L-MT-14-093, Expedited Seismic Evaluation Process (ESEP) - Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1

Expedited Seismic Evaluation Process (ESEP) - Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1

ML14357A280
Person / Time
Site:	Monticello
Issue date:	12/23/2014
From:	Fili K D Northern States Power Co, Xcel Energy
To:	Document Control Desk, Division of Operating Reactor Licensing
References
L-MT-14-093 14C4247-RPT-002, Rev. 2
Download: ML14357A280 (57)

Text

December 23, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 Renewed Facility Operating License No. DPR-22 Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 L-MT-14-093 10 CFR 50.54(f) Monticello Nuclear Generating Plant: Expedited Seismic Evaluation Process (ESEP) -Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1

References:

1) NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" dated March 12, 2012, (ADAMS Accession No. ML 12056A046).

2) Letter from K Fili (NSPM) to Document Control Desk (NRC), "Request Commitment Change for Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", L-MT-14-027, dated March 31, 2014 (ADAMS Accession No. ML 14090A297)

On March 12, 2012, the NRC issued "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" ("information request")

to all NRC power reactor licensees and holders of construction permits in active or deferred status (Reference 1 ). On March 31, 2014, in accordance with this information request, Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, committed to provide an Expedited Seismic Evaluation Process (ESEP) report to the NRC by December 31, 2014 (Reference 2). The purpose of this letter and enclosure is to provide the NRC with report 14C4247-RPT-002, Rev. 2, entitled, "Expedited Seismic Evaluation Process (ESEP)

Document Control Desk Page 2 Report in Response to the 50.54(f) Information Request Regarding Fukushima Term Task Force Recommendation 2.1: Seismic," for the Monticello Nuclear Generating Plant. The ESEP report was performed to demonstrate that a subset of the plant equipment can be relied upon to protect the reactor core following beyond design basis seismic events. The report results indicate that additional action (e.g. evaluation or modification or other action) is required to assure that sufficient seismic margin is available for a small set of plant equipment.

See the attached report for further details. These results are being tracked in the Monticello Corrective Action Program to ensure the actions are taken in a timely manner. If there are any questions or if additional information is needed, please contact John Fields, Fukushima Response Licensing, at 763-271-6707.

Summary of Commitments This letter completes the regulatory commitment to provide the ESEP report to the NRC by December 31, 2014. This letter contains no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December Z.3, 2014. ' ill:-' ( /1. p

// .

<!____ 0 ( Karen D. Fill '** Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosure cc: Administrator, Region Ill, USNRC Director of Nuclear Reactor Regulation (NRR), USNRC NRR Project Manager, MNGP, USNRC Senior Resident Inspector, MNGP, USNRC L-MT-14-093 ENCLOSURE MONTICELLO NUCLEAR GENERATING PLANT EXPEDITED SEISMIC EVALUATION PROCESS REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEARmTERM TASK FORCE RECOMMENDATION 2.1: SEISMIC 54 pages follow EXPEDITED SEISMIC EVALUATION PROCESS REPORT IN RESPONSE TO THE INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC for the Monticello Nuclear Generating Plant 2807 West County Road 75, Monticello MN 55362 Renewed Facility Operating License No. DPR-22 NRC Docket No. 50-236 Preparer:

Reviewer:

Approver:

Corporate Acceptance:

Monticello Nuclear Generating Plant 2807 West County Road 75, Monticello MN 55362 Prepared by: Stevenson

& Associates 275 Mishawum Road, Suite 200 Woburn, MA 01801 Report Number: 14C4247-RPT-002, Rev. 2 Printed Name Signature Jalal Farooq Todd Radford Walter Djordjevic 12/22/2014 12/22/2014 12/22/2014 Stevenson

& Associates Document Title: Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 2 of 54 Revision 2 EXPEDITED SEISMIC EVALUATION PROCESS (ESEP) REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC FOR THE MONTICELLO NUCLEAR GENERATING PLANT Document Type: Criteria 0 Interface D Report cgj Specification 0 Other D Drawing D Project Name: Monticello ESEP Program Job No.: 14C4247 Client: Northern States Power Company, a Minnesota corporation, d/b/a Xcel Energy (NSPM) This document has been prepared in accordance with the S&A Quality Assurance Program Manual, Revision 1I and project requirements:

Initial Issue: 14C4247-RPT-002, Revision 0 Prepared by: S. Kim v Reviewed by: W. Djordjevic

/4 j / 'IIIII Approved by: W. Djordjevic U j /. wr Revision Record: Revision Prepared by/ No. Date 1 Jalal Farooq 12/19/2014 f};V 2 Jalal Farooq 12/22/2014 Reviewed by/ Approved by/ Todd Radford Walter Djordjevic 12/19/2014 12/19/2014 Todd Radford Walter Djordjevic 12/22/2014 12/22/2014 It) /yl(-Date: 12/12/2014 Date: 12/12/2014 Date: 12/12/2014 Description of Revision Incorporation of minor editorial site comments.

Equipment ID for LIS-2-3-672E and LIS-2-3-672F changed to LS-2-3-672E and LS-2-3-672F, respectively.

References 29 and 30 added. Updated Section 8.4. pv IL-;:b Stevenson

& Associates DOCUMENT APPROVAL SHEET Figure 2.8 CONTRACT NO. 14C4247 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates TABLE OF CONTENTS Sheet 3 of 54 Revision 2 1. PURPOSE AND OBJECTIVE

........................................................................................................................

6 2. BRIEF

SUMMARY

OF THE FLEX SEISMIC IMPLEMENTATION STRATEGIES

........................................

7 3. EQUIPMENT SELECTION PROCESS AND ESEL .......................................................................................

8 3.1 EQUIPMENT SELECTION PROCESS AND ESEL ................................................................................

8 3.1.1 ESEL Development

.........................................................................................................................

8 3.1.2 Power Operated Valves ..................................................................................................................

9 3.1.3 Pull Boxes ........................................................................................................................................

9 3.1.4 Termination Cabinets ................................................................................

.....................................

9 3.1.5 Critical Instrumentation Indicators

...................................................................................................

9 3.1.6 Phase 2 and Phase 3 Piping Connections

......................................................................................

9 3.2 JUSTIFICATION FOR USE OF EQUIPMENT THAT IS NOT THE PRIMARY MEANS FOR FLEX IMPLEMENTATION

...........................................................................................................................................

10 4. GROUND MOTION RESPONSE SPECTRUM (GMRS) ..............................................................................

11 4.1 PLOT OF GMRS SUBMITTED BY THE LICENSEE ............................................................................

11 4.2 COMPARISON TO SSE ........................................................................................................................

12 5. REVIEW LEVEL GROUND MOTION (RLGM) .............................................................................................

15

5.1 DESCRIPTION

OF RLGM SELECTED ................................................................................................

15 5.2 METHOD TO ESTIMATE ISRS ............................................................................................................

19 6. SEISMIC MARGIN EVALUATION APPROACH ..........................................................................................

20 6.1

SUMMARY

OF METHODOLOGIES USED ..........................................................................................

20 6.2 HCLPF SCREENING PROCESS ..........................................................................................................

20 6.3 SEISMIC WALKDOWN APPROACH ....................................................................................................

20 6.3.1 Walkdown Approach ......................................................................................................................

20 6.3.2 Application of Previous Walkdown Information

.............................................................................

21 6.3.3 Significant Walkdown Findings ......................................................................................................

22 6.4 HCLPF CALCULATION PROCESS ......................................................................................................

22 6.5 FUNCTIONAL EVALUATION OF RELAYS ..........................................................................................

23 6.6 TABULATED ESEL HCLPF VALUES (INCLUDING KEY FAILURE MODES) .....................................

24 7. INACCESSIBLE ITEMS ............................................................................ , ...................................................

25 7.1 IDENTIFICATION OF ESEL ITEMS INACCESSIBLE FOR WALKDOWNS

........................................

25 7.2 PLANNED WALKDOWN I EVALUATION SCHEDULE I CLOSE OUT ................................................

25 8. ESEP CONCLUSIONS AND RESULTS ......................................................................................................

26 8.1 SUPPORTING INFORMATION

.............................................................................................................

26 8.2 IDENTIFICATION OF ITEMS REQUIRING FURTHER RESOLUTION

...............................................

27 8.3 IMPLEMENTATION SCHEDULE ........................................................................................ .................

28 8.4

SUMMARY

OF REGULATORY COMMITMENTS

................................................................................

28 9. REFERENCES

..............................................................................................................................................

29 ATTACHMENT A-MNGP ESEL ........................................................................................................................

31 ATTACHMENT B-ESEP HCLPF VALUES AND FAILURE MODES TABULATION

.......................................

43 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates LIST OF TABLES Sheet 4 of 54 Revision 2 Table 4-1: MNGP GMRS ......................................................................................................................................

11 Table 4-2: MNGP GMRS and SSErAFT between 1-10Hz ..................................................*...*.............................

12 Table 4-3: MNGP GMRS and SSEREG1.6o between 1-10Hz ...................................................*...........................*

13 Table 5-1: MNGP Maximum GMRS/SSErAFT Ratio (SF) ......................................*.............................................

15 Table 5-2: MNGP RLGMrAFT*****************************************************************************************************************************

... 15 Table 5-3: MNGP Maximum GMRS/SSEREG1.6o Ratio (SF) ................................................................................

16 Table 5-4: MNGP RLGMREG1.6o

............................................................................................................................

17 Table 6-1: MNGP Maximum GMRS/SSE Ratio (SF) ..........................................................................................

23 Table A-1: MNGP ESEL [19] ...............................................................................................................................

32 Table B-1: ESEP HCLPF Values and Failure Modes for EFT Building ...........................................................

44 Table B-2: ESEP HCLPF Values and Failure Modes for RX, ADMIN, & Turbine Building ............................

45 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates LIST OF FIGURES Sheet 5 of 54 Revision 2 Figure 4-1: MNGP GMRS ....................................................................................................................................

12 Figure 4-2: MNGP GMRS to SSErAFT Comparison

............................................................................................

13 Figure 4-3: MNGP GMRS to SSEREG1.so Comparison

........................................................................................

14 Figure 5-1: MNGP RLGMrAFT*********************************************************************************************************

......................

16 Figure 5-2: MNGP RLGMREG1.so

...........................................................................................................................

19 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

1. PURPOSE AND OBJECTIVE Sheet 6 of 54 Revision 2 Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the Nuclear Regulatory Commission (NRC) established a Near Term Task Force (NTTF) to conduct a systematic review of NRC processes and regulations and to determine if the agency should make additional improvements to its regulatory system. The NTTF developed a set of recommendations intended to clarify and strengthen the regulatory framework for protection against natural phenomena.

Subsequently, the NRC issued a 50.54(f) letter on March 12, 2012 [1], requesting information to assure that these recommendations are addressed by all U.S. nuclear power plants. The 50.54(f) letter requests that licensees and holders of construction permits under 10 CFR Part 50 reevaluate the seismic hazards at their sites against present-day NRC requirements and guidance.

Depending on the comparison between the reevaluated seismic hazard and the current design basis, further risk assessment may be required.

Assessment approaches acceptable to the staff include a seismic probabilistic risk assessment (SPRA), or a seismic margin assessment (SMA). Based upon the assessment results, the NRC staff will determine whether additional regulatory actions are necessary.

This report describes the Expedited Seismic Evaluation Process (ESEP) undertaken for the Monticello Nuclear Generating Plant (MNGP). The intent of the ESEP is to perform an interim action in response to the NRC's 50.54(f) letter [1] to demonstrate seismic margin through a review of a subset of the plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events. The ESEP is implemented using the methodologies in the NRC endorsed guidance in EPRI 3002000704, Seismic Evaluation Guidance:

Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic [2]. Note that this process is based on the MNGP FLEX strategy as of October 9, 2014. The objective of this report is to provide summary information describing the ESEP evaluations and results. The level of detail provided in the report is intended to enable the NRC to understand the inputs used, the evaluations performed, and the decisions made as a result of the interim evaluations Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

2. BRIEF

SUMMARY

OF THE FLEX SEISMIC IMPLEMENTATION STRATEGIES Sheet 7 of 54 Revision 2 The Monticello Nuclear Generating Plant (MNGP) FLEX strategies for reactor core cooling and heat removal and containment function are summarized below. This summary is derived from the MNGP Overall Integrated Plan (OIP) in response to the March 12, 2012, Commission Order EA-12-049

[3]. Reactor core cooling and heat removal is initially achieved using the Reactor Core Isolation Cooling System (RCIC) and High Pressure Coolant Injection System (HPCI) to provide high pressure makeup to the reactor. Both HPCI and RCIC automatically trip on high reactor water level. The normal suction supply for both HPCI and RCIC is the non-seismically qualified Condensate Storage Tanks (CSTs), if they are available.

If the CSTs are unavailable, suction automatically transfers to the suppression pool (torus). After the initial automatic initiation and trip of HPCI and RCIC, RCIC will be used as the primary strategy to provide makeup to the reactor. HPCI will be secured to extend the Division II battery life. Reactor depressurization will be initiated using safety-relief valves (SRVs) at a rate not to exceed 100 OF/hr to lower and maintain reactor pressure within the range of 150 psig to 300 psig. The torus performs as the heat sink for core cooling. The Hardened Containment Vent System (HVCS) line for the torus will be opened per the emergency operating procedures to remove heat from the torus and maintain the containment.

The strategy for phase 2 core cooling will rely on RCIC and the torus with venting through the HVCS as long as possible.

Once RCIC operation is no longer possible, the reactor will be fully depressurized using SRVs, and core makeup will be provided by a FLEX portable diesel-driven pump, drawing a suction from the discharge canal or the Mississippi River, and injecting to the reactor via a connection to the Residual Heat Removal Service Water (RHRSW) system. In Phase 2, DC powered equipment will be supported by a FLEX portable diesel generator connected to battery chargers, and supplemental nitrogen will be provided as needed to support operation of the HVCS and SRVs.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

3. EQUIPMENT SELECTION PROCESS AND ESEL Sheet 8 of 54 Revision 2 The selection of equipment for the ESEL followed the guidelines of EPRI 3002000704

[2]. The ESEL for Monticello Nuclear Generating Plant (MNGP) is presented in Attachment A. 3.1 Equipment Selection Process and ESEL The selection of equipment on the ESEL was based on installed plant equipment credited in the FLEX strategies during Phase 1, 2 and 3 mitigation of a Beyond Design Basis External Event (BDBEE), as outlined in the MNGP Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049

[3]. The OIP provides the MNGP FLEX mitigation strategy and serves as the basis for equipment selected for the ESEP. The scope of "installed plant equipment" includes equipment relied upon for the FLEX strategies to sustain the critical functions of core cooling and containment integrity consistent with the MNGP OIP [3]. FLEX recovery actions are excluded from the ESEP scope per EPRI 3002000704

[2]. The overall list of planned FLEX modifications and the scope for consideration herein is limited to those required to support core cooling, reactor coolant inventory, sub-criticality, and containment integrity functions.

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

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

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

The instrumentation monitoring requirements for core cooling/containment safety functions are limited to those outlined in the EPRI 3002000704 guidance, and are a subset of those outlined in the MNGP OIP [3]. 2. The scope of components is limited to installed plant equipment, and FLEX connections necessary to implement the MNGP OIP [3] as described in Section 2. 3. The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either "Primary" or up/Alternate").

4. The "Primary" FLEX success path is to be specified.

Selection of the "Back-up/Alternate" FLEX success path must be justified.

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

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

[2] guidance are: " Structures (e.g. containment, reactor building, control building, auxiliary building, etc.) " Piping, cabling, conduit, HVAC, and their supports. " Manual valves and rupture disks.

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

.. Nuclear steam supply system components (e.g. reactor pressure vessel and internals, reactor coolant pumps and seals, etc.) 7. For cases in which neither train was specified as a primary or back-up strategy, then only one train component (generally

'A' train) is included in the ESEL. 3. 1. 1 ESEL Development The ESEL was developed by reviewing the MNGP OIP [3] to determine the major equipment involved in the FLEX strategies.

Further reviews of plant drawings (e.g., Piping and Instrumentation Diagrams (P&IDs) and Electrical One Line Diagrams) were performed to identify the boundaries of the flow paths to be used in the FLEX strategies and to identify specific components in the flow paths needed to support implementation of the FLEX strategies.

Boundaries were established at an electrical or mechanical isolation device (e.g., isolation Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 9 of 54 Revision 2 amplifier, valve, etc.) in branch circuits I branch lines off the defined electrical or fluid flow path. P&IDs were the primary reference documents used to identify mechanical components and instrumentation.

The flow paths used for FLEX strategies were selected and specific components were identified using detailed equipment and instrument drawings, piping isometrics, electrical schematics and one-line drawings, system descriptions, design basis documents, etc., as necessary.

3.1.2 Power

Operated Valves Page 3-3 of EPRI 3002000704

[2) notes that power operated valves not required to change state are excluded from the ESEL. Page 3-2 also notes that "functional failure modes of electrical and mechanical portions of the installed Phase 1 equipment should be considered (e.g. RCIC/AFW trips)." To address this concern, the following guidance is applied in the MNGP ESEL for functional failure modes associated with power operated valves: " Power operated valves that remain energized during the Extended Loss of all AC Power (ELAP) events (such as DC powered valves), were included on the ESEL. " Power operated valves not required to change state as part of the FLEX mitigation strategies were not included on the ESEL. The seismic event also causes the !:LAP event; therefore, the valves are incapable of spurious operation as they would be de-energized. " Power operated valves not required to change state as part of the FLEX mitigation strategies during Phase 1, and are re-energized and operated during subsequent Phase 2 and 3 strategies, were not evaluated for spurious valve operation as the seismic event that caused the ELAP has passed before the valves are re-powered.

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

[2]. 3.1.4 Termination Cabinets Termination cabinets, including cabinets necessary for FLEX Phase 2 and Phase 3 connections, provide consolidated locations for permanently connecting multiple cables. The termination cabinets and the internal connections provide a completely passive function; however, the cabinets are included in the ESEL to ensure industry knowledge on panel/anchorage failure vulnerabilities is addressed.

3.1.5 Critical

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

3.1.6 Phase

2 and Phase 3 Piping Connections Item 2 in Section 3.1 above notes that the scope of equipment in the ESEL includes " ... FLEX connections necessary to implement the MNGP OIP [3) as described in Section 2." Item 3 in Section 3.1 notes that "The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either "Primary" or "Back-up/Alternate")." Item 6 in Section 3 goes on to explain that "Piping, cabling, conduit, HVAC, and their supports" are excluded from the ESEL scope in accordance with EPRI 3002000704

[2).

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 10 of 54 Revision 2 Therefore, piping and pipe supports associated with FLEX Phase 2 and Phase 3 connections are excluded from the scope of the ESEP evaluation. However, any active valves in the FLEX Phase 2 and Phase 3 connection flow path are included in the ESEL. The complete ESEL for MNGP is presented in Attachment A. 3.2 Justification for Use of Equipment That Is Not the Primary Means for FLEX Implementation No alternate equipment is used to support the "Primary" means for Flex implementation.

The complete ESEL for MNGP is presented in Attachment A.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

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4. GROUND MOTION RESPONSE SPECTRUM (GMRS) 4.1 Plot of GM RS Submitted by the Licensee Sheet 11 of 54 Revision 2 MNGP USAR does not explicitly define the Safe Shutdown Earthquake (SSE) control point. Therefore, the MNGP SSE control point is defined per Section 2.4.2 of the SPID [14] for the purposes of the SSE-to-GMRS comparisons as part of the 50.54(f) 2.1 seismic evaluations.

As a soil site with generally uniform, horizontally layered stratigraphy and with soil-founded key structures, the control point at MNGP is defined as the highest point in the material where a safety-related structure is founded. The highest soil elevation where a related structure is found is at Elevation 930 ft. Reference

[4] also states that the site SSE is anchored to a PGA of0.12g. The GMRS, taken from Reference 4 is shown in Table 4-1 and Figure 4-1 below. Table 4-1: MNGP GMRS Freq. (Hz) GMRS (unsealed, g) 0.1 0.01 0.125 0.01 0.15 --....... -. 0.01 0.2 0.01 0.25 0.02

.. 10.,2,c ___ ..... ---* 0.35 0.02 0.4 0,03 0.5 0.03 0.6 0.03 0.7 0.03 --------------------------

0.8 0.04 0.9 0.04 1 0.04 1.25 0.05 1.5 0.06 2 0.09 2.5 0.12 3 0.14 3.5 0.16 ----------

4 0.18 5 0.22 6 0.26 0.29 8 0.30 9 0.31 10 0.32 12.5 0.33

_____ _:oc:.:.3:..:4c___

__ _ 20 0.32 25 0.28 30 0.26 35 0.24 *------------------

---

---

40 50 60 70 so 90 100 0.22 0.19 0.17 0.16 0.16 0.15 ----------------------

---

0.15 Stevenson

& Associates 0.40 0.35 0.30 0.25 c 0 0.20 OJ ] 0.15 0.10 0.05 0.00 0 I Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report I I' I lh I I i i I I Ill \ J 1 11 I i I ;{111111 I I

• I ;) 111111 . I ' . -1 I I Ill I I : _j_ ------I I II II f-"" II I I ! I 1 10 Frequency (Hz) Figure 4-1: MNGP GMRS 4.2 Comparison to SSE ! I I I \I ! I I '\ 1'--1 I i I I I ' I ! . ------. I I 100 Sheet 12 of 54 Revision 2 -GMRS As identified in the Reference 4, the GMRS exceeds the SSE in the 1-10Hz range. A comparison of the GMRS to the SSE between 1-1OHz is shown in Table 4-2 and Figure 4-2. Table 4-2: MNGP GMRS and SSETAFT between 1-10Hz Freq. (Hz) GMRS (unsealed, g) Horizontal SSE (g) 1.00 0.038 0.142 1.25 0.048 0.175 1.50 0.060 0.202 2.00 0.091 0.245 2.50 0.119 0.275 ---3.00 0.143 0.291 3.50 0.164 0.301 4.00 0.184 0.306 ------------5.00 0.215 0.304 -6.00 0.263 0.287 I -----7.00 0.294 0.270 8.00 I ----. -*------0.302 0.249 9.00 0.313 0.232 . 10.00 __ . __ 1 0.324 0.217 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates 0.35 -,------0.30 -__ ,, I i 0.20 ] 0.15 .........

• -------,

u <( 0.10

--'-----+---------1 0.05 1 10 Frequency (Hz) Figure 4-2: MNGP GMRS to SSErAFT Comparison Sheet 13 of 54 Revision 2 -GMRS -SSE(TAFT)

In addition to the original SSE, the Emergency Filtration Train (EFT) Building was designed to a Regulatory Guide 1.60 RS shape anchored to 0.12g. Therefore, a second comparison of the GMRS and SSEREG1.eo is shown in the following.

Table 4-3: MNGP GMRS and SSEREG1.so between 1-10Hz Freq (Hz) GMRS (g) Horizontal SSE (g) 1.00 0.038 0.177 . ------1.25 0.048 0.221 *--------*-*

1.50 0.060 0.256 -----------------

2.00 0.091 0.313 2.50 0.119 0.376 ----*--3.00 0.143 0.366 3.50 0.164 0.358

---

4.00 0.184 0.351 5.00 0.215 0.340 ----------------------

---

6.00 0.263 0.332 7.00 0.294 0.325 8.00 0.302 0.318 9.00 0.313 0.313 -------10.00 0.324 0.290 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates 0.40 I I I I I ./ / . I . / v ' 0.35 0.30 0.25 ..!:!l g 0.20 "' Qj / v / I " 0.15 / I I I I I I I ----I I ____ j ___ I I I 0.10 0.05 0.00 1 10 Frequency (Hz} Figure 4-3: MNGP GMRS to SSEREG1.so Comparison Sheet 14 of 54 Revision 2 -GMRS -SSE(REG1.60)

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

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5. REVIEW LEVEL GROUND MOTION (RLGM) 5.1 Description of RLGM Selected Sheet 15 of 54 Revision 2 The RLGM for MNGP was determined in accordance with Section 4 of EPRI 3002000704

[2) by linearly scaling the MNGP SSErAFT by the maximum safety factor (SF = GMRS/SSErAFT ratio) between the 1 and 1OHz range. This calculation is shown in Table 5-1. Table 5-1: MNGP Maximum GMRS/SSETAFT Ratio (SF) Freq (Hz) GMRS (g) Horizontal SSErAFT (g) SF = GMRS/SSE 1.00 0.038 0.142 0.26 I --------1.25 0.048 0.175 0.28 1.50 0.060 0.202 0.30 -----------------------------------

2.00 0.091 0.245 0.37

---

*

2.50 0.119 0.275 0.43 ---* 3.00 0.143 0.291 0.49 ------*-*

-*-------**-------*

---3.50 0.164 0.301 0.54 ----------4.00 0.184 0.306 0.60 5.00 0.215 0.304 0.71 6.00 0.263 0.287 0.92 7.00 0.294 0.270 1.09 -----------8.00 0.302 0.249 1.21 ----***-*-

---

---

-*---------*-----9.00 0.313 0.232 1.35 10.00 0.324 0.217 1.49 As shown above, the maximum GMRS/SSErAFT ratio for MNGP occurs at 10 Hz and equals 1.49. The resulting 5% damped RLGM, based on scaling the horizontal SSErAFT by the SF of 1.49, is shown in Table 5-2 and Figure 5-1 below. Note that the RLGMrAFT PGA is 0.19g. Table 5-2: MNGP RLGMrAFT Freq. (Hz) 5% damped Horizontal RLGMTAFT (g) 0.50 0.092 0.53 0.100 0.56 0.108 0.59 0.114 0.63 0.128 ----------

0.66 0.136 ---*--------

0.71 0.146 0.76 0.156 0.83 0.174 --0;91 0.190 1.00 0.212 1.10 0.235 1.25 0.261 -------1.40 0.283 ------1.46 0.295 1.68 0.330 -----------

1.82 0.348 2.04 0.368 2.26 0.389 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates 0.50 0.45 0.40 0.35 ::§ 0.30 6 . .., 0.25 ., Gi 0.20 0.15 0.10 0.05 0.00 Freq. (Hz) 5% damped Horizontal RLGMTAFT (g) 2.50 0.409 ----------

2.76 0.425 3.40 0.448 ----4.27 0.460 4.95 0.454 --------5.42 0.447 6.13 0.423 7.23 0.396 8.29 0.362 -------10.44 0.313 ---12.26 0.282 ------------14.84 0.243 *--------18.80 0.204 --35.25 0.190 I I I I Ill I ! I I I ! v I \I I I / I \. I I I I \.1 I I I I I I ! I /I I I I I I :1 I / Kl \ ---

/!II 1'-. \. "'\ /i I -:--I / I I I "---l_ -i I rv / . ' I I I I I I I .......

