ML14363A313

Ameren Missouri Callaway Energy Center Expedited Seismic Evaluation Process Report

ML14363A313
Person / Time
Site:	Callaway
Issue date:	12/31/2014
From:	Ameren Missouri, Stevenson & Associates, Westinghouse
To:	Office of Nuclear Reactor Regulation
Shared Package
ML14363A311	List: ML14363A313 ULNRC-06161, Response to NRC Request for Information Pursuant to 10CFR50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident - Expedited.
References
ULNRC-06161
Download: ML14363A313 (61)

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Enclosure 2 to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report AMEREN MISSOURI CALLAWAY ENERGY CENTER EXPEDITED SEISMIC EVALUATION PROCESS (ESEP) REPORT December 31, 2014 Prepared by: Ameren Missouri Westinghouse Electric Company LLC Stevenson & Associates 12/1/14 Page 1 of 61

© 2014 by Westinghouse Electric Company LLC. All Rights Reserved.

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report EXPEDITED SEISMIC EVALUATION PROCESS REPORT Table of Contents 1.0 Purpose and Objective ..................................................................................................................... 4 2.0 Brief Summary of the FLEX Seismic Implementation Strategies .................................................... 5 3.0 Equipment Selection Process and ESEL ........................................................................................... 6 3.1 Equipment Selection Process and ESEL.......................................................... 6 3.1.1 ESEL Development .......................................................................................... 7 3.1.2 Power Operated Valves .................................................................................. 7 3.1.3 Pull Boxes ........................................................................................................ 8 3.1.4 Termination Cabinets ..................................................................................... 8 3.1.5 Critical Instrumentation Indicators ................................................................ 8 3.1.6 Phase 2 and Phase 3 Piping Connections ....................................................... 8 3.1.7 Relays .............................................................................................................. 9 3.2 Justification for Use of Equipment That Is Not the Primary Means for FLEX Implementation .............................................................................................. 9 4.0 Ground Motion Response Spectrum (GMRS) .................................................................................. 9 4.1 Plot of GMRS Submitted by the Licensee ...................................................... 9 4.2 Comparison to SSE ........................................................................................ 12 5.0 Review Level Ground Motion (RLGM) ........................................................................................... 13 5.1 Description of RLGM Selected ...................................................................... 13 5.2 Method to Estimate ISRS.............................................................................. 14 6.0 Seismic Margin Evaluation Approach ............................................................................................ 15 6.1 Summary of Methodologies Used................................................................ 15 6.2 HCLPF Screening Process .............................................................................. 15 6.2.1 Overview ....................................................................................................... 15 6.2.2 Generic Screening Results ............................................................................ 16 6.3 Seismic Walkdown Approach ....................................................................... 19 6.3.1 Walkdown Approach .................................................................................... 19 6.3.2 Application of Previous Walkdown Information ......................................... 19 6.3.3 Significant Walkdown Findings .................................................................... 19 12/2/14 Page 2 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 6.4 HCLPF Calculation Process ............................................................................ 23 6.5 Functional Evaluations of Relays.................................................................. 23 6.6 Tabulated ESEL HCLPF Values (Including Key Failure Modes) ..................... 23 7.0 Inaccessible Items .......................................................................................................................... 26 7.1 Identification of ESEL items inaccessible for walkdowns ............................ 26 8.0 ESEP Conclusions and Results ........................................................................................................ 26 8.1 Supporting Information ................................................................................ 26 8.2 Indication of Planned Modifications ............................................................ 28 8.3 Modification Implementation Schedule ...................................................... 29 8.4 Summary of Regulatory Commitments ....................................................... 29 9.0 References ...................................................................................................................................... 31 Attachment A Callaway ESEL................................................................................................ 34 Attachment B ESEP HCLPF Values and Failure Modes Tabulation ..................................... 50 12/2/14 Page 3 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 1.0 Purpose and Objective Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the Nuclear Regulatory Commission (NRC) established a Near-Term Task Force (NTTF) to conduct a systematic review of NRC processes and regulations and to determine if the agency should make additional improvements to its regulatory system. The NTTF developed a set of recommendations intended to clarify and strengthen the regulatory framework for protection against natural phenomena. Subsequently, the NRC issued a 50.54(f) letter on March 12, 2012 [1], requesting information to assure that these recommendations are addressed by all U.S. nuclear power plants. The 50.54(f) letter requests that licensees and holders of construction permits under 10 CFR Part 50 reevaluate the seismic hazards at their sites against present-day NRC requirements and guidance. Depending on the comparison between the reevaluated seismic hazard and the current design basis, further risk assessment may be required. Assessment approaches acceptable to the staff include a seismic probabilistic risk assessment (SPRA), or a seismic margin assessment (SMA). Based upon the assessment results, the NRC staff will determine whether additional regulatory actions are necessary.

This report describes the Expedited Seismic Evaluation Process (ESEP) undertaken for the Callaway Energy Center (CEC). The intent of the ESEP is to perform an interim action in response to the NRCs 50.54(f) letter [1] and to demonstrate seismic margin through a review of a subset of the plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events.

The ESEP is implemented using the methodologies in the NRC endorsed guidance in EPRI 3002000704, Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic [2]. The guidance discusses the use of the ongoing FLEX process [3] as a starting point for consideration.

This report examines the FLEX equipment and strategy [3] (Section 2.0) to develop the initial Expedited Seismic Equipment List (ESEL) and uses an iterative process to develop the final ESEL [4] (Section 3.0).

The ESEL is used to evaluate the listed equipment against the review level ground motion (RLGM) data (Section 5) with respect to the equipments seismic capacity based on characterization of the high confidence of a low probability of failure (HCLPF).

Equipment which has seismic capacity larger than the RLGM data can be screened from further evaluation. For equipment that has a seismic capacity below the RLGM, modifications need to be performed following the NRC endorsed guidance in EPRI 3002000704.

The objective of this report is to provide summary information describing the ESEP evaluations and results. The level of detail provided in this report is intended to enable the NRC to understand the inputs used, the evaluations performed, and the decisions made as a result of the interim evaluations.

12/2/14 Page 4 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 2.0 Brief Summary of the FLEX Seismic Implementation Strategies The Callaway FLEX strategies for Reactor Core Cooling and Heat Removal, Reactor Inventory Control/Long-term Subcriticality, and Containment Function are summarized below. This summary is derived from the Callaway Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049 [3].

Reactor core cooling and heat removal is achieved via steam release from the Steam Generators (SGs) with SG makeup from the Turbine Driven Auxiliary Feedwater Pump (TDAFP) during FLEX Phase 1 with suction from the Condensate Storage Tank (CST).

Ameren Missouri has elected to construct a new Hardened Condensate Storage Tank (HCST) [3]. The larger HCST volume would be capable of feeding the steam generators for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This extended coping duration will not require HCST make-up from the UHS before the Phase 3 off-site equipment is deployed. The TDAFP flow control valves and Main Steam Atmospheric Relief Valves (ARVs) are also required to provide reactor core heat-removal capability. Phase 2 reactor core heat removal is achieved via the new FLEX mechanical connections. The only permanent plant equipment manipulated for the Phase 2 is manual valves.

Reactor Inventory Control/Long-term Subcriticality strategy consists of reactor coolant system borated make-up via the FLEX primary make-up connections.

Reactor coolant system (RCS) inventory reduction is a result of water volume reduction due to cooldown, reactor coolant pump seal leakage, and letdown via head-vents and/or pressurizer PORVs. The reactor coolant pump seal leak-off containment isolation valve is manually isolated to conserve inventory and keep leak-off flow within the Reactor Building. To avoid adverse effects on the RCS natural circulation flow, the accumulator isolation valves are electrically closed during the cooldown to prevent nitrogen injection into the reactor coolant system.

There are no Phase 1 or Phase 2 FLEX actions required to maintain containment integrity. In fact, containment function is not expected to be challenged during all three phases.

Necessary electrical components are outlined in the Callaway FLEX OIP submittal [3],

and primarily entail the installation of a 480V generator (FLEX) to provide power to vital batteries, equipment installed to support FLEX electrical connections, and monitoring instrumentation required for core cooling, reactor coolant inventory, and containment integrity.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 3.0 Equipment Selection Process and ESEL The selection of equipment for the Expedited Seismic Equipment List (ESEL) followed the guidelines of EPRI 3002000704 [2]. The ESEL for Callaway is presented in Attachment A.

3.1 Equipment Selection Process and ESEL The selection of equipment to be included on the ESEL was based on installed plant equipment credited in the FLEX strategies during Phases 1, 2 and 3 mitigation of a Beyond Design Basis External Event (BDBEE), as outlined in the Callaway Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049 [3]. The OIP provides the Callaway FLEX mitigation strategy and serves as the basis for equipment selected for the ESEP.

The scope of installed plant equipment includes equipment relied upon for the FLEX strategies to sustain the critical functions of core cooling and containment integrity consistent with the Callaway OIP [3]. FLEX recovery actions are excluded from the ESEP scope per EPRI 3002000704 [2]. The overall list of planned FLEX modifications and the scope for consideration herein is limited to those required to support core cooling, reactor coolant inventory and subcriticality, and containment integrity functions. Portable and pre-staged FLEX equipment (not permanently installed) are excluded from the ESEL per EPRI 3002000704 [2].

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

1. The scope of components is limited to that required to accomplish the core cooling and containment safety functions identified in Table 3-2 of EPRI 3002000704. The instrumentation monitoring requirements for core cooling/containment safety functions are limited to those outlined in the EPRI 3002000704 guidance, and are a subset of those outlined in the Callaway OIP [3].

2. The scope of components is limited to installed plant equipment and the FLEX connections necessary to implement the Callaway OIP [3] as described in Section 2.

3. The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either Primary or Back-up/Alternate).

4. The Primary FLEX success path is to be specified. Selection of the Back-up/Alternate FLEX success path must be justified.

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

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report

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

[2] guidance are:

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

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

• Manual valves and rupture disks.

