Text

Response to Request for Additional Information Regarding the License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.
	ML18156A129
Person / Time
Site:	Wolf Creek
Issue date:	05/29/2018
From:	Mccoy J; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ET 18-0014
	Download: ML18156A129 (44)
	v • d • e

Jaime H. McCoy Vice President Engineering W$LFCREEK

'NUCLEAR OPERATING CORPORATION May 29, 2018 ET 18-0014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

Subject:

1) Letter ET 17-0010, dated June 28, 2017, from J. H. McCoy, WCNOC, to USNRC 2) Letter ET 18-0007, dated February 15, 2018, from J. H. McCoy, WCNOC, to USNRC 3) Letter dated April 6, 2018, from B. K. Singal, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station, Unit 1 -Request for Additional Information Re: License Amendment Request for Addition of New Technical Specification

3. 7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System" (CAC NO. MF9961; EPID L-2017-LLA-0262)" Docket No. 50-482: Response to Request for Additional Information Regarding the License Amendment Request for Addition of New Technical Specification 3.7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System" To Whom It May Concern: Reference 1 provided a license amendment request that proposed to add new TS 3.7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System," to the Wolf Creek Generating Station (WCGS) Technical Specifications (TS). During the week of November 7, 2017, the Nuclear Regulatory Commission (NRC) staff performed a regulatory audit at the WCGS site in support of the review of the proposed TS 3.7.20. Reference 2 provided requested supplemental information as a result of the regulatory audit. Reference 3 provided a request for additional information (RAI) related to the license amendment request provided in Reference

1. P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET I ET 18-0014 Page 2 of 3 In References 1, 2, 3 and in Wolf Creek Nuclear Operating Corporation's (WCNOC) responses to the RAls, reference is made to a planned modification for the installation of recirculation fans, dampers and associated equipment for a recirculation subsystem.

Installation and testing of Train 'A' of the recirculation subsystem is complete.

Installation and testing of Train 'B' is expected to be completed by June 4, 2018. On April 26, 2018, Wolf Creek Nuclear Operating Corporation (WCNOC) personnel contacted Balwant Singal, NRC Project Manager, and provided notification that additional time was required to complete some of the RAI responses.

A revision to calculation GK-E-001, "Electrical Equipment Heat Loads in ESF SWGR, DC SWBD and Battery Rooms," was determined to be required based on the RAls. As a result of this revision, the new heat loads are being utilized in a revision to calculation GK-M-016, "Wolf Creek Control Building Loss of Class 1 E A/C GOTHIC Room Heat Up Analysis With Installed Crosstie Fans and Louvers." Rerunning the GOTHIC models with the new heat loads and revising calculation GK-M-016 cannot be completed within* the required submittal date of this RAI response.

WCNOC has received preliminary results of the GOTHIC model runs for Cases 1 through 4. These preliminary results show an approximate

+/-1°F change from the results provided in Table 4 of Reference 1, with no rooms exceeding 104°F. Attachment I provides WCNOC's responses to the RAls. The additional information provided in Attachment I does not expand the scope of the application and does not impact the conclusions of the No Significant Hazards Consideration provided in Reference

1. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this letter is provided to the designated Kansas Sate official.

SPCB RAl-2 requested that the regulatory commitments specified in Reference 1 be consistent with the proposed modification description provided in Reference

2. The list of regulatory commitments has been updated in the response to SPCB RAl-2. This letter contains no new regulatory commitments.

If you have any questions concerning this matter, please contact me at (620) 364-4156, or Cynthia R. Hafenstine at (620) 364-4204.

Sincerely, JHM/rlt

Attachment:

I Response to Request for Additional Information II Revised TS Bases Pages (for information only)

Enclosure:

Piping and Instrumentation Diagrams for the Control Building HVAC cc: K. M. Kennedy, (NRC), w/a B. K. Singal (NRC), w/a K. S. Steves (KDHE), w/a N. H. Taylor (NRC), w/a Senior Resident Inspector (NRC), w/a ET 18-0014 Page 3 of 3 STATE OF KANSAS COUNTY OF COFFEY ss Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief. By~~==~~=-L-1.~~___!:..~.::.._:~~~~~~

Jamie H. cCoy Vice Pr ident Engineering SUBSCRIBED and sworn to before me this 2.._qfj day of mCLd , 2018. ~tiic,JLJJ GAYLE SHEPHEARD My Appointment Expires July 24, 2019 Expiration Date --~-/ ~-c-f-'-f/_]__(.)--'-f__,1'---

1 Attachment I to ET 18-0014 Page 1 of 32 Response to Request for Additional Information Reference 1 provided a license amendment request that proposed to add new TS 3.7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System," to the Wolf Creek Generating Station (WCGS) Technical Specifications (TS}. During the week of November 7, 2017, the NRG staff performed the regulatory audit at the WCGS site. Reference 2 provided requested supplemental information as

a result of the regulatory audit. Reference 3 provided a request for additional information (RAI) related to the license amendment request provided in Reference

1. On April 26, 2018, Wolf Creek Nuclear Operating Corporation (WCNOC) personnel contacted Balwant Singal, NRG Project Manager, and provided notification that additional time is required to complete some of the RAI responses.

A revision to calculation GK-E-001, "Electrical Equipment Heat Loads in ESF SWGR, DC SWBD and Battery Rooms," was determined to be required based on the RAls. This also impacts several additional calculations associated with the modification.

The NRG Request is provided in italics. RA/ SCPB-1 Attachment II of the letter dated June 28, 2018, states, in part: During normal or emergency operations, each Class 1 E electrical equipment A/C train maintains the temperature in its associated electrical equipment rooms at a temperature of :5 [less than or equal to] 90 °F [degrees Fahrenheit}.

The Class 1 E electrical equipment A/C trains are designed in accordance with Seismic Category I requirements.

Please describe the safety classification of the Class 1 E electrical equipment A/C train. Response:

Updated Safety Analysis Report (USAR) Table 3.2-1 lists the safety class assigned to applicable systems and components in accordance with ANSI N18.2, "Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants," November 1973. USAR Table 3.2-1 (Sheet 17) specifies that the Class 1 E Electrical Equipment Air Conditioning System is ANS Safety Class 3. Additionally, USAR Section 9.4.1.1.1, "Safety Design Bases," specifies that the Class 1 E Electrical Equipment Air Conditioning System is safety related and is required to function following a Design Basis Accident and to achieve and maintain the plant in a post-accident safe shutdown condition.

SCPB RAl-2 Attachment VI, "List of Regulatory Commitments," of the letter dated June 28, 2017, describes the proposed plant modifications including recirculation fans and associated dampers and LED lighting being implemented in support of the LAR for 2016 feet and 2000 feet levels. Attachment I (page 6, Item 9), of the letter dated February 15, 2018, describes the planned modification in detail, including the number of safety-related fans; isolation dampers; fire dampers; transition grills; heating, ventilation, and air-conditioning (HVAC) ductwork; and power supplies and control cables. Also, the letter described the post modification testing. As a result, the regulatory commitments specified in the letter dated Attachment I to ET 18-0014 Page 2 of 32 June 28, 2017, are not consistent with the proposed modification description provided in the Jetter dated February 15, 2018. a. Please revise the regulatory commitments specified in the Jetter dated June 28, 2017, to be consistent with the proposed modification description provided in the letter dated February 15, 2018. Regulatory commitments incorporated in the description of the LAR may be removed. b. Please provide a copy of the Piping and Instrumentation Diagram for the Control Building (HVAC) system for the NRG staff to fully understand the proposed planned modification described in the application.

Response:

a. The response to NRC Item 9 in Reference 2 provided additional details on the planned modification.

The response provided specific number of components being added at the time of the response.

WCNOC is revising the regulatory commitments provided in Reference 1 but is not including the specific number of components as this may change during final design and installation.

The below List of Regulatory Commitments replaces the list provided in Attachment VI of Reference

1. Regulatory Commitment Due Date Planned modifications are in process to achieve the capability It is anticipated that the for one Class 1 E electrical equipment A/C train to provide planned modifications will be adequate cooling for both trains of electrical equipment during completed during the Spring normal and accident conditions by 'design changes. The 2018 Refueling Outage. planned modifications include the following:

Computer points are used to verify the DC switchboard rooms The bulk of the field work was completed in Spring and ESF switchgear room temperatures are less than 87°F 2018 Refueling Outage. and provide an alarm on the main control board. The Remaining work includes temperature limits established for these rooms is :5 90°F (this fireproofing and indicating includes an allowance for instrument error of +/-3°F). The lights which are scheduled to alarm setpoint on the associated temperature indicators will be completed May 31, 2018. be lowered to 83°F. Installation of safety related components that includes recirculation fans, isolation dampers, fire dampers, transition grills, HVAC ductwork, and associated power supplies, power and control cables. Since the installation of the additional cooling capability is considered a safety related modification, the appropriate Class 1 E power is being utilized and the appropriate qualification of equipment is being performed.

A post modification test plan has been developed and is part of the design change for the installation of the recirculation fans and associated equipment.

LED lighting installed in the Class 1 E electrical equipment rooms to replace the fluorescent liQhts. --_J Attachment I to ET 18-0014 Page 3 of 32 b. The following Piping and Instrumentation Diagrams for the Control Building HVAC are provided in Enclosure I: M-12GK01, Revision 14 M-12GK02, Revision 22 M-12GK03, Revision 21 M-12GK04, Revision 14 WIP-M-12GK05-000-A-1 SCPB RAl-3 Attachment II (page 3) of the letter dated June 28, 2017, states, in part: The Class 1 E electrical equipment AIC trains provide a suitable environment for the Class 1 E electrical equipment.

Attachment

\I, "Proposed TS Bases Changes," of the letter dated June 28, 2017, states, in part, the following for SR 3. 7. 20. 2 Bases: Testing of the Class 1 E Electrical Equipment Air Conditioning (AIC) System condenser heat exchangers under design conditions is impractical.

This SR verifies that the heat removal capability of the air conditioning units is adequate to remove the heat load assumed in the control room during design basis accidents.

This SR consists of verifying the heat removal capability of the condenser heat exchanger ( either through performance testing or inspection), ensuring the proper operation of major components in the refrigeration cycle, verification of unit air flow capacity, and water flow measurement

... The bases for SR 3. 7. 20. 2 state that this SR verifies that the heat removal capability of the AIC units is adequate to remove the heat load assumed in the control room during design basis accidents.

Please clarify if the intent was to state that this SR verifies that the heat removal capability of the AIC units is adequate to remove the heat load assumed in the Class 1 E Electrical area during design basis accidents.

Response:

It was the intent of the SR 3. 7.20.2 Bases to state that this SR verifies the heat removal capability of the Cl~ss 1 E electrical equipment A/C trains is adequate to remove the heat load assumed in the affected rooms during design basis accidents.