I -+-II ,. I I 0 1 10 Frequency (Hz) Figure 5-1: MNGP RLGMTAFT II ! ! I I I ! I I I I 100 Sheet 16 of 54 Revision 2 -GMRS -SSE -RLGMrAFT As stated previously, the EFT building requires a separate RLGMREG1.so.

The same methodology is followed, and is presented in the following.

Table 5-3: MNGP Maximum GMRS/SSEREG1.sa Ratio (SF) Freq. (Hz) GMRS (g) Horizontal SSE REG1.so (g) SF= GMRS/SSE 1.00 0.038 0.177 0.21

---

1.25 0.048 0.221 0.22 ----------

---

1.50 0.060 0.256 0.23 2.00 0.091 0.313 0.29 ****-------

... --2.50 0.119 0.376 0.32 3.00 0.143 0.366 0.39 -*-*--------

3.50 0.164 0.358 0.46 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Freq. (Hz) GMRS (g) Horizontal SSE REG1.6o (g) 4.00 0.184 0.351 5.00 0.215 0.340 6.00 0.263 0.332 7.00 0.294 0.325 --8.00 0.302 0.318 --*-

9.00 0.313 0.313 -------

---

10.00 0.324 0.290 Sheet 17 of 54 Revision 2 SF= GMRS/SSE 0.52 0.63 0.79 --------*--

0.91 0.95 --*-**--------------*-*

1.00 ----------

1.12 As shown above, the maximum GMRS/SSEREG1.6o ratio for MNGP occurs at 10 Hz and equals 1.12. The resulting 5% damped RLGMREG1.6o, based on scaling the horizontal SSEREG1.6o by the SF of 1.12, is shown in Table 5-4 and Figure 5-2 below. Note that the RLGMREG1.6o PGA is 0.134g. Table 5-4: MNGP RLGMREG1.so Freq. (Hz) 5% damped Horizontal RLGM REG1.60 (g) 0.20 0.041 0.30 0.074 0.40 0.093 0.50 0.112 -----0.60 0.130 0.70 0.148 0.80 0.165 0.90 0.182 1.00 0.198 1.10 0.214 1.20 0.230 1.30 0.246 1.40 0.261 1.50 0.276 1.60 0.291 --------1.70 0.306 ---------* 1.80 0.321 1.90 0.336 2.00 0.350 2.10 0.364 2.20 0.379 2.30 0.393 ------------------2.40 0.407 2.50 0.421 2.60 0.418 2.70 0.416 2.80 0.414 ------2.90 0.412 3.00 0.410 3.15 0.407 ------------------------------

3.30 0.404 3.45 0.402 3.60 0.399 3.80 0.396 4.00 0.394

---

Stevenson

& Associates Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Freq. (Hz) 5% damped Horizontal RLGM REG1.60 (g) 4.20 0.391 -------------4.40 0.388 4.60 0.386 ---4.80 0.383 5.00 0.381 -5.25 0.379 5.50 0.376 5.75 0.374 6.00 0.372 -------6.25 0.369 6.50 0.367 6.75 0.365 ------7.00 0.364 ----7.25 0.362 ----7.50 0.360 -------7.75 0.358 --*-* 8.00 0.357 8.50 0.354 9.00 0.351 9.50 0.337 10.00 0.325 10.50 0.313 11.00 0.302 11.50 0.293 -----------12.00 0.284 12.50 0.275 ----------13.00 0.267 13.50 0.260 ----------

14.00 0.253 14.50 0.247 ---------------*-

---

15.00 0.241 16.00 0.229 17.00 0.219 18.00 0.210 20.00 0.195 22.00 0.181 **--25.00 0.165 28.00 0.152 -----31.00 0.141 34.00 0.134 Sheet 18 of 54 Revision 2 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

§ 6 0.25 "' ] 0.20 u <:( 0.45 ll_ i I i I ! I I i I I I II I I I I I Ill IY I lit--

I I I i

• I I I Ill 1111} 1/ I I I I I lm-II! '\ I I "\ I ' l/v I '\ I ' " ' w !L / I II ' / . I I I IV I I I I Ill -----------*-----

I *--'------

0.40 0.35 0.30 0.15 0.10 0.05 0.00 0 1 10 Frequency (Hz) Figure 5-2: MNGP RLGMREG1.so

5.2 Method

to Estimate ISRS I i I c-! I I ! I 100 Sheet 19 of 54 Revision 2 -GMRS -SSE -RLGMREG1.60 The method used to derive the ESEP in-structure response spectra (ISRS) was to uniformly scale existing based ISRS from 50097-R-001

[17] by the maximum SF from Table 5-1 and Table 5-3 of 1.49 and 1.12, respectively.

ISRS used for the ESEP were developed for the USI A-46 program. Scaled ISRS are calculated for all buildings and elevations where ESEL items are located at MNGP. These scaled ISRS are documented within S&A Calculation 14C4247-CAL-001

[9].

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

6. SEISMIC MARGIN EVALUATION APPROACH Sheet 20 of 54 Revision 2 It is necessary to demonstrate that ESEL items have sufficient seismic capacity to meet or exceed the demand characterized by the RLGM. The seismic capacity is characterized as the highest peak ground acceleration (PGA) for which there is a high confidence of a low probability of failure (HCLPF). The PGA is associated with a particular spectral shape; in this case the 5% damped RLGM spectral shape. The calculated HCLPF capacity must be equal to or greater than the RLGM PGA (0.19g from Table 5-2 and 0.134g from Table 5-4). The criteria for seismic capacity determination are given in Section 5 of EPRI 3002000704

[2]. There are two basic approaches for developing HCLPF capacities:

1. Deterministic approach using the Conservative Deterministic Failure Margin (CDFM) methodology of EPRI NP-6041 [7]. 2. Probabilistic approach using the fragility analysis methodology of EPRI TR-1 03959 [8]. For MNGP, the deterministic approach using the CDFM methodology of EPRI NP-6041 [7] was used to determine HCLPF capacities.

6.1 Summary

of Methodologies Used MNGP conservatively applied the methodology of EPRI NP-6041 [7] to all items on the ESEL. The screening walkdowns used the screening tables from Chapter 2 of EPRI NP-6041 [7]. The walkdowns were conducted by engineers who as a minimum attended the SQUG Walkdown Screening and Seismic Evaluation Training Course. The walkdowns were documented on Screening Evaluation Work Sheets from EPRI NP-6041 [7]. Anchorage capacity calculations used the CDFM criteria from EPRI NP-6041 [7] with MNGP specific allowables and material strengths used as applicable.

The input seismic demand used was the RLGM shown in Table 5-2, Figure 5-1, Table 5-4 and Figure 5-2. 6.2 HCLPF Screening Process From the two tables Table 5-2 and Table 5-4, the maximum spectral peak of the RLGM for MNGP equals 0.46g. Screening lanes 1 and 2 in Table 2-4 of NP-6041 [7] are bounded by peak spectral accelerations of 0.8g and 1.2g, respectively.

Both lane limits exceed the RLGM peak spectral acceleration.

MNGP ESEL components were screened to lane 1 of Table 2-4 in NP-6041 [7]. For components located 40' above grade, screening based on ground peak spectral acceleration is not applicable and additional consideration is required.

However, only three items are located above 40' above grade. The three items are two (2) temperature elements and one (1) pressure transmitter.

These types of components are inherently seismically rugged. The ESEL contains 83 valves, both power operated and relief. In accordance with Table 2-4 of EPRI NP-6041 [7], active valves may be assigned a functional capacity of 0.8g peak spectral acceleration without any review other than looking for valves with large extended operators on small diameter piping, and anchorage is not a failure mode. Therefore, valves on the ESEL may be screened out from ESEP seismic capacity determination, subject to the caveat regarding large extended operators on small diameter piping. Power operated valves were addressed in the USI A-46 program. These valves were walked down extensively and were evaluated per plant documentations when deemed necessary.

In addition, the SRT performed a walkdown and reviewed plant valve drawings for most of the valves, and determined they met the intent of Table 2-4 of EPRI NP-6041 [7]. The non-valve components in the ESEL are generally screened based on the USI A-46 results. Where possible, the results of the USI A-46 analysis were scaled. If the scaling approach was not straight forward, then a more detailed analysis was performed and presented in S&A Calculation 14C4247-CAL-002

[10]. 6.3 Seismic Walkdown Approach 6.3.1 Walkdown Approach Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 21 of 54 Revision 2 Walkdowns for MNGP were performed in accordance with the criteria provided in Section 5 of EPRI 3002000704

[2], which refers to EPRI NP-6041 [7] for the Seismic Margin Assessment process. Pg. 2-26 through 2-30 of EPRI NP-6041 [7] describes the seismic walkdown criteria, including the following key criteria: "The SRT [Seismic Review Team] should "walk by" 100% of all components which are reasonably accessible and in non-radioactive or low radioactive environments.

Seismic capability assessment of components which are inaccessible, in high-radioactive environments, or possibly within contaminated containment, will have to rely more on alternate means such as photographic inspection, more reliance on seismic reanalysis, and possibly, smaller inspection teams and more hurried inspections.

A 100% "walk by" does not mean complete inspection of each component, nor does it mean requiring an electrician or other technician to de-energize and open cabinets or panels for detailed inspection of all components.

This wa/kdown is not intended to be a QA or QC review or a review of the adequacy of the component at the SSE level. If the SRT has a reasonable basis for assuming that the group of components are similar and are similarly anchored, then it is only necessary to inspect one component out of this group. The basis" should be developed before the walkdown during the seismic capability preparatory work (Step 3) by reference to drawings, calculations or specifications.

The one component or each type which is selected should be thoroughly inspected which probably does mean de-energizing and opening cabinets or panels for this very limited sample. Generally, a spare representative component can be found so as to enable the inspection to be performed while the plant is in operation.

At least for the one component of each type which is selected, anchorage should be thoroughly inspected.

The walkdown procedure should be performed in an ad hoc manner. For each class of components the SRT should look closely at the first items and compare the field configurations with the construction drawings and/or specifications.

If a one-to-one correspondence is found, then subsequent items do not have to be inspected in as great a detail. Ultimately the wa/kdown becomes a "walk by" of the component class as the SRT becomes confident that the construction pattern is typical. This procedure for inspection should be repeated for each component class; although, during the actual wa/kdown the SRT may be inspecting several classes of components in parallel.

If serious exceptions to the drawings or questionable construction practices are found then the system or component class must be inspected in closer detail until the systematic deficiency is defined. The 100% "walk by" is to look for outliers, lack of similarity, anchorage which is different from that shown on drawings or prescribed in criteria for that component, potential Sf [Seismic Interaction]

problems, situations that are at odds with the team members' past experience, and any other areas of serious seismic concern. If any such concerns surface, then the limited sample size of one component of each type for thorough inspection will have to be increased.

The increase in sample size which should be inspected will depend upon the number of outliers and different anchorages, etc., which are observed.

It is up to the SRT to ultimately select the sample size since they are the ones who are responsible for the seismic adequacy of all elements which they screen from the margin review. Appendix D gives guidance for sampling selection.

The MNGP walkdowns included, as a minimum, a 100% walk-by of all "existing" items on the MNGP ESEL except as noted in Section 7. Any previous walkdown information that was relied upon as the basis for SRT judgment in excluding an item walkdown is documented in Section 6.3.2. 6.3.2 Application of Previous Walkdown Information The seismic walkdowns for MNGP included, as a minimum, a walk-by of all the components on the ESEL by the SRT with the exception of the items inside Drywell or high radiation locations as they were not accessible at the time of the walkdowns:

Fluid-Operated Valves (RV-3242A, RV-3243A, RV-3244A, RV-3245A, RV-7440A, RV-7441A, RV-7467A, RV-7468A)

Fluid-Operator Valves (A0-2386 & A0-2387) Motor Operated and Solenoid-Operated Valves (M0-2035, M0-2076, SV-2-71A-SV-2-71M)

Temperature Elements (TE-4247 A-TE-4247H)

Accumulators (T-57A-T-57H)

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates A detailed discussion and resolution for each item listed above is provided in Section 7. Sheet 22 of 54 Revision 2 Previous seismic walkdowns were used to support the ESEP seismic evaluations.

Some of the components on the ESEL were included in the NTTF 2.3 seismic walkdowns

[15]. Those walkdowns were recent enough that they did not need to be repeated for the ESEP. Several ESEL items were previously walked down during the MNGP USI A-46 evaluation.

Those walkdown results were reviewed and the following steps were taken to confirm that the previous walkdown conclusions remained valid. " A walk by was performed to confirm that the equipment material condition and configuration is consistent with the walkdown conclusions and that no new significant interactions related to block walls or piping attached to tanks exists. " If the ESEL item was screened out based on the previous walkdown, that screening evaluation was reviewed and reconfirmed for the ESEP. 6.3.3 Significant Walkdown Findings Consistent with that guidance from NP-6041 [7], no significant outliers or anchorage concerns were identified during the MNGP ESEP walkdowns.

The following findings were noted during the walkdowns. " Masonry walls and columns were identified in the proximity of ESEL equipment.

These masonry walls and columns were assessed for their structural adequacy to withstand the seismic loads resulting from the RLGM. For any cases where the block wall represented the HCLPF failure mode for an ESEL item, it is noted in the tabulated HCLPF values described in Attachment B. 6.4 HCLPF Calculation Process ESEL items were evaluated using the criteria in EPRI NP-6041 [7]. Those evaluations included the following -* Performing seismic capability walkdowns for equipment to evaluate the equipment installed plant conditions " Performing screening evaluations using the screening tables in EPRI NP-6041 [7) as described in Section 6.2 " Performing HCLPF calculations considering various failure modes that include both structural (e.g. anchorage, load path etc.) and functional failure modes. All HCLPF calculations were performed using the CDFM methodology and are documented in S&A Calculation 14C4247-CAL-002

[10). Anchorage configurations for non-valve components were evaluated either by SRT judgment, large margins in existing design basis calculations, or CDFM based HCLPF calculations

[1 0]. The results of these analysis methods are documented in Attachment B. For components beyond 40' above grade, Table 2-4 of NP-6041 [7) is not directly applicable.

ESEP equipment items which are beyond 40ft above grade are located in the Reactor Building (RX) at elevation 985' & 994'. However, the three components are pressure transmitter (PT-72518) and temperature elements (TE-4247G

& TE-4247H).

These types of components are inherently seismically rugged and were ruggedly attached to structural components.

As described in Section 6.0, for HCLPF calculations the Conservative Deterministic Failure Margin (CDFM) analysis criteria established in Section 6 of EPRI NP-6041 [7) are used for a detailed analysis of components.

The relevant CDFM criteria from EPRI NP-6041 [7] are summarized in Table 6-1.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Table 6-1: MNGP Maximum GMRS/SSE Ratio (SF) Load combination:

Normal + seismic margin earthquake (SME) Ground response spectrum:

Conservatively specified (84% non-exceedance probability)

Damping: Conservative estimate of median damping. Structural model: Best estimate (median) + uncertainty variation in frequency.

Soil-structure interaction Best estimate (median) + parameter variation Material strength:

Code specified minimum strength or 95% exceedance of actual strength if test data is available.

Code ultimate strength (ACI), maximum strength (AISC), Service Level 0 (ASME) or functional limits. If test data Static capacity equations:

is available to demonstrate excessive conservatism of code equations then use 84% exceedance of test data for capacity equations.

For non-brittle failure modes and linear analysis, use Inelastic energy absorption:

80% of computed seismic stress in capacity evaluation to account for ductility benefits or perform nonlinear analysis and use 95% exceedance ductility levels. In-structure (floor) spectra Use frequency shifting rather than peak broadening to generation:

account for uncertainty and use median damping. Sheet 23 of 54 Revision 2 The HCLPF capacity is equal to the PGA at which the strength limit is reached. The HCLPF earthquake load is calculated as follows: U = Normal + Ec Where:

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

• Ec = HCLPF earthquake load " Normal = Normal operating loads (dead and live load expected to be present, etc.) For this calculation, the HCLPF earthquake load is related to a fixed reference earthquake:

Ec = SFc*Eref Where: " Eref = reference earthquake from the relevant in-structure response spectrum (ISRS) " SFc = component-specific scale factor that satisfies U = Normal +Ec The HCLPF will be defined as the PGA produced by Ec. Because the MNGP RLGM PGA is 0.19g or 0.134g depending on building:

HCLPFrAFt

= 0.19g*SFc HCLPFREG1.6o

= 0.134g*SFc

6.5 Functional

Evaluation of Relays A HCLPF evaluation is performed for all relays and switches which may negatively "seal in" or "lock out" on the MNGP ESEL [19].

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates For relay evaluations, NP-6041-SL Appendix Q describes the following steps: " Calculate in-cabinet response spectra (ICRS): " Establish a clipping factor to be applied to the ICRS: " Determine a relay's GERS Capacity: " Establish adjustment factors to convert the relay's GERS capacity to a CDFM level: .. Compare clipped-peak and ZPA demands to the GERS capacity:

Sheet 24 of 54 Revision 2 The ESEL has 26 relays and 49 switches that have chatter concerns [20] -[25]. HCLPF capacities for these components are calculated in S&A Calculation 14C4247-CAL-004

[27] and are presented in Attachment B. 6.6 Tabulated ESEL HCLPF Values (Including Key Failure Modes) Tabulated ESEL HCLPF values including the key failure modes are included in Attachment B following the criteria below: " For items screened out using NP 6041 [7] screening tables, the HCLPF is listed as "> RLGM" (> 0.19g or 0.134g, depending on building location) and the failure mode is "Screened out" ., For items where anchorage controls the HCLPF value, the anchorage HCLPF value is listed in the table and the failure mode is set to "Anchorage Capacity" " For Items whose capacities were controlled by nearby block walls as the nearby block wall capacities were lower than the equipment and the anchorage capacities, the failure mode is noted as "Block Wall Capacity" and the block wall HCLPF value is listed " For items where a relay or switch HCLPF controls, the relay or switch HCLPF value is listed in the table and the failure mode is set to "Functionality Capacity"

• For items where an equipment capacity is based upon the screening lane values of Table 2-4 of ERPI NP-6041 [7] controls the HCLPF value (e.g. anchorage or relay HCLPF capacity exceeds the equipment capacity derived from screening lanes), the screening lane HCLPF value is listed in the table and the failure mode is set to "Equipment Capacity".

Based on NP-6041 Table 2-4 lane 1, this limit is equal to 0.33g (RLGMTAFT) and 0.25g (RLGMREG1.so) for items below 40 feet above grade. The "Equipment Capacity" limits from above are calculated as follows: The upper-bound spectral peak to NP-6041 Table 2-4 lane 1 is 0.8g. From Table 5-2 and Table 5-4, the RLGM spectral peak is 0.46g for RLGMTAFT and 0.421 g for RLGMREG1.so, and the PGA is 0.19g for RLGMTAFT and 0.134g for RLGMREG1.so.

Thus, for equipment less than 40 feet above grade, the "Equipment Capacity" HCLPF is limited to 0.8/0.46*0.19

= 0.33g for RLGMTAFT and 0.8/0.421

• 0.134 = 0.25g for RLGMREG1.so.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

7. INACCESSIBLE ITEMS 7.1 Identification of ESEL Items Inaccessible for Walkdowns Sheet 25 of 54 Revision 2 All items located inside the Drywell or high radiation locations were inaccessible.

A description of circumstances and disposition for each of these items is provided below. Fluid-Operated Valves (RV-2-71A-RV-2-71 H) These items were walked down during the MNGP USI A-46 evaluation.

The Screening Evaluation Work Sheet (SEWS) provides detailed description of the valves and includes photos. The valves have no vulnerabilities.

In addition, valve drawings were reviewed.

This inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Fluid-Operated Valves (RV-3242A, RV-3243A, RV-3244A, RV-3245A.

RV-7440A, RV-7441A, RV-7467A, RV-7468A) These items were walked down during the MNGP USI A-46 evaluation.

The SEWS provide detailed description of the valves and includes photos. The small valves have no operators or vulnerabilities.

In addition, valve drawings were reviewed.

This inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Fluid-Operator Valves (A0-2386 & A0-2387) These items were walked down during the MNGP USI A-46 evaluation.

The SEWS provide detailed description of the valves and includes photos. The valves have no vulnerabilities.

In addition, valve drawings were reviewed.

This inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Motor Operated and Solenoid-Operated Valves (M0-2035, M0-2076. SV-2-71A-SV-2-71 M) Same as the fluid operated valves, these motor-operated and solenoid-operated valves were evaluated during the MNGP USI A-46 evaluation.

The SEWS provide detailed description of the valves and includes photos. In addition, valve drawings were also reviewed.

This inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Temperature Elements (TE-4247 A-TE-4247H)

These temperature elements were evaluated during the MNGP USI A-46 evaluation.

The SEWS provided detailed description of the valves and include photos. These items are inherently seismically rugged and the notes state the items are securely attached to structural components.

No other vulnerabilities are noticed. The inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Accumulators (T-57A-These accumulators were evaluated during the MNGP USI A-46 evaluation.

The SEWS state the 2 large U bolts typically to the structural steel was acceptable due to their large margin. The photos also confirm the accumulators are secured. Therefore, these items were judged to be acceptable by the SRT. 7.2 Planned Walkdown I Evaluation Schedule I Close Out No additional walkdowns are required.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

8. ESEP CONCLUSIONS AND RESULTS 8.1 Supporting Information Sheet 26 of 54 Revision 2 MNGP has performed the ESEP as an interim action in response to the NRC's 50.54(f) letter [1]. It was performed using the methodologies in the NRC endorsed guidance in EPRI 3002000704

[2]. The ESEP provides an important demonstration of seismic margin and expedites plant safety enhancements through evaluations and potential near-term modifications of plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events. The ESEP is part of the overall MNGP response to the NRC's 50.54(f) letter [1]. On March 12,2014, NEI submitted to the NRC results of a study [12] of seismic core damage risk estimates based on updated seismic hazard information as it applies to operating nuclear reactors in the Central and Eastern United States (CEUS). The study concluded that "site-specific seismic hazards show that there has not been an overall increase in seismic risk for the fleet of U.S. plants" based on the re-evaluated seismic hazards. As such, the "current seismic design of operating reactors continues to provide a safety margin to withstand potential earthquakes exceeding the seismic design basis." The NRC's May 9, 2014 NTTF 2.1 Screening and Prioritization letter [13] concluded that the "fleet wide seismic risk estimates are consistent with the approach and results used in the Gl-199 safety/risk assessment." The letter also stated that "As a result, the staff has confirmed that the conclusions reached in Gl-199 safety/risk assessment remain valid and that the plants can continue to operate while additional evaluations are conducted." An assessment of the change in seismic risk for MNGP was included in the fleet risk evaluation submitted in the March 12, 2014 NEIIetter

[12] therefore, the conclusions in the NRC's May 9 letter [13] also apply to MNGP. In addition, the March 12, 2014 NEIIetter

[12] provided an attached "Perspectives on the Seismic Capacity of Operating Plants," which (1) assessed a number of qualitative reasons why the design of Structures, Systems, and Components (SSCs) inherently contain margin beyond their design level, (2) discussed industrial seismic experience databases of performance of industry facility components similar to nuclear SSCs, and (3) discussed earthquake experience at operating plants. The fleet of currently operating nuclear power plants was designed using conservative practices, such that the plants have significant margin to withstand large ground motions safely. This has been borne out of those plants that have actually experienced significant earthquakes.

The seismic design process has inherent (and intentional) conservatisms which result in significant seismic margins within SSCs. These conservatisms are reflected in several key aspects of the seismic design process, including: " Safety factors applied in design calculations " Damping values used in the dynamic analysis of SSCs

• Bounding synthetic time histories for in-structure response spectra calculations " Broadening criteria for in-structure response spectra " Response spectra enveloping criteria typically used in SSC analysis and testing applications " Response spectra based frequency domain analysis rather than explicit time history based time domain analysis " Bounding requirements in codes and standards " Use of minimum strength requirements of structural components (concrete and steel) " Bounding testing requirements, and .. Ductile behavior of the primary materials (that is, not crediting the additional capacity of materials such as steel and reinforced concrete beyond the essentially elastic range, etc.). These design practices combine to result in margins such that the SSCs will continue to fulfill their functions at ground motions well above the SSE.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

8.2 Identification

of Items Requiring Further Resolution Sheet 27 of 54 Revision 2 Insights from the ESEP identified the following potential items where the HCLPF is below the RLGM. A more detailed analysis may result in a HCLPF that exceeds the RLGM for these components.

If not, modifications or other measures will be considered to provide additional seismic margin such that the HCLPF will exceed the RLGM. 1. RHR Heat Exchanger E-2008 has a HCLPF capacity below the RLGM. High strength bolts are used throughout the supporting frame, except for the connection between the heat exchanger supporting frame and the heat exchanger itself. The A307 bolts connecting the heat exchanger support frame and the heat exchanger are currently overstressed by 5%. A potential modification would be to change the existing A307 bolts to an A325 or equivalent to provide the additional seismic margin required.

2. Relays with very low capacities in specific configurations are known as "bad actors". These relays have been shown to perform poorly seismically.

