approach for screening support system initiating events should be documented.

Related to this modeling of special initiating events are the following observations:

1. The loss of Vital I&C Power is modeled as loss of panel D based on the fact that this panel supportstwo PORVs. However, the potential impact of loss of panel A on other supported components is notclearly addressed.

2. The basis for not including loss of the 125 V DC Auxiliary Control Power panel as a special initiating event when at least two such events have occurred in plant operating history is not documented.

Justification for Level of Significance:

It is likely that the excluded failures are less important than those modeled, but a clear basis for thedetermination of which special initiating events to model should be provided, especially for events thathave previously occurred at the plant.Possible Resolution

.......Document the disposition of each support system as a potential initiating event during the next update.Consider modeling the loss of Vital I&C Panel A as a separate initiating event.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The workplace procedure for PRA Modeling Guidelines (Reference 8.82) was updated to include therequirement to document in each system notebook whether an initiating event could occur due to afailure of the system. This discussion was then formally documented as part of the update to the PRAmodel of record. This update did not include a new methodology nor did it involve a significant changein scope or capability because the review for system initiators was previously performed, but was notformally documented.

No new system initiators were identified as a result of this update.Page A-5 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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Level of Significance:

IE-6 IE-12 BPeer Review F&O: ... ...The method used for calculating generic prior distributions for Bayesian updating seems tounderestimate the generic frequencies.

The McGuire approach combines the experienced failures intoone bin and calculates a single generic prior based on this experience and the time period covered.

Thetypical industry approach would be to use published generic values to define the prior mean anddistribution or to input industry experience into a two-stage Bayesian update process which generates ageneric mean and distribution for use in Bayesian updating the plant-specific data. It is not clear thatthe approach used for McGuire produces equivalent results.Justification for Level of Significance:

Initiating event values may be underestimated.

Possible Resolution....:

Perform two-stage Bayesian updating based on industry experience or adopt published generic valuesfrom sources such as NUREG/CR-5750.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The McGuire initiator frequency calculation (Reference 8.29) was revised to include the basis for whento use plant-specific data, generic (industry) data or a fault tree solution.

Additionally, the methodology for performing a Bayesian update using plant-specific data has been formally documented withinReference 8.29. This update did not change the Bayesian update methodology, it merely providedformal documentation.

This update also subdivided the small break LOCA initiator into small break LOCA (SBLOCA),

reactorcoolant pump seal LOCA (RCPSL),

stuck-open PORV and stuck-open SAFETY as defined in NUREG/CR-5750. However, this update did not include a new methodology nor did it involve a significant change inscope or capability.

Similar to Example 15 in Section 1-A.3.15 of RA-Sa-2009, the modeling isstraightforward and does not involve any new methodology beyond the separation of the initiating events. The quantified impact on initiating event frequency from splitting the SBLOCA initiating eventwas small; therefore this change falls into the category of model error correction.

Page A-6 of A-168 F&O Regarding PRA Technical Elements:

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Level of Significance:

AS-1 AS-4 AS-12, AS-13, QU-11 APeer Review F&O:LOOP and SBO sequences are quantified using the transient event tree rather than a special event tree.Modeling of special station blackout issues is done through fault tree fault logic. It appears there maynot be enough sequences on the transient event tree to capture all of the necessary SBO modelingconcerns.

Only 2 sequences on the transient event tree result in cutsets for SBO (class 7,14). Thetransient event tree only has one branch to discern seal LOCA sequences Q(S). It appears the fault treelogic combines the probability of seal failure with the probability of non-recovery of offsite power forfailure at Q(S). After success of seal integrity and SSHR, no further systems are required by the modelfor successful mitigation.

Furthermore, there is no time phasing for SBO. In Rev 2, effects of batterydepletion in long term station blackout are neglected.

An operator error for failure to control AFW TDPafter battery depletion is included, but the value of the HEP is indicative of control failures wheninstrumentation is available.

The overall probability to maintain safe shutdown and recover offsitepower without DC power or instrumentation (ie., after battery depletion) is not addressed.

The SBO quantification neglects two classes of sequences which have been shown to be important atother plants -1) Maintenance of safe shutdown and restoration of AC power after battery depletion

2) Sequences when offsite power (OSP) is recovered while a seal LOCA is in progress, but the core isstill covered at the time of OSP recovery.

The event tree structure delineates seal LOCA through theevent Q(S). It appears the failure branch represents failure to recover AC power prior to coredamage due to seal LOCA. The success branch is therefore a) no seal failure or b) seal failure, but ACpower recovery prior to core uncovery.

Justification for Level of Significance:

This was assigned a significance A, because of the very low probability of SBO CD sequences in thecurrent results, which is not typical of results for similar plants that have addressed the types ofconsiderations listed above.Possible Resolution

1. Verify that it is possible (highly probable) to maintain the plant safe shutdown without DC power ormodify the model to result in CD after battery depletion.

2. Verify that the seal LOCA sequences that are considered success are small contributors or revise theseal LOCA model.Page A-7 of A-168 Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The AC Power model (Reference 8.30) was updated to include the impact of battery depletion withsubsequent recovery of offsite power. This update involved adding a new event to the fault treerepresenting the failure to manually close essential bus supply breakers given a loss of DC power. Theupdate did not include any new methodology nor did it involve a significant change in scope orcapability because the impact from this change on CDF was small and significant accident sequences andsignificant accident progression sequences were not impacted.

Similar to Example 7 in Section 1-A.3.15of RA-Sa-2009, the change involved correcting a model omission without a significant change in scope orin capability.

The RCP seal LOCA model (Reference 8.46) was updated to use the WOG2000 seal leakage model ratherthan the model from WCAP-10541.

This update included high seal leak rates prior to 90 minutes inaddition to those already included after 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Whereas this update involved a change in industry sealleakage models, it does not constitute a methodology change in the RCP seal leakage fault tree logic.This is due to there being existing logic in the PRA model addressing an induced RCP seal leak. TheWCAP-10541 seal failure occurs much later in time than in the WOG2000 model, but the addition of anearlier seal failure was applied to the fault tree logic using existing methodologies.

This update did not involve a significant change in scope or capability because the change incontribution to CDF from an RCP seal LOCA was small and no new significant accident sequences orsignificant accident progression sequences were introduced.

Similar to Example 3 in Section 1-A.3.15 ofRA-Sa-2009, this update required the selection of a new industry model which contained newinformation on seal performance.

Similar to Example 15 in Section 1-A.3.15 of RA-Sa-2009, whereas thisupdate was fairly extensive in terms of the number of model locations

involved, the modeling itself isstraightforward and does not involve any new methodology beyond the addition of a new failure modeearlier in the accident sequence.

The transient event tree does not reflect the success path for recovering offsite power following a lossof seal cooling but prior to core damage (Reference 8.74). However, offsite power recovery is reflected in the PRA model using the recovery rule file during post-processing of the cutset file. Historically, thePRA documentation did not include post-processing actions in the event tree. This is a documentation issue only, since the model accurately reflects the prevention of core damage due to a successful recovery of offsite power. Therefore, there is no impact to the results or conclusions of this application from this omission to the event tree.Page A-8 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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Level of Significance:

AS-3 AS-9 DE-5 BPeer Review F&O:Success criteria for AFW for SGTR is AFW flow to 2/3 SG, assuming the ruptured generator is not fed.The logic in the fault tree model is 2/4 SG. An IE FLAG for SGTR is needed for the "B" SG, in accordance with the report write-up such that credit is not taken for the ruptured SG.Justification for Level of Significance:

Need to ensure that the AFW logic is correct.Possible Resolution Verify/correct the AFW logic modeling for SGTR.Disposition of the Peer Review Finding:

........This F&O has been addressed and incorporated into the PRA model of record.The Auxiliary Feedwater (CA) model (Reference 8.32) was updated to include the existing SGTR initiating event as a failure of the ruptured steam generator.

The update did not include a new methodology nordid it involve a significant change in scope or capability due to the insignificant amount of risk associated with the fault tree logic change. Similar to Example 7 in Section 1-A.3.15 of RA-Sa-2009, the changeinvolved correcting a model omission without a significant change in scope or in capability.

Page A-9 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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Level of Significance:

AS-4 AS-12 HR-12 BPeer Review F&O:Restoration of seal cooling:The time to connect the SSF is 15 minutes.

The operator error associated with restoration of cooling isbased on a time constraint of 15 minutes.

Current WOG ERG recommendation for restoration of sealcooling is that if seal cooling is lost for 15 minutes, thermal barrier cooling is to be re-established priorto restoring seal injection flow. The WOG recommendation is to prevent shocking of the seal with coldwater which could lead to seal failure itself.The success path for the SSF would have seal injection flow restored prior to 15 minutes and therewould be no seal shocking or induced seal failure.

There are two potential failures paths for the SSF -a)failure to restore seal cooling at any time, and b) restoration of seal cooling after the 15 minute timeframe, leading to induced seal failure.

The second path is not addressed in the McGuire PRA.Justification for Level of Significance:

Seal failure after blackout is already included in the model. This failure path represents an additional failure mode which should be examined.

It was labeled a "B", because the worst result is to raise SLOCAprobability during blackout.

It would not add a new sequence to the PRA.Possible Resolution Consider the need to model the additional

scenario, and implement if appropriate or document theadequacy of the current model.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The RCP seal LOCA model (Reference 8.46) was updated to use the WOG2000 seal leakage model ratherthan the model from WCAP-10541.

This update included high seal leak rates prior to 90 minutes inaddition to those already included after 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Site-specific MAAP runs were performed to estimatecore uncovery times and the core uncovery time was determined to be less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for all cases.The MAAP code is used by the PRA group for thermal-hydraulic calculations and implementation of thecore uncovery timing was consistent with existing modeling techniques.

Therefore, similar to Example 8in Section 1-A.3.8 of RA-Sa-2009, this update is considered PRA maintenance.

The PRA model does not account for restoration of seal cooling after the 15 minute time frame. Whileshock-induced seal failure could increase seal leakage flows, it is judged to not significantly impact thetime to core uncovery due to the already high assumed leakage rates. Additionally, there is a sitecalculation on RCP and NV seal leakoff piping response (Reference 8.18) which shows that the seals willPage A-10 of A-168 not fail for a loss of all AC or Appendix R events that requires manual initiation of seal injection with thestand-by make-up pump from the SSF even if the action takes longer than 15 minutes."The potential for the thermal shock to the No. 1 seal faces was evaluated using simple and conservative calculations.

The calculations indicated that the stresses induced in the seal during the heatup and the cooldown phases of thetransient are acceptable" For other procedures requiring restoration of seal cooling (e.g., loss of RN, loss of charging, etc.), theprocedure directs the operators to ensure that the RCP seals are not hot. If the RCP seals are hot, theoperators will not start the stand-by make-up pump.No modeling changes were required to address this part of the F&O and therefore there is no impact tothe results or conclusions of this application due to the omission of the shock-induced seal failure.Page A-11 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element-Related Elements:

Level of Signi ficance:AS-5 AS-12 QU-11 APeer Review F&O:WCAP 10451, Rev 2 is the basis for seal LOCA in MPRA Rev2. There are three timing discrepancies in theuse of this model. When they are taken together, the effect is that only seal failures between 90minutes and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> are considered.

1) The McGuire SBO model extends to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The WCAP model provides data and tables toestimate the probability of core damage up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the time of loss of seal cooling.

Byusing the WCAP data, core uncovery sequences after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> are neglected.

2) 90 minutes is the assumed time for cross-connect of AC power to avoid a SBO. Cross-tie of ACpower in less than 90 minutes avoids an SBO and thus avoids a seal LOCA.3) The McGuire model uses the WCAP probabilities for core uncovery, not seal failure.

Considering the core uncovery time, core damage at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is caused by seal failure at 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.Rev 3 models address all probability of seal failures, but Rev 3 was not complete at the time of thisreview and was reviewed.

Justification for Level of Significance:

This was significance A due to the unusually low CDF from SBO and the possibility some sequences aremissing.Possible Resolution Verify acceptability of the 90min to 5 hr time frame for seal LOCA or add the complete spectrum of sealLOCA's to the model.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The RCP seal LOCA model (Reference 8.46) was updated to use the WOG2000 seal leakage model ratherthan the model from WCAP-10541.

This update included high seal leak rates prior to 90 minutes inaddition to those already included after 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Whereas this update involved a change in industry sealleakage models, it does not constitute a methodology change in the RCP seal leakage fault tree logic.This is due to there being existing logic in the PRA model addressing an induced RCP seal leak. TheWCAP-10541 seal failure occurs much later in time than in the WOG2000 model, but the addition of anearlier seal failure was applied to the fault tree logic using existing methodologies.

This update did not involve a significant change in scope or capability because the change incontribution to CDF from an RCP seal LOCA was small and no new significant accident sequences orPage A-12 of A-168 significant accident progression sequences were introduced.

Similar to Example 3 in Section 1-A.3.3 ofRA-Sa-2009, this update required the selection of a new industry model which contained newinformation on seal performance.

Similar to Example 15 in Section 1-A.3.15 of RA-Sa-2009, whereas thisupdate was fairly extensive in terms of the number of model locations

involved, the modeling itself isstraightforward and does not involve any new methodology beyond the addition of a new failure modeearlier in the accident sequence.

Page A-13 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:'

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TH-1 TH-7 BPeer Review F&O:Success criteria for some systems are supported by MAAP runs with MAAP 3b, Version 16. This versionof MAAP has been found to have deficiencies which can impact conclusions and results.

In particular forthe McGuire PRA, the simple pressurizer model impacts the analyses that involve RCS cooldown anddepressurization using SG heat removal by permitting RCS depressurization to match RCS cooldown fortransients, without the possible need for pressurizer PORVs, spray or aux spray.Justification for Level of Significance

<Some success criteria may be overly optimistic as a result of the use of the older version of the code.Possible Resolution:

Re-run selected analyses with later version of MAAP code that has an enhanced pressurizer model todetermine extent of impact, OR make use of other transient analysis results (including the full scopesimulator).

Disposition of the Peer Review Finding:The McGuire PRA model is currently undergoing a revision.

An updated success criteria analysis hasbeen performed in calculation MCC-1535.00-00-0120 (Reference 8.49), which received an independent review per the Duke QA program.

This analysis used existing methodologies to generate the successcriteria.

The updated success criteria were compared against those used in the model of record and nosignificant differences were found (refer to the following table). The new analysis used MAAP revision5.0.1 and specifically considered whether pressurizer PORVs, spray or aux spray were required for eachaccident scenario.

Table 1: Comparison of MOR Success Criteria Against the Updated PRA ModelEvent Model of Record Updated Success CriteriaLBLOCA -1 ND pump & 2 accumulators

-1 ND pump & 2 accumulators MBLOCA -1 NV pump or 1 NI pump -1 NV pump or 1 NI pump with SSHR-< 2" break is classified as an SBLOCA -1 NV pump w/o SSHR for 1.5" -2" breakSBLOCA -1 NV pump or 1 NI pump with SSHR -1 NV pump or 1 NI pump with SSHR-lNV pump or I NI pump & 2 open PORVsw/o

-I NV pump & 1 open PORV or 1 NI pump & 2SSHR open PORVs w/o SSHRSGTR -1 NV pump or 1 NI pump with SSHR -1 NV pump or 1 NI pump or primary-1 NV pump or 1 NI pump & 2 open PORVs w/o depressurization with SSHRSSHR -Feed & Bleed cooling w/o SSHRPage A-14 of A-168 Stuck-Open

-1 NV pump or I NI pump with SSHR for stuck -1 NV pump or I NI pump with SSHR for stuckValves PORV PORV-1 NV pump or 1 NI pump & 2 open PORVs w/o -1 NV pump or 2 NI pumps w/o SSHR for stuckSSHR for stuck PORV PORV-1 NV pump or 1 NI pump for stuck SRV -1 NV pump 2r I NI pump for stuck SRVFeed & Bleed -1NVpump&

1 NI pump& 1 PORVor2 NV -1 NVpump& 1 PORVwithSSHRorl NI pump&pumps & 1 PORV w/o SSHR 2 PORVs w/o SSHR-1 NV pump or 1 NI pump & 1 PORV with SSHRrun failureBased on a comparison of the revision to the success criteria calculation to the PRA model of record, thisF&O has an insignificant risk impact and will not impact the results and conclusions of the RI-ISIapplication.

Page A-15 of A-168 F&O Regarding PRA Technical Elements......: ::. : .. * ......Observation ID: Element:

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TH-2 TH-2 AS-22 BPeer Review F&O:Success Criteria for core damage in SAAG calculation records (e.g., Medium LOCA and Feed and Bleed) isgiven as 4040 degree F, which corresponds to eutectic melting point of the fuel. Industry practice is touse something in the neighborhood of 2000 degree F because most of the fission products are releasedat temperatures just above that point. Clad damage becomes widespread at about 2200 F and volatilefission product species are released from the core matrix at 2400 to 3000 F. Thus, risk (LERF) isimportant from that point forward.Justification for Level of Significance:

.. .....None of the success criteria runs reviewed predicted that temperatures would exceed about 1800 F, sothe overall results are not likely to be impacted, but it is important to clearly define the core damageassumption for the PRA.Possible Resolution Define overall core cooling success criteria consistent with industry practices.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The McGuire success criteria calculations (References 8.75, 8.76, 8.77 and 8.78) have been revised todefine success criteria as core temperature remains below 2000 Deg F. The new definition definessuccess criteria as "the hottest core node remained below 2000 Deg F". In addition, a reference for the2000 Deg F is included in these calculations, which is EPRI document NP-6328, "Release of VolatileFission Products From Irradiated LWR Fuel: Mass Spectrometry Studies",

Final Report, April 1989. Thedifference in time to core damage is not significant when using either 2000 Deg F or 4000 Deg F becausethe exothermic nature of the zircaloy-water reaction rapidly increases the fuel temperature.

Therefore, this update did not have a significant impact on the time available for human recoveries or other non-recovery events such as loss of offsite power recoveries.

The MAAP code is used by the PRA group for thermal-hydraulic calculations and implementation of thedefinition of success criteria was consistent with existing modeling techniques.

Therefore, similar toExample 8 in Section 1-A.3.8 of RA-Sa-2009, this update is considered PRA maintenance.

Page A-16 of A-168 F&O Regarding PRA Technical Elements.Observation ID: Element:

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...........: ...... .. ....: .TH-3 TH-4 AS-18 B*Peer. Review F&O:Success Criteria analyses were not done for the range of possible plant conditions to which they areapplied.

For example, MLOCA success criteria analyses are done for a 3.5 inch break, while the MLOCAis defined as a 2 to 5 inch break. The combinations of systems and operator recoveries that are definedas success at 3.5 inches may not be success at 2 inches or at 5 inches. This issue also applies to largeLOCA (8.25 ft2 break analyzed) vs a break range down to 6 inches, and small LOCA (1 inch breakanalyzed) vs. break sizes from 3/8 to 2 inches.Also, MAAP is not an appropriate code to use in performing analyses for rapid blowdown events such aslarge and some medium LOCAs.tification for Level of Significance Some success criteria may be impacted if the extremes of the ranges are considered.

The potential effects should be understood and documented, even if the examples given are not dominantcontributors to the base PRA results.Possible Resolution:

Perform success criteria analyses for a range of possible conditions for each application.

Also, a codeother than MAAP should be used if large and medium LOCA success criteria are being defined.Disposition of the Peer Review Finding:The McGuire PRA model is currently undergoing a revision.

A calculation was created which defines theLOCA break sizes for Catawba and McGuire (Reference 8.16). This calculation performed MAAPanalyses at a range of break sizes and compared the accident progression to define a range of sizes for asmall, medium and large break LOCA. Additionally, an updated success criteria analysis has beenperformed in calculation MCC-1535.00-00-0120 utilizing the LOCA break ranges (Reference 8.49). Thesuccess criteria calculation ran the MAAP cases for a range of break sizes within each LOCA categoryrange. Both calculations have received an independent review per the Duke QA program and wereperformed using existing methodologies and software codes.The updated success criteria were compared against those used in the model of record and nosignificant differences were found (refer to Table 1).The success criteria analysis recognizes that MAAP has limitations and is not an acceptable tool fordeveloping the basis for the large break LOCA success criteria.

LBLOCAs were mainly addressed using aproprietary deterministic report from Westinghouse, "LOCA Engineering Report for McGuire Units 1&2and Catawba Unit 1" (Reference 8.10), that demonstrates acceptable performance during design-basis Page A-17 of A-168 accidents.

The Westinghouse report does not use the MAAP code. Engineering judgment was appliedto merge the results of LBLOCA MAAP runs and the Westinghouse analysis and generate the LBLOCAsuccess criteria.

Based on a comparison of the revision to the success criteria calculation to the PRA model of record andthe development of the LOCA break size calculation, this F&O has an insignificant risk impact and willnot impact the results and conclusions of the RI-ISI application.

Page A-18 of A-168 F&O Regarding PRA Technical Elements.:* ..... , ..:. % .........

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TH-4 TH-9 AS-18 BPeer Review F&O.: ......Success Criteria do not appear to have been sufficiently reviewed.

The reviewers identified severalapparent errors in the MAAP analyses, including the following:

1. The MLOCA MAAP runs do not appear to disable accumulators when defining the minimum ECCrequirements, but accumulators are not required by the resulting MLOCA success criteria.

2. The secondary side heat removal case (SAAG-98) shows no RCS pressure increase when 180gpm of CA is supplied to 1SG and NC pumps are tripped.3. For the F/B case, it appears that full CA was used in the MAAP run rather than the definedsuccess criteria of I CA pump to 2 SG.Justification for Level of Significance

.. .....Some of the analysis

results, and bases for the applied success criteria, may be impacted.

Possible Resolution:

Perform independent review of success criteria analyses.

Verify that any indentified analysis errors donot change the success criteria bases.Disposition of the Peer Review Finding:The McGuire PRA model is currently undergoing a revision.

An updated success criteria analysis hasbeen performed in calculation MCC-1535.00-00-0120 (Reference 8.49), which received an independent review per the Duke QA program.

This analysis used existing methodologies to generate the successcriteria.

The updated success criteria were compared against those used in the model of record and nosignificant differences were found (refer to Table 1).Based on a comparison of the revision to the success criteria calculation to the PRA model of record, thisF&O has an insignificant risk impact and will not impact the results and conclusions of the RI-ISIapplication.

Page A-19 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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TH-5 TH-9 TH-5, HR-18, HR-19 BPeer Review F&O:There do not appear to be success criteria analyses to support timing for operator actions.

Further,most analysis do not include the effects of possible operator interventions.

Even where they do, theminimum time window for operator action is not analyzed.

For example, in the feed and bleed case,two pressurizer PORVs are opened at 10% SG level (per EOPs) and flow from 1 ECC pump is modeled.This results in a core heatup to about 1800 F. If this were to be used to define the basis for an operatoraction success, the results would have to be interpreted as indicating that there must be instantaneous operator actions without any recovery time for the HRA analysis.

Justification for Level of Significance Analyses should be available to support available time windows for modeled operator actions.

Further,the success criteria analyses should reflect impacts of anticipated operator interventions.

Possible Resolution:

Review success criteria analyses to determine whether they adequately reflect modeled scenarios, including expected operator actions.

More clearly relate available times for modeled operator actionsto success criteria analyses.

Perform independent review of success criteria analyses.

Disposition of the Peer Review Finding:Timing analyses were performed using a systematic approach but were not adequately documented inthe human reliability notebook as required by the standard.

Action timings were based upon simulator information and RETRAN and MAAP analyses.

The HRA notebook (Reference 8.28) was examined toconfirm the presence of timing analyses.

Whereas the MAAP code runs are referred to in the HRA basicevent worksheets, the basis for the timing is typically found in Attachment 1, Miscellaneous Notes andCalculations.

Therefore, whereas the documentation can be improved to specifically discuss the timing analysis runs;there is a high level of confidence that this timing analysis was performed.

This is a documentation issue with regards to the system notebooks and does not have a significant impact on the MNS PRAmodel or the RI-ISI application.

Page A-20 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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TH-6 TH-8 SY-10, DE-1O BPeer Review F&O:There is no room heatup analysis notebook

/ evaluation of loss of HVAC to equipment rooms for theMcGuire PRA, and apparently no retrievable room heatup calculations or documentation to support theassumption that room cooling need not be modeled in the PRA. Other PRAs have found that roomcooling is required for some rooms such as electrical equipment rooms and small rooms housing criticalpumps. (Internal Duke corrspondence, and past interactions with NRC, have also identified this as anarea requiring attention.)

Justification for Level of Significance Failure of room cooling is typically detectable such that recovery actions are possible to limit impacts.However, without an evaluation, it is difficult to ascertain whether or not there are specific areasrequiring cooling for equipment success.Possible Resolution:

... .......Perform an evaluation, with equipment room-specific calculations, if possible, of the potential for, andmagnitude of the room heatup for rooms housing electrical equipment, pumps, and other keyequipment credited in the PRA. Document the basis for any determinations that equipment will survivethe anticipated room heatups, and model loss of room cooling as a failure mode in the system faulttrees (with recoveries as appropriate) for equipment that may not survive the anticipated heatup for thePRA mission time.Disposition of the Peer Review Finding:This F&O is under evaluation as part of the in-progress McGuire PRA model update. Equipment roomsthat have not been screened or previously modeled will be modeled as part of the update. This findingstates that there is no room heat-up analysis

notebook, which is true. There is no single notebook orevaluation for a room heat-up analysis;

however, there are several individual calculations which apply tothe topic.The following table lists the McGuire calculations related to a loss of HVAC.System Reference(s)

Modeled in Screening Results:

Justification for no explicit Modeling/Comments VA -Auxiliary 8.64 ECCS HVAC for NS/ND pump rooms are Remaining parts of the system are not modeled in theBuilding HVAC 8.38 explicitly modeled as failure modes for PRA because the primary function is to purge the AB8.40 RHR pumps A and B. Analyzed under atmosphere and filter the release.

This system functiongates LNDAHU1A and LNOAHU1B.

A does not influence the estimation of CDF or LERF.loss of HVAC cooling to anycontainment spray (NS) or residualPage A-21 of A-168 heat removal (ND) pump in theengineered safeguards pump room isassumed to result in a loss of thepump.VB -Breathing Air N/A Not modeled in the PRA None of the operator actions modeled in the PRArequires the use of the breathing air system. Thissystem function does not influence the estimation ofCDF or LERF.VC -Control Area 8.66 VC to Battery Room #701 is analyzed in The Control Area Ventilation System (VC) and theVentilation System 8.20 this calculation Control Area Chilled Water System (YC) combine to form8.21 one system whose purpose is to provide the normal and8.22 emergency ventilation requirements to the following 8.81 plant areas:8.868.83 (1) Control Room -Addendum 1 of reference 8.20 re-8.84 analyzed the Control Room heat up calculation using a8.85 "best estimate" approach and determined that theControl Room would not reach the 120 F limit within 24hours. Also, in a loss of Control Room HVAC, operators will enter AP/0/A/5500/39 (Reference 8.81) and step 5in this procedure instructs the operators to initiateshutdown of affected Unit when Control Roomtemperature reaches 90 F. Therefore, based on theControl Room loss of HVAC being a slow movingtransient and a Unit shutdown would occur beforereaching the 120 F limit, the loss of Control Room HVACis not modeled in the PRA.(2) Control Room Area (CRA) includes the equipment rooms, cable room, and battery rooms -Reference 8.86 shows that the only equipment roomcontaining important equipment related to HVAC is theControl Room Mechanical Equipment Room. This roomcontains the CRA HVAC equipment used tocool its ownequipment room. Therefore, a loss of CRA HVACequipment room cooling is not modeled in the PRA.Reference 8.83 shows that the Battery Rooms (#'s 706,707, 708, 709, 710, 711) contain vital batteries.

The onlytime these batteries are in use is when there is a loss ofpower event on that Unit. When a loss of power doesoccur, then these rooms do not require HVAC cooling.Therefore, loss of HVAC cooling to these rooms is notmodeled in the PRA.The Battery Room #701 contains transformers, voltageregulators, battery chargers, inverters, 125 V dcdistribution

centers, 240/120 V ac regulated powerdistribution

centers, 125 V dc panelboards and 120 V acpanelboards that are important in supporting accidentmitigation and are required to be available throughout the PRA mission time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Therefore, asensitivity study of the impact of a CRA HVAC model toprovide cooling to Battery Room #701 is required.

The cable room does not contain safety-related equipment requiring HVAC and is not modeled in thePRA.(3) Switchgear Rooms (1ETA, 2ETA, 1ETB, 2ETB) -theserooms contain safety-related equipment (see references 8.84 and 8.85) important in supporting accidentmitigation and are required to be available throughout the PRA mission time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Reference 8.22contains a room heat up calculation for one of theseswitchgear rooms (see Attachments 4 and 5 of reference 8.22) considering two different heat loads (for SSF eventand blackout),

and the results from this analysis showsPage A-22 of A-168 that the estimated switchgear room temperatures at 24hours into the event do not exceed the maximumallowable temperatures.

Attachment 4 in reference 8.22states that the 2ETA switchgear room is very similar tolETA. Therefore, the other 2 switchgear rooms (1ETBand 2ETB) would also be similar.

This calculation showsthat these rooms will not exceed the maximumallowable temperature limits during the 24-hour missiontime, then a loss of Switchgear Room (IETA, 2ETA, 1ETB,and 2ETB); however, this analysis does not include allapplicable accident scenarios that might require HVACcooling for components.

In particular, the requirements for LOCAs are not considered.

Therefore, a sensitivity study of the impact of a CRA HVAC model to providecooline to the switch~ear room is rerouired.

cooling to the............

ro m ............

ed... .VD -Diesel 8.67 Analyzed elsewhere in the PRA Not screened, modeled as necessary as part of the DGGenerator Room 8.31 system.CoolingVE -Annulus 8.61 Not modeled in the PRA This system functions to maintain a negative pressure inVentilation the annulus for the purpose of filtering containment leakage.

The system does not support any equipment oroperator actions modeled in the PRA; therefore, thissystem function does not influence the estimation ofCDF or LERF.VF -Fuel Handling 8.65 Not modeled in the PRA This system functions to filter any releases from theArea HVAC FHA. The system does not support any equipment oroperator actions modeled in the PRA; therefore, thissystem function does not influence the estimation ofCDF or LERF.VH -Tech. Support 8.68 Not modeled in the PRA The technical support center is not explicitly modeled inCenter HVAC the PRA. Operator actions that rely in the TSC forproper operator response are rare. Inhabitability of theTSC would require relocation of the TSC or reliance onthe EOF for operator support.

The influence of the TSCventilation system on the risk metrics is assumed to benegligible.

VI -Instrument Air 8.70 Analyzed elsewhere in the PRA Not screened, explicitly modeled.

However, VI is not a8.35 cooling system.VL -Lower 8.63 Not modeled in the PRA The purpose of the Lower Containment Ventilation Containment HVAC System (VI) is to provide cooling to the lowercompartment of Containment during normal operation and shutdown.

The system does not support anyequipment or operator actions modeled in the PRA;therefore, this system function does not influence theestimation of CDF or LERF.VO -Turbine N/A Not modeled in the PRA This system functions to control the temperature in theBuilding HVAC turbine building for personnel comfort and equipment longevity.

The system does not support any equipment or operator actions modeled in the PRA; therefore, thissystem function does not influence the estimation ofCDF or LERF.VP -Containment 8.62 Analyzed elsewhere in the PRA (for The purpose of the Containment Purge (VP) is to purgePurge 8.37 containment isolation) the containment atmosphere prior to containment entryfor outages.

The system does not support any accidentmitigating equipment or operator actions modeled inthe PRA; therefore, this system function does notinfluence the estimation of CDF or LERF.VQ- Containment 8.37 Analyzed elsewhere in the PRA(for Not screened, explicitly modeled.Air Addition/Release 8.69 containment isolation)

VR -Control Rod 8.63 Not modeled in the PRA The purpose of the Control Rod Drive Ventilation SystemDrive Mechanism (VR) is to provide cooling to the control rod driveCooling mechanism shroud during normal plant operation.

Thesystem does not support any equipment or operatoractions modeled in the PRA; therefore, this systemI function does not influence the estimation of COD orPage A-23 of A-168 LERF.VW -SSF HVAC 8.59 Analyzed elsewhere in the PRA Not screened, explicitly modeled.

In section 3.3.2.3.3 ofSystem 8.41 Reference 8.59 states "considered part of the VO,Turbine Building Ventilation System".VX -Containment 8.60 Analyzed elsewhere in the PRA Not screened, explicitly modeled.Air Return and 8.36Hydrogen SkimmerSystemVU -Upper 8.63 Not modeled in the PRA The purpose of the Upper Containment Ventilation Containment System (VU) is to provide cooling to the upperVentilation System compartment of Containment during normal operation and shutdown.

The system does not support anyequipment or operator actions modeled in the PRA;therefore, this system function does not influence theestimation of CDF or LERF.VT -Incore 8.63 Not modeled in the PRA The purpose of the Incore Instrumentation Ventilation Instrumentation System (VT) is to maintain the incore instrumentation Ventilation System room during normal operation and shutdown to withinthe design temperature range for operation ofequipment and for personnel access for inspection, maintenance and testing as required.