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

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

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

3.1.1 ESEL Development The ESEL was developed by reviewing the Callaway OIP [3] to determine the major equipment involved in the FLEX strategies. Further reviews of plant drawings (e.g., Process and Instrumentation Diagrams (P&IDs) and Electrical One Line Diagrams) were performed to identify the boundaries of the flowpaths to be used in the FLEX strategies and to identify specific components in the flowpaths needed to support implementation of the FLEX strategies.

Boundaries were established at an electrical or mechanical isolation device (e.g.,

isolation amplifier, valve, etc.) in branch circuits / branch lines off the defined strategy electrical or fluid flowpath. P&IDs were the primary reference documents used to identify mechanical components and instrumentation. The flow paths used for FLEX strategies were selected and specific components were identified using detailed equipment and instrument drawings, piping isometrics, electrical schematics and one-line drawings, system descriptions, design basis documents, etc., as necessary. The P&IDs are also used to determine the normal position of system valves and the valve positioning required in order to align the system in support of the FLEX functions.

The electrical equipment required to support the mechanical components used in the FLEX strategies evaluated for the ESEL was also evaluated for its inclusion on the ESEL using electrical drawings and guidance [2].

3.1.2 Power Operated Valves Page 3-3 of EPRI 3002000704 [2] notes that power operated valves not required to change state are excluded from the ESEL. Page 3-2 also notes that functional failure modes of electrical and mechanical portions of the installed Phase 1 equipment should be considered (e.g., RCIC/AFW trips). To address this 12/2/14 Page 7 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report concern, the following guidance is applied in the Callaway ESEL for functional failure modes associated with power operated valves:

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

• Power operated valves not required to change state as part of the FLEX mitigation strategies were not included on the ESEL. The seismic event also causes the ELAP event; therefore, the valves are incapable of spurious operation as they would be de-energized.

• Power operated valves not required to change state as part of the FLEX mitigation strategies during Phase 1, and are re-energized and operated during subsequent Phase 2 and 3 strategies, were not evaluated for spurious valve operation as the seismic event that caused the ELAP has passed before the valves are re-powered.

3.1.3 Pull Boxes Pull boxes were deemed unnecessary to add to the ESELs as these components provide completely passive locations for pulling or installing cables. No breaks or connections in the cabling are included in pull boxes. Pull boxes were considered part of conduit and cabling, which are excluded in accordance with EPRI 3002000704 [2].

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

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

3.1.6 Phase 2 and Phase 3 Piping Connections Item 2 in Section 3.1 above notes that the scope of equipment in the ESEL includes FLEX connections necessary to implement the Callaway OIP [3] as described in Section 2. Item 3 in Section 3.1 also notes that The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either Primary or Back-up/Alternate).

12/2/14 Page 8 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Item 6 in Section 3.1 above goes on to explain that Piping, cabling, conduit, HVAC, and their supports are excluded from the ESEL scope in accordance with EPRI 3002000704 [2].

Therefore, piping and pipe supports associated with FLEX Phase 2 and Phase 3 connections are excluded from the scope of the ESEP evaluation. However, any active valves in FLEX Phase 2 and Phase 3 connection flow path are included in the ESEL.

3.1.7 Relays Relays essential to the FLEX strategy were explicitly addressed [5]. Relays were screened and where relay chatter was found to result in an undesirable alignment the relay, and its parent cabinet, were added to the analysis. Parent cabinets were walked down and, if needed, HCLPF estimates were performed.

3.2 Justification for Use of Equipment That Is Not the Primary Means for FLEX Implementation No equipment outside of the primary FLEX strategy is credited in the Callaway ESEP [4].

The complete ESEL for Callaway [4] is presented in Attachment A.

4.0 Ground Motion Response Spectrum (GMRS) 4.1 Plot of GMRS Submitted by the Licensee The CEC design response spectra are stated to be applied in the free field at finished grade [6].

The 1E-4 and 1E-5 Uniform Hazard Response Spectra (UHRS), along with a design factor (DF), are used to compute the GMRS at the control point as shown in the seismic hazard and GMRS submittal to the NRC [7].

Table 4-1 shows the UHRS and GMRS spectral accelerations.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Table 4-1: UHRS for 10-4 and 10-5 and GMRS at the control point for Callaway

-4 -5 Freq. (Hz) 10 UHRS (g) 10 UHRS (g) GMRS (g) 100 4.20E-01 9.88E-01 5.00E-01 90 4.24E-01 1.00E+00 5.06E-01 80 4.30E-01 1.02E+00 5.15E-01 70 4.40E-01 1.05E+00 5.30E-01 60 4.61E-01 1.11E+00 5.57E-01 50 5.12E-01 1.23E+00 6.17E-01 40 6.17E-01 1.45E+00 7.34E-01 35 6.83E-01 1.60E+00 8.12E-01 30 7.68E-01 1.82E+00 9.20E-01 25 8.70E-01 2.10E+00 1.06E+00 20 9.16E-01 2.21E+00 1.11E+00 15 9.02E-01 2.18E+00 1.10E+00 12.5 9.10E-01 2.16E+00 1.09E+00 10 9.54E-01 2.17E+00 1.11E+00 9 9.90E-01 2.21E+00 1.13E+00 8 1.02E+00 2.24E+00 1.15E+00 7 1.03E+00 2.24E+00 1.15E+00 6 1.01E+00 2.19E+00 1.12E+00 5 9.14E-01 2.00E+00 1.02E+00 4 6.74E-01 1.55E+00 7.85E-01 3.5 5.29E-01 1.25E+00 6.32E-01 3 4.00E-01 9.59E-01 4.83E-01 2.5 2.87E-01 6.81E-01 3.44E-01 2 2.31E-01 5.32E-01 2.70E-01 1.5 1.70E-01 3.75E-01 1.92E-01 12/2/14 Page 10 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report

-4 -5 Freq. (Hz) 10 UHRS (g) 10 UHRS (g) GMRS (g) 1.25 1.58E-01 3.39E-01 1.75E-01 1 1.36E-01 2.86E-01 1.48E-01 0.9 1.24E-01 2.61E-01 1.35E-01 0.8 1.12E-01 2.38E-01 1.23E-01 0.7 1.02E-01 2.19E-01 1.13E-01 0.6 9.47E-02 2.04E-01 1.05E-01 0.5 8.64E-02 1.89E-01 9.68E-02 0.4 6.91E-02 1.51E-01 7.75E-02 0.35 6.05E-02 1.32E-01 6.78E-02 0.3 5.18E-02 1.13E-01 5.81E-02 0.25 4.32E-02 9.44E-02 4.84E-02 0.2 3.45E-02 7.55E-02 3.87E-02 0.15 2.59E-02 5.66E-02 2.91E-02 0.125 2.16E-02 4.72E-02 2.42E-02 0.1 1.73E-02 3.77E-02 1.94E-02 12/2/14 Page 11 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Figure 4-1 shows the control point UHRS and GMRS.

Mean Soil UHRS and GMRS at Callaway 2.5 2.

1E-5 UHRS Spectral acceleration, g 1.5 GMRS 1E-4 UHRS 1.

0.5 0.

0.1 1 10 100 Spectral frequency, Hz Figure 4-1: Plots of 1E-4 and 1E-5 UHRS and GMRS at control point for Callaway (5%-damped response spectra) 4.2 Comparison to SSE The definition of the SSE for Callaway is discussed in Section 2.5, 3.7 and 3.7(B) of the FSAR [6]. The SSE is anchored to a 0.20g Peak Ground Acceleration (PGA) and is presented in Table 4-2.

Table 4-2: SSE for Callaway Freq (Hz) SA (g) 0.25 0.09 2.50 0.63 9.00 0.52 33.00 0.20 100.00 0.20 12/2/14 Page 12 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report As shown in Figure 4-2, the GMRS begins to exceed the SSE at around 3.5 Hz.

SSE GMRS 10.00 1.00 Acceleration (g) 0.10 0.01 0.1 1 10 100 Frequency (Hz)

Figure 4-2: Callaway SSE - GMRS Comparison 5.0 Review Level Ground Motion (RLGM) 5.1 Description of RLGM Selected The Review Level Ground Motion is derived by linearly scaling the current design basis SSE by the maximum ratio of the GMRS to the SSE between the 1 and 10 Hz range (not to exceed two times the SSE) [2]. The maximum GMRS/SSE ratio occurs at 10 Hz as seen in Figure 4-2. The In-Structure Response Spectra document provides logarithmic interpolation at 10 Hz to determine that the SSE spectral acceleration is 0.48 g [8]. Examination of Table 4-1 shows that the GMRS spectral acceleration is 1.11 g. The result is a maximum GMRS/SSE ratio between 1 - 10 Hz of 2.31 (witness 1.11 g / 0.48 g = 2.31). Since the GMRS/SSE ratio cannot exceed 2 the RGLM is scaled at 2 X SSE. The resulting RLGM is shown in Table 5-1 and Figure 5-1.

It is noted that for surface-mounted structures, systems, and components (SSC)

(TAP01, TBN01, and the CST pipe house) directly applying the GMRS for HCLPF 12/2/14 Page 13 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report determination is acceptable. Results based upon the GMRS as the seismic margins earthquake are noted where applicable herein.

Table 5-1: RLGM for Callaway Freq. (Hz) 100 33 9 2.5 0.25 RLGM (g) 0.4 0.4 1.04 1.26 0.18 SSE GMRS RLGM 10.00 1.00 Acceleration (g) 0.10 0.01 0.1 1 10 100 Frequency (Hz)

Figure 5-1: Callaway RLGM vs GMRS 5.2 Method to Estimate In-Structure Response Spectra (ISRS)

The ISRS for Callaway [10a] uses the scaled approach to estimate the ISRS. As mentioned in Section 5.1, the RLGM is scaled by a factor of 2 which is also applied to the existing ISRS curves.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 6.0 Seismic Margin Evaluation Approach It is necessary to demonstrate that the ESEL items have sufficient seismic capacity to meet or exceed the demand characterized by the RLGM. The seismic capacity is characterized as the peak ground acceleration (PGA) for which there is a high confidence of a low probability of failure (HCLPF). The PGA is associated with a specific spectral shape, in this case the 5%-damped RLGM spectral shape. The HCLPF capacity must be equal to or greater than the RLGM PGA. The criteria for seismic capacity determination are given in Section 5 of EPRI 3002000704 [2].