All inadequate relays have contacts which are both normally open and normally closed; thus, the (lower) normally closed capacity was used throughout the evaluation.

Further evaluation may show that the chatter of the normally closed contacts for these relays would not negatively impact the FLEX plan; then these relays could be qualified.

MNGP may also be able to determine that operator actions I workarounds exist for these relays or that they are not truly essential to the success of the FLEX strategy (i.e. removal from ESEL). The following are the list of relays that do not screen out. .. 13A-K13 .. 13A-K14 .. 13A-K17 .. 13A-K3

• 13A-K5

• 13A-K29 .. 13A-K30

• 13A-K28 Relay K1 028 is located in the EFT building at Elevation 960', where the in-structure cabinet response exceeds the capacity.

Solutions which may be considered are to stiffen or replace host cabinet (C-3038), relocate the subject relay to a more seismically favorable location, replace the subject relay with a compatible relay model or determine a higher capacity by shake table testing of this relay model. " K1028 3. The following are switches without capacity data or where capacity data is insufficient.

MNGP may seek other measures, i.e., contacting the switch manufacturer and/or look for guidance within the industry, replacing the subject with a compatible model or determine capacity by shake table testing of these items. This applies to the following switches.

• dPIS-13-83 " dPIS-13-84

• PS-13-87A

• PS-13-878 " PS-13-87C " PS-13-870 " LIS-2-3-672A

• LIS-2-3-6728 " LIS-2-3-672C

• LIS-2-3-6720

• LS-2-3-672E

.. LS-2-3-672F Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates " LS-23-74 " LS-23-75 8.3 Implementation Schedule Sheet 28 of 54 Revision 2 Per Sec. 8.2, further analysis is warranted for components with HCLPF < RLGM. If more detailed analysis methods cannot produce a HCLPF > RLGM, a modification will be performed.

Plant modifications will be performed in accordance with the schedule identified in NEIIetter dated April 9, 2013 [28], which states that plant modifications not requiring a planned refueling outage will be completed by December 2016 and modifications requiring a refueling outage will be completed within two planned refueling outages after December31, 2014. 8.4 Summary of Regulatory Commitments No regulatory commitments are being made but the equipment identified in Section 8.2 are included in the MNGP corrective action program and will be resolved accordingly.

Stevenson

& Associates

9. REFERENCES Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 29 of 54 Revision 2 NRC (E Leeds and M Johnson) Letter to All Power Reactor Licensees et al., "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3 and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," March 12, 2012. 2 Seismic Evaluation Guidance:

Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1 -Seismic.

EPRI, Palo Alto, CA: May 2013. 3002000704.

3 Order Number EA-12-049 responses:

3.1 NRC Letter L-MT-13-017 from NSPM (ML 13066A066), "Monticello Nuclear Generating Plant's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)", February 28, 2013. 3.2 NRC Letter L-MT-13-079 from NSPM (ML 13241A200), "Monticello's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)", August 28, 2013. 3.3 NRC Letter L-MT-14-014 from NSPM (ML 14065A037), "Monticello Nuclear Generating Plant's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events (Order Number EA-12-049)", February 28, 2014. 3.4 NRC Letter L-MT-14-073 from NSPM (ML 14241A262), "Monticello Nuclear Generating Plant's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events (Order Number EA-12-049)", August 28, 2014. 4 14C4229-RPT-001 Rev. 2 (ML 14136A289), "Monticello Nuclear Generating Plant Seismic Hazard and Screening Report", May 12, 2014 5 Nuclear Regulatory Commission, NUREG-1407, Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, June 1991. 6 Nuclear Regulatory Commission, Generic Letter No. 88-20 Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities-1 OCFR 50.54(f), June 1991. 7 A Methodology for Assessment of Nuclear Power Plant Seismic Margin, Rev. 1, August 1991, Electric Power Research Institute, Palo Alto, CA. EPRI NP 6041. 8 Methodology for Developing Seismic Fragilities, August 1991, EPRI, Palo Alto, CA. 1994, TR-1 03959. 9 S&A Calculation No. 14C4247-CAL-001 Rev O,"Generation of In-Structure Response Spectra for Use in ESEP Evaluations" 10 S&A Calculation No. 14C4247-CAL-002 Rev O,"HCLPF Analysis for ESEP Evaluations for MNGP" 11 Nuclear Regulatory Commission, NUREG/CR-0098, Development of Criteria for Seismic Review of Selected Nuclear Power Plants, published May 1978. 12 Nuclear Energy Institute (NEI), A Pietrangelo, Letter to D. Skeen of the USNRC, "Seismic Core Damage Risk Estimates Using the Updated Seismic Hazards for the Operating Nuclear Plants in the Central and Eastern United States", March 12, 2014. 13 NRC (E Leeds) Letter to All Power Reactor Licensees et al., "Screening and Prioritization Results Regarding Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(F) Regarding Seismic Hazard Re-Evaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-lchi Accident," May 9, 2014. 14 Seismic Evaluation Guidance:

Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic. EPRI, Palo Alto, CA: February 2013. 1025287. 15 NRC Letter L-MT-13-051 from NSPM (ML 13263A032), "MNGP Updated Final Response to NRC Request for Information Pursuaht to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated September 16, 2013. 16 NSP Letter to NRC "Response to Supplement 1 to Generic Letter 87-02, Submittal of A-46 Seismic Evaluation Report (T AC M69460)", November 20 1 h, 1995 17 MNGP Calc. No.92-369, "Monticello Nuclear Generating Plant Reactor Building In-Structure Response Spectra", Rev. 1, September, 1992 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 30 of 54 Revision 2 18 Seismic Fragility Applications Guide Update, December 2009, EPRI, Palo Alto, CA. 1994, 1019200. 19 NSPM Calculation (Doc) No.: 14-053 Rev 0, "Monticello FLEX Expedited Seismic Equipment List (ESEL)" 20 Xcel Energy Design Information Transmittal (DIT) No: 24221-04, "Expedited Seismic Equipment List (ESEL), 10/27/2014 21 Xcel Energy Design Information Transmittal (DIT) No: 24221-05, "Expedited Seismic Equipment List (ESEL), 11/07/2014 22 Xcel Energy Design Information Transmittal (DIT) No: 24221-06, "Expedited Seismic Equipment List (ESEL), 11/19/2014 23 Xcel Energy Design Information Transmittal (DIT) No: 24221-07, "Expedited Seismic Equipment List (ESEL), 11/19/2014 24 Xcel Energy Design Information Transmittal (DIT) No.24221-08, "Expedited Seismic Equipment Process (ESEP) Report", 12/11/2014 25 Xcel Energy Design Information Transmittal (DIT) No.24221-09, "Expedited Seismic Equipment Process (ESEP) Report", 12/12/2014 26 Xcel Energy Design Information Transmittal (DIT) No.24221-1 0, "Expedited Seismic Equipment Process (ESEP) Report", 12/4/2014 27 S&A Calculation No. 14C4247-CAL-004 Rev O,"ESEP HCLPFs for Relays" 28 Nuclear Energy Institute (NEI), A. Pietrangelo, Letter to D. Skeen of the USNRC, "Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations", April 9, 2013 29 S&A Calculation No. 14C4247-CAL-003 Rev 0, "ESEP Block Wall HCLPFs" 30 S&A Report No. 14C4247-RPT-001 Rev 0, "Monticello ESEP SEWS Report" Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates ATTACHMENT A-MNGP ESEL Sheet 31 of 54 Revision 2 Stevenson

& Associates Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 32 of 54 Revision 2 Table A-1 presents the MNGP ESEL. The selection process for items on this list is described in Section 3. Note that below, the "Normal State" and "Desired State" were determined when it was material to evaluating the seismic capacity of the component.

In other cases, those columns are left blank. Table A-1: MNGP ESEL [19] ESEL Equipment Operating State Item ID Description Normal State Desired State Notes/Comments Ilium 1 E-200A RHR DIV 1 HEAT EXCHANGER 2 E-200B RHR DIV 2 HEAT EXCHANGER RCIC TORUS SUCTION Interlocks w/M0-2102 (See NX-7822-5, 3 M0-2100 INBOARD Closed Open relays 13A-K18 and 13A-K19. M0-2100 (Local) on NX-7822-22-2.

4 M0-2101 RCIC TORUS SUCTION Closed Open M0-2101 (Local) on NX-7822-22-2.

OUTBOARD 5 RV-2103 RCIC PUMP SUCTION RELIEF VALVE 6 P-207 RCIC PUMP 7 M0-2106 RCIC PUMP DISCHARGE Closed Open Open on Rx Vessel Lvl Low OUTBOARD 8 M0-2107 RCIC PUMP DISCHARGE Closed Open Open on Rx Vessel Lvl Low INBOARD 9 M0-2110 RCIC TEST FLOW Closed Closed Close on Reactor Vessel Low-low Lvl or ISOLATION M0-2100 or M0-2101 Open Full 10 M0-3502 RCIC TEST RETURN Closed Closed Close on Reactor Vessel Low-low Lvl or ISOLATION M0-2100 or M0-2101 Open Full 11 CV-2104 RCIC PUMP MINIMUM Closed Open Fails Open on Loss of Air FLOW RCIC COOLING WATER 12 PCV-2092 TO BAROMETRIC CONDENSER RCIC BAROMETRIC Close on Rx Vessel Lvl High/Open on 13 M0-2096 CONDENSER COOLING Closed Open WATER SUPPLY Rx Vessel Lvl* Low COOLING WATER TO 14 RV-2097 BAROMETRIC CONDENSER RELIEF VALVE 15 E-205 RCIC OIL COOLER 16 E-203 RCIC BAROMETRIC CONDENSER RCIC TURBINE 17 P-210 BAROMETRIC Standby Operating CONDENSER CONDENSATE PUMP RCIC BAROMETRIC 18 P-211 CONDENSER VACUUM Standby Operating PUMP 19 M0-2076 RCIC STEAM LINE Open Open Close on High Flow/Open on Reactor ISOLATION OUTBOARD vessel Low Level/Steam line Monitoring 20 M0-2078 RCIC TURBINE STEAM Closed Open Close on Rx Vessel Lvl High/Open on SUPPLY Rx Vessel Lvl Low 21 M0-2080 RCIC TURBINE TRIP Open Open Close on .Turbine Trip RESET MOTOR (H0-7)

Stevenson

& Associates ESEL Item ID Num 22 H0-8 23 S-200 24 T-73 25 SV-2104 26 SV-2848 27 SV-2849 28 SV-2082A 29 SV-2082B 30 RV-1745 31 RV-2-71 H 32 SV-2-71 H 33 SV-2-71L 34 RV-2-71C 35 SV-2-71C 36 RV-2-71D 37 SV-2-71D 38 T-57C 39 T-57D 40 T-57H 41 T-57F 42 RV-2-71F 43 SV-2-71F 44 SV-2-71M 45 RV-2-71E 46 SV-2-71E 47 SV-2-71J 48 RV-2-71A 49 SV-2-71A 50 RV-2-71B 51 SV-2-71B 52 RV-2-71G 53 SV-2-71G 54 SV-2-71K 55 T-57A Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report . Equipment Operating State Description Normal State Desired State RCIC TURBINE GOVERNING VALVE RCIC TERRY TURBINE CV-2104 MINIMUM FLOW VALVE ACCUMULATOR TANK CV-2104 SOLENOID CV-2848 SOLENOID CV-2849 SOLENOID CV-2082A SOLENOID CV-2082B SOLENOID 11 CORE SPRAY PUMP DISCHARGE RELIEF VALVE H SRV H SRV AIR OPERATOR sv H SRV ASDS AIR OPERATORSV CSRV C SRV AIR OPERATOR sv DSRV D SRV AIR OPERATOR sv PRI STEAM SRV D ACCUMULATOR PRI STEAM SRV D ACCUMULATOR PRI STEAM SRV D ACCUMULATOR PRI STEAM SRV D ACCUMULATOR F SRV F SRV AIR OPERATOR sv F SRV ASDS AIR OPERATORSV ESRV E SRV AIR OPERATOR sv E SRV ASDS AIR OPERATORSV ASRV A SRV AIR OPERATOR sv BSRV B SRV AIR OPERATOR sv GSRV G SRV AIR OPERATOR sv G SRV ASDS AIR OPERATORSV PRI STEAM SRV G ACCUMULATOR Sheet 33 of 54 Revision 2 Notes/Comments Stevenson

& Associates ESEL Item ID Num 56 T-57B 57 T-57E 58 T-57G 59 RV-3243A 60 RV-7467A 61 RV-7440A 62 RV-3242A 63 RV-7468A 64 RV-3244A 65 RV-3245A 66 RV-7441A 67 M0-2035 68 CV-3503 69 M0-2071 70 PT-13-65 71 Pl-13-96 72 PS-13-67A 73 PT-13-60 74 Pl-13-93 75 FS-13-57 76 FT-13-58 77 FIC-13-91 78 Fl-13-91 79 FY-13-1 02 80 LS-7323 81 dPIS-13-83 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State . PRI STEAM SRV G ACCUMULATOR PRI STEAM SRV G ACCUMULATOR PRI STEAM SRV G ACCUMULATOR B SRV DISCH 8" VAG RV G SRV DISCH 8" VAG RV E SRV DISCH 8" VAG RV A SRV DISCH 8" VAG RV H SRV DISCH 8" VAG RV C SRV DISCH 8" VAG RV D SRV DISCH 8" VAG RV F SRV DISCH 8" VAG RV HPCI STEAM LINE ISOLATION OUTBOARD Open Closed HPCI TEST RETURN FLOW HPCI TEST RETURN Closed Closed ISOLATION RCIC PUMP SUCTION PRESSURE RCIC PUMP SUCTION RCIC LOW PUMP SUCTION PRESSURE energized energized TURBINE TRIP RCIC PUMP DISCHARGE PRESSURE RCIC PUMP DISCHARGE RCIC PUMP DISCHARGE MINIMUM FLOW energized energized CONTROL RCIC PUMP DISCHARGE FLOW CONTROL RCIC PUMP FLOW RCIC FLOW RCIC PUMP FLOW LOOP ISOLATOR RCIC CONDENSER HIGH VACUUM TANK LEVEL ALARM RCIC HIGH STEAM FLOW energized energized ISOLATION Sheet 34 of 54 Revision 2 Notes/Comments HPCIInitiated on Lo-Lo Reactor Water or High Drywell Pressure (OPEN)/Ciose on High Flow/Close on Steam Leak.1 See Footnote 1. See Footnote 1. Control Room Indication RCIC Turbine Trip Control Room Indication RCIC Turbine Control Logic 1 valves M0-2035, M0-2071 and CV-3503 are included as part of the ESEL, because although not credited in any FLEX strategy, HPCI is safety-related and would automatically initiate in the event of an SBO, and would be secured as part of the. ELAP procedures.

The test line return path to the CST represents a potential problem for implementation of FLEX strategies because any water that is directed from the Torus to the CST would be lost should either valve fail to close. Therefore, the HPCI test line valves were included in the ESEL to ensure that if HPCI runs prior to being secured; the flow is only directed to the reactor or Torus. M0-2035 is closed as part of SBO procedures.

Stevenson

& Associates ESEL Item ID Num 82 dPIS-13-84 83 PS-13-87A 84 PS-13-87B 85 PS-13-87C 86 PS-13-870 87 TS-13-79A-1 88 TS-13-79A-2 89 TS-13-79B-1 90 TS-13-79B-2 91 TS-13-79C-1 92 TS-13-79C-2 93 TS-13-790-1 94 TS-13-790-2 95 TS-13-80A-1 96 TS-13-80B-1 97 TS-13-80C-1 98 TS-13-800-1 99 TS-13-81A-1 100 TS-13-81 B-1 101 TS-13-81C-1 102 TS-13-81 0-1 103 TS-13-82A-1 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State RCIC HIGH STEAM FLOW energized energized ISOLATION RCIC TURBINE STEAM SUPPLY LOW PRESS energized energized ISOLATION RCIC TURBINE STEAM SUPPLY LOW PRESS energized energized ISOLATION RCIC TURBINE STEAM SUPPLY LOW PRESS energized energized ISOLATION RCIC TURBINE STEAM SUPPLY LOW PRESS energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION Sheet 35 of 54 Revision 2 Notes!Comments Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Stevenson

& Associates ESEL Item ID Num 104 TS-13-82B-1 105 TS-13-82C-1 106 TS-13-82D-1 107 TS-13-80A-2 108 TS-13-80B-2 109 TS-13-80C-2 110 TS-13-80D-2 111 TS-13-81 A-2 112 TS-13-81 B-2 113 TS-13-81 C-2 114 TS-13-810-2 115 TS-13-82A-2 116 TS-13-82B-2 117 TS-13-82C-2 118 TS-13-82D-2 119 PT-13-68 120 Pl-13-94 121 SY-7321 122 SCP-7925 123 SE-7925 124 LS-5 125 PT-13-70 126 Pl-13-95 127 PS-13-72A Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC TURBINE STEAM SUPPLY PRESSURE RCIC TURBINE INLET RCIC TURBINE SPEED SIGNAL CONVERTER RCIC TURBINE SPEED GOVERNOR EGM RCIC TURBINE SPEED MAGNETIC PICKUP RCIC TURBINE OVERSPEED TRIP LEVEL SWITCH RCIC TURBINE EXHAUST PRESSURE RCIC TURBINE EXHAUST RCIC HIGH TURBINE EXHAUST PRESSURE energized energized TURBINE TRIP Sheet 36 of 54 Revision 2 Notes/Comments Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Control Room Indication Control Room Indication Control Room Indication Turbine Trip Stevenson

& Associates ESEL Item ID Num 128 PS-13-72B 129 L T-2-3-61 130 PT-6-53B 131 PI-6-90B 132 LT-2-3-85B 133 LI-2-3-85B 134 LT-2-3-72A 135 LT-2-3-72C 136 LIS-2-3-672A 137 LIS-2-3-672C 138 LS-2-3-672E 2 139 LT-2-3-72B 140 LT-2-3-72D 141 LIS-2-3-672B 142 LIS-2-3-672D 143 LS-2-3-672F 3 144 LT-2-3-85A 145 LI-2-3-85A 146 PT-6-53A 147 PI-6-90A 148 LT-2-3-112B 149 PT-4067B 150 PT-4067D 151 L T 3-112A 152 PT-4067A 153 PT-4067C 154 LS-23-74 155 LS-23-75 156 PCV-4897 157 PCV-4879 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State RCIC HIGH TURBINE EXHAUST PRESSURE energized energized TURBINE TRIP REACTOR FLOODING LEVEL REACTOR PRESSURE WIDE RANGE B (REF COLUMNA) FW REACTOR PRESS TO B LVL CONTROL REACTOR VESSEL WATER LEVEL (FROM COLUMNA) REACTOR VESSEL WATER LEVEL LO LO REACTOR L VL ECCS INITIATION LO LO REACTOR LVL ECCS INITIATION HPCI LO LEVEL START energized energized HPCI LO LEVEL START energized energized HPCI/RCIC HI LVL TURB TRIP LO LO REACTOR LVL ECCS INITIATION LO LO REACTOR LVL ECCS INITIATION HPCI LO LEVEL START energized energized HPCI LO LEVEL START energized energized HPCI/RCIC HI LVL TURB TRIP REACTOR VESSEL WATER LEVEL (FROM COLUMN B) REACTOR VESSEL WATER LEVEL REACTOR PRESSURE WIDE RANGE A (REF COLUMN B) FW REACTOR PRESS TO A LVL CONTROL RX WTR LEVEL B FUEL ZONE (REF COLUMN A) LOWLOWSET REACTOR PRESSURE LOWLOWSET REACTOR PRESSURE RX WTR LEVEL A FUEL ZONE (REF COLUMN B) LOWLOWSET REACTOR PRESSURE LOWLOWSET REACTOR PRESSURE HPCI COND STORAGE TANK INTLK HPCI COND STORAGE TANK INTLK AL T N2 TRAIN A PRESSURE REGULATOR AL T N2 TRAIN A PRESSURE REGULATOR Sheet 37 of 54 Revision 2 Notes/Comments Turbine Trip Control Room Indication Control Room Indication RCIC Pump Suction Transfer Instruments RCIC Pump Suction Transfer Instruments Stevenson

& Associates ESEL Item ID . Num 158 PCV-4903 159 PCV-4904 160 SV-4234 161 RV-4673 162 RV-4878 163 PCV-4898 164 PCV-4881 165 PCV-4905 166 PCV-4906 167 RV-4236 168 SV-4235 169 RV-4880 170 A0-2377 171 A0-2387 172 A0-2896 173 A0-2378 174 A0-2379 175 SV-2379 176 A0-2380 177 SV-2380 178 A0-2381 179 A0-2383 180 A0-2386 181 SV-4539 182 SV-4540 183 SV-4541 184 SV-4542 185 A0-4539 186 A0-4540 187 PS-4662 188 PS-4237 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State .Description Normal State Desired State AL T N2 TRAIN A PRESSURE REGULATOR AL T N2 TRAIN A PRESSURE REGULATOR AL T N2 TRAIN A MANIFOLD ISOLATION AL T N2 TRAIN A MANIFOLD RELIEF AL T N2 TRAIN A RELIEF AL T N2 TRAIN B PRESSURE REGULATOR AL T N2 TRAIN B PRESSURE REGULATOR AL T N2 TRAIN B PRESSURE REGULATOR AL T N2 TRAIN B PRESSURE REGULATOR AL T N2 TRAIN B MANIFOLD RELIEF AL T N2 TRAIN B MANIFOLD ISOLATION ALTERNATE N2 TRAIN B RELIEF DRYWELL & TORUS PURGE OTBD ISOL DWOTBDVENT TORUS MAIN EXHAUST TORUS PURGE INBD I SOL VACUUM RELIEF DAMPER SV FOR A0-2379 TORUS TO RX BLDG VACUUM BREAKER VACUUM RELIEF DAMPER SV FOR A0-2380 TORUS VACUUM RELIEF DRYWELL PURGE INBD I SOL TORUS VENT OW PURGE EXHAUST INBD N2 SUPPLY TO HPV INBOARD ISOLATION AO-4539 N2 SUPPLY FOR HPV OUTBD ISOLATION AO-4540 INBOARD N2 SUPPLY TO HPV RUPTURE DISC OUTBOARD N2 SUPPLY TO HPV RUPTURE DISC HARD PIPE VENT INBOARD ISOLATION VALVE HARD PIPE VENT OUTBOARD ISOLATION VALVE AL T N2 TRAIN A SUPPLY ISOLATION/ALARM AL T N2 TRAIN B SUPPLY ISOLATION/ALARM Sheet 38 of 54 Revision 2 Notes/Comments . Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Fail Closed Fail Closed Stevenson

& Associates ESEL Item ID Num 189 L T-7338A 190 L Y-73388 191 L T-73388 192 PT-7251A 193 PLR-7251A 194 PT-7251 8 195 PY-7251 8 196 PLR-7251 8 197 TE-4073A 198 TE-4074A 199 TE-4075A 200 TE-4076A 201 TE-4077A 202 TE-4078A 203 TE-4079A 204 TE-4080A 205 TE-40738 206 TE-40748 207 TE-40758 208 TE-40768 209 TE-40778 210. TE-40788 211 TE-40798 212 TE-40808 213 TI-4072A Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State TORUS WIDE RANGE LEVEL TORUS WIDE RANGE LEVEL TORUS WIDE RANGE LEVEL DRYWELL WIDE RANGE PRESSURE OW PRESS-TOR LVL-DW RAD-ACCDIRNG DRYWELL WIDE RANGE PRESSURE PRIMARY CONTAINMENT WIDE RANGE PI ISOLATOR OW PRESS-TOR LVL-DW RAD-ACCDIRNG TORUS SENSOR 1 -SRV71 H I RCIC DISCHARGE AREA TORUS SENSOR 2 -SRV71 C DISCHARGE AREA TORUS SENSOR 3 -SRV71 8 DISCHARGE AREA TORUS SENSOR 4 -SRV71 G I HPCI DISCHARGE AREA TORUS SENSOR 5 -SRV71A DISCHARGE AREA TORUS SENSOR 6 -SRV71E DISCHARGE AREA TORUS SENSOR 7 -SRV71F DISCHARGE AREA TORUS SENSOR 8-SRV71 0 DISCHARGE . AREA TORUS SENSOR 1 -SRV71 H I RCIC DISCHARGE AREA TORUS SENSOR 2 -SRV71 C DISCHARGE AREA TORUS SENSOR 3-SRV71 8 DISCHARGE AREA TORUS SENSOR 4 -SRV71 G I HPCI DISCHARGE AREA TORUS SENSOR 5 -SRV71A DISCHARGE AREA TORUS SENSOR 6 -SRV71 E DISCHARGE AREA TORUS SENSOR 7 -SRV71F DISCHARGE AREA TORUS SENSOR 8-SRV71 0 DISCHARGE AREA DIV 1 TORUS TEMP Sheet 39 of 54 Revision 2 Notes/Comments Stevenson