The system doesnot support any equipment or operator actions modeledin the PRA; therefore, this system function does notinfluence the estimation of CDF or LERF.VM -Administration N/A Not modeled in the PRA The administration building does not support anyBuilding Ventilation equipment or operator actions modeled in the PRA;therefore, this system function does not influence theestimation of CDF or LERF.VZ- Miscellaneous N/A Not modeled in the PRA The system does not support any equipment or operatorHVAC (for example actions modeled in the PRA; therefore, this systemsecurity huts) function does not influence the estimation of CDF orLERF.VK- Equipment N/A Not modeled in the PRA The equipment staging building does not support anyStaging Building equipment or operator actions modeled in the PRA;Ventilation therefore, this system function does not influence theestimation of CDF or LERF.VG- Diesel 8.31 Modeled as necessary to support DG Not screened, modeled as necessary as part of the DGGenerator Starting 8.72 operation, system.Air SystemVN- Diesel 8.31 Modeled as necessary to support DG Not screened, modeled as necessary as part of the DGGenerator Engine 8.73 operation, system.Air Intake andExhaust SystemVS- Station Air 8.71 Not modeled in the PRA The system does not support any equipment or operatorSystem actions modeled in the PRA; therefore, this systemfunction does not influence the estimation of CDF orI_ I LERF.Based on the comparison to the model of record in the above table, the current modeling for HVAC iscorrect with the exception that the Control Room Area HVAC cooling to Battery Room #701 and theSwitchgear Rooms. A sensitivity study was performed in Section 7.1 to determine the impacts of thisF&O on the RI-ISI application.

This study found that for initiating event sequences that impact the RI-ISIapplication, the impact from Control Room Area Ventilation is insignificant with respect to risk.Therefore, this sensitivity study and the screening analysis above show that this F&O has an insignificant impact on the results and conclusions for the RI-ISl application.

Page A-24 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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.Level of Significance; SY-3 SY-5 SY-8 BPeer Review F&O:Appendix F.5, Auxiliary Feedwater System (CA) states that "If, during CA operation, the suction pressuredrops below a preset pressure for three seconds, the RN (Nuclear Service Water) System water source isaligned automatically"

[pg. F.5-7, Rev 31. Design Basis Specification for the CA System, Spec. MCS-1592.CA-00-0001, Revision 12, page 50, section 31.3.2.6 lists six valves that must automatically swapposition (closed to open) to provide nuclear service water to the suction of the auxiliary feedwater pumps based on the response of six suction pressure switches.

These pressure switches do not seem tobe modeled nor is an operator action to open the six RN suction supply valves to CA due to CCF of thepressure switches to provide signal to automatically open the supply valves.Justification for Level of Significance An operator action to open the RN supply to CA in the event of automatic swapover failure could be animportant event in the PRA model; the impact of the actuation logic components should also beaddressed so that the model is complete.

Possible Resolution:

Evaluate the need for modeling of the pressure switches and/or operator action discussed above;incorporate into the model or document the rationale for excluding.

Disposition of the Peer Review Finding:The six valves referred to in the F&O are CA-15A, CA-18B, CA-86A, CA-116B, RN-69A and RN-162B.These valves are modeled in the McGuire PRA model of record; however as the F&O points out,-thepressure switches for these valves are not. The model of record basecase cutset file was examined andthe individual failure of these valves does not show up above the truncation limit.The database calculation (Reference 8.15) was reviewed to determine component boundary definitions.

Per Section 4.5.2 of this reference, the boundary for an AFW motor-operated valve includes the internalpiece-part, motor operator, circuit breaker, power leads, sensors and logic circuit.

Only sensors uniqueto the operation of the individual valve are included within the boundary of a motor-operated valve.Therefore, the pressure switches in question would be part of the motor-operated valve component boundary and are not individually modeled.

Adding an operator action to open the valves in the eventthat the automatic actuation logic fails is a recovery action. It is conservative to not credit the operatorrecovery action. No model changes are required to address this F&O and the F&O does not have asignificant impact on the results or conclusions of this application due to the insignificant amount of riskassociated with these valves.Page A-25 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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SY-4 SY-8 BPeer Review F&O:The Nuclear Service Water (RN) supply to the Auxiliary Feedwater System (CA) contains a total of sixvalves which must open automatically (3 per train) to provide RN to the auxiliary feedwater pumpssuction.

The model does not appear to include any common-cause failure of these valves to open toprovide water to the CA system.Justification for Level of Significance

...The common-cause failure of these valves could be a significant contributor to cut sets involving thefailure of the CA system.Possible Resolution:

Consider adding CCF events for the RN/CA supply to the CA pump suction, or providing, in thedocumentation, the rationale for excluding this.Disposition of the Peer Review Finding:The six valves referred to in the F&O are CA-15A, CA-18B, CA-86A, CA-116B, RN-69A and RN-162B.These valves are modeled in the McGuire PRA model of record; however as the F&O points out, themodel of record does not include a common cause failure of these valves. The model of recordbasecase cutset file was examined and the individual failures of these valves do not show up above thetruncation limit.This F&O is under evaluation as part of the in-progress McGuire PRA model update. The Auxiliary Feedwater System Notebook (Reference 8.32) has been completed as part of this model update. Thenew CA system model was examined to determine the impact of adding the common cause failures ofthese valves to the system model. The system model was solved at a truncation of IE-12 and thecutsets were examined.

The first occurrence of any common cause failure for these valves in the systemmodel is at 4E-12. it is therefore judged that these valves are insignificant to risk and the addition of thecommon cause events will not have a significant impact on the results or conclusions of this application.

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SY-5 SY-8 BPeer Review F&O:There are two operator actions modeled which take credit for aligning Unit 2 RN supply, RNLOUT2RHE and RNUNIT2RHE;

however, common-cause failure events for the failure of all RN pumps or all RNfilter/strainers are not modeled.Justification for Level of Significance:

Since Unit 2 is used to help recover Unit 1 RN, then common-cause failures such as flooding, filterplugging, etc. could affect all RN pumps or filter/strainers and should be addressed in the model.Possible Resolution Include CCF of RN pumps, filter/strainers, etc. in the model.Dispositioriof the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The RN fault tree logic has been updated to incorporate common cause failures of all RN pumps and thecommon cause failure of all strainers (Reference 8.39). Similar to Example 9 in Section 1-A.3.9 of RA-Sa-2009, this update corrects an omission to the fault tree logic using existing methodology.

The updatedid not involve a significant change in scope or capability due to the small amount of risk associated with the new common cause events.Page A-27 of A-168 F&O Regarding PRA Technical ElementsObservation D: Element:

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-Level of Significance:

SY-7 SY-8 BPeer Review F&O:The following comments apply to the T1O initiating event tree (Loss of KC):1. Common cause failure of the two normally running pumps is noted as having been removed inRevision

2. Since failure of the normally running pumps must be followed by start of the standbypumps, an annualized common cause failure of the two normally operating pumps is appropriate.

2. Cutsets with more than one annualized frequency should be eliminated and one of the failuresreplaced with a mission time event. For example, the top cutset for the TiO solve contains eventsKKCO1A2PPR and KKCO1AIPPR which both have annual mission times. These two random failuresshould be replaced with a common cause event.3. The TIO and KCTOP fault trees do not contain operator action events for start of the standbypumps. This may be valid for the KCTOP tree if it can be shown that all sequences where KC iscredited result in an SS or LOSP start, but the operator failure to start the standby pumps should beincluded in the T10 solve.4. Transfer close of valves in the RCP cooling header are not accounted for. Although these failures donot cause loss of all KC, they would result in reactor trip with partial loss of seal cooling.

Forexample, if only the three MOVs in the supply and return headers to the RCPs (1KC338B, 1KC424Band 1KC425A) are considered, this would have an initiating event value of 2.06E-04.

In additionthere are several manual valves in common portions of the piping which would cause loss of RCPmotor cooling if they transferred close.Justification for Level of Significance:

The noted problems could lead to underestimation of the T1O initiating event frequency andunderestimation of human error contributions to the CDF.Possible Resolution Include the noted common cause and human actions in the T10 fault tree. Evaluate the need to developan initiating event tree for loss of KC to the RCPs and include in the PRA if appropriate.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The F&O identified four areas of concern.

The first recommended that a common cause failure of thetwo running KC pumps be added to the model. The McGuire PRA model of record includes twocommon cause groups for the KC pumps: a single event representing the combined failure probabilities Page A-28 of A-168 of 2/4, 3/4 and 4/4 KC pumps to run and the common cause failure of the two standby pumps to start.The KC pump run failure is calculated using the same methodology applied to all common cause groups,where the individual failure combination probabilities are calculated and then summed to create asingle failure event. This event is then inserted into the fault tree logic and represents a failure of allcomponents within that group. No model changes were required to address this part of the F&O sincethe current methodology is judged to be adequate to address potential common cause run failures ofthe KC pumps.The second comment recommended replacing cutsets with more than one annualized frequency with amission time event. A recovery rule was added to the model to correct this error. Similar to Example 6in Section 1-A.3.9 of RA-Sa-2009, this update corrects an error in the calculation of the loss of KCinitiating event frequency.

This update used existing methodology to calculate and apply the newrecovery rule to the logic. The loss of KC initiating event was not a significant accident sequence andremains insignificant after the error correction.

Therefore, there was no change in the scope orcapability due to this change.The last two comments do not require model changes because the referenced logic omissions arealready contained in the model. Existing event KKCSTNBDHE represents the failure of the operators tostart the standby KC train. It is also not necessary to include additional valve failures that will result inan isolated RCP header. Per the KC system notebook (Reference 8.34), a failure of a valve in the reactorcoolant pump cooling header would lead to a loss of cooling flow, a loss of the RCPs and a resulting reactor trip. This sequence is already covered by the reactor trip initiating event. There would not be aresulting loss of KC. Flow would still be available to the ND heat exchanger and the auxiliary buildingnon-essential header. Including failures of the RCP cooling heater would over-predict the likelihood ofthe Loss of KC initiating event.Page A-29 of A-168 F&O Regarding PRA Technical ElementsObservation ID: eiement:

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DA-2 DA-5 BPeer Review F&O:The failure rate of CMS in Rev. 2 and in the generic data of Rev. 3 is 2.9E-2 in both, but after Bayesianupdating, in Rev. 3, the failure rate is 3.2E-5. The demand data for CMR and CMS grouped Reciprocating Compressors A, B, C, D, E, & F, and Compressor lAl, 1A2, 1B1, & 1B2 together.

Compressors 1A1, 1B1,1A2, 1B2 only have I start and 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> running for each, whereas the Reciprocating Compressors have 54 starts and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> running for each. Given the significantly different operating experience, these two kinds of compressors should not be grouped together to evaluate the failure rate.Justification for Level of Significance:

The failure rate for the compressor is significantly reduced from Rev 2 to Rev 3 and is greatly below thegeneric data. The reviewers suspect that this is because of the inappropriate combination of thedemands and failures noted above.Possible Resolution:

Separate the compressors into two groups and evaluate the failure rates separately.

.Disposition of the Peer Review Finding:In the model of record, the reciprocating compressors (normally running) are grouped with thecentrifugal compressors (standby) into a single type code despite having different denominator data.The compressor type codes CMR and CMS were increased by a factor of 100 and the cutsets wereexamined.

Failures of the centrifugal and reciprocating compressors do not appear in cutsets above themodel truncation limit even when the basic event probability is increased by an factor of 100. Theinstrument air system is very redundant and only the diesel air compressors are risk significant to theMcGuire PRA model since a loss of power fails all but the two diesel compressors.

When power isavailable, the instrument air (VI) system is available unless either of the following failure combinations occur:* 2 out of 3 centrifugal compressors, 2 out of 3 backup reciprocating compressors, 2 out of 2diesel powered compressors and the VS system fails to isolate from VI* 3 out of 3 centrifugal compressors and 2 out of 2 diesel powered compressors The air compressors identified in this F&O do not have a significant impact on the results or conclusions of the RI-ISI application due to the redundancy of the VI system.Page A-30 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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DA-5 DA-11 DA-10, DA-12, DA-14, AQU-9Peer Review F&O:CCF modeling:

There is no evidence of a systematic process to identify and include common cause failures of similarcomponents.

There are several cases where the McGuire station has component groups of similardesign, location, maintenance, manufacture, lubrication, and cooling, ie., RN pumps, PORV's. One setis similar components associated with the onsite power AC power system. The 2 DG assigned to Unit 1have a common cause to run and start. The output breakers for the DG and the feed breakers for theemergency buses do not have a CCF event. And the reviewers did not note CCF of the SSF and stationDG's. There might be commonalities in fuel oil or maintenance that would warrant at least a minimalCCF factor applied to all three DG's.Specifically, for the onsite AC power system, there are no CCF of:1. 4160v bus feed breakers2. DG output breakers3. DG fuel oil transfer pumps4. station batteries

5. no CCF analysis for SSF DG and main DGOther components noted without common cause failure are:6. all RN pumps7. ECCS injection valvesJustification for Level of Significance.:*

The noted CCFs could have an impact on PRA results and should be reviewed for inclusion in the PRA.Possible Resolution:

Evaluate the need for these items, include if appropriate, document the bases for exclusion if notincluded.

Disposition of the Peer Review Finding:

.. .....This F&O has been addressed and incorporated into the PRA model of record.New common cause events were added to the system fault tree logic. These new common cause eventswere quantified and applied to the logic using existing methodologies and processes.

Page A-31 of A-168 The DC power system logic was updated to include common cause failures of the EVCA, EVCB, EVCC andEVCD batteries (Reference 8.42). The RN system logic was updated to include common cause failures ofthe RN pumps and strainers (Reference 8.39). The Emergency Core Cooling system logic was updated toinclude common cause failures of the NI check valves, ND check valves and the common primary checkvalves (References 8.33 & 8.38).The diesel generator and 4kV power system logic was updated to include common cause failures of thefuel oil transfer pumps (both to start and run), of the 4kV feed breakers, the diesel generator outputbreakers and the failures of the diesel generators and the SSF diesel (Reference 8.31). The onlyidentifiable common link between the SSF Diesel and the diesel generators (EDGs) is that they takedelivery of the same fuel. The SSF has its own fuel oil storage tanks, and is in every other waycompletely diverse from the EDGs.The contribution to CDF for all cutsets containing these new CCF events is small, which is an indication that the important CCF events were already captured in the model. Therefore this update did notinvolve a significant change in scope or capability.

Similar to Example 9 in Section 1-A.3.9 of RA-Sa-2009, this update corrects omissions to the fault tree logic using existing methodology.

The common cause calculation was updated to include a detailed discussion of the systematic processused to identify common cause groups. This update addressed the documentation issue; however, ithad no impact on the quantitative model results.Page A-32 of A-168 F&O Regarding PRA Technical Elements..i .. ~ ~~~ ....... ..'i: ..Observation ID: Element:

Related Elements:

Level of Significance:

HR-1 HR-4 HR-1, HR-3, HR-4, HR-5 BPeer Review F&O:Table 2 of SAAG-501 lists the pre-initiator His considered in the analysis.

The table does not include Hisfor modeling instrument miscalibration events.Further, no systematic process to identify pre-initiator human actions is identified in the HRA calc.Justification for Level of Significance The effect of lack of miscalibration His is not known. Although typically not large, the potential for sucherrors to cause inter-system or cross-train dependencies should be investigated and documented.

Possible Resolution:

... .If a systematic process was followed to identify pre-initiator actions in the HRA, document the processfollowed.

If such a process was not followed, develop a process and determine whether additional actions should be included.

Provide the basis for excluding miscalibration events, or developappropriate events for inclusion in the next update of the PSA model.Disposition of the Peer Review Finding:Duke utilizes a train-level latent human error (LHE) event for each system train. This train-level LHEincludes the effects of mispositions and miscalibrations.

These events use a screening value of 8E-03based on the basic human error probability in the ASEP method. For those risk-significant pre-initiator events, Duke calculates specific values.However, the McGuire PRA model is currently undergoing a major model update. During this update,several miscalibration events were identified in the ESFAS and RPS systems.

These new miscalibration events were added to the PRA model as part of a sensitivity study (refer to Section 7.2). This studyfound that only the miscalibration of the RWST level indication appears above the truncation limit. Thismiscalibration event appears in small LOCA accident sequences;

however, the event does not appearabove the truncation limit with the small break LOCA initiating event itself. The overall CDF contribution from this event is 1.2E-09, which is an insignificant risk impact. Therefore, this F&O is a documentation issue and has no impact on the results or conclusions of the RI-ISI application.

Page A-33 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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HR-3 HR-17 BPeer Review F&O:Some of the Type Cp His are evaluated using the HCR model. For these, the only performance shapingfactors considered are time available and operator response time. Table 4 of SAAG-501 lists thepotential effects of additional PSFs, such as operator experience, but table 4 does not appear to havebeen applied in the quantification of HI events..Justification for Level of Significance.

The PSF guidance provided should be applied/considered in the development of the His..Possible Resolution:

Consider the effects of the various PSFs in table 4 in the HCR model.Disposition of the Peer Review Finding:The McGuire PRA model calculates both the HCR and CBDTM probabilities for each operator action anduses the maximum value for each HRA event. The F&O is against those HRA events which used the HRCmethod and specifically cites the lack of incorporating performance shaping factors into the calculation of the cognitive element of the action.Table 4 lists the HCR performance shaping factors and related coefficients for operator experience, stress level and quality of operator/plant interface.

The choices for operator experience are 1) expert,well trained (0.78), 2) average knowledge training (1.0) or 3) novice, minimum training (1.44). Theoperations crews are considered to be at least in the average knowledge training category and morelikely in the expert, well trained category.

Therefore, lack of use of the operator coefficient isconsidered to be conservative.

The choices for stress level are 1) situation of grave emergency (1.44), 2) situation of potential emergency (1.28), 3) active, no emergency (1.0) and 4) low activity, implying low vigilance (1.28). In thecase of stress level, lack of use of the coefficients is considered to be liberal.The choices for quality of operator/plant interface are 1) excellent (0.78), 2) good (1.0), 3) fair (1.44),poor (1.78) and extremely poor (1.92). However, Duke performed an initiative to address humanfactors concerns with the man/machine interface.

Thus, the quality of operator/plant interface isjudged to be in the good to excellent range. Therefore, lack of use of the operator/plant interface coefficient is considered to be conservative.

In aggregate, with conservative treatment of two of the coefficients and liberal treatment of onecoefficient, the impact on the overall human events failure probabilities is judged to be minimal and willPage A-34 of A-168 not have a significant impact on the results or conclusions of this application.

Since the PSFs in the referenced Table 4 were not being applied to the model (as noted in the F&O)Table 4 was removed from the HRA documentation.

Page A-35 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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Level of Significance:

HR-5 HR-27 HR-26, HR-3, QU-1O APeer Review F&O:In Rev 2, there was no documentation of the identification of dependent human error events in thesame cutset. This effort is being done for Rev 3, but Rev 3 is not implemented as of the date of thisreview.The Peer review of the Rev 3 HEP dependency analysis found:A. the bases/criteria for the selection of dependency factors are not stated and appear to be appliedinconsistently for similar events- in particular, credit for SSF to prevent seal LOCA for SBO, loss ofRN, fire and seismic is not consistent.

B. limited reference to the procedural direction for dependent

actions, i.e., the dependent actionscould be called by the same procedural step and are therefore highly dependent and this analysiswould not show it.C. the value of the final HEP is dependent on the order in which the HEPs are arranged.

Because thesequence of events is not clear and the procedural direction is not stated, the order of HEPs is leftup to the analyst.D. the basis for decision on each dependency factor is not documented and does not appear to bereadily reproducible.

E. lack of guidance for the above.Justification for Level of Significance This is significance A because there is no apparent identification and correction for dependent humanerrors in Rev. 2. Although this effort is underway in Rev. 3, it was not in place for the review. Riskapplications at this time are based on Rev. 2, which does not have the dependent HE evaluation.

Possible Resolution:

The approach being implemented in Rev 3 is providing an appropriate resolution.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The HEP dependency analysis

approach, which is stated in the Possible Resolution as providing anappropriate resolution of the F&O, has been added to McGuire PRA model. This dependency approachmeets the definition of a PRA upgrade;

however, the approach was reviewed during the peer reviewand thus no new peer review is required.

The documentation issues noted in the F&O were also addressed.

The HRA notebook (Reference 8.28)was revised to include a discussion of the process, basis and criteria for the selection of dependency Page A-36 of A-168 factors.

The dependency quantification worksheets have also been added to the HRA notebook and thedependency events, using the same methodology as was presented to the peer review team, have beenadded to the PRA model of record. Inconsistencies identified during the peer review have beenresolved using the peer reviewed methodologies and documented in the HRA notebook.

Procedural guidance for the dependent actions is identified in the individual action quantifications in Appendix Band C of the HRA notebook.

The sequence of events for the dependency evaluation is described in the"situation" and "relative timing" sections of the individual worksheets in Appendix D. The basis for thedecision on each dependency factor is described in the appropriate sections on the HRA worksheets.

The remaining points in the F&O pertained to documentation, which was greatly expanded in the HRAnotebook.

The documentation issues do not have an impact on the MNS PRA model or on thisapplication.

Page A-37 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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Level of Significance:

HR-6 HR-30 B:Peer Review F&O:In Rev 3, the documentation of the HEPs for single events is not reproducible.

The HRA methodcalculated 3 different HEP contributors for each HI [HCR, P(e) and P(c)]. In many circumstances, oneelement is assumed to be dominant and the others are neglected.

In support of this, summaryjudgments are made like -"execution errors were assessed negligible",

"event not evaluated in detailbecause was time critical",

"cause based calculation not performed because action is time critical".

Thetime is not referenced to any T/H basis or generic analysis.

The basis for assumptions and criteria is notdocumented.

In general, there is limited documentation for the HRA in the following areas.1. The sequence context of each HI is not stated.2. The previous failures in the event sequence, the performance shaping factors, or stress levelsare not stated.3. Procedural steps applicable to each HEP are not consistently provided.

4. Basis (T/H) for timing of each action is not provided.

The lack of these types of information in the documentation of the HRA limits the ability to verify andreproduce the results, and to determine their applicability in specific scenarios.

Justification for Level of Significance The issue is one of inability to verify and review because the documentation is inadequate.

No specificerrors were found, and errors may not exist. But, the analysis is not reproducible in the current state....* .....Possible Resolution:

Enhance the HRA documentation to address the listed items.Disposition of the Peer Review Finding:The areas stated in the F&O were addressed in the PRA model but were not adequately documented inthe human reliability notebook as required by the standard.

The sequence context was described at a high level; however, not to the extent as required by thestandard.

For those HRA events which appear in multiple sequences (such as small and medium breakLOCAs) the more limiting consequence timings and action limitations were applied.The procedural steps applicable to each HRA event were considered; however not necessarily eachindividual step.The dispositions for F&Os TH-5 and HR-3 address the PSFs, stress levels and basis for the HRA timings.Page A-38 of A-168 The HRA notebook review confirmed that there is reasonable assurance that the F&O items areconsidered throughout the model. Therefore, this is a documentation issue with regards to the HRAnotebook and does not have a significant impact on the MNS PRA model or the RI-ISI application.

Page A-39 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

" Related Elements:

Level of Significance:

HR-8 HR-26 HR-27 BPeer Review F&O: '":In Rev 3, the calc sheet for RNUNIT2RHE states that the resultant calculation is the product ofRNLOUT2RHE and this event, which has a probability of .1, for a total non-recovery probability of 0.03.So, this result is the product of 2 recoveries.

This violates the time constraints set down in the recoveryfile.Justification for Level of Significance The HEP calculations should account for the time available for each action credited, such that the totaltime credited is no longer than the overall time available for action, per the success criteria.

.Possible Resolution:.

.... :Review the calculation, and revise as appropriate.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The two operator actions RNUNIT2RHE and RNLOUTRHE have been deleted and replaced with two newoperator actions WRVBACKDHE and WRNUNT2DHE in the RN system logic. These two operator actionsaccount for the operator failure to align RV backup cooling and the operator failure to cross-connect RNfrom the other unit, respectively.

An equipment failure event WRVBACKDEX has also been added to theRN system PRA model to account for equipment failures of the RV system. The new basic events havebeen quantified and incorporated into the model logic using existing methodologies.

Similar to Example 9 in Section 1-A.3.9 of RA-Sa-2009, this update corrects omissions to the fault treelogic using existing methodology.

The update did not involve a significant change in scope or capability impacting the significant accident progression sequences because the RN system is considered asignificant accident progression sequence for both the peer reviewed PRA model and in the model ofrecord.Page A-40 of A-168 F&O Regarding PRA Technical Elements

.. ....Observation ID: Element:

Related Elements:

Level of Significance:

DE-3 DE-1 DE-2, DE-3, DE-14 BPeer Review F&O:No specific guidance is given regarding modeling of system dependencies in the system notebooks;

however, a highly knowledgeable analyst could reproduce the given results.

A dependency matrix isprovided but contains little detailed explanation of how dependencies were determined.

Flood Analysisdoes not seem to provide detail required to reproduce the results except by a highly knowledgeable analyst.Justification for Level of Significance Sufficient guidance should be provided to explain how dependencies are treated in the PRA, such thatthe approach can be explained,

reviewed, and defended, and so that future PRA updates are performed correctly and consistently.

Possible Resolution:

Provide guidance for treatment of dependencies, including types of dependencies treated in the model,approaches used to model dependencies, and important considerations regarding how dependencies may affect the model and results.Disposition of the Peer Review Finding:The peer review comments indicate that a highly knowledgeable analyst could reproduce the givenresults.

This indicates that there is not an issue with the analysis; rather the issue is with documentation needing improvement.

The system notebooks include a section on system boundaries, which has beenused to identify the system dependencies.

Therefore, whereas the documentation can be improved tospecifically identify dependencies; there is a high level of confidence that this dependency analysis wasperformed.

The following is an example of the system boundaries section in the system notebooks.

From the Instrument Air system notebook (Reference 8.35):"A.3 System Boundaries Cooling Water SystemsRecirculating Cooling Water (KR) cools the built-in intercooler, the built-in aftercooler, and the oil cooler of thecentrifugal compressors as well as the water jacket and intercooler of the reciprocating compressors.

TheConventional Low Pressure Service Water (RL) System provides cooling to two identical aftercoolers locateddownstream of the reciprocal compressors.

(Note: The aftercoolers for the Diesel Compressors G and H are aircooled.)Electrical Power SupplyThe 600 V ac and 120 V ac Normal Auxiliary Power Systems supply motive and control power to VI components withthe exception of the Diesel Compressors G and H which are run on diesel fuel. A list of major components andPage A-41 of A-168 associated power supplies are given in Table A-2. VI compressors D and E receive power from load centers of Units 1and 2, respectively, while VA compressor F can be aligned to receive power from either unit via a transfer switch.Reciprocating compressors A, B and C receive power from non-essential buses shared by both units.External Control SystemsThe VI System does not receive any signals from external control systems.Additionally, the specific example cited by the peer review team, which involves the flooding

analysis, has been updated and received a focused peer review against the ASME/ANS PRA Standard.

This is a documentation issue with regards to the system notebooks and has no impact on the MNS PRAmodel or the RI-ISI application.

Page A-42 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

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Level of Significance:

DE-4 DE-8 DE-14, SY-8, DA-10, RU- B9Peer Review F&O:: "... ....:Review of several systems indicates that similar components within a system are not consistently included in a common cause group. Examples where CCF is not sufficiently considered include RNheader cross-connect valves, CA suction supply valves from the RN flowpath, Safety Injection Cold/HotLeg Injection check valves, KC system train valves, etcJustification for Level of Significance:.

When CCF events are not modeled for important components, the overall risk of that component beingunavailable can be understated causing the core melt frequency to be understated.

Possible Resolution Review PRA model and provide more complete treatment of CCF events across the model and/orprovide basis for not modeling CCF of the components/failure modes.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.A review of the McGuire PRA model identified 19 new common cause groups that were not included inthe PRA. A model update was performed, using the existing common cause methodology, toincorporate the new common cause events into the model of record. The contribution to CDF for allcutsets containing these new CCF events is small, which is an indication that the important CCF eventswere already captured in the model. Therefore this update did not involve a significant change in scopeor capability.

Page A-43 of A-168 F&O Regarding PRA Technical ElementsObservation ID Element::

.Related Elements:

Level of Significance:

ST-1 ST-9 BPeer Review F&O:An analysis is available of the effect of overpressurizing the RHR discharge line to the RCS. The analysisconsiders the effect of static pressure on the piping integrity by comparing the calculated hoop stressfrom static RCS pressure and the ultimate strength of the piping. The results show that expected hoopstresses are below the ultimate strength and thus piping failures are not expected to occur. The analysisthen assesses the impact of damaging all sealant materials in the lines (gaskets, valve packing, etc.) toconclude that the break area can be conservatively bounded by a 13.5 inch equivalent diameter break.Based on this, all ISLOCAs go to core damage.The present approach does not consider dynamic effects of the isolation valve failures with respect topiping integrity.

The present approach also does not factor in later industry generic analyses andmethodology, e.g., NUREG/CR-5744.

If piping failures are considered to have a non-zero failureprobability, then other specific failure locations can be considered for which some response is available to avoid core damage. As documented in NUREG/CR-5744, other components such as RHR heatexchanger components,

flanges, etc. often represent the weak links. Rather than consider these as asingle equivalent large break, as was done for the current McGuire ISLOCA evaluation, specific scenarios could be addressed explicitly, following the NUREG methodology.

In addition, there would be a scenarioinvolving a small but nonzero pipe rupture probability to address.In summary, assigning a zero probability of gross piping system rupture due to a simple pipe hoop stresscomputation is not consistent with current PRA practice for these events; the present approach may notbe sufficiently realistic, and may overstate the ISLOCA CDF contribution.

Justification for the Level of Significance Since the ISLOCA is the major contributor to LERF, changes in the ISLOCA model could have a significant impact on the McGuire LERF calculations.

Possible Resolution:

Consider implementing the more recent methodology, including the dynamic effects of valve rupture onpiping integrity and possibly incorporating the results of the ongoing risk-informed in-service inspection of piping study if appropriate, to ensure that the McGuire approach is sufficiently realistic.

Disposition of the Peer Review Finding:The ISLOCA sequence notebook (Reference 8.43) defines an ISLOCA as follows:"Failures of the components that isolate the NC [primary]

system from the low pressure

systems, or personnel errorsin assuring isolation, can result in overpressurization events. If the overpressurization causes a fluid boundary failure,then a loss of coolant (LOCA) occurs. If the failure occurs outside containment, then the lost reactor coolant is notPage A-44 of A-168 returned to the containment sump for recirculation, and no suction source will be available for the safety injection pumps upon depletion of the Refueling Water Storage Tank (RWST). In addition, a release path to the atmosphere isestablished."

By this definition, the ISLOCA frequency is largely a function of passive valve failures.

The RI-ISI programmonitors and inspects piping flaws and degradation modes, which do not contribute to ISLOCA. Thefollowing table lists the overall frequencies of the ISLOCAs through all the modeled flow paths:ISLOCA Flow Path Frequency NI-173A, NI-178B 8.9E-07ND-2AC 5.2E-08NI-183B 1.7E-08NV-840 1.4E-08NV-458A 4.OE-09The McGuire PRA model is currently undergoing a revision.

This model revision will address this F&O byadopting the ISLOCA model from WCAP-17154-P (Reference 8.9). Implementation of this new ISLOCAmodel is expected to result in a decrease in CDF and LERF because, as indicated in the F&O, the currentapproach likely overstates the ISLOCA contribution.

However, the ISLOCA accident sequences arecurrently considered significant accident sequences and are not expected to change status due to thismodel update.This F&O is judged to not have a significant impact on the results and conclusions of the RI-ISIapplication.

Page A-45 of A-168 F&O Regarding PRA Technical ElementsObseirvation ID: Element:

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Level of Significance:

QU-1 QU-1 QU-2, QU-3 BPeer Review F&O:Written guidance to describe the quantification process was not available.

The McGuire PRA makes useof a top logic fault tree for quantification of accident sequences.

The process for building, validating andreviewing the top logic fault tree is complex, requiring the collection and integration of a diverse set ofinformation from all parts of the PRA. A description of this process, guidance on key inputs and sources,and interpretation of outputs, was not available.

Justification for Level of Significance:

Any PRA quantification process is complex and prone to error if explicit guidance is not available.

Possible Resolution A PRA Integration Notebook for the Catawba PRA was shown to the reviewers as an example of the typeof guidance and quantification documentation that is planned for the McGuire PRA. Implementation ofan integration notebook similar to that developed for Catawba would resolve this comment.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.A model integration notebook (Reference 8.45) was created to discuss the processes used to:" build the integrated plant model (database and fault tree)," select an appropriate truncation limit," solve the model,* apply recoveries,

• resolve human error dependencies, and* assign plant damage states.The notebook also provides a high level summary of the PRA model results and a comparison with theprevious model revision results.

The notebook addressing this F&O compiled the documentation describing the model integration process into a single document;

however, the process documented existing methodologies and had no impact on the model results or on the significant accidentsequences.

Page A-46 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

Related Elements:

Level of Significance:

QU-2 QU-19 AS-16, SY-24, HR-21, AHR-25Peer Review F&O:Much of the sequence "recovery" is added to the sequences by means of cut-set editing rather thanintegration into the fault tree top logic. In doing this, some potential hardware failures have beenneglected.

Recovery was not done systematically over all sequences, but rather recovery rules werewritten by hand and as such were only written for high CDF sequences.

An example of these concerns is that alignment of RN gives no consideration of the hardware faults orthe condition of the operating status of Unit 2. At least one RN pump at unit 2 is always assumed to beavailable for cross-tie to unit 1, which may not be the case during modes 5 and 6 at Unit 2.There is no process document for the recovery analysis to describe1. which sequences are recovered

2. how many recoveries are added to each sequence3. how to decide which recovery is applicable to which sequence.