The revised TS Bases in Attachment II (Page 3 of 3) of this submittal reflects this correction and replaces Page 6 of 6 of Attachment V in Reference

1. The revised TS Bases page is provided for information only. SCPB-RAl-4 Attachment I (page 7, Item 17), of the letter dated February 15, 2018, the licensee has proposed to develop a new technical requirements manual (TRM) specification associated with the recirculation subsystem and include associated SRs in the TRM.

Attachment I to ET 18-0014 Page 4 of 32 Please provide description of the proposed TRM. Response:

In Reference 2, WCNOC proposed a new Technical Requirements Manual (TRM) specification to address the NRC concern about surveillance testing of the recirculation subsystem trains. The proposed TRM (TR 3. 7 .20, "Class 1 E Electrical Equipment Air Conditioning (A/C) Recirculation Subsystem")

would require two independent Class 1 E electrical equipment A/C recirculation subsystem trains be FUNCTIONAL in MODES 1, 2, 3 and 4, and available to be placed in service if a Class 1 E electrical equipment A/C train is determined to be inoperable.

Required Actions include restoring the nonfunctional recirculation subsystem train within 30 days. With two nonfunctional recirculation subsystem trains, the Required Actions specify restoring one train in 7 days. Technical Surveillance Requirements (TSR) are proposed for the testing of the recirculation subsystem.

The TSRs verify each recirculation subsystem train is available and each subsystem train actuates and provides recirculation air flow. RA/ APHB-1 The licensee's letter dated June 28, 2017, includes information regarding potential train impacts related to fire protection, hydrogen gas buildup. The NRG staff is evaluating if the proposed operator action creates a condition that adversely impacts plant system independence, redundancy, or separation.

Please provide or summarize evaluations that addresses maintaining train independence, redundancy, and separation when opening a communication pathway between the Operable and Inoperable redundant trains for any other applicable hazard or condition such as, flooding or any requirements to maintain negative pressure in the affected areas for HVAC/radiologica/

control issues (Reference NUREG-1764, Section 4, "Level II Review Guidance'?.

Response:

The engineering disposition issued in support of the modification to install the recirculation subsystem details the impacts to the plant from installation of the communication pathways and operation of the recirculation subsystem.

The recirculation subsystem is maintained train-separated, such that the 'A' recirculation subsystem train operates using the 'A' Class 1 E electrical equipment A/C train when the 'B' Class 1 E Electrical Equipment A/C train is out of service. Similarly, the 'B' recirculation subsystem train operates using the 'B' Class 1 E Electrical Equipment A/C train when the 'A' Class 1 E Electrical Equipment A/C train is out of service. Each recirculation subsystem train is powered from the associated diesel-backed electrical supply. Each recirculation subsystem train does not rely on any action from the opposite train, thus train independence is maintained.

The use of the recirculation subsystem to maintain OPERABILITY of both trains of Class 1 E electrical equipment is not intended to deliver redundancy to the Class 1 E Electrical Equipment A/C System. Rather, the recirculation subsystem provides a consistent, verifiable method of circulating the air between the two trains of Class 1 E electrical equipment rooms. The mitigating actions proposed in new TS 3. 7.20 maintain the Class 1 E electrical equipment OPERABLE (but degraded) because, except for the loss of the active cooling function of one of the Class 1 E electrical equipment A/C trains (a support system), the Class 1 E electrical equipment itself is still fully OPERABLE.

Attachment I to ET 18-0014 Page 5 of 32 While the recirculation subsystem is in standby (the normal state of the subsystem), there is no active mixing of the air between the two trains of Class 1 E electrical equipment rooms. There are open duct pathways that cross-connect the 'A' train and 'B' train rooms. However, these duct paths being installed contain fire dampers that maintain separation of the different fire areas. Additionally, the ductwork that serve the recirculation fans on the 2000' level contain bubble-tight control dampers (normally closed and spring-closed operation on loss of power) to seal the rooms in the event of a halon discharge.

All of the through-wall ducts located in the Class 1 E electrical equipment rooms are located high enough on the walls, or in the ceiling, such that there is no opportunity for any potential flooding in one room to impact any other rooms. Generally, the Class 1 E electrical equipment rooms do not contain any water-bearing pipes to serve as a flood hazard, with the primary exception being the 'B' train switchgear room on 2000', where the Essential Service Water (ESW) piping to the emergency diesel generators (EDGs) briefly passes through the corner of the room (the EDGs are located adjacent to the switchgear room). There are also fire-protection stanchions for fire hose connections located in both switchgear rooms on 2000' level. In the 'A' train switchgear room, there is no flooding accumulation from the bounding flood scenario.

In the 'B' train switchgear room, there is a potential for up to 1.26" of flooding from a bounding flood scenario.

In the 'B' train switchgear room there is a recirculation fan and duct mounted at floor level. However, the fan and duct opening to the adjacent room is located above the bounding flood level. On the 2016' level, the recirculation subsystem operates by transferring cool air from the operating Class 1 E battery room (either Battery Room 2 or 3, depending on which recirculation fan is in operation) to the opposite train battery room. The conditioned air is then recirculated through the switchboard rooms and to the other battery room (either Battery Room 1 or 4), which is then returned to the operating Class 1 E electrical equipment A/C train rooms through a passive return duct to the opposite train battery room. The potential for disruption of the hydrogen removal from the battery rooms is evaluated in the GOTHIC calculation (GK-M-016) and discussed within the engineering disposition for the modification.

In the 4 cases modeled in GOTHIC, the hydrogen concentration in any one room does not exceed 0.0070% in the 30 days modeled. Throughout the cases modeled, the highest hydrogen concentration accumulation is in Battery Room 4, with the 'B' train Class 1 E electrical equipment A/C train out of service, with a hydrogen concentration approximately 0.0066%. The maximum hydrogen concentrations are well below the 2% limit. Post-modification testing has been performed to validate that the recirculation fans are supplying the minimum modeled airflow and that the modification does not adversely impact the other HVAC Systems in the Control Building, particularly the Control Building Pressurization System (also referred to the Control Room Pressurization System in the USAR and some design documents), responsible for maintaining positive pressur~ in the Control Room during an accident scenario.

There are no adverse consequences expected from implementation of this modification.

Attachment I to ET 18-0014 Page 6 of 32 RAIAPHB-2 The NRG staff is evaluating the proposed compensatory actions that will support the operability temperature limit of::;; 90 °F and the GOTHIC model assumption that mitigating actions are completed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months as described in Attachment II, Section 3.4, of the letter dated June 28, 2017. Please describe the validation completed to confirm that the various ways, described on page 12 of 48 of Attachment II of the letter dated June 28, 2017, that an AIC train failure can be identified in enough time to allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to implement the mitigating actions before the rooms reach 90 °F. Response:

The ::;; 90°F proposed in new TS 3.7.20 (Required Action A.2) is not the OPERABILITY limit for the Class 1 E electrical equipment.

The Class 1 E electrical equipment is qualified for ambient temperature up to 104°F, which is the maximum room temperature listed in the design specifications for the Class 1 E electrical equipment and is listed in Equipment Qualification Design Basis Document (EQSD-1) as the maximum room temperature for the Class 1 E electrical equipment rooms with a single Class 1 E electrical equipment A/C train (SGK05A/B) out-of-service and accident condition heat loading. WCNOC conservatively set Required Action A.2 to the room temperatures of ::;; 90°F for one Class 1 E electrical equipment A/C train inoperable.

Implementing the mitigating actions per proposed TS 3.7.20 at 90°F corresponds to that cooling train's capability to maintain area temperatures::;;

104°F for both trains of electrical equipment during accident conditions.

The ::;; 90°F temperature was chosen to coincide with the normal operation maximum expected temperature in the Class 1 E electrical equipment rooms and to provide some margin to the initial Class 1 E electrical equipment rooms temperature for the GOTHIC accident condition evaluations.

It is also noteworthy that the GOTHIC calculation results show the Class 1 E electrical equipment rooms do not approach 90°F until 2 days or more after loss of the Class 1 E electrical equipment A/C train. Page 12 of 48 of Attachments I and II of Reference 1 specifies various ways in which a

failure of a Class 1 E electrical equipment A/C train can be identified.

The identification of a failure would typically occur well before the 87°F temperature limit specified in TRM TR 3.7.22, "Area Temperature Monitoring," as the equipment rooms are normally maintained at approximately 66°F to 68°F. As discussed in Section 3.5 of Reference 1, computer points are used to verify the DC switchboard rooms and ESF switchgear room temperatures are less than 87°F and provide an alarm on the main control board. The alarm setpoint on the associated temperature indicators will be lowered to 83°F as part of the planned modification.

This same limit will be applied to the battery rooms that are monitored locally. This will provide earlier indication of potential problems with a Class 1 E electrical equipment A/C train. With the planned modification, the expected time to start the applicable recirculation subsystem train and transfer battery charging capability to the spare battery chargers is less than the time to implement the current compensatory measures that include opening affected area room doors, establishing fire watches, installing (physically moving fans from a stored location to the applicable rooms) seismic temporary fans powered from a safety related source, increased monitoring of room temperatures, and monitoring specified load center transformer amps. The compensatory measures are discussed on Page 11 of 48 of Attachments I and II of Reference

1.

Attachment I to ET 18-0014 Page 7 of 32 Two Operations personnel have completed a time sensitive action validation in accordance with procedure Al 21-016, "Operator Time Critical Action Validation", for implementation of draft procedure SYS GK-200, "Non-Functional Class 1 E A/C Unit." Procedure SYS GK-200 will be used for operation of the recirculation subsystem trains until proposed TS 3.7.20 is approved and implemented.

In the time sensitive action validation, the plant operators were capable of starting the recirculation subsystem train, aligning the spare battery chargers, and verifying the Class 1 E electrical equipment room temperatures in less than 45 minutes. The draft revision to procedure SYS GK-200 is similar to the draft Operations procedure SYS GK-201 which will be used to implement the TS 3.7.20 mitigating actions. To ensure that the GOTHIC model is conservative in the heat loading assumptions, the latest process revision of the GOTHIC calculation assumes that the battery chargers are swapped at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months instead of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Preliminary resul.ts from the calculation show little impact to the room temperature results. RA/ APHB-3 Please describe the following so that the NRG staff can evaluate the effectiveness of the manual operator actions: a. The procedures/administrative controls used to direct, and the operator actions to place the switchgear room recirculation fans in service. b. Procedures used to de-energize NK021/NK024 battery chargers and transfer charging of Class IE batteries to battery chargers NK025/NK026.

c. The validation completed to confirm that all required actions listed in Attachment II, Section 3.4, of letter dated June 28, 2017, can be completed in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months once TS 3. 7.20, Action A. 1 is entered. d. The procedures used to secure one train of the Control Building Pressurization System (GBPS) Post-Loss-of-Coolant Accident (LOCA). e. The validation completed to confirm that all human actions required to secure one train of the GBPS Post-LOCA within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months can be accomplished.

f. The procedure controls for any applicable human actions that are not listed in Attachment II, Section 3.4, of the letter dated June 28, 2017, such as the establishment of temperature monitoring.

g. The validation completed for any applicable human actions that are not listed in Attachment II, Section 3.4, of the letter dated June 28, 2017, such as the establishment of temperature monitoring.

h. The planned training to operating personnel regarding the operation of the new recirculating fans, and implementation of the compensatory actions described in Attachment II, Section 3.4, of the letter dated June 28, 2017.