There are two basic approaches for developing HCLPF capacities:

1. Deterministic approach using the conservative deterministic failure margin (CDFM) methodology of EPRI NP-6041, A Methodology for Assessment of Nuclear Power Plant Seismic Margin (Revision 1) [8].

2. Probabilistic approach using the fragility analysis methodology of EPRI TR-103959, Methodology for Developing Seismic Fragilities [9].

Callaway has elected to use the deterministic approach by applying the EPRI NP-6041 screening process [8].

6.1 Summary of Methodologies Used The seismic margins methodology of EPRI report NP-6041-SL [8] was applied for this effort. Use of this methodology conforms to Section 5 of EPRI 3002000704. The primary tasks performed were:

• Generic seismic screening per NP-6041, Table 2-4.

• Performance of seismic walkdowns.

• Item-specific screening via walkdown, review of design data, and performance of screening calculations.

• Performance of HCLPF calculations for screened-in equipment 6.2 HCLPF Screening Process 6.2.1 Overview The seismic margins screening methodology of NP-6041-SL was applied. The primary steps for this screening process are:

1. Apply NP-6041-SL, Table 2-4 to determine which equipment items and failure modes may be screened-out on a generic basis.

2. For each equipment item, perform a seismic walkdown to verify generic screening may be applied and to verify the item does not have any specific seismic vulnerabilities.

3. Verify anchorage capacity.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report The generic screening criteria of Table 2-4 are dependent on the applied screening level and are applicable to equipment located within 40 feet of plant grade. For the Callaway ESEP project:

• The peak 5% spectral acceleration of the RLGM is 1.26g and occurs at 2.5 Hz. At 3.5 Hz, the RLGM decreases to 1.2g 1. From FSAR SP Table 3.7(B)-4 and SA Tables 3.7-3 and 3.7-4, all Category I structures have fundamental frequencies exceeding 3.5 Hz and can reasonably be considered to respond in the frequency range corresponding to accelerations less than 1.2g. Accordingly, the 2nd screening column (0.8 - 1.2g) screening criteria of NP-6041-SL, Table 2-4, were applied with special consideration for components with low frequencies.

• A number of components in the Auxiliary/Control Building and the Reactor Building were located above 40 from grade; all other equipment was located within 40 of plant grade. Per Appendix A of NP-6041-SL, components that are above 40 from grade and have corresponding ISRS at the base of component in exceedance of 1.5 times the bounding spectrum (equivalent to a 1.8g peak spectral acceleration) may not be screened to the 2nd screening column and require HCLPF analysis.

Table 6-1 below summarizes the application of Table 2-4 screening for the ESEP.

Applied plant grade was Elevation 2000. Per the FSAR this grade elevation is constant through-out the power block area.

After completion of the screening process, an item is either screened-out or screened-in. The presumptive seismic capacity of a screened-out item exceeds the applied screening level and no further evaluation is needed. An item that is screened-in requires a HCLPF analysis to address the failure mode cited by the seismic review team (SRT). The HCLPF capacity may or may not be above the screening level.

6.2.2 Generic Screening Results Table 6-1 summarizes the generic screening results for the ESEL. Only the relevant equipment types are listed. Based on the generic screening:

• HCLPF analyses are required for atmospheric storage tanks

• Relay chatter requires evaluation 1

The frequency where the RLGM spectra equals 1.2g is determined by logarithmic interpolation based on the control point accelerations and frequencies in Reference 8 as follows:

log(1.04 g ) log(1.26 g )

(log( X Hz ) log( 2.5 Hz ) + log(1.26 g )

log( 9 Hz ) log( 2.5 Hz )

1.2 g = 10 X = 3.46 Hz 12/2/14 Page 16 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Other generic screening requirements were addressed by walkdown, design review and anchorage verification. These assessments are documented in the screening evaluation work sheets (SEWS) [10f].

Table 6-1: Summary of generic screening per NP-6041-SL Table 2-4, 1.2g Screening Level Equipment Type Generic Screening Criteria Screening Result Active valves Note (f) applies. There are no extremely large extended motor operators on 2-inch or smaller piping.

Passive valves No evaluation required. N/A Atmospheric storage tanks Evaluation required. HCLPF analyses required for the atmospheric storage tanks.

Pressure vessels Notes (h), (i) apply For the pressurized tanks on the ESEL, anchorage and load path were verified by bounding calculations using qualification reports during screening. Potential failure modes of the vessel bodies were addressed by walkdown and design review.

Batteries and racks Note (k) applies. Batteries are braced racks and are designed for seismic loads. HCLPF analyses are required for the battery rack anchorage.

Horizontal pumps No evaluation required. Although no evaluation is required for the component per se, a HCLPF evaluation for the auxiliary feedwater turbine-driven pump is required.

Active electrical power Notes (s) and (t) apply. Note (s) was addressed by walkdown and distribution panels design review. Where bounding analysis of anchorage configurations for the RLGM could not be provided, HCLPF analyses are required.

Relays are evaluated separately per Reference 5.

Passive electrical power Note (s) applies. Note (s) was addressed by walkdown and distribution panels design review. Where bounding analysis of anchorage configurations for the RLGM could not be provided, HCLPF analyses are required.

Transformers Notes (u) and (v) apply. The ESEL includes dry-type transformers. A design review verified coil restraint. HCLPF analysis of anchorage is required.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Equipment Type Generic Screening Criteria Screening Result Battery chargers & inverters Note (w) applies. Per walkdown and design review, the items on the ESEL are solid state units. Where bounding analysis of anchorage configurations for the RLGM could not be provided, HCLPF analyses are required.

Instrumentation and control Notes (s) and (t) apply. Note (s) was addressed by walkdown and panels and racks design review. Where bounding analysis of anchorage configurations for the RLGM could not be provided, HCLPF analyses are required.

Relays are evaluated separately per Reference 5.

Temperature sensors; pressure Note (x) applies. Note (x) was addressed by walkdown and and level sensors. design review. Sensors in the scope were typically mounted in-line on piping.

Relevant notes from NP-6041-SL Table 2-4

f. Evaluation recommended for MOVs in piping lines of 2 inches diameter or less.

h. Margin evaluation only needs to consider anchorage and supports.

i. For vessels designed by dynamic analysis or equivalent static analysis enveloping vessel inertial and piping loading, only the anchorage and supports require evaluation. For vessel not meeting these criteria, all potential failure modes require evaluation.

k. Batteries mounted in braced racks designed for seismic loads or qualified by dynamic testing do not require evaluation. Rigid spacers between batteries and end restraints are required. Batteries should be tightly supported by side rails.

s. Walkdown should be conducted to verify that the instruments are properly attached to the cabinets.

t. Relays, contactors, switches, and breakers must be evaluated for chatter and trip if functionality during strong shaking is required.

u. Anchorage evaluation required.

v. Liquid-filled transformers require evaluation of overpressure safety switches. The transformer coils should be restrained within the cabinet for dry transformers.

w. Solid state units require anchorage checks. Others require evaluation.

x. Insufficient data are available for screening guidelines. Emphasis should be on attachments.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 6.3 Seismic Walkdown Approach 6.3.1 Walkdown Approach Walkdowns were performed by two-person seismic review teams (SRTs) consisting of engineers with seismic experience. Walkdowns followed the guidance of Section 5 of EPRI 3002000704 [2] and Section 2 of NP-6041-SL [8]. The SRT used NP-6041-SL, Appendix F, to evaluate item-specific equipment caveats. The SRT also recorded notes and took photographs of the items under review.

Two walkdown sessions have been performed as indicated below.

Walkdown Date SRT Plant Support Week of July 14, 2014 Hunter Young (S&A) Jim Cunningham (Callaway)

Samer El-Bahey (S&A) Steve Sampson (Callaway)

George Belchik (Callaway)

Week of November 3, 2014 Hunter Young (S&A) David Hollabaugh (Callaway)

Apostolos Karavoussianis (S&A)

The walkdown findings for each item are documented in screening evaluation work sheets (SEWS). The SEWS notes also identify evaluations and reviews performed to support screening. The SEWS are included in Appendix C of Reference 10f. Also, Appendix A [10f] provides a concise summary of screening results in tabular format.

6.3.2 Application of Previous Walkdown Information New seismic walkdowns were performed for ESEL equipment. The results of the previous seismic margin evaluation, performed for the Seismic IPEEE program [11], were reviewed and used for background purposes only.

6.3.3 Significant Walkdown Findings The walkdown and screening results are summarized in Table 6-2.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Table 6-2: Items Selected for HCLPF Analysis No. ID Description Bldg Elev Basis for Selection

1. NB001 4.16KV SWGR NB001 (Class CB 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis 1E, Train A) of anchorage.

2. NG001 480 V LOAD CENTER NG01 CB/CC 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis of anchorage.

Apply results to similar items NG002 and NG003.

3. NK011 125 V BATTERY NK011 CB/CC 2016-00 Anchorage could not be readily screened. Perform HCLPF analysis of anchorage.

Apply results to similar items NK013 and NK014.

4. NK021 125 V BATTERY CHARGER CB/CC 2016-00 Anchorage could not be readily screened. Perform HCLPF analysis NK021 of anchorage.

Apply results to similar items NK023 and NK024.

5. NK025 125 V BATTERY CHARGER CB 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis NK025 (Swing Battery of anchorage.

Charger)

6. NN001 Class 1E AC DIST SWBD CB/CC 2016-00 Anchorage could not be readily screened. Perform HCLPF analysis NN01 (SEP GRP 1) of anchorage.

Apply results to similar items NK043, NN003, NK051, NK041, NK001, NK003, NK004, and NN004.