Justification for Level of Significance:

The cutset/sequence recovery analysis for the McGuire PRA is an extension of the accident sequencedevelopment and integral to the quantification and interpretation of results.

As implemented in thePRA as reviewed, the process makes it difficult to determine the adequacy and appropriateness of thesePRA elements.

Possible Resolution As a minimum, provide more specific guidance and documentation of the existing process for sequencerecovery.

Consider modifying the process to be more aligned with current practice at other utilities, whereby anticipated, proceduralized actions (and associated hardware failures) are developed withinthe accident sequences in the fault tree / event tree work and not left for post quantification cutsetediting.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.The recovery process was updated to separate the equipment and human error failure modes. Asecond recovery rule file was created and the human error recoveries were moved to the new rule file.A model integration notebook (Reference 8.45) was created which describes the processes used toapply recovery events and to resolve human error dependencies for cutsets containing multiple humanPage A-47 of A-168 error events. Annotated copies of the rule files used to apply the recoveries are included in thenotebook.

Each general recovery event is commented to explain why the recovery applies.

In caseswhere it might not be obvious why a recovery is applied to specific sequences, the recovery rules arecommented to provide the rationale.

The integration notebook compiled the documentation describing the recovery process into a singledocument;

however, the process documented existing methodologies and had no impact on the modelresults or on the significant accident sequences.

Some recoveries were moved from the recovery rule file into the fault tree logic. For example, toaddress the hardware failures associated with aligning RN via the cross-tie to the other unit, commoncause failure of the RN pumps and RN pump strainers were added to the fault tree logic. The new faulttree logic ensures that a common cause failure affecting both units will prevent RN from being creditedfrom the opposite unit. The model update was performed using the existing methodology toincorporate the new common cause events into the model of record. The contribution to CDF for allcutsets containing these new CCF events is small, which is an indication that the important CCF eventswere already captured in the model. Therefore this update did not involve a significant change in scopeor capability.

Page A-48 of A-168 F&O Regarding PRA Technical ElementsObservation

lD Elemen: Related Elements:

Level of Significance:

QU-4 QU-22 BPeer Review F&O:The quantification cutoff (truncation level) for Rev 2 was 1E-8. The truncation for Rev 3 is 1E-9. TheMcGuire PRA staff has quantified the PRA at cutoffs of IE-10 and 1E-11 and shown that the modelresults converge (to about 3.9E-05 at the time of this review).

The sub-element

criteria, however,require that four orders of magnitude from total LERF be used to get a grade 2 or 3. The quantified valueof LERF is 2E-7 as of this review, so the base line cutoff for LERF quantification per the sub-element criterion would need to be 2 E-11 to get a grade 3 for this element.

Use of a lower cutoff should bepossible using the available quantification software.

Justification for Level of Significance:

It is important to demonstrate that an appropriately low truncation value is used in the quantification.

Possible Resolution Consider implementing a lower LERF quantification cutoff value. Alternatively, perform a resultsconvergence sensitivity to demonstrate that a lower cutoff is not necessary.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record. However, since thisfinding was received, the ASME/ANS Standard has redefined the definition of truncation convergence inSR QU-B3:"ESTABLISH truncation limits by an iterative process of demonstrating that the overall modelresults converge and that no significant accident sequences are inadvertently eliminated.

Forexample, convergence can be considered sufficient when successive reductions in truncation value of one decade result in decreasing changes in CDF or LERF, and the final change is lessthan 5%."The McGuire PRA model of record was solved at successive reductions in truncation limits of onedecade. CDF was found to converge within 1.8% at a truncation limit of 1E-09 and LERF was found toconverge within 2.9% at a truncation limit of 1E-10.No model changes were required as a result of this F&O; however the documentation was expanded todocument the truncation study. This F&O had no impact on the model results or on the significant accident sequences.

Page A-49 of A-168 F&O Regarding PRA Technical ElementsObservation ID: Element:

Related Elements:

Level of Significance:.

MU-1 BPeer Review F&O: .:. .Proposed PRA Model Change forms are used to identify modeling problems and plant changes forconsideration in the update process.

The following potential problems were noted in this process:1. Although there appears to be an intent that a central repository of these forms be maintained, theresponsible analyst could not state with certainty that there is consistent application of this intent inthat the original forms are sometimes distributed to the applicable system modelers rather thancopies. This leads to the potential for forms to be misplaced and the possibility that intendedchanges are not incorporated.

2. The Proposed PRA Model Change forms are not consistently reviewed and approved due to theabsence of a requirement for timely review and approval.

One PRA Update form dated 6/3/98 wasreviewed which reported a problem with RN Train Maintenance events not causing diesel failurefollowing an LOSP. The risk significance was marked Unknown and no apparent attempt was madeto investigate the potential impact on the Revision 2 results, even though the problem wasdetermined to be a potentially incorrect breaking of circular logic.3. There is no closure mechanism for ensuring that all changes have been incorporated into a modelrevision or disposed of by evaluation.

The current process relies on the system notebook reviewers to verify implementation of proposed changes.

However, without a central database or repository of proposed

changes, the reviewer can only check those forms passed along to him by the systemnotebook preparer.

For example, a Proposed PRA Model Change for was found which evaluated LER 369/97-09 as representing a potential unmodeled dependence within the CA system, an impacton automatic operation of the PORVs and a potential dual-unit initiating event. The appropriate system model changes appear to have been incorporated, but the rationale for not adding a dual-unit trip initiating event on loss of the 125V DC Auxiliary Control Panel is not documented.

Likewise, a proposed change form dated 3/29/99 documents a flood event in the McGuire CA pump room.However, this event is not listed in the flood events table for the latest revision of the flooding studyand does not appear to have been considered through Bayesian updating of generic flood data assuggested in the proposed resolution.

4. It is not clear that the Proposed PRA Model Change forms are distributed to all of the analystspotentially affected by the change. A proposed change noting that the SSF is not typically mannedduring a T6 event was found in the Transient Analysis notebook.

However, it appears that thischange affects the SSF system model and was not incorporated into Revision 3 of the SSF fault tree.Justification for Level of Significance:

There is no evidence that the noted process implementation problems have a significant impact on CDF,Page A-50 of A-168 but it appears that the process could allow items with potentially significant impact to "slip through thecracks."Possil~ie Resolution Develop guidelines for timely review and consistent retention of the Proposed PRA Model Change formsand a database/process to document the disposition of each proposed change.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record.A PRA workplace procedure was created for PRA maintenance and update. This workplace procedure defines the PRA model configuration and control process including how known model changes or errorsare addressed for risk-informed applications.

Any identified model changes are entered into thePRATracker database along with a risk evaluation to determine the risk significance of the change. Allcompleted changes in the database are reviewed as part of any subsequent risk application, including this application submittal (refer to Section 7.3). Any model changes that can impact the results orconclusions of an application must be addressed.

The PRATracker database is reviewed annually to determine the cumulative effect of proposed changeson the PRA model. PRA personnel are trained on the use and application of this database for risk-informed applications.

No model changes are required to address this F&O and the F&O has no impacton the results or conclusions of this application.

Page A-51 of A-168 4.2 Internal Events Gap Assessment to ASME/ANS RA-Sa-2009 PRA StandardSubsequent to the previously discussed peer review, the ASME/ANS PRA Standard was developed andissued. Duke Energy performed a self assessment that evaluated the differences between the originalpeer review against NEI 00-02 and RA-S-2008 of the ASME/ANS PRA Standard, as endorsed byRegulatory Guide 1.200, Revision

1. The self assessment was performed in 2008. The results of this selfassessment are documented in DPC-1535.00-00-0013 (Reference 8.14).The assessment indicated that 230 of the 306 Supporting Requirements (SRs) for Revision 1 were fullymet at Capability Category II. In addition, 24 of the SRs were not applicable to McGuire, either becausethe referenced techniques were not used in the PRA or because the SR was not required for Capability Category (CC) II. Of the 52 open SRs, 42 require enhanced documentation, and only 10 were of atechnical nature. The self assessment team indicated that none of the open items are expected to havea significant impact on the PRA results or insights.

Two of the technical open items have been addressed and incorporated into the model of record. Focused peer reviews have been performed for the internalflood and large early release (LERF) models, which supersede a further thirteen open items. Theremaining 37 SRs that were determined to be not fully met have been dispositioned for the RI-ISIapplication.

EPRI report TR 1021467-A, "Nondestructive Evaluation:

Probabilistic Risk Assessment Technical Adequacy Guidance for Risk-Informed In-Service Inspection Programs" (Reference 8.6), providesguidance on determining the technical adequacy of PRAs used to develop a RI-ISI program.

This reporthas been reviewed by the NRC staff and found to be acceptable for referencing in licensing applications for RI-ISI programs with comments provided in an attached SE. Revision 1021467-A incorporates the SEcomments and was used to determine the minimum capability category (CC) recommended for eachsupporting requirement (SR) in the ASME/ANS PRA Standard within the scope of the RI-ISI program.Table 2 maps the SR listed in the EPRI report to the SR identifier in version ASME/ANS RA-Sa-2009 of theASME/ANS PRA Standard.

Table 2 then lists the recommended minimum CC for the EPRI Streamlined RI-ISI application from the EPRI report and summarizes the results of the gap assessment for those SRsdetermined to not fully meet CC II.Table 2: Comparison of McGuire Internal Events Gap Assessment to the EPRI Streamlined RI-ISI Requirements 2005 PRA 2009 PRA EPRI Streamlined Standard SR Standard SR RI-ISI Requirements IE-Al IE-Al CC 1/11/111 Partially Met at CC 1/11/111IE-A3 IE-A3 CC 1/11/111 Partially Met at CC 1/11/111IE-A3a IE-A4 CC 1/11 Partially Met at CC 1/11IE-A4 IE-A5 CC II Partially Met at CC IIIE-A4a IE-A6 CC I Partially Met at CC IIIE-A5 IE-A7 CC 1/11/111 Partially Met at CC 1/11/111IE-A6 IE-A8 CC I NoIE-A7 IE-A9 CC I Partially Met at CC IIIE-B1 IE-B1 CC 1/11/111 NoIE-B2 IE-B2 CC 1/11/111 Partially Met at CC 1/11/111Page A-52 of A-168 2005 PRA 2009 PRA EPRI Streamlined Standard SR Standard SR RI-ISI Requirements IE-B3 IE-B3 CC I Partially Met at CC IIIE-D3 IE-D3 Need not be met NoAS-B3 AS-B3 CC I/Il/Ill Partially Met at CC I/Il/IllSC-A4 SC-A3 CC I/Il/Ill Partially Met at CC I/Il/IllSC-B5 SC-B5 CC I/Il/Ill Partially Met at CC I/Il/IllSC-Ci SC-Cl CC I/Il/Ill Partially Met at CC I/Il/IllSC-C2 SC-C2 CC I/Il/Ill Partially Met at CC I/Il/IllSY-A4 SY-A4 CC I Partially Met at CC Il/Il1SY-A8 SY-A8 CC I/Il/Ill NoSY-A14 SY-A15 CC I/Il/Ill Partially Met at CC I/Il/IllSY-B8 SY-B8 CC I/Il/Ill Partially Met at CC I/Il/IllSY-B25 SY-B14 CC I/Il/Ill Partially Met at CC I/Il/IllSY-C2 SY-C2 CC I/Il/Ill Partially Met at CC I/Il/IllHR-A2 HR-A2 CC I/Il/Ill Partially Met at CC I/Il/IllHR-A3 HR-A3 CC I/Il/Ill NoHR-D6 HR-D6 CC I/Il/Ill NoHR-G3 HR-G3 CC I Partially Met at CC Il/IllHR-G4 HR-G4 CC I Partially Met at CC IIHR-G6 HR-G6 CC I/Il/Ill NoHR-G9 HR-G8 CC I/Il/Ill NoHR-H2 HR-H2 CC I/Il/Ill Partially Met at CC I/Il/IllDA-Ala DA-A2 CC I/Il/Ill NoDA-B1 DA-B1 CC I Partially Met at CC IIDA-D4 DA-D4 CC I Partially Met at CC Il/111DA-D6 DA-D6 CC I Partially Met at CC IIQU-D3 QU-D4 CC I NoQU-E4 QU-E4 Need not be met NoQU-F2 QU-F2 CC 1/11/111 Partially Met at CC 1/11/111QU-F6 QU-F6 CC 1/11/111 Partially Met at CC 1/11/111Page A-53 of A-168 Supporting Requirement IE-AlEPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially Met at CC 1/11/111Capability Category 1/11/111 Requirements:

IDENTIFY those initiating events that challenge normal plant operation and that require successful mitigation to prevent core damage using a structured, systematic process for identifying initiating events that accounts for plant-specific features.

For example, such a systematic approach may employmaster logic diagrams, heat balance fault trees, or failure modes and effects analysis (FMEA). Existinglists of known initiators are also commonly employed as a starting point.Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance the IE documentation (as was done in OSC-9068).

Disposition of the Gap Assessment Finding:The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.The sources for this list include previous PRAs, the PRA success criteria

analysis, precursor events, theMaintenance Rule function list, multiple failure events that have occurred at McGuire, events thatoccurred at shutdown conditions, the PSA WOG database, NUREG/CR-5750 and NUREG/CR-6928 data.This list was compared against the initiating events considered in the model of record (MOR) and foundto be consistent with the previous

modeling, with the exception of HVAC. HVAC is dispositioned inF&Os IE-2 and TH-6 and assessed for impact to the RI-ISI application in a sensitivity study in Section 7.1.Therefore, this gap is considered to be a documentation issue and does not have a significant impact onthe results or conclusions of this application.

Table 3: Comparison of the MOR Initiating Events to the Updated List for the Next Model RevisionInitiating Event MOR Updated ModelReactor/Turbine Trip Yes YesLoss of Main Feedwater Yes YesExcess Feedwater Yes YesFeedwater or Condensate Line Breaks Yes YesSteam Line Break Inside Containment Yes YesSteam Line Break Outside Containment Yes YesLoss of Load Yes I YesPage A-54 of A-168 Loss of Instrument AirYesYesFires Affecting Necessary Systems Yes YesInternal Flooding Affecting Necessary Systems Yes YesLoss of HVAC No No (refer to NEI00-02 F&O IE-2)RCP Seal LOCA Yes YesSmall RCS Pipe Breaks Yes YesMedium RCS Pipe Breaks Yes YesLarge RCS Pipe Breaks Yes YesInadvertent PORV Opening Yes YesInadvertent Safety Valve(s)

Opening Yes YesInterfacing-system LOCA Yes YesReactor Pressure Vessel Rupture Yes YesSteam Generator Tube Leak/Rupture Yes YesInadvertent High Pressure Injection Initiator Yes YesLoss of Service Water Yes YesPartial Loss of Service Water (included in loss Yesof SW 1E)Loss of Component Cooling Water Yes YesPartial Loss of Component Cooling Water (included in loss Yesof CCW IE)Loss of Offsite Power Yes YesPartial Loss of Offsite Power (included in LOOP YesIE)Loss of 6.9 kV Normal Auxiliary Power Yes YesLoss of 4160V Essential Buss/CCF Loss of Essential Yes YesBus ETA & ETBLoss of 600V Normal Auxiliary Power Yes YesLoss of 240/120 VAC Normal Auxiliary Control Yes YesPowerLoss of 120 VAC Vital Instrumentation and Control Yes YesPowerLoss of 125 VDC Auxiliary Control Power Yes YesLoss of 125 VDC Vital Instrumentation and Control Yes YesPowerLoss of 13.8kV Normal Auxiliary Power Yes YesLoss of KXB Bus Yes YesLoss of 25OVDC Auxiliary Power Yes YesPage A-55 of A-168 Supporting Requirement IE-A3EPRI Streamlined RI-SI CC Requirement:I McGuire PRA Model CC Assessment:

CC 1/11/111 Partially Met at CC 1/11/111Capability Category 1/11/111 Requirements:

REVIEW the plant-specific initiating event experience of all initiators to ensure that the list of challenges accounts for plant experience.

See also IE-A7.Gap Assessment Finding:*

The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Perform a review of the plant-specific initiating event experience of all initiators to ensure that the list ofchallenges accounts for plant experience.

Disposition of the Gap Assessment Finding:The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.The sources for this list include previous PRAs, the PRA success criteria

analysis, precursor events, theMaintenance Rule function list, multiple failure events that have occurred at McGuire, events thatoccurred at shutdown conditions, the PSA WOG database, NUREG/CR-5750 and NUREG/CR-6928 data.An example from the plant-specific review is provided as follows.The following plant-specific initiating events were identified from the review of plant-specific sources such as LERs and SOERs:* Rod drop* Inadvertent rod withdrawal

• Rod ejection* Inadvertent boration or deboration

• Reactor tripC Cold water addition* Reactor coolant pump trip* Reactor coolant pump seizure* Flow channel blockage* Loss of main feedwater

• Excess feedwater (main or emergency)

• Loss of condenser vacuum* Inadequate main feedwater

• Feedwater or condensate line breaks* Steamline breaks (inside and outside containment)

• Turbine control valve malfunction

• Turbine bypass valve inadvertent openingPage A-56 of A-168

• Turbine trip or malfunction

• Loss of circulating water* Loss of instrument air* Loss of Vital I&C power* Fire affecting necessary systems* Internal flooding affecting necessary systems* Loss of HVAC* Generator faults* Grid disturbances

• Administratively caused shutdowns

• Small RCS pipe breaks* Medium RCS pipe breaks* Large RCS pipe breaks* Inadvertent PORV or safety valve opening* Failure of reactor coolant pump seals* Leakage of control rod drive seals* Interfacing-system loss of coolant* Reactor vessel rupture* Steam generator tube leak/rupture

• Charging exceeds letdown* Letdown exceeds charging* Inadvertent high pressure injection

• Failure on or off of pressurizer heaters* Failure on or off of pressurizer spray* Loss of offsite power* Loss of power to necessary systems* Partial losses of power to control systems* Loss of service water* Loss of component coolingThe final potential initiating event list was compared against the initiating events considered in themodel of record and found to be consistent with the previous modeling (refer to Table 3 in gap IE-Al).Therefore, this gap is considered to be a documentation issue and does not have a significant impact onthe results or conclusions of this application.

Page A-57 of A-168 Supporting Requirement IE-A4EPRI Streamlined RI-ISI.CC Requirement:

"" McGuire PRA Model CC Assessment:

CC 1/11 Partially Met at CC 1/11Capability Category I/1i Requirements:

REVIEW generic analyses of similar plants to assess whether the list of challenges included in the modelaccounts for industry experience.

Gap Assessment Finding:

,. ..The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Ensure the list of challenges included in the McGuire PRA accounts for industry experience using a morerecent reference, such as the WOG PSA Model and Results Comparison Database

-Revision 4.Disposition ofthe Gap Assessment Finding:The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.The sources for this list include previous PRAs, the PRA success criteria

analysis, precursor events, theMaintenance Rule function list, multiple failure events that have occurred at McGuire, events thatoccurred at shutdown conditions, the PSA WOG database, NUREG/CR-5750 and NUREG/CR-6928 data.An example from the review of similar plants is provided as follows.The following plant-specific initiating events were identified from the review of the PSA WOGdatabase:

• Anticipated Transient Without Scram (ATWS)I Inadvertent Safety Injection Signal* Interfacing Systems LOCA.Internal Flooding* Large LOCA* Loss of 120V Vital AC* Loss of 125V Vital DC* Loss of Charging (CVCS)* Loss of Chilled Water* Loss of Component Cooling Water* Loss of High Voltage Vital AC* Loss of HVAC* Loss of Instrument Air* Loss of Offsite Power (multi-unit)

• Loss of Offsite Power (single unit)* Loss of Service Water (multi-unit)

Page A-58 of A-168

• Loss of Service Water (single unit)" Medium LOCA" Reactor Vessel Rupture* Secondary Side Breaks Inside Containment

" Secondary Side Breaks Outside Containment

" Small LOCA" Station Blackout" Steam Generator Tube RuptureThe final potential initiating event list was compared against the initiating events considered in themodel of record and found to be consistent with the previous modeling (refer to Table 3 in gap IE-Al).Therefore, this gap is considered to be a documentation issue and does not have a significant impact onthe results or conclusions of this application.

Page A-59 of A-168 Supporting Requirement IE-A5EPRI Streamlined al-IS C;C Require .ment: McGuire PRA Model CC Assessment::" CC 11 Partially Met at CC 11Capability Category II Requirements:

PERFORM a systematic evaluation of each system, including support systems, to assess the possibility ofan initiating event occurring due to a failure of the system.USE a structured approach

[such as a system-by-system review of initiating event potential, or afailure modes and effects analysis (FMEA), or other systematic process]

to assess and document thepossibility of an initiating event resulting from individual systems or train failures.

Gap Assessment Findingg:

The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Provide documentation of a systematic evaluation of all plant systems, including support systems(including those not explicitly modeled in the PRA), to assess the possibility of an initiating eventoccurring due to a failure of the system.Disposition of th e Gap Assessment Finding:The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.

TheMaintenance Rule functions were used to develop a comprehensive list of systems and subsystems thatare identified as possibly causing a plant transient, including those resulting from multiple failures.

Thislist was then validated by interviews with plant engineering, operations and maintenance, who alsodetermined the sequential plant response for each function.

The following is an example of thedocumentation provided in the calculation from this review.Sequential plant response If applicable

-- sequential plantssc MR up to a reactor trip or SS response up to a reactor trip, Potential Description Function MR Function Description actuation if function fails SS actuation if function Initiating or manual shutdown spuriously performs or a Event(s)required manual shutdownAuxiliary AS.1 Maintains auxiliary steam Loss of condenser vacuum. Loss of condenser vacuum and ReactorSteam to each unit as required subsequent turbine Trip/Loss ofduring startup, normal trip/reactor trip. Condenser I operation, and shutdown.

I VacuumThe final list was compared against the initiating events considered in the model of record and found tobe consistent with the previous modeling (refer to Table 3 in gap IE-Al). Therefore, this gap isPage A-60 of A-168 considered to be a documentation issue and does not have a significant impact on the results orconclusions of this application.

Page A-61 of A-168 Supporting Requirement IE-A6EPRI Streamlined Rl'I.[SI CC Requirement:

PRA Model CC Assessment:

CC I Partially Met at CC 11,:... ~ ~~ ~~. .* .... ,.. ... ,. ..: * : :....:Capability Category Ii Requirements:

When performing the systematic evaluation required in IE-A5, INCLUDE initiating events resulting frommultiple

failures, if the equipment failures result from a common cause, and from routine systemalignments.

Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance the IE documentation (as was done in OSC-9068).

Disposition of the Gap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2. However, the following discussion considers CC II for this SR.The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.

TheMaintenance Rule functions were used to develop a comprehensive list of systems and subsystems thatare identified as possibly causing a plant transient, including those resulting from multiple failures.

Thislist was then validated by interviews With plant engineering, operations and maintenance, who alsodetermined the sequential plant response for each function.

An example from the review of initiating events resulting from multiple failures is provided as follows:The following plant-specific initiating events were identified from the review of events involving multiple failures:

• Manual Shutdown due to CCF Loss of Diesel Generators

• Failure Off of Pressurizer Heaters* Loss of Charging (CVCS)* ATWS* Loss of 125 VDC Vital Instrumentation

& Control Power System* ISLOCAThe final list was compared against the initiating events considered in the model of record and found tobe consistent with the previous modeling (refer to Table 3 in gap IE-Al). Therefore, this gap isPage A-62 of A-168 considered to be a documentation issue and does not have a significant impact on the results orconclusions of this application.

Page A-63 of A-168 Supporting Requirement IE-A7EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model C C Assessment:

CC 1/11/111 Partially Met at CC 1/11/111Capability Category

/!I!/Ill Requirements:

In the identification of the initiating events, INCORPORATE a) events that have occurred at conditions other than at-power operation (i.e., during low-power orshutdown conditions),

and for which it is determined that the event could also occur during at-power operation b) events resulting in an unplanned controlled shutdown that includes a scram prior to reaching low-power conditions, unless it is determined that an event is not applicable to at-power operation Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance the IE documentation (as was done in OSC-9068).

Disposition of the Gap Assessment Finding:The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.The sources for this list include previous PRAs, the PRA success criteria

analysis, precursor events, theMaintenance Rule function list, multiple failure events that have occurred at McGuire, events thatoccurred at shutdown conditions, the PSA WOG database, NUREG/CR-5750 and NUREG/CR-6928 data.An example from the review of initiating events at shutdown conditions is provided as follows:The following plant-specific initiating events were identified from the review of EPRI TR 1003113:Initiating Event Initiating Event Description Potential for at-Power Initiating EventCategoryla Loss of running RHR pump or This is a failure during an accident sequence that involves a loss of low pressureRHR flow during midloop injection in a configuration the plant would not be in during at-power conditions.

This is not an initiator.

lb Loss of running RHR pump all This is a failure during an accident sequence that involves a loss of low pressureother times or conditions injection.

The low pressure injection would not start until an initiator occurred thatrequired injection from this source. This is not an initiator.

2 Loss of cooling water or heat This is a failure during an accident sequence that involves a loss of the low pressuretransfer capability to RHR heat injection system function.

The low pressure injection system would not start until anexchangers initiator occurred that required injection from this source. This is not an initiator.

The final list was compared against the initiating events considered in the model of record and found toPage A-64 of A-168 be consistent with the previous modeling (refer to Table 3 in gap IE-Ai). Therefore, this gap isconsidered to be a documentation issue and does not have a significant impact on the results orconclusions of this application.

Page A-65 of A-168 Supporting Requirement IE-A8EPRI Streamlined Rl-lS~ICC Requirement:

McGuire PRA Model CC Assessment:

CC I Not MetCapability Category Ii.Requirements:.

INTERVIEW plant personnel (e.g., operations, maintenance, engineering, safety analysis) to determine ifpotential initiating events have been overlooked.

Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Obtain plant personnel input (as was done in OSC-9068).

Disposition of theGap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2. However, the following discussion considers CC II for this SR.The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.

TheMaintenance Rule functions were used to develop a comprehensive list of systems and subsystems thatare identified as possibly causing a plant transient, including those resulting from multiple failures.

Thislist was then validated by interviews with plant engineering, operations and maintenance, who alsodetermined the sequential plant response for each function.

The final list was compared against the initiating events considered in the model of record and found tobe consistent with the previous modeling (refer to Table 3 in gap IE-Al). Therefore, this gap isconsidered to be a documentation issue and does not have a significant impact on the results orconclusions of this application.

Page A-66 of A-168 Supporting Requirement IE-A9EPRI Stream~rlined RI-ISI CC Requirement:

iMcGuire PRA Model CC Assessment:

CC I Partially Met at CC 11Capability Category I1 Requirements:

REVIEW plant-specific operating experience for initiating event precursors, for identifying additional initiating events. For example, plant-specific experience with intake structure clogging might indicatethat loss of intake structures should be identified as a potential initiating event.Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Include review of precursor events for their potential to be initiating events.Disposition of the Gap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2. However, the following discussion considers CC II for this SR.The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.

Thiscalculation reviewed the series of NUREG/CRs:

'Precursors to Potential Severe Core Damage Accidents' for plant-specific precursors that had the potential to be an initiating event. An example from the plant-specific review is provided as follows.The following plant-specific initiating events were identified from the review of precursor events:* Loss of 120 VAC Vital Instrumentation

& Control Power Bus* Loss of Offsite Power* Reactor Trip with Stuck-Open SG Relief Valve* Reactor Trip* Loss of KXB Bus* Loss of Main Feedwater

• Steam Generator Tube Rupture* Manual shutdown due to LCO with both OGs unavailable The final list was compared against the initiating events considered in the model of record and found tobe consistent with the previous modeling (refer to Table 3 in gap IE-Al). Therefore, this gap isconsidered to be a documentation issue and does not have a significant impact on the results orconclusions of this application.

Page A-67 of A-168

... .Supporting Requirement IE :"EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Not MetCapability Category 1/11/111 Requirements:

COMBINE initiating events into groups to facilitate definition of accident sequences in the AccidentSequence Analysis (2-2.2) and to facilitate quantification in the Quantification (2-2.7).Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Enhance the IE documentation (as was done in OSC-9068).

Disposition of the Galp Assessment Finding:The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.This calculation combined the initiating events into groups based on similar plant response andcomparable impacts including success criteria, timing and operator response.

The initiating eventgroups were chosen such that all events in a group are bounded by the worst case impacts for the wholegroup. An example of initiating event grouping is provided as follows.

Each initiating event ID numberwas compiled from a difference data source.Table 4: Example of Initiating Event GroupingInitiating Events (ID #) Initiating EventGroupLoss of component cooling (46), Component Cooling (143), Loss of Component Cooling Loss of component Water (207), Total loss of component cooling water (271) coolingGenerator faults (25), 24 kV Unit Main Power (93), Unit Main Power Protective Relaying Generator faults(106), Unit Main Power Control (107), Unit Main Power Metering

& Monitoring (108)The final list was compared against the initiating events considered in the model of record and found tobe consistent with the previous modeling (refer to Table 3 in gap IE-Al). Therefore, this gap isconsidered to be a documentation issue and does not have a significant impact on the results orconclusions of this application.

Page A-68 of A-168 Supporting Requirement IE-B2EPRI Streamlined.

R-IHSI CC Requirement:

McGuire PRA Model.CC Assessment:

CC 1/11/111 Partially Met at CC 1/11/111PCapability Category 1/11/111 Requirements:

USE a structured, systematic process for grouping initiating events. For example, such a systematic approach may employ master logic diagrams, heat balance fault trees, or failure modes and effectsanalysis (FMEA).Gap Assessment Finding:

... ....The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Document a structured, systematic grouping of initiating events (as was done in OSC-9068).

Disposition of the Gap Assessment Finding:

......The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.This calculation combined the initiating events into groups based on similar plant response andcomparable impacts including success criteria, timing and operator response.

The initiating eventgroups were chosen such that all events in a group are bounded by the worst case impacts for the wholegroup. Refer to Table 4 in gap IE-B1 for an example of initiating event grouping.

The final list was compared against the initiating events considered in the model of record and found tobe consistent with the previous modeling (refer to Table 3 in gap IE-Al). Therefore, this gap isconsidered to be a documentation issue and does not have a significant impact on the results orconclusions of this application.

Page A-69 of A-168 Supporting Requirement IE-B3EPRI Streamlined RI-ISI CC Requirement:

..McGuire PRA Moe' C sssmetCC I Partially Met at CC 11Capability Category I Requirements:

......GROUP initiating events only when the following can be ensured:a) events can be considered similar in terms of plant response, success criteria, timing, and the effecton the operability and performance of operators and relevant mitigating systems; orb) events can be subsumed into a group and bounded by the worst case impacts within the "new"groupDO NOT SUBSUME scenarios into a group unless1) the impacts are comparable to or less than those of the remaining events in that groupAND2) it is demonstrated that such grouping does not impact significant accident sequences Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance documentation of the grouping process (as was done in OSC-9068).

Disposition of the Gap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2. However, the following discussion considers CC II for this SR.The McGuire PRA model is undergoing an update. The calculation for identifying potential initiating events (Reference 8.48) has been completed.

The level of documentation was greatly expanded in thiscalculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the initiating events methodology has not been changed.This calculation determined an updated list of potential initiating events that could impact McGuire.This calculation combined the initiating events into groups based on similar plant response andcomparable impacts including success criteria, timing and operator response.

The initiating eventgroups were chosen such that all events in a group are bounded by the worst case impacts for the wholegroup. Refer to Table 4 in gap IE-B1 for an example of initiating event grouping.

The final list was compared against the initiating events considered in the model of record and found tobe consistent with the previous modeling (refer to Table 3 in gap IE-Al). Therefore, this gap isconsidered to be a documentation issue and does not have a significant impact on the results orconclusions of this application.

Page A-70 of A-168 Supporting Requirement IE-D3SE.PRI Streamlined.

RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

Need not be met Not MetCapability Category 1/11/111 Requirements:

DOCUMENT the sources of model uncertainty and related assumptions (as identified in QU-E1 and QU-E2). associated with the initiating event analysis.

Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Enhance the IE documentation (as was done in OSC-9068).

Disposition of the Gap Assessment Finding:The Gap Assessment determined that this SR is not met when compared with the CC 1/11/111requirements.

For RI-ISI applications this SR is not required to be met in accordance with EPRI TR-1021467, Table 2-2.Page A-71 of A-168 Supporting Requirement AS-B3Streamlined RI-ISI CC: R=::=equi~rement:

Mc:Guire PRA Model CC Assessment:*

cc 1/11/111 Partially metCapability Category 1/11/111 Requirements:

For each accident

sequence, IDENTIFY the phenomenological conditions created by the accidentprogression.

Phenomenological impacts include generation of harsh environments affecting temperature,

pressure, debris, water levels, humidity, etc. that could impact the success of the systemor function under consideration

[e.g., loss of pump net positive suction head (NPSH), clogging of flowpaths]. INCLUDE the impact of the accident progression phenomena, either in the accident sequencemodels or in the system models.Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Accident sequence notebooks and system model notebooks should identify those environmental effectsof the initiating event and the impact on mitigation systems.Disposition of the Gap Assessment Finding:The phenomenological effects are already considered in the model but were not adequately documented in the various accident sequence notebooks or the system notebooks as required by thestandard.