& Associates ESEL Item ID Num 214 Tl-40728 215 TY-4072A 216 TY-40728 217 TE-4247A 218 TE-42478 219 TE-4247C 220 TE-42470 221 TE-4247E 222 TE-4247F 223 TE-4247G 224 TE-4247H 225 RE-4544 226 RM-4544 227 010 228 020 229 052 230 053 231 054 232 070 233 080 234 090 235 Y71 236 Y75 237 Y70 238 Y81 239 Y85 240 Y80 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State DIV 2 TORUS TEMP DIV 1 TORUS TEMP DIV 2 TORUS TEMP OW TEMPERATURE ELEMENT(DUAL ELEMENT A1/A2) OW TEMPERATURE ELEMENT(DUAL ELEMENT B1/B2) OW TEMPERATURE ELEMENT (DUAL ELEMENT C1/C2) OW TEMPERATURE ELEMENT (DUAL ELEMENT 01/02} OW TEMPERATURE ELEMENT (DUAL ELEMENT E1/E2) OW TEMPERATURE ELEMENT (DUAL ELEMENT F1/F2) OW TEMPERATURE ELEMENT (DUAL ELEMENT G1/G2) OW TEMPERATURE ELEMENT (DUAL ELEMENT H1/H2) HARD PIPE VENT RADIATION DETECTOR HARD PIPE VENT RADIATION MONITOR 125 VDC CHARGER FOR #11 BATI 125 VDC CHARGER FOR #12 BATI CHARGER, D3A (13) BATIERY CHARGER, 038 (13) BATIERY CHARGER, SWING D3A,D3B (13) BATIERY CHARGER, 068 (16) BATIERY CHARGER, D6A (16) BATIERY CHARGER, SWING D6A,D6B (16)BATIERY DIV 1120VAC CLASS 1E Energized Energized INVERTER DIV 1 FUSED Energized Energized DISCONNECT SWITCH DIV 1 UNINTERRUPTIBLE 120VAC CLASS 1E DIST Energized Energized PANEL DIV 2 120VAC CLASS 1 E . Energized Energized INVERTER DIV 2 FUSED Energized Energized DISCONNECT SWITCH DIV 2 UNINTERRUPTIBLE 120VAC CLASS 1E DIST Energized Energized PANEL Sheet 40 of 54 Revision 2 Notes/Comments DOOR #11 0 INSIDE ON SOUTH WALL, EC720 replaced charger, DOOR #103 INSIDE ON NORTH WALL, Mod 000370 replaced charger DOOR #109 INSIDE ON NORTH WALL DOOR #109 INSIDE ON NORTH WALL DOOR #109 INSIDE ON NORTH WALL Drawing Available NORTH SIDE NORTH SIDE Stevenson

& Associates ESEL Item ID Num 241 D1 242 D11 243 D2 244 D21 245 D33 246 D100 247 D31 248 D3A 249 D3B 250 D6A 251 D6B 252 D311 253 D312 254 D313 255 C-03 256 C-04 257 C-15 258 C-30 259 C-41 260 C-42 261 C-55 262 C-56 263 C-121 264 C-122 265 C-128 266 C-253A 267 C-253B 268 C-292 269 C-32 270 C-33 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment . Operating State Description Normal State Desired State #11 BATTERY 125VDC DIV 1125VDC Energized Energized DISTRIBUTION CENTER #12 BATTERY 125VDC DIVI125 VDC Energized Energized DISTRIBUTION PANEL 125 VDC DISTRIBUTION Energized Energized CENTER DIV 2 125/250 VDC DISTRIBUTION PANEL DIV I 125/250 VDC DISTRIBUTION PANEL #13 (DIV 1) 125/250VDC BATTERY "A" #13 (DIV 1) 125/250VDC BATTERY "B" #16 (DIV 2) 125/250VDC BATTERY "A" #16 (DIV 2) 125/250VDC BATTERY "B" DIV 1 (RCIC) 250V DC MOTOR CONTROL Energized Energized CENTER 311 DIV 2 ( HPCI) 250V DC MOTOR CONTROL Energized Energized CENTER 312 DIV 1 (RCIC) 250V DC MOTOR CONTROL Energized Energized CENTER 313 RX AND CTMT COOLING AND ISOL BENCH BOARD RWC RECIRCULATING BENCH BOARD CHANNEL A PRIMARY !SOLAND RPS VERTICAL BOARD RCIC CABLE SPR RM CONTROL PANEL INBOARD ISOLATION RELAY PANEL OUTBOARD ISOLATION RELAY PANEL REACTOR VESSEL LEVEL AND PRESSURE RACK REACTOR VESSEL LEVEL AND PRESSURE RACK JET PUMP INSTRUMENT RACK JET PUMP INSTRUMENT RACK RCIC INSTRUMENT RACK SRV LOW LOW SET DIV 1 CONTROL PANEL SRV LOW LOW SET DIV 2 CONTROL PANEL ASDS BENCHBOARD A RHR, CORE SPRAY, ADS CONTROL PANEL B RHR, CORE SPRAY, ADS CONTROL PANEL Sheet 41 of 54 Revision 2 Notes/Comments DOOR#110 DOOR #11 0 INSIDE ON SOUTH WALL DOOR #103 INSIDE ON NORTH WALL DOOR #11 0 INSIDE ON SOUTH WALL DOOR#109 DOOR #109 DOOR #109 SOUTH SIDE NORTH SIDE CENTER CENTER NORTH OF C-05 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates ESEL Equipment Operating State Item ID Description Normal State Desired State Num 271 C-303A ECCS DIV I ANALOG TRIP SYSTEM 272 C-3038 ECCS DIV II ANALOG TRIP SYSTEM 273 13A-K1 Control Relay de-energized 274 13A-K2 Control Relay de-energized 275 13A-K3 Control Relay de-energized de-energized 276 13A-K5 Control Relay de-energized de-energized 277 13A-K6 Control Relay de-energized 278 13A-K7 Control Relay de-energized de-energized 279 13A-K10 Control Relay de-energized de-energized 280 13A-K12 Control Relay de-energized 281 13A-K13 Control Relay de-energized 282 13A-K14 Control Relay de-energized de-energized 283 13A-K16 Control Relay de-energized 284 13A-K17 Control Relay de-energized de-energized 285 13A-K18 Control Relay de-energized de-energized 286 13A-K19 Control Relay de-energized de-energized 287 13A-K22 Control Relay de-energized de-energized 288 13A-K27 Control Relay de-energized 289 13A-K29 Control Relay de-energized 290 13A-K30 Control Relay de-energized 291 13A-K31 Control Relay de-energized de-energized 292 13A-K32 Control Relay de-energized 293 13A-K33 Control Relay de-energized de-energized 294 13A-K34 Control Relay de-energized 295 13A-K37 Control Relay energized energized 295 13A-K28 Control Relay de-energized de-energized 297 K102A Control Relay de-energized de-energized 298 K102B Control Relay de-energized de-energized 2 Listed as LIS-2-3-672E in the MNGP ESEP SEWS (14C4247-RPT-001) and 14C4247-CAL-004.

3 Listed as LIS-2-3-672F in the MNGP ESEP SEWS (14C4247-RPT-001) and 14C4247-CAL-004.

Sheet 42 of 54 Revision 2 Notes/Comments Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 43 of 54 Revision 2 ATTACHMENT B-ESEP HCLPF VALUES AND FAILURE MODES TABULATION Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 44 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL orTPNS) 06A 06B 070 080 090 Y71 -Y81 C-253B Table B-1: ESEP HCLPF Values and Failure Modes for EFT Building (RLGMREG1.6o

= 0.134g) Failure Mode HCLPF (g) Additional Discussions Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

---

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

• ----**--*-------**----C-289B [1] Anchorage Capacity 0.18 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

C-292 Screened out > RLGM Component screened by SRT Judgment.

r-* C-303B Equipment Capacity 0.25 Component evaluated by HCLPF calculation LY-7338B Screened out > RLGM Rule of Box to C-292. See Parent 0100 Screened out > RLGM Component screened by SRT analysis.

""" Y70 Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

--*-----------

-****--**--*

---

*----

Y75 Screened out > RLGM Component screened by SRT Judgment Y80 Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002. ---------*--

Y85 Screened out > RLGM Component screened by SRT Judgment Ll S-2-3-6 72 B Functionality Capacity 0.00 Rule of Box to C-303B. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-0_04.

No public capacity data available for this item. LIS-2-3-6720 Functionality Capacity 0.00 Rule of Box to C-303B. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. --------------------------------

LS-2-3-672F Functionality Capacity 0.00 Rule of Box to C-303B. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. PY-7251B Screened out > RLGM Rule of Box to C-292. See Parent. -*-* -------*--*-

RM-4544 Anchorage Capacity 0.18 Rule of Box to C-289B. See Parent. TY-4072B Anchorage Capacity 0.18 Rule of Box to C-289B. See Parent. Notes: [1] This item is not included in the ESEL; however, it is evaluated since it is a parent to ESEL items Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 45 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL orTPNS) 0311 0312 0313 01 -----.. 02 --03A 03B 010 020 052 -053 054 C-253A C-289A [1] C-30 ---C-303A C-32 --C-33 --C-41 ----C-42 C-03 ------------

C-04 C-05 [1] C-15 C-02 [1] C-128 Table B-2: ESEP HCLPF Values and Failure Modes for RX, ADMIN, & Turbine Building (RLGMrAFT

= 0.19g) Failure Mode HCLPF (g) Additional Discussions Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis.

Anchorage Capacity 0.23 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

-***-*-*-**

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

• • -------Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---*-*-"""""

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Component evaluated by HCLPF calculation 14C4247-CAL-002.

The Anchorage Capacity 0.21 cabinet itself is seismically adequate; however, some of the relays inside are "bad actors". These are evaluated separately.

See Relay HCLPF calculation 14C4247-CAL-004.

---

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

• • -*------

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

---

Component evaluated by HCLPF calculation 14C4247-CAL-002.

The Anchorage Capacity 0.21 cabinet itself is seismically adequate; however, some of the relays inside are "bad actors". These are evaluated separately.

See Relay HCLPF calculation 14C4247-CAL-004.

---Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

• -**--*--*-----

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adequate by SRT.

---

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 46 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) Additional Discussions or TPNS) L T-7338A Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adequate by SRT. L T-7338B Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adequate by SRT.

---

C-121 Anchorage Capacity 0.24 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

---

---

---

C-122 Anchorage Capacity 0.24 Component evaluated by HCLPF calculation 14C4247-CAL-002.

LS-23-74 Functionality Capacity 0.00 Functionality was evaluated in 14C4247-CAL-004.

No capacity data for (HCLPF < RLGM) these items. LS-23-75 Functionality Capacity 0.00 Functionality was evaluated in 14C4247-CAL-004.

No capacity data for (HCLPF < RLGM) these items.

-***-*-*------

• -----------

""" ----C-55 Block Wall Capacity & 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, Anchorage Capacity adjacent block wall is evaluated in 14C4247-CAL-003.

---

---

*--

C-56 Anchorage Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

---

PT-7251A Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adeguate by SRT. PT-7251B Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adequate by SRT. IR-PCV-4879

[1] Screened out > RLGM Component is judged to be adequate per SRT. IR-PCV-4881

[1] Block Wall Capacity 0.28 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

Fl-13-102

[2] Equipment Capacity 0.33 Rule of Box to C-04. See Parent. LS-5 Screened out > RLGM Rule of Box to S-200. See Parent SCP-7925 Screened out > RLGM Rule of Box to S-200. See Parent SE-7925 Screened out > RLGM Rule of Box to P-211. See Parent ----------

-C-215 [1] Anchorage Capacity 0.24 Rule of Box to C-122. See Parent dPIS-13-83 Functionality Capacity 0.05 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C424 7 -CAL -004. dPIS-13-84 Functionality Capacity 0.05 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247 -CAL-004.

L T-2-3-112A Anchorage Capacity 0.24 Rule of Box to C-122. See Parent PS-13-87A Functionality Capacity 0.00 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No capacity data for these items. -----PS-13-87B Functionality Capacity 0.00 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No capacity data for these items. ----PS-13-87C Functionality Capacity 0.00 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No capacity data for these items. PS-13-870 Functionality Capacity 0.00 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No capacity data for these items. PT-4067A Anchorage Capacity 0.24 Rule of Box to C-122. See Parent PT-4067C Anchorage Capacity 0.24 Rule of Box to C-122. See Parent -PS-4237 Block Wall Capacity 0.28 Rule of Box to IR-PCV-4881.

See Parent --PS-4662 Screened out > RLGM Rule of Box to IR-PCV-4879.

See Parent 011 Block Wall Capacity 0.19 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 47 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) Additional Discussions or TPNS) 021 Block Wall Capacity 0.19 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

031 Block Wall Capacity 0.19 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

033 Block Wall Capacity 0.19 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

SY-7321 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. TS-13-82C-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-82C-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004. ------TS-13-820-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-820-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7 -CAL -004. -------------TE-4073A Screened out > RLGM Component screened by SRT Judgment TE-4073B Screened out > RLGM Component screened by SRT Judgment TE-4074A Screened out > RLGM Component screened by SRT Judgment ---:------* TE-4074B Screened out > RLGM Component screened by SRT Judgment ---*---*--------

---

TE-4075A Screened out > RLGM Component screened by SRT Judgment TE-4075B Screened out > RLGM Component screened by SRT Judgment TE-4076A Screened out > RLGM Component screened by SRT Judgment ---*-*--------TE-4076B Screened out > RLGM Component screened by SRT Judgment TE-4077A Screened out >

Component screened by SRT Judgment TE-4077B Screened out > RLGM Component screened by SRT Judgment TE-4078A Screened out > RLGM Component screened by SRT Judgment ---TE-4078B Screened out > RLGM Component screened by SRT Judgment TE-4079A Screened out > RLGM Component screened by SRT Judgment TE-4079B Screened out > RLGM Component screened by SRT Judgment TE-4080A Screened out > RLGM Component screened by SRT Judgment

---

.. *----------TE-4080B Screened out > RLGM Component screened by SRT Judgment RE-4544 Screened out > RLGM Component screened by SRT Judgment ---------TE-4247A Screened out > RLGM Component screened by SRT Judgment -*-*--------

---

---

TE-4247B Screened out >RLGM Component screened by SRT Judgment L T-2-3-112B Screened out > RLGM Component screened by SRT Judgment PT-4067B Screened out > RLGM Component screened by SRT Judgment ------------------*

• ----------

PT-40670 Screened out > RLGM Component screened by SRT Judgment ------------

---

TS-13-79A-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7 -CAL -004. -----------

TS-13-79A-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 48 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) or TPNS) Additional Discussions TS-13-798-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

TS-13-798-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

TS-13-79C-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7 -CAL -004. TS-13-79C-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

-*--------TS-13-790-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

--

-TS-13-790-2 Screened out Component screened by SRT Judgment.

Functionality was evaluated in -> RLGM 14C4247-CAL-004.

---

TS-13-80A-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluate-d-in

_____ 14C424 7 -CAL-004. -----TS-13-80A-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was

_____ 14C4247-CAL-004.

TS-13-808-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated-in

_____ 14C4247-CAL-004.

TS-13-808-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was -evaluated in 14C4247-CAL-004.

TS-13-80C-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-80C-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7-CAL-004.

---

TS-13-800-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-800-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81A-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81A-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81 8-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81 8-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81 C-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81 C-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

--*---TS-13-810-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-810-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7-CAL-004.

TS-13-82A-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-82A-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-828-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7-CAL-004.

---

TS-13-828-2 Screened out > RLGM Component screened by SRT Judgment.

Functionalitywas evaluated in 14C4247-CAL-004.

---

TE-4247C Screened out > RLGM Component screened by SRT Judgment ----------TE-42470 Screened out > RLGM Component screened by SRT Judgment TE-4247E Screened out > RLGM Component screened by SRT Judgment -----------------------

TE-4247F Screened out > RLGM Component screened by SRT Judgment TE-4247G Screened out > RLGM Component screened by SRT Judgment TE-4247H Screened out > RLGM Component screened by SRT Judgment Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 49 of 54 Revision 2 Stevenson

& Associates Equip ID (IVIPL Failure Mode HCLPF (g) Additional Discussions orTPNS) LIS-2-3-672A Functionality Capacity 0.00 Rule of Box to C-303A. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. LIS-2-3-672C Functionality Capacity 0.00 Rule of Box to C-303A. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. LS-2-3-672E Functionality Capacity 0.00 Rule of Box to C-303A. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. TY-4072A Anchorage Capacity 0.21 Rule of Box to C-289A. See Parent. -* ... Fl-13-91 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. *------FIC-13-91 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. *-*--LI-2-3-85A Equipment Capacity 0.33 Rule of Box to C-05. See Parent. -*-------LI-2-3-85B Equipment Capacity 0.33 Rule of Box to C-05. See Parent. Pl-13-93 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. -* -----* Pl-13-94 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. . --------------------

Pl-13-95 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. --Pl-13-96 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. PI-6-90A Equipment Capacity 0.33 Rule of Box to C-05. See Parent.

---

* ------------*

---

PI-6-90B Equipment Capacity 0.33 Rule of Box to C-05. See Parent. PLR-7251A Equipment Capacity 0.33 Rule of Box to C-03. See Parent. PLR-7251B Equipment Capacity 0.33 Rule of Box to C-03. See Parent. ----------TI-4072A Equipment Capacity 0.33 Rule of Box to C-02. See Parent. -------*--

---*-*------------TI-4072B Equipment Capacity 0.33 Rule of Box to C-02. See Parent. FS-13-57 Screened out > RLGM Rule of Box to C-128. See Parent. FT-13-58 Screened out > RLGM Rule of Box to C-128. See Parent. ---*---LS-7323 Screened out > RLGM Rule of Box to S-200. See Parent PS-13-67A Screened out > RLGM Rule of Box to C-128. See Parent. Functionality was evaluated in 14C4247-CAL-004.

---PS-13-72A Screened out > RLGM Rule of Box to C-128. See Parent. ----PS-13-72B Screened out > RLGM Rule of Box to C-128. See Parent. --**---------------

PT-13-60 Screened out > RLGM Rule of Box to C-128. See Parent. --**---PT-13-65 Screened out > RLGM Rule of Box to C-128. See Parent. --PT-13-68 Screened out > RLGM Rule of Box to C-128. See Parent. PT-13-70 Screened out > RLGM Rule of Box to C-128. See Parent. --L T-2-3-61 Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. LT-2-3-72A Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. LT-2-3-72B Anchorage Capacity 0.25 Rule of Box to C-56. See Parent. LT-2-3-72C Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. --LT-2-3-720 Anchorage Capacity 0.25 Rule of Box to C-56. See Parent.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 50 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) or TPNS) Additional Discussions L T-2-3-85A Anchorage Capacity 0.25 Rule of Box to C-56. See Parent. --*** L T-2-3-85B Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. ---------------------PT-6-53A Anchorage Capacity 0.25 Rule of Box to C-56. See Parent. PT-6-53B Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. S-200 Screened out > RLGM Rule of Box to P-207. See Parent. P-207 Screened out > RLGM Component screened by SRT Judgment .. ------**----

P-210 Screened out > RLGM Component screened by SRT Judgment *---------

P-211 Screened out > RLGM Rule of Box to P-21 0. See Parent. CV-2104 Screened out > RLGM Component screened by SRT Judgment . --------PCV-2092 Screened out > RLGM Component screened by SRT Judgment RV-1745 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -**-RV-2097 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) by SRT.

---

Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate . -RV-2103 Screened out > RLGM by SRT. CV-3503 Screened out > RLGM Component screened by SRT analysis A0-2377 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be adequate by SRT. -----------... A0-2378 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. A0-2379 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. A0-2380 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be bySRT. **----A0-2381 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT . .. A0-2383 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. A0-2896 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -------A0-4539 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. A0-4540 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-4878 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-4880 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be adequate by SRT. -** SV-4234 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ------SV-2-71A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ----*--*-* __ , ______ SV-2-71B Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. SV-2-71C Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. SV-2-710 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. *-** ... ------SV-2-71E Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as judged to be adequate by SRT . ..

Report. No.: 14C424 7 -RPT-002 Expedited Seismic Evaluation Process Report Sheet 51 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) orTPNS) Additional Discussions SV-2-71 F Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --------SV-2-71G Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. SV-2-71 H Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT.

---

SV-2-71J Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -**** -------SV-2-71 K Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. SV-2-71 L Screened out > RLGM Meets NP-6041 Table 2-4 caveats applicable)judged to be adequate by SRT. --*------* SV-2-71M Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -----------A0-2386 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged by SRT. A0-2387 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT . . -------* RV-3242A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) by SRT. RV-3243A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to adequate by SRT. RV-3244A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-3245A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ---RV-7440A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-7441A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. RV-7467A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. ------RV-7468A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-4236 Block Wall Capacity 0.28 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

RV-4673 Screened out > RLGM Component screened by SRT analysis.

---

SV-4235 Block Wall Capacity 0.28 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

---

PCV-4879 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate _ SRT. Also, Rule of Box to IR-PCV-4879, see parent. PCV-4881 Block Wall Capacity 0.28 Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate -----by SRT. Also, of Box to IR-PCV-4881, see parent. PCV-4897 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Also, Rule of Box to IR-PCV-4879, see parent. ---------PCV-4898 Block Wall Capacity 0.28 Meets NP-6041 Table 2-4 caveats (as applicable) judged to by SRT. Also, Rule of Box to IR-PCV-4881, see parent. PCV-4903 Screened out > RLGM Meets NP-6041Table 2-4 caveats (as applicable) judged to be adequate by SRT. Also, Rule of Box to IR-PCV-4879, see parent. PCV-4904 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate ----tJY_SRT. Also, Rule of Box to IR-PCV-4879, see parent. PCV-4905 Block Wall Capacity 0.28 Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Also, Rule of Box to IR-PCV-4881, see parent. PCV-4906 Block Wall Capacity 0.28 Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Also, Rule of Box to IR-PCV-4881, see parent. H0-8 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --

Stevenson

& Associates Equip ID (MPL or TPNS) M0-2078 M0-2106 --M0-2096 M0-2080 M0-2100 M0-2101 M0-2110 M0-2071 M0-3502 M0-2035 M0-2076 M0-2107 SV-2082A SV-20828 SV-2104 --SV-2848 SV-2849 SV-4541 -----SV-4542 SV-2379 SV-2380 SV-4539 SV-4540 --**-* RV-2-71A RV-2-71 B RV-2-71C RV-2-710 RV-2-71E RV-2-71 F RV-2-71G RV-2-71H Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 52 of 54 Revision 2 Failure Mode HCLPF (g) Additional Discussions Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -. Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis. -----Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis. "

Screened out > RLGM Component screened by SRT analysis.

---*-------------------

---

Screened out > RLGM Component screened by SRT analysis.

---

Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis.

---

Screened out > RLGM Component screened by SRT Judgment Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ----Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --***-

Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT . .. . -Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ----* Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. -------

Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. ----------------*-

Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 53 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) Additional Discussions or TPNS) E-200A Anchorage Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

-*

Anchorage Capacity E-200B (HCLPF < RLGM) 0.181 Component does not screen out; a more detailed evaluation is required.

E-203 Screened out > RLGM Component screened by SRT analysis.

E-205 Screened out. > RLGM Rule of Box to P-207. See Parent. T-73 Screened out > RLGM Component screened by SRT Judgment T-57A Screened out > RLGM Component screened by SRT Judgment.

---

T-57B Screened out > RLGM Component screened by SRT Judgment.

T-57C Screened out > RLGM Component screened by SRT Judgment.

T-570 Screened out > RLGM Component screened by SRT Judgment.

---

---

T-57E Screened out > RLGM Component screened by SRT Judgment.

T-57F Screened out > RLGM Component screened by SRT Judgment. T-57G Screened out > RLGM Component screened by SRT Judgment.

--T-57H Screened out > RLGM Component screened by SRT Judgment.

13A-K1 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K10 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF.

---

---

---

13A-K12 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K13 (HCLPF < RLGM) 0.00 is a "bad actor, and does not have any seismic capacity under the undesirable state. The relay is ROB to C-30. ---Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K14 (HCLPF < RLGM) 0.00 is a "bad actor, and does not have any seismic capacity under the undesirable state. The relay is ROB to C-30. --* 13A-K16 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The re)ay is a ROB to C-30, and is governed by the host HCLPF. -----------Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K17 0.00 is a "bad actor, and does not have any seismic capacity under the (HCLPF < RLGM) undesirable state. The relays is ROB to C-30. f----*-

---

..

---

--13A-K18 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K19 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K2 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K22 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. **-* -------13A-K27 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K28 0.00 is a "bad actor, and does not have any seismic capacity under the (HCLPF < RLGM) undesirable state. The relay is ROB to C-33. --------Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K29 (HCLPF < RLGM) 0.00 is a "bad actor, and does not have any seismic capacity under the undesirable state. The relay is ROB to C-33.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 54 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) orTPNSl Additional Discussions 13A-K3 Functionality Capacity 0.00 Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay (HCLPF < RLGM) is a "bad actor", and does not have any seismic capacity under the undesirable state. The relay is ROB to C-30 . .. . --*-13A-K30 Functionality Capacity 0.00 Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay (HCLPF < RLGM) is a actor', and does not have any seismic capacity under the . undesirable state. The relay is ROB to C-33. _" ____ 13A-K31 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-33, and is governed by the host HCLPF.

13A-K32 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-OM*.

The relay is a ROB to C-33, and is governed by the host HCLPF. Component evaluated in Relay Calculation 14C4247:CAl-004.

The relay is 13A-K33 Anchorage Capacity 0.21 a ROB to C-30, and is tbe host HCLPF. 13A-K34 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. ----------13A-K37 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K5 Functionality Capacity 0.00 Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay (HCLPF < RLGM) is a "bad actor', and does not have any seismic capacity under the undesirable state. The relay is ROB to C-30. -------------13A-K6 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K7 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. K102A Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-303A, and is governed by the host HCLPF. K102B Functionality Capacity 0.06 evaluated Relay Calculation 14C4247-CAL-004.

This relay . (HCLPF < RLGM) IS ROB to C-303B. The In-cabinet structure response exceeds the capacity of the relay. Notes: [1] This item is not included in the ESEL; however, it is evaluated since it is a parent to ESEL items December 23, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 Renewed Facility Operating License No. DPR-22 Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 L-MT-14-093 10 CFR 50.54(f) Monticello Nuclear Generating Plant: Expedited Seismic Evaluation Process (ESEP) -Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1

References:

1) NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" dated March 12, 2012, (ADAMS Accession No. ML 12056A046).