Attachment I to ET 18-0014 Page 8 of 32 i. The administrative controls that alert control room operators during Normal Operations of the need to initiate mitigating actions to start the switchgear room recirculation fans within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . j. The administrative controls that alert control room operators during post-LOCA conditions of the need to secure one train of GBPS pressurization fans within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the switchgear room recirculation fans are operating.

Response:

During the final design process, halon interlock relays were installed that would secure the recirculation subsystem train should a halon actuation occur in either train. This ensures that the halon boundary between rooms is maintained by securing the recirculation subsystem fans and closing the dampers. The halon interlock relays are required to be enabled prior to starting the recirculation subsystem fan. The required recirculation fan dampers and the fan will not start if the halon relays are not enabled. Enabling the halon interlock relays requires a plant operator to turn two isolation switches to the "ON" position.

The two isolation switches are located on panel GK360 which is located in ESF switchgear room #1 (Room 3301 ). Indicating lights on panel GK360 provide the status of the halon interlock relay for the recirculation subsystem.

As such, WCNOC considers this operator action to be a mitigating action required under Required Action A.1. The time sensitive action validation discussed in the response to RAI APHB-2 included this action. Attachment II of this submittal provides revised TS Bases that includes this as a mitigating action. a. New procedure SYS GK-201 "Mitigating Actions for an Inoperable SGK05 Train," currently in draft form, will provide direction to plant operators for placing a recirculation subsystem train in service. The following actions (that include mitigating actions) are directed by draft procedure SYS GK-201:

Enable Class 1 E halon relays.

Start the applicable recirculation subsystem train.

Verify indicating lights display dampers open and the recirculation fans running.

Within one hour verify Class 1 E electrical equipment room temperatures

s; 9Q°F and once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter.

Verify recirculation fan air flows into affected rooms.

Ensure INOPERABLE Class 1 E electrical equipment A/C unit is secured.

Align NK025/NK026 spare battery chargers.

b. New procedure SYS GK-201 will direct plant operators when to de-energize NK021/NK024 battery chargers and transfer charging of Class 1 E batteries to spare battery chargers NK025/NK026.

The basic steps to energizing the spare battery charger are to ensure power is available to the charger, obtain transfer switch key, ensure breaker is on, realign DC circuits from charger to be secured to the spare battery charger, reduce charger DC output voltage, place energized charger in equalize mode, align charger, adjust charger output. c. Two Operations personnel have completed a time sensitive action validation to ensure the steps of Condition A of TS 3.7.20 can be completed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In the time sensitive action validation, two plant operators were capable of starting the recirculation subsystem train, aligning the spare battery chargers, and verifying the Class 1 E electrical equipment room temperatures in less than 45 minutes. To ensure Attachment I to ET 18-0014 Page 9 of 32 that the GOTHIC model is conservative in the heat loading assumptions, the latest process revision of the GOTHIC calculation assumes that the spare battery chargers are aligned at 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months instead of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . d. The Control Building Pressurization System is secured from the control room, therefore a specific procedure may not be utilized.

New procedure SYS GK-201 will provide guidance to secure 1 train of pressurization within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if the Control Building Pressurization System actuates.

e. The handswitch for securing the Control Building Pressurization System train is located in the control room. A time sensitive action validation has not been performed for this mitigating action but it is reasonable to assume the control room operator could easily meet the time requirement.

f. New procedure SYS GK-201 "Mitigating Actions for an Inoperable SGK05 Train," will direct plant operators when to monitor Class 1 E electrical equipment room temperatures to meet TS 3.7.20 Required Action A.2 when a recirculation subsystem train is placed in service. The Class 1 E equipment rooms are listed in Attachment A of the procedure, and instrument number and room temperature are recorded.

g. The monitoring of Class 1 E electrical equipment room temperatures required by TS 3.7.20 Required Action A.2 was included in the time sensitive action validation discussed in the response to RAI APHB-2 and item c. of RAI APHB-3. h. Training Requests have been generated to develop the required Licensed Reactor and Nuclear Station Operator training on the new recirculation subsystem requirements.

i. Refer to Page 12 of 48 of Attachments I and II of Reference

1. Additionally, refer to the response to RAI APHB-2 above. j. New procedure SYS GK-201 "Mitigating Actions for an Inoperable SGK05 Train," directs plant operators when to secure loads, which includes securing one train of Control Building Pressurization System. RAJ EEOB-1 Applicable Regulations:

GOGs 13 and 17 The licensee is implementing plant modifications to maintain the environment for operability of onsite and offsite power systems required for conformance with GOG 17. The licensee is installing instrumentation to monitor variables and systems over their anticipated ranges (to maintain the variables and systems within prescribed operating ranges) in accordance with GOG 13. In the LAR, the licensee has discussed the proposed temperature range for the GOG 17 required power sources. The NRG staff is requesting additional information on events and accidents considered for instrumentation needed during anticipated ranges for room temperatures during normal operation, for anticipated operational occurrences, and for accident conditions.

Attachment I to ET 18-0014 Page 10 of 32 Section 3.2.2 "Inputs/Assumptions" of the letter dated June 28, 2017, references GK-E-001, Revision 4, "Electrical Equipment Heat Loads in ESF [Engineered Safety Features]

SWGR [Switchgear], DC SWBD [Switchboard]

and Battery Rooms." This calculation was used to determine heat loads due to electrical equipment in ESF SWGR Rooms, DC SWBD Rooms, and Battery Rooms during Normal operation (Mode 1 with off-site power available), LOCA condition, station blackout condition, and one HVAC operating during the post-LOCA condition.

The electrical heat loads identified in this calculation support the Class 1E HVAC calculations as described in the LAR. Section 3.2.2 also states, in part, 'Tilt is noted that in many safety analysis calculations, a Joss of offsite power (LOOP) is assumed to occur. USAR Section 15.6.5.3.2 specifically states that "for the small break LOCA (SBLOCA), LOOP is assumed, which results in the limiting single failure assumption of the loss of one diesel generator (DG) and a subsequent loss of one train of pumped Emergency Core Cooling System (EGGS)." The NRG staff is reviewing the combinations of events and plant conditions that were considered for heat load calculations.

Please provide a discussion on the plant conditions and corresponding source of power. Please include in your discussion whether the accident condition(s) considered in the evaluations assume a concurrent LOOP or an accident/event with offsite power available and also provide details on any postulated failures.

Please include a copy of the current revision of the calculation GK-E-001, Revision 4, referenced in the LAR. Response:

Evaluation of the heat loading variations during the loss of offsite power (LOOP) and Non-LOOP conditions, concurrent with normal operation as well as accident conditions, shows the Non-LOOP condition could result in approximately a 21 % increase in heat load whereas the LOOP condition could result in approximately a 3% increase in heat load. Factors considered were EOG frequency tolerance, switchyard voltage tolerance, voltage losses, etc. Thus, the Non-LOOP condition is assumed in GK-E-001, Revision 5, "Electrical Equipment Heat Loads in ESF SWGR, DC SWBD and Battery Rooms," as the bounding condition.

The current values (amps) are calculated from load values under the same bounding conditions identified above as extracted from the appropriate appendices of calculation XX-E-006, Revision 7, "AC System Analysis." Evaluation of Accidents:

Normal operation and three event/accident cases (LOCA/Post-LOCA, Station Blackout, and Post-LOCA with reduced loading) were analyzed for heat loading in the Class 1 E electrical equipment rooms. The largest h~at loadings are based on Normal and large break LOCA/Post-LOCA cases which produces the highest overall heat load generation.

For the Normal, LOCA/Post-LOCA and Post-LOCA with reduced loading cases analyzed, offsite power is assumed to be available and the switchyard voltage is modeled at 97% (334.65 KV) of 345KV nominal voltage to produce the maximum expected heat load (approximately 21% increase).

Conservatively, no Class 1 E electrical equipment A/C train failures are assumed for the Normal, and LOCA/Post-LOCA modeling cases. For the Station Blackout (SBO) case a complete loss of all offsite and onsite AC power generation (loss of EDGs) is assumed for a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months coping period using the Turbine Driven Auxiliary Feedwater (TDAFW) pump to provide cooling. The SBO case assumes a loss of*

Attachment I to ET 18-0014 Page 11 of 32 all offsite and onsite AC generation for the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months coping period and no other failures are assumed. For the Post-LOCA with reduced loading case a loss of one Class 1 E electrical equipment A/C train is assumed, the Class 1 E electrical equipment A/C recirculation subsystem is in service and no additional failures are required to be assumed. The bounding assumptions for the cases analyzed are from calculation XX-E-006 and provided as follows. Normal Operation:

The 't<:i/v and KVAR values are from calculation XX-E-006 Appendix 16 (Normal case Scenario N 1 ). This case has the following inputs: 1. 97% switchyard voltage. 2. Main Generator on with terminal voltage at 95%. 3. Maximum loading. Loading Category (Normal max). 4. NB01 is supplied from transformer No. 7. 5. NB02 is supplied from the startup transformer XMR01. 6. PA01 and PA02 are supplied from unit auxiliary transformer XMA02. 7. Non-safety related buses are all energized and supplied from their preferred power sources PA01 and PA02. 8. ESW pumps A and B are running for testing. 9. Cable resistance is conservatively corrected to an assumed maximum temperature of 90'C. LOCA Condition:

The 't<:i/v and KVAR values are from calculation XX-E-006 Appendix 38 (Post LOCA [PLOCA] Scenario PL 1) at T= 15+ seconds. This case has the following inputs: 1. 97% switchyard voltage. 2. Main Generator Off. 3. All Class 1 E loads remain on and additional loads that were shed during LOCA conditions are added. Loading Category (PLOCA max). 4. NB01 is supplied from transformer No. 7. 5. NB02 is supplied from the startup transformer XMR01. 6. PA01 and PA02 are supplied from startup transformer XMR01. 7. Non-safety related buses are all energized and supplied from their preferred power sources PA01 and PA02. 8. ESW pump A starts at T = 0 seconds, ESW B pump starts at T = 5 seconds, and Instrument Air compressors DCKA01 A and DCKA01 B are started at T = 10 seconds. 9. Cable resistance is conservatively corrected to an assumed maximum temperature of 90'C.