The PRA model was examined to confirm the presence of the phenomenological effects.Examples from the model include:* LNPSH -Loss of NPSH Margin Due to Sump Blockage* LNPSHMED

-Loss of NPSH Margin Due to Sump Blockage for Medium LOCAs* LNPSHLAR

-Loss of NPSH Due to Sump Blockage for Large LOCAs* LNPSHSML

-Loss of NPSH Due to Sump Blockage for Small LOCAs" LNPSHTIL

-Loss of NPSH Margin Due to Sump Blockage for Transient Induced LOCAs" LN4NPSHDEX

-Debris Induced Loss of NPSH Margin Due to PRT Rupture or Transient LOCA Events" W1005A -Flow Path Through RN Strainer 1A Blocked" W1020B -Strainer B Automatic Backwash Flow Path BlockedThe model examination confirmed that there is reasonable assurance that phenomenological effects areconsidered throughout the model. Therefore, this gap is considered to be a documentation issue anddoes not have a significant impact on the results or conclusions of this application.

Page A-72 of A-168 Supporting Requirement SC-A3EPRI Streamlined RI-ISI CC Requirement:*

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially met at CC 1/11/111...Capability Category 1/11/11 Requirements:

SPECIFY success criteria for each of the key safety functions identified per SR AS-A2 for each modeledinitiating event [Note (2)].Gap Assessment Finding:The gap assessment concluded that this SR was partially met at CC 1/11/111 in the original analysis.

Thisgap can be addressed as follows:Improve the documentation on the TH bases for all safety function success criteria for all initiators.

Disposition of the Gap Assessment Finding:The McGuire PRA model is currently undergoing a revision.

An updated success criteria analysis hasbeen performed (Reference 8.49). The level of documentation was greatly expanded in this calculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the success criteriamethodology has not been changed and the MAAP thermal-hydraulic code was used for both modelrevisions.

The success criteria calculation defines success criteria for each of the key safety functions forall initiators defined in the McGuire PRA model (refer to Table 1 in F&O TH-1).The updated success criteria were compared against those used in the model of record and nosignificant differences were found (refer to Table 1 in F&O TH-1). Therefore, this gap is considered to bea documentation issue and does not have a significant impact on the results or conclusions of thisapplication.

Page A-73 of A-168 S..Supporting Requirement SC-B5EPRI Streamlined RI-ISI CC Requirement:

McGuirePRAýModel CC Assessment:

CC 1/11/111 Partially met at CC 1/11/111Capability Category 1/11/111 Requirements:

CHECK the reasonableness and acceptability of the results of the thermal/hydraulic, structural, or othersupporting engineering bases used to support the success criteria.

Examples of methods to achieve this include(a) comparison with results of the same analyses performed for similar plants, accounting fordifferences in unique plant features(b) comparison with results of similar analyses performed with other plant-specific codes(c) check by other means appropriate to the particular analysisGap Assessment Finding:The gap assessment concluded that this SR was partially met at CC 1/11/111 in the original analysis.

Thisgap can be addressed as follows:Provide evidence that an acceptability review of the T/H analyses is performed.

Disposition of the Gap Assessment Finding:The McGuire PRA model is currently undergoing a revision.

An updated success criteria analysis hasbeen performed (Reference 8.49). The level of documentation was greatly expanded in this calculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the success criteriamethodology has not been changed and the MAAP thermal-hydraulic code was used for both modelrevisions.

The success criteria calculation performed a comparison of the McGuire success criteria to the industryand the McGuire success criteria were determined to be reasonable and acceptable.

Table 5summarizes this comparison:

Table 5: Comparison of McGuire Success Criteria to IndustryEVENT MCGUIRE RANGE OF INDUSTRY CRITERIALEAST REQUIRED MOST REQUIREDLLOCA 1 ND pump & 2 Accumulators

-1 lo press pump -1 Io press pump-No accum -2 med/hi press pumps-3 accumMLOCA 1 NV pump or 1 NI pump with SSHR -1 lo press pump -1 lo press pump1 NV pump w/o SSHR for 1.5" -2" -1 med/hi press pump -2 med/hi press pump-No accum -3 accumPage A-74 of A-168 SLOCA 1 NV pump or 1 NI pump with SSHR With SSHR: With SSHR:-1 med/hi press pump -1 med/hi press pump-2 PORVs-2 accum1 NV pump & I open PORV OR With SSHR failure:

With SSHR failure:1 NI pump & 2 open PORVs w/o SSHR -1 med/hi press pump -1 med/hi press pump1 NV pump OR Feed & Bleed cooling (as w/o SSHR) -2 PORVswith SSHR run failure -1 SRVSGTR 1 NV pump or I NI pump AND -SSHR -SSHRRCS depressurization or RWST refill with SSHR -1 med/hi press pump -1 med/hi press pumpFeed & bleed cooling w/o SSHR (similar to SLOCA w/o -1 PORV -3 PORVsSSHR) -Pressurizer spray-SS cooldownStuck-Open 1 NV pump or 1 NI pump with SSHR for stuck PORV Treated as LOCAs in database.

Valves 1 NV pump or 2 NI pumps w/o SSHR for stuck PORV1 NV pump or 1 NI pump for stuck SRVFeed & 1 NV pump AND 1 PORV with SSHR OR -1 med/hi press pump -2 med/hi press pumpsBleed 1 NI pump AND 2 PORVs (or 2 NI and 1 PORV) w/o -1 PORV -3 PORVsSSHR -1 SRV1 NV pump (bleed thru 1 PORV or 1 SRV) OR1 NI pump AND 1 PORV with SSHR run failureThe updated success criteria were compared against those used in the model of record and nosignificant differences were found (refer to Table 1 in F&O TH-1). Therefore, this gap is considered to bea documentation issue and does not have a significant impact on the results or conclusions of thisapplication.

Page A-75 of A-168 Supporting Requirement SC-C IEPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially met at CC 1/11/111Capability Category I/ll/lli Requirements:

... ..DOCUMENT the success criteria in a manner that facilitates PRA applications,

upgrades, and peerreview.Gap Assessment Finding:The gap assessment concluded that this SR was partially met at CC 1/11/111 in the original analysis.

Thisgap can be addressed as follows:Improve the documentation on the TH bases for all safety function success criteria for all initiators.

Disposition of the Gap Assessment Finding:The McGuire model of record success criteria calculations (References 8.75, 8.76, 8.77 & 8.78) werereviewed and it was determined that the documentation needs to be expanded in order to fully meetthe intent of this SR.The McGuire PRA model is currently undergoing a revision.

An updated success criteria analysis hasbeen performed (Reference 8.49). The level of documentation was greatly expanded in this calculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the success criteriamethodology has not been changed and the MAAP thermal-hydraulic code was used for both modelrevisions.

The success criteria calculation has been documented with a clear road map to theASME/ANS PRA Standard in order to facilitate an independent review of the success criteria.

An excerptfrom this roadmap follows:SR CATEGORY II ROADMAPSC-Al USE the definition of core damage provided in Section 1-2 The definition of core damage used for thisof this Standard.

If core damage has been defined analysis is provided in Section 2.2, and the basis isdifferently than in Section 1-2, in Reference

[6].(a) IDENTIFY any substantial differences from the Section 1-2 definition (b) PROVIDE the bases for the selected definition The updated success criteria were compared against those used in the model of record and nosignificant differences were found (refer to Table 1 in F&O TH-1). Therefore, this gap is considered tobe a documentation issue and does not have a significant impact on the results or conclusions of thisapplication.

Page A-76 of A-168 Supporting Requirement SC-C2EPRI Streamlined RI-SI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially met at CC 1/11/111Capability Category 1/11/111 Requirements:

DOCUMENT the processes used to develop overall PRA success criteria and the supporting engineering bases, including the inputs, methods, and results.

For example, this documentation typically includes(a) the definition of core damage used in the PRA including the bases for any selected parameter valueused in the definition (e.g., peak cladding temperature or reactor vessel level)(b) calculations (generic and plant-specific) or other references used to establish success criteria, andidentification of cases for which they are used(c) identification of computer codes or other methods used to establish plant-specific success criteria(d) a description of the limitations (e.g., potential conservatisms or limitations that could challenge theapplicability of computer models in certain cases) of the calculations or codes(e) the uses of expert judgment within the PRA, and rationale for such uses(f) a summary of success criteria for the available mitigating systems and human actions for eachaccident initiating group modeled in the PRA(g) the basis for establishing the time available for human actions(h) descriptions of processes used to define success criteria for grouped initiating events or accidentsequences Gap Assessment Finding:The gap assessment concluded that this SR was partially met at CC 1/11/111 in the original analysis.

Thisgap can be addressed as follows:Improve the documentation on the TH bases for all safety function success criteria for all initiators.

Disposition of the Gap Assessment Finding:The McGuire model of record success criteria calculations (References 8.75, 8.76, 8.77 & 8.78) werereviewed and it was determined that the documentation needs to be expanded in order to fully meetthe intent of this SR.The McGuire PRA model is currently undergoing a revision.

An updated success criteria analysis hasbeen performed (Reference 8.49). The level of documentation was greatly expanded in this calculation to clearly roadmap adherence to the ASME/ANS PRA Standard;

however, the success criteriamethodology has not been changed and the MAAP thermal-hydraulic code was used for both modelrevisions.

The success criteria calculation includes documentation for each initiating event detailing thethermal-hydraulic bases for all safety function success criteria.

For example, the documentation relatedto the recommended items from the SR have been addressed in the calculation as follows:(a) Section 2.2Page A-77 of A-168 (b) Appendices for each event(c) MAAP (mentioned throughout)

(d) Limitations of MAAP in Section 3.1; assumptions and uncertainties in each appendix(e) Expert judgment not used as basis for success criteria(f) Tables in Section 3(g) Not in this document

-see HRA notebooks (h) Process for each group of events described in each respective AppendixThe updated success criteria were compared against those used in the model of record and nosignificant differences were found (refer to Table 1 in F&O TH-1). Therefore, this gap is considered tobe a documentation issue and does not have a significant impact on the results or conclusions of thisapplication.

Page A-78 of A-168 Supporting Requirement SY-A4EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

.iCC I Partially Met at CC 11/111Capability Category 1, Requirements

.CONFIRM that the system analysis correctly reflects the as-built, as-operated plant throughdiscussions with knowledgeable plant personnel (e.g., engineering, plant operations, etc.)Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance the system documentation to include an up-to-date system walkdown checklist and systemengineer review for each system. Consider revising workplace procedure XSAA-106 to require that suchdocumentation be revisited with each major PRA revision.

Disposition of.the Gap Assessment Finding:Knowledgeable plant personnel were consulted to confirm that the PRA model systems analysiscorrectly reflects the as-built, as-operated plant but these discussions were not adequately documented in the various system notebooks as required by the standard.

However, these reviews with plantpersonnel were also performed and documented for other applications such as Maintenance Rule SSCreview (Reference 8.23), valve risk ranking programs (References 8.24 & 8.19) and the fire and floodingPRA model walkdowns (References 8.47 & 8.50).Per the PRA model configuration control program, any discrepancies identified between the model andthe as-built, as-operated plant must be entered into the PRA Tracker database along with a riskevaluation to determine the risk significance of the discrepancy.

All completed changes in the databaseare reviewed as part of any subsequent risk application, including this application submittal (refer toSection 7.3). Any model changes that can impact the results or conclusions of an application must beaddressed.

No model changes are required to address this F&O and the F&O has no impact on the results orconclusions of this application.

Page A-79 of A-168 Supporting Requirement SY-A8EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Not MetCapability Category I/!1/111 Requirements:

ESTABLISH the boundaries of the components required for system operation.

MATCH the definitions used to establish the component failure data. For example, a control circuit for a pump does not need tobe included as a separate basic event (or events) in the system model if the pump failure data used inquantifying the system model include control circuit failures.

MODEL as separate basic events of the model, those subcomponents (e.g., a valve limit switch that isassociated with a permissive signal for another component) that are shared by another component oraffect another component, in order to account for the dependent failure mechanism.

Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Enhance systems analysis documentation to discuss component boundaries.

Disposition of the Gap Assessment Finding:Consistent component boundaries have been applied throughout the model but were not adequately documented in the various system notebooks or the data notebook as required by the standard.

Historically, the component boundary definitions are defined to match the supporting generic datasource used at the time of the model revision;

however, this was not formally documented.

The PRAmodel was examined to confirm the application of consistent component boundary definitions.

Examples from the model include:The boundary for a motor-operated valve (MOV) includes the valve, the valve operator, localcircuit breaker and local instrumentation and control circuitry.

The valve transfers positionfailure mode includes spurious operation of either the valve or the actuator.

MOVs wereexamined throughout the model to confirm that only remote instrumentation and controlcircuitry is individually modeled.

Diesel generator cooling is established from the RN system andrelies on MOVs to open. Local circuitry for these MOVs was confirmed to not be included in themodel; however the diesel auxiliary relay 2TRA1, which opens the MOVs on a DG start, ismodeled as a separate failure event." The boundary for motor-driven fans includes the fan, motor, local circuit breaker, locallubrication or cooling systems, and local instrumentation and control circuitry.

Motor-driven fans were examined throughout the model to confirm that the boundary is applied consistently.

For the 1A VX air return fan, local instrumentation and control circuitry were confirmed to not beincluded in the model; however the CPCS permissives, the 1RAF-D-2 limit switch, remote controlswitch VX29 and power supplies are modeled as separate failure events.Page A-80 of A-168 The model examination confirmed that there is reasonable assurance that component boundaries wereconsistently applied throughout the model. Therefore, this gap is considered to be a documentation issue and does not have a significant impact on the results or conclusions of this application.

Page A-81 of A-168 Supporting Requirement SY-A15:EPRI Streamlined Rl.-ISI CC Requirement:.

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially Met at CC 1/11/111Capability Category I/1l/lll Requirements:

In meeting SY-All and SY-A14, contributors to system unavailability and unreliability (i.e., components and specific failure modes) may be excluded from the model if one of the following screening criteria ismet:a) A component may be excluded from the system model if the total failure probability of thecomponent failure modes resulting in the same effect on system operation is at least two orders ofmagnitude lower than the highest failure probability of the other components in the same systemtrain that results in the same effect on system operation.

b) One or more failure modes for a component may be excluded from the systems model if thecontribution of them to the total failure rate or probability is less than 1% of the total failure rate orprobability for that component, when their effects on system operation are the same.Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Provide quantitative evaluations for screening.

Disposition of the Gap Assessment Finding:The MNS PRA model used a combination of quantitative and qualitative analysis to excludecomponents.

The qualitative portion of this approach was not adequately documented in the varioussystem notebooks as required by the standard;

however, the approach was applied in a mannerconsistent with the intent of the SR.The following are examples of where components were qualitatively excluded from the model becausetheir failure contribution is negligible compared to other components in the system." The decay heat removal system notebook (Reference 8.38) modeling assumption

1. 5 states the following:

"For eachtrain there are two injection lines each with two check valves in series. The probability of two check valves failing toopen on demand is relatively small. When the two injection lines are 'and-ed,'

this train failure drops far below othertrain failures and becomes insignificant.

Therefore, individual injection paths are not modeled."

" The decay heat removal system notebook (Reference 8.38) modeling assumption

1. 9 states the following:

"Motor-operated heat exchanger bypass valves [...] are not included in this analysis because failure to remain closed, coupledwith [a normally closed valve] transferring open, is considered probabilistically insignificant.

Use of this flow path andthe hardware failures associated with it are included as a recovery."

" The instrument air system notebook (Reference 8.35) modeling assumption

1. 1 states the following:

"Passivecomponents such as air receivers and piping are not modeled because of low failure probability."

Page A-82 of A-168

• The high pressure injection system notebook (Reference 8.33) modeling assumption

1. 8 states the following:

"The NVCCP miniflow line is not explicitly modeled.

Failures are assumed to make an insignificant contribution to systemfailures due to redundancy of equipment (two valves in series) and guidance for operation in Emergency Procedures."

It is acknowledged that the actual process (two orders of magnitude) was not used but the intent of theSR was met using similar qualitative criteria (e.g., "relatively small compared to..." or "probabilistically insignificant").

The qualitative assessment can be validated by quantitatively comparing the failuremode probabilities of the screened components with other modeled components that are in the samesystem with the same effect on system operation.

For example, in the first case the failure modeprobability of a check valve to open in the McGuire PRA model is 6E-05. Assuming a generic MGL betafactor of 0.1, the common cause failure mode of two check valves in parallel failing to open would be7E-05, which is at least two orders of magnitude lower than the decay heat removal pump failing tostart.Although this SR is not satisfied by the strict definition, the intent was met and has no bearing on thetechnical adequacy of the MNS PRA model. Therefore, this gap is considered to be a documentation issue and does not have a significant impact on the results or conclusions of this application.

Page A-83 of A-168 Supporting Requirement SY-B8EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment!:

CC 1/11/111 Partially Met at CC 1/11/111Capability Category 1/11/111 Requirements:

IDENTIFY spatial and environmental hazards that may impact multiple systems or redundant components in the same system, and ACCOUNT for them in the system fault tree or the accidentsequence evaluation.

Example:

Use results of plant walkdowns as a source of information regarding spatial/environmental

hazards, for resolution of spatial/environmental issues, or evaluation of the impacts of such hazards.Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Per Duke's PRA modeling guidelines, ensure that a walkdown/system engineer interview checklist isincluded in each system notebook.

Based on the results of the system walkdown, summarize in thesystem write-up any possible spatial dependencies or environmental hazards that may impact systemoperation.

Disposition of the Gap Assessment Finding:Spatial and environmental hazards that may impact multiple systems or redundant components havebeen applied throughout the model but were not adequately documented in the various systemnotebooks as required by the standard.

However, these hazards have been identified and documented in other model calculations and applications such as the tornado PRA model and during the fire andflooding PRA model walkdowns (References 8.44, 8.47 & 8.50).Per the PRA model configuration control program, any discrepancies identified between the model andthe as-built, as-operated plant must be entered into the PRA Tracker database along with a riskevaluation to determine the risk significance of the discrepancy.

All completed changes in the databaseare reviewed as part of any subsequent risk application, including this application submittal (refer toSection 7.3). Any model changes that can impact the results or conclusions of an application must beaddressed.

No model changes are required to address this F&O and the F&O has no impact on the results orconclusions of this application.

Page A-84 of A-168 Supporting Requirement SY-B14EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially Met at CC 1/11/111Capability Category 1/11/111 Requirements:

IDENTIFY SSCs that may be required to operate in conditions beyond their environmental qualifications.

INCLUDE dependent failures of multiple SSCs that result from operation in these adverse conditions.

Examples of degraded environments includea) LOCA inside containment with failure of containment heat removalb) safety relief valve operability (small LOCA, drywell spray, severe accident)

(for BWRs)c) steam line breaks outside containment d) debris that could plug screens/filters (both internal and external to the plant)e) heating of the water supply (e.g., BWR suppression pool, PWR containment sump) that could affectpump operability f) loss of NPSH for pumpsg) steam binding of pumpsGap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Cut set review during applications should address this. Suggest adding this guidance to workplace procedure XSAA-103.

Disposition of the Gap Assessment Finding:Environmental qualifications for SSCs are already considered in the model but were not adequately documented in the various accident sequence notebooks or the system notebooks as required by thestandard.

However, these hazards have been identified and documented in other model calculations and applications such as the tornado PRA model and during the fire and flooding PRA model walkdowns (References 8.44, 8.47 & 8.50).Per the PRA model configuration control program, any discrepancies identified between the model andthe as-built, as-operated plant must be entered into the PRA Tracker database along with a riskevaluation to determine the risk significance of the discrepancy.

All completed changes in the databaseare reviewed as part of any subsequent risk application, including this application submittal (refer toSection 7.3). Any model changes that can impact the results or conclusions of an application must beaddressed.

Additionally, the PRA model was examined for SSCs modeled with failures due to environmental effects.Examples from the model include:Page A-85 of A-168

" LNPSH -Loss of NPSH Margin Due to Sump Blockage" LNPSHMED

-Loss of NPSH Margin Due to Sump Blockage for Medium LOCAs" LNPSHLAR

-Loss of NPSH Due to Sump Blockage for Large LOCAs" LNPSHSML

-Loss of NPSH Due to Sump Blockage for Small LOCAs" LNPSHTIL

-Loss of NPSH Margin Due to Sump Blockage for Transient Induced LOCAs" LN4NPSHDEX

-Debris Induced Loss of NPSH Margin Due to PRT Rupture or Transient LOCA Events* W1005A -Flow Path Through RN Strainer 1A Blocked" W1020B -Strainer B Automatic Backwash Flow Path BlockedThe model examination confirmed that there is reasonable assurance that environmental effects areconsidered throughout the model. Therefore, this gap is considered to be a documentation issue anddoes not have a significant impact on the results or conclusions of this application.

Page A-86 of A-168 S. upporting Requirement SY-C2EPRl:Streamlined RI-SI CC Requirement:,,

.... .McGuire PRA Model CC Assessmentii

CC 1/11/111 Partially Met at CC 1/11/111Capability Category 1/11/111 Requirementsi:f

......DOCUMENT the sources of model uncertainty and related assumptions (as identified in QU-E1 and QU-E2) associated with the systems analysis.

Gap Assessmen Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance system model documentation to comply with all ASME PRA Standard requirements.

.Disposition of the Gap Assessment Finding:

... ...... .... .... ...... :Jn g.:: ...::: .Sources of model uncertainty and related assumptions have been identified;

however, they are notadequately documented in the various system notebooks as required by the standard.

The modelresults and insights notebook (Reference 8.25) derives the CDF and LERF probability distributions usingthe component uncertainty parameters as defined in the data and system notebooks.

Assumptions related to model uncertainty were documented in the model results and insights notebook and themodel integration notebook (Reference 8.56). The following are examples of system assumptions related to model uncertainty.

" From the model results and insights notebook assumption

1. 8.2: "Error factors are assigned using engineering

judgment, according to the guidance provided in section 9.6. The error factors selected for basic events identified insection 9.6 do not have a large impact on the calculated mean COF and associated error factor or mean LERF andassociated error factor."" From the model integration notebook assumption

1. 3: "Successful cooldown to RHR conditions prior to FWSTdepletion is assumed to require that the condenser and associated dump valves be available.

The SG PORV capacityis assumed to be too small because the RCS is in subcooled conditions.

This is less efficient heat transfer thansaturated conditions.

Those LOCA sequences involving loss of offsite power or instrument air cannot be brought toRHR conditions, this assumption is the basis for the inclusion of gate SX0103 as an input to SX01. Support systemsare expected to be the dominant contributors to the unavailability of the components needed for secondary sidedepressurization.

Failures on the individual SGs have been neglected.

This is a limitation of the model which shouldbe considered for its influence on any specific application."

Although this SR is not satisfied by the strict definition, there is reasonable assurance that intent of thestandard was met. Therefore, this gap is considered to be a documentation issue and does not have asignificant impact on the results or conclusions of this application.

Page A-87 of A-168 Supporting Requirement HR-A2EPRI.Str

.eamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially metCapability Category 1/11/1il Requirements:

IDENTIFY, through a review of procedures and practices, those calibration activities that if performed incorrectly can have an adverse impact on the automatic initiation of standby safety equipment.

Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance the HRA to consider the potentialfor calibration errors.Disposition of the Gap Assessment Finding:Duke utilizes a train-level latent human error (LHE) event for each system train. This train-level LHEincludes the effects of mispositions and miscalibrations.

These events use a screening value of 8E-03based on the basic human error probability in the ASEP method. For those risk-significant pre-initiator events, Duke calculates specific values.However, the McGuire PRA model is currently undergoing a major model update. During this update,several miscalibration events were identified in the ESFAS and RPS systems.

These new miscalibration events were added to the PRA model as part of a sensitivity study (refer to Section 7.2). This studyfound that only the miscalibration of the RWST level indication appears above the truncation limit. Thismiscalibration event appears in small LOCA accident sequences;

however, the event does not appearabove the truncation limit with the small break LOCA initiating event itself. The overall CDF contribution from this event is 1.2E-09, which is an insignificant risk impact. Therefore, this F&O is a documentation issue and has no impact on the results or conclusions of the RI-ISI application.

Page A-88 of A-168 Supporting Requirement HR-A3EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Not metCapability Category 1/1l/lll Requirements:

>. "IDENTIFY the work practices identified above (HR-Al, HR-A2) that involve a mechanism thatsimultaneously affects equipment in either different trains of a redundant system or diverse systems[e.g., use of common calibration equipment by the same crew on the same shift, a maintenance or testactivity that requires realignment of an entire system (e.g., SLCS)].Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Identify maintenance and calibration activities that could simultaneously affect equipment in eitherdifferent trains oa a redundant system or diverse systems.Disposition of the Gap Assessment Finding:Duke utilizes a train-level latent human error (LHE) event for each system train. This train-level LHEincludes the effects of mispositions and miscalibrations.

These events use a screening value of 8E-03based on the basic human error probability in the ASEP method. For those risk-significant pre-initiator events, Duke calculates specific values.However, the McGuire PRA model is currently undergoing a major model update. During this update,several miscalibration events were identified in the ESFAS and RPS systems.

These miscalibration eventswere developed to capture common calibration failures of equipment on redundant or diverse systems.These new miscalibration events were added to the PRA model as part of a sensitivity study (refer toSection 7.2). This study found that only the miscalibration of the RWST level indication appears abovethe truncation limit. This miscalibration event appears in small LOCA accident sequences;

however, theevent does not appear above the truncation limit with the small break LOCA initiating event itself. Theoverall CDF contribution from this event is 1.2E-09, which is an insignificant risk impact. Therefore, thisF&O is a documentation issue and has no impact on the results or conclusions of the RI-ISI application.

Page A-89 of A-168 Supporting Requirement HR-D6EPRI Streamlined Ri-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Not metCapability Category 1/11/111 Requirements:

PROVIDE an assessment of the uncertainty in the HEPs in a manner consistent with the quantification approach.

USE mean values when providing point estimates of HEPs.Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Develop mean values for pre-initiator HEPs.Disposition of the Gap Assessment Finding:This item has been addressed.

Mean values for pre-initiator HEPs have been developed (Reference 8.17) and are in use in the model of record. Converting a median probability to a mean probability involves a simple mathematical equation and is not considered a methodology change. The HRAprobabilities were applied to the model using existing methodologies and techniques.

Page A-90 of A-168 Supporting Requirement HR-G3EPRI Streamlined RI-iSI CC Requirement:

McGuire PRA ModelCC Assessment:

CC I Partially met at CC Il/111.~ ~ ~ ~ ~ ~.......

... .. .:: : """ ...... ..?: ..i~iCapability Cat"gory I Requirements:

USE an approach that takes the following into account:(a) the complexity of the response(b) the time available and time required to complete the response(c) some measure of scenario-induced stressThe ASEP Approach

[2-6) is an acceptable approach.

Gap Assessment Finding:

.* ~ ~ ~ ~ ~~~~~~~~

.... .:.::, :. ... ..... * ....The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Document in more detail the influence of performance shaping factors on execution human errorprobabilities.

Disposition of the Gap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2.The McGuire PRA model calculates both the HCR and CBDTM probabilities for each operator action anduses the maximum value for each HRA event. The HRA notebook (Reference 8.28), meets the CC Irequirements.

The post-initiator events considered environment, complexity and training.

From theHRA notebook:

Three probabilities are presented in the table for each type of error, corresponding to three different levels of stress:optimal, moderately high, and extremely high. Optimal stress would apply for actions that are part of a normalresponse to a reactor trip, and for which the operators would be alert. Moderately high stress would apply when theoperators are responding to unusual events, including multiple failures (e.g., station blackout or a total loss offeedwater).

The values for extremely high stress apply for scenarios in which there is a significant threat, such as thepotential that core damage is imminent if the actions are not successful, or when actions must be accomplished inless than optimal conditions (e.g., operating the turbine-driven AFW pump manually during a station blackout event).[...] This screening assessment entailed applying the following bounding composite probabilities of failure during theexecution phase:.0.003, for a straightforward action involving a single component (e.g., repositioning a valve);.0.01, for straightforward actions involving multiple components (e.g., opening a suction valve and adischarge valve and starting a pump); and0 0.05, for a more complex series of ex-control room actions.The dispositions for F&Os TH-5 and HR-3 provide additional discussion on the PSFs, stress levels andbasis for the HRA timings.Page A-91 of A-168 Supporting Requirement HR-G4EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC I Partially met at CC 11Capability Category II Requirements:

BASE the time available to complete actions on appropriate realistic generic thermal/hydraulic

analyses, or simulation from similar plants (e.g., plant of similar design and operation).

SPECIFY thepoint in time at which operators are expected to receive relevant indications.

Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance HRA documentation accordingly.

Disposition of the Gap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2. However, the following discussion considers CC II for this SR.Timing analyses were performed using a systematic approach but were not adequately documented inthe human reliability notebook as required by the standard.

Action timings were based upon simulator information and RETRAN and MAAP analyses.

The HRA notebook (Reference 8.28) was examined toconfirm the presence of timing analyses.

Whereas the MAAP code runs are referred to in the HRA basicevent worksheets, the basis for the timing is typically found in miscellaneous notes and calculations.

Therefore, whereas the documentation can be improved to specifically discuss the timing analysis runs;there is a high level of confidence that this timing analysis was performed.

This is a documentation issue with regards to the system notebooks and does not have a significant impact on the MNS PRAmodel or the RI-ISI application.

Page A-92 of A-168 Supporting Requirement HR-G6EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/1/11 NoCapability Category I Requirements:

CHECK the consistency of the post-initiator HEP quantifications.

REVIEW the HFEs and their final HEPsrelative to each other to check their reasonableness given the scenario

context, plant history,procedures, operational practices, and experience.

Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Document a review of the HFEs and their final HEPs relative to each other to confirm theirreasonableness given the scenario

context, plant history, procedures, operational practices, andexperience.

Disposition of the Gap Assessment Finding:A review of the HRA documentation (Reference 8.28) indicates that a reasonableness check wasperformed;

however, the actual process used was not adequately documented in the HRA notebook asrequired by the standard.

Section 4 of the HRA notebook includes the following discussion:

Effective review is a critical element of each step of a PRA, and this was no exception for the assessment of humaninteractions.

Review of the human reliability analysis involved both other PRA analysts and operations personnel fromMcGuire.The initial definition of each event entailed interaction between the system analyst and the human reliability analysis.

This interaction typically involved refinement of the definition and implications of the event. Additional integrated review took place during the initial sequence quantification, during which further understanding of the context ofspecific core-damage cut sets was gained, and the events that required more detailed quantification were identified.

The quantification of the human interactions required input from operations personnel, who often provided input ontiming and qualitative insights that led to changes in the definition or application of specific events. The assessment for each event was reviewed in detail by at least one other PRA analyst.

Review of the overall reasonableness of theevents and their treatment was also gained during the final review of the sequence cut sets. This review processincluded both other members of the PRA project team and McGuire operations personnel.

The HRA notebook provides a reasonable assurance and confidence that the intent of the standard wasmet. This is a documentation issue and has no impact on the MNS PRA model or the RI-ISI application.

Page A-93 of A-168 Supporting Requirement HR-G8EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Not metCapability Category I Requirements:

Characterize the uncertainty in the estimates of the HEPs in a manner consistent with the quantification

approach, and PROVIDE mean values for use in the quantification of the PRA results.Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Develop mean values for post-initiator HEPs.Disposition of the Gap Assessment Finding:This item has been addressed.

Mean values for post-initiator HEPs have been developed (Reference 8.17) and are included in the model of record used for the RI-ISI application.

Converting a medianprobability to a mean probability involves a simple mathematical equation and is not considered amethodology change. The HRA probabilities were applied to the model using existing methodologies and techniques.

Page A-94 of A-168 Supporting Requirement HR-H2EPRI Streamlined R1-ISI CC Requirement:

/McGuire PRA Model CC Assessment:

CC 1/11/111 Partially met at CC 1/11/111CapabilityCategoryIRequiremnents:

CREDIT operator recovery actions only if, on a plant-specific basis, the following occur:a) a procedure is available and operator training has included the action as part of crew's training, orjustification for the omission for one or both is providedb) "cues" (e.g., alarms) that alert the operator to the recovery action provided procedure,

training, orskill of the craft existc) attention is given to the relevant performance shaping factors provided in HR-G3d) there is sufficient manpower to perform the actionGap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Develop more detailed documentation of operator cues, relevant performance shaping factors, andavailability of sufficient manpower to perform the action.Disposition of the Gap Assessment Finding:A review of the HRA documentation (Reference 8.28) indicates that, whereas a limited number ofrecovery actions were included in the PRA model, the process for how the recovery action is calculated was not adequately documented in the HRA notebook as required by the standard.

However, thereview also determined that the HRA notebook provides a reasonable assurance and confidence thatthe intent of the standard was met. This is a documentation issue and has an insignificant impact on theMNS PRA model or the RI-ISI application.

Page A-95 of A-168 EVENT INFORMATION page I of IName Dafiniton SMAN001RHE Operators fall to iniliate switchover to sump recirculation during a small LOCA in the event o1 IS failure of FWST level transmitters to actuate aulomatic swichover..

DESCRIPTION Following a LOCA, the ECCS wilt draw suction from the FWST until level in the lank drops to the selpoint forautomatic switchover to recirculation from the containment sump. The switchover is initiated upon indication of lowlevel by two of three wide-range level transmitters.

However.

if the transmitters were to fail to respond to thechange in tank level, the automatic switchover would not occur, and the operators would not necessarily be awareimmediately of their failures.