7. NN011 7.5KVA INVERTER (FED CB/CC 2016-00 Anchorage could not be readily screened. Perform HCLPF analysis FROM BATT CHARGER of anchorage.

NK021)

Apply results to similar item NN013.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report No. ID Description Bldg Elev Basis for Selection

8. PA003 CUBICLE PT FOR RCP AUX 2026-00 Anchorage could not be readily screened. Perform HCLPF analysis MOTOR DPBB01A of anchorage.

Apply results to similar item PA004.

9. PAL02 TDAFW Pump AUX 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis of anchorage.

10. RL001 REACTOR COOLANT AND CB 2047-06 Anchorage could not be readily screened. Perform HCLPF analysis SUPT SYS CONSOLE of anchorage.

Apply results to similar items RL002, RL005, RL006, and RL017 thru RL026.

11. SB102A W CABINET FOR REACTOR AUX 2026-00 Anchorage could not be readily screened. Perform HCLPF analysis TRIP SWG TRAIN-A of anchorage.

12. TAP01 Condensate Storage Tank YARD 2000-00 Perform HCLPF analysis per Appendix H of NP-6041. In addition, evaluate block wall doghouse that is adjacent for interaction hazard.

13. TBN01 RWST YRD 2000-00 Perform HCLPF analysis per Appendix H of NP-6041.

14. XNG01 4.16-KV/480 V LOAD CB/CC 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis CENTER TRANSFORMER of anchorage.

XNG01 FOR LC NG001 12/2/14 Page 21 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report No. ID Description Bldg Elev Basis for Selection

15. Generic Equipment 40 above grade AB/CB 2047-06 Equipment on the Aux/Ctrl 2047.5' elevation are 40' above grade and have ISRS spectral accelerations in both horizontal directions exceeding 1.8g (with clipping) and therefore do not screen to the 2nd screening lane. HCLPF analysis for component functionality and structure (including anchorage) are required for the associated components.

Affected components include NF039A, NF039B, NF039C, NG003C, NG004C, RP053AC, RP053BC, RP053DB, RP068, RP081A, RP081B, RP289, SA036A, SA036C, SA066A, SA066B, SA075A, SB029A, SB029D, SB030A, SB032A, SB032D, SB033A, SB037, SB038, SB041, SB078, SB079, SE054A, SE054C, and SE054D.

16. Generic BLOCK WALLS AB/ CB Var. Per NP-6041-SL Table 2-4 seismic capacity cannot be screened and HCLPF analysis is required for block wall seismic capacity.

Affected components include NB001, NK025, NG003, TAP01, NK043, NN003, NN013, NK041, NN001, NK021, NN011, NK051, NK001, NK023, NK071, NK073, NK011, NK013, AB007, NK003, RP209, NG002, NK024, NK074, NK004, NK014, NN014, NN004, RP140, and RP334.

12/2/14 Page 22 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 6.4 HCLPF Calculation Process All HCLPF values were calculated using the conservative, deterministic failure margin (CDFM) criteria of NP-6041-SL [8]. CDFM analysis criteria are summarized in NP-6041-SL, Table 2-5.

For structural failure modes, the HCLPF capacity is equal to the earthquake magnitude at which the strength limit is reached. For equipment functionality, experience data or available test response spectra (TRS) are typically used to define the HCLPF capacity.

The methods of NP-6041-SL, Appendix Q were applied for functionality evaluations.

6.5 Functional Evaluations of Relays Verification of the functional capacity for equipment mounted within 40 of grade was addressed by application NP-6041-SL, Table 2-4 generic screening criteria as described above. For equipment mounted higher than 40 above grade and for in-scope relays, the methods of NP-6041-SL, Appendix Q were applied for functionality evaluations. In those cases the seismic capacity was based upon one of the following:

• Test response spectra (TRS) from plant-specific seismic qualification reports.

• Generic equipment ruggedness spectra (GERS) from EPRI report NP-5223-SL [12].

• Experience based seismic capacity per the guidelines of EPRI TR-1019200 [13].

Screening of relays within the scope of the ESEP (in accordance with EPRI 3002000704) is conducted within 14C4258-RPT-003 [5]. Cabinets requiring HCLPF evaluation for relay functionality are noted in Table 7-2 [5] under Item 17.

6.6 Tabulated ESEL HCLPF Values (Including Key Failure Modes)

Table 6-3 lists HCLPF analysis results. The failure modes analyzed are identified.

Supporting calculation documents [10.d &e] containing the detailed HCLPF calculations are also identified.

For the following discussion, an ESEP outlier is defined as an item whose HCLPF capacity is less than the RLGM. There are currently four ESEP outliers:

• NG003C (Relay Capacity)

• NG004C (Relay Capacity)

• TAP01 (Anchorage Capacity)

• TBN01 (Anchorage Capacity)

Note that for the CST (TAP01) and RWST (TBN01), the applied ground motion and HCLPF are based on the GMRS of Reference 7. The GMRS is acceptable as an alternative RLGM per EPRI 3002000704, Section 4, Option 2. The CST and RWST are founded on a slab-on-grade in the yard. The GMRS has a horizontal PGA of 0.50g.

12/2/14 Page 23 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Relay Chatter Failure Modes NG003C and NG004C are ESEP-outliers with respect to relay chatter. Refer to 14C4258-RPT-003 [5] for specific relays. Credit for operator action may resolve the relay chatter failure modes.

Tabulated HCLPF Values In general, the HCLPF values for screened-out items equals or exceeds the RLGM.

HCLPF 0.40g The HCLPF for screened-out items and failure modes Unless justified by calculations, the above HCLPF is applicable for all screened-out items and covers the relevant failure modes.

The HCLPF values for all ESEL items are tabulated in Appendix B.

Table 6-3: HCLPF Analysis Results No. ID Description Bldg Elev HCLPF2 Failure Mode Basis Related Components (g, PGA) Analyzed

1. NB001 4.16KV SWGR NB001 CB 2000-00 0.41 Equipment 14C4258- n/a (Class 1E, Train A) capacity and CAL-005 anchorage

2. NG001 480 V LOAD CENTER CB/CC 2000-00 0.41 Equipment 14C4258- NG002, NG003 NG01 capacity and CAL-005 anchorage

3. NK011 125 V BATTERY NK011 CB/CC 2016-00 2.36 Anchorage 14C4258- NK013, NK014 CAL-004

4. NK021 125 V BATTERY CB/CC 2016-00 1.33 Anchorage 14C4258- NK023, NK024 CHARGER NK021 CAL-004

5. NK025 125 V BATTERY CB 2000-00 0.85 Anchorage 14C4258- n/a CHARGER NK025 (Swing CAL-004 Battery Charger)

6. NN001 Class 1E AC DIST SWBD CB/CC 2016-00 0.71 Anchorage 14C4258- NK043, NN003, NK051, NK041, NN01 (SEP GRP 1) CAL-004 NK001, NK003, NK004, NN004

7. NN011 7.5KVA INVERTER (FED CB/CC 2016-00 0.75 Anchorage 14C4258- NN013 FROM BATT CHARGER CAL-004 NK021)

8. PA003 CUBICLE PT FOR RCP AUX 2026-00 0.62 Anchorage 14C4258- PA004 MOTOR DPBB01A CAL-004 2

HCLPFs based upon RLGM (PGA=0.40g) as the seismic margins earthquake with the exception of TAP01, TBN01, and the CST pipe house block walls, which are based upon the GMRS (PGA=0.50g).

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report No. ID Description Bldg Elev HCLPF2 Failure Mode Basis Related Components (g, PGA) Analyzed

9. PAL02 TDAFW Pump AUX 2000-00 1.75 Anchorage 14C4258- n/a CAL-004

10. RL001 REACTOR AUX CNTRL CB 2047-06 0.71 Anchorage 14C4258- RL002, RL005, RL006, RL017 thru PANEL CAL-004 RL026

11. SB102A W CABINET FOR AUX 2026-00 0.58 Anchorage 14C4258- n/a REACTOR TRIP SWG CAL-004 TRAIN-A

12. TAP01 Condensate Storage YARD 2000-00 0.30 Equipment 14C4258- n/a Tank capacity and CAL-002 anchorage

13. TBN01 RWST YRD 2000-00 0.33 Equipment 14C4258- n/a capacity and CAL-002 anchorage

14. XNG01 4.16-KV/480 V LOAD CB/CC 2000-00 0.45 Anchorage 14C4258-CENTER TRANSFORMER CAL-004 XNG01 FOR LC NG001

15. Generic Equipment >40 SE054A NIS Cabinet CB 2047-06 0.41 Equipment 14C4258- SE054C, SE054D capacity and CAL-005 anchorage SB037 7300 Series Three Bay CB 2047-06 0.41 Equipment 14C4258- SB038, SB041, SB078, SB079 Cabinets capacity and CAL-005 anchorage SA066A STATUS INDICATING CB 2047-06 0.41 Equipment 14C4258- SA066B SYS capacity and CAL-005 anchorage RP068 BOP Instrumentation CB 2047-06 0.41 Equipment 14C4258- n/a Panel capacity and CAL-005 anchorage RP053AC BOP Instrumentation CB 2047-06 0.41 Equipment 14C4258- RP053BC, RP053DB Rack capacity and CAL-005 anchorage RP081A T/C SUBCOOLING CB 2047-06 0.41 Equipment 14C4258- RP081B MONITOR CABINET capacity and CAL-005 anchorage

16. Generic Block Wall Seismic Interaction CTRL 2000 All block walls on CTRL CB 2000-00 1.17 Seismic interaction 14C4258- NB001, NK025, NG003, RP140, 2000 elev CAL-003 and RP334.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report No. ID Description Bldg Elev HCLPF2 Failure Mode Basis Related Components (g, PGA) Analyzed CTRL 2016 All block walls on CTRL CB 2016-00 0.87 Seismic interaction 14C4258- NK043, NN003, NN004, NN013, 2016 elev CAL-003 NN014, NK041, NN001, NK021, NN011, NK051, NK001, NK023, NK071, NK073, NK074 NK011, NK013, NK014, AB007, NK003, NK004, NK024 AUX 2000 2000 elev wall on AUX 2000-00 0.67 Seismic interaction 14C4258- RP209 column line AF north of CAL-003 Stair A-2 CST House CST Pipe house YARD 2000-00 0.40 Seismic interaction 14C4258- TAP01 masonry walls CAL-003

17. Generic Cabinets containing essential relays NG003C MCC NG03C BUS CB 2047-06 0.32 Functional 14C4258- NG004C capacity and host CAL-005 component capacity NG002B MCC NG02B BUS CB 2026-00 0.40 Functional 14C4258- NG001A capacity and host CAL-005 component capacity FC0219 LOCAL CONTROL PANEL AB 2000-00 0.41 Functional 14C4258- n/a FOR TD AFW PUMP capacity and host CAL-005 component capacity 7.0 Inaccessible Items 7.1 Identification of ESEL items inaccessible for walkdowns Sufficient access was provided for all ESEL items and no additional walkdowns are planned.