Attachment!

to ET 18-0014 Page 12 of 32 SBO Condition:

Prior to the SBO event, the plant is at 100% power with offsite power available, Train A and B available.

For the SBO event, the DC loading is from calculation NK-E-001, Revision 4, "125 VDC Class 1 E Battery System Sizing, Voltage Drop and Short Circuit Studies," and inverter loading is from calculation change notices NN-E-001-000-CN002 and NN-E-001-000-CN004, "Class 1 E NN Inverter Loading." This case has the following inputs: 1. Cable resistance is conservatively corrected to an assumed maximum temperature of go*c. 2. Power cables are conservatively modeled at a 10% increased current. PLOCA Condition Scenario PL 1 with one Class 1 E electrical equipment A/C train and the recirculation subsystem operating with Reduced Train 'A' and Train 'B' Loads at Times T=O, T=24 hours, and T=7 days: The KW and KVAR values are from Attachment H of calculation GK-E-001, which was developed using calculation XX-E-006 Appendix 38. Post LOCA Scenario PL 1 with reduced loads. This case has the following inputs: 1. 97% switchyard voltage. 2. Main Generator Off. 3. NB01 is supplied from transformer No. 7. 4. NB02 is supplied from the startup transformer XMR01. 5. PA01 and PA02 are supplied from startup transformer XMR01. 6. Cable resistance is conservatively corrected to an assumed maximum temperature of go*c. 7. The. loading is similar to Post LOCA Scenario PL 1 of calculation XX-E-006, except some of the loads are off as shown in the tables below. Post-LOCA load reductions when Train 'A' is selected for long term shutdown cooling. Train 'A' Selected for Long Term Shutdown Cooling Train 'B' Loads Removed from PLOCA Scenario Equipment T=24 T=7 ID Equipment Description T=O Hrs. Days NB02 DPAL01B Auxiliary Feedwater (AFW) Pump ON OFF OFF DPEM01B Safety Injection (SI) Pump ON OFF OFF DPEN01B Containment Spray (CS) Pump ON OFF OFF DPBG05B Centrifugal Charging Pump ON ON OFF DPEF01B Essential Service Water (ESW) Pump ON ON OFF DPEG01A Component Cooling Water (CCW) Pump ON ON OFF DPEJ01B Residual Heat Removal (RHR) Pump ON ON OFF Attachment I to ET 18-0014 Page 13 of 32 Train 'A' Selected for Long Term Shutdown Cooling Train 'B' Loads Removed from PLOCA Scenario Equipment T=24 ID Equipment Description T=O Hrs. LC NG02 SGK04B Control Room HVAC #1 ON OFF NK024 125V Battery Charger OFF OFF DPEC01B Spent Fuel Pump OFF OFF MCC NG02A XQB60 Standby AC Lk1hting OFF OFF XQB?O Standby AC Lighting OFF OFF DSGL09B Safety Injection Pump Room Cooler ON OFF DCGK04B Control Room Pressurization Fan ON OFF DPBG02B Boric Acid Transfer Pump OFF OFF DSGL 128 Centrifuqal Charqinq Pump Room Cooler ON ON Control Room Press System Filter -FGK02B Absorber Unit Heater ON ON DSGL 138 Containment Spray Pump Room Cooler ON OFF RHR Pump Room Cooler Fan -Runs DSGL 108 when RHR runs ON ON MCC NG02B Control Rod Drive Mechanism (CROM) DCGN01C Cooling Fan OFF OFF XQB85 Standby AC Lighting OFF OFF XQB95 Standby AC Lighting OFF OFF DSGF02B AFW Pump Room Cooler Fan ON OFF MCC NG02T DSGN01B Containment Cooler Fan ON ON LC NG04 DCKA01B Instrument Air Compressor OFF OFF MCC NG04C Component Cooling Water Pump Room DSGL 118 Cooler ON ON DSGG04B Spent Fuel Pool Pump Room Cooler OFF OFF MCC NG04T DSGN01D Containment Cooler Fan ON ON MCC NG06E XQB51 Standby AC Lighting OFF OFF EDG01B ESW Pumphouse Heaters OFF OFF EDG01D ESW Pumphouse Heaters OFF OFF EDG01F ESW Pumphouse Heaters OFF OFF EDG01H ESW Pumphouse Heaters OFF OFF LC PG22 TBB02 Backup Pressurizer Heaters OFF OFF T=7 Days OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF Attachment I to ET 18-0014 Page 14 of 32 Train 'A' Selected for Long Term Shutdown Cooling Train 'A' Loads Removed from PLOCA Scenario Equipment T=24 ID Equipment Description T=O Hrs. NB01 DPAL01A AFW ON OFF DPEM01A Safety Injection Pump ON OFF DPEN01A Containment Spray Pump ON OFF LC NG03 PJ021 250V Battery Charger OFF OFF NK021 125V Battery Charger OFF OFF DPEC01A Spent Fuel Pool Pump ON ON MCC NG01A XQB60 Standby AC Liqhting OFF OFF XQB70 Standby AC Lighting OFF OFF DSGL09A Safety Injection Pump Room Cooler ON OFF DPBG02A Boric Acid Transfer Pump OFF ON MCC NG01B DCGN01A CRDM Cooling Fan OFF OFF XQB85 Standby AC Lighting OFF OFF XQB95 Standby AC Lighting OFF OFF MCC NG05E XQB50 Standby AC Lighting OFF OFF EDG01A ESW Pumphouse Heaters OFF OFF EDG01C ESW Pumphouse Heaters OFF OFF EDG01E ESW Pumphouse Heaters OFF OFF EDG01G ESW Pumphouse Heaters OFF OFF LC PG21 TBB02 Backup Pressurizer Heaters OFF OFF T=7 Days OFF OFF OFF OFF OFF ON OFF OFF OFF ON OFF OFF OFF OFF OFF OFF OFF OFF OFF Post-LOCA load reductions when Train 'B' is selected for long term shutdown cooling. Train 'B' Selected for Long Term Shutdown Cooling Train 'A' Loads Removed from PLOCA Scenario Equipment T=24 T=7 ID Equipment Description T=O Hrs. Days NB01 DPAL01A Auxiliary Feedwater (AFW) ON OFF OFF DPEM01A Safety Injection Pump ON OFF OFF DPEN01A Containment Spray Pump ON OFF OFF DPBG05A Centrifuqal Charqinq Pump ON ON OFF DPEF01A Essential Service Water Pump ON ON OFF DPEG01C Comp. Cooling Water Pump ON ON OFF DPEJ01A Residual Heat Removal Pump ON ON OFF LC NG01 SGK04A Control Room HVAC #1 ON OFF OFF NK021 125V Battery Charqer OFF OFF OFF Attachment I to ET 18-0014 Page 15 of 32 Train 'B' Selected for Long Term Shutdown Cooling Train 'A' Loads Removed from PLOCA Scenario Equipment T=24 ID Equipment Description T=O Hrs. DPEC01A Spent Fuel Pump OFF OFF MCC NG01A XQB65 Standby AC Liqhtinq OFF OFF XQB75 Standby AC Liqhtinq OFF OFF DSGL09A Safety Injection Pump Room Cooler ON OFF DCGK04A Control Room Pressurization Fan ON OFF DPBG02A Boric Acid Transfer Pump OFF OFF DSGL 12A Centrifugal Charging Pump Room Cooler ON ON Control Rm Press System Filter -FGK02A Absorber Unit Heater ON ON DSGL 13A Containment Spray Pump Room Cooler ON OFF RHR Pump Room Cooler Fan -Runs DSGL10A when RHR runs ON ON MCC NG01B DCGN01D CROM Cooling Fan OFF OFF XQB80 Standby AC Lighting OFF OFF XQB90 Standby AC Lightinq OFF OFF DSGF02A AFW Pump Room Cooler Fan ON OFF MCC NG01T DSGN01A Containment Cooler Fan ON ON LC NG03 DCKA01A Instrument Air Compressor OFF OFF MCC NG03C Component Cooling Water Pump Room DSGL 11A Cooler ON ON 0SGG04A Spent Fuel Pool Pump Room Cooler OFF OFF MCC NG03T DSGN01C Containment Cooler Fan ON ON MCC NGOSE XQB50 Standby AC Liqhtinq OFF OFF EDG01A ESW Pumphouse Heaters OFF OFF EDG01C ESW Pumphouse Heaters OFF OFF EDG01E ESW Pumphouse Heaters OFF OFF EDG01G ESW Pumphouse Heaters OFF OFF LC PG21 TBB03 Backup Pressurizer Heaters OFF OFF T=7 Days OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF OFF Attachment I to ET 18-0014 Page 16 of 32 Train '8' Selected for Long Term Shutdown Cooling Train '8' Loads Removed from PLOCA Scenario Equipment T=24 ID Equipment Description T=O Hrs. NB02 DPAL01B AFW ON OFF DPEM01B Safety Injection Pump ON OFF DPEN01B Containment Spray Pump ON OFF LC NG02 PJ031 250V Battery Charger OFF OFF NK024 125V Battery Charger OFF OFF DPEC01B Spent Fuel Pool Pump ON ON MCC NG02A XQB60 Standby AC Liqhting OFF OFF XQB70 Standby AC Lighting OFF OFF DSGL09B Safety Injection Pump Room Cooler ON OFF DPBG02B Boric Acid Transfer Pump OFF ON MCC NG028 DCGN01B CROM Cooling Fan OFF OFF XQB85 Standby AC Lighting OFF OFF XQB95 Standby AC Liqhtinq OFF OFF MCC NG06E XQB51 Standby AC Lighting OFF OFF EDG018 ESW Pumphouse Heaters OFF OFF EDG01D ESW Pumphouse Heaters OFF OFF EDG01F ESW Pumphouse Heaters OFF OFF EDG01H ESW Pumphouse Heaters OFF OFF LC PG22 TBB03 Backup Pressurizer Heaters OFF OFF T=7 Days OFF OFF OFF OFF OFF ON OFF OFF OFF ON OFF OFF OFF OFF OFF OFF OFF OFF OFF In response to RAI EEOB-2, item d., Calculation GK-E-001 has been revised. A copy of calculation GK-E-001, Revision 5, is not included as part of this submittal.