2) Letter from K Fili (NSPM) to Document Control Desk (NRC), "Request Commitment Change for Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", L-MT-14-027, dated March 31, 2014 (ADAMS Accession No. ML 14090A297)

On March 12, 2012, the NRC issued "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" ("information request")

to all NRC power reactor licensees and holders of construction permits in active or deferred status (Reference 1 ). On March 31, 2014, in accordance with this information request, Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, committed to provide an Expedited Seismic Evaluation Process (ESEP) report to the NRC by December 31, 2014 (Reference 2). The purpose of this letter and enclosure is to provide the NRC with report 14C4247-RPT-002, Rev. 2, entitled, "Expedited Seismic Evaluation Process (ESEP)

Document Control Desk Page 2 Report in Response to the 50.54(f) Information Request Regarding Fukushima Term Task Force Recommendation 2.1: Seismic," for the Monticello Nuclear Generating Plant. The ESEP report was performed to demonstrate that a subset of the plant equipment can be relied upon to protect the reactor core following beyond design basis seismic events. The report results indicate that additional action (e.g. evaluation or modification or other action) is required to assure that sufficient seismic margin is available for a small set of plant equipment.

See the attached report for further details. These results are being tracked in the Monticello Corrective Action Program to ensure the actions are taken in a timely manner. If there are any questions or if additional information is needed, please contact John Fields, Fukushima Response Licensing, at 763-271-6707.

Summary of Commitments This letter completes the regulatory commitment to provide the ESEP report to the NRC by December 31, 2014. This letter contains no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December Z.3, 2014. ' ill:-' ( /1. p

// .

<!____ 0 ( Karen D. Fill '** Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosure cc: Administrator, Region Ill, USNRC Director of Nuclear Reactor Regulation (NRR), USNRC NRR Project Manager, MNGP, USNRC Senior Resident Inspector, MNGP, USNRC L-MT-14-093 ENCLOSURE MONTICELLO NUCLEAR GENERATING PLANT EXPEDITED SEISMIC EVALUATION PROCESS REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEARmTERM TASK FORCE RECOMMENDATION 2.1: SEISMIC 54 pages follow EXPEDITED SEISMIC EVALUATION PROCESS REPORT IN RESPONSE TO THE INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC for the Monticello Nuclear Generating Plant 2807 West County Road 75, Monticello MN 55362 Renewed Facility Operating License No. DPR-22 NRC Docket No. 50-236 Preparer:

Reviewer:

Approver:

Corporate Acceptance:

Monticello Nuclear Generating Plant 2807 West County Road 75, Monticello MN 55362 Prepared by: Stevenson

& Associates 275 Mishawum Road, Suite 200 Woburn, MA 01801 Report Number: 14C4247-RPT-002, Rev. 2 Printed Name Signature Jalal Farooq Todd Radford Walter Djordjevic 12/22/2014 12/22/2014 12/22/2014 Stevenson

& Associates Document Title: Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 2 of 54 Revision 2 EXPEDITED SEISMIC EVALUATION PROCESS (ESEP) REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC FOR THE MONTICELLO NUCLEAR GENERATING PLANT Document Type: Criteria 0 Interface D Report cgj Specification 0 Other D Drawing D Project Name: Monticello ESEP Program Job No.: 14C4247 Client: Northern States Power Company, a Minnesota corporation, d/b/a Xcel Energy (NSPM) This document has been prepared in accordance with the S&A Quality Assurance Program Manual, Revision 1I and project requirements:

Initial Issue: 14C4247-RPT-002, Revision 0 Prepared by: S. Kim v Reviewed by: W. Djordjevic

/4 j / 'IIIII Approved by: W. Djordjevic U j /. wr Revision Record: Revision Prepared by/ No. Date 1 Jalal Farooq 12/19/2014 f};V 2 Jalal Farooq 12/22/2014 Reviewed by/ Approved by/ Todd Radford Walter Djordjevic 12/19/2014 12/19/2014 Todd Radford Walter Djordjevic 12/22/2014 12/22/2014 It) /yl(-Date: 12/12/2014 Date: 12/12/2014 Date: 12/12/2014 Description of Revision Incorporation of minor editorial site comments.

Equipment ID for LIS-2-3-672E and LIS-2-3-672F changed to LS-2-3-672E and LS-2-3-672F, respectively.

References 29 and 30 added. Updated Section 8.4. pv IL-;:b Stevenson

& Associates DOCUMENT APPROVAL SHEET Figure 2.8 CONTRACT NO. 14C4247 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates TABLE OF CONTENTS Sheet 3 of 54 Revision 2 1. PURPOSE AND OBJECTIVE

........................................................................................................................

6 2. BRIEF

SUMMARY

OF THE FLEX SEISMIC IMPLEMENTATION STRATEGIES

........................................

7 3. EQUIPMENT SELECTION PROCESS AND ESEL .......................................................................................

8 3.1 EQUIPMENT SELECTION PROCESS AND ESEL ................................................................................

8 3.1.1 ESEL Development

.........................................................................................................................

8 3.1.2 Power Operated Valves ..................................................................................................................

9 3.1.3 Pull Boxes ........................................................................................................................................

9 3.1.4 Termination Cabinets ................................................................................

.....................................

9 3.1.5 Critical Instrumentation Indicators

...................................................................................................

9 3.1.6 Phase 2 and Phase 3 Piping Connections

......................................................................................

9 3.2 JUSTIFICATION FOR USE OF EQUIPMENT THAT IS NOT THE PRIMARY MEANS FOR FLEX IMPLEMENTATION

...........................................................................................................................................

10 4. GROUND MOTION RESPONSE SPECTRUM (GMRS) ..............................................................................

11 4.1 PLOT OF GMRS SUBMITTED BY THE LICENSEE ............................................................................

11 4.2 COMPARISON TO SSE ........................................................................................................................

12 5. REVIEW LEVEL GROUND MOTION (RLGM) .............................................................................................

15

5.1 DESCRIPTION

OF RLGM SELECTED ................................................................................................

15 5.2 METHOD TO ESTIMATE ISRS ............................................................................................................

19 6. SEISMIC MARGIN EVALUATION APPROACH ..........................................................................................

20 6.1

SUMMARY

OF METHODOLOGIES USED ..........................................................................................

20 6.2 HCLPF SCREENING PROCESS ..........................................................................................................

20 6.3 SEISMIC WALKDOWN APPROACH ....................................................................................................

20 6.3.1 Walkdown Approach ......................................................................................................................

20 6.3.2 Application of Previous Walkdown Information

.............................................................................

21 6.3.3 Significant Walkdown Findings ......................................................................................................

22 6.4 HCLPF CALCULATION PROCESS ......................................................................................................

22 6.5 FUNCTIONAL EVALUATION OF RELAYS ..........................................................................................

23 6.6 TABULATED ESEL HCLPF VALUES (INCLUDING KEY FAILURE MODES) .....................................

24 7. INACCESSIBLE ITEMS ............................................................................ , ...................................................

25 7.1 IDENTIFICATION OF ESEL ITEMS INACCESSIBLE FOR WALKDOWNS

........................................

25 7.2 PLANNED WALKDOWN I EVALUATION SCHEDULE I CLOSE OUT ................................................

25 8. ESEP CONCLUSIONS AND RESULTS ......................................................................................................

26 8.1 SUPPORTING INFORMATION

.............................................................................................................

26 8.2 IDENTIFICATION OF ITEMS REQUIRING FURTHER RESOLUTION

...............................................

27 8.3 IMPLEMENTATION SCHEDULE ........................................................................................ .................

28 8.4

SUMMARY

OF REGULATORY COMMITMENTS

................................................................................

28 9. REFERENCES

..............................................................................................................................................

29 ATTACHMENT A-MNGP ESEL ........................................................................................................................

31 ATTACHMENT B-ESEP HCLPF VALUES AND FAILURE MODES TABULATION

.......................................

43 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates LIST OF TABLES Sheet 4 of 54 Revision 2 Table 4-1: MNGP GMRS ......................................................................................................................................

11 Table 4-2: MNGP GMRS and SSErAFT between 1-10Hz ..................................................*...*.............................

12 Table 4-3: MNGP GMRS and SSEREG1.6o between 1-10Hz ...................................................*...........................*

13 Table 5-1: MNGP Maximum GMRS/SSErAFT Ratio (SF) ......................................*.............................................

15 Table 5-2: MNGP RLGMrAFT*****************************************************************************************************************************

... 15 Table 5-3: MNGP Maximum GMRS/SSEREG1.6o Ratio (SF) ................................................................................

16 Table 5-4: MNGP RLGMREG1.6o

............................................................................................................................

17 Table 6-1: MNGP Maximum GMRS/SSE Ratio (SF) ..........................................................................................

23 Table A-1: MNGP ESEL [19] ...............................................................................................................................

32 Table B-1: ESEP HCLPF Values and Failure Modes for EFT Building ...........................................................

44 Table B-2: ESEP HCLPF Values and Failure Modes for RX, ADMIN, & Turbine Building ............................

45 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates LIST OF FIGURES Sheet 5 of 54 Revision 2 Figure 4-1: MNGP GMRS ....................................................................................................................................

12 Figure 4-2: MNGP GMRS to SSErAFT Comparison

............................................................................................

13 Figure 4-3: MNGP GMRS to SSEREG1.so Comparison

........................................................................................

14 Figure 5-1: MNGP RLGMrAFT*********************************************************************************************************

......................

16 Figure 5-2: MNGP RLGMREG1.so

...........................................................................................................................

19 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

1. PURPOSE AND OBJECTIVE Sheet 6 of 54 Revision 2 Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the Nuclear Regulatory Commission (NRC) established a Near Term Task Force (NTTF) to conduct a systematic review of NRC processes and regulations and to determine if the agency should make additional improvements to its regulatory system. The NTTF developed a set of recommendations intended to clarify and strengthen the regulatory framework for protection against natural phenomena.

Subsequently, the NRC issued a 50.54(f) letter on March 12, 2012 [1], requesting information to assure that these recommendations are addressed by all U.S. nuclear power plants. The 50.54(f) letter requests that licensees and holders of construction permits under 10 CFR Part 50 reevaluate the seismic hazards at their sites against present-day NRC requirements and guidance.

Depending on the comparison between the reevaluated seismic hazard and the current design basis, further risk assessment may be required.

Assessment approaches acceptable to the staff include a seismic probabilistic risk assessment (SPRA), or a seismic margin assessment (SMA). Based upon the assessment results, the NRC staff will determine whether additional regulatory actions are necessary.

This report describes the Expedited Seismic Evaluation Process (ESEP) undertaken for the Monticello Nuclear Generating Plant (MNGP). The intent of the ESEP is to perform an interim action in response to the NRC's 50.54(f) letter [1] to demonstrate seismic margin through a review of a subset of the plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events. The ESEP is implemented using the methodologies in the NRC endorsed guidance in EPRI 3002000704, Seismic Evaluation Guidance:

Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic [2]. Note that this process is based on the MNGP FLEX strategy as of October 9, 2014. The objective of this report is to provide summary information describing the ESEP evaluations and results. The level of detail provided in the report is intended to enable the NRC to understand the inputs used, the evaluations performed, and the decisions made as a result of the interim evaluations Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

2. BRIEF

SUMMARY

OF THE FLEX SEISMIC IMPLEMENTATION STRATEGIES Sheet 7 of 54 Revision 2 The Monticello Nuclear Generating Plant (MNGP) FLEX strategies for reactor core cooling and heat removal and containment function are summarized below. This summary is derived from the MNGP Overall Integrated Plan (OIP) in response to the March 12, 2012, Commission Order EA-12-049

[3]. Reactor core cooling and heat removal is initially achieved using the Reactor Core Isolation Cooling System (RCIC) and High Pressure Coolant Injection System (HPCI) to provide high pressure makeup to the reactor. Both HPCI and RCIC automatically trip on high reactor water level. The normal suction supply for both HPCI and RCIC is the non-seismically qualified Condensate Storage Tanks (CSTs), if they are available.

If the CSTs are unavailable, suction automatically transfers to the suppression pool (torus). After the initial automatic initiation and trip of HPCI and RCIC, RCIC will be used as the primary strategy to provide makeup to the reactor. HPCI will be secured to extend the Division II battery life. Reactor depressurization will be initiated using safety-relief valves (SRVs) at a rate not to exceed 100 OF/hr to lower and maintain reactor pressure within the range of 150 psig to 300 psig. The torus performs as the heat sink for core cooling. The Hardened Containment Vent System (HVCS) line for the torus will be opened per the emergency operating procedures to remove heat from the torus and maintain the containment.

The strategy for phase 2 core cooling will rely on RCIC and the torus with venting through the HVCS as long as possible.

Once RCIC operation is no longer possible, the reactor will be fully depressurized using SRVs, and core makeup will be provided by a FLEX portable diesel-driven pump, drawing a suction from the discharge canal or the Mississippi River, and injecting to the reactor via a connection to the Residual Heat Removal Service Water (RHRSW) system. In Phase 2, DC powered equipment will be supported by a FLEX portable diesel generator connected to battery chargers, and supplemental nitrogen will be provided as needed to support operation of the HVCS and SRVs.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

3. EQUIPMENT SELECTION PROCESS AND ESEL Sheet 8 of 54 Revision 2 The selection of equipment for the ESEL followed the guidelines of EPRI 3002000704

[2]. The ESEL for Monticello Nuclear Generating Plant (MNGP) is presented in Attachment A. 3.1 Equipment Selection Process and ESEL The selection of equipment on the ESEL was based on installed plant equipment credited in the FLEX strategies during Phase 1, 2 and 3 mitigation of a Beyond Design Basis External Event (BDBEE), as outlined in the MNGP Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049

[3]. The OIP provides the MNGP FLEX mitigation strategy and serves as the basis for equipment selected for the ESEP. The scope of "installed plant equipment" includes equipment relied upon for the FLEX strategies to sustain the critical functions of core cooling and containment integrity consistent with the MNGP OIP [3]. FLEX recovery actions are excluded from the ESEP scope per EPRI 3002000704

[2]. The overall list of planned FLEX modifications and the scope for consideration herein is limited to those required to support core cooling, reactor coolant inventory, sub-criticality, and containment integrity functions.

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

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

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

The instrumentation monitoring requirements for core cooling/containment safety functions are limited to those outlined in the EPRI 3002000704 guidance, and are a subset of those outlined in the MNGP OIP [3]. 2. The scope of components is limited to installed plant equipment, and FLEX connections necessary to implement the MNGP OIP [3] as described in Section 2. 3. The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either "Primary" or up/Alternate").

4. The "Primary" FLEX success path is to be specified.

Selection of the "Back-up/Alternate" FLEX success path must be justified.

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

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

[2] guidance are: " Structures (e.g. containment, reactor building, control building, auxiliary building, etc.) " Piping, cabling, conduit, HVAC, and their supports. " Manual valves and rupture disks.

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

.. Nuclear steam supply system components (e.g. reactor pressure vessel and internals, reactor coolant pumps and seals, etc.) 7. For cases in which neither train was specified as a primary or back-up strategy, then only one train component (generally

'A' train) is included in the ESEL. 3. 1. 1 ESEL Development The ESEL was developed by reviewing the MNGP OIP [3] to determine the major equipment involved in the FLEX strategies.

Further reviews of plant drawings (e.g., Piping and Instrumentation Diagrams (P&IDs) and Electrical One Line Diagrams) were performed to identify the boundaries of the flow paths to be used in the FLEX strategies and to identify specific components in the flow paths needed to support implementation of the FLEX strategies.

Boundaries were established at an electrical or mechanical isolation device (e.g., isolation Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 9 of 54 Revision 2 amplifier, valve, etc.) in branch circuits I branch lines off the defined electrical or fluid flow path. P&IDs were the primary reference documents used to identify mechanical components and instrumentation.

The flow paths used for FLEX strategies were selected and specific components were identified using detailed equipment and instrument drawings, piping isometrics, electrical schematics and one-line drawings, system descriptions, design basis documents, etc., as necessary.

3.1.2 Power

Operated Valves Page 3-3 of EPRI 3002000704

[2) notes that power operated valves not required to change state are excluded from the ESEL. Page 3-2 also notes that "functional failure modes of electrical and mechanical portions of the installed Phase 1 equipment should be considered (e.g. RCIC/AFW trips)." To address this concern, the following guidance is applied in the MNGP ESEL for functional failure modes associated with power operated valves: " Power operated valves that remain energized during the Extended Loss of all AC Power (ELAP) events (such as DC powered valves), were included on the ESEL. " Power operated valves not required to change state as part of the FLEX mitigation strategies were not included on the ESEL. The seismic event also causes the !:LAP event; therefore, the valves are incapable of spurious operation as they would be de-energized. " Power operated valves not required to change state as part of the FLEX mitigation strategies during Phase 1, and are re-energized and operated during subsequent Phase 2 and 3 strategies, were not evaluated for spurious valve operation as the seismic event that caused the ELAP has passed before the valves are re-powered.

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

[2]. 3.1.4 Termination Cabinets Termination cabinets, including cabinets necessary for FLEX Phase 2 and Phase 3 connections, provide consolidated locations for permanently connecting multiple cables. The termination cabinets and the internal connections provide a completely passive function; however, the cabinets are included in the ESEL to ensure industry knowledge on panel/anchorage failure vulnerabilities is addressed.

3.1.5 Critical

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

3.1.6 Phase

2 and Phase 3 Piping Connections Item 2 in Section 3.1 above notes that the scope of equipment in the ESEL includes " ... FLEX connections necessary to implement the MNGP OIP [3) as described in Section 2." Item 3 in Section 3.1 notes that "The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either "Primary" or "Back-up/Alternate")." Item 6 in Section 3 goes on to explain that "Piping, cabling, conduit, HVAC, and their supports" are excluded from the ESEL scope in accordance with EPRI 3002000704

[2).

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 10 of 54 Revision 2 Therefore, piping and pipe supports associated with FLEX Phase 2 and Phase 3 connections are excluded from the scope of the ESEP evaluation. However, any active valves in the FLEX Phase 2 and Phase 3 connection flow path are included in the ESEL. The complete ESEL for MNGP is presented in Attachment A. 3.2 Justification for Use of Equipment That Is Not the Primary Means for FLEX Implementation No alternate equipment is used to support the "Primary" means for Flex implementation.

The complete ESEL for MNGP is presented in Attachment A.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

4. GROUND MOTION RESPONSE SPECTRUM (GMRS) 4.1 Plot of GM RS Submitted by the Licensee Sheet 11 of 54 Revision 2 MNGP USAR does not explicitly define the Safe Shutdown Earthquake (SSE) control point. Therefore, the MNGP SSE control point is defined per Section 2.4.2 of the SPID [14] for the purposes of the SSE-to-GMRS comparisons as part of the 50.54(f) 2.1 seismic evaluations.

As a soil site with generally uniform, horizontally layered stratigraphy and with soil-founded key structures, the control point at MNGP is defined as the highest point in the material where a safety-related structure is founded. The highest soil elevation where a related structure is found is at Elevation 930 ft. Reference

[4] also states that the site SSE is anchored to a PGA of0.12g. The GMRS, taken from Reference 4 is shown in Table 4-1 and Figure 4-1 below. Table 4-1: MNGP GMRS Freq. (Hz) GMRS (unsealed, g) 0.1 0.01 0.125 0.01 0.15 --....... -. 0.01 0.2 0.01 0.25 0.02

.. 10.,2,c ___ ..... ---* 0.35 0.02 0.4 0,03 0.5 0.03 0.6 0.03 0.7 0.03 --------------------------

0.8 0.04 0.9 0.04 1 0.04 1.25 0.05 1.5 0.06 2 0.09 2.5 0.12 3 0.14 3.5 0.16 ----------

4 0.18 5 0.22 6 0.26 0.29 8 0.30 9 0.31 10 0.32 12.5 0.33

_____ _:oc:.:.3:..:4c___

__ _ 20 0.32 25 0.28 30 0.26 35 0.24 *------------------

---

---

40 50 60 70 so 90 100 0.22 0.19 0.17 0.16 0.16 0.15 ----------------------

---

0.15 Stevenson

& Associates 0.40 0.35 0.30 0.25 c 0 0.20 OJ ] 0.15 0.10 0.05 0.00 0 I Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report I I' I lh I I i i I I Ill \ J 1 11 I i I ;{111111 I I

• I ;) 111111 . I ' . -1 I I Ill I I : _j_ ------I I II II f-"" II I I ! I 1 10 Frequency (Hz) Figure 4-1: MNGP GMRS 4.2 Comparison to SSE ! I I I \I ! I I '\ 1'--1 I i I I I ' I ! . ------. I I 100 Sheet 12 of 54 Revision 2 -GMRS As identified in the Reference 4, the GMRS exceeds the SSE in the 1-10Hz range. A comparison of the GMRS to the SSE between 1-1OHz is shown in Table 4-2 and Figure 4-2. Table 4-2: MNGP GMRS and SSETAFT between 1-10Hz Freq. (Hz) GMRS (unsealed, g) Horizontal SSE (g) 1.00 0.038 0.142 1.25 0.048 0.175 1.50 0.060 0.202 2.00 0.091 0.245 2.50 0.119 0.275 ---3.00 0.143 0.291 3.50 0.164 0.301 4.00 0.184 0.306 ------------5.00 0.215 0.304 -6.00 0.263 0.287 I -----7.00 0.294 0.270 8.00 I ----. -*------0.302 0.249 9.00 0.313 0.232 . 10.00 __ . __ 1 0.324 0.217 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates 0.35 -,------0.30 -__ ,, I i 0.20 ] 0.15 .........

• -------,

u <( 0.10

--'-----+---------1 0.05 1 10 Frequency (Hz) Figure 4-2: MNGP GMRS to SSErAFT Comparison Sheet 13 of 54 Revision 2 -GMRS -SSE(TAFT)

In addition to the original SSE, the Emergency Filtration Train (EFT) Building was designed to a Regulatory Guide 1.60 RS shape anchored to 0.12g. Therefore, a second comparison of the GMRS and SSEREG1.eo is shown in the following.

Table 4-3: MNGP GMRS and SSEREG1.so between 1-10Hz Freq (Hz) GMRS (g) Horizontal SSE (g) 1.00 0.038 0.177 . ------1.25 0.048 0.221 *--------*-*

1.50 0.060 0.256 -----------------

2.00 0.091 0.313 2.50 0.119 0.376 ----*--3.00 0.143 0.366 3.50 0.164 0.358

---

4.00 0.184 0.351 5.00 0.215 0.340 ----------------------

---

6.00 0.263 0.332 7.00 0.294 0.325 8.00 0.302 0.318 9.00 0.313 0.313 -------10.00 0.324 0.290 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates 0.40 I I I I I ./ / . I . / v ' 0.35 0.30 0.25 ..!:!l g 0.20 "' Qj / v / I " 0.15 / I I I I I I I ----I I ____ j ___ I I I 0.10 0.05 0.00 1 10 Frequency (Hz} Figure 4-3: MNGP GMRS to SSEREG1.so Comparison Sheet 14 of 54 Revision 2 -GMRS -SSE(REG1.60)

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

5. REVIEW LEVEL GROUND MOTION (RLGM) 5.1 Description of RLGM Selected Sheet 15 of 54 Revision 2 The RLGM for MNGP was determined in accordance with Section 4 of EPRI 3002000704

[2) by linearly scaling the MNGP SSErAFT by the maximum safety factor (SF = GMRS/SSErAFT ratio) between the 1 and 1OHz range. This calculation is shown in Table 5-1. Table 5-1: MNGP Maximum GMRS/SSETAFT Ratio (SF) Freq (Hz) GMRS (g) Horizontal SSErAFT (g) SF = GMRS/SSE 1.00 0.038 0.142 0.26 I --------1.25 0.048 0.175 0.28 1.50 0.060 0.202 0.30 -----------------------------------

2.00 0.091 0.245 0.37

---

*

2.50 0.119 0.275 0.43 ---* 3.00 0.143 0.291 0.49 ------*-*

-*-------**-------*

---3.50 0.164 0.301 0.54 ----------4.00 0.184 0.306 0.60 5.00 0.215 0.304 0.71 6.00 0.263 0.287 0.92 7.00 0.294 0.270 1.09 -----------8.00 0.302 0.249 1.21 ----***-*-

---

---

-*---------*-----9.00 0.313 0.232 1.35 10.00 0.324 0.217 1.49 As shown above, the maximum GMRS/SSErAFT ratio for MNGP occurs at 10 Hz and equals 1.49. The resulting 5% damped RLGM, based on scaling the horizontal SSErAFT by the SF of 1.49, is shown in Table 5-2 and Figure 5-1 below. Note that the RLGMrAFT PGA is 0.19g. Table 5-2: MNGP RLGMrAFT Freq. (Hz) 5% damped Horizontal RLGMTAFT (g) 0.50 0.092 0.53 0.100 0.56 0.108 0.59 0.114 0.63 0.128 ----------

0.66 0.136 ---*--------

0.71 0.146 0.76 0.156 0.83 0.174 --0;91 0.190 1.00 0.212 1.10 0.235 1.25 0.261 -------1.40 0.283 ------1.46 0.295 1.68 0.330 -----------

1.82 0.348 2.04 0.368 2.26 0.389 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates 0.50 0.45 0.40 0.35 ::§ 0.30 6 . .., 0.25 ., Gi 0.20 0.15 0.10 0.05 0.00 Freq. (Hz) 5% damped Horizontal RLGMTAFT (g) 2.50 0.409 ----------

2.76 0.425 3.40 0.448 ----4.27 0.460 4.95 0.454 --------5.42 0.447 6.13 0.423 7.23 0.396 8.29 0.362 -------10.44 0.313 ---12.26 0.282 ------------14.84 0.243 *--------18.80 0.204 --35.25 0.190 I I I I Ill I ! I I I ! v I \I I I / I \. I I I I \.1 I I I I I I ! I /I I I I I I :1 I / Kl \ ---

/!II 1'-. \. "'\ /i I -:--I / I I I "---l_ -i I rv / . ' I I I I I I I .......

I -+-II ,. I I 0 1 10 Frequency (Hz) Figure 5-1: MNGP RLGMTAFT II ! ! I I I ! I I I I 100 Sheet 16 of 54 Revision 2 -GMRS -SSE -RLGMrAFT As stated previously, the EFT building requires a separate RLGMREG1.so.

The same methodology is followed, and is presented in the following.