It is reasonable to expect that the operators would track FWST level as it was drawn down. This was confirmed during exercises on the McGuire simulator conducted in March of 1996.For the small LOCA condition.

drawdown of the FWST would take more than one hour so the time assumed in thn.simplified calcuation is inter ru edla:e. The operators clearly have received training on the significance of theswitchover, parameters to monitor during a LOCA, and the steps to take to perform the switchover manually.

Because of the potential need to inter the swilchover time from other than the normal Instruments and the specificactions required to accomplish the switchover, this action is taken to be comp!ox in nature. The actions could beaccomplished from the control room, so the environment would be good.A similar event. SMANO02RHE.

addresses the same conditions for a medium and large LOCA.INFLUENCE FACTORS77me available II, ]Training/practice?

yes EDComplexity simple --Environment good ElOverall time Information sourceslcomments Ii'rmcdiale lno F ]Icomplex F--J Inference ot swapover poinl coultd he complex.poor f IControl room action; good environmenlt, QUANTIFICATION Meihodraiue Selection HCR -'- E-SImplified E7naOther Fii 1IResult mean I~2 EF j jJustification for Selection Page A-96 of A-168 Supporting Requirement DA-A2EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Mod el CC Assessme nt:CC 1/11/111 Not metCapability Category 1/11/11 Requirements:

ESTABLISH definitions of SSC boundaries, failure modes, and success criteria in a manner consistent withcorresponding basic event definitions in Systems Analysis (SY-A5, SY-A7, SY-A8, SY-A9 through SY-A14and SY-B4) for failure rates and common cause failure parameters, and ESTABLISH boundaries ofunavailability events in a manner consistent with corresponding definitions in Systems Analysis (SY-A19).

Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Revise the data caic. to discuss component boundaries definitions.

Disposition of the Gap Assessment Finding:A review of the PRA model indicates that system boundaries were considered and included.

The actualprocess used was not adequately documented in the various applicable system notebooks as requiredby the standard.

A review of the model of record indicates that component boundaries were considered and included inthe modeling.

Examples from the model are:* IR27 -Interlocks on ND System Prevent Opening Valve NI136B" INI0184LLD

-Limit Switch 1N1184 Fails to Indicate Valve Has Opened" INI136BMVO

-Motor Operated Valve N1136B Fails to Open-and-1006R -Motor Operated Valve N1144B or NI115B Fails to Isolate" 1008R -Motor Operated Valve Nl115B Fails to Isolate" INII15BLLD

-Limit Switch 1NI115B Fails to Operate on Demand" INI115BMVC

-Motor Operated Valve 1NI115B Fails to Close" P1EMXB1 -Loss of Power on Unit 1 600 V ac MCC 1EMXB-1This attribute has been satisfied and the results of the model provide reasonable assurance andconfidence that the intent of the standard was used. This is a documentation issue and has no impacton the MNS PRA model or the RI-ISI application.

Page A-97 of A-168 Supporting Requirement DA-B1EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

cc I Partially met at CC 11Capability Category II Requirements:

For parameter estimation, GROUP components according to type (e.g., motor-operated pump, air-operated valve) and according to the characteristics of their usage to the extent supported by data:a) Mission type (e.g., standby, operating) b) Service condition (e.g., clean vs. untreated water, air)Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Revise the data calc. to segregate standby and operating component data. Segregate components byservice condition to the extent supported by the data.Disposition of the Gap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2. However, the following discussion considers CC II for this SR.A review of the PRA model indicates that components were grouped according to type and according tothe characteristics of their usage. However, the actual process used was not adequately documented inthe various applicable system notebooks as required by the standard.

Basic events are grouped by type codes, which are segregated in the PRA model failure rate databasenotebook (Reference 8.27) consistent with the definitions in SAROS Generic Equipment Failure RateDatabase.

Examples from the model are:* AVC: Air Operated Valve Fails to Close on Demand* MVC: Motor Operated Valve Fails to Close on Demand* CVC: Check Valve Fails to Close on Demand" DCR: Diesel Air Compressor Fails to Run* CMR: Air Compressor Fails to Run* HPR: High Pressure Injection Pump Fails to Run* LPR: Low Pressure Injection Pump Fails to Run" MPR: Motor-Driven EFW Pump Fails to Run" PPR: High Pressure Service Water Pump Fails to Run* WPR: Low Pressure Service Water Pump Fails to RunThis attribute has been satisfied and the results of the model provide reasonable assurance andconfidence that the intent of the standard was used. This is a documentation issue and has no impacton the MNS PRA model or the RI-ISI application.

Page A-98 of A-168 Supporting Requirement DA-D4EPRI Streamlined RI-SI CC Requirement:

McGuire PRA Model CC Assessment:

• ...CC I Partially met at CC 11/111Capability Category I Requirements:

No requirement for use of Bayesian approach.

Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Enhance the documentation to include a discussion of the specific checks performed on the Bayesian-updated data, as required by this SR.Disposition of the Gap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2. There is no requirement for use of the Bayesian approach at CC I; therefore this SR is judgedto be fully met at CC I and is sufficient to meet the technical adequacy requirements for the RI-ISIapplication.

Page A-99 of A-168 Supporting Requirement DA-D6EPRI Streamlined RI-SI CC Requirement:

McGuire PRA Model CC Assessment:

CC I Partially met at CC 11Capability Category I Requirements:

USE generic common cause failure beta factors or equivalent.

ENSURE that the beta factors areevaluated in a manner consistent with the component boundaries.

Gap Assessment Finding:The gap assessment concluded that this SR was partially met in the original analysis.

This gap can beaddressed as follows:Provide documentation in SAAG 637 of the comparison of the component boundaries assumed for thegeneric CCF estimates to those assumed in the McGuire PRA to ensure that these boundaries areconsistent.

Disposition of the Gap Assessment Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2.The common cause notebook (Reference 8.26) documents the selection and quantification of commoncause basic events for the McGuire PRA model of record. Section 4.1 discusses the use of generic CCFand Section 4.2 discusses how plant-specific experience was incorporated.

Review of the McGuire PRA model of record shows that the CCF boundaries are consistent and thatgeneric CCF estimates were used.The component failures were then reviewed (refer to SR DA-B1 Disposition) and it was determined thatthey are grouped by type codes, which are segregated as evidenced in the failure rate databasenotebook (Reference 8.27).An example is provided in Section 4.2.1 of the common cause notebook, which compares the CCF forthe emergency diesel failing to run with previous generic values. This example displays reasonable confidence that this methodology was used.Therefore, this SR is judged to be fully met at CC I and is sufficient to meet the technical adequacyrequirements for the RI-ISI application.

Page A-100 of A-168 Supporting Requirement QU-D4EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC I Not MetCapability Category I Requirements:

No requirement to compare results to those from similar plants.Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Perform and document a comparison of results between the MNS PRA and other similar plants.Disposition of the Gap Assessment Finding:The Gap Assessment determined that this SR is not met when compared with the CC II requirements.

For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2.There is no requirement to compare results to similar plants at CC I; therefore this SR is judged to befully met at CC I and is sufficient to meet the technical adequacy requirements for the RI-ISI application.

Page A-101 of A-168 Supporting Requirement QU-E4EPRI Streamlined RI-ISI CC Requirement: :McGuire PRA Model CC Assessment*:

'Need not be met Not MetCapability Category 1/ I/ll/i Requirements:

For each source of model uncertainty and related assumption identified in QU-E1 and QU-E2,respectively, IDENTIFY how the PRA model is affected (e.g., introduction of a new basic event, changesto basic event probabilities, change in success criterion, introduction of a new initiating event) [Note(1)].Gap Assessment Finding:The gap assessment concluded that this SR was not met in the original analysis.

This gap can beaddressed as follows:Perform and document a set of sensitivity cases to determine the impact of the assumptions and sourcesof model uncertainty on the results.Disposition of the Gap Assessment The Gap Assessment determined that this SR is not met when compared with the Capability Category1/11/111 requirements.

For RI-ISI applications this SR does not need to be met in accordance with EPRI TR-1021467, Table 2-2, therefore this gap has no impact on the RI-ISI application.

Page A-102 of A-168 Supporting Requirement QU-F2EPRI Streamlined RI-SI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially met at CC 1/11/111Capability Category 1/11/111 Requirements:

DOCUMENT the model integration process including any recovery

analysis, and the results of thequantification including uncertainty and sensitivity analyses.

For example, documentation typically includes(a) records of the process/results when adding non-recovery terms as part of the final quantification (b) records of the cutset review process(c) a general description of the quantification process including accounting for systems successes, thetruncation values used, how recovery and post-initiator HFEs are applied(d) the process and results for establishing the truncation screening values for final quantification demonstrating that convergence towards a stable result was achieved(e) the total plant CDF and contributions from the different initiating events and accident classes(f) the accident sequences and their contributing cutsets(g) equipment or human actions that are the key factors in causing the accidents to be nondominant (h) the results of all sensitivity studies(i) the uncertainty distribution for the total CDF(j) importance measure results(k) a list of mutually exclusive events eliminated from the resulting cutsets and their bases forelimination (I) asymmetries in quantitative modeling to provide application users the necessary understanding ofthe reasons such asymmetries are present in the model(m) the process used to illustrate the computer code(s) used to perform the quantification will yieldcorrect results processGap Assessment Finding:The gap assessment concluded that this SR was partially met at CC 1/11/111 in the original analysis.

Thisgap can be addressed as follows:Expand the documentation of PRA model results to address all required items.Disposition of the Gap Assessment Finding:A systematic model integration process has been used in the model integration; however this processwas not adequately documented in the integration notebook to the extent required by the standard.

There are two documents which comprise the model integration, results and insights:

the integration notebook (Reference 8.45) and the results and insights notebook (Reference 8.25). These twodocuments were examined to determine which of the typical documentation items are not adequately Page A-103 of A-168 discussed.

a) This practice is typically avoided.

Recovery items are documented within the recovery rule file.b) This is an area where more documentation is needed. However, a systematic review of the cutsets was performed tovalidate human action dependencies and to look for invalid or incomplete cutsets.c) The integration notebook adequately covers this item.d) The results and insights notebook adequately covers this item.e) The results and insights notebook covers the total CDF and CDF contributions for initiating events, but is not asdescriptive of accident classes.f) The results and insights notebook adequately covers this item.g) The results and insights notebook adequately covers this item.h) The results and insights notebook adequately covers this item.i) The results and insights notebook adequately covers this item.j) The results and insights notebook adequately covers this item.k) This is an area where more documentation is needed. However, the mutually exclusive events and their bases aredocumented within the recovery rule files.I) This is an area where more documentation is needed. However, system and model asymmetries are documented inthe individual model notebooks.

m) This is an area where more documentation is needed. However, the software codes used to perform the modelintegration are documented and validated as part of the Duke Energy Software and Data Quality Assurance (SDQA)program.This attribute has been satisfied and an inspection of the model and related documentation providesreasonable assurance and confidence that the intent of the standard was used. This is a documentation issue and has no impact on the MNS PRA model or the RI-ISI application.

Page A-104 of A-168 SUpporting Requirement QU-F6 .... ..EPRI Streamlined RI-ISI CC Requirement:

McGuire PRA Model CC Assessment:

CC 1/11/111 Partially met at CC 1/11/111Capability Category 1/11/111 Requirements:

DOCUMENT the quantitative definition used for significant basic event, significant cut set, andsignificant accident sequence.

If it is other than the definition used in Part 2, JUSTIFY the alternative.

Gap Assessment Finding:The gap assessment concluded that this SR was partially met at CC 1/11/111 in the original analysis.

Thisgap can be addressed as follows:Document the required definitions.

Disposition of the Gap Assessment Finding:The quantitative definitions for significant basic event, significant cut set and significant accidentsequence have not been documented in the integration notebook to the extent required by thestandard.

However, the intent of this SR is met through the model usage in downstream processes suchas Maintenance Rule a(1) through a(3) (Reference 8.23) and component risk ranking programs(References 8.24 & 8.19).The standard defines a significant basic event as an "event that contributes significantly to thecomputed risks for a specific hazard group. For internal events, this includes any basic event that has anFV importance greater than 0.005 or a RAW importance greater than 2." The PRA model andapplications were examined and it was determined that this definition is consistently used in PRAapplications to determine which components and events are significant contributors to risk.The standard defines a significant cutset as "one of a set of cutsets resulting from the analysis of aspecific hazard group that, when rank-ordered by decreasing frequency, sum to a specified percentage of the core damage frequency (or large early release frequency) for that hazard group, or thatindividually contribute more than a specified percentage of core damage frequency (or large earlyrelease frequency).

For this version of the Standard, the summed percentage is 95% and the individual percentage is 1% of the applicable hazard group." During the integrated model review, all cutsets abovethe model truncation limit are reviewed for HRA dependencies.

Additionally, similar to the discussion for significant basic events, the definition for a significant cutset is applied consistent with the standarddefinition for PRA applications.

The standard defines a significant accident sequence as "one of the set of accident sequences resulting from the analysis of a specific hazard group, defined at the functional or systematic level, that, whenrank-ordered by decreasing frequency, sum to a specified percentage of the core damage frequency forthat hazard group, or that individually contribute more than a specified percentage of core damagefrequency.

For this version of the Standard, the summed percentage is 95% and the individual Page A-105 of A-168 percentage is 95% of the applicable hazard group." The significant accident sequences for the modelused in this application are listed in the following table.% Contribution Cumulative Accident Sequence to CDF Contribution to CDFRN Major Flood in the CA Pump Room 26.6% 26.6%Stuck Open Safety Valve 15.7% 42.3%RN Flood in the CA Pump Room 8.4% 50.7%LOOP 8.3% 59.0%Interfacing Systems LOCA 5.4% 64.4%Reactor Vessel Rupture 5.4% 69.8%RCP Seal LOCA 4.5% 74.3%SGTR 3.6% 77.9%Loss of Nuclear Service Water 3.0% 80.9%ATWS 2.8% 83.7%Loss of Load 2.1% 85.8%Steamline Break Outside Containment 2.1% 87.9%Loss Of Main Feedwater 2.0% 89.9%Small Break LOCA 1.7% 91.6%Reactor Trip 1.4% 93.0%RN Flood in the KC Pump Area 1.1% 94.1%Loss Of 4160 V Essential Bus 0.9% 95.0%This attribute has been satisfied and an inspection of the model and related documentation providesreasonable assurance and confidence that the intent of the standard was used. This is a documentation issue and has no impact on the MNS PRA model or the RI-ISI application.

Page A-106 of A-168 4.3 Focused LERF Peer Review to ASME/ANS RA-Sa-2009 PRA StandardThe PWR Owners Group conducted a focused peer review on the McGuire Nuclear Station Large EarlyRelease Frequency (LERF) PRA model on December 11-14, 2012. This review was limited to the HighLevel and Supporting Requirements in Part 2, Requirements For Internal Events At-Power PRA, Tables 2-2.8-1 and 2-2.8-2 through 2-2.8-8, of the ASME/ANS RA-Sa-2009 PRA Standard.

The overall conclusions of the peer review team regarding the McGuire LERF PRA are as follows:" The overall model structure is robust and well-developed for both plants." Documentation is generally very thorough and detailed.

" Catawba and McGuire used a simplified NUREG/CR-6595 LERF model which the NRC has foundacceptable for calculating the Large Early Release Frequency.

The ASME/ANS PRA Standard contains a total of 41 numbered supporting requirements for the LERFportion of the internal events standard requirements.

This focused scope peer review covered these 41supporting requirements associated with the LERF Analyses.

Only two of the LERF SRs were determined to be not applicable to the McGuire LERF PRA. Of the 39 applicable SRs 26 SRs were rated as SR Met,Capability Category 1/11, or greater.

Only three SRs were not met. However, ten of the SRs wereassessed at Capability Category

1. McGuire uses a LERF model based on the simplified LERF model inNUREG/CR-6595 (Reference 8.3). While a NUREG/CR-6595 model is classified as Capability Category I,historically the NRC has indicated that a NUREG/CR-6595 model is of sufficient capability to support risk-informed applications.

The peer review found nine new Facts and Observations (F&Os), including five suggestions and fourfindings.

The four findings have been dispositioned in the following section for the RI-ISI application.

EPRI report TR 1021467-A, "Nondestructive Evaluation:

Probabilistic Risk Assessment Technical Adequacy Guidance for Risk-Informed In-Service Inspection Programs" (Reference 8.6), providesguidance on determining the technical adequacy of PRAs used to develop a RI-ISI program.

This reporthas been reviewed by the NRC staff and found to be acceptable for referencing in licensing applications for RI-ISI programs with comments provided in an attached SE. Revision 1021467-A incorporates the SEcomments and was used to determine the minimum capability category (CC) recommended for eachsurveillance requirement (SR) in the ASME/ANS PRA Standard within the scope of the RI-ISI program.Table 6 maps the SR listed in the EPRI report to the SR identifier in version ASME/ANS RA-Sa-2009 of theASME/ANS PRA Standard.

Table 6 then lists the recommended minimum CC for the EPRI Streamlined RI-ISI application from the EPRI report and summarizes the results of those SRs that do not fully meet CC II.Page A-107 of A-168 Table 6: Comparison of McGuire LERF Gap Assessment to the EPRI Streamlined RI-ISI Requirements 2005 PRA 2009 PRA EPRI Streamlined Standard SR Standard SR RI-ISI Requirements LE-E2 LE-E2 CC I NoLE-G3 LE-G3 CC I CC ILE-G5 LE-G5 CC 1/11/111 NoLE-G6 LE-G6 CC 1/11/111 NoLE-Fla LE-Fl CC I CC IPage A-108 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs:LE-E2-01EPRI Streamlined RI-ISI CC Requirement:

Peer Review CC Assessment:

CC I Not metCapability Category I Requirements:

USE conservative parameter estimates to characterize accident progression phenomena.

Aconservative data set for some key parameters is included in NUREG/CR-6595

[2-16].F&O Issue and Proposed Resolution:

McGuire basically used the conservative parameter estimates from NUREG/CR-6595 to characterize theaccident progression phenomena.

This approach would satisfy CC I. However, Duke is using theConditional Containment Failure Probabilities (CCFPs) from Revision 0 of NUREG/CR-6595 rather thanthe more restrictive values from Revision

1. To meet this requirement would require using theNUREG/CR-6595, Rev. 1 CCFP values or providing an engineering analysis to defend use of the oldervalues.At the time of the peer review, Duke did have a white paper, "Conditional Containment FailureProbabilities for the McGuire and McGuire Large Early Release Frequency Models",

November 2012,(Reference

10) that discusses the basis for the use of the CCFPs from Rev. 0 of NUREG/CR-6595.

However, this white paper was not provided as part of the official documentation for the review and assuch, was not directly reviewed.

A later review of this white paper indicates that Duke appears to have areasonable basis for using the revision 0 CCFP values based on plant-specific analysis.

Duke shouldinclude this information in their LERF analysis reports.Disposition of the Peer Review Finding:The peer review finding recommends that Duke include a discussion of the basis behind using CCFPsfrom Revision 0 of NUREG/CR-6595 in the LERF analysis reports.

This basis is instead documented in theposition paper, "Conditional Containment Failure Probabilities for the McGuire and McGuire Large EarlyRelease Frequency Models" (Reference 8.80).The position paper reviewed the supporting analyses for the conditional containment failureprobabilities provided in the various revisions to NUREG/CR-6595 and evaluated whether the twoparameters

(% clad reacted in vessel and peak pressure) related to containment failure when thedeliberate ignition system (hydrogen igniters) is unavailable due to a station blackout.

As part of thisposition paper, Duke performed a set of plant-specific MAAP analyses where the igniters are turned offfor the time period prior to reactor vessel failure.

This allows hydrogen generated during core damageto accumulate in the containment.

At the time of RV failure the igniters are turned on thus assuring thatPage A-109 of A-168 an ignition source is available.

The CCFP provided is the contribution from the hydrogen combustion overpressure event following RV failure.

The value does not include any contributions to containment failure from non-overpressure containment failure modes (e.g., debris contact with the containment steel).% Clad PeakSequence (McGuire)

Reacted In Pressure CCFPVessel (psia)SBO event with cycling safety relief valves with a start failure of 50.8 60.49 0.00the turbine driven auxiliary feedwater pump, RCS at DCH relevantpressureSBO event with cycling safety relief valves with a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 37.84 51.65 0.00available run time for the turbine driven auxiliary feedwater pump, RCS at DCH relevant pressureSBO event with cycling safety relief valves with a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 40.2 76.64 0.06available run time for the turbine driven auxiliary feedwater pump, RCS at non DCH relevant pressure due to hot leg creepruptureSBO event with a 250 gpm/pump reactor coolant pump seal LOCA 36.4 75.38 0.06at time equals 0. Secondary side heat removal (SSHR) via theturbine driven auxiliary feedwater pump is available during theentire event, RCS at DCH relevant pressureThe result of the MAAP runs show how wide the range of results can be for various accident sequences and how many sequences result in no challenge to containment integrity.

The frequency weighting theresults is more important than selecting a single scenario for a point estimate.

As noted in NUREG/CR-6427, hydrogen combustion phenomena are also a source of uncertainty in theresults.

The peak pressures predicted by the plant specific MAAP analyses are lower than thosepredicted by the NUREG/CR-6427 analysis using CONTAIN.

This is likely due to differences in the detailsof the hydrogen combustion event such as flame speeds, heat transfer to structures, and impact of thesteam present in the containment.

Section 4.2.5 of NUREG/CR-6427 discusses the non-direct containment heating (DCH) relevantchallenges.

The implication is that ignition is the result of power restoration following vessel breach.Such an approach does not consider that power restoration need not lead to uncontrolled combustion.

Power restoration to the igniters in a strategic manner can provide a means for a controlled reduction ofthe hydrogen concentration to non-threatening levels. Neglecting this capability artificially raises theprobability of uncontrolled combustion and consequently the probability of containment failure for thenon-DCH case. This is one reason the CCFP for the non-DCH case is also very near 1.0. Furthermore, late restoration of power may not contribute to an "early" release as is required for a LERF evaluation even if the containment is challenged.

The position paper concludes that the MAAP runs determining CCFP results demonstrate how plantspecific examination of relevant accident sequences can produce results that are different than aPage A-110 of A-168 generic more conservative analysis.

The major sources of uncertainty identified by NUREG/CR-6427 indeed do matter. The high CCFPs provided in NUREG/CR-6595 revision 1, while possible for certainaccident sequences, are not representative of the overall class of station blackout core damagesequences.

Based on the plant specific analyses performed, the CCFPs utilized in the current MNS LERFanalyses (based on NUREG/CR-6595 original issue) are judged to be better estimates than the estimates available from NUREG/CR-6427 or NUREG/CR-6595 revision 1 and are appropriate for a LERF model atcc 1.The peer review noted that the position paper appeared to be a reasonable basis for using theNUREG/CR-6595 revision 0 results.

Duke also believes that the NUREG/CR-6595 revision 0 results arebetter estimates than the revision 1 results.

Therefore, there is no impact from this finding to theresults and conclusions for the MNS LAR submittal.

Page A-111 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs:LE-G3-01 LE-F1EPRI Streamlined RI-ISI CC Requirement:

Peer Review CC Assessment:

CC I CC ICapability Category I Requirements:

LE-Fi:IDENTIFY the significant contributors to large early releases (e.g., plant damage states, containment failure modes).LE-G3:DOCUMENT the significant contributors to LERF.F&O Issue and Proposed Resolution:

In MCC-1535.00-00-061, McGuire documents the significant contributors to LERF in terms ofcontribution by initiating events. However, they did not document the relative contribution ofcontributors such as plant damage states, accident progression sequences, phenomena, containment challenges and containment failure modes.To move from CC I to CC Il/111, McGuire needs to evaluate the relative contributions to LERF by suchthings as plant damage states, accident progression sequences, phenomena, containment challenges, and containment failure modes.Disposition of the Peer Review Finding:For RI-ISI applications only CC I is required to be met for this SR in accordance with EPRI TR-1021467, Table 2-2. The Peer Review determined that the affected SRs were met at CC I and the F&O was writtenagainst CC Il/111. Therefore this SR is judged to be fully met at CC I and is sufficient to meet the technical adequacy requirements for the RI-ISI application.

Page A-112 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs:LE-G5-01EPRI Streamlined RI-ISI CC Requirement:

Peer Review CC Assessment:

CC 1/11/111 Not metCapability Category 1/11/111 Requirements:

IDENTIFY limitations in the LERF analysis that would impact applications.

F&O Issue and Proposed Resolution:

The limitations of the McGuire LERF model are at best briefly mentioned in Section 8 of MCC-1535.00-00-0156.

McGuire uses a NUREG/CR-6595 LERF model which has a number of limitations associated with the conservative nature of such a model. McGuire should discuss these in more detail in Section 8of MCC-1535.00-00-0156.

McGuire uses a NUREG/CR-6595 LERF model which has a number of limitations associated with theconservative nature of such a model. McGuire should discuss these in more detail in Section 8 of MCC-1535.00-00-0156.

Disposition of the Peer Review Finding:The finding states that the limitations associated with using a NUREG/CR-6595 model should bedocumented within the LERF analysis.

However, per SR LE-E2, a NUREG/CR-6595 model is acceptable tomeet CC I, which is acceptable per the EPRI Streamlined RI-ISI guidance.

In the 'Scope and Limitations' section of NUREG/CR-6595, the containment event trees are identified to be bounding in nature. TheNUREG recommends a more detailed analysis if the LERF estimated using the methodology is close to orlarger than the acceptance guideline.

Additionally, a review of the McGuire simplified LERF methodology calculation (Reference 8.57) showsthat there are assumptions and limitations listed in Section 8 of the document; however this section isnot very comprehensive and requires more documentation.

Therefore, while the LERF analysis needs to be updated to include a more detailed discussion of themodel limitations, this finding only impacts the model documentation.

This finding has no impact onthe results or conclusions of this application.

Page A-113 of A-168 F&Qs Regarding PRA Supporting Requirements F&O ID: Other Affected SRs:LE-G6-01Streamlined RI-ISI CC-Requirement:

Peer Review CC:Assessm'ent:

CC 1/11/111 Not metCapability 111/111 Requirements:

.: Ca~ ~ ~ ........................................

DOCUMENT the quantitative definition used for significant accident progression sequence.

If other thanthe definition used in Section 2, JUSTIFY the alternative.

F9O Issue and Proposed Resolution:..

McGuire did not document the quantitative definition of significant accident progression sequence.McGuire needs to add a definition for significant accident progression sequence to MCC-1535.00-00-0156.

This can be accomplished by adding a specific definition or referencing theappropriate definition in Section 1-2 of RA-Sa-2009.

<Disposition of the Peer Review'Finding:

The definition of a significant accident progression sequence from Section 1-2 of RA-Sa-2009 is asfollows:One of a set of accident sequences contributing to large early release frequency resulting from the analysis of a specifichazard group that, when rank-ordered by decreasing frequency, sum to a specified percentage of the large early releasefrequency, or that individually contribute more than a specified percentage of large early release frequency for thathazard group. For this version of the Standard, the summed percentage is 95% and the individual percentage is 1% of theapplicable hazard group. (See Part 2 Requirements LE-C3, LE-C4, LE-E5, LE-ClO, LE-C12, LE-Di, LE-D4, LE-DS, LE-D7, andLE-E2.) For hazard groups that are analyzed using methods and assumptions that can be demonstrated to be conservative or bounding, alternative numerical criteria may be more appropriate, and, if used, should be justified.

Consistent with the above definition, the following table provides the significant accident progression sequences for the base model used in the MNS submittal:

% Contribution Cumulative

%Accident Progression Sequence Contribution toto LERFLERFInterfacing Systems LOCA 36% 36%Low Pressure Early Containment Failure 32% 68%Steam Generator Tube Rupture 25% 93%ATWS-Related Failure 4% 97%High Pressure Early Containment Failure 3% 100%This finding is a documentation issue and will have no impact on the results or conclusions of the MNSsubmittal.

4.4 Focused Internal Flood Peer Review to ASME/ANS PRA StandardPage A-114 of A-168 The PWR Owners Group conducted a focused peer review on the McGuire Nuclear Station InternalFlooding PRA model on September 13-15, 2011. This review was limited to the High Level andSupporting Requirements in Part 3, Requirements for Internal Flood At-Power PRA of the ASME/ANS RA-Sa-2009 PRA Standard.

The ASME/ANS PRA Standard contains a total of 316 numbered supporting requirements (SRs) forinternal events and internal flooding in nine technical elements.

This focused-scope peer review covereda total of 62 SRs associated with Internal Flood PRA. One of the SRs was determined to be not applicable to the MNS Internal Flood PRA. Of the 61 remaining SRs, 44 SRs were rated as SR Met, Capability Category (CC) 1/11, or greater.

One SR was rated as CC I and 16 SRs were not met.The peer review found 20 new Facts and Observations (F&Os), including three suggestions and 17findings.

Potential areas for enhancement identified during the review include the following:

" All assumptions should be listed under the Assumptions Section so that the uncertainty analysisconsiders all of these areas." The documentation of the walkdown data and flood scenarios should be consolidated so that itfacilitates the peer review, PRA applications, and PRA updates." A walkdown should be performed to verify the information that was provided by plantdocuments.

This will ensure the plant as-built configuration.

" A review of industry maintenance induced flood events should be performed to ensure thatsimilar events could not occur at MNS." Identify the pressure and temperature of all flood sources." Provide documentation for the determination of floor drain capacities.

" Prior to screening out flood areas, provide the propagation paths.Overall the peer review concluded that the flooding methodology used for MNS is sound and most ofthe areas of concern were due to documentation issues.A subsequent update to the McGuire Internal Flood PRA model was performed to address the 16 SRsrated as not met and the one SR rated as CCI. Westinghouse released LTR-RAM-11-112 (Reference 8.11),which describes how each finding and observation was addressed.

This update did not meet the criteriadefined in the ASME/ANS Standard for a PRA model upgrade and does not require a subsequent peerreview. A discussion of how the 17 Findings were addressed follows.There are a total of six calculations that make up the flood model. The following table correlates theDuke calculation numbers to the Westinghouse document IDs.Page A-115 of A-168 McGuire PRA Flood Model Calculations Duke Calculation

1. Westinghouse Document ID Reference

1. MCC-1535.00-00-0121 CN-RAM-10-002 8.50MCC-1535.00-00-0122 CN-RAM-10-003 8.51MCC-1535.00-00-0123 CN-RAM-I0-004 8.52MCC-1535.00-00-0124 CN-RAM-I0-005 8.53MCC-1535.00-00-0125 CN-RAM-10-006 8.54MCC-1535.00-00-0126 CN-RAM-10-010 8.55Any cited references in the following section are from LTR-RAM-II-112.

For information on thereferences in the following

section, refer to LTR-RAM-II-112.

Page A-116 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFPP Al-01 Met at CC 1/11/111Capability Category 1/11/111 Requirements:

DEFINE flood areas by dividing the plant into physically separate areas where flood area is viewed asgenerally independent of other areas in terms of the potential for internal flood effects and floodpropagation.

F&O Issue and Proposed Resolution:

The plant was not correctly divided into flood areas using physical separation as the criteria.

An exampleis that rooms 500, 501, 502, and 503 were grouped together but were not grouped to the hallway.

Thereis no physical separation from these rooms to the hallway.

Additionally, several rooms were identified during the walkdown that were not included in the Plant Partitioning definition of flood areas.Revisit the plant partitioning for flood areas and make changes as necessary and additions as necessary.

Ensure all rooms within the affected buildings are included in the analysisDisposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.These rooms are combined into one flood area in the evaluation.

They are documented as separaterooms in the walkdown forms so that spray impacts in this flood area (695-AO1) can be more easilyevaluated.

The purpose for this flood area definition is to appropriately capture the possible impact dueto a spray event. By defining the rooms separately, the impact due to a spray event is appropriately captured and analyzed.

By grouping the rooms together along with the hallway it becomes unclear howthe analysis treats the impact of these rooms due to spray. If these rooms are grouped with the hallwayit is the opinion of the internal flooding analysts that spray impacts on the equipment in the identified rooms would be unclear.

Furthermore, grouping these rooms (500, 501, 502, 503, 504, 505, 506 and507) with the adjoining hallway would have no impact on the analysis.

Clarification will be made in thewalkdown forms to ensure that this is clearer to reviewers.

The following generic statement should beadded to the walkdown forms in CN-RAM-10-002 for rooms 500, 501, 502 503, 504, 505, 506 and 507under the table in Section A:"This room is part of flood area 695-AO1.

The walkdown form is documented separately in thissituation so that spray impacts to the equipment in the different rooms can be more easilyevaluated."

A further review of existing flood area definitions confirmed that the existing flood area partitioning waswell suited for the analysis.

Furthermore, no rooms were identified which were not included in theplant partitioning definition of flood areas. Walkdown forms have been documented on a flood areaPage A-117 of A-168 basis rather than a plant room basis and it may have been misleading to reviewers.

Section 2.3 providesa more detailed discussion of this issue and the resolution.

Page A-118 of A-168

... F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs:. Peer Review CC Assessment:

IFPP A5-01 Not MetCapability Category 1/11/111 Requirements:

CONDUCT a plant walkdown to verify the accuracy of information obtained from plant information sources and to obtain or verify:a) spatial information needed for the development of flood areas, andb) plant design features credited in defining flood areas.F&O Issue and Proposed Resolution:

Based on walk downs performed by the Peer Review Team, several rooms were identified that are notincluded in the current walkdown forms for the Plant.Ensure all rooms and areas are walked down and documented in the Internal Flooding analysis.