As discussed with the NRG Project Manager, in lieu of providing the calculation on the docket, the RAI EEOB responses provide the inputs, assumptions, and results, (detailed herein) as they relate to the RAI. RA/ EEOB-2 Applicable Regulations:

GOGs 13 and 17 The licensee is implementing plant modifications to maintain the environment for operability of onsite and offsite power systems required for conformance with GOG 17. The licensee is installing instrumentation to monitor variables and systems over their anticipated ranges (to maintain the variables and systems within prescribed operating ranges) in accordance with GOG 13. In the LAR, the licensee has discussed the proposed temperature range for the GOG 17 required power sources. The NRG staff is requesting additional information on Attachment I to ET 18-0014 Page 17 of 32 parameters that were considered for instrumentation needed during anticipated ranges of room temperatures for normal operation, for anticipated operational occurrences, and for accident conditions.

WCGS has a large number of motor loads which are operating during normal operation and accident conditions.

These motors draw a higher load current as the voltage drops at the motor terminals.

The voltage drop in the plant distribution system will increase after a main generator trip. The loss of generation from the main generator will also result in switchyard voltage to drop to a value below nominal and can be as low as 95-97 percent of nominal. Electrical calculations make assumptions related to system voltage, conductor temperatures, diversity factors, raceway fills, etc. Assumptions and input criteria for heat load calculation should correspond to the assumptions and input criteria used in calculations

developed for AC system analyses.

The NRG staff is seeking the following information on input criteria used in the calculations.

a. With offsite power at minimum voltage for normal operation or postulated accident conditions, please provide a discussion comparing the voltage drop and associated load current for room heat calculations discussed in the LAR with voltage and current values developed in corresponding AC system load flow and voltage drop analysis.

b. Please provide a discussion comparing the magnitude of loads considered in WCGS ca/cu/ation(s) deveioped for heat load evaluations with the bus loads assumed in calculations developed for AC system analyses for normal and accident conditions.

c. Please provide a discussion comparing the actual tray fill for raceways associated with EGGS power cables with percentage fill assumed in the heat load calculation.

In areas where cables may be routed in conduits or other raceway systems, provide a discussion of the actual loading criteria used. d. Please provide a discussion related to the change in heat load calculations described in the LAR assuming the temperature of the current carrying conductors is 90 degrees Centigrade ( design limit) at steady state conditions.

e. Please provide a discussion oh any load diversity factor used in calculation of heat loads during accident conditions when majority of safety-related equipment is operating.

Response:

a. The AC System load flow and voltage drop analysis is performed in calculation XX-E-006. Calculation XX-E-006 uses a minimum switchyard voltage of 97%. Cable resistance is conservatively corrected to an assumed maximum temperature of go*c in calculations XX-E-006 and GK-E-001.

For the Normal loading case in calculation GK-E-001, the load flow values are taken from Appendix 16 of calculation XX-E-006 and bounded by the inputs identified in the response to RAI EEOB-1 for the Normal case (N1 ). For this heat loading case it is Attachment I to ET 18-0014 Page 18 of 32 assumed that both Class 1 E electrical equipment A/C trains are operating and no load reductions are assumed. Conservative loading on each of the two Class 1 E 4.16 KV NB busses is assumed by continuous loading of two ESW, Component Cooling Water and Charging Pumps (from Appendix 38 of calculation XX-E-006).

The ESW pumps are not continuous loads during normal operation.

Additional loading on the Class 1 E 4KV busses includes the four 4.16KV/480V NG transformers XNG01, 02, 03 and 04. Transformer loading on each of the four Class 1 E 480V NG load center busses is based on the maximum 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months average KVA loading over an 8 year period (2005-2012) and applied as the loading value during Normal operations.

These loading values are applied to the four XNG transformers.

The resulting currents from the equipment KVA loading values are then corrected to a 97% switchyard voltage value (approximately 10% increase in current) and this current is used to calculate heat loss of cables and breakers.

Because the loading values used for the heat load calculation are the same load values obtained from Appendix 16 of calculation XX-E-006, the voltage drops would be the same but are not recalculated in the heat load calculation GK-E-001.

The transformer test report shows that the transformers have a temperature rise of 88.9°C. With a maximum ambient temperature of 40°C, the transformer winding temperature at full load will be 128.9°C (40°C + 88.9°C). For conservatism, the load losses are corrected to 135°C. With the above correction factors applied only to the four NG transformers' loadings the Normal loads utilized for the AC distribution system modeling are taken from Appendix 16 of calculation XX-E-006 as indicated in the two tables below. Load Center Loading (KW and KV AR Values from calculation XX-E-006 Appendix 16) TRAIN 'A' TRAIN '8' 480V BUS KW KVAR KVA 480V BUS KW KVAR KVA LC NG01 LC NG04 MCC NG01A 122 62 137 MCC NG04C 60 22 64 MCC NG01B 141 99 172 MCC NG04D 92 18 94 MCC NG01T 121 60 135 MCC NG04T 121 60 135 NK021 12 10 16 NK22 23 22 32 NK025 34 32 47 NK026 34 32 47 PK21 47 45 65 PK22 48 45 66 PK23 47 45 65 PK24 47 45 65 DPEC01A 99 69 121 DCKA01B 196 132 236 SGK04A 72 54 90 DCGM01B 84 87 121 LC NG03 LC NG02 MCC NG03C 57 21 61 MCC NG02A 135 79 156 MCC NG03D 89 17 91 MCC NG02B 168 110 201 MCC NG03T 120 59 134 MCC NG02T 121 60 135 NK023 12 10 16 NK024 34 32 47 DCKA01A 196 131 236 PJ31 63 60 87 DCGM01A 84 87 121 DPEC01B 98 69 120 SGK04B 72 54 90 MCC NG05E 104 17 105 MCC NG06E 111 19 113 Attachment I to ET 18-0014 Page 19 of 32 4.16KV Switchgear Bus NB01 and NB02 Loading (KW and KV AR Values from calculation XX-E-006 Appendix 16) TRAIN 'A' TRAIN 'B' 4.16KV BUS KW KVAR KVA 4.16KV BUS KW KVAR SWGR NB01 SWGR NB02 XFMRXNG01 706 520 877 XFMRXNG02 702 503 XFMRXNG03 556 351 658 XFMRXNG04 710 506 XFMRXNG05 105 19 107 XFMRXNG06 112 22 XFMRXPG21 601 29 602 XFMRXPG22 631 30 DPEF01A# 1412 733 1591 DPEF01 B# 1412 732 DPEG01C# 508 377 633 DPEG01D# 508 377 DPBG05A# 546 221 589 DPBG05B# 546 221 TRAIN 'A' TRAIN 'B' 4.16KV BUS KW KVAR KVA 4.16KV BUS KW KVAR SWGR NB01 SWGR NB02 Total w/ NK025 4434 2250 4972 Total w/ NK026 4621 2391 NK025 34 32 47 NK026 34 32 Total w/o 4400 2218 4927 Total w/o 4587 2359 XFMR XNG01 w/o NK025 830 XFMR XNG04 w/o NK026 KVA 864 872 114 632 1590 633 589 KVA 5203 47 5158 825 Appendix 16 of Calculation XX-E-006 shows DPEF01A & Band DPEG01C & D loads as running, and DPBGOSA & B loads de-energized for load flow modeling purposes.

During Normal Operation, ESW Pumps are not continuous loads and one CCW pump runs at a time. DPBGOSA & B loads (from Appendix 38 of calculation XX-E-006) run when DPBG04 normal charging pump loads are taken out of service. For the LOCA loading case the load flow values are taken from Appendix 38 of calculation XX-E-006 and bounded by the inputs identified in the response to RAI EEOB-1 for the LOCA case. Loading on the Class 1 E distribution system is at full LOCA loading with additional previously shed Post-LOCA loads added and no load reductions are taken. For this case it is assumed that both Class 1 E electrical equipment A/C trains are operational.

The transformer test report shows that the transformers have a temperature rise of 88.9°C. With a maximum ambient temperature of 40°C, the transformer winding temperature at full load will be 128.9°C (40°C + 88.9°C). For conservatism, the load losses are corrected to 135°C. Because the loading values used for the heat load calculation are the same load values obtained from Appendix 38 of calculation XX-E-006 for the Post-LOCA scenario, the voltage drops would be the same but are not recalculated in the heat load calculation GK-E-001.

With the above correction factors applied only to the four NG transformers' loadings the LOCA/Post-LOCA loads utilized for the AC distribution system modeling are taken from Appendix 38 of calculation XX-E-006 as indicated in the two tables below.

Attachment I to ET 18-0014 Page 20 of 32 Load Center Loading (KW and KVAR Values from Appendix 38 of calculation