Table 5-3: MNGP Maximum GMRS/SSEREG1.sa Ratio (SF) Freq. (Hz) GMRS (g) Horizontal SSE REG1.so (g) SF= GMRS/SSE 1.00 0.038 0.177 0.21

---

1.25 0.048 0.221 0.22 ----------

---

1.50 0.060 0.256 0.23 2.00 0.091 0.313 0.29 ****-------

... --2.50 0.119 0.376 0.32 3.00 0.143 0.366 0.39 -*-*--------

3.50 0.164 0.358 0.46 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Freq. (Hz) GMRS (g) Horizontal SSE REG1.6o (g) 4.00 0.184 0.351 5.00 0.215 0.340 6.00 0.263 0.332 7.00 0.294 0.325 --8.00 0.302 0.318 --*-

9.00 0.313 0.313 -------

---

10.00 0.324 0.290 Sheet 17 of 54 Revision 2 SF= GMRS/SSE 0.52 0.63 0.79 --------*--

0.91 0.95 --*-**--------------*-*

1.00 ----------

1.12 As shown above, the maximum GMRS/SSEREG1.6o ratio for MNGP occurs at 10 Hz and equals 1.12. The resulting 5% damped RLGMREG1.6o, based on scaling the horizontal SSEREG1.6o by the SF of 1.12, is shown in Table 5-4 and Figure 5-2 below. Note that the RLGMREG1.6o PGA is 0.134g. Table 5-4: MNGP RLGMREG1.so Freq. (Hz) 5% damped Horizontal RLGM REG1.60 (g) 0.20 0.041 0.30 0.074 0.40 0.093 0.50 0.112 -----0.60 0.130 0.70 0.148 0.80 0.165 0.90 0.182 1.00 0.198 1.10 0.214 1.20 0.230 1.30 0.246 1.40 0.261 1.50 0.276 1.60 0.291 --------1.70 0.306 ---------* 1.80 0.321 1.90 0.336 2.00 0.350 2.10 0.364 2.20 0.379 2.30 0.393 ------------------2.40 0.407 2.50 0.421 2.60 0.418 2.70 0.416 2.80 0.414 ------2.90 0.412 3.00 0.410 3.15 0.407 ------------------------------

3.30 0.404 3.45 0.402 3.60 0.399 3.80 0.396 4.00 0.394

---

Stevenson

& Associates Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Freq. (Hz) 5% damped Horizontal RLGM REG1.60 (g) 4.20 0.391 -------------4.40 0.388 4.60 0.386 ---4.80 0.383 5.00 0.381 -5.25 0.379 5.50 0.376 5.75 0.374 6.00 0.372 -------6.25 0.369 6.50 0.367 6.75 0.365 ------7.00 0.364 ----7.25 0.362 ----7.50 0.360 -------7.75 0.358 --*-* 8.00 0.357 8.50 0.354 9.00 0.351 9.50 0.337 10.00 0.325 10.50 0.313 11.00 0.302 11.50 0.293 -----------12.00 0.284 12.50 0.275 ----------13.00 0.267 13.50 0.260 ----------

14.00 0.253 14.50 0.247 ---------------*-

---

15.00 0.241 16.00 0.229 17.00 0.219 18.00 0.210 20.00 0.195 22.00 0.181 **--25.00 0.165 28.00 0.152 -----31.00 0.141 34.00 0.134 Sheet 18 of 54 Revision 2 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates

§ 6 0.25 "' ] 0.20 u <:( 0.45 ll_ i I i I ! I I i I I I II I I I I I Ill IY I lit--

I I I i

• I I I Ill 1111} 1/ I I I I I lm-II! '\ I I "\ I ' l/v I '\ I ' " ' w !L / I II ' / . I I I IV I I I I Ill -----------*-----

I *--'------

0.40 0.35 0.30 0.15 0.10 0.05 0.00 0 1 10 Frequency (Hz) Figure 5-2: MNGP RLGMREG1.so

5.2 Method

to Estimate ISRS I i I c-! I I ! I 100 Sheet 19 of 54 Revision 2 -GMRS -SSE -RLGMREG1.60 The method used to derive the ESEP in-structure response spectra (ISRS) was to uniformly scale existing based ISRS from 50097-R-001

[17] by the maximum SF from Table 5-1 and Table 5-3 of 1.49 and 1.12, respectively.

ISRS used for the ESEP were developed for the USI A-46 program. Scaled ISRS are calculated for all buildings and elevations where ESEL items are located at MNGP. These scaled ISRS are documented within S&A Calculation 14C4247-CAL-001

[9].

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6. SEISMIC MARGIN EVALUATION APPROACH Sheet 20 of 54 Revision 2 It is necessary to demonstrate that ESEL items have sufficient seismic capacity to meet or exceed the demand characterized by the RLGM. The seismic capacity is characterized as the highest peak ground acceleration (PGA) for which there is a high confidence of a low probability of failure (HCLPF). The PGA is associated with a particular spectral shape; in this case the 5% damped RLGM spectral shape. The calculated HCLPF capacity must be equal to or greater than the RLGM PGA (0.19g from Table 5-2 and 0.134g from Table 5-4). The criteria for seismic capacity determination are given in Section 5 of EPRI 3002000704

[2]. There are two basic approaches for developing HCLPF capacities:

1. Deterministic approach using the Conservative Deterministic Failure Margin (CDFM) methodology of EPRI NP-6041 [7]. 2. Probabilistic approach using the fragility analysis methodology of EPRI TR-1 03959 [8]. For MNGP, the deterministic approach using the CDFM methodology of EPRI NP-6041 [7] was used to determine HCLPF capacities.

6.1 Summary

of Methodologies Used MNGP conservatively applied the methodology of EPRI NP-6041 [7] to all items on the ESEL. The screening walkdowns used the screening tables from Chapter 2 of EPRI NP-6041 [7]. The walkdowns were conducted by engineers who as a minimum attended the SQUG Walkdown Screening and Seismic Evaluation Training Course. The walkdowns were documented on Screening Evaluation Work Sheets from EPRI NP-6041 [7]. Anchorage capacity calculations used the CDFM criteria from EPRI NP-6041 [7] with MNGP specific allowables and material strengths used as applicable.

The input seismic demand used was the RLGM shown in Table 5-2, Figure 5-1, Table 5-4 and Figure 5-2. 6.2 HCLPF Screening Process From the two tables Table 5-2 and Table 5-4, the maximum spectral peak of the RLGM for MNGP equals 0.46g. Screening lanes 1 and 2 in Table 2-4 of NP-6041 [7] are bounded by peak spectral accelerations of 0.8g and 1.2g, respectively.

Both lane limits exceed the RLGM peak spectral acceleration.

MNGP ESEL components were screened to lane 1 of Table 2-4 in NP-6041 [7]. For components located 40' above grade, screening based on ground peak spectral acceleration is not applicable and additional consideration is required.

However, only three items are located above 40' above grade. The three items are two (2) temperature elements and one (1) pressure transmitter.

These types of components are inherently seismically rugged. The ESEL contains 83 valves, both power operated and relief. In accordance with Table 2-4 of EPRI NP-6041 [7], active valves may be assigned a functional capacity of 0.8g peak spectral acceleration without any review other than looking for valves with large extended operators on small diameter piping, and anchorage is not a failure mode. Therefore, valves on the ESEL may be screened out from ESEP seismic capacity determination, subject to the caveat regarding large extended operators on small diameter piping. Power operated valves were addressed in the USI A-46 program. These valves were walked down extensively and were evaluated per plant documentations when deemed necessary.

In addition, the SRT performed a walkdown and reviewed plant valve drawings for most of the valves, and determined they met the intent of Table 2-4 of EPRI NP-6041 [7]. The non-valve components in the ESEL are generally screened based on the USI A-46 results. Where possible, the results of the USI A-46 analysis were scaled. If the scaling approach was not straight forward, then a more detailed analysis was performed and presented in S&A Calculation 14C4247-CAL-002

[10]. 6.3 Seismic Walkdown Approach 6.3.1 Walkdown Approach Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 21 of 54 Revision 2 Walkdowns for MNGP were performed in accordance with the criteria provided in Section 5 of EPRI 3002000704

[2], which refers to EPRI NP-6041 [7] for the Seismic Margin Assessment process. Pg. 2-26 through 2-30 of EPRI NP-6041 [7] describes the seismic walkdown criteria, including the following key criteria: "The SRT [Seismic Review Team] should "walk by" 100% of all components which are reasonably accessible and in non-radioactive or low radioactive environments.

Seismic capability assessment of components which are inaccessible, in high-radioactive environments, or possibly within contaminated containment, will have to rely more on alternate means such as photographic inspection, more reliance on seismic reanalysis, and possibly, smaller inspection teams and more hurried inspections.

A 100% "walk by" does not mean complete inspection of each component, nor does it mean requiring an electrician or other technician to de-energize and open cabinets or panels for detailed inspection of all components.

This wa/kdown is not intended to be a QA or QC review or a review of the adequacy of the component at the SSE level. If the SRT has a reasonable basis for assuming that the group of components are similar and are similarly anchored, then it is only necessary to inspect one component out of this group. The basis" should be developed before the walkdown during the seismic capability preparatory work (Step 3) by reference to drawings, calculations or specifications.

The one component or each type which is selected should be thoroughly inspected which probably does mean de-energizing and opening cabinets or panels for this very limited sample. Generally, a spare representative component can be found so as to enable the inspection to be performed while the plant is in operation.

At least for the one component of each type which is selected, anchorage should be thoroughly inspected.

The walkdown procedure should be performed in an ad hoc manner. For each class of components the SRT should look closely at the first items and compare the field configurations with the construction drawings and/or specifications.

If a one-to-one correspondence is found, then subsequent items do not have to be inspected in as great a detail. Ultimately the wa/kdown becomes a "walk by" of the component class as the SRT becomes confident that the construction pattern is typical. This procedure for inspection should be repeated for each component class; although, during the actual wa/kdown the SRT may be inspecting several classes of components in parallel.

If serious exceptions to the drawings or questionable construction practices are found then the system or component class must be inspected in closer detail until the systematic deficiency is defined. The 100% "walk by" is to look for outliers, lack of similarity, anchorage which is different from that shown on drawings or prescribed in criteria for that component, potential Sf [Seismic Interaction]

problems, situations that are at odds with the team members' past experience, and any other areas of serious seismic concern. If any such concerns surface, then the limited sample size of one component of each type for thorough inspection will have to be increased.

The increase in sample size which should be inspected will depend upon the number of outliers and different anchorages, etc., which are observed.

It is up to the SRT to ultimately select the sample size since they are the ones who are responsible for the seismic adequacy of all elements which they screen from the margin review. Appendix D gives guidance for sampling selection.

The MNGP walkdowns included, as a minimum, a 100% walk-by of all "existing" items on the MNGP ESEL except as noted in Section 7. Any previous walkdown information that was relied upon as the basis for SRT judgment in excluding an item walkdown is documented in Section 6.3.2. 6.3.2 Application of Previous Walkdown Information The seismic walkdowns for MNGP included, as a minimum, a walk-by of all the components on the ESEL by the SRT with the exception of the items inside Drywell or high radiation locations as they were not accessible at the time of the walkdowns:

Fluid-Operated Valves (RV-3242A, RV-3243A, RV-3244A, RV-3245A, RV-7440A, RV-7441A, RV-7467A, RV-7468A)

Fluid-Operator Valves (A0-2386 & A0-2387) Motor Operated and Solenoid-Operated Valves (M0-2035, M0-2076, SV-2-71A-SV-2-71M)

Temperature Elements (TE-4247 A-TE-4247H)

Accumulators (T-57A-T-57H)

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& Associates A detailed discussion and resolution for each item listed above is provided in Section 7. Sheet 22 of 54 Revision 2 Previous seismic walkdowns were used to support the ESEP seismic evaluations.

Some of the components on the ESEL were included in the NTTF 2.3 seismic walkdowns

[15]. Those walkdowns were recent enough that they did not need to be repeated for the ESEP. Several ESEL items were previously walked down during the MNGP USI A-46 evaluation.

Those walkdown results were reviewed and the following steps were taken to confirm that the previous walkdown conclusions remained valid. " A walk by was performed to confirm that the equipment material condition and configuration is consistent with the walkdown conclusions and that no new significant interactions related to block walls or piping attached to tanks exists. " If the ESEL item was screened out based on the previous walkdown, that screening evaluation was reviewed and reconfirmed for the ESEP. 6.3.3 Significant Walkdown Findings Consistent with that guidance from NP-6041 [7], no significant outliers or anchorage concerns were identified during the MNGP ESEP walkdowns.

The following findings were noted during the walkdowns. " Masonry walls and columns were identified in the proximity of ESEL equipment.

These masonry walls and columns were assessed for their structural adequacy to withstand the seismic loads resulting from the RLGM. For any cases where the block wall represented the HCLPF failure mode for an ESEL item, it is noted in the tabulated HCLPF values described in Attachment B. 6.4 HCLPF Calculation Process ESEL items were evaluated using the criteria in EPRI NP-6041 [7]. Those evaluations included the following -* Performing seismic capability walkdowns for equipment to evaluate the equipment installed plant conditions " Performing screening evaluations using the screening tables in EPRI NP-6041 [7) as described in Section 6.2 " Performing HCLPF calculations considering various failure modes that include both structural (e.g. anchorage, load path etc.) and functional failure modes. All HCLPF calculations were performed using the CDFM methodology and are documented in S&A Calculation 14C4247-CAL-002

[10). Anchorage configurations for non-valve components were evaluated either by SRT judgment, large margins in existing design basis calculations, or CDFM based HCLPF calculations

[1 0]. The results of these analysis methods are documented in Attachment B. For components beyond 40' above grade, Table 2-4 of NP-6041 [7) is not directly applicable.

ESEP equipment items which are beyond 40ft above grade are located in the Reactor Building (RX) at elevation 985' & 994'. However, the three components are pressure transmitter (PT-72518) and temperature elements (TE-4247G

& TE-4247H).

These types of components are inherently seismically rugged and were ruggedly attached to structural components.

As described in Section 6.0, for HCLPF calculations the Conservative Deterministic Failure Margin (CDFM) analysis criteria established in Section 6 of EPRI NP-6041 [7) are used for a detailed analysis of components.

The relevant CDFM criteria from EPRI NP-6041 [7] are summarized in Table 6-1.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Table 6-1: MNGP Maximum GMRS/SSE Ratio (SF) Load combination:

Normal + seismic margin earthquake (SME) Ground response spectrum:

Conservatively specified (84% non-exceedance probability)

Damping: Conservative estimate of median damping. Structural model: Best estimate (median) + uncertainty variation in frequency.

Soil-structure interaction Best estimate (median) + parameter variation Material strength:

Code specified minimum strength or 95% exceedance of actual strength if test data is available.

Code ultimate strength (ACI), maximum strength (AISC), Service Level 0 (ASME) or functional limits. If test data Static capacity equations:

is available to demonstrate excessive conservatism of code equations then use 84% exceedance of test data for capacity equations.

For non-brittle failure modes and linear analysis, use Inelastic energy absorption:

80% of computed seismic stress in capacity evaluation to account for ductility benefits or perform nonlinear analysis and use 95% exceedance ductility levels. In-structure (floor) spectra Use frequency shifting rather than peak broadening to generation:

account for uncertainty and use median damping. Sheet 23 of 54 Revision 2 The HCLPF capacity is equal to the PGA at which the strength limit is reached. The HCLPF earthquake load is calculated as follows: U = Normal + Ec Where:

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

• Ec = HCLPF earthquake load " Normal = Normal operating loads (dead and live load expected to be present, etc.) For this calculation, the HCLPF earthquake load is related to a fixed reference earthquake:

Ec = SFc*Eref Where: " Eref = reference earthquake from the relevant in-structure response spectrum (ISRS) " SFc = component-specific scale factor that satisfies U = Normal +Ec The HCLPF will be defined as the PGA produced by Ec. Because the MNGP RLGM PGA is 0.19g or 0.134g depending on building:

HCLPFrAFt

= 0.19g*SFc HCLPFREG1.6o

= 0.134g*SFc

6.5 Functional

Evaluation of Relays A HCLPF evaluation is performed for all relays and switches which may negatively "seal in" or "lock out" on the MNGP ESEL [19].

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& Associates For relay evaluations, NP-6041-SL Appendix Q describes the following steps: " Calculate in-cabinet response spectra (ICRS): " Establish a clipping factor to be applied to the ICRS: " Determine a relay's GERS Capacity: " Establish adjustment factors to convert the relay's GERS capacity to a CDFM level: .. Compare clipped-peak and ZPA demands to the GERS capacity:

Sheet 24 of 54 Revision 2 The ESEL has 26 relays and 49 switches that have chatter concerns [20] -[25]. HCLPF capacities for these components are calculated in S&A Calculation 14C4247-CAL-004

[27] and are presented in Attachment B. 6.6 Tabulated ESEL HCLPF Values (Including Key Failure Modes) Tabulated ESEL HCLPF values including the key failure modes are included in Attachment B following the criteria below: " For items screened out using NP 6041 [7] screening tables, the HCLPF is listed as "> RLGM" (> 0.19g or 0.134g, depending on building location) and the failure mode is "Screened out" ., For items where anchorage controls the HCLPF value, the anchorage HCLPF value is listed in the table and the failure mode is set to "Anchorage Capacity" " For Items whose capacities were controlled by nearby block walls as the nearby block wall capacities were lower than the equipment and the anchorage capacities, the failure mode is noted as "Block Wall Capacity" and the block wall HCLPF value is listed " For items where a relay or switch HCLPF controls, the relay or switch HCLPF value is listed in the table and the failure mode is set to "Functionality Capacity"

• For items where an equipment capacity is based upon the screening lane values of Table 2-4 of ERPI NP-6041 [7] controls the HCLPF value (e.g. anchorage or relay HCLPF capacity exceeds the equipment capacity derived from screening lanes), the screening lane HCLPF value is listed in the table and the failure mode is set to "Equipment Capacity".

Based on NP-6041 Table 2-4 lane 1, this limit is equal to 0.33g (RLGMTAFT) and 0.25g (RLGMREG1.so) for items below 40 feet above grade. The "Equipment Capacity" limits from above are calculated as follows: The upper-bound spectral peak to NP-6041 Table 2-4 lane 1 is 0.8g. From Table 5-2 and Table 5-4, the RLGM spectral peak is 0.46g for RLGMTAFT and 0.421 g for RLGMREG1.so, and the PGA is 0.19g for RLGMTAFT and 0.134g for RLGMREG1.so.

Thus, for equipment less than 40 feet above grade, the "Equipment Capacity" HCLPF is limited to 0.8/0.46*0.19

= 0.33g for RLGMTAFT and 0.8/0.421

• 0.134 = 0.25g for RLGMREG1.so.

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7. INACCESSIBLE ITEMS 7.1 Identification of ESEL Items Inaccessible for Walkdowns Sheet 25 of 54 Revision 2 All items located inside the Drywell or high radiation locations were inaccessible.

A description of circumstances and disposition for each of these items is provided below. Fluid-Operated Valves (RV-2-71A-RV-2-71 H) These items were walked down during the MNGP USI A-46 evaluation.

The Screening Evaluation Work Sheet (SEWS) provides detailed description of the valves and includes photos. The valves have no vulnerabilities.

In addition, valve drawings were reviewed.

This inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Fluid-Operated Valves (RV-3242A, RV-3243A, RV-3244A, RV-3245A.

RV-7440A, RV-7441A, RV-7467A, RV-7468A) These items were walked down during the MNGP USI A-46 evaluation.

The SEWS provide detailed description of the valves and includes photos. The small valves have no operators or vulnerabilities.

In addition, valve drawings were reviewed.

This inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Fluid-Operator Valves (A0-2386 & A0-2387) These items were walked down during the MNGP USI A-46 evaluation.

The SEWS provide detailed description of the valves and includes photos. The valves have no vulnerabilities.

In addition, valve drawings were reviewed.

This inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Motor Operated and Solenoid-Operated Valves (M0-2035, M0-2076. SV-2-71A-SV-2-71 M) Same as the fluid operated valves, these motor-operated and solenoid-operated valves were evaluated during the MNGP USI A-46 evaluation.

The SEWS provide detailed description of the valves and includes photos. In addition, valve drawings were also reviewed.

This inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Temperature Elements (TE-4247 A-TE-4247H)

These temperature elements were evaluated during the MNGP USI A-46 evaluation.

The SEWS provided detailed description of the valves and include photos. These items are inherently seismically rugged and the notes state the items are securely attached to structural components.

No other vulnerabilities are noticed. The inspection was performed to the satisfaction of the SRT and is therefore acceptable.

Accumulators (T-57A-These accumulators were evaluated during the MNGP USI A-46 evaluation.

The SEWS state the 2 large U bolts typically to the structural steel was acceptable due to their large margin. The photos also confirm the accumulators are secured. Therefore, these items were judged to be acceptable by the SRT. 7.2 Planned Walkdown I Evaluation Schedule I Close Out No additional walkdowns are required.

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8. ESEP CONCLUSIONS AND RESULTS 8.1 Supporting Information Sheet 26 of 54 Revision 2 MNGP has performed the ESEP as an interim action in response to the NRC's 50.54(f) letter [1]. It was performed using the methodologies in the NRC endorsed guidance in EPRI 3002000704

[2]. The ESEP provides an important demonstration of seismic margin and expedites plant safety enhancements through evaluations and potential near-term modifications of plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events. The ESEP is part of the overall MNGP response to the NRC's 50.54(f) letter [1]. On March 12,2014, NEI submitted to the NRC results of a study [12] of seismic core damage risk estimates based on updated seismic hazard information as it applies to operating nuclear reactors in the Central and Eastern United States (CEUS). The study concluded that "site-specific seismic hazards show that there has not been an overall increase in seismic risk for the fleet of U.S. plants" based on the re-evaluated seismic hazards. As such, the "current seismic design of operating reactors continues to provide a safety margin to withstand potential earthquakes exceeding the seismic design basis." The NRC's May 9, 2014 NTTF 2.1 Screening and Prioritization letter [13] concluded that the "fleet wide seismic risk estimates are consistent with the approach and results used in the Gl-199 safety/risk assessment." The letter also stated that "As a result, the staff has confirmed that the conclusions reached in Gl-199 safety/risk assessment remain valid and that the plants can continue to operate while additional evaluations are conducted." An assessment of the change in seismic risk for MNGP was included in the fleet risk evaluation submitted in the March 12, 2014 NEIIetter

[12] therefore, the conclusions in the NRC's May 9 letter [13] also apply to MNGP. In addition, the March 12, 2014 NEIIetter

[12] provided an attached "Perspectives on the Seismic Capacity of Operating Plants," which (1) assessed a number of qualitative reasons why the design of Structures, Systems, and Components (SSCs) inherently contain margin beyond their design level, (2) discussed industrial seismic experience databases of performance of industry facility components similar to nuclear SSCs, and (3) discussed earthquake experience at operating plants. The fleet of currently operating nuclear power plants was designed using conservative practices, such that the plants have significant margin to withstand large ground motions safely. This has been borne out of those plants that have actually experienced significant earthquakes.

The seismic design process has inherent (and intentional) conservatisms which result in significant seismic margins within SSCs. These conservatisms are reflected in several key aspects of the seismic design process, including: " Safety factors applied in design calculations " Damping values used in the dynamic analysis of SSCs

• Bounding synthetic time histories for in-structure response spectra calculations " Broadening criteria for in-structure response spectra " Response spectra enveloping criteria typically used in SSC analysis and testing applications " Response spectra based frequency domain analysis rather than explicit time history based time domain analysis " Bounding requirements in codes and standards " Use of minimum strength requirements of structural components (concrete and steel) " Bounding testing requirements, and .. Ductile behavior of the primary materials (that is, not crediting the additional capacity of materials such as steel and reinforced concrete beyond the essentially elastic range, etc.). These design practices combine to result in margins such that the SSCs will continue to fulfill their functions at ground motions well above the SSE.

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8.2 Identification

of Items Requiring Further Resolution Sheet 27 of 54 Revision 2 Insights from the ESEP identified the following potential items where the HCLPF is below the RLGM. A more detailed analysis may result in a HCLPF that exceeds the RLGM for these components.

If not, modifications or other measures will be considered to provide additional seismic margin such that the HCLPF will exceed the RLGM. 1. RHR Heat Exchanger E-2008 has a HCLPF capacity below the RLGM. High strength bolts are used throughout the supporting frame, except for the connection between the heat exchanger supporting frame and the heat exchanger itself. The A307 bolts connecting the heat exchanger support frame and the heat exchanger are currently overstressed by 5%. A potential modification would be to change the existing A307 bolts to an A325 or equivalent to provide the additional seismic margin required.

2. Relays with very low capacities in specific configurations are known as "bad actors". These relays have been shown to perform poorly seismically.

All inadequate relays have contacts which are both normally open and normally closed; thus, the (lower) normally closed capacity was used throughout the evaluation.

Further evaluation may show that the chatter of the normally closed contacts for these relays would not negatively impact the FLEX plan; then these relays could be qualified.

MNGP may also be able to determine that operator actions I workarounds exist for these relays or that they are not truly essential to the success of the FLEX strategy (i.e. removal from ESEL). The following are the list of relays that do not screen out. .. 13A-K13 .. 13A-K14 .. 13A-K17 .. 13A-K3

• 13A-K5

• 13A-K29 .. 13A-K30

• 13A-K28 Relay K1 028 is located in the EFT building at Elevation 960', where the in-structure cabinet response exceeds the capacity.

Solutions which may be considered are to stiffen or replace host cabinet (C-3038), relocate the subject relay to a more seismically favorable location, replace the subject relay with a compatible relay model or determine a higher capacity by shake table testing of this relay model. " K1028 3. The following are switches without capacity data or where capacity data is insufficient.

MNGP may seek other measures, i.e., contacting the switch manufacturer and/or look for guidance within the industry, replacing the subject with a compatible model or determine capacity by shake table testing of these items. This applies to the following switches.