8.0 ESEP Conclusions and Results 8.1 Supporting Information Callaway has performed the ESEP as an interim action in response to the NRCs 50.54(f) letter [1]. It was performed using the methodologies in the NRC endorsed guidance in EPRI 3002000704 [2].

The ESEP provides an important demonstration of seismic margin and expedites plant safety enhancements through evaluations and potential near-term 12/2/14 Page 26 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report modifications of plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events.

The ESEP is part of the overall Callaway response to the NRCs 50.54(f) letter [1].

On March 12, 2014, NEI submitted to the NRC results of a study [14] of seismic core damage risk estimates based on updated seismic hazard information as it applies to operating nuclear reactors in the Central and Eastern United States (CEUS). The study concluded that "site-specific seismic hazards show that there

[...] has not been an overall increase in seismic risk for the fleet of U.S. plants" based on the re-evaluated seismic hazards. As such, the "current seismic design of operating reactors continues to provide a safety margin to withstand potential earthquakes exceeding the seismic design basis."

The NRCs May 9, 2014 NTTF 2.1 Screening and Prioritization letter [15]

concluded that the fleetwide seismic risk estimates are consistent with the approach and results used in the Gl-199 safety/risk assessment. The letter also stated that, As a result, the staff has confirmed that the conclusions reached in Gl-199 safety/risk assessment remain valid and that the plants can continue to operate while additional evaluations are conducted.

An assessment of the change in seismic risk for Callaway was included in the fleet risk evaluation submitted in the March 12, 2014 NEI letter [14] therefore, the conclusions in the NRCs May 9 letter [15] also apply to Callaway.

In addition, the March 12, 2014 NEI letter [14] provided an attached "Perspectives on the Seismic Capacity of Operating Plants," which: (1) assessed a number of qualitative reasons why the design of SSCs inherently contain margin beyond their design level, (2) discussed industrial seismic experience databases of performance of industry facility components similar to nuclear SSCs, and (3) discussed earthquake experience at operating plants.

The fleet of currently operating nuclear power plants was designed using conservative practices, such that the plants have significant margin to withstand large ground motions safely. This has been borne out for those plants that have actually experienced significant earthquakes. The seismic design process has inherent (and intentional) conservatisms which result in significant seismic margins within SSCs. These conservatisms are reflected in several key aspects of the seismic design process, including:

• Safety factors applied in design calculations

• Damping values used in dynamic analysis of SSCs

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

• Broadening criteria for in-structure response spectra

• Response spectra enveloping criteria typically used in SSC analysis and testing applications 12/2/14 Page 27 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report

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

• Bounding requirements in codes and standards

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

• Bounding testing requirements, and

• Ductile behavior of the primary materials (that is, not crediting the additional capacity of materials such as steel and reinforced concrete beyond the essentially elastic range, etc.).

These design practices combine to result in margins such that the SSCs will continue to fulfill their functions at ground motions well above the SSE.

The intent of the ESEP is to perform an interim action in response to the NRCs 50.54(f) letter [1] to demonstrate seismic margin through a review of a subset of the plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events. In order to complete the ESEP in an expedited amount of time, the RLGM used for the ESEP evaluation is a scaled version of the plants SSE rather than the actual GMRS. To more fully characterize the risk impacts of the seismic ground motion represented by the GMRS on a plant specific basis, a more detailed seismic risk assessment (SPRA or risk-based SMA) is to be performed in accordance with EPRI 1025287 [16]. As identified in the Callaway Seismic Hazard and GMRS submittal [7], Callaway screens in for a risk evaluation. The complete risk evaluation will more completely characterize the probabilistic seismic ground motion input into the plant, the plant response to that probabilistic seismic ground motion input, and the resulting plant risk characterization. Callaway will complete that evaluation in accordance with the schedule identified in NEIs letter dated April 9, 2013 [17]

and endorsed by the NRC in their May 7, 2013 letter [2].

8.2 Indication of Planned Modifications This report presents the seismic evaluation results for the ESEP as applied to Callaway Energy Center. A primary goal of the ESEP is to demonstrate that HCLPF seismic capacities of ESEL items exceed the RLGM seismic demand. For Callaway, the RLGM is equal to the SSE scaled-up by a 2.0 factor. The RLGM has a PGA of 0.40g at grade. Exceptions to this include the CST (TAP01) and RWST (TBN01),

which apply the GMRS (PGA of 0.50g) for HCLPF evaluation [10b].

Insights from the ESEP identified the following items (Table 8-1) where the HCLPF is below the RLGM and plant modifications will be made in accordance with EPRI 3002000704 [2] to enhance the seismic capacity of the plant.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Table 8-1: Equipment with HCLPF Capacities below the RLGM Requiring Modification 3

HCLPF Capacity ID Description (g, PGA) Failure Mode NG003C MCC NG03C BUS 0.32 Relay functionality NG004C MCC NG04C BUS 0.32 Relay functionality TAP01 Condensate Storage Tank 0.30 Anchorage TBN01 RWST 0.33 Anchorage 8.3 Modification Implementation Schedule Plant modifications will be performed in accordance with the schedule identified in NEI letter dated April 9, 2013 [15], which states that plant modifications not requiring a planned refueling outage will be completed by December 2016 and modifications requiring a refueling outage will be completed within two planned refueling outages after December 31, 2014.

Section 8.4 contains the regulatory commitment dates to complete planned plant modifications as a result of ESEP. Referencing Section 8.4, Actions 1 and 2 do not require a refueling outage and will be completed by December 31, 2016.

Action 3 requires a refueling outage and will be completed by the end of RF21, Spring 2016, as required to support FLEX implementation. Action 4 requires a refueling outage and will be completed no later than the end of the second refueling outage after 12/31/14, currently RF22 scheduled for Fall 2017.

8.4 Summary of Regulatory Commitments The following actions will be performed as a result of the ESEP.

Completion Action # Equipment ID Equipment Description Action Description Date 1 Modify FLEX Support Guidelines December 31, to include operator actions to 2016 reset relays with HCLPF values NG003C MCC NG03C BUS less than the RLGM.

2 Modify FLEX Support Guidelines December 31, to include operator actions to 2016 reset relays with HCLPF values NG004C MCC NG04C BUS less than the RLGM.

3 Install a new hardened End of RF21, TAP01 Condensate Storage Tank Condensate Storage Tank. Spring 2016 3

All HCLPFs based upon RLGM (PGA=0.40g) as the seismic margins earthquake with the exception of TAP01, TBN01, and the CST pipe house block walls, which are based upon the GMRS (PGA=0.50g).

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Completion Action # Equipment ID Equipment Description Action Description Date 4 Three step response in order of No later than priority: 1) Re-evaluate FLEX the end of the response strategies to eliminate second the need for the tank. 2) Re- refueling analyze the tank with the more outage after realistic median-centered 12/31/14, structural response based on the currently RF22 new GMRS which will be scheduled for generated once the Seismic PRA Fall 2017 starts, 3) Upgrade/replace the TBN01 RWST tank.

12/2/14 Page 30 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 9.0 References

1. Letter from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, March 12, 2012.

ADAMS Accession No. ML12053A340.

2. Letter from E. J. Leeds, USNRC, to J. E. Pollock, NEI, Electric Power Research Institute Final Draft Report XXXXXX, Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic, as an Acceptable Alternative to the March 12, 2012, Information Request for Seismic Reevaluations, May 7, 2013.

3002000704; ADAMS Accession No. ML13106A331.

3. Callaway Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049.

a. Callaway Letter ULNRC-05962, Docket No. 50-483: Callaway Plant Unit 1 Union Electric Co. Facility Operating License NPF-30 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), February 18, 2013, (ADAMS Accession Number ML13063A459).

b. Callaway Letter ULNRC-06024, Docket No. 50-483: Callaway Plant Unit 1 Union Electric Co. Facility Operating License NPF-30 First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), August 29, 2013, (ADAMS Accession Number ML13242A239).

c. Callaway Letter ULNRC-06087, Docket No. 50-483: Callaway Plant Unit 1 Union Electric Co. Facility Operating License NPF-30 Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), February 26, 2014, (ADAMS Accession Number ML14057A770).

d. Callaway Letter ULNRC-06135, Docket No. 50-483: Callaway Plant Unit 1 Union Electric Co. Facility Operating License NPF-30 Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-12/2/14 Page 31 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Design-Basis External Events (Order Number EA-12-049), August 28, 2014, (ADAMS Accession Number ML13063A459).

4. SCP-14-82, Transmittal of Updated Callaway ESEL for ESEP Report, December 2014.

5. S&A report 14C4258-RPT-003 Rev. 0, Callaway ESEL Relay Assessment, December 2014.

6. CEC FSAR, Rev. OL-20, Callaway Energy Center Final Safety Analysis Report (FSAR). December 2013.

7. Callaway Seismic Hazard and GMRS submittal, dated March 31, 2014.

8. Electric Power Research Institute Report, NP-6041-SLR1, Revision 1, A Methodology for Assessment of Nuclear Power Plant Seismic Margin, 1991.