XX-E-006 at t = 15+) 480V BUS KW KVAR KVA 480V BUS KW KVAR KVA LC NG01 LC NG04 MCC 160 125 203 MCC 67 38 77 NG01A NG04C MCC 142 143 202 MCC 26 18 32 NG018 NG04D MCC 121 60 135 MCC 121 60 135 NG01T NG04T NK021 12 10 16 NK022 23 22 32 NK025 34 32 47 NK026 34 32 47 PK021 47 45 65 PK022 48 45 66 PK023 47 45 65 PK024 47 45 65 DPEC01A 99 69 121 DCKA01B 197 132 237 SGK04A 72 54 90 DCGM01B 84 87 121 Total w/ 734 583 937 Total w/ 563 479 739 NK025 NK026 Total w/o 700 551 891 Total w/o 529 447 693 NK025 NK026 LC NG03 LC NG02 MCC 81 47 94 MCC 162 125 205 NG03C NG02A MCC 26 18 32 MCC 158 150 218 NG03D NG028 MCC 120 60 134 MCC 121 60 135 NG03T NG02T NK023 12 10 16 NK024 34 32 47 DCKA01A 196 132 236 PJ31 63 60 87 DCGM01A 84 87 121 DPEC01B 98 69 120 SGK04B 72 54 90 Total 435 354 561 Total 708 550 897 MCC 106 19 108 MCC 107 19 109 NG05E NG06E Attachment I to ET 18-0014 Page 21 of 32 4.16KV Switchgear Bus NB01 and NB02 Loading (KW and KVAR Values from Appendix 38 of calculation XX-E-006 at t = 15+) 4.16KV BUS KW KVAR KVA 4.16KV BUS KW KVAR SWGR NB01 SWGR NB02 XFMRXNG01 749 638 984 XFMRXNG02 723 601 XFMRXNG03 517 377 640 XFMRXNG04 651 521 XFMRXNG05 107 22 109 XFMRXNG06 107 22 XFMRXPG21 586 29 587 XFMRXPG22 593 28 DPEF01A 1,422 735 1601 DPEF01B 1,422 735 DPEG01C 508 377 633 DPEG01D 508 377 DPAL01A 552 312 634 DPAL01B 552 312 DPEJ01A 264 136 297 DPEJ01B 264 136 DPEM01A 371 177 411 DPEM01B 371 177 DPEN01A 405 183 444 DPEN01B 405 183 DPBG05A 546 221 589 DPBG05B 546 221 Total w/ NK025 6027 3207 6827 Total w/ NK026 6142 3313 NK025 34 32 47 . NK026 34 32 Total w/o NK025 5993 3175 6782 Total w/o NK026 6108 3281 XFMR XNG01 w/o 937 XFMR XNG04 w/o NK025 NK026 KVA 940 834 109 594 1601 633 634 297 411 444 589 6979 47 6933 787 For the SBO loading case the load flow values are taken from Appendices AA.9 (Battery NK011 ), BB.9 (Battery NK012), CC.9 (Battery NK013) and DD.9 (Battery NK014) of calculation NK-E-001 and bounded by the inputs identified in the response to RAI EEOB-1 for the SBO case. The SBO loads utilized for the DC distribution modeling are taken from the AA.9, BB.9, CC.9 and DD.9 Appendices of calculation NK-E-001 (and calculation change notices NN-E-001-000-CN002 and NN-E-001-000-CN004) as indicated in the two tables below. Inverter Loading Inverter Design Load (VA) Normal LOCA SBO NN011 4716.6 5429 4716.6 NN012 5508.3 5508.3 5508.3 NN013 4019.8 4019.8 4019.8 NN014 4526.2 5238.6 4526.2 NN015 4716.6 5429 4716.6 NN016 5508.3 5508.3 4526.2 Attachment I to ET 18-0014 Page 22 of 32 Fused Fuse Battery Switch (amps) NK0102 600 NK0103 100 NK0104 300 NK011 NK0105 300 NK0111 100 NK0101 1200 NK0202 600 NK0203 100 NK012 NK0204 100 NK0211 100 NK0201 1200 NK0302 600 NK0303 100 NK013 NK0304 100 NK0311 100 NK0301 1200 NK0402 600 NK0403 100 NK0404 300 NK014 NK0405 300 NK0411 100 NK0401 1200 Battery Loading During SBO SBO Equipment Loading Reference (Amps) NK021 or 0 NK-E-001 Appendix AA.9 NK025 NN015 via 66.2 NK-E-001 Appendix AA.9, E-NK079 13NN01 R/8 NK041 68.8 NK-E-001 Appendix AA.9 NK051 49.3 NK-E-001 Appendix AA.9 NK-E-001 Appendix AA.9, NK-E-NN011 0 001 calculates the battery loading with NN015 supplying the NN011 loads with NN011 off. Relayinq 0.8 NK-E-001 Appendix AA.9 NK011 185.1 Total NK022 0 NK-E-001 Appendix BB.9 NN016 via 0 E-13NN01 NK080 NK042 6.3 NK-E-001 Appendix BB.9 NN012 64.2 NK-E-001 Appendix BB.9 Relaying 0.8 NK-E-001 Appendix BB.9 NK012 71.4 NK-E-001 Appendix BB.9 NK023 0 NK-E-001 Appendix CC.9 NN015 via 0 E-13NN01 NK079 NK043 0.4 NK-E-001 Appendix CC.9 NN013 64.1 NK-E-001 Appendix CC.9 Relaying 0.8 NK-E-001 Appendix CC.9 NK013 65.3 NK-E-001 Appendix CC.9 NK024 or 0 NK-E-001 Appendix DD.9 NK026 NN016 via 65.7 NK-E-001 Appendix DD.9, E-NK080 13NN01 NK044 77.2 NK-E-001 Appendix DD.9 NK054 40.6 NK-E-001 Appendix DD.9 NK-E-001 Appendix AA.9, NK-E-NN014 0 001 calculates the battery loading with NN016 supplying the NN014 loads with NN014 off. Relaying 0.8 NK-E-001 Appendix DD.9 NK014 184.3 Total For the Post-LOCA with reduced loading case the load flow values are taken from Attachment H of calculation GK-E-001 for time frames T=O, T=24 hours and T= 7 days. The load values in Attachment H are extracted from Appendix 38 of calculation XX-E-006 and the loading is reduced at the end of the time frames by the equipment removals indicated in the Post-LOCA scenario PL 1 as identified in the response to RAI Attachment I to ET 18-0014 Page 23 of 32 EEOB-1 above. The Post-LOCA case with reduced loading is bounded by the inputs identified in the response to RAI EEOB-1. Because the loading values used for the heat load calculation are reduced by the equipment removals identified in the LOCA case the resultant voltage drops would be less than those resulting from Appendix 38 of calculation XX-E-006 but are not recalculated in the heat load calculation GK-E-001 as the resultant voltage drops evaluated in calculation XX-E-006 are bounding.

b. The loading values used in the heat load calculation GK-E-001 are taken from calculation XX-E-006 for the Normal (N1) and LOCA (PL 1) cases and therefore, the magnitude of the currents are the same as those in calculation XX-E-006.

For the PLOCA with reduced loads case the loading values used are reduced by the loads associated with the equipment removals indicated in the response to RAI EEOB-1 under the PLOCA condition.

Therefore, the magnitude of the currents for the T=O, T=24 hours and T=7 days are less than those modeled in Appendix 38 of calculation XX-E-006 which would be expected due to the reduced loading indicated in the response to RAI EEOB-1 for the PLOCA case. c. Appendix 1 of the heat load calculation GK-E-001 provides power. cables in tray information taken from the Setroute (E-15000)

Cable and Raceway Program for the rooms. For the Service Level B (4160 V) trays, Service Level G (480 V) trays and Service Level U (480V, 120V and 125V) trays the power heat loss is calculated based on the P=l 2 R. R is determined based upon the conductor resistance corrected to a maximum temperature of go*c. The currents used to determine heat loss from cables in Service Level B and G trays are determined in the applicable calculation GK-E-001 section based on the loads in calculation XX-E-006 with a 97% switchyard voltage. For Service Level U trays, the load currents for cables are based on design documents or calculations and are increased by 10% conservatively resulting in a 21 % increase in heat load (Reference Design Input 3.8.17 of calculation GK-E-001 ). The cable resistances assumed are based upon a conductor resistance corrected to a maximum temperature of go*c. The heat loss for Service Level U (120V and 125V control cable), Service Level C (Control cable) Service Level J (Instrumentation cable) are negligible based on their minimal currents and their intermittent loading. This is based on their omission as heat loads inputs from IEEE and ASHRE Transactions. (Reference Assumption 3.A.12 of calculation GK-E-001 ). The heat loss from power cables in conduit is negligible since there are no large groups of power conduits, carrying continuously loaded cable for an appreciable distance in these rooms. (Reference Assumption 3.A.5 of calculation GK-E-001 ). d. Calculation GK-E-001 applies the assumed conductor resistance based upon a corrected maximum conductor temperature of go*c and therefore provides a conservative resistance to be utilized for the cable heat load calculation.

e. In calculation GK-E-001 no diversity factor is taken.

Attachment I to ET 18-0014 Page 24 of 32 RA/ EEOB-3 Applicable Regulations:

GDCs 13 and 17 The licensee is implementing plant modifications to maintain the environment for operability of onsite and offsite power systems required for conformance with GOG 17. The licensee is installing instrumentation to monitor variables and systems over their anticipated ranges (to maintain the variables and systems within prescribed operating ranges) in accordance with GOG 13. In the LAR, the licensee has discussed the proposed temperature range for the GOG 17 required power sources. The NRG staff is requesting additional information on parameters that were considered for instrumentation needed during anticipated ranges of room temperatures for normal operation, for anticipated operational occurrences, and for accident conditions.

The NRG staff needs clarification on heat loads for normal operation and post-LOGA.

Please provide a discussion on heat loss results when using just one HVAG unit during the post-LOGA for the following scenarios:

Train A Heat Loss Results with One HVAG Unit Operating post-LOGA.

Train B Heat Loss Results with One HVAG Unit Operating post-LOGA.

Please include a discussion on heat loads at T=O if accident mitigating equipment in Train A and Train B starts when an accident signal is actuated.

Response:

Train 'A' Heat Loss Results with One HVAC Unit Operating Post-LOCA.

Train 'A' heat loss results when using a single Class 1 E electrical equipment A/C train are bounded by the Post-LOCA Scenario and indicated Train 'A' and Train 'B' load reductions when Train 'A' is selected as the long term shutdown cooling train as indicated in the tables in the response to RAI EEOB-1. From the LOCA Condition Heat Loss Results Table below, it is shown that the largest heat load losses for LOCA/PLOCA full loading (accident and post-accident loading) are represented by the Train 'B' results. Therefore, the limiting case is the use of Train 'B' components to provide the LOCA/PLOCA loading as this provides the highest heat loss to the single operating Class 1 E electrical equipment A/C train associated with the selected long term cooling train. Because of this resultant disparity in heating losses between Train 'A' and Train 'B' equipment, utilization of Train 'A' loads while securing the Train 'B' loads is not the bounding heat loading case and therefore the Train 'B' heat loss results discussed in the response below is the limiting case. For comparison with Train 'B' heat loss results below the Train 'A' Heat Loss Results-One HVAC Unit Operating PLOCA, Train 'B' Selected for Long Term Shutdown Cooling Table is inserted below.

Attachment I to ET 18-0014 Page 25 of 32 LOCA Condition Heat Loss Results TRAIN A ROOM No. HEAT LOSS (watts) w/ NK025 w/o NK025 ESF Swgr. Rm. #1 3301 30,926 28,481 Battery Room #1 3407 134 134 DC Swbd. Room #1 3408 6,907 6,907 Battery Room #3 3413 326 326 DC Swbd. Room #3 3414 4,357 5,255 Total 42,618 41,071 TRAIN B ROOM No. HEAT LOSS (watts) w/ NK026 w/o NK026 ESF Swgr. Rm. #2 3302 35,225 32,944 Battery Room #4 3405 134 134 DC Swbd. Room #4 3404 6,780 6,780 Battery Room #2 3411 260 260 DC Swbd. Room #2 3410 4,396 5,249 Total 46,795 45,367 Train 'A' Heat Loss Results-One HVAC Unit Operating PLOCA, Train 'B', Selected for Long Term Shutdown Cooling Heat Loss Heat Loss at Heat Loss at ROOM No. atT=O T=24 Hours T=7 Days (Watts) (Watts) (Watts) ESF Swgr. Rm. # 1 3301 24,223 21,946 19,041 Batt. Rm.# 1 3407 68 68 68 DC Swbd. Rm.# 1 3408 4,123 4,123 4,123 Batt. Rm.# 3 3413 484 484 484 DC Swbd. Rm. # 3 3414 5,189 5,189 5,189 Total 34,087 31,810 28,905

Train 'B' Heat Loss Results with One HVAC Unit Operating post-LOCA.