• dPIS-13-83 " dPIS-13-84

• PS-13-87A

• PS-13-878 " PS-13-87C " PS-13-870 " LIS-2-3-672A

• LIS-2-3-6728 " LIS-2-3-672C

• LIS-2-3-6720

• LS-2-3-672E

.. LS-2-3-672F Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates " LS-23-74 " LS-23-75 8.3 Implementation Schedule Sheet 28 of 54 Revision 2 Per Sec. 8.2, further analysis is warranted for components with HCLPF < RLGM. If more detailed analysis methods cannot produce a HCLPF > RLGM, a modification will be performed.

Plant modifications will be performed in accordance with the schedule identified in NEIIetter dated April 9, 2013 [28], which states that plant modifications not requiring a planned refueling outage will be completed by December 2016 and modifications requiring a refueling outage will be completed within two planned refueling outages after December31, 2014. 8.4 Summary of Regulatory Commitments No regulatory commitments are being made but the equipment identified in Section 8.2 are included in the MNGP corrective action program and will be resolved accordingly.

Stevenson

& Associates

9. REFERENCES Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 29 of 54 Revision 2 NRC (E Leeds and M Johnson) Letter to All Power Reactor Licensees et al., "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3 and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," March 12, 2012. 2 Seismic Evaluation Guidance:

Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1 -Seismic.

EPRI, Palo Alto, CA: May 2013. 3002000704.

3 Order Number EA-12-049 responses:

3.1 NRC Letter L-MT-13-017 from NSPM (ML 13066A066), "Monticello Nuclear Generating Plant's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)", February 28, 2013. 3.2 NRC Letter L-MT-13-079 from NSPM (ML 13241A200), "Monticello's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)", August 28, 2013. 3.3 NRC Letter L-MT-14-014 from NSPM (ML 14065A037), "Monticello Nuclear Generating Plant's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events (Order Number EA-12-049)", February 28, 2014. 3.4 NRC Letter L-MT-14-073 from NSPM (ML 14241A262), "Monticello Nuclear Generating Plant's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events (Order Number EA-12-049)", August 28, 2014. 4 14C4229-RPT-001 Rev. 2 (ML 14136A289), "Monticello Nuclear Generating Plant Seismic Hazard and Screening Report", May 12, 2014 5 Nuclear Regulatory Commission, NUREG-1407, Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, June 1991. 6 Nuclear Regulatory Commission, Generic Letter No. 88-20 Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities-1 OCFR 50.54(f), June 1991. 7 A Methodology for Assessment of Nuclear Power Plant Seismic Margin, Rev. 1, August 1991, Electric Power Research Institute, Palo Alto, CA. EPRI NP 6041. 8 Methodology for Developing Seismic Fragilities, August 1991, EPRI, Palo Alto, CA. 1994, TR-1 03959. 9 S&A Calculation No. 14C4247-CAL-001 Rev O,"Generation of In-Structure Response Spectra for Use in ESEP Evaluations" 10 S&A Calculation No. 14C4247-CAL-002 Rev O,"HCLPF Analysis for ESEP Evaluations for MNGP" 11 Nuclear Regulatory Commission, NUREG/CR-0098, Development of Criteria for Seismic Review of Selected Nuclear Power Plants, published May 1978. 12 Nuclear Energy Institute (NEI), A Pietrangelo, Letter to D. Skeen of the USNRC, "Seismic Core Damage Risk Estimates Using the Updated Seismic Hazards for the Operating Nuclear Plants in the Central and Eastern United States", March 12, 2014. 13 NRC (E Leeds) Letter to All Power Reactor Licensees et al., "Screening and Prioritization Results Regarding Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(F) Regarding Seismic Hazard Re-Evaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-lchi Accident," May 9, 2014. 14 Seismic Evaluation Guidance:

Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic. EPRI, Palo Alto, CA: February 2013. 1025287. 15 NRC Letter L-MT-13-051 from NSPM (ML 13263A032), "MNGP Updated Final Response to NRC Request for Information Pursuaht to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated September 16, 2013. 16 NSP Letter to NRC "Response to Supplement 1 to Generic Letter 87-02, Submittal of A-46 Seismic Evaluation Report (T AC M69460)", November 20 1 h, 1995 17 MNGP Calc. No.92-369, "Monticello Nuclear Generating Plant Reactor Building In-Structure Response Spectra", Rev. 1, September, 1992 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 30 of 54 Revision 2 18 Seismic Fragility Applications Guide Update, December 2009, EPRI, Palo Alto, CA. 1994, 1019200. 19 NSPM Calculation (Doc) No.: 14-053 Rev 0, "Monticello FLEX Expedited Seismic Equipment List (ESEL)" 20 Xcel Energy Design Information Transmittal (DIT) No: 24221-04, "Expedited Seismic Equipment List (ESEL), 10/27/2014 21 Xcel Energy Design Information Transmittal (DIT) No: 24221-05, "Expedited Seismic Equipment List (ESEL), 11/07/2014 22 Xcel Energy Design Information Transmittal (DIT) No: 24221-06, "Expedited Seismic Equipment List (ESEL), 11/19/2014 23 Xcel Energy Design Information Transmittal (DIT) No: 24221-07, "Expedited Seismic Equipment List (ESEL), 11/19/2014 24 Xcel Energy Design Information Transmittal (DIT) No.24221-08, "Expedited Seismic Equipment Process (ESEP) Report", 12/11/2014 25 Xcel Energy Design Information Transmittal (DIT) No.24221-09, "Expedited Seismic Equipment Process (ESEP) Report", 12/12/2014 26 Xcel Energy Design Information Transmittal (DIT) No.24221-1 0, "Expedited Seismic Equipment Process (ESEP) Report", 12/4/2014 27 S&A Calculation No. 14C4247-CAL-004 Rev O,"ESEP HCLPFs for Relays" 28 Nuclear Energy Institute (NEI), A. Pietrangelo, Letter to D. Skeen of the USNRC, "Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations", April 9, 2013 29 S&A Calculation No. 14C4247-CAL-003 Rev 0, "ESEP Block Wall HCLPFs" 30 S&A Report No. 14C4247-RPT-001 Rev 0, "Monticello ESEP SEWS Report" Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates ATTACHMENT A-MNGP ESEL Sheet 31 of 54 Revision 2 Stevenson

& Associates Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 32 of 54 Revision 2 Table A-1 presents the MNGP ESEL. The selection process for items on this list is described in Section 3. Note that below, the "Normal State" and "Desired State" were determined when it was material to evaluating the seismic capacity of the component.

In other cases, those columns are left blank. Table A-1: MNGP ESEL [19] ESEL Equipment Operating State Item ID Description Normal State Desired State Notes/Comments Ilium 1 E-200A RHR DIV 1 HEAT EXCHANGER 2 E-200B RHR DIV 2 HEAT EXCHANGER RCIC TORUS SUCTION Interlocks w/M0-2102 (See NX-7822-5, 3 M0-2100 INBOARD Closed Open relays 13A-K18 and 13A-K19. M0-2100 (Local) on NX-7822-22-2.

4 M0-2101 RCIC TORUS SUCTION Closed Open M0-2101 (Local) on NX-7822-22-2.

OUTBOARD 5 RV-2103 RCIC PUMP SUCTION RELIEF VALVE 6 P-207 RCIC PUMP 7 M0-2106 RCIC PUMP DISCHARGE Closed Open Open on Rx Vessel Lvl Low OUTBOARD 8 M0-2107 RCIC PUMP DISCHARGE Closed Open Open on Rx Vessel Lvl Low INBOARD 9 M0-2110 RCIC TEST FLOW Closed Closed Close on Reactor Vessel Low-low Lvl or ISOLATION M0-2100 or M0-2101 Open Full 10 M0-3502 RCIC TEST RETURN Closed Closed Close on Reactor Vessel Low-low Lvl or ISOLATION M0-2100 or M0-2101 Open Full 11 CV-2104 RCIC PUMP MINIMUM Closed Open Fails Open on Loss of Air FLOW RCIC COOLING WATER 12 PCV-2092 TO BAROMETRIC CONDENSER RCIC BAROMETRIC Close on Rx Vessel Lvl High/Open on 13 M0-2096 CONDENSER COOLING Closed Open WATER SUPPLY Rx Vessel Lvl* Low COOLING WATER TO 14 RV-2097 BAROMETRIC CONDENSER RELIEF VALVE 15 E-205 RCIC OIL COOLER 16 E-203 RCIC BAROMETRIC CONDENSER RCIC TURBINE 17 P-210 BAROMETRIC Standby Operating CONDENSER CONDENSATE PUMP RCIC BAROMETRIC 18 P-211 CONDENSER VACUUM Standby Operating PUMP 19 M0-2076 RCIC STEAM LINE Open Open Close on High Flow/Open on Reactor ISOLATION OUTBOARD vessel Low Level/Steam line Monitoring 20 M0-2078 RCIC TURBINE STEAM Closed Open Close on Rx Vessel Lvl High/Open on SUPPLY Rx Vessel Lvl Low 21 M0-2080 RCIC TURBINE TRIP Open Open Close on .Turbine Trip RESET MOTOR (H0-7)

Stevenson

& Associates ESEL Item ID Num 22 H0-8 23 S-200 24 T-73 25 SV-2104 26 SV-2848 27 SV-2849 28 SV-2082A 29 SV-2082B 30 RV-1745 31 RV-2-71 H 32 SV-2-71 H 33 SV-2-71L 34 RV-2-71C 35 SV-2-71C 36 RV-2-71D 37 SV-2-71D 38 T-57C 39 T-57D 40 T-57H 41 T-57F 42 RV-2-71F 43 SV-2-71F 44 SV-2-71M 45 RV-2-71E 46 SV-2-71E 47 SV-2-71J 48 RV-2-71A 49 SV-2-71A 50 RV-2-71B 51 SV-2-71B 52 RV-2-71G 53 SV-2-71G 54 SV-2-71K 55 T-57A Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report . Equipment Operating State Description Normal State Desired State RCIC TURBINE GOVERNING VALVE RCIC TERRY TURBINE CV-2104 MINIMUM FLOW VALVE ACCUMULATOR TANK CV-2104 SOLENOID CV-2848 SOLENOID CV-2849 SOLENOID CV-2082A SOLENOID CV-2082B SOLENOID 11 CORE SPRAY PUMP DISCHARGE RELIEF VALVE H SRV H SRV AIR OPERATOR sv H SRV ASDS AIR OPERATORSV CSRV C SRV AIR OPERATOR sv DSRV D SRV AIR OPERATOR sv PRI STEAM SRV D ACCUMULATOR PRI STEAM SRV D ACCUMULATOR PRI STEAM SRV D ACCUMULATOR PRI STEAM SRV D ACCUMULATOR F SRV F SRV AIR OPERATOR sv F SRV ASDS AIR OPERATORSV ESRV E SRV AIR OPERATOR sv E SRV ASDS AIR OPERATORSV ASRV A SRV AIR OPERATOR sv BSRV B SRV AIR OPERATOR sv GSRV G SRV AIR OPERATOR sv G SRV ASDS AIR OPERATORSV PRI STEAM SRV G ACCUMULATOR Sheet 33 of 54 Revision 2 Notes/Comments Stevenson

& Associates ESEL Item ID Num 56 T-57B 57 T-57E 58 T-57G 59 RV-3243A 60 RV-7467A 61 RV-7440A 62 RV-3242A 63 RV-7468A 64 RV-3244A 65 RV-3245A 66 RV-7441A 67 M0-2035 68 CV-3503 69 M0-2071 70 PT-13-65 71 Pl-13-96 72 PS-13-67A 73 PT-13-60 74 Pl-13-93 75 FS-13-57 76 FT-13-58 77 FIC-13-91 78 Fl-13-91 79 FY-13-1 02 80 LS-7323 81 dPIS-13-83 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State . PRI STEAM SRV G ACCUMULATOR PRI STEAM SRV G ACCUMULATOR PRI STEAM SRV G ACCUMULATOR B SRV DISCH 8" VAG RV G SRV DISCH 8" VAG RV E SRV DISCH 8" VAG RV A SRV DISCH 8" VAG RV H SRV DISCH 8" VAG RV C SRV DISCH 8" VAG RV D SRV DISCH 8" VAG RV F SRV DISCH 8" VAG RV HPCI STEAM LINE ISOLATION OUTBOARD Open Closed HPCI TEST RETURN FLOW HPCI TEST RETURN Closed Closed ISOLATION RCIC PUMP SUCTION PRESSURE RCIC PUMP SUCTION RCIC LOW PUMP SUCTION PRESSURE energized energized TURBINE TRIP RCIC PUMP DISCHARGE PRESSURE RCIC PUMP DISCHARGE RCIC PUMP DISCHARGE MINIMUM FLOW energized energized CONTROL RCIC PUMP DISCHARGE FLOW CONTROL RCIC PUMP FLOW RCIC FLOW RCIC PUMP FLOW LOOP ISOLATOR RCIC CONDENSER HIGH VACUUM TANK LEVEL ALARM RCIC HIGH STEAM FLOW energized energized ISOLATION Sheet 34 of 54 Revision 2 Notes/Comments HPCIInitiated on Lo-Lo Reactor Water or High Drywell Pressure (OPEN)/Ciose on High Flow/Close on Steam Leak.1 See Footnote 1. See Footnote 1. Control Room Indication RCIC Turbine Trip Control Room Indication RCIC Turbine Control Logic 1 valves M0-2035, M0-2071 and CV-3503 are included as part of the ESEL, because although not credited in any FLEX strategy, HPCI is safety-related and would automatically initiate in the event of an SBO, and would be secured as part of the. ELAP procedures.

The test line return path to the CST represents a potential problem for implementation of FLEX strategies because any water that is directed from the Torus to the CST would be lost should either valve fail to close. Therefore, the HPCI test line valves were included in the ESEL to ensure that if HPCI runs prior to being secured; the flow is only directed to the reactor or Torus. M0-2035 is closed as part of SBO procedures.

Stevenson

& Associates ESEL Item ID Num 82 dPIS-13-84 83 PS-13-87A 84 PS-13-87B 85 PS-13-87C 86 PS-13-870 87 TS-13-79A-1 88 TS-13-79A-2 89 TS-13-79B-1 90 TS-13-79B-2 91 TS-13-79C-1 92 TS-13-79C-2 93 TS-13-790-1 94 TS-13-790-2 95 TS-13-80A-1 96 TS-13-80B-1 97 TS-13-80C-1 98 TS-13-800-1 99 TS-13-81A-1 100 TS-13-81 B-1 101 TS-13-81C-1 102 TS-13-81 0-1 103 TS-13-82A-1 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State RCIC HIGH STEAM FLOW energized energized ISOLATION RCIC TURBINE STEAM SUPPLY LOW PRESS energized energized ISOLATION RCIC TURBINE STEAM SUPPLY LOW PRESS energized energized ISOLATION RCIC TURBINE STEAM SUPPLY LOW PRESS energized energized ISOLATION RCIC TURBINE STEAM SUPPLY LOW PRESS energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION Sheet 35 of 54 Revision 2 Notes!Comments Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Stevenson

& Associates ESEL Item ID Num 104 TS-13-82B-1 105 TS-13-82C-1 106 TS-13-82D-1 107 TS-13-80A-2 108 TS-13-80B-2 109 TS-13-80C-2 110 TS-13-80D-2 111 TS-13-81 A-2 112 TS-13-81 B-2 113 TS-13-81 C-2 114 TS-13-810-2 115 TS-13-82A-2 116 TS-13-82B-2 117 TS-13-82C-2 118 TS-13-82D-2 119 PT-13-68 120 Pl-13-94 121 SY-7321 122 SCP-7925 123 SE-7925 124 LS-5 125 PT-13-70 126 Pl-13-95 127 PS-13-72A Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC STEAM LINE HIGH AREA TEMPERATURE energized energized ISOLATION RCIC TURBINE STEAM SUPPLY PRESSURE RCIC TURBINE INLET RCIC TURBINE SPEED SIGNAL CONVERTER RCIC TURBINE SPEED GOVERNOR EGM RCIC TURBINE SPEED MAGNETIC PICKUP RCIC TURBINE OVERSPEED TRIP LEVEL SWITCH RCIC TURBINE EXHAUST PRESSURE RCIC TURBINE EXHAUST RCIC HIGH TURBINE EXHAUST PRESSURE energized energized TURBINE TRIP Sheet 36 of 54 Revision 2 Notes/Comments Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Local per NX-7822-22-3 Control Room Indication Control Room Indication Control Room Indication Turbine Trip Stevenson

& Associates ESEL Item ID Num 128 PS-13-72B 129 L T-2-3-61 130 PT-6-53B 131 PI-6-90B 132 LT-2-3-85B 133 LI-2-3-85B 134 LT-2-3-72A 135 LT-2-3-72C 136 LIS-2-3-672A 137 LIS-2-3-672C 138 LS-2-3-672E 2 139 LT-2-3-72B 140 LT-2-3-72D 141 LIS-2-3-672B 142 LIS-2-3-672D 143 LS-2-3-672F 3 144 LT-2-3-85A 145 LI-2-3-85A 146 PT-6-53A 147 PI-6-90A 148 LT-2-3-112B 149 PT-4067B 150 PT-4067D 151 L T 3-112A 152 PT-4067A 153 PT-4067C 154 LS-23-74 155 LS-23-75 156 PCV-4897 157 PCV-4879 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State RCIC HIGH TURBINE EXHAUST PRESSURE energized energized TURBINE TRIP REACTOR FLOODING LEVEL REACTOR PRESSURE WIDE RANGE B (REF COLUMNA) FW REACTOR PRESS TO B LVL CONTROL REACTOR VESSEL WATER LEVEL (FROM COLUMNA) REACTOR VESSEL WATER LEVEL LO LO REACTOR L VL ECCS INITIATION LO LO REACTOR LVL ECCS INITIATION HPCI LO LEVEL START energized energized HPCI LO LEVEL START energized energized HPCI/RCIC HI LVL TURB TRIP LO LO REACTOR LVL ECCS INITIATION LO LO REACTOR LVL ECCS INITIATION HPCI LO LEVEL START energized energized HPCI LO LEVEL START energized energized HPCI/RCIC HI LVL TURB TRIP REACTOR VESSEL WATER LEVEL (FROM COLUMN B) REACTOR VESSEL WATER LEVEL REACTOR PRESSURE WIDE RANGE A (REF COLUMN B) FW REACTOR PRESS TO A LVL CONTROL RX WTR LEVEL B FUEL ZONE (REF COLUMN A) LOWLOWSET REACTOR PRESSURE LOWLOWSET REACTOR PRESSURE RX WTR LEVEL A FUEL ZONE (REF COLUMN B) LOWLOWSET REACTOR PRESSURE LOWLOWSET REACTOR PRESSURE HPCI COND STORAGE TANK INTLK HPCI COND STORAGE TANK INTLK AL T N2 TRAIN A PRESSURE REGULATOR AL T N2 TRAIN A PRESSURE REGULATOR Sheet 37 of 54 Revision 2 Notes/Comments Turbine Trip Control Room Indication Control Room Indication RCIC Pump Suction Transfer Instruments RCIC Pump Suction Transfer Instruments Stevenson

& Associates ESEL Item ID . Num 158 PCV-4903 159 PCV-4904 160 SV-4234 161 RV-4673 162 RV-4878 163 PCV-4898 164 PCV-4881 165 PCV-4905 166 PCV-4906 167 RV-4236 168 SV-4235 169 RV-4880 170 A0-2377 171 A0-2387 172 A0-2896 173 A0-2378 174 A0-2379 175 SV-2379 176 A0-2380 177 SV-2380 178 A0-2381 179 A0-2383 180 A0-2386 181 SV-4539 182 SV-4540 183 SV-4541 184 SV-4542 185 A0-4539 186 A0-4540 187 PS-4662 188 PS-4237 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State .Description Normal State Desired State AL T N2 TRAIN A PRESSURE REGULATOR AL T N2 TRAIN A PRESSURE REGULATOR AL T N2 TRAIN A MANIFOLD ISOLATION AL T N2 TRAIN A MANIFOLD RELIEF AL T N2 TRAIN A RELIEF AL T N2 TRAIN B PRESSURE REGULATOR AL T N2 TRAIN B PRESSURE REGULATOR AL T N2 TRAIN B PRESSURE REGULATOR AL T N2 TRAIN B PRESSURE REGULATOR AL T N2 TRAIN B MANIFOLD RELIEF AL T N2 TRAIN B MANIFOLD ISOLATION ALTERNATE N2 TRAIN B RELIEF DRYWELL & TORUS PURGE OTBD ISOL DWOTBDVENT TORUS MAIN EXHAUST TORUS PURGE INBD I SOL VACUUM RELIEF DAMPER SV FOR A0-2379 TORUS TO RX BLDG VACUUM BREAKER VACUUM RELIEF DAMPER SV FOR A0-2380 TORUS VACUUM RELIEF DRYWELL PURGE INBD I SOL TORUS VENT OW PURGE EXHAUST INBD N2 SUPPLY TO HPV INBOARD ISOLATION AO-4539 N2 SUPPLY FOR HPV OUTBD ISOLATION AO-4540 INBOARD N2 SUPPLY TO HPV RUPTURE DISC OUTBOARD N2 SUPPLY TO HPV RUPTURE DISC HARD PIPE VENT INBOARD ISOLATION VALVE HARD PIPE VENT OUTBOARD ISOLATION VALVE AL T N2 TRAIN A SUPPLY ISOLATION/ALARM AL T N2 TRAIN B SUPPLY ISOLATION/ALARM Sheet 38 of 54 Revision 2 Notes/Comments . Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Included for N2 System Integrity Only Fail Closed Fail Closed Stevenson

& Associates ESEL Item ID Num 189 L T-7338A 190 L Y-73388 191 L T-73388 192 PT-7251A 193 PLR-7251A 194 PT-7251 8 195 PY-7251 8 196 PLR-7251 8 197 TE-4073A 198 TE-4074A 199 TE-4075A 200 TE-4076A 201 TE-4077A 202 TE-4078A 203 TE-4079A 204 TE-4080A 205 TE-40738 206 TE-40748 207 TE-40758 208 TE-40768 209 TE-40778 210. TE-40788 211 TE-40798 212 TE-40808 213 TI-4072A Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State TORUS WIDE RANGE LEVEL TORUS WIDE RANGE LEVEL TORUS WIDE RANGE LEVEL DRYWELL WIDE RANGE PRESSURE OW PRESS-TOR LVL-DW RAD-ACCDIRNG DRYWELL WIDE RANGE PRESSURE PRIMARY CONTAINMENT WIDE RANGE PI ISOLATOR OW PRESS-TOR LVL-DW RAD-ACCDIRNG TORUS SENSOR 1 -SRV71 H I RCIC DISCHARGE AREA TORUS SENSOR 2 -SRV71 C DISCHARGE AREA TORUS SENSOR 3 -SRV71 8 DISCHARGE AREA TORUS SENSOR 4 -SRV71 G I HPCI DISCHARGE AREA TORUS SENSOR 5 -SRV71A DISCHARGE AREA TORUS SENSOR 6 -SRV71E DISCHARGE AREA TORUS SENSOR 7 -SRV71F DISCHARGE AREA TORUS SENSOR 8-SRV71 0 DISCHARGE . AREA TORUS SENSOR 1 -SRV71 H I RCIC DISCHARGE AREA TORUS SENSOR 2 -SRV71 C DISCHARGE AREA TORUS SENSOR 3-SRV71 8 DISCHARGE AREA TORUS SENSOR 4 -SRV71 G I HPCI DISCHARGE AREA TORUS SENSOR 5 -SRV71A DISCHARGE AREA TORUS SENSOR 6 -SRV71 E DISCHARGE AREA TORUS SENSOR 7 -SRV71F DISCHARGE AREA TORUS SENSOR 8-SRV71 0 DISCHARGE AREA DIV 1 TORUS TEMP Sheet 39 of 54 Revision 2 Notes/Comments Stevenson

& Associates ESEL Item ID Num 214 Tl-40728 215 TY-4072A 216 TY-40728 217 TE-4247A 218 TE-42478 219 TE-4247C 220 TE-42470 221 TE-4247E 222 TE-4247F 223 TE-4247G 224 TE-4247H 225 RE-4544 226 RM-4544 227 010 228 020 229 052 230 053 231 054 232 070 233 080 234 090 235 Y71 236 Y75 237 Y70 238 Y81 239 Y85 240 Y80 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment Operating State Description Normal State Desired State DIV 2 TORUS TEMP DIV 1 TORUS TEMP DIV 2 TORUS TEMP OW TEMPERATURE ELEMENT(DUAL ELEMENT A1/A2) OW TEMPERATURE ELEMENT(DUAL ELEMENT B1/B2) OW TEMPERATURE ELEMENT (DUAL ELEMENT C1/C2) OW TEMPERATURE ELEMENT (DUAL ELEMENT 01/02} OW TEMPERATURE ELEMENT (DUAL ELEMENT E1/E2) OW TEMPERATURE ELEMENT (DUAL ELEMENT F1/F2) OW TEMPERATURE ELEMENT (DUAL ELEMENT G1/G2) OW TEMPERATURE ELEMENT (DUAL ELEMENT H1/H2) HARD PIPE VENT RADIATION DETECTOR HARD PIPE VENT RADIATION MONITOR 125 VDC CHARGER FOR #11 BATI 125 VDC CHARGER FOR #12 BATI CHARGER, D3A (13) BATIERY CHARGER, 038 (13) BATIERY CHARGER, SWING D3A,D3B (13) BATIERY CHARGER, 068 (16) BATIERY CHARGER, D6A (16) BATIERY CHARGER, SWING D6A,D6B (16)BATIERY DIV 1120VAC CLASS 1E Energized Energized INVERTER DIV 1 FUSED Energized Energized DISCONNECT SWITCH DIV 1 UNINTERRUPTIBLE 120VAC CLASS 1E DIST Energized Energized PANEL DIV 2 120VAC CLASS 1 E . Energized Energized INVERTER DIV 2 FUSED Energized Energized DISCONNECT SWITCH DIV 2 UNINTERRUPTIBLE 120VAC CLASS 1E DIST Energized Energized PANEL Sheet 40 of 54 Revision 2 Notes/Comments DOOR #11 0 INSIDE ON SOUTH WALL, EC720 replaced charger, DOOR #103 INSIDE ON NORTH WALL, Mod 000370 replaced charger DOOR #109 INSIDE ON NORTH WALL DOOR #109 INSIDE ON NORTH WALL DOOR #109 INSIDE ON NORTH WALL Drawing Available NORTH SIDE NORTH SIDE Stevenson