Disposition of the Peer Review Finding:-

This F&O has been addressed and incorporated into the PRA model of record as follows.A follow-on walkdown was performed by WEC on October 24th-25th, 2011. No missing rooms wereidentified during the walkdown, but some walkdown sheets were documented on a flood area basisrather than a plant room basis. This is acceptable to meet the ASME/ANS PRA Standard, and isconsistent with the original internal flooding evaluation which was performed to some CC-I SRs. Anadditional walkdown was performed and walkdown forms which represented flood areas identified what plant features correspond to each individual room so that it would not appear any plant roomswere missed. Any rooms which were identified as grouped during the original evaluation are nowidentified individually in each flood area. Appendix A contains the additional information which shouldbe added to each rooms corresponding flood area walkdown sheet in CN RAM 10 002. Section 2.21provides a detailed discussion on the issues identified in F&O IFSN A17 01.Page A-119 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFPP B1-01 IFSO-B1, IFSN-B1, IFEV-B1 Not Met (IFPP-B1 Met at CC0/0//I/)Capability Category 1/11/111 Requirements:

Document the internal flood scenarios in a manner that facilitates PRA applications,

upgrades, and peerreview.F&O Issue and Proposed Resolution:

Documentation is not easy to follow in a few spots. Difficult to see why specific flood sources screened.

The analysis also lacks a list of critical component heights.It would be more helpful to reviewers if tabular information was documented in a more user-friendly manner. The analysis needs tables of flood sources/pipes retained and critical component heights forsafety-related components.

Disposition of the Peer Review Finding:

.......This F&O has been addressed and incorporated into the PRA model of record as follows.Documentation has been reviewed to ensure that the difficulty the peer review team had reviewing screened flood sources is addressed.

Documenting plant walkdowns on a room-by-room basis ratherthan a flood area basis was performed.

This is intended to aid in the peer review process.

Additionally, by not identifying the list of critical component heights found in CN-RAM-10-004 Appendix A, the peerreview team considered the documentation difficult to follow. Therefore, no change is needed toaddress that comment.

No additional issues with regard to the difficulty the team had reviewing thedocumentation were identified.

Page A-120 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFPP B3-01 IFSO-B3, IFSN-B3, IFEV-B3, IFQU- Not MetB3Capability Category 1/11/111 Requirements:

DOCUMENT sources of model uncertainty and related assumptions (as identified in QU-E1 and QU-E2)associated with the internal flood plant partitioning.

F&O Issue and Proposed Resolution:

Some of the key assumptions and areas of uncertainty were not all identified as such. These shouldappear in Section 4.4 but are found throughout the documents.

Many of the assumptions are not calledassumption but are identified as expectations.

Identify all assumption and areas of uncertainty in one section (i.e., Section 4.4)Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.The existing analysis was reviewed to identify any missing assumptions.

Any missing assumptions havebeen identified, included in that particular calculation note assumption section (Section 4.4) and havebeen characterized as part of the uncertainty evaluation.

Page A-121 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFSO Al-01 Met at CC 0/11/I11Capability Category 1/11/111 Requirements:

For each flood area, IDENTIFY the potential sources of flooding

[Note (1)]. INCLUDE:a) Equipment (e.g., piping, valves, pumps) located in the area that are connected to fluid systems (e.g.,circulating water system, service water system, component cooling water system, feedwater system, condensate and steam systems)b) Plant internal sources of flooding (e.g., tanks or pools) located in the flood areac) Plant external sources of flooding (e.g., reservoirs or rivers) that are connected to the area throughsome system or structure d) In-leakage from other flood areas (e.g., back flow through drains, doorways, etc.)F&O Issue and Proposed Resolution:

Although the walkdown notes did normally identify major equipment in the rooms, there was noidentification of water piping in the walkdown notes. Although a review of the Internal Flooding Analysisdid identify a description of water sources in those flood areas that were quantified, the SR requiresidentification of flood sources for all flood areas, including those that are eventually screened to ensurethey are not screened inadvertently.

Add a listing of the line sizes and fluid sources in each room on its associated walkdown notes form.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.The walkdown documentation refers to the Flood Initiating Event Notebook, CN-RAM-10-005 fordocumentation of piping present in all flood areas. This is currently documented in Section 5.0, Part C inCN-RAM-10-002.

Additionally, Section 5.3 in CN-RAM-10-003 contains descriptions of all plant watersources, including water sources in flood areas that were screened.

It is believed that the peer reviewteam typically saw the water source information documented in a single area, however the internalflooding team believes that separating out documentation of the water sources better suits the mannerin which the internal flooding analysis is documented.

All screened flooding sources are documented along with flood areas which are screened from the analysis.

All piping sources included in the analysisare documented along with analysis which determines the initiating event frequencies of each floodingsource. The manner in which the documents were constructed were done so to facilitate the mostefficient process by which the internal flooding team could perform the analysis, which may notnecessarily be the most beneficial method for a peer review team. Section 2.16 provides a detaileddiscussion on the issues identified in F&O IFSN A8-01.Page A-122 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFSO A4-01 Not MetCapability Category 1/11/111 Requirements:

For each potential source of flooding, IDENTIFY the flooding mechanisms that would result in a release.INCLUDEa) failure modes of components such as pipes, tanks, gaskets, expansion joints, fittings, seals, etc.b) human-induced mechanisms that could lead to overfilling tanks, diversion of flow-through openingscreated to perform maintenance; inadvertent actuation of fire-suppression systemc) (c) other events resulting in a release into the flood areaF&O Issue and Proposed Resolution:

Although there is a discussion of Maintenance-Induced flood scenarios in MCC-1535-0124, theassumptions noted in this section do not appear to be valid or defendable.

These assumptions couldresult in potential maintenance-induced floods not being identified and modeled appropriately.

For example, the first assumption (5a) states that reconfiguration of a fluid system for maintenance activities is performed while the unit is in cold shutdown conditions.

It was therefore assumed thatmajor pumps relied on for power production have been secured and would influence the flow rate.Although it is agreed that most preventive maintenance is performed while a unit is in shutdownconditions (hot shutdown or cold shutdown),

corrective maintenance, and some preventive maintenance activities, which require system reconfigurations while the unit at power are not precluded unless Technical Specifications exist which would not allow them to be performed in the Tech Specallowed outage time. For example, fluid systems with a 3 day allowed outage time that have morepumps than are required for continued operation (component cooling water, service water, charging) could have valve maintenance performed that requires system reconfigurations that have the potential to result in maintenance induced floods with the unit at power.Additionally, when valves require maintenance (e.g., internals replacement following valve failure),

isolation valves are typically closed under a clearance order, or a freeze seal is used to isolate the valvefor work. However, there have been instances where the isolation valve or freeze seal has failedresulting in a flood path through the removed internals.

The potential for these types of maintenance induced floods need to be evaluated.

The second set of assumptions (6a-g) is not supported by actual industry OE. For example, severalevents have occurred in the industry that were not readily recognizable by the personnel who initiated the event, but were identified by operations when levels raised/lowered unexpectedly in tanks/sumps.

The time to diagnose and respond to the induced floods by the operators exceeded five minutes foreach task, the actions required to mitigate the flood were not always simple, and stress levels were notPage A-123 of A-168 low.Industry OE associated with human-induced floods need to be reviewed and the potential for similarhuman-induced floods needs to be considered for McGuire.

Assumptions associated with screening and/or evaluating potential human-induced floods needs to be consistent with actual industry OE, or avalid justification for why industry OE is not applicable to McGuire needs to be provided.

All potential human-induced floods that are identified after reviewing industry OE and McGuire practices need to beincluded in the internal flooding analysis.

Note: A list of flooding related Industry OE through 2008 wasprovided to Duke Energy to help facilitate this review.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.The peer review team identified that Assumption 5a was not valid given that MNS Units 1 & 2 doesperiodically perform at-power maintenance.

However, this maintenance is infrequent, major systemreconfiguration is typically not performed at power and plant staff is well aware of the maintenance.

Therefore Assumption 5a has been rewritten.

Plant staff being immediately aware of flooding eventsgreatly increases successful event mitigation.

Assumption 5a has been rewritten as follows and will beupdated in CN-RAM-10-005:

"Reconfiguration of a normally operating fluid system for maintenance activities is typically performed while the unit is in cold shutdown conditions.

Additionally, plant staff will beimmediately aware of any possible flooding events resulting from potential maintenance-induced flooding scenarios.

It was therefore assumed that major pumps relied on for powerproduction have been secured and would not influence the flow rate."Additionally, some examples are given by the team of specific at-power flooding events, however nochanges are made to the MNS Units 1 & 2 maintenance induced flood assessment as their maintenance activities have been thoroughly evaluated and the applicable maintenance induced flooding scenarios have already been included in the analysis.

However, industry operating experience specifically dealingwith maintenance induced flooding events was not evaluated, and this information has been reviewedand identified as such in the analysis.

(Note, the peer review team provided the industry experience data.) The industry experience reviewed is captured in this letter report in Appendix B. This Appendix isreferred to as Appendix D in the quoted excerpt intended to be included in CN-RAM-10-005 documented below. The table is a collection of human-induced floods from the following resources:

• Table C-2 of EPRI TR-1013141, which documents significant internal flood events at nuclearpower plants world-wide from 1970 to 2002.* INPO Operating Experience databases from 1980 to 2008, which includes US & foreign events.* Licensee Event Reports (LERs) from 1980 to 2008, through the INPO website.* NRC Information Notice 2009-06 "Construction-Related Experience with Flood Protection Features".

" SOER 85-5 "Internal Flooding of Power Plant Bldgs."Page A-124 of A-168 0 SER 3-98 "Flooding of ECCS Rooms Caused by Fire Protection System Water Hammer."No new maintenance induced scenarios have been identified in the McGuire internal flooding analysis asa result of this review. The following should replace the discussion present in Section 5.1 inCN-RAM-10-005:

"The primary source of rupture data used here is the 2006 EPRI report on pipe rupturefrequencies (Ref. 5). In this EPRI report, the rupture frequency is expressed as a per unit lengthof line of a specific line diameter, magnitude of the discharge, and type of pipe service.

Thisreport notes that the piping failure data include all failures associated with valve bodies, heatexchangers and other similar components.

The data does include components susceptible toflow-accelerated corrosion and expansion joints in the Circulating Water System (RC) for whichspecific failure rates are presented.

In other words, the EPRI report asserts that the frequency with which a rupture would occur in a specific system in a specific flood area can be adequately predicted from counts of the total length of line of a specific size in that flood area and that thepresence of valves and other equipment can be ignored.

Baseline frequencies obtained usingthe EPRI method are presented in Table 5-1.The last 10 years of the MNS Units 1 & 2 PIPs database was searched using the following keywords:

"flood, HELB, rupture,

overfill, submerge,

overflow, spray, or pipe." Additionally, theMNS Units 1 & 2 LER database over the past 10 years was reviewed to ensure no keyoccurrences were missed as part of the evaluation.

Key issues identified were incorporated intothe flooding evaluation as appropriate.

The following two issues were identified and explicitly modeled as part of the internal flooding evaluation:

• Condenser Circulating Water System (RC) floods in the Turbine Building which mayinduce a dual unit Loss of Offsite Power (LOOP).* Flooding backflow via the Groundwater Drainage System (WZ) into the CA Pump Rooms.Additionally, maintenance process documents were evaluated to ensure that maintenance activities would prevent maintenance induced flooding events. The MNS Units 1 & 2"Operational Risk Management" (Ref. 9), "Work Activity Risk Management Process" (Ref. 10)and the "Risk Management Process" (Ref. 11) process documents were specifically reviewed.

Key issues were identified and incorporated into the evaluation.

Furthermore, industrymaintenance events were specifically examined and insights were incorporated as appropriate into the existing analysis.

These issues are discussed in detail in Section 5.5.Additionally, the "Operational Risk Management" (Ref. 11) Nuclear Policy Manual states that:"If the evaluation determines that there is a risk of causing flood damage to equipment identified in the Electronic Risk Assessment Tool, the following risk mitigation strategies shall beconsidered:

Page A-125 of A-168

" Development of a Complex/Critical Activity Plan containing risk management actions asdescribed in Appendix E (Risk Management Actions).

Guidance for developing aComplex/Critical Activity Plan can be found in NSD 213 (Risk Management Process).

• Consider revising the isolation plan to include double isolation between the open pipingand the water source, tagging of pumps which could move the water to the open piping,or draining piping to eliminate the water source.* When possible, work activities and isolations shall be structured such that a floodingpotential does not impact redundant trains of equipment identified in the Electronic Risk Assessment Tool.* When possible, work activities and isolations shall be structured such that a floodingpotential does not impact redundant functions.

For example, the SSF performs afunction that is redundant to the centrifugal charging pumps. If an activity is in progressthat presents a flood risk to a centrifugal charging pump, consideration should be givento not performing activities that could affect the ability of the SSF to perform itsredundant function.

• Identify items such as valves or pumps in the path from the water source to the breachthat could be used to isolate or stop a flood."Note, the previously referenced "Appendix E" refers to an appendix in the "Operational RiskManagement" (Ref. 11) Nuclear Policy Manual.This risk mitigation approach identified in the "Operational Risk Management" (Ref. 11) NuclearPolicy Manual ensures that maintenance procedures will not produce flooding events.The results of the PIPs and LER search can be found in Appendices B and C respectively while theindustry operating experience specifically dealing with maintenance induced floods can befound in Appendix D. This treatment is intended to meet IFEV-A6 at CC-Il/Ill."

Page A-126 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFSO A5-01 Not MetCapability Category I/Il/Ill Requirements:

For each source and its identified failure mechanism, IDENTIFY the characteristic of release and thecapacity of the source. INCLUDEa) a characterization of the breach, including type (e.g., leak, rupture, spray)b) flow ratec) capacity of source (e.g., gallons of water)d) the pressure and temperature of the sourceF&O Issue and Proposed Resolution:

A review of the Internal Flooding notebooks did not identify where the characterization of each sourceand flood mechanism was documented.

The flood scenarios in MCC-1535-123 did discuss some of therequired information such as type of breach, but not all the required information.

Although thewalkdown forms provided in Appendix A of MCC-1535-121 has fields available for some of the requiredinformation, these fields were not always filled out, and some of the required information was not listedon the walkdown forms so it was not looked for during the walk downs.Create a spreadsheet or table that lists each potential flood source, the capacity of the source, and thecharacteristics of each potential release associated with the source. Note that some sources may havemore than one potential release (e.g., leak and rupture),

and each should be documented separately.

The characteristics identified need to include the source, the type of breach, the flow rate through thebreach, the capacity of the source (e.g. gallons of water), and the pressure and temperature of thesource.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.Walkdown forms have been reviewed to ensure all fields have been filled out. Additionally, thetemperatures and pressures of the plant fluid systems do not need to be defined as all flooding impactsare inherently considered due to Assumption 2 in CN-RAM-10-004 that all equipment in the flood areawhere a flood initiating in, is failed. (Note, Assumption 2 has been rewritten so that this treatment isclearer.)

Therefore, the following statement should be added to the end of Section 5.3 inCN-RAM-10-003:

"The temperatures and pressures of the plant fluid systems do not need to be defined as allflooding impacts are inherently considered due to Assumption 2 in CN-RAM-10-004 whichidentifies that all equipment in the flood area in which a flood initiates, is assumed failed.Page A-127 of A-168 Therefore it is not necessary to describe systems in terms of pressure and temperature todetermine potential flood induced failure modes."The following modification to Assumption 2 is provided for replacing the wording of the existingassumption in the original

analysis, CN-RAM-10-004:

"All components within a flood area where the flood originates were assumed susceptible andfailed as a result of the flood, spray, steam, jet impingement, pipe whip, humidity, condensation and temperature concerns except when component design (e.g., water-proofing) spatial effects,low pressure source potential or other reasonable judgment could be used for limiting theeffect."Page A-128 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFSN A2-01 Met at CC 1/11/111Capability Category 1/11/111 Requirements:

For each defined flood area and each flood source, IDENTIFY plant design features that have the abilityto terminate or contain the flood propagation.

INCLUDE the presence ofa) flood alarmsb) flood dikes, curbs, sumps (i.e., physical structures that allow for the accumulation and retention ofwater)c) drains (i.e., physical structures that can function as drains)d) sump pumps, spray shields, water-tight doorse) blowout panels or dampers with automatic or manual operation capability F&O Issue and Proposed Resolution:

Only met for non-screened flood sources, but per the standard, needs to be met for ALL flood sources.Walkdown documentation (Notebook 1, Appendix A) also appears to be hit or miss, with regard todesign features some forms are much more detailed than others.Include design features for all flood sources.

Also need to resolve consistency issues between walkdownforms.Disposition of the Peer Review Finding:

......This F&O has been addressed and incorporated into the PRA model of record as follows.Walkdown documentation has been reviewed to ensure that all plant design features are included asappropriate for each flood area and flood source. The main insight which resulted from this F&O wasthat having the walkdowns documented on a flood area basis rather than a room-by-room basis couldhave been confusing for a peer review team. Therefore, walkdowns are now documented so thatindividual room characteristics can be identified to a reviewer.

CN-RAM-1O-003 (Ref. 5) Section 5.3provides documentation of all flood sources, including flood sources which are screened from furtheranalysis.

Furthermore, the features mentioned in the SR are applicable on an area basis, not a sourcebasis, and are documented in that way. In addition, no specific examples of places where the currenttreatment of these features have adversely impacted the analysis and therefore, the currentdocumentation approach adequately meets the SR intention.

Page A-129 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFSN A4-01 IFSN A13 Not Met (IFSN-A13 Met at CC00/I//l)Capability Category 1/11/111 Requirements:

ESTIMATE the capacity of the drains and the amount of water retained by sumps, berms, dikes, andcurbs. ACCOUNT for these factors in estimating flood volumes and SSC impacts from flooding.

F&O Issue and Proposed Resolution:

The analysis states that two inch line breaks were screened due to the fact that the floor drain had thecapacity to contain the water. There is not documentation to support this.The analysis states that spray events were screened from the flood analysis due to the fact that the floordrain had the capacity to contain the water. There is not documentation to support this.It should be noted that very few floor drains were noted in the Auxiliary Building during the Plantwalkdown.

Provide the documentation to support these two assumptions.

Verify floor drains exist throughout theAuxiliary Building or remove the assumption for the floor drains in the Auxiliary Building.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.Piping less than two inches was not screened from the analysis.

In some cases piping less than twoinches was not measured and included in the pipe length for a given flood area, but this was only donewhen appropriate.

Assumption 2 in CN-RAM-10-005 provides justification for this approach:

"Pipe sizes of less than or equal to 2 inch diameter were not included in generating pipe breakfrequencies resulting from floods or major floods, however they were considered for sprayeffects on an individual basis. Flood areas that only contained piping less than 2 inches indiameter were not screened from the analysis if no other larger piping was present in the floodareas. Not including piping less than 2 inches in diameter only marginally reduced the Initiating Event Frequency (IEF), and did not impact the methodology used in the evaluation.

Thisreduction is not verified anywhere but is generally understood as the less than 2 inch diameterpiping only provides a small length of pipe compared to the rest of the piping in the rooms.Additionally, if the initiating event frequencies are examined, the larger piping has greater IEFsby an order of magnitude.

Therefore, no comparison was performed.

Additionally, the impactof the less than 2 inch diameter piping when compared to the larger piping is significantly less.Finally, in cases in which none of these assumptions hold true, the impact of the less than 2 inchdiameter piping is explicitly evaluated.

This treatment is intended to support IFSO-A1 at CC-Page A-130 of A-168 l/11/111."All spray events were not screened from the analysis.

Spray events were evaluated to determine whether or not a pressure boundary failure of a nearby fluid source spraying onto a set of equipment could lead to a plant trip. As part of this evaluation the floor drains present in the flood area wereconsidered.

As appropriate floor drains were credited as a way of mitigating the accumulation of thewater in a flood area from a spray event. Documentation to more clearly state this treatment is beingincorporated into the flooding evaluation.

The MNS Units 1&2 floor drain calculation, MCC-1206.47 1001, should be referenced in the Calculation Note to further justify the treatment.

The following isrecommended to replace Assumption 3 in CN-RAM-10-004 to clarify this treatment:

"Floor drains were assumed to be capable of controlling water levels for spray events. This isbased on the expectation that a spray event will not result in a significant accumulation ofstanding water. During plant walkdowns it was observed that drain entrances were maintained in proper working conditions and free of debris. Additionally, walkdowns confirmed that drainswere present in all flood areas where spray events were considered.

Reviews of severalProblem Investigation Process (PIP) reports suggest that the floor drains that discharge to sumpsthat provided level alarms in the control room are maintained in working conditions.

Finally,MCC-1206.47-69-1001 (Ref. 15) has verified that drains present in identified flood areas arecapable of adequately relieving flood area water levels due to spray events. Drains were notcredited for any flood or major flood events. Table 4.4-1, shown below, provides a summary ofspray event treatment in the analysis."

Table 4.4-1 -Spray Impact SummaryFlood Area ID Description Number of Drains767-Ao1 Auxiliary Building 767' Elevation Screened per SR IFSN-A12(b) 750-AOl Auxiliary Building 750' Hallway Area This area includes all except therooms listed in other flood areas,10+ floor drains ( MC-1204-02.OA-065/MC-1204-03.OA-052) 750-803 Auxiliary Building 750' Unit 1 Switchgear Spray event retainedArea750-805 Auxiliary Building 750' Unit 2 Switchgear Spray event retainedArea733-AO1 Auxiliary Building 733' Hallway Area This area includes all except therooms listed in other flood areas,20+ floor drains ( MC-1202-02.OA-047) 733-705 Auxiliary Building 733' Unit 1 Switchgear Spray event retainedArea733-716 Auxiliary Building 733' Unit 2 Switchgear Spray event retainedArea733-BR1Auxiliary Building 733' Units 1 and 2Battery Room AreaFloor drains underneath thetrenches (MC-1220-014)

Page A-131 of A-168 716-AOlAuxiliary Building 716' Unit 1 NV/NI PumpRoom Area6 floor drains (MC-1201-02.OA-067)716-A02 Auxiliary Building 716' Unit 2 NV/NI Pump 6 floor drains (MC-1201-03.OA-Room Area 067)716-A03 Auxiliary Building 716' Hallway Area This area includes all except therooms listed in other flood areas,20+ floor drains ( MC-1201-02.OA-067) 716-CAI Auxiliary Building 716' Unit 1 CA Pump 8 floor drains (MC-1201-04.OA-Room Area 033)716-CA2 Auxiliary Building 716' Unit 2 CA Pump 8 floor drains (MC-1201-04.OA-Room Area 033)695-AO1 Auxiliary Building 695' ND/NS Pump Room 16 floor drains (MC-1200-01.OA-Area 016)736-703 Unit 1 Emergency Diesel Generator 1B 8 floor drains (MC-1203-02.OA-Area 029)736-704 Unit 1 Emergency Diesel Generator 1A 8 floor drains (MC-1203-02.OA-Area 029)736-714 Unit 2 Emergency Diesel Generator 1B 8 floor drains (MC-1203-04.0A-Area 030)736-715 Unit 2 Emergency Diesel Generator 1A 8 floor drains (MC-1203-04.0A-Area 030)739-TB1 Unit 1 Turbine Building Area Multiple floor drains/trenches 739-TB2 Unit 2 Turbine Building Area Multiple floor drains/trenches 739-SB1Shared Service Building AreaMultiple floor drains/trenches Page A-132 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFSN A5-01 IFSN-A6, IFSN-A15, IFQU-A9 Not Met (IFSN-A6, IFSN-A15

&IFQU-A9 Met at CC 1/11/111)

Capability Category 1/11/111 Requirements:

For each flood area not screened out using the requirements under other Internal Flood Supporting requirements (e.g. IFSO-A3 and IFSN-A12),

IDENTIFY the SSCs located in each defined flood area andalong flood propagation paths that are modeled in the internal events PRA model as being required torespond to an initiating event or whose failure would challenge normal plant operation, and aresusceptible to flood. For each identified SSC, IDENTIFY, for the purpose of determining its susceptibly perIFSN-A6, its spatial location in the area and any flooding mitigative features (e.g., shielding, flood, orspray capability ratings).

F&O Issue and Proposed Resolution:

Although some of the flood areas appear to identify all PRA related SSCs in them, others do not. Forexample, the Unit 2 AFW Pump Room only lists the major pumps and the Safe Shutdown Panels. Noadditional valves or other PRA-related equipment located in the room are identified.

Additionally, nospatial information of any of the PRA-related equipment in the flood areas appears to be documented inthe Internal Flooding Analysis.

Table 5-5 screening criteria may not be appropriate.

Using the list of PRA-related components contained in the Fire Database, develop a table for the InternalFlooding analysis that identifies the PRA-related equipment in each flood area, it spatial information, and any mitigative features available in the flood area. Once all SSCs in each identified flood area areidentified, identify the susceptibility of each SSC in the flood area to flood-induced failure mechanisms (see IFSN-A6 requirements) and ensure they are included in the quantification process.

Verify that thescreening criteria for Table 5-5 is appropriate for all components.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.See Finding IFSN A17-01 for resolution of PRA equipment documentation.

Assumption 2 in CN-RAM 004 provides justification as to why only limited equipment spatial information is documented.

Additionally, justification for not providing a full set of PRA equipment listing in the internal floodingdocumentation is provided in Finding IFSN A17-01. In all cases equipment was conservatively assumedto fail as a result of the different flooding mechanisms (as appropriate) and then refinement wasperformed as appropriate.

Documentation includes spatial information as appropriate as refinement tothe modeled scenarios were performed.

For example, the CA pump room includes a detailed discussion of equipment in the room and its proximity to potential flooding hazards.

No change is made to Table 5-5 in CN-RAM-10-003 as no example of issues were provided other than asking that the table be verified.

Page A-133 of A-168 The table was compiled based on numerous flooding efforts and was cross-checked with McGuire plantstaff to ensure Table 5-5 appropriately represented plant equipment susceptibility.

No documentation change is recommended as a result of this F&O.Page A-134 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFSN A8-01 IFSO-A1 Met at CC I (IFSO-A1 Met at CC00///11)Capability Category 1i Requirements:

IDENTIFY interarea propagation through the normal flow path from one area to another via drain lines;and areas connected via backflow through drain lines involving failed check valves, pip and cablepenetrations (including cable trays), doors, stairwells, hatchways, and HVAC ducts.INCLUDE potential for structural failure (e.g., of doors or walls) due to flooding loads.F&O Issue and Proposed Resolution:

A review of the analysis did not identify anywhere that potential connections between areas due to backflow through drains with failed check valves, pipe, and cable penetrations including cable trays or HVACducts were evaluated.

Additionally, no discussion of potential for structural failures due to floodingloads resulting in additional propagation pathways could be found.Re-evaluate the propagation pathways to ensure that these potential pathways are considered andincluded where applicable.

Disposition of the Peer Review Finding:,,

This F&O has been addressed and incorporated into the PRA model of record as follows.It is likely the peer review team did not identify a specific assessment of this SR in the assessment due tothe fact that this SR is inherently addressed throughout the analysis.

The following provides a simplehigh-level justification as to how each of the inter-area propagation pathways is treated in the analysis.

Each of the potential inter-area propagation mediums was not addressed separately, but rather wasaddressed as appropriate in Section 5.0 in CN-RAM-10-004 as the propagation means was applicable tothe scenario and flood areas being discussed.

Each scenario identified in Section 5.0 in CN-RAM-10-004 identifies the flooding initiator, the pathway (and the inter-area propagation means taken by theflooding source along that pathway) and the impacted equipment.

The following explicit discussion oninter-area propagation pathways will be included after paragraph one in Section 4.3 in CN-RAM-10-004:

"The following provides an explicit description on each of the inter-area propagation pathway meansrequired in SR IFSN-A8 to meet CC-Il:Drain lines -MNS Units 1 & 2 drainage systems were specifically addressed throughout theanalysis.

The groundwater drainage system (WZ) especially, was thoroughly analyzed andSensitivity Study 6 was included in the analysis to determine the degree of interaction betweenflood areas due to this inter-connected drainage system. All plant drainage systems wereevaluated in the internal flooding analysis and the connection between flood areas wasPage A-135 of A-168 identified to determine the potential impact.* Backflow through drain lines -Backflow through drain lines was evaluated for all drainagesystems at MNS Units 1 & 2. The WZ system was identified as a system which could potentially impact plant risk from an internal flooding perspective, and this scenario is explicitly evaluated in the analysis.

Flooding connections between the CA pump rooms for Unit 1 and Unit 2 wasdiscussed in the evaluation and is described here as an example of one of the backflow scenarios evaluated in the analysis.

• Failed check valves -No potential scenarios were identified with potential backflow issues asidefrom the WZ system scenarios.

This scenario did not credit check valves, and therefore failedcheck valves are inherently included in the assessment.

No other systems were identified dueto the wide-open nature of the plant and subsequent defined wide-open flood areas." Pipe and cable penetrations

-During plant walkdowns all penetrations were identified anddocumented in the walkdown forms which were deemed important to the internal floodinganalysis (penetrations which were either sealed or higher than potential flood levels were notdocumented).

It is reasonable to expect that the non-water tight door(s) associated with theflood area would fail prior to the accumulation of water to these penetration elevations.

Nopenetrations were identified which would impact a propagation pathway.

This does not implythat no penetrations exist within the plant, but rather no penetrations exist which wouldprovide a propagation pathway which would either change the described

pathway, or produce anew propagation pathway.

Penetrations were identified as sealed throughout the plant.* Doors -Doors were identified and included in all the described scenarios.

• Stairwells

-Stairwells were identified and included in all the described scenarios.

" Hatchways

-Equipment hatchways identified throughout the plant were determined to besealed and did not provide a propagation pathway from one flood area to another.

Additionally, in all cases the potential new propagation pathway that the hatchway would have providedwould not change the analyzed propagation pathway.

For example, flooding from the 716'elevation through the equipment hatches would lead to flooding out the 695' elevation.

Theimpact of the hatchway propagation path is the same as the propagation pathway analyzed viathe open stairwell from the 716' elevation to the 695' elevation.

• HVAC ducts -Similarly to pipe and cable penetrations, all HVAC ducts were identified anddocumented in the walkdown forms which were deemed important to the internal floodinganalysis (ducts which were higher than potential flood levels were not documented).

It isreasonable to expect that the non-water tight door(s) associated with the flood area would failprior to the accumulation of water to these HVAC duct elevations.

No HVAC ducts wereidentified which would impact a propagation pathway.

This does not imply that no HVAC ductsexist within the plant, but rather no HVAC ducts exist which would provide a propagation pathway which would either change the described

pathway, or produce a new propagation pathway.* Structural failure -No break-out walls or structural failures aside from doors or the plugbetween the Service Building and the Auxiliary Building were identified.

The only potentially Page A-136 of A-168 structural failures were discussed in detail as appropriate in the documentation."

Page A-137 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFSN A10-01 Met at CC 1/11/111Capability Category 1/11/111 Requirements:

DEVELOP flood scenarios (i.e., the set of information regarding the flood area, source, flood rate andsource capacity, operator

actions, and SSC damage that together form the boundary conditions for theinterface with the internal events PRA) by examining the equipment and relevant plant features in theflood area and areas in potential propagation paths, giving credit for appropriate flood mitigation systems or operator

actions, and identifying susceptible SSCs.F&O Issue and Proposed Resolution:->

Based on discussions with Operations personnel, it was identified that the Operators have specificprocedures to take equipment to lockout or manual control in the event the Alternate Shutdown Panels(ASP) are subjected to potential flooding.

A review of Section 5.4.1 of MCC-1535-123 associated with theAuxiliary Feedwater pump rooms revealed that the ASP was identified as being located in the room andwas identified as potentially susceptible

flooding, but the discussion of the impact of the flooding on theASP did not include the Operators requirements to disable automatic features in the plant.A walkdown of the outer doghouse identified that PORV controllers were present in the area that werenot identified in the discussion of the doghouse in Section 5.2.4 in MCC-1535-122.

Additionally, nodiscussion of the potential for spray causing AFW isolation valves to spuriously close is included in thisSection.

The impact of spray events on this equipment need to be evaluated, and if the valves couldspuriously change position, then outer doghouses cannot be screened.

PRA personnel and Operations personnel should review any procedures and resulting Operator actionsthat are implemented when the ASP is subjected to flooding and ensure that the impact is accurately reflected in the quantification of the flooding scenario.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.A site walkdown and discussions with plant personnel confirmed that treatment of the Auxiliary Shutdown Panel (ASP) in the current analysis is appropriate.

The documentation accurately describes the impact to the ASP and the operations response to its failure.

The peer review team believed thatspray on the ASP would render the equipment which could be controlled via the ASP unavailable; however recovery of that equipment could be credited.

This was the reasoning the peer review teamgave for the ASP related F&O related to the operator requirements.

These potential actions werereviewed and it was determined that recovery of the equipment is not credible for an internal floodingPRA and the impact of flooding on the ASP should not change. The following paragraph is currently Page A-138 of A-168 contained in Section 5.4.1 in CN-RAM 10-004 which describes the ASP treatment.

"The potential flood sources for the CA pump room were identified as the CA storage tank andthe RN. The impact of flooding on the ASP has been a concern that was addressed through theProblem Investigation Process (PIP). The ASP is sealed and not susceptible to spray. Theinvestigation determined that the contacts associated with ASP/Control Room transfer selectorswitches, which are located in the ASP, provides input to the Control Room board logic foraffected equipment.