9. Electric Power Research Institute Report, TR-103959, Methodology for Developing Seismic Fragilities, 1994.

10. S&A Calculations:

a) 14C4258-CAL-001 Rev. 0, Generation of Scaled In-Structure Response Spectra for Callaway, December 2014.

b) 14C4258-CAL-002 Rev. 0, Seismic Capacity of CST (TAP01) and RWST (TBN01), December 2014.

c) 14C4258-CAL-003 Rev. 0, HCLPF Analyses for Block Walls, December 2014.

d) 14C4258-CAL-004 Rev. 0, HCLPF Seismic Capacity Evaluations for Selected Equipment, December 2014.

e) 14C4258-CAL-005 Rev. 0, HCLPF Analysis of Components Based on Seismic Test Data, December 2014.

f) 14C4258-RPT-002, Revision 1, Seismic Evaluation of Equipment at CEC for the Expedited Seismic Evaluation Process, December 2014.

11. ULNRC-3232, Callaway Plant Individual Plant Examination of External Events (IPEEE), June 1995.

12. Electric Power Research Institute Report, NP-5223-SL, Revision 1, Generic Seismic Ruggedness of Power Plant Equipment, 1991.

13. Electric Power Research Institute Technical Report, TR-1019200, Seismic Fragility Applications Guide Update, 2009.

14. Letter from A. R. Pietrangelo, NEI, to D. L Skeen, USNRC, Seismic Risk Estimates for Plants in the Central and Eastern United States, March 12, 2014. ADAMS Accession No. ML14083A584.

15. NRC (E Leeds) Letter to All Power Reactor Licensees et al., Screening and Prioritization Results Regarding Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(F) Regarding Seismic Hazard Re-Evaluations for 12/2/14 Page 32 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Recommendation 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-Ichi Accident, May 9, 2014.

16. Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic. EPRI, Palo Alto, CA: February 2013. 1025287.

17. Letter from A. R. Pietrangelo, NEI, to D. L. Skeen, USNRC, Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations, April 9, 2013.

ADAMS Accession No. ML13107B386.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Attachment A Callaway ESEL 12/2/14 Page 34 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State Mechanical ESEL Items 1 TAP01 Condensate Storage CST provides AFW suction for Tank Operable Operable the first 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> 2 PAL02 TDAFW Pump Not TDAFW provides pump power Operating Operating to move AFW to SG 3 ALHV0034 MOV MOV required to isolate flow Open Closed path 4 ALHV0035 MOV MOV required to isolate flow Open Closed path 5 ALPI0029 Suction Pressure Indicator 6 ALFE0049 TDAFWP Miniflow Flow Element 7 ALFI0049 TDAFWP Miniflow Flow Indicator 8 APLV0002 Level Control Valve Open Closed Fail closed valve 9 ALPI0020 TDAFW Pump Discharge Pressure Indicator 10 ALHV0012 Air Operated Valve Valve may be operated to Open Open throttle AFW flow to SG 11 ALFE0004 Flow Element AFW flow related hardware 12 ALFT0004 Flow Transmitter AFW flow related hardware 13 ALFT0011 Flow Transmitter AFW flow related hardware 14 AEFV0041 Feedwater Isolation Valve Open Closed Fail closed valve 15 ALHV0010 Air Operated Valve Valve may be operated to Open Open throttle AFW flow to SG 16 ALFE0003 Flow Element 17 ALFT0003 Flow Transmitter AFW flow related hardware 18 ALFT0009 Flow Transmitter AFW flow related hardware 19 AEFV0040 Feedwater Isolation Valve Open Closed Fail closed valve 20 ALHV0008 Air Operated Valve Valve may be operated to Open Open throttle AFW flow to SG 21 ALFE0002 Flow Element AFW flow related hardware 22 ALFT0002 Flow Transmitter AFW flow related hardware 23 ALFT0007 Flow Transmitter AFW flow related hardware 12/2/14 Page 35 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 24 AEFV0039 Feedwater Isolation Valve Open Closed Fail closed valve 25 ALHV0006 Air Operated Valve Valve may be operated to Open Open throttle AFW flow to SG 26 ALFE0001 Flow Element AFW flow related hardware 27 ALFT0001 Flow Transmitter AFW flow related hardware 28 AEFV0042 Feedwater Isolation Valve Open Closed Fail closed valve 29 ABHV0005 Air Operated Valve TDAFW controls and steam Closed Fail Open flow controls. Fails open.

30 ABHV0048 Air Operated Valve Fail TDAFW controls and steam Open Closed flow controls. Fails closed.

31 ABHV0006 Air Operated Valve TDAFW controls and steam Closed Fail Open flow controls. Fails open.

32 ABHV0049 Air Operated Valve Fail TDAFW controls and steam Open Closed flow controls. Fails closed.

33 FCPI0311 Pressure Indicator 34 FCLT0010 Level Indicator Needed to prevent water intrusion in TDAFWP 35 FCFV0310 Level Control Valve Needed to prevent water Fail intrusion in TDAFWP. Valve Open Closed fails closed.

36 FCHV0312 Trip and Throttle Valve TDAFW controls and steam flow controls. Operation of this manual valve should be accounted for in operating Closed Operating procedures.

37 Speed Speed Governor TDAFW controls and steam Governor Standby Operating flow controls.

38 FCFV0313 Speed Governor Valve TDAFW controls and steam Open Operating flow controls.

39 KFC02 AFW Pump Turbine Not TDAFW controls and steam Operating Operating flow controls.

40 BBPV8702A RHR TO RCS Closed Open 41 EMHV8803B MOTOR-OPERATED Primary flow path, can be VALVE EMHV8803B Closed Open operated manually 42 EMHV8801B MOTOR-OPERATED Primary flow path, can be VALVE EMHV8801B Closed Open operated manually 12/2/14 Page 36 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 43 EMFE0924 ECCS FLOW TO RCS COLD-LEG 1 44 EMFE0925 ECCS FLOW TO RCS COLD-LEG 2 45 EMFE0926 ECCS FLOW TO RCS COLD-LEG 3 46 EMFE0927 ECCS FLOW TO RCS COLD-LEG 4 47 TBN01 RWST Secondary source for core makeup after BAT exhausted 48 BNLT0930 RWST Level Transmitter Monitor RWST level 49 EJHCV0606 RHR Heat Exchanger A Outlet Isolation Valve Fail Open Closed Can be operated manually 50 TBG03A Boric Acid Tank 51 BGLT0102 BORIC ACID TANK A LEV Monitor BAT level 52 BGLI0102 BORIC ACID TANK A LEV Local level indicator 53 EJFCV0610 RHR Pump A miniflow Valve Open Closed 54 EJFCV0610 RHR Pump A miniflow Valve Open Closed 55 EJFCV0610 RHR Pump A miniflow Valve Open Closed Electrical ESEL Items 56 NB001 4.16KV SWGR NB001 This component is powered by (Class 1E, Train A) the FLEX DG in Phase 3 as stated in Sec. 8 of the Callaway N/A N/A Plant FLEX Integrated Plan 57 NB00101 4.16 kV FDR BKR FOR This component is powered by RHRP-A DPEJ01A the FLEX DG in Phase 3 as (Residual Heat stated in Sec. 8 of the Callaway Removal Pump A)

N/A N/A Plant FLEX Integrated Plan 58 NB00107 4.16 kV FDR BKR FOR This component is powered by CCWP-A DPEG01A the FLEX DG in Phase 3 as (Component Cooling stated in Sec. 8 of the Callaway Water Pump A)

N/A N/A Plant FLEX Integrated Plan 12/2/14 Page 37 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 59 NB00109 4.16 kV FLEX GEN (Phase 3) TIE-IN POINT This breaker position is the tie-(BKR) FOR TRAIN A in point for the Phase 3 FLEX N/A N/A diesel generator 60 NB00113 4.16 kV FDR BKR FOR This component is powered by XFMR XNG01 (4160 V the FLEX DG in Phase 3 as to 480 V for LC stated in Sec. 8 of the Callaway NG001)

N/A N/A Plant FLEX Integrated Plan 61 XNG01 4.16-KV/480 V LOAD This component is powered by CENTER the FLEX DG in Phase 3 as TRANSFORMER stated in Sec. 8 of the Callaway XNG01 FOR LC NG001 N/A N/A Plant FLEX Integrated Plan 62 NG001 480 V LOAD CENTER This component is powered by NG01 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 63 NG00101 MAIN BKR FOR LC This component is powered by NG01 the FLEX DG in Phase 3 as stated in Sec. 8 of the Callaway N/A N/A Plant FLEX Integrated Plan 64 NG00103 FDR BKR FOR 125 V This component is powered by VITAL BATTERY the FLEX DG, first Phase 2, CHARGER NK021 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 65 NG00112 FLEX 500 kW TIE IN This component is powered by BRK (Phase 2 the FLEX DG in Phase 2 as connection point) stated in Sec. 8 of the Callaway N/A N/A Plant FLEX Integrated Plan 66 NG00116 TIE BKR (CONNECTS This component is powered by NG01 AND NG03) the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 67 NG003 480 V LOAD CENTER This component is powered by NG03 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 12/2/14 Page 38 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 68 NG00303 FDR BKR FOR 125 V This component is powered by VITAL BATTERY the FLEX DG, first Phase 2, CHARGER NK023 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 69 NK021 125 V BATTERY This component is powered by CHARGER NK021 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 70 NK071 TRANSFER SWITCH This component is powered by BUS NK01 BATTERY the FLEX DG, first Phase 2, CHARGER NK21/NK25 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 71 NK001 125 VDC BUS This component is powered SWITCHBOARD NK001 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 72 NK00102 FDR BKR FROM BATT This component is powered by CHGR NK021 TO the FLEX DG, first Phase 2, NK001 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 73 NK00104 MAIN BREAKER FOR This component is powered CNTRL AND DIST PNL during ALL phases of the FLEX NK041 (PART OF strategy as stated in Sec. 8 of SWBD NK001) the Callaway Plant FLEX N/A N/A Integrated Plan 74 NK00105 MAIN BREAKER FOR This component is powered CNTRL AND DIST PNL during ALL phases of the FLEX NK051 (PART OF strategy as stated in Sec. 8 of SWBD NK001) the Callaway Plant FLEX N/A N/A Integrated Plan 75 NK011 125 V BATTERY NK011 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 39 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 76 NK00101 ISOLATION BKR FOR This component is powered BATTERY NK011 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 77 NK00111 FDR BKR FOR This component is powered INVERTER NN011 during ALL phases of the FLEX (PART OF SWBD strategy as stated in Sec. 8 of NK001) the Callaway Plant FLEX N/A N/A Integrated Plan 78 NN011 7.5KVA INVERTER This component is powered (FED FROM BATT during ALL phases of the FLEX CHARGER NK021) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 79 NN001 Class 1E AC DIST This component is powered SWBD NN01 (SEP GRP during ALL phases of the FLEX

1) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 80 SA066A STATUS INDICATING This component is powered SYS during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 81 SENY0060A NEUTRON FLUX This component is powered MONITORING SYSTEM during ALL phases of the FLEX DETECTOR AMPLIFIER strategy as stated in Sec. 8 of SENY 60A the Callaway Plant FLEX N/A N/A Integrated Plan 82 SENY0060B NEUTRON FLUX This component is powered MONITORING SYSTEM during ALL phases of the FLEX DETECTOR AMPLIFIER strategy as stated in Sec. 8 of SENY 60B the Callaway Plant FLEX N/A N/A Integrated Plan 83 SB038 W PROCESS ANALOG This component is powered PROTECTION SET CAB- during ALL phases of the FLEX 01 strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 40 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 84 SE054A W NUC INSTM NIS 1 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 85 RP053AC BOP This component is powered INSTRUMENTATION during ALL phases of the FLEX RACK (TERMINATION strategy as stated in Sec. 8 of AREA) the Callaway Plant FLEX N/A N/A Integrated Plan 86 SB078 RPV LEVEL INSTR SYS This component is powered (RVLIS) PROC PROT during ALL phases of the FLEX SYS CABINET strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 87 RP081A T/C SUBCOOLING This component is powered MONITOR CABINET during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 88 NK041 CNTRL & INSTR DIST This component is powered SWBD NK041 (CLASS during ALL phases of the FLEX 1E 125 VDC) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 89 NE107 DIESEL GEN PNL This component is powered NE107 & FIELD during ALL phases of the FLEX FLASHING strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 90 RL005 TURBINE GENERATOR This component is powered AND FW CONSOLE during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 91 RL006 TURBINE GENERATOR This component is powered AND FW CONSOLE during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 41 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 92 RP315 DC DIST PNL RP315 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 93 RL023 TURBINE GENERATOR This component is powered AND FW MCB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 94 RL024 TURBINE GENERATOR This component is powered AND FW MCB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 95 RL017 ESF MCB This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 96 RL018 ESF MCB This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 97 RL019 ESF MCB This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 98 RL020 ESF MCB This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 99 RL001 REACTOR COOLANT This component is powered AND SUPT SYS during ALL phases of the FLEX CONSOLE strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 42 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 100 RL002 REACTOR COOLANT This component is powered AND SUPT SYS during ALL phases of the FLEX CONSOLE strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 101 RL025 TURBINE GENERATOR This component is powered AND FW MCB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 102 RL026 TURBINE GENERATOR This component is powered AND FW MCB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 103 RP317 FUSED 125 VDC DIST This component is powered PNL RP317 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 104 NK051 CNTRL & INSTR DIST This component is powered SWBD NK051 (CLASS during ALL phases of the FLEX 1E 125 VDC) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 105 BBPCV0455A BBPCV0455A PORV This component is powered SOLENOID FAILS TO during ALL phases of the FLEX OPEN ON DEMAND strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 106 RL021 REACTOR AUX CNTRL This component is powered PANEL during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 107 RL022 REACTOR AUX CNTRL This component is powered PANEL during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 43 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 108 KJ0121 DIESEL GAUGE AND This component is powered CONTROL PANEL during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 109 RP209 B AUXILIARY RELAY This component is powered RACK during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 110 RP289 DC DIST PNL RP289 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 111 RP068 MISC BOP This component is powered INSTRUMENT RACK during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 112 RP330 AUX RELAY RACK This component is powered RP330 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 113 RP332 B AUXILIARY RELAY This component is powered RACK during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 114 NK051A EM'CY LIGHTING DIST This component is powered SWBD NK051A during ALL phases of the FLEX (SUBPNL OF NK051) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 115 NK023 125 V BATTERY This component is powered by CHARGER NK023 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 12/2/14 Page 44 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 116 NK073 TRANSFER SWITCH This component is powered by BUS NK03 BATTERY the FLEX DG, first Phase 2, CHARGER NK23/NK25 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 117 NK003 125 VDC BUS This component is powered SWITCHBOARD NK003 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 118 NK00302 FDR BKR FROM BATT This component is powered by CHGR NK023 TO the FLEX DG, first Phase 2, NK003 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 119 NK00304 MAIN BREAKER FOR This component is powered CNTRL AND DIST PNL during ALL phases of the FLEX NK043 (PART OF strategy as stated in Sec. 8 of SWBD NK003) the Callaway Plant FLEX N/A N/A Integrated Plan 120 NK013 125 V BATTERY NK013 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 121 NK00301 ISOLATION BKR FOR This component is powered BATTERY NK013 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 122 NK00311 FDR BKR FOR This component is powered INVERTER NN013 during ALL phases of the FLEX (PART OF SWBD strategy as stated in Sec. 8 of NK003) the Callaway Plant FLEX N/A N/A Integrated Plan 123 NN013 7.5KVA INVERTER This component is powered (FED FROM BATT during ALL phases of the FLEX CHARGER NK023) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 45 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 124 NN003 Class 1E AC DIST This component is powered SWBD NN03 (SEP GRP during ALL phases of the FLEX

3) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 125 RP053DB BOP INSTR RACK This component is powered RP053DB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 126 SB037 W PROCESS ANALOG This component is powered PROTECTION SET CAB- during ALL phases of the FLEX 03 strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 127 SE054C W NUC INSTM NIS 3 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 128 NK043 CNTRL & INSTR DIST This component is powered SWBD NK043 (CLASS during ALL phases of the FLEX 1E 125 VDC) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 129 AB007 Aux Relay Rack This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 130 NG00109 FDR BKR FOR 125 V SWING BATTERY This component provides CHARGER NK025 power to NK025 and, in turn, N/A N/A Separation Group 1.

131 NK025 125 V BATTERY CHARGER NK025 The A-Train swing charger will (Swing Battery be used to power Separation Charger)

N/A N/A Group 1.

132 NG002 480 V LOAD CENTER This component is powered by NG02 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 12/2/14 Page 46 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 133 NG00212 FLEX 500 kW TIE IN This component is powered by BKR from FD201 the FLEX DG, first Phase 2, (Phase 2 connection then in Phase 3, as stated in point) Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 134 NG00203 FDR BKR FOR 125 V This component is powered by VITAL BATTERY the FLEX DG, first Phase 2, CHARGER NK024 then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 135 NK024 125 V BATTERY This component is powered by CHARGER NK024 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 136 NK074 TRANSFER SWITCH This component is powered by BUS NK04 BATTERY the FLEX DG, first Phase 2, CHARGER NK24/NK26 then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 137 NK004 125 VDC BUS This component is powered SWITCHBOARD NK004 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 138 NK00402 FDR BKR FROM BATT This component is powered by CHGR NK024 TO the FLEX DG, first Phase 2, NK004 then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 139 NK014 125 V BATTERY NK014 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 140 NK00401 ISOLATION BKR FOR This component is powered BATTERY NK014 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 12/2/14 Page 47 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 141 NK00411 FDR BKR FOR This component is powered INVERTER NN011 during ALL phases of the FLEX (PART OF SWBD strategy as stated in Sec. 8 of NK004) the Callaway Integrated FLEX N/A N/A Plan 142 NN014 7.5KVA INVERTER This component is powered (FED FROM BATT during ALL phases of the FLEX CHARGER NK024) strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 143 NN004 Class 1E AC DIST This component is powered SWBD NN04 (SEP GRP during ALL phases of the FLEX

4) strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 144 RP147B BOP Instrumentation This component is powered Rack RP147B during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 145 SENY0061A NEUTRON FLUX This component is powered MONITORING SYSTEM during ALL phases of the FLEX DETECTOR AMPLIFIER strategy as stated in Sec. 8 of SENY 61A the Callaway Integrated FLEX N/A N/A Plan 146 SENY0061B NEUTRON FLUX This component is powered MONITORING SYSTEM during ALL phases of the FLEX DETECTOR AMPLIFIER strategy as stated in Sec. 8 of SENY 61B the Callaway Integrated FLEX N/A N/A Plan 147 SE054D W NUC INSTM NIS 4 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 148 SB041 W PROCESS ANALOG This component is powered PROTECTION SET CAB- during ALL phases of the FLEX 04 strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 12/2/14 Page 48 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 149 RP053BC BOP Instrumentation This component is powered Rack RP053BC during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 150 SB079 RVLIS Process Cabinet This component is powered SB079 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 151 RP081B Subcooling Monitor This component is powered Cabinet during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 152 SB148B W PROCESS This component is powered PROTECTION (Fire during ALL phases of the FLEX Isolation) strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 153 SA066B STATUS INDICATING This component is powered SYS during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 154 RP140 PANEL RP140 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 12/2/14 Page 49 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Attachment B ESEP HCLPF Values and Failure Modes Tabulation HCLPF values are listed in Table B-1. These notes are applicable:

1. The listed HCLPF value is for comparison to the horizontal PGA at the bedrock surface.

2. Items covered by the NP-6041-SL rule of the box (ROB) are identified in Table A-2 [9].

In each case, the HCLPF value for the parent item applies.