Train 'B' heat loss results when using a single Class 1 E electrical equipment A/C train is bounded by the Post-LOCA Scenario and indicated Train 'A' and Train 'B' load reductions when Train 'B' is selected as the long term shutdown cooling train as indicated in the tables in the response to RAI EEOB-1. For the reasons discussed in the Train 'A' Heat Loss Results above, the limiting case is the Train 'B' heat loss case. The resultant heat loads for the Train 'B' verses Train 'A' results indicate the Train 'B' heat loads range from approximately 7 KW at T=O+ to approximately 10 KW higher at T=7 days for the same corresponding Train 'A' time frames. The heat load results for each Train 'B' room are calculated and summarized in the table below.

Attachment I to ET 18-0014 Page 26 of 32 Train '8' Heat Loss Results-One HVAC Unit Operating PLOCA, Train '8' Selected for Long Term Shutdown Cooling Heat Loss Heat Loss at Heat Loss at ROOM No. at T=O T=24 Hours T=7 Days (Watts) (Watts) (Watts) ESF Swgr. Rm. # 2 3302 31,080 30,646 30,646 Batt. Rm. #4 3405 68 68 68 DC Swbd. Rm.# 4 3404 4,048 4,048 4,048 Batt. Rm.# 2 3411 418 418 418 DC Swbd. Rm. # 2 3410 5,183 5,183 5,183 Total 40,797 40,363 40,363

Discussion on heat loads at T=O if accident mitigating equipment in Train 'A' and Train 'B' starts when an accident signal is actuated.

At T=O, the plant is assumed to be in Normal Operation and the Heat Loads indicated in the Normal Operation Heat Loss Results Table below are indicative of the room heat loading for Train 'A' and Train 'B'. At T=O+ the plant is assumed to be in the Post LOCA (PLOCA) Loading Condition and the heat loads indicated in the Train 'A' Heat Loss Results-One HVAC Unit Operating PLOCA, Train 'B' Selected for Long Term Shutdown Cooling Table for Train 'A' rooms and the Train 'B' Heat Loss Results-One HVAC Unit Operating PLOCA, Train 'B' Selected for Long Term Shutdown Cooling Table for Train 'B' rooms at T=O provide the initial PLOCA heat loading. Note that certain loads are shed for the PLOCA condition (loads shed on an SI signal) and certain loads at T=O+ to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as indicated on drawing E-11005 for EOG loading are added back. The loads are modeled similarly in Appendix 12 of calculation XX-E-006 and incorporated into the loading for PLOCA in calculation GK-E-001.

These Train 'A' and 'B' room heat loads remain constant until T=24 hours when further heat load reductions are taken and then again at T=7 days when the desired cooling train is secured. See tables below for a comparison of time based heat loading and reductions.

Attachment I to ET 18-0014 Page 27 of 32 Normal Operation Heat Loss Results TRAIN 'A' TRAIN '8' HEAT LOSS (watts) HEAT LOSS (watts) ROOM No. w/NK025 w/o NK025 ROOM No. w/ NK026 w/o NK026 ESF Swgr. 3301 24,576 22,859 ESF Swgr. 3302 27,838 26,261 Rm. #1 Rm.#2 Battery Room 3407 134 134 Battery 3405 134 134 #1 Room #4 DC Swbd. 3408 6,278 6,278 DC Swbd. 3404 6,154 6,154 Room #1 Room #4 Battery Room 3413 326 326 Battery 3411 260 260 #3 Room #2 DC Swbd. 3414 4,356 5,329 DC Swbd. 3410 4,394 5,307 Room #3 Room #2 Total 1 35,670 34,926 Total 1 38,780 38,116 EOG NE01 3301 513 513 EOG NE02 3302 513 513 Breaker Breaker Total 2 36,183 35,439 Total 2 39,293 38,629 Train 'A' Heat Loss Results-One HVAC Unit Operating PLOCA, Train '8' Selected for Long Term Shutdown Cooling Heat Loss Heat Loss at Heat Loss at ROOM No. at T=O T=24 Hours T=7 Days (Watts) (Watts) (Watts) ESF Swgr. Rm. # 1 3301 24,223 21,946 19,041 Batt. Rm.# 1 3407 68 68 68 DC Swbd. Rm.# 1 3408 4,123 4,123 4,123 Batt. Rm.# 3 3413 484 484 484 DC Swbd. Rm.# 3 3414 5,189 5,189 5,189 Total 34,087 31,810 28,905 Train '8' Heat Loss Results-One HVAC Unit Operating PLOCA, Train '8' Selected for Long Term Shutdown Cooling Heat Loss Heat Loss at Heat Loss at ROOM No. atT=O T=24 Hours T=7 Days (Watts) (Watts) (Watts) ESF Swgr. Rm. # 2 3302 31,080 30,646 30,646 Batt. Rm.# 4 3405 68 68 68 DC Swbd. Rm. # 4 3404 4,048 4,048 4,048 Batt. Rm.# 2 3411 418 418 418 DC Swbd. Rm. # 2 3410 5,183 5,183 5,183 Total 40,797 40,363 40,363 Attachment I to ET 18-0014 Page 28 of 32 RA/ EEOB-4 Applicable Regulations:

10 CFR 50.36, GOG 13 and 17, and related Licensing Basis described below: 1. Technical Specification

3. 8. 6, "Battery Cell Parameters, " has SR 3. 8. 6. 3, which states, "Verify average electrolyte temperature of representative cells is [greater than or equal to] 60°F." 2. WCGS USAR, Section 9.4, Air Conditioning, Heating, Cooling and Ventilation." The licensee is implementing plant modifications to maintain the environment for operability of onsite and offsite power systems required for conformance with GOG 17. The licensee is installing instrumentation to monitor variables and systems over their anticipated ranges (to maintain the variables and systems within prescribed operating ranges) in accordance with GOG 13. In the LAR, the licensee has discussed the proposed upper limit for temperature for the GOG 17 required power sources. The LAR does not discuss the lower allowable temperature limit. The NRG staff is requesting additional information on parameters that were considered for instrumentation and actions needed for managing battery operability for normal operation, for anticipated operational occurrences, and for accident conditions when ambient conditions change. USAR Section 9.4 provides details on control building ventilation design basis and states that periods of control building isolation can be maintained for approximately 3 days before purging is required to prevent local hydrogen concentration from approaching

2. 0 volume percent. USAR Section 1.2 states that the plant site experiences a wide seasonal range of temperatures

-maximum of 117°F and lowest temperature of -26°F. The ambient temperature in the battery rooms, under any mode of operation, is required to be maintained between 60°F and 90°F. The LAR proposes plant operation for 30 days with one Class 1 E electrical equipment HVAC train supporting redundant electrical equipment areas. Section 3.4 "Operator Actions" of Attachment II of the letter dated June 28, 2017, states that calculation GK-E-001 takes credit for equipment that can be turned off within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and 7 days after initiation of a LOCA event. Hence the load shedding will result in considerable reduction in heat input from electrical loads after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The LAR does not discuss the consequences on room temperatures when the site experiences low winter temperatures.

Please provide a discussion that battery electrolyte temperatures will not drop below the design basis temperature of 60°F for the duration of planned or unplanned HVAC system outage with prevailing winter conditions and any make up outside air required to maintain design basis conditions in the control building.

Response:

The removal/failure of a Class 1 E electrical equipment A/C train does not secure any electrical equipment in the rooms adjacent to the battery rooms, except to transfer battery charging from the normal battery chargers to the spare battery chargers in the Class 1 E electrical equipment rooms on the 2000' level. The battery rooms are located on the 2016' level in the Control Building.

The battery rooms are located above ESF Switchgear Rooms A and B (NB001/NB002 switchgear rooms). The switchgear rooms are heated areas. The battery rooms are located below the Lower Cable Spreading Room (2032' level). The Lower Cable Spreading Room is also a heated area. The battery rooms Attachment I to ET 18-0014 Page 29 of 32 are not adjacent to any exterior walls of the Control Building.

As discussed in Reference 1, Page 12 of 48 of Attachment I, Procedure STS CR-001, "Shift Log for MODES 1, 2 & 3," and STS CR-002, "Shift Log for MODES 4, 5, and 6," satisfies the monitoring requirements of TSR 3.7.22.1 by verifying the area room temperatures every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The temperatures in the battery rooms are manually verified once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months with a thermometer installed in the rooms (the DC switchboard rooms and ESF switchgear rooms also have thermometers) by procedures STS CR-001 and STS CR-002. Additionally, the temperature in the battery rooms is monitored and documented by the Turbine Building roving watch once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months shift per procedure CKL ZL-004. The temperature of the Battery Rooms is monitored on a

routine basis to ensure that the temperature of the rooms do not drop below 60°F. WCNOC calculation GK-M-007 "Battery Room, Switchboard room, Switchgear room temperature during winter concurrent with station black out conditions" evaluates the temperature of the battery rooms during the extreme winter condition temperature.

This calculation assumes SBO conditions, thus there is no internal heating from the electrical equipment during this period. The results of the calculation determined that the temperature of the battery rooms would be maintained above 60°F. Thus, if the battery rooms can be maintained above 60°F during SBO conditions and is maintained above 60°F during normal conditions with two Class 1 E electrical equipment A/C trains operating, then it can be concluded the battery rooms will remain above 60°F with a single Class 1 E electrical equipment A/C train operating and the same amount of electrical heat loading. The only outside air introduced into the Control Building is via the Control Building Pressurization System. This system is discussed on page 26 of 48 of Attachments I and II of Reference

1. RAJ EEOB-5 Applicable Regulations:

GOCs 13 and 17 The licensee is implementing plant modifications to maintain the environment for operability of onsite and offsite power systems required for conformance with GOG 17. The licensee is installing instrumentation to monitor variables and systems over their anticipated ranges (to maintain the variables and systems within prescribed operating ranges) in accordance with GOG 13. In the LAR, the licensee has discussed the proposed temperature range for the GOG 17 required power sources. The NRG staff is requesting additional information on parameters that were considered for instrumentation needed during anticipated ranges of room temperatures to provide reasonable assurance that the onsite and offsite power systems provide sufficient capacity and capability to assure that ( 1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

Section 3.2.2 "Inputs/Assumptions" of Attachment II of the Jetter dated June 28, 2017, discusses accidents analyses and various types of line breaks considered in Chapter 15 of the USAR. Section 3.4 of Attachment II of letter dated June 28, 2017, states that calculation GK-E-001 takes credit for equipment that can be turned off within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and 7 days after initiation of a LOCA event. The evaluation assumes that significant safety-related operating loads can be shed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to reduce heat loads in the area. The evaluation also assumes that LOCA loads provide the bounding condition for heat generation.

A large Attachment I to ET 18-0014 Page 30 of 32 break LOCA condition may be bounding for magnitude of heat load considerations over a short duration.