& Associates ESEL Item ID Num 241 D1 242 D11 243 D2 244 D21 245 D33 246 D100 247 D31 248 D3A 249 D3B 250 D6A 251 D6B 252 D311 253 D312 254 D313 255 C-03 256 C-04 257 C-15 258 C-30 259 C-41 260 C-42 261 C-55 262 C-56 263 C-121 264 C-122 265 C-128 266 C-253A 267 C-253B 268 C-292 269 C-32 270 C-33 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Equipment . Operating State Description Normal State Desired State #11 BATTERY 125VDC DIV 1125VDC Energized Energized DISTRIBUTION CENTER #12 BATTERY 125VDC DIVI125 VDC Energized Energized DISTRIBUTION PANEL 125 VDC DISTRIBUTION Energized Energized CENTER DIV 2 125/250 VDC DISTRIBUTION PANEL DIV I 125/250 VDC DISTRIBUTION PANEL #13 (DIV 1) 125/250VDC BATTERY "A" #13 (DIV 1) 125/250VDC BATTERY "B" #16 (DIV 2) 125/250VDC BATTERY "A" #16 (DIV 2) 125/250VDC BATTERY "B" DIV 1 (RCIC) 250V DC MOTOR CONTROL Energized Energized CENTER 311 DIV 2 ( HPCI) 250V DC MOTOR CONTROL Energized Energized CENTER 312 DIV 1 (RCIC) 250V DC MOTOR CONTROL Energized Energized CENTER 313 RX AND CTMT COOLING AND ISOL BENCH BOARD RWC RECIRCULATING BENCH BOARD CHANNEL A PRIMARY !SOLAND RPS VERTICAL BOARD RCIC CABLE SPR RM CONTROL PANEL INBOARD ISOLATION RELAY PANEL OUTBOARD ISOLATION RELAY PANEL REACTOR VESSEL LEVEL AND PRESSURE RACK REACTOR VESSEL LEVEL AND PRESSURE RACK JET PUMP INSTRUMENT RACK JET PUMP INSTRUMENT RACK RCIC INSTRUMENT RACK SRV LOW LOW SET DIV 1 CONTROL PANEL SRV LOW LOW SET DIV 2 CONTROL PANEL ASDS BENCHBOARD A RHR, CORE SPRAY, ADS CONTROL PANEL B RHR, CORE SPRAY, ADS CONTROL PANEL Sheet 41 of 54 Revision 2 Notes/Comments DOOR#110 DOOR #11 0 INSIDE ON SOUTH WALL DOOR #103 INSIDE ON NORTH WALL DOOR #11 0 INSIDE ON SOUTH WALL DOOR#109 DOOR #109 DOOR #109 SOUTH SIDE NORTH SIDE CENTER CENTER NORTH OF C-05 Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates ESEL Equipment Operating State Item ID Description Normal State Desired State Num 271 C-303A ECCS DIV I ANALOG TRIP SYSTEM 272 C-3038 ECCS DIV II ANALOG TRIP SYSTEM 273 13A-K1 Control Relay de-energized 274 13A-K2 Control Relay de-energized 275 13A-K3 Control Relay de-energized de-energized 276 13A-K5 Control Relay de-energized de-energized 277 13A-K6 Control Relay de-energized 278 13A-K7 Control Relay de-energized de-energized 279 13A-K10 Control Relay de-energized de-energized 280 13A-K12 Control Relay de-energized 281 13A-K13 Control Relay de-energized 282 13A-K14 Control Relay de-energized de-energized 283 13A-K16 Control Relay de-energized 284 13A-K17 Control Relay de-energized de-energized 285 13A-K18 Control Relay de-energized de-energized 286 13A-K19 Control Relay de-energized de-energized 287 13A-K22 Control Relay de-energized de-energized 288 13A-K27 Control Relay de-energized 289 13A-K29 Control Relay de-energized 290 13A-K30 Control Relay de-energized 291 13A-K31 Control Relay de-energized de-energized 292 13A-K32 Control Relay de-energized 293 13A-K33 Control Relay de-energized de-energized 294 13A-K34 Control Relay de-energized 295 13A-K37 Control Relay energized energized 295 13A-K28 Control Relay de-energized de-energized 297 K102A Control Relay de-energized de-energized 298 K102B Control Relay de-energized de-energized 2 Listed as LIS-2-3-672E in the MNGP ESEP SEWS (14C4247-RPT-001) and 14C4247-CAL-004.

3 Listed as LIS-2-3-672F in the MNGP ESEP SEWS (14C4247-RPT-001) and 14C4247-CAL-004.

Sheet 42 of 54 Revision 2 Notes/Comments Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Stevenson

& Associates Sheet 43 of 54 Revision 2 ATTACHMENT B-ESEP HCLPF VALUES AND FAILURE MODES TABULATION Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 44 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL orTPNS) 06A 06B 070 080 090 Y71 -Y81 C-253B Table B-1: ESEP HCLPF Values and Failure Modes for EFT Building (RLGMREG1.6o

= 0.134g) Failure Mode HCLPF (g) Additional Discussions Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

---

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

• ----**--*-------**----C-289B [1] Anchorage Capacity 0.18 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

C-292 Screened out > RLGM Component screened by SRT Judgment.

r-* C-303B Equipment Capacity 0.25 Component evaluated by HCLPF calculation LY-7338B Screened out > RLGM Rule of Box to C-292. See Parent 0100 Screened out > RLGM Component screened by SRT analysis.

""" Y70 Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

--*-----------

-****--**--*

---

*----

Y75 Screened out > RLGM Component screened by SRT Judgment Y80 Equipment Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002. ---------*--

Y85 Screened out > RLGM Component screened by SRT Judgment Ll S-2-3-6 72 B Functionality Capacity 0.00 Rule of Box to C-303B. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-0_04.

No public capacity data available for this item. LIS-2-3-6720 Functionality Capacity 0.00 Rule of Box to C-303B. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. --------------------------------

LS-2-3-672F Functionality Capacity 0.00 Rule of Box to C-303B. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. PY-7251B Screened out > RLGM Rule of Box to C-292. See Parent. -*-* -------*--*-

RM-4544 Anchorage Capacity 0.18 Rule of Box to C-289B. See Parent. TY-4072B Anchorage Capacity 0.18 Rule of Box to C-289B. See Parent. Notes: [1] This item is not included in the ESEL; however, it is evaluated since it is a parent to ESEL items Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 45 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL orTPNS) 0311 0312 0313 01 -----.. 02 --03A 03B 010 020 052 -053 054 C-253A C-289A [1] C-30 ---C-303A C-32 --C-33 --C-41 ----C-42 C-03 ------------

C-04 C-05 [1] C-15 C-02 [1] C-128 Table B-2: ESEP HCLPF Values and Failure Modes for RX, ADMIN, & Turbine Building (RLGMrAFT

= 0.19g) Failure Mode HCLPF (g) Additional Discussions Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis.

Anchorage Capacity 0.23 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

-***-*-*-**

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

• • -------Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Block Wall Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---*-*-"""""

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Component evaluated by HCLPF calculation 14C4247-CAL-002.

The Anchorage Capacity 0.21 cabinet itself is seismically adequate; however, some of the relays inside are "bad actors". These are evaluated separately.

See Relay HCLPF calculation 14C4247-CAL-004.

---

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

• • -*------

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

---

Component evaluated by HCLPF calculation 14C4247-CAL-002.

The Anchorage Capacity 0.21 cabinet itself is seismically adequate; however, some of the relays inside are "bad actors". These are evaluated separately.

See Relay HCLPF calculation 14C4247-CAL-004.

---Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Anchorage Capacity 0.21 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

• -**--*--*-----

Equipment Capacity 0.33 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adequate by SRT.

---

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 46 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) Additional Discussions or TPNS) L T-7338A Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adequate by SRT. L T-7338B Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adequate by SRT.

---

C-121 Anchorage Capacity 0.24 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, adjacent block wall is evaluated in 14C4247-CAL-003.

---

---

---

C-122 Anchorage Capacity 0.24 Component evaluated by HCLPF calculation 14C4247-CAL-002.

LS-23-74 Functionality Capacity 0.00 Functionality was evaluated in 14C4247-CAL-004.

No capacity data for (HCLPF < RLGM) these items. LS-23-75 Functionality Capacity 0.00 Functionality was evaluated in 14C4247-CAL-004.

No capacity data for (HCLPF < RLGM) these items.

-***-*-*------

• -----------

""" ----C-55 Block Wall Capacity & 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

Also, Anchorage Capacity adjacent block wall is evaluated in 14C4247-CAL-003.

---

---

*--

C-56 Anchorage Capacity 0.25 Component evaluated by HCLPF calculation 14C4247-CAL-002.

---

---

PT-7251A Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adeguate by SRT. PT-7251B Screened out > RLGM Meets NP-6041 Table 2-4 caveats I anchorage (as applicable) judged to be adequate by SRT. IR-PCV-4879

[1] Screened out > RLGM Component is judged to be adequate per SRT. IR-PCV-4881

[1] Block Wall Capacity 0.28 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

Fl-13-102

[2] Equipment Capacity 0.33 Rule of Box to C-04. See Parent. LS-5 Screened out > RLGM Rule of Box to S-200. See Parent SCP-7925 Screened out > RLGM Rule of Box to S-200. See Parent SE-7925 Screened out > RLGM Rule of Box to P-211. See Parent ----------

-C-215 [1] Anchorage Capacity 0.24 Rule of Box to C-122. See Parent dPIS-13-83 Functionality Capacity 0.05 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C424 7 -CAL -004. dPIS-13-84 Functionality Capacity 0.05 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247 -CAL-004.

L T-2-3-112A Anchorage Capacity 0.24 Rule of Box to C-122. See Parent PS-13-87A Functionality Capacity 0.00 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No capacity data for these items. -----PS-13-87B Functionality Capacity 0.00 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No capacity data for these items. ----PS-13-87C Functionality Capacity 0.00 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No capacity data for these items. PS-13-870 Functionality Capacity 0.00 Rule of Box to C-122. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No capacity data for these items. PT-4067A Anchorage Capacity 0.24 Rule of Box to C-122. See Parent PT-4067C Anchorage Capacity 0.24 Rule of Box to C-122. See Parent -PS-4237 Block Wall Capacity 0.28 Rule of Box to IR-PCV-4881.

See Parent --PS-4662 Screened out > RLGM Rule of Box to IR-PCV-4879.

See Parent 011 Block Wall Capacity 0.19 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 47 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) Additional Discussions or TPNS) 021 Block Wall Capacity 0.19 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

031 Block Wall Capacity 0.19 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

033 Block Wall Capacity 0.19 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

SY-7321 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. TS-13-82C-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-82C-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004. ------TS-13-820-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-820-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7 -CAL -004. -------------TE-4073A Screened out > RLGM Component screened by SRT Judgment TE-4073B Screened out > RLGM Component screened by SRT Judgment TE-4074A Screened out > RLGM Component screened by SRT Judgment ---:------* TE-4074B Screened out > RLGM Component screened by SRT Judgment ---*---*--------

---

TE-4075A Screened out > RLGM Component screened by SRT Judgment TE-4075B Screened out > RLGM Component screened by SRT Judgment TE-4076A Screened out > RLGM Component screened by SRT Judgment ---*-*--------TE-4076B Screened out > RLGM Component screened by SRT Judgment TE-4077A Screened out >

Component screened by SRT Judgment TE-4077B Screened out > RLGM Component screened by SRT Judgment TE-4078A Screened out > RLGM Component screened by SRT Judgment ---TE-4078B Screened out > RLGM Component screened by SRT Judgment TE-4079A Screened out > RLGM Component screened by SRT Judgment TE-4079B Screened out > RLGM Component screened by SRT Judgment TE-4080A Screened out > RLGM Component screened by SRT Judgment

---

.. *----------TE-4080B Screened out > RLGM Component screened by SRT Judgment RE-4544 Screened out > RLGM Component screened by SRT Judgment ---------TE-4247A Screened out > RLGM Component screened by SRT Judgment -*-*--------

---

---

TE-4247B Screened out >RLGM Component screened by SRT Judgment L T-2-3-112B Screened out > RLGM Component screened by SRT Judgment PT-4067B Screened out > RLGM Component screened by SRT Judgment ------------------*

• ----------

PT-40670 Screened out > RLGM Component screened by SRT Judgment ------------

---

TS-13-79A-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7 -CAL -004. -----------

TS-13-79A-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 48 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) or TPNS) Additional Discussions TS-13-798-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

TS-13-798-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

TS-13-79C-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7 -CAL -004. TS-13-79C-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

-*--------TS-13-790-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

---

--

-TS-13-790-2 Screened out Component screened by SRT Judgment.

Functionality was evaluated in -> RLGM 14C4247-CAL-004.

---

TS-13-80A-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluate-d-in

_____ 14C424 7 -CAL-004. -----TS-13-80A-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was

_____ 14C4247-CAL-004.

TS-13-808-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated-in

_____ 14C4247-CAL-004.

TS-13-808-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was -evaluated in 14C4247-CAL-004.

TS-13-80C-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-80C-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7-CAL-004.

---

TS-13-800-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-800-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81A-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81A-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81 8-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81 8-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81 C-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-81 C-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

--*---TS-13-810-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-810-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7-CAL-004.

TS-13-82A-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-82A-2 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C4247-CAL-004.

TS-13-828-1 Screened out > RLGM Component screened by SRT Judgment.

Functionality was evaluated in 14C424 7-CAL-004.

---

TS-13-828-2 Screened out > RLGM Component screened by SRT Judgment.

Functionalitywas evaluated in 14C4247-CAL-004.

---

TE-4247C Screened out > RLGM Component screened by SRT Judgment ----------TE-42470 Screened out > RLGM Component screened by SRT Judgment TE-4247E Screened out > RLGM Component screened by SRT Judgment -----------------------

TE-4247F Screened out > RLGM Component screened by SRT Judgment TE-4247G Screened out > RLGM Component screened by SRT Judgment TE-4247H Screened out > RLGM Component screened by SRT Judgment Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 49 of 54 Revision 2 Stevenson

& Associates Equip ID (IVIPL Failure Mode HCLPF (g) Additional Discussions orTPNS) LIS-2-3-672A Functionality Capacity 0.00 Rule of Box to C-303A. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. LIS-2-3-672C Functionality Capacity 0.00 Rule of Box to C-303A. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. LS-2-3-672E Functionality Capacity 0.00 Rule of Box to C-303A. See Parent. Functionality was evaluated in (HCLPF < RLGM) 14C4247-CAL-004.

No public capacity data available for this item. TY-4072A Anchorage Capacity 0.21 Rule of Box to C-289A. See Parent. -* ... Fl-13-91 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. *------FIC-13-91 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. *-*--LI-2-3-85A Equipment Capacity 0.33 Rule of Box to C-05. See Parent. -*-------LI-2-3-85B Equipment Capacity 0.33 Rule of Box to C-05. See Parent. Pl-13-93 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. -* -----* Pl-13-94 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. . --------------------

Pl-13-95 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. --Pl-13-96 Equipment Capacity 0.33 Rule of Box to C-04. See Parent. PI-6-90A Equipment Capacity 0.33 Rule of Box to C-05. See Parent.

---

* ------------*

---

PI-6-90B Equipment Capacity 0.33 Rule of Box to C-05. See Parent. PLR-7251A Equipment Capacity 0.33 Rule of Box to C-03. See Parent. PLR-7251B Equipment Capacity 0.33 Rule of Box to C-03. See Parent. ----------TI-4072A Equipment Capacity 0.33 Rule of Box to C-02. See Parent. -------*--

---*-*------------TI-4072B Equipment Capacity 0.33 Rule of Box to C-02. See Parent. FS-13-57 Screened out > RLGM Rule of Box to C-128. See Parent. FT-13-58 Screened out > RLGM Rule of Box to C-128. See Parent. ---*---LS-7323 Screened out > RLGM Rule of Box to S-200. See Parent PS-13-67A Screened out > RLGM Rule of Box to C-128. See Parent. Functionality was evaluated in 14C4247-CAL-004.

---PS-13-72A Screened out > RLGM Rule of Box to C-128. See Parent. ----PS-13-72B Screened out > RLGM Rule of Box to C-128. See Parent. --**---------------

PT-13-60 Screened out > RLGM Rule of Box to C-128. See Parent. --**---PT-13-65 Screened out > RLGM Rule of Box to C-128. See Parent. --PT-13-68 Screened out > RLGM Rule of Box to C-128. See Parent. PT-13-70 Screened out > RLGM Rule of Box to C-128. See Parent. --L T-2-3-61 Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. LT-2-3-72A Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. LT-2-3-72B Anchorage Capacity 0.25 Rule of Box to C-56. See Parent. LT-2-3-72C Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. --LT-2-3-720 Anchorage Capacity 0.25 Rule of Box to C-56. See Parent.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 50 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) or TPNS) Additional Discussions L T-2-3-85A Anchorage Capacity 0.25 Rule of Box to C-56. See Parent. --*** L T-2-3-85B Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. ---------------------PT-6-53A Anchorage Capacity 0.25 Rule of Box to C-56. See Parent. PT-6-53B Anchorage Capacity 0.25 Rule of Box to C-55. See Parent. S-200 Screened out > RLGM Rule of Box to P-207. See Parent. P-207 Screened out > RLGM Component screened by SRT Judgment .. ------**----

P-210 Screened out > RLGM Component screened by SRT Judgment *---------

P-211 Screened out > RLGM Rule of Box to P-21 0. See Parent. CV-2104 Screened out > RLGM Component screened by SRT Judgment . --------PCV-2092 Screened out > RLGM Component screened by SRT Judgment RV-1745 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -**-RV-2097 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) by SRT.

---

Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate . -RV-2103 Screened out > RLGM by SRT. CV-3503 Screened out > RLGM Component screened by SRT analysis A0-2377 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be adequate by SRT. -----------... A0-2378 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. A0-2379 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. A0-2380 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be bySRT. **----A0-2381 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT . .. A0-2383 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. A0-2896 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -------A0-4539 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. A0-4540 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-4878 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-4880 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be adequate by SRT. -** SV-4234 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ------SV-2-71A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ----*--*-* __ , ______ SV-2-71B Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. SV-2-71C Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. SV-2-710 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. *-** ... ------SV-2-71E Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as judged to be adequate by SRT . ..

Report. No.: 14C424 7 -RPT-002 Expedited Seismic Evaluation Process Report Sheet 51 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) orTPNS) Additional Discussions SV-2-71 F Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --------SV-2-71G Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. SV-2-71 H Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT.

---

SV-2-71J Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -**** -------SV-2-71 K Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. SV-2-71 L Screened out > RLGM Meets NP-6041 Table 2-4 caveats applicable)judged to be adequate by SRT. --*------* SV-2-71M Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -----------A0-2386 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged by SRT. A0-2387 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT . . -------* RV-3242A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) by SRT. RV-3243A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to adequate by SRT. RV-3244A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-3245A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ---RV-7440A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-7441A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. RV-7467A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. ------RV-7468A Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. RV-4236 Block Wall Capacity 0.28 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

RV-4673 Screened out > RLGM Component screened by SRT analysis.

---

SV-4235 Block Wall Capacity 0.28 Component is judged to be adequate per SRT. Block wall evaluated in HCLPF Calculation 14C4247-CAL-003.

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PCV-4879 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate _ SRT. Also, Rule of Box to IR-PCV-4879, see parent. PCV-4881 Block Wall Capacity 0.28 Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate -----by SRT. Also, of Box to IR-PCV-4881, see parent. PCV-4897 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Also, Rule of Box to IR-PCV-4879, see parent. ---------PCV-4898 Block Wall Capacity 0.28 Meets NP-6041 Table 2-4 caveats (as applicable) judged to by SRT. Also, Rule of Box to IR-PCV-4881, see parent. PCV-4903 Screened out > RLGM Meets NP-6041Table 2-4 caveats (as applicable) judged to be adequate by SRT. Also, Rule of Box to IR-PCV-4879, see parent. PCV-4904 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate ----tJY_SRT. Also, Rule of Box to IR-PCV-4879, see parent. PCV-4905 Block Wall Capacity 0.28 Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Also, Rule of Box to IR-PCV-4881, see parent. PCV-4906 Block Wall Capacity 0.28 Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Also, Rule of Box to IR-PCV-4881, see parent. H0-8 Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --

Stevenson

& Associates Equip ID (MPL or TPNS) M0-2078 M0-2106 --M0-2096 M0-2080 M0-2100 M0-2101 M0-2110 M0-2071 M0-3502 M0-2035 M0-2076 M0-2107 SV-2082A SV-20828 SV-2104 --SV-2848 SV-2849 SV-4541 -----SV-4542 SV-2379 SV-2380 SV-4539 SV-4540 --**-* RV-2-71A RV-2-71 B RV-2-71C RV-2-710 RV-2-71E RV-2-71 F RV-2-71G RV-2-71H Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 52 of 54 Revision 2 Failure Mode HCLPF (g) Additional Discussions Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. -. Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis. -----Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis. "

Screened out > RLGM Component screened by SRT analysis.

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Screened out > RLGM Component screened by SRT analysis.

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Screened out > RLGM Component screened by SRT analysis.

Screened out > RLGM Component screened by SRT analysis.

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Screened out > RLGM Component screened by SRT Judgment Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable}

judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ----Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --***-

Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT . .. . -Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. ----* Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. -------

Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate bySRT. ----------------*-

Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT. --Screened out > RLGM Meets NP-6041 Table 2-4 caveats (as applicable) judged to be adequate by SRT.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 53 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) Additional Discussions or TPNS) E-200A Anchorage Capacity 0.19 Component evaluated by HCLPF calculation 14C4247-CAL-002.

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Anchorage Capacity E-200B (HCLPF < RLGM) 0.181 Component does not screen out; a more detailed evaluation is required.

E-203 Screened out > RLGM Component screened by SRT analysis.

E-205 Screened out. > RLGM Rule of Box to P-207. See Parent. T-73 Screened out > RLGM Component screened by SRT Judgment T-57A Screened out > RLGM Component screened by SRT Judgment.

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T-57B Screened out > RLGM Component screened by SRT Judgment.

T-57C Screened out > RLGM Component screened by SRT Judgment.

T-570 Screened out > RLGM Component screened by SRT Judgment.

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T-57E Screened out > RLGM Component screened by SRT Judgment.

T-57F Screened out > RLGM Component screened by SRT Judgment. T-57G Screened out > RLGM Component screened by SRT Judgment.

--T-57H Screened out > RLGM Component screened by SRT Judgment.

13A-K1 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K10 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF.

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13A-K12 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K13 (HCLPF < RLGM) 0.00 is a "bad actor, and does not have any seismic capacity under the undesirable state. The relay is ROB to C-30. ---Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K14 (HCLPF < RLGM) 0.00 is a "bad actor, and does not have any seismic capacity under the undesirable state. The relay is ROB to C-30. --* 13A-K16 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The re)ay is a ROB to C-30, and is governed by the host HCLPF. -----------Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K17 0.00 is a "bad actor, and does not have any seismic capacity under the (HCLPF < RLGM) undesirable state. The relays is ROB to C-30. f----*-

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--13A-K18 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K19 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K2 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K22 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. **-* -------13A-K27 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K28 0.00 is a "bad actor, and does not have any seismic capacity under the (HCLPF < RLGM) undesirable state. The relay is ROB to C-33. --------Functionality Capacity Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay 13A-K29 (HCLPF < RLGM) 0.00 is a "bad actor, and does not have any seismic capacity under the undesirable state. The relay is ROB to C-33.

Report. No.: 14C4247-RPT-002 Expedited Seismic Evaluation Process Report Sheet 54 of 54 Revision 2 Stevenson

& Associates Equip ID (MPL Failure Mode HCLPF (g) orTPNSl Additional Discussions 13A-K3 Functionality Capacity 0.00 Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay (HCLPF < RLGM) is a "bad actor", and does not have any seismic capacity under the undesirable state. The relay is ROB to C-30 . .. . --*-13A-K30 Functionality Capacity 0.00 Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay (HCLPF < RLGM) is a actor', and does not have any seismic capacity under the . undesirable state. The relay is ROB to C-33. _" ____ 13A-K31 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-33, and is governed by the host HCLPF.

13A-K32 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-OM*.

The relay is a ROB to C-33, and is governed by the host HCLPF. Component evaluated in Relay Calculation 14C4247:CAl-004.

The relay is 13A-K33 Anchorage Capacity 0.21 a ROB to C-30, and is tbe host HCLPF. 13A-K34 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. ----------13A-K37 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K5 Functionality Capacity 0.00 Component evaluated in Relay Calculation 14C4247-CAL-004.

This relay (HCLPF < RLGM) is a "bad actor', and does not have any seismic capacity under the undesirable state. The relay is ROB to C-30. -------------13A-K6 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. 13A-K7 Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-30, and is governed by the host HCLPF. K102A Anchorage Capacity 0.21 Component evaluated in Relay Calculation 14C4247-CAL-004.

The relay is a ROB to C-303A, and is governed by the host HCLPF. K102B Functionality Capacity 0.06 evaluated Relay Calculation 14C4247-CAL-004.

This relay . (HCLPF < RLGM) IS ROB to C-303B. The In-cabinet structure response exceeds the capacity of the relay. Notes: [1] This item is not included in the ESEL; however, it is evaluated since it is a parent to ESEL items