3. For the CST and RWST only (TAP01 and TBN01, respectively), the applied ground motion was based on the GMRS (PGA = 0.50g).

4. Where an anchorage HCLPF is performed but the component per se is screened, the equipment capacity is assigned based upon the 1.2g peak spectral acceleration coinciding with the 2nd screening lane of NP-6041-SL. Since the Callaway RLGM has a peak spectral acceleration of 1.2g in the building frequency range of interest (see Section 6.2.1) and PGA of 0.40g [Ref. 7], the equipment capacity is assigned as 0.40g PGA.

5. As a result of the relay chatter evaluation, additional items were added to the ESEL list for evaluation.

12/2/14 Page 50 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Table B-1: ESEL HCLPF Values ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number Condensate Storage Tank capacity evaluated in 14C4258-CAL-002. Block wall 1 TAP01 YARD 2000-00 0.3 Anchorage Tank evaluated per 14C4258-CAL-003.

Component per se screened. Anchorage evaluated per 2 PAL02 TDAFW Pump AUX 2000-00 0.4 Equipment Capacity 14C4258-CAL-004.

3 ALHV0034 MOV AUX 1988-00 >RLGM Screened SRT disposition 4 ALHV0035 MOV AUX 1988-00 >RLGM Screened SRT disposition Suction Pressure 5 ALPI0029 AUX 2000-00 >RLGM Screened SRT disposition Indicator TDAFWP Miniflow Flow 6 ALFE0049 AUX 2000-00 >RLGM Screened SRT disposition Element TDAFWP Miniflow Flow 7 ALFI0049 AUX 2000-00 >RLGM Screened SRT disposition Indicator 8 APLV0002 Level Control Valve YARD 2000-00 >RLGM Screened SRT disposition TDAFW Pump Discharge 9 ALPI0020 AUX 2000-00 >RLGM Screened SRT disposition Pressure Indicator 10 ALHV0012 Air Operated Valve AUX 2004-07 >RLGM Screened SRT disposition 11 ALFE0004 Flow Element AUX 2000-00 >RLGM Screened SRT disposition 12 ALFT0004 Flow Transmitter AUX 2016-01 >RLGM Screened SRT disposition 13 ALFT0011 Flow Transmitter AUX 2000-00 >RLGM Screened SRT disposition Feedwater Isolation 14 AEFV0041 AUX 2028-00 >RLGM Screened SRT disposition Valve 15 ALHV0010 Air Operated Valve AUX 2002-09 >RLGM Screened SRT disposition 16 ALFE0003 Flow Element AUX 2000-00 >RLGM Screened SRT disposition 17 ALFT0003 Flow Transmitter AUX 2016-00 >RLGM Screened SRT disposition 18 ALFT0009 Flow Transmitter AUX 2000-00 >RLGM Screened SRT disposition Feedwater Isolation 19 AEFV0040 AUX 2027-10 >RLGM Screened SRT disposition Valve 20 ALHV0008 Air Operated Valve AUX 2004-00 >RLGM Screened SRT disposition 12/2/14 Page 51 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number 21 ALFE0002 Flow Element AUX 2000-00 >RLGM Screened SRT disposition 22 ALFT0002 Flow Transmitter AUX 2016-00 >RLGM Screened SRT disposition 23 ALFT0007 Flow Transmitter AUX 2000-00 >RLGM Screened SRT disposition Feedwater Isolation 24 AEFV0039 AUX 2028-00 >RLGM Screened SRT disposition Valve 25 ALHV0006 Air Operated Valve AUX 2001-06 >RLGM Screened SRT disposition 26 ALFE0001 Flow Element AUX 2000-00 >RLGM Screened SRT disposition 27 ALFT0001 Flow Transmitter AUX 2015-00 >RLGM Screened SRT disposition Feedwater Isolation 28 AEFV0042 AUX 2027-10 >RLGM Screened SRT disposition Valve 29 ABHV0005 Air Operated Valve AUX 2027-10 >RLGM Screened SRT disposition 30 ABHV0048 Air Operated Valve AUX 2027-10 >RLGM Screened SRT disposition 31 ABHV0006 Air Operated Valve AUX 2027-10 >RLGM Screened SRT disposition 32 ABHV0049 Air Operated Valve AUX 2027-10 >RLGM Screened SRT disposition 33 FCPI0311 Pressure Indicator AUX 2000-00 >RLGM Screened SRT disposition 34 FCLT0010 Level Indicator AUX 2000-00 >RLGM Screened SRT disposition 35 FCFV0310 Level Control Valve AUX 1988-00 >RLGM Screened SRT disposition 36 FCHV0312 Trip and Throttle Valve AUX 2000-00 >RLGM Screened SRT disposition Item is ROB to PAL02. Component per se screened. Anchorage 37 Speed Governor Speed Governor AUX 2000-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

Item is ROB to PAL02. Component per se screened. Anchorage 38 FCFV0313 Speed Governor Valve AUX 2000-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

Item is ROB to PAL02. Component per se screened. Anchorage 39 KFC02 AFW Pump Turbine AUX 2000-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

40 BBPV8702A RHR TO RCS RB 2007-09 >RLGM Screened SRT disposition MOTOR-OPERATED 41 EMHV8803B AUX 1975-08 >RLGM Screened SRT disposition VALVE EMHV8803B MOTOR-OPERATED 42 EMHV8801B AUX 2002-00 >RLGM Screened SRT disposition VALVE EMHV8801B 12/2/14 Page 52 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number ECCS FLOW TO RCS 43 EMFE0924 RB 1998-06 >RLGM Screened SRT disposition COLD-LEG 1 ECCS FLOW TO RCS 44 EMFE0925 RB 1998-06 >RLGM Screened SRT disposition COLD-LEG 2 ECCS FLOW TO RCS 45 EMFE0926 RB 1998-06 >RLGM Screened SRT disposition COLD-LEG 3 ECCS FLOW TO RCS 46 EMFE0927 RB 1998-06 >RLGM Screened SRT disposition COLD-LEG 4 47 TBN01 RWST YRD 2000-00 0.33 Anchorage Tank capacity evaluated in 14C4258-CAL-002.

48 BNLT0930 RWST Level Transmitter YRD 1993-00 >RLGM Screened SRT disposition RHR Heat Exchanger A 49 EJHCV0606 AUX 2001-06 >RLGM Screened SRT disposition Outlet Isolation Valve 50 TBG03A Boric Acid Tank AUX 1974-00 >RLGM Screened SRT disposition 51 BGLT0102 BORIC ACID TANK A LEV AUX 1968-01 >RLGM Screened SRT disposition Item is ROB to RL001. Component per se screened. Anchorage 52 BGLI0102 BORIC ACID TANK A LEV CB 2047-06 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

RHR Pump A miniflow 53 EJFCV0610 AUX 1968-01 >RLGM Screened SRT disposition Valve Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 4.16KV SWGR NB001 56 NB001 CB 2000-00 0.41 Anchorage evaluated per 14C4258-CAL-005 Block wall evaluated per (Class 1E, Train A) 14C4258-CAL-003.

4.16 kV FDR BKR FOR Item is ROB to NB001. Equipment capacity evaluated in RHRP-A DPEJ01A 57 NB00101 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-(Residual Heat Removal 005. Block wall evaluated per 14C4258-CAL-003.

Pump A) 4.16 kV FDR BKR FOR Item is ROB to NB001. Equipment capacity evaluated in CCWP-A DPEG01A 58 NB00107 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-(Component Cooling 004. Block wall evaluated per 14C4258-CAL-003.

Water Pump A) 4.16 kV FLEX GEN Item is ROB to NB001. Equipment capacity evaluated in 59 NB00109 (Phase 3) TIE-IN POINT CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-(BKR) FOR TRAIN A 004. Block wall evaluated per 14C4258-CAL-003.

4.16 kV FDR BKR FOR Item is ROB to NB001. Equipment capacity evaluated in 60 NB00113 XFMR XNG01 (4160 V to CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-480 V for LC NG001) 004. Block wall evaluated per 14C4258-CAL-003.

12/2/14 Page 53 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number 4.16-KV/480 V LOAD Component per se screened. Anchorage evaluated per 61 XNG01 CENTER TRANSFORMER CB/CC 2000-00 0.4 Equipment Capacity 14C4258-CAL-004.

XNG01 FOR LC NG001 480 V LOAD CENTER Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 62 NG001 CB/CC 2000-00 0.41 Anchorage NG01 evaluated per 14C4258-CAL-005.

Item is ROB to NG001. Equipment capacity evaluated in 63 NG00101 MAIN BKR FOR LC NG01 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-004.

FDR BKR FOR 125 V Item is ROB to NG001. Equipment capacity evaluated in 64 NG00103 VITAL BATTERY CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHARGER NK021 004.

FLEX 350 kW TIE IN BRK Item is ROB to NG001. Equipment capacity evaluated in 65 NG00112 (Alternate Phase 2 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-connection point) 004.

Item is ROB to NG001. Equipment capacity evaluated in TIE BKR (CONNECTS 66 NG00116 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NG01 AND NG03) 005.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 480 V LOAD CENTER 67 NG003 CB/CC 2000-00 0.41 Anchorage evaluated per 14C4258-CAL-005. Block wall evaluated per NG03 14C4258-CAL-003.

FDR BKR FOR 125 V Item is ROB to NG003. Equipment capacity evaluated in 68 NG00303 VITAL BATTERY CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHARGER NK023 005. Block wall evaluated per 14C4258-CAL-003.

125 V BATTERY Component per se screened. Anchorage evaluated per 69 NK021 CB/CC 2016-00 0.4 Equipment Capacity CHARGER NK021 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

TRANSFER SWITCH BUS Component per se screened. Block wall evaluated per 70 NK071 NK01 BATTERY CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

CHARGER NK21/NK25 Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 125 VDC BUS 71 NK001 CB/CC 2016-00 0.71 Anchorage evaluated