It was determined that flood-induced electrical failure of the transferselector switches would affect the control schemes for the ASP and control board. This wouldresult in loss of indication lights at ASP and control board for associated equipment.

Also, therewould be a loss of control from the ASP and control board for the associated equipment.

Forexample, a flood-induced failure of the ASP would prevent the subsequent alignment of a safetyrelated pump (e.g. high pressure safety injection pump) to the RCS as the valves needed to openor close cannot be controlled once the ASP fails. Manual action may be possible to align theseinjection flow paths; however recovery of these flow paths and equipment is not credited in theinternal flooding PRA."Plant personnel confirmed that neither the PORV controllers nor the CA isolation valves are susceptible to spray and therefore no change to the existing analysis is appropriate.

A discussion justifying thistreatment has been added to the existing analysis.

The following should be input to Section 5.2.4,paragraph six in CN-RAM-10-003:

"Furthermore, both AFW isolation valves and PORV controllers were examined to determine ifspray event could impact this equipment.

Discussions with plant personnel confirmed thatneither the PORV controllers (Ref. 54) not the CA isolation valves (Ref. 55) is susceptible tospray, and therefore has not been incorporated into the analysis.

Additionally, the PORVcontrollers are listed as EQ equipment in a harsh environment and are expected to operate inthe defined spray scenario."

Page A-139 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID:... Other Affected SRs: Peer Review CC Assessment:

IFSN A12-01 Not MetCapability Category 1/11/111 Requirements:

SCREEN OUT flood areas where flooding of the area does not cause an initiating event or a need forimmediate plant shutdown, AND either of the following applies:a) the flood area (including adjacent areas where flood sources can propagate) contains no mitigating equipment modeled in the PRA; ORb) the flood area has no flood sources sufficient (e.g., through spray, immersion, or other applicable mechanism) to cause failure of the equipment identified in IFSN-A5.DO NOT USE failure of a barrier against inter-area propagation to justify screening (i.e., for screening, donot credit such failures as a means of beneficially draining the area).JUSTIFY any other qualitative screening criteria.

F&O Issue and Proposed Resolution:

Based on the write-ups in MCC-1535-122, several potential flood areas were screened based onpotentially invalid criteria/assumptions.

For example, Section 5.2.1 screens out the Annulus regionsbased on the length of the piping being relatively short, the PRA-components being primarily valveswhich are not susceptible to submergence, and that the unavailability of these valves are "not expectedto" result in a reactor trip. Regardless of the length of the piping, the potential/frequency of a pipebreak needs to be evaluated; no listing of PRA-components or their physical location in the flood area isprovided nor is the potential impact of spray on them causing them to fail discussed; the actual impactof a failure of these valves on continued plant operations needs to be validated.

It is not appropriate toscreen out a flood area based on these assumptions since they do not meet the criteria for screening.

Section 5.2.4 screens out the AFW isolation valves as being impacted by a flood event since the valvesare normally open and fail open on a loss of power. There is no discussion of the potential impact ofspray on the valves causing them to spuriously close resulting in a partial loss of AFW following a loss ofMFW due to the break in the Dog House. The spurious closing of the AFW Isolation valves in thisscenario would result in a situation that cannot be screened.

Re-evaluate the screening criteria applied for each screened flood area to ensure they are valid andcomplete.

Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.The Annulus was not screened due to relatively short piping. This was a poor choice of words used todescribe the flood area. The Annulus was initially screened due to the fact that no equipment in thatPage A-140 of A-168 flood area could lead to a plant trip or immediate plant shutdown.

Identification of short piping in theAnnulus was to support the stance that the piping was sufficiently short to allow that flooding initiator to be subsumed under the loss of system initiators corresponding to the fluid systems in the flood area.Upon further investigation however it was determine that additional scenarios warranted modeling inthe Annulus.

Scenarios requiring modeling included Pressure Boundary Failures (PBFs) in the ND, NVand KC systems causing a plant trip and a consequential failure of the standby makeup pump for thestandby shutdown facility.

The following required documentation changes needed to include thesescenarios in the model are identified below. No CDF or LERF changes were identified due to theseadditional scenarios.

The contribution to plant risk was not great enough to be retained afterquantification truncation limits were applied.

In addition to the changes identified below, thequantification Calculation Note CN-RAM-10-010 has been updated to reflect the identified modelchanges.

These changes have not been included in this letter report due to the large number of changesand will be incorporated in the revision of CN-RAM-10-010.

The discussion in paragraph three in Section 5.2.1 in CN-RAM-10-003 should be rewritten as follows:"The annulus is the space between the metal pressure retaining shell of containment and theconcrete shell and is considered an open area with one elevation.

This space is traversed bymany fluid systems as they penetrate into containment.

As a result the annulus region containsa variety of piping from different fluid systems.

PRA-related components and potential floodsources which could cause an immediate plant trip are located in the annulus.

As a result thisarea is retained for further analysis as 716-ANN."

The following table should replace Table 5-4 in Section 5.5 in CN-RAM-1O-003:

Table 5-4Potential Flood SourcesFlood Area ID Description Potential Flood Sources767-AOI Auxiliary Building 767' Elevation RN750-AOI Auxiliary Building 750' Hallway Area KC, KR, RWST, RF, RN750-803 Auxiliary Building 750' Unit I Switchgear RFArea750-805 Auxiliary Building 750' Unit 2 Switchgear RFArea733-AO1 Auxiliary Building 733' Hallway Area KC, KR, RWST, RF, RN733-705 Auxiliary Building 733' Unit 1 Switchgear RFArea733-716 Auxiliary Building 733' Unit 2 Switchgear RFArea733-BRI Auxiliary Building 733' Units 1 and 2 RN, KRBattery Room Area716-AOI Auxiliary Building 716' Unit I NV/NI Pump RWST, VCT, RF, RNRoom AreaPage A-141 of A-168 716-A02 Auxiliary Building 716' Unit 2 NV/NM Pump RWST, VCT, RF, RNRoom Area716-A03 Auxiliary Building 716' Hallway Area RN, RF716-CAI Auxiliary Building 716' Unit 1 CA Pump CAST, RNRoom Area716-CA2 Auxiliary Building 716' Unit 2 CA Pump CAST, RNRoom Area695-AOI Auxiliary Building 695' NDiNS Pump Room RF, RWST, RNArea736-703 Unit 1 Emergency Diesel Generator IB Area RN, KD736-704 Unit I Emergency Diesel Generator 1A Area RN, KDFlood Area ID Description Potential Flood Sources736-714 Unit 2 Emergency Diesel Generator 1B Area RN, KD736-715 Unit 2 Emergency Diesel Generator 1A Area RN, KD739-TB1 Unit I Turbine Building Area SM, CM, CF, RC, CAST,739-TB2 Unit 2 Turbine Building Area SM, CM, CF, RC, CAST739-SB 1 Shared Service Building Area KR, RL, CST, CAST, RWST, RF716-ANNI Annulus Area Unit 1 NS, ND, KC, NI, NV716-ANN2 Anmulus Area Unit 2 NS, ND, KC, NI, NVThe following section should be added to CN-RAM-10-004 after Section 5.4:5.5 Annulus Building Flood Scenario Characterization and Consequences 5.5.1 Annulus AreaThe standby makeup pump for the standby shutdown facility is located in this area. Access to this area isnot normally available during at power operation.

Therefore this area is considered by itself with no abilityto propagate to other areas or impact equipment located outside of this area.This flood area includes the area between pressure retaining metal shell and the concrete shell ofcontainment.

This area is equipped with floor sumps.Potential flood sources for this area include the Safety Injection System (NI), Containment Spray System(NS), Residual Heat Removal System (ND), Component Cooling Water System (KC), and ChemicalVolume and Control System (NV).The NV system normally receives inventory from the VCT. Once low-low level is reached in the VCT theRWST is automatically aligned as the suction source for the NV system. The RWST provides a substantial amount of inventory that could impact PRA-related equipment if a PBF is not isolated.

Due to the size ofthe NV piping within the Annulus only sprays and floods will be evaluated.

The KC system is a closed loop system. This system is retained in this flood area due to the limited area ofthe Annulus, close proximity of the components, and the resultant plant trip from the depletion of the KCsystem. Therefore this system is retained for further analysis.

The ND system receives inventory from the RWST. The RWST contains a considerable amount ofPage A-142 of A-168 inventory that would impact PRA-related equipment within the flood area. Therefore the ND system isretained for further analysis.

The NI and NS system piping is isolated in the Auxiliary Building.

Therefore the piping that exists withinthe Annulus region is not pressurized during normal operation and therefore does not need to be considered further.

Therefore this flood source is screened using the criteria of IFSN-A15.

5.5.1.1 Annulus Area Flood Scenario Development Based on the information presented in Section 5.5.1, a decision tree was developed to characterize the floodscenarios.

The decision tree accounted for possible combinations of factors that characterized the scenarios in a logical manner. These factors included the following:

0000The flood may be initiated by a PBF in the ND, KC or NV,The PBF can occur in any location within Annulus area,The pipe failure mode may vary (i.e., spray, flood, and major flood),The operator may take the appropriate steps to isolate the RWST or KC system and terminate theflow of water following indication in the Control Room.The flood scenarios for the ND, KC or NV flood source are shown in Figure 5-10.ANNULUS PBF FM ISO RantRessure Boundary Faglure Mode Iso. Before Affectng hipactFailure PRA EquipSPRAYANNFDS-1FLOOD ANNFDS-2ANNFDS-3X FLOOD ANNFDS-4ANNFDS-5Figure 5-10Annulus Area Flood Scenarios The following summarizes the flood damage states for either Annulus flood area and identifies the floodscenarios of concern.ANNFDS-1 This scenario represents a PBF that causes a spray event. The event is not of concernbecause the spray induced loss of the standby makeup pump will not induce an immediate plant trip. The resultant loss of inventory from the affected system is not expected to resultin the failure of that system to perform its plant function.

The spill rate for a spray event iswithin the capacity of the floor drain system. Therefore this scenario does not requireadditional consideration as a flood initiating event.Page A-143 of A-168 ANNFDS-2 This scenario represents a PBF that causes a flood event followed by successful operatoractions to isolate the flood source before impacting PRA-related equipment.

For a KCflood event, the plant response would be similar to a loss of KC caused by any of the othertypes of failure mechanisms.

The limited KC inventory and the openness of the flood areaprevent the threat of submergence of PRA-related components in the area. Therefore, thisKC flood scenario does not require additional consideration as a flood initiating event.The successful isolation of an ND/NV flood would render the supply for all standby ECCSpumps unavailable.

This condition would initiate an immediate plant shutdown to complywith Technical Specification 3.0.3 limiting conditions of operation.

This scenario is ofconcern for ND flood because the flood would initiate an immediate plant shutdown andcaused the unavailability of the ECCS pumps to perform their bleed and feed function.

ANNFDS-3 This scenario represents a PBF that causes a flood event followed by failure of operatoractions to isolate the source. The KC inventory is sufficient to threaten PRA-related components in the flood area submerge, the standby makeup pump. Loss of KC inventory would also result in an immediate plant trip. Failure to isolate the NV or ND flood sourcewould deplete the RWST inventory and render the standby ECCS pumps incapable ofperforming their functions.

This condition would initiate an immediate plant shutdown tocomply with Technical Specification 3.0.3 limiting conditions for operation.

This scenariois of concern because of 6n immediate plant shutdown or plant trip and flood-induced failures of PRA-related components.

ANNFDS-4 This scenario is similar to ANNFDS-2, except that a major flood event occurs.ANNFDS-5 This scenario is similar to ANNFDS-3, except that a major flood event occurs.Based on the above flood damage states and similarities between the units, the Annulus area floodscenarios for MNS Units I and 2 are provided in Table 5-19.Table 5-19Annulus Flood Scenarios Flood Scenario ID Damage Description State%IF716ANN10INDF ANNFDS-3 Unit 1 ND flood in Annulus area followed by unsuccessful isolation of this flood source and an immediate plant shutdowndue to loss of suction to the ECCS pumps.%IF716ANN102NVF ANNFDS-3 Unit 1 NV flood in Annulus area followed by unsuccessful isolation of this flood source and an immediate plant shutdowndue to loss of suction to the ECCS pumps.%IF716ANN103KCF ANNFDS-3 Unit 1 KC flood in the Annulus area followed by unsuccessful isolation of this flood source and an immediate plant shutdowndue the loss of KC.%2F716ANN104NDF ANNFDS-3 Unit 2 ND flood in Annulus area followed by unsuccessful isolation of this flood source and an immediate plant shutdowndue to loss of suction to the ECCS pumps.%2F716ANN105NVF ANNFDS-3 Unit 2 NV flood in Annulus area followed by unsuccessful isolation of this flood source and an immediate plant shutdowndue to loss of suction to the ECCS pumps.Page A-144 of A-168

%2F716ANN106KCF ANNFDS-3 Unit 2 KC flood in the Annulus area followed by unsuccessful isolation of this flood source and an immediate plant shutdowndue the loss of KC.%IF716ANN107NDX ANNFDS-5 Unit I ND major flood in the Annulus area followed byunsuccessful isolation of this flood source and an immediate plant shutdown due to loss of suction to the ECCS pumps.%IF716ANN108KCX ANNFDS-5 Unit 1 KC major flood in the Annulus area followed byunsuccessful isolation of this flood source and an immediate plant trip.%2F716ANN109NDX ANNFDS-5 Unit 2 ND major flood in the Annulus area followed byunsuccessful isolation of this flood source and an immediate plant shutdown due to loss of suction to the ECCS pumps.%2F716ANN10 OKCX ANNFDS-5 Unit 2 KC major flood in the Annulus area followed byunsuccessful isolation of this flood source and an immediate plant trip.5.5.1.2 Annulus Area Flood Corresponding Initiating Event GroupThe internal events initiating events were reviewed to identify the corresponding initiating event group forthe Annulus area flood scenarios.

A PBF in the KC would affect the ability of the affected KC train toremove heat from essential and non-essential equipment.

The inability to remove heat from equipment would cause a plant trip. The plant would respond similar to a transient-induced loss of KC.Consequently, loss of KC (%T1O) was identified as the corresponding internal initiating event group forKC PBFs.A PBF in the NV or ND pipe would affect the ability of the ND and NV pumps to perform their functions for bleed and feed operation.

Under this condition, an immediate plant shutdown would be initiated tocomply with Technical Specification 3.0.3. Consequently, reactor trip (%T1) was identified as thecorresponding internal initiating event group for flood-induced initiating events in the Annulus flood area.The flood-induced failures of SSCs required to respond to the initiating event are provided in Appendix A.The following entry should be added to CN-RAM-10-004 in Appendix A.1:4"716-ANN1/716-ANN2

-This flood area includes the Annulus area of each unit. Thestandby makeup pump for the Standby Shutdown Facility was selected as the PRA-related component that is located closest to the floor in this flood area. This component isassumed to be located on the floor and will fail immediately."

The following entries should be added to CN-RAM-10-004 in Appendix B.1:%IF716ANNIOIND ND flood event in Annulus area and loss TI Reactor TripF of RWST and standby makeup pumpsIFWRWSTTKF Refueling Water StorageTank FailsNNVOSMPDPR SSF Reactor CoolantMakeup Pump Fails To Run%IF716ANNI02NVF ND flood event in Annulus area and loss TI Reactor Tripof RWST and standby makeup pumpsIFWRWSTTKF Refueling Water StorageTank FailsNNVOSMPDPR SSF Reactor CoolantPage A-145 of A-168 Makeup Pump Fails To Run%IF716ANN103KCF KC flood event in the Annulus area and T1O Loss Of KCKC system and standby makeup pumpsNNVOSMPDPR SSF Reactor CoolantMakeup Pump Fails To Run%/IF716ANN107NDX ND major flood event in Annulus area TI Reactor Tripand loss of RWST and standby makeuppumpsIFWRWSTTKF Refueling Water StorageTank FailsNNVOSMPDPR SSF Reactor CoolantMakeup Pump Fails To Run%IF716ANNI08KCX KC major flood event in the Annulus area TIO Loss Of KCand KC system and standby makeuppumpsNNVOSMPDPR SSF Reactor CoolantMakeup Pump Fails To RunThe following entries should be added to CN-RAM-10-005 in Section 4.6 in Table 4-1:Total Pipe Diameter (in) Flood Area IDSystem Length (ft)KC 272' 4" 716-ANN I/716-ANN2 NV 471' 0.5-2"' 716-ANN 1/716-ANN2 ND 413' 6-8" 716-ANN I/716-ANN2 The following entries should be added to CN-RAM-10-005 in Section 5.4 in Table 5-4:Flood Frequency Major Flood Frequency (Event/Year)

(Event/Year)

KC 716-ANN I/716-ANN2 1.76E-06 2.49E-07NV 716-ANN I/716-ANN2 3.04E-06 N/A*ND 716-ANN 1/716-ANN2 1.72E-06 2.05 E-07*Piping in this of this system is too small for a major flood.The following entries should be added to CN-RAM-1O-005 in Section 5.4 in Table 5-5:Internal Flood Initiator Initiating Event Frequency Initiator Description Internal_____Flood___Initiator___

(per year) InitiatorDescription

%IF716ANNIOINDF 1.72E-06 ND flood in Annulus area%1F716ANN 102NVF 3.04E-06 NV flood in Annulus area%IF716ANNI03KCF 1.76E-06 KC flood in the Annulus area%IF716ANN107NDX 2.05E-07 ND major flood in the Annulus area%IF716ANNI08KCX 2.49E-07 I KC major flood in the Annulus areaThe following entries should be added to CN-RAM-10-005 (Ref. 7) in Appendix A Table A-i:Pipe Pipe Layout DrawingSytmElevation Location/Room System Length Diameter Elevation (ft) (in) NumberI (ft)Flood Area IDtPage A-146 of A-168 MC-KC 272 4 716 1411 716 Annulus 716-ANN 1/716-ANN2 20-00MC-NV 471 0.5-2 716 1414- 716 Annulus 716-ANNI/716-ANN2 22.21-0MC-ND 413 8 716 2414- 716 Annulus 716-ANNI/716-ANN2 09.21-00Refer to Finding IFSO Bl-01 for Doghouse F&O resolution.

Screening

criteria, which was used to screen out potential flood areas, were revisited.

Upon review noinstances aside from those in the previously discussed flood areas were identified which requiredreassessment.

Therefore, with the recommended

changes, the screening criteria used to screenpotential flood areas are valid and complete.

Page A-147 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID6:::, Other Affected SRs: Peer Review CC Assessment:

IFSN A17-01 IFPP-A5, IFSO-A6, IFQU-A11 Not Met (IFSO-A6 Met at CCI/CC///u)

Capability Category I/Il/Ill Requirements:

CONDUCT plant walkdown(s) to verify the accuracy of information obtained from plant information sources and to obtain or verifya) SSCs located within each defined flood areab) flood/spray/other applicable mitigative features of the SSCs located within each defined flood area(e.g., drains, shields, etc.)c) pathways that could lead to transport to the flood areaF&O Issue and Proposed Resolution:

A review of the walkdown forms provided in Appendix A of MCC-1535-121 identified that some criticalinformation required to support the SRs mentioned above was not available on the walkdown forms.For example, although the forms contained a field for Flood Sources, this appeared to only includetanks, and not piping in the area (note states that piping and corresponding lengths were determined from isometric and layout drawings),

and the volume of the tanks was not always provided.

Althoughthere is a field on the form for PRA-related equipment in the Area, this information was not filled outconsistently, resulting in some of the flood zones only listing major equipment such as pumps andpanels, but not all PRA equipment in the room so it is not always possible to determine what issusceptible to flood-related

impacts, including submergence and/or spray impacts in the room.Additionally, some of the information provided is contradictory for example, on the walkdown for Unit 2CA Pump Room although doors are listed, the Door Type and Door Sizes are given as N/A, and noinformation is provided with respect to which way the door opens. Some of the walkdown forms saidthey assumed the information was the same as Unit I which implies that an actual walkdown of theroom was never performed.

Since the some of the original walk downs are incomplete with respect to identifying all the information required to satisfy the requirements of SRs IFSOA6, IFPP-A5, IFSN-A17, IFQU-A11 (e.g., equipment locations in the rooms, door propagation

pathways, some information on the forms is assumedinformation, pipe lengths and sizes are taken from isometric and layout drawings, etc.) walk downs toverify the information not documented during the original walk downs are required to ensure validity ofthe information.

Ensure that walk downs are performed and documented that specifically address the requirements ofthese SRs. If these walk downs were performed, ensure that the information is complete, and can beeasily found.Page A-148 of A-168 Disposition of the Peer:Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.Walkdowns have been verified and forms have been reviewed to ensure all fields have been filled out.The items identified by the peer review team have been addressed with the exception of more fullylisting the PRA equipment located in a flood area. The walkdown sheets continue to identify only thePRA-related equipment critical to developing the internal flooding PRA model sufficient to capture theimpact of the flooding events. For example, a flood area may contain a motor-driven pump andassociated motor operated suction and/or discharge valves. The impact on system operation is thesame if either the motor-driven pump or motor operated valve is affected by a flooding event. It istherefore not necessary to list both the pump and valves to assess the flooding impact. Inclusion ofeither the pump or valve(s) is sufficient to assess the flooding impact on PRA-related equipment in theflood area. This is consistent with an inquiry and subsequent response by the NRC on the topic. Theinquiry is identified below:File # 08-503

Subject:

SR IF-C2c [IFSN-AS]

Applicability:

RA-Sc-2007 up to and including RA-Sa-2009 Date Issued: September 10, 2009Question:

Is it the case that SR IF-C2c [IFSN-A5]

can only be met if individual components located in the flood area are documented?

Response:

No. However if individual components are not identified, adequate justification tosupport the level at which SSCs are modeled should be documented.

As a result the level of detail presented in the walkdown forms is adequate and a statement justifying the level of detail presented has been incorporated into the documentation.

The following statement isrecommended to be added to Section 5.0 at the end of Part B in CN-RAM-10-002:

"The walkdown sheets identify only the PRA equipment critical to developing the internalflooding PRA model sufficient to capture the impact of the flooding events. This is consistent with NRC inquiry and subsequent response by the NRC on the topic. The inquiry is identified below:File # 08-503

Subject:

SR IF-C2c [IFSN-AS]

Applicability:

RA-Sc-2007 up to and including RA-Sa-2009 Date Issued: September 10, 2009Question:

Is it the case that SR IF-C2c [IFSN-A5]

can only be met if individual components located in the flood area are documented?

Response:

No. However if individual components are not identified, adequatejustification to support the level at which SSCs are modeled should be documented."

Page A-149 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:.

IFEV A1-01 Met at CC I/Il/IllCapability Category I//Ill Requirements:.*

For each flood scenario, IDENTIFY the corresponding plant initiating event group identified per 2-2.1 andthe scenario-induced failures of SSCs required to respond to the plant initiating event. INCLUDE thepotential for a flooding-induced transient or LOCA. If an appropriate plant-initiating event group doesnot exist, CREATE a new plant-initiating event group in accordance with the applicable requirements of2-2.1.F&O.Issue and Proposed Resolution:

Pipe routing in Unit 2 Turbine Building have the potential to impact 600 volt load center and multipleMG set related transformer.

This results in Unit 2 having multiple initiating events and not just MFLB orMSLB.Review this flood area for other potential plant initiating events.Disposition ofthe Peer Review Finding:

....This F&O has been addressed and incorporated into the PRA model of record as follows.Plant walkdowns confirmed that pipe routing in the Turbine Building near the 600 volt load centers(LXA-LGA) do present the possibility of additional reactor trips, due to spray events, previously notaccounted for in the existing evaluation.

Discussion of these spray scenarios has been added to thecurrent analysis.

However, due to the types of trips possible, no significant impact to the floodingevaluation has been identified as potential reactor trips are already accounted for in the internal eventsmodel, with much higher frequency than the frequency attributed to a spray event. Therefore no newadditional scenarios due to internal flooding are added to the MNS Units 1 & 2 internal flooding model.A discussion and justification of this approach has been added to the existing studies.

Flood damagestate TBFDS-1 in Section 5.1.1 in CN-RAM-10-004 has been rewritten as follows to more accurately capture the potential impact due to a spray event in the Turbine Building on the 600 volt load centers:"TBFDS-1 This scenario represents a PBF that causes a spray event. Spray on the 600 VACload centers is a concern because the 600 VAC load centers (i.e., LXA and LXG)provide power to the cooling equipment of the main transformers.

A loss ofcooling to the transformers could render them unavailable to provide offsitepower after a reactor trip. Load centers LXA and LXG are located sufficiently farapart (> 30 ft) to ensure that both trains of equipment that provide cooling tothe main transformers cannot be lost during the same spray event. Loadcenters LXF and LXG, which are located close together, provide power to themotor-generator sets. A loss of power to the motor-generator sets due to aPage A-150 of A-168 spray event would cause an uncomplicated reactor trip. The frequency ofreactor trip for this flood damage state is relatively small in comparison to othercause of reactor trip and would not change the frequency of an uncomplicated reactor trip significantly.

An uncomplicated reactor trip was explicitly modeledas part of the internal events PRA. Since the loss of both trains of coolingequipment for the main transformers is unlikely and an uncomplicated reactortrip has already been addressed, this scenario does not require explicitmodeling."

Page A-151 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFQU A6-01 Met at CC 1/11/111Capability Category 1/11/111 Requirements:

For all human failure events in the internal flood scenarios, INCLUDE the following scenario-specific impacts on PSFs for control room and ex-control room actions as appropriate to the HRA methodology being used:a) additional workload and stress (above that for similar sequences not caused by internal floods)b) cue availability c) effect of flood on mitigation, required

response, timing, and recovery activities (e.g., accessibility restrictions, possibility of physical harm)d) flooding-specific job aids and training (e.g., procedures, training exercises)

F&O Issue and Proposed Resolution:

The McGuire Operations staffing in the Control Rooms uses a single Shift Supervisor to oversee bothOperating Units. In the event of a single Unit trip, the Shift Supervisor is responsible for directing Operations personnel in the tripped Unit and following the EOP/AOP network of procedures to bring theUnit to a safe stable state. In the event of a dual Unit trip, this same Shift Supervisor is responsible fordirecting Operations personnel in BOTH tripped units and following the EOP/AOP network in each Unitto bring both Units to safe stable states. Since the same person is responsible for directing Operation actions in both units during a dual unit trip, the timing of actions and stress levels in the Control Roomwill be different during dual unit trips versus single unit trips. Therefore, different Operator actions needto be considered when responding to dual Unit versus single Unit events.Review the HRA events to ensure that the timing and actions are procedurally correct.Disposition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.The current analysis evaluated human responses in the most practical conservative manner that currentindustry accepted methodologies utilize.

No credit was taken for extra staff, and all stress levels wereadjusted to the high stress conditions to account for the multiple activities concurrently occurring.

Therefore, the current analysis is appropriate and no changes are necessary.

Additional documentation has been added to the evaluation to more fully describe the approach taken. The following enhanceddiscussion describing the justification for the current HRA treatment is recommended to be added to theend of Section 5.3 in CN-RAM-10-006:

"Newly created internal flooding isolation actions were built in the most practical conservative manner that current methodologies allow. No credit was taken for extra staff, and all stressPage A-152 of A-168 levels were adjusted to high stress conditions to account for multiple activities concurrently occurring.

It has been noted that the same Shift Supervisor is responsible for directing personnel in both units in the event of a dual unit trip. This does not impact internal floodingisolation actions however, as operators do not step through large numbers of steps in theEOPs/AOPs as they do with other operator actions.

Internal flooding isolation procedures require staff to identify the leak location, and then isolate the leak, typically in only a few steps.Therefore, the staff would not be hindered by only having one shared Shift Supervisor directing both control rooms. The activities to identify and isolate internal floods often require controlroom staff to leave the control room and travel into the plant, which again, would not beimpacted by only having one Shift Supervisor.

(Note, the arrival of the second Shift Supervisor will only be a matter of minutes, and although no credit is taken for their arrival, theimpact isexpected to be minimal.)"

Page A-153 of A-168 F&Os Regarding PRA Supporting Requirements F&O ID: Other Affected SRs: Peer Review CC Assessment:

IFQU A10-01 Met at CC 1/11/111Capability Category I/Il/Ill Requirements:

For each flood scenario, REVIEW the LERF analysis to confirm applicability of the LERF sequences.

If appropriate LERF sequences do not exist, MODIFY the LERF analysis as necessary to account for anyunique flood-induced scenarios or phenomena in accordance with the applicable requirements described in 2-2.8.F&OjIssue and Proposed Resolution:

.: ..........

i !i! , , ' : '~ =: ' i::i,!The current Internal Flooding analysis does include a review of cutsets to ensure that the cutsets makesense from a LERF perspective;

however, it still does not contain a discussion of the review that wasperformed to determine if any NEW LERF sequences needed to be considered due to the unique impactsof a flood. Potential NEW LERF impacts could be required if the flood could cause bypass scenarios thatwere not previously evaluated due to multiple spurious operations, inadvertent openings ofcontainment purge valves due to flood impacts on control panels, etc.These types of potential NEW [ERF impacts need to be included in the analysis, either by confirming thatthere are no NEW LERF sequences, or by modifying the LERF analysis as appropriate to address any NEWLERF sequences that are identified.

Dispossition of the Peer Review Finding:This F&O has been addressed and incorporated into the PRA model of record as follows.The LERF cutsets have been reviewed to ensure that no new LERF impacts are identified which were notpreviously evaluated.

The following discussion has been added to Section 5.2 before Table 5-5 inCN-RAM-10-010:

"Additionally, the cutsets were reviewed to ensure that no new containment isolation scenarios were identified which were not already captured in the Internal Flooding LERF cutsets.Additionally, no multiple spurious operations were identified which could potentially causeinadvertent openings of containment valves which could lead to new bypass events. The onlyplant equipment impacted by flood in such a manner which could create a situation such as thiswould be in the control room or in the CA pump room (ASP), and no such scenarios have beenidentified."

Page A-154 of A-168 5 Assessment of Technical Adequacy for the External Events ModelsIn accordance with EPRI TR-1021467 (Reference 8.6), external events PRA models are not includedwithin the scope of the RI-ISI program."With respect to the influence of RG 1.200 revision 2 (that is, hazards groups) on RI-ISI program development, it isimportant to note that the Rl-ISI supporting analyses (for example, consequence assessment) are based on theinternal events PRA. The purpose of developing a RI-ISI program is to define an alternative ISI strategy for pipingsystems (for example, nondestructive examination

[NDE] of a piping weld). The use of only the internal events PRAcan be justified by the following:

• The very small changes in the potential for piping failure because of changes in ISI, when augmented inspection programs such flow-accelerated corrosion (FAC), intergranular stress corrosion cracking (IGSCC)BWR categories B through G, localized corrosion (for example, microbial corrosion

[MI]) are left unchanged or improved" The small contribution of piping failure, which would be influenced by changes in ISI, to the risk attributable to external events such as fire" The use of defense in depth and safety margin to provide additional assurance of piping integrity Therefore, any potential quantitative insights from the analyses of other hazards groups would not impactconclusions with respect to acceptance criteria.

This approach was and is consistent with risk-informed decisionmaking as described, for example, in RG 1.174. However, for completeness, the RI-ISI methodologies were originally developed to assess the impact, as appropriate, on a qualitative basis, of other hazard groups. Experience with RI-ISIapplication to almost the entire U.S. fleet has shown that these hazard groups do not impact the RI-ISI conclusions.

6 PRA Model Configuration and Control ProgramThe PRA is maintained and updated such that its representation of the as-built, as-operated plant issufficient to support the applications for which it is used. Duke Energy maintains workplace procedures that evaluate and prioritize changes in PRA inputs as well as address discovery of new information thatcould affect the PRA.The PRA model is reviewed whenever plant accident response characteristics are changed.

Anyidentifiable plant change is analyzed for its risk significance.

This includes plant physical modifications, changes to Emergency or Abnormal Procedures, as well as Technical Specifications and SelectedLicensee Commitment changes.

The Duke Energy PRA group is on distribution for receipt of thesechanges from McGuire.The PRA Section has implemented a living PRA database program (PRA Tracker) to provide the meansfor formal documentation, tracking and resolution of any potential changes to the PRA based on plantmodifications, discovered errors or industry information.

When an issue is identified that calls intoquestion some aspect of the PRA model or related analysis, or if during the review of a site designchange package some issue is identified, the issue is entered into the PRA Tracker program.

At that timea determination of the risk significance of the issue based on Core Damage Frequency (CDF) and LargeEarly Release Frequency (LERF) is made, placing the issue in one of the following three categories:

Page A-155 of A-168

" the change in CDF or LERF is less than 1.OE-06 or 1.OE-07 / reactor-year, respectively

= LOW risksignificance

• the change in CDF or LERF is between 1.OE-06 to 1.OE-05 / reactor-year or 1.OE-07 to 1.OE-06 /reactor-year, respectively

= MEDIUM risk significance

" the change in CDF or LERF is greater than 1.OE-05 or 1.OE-06 / reactor-year, respectively

= HIGHrisk significance All open PRA Tracker items are reviewed prior to the start of an application for their impact on thatapplication.

There are no open HIGH PRA Tracker items. There are 9 open MEDIUM PRA Tracker items,which are dispositioned in Table 7.A sensitivity study was performed in Section 7.3 to determine the impact of open PRA Tracker items onthe RI-ISI application.