A small break, midsize break, or a steamline rupture may impose a lower heat load at the onset of an event but the duration of some large loads maybe more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months assumed in the heat load calculations.

a. Please provide a discussion that the heat load calculation and associated load curtailment is bounding for all events considered in the safety analysis of WCGS. b. Please provide a discussion that plant procedures (normal operation and emergency operation) and accident analyses provide guidance and basis for load shedding.

Response:

a. The Containment Spray (CS) pump, Safety Injection (SI) pump, and Auxiliary Feedwater (AFW) pump are secured within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Small Break LOCA (SBLOCA) and Main Steam Line Break (MSLB) scenarios.

Calculation GK-E-001 determines the heat loading for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with the CS pump, SI pump, and AFW pump operating in both trains for the Large Break LOCA (LBLOCA) scenario; therefore, the heat loading is similar for the LBLOCA, SBLOCA, and MSLB scenarios.

A charging pump (589 KVA), RHR pump (297 KVA), CCW pump (633 KVA), and ESW pump (1601 KVA) are operating for the first 7 days for both trains in the LBLOCA scenario.

For the MSLB scenario, one train can be secured within 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months ; therefore, the heat loading for the LBLOCA scenario is more conservative than the MSLB scenario since the electrical loading after 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months is 3,120 KVA greater for the LBLOCA scenario.

In addition, the charging pumps are used intermittently; therefore, the heat loss is less than calculated.

A charging pump (589 KVA), RHR pump (297 KVA), CCW pump (633 KVA), and ESW pump (1601 KVA) are operating for the first 7 days for both trains in the LBLOCA scenario.

For the SBLOCA scenario, one train can be secured within 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months ; therefore, the heat loading for the LBLOCA scenario is more conservative than the SBLOCA scenario since the electrical loading after 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months is 3, 120 KVA greater for the LBLOCA scenario.

In addition, the charging pumps are used intermittently; therefore, the heat loss is less than calculated.

A charging pump (589 KVA), RHR pump (297 KVA), CCW pump (633 KVA), and ESW pump (1601 KVA) are operating for the first 7 days for both trains in the LBLOCA scenario.

For a LOOP, one train can be secured within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; therefore, the heat loading for the LBLOCA scenario is more conservative than the LOOP scenario since the electrical loading after 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is 3,120 KVA greater for the LBLOCA scenario.

In addition, the charging pumps are used intermittently; therefore, the heat loss is less than calculated.

The pressurizer backup heaters may be used by plant operators in the LOOP scenario to maintain pressure; however, the heaters would be on a maximum of 20 minutes per hour and the heat loss into the switchgear room is just the heat loss from the switchgear breaker which is 6 Watts. Regarding the remaining accidents considered in the safety analysis (other than LOOP, MSLB, SBLOCA, and LBLOCA), the LBLOCA event is bounding in regards to heat loads. This is due to the number of components automatically loaded as a result Attachment I to ET 18-0014 Page 31 of 32 of the Safety Injection Signal and Containment Pressure -High-3 Signal generated at the onset of the event. Furthermore, equipment will be needed for a longer duration following a LBLOCA in order to support the PLOCA phase of the event. Therefore, since LBLOCA bounds the remaining events considered in the safety analysis (other than the differences previously discussed associated with a LOOP, MSLB, or SBLOCA), in regards to heat loads, the remaining accidents are not individually discussed.

b. As discussed in Section 3.1 of the USAR, the accident analyses consider the failure of one component during an event. In order to ensure that the required safety functions necessary to mitigate an event can be performed, two redundant trains of protection equipment are available.

Thus, if one component fails on one train of protection equipment, then the corresponding component on the opposite protection train will be available to perform the required safety function.

If one Class 1 E electrical equipment A/C train failed during an event, that failure would be considered the single failure and thus the other Class 1 E electrical equipment A/C train would be assumed to be available to perform the required safety function.

Depending on the event, loads would then be shed as they were assessed to be no longer required.

In addition to the loads shed on the protection train corresponding to the failed Class 1 E electrical equipment A/C train, the SI pump (and associated room cooler), CS pump, and AFW pumps can also be shed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after event initiation.

The basis for shedding these loads is as follows: Safety Injection Pump The SI pump will be needed during the injection phase of a SBLOCA and LBLOCA. However, once the initial event has been mitigated and the long term core cooling phase begins, the SI pump is no longer required as the RHR System will provide sufficient flow to provide long term decay heat removal. Containment Spray Pump In order to support the decontamination factors assumed in the LOCA dose analysis, a CS pump needs to operate for -10 hours directly following an event. Additionally, in order to support the assumptions within the LOCA or MSLB Containment Pressure and Temperature Analyses, the CS pump will need to operate during the injection phase of the event. Following the injection phase of the event, the CS pump will be switched to recirculation.

As there is not a heat exchanger on the CS System, following the swap to recirculation, the CS pump will provide little to no cooling (only cooling will be due to moving cooler water in the sump to the top of the containment atmosphere) and will primarily be used for iodine removal. Thus, after the CS pump has operated for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months following a LOCA, it can be shed as it has completed its required safety function.

Attachment I to ET 18-0014 Page 32 of 32 Auxiliary Feedwater Pumps The AFW pumps can be shed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a LOOP, MSLB, LBLOCA, or SBLOCA. This is due to the fact that RHR cut-in conditions will be reached in less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (as discussed in USAR Section 10.4.9, the AFW System is designed to hold the Reactor Coolant System at no load conditions for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and then cooldown the RCS to 350°F at 50°F/hour).

Once RHR cut-in conditions are reached, the RHR System will remove heat from the primary system and the AFW pumps can be shed. During Normal Operation with a non-functional Class 1 E electrical equipment A/C train, procedure SYS GK-200, "Non-Functional Class 1 E A/C Unit," will be used for operation of the recirculation subsystem trains until proposed TS 3.7.20 is approved and implemented.

Procedure SYS GK-200 provides the guidance for implementing the mitigating actions for starting the recirculation subsystem train, aligning the spare battery chargers, and verifying the Class 1 E electrical equipment room temperatures.

After TS 3.7.20 is approved and implemented, procedure SYS GK-201, "Mitigating Actions for an Inoperable SGKOS Train," which is similar to procedure SYS GK-200, will be used. When a single Class 1 E electrical equipment A/C train is available and mitigating actions for an inoperable cooling train are in effect coincident with a DBA LOCA, the emergency operating (EMG) procedures would be followed as written. The EMG procedures provide operator guidance for shedding components, such as Emergency Core Cooling System (ECCS) pumps, when conditions indicate that they are no longer required.

The components are shed prior to the times indicated in calculation GK-E-001 for one Class 1 E electrical equipment A/C train operating PLOCA.

References:

1. WCNOC Letter ET 17-0010 from J. H. McCoy to USNRC, "License Amendment Request for Addition New Technical Specification

3. 7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System"," June 28, 2017. ADAMS Accession No. ML17186A082.

2. WCNOC Letter ET 18-0007, from J. H. McCoy to USNRC, "Supplement to License Amendment Request for Addition New Technical Specification

3. 7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System"," February 15, 2018. ADAMS Accession No. ML18058A743.

3. Letter from B. K. Singal, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station, Unit 1 -Request for Additional Information Re: License Amendment Request for Addition of New Technical Specification

3. 7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System" (CAC NO. MF9961; EPID L-2017-LLA-0262)," April 6, 2018. ADAMS Accession No. ML18074A310.

Attachment II to ET 18-0014 Page 1 of 3 ATTACHMENT II Revised TS Bases Pages (for information only)

Attachment II to ET 18-0014 Page 2 of 3 BASES ACTIONS Wolf Creek -Unit 1 Class 1 E Electrical Equipment Air-Conditioning (A/C) System B 3.7.20 A.1, A.2, and A.3 With one Class 1 E electrical equipment A/C train inoperable, action must be initiated immediately to implement mitigating actions. The mitigating action taken with one Class 1 E electrical equipment A/C train inoperable include enabling the halon interlock relay, starting the appropriate single train recirculating fans (includes opening discharge damper), and placing in service the spare battery chargers within one hour. One train of Control Building pressurization is secured within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if both trains are in operation.

These mitigating actions (i.e., actions that are taken to offset the consequences of an inoperable Class 1 E electrical equipment A/C train) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.

A room area temperature limit of s; go°F is based on the normal operating maximum steady state environmental condition and a plant specific calculation for a single Class 1 E electrical equipment A/C train maintaining both Class 1 E electrical equipment train rooms at a temperature of s; 104 °F during design basis accident conditions.

The plant specific calculation envelopes affected room area temperatures being s; go°F at the onset of the design basis accident.

With one Class 1 E electrical equipment A/C train inoperable, the overall reliability of the cooling function is reduced. The remaining OPERABLE train can provide the required cooling function if mitigating actions are taken. The specified mitigating actions assume that the OPERABLE Class 1 E electrical equipment A/C train is capable of operating at full capacity.

As demonstrated by analysis, the capability of a single Class 1 E electrical equipment A/C train to maintain area temperatures s; go°F for both trains of electrical equipment during normal conditions, with the mitigating actions implemented, corresponds to that train's capability to maintain area temperatures s; 104°F for both trains of electrical equipment during accident conditions.

Verifying the room area temperatures within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter is adequate to ensure temperatures remain belows; go°F. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable based on the minimal increase in room temperatures during this time period. B 3.7.20-3 Revision XX Attachment II to ET 18-0014 Page 3 of 3 BASES SURVEILLANCE REQUIRMENTS (continued)

REFERENCES Wolf Creek -Unit 1 Class 1 E Electrical Equipment Air-Conditioning (A/C) System B 3.7.20 SR 3.7.20.2 Testing of the Class 1 E Electrical Equipment Air Conditioning (A/C) System condenser heat exchangers under design conditions is impractical.

This SR verifies the heat removal capability of the Class 1 E electrical equipment A/C trains is adequate to remove the heat load assumed in the affected rooms during design basis accidents.

This SR consists of verifying the heat removal capability of the condenser heat exchanger (either through performance testing or inspection), ensuring the proper operation of major components in the refrigeration cycle, verification of unit air flow capacity, and water flow measurement.

This SR is performed in the same manner as SR 3. 7 .11.1 (Reference 2). The 18 month Frequency is appropriate since significant degradation of the Class 1 E Electrical Equipment A/C System is slow and is not expected over this time period. 1. USAR, Section 9.4.1. 2. Letter from C.F. Lyon, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station -Interpretation of Technical Specification Surveillance Requirement 3.7.11.1, "Verify each CRACS train has the capability to remove the assumed heat load" (TAC NO. MF3665)," May 28, 2014. B 3.7.20-5 Revision XX Enclosure I to ET 18-0014 Enclosure I Piping and Instrumentation Diagrams for the Control Building HVAC 8

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