This study included 20 LOW PRA Tracker items and two MEDIUM PRA Trackeritems.Page A-156 of A-168 Table 7: Medium PRA Tracker ItemsTracker ID Description Impact Assessment Disposition for RI-ISI Application M-02-0001 The ISLOCA analysis contains a non-conservative The ability to close these valves is critical with This model change is a function of active valve failures.

Themodeling assumption that motor-operated respect to LERF. However, it is expected that the RI-ISI program monitors and inspects piping flaws andvalves NI-173 and NI-178 can close against the operators would be able to close the valves once degradation modes, which are not impacted by this change.high differential pressure induced by an ISLOCA. the primary system has depressurized via theUpdate the ISLOCA analysis to incorporate the ISLOCA and/or by using the steam generators.

Additionally, PIP M-02-0247 CA#24 documents a sensitivity insights from PA-RMSC-0464, "Consensus ISLOCA There is also a possible recovery to close the study considering the expected impact of the valvePRA Model". valve after the valve dp has decreased.

Thus, for limitations for NI-173 and NI-178. This analysis assumes thatcertain break sizes eventual valve closure is given failure of the cold leg injection check valves, theexpected.

resulting break flow from failure of the ND heat exchanger gaskets is equivalent to a 7.5" break. For McGuire, this breakflow is limited to 5 3/8" due to the check valve inlet/outlet restriction.

For breaks larger than 3", the NC system willdepressurize by low enough to allow operators to isolate thebreak, within the capability of the existing isolation valves.The exljected ISLOCA break range is > 3". Breaks in thelimiting range are not generally expected.

The issues with the current ISLOCA model are not considered to be risk significant and are judged to have no impact on theRI-ISI analysis.

M-04-0014 The McGuire PRA model is not taking credit for a Applying a recovery to accident sequences YOD3 This model change results in a CDF and LERF decrease andrecovery that is credited in WCAP-15955 to refill and YOX will result in a CDF and LERF reduction.

has conservatively not been included in the RI-ISI sensitivity the FWST in the YOD3 and YOX accident analysis.

sequences.

The ability to refill the FWST iscovered in plant procedures and plant operators are trained to perform this task.M-06-0004 A review of manual operator actions credited in Update the time available to take this action Include in the sensitivity study.the PRA for event mitigation by operations and during a station blackout event to 50 minutes.PRA engineers identified a suggested revision to This accounts for post-throttling swell ofevent FCATHRODHE (Operator Fails to Manually inventory in the steam generators to ensureThrottle the Auxiliary FW Flow After Loss of water is not discharged to the turbine-driven CAInstrument Air Due to a Loss of Power" steam supply.M-06-0011 A review for the Maintenance Rule update Examination of the basecase mr3a cutsets shows This model change results in a CDF and LERF decrease andidentified that the SGTR logic included a loss of that the total frequency of SGTR events that has conservatively not been included in the RI-ISI sensitivity instrument air as a failure mechanism for the SG would be recoverable is approximately 2E-07/yr.

analysis.

PORV, but did not credit operator action tomanually open the valves locally.

The SGTRmodel should be evaluated for the inclusion ofthis operator recovery factor.Page A-157 of A-168 Tracker ID Description Impact Assessment Disposition for RI-ISI Application M-07-0015 The plant has implemented a new way to supply Applying a recovery action to refill the RWST will This model change results in a CDF and LERF decrease andthe RWST externally via a fire hose. result in a CDF and LERF reduction, particularly has conservatively not been included in the RI-ISI sensitivity for accident sequences involving a CA pump analysis.

room flood and a loss of Main Feedwater following a reactor trip.M-08-0007 Revise the McGuire seismic PRA model to Based upon a review of the McGuire IPEEE This model change impacts the seismic PRA model, which isremove plant level (surrogate) fragilities and results it is expected that when the component outside the scope of the RI-ISI application.

reinstate component level fragilities per the fragility values are reinstated into the currentIPEEE. seismic model, the percent contribution to theseismic CDF from ESFAS component failures isexpected to drop from 34% to less than 1%.M-11-0001 The plant has implemented a new way to supply Applying a recovery action to provide an This model change results in a CDF and LERF decrease andthe CA system externally via a fire hose. alternate, external supply to CA will result in a has conservatively not been included in the RI-ISI sensitivity CDF and LERF reduction, particularly for accident analysis.

sequences involving a CA pump room flood and aloss of Main Feedwater following a reactor trip.M-12-0003 The MR3 seismic analysis uses an assumed value Incorporate revised seismic fragility values for This model change impacts the seismic PRA model, which isfor the Low Level Intake (LLI) fragility based upon the Cowans Ford Dam into the seismic PRA. outside the scope of the RI-ISI application.

the Oconee intake canal east dike which is abouttwice as high as the value calculated by HDR.M-12-0008 Plant modifications were performed to delete Revise the CA system model to reflect the need Include in the sensitivity study.the auto-open function for valves CA-161 and for the operators to manually open valves CA-CA-162. After air is purged from the piping, the 161 and CA-162 to provide an alternate supply tovalves can be manually opened to supply the CA the turbine-driven CA pump.pump.Page A-158 of A-168 7 Sensitivity Studies7.1 Control Room Area HVACBattery Room #701 and the Control Room Area Switchgear Room HVAC have been screened from theMcGuire PRA model of record (model revision mr3c); however, these rooms may be included in the nextmodel of record. A sensitivity study was performed to address the impact of the resolution for F&Os IE-2 and TH-6.The following table summarizes the results of this sensitivity study for those initiating event sequences which impact the RI-ISI application.

Initiating Event CCDF CLERFSmall Break LOCA 3.54E-09 5.78E-09Steamline Break Outside Containment 0.OOE+00 5.92E-09Medium Break LOCA 0.OOE+00 1.14E-10The following table provides a comparison of the sensitivity study CCDF and CLERF results to the modelof record results for the initiating event sequences of interest.

Model of Record Sensitivity StudyCDF I LERF I CDF LERFSteamline Break Outside Containment 3.91E-07 1.14E-09 3.91E-07 7.06E-09Small Break LOCA 3.20E-07 3.32E-08 3.24E-07 3.90E-08Medium Break LOCA 6.06E-08 2.59E-09 6.06E-08 2.71E-09For the initiating event sequences that impact the RI-ISI application, the impact from Control Room AreaVentilation is insignificant with respect to risk. Therefore, this sensitivity study has no impact on theresults or conclusions of the RI-ISI application.

7.2 HRA Miscalibration EventsFour new HRA miscalibration events were identified in an analysis performed to address F&O HR-1 andgaps HR-A2 and HR-A3. A sensitivity study was performed to address the impact of these new HRAmiscalibration events on the RI-ISI application.

The overall CDF contribution from this study is 1.3E-07 and from those initiating events that impact theRI-ISI application (small and medium break LOCAs), the CDF contribution is 4.1E-08, which is aninsignificant risk impact. Therefore, this sensitivity study has no impact on the results or conclusions ofthe RI-ISI application.

Page A-159 of A-168 7.3 PRA Tracker ItemsTwenty-two PRA Tracker items were identified during the open item review in Section 6 as candidates for a sensitivity study to assess the impactof the model changes on the RI-ISI application.

Table 8: PRA Tracker Items Included in the Sensitivity StudyTracker ID Description of the Issue and Model ChangesM-01-0014 ND can supply water to NV from ND Train A via ND58A to the NV pump suction.

ND can alternatively supply NV from ND Train B via N1136B toNI train B, N1135B, NI103A, N1333B/NI332A, and N1334B to the NV pump suction.

With either A or B trains of NI in maintenance, NI1O3A andN1135B, respectively, may not be available.

0M-02-0011 WRNUNT2DHE (Operators Fail to Cross-tie to Unit 2 RN) and WRVBACKDHE (Operators Fail to Align RV as Back-up to RN) are recoveries generally applied to T9 (Loss of RN) sequences;

however, these recoveries do not apply if the T9 is due to CCF of both units' RN pumps.M-02-0017 Gate NVW17, "Loss of Ventilation to Diesel Generator Room", was mistakenly removed from revision 3 of the MNS SSF model.0M-04-0003 Basic events FSA00SVAVT and FSAOOCVAVT are modeled in the CA system; however, these valves are included within the component boundary of the CA turbine-driven pump.UM-04-0007 Update the McGuire HRA for basic events NNVSSFADHE and NNVSSFBDHE to incorporate the latest Westinghouse RCP seal leakage modeltiming information (available recovery time reduced from 30 min. to 13 min.).0M-04-0010 Revise AC Power logic to reflect correct power supplies to load centers 2SLXG and 1SLXB and motor control center SMXY.0M-05-0006 Event WRN0001VVT (Motor Operated Valve [Power Removed]

1RN2 Transfers Position) is a common suction valve for both units and shouldalso fail Unit 2.0 Event WRNOOO1VVT was added to gate WRNUNIT2 in the fault treeM-05-0009 Failure of KC Heat Exchanger 1A Cooling Water Discharge Valve 1RN89A to open is not currently in the KC system model; however, this eventshould be added, since for accident mitigation the valve would need to open further to provide adequate KC heat exchanger flow.0M-06-0004 Revise event FCATHRODHE (Operator Fails to Manually Throttle the Auxiliary FW Flow After Loss of Instrument Air Due to a Loss of Power) toreflect that the available time for an SBO event is 50 min.0Page A-160 of A-168 Tracker ID Description of the Issue and Model ChangesM-06-0016 The.VCT outlet valves do not receive an Sp signal to close. Revise fault tree logic under gate H40 to delete the SP signal.0M-07-0002 Revise the SSF system notebook to reflect the fact that valve NV1013 is normally open.0M-07-0011 Gate TQ74 should include the T6 initiator "Secondary Line Break Inside Containment" as an input. Secondary line breaks in containment arepotential overcooling events.0M-08-0002 Modification MD100466 removed valves NV-498 and -499 from system piping.M-09-0003 Revise the exposure times for basic events representing the ESFAS logic modules from 30 to 92 days based on the revision to Tech. Spec.Surveillance Requirement 3.3.2.2.0M-09-0005 Revise the RN system model to address two model improvements identified during performance of the fire PRA.0M-11-0007 A Tech Spec Bases 3.7.7 change package deleted the RN pump discharge crossover capability from the opposing unit from the TS Bases. Thediscussion of this capability was moved into the TSC Guidance documentation.

M-12-0008 The auto open function for valves CA-161C and CA-162C was removed.

These valves are now opened from the SSF during LOOP events. Createnew HRA event and dependency analysis.

Prevent RC from being used as a recovery for non-LOOP scenarios.

0M-12-0013 RN Segments 6 and 7 (intake and discharge piping for RN Trains A and B, respectively) do not have a representative maintenance event.Create new maintenance events to represent RN train UA for: (1) RN B Train [takes out 1B and 2B pump trains],

(2) RN 1B pump train and (3)RN 2B pump train.M-12-0014 Per FAQ 468 process, the PRA is not representative of the maintenance unavailability assumed for CA Train C (CA TDP) and ND Trains A and B.M-12-0015 Page A-161 of A-168 Table 9 shows the CDF impacts of the sensitivity study for each individual initiating event and the floodgroup. Table 10 shows the LERF impacts of the sensitivity study for each individual initiating event andthe flood group.Table 9: Comparison of CDF Contribution Individual IE Comparison IE Group Comparison 4 ________

.-_________

BasecaseSensitivity DeltaBasecaseSensitivity Delta%OF695NDDSO3FTF 1.36E-09 8.25E-09 6.89E-091.36E-09 8.25E-09 6.89E-09%1F695NDDSO2FTF 0.OOE+00 O.00E000 0.OOE+00 160__6.E%OF716NIDS03FTF O.OOE+O0 3.09E-09 3.09E-09O.OOE+00 3.09E-09 3.09E-09%1F716NIDS02FTF O.OOE+00 O.OOE+00 O.OOE+00%1F733KCDSO2FTF 0.OOE+00 O.OOE+O0 0.OOE+00O 0.00E+00 0.00E+00 0.00E+O0%1F733KCDS04FTF O0E0 0.OOE+O 0 O.00E+-00 O..O.E+..,

%lF750KCDSO2FTF 0.OOE+00 O.OOE+00 0.OOE+000.OOE+O0

.O.E+OO0O.OOE+O0

%1F750KCDSO4FTF O.OOE+00 O.OOE+00 O.OOE+0O%OF739SBDSO2KRS O.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 O.'OOE+00 O.OOE+O0%OF739TBDSO4RCF O.OOE+00 O.OOE+00 O.OOE+00%OF739TBDSO8RCF O.OOE+00 1.86E-08 1.86E-08%OF739TBDS11RCX O.OOE+00 2.61E-08 2.61E-081.20E-08 1.58E-07 1.46E-07%OF739TBDS15RCX 1.20E-08 1.13E-07 1.01E-07%lF739TBDSO6RCF O.OOE+00 O.OOE+00 O.OOE+00%1F739TBDS13RCX O.OOE+00 O.OOE+00 O.OOE+00%OF739SBDSO5RFX O.OOE+00 7.72E709 7.72E-09 0.OOE+00 7.72E-09 7.72E-09%OF733BRDS01RLM 5.87E-08 7.46E-08 1.59E-08 5.87E-08 7.46E-08 1.59E-08%OF.739SBDSO5RLX 1.49E-08.

.2.52E-08

.1.03E-08 1.49E-08 2.52E-08 1.03E-08%OF716RNDSOSRN1F 0.OOE+00 O.OOE+00 0.OOE+0O%OF716RNDS05RN2F 8.34E-08 2.02E-07 1.19E-078.78E-08 2.20E-07 1.32E-07%OF716RNDSO8RNlX O.OOE+00 1.36E-09 1.36E-09%OF716RNDSO8RN2X 4.37E-09 1.63E-08

1. 19E-08%OF716RNDS06RN1F O.OOE+00 0.OOE+00 0.OOE+00%OF716RNDS06RN2F 8.34E-08 2.02E-07 1.19E-078.78E-08 2.20E-07 1.32E-07%OF716RNDSO9RN1X O.OOE+00 1.36E-09 1.36E-09%OF716RNDSO9RN2X 4.37E-09 1.63E-08 1.19E-08%1F716CADSO5RNAF 7.76E-07 9.17E-07 1.42E-07 32EO :3-6 18E0%lF716CADS07RNAX

' 2. 6 4.11E-08 3.25,ý"6 3.43F-06..

1.83E-07%1F716CADSO5RNBF 7.76E-07 9.17E-07 1.42E-07

-6E 06 -07%1F716CADSO7RNBX 2E-6 .52E-06 4.11E-086 1.83E-07%lF733KCDSO2RNAF 1.98E-07 1.98E-07 0.OOE+00%1F733KCDS03RNAX 2.51E-08 2.51E-08 0.OOE+00 3.16E-07 3.17E-07 1.06E-09%1F733KCDSO5RNAX 9.24E-08 9.35E-08 1.06E-09%1F733KCDSO2RNBF 6.29E-09 6.29E-09 O.OOE+00%1F733KCDSO3RNBX 0.OOE+00 0.OOE+00 O.OOE+00 4.51E-08 4.62E-08 1.06E-09%1F733KCDSOSRNBX 3.88E-08 3.99E-08 1.06E-09%OF750KCDSO2RNAF 1.46E-09 1.46E-09 O.OOE+O0%OF750KCDSO3RNAX 0.OOE+00 O.OOE+00 0.OOE+005.01E-09 1.08E-08 5.75E-09%OF750KCDS04RNAF 1.46E-09 1.46E-09 O.OOE+00%OF750KCDSO5RNAX 2.10E-09 7.85E-09 5.75E-09%OFTSOKCDSO2RNBF O.OOE+00 O.OOE+00 O.OOE+00 2.10E-709

7.85E-09.1 5.75E-09Page A-162 of A-168 Individual IE Comparison IE Group Comparison Basecase I Sensitivity Delta Basecase Sensitivity I Delta%OF75OKCDSO4RN BF0.OOE+00o.ou+'ob I O.OOE+00%OF75OKCDSO5RNBX 2.10E-097.85E095.75E-09%1F716CADS05STF 1.47E-08 1.82E-08 3.46E-091.53E-07 1.59E-07 5.98E-09%1F716CADSO7STX 1.38E-07 1.41E-07 2.52E-09SL 3.20E-07 3.23E-07 2.50E-09 3.20E-07 3..23E-07 2.50E-09ML 6.06E-08 6.02E-08

-3.73E-10 6.06E-08 6.02E-08

-3.73E-10 LL 0.OOE+00 O.OOE+O0 O.OOE+00 O.OOE+00 O.OOE+/-O0 O.OOE+00T6 7.11E-09 9.20E-09 2.09E-09 7.11E-09 9.20E-09 2.09E-09T7 3.77E-08 4.61E-08 8.42E-09 3.77E-08 4.61E-08 8.42E-09T8 3.91E-07 4.58E-07 6.69E-08 3.91E-07 4.58E-07 6.69E-08Table 10: Comparison of LERF Contribution Individual IE Comparison IE Group Comparison Basecase Sensitivity Delta Basecase Sensitivity Delta%OF695NDIS03FTF O.OOE+00 O.OOE+00 0.OOE+00

...0.OOE+00 0.OOE+00 0.OOE+00%1F695NDDS02FTF 0.OOE+00 O.OOE+00 0.OOE+00%OF716NIDS03FTF 0.OOE+0O 0.OOE+00 0.OOE+000.O0E+00 0.00E+00 0O.E+00%lF716NIDS02FTF 0.OOE+00 0.OOE+00 0.OOE+00%lF733KCDSO2FTF 0.OOE+00 O.OOE+00 O.OOE+O0 0.OOE+0O.OOE+0.

O.OOE+00%1F733KCDS04FTF 0.OOE+00 0.OOE+00..

0.OOE+00%lF750KCDSO2FTF O.OOE+00 O.OOE+O0 O.OOE+0OO.OOE+OO0O.OOE+00 0.OOE+O0%lF750KCDSO4FTF O.OOE+O0 O.OOE+00 O.OOE+0O%OF739SBDSO2KRS 0.OOE+00 O.OOE+00.:IL0.OOE+00 O.OOE+00 0,0OE+0O 000E+00%OF739TBDSO4RCF 0.OOE+00 O.OOE+00 O.OOE+00%OF739TBDSO8RCF 0.OOE+00 3.54E-09 3.54E-09%OF739TBDS11RCX O.OOE+00 2.35E-09 2.35E-091.88E-09 2.85E-08 2.67E-08%OF739TBDS15RCX 1.88E-09 2.27E-08 2.08E-08%1F739TBDS06RCF 0.OOE+O0 O.OOE+00 O.OOE+00%lF739TBDS13RCX O.OOE+00 O.OOE+00 O.OOE+00%OF739SBDSO5RFX 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00%OF733BRDS01RLM 1.19E-08 1.53E-08 3.33E-09 1.19E-08 1.53E-08 3.33E-09%OF739SBDSO5RLX 0.OOE+00 O.OOE+0"O.

.OOE+00 0.OOE+00 O.OOE+0O 0O.OOE+00

%OF716RNDS05RN1F O.OOE+00 O.OOE+00 O.OOE+00%OF716RNDS05RN2F 0.OOE+00 O.OOE+00 0.OOE+00O O.OOE+00 0.00E+00 0.00E+O0%OF716RNDSO8RN1X 0.OOE+00 O.OOE+00 O.OOE+00%OF716RNDSO8RN2X O.OOE+00 0.OOE+00 O.OOE+00%OF716RNDS06RN1F 0.OOE+00 O.OOE+00 O.OOE+00%OF716RNDS06RN2F 0.OOE+00 0.OOE+00 O.OOE+000O.E+00 O.OOE+O0 0.OOE+00%OF716RNDSO9RN2X O.OOE+00 O.OOE+O0 O.OOE+00%OF716RNDS09RN2X O.OOE+00 0.00E+00

.O.E+00 ....._...%lF716CADSO5RNAF 1.74E-08 1.74E-08 0.OOE+008.17E-08 8.17E-08 0.00E+00%lF716CADS07RNAX 6.43E-08 6.43E-08 0.OOE+00%1F716CADSO5RNBF 1.74E-08 1.74E-08 O.OOE+O0 8.17E-08 8.17E-08 O.OOE+00%lF716CADSO7RNBX 6.43E-08 6.43E-08 O.OOE+0O

'%1F733KCDS02RNAF 1.67E-09 1.67E-09 0.OOE+00 2.37E-09 2.37E-09 0.O0E+00Page A-163 of A-168 Individual IE Comparison I IE Group Comparison Basecase Sensitivity Delta Basecase I Sensitivity I Delta%1F733KCDS03RNAX OOE0 .O+00OEOOOOE+O0O.OOE+O0O.OOE+O0%lF733KCDS05RNAX 6.94E-106.94E-10O.OOE+O0%lF733KCDS02RNBF O.OOE+00 O.OOE+00 0.00E00%lF733KCDSO3RNBX O.OOE+00 O.OOE+00 O.00E+0OM 3.88E-10 3.88E-10 O.OOE+00%lF733KCDS05RNBX 3.88E-10 3.88E-10 0.OOE+00__

%OF750KCDSO2RNAF O.OOE+00 O.OOE+00 O.OOE+0O%OF750KCDSO3RNAX O.OOE+00 O.OOE+00 O.OOE+00O 0.OOE+00 0.OOE+O0 O.OOE+O0%OF75OKCDSO4RNAF O.OOE+00 O.OOE+00 O.OOE+00%OF750KCDSO5RNAX O.OOE+00 O.OOE+00 O.OOE+00%OF750KCDS02RNBF O.OOE+O0 0.OOE+00 O.00E+00%OF750KCDSO4RNBF 0.OOE+0O O.OOE+00 O.OOE+00 0.OOE+00 O.oOE+00

'O.OOE+00

%OF750KCDSO5RNBX O.00E+00 O.OOE+00 O.OOE+00%1F716CADSO5STF 2.21E-10 2.21E-10 O.OOE+003.52E-09 3.52E-09 O.OOE+00%lF716CADSO7STX 3.30E-09 3.30E-09 O.OOE+00SL 3.32E-08 3.32E-08 O.OOE+00 3.32E-08 3.32E-08 0.00E+00ML 2.59E-09 2.59E-09 O.OOE+00 2.59E-09 2.59E-09 O.OOE+00LL o.OOE+oO O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00.

I:.O.OOE+00 T6 0.OOE+00 O.OOE+O0 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00T7 .........

0.00EA0OI:

O.OOE+00 O.OOE+00 0.00E+00 O.OOE+00

O.OOE+00 T8 1.14E-09 1.14E-09 O.OOE+00 1.14E-09 1.14E-09 O.OOE+00The results of the sensitivity study do not impact the results or conclusions of the RI-ISI application.

Forthose initiating event sequences within the scope of RI-ISI, there was not a significant change in eitherCDF or LERF contribution.

8 References Documents 8.1. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis", Revision 2.8.2. Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking forInservice Inspection of Piping",

Revision 1.8.3. NUREG/CR-6595, "An Approach for Estimating the Frequencies of Various Containment FailureModes and Bypass Events",

Revision 0.8.4. NUREG/CR-6595, "An Approach for Estimating the Frequencies of Various Containment FailureModes and Bypass Events",

Revision 1.8.5. NUREG/CR-6928, "2010 Update of Parameter Estimation and Component Reliability DataSheets",

September 2010.8.6. EPRI TR 1021467-A, "Nondestructive Evaluation:

Probabilistic Risk Assessment Technical Adequacy Guidance for Risk-Informed In-Service Inspection Programs",

NRC Update, June 2012.Page A-164 of A-168 8.7. NEI 00-02, "Probabilistic Risk Assessment (PRA) Peer Review Process Guidance",

January 2000.8.8. NEI 05-04, "Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRAStandard",

Revision 2.8.9. WCAP-17154-P, "ISLOCA Risk Model", Revision 0.8.10. Westinghouse

Electric, OODA-G-0016, "Definition of Core Damage for PRA Application",

Revision0 (Proprietary).

8.11. Westinghouse

Electric, LTR-RAM-lI-11-112, "Internal Flooding PRA Peer Review Facts andObservation Resolutions for McGuire Nuclear Station Units 1 & 2", December 9, 2011.8.12. Westinghouse Owners Group, "McGuire Nuclear Station Probabilistic Risk Assessment PeerReview Report",

Final Report Issued January 2002.8.13. McGuire Nuclear Station, Mechanical/Nuclear

Systems, "Engineering Support Program, ControlRoom Area Ventilation System (VC), Control Room Area Chilled Water System (YC)", Revision 3.8.14. DPC-1535.00-00-0013, "PRA Quality Self-Assessment",

Revision 3.8.15. DPC-1535.00-00-0016, "Development of Generic Database",

Revision 2.8.16. DPC-1535.00-00-0017, "Catawba

/ McGuire Nuclear Station LOCA Break Size Determination forPRA", Revision 0.8.17. DPC-1535.00-00-0018, "Conversion of PRA Databases to Mean HEP Values",

Revision 1.8.18. MCC-1201.01-00-0055, "MNS RCP and NV Seal Leakoff Piping Delayed Response to Loss of SealCooling",

Revision 0.8.19. MCC-1205.06-00-0029, "McGuire Air Operated Valve Risk Ranking",

Revision 2.8.20. MCC-1211.00-33-0011, "Analysis of YC Chiller Response Time to a Station Blackout (SBO) Event",Revision 2.8.21. MCC-1211.00-00-0042, "Control Cable Battery and Switchgear Room HVAC", Revision 40.8.22. MCC-1240.00-00-0008, "Auxiliary Building Temperature Analysis During SSF Operation",

Revision 4.8.23. MCC-1535.00-00-0006, "PRA Risk Significant SSCs for the Maintenance Rule", Revision 4.8.24. MCC-1535.00-00-0007, "Assessment of Relative Risk Significance of McGuire's PRA Active MotorOperated Valves",

Revision 5.8.25. MCC-1535.00-00-0017, "Results and Insights from McGuire PRA Revision 3a", Revision 1.8.26. MCC-1535.00-00-0018, "Common Cause Analysis",

Revision 0.Page A-165 of A-168 8.27. MCC-1535.00-00-0019, "McGuire PRA -Failure Rate Database",

Revision 0.8.28. MCC-1535.00-00-0020, "McGuire Severe Accident Analysis PRA System Documentation

-HumanReliability Analysis Reference Document",

Revision 1.8.29. MCC-1535.00-00-0021, "Internal Initiator Events Frequency Data", Revision 0.8.30. MCC-1535.00-00-0023, "McGuire PRA -Essential Auxiliary Power System",

Revision 0.8.31. MCC-1535.00-00-0024, "McGuire Diesel Generators and Load Sequencers PRA", Revision 0.8.32. MCC-1535.00-00-0025, "Auxiliary

/ Emergency Feedwater System",

Revision 1.8.33. MCC-1535.00-00-0027, "Chemical and Volume Control (NV) System Notebook",

Revision 1.8.34. MCC-1535.00-00-0028, "McGuire PRA -Component Cooling Water System (KC)", Revision 0.8.35. MCC-1535.00-00-0029, "McGuire PRA -Compressed (Instrument)

Air System",

Revision 1.8.36. MCC-1535.00-00-0030, "McGuire PRA -Containment Air Return and Hydrogen SkimmerSystem",

Revision 1.8.37. MCC-1535.00-00-0031, "McGuire PRA -Containment Isolation",

Revision 1.8.38. MCC-1535.00-00-0032, "McGuire PRA -Residual Heat Removal System",

Revision 1.8.39. MCC-1535.00-00-0034, "Nuclear Service Water System (RN)", Revision 0.8.40. MCC-1535.00-00-0036, "McGuire PRA -Containment Spray System (NS), Reactor BuildingSpray", Revision 1.8.41. MCC-1535.00-00-0040, "McGuire PRA -Standby Shutdown System (SSF)", Revision 1.8.42. MCC-1535.00-00-0041, "AC and DC Vital Instrumentation and Control Power System",

Revision0.8.43. MCC-1535.00-00-0043, "ISLOCA Analysis",

Revision 0.8.44. MCC-1535.00-00-0050, "Tornado Analysis",

Revision 0.8.45. MCC-1535.00-00-0051, "McGuire Rev 3A PRA Model Integration Notebook",

Revision 0.8.46. MCC-1535.00-00-0086, "McGuire Nuclear Station RCP Seal LOCA T/H Analysis for PRA", Revision0.8.47. MCC-1535.00-00-0104, "MNS Fire Scenario Report",

Revision 0.8.48. MCC-1535.00-00-0116, "Potential Internal Initiating Events for the McGuire PRA", Revision 1.8.49. MCC-1535.00-00-0120, "McGuire Nuclear Station Success Criteria Notebook",

Revision 1.Page A-166 of A-168 8.50. MCC-1535.00-00-0121, "McGuire Nuclear Station Units 1 & 2 for Plant Walkdowns (CN-RAM 002)", Revision 2.8.51. MCC-1535.00-00-0122, "McGuire Nuclear Station Units 1 & 2 for Identification of Flood Areasand Flood Sources (CN-RAM-10-003)",

Revision 2.8.52. MCC-1535.00-00-0123, "McGuire Nuclear Station Units 1 & 2 for Characterization of FloodScenarios (CN-RAM-10-004)",

Revision 2.8.53. MCC-1535.00-00-0124, "McGuire Nuclear Station Units 1 & 2 for Identification and Estimation ofInitiating Event Frequencies (CN-RAM-10-005)",

Revision 2.8.54. MCC-1535.00-00-0125, "McGuire Nuclear Station Units 1 & 2 for HRA Flood Mitigation Strategies (CN-RAM-10-006)",

Revision 2.8.55. MCC-1535.00-00-0126, "McGuire Nuclear Station Units 1 & 2 for Flood PRA Modeling andQuantification (CN-RAM-10-010)",

Revision 2.8.56. MCC-1535.00-00-0148, "McGuire PRA Rev. 3c", Revision 2.8.57. MCC-1535.00-00-0156, "McGuire Simplified LERF Analysis

-Reference SAAG-683",

Revision 0.8.58. MCC-1535.00-00-0166, "McGuire PRA Quality Self-Assessment",

Revision 0.8.59. MCS-1223.SS-00-0001, "Design Basis Specification for the Standby Shutdown System",

Revision29.8.60. MCS-1557.VX-00-0001, "Design Basis Specification for the VX System",

Revision 9.8.61. MCS-1564.VE-00-0001, "Design Basis Specification for the VE System",

Revision 15.8.62. MCS-1576.VP-00-0001, "Design Basis Specification for the VP System",

Revision 9.8.63. MCS-1576.VU-00-0001, "Design Basis Specification for the VL/VR/VT/VU Systems",

Revision 16.8.64. MCS-1577.VA-00-0001, "Design Basis Specification for the VA System",

Revision 24.8.65. MCS-1577.VF-00-0001, "Design Basis Specification for the VF System",

Revision 12.8.66. MCS-1578.VC-00-0001, "Design Basis Specification for the VC/YC System",

Revision 28.8.67. MCS-1579.VD-00-0001, "Design Basis Specification for the VD System",

Revision 10.8.68. MCS-1579.VH-00-0001, "Design Basis Specification for the VH System",

Revision 2.8.69. MCS-1585.VQ-00-0001, "Design Basis Specification for the Containment Air Release andAddition (VQ) System",

Revision 5.8.70. MCS-1605.VI-00-0001, "Design Basis Specification for the VI System",

Revision 18.Page A-167 of A-168 8.71. MCS-1605.VS-00-0001, "Design Basis Specification for the VS System",

DELETED.8.72. MCS-1609.VG-00-0001, "Design Basis Specification for the VG System",

Revision 21.8.73. MCS-1609.VN-00-0001, "Design Basis Specification for the VN System",

Revision 4.8.74. Duke Power Company, "McGuire Nuclear Station Unit 1 Probabilistic Risk Assessment",

November 1991.8.75. SAAG File 95, "Small LOCA Feed & Bleed Success Criteria",

August 9, 1990.8.76. SAAG File 96, "Medium LOCA Feed & Bleed Success Criteria",

August 9, 1990.8.77. SAAG File 97, "McGuire Risk Assessment:

Large LOCA Success Criteria",

July 11, 1990.8.78. SAAG File 98, "McGuire Risk Assessment:

SSHR Success Criteria",

July 9, 1990.8.79. Selected License Commitment (SLC) 16.9.22, "Switchgear Room Ventilation System (SGRVS)",

Revision 109.8.80. Position paper, "Conditional Containment Failure Probabilities for the McGuire and CatawbaLarge Early Release Frequency Models",

November 2012.Procedures 8.81. Abnormal Procedure AP/0/A/5500/39, "Control Room HI Temperature",

Revision 14.8.82. Workplace Procedure XSAA-115, "PRA Modeling Guidelines",

Revision 15.Drawings8.83. MC-1202-04.00, "AUX BLDG UNITS 1 & 2 -FLOOR EL. 733+0 GENERAL ARRANGEMENT BATTERYROOM PLAN", Revision 31.8.84. MC-1202-05.OA, "AUX BLDG UNITS 1 & 2 -FLR EL 733 + 0 GENERAL ARRANGEMENT SWGR RMPLANS", Revision 53.8.85. MC-1204-05.OA, "AUX BLDG UNITS 1 & 2 GEN ARRANGEMENT",

Revision 22.8.86. MC-1578-01.01, "FLOW DIAGRAM OF CONTROL AREA VENTILATION SYSTEM (VC)", Revision 30.Page A-168 of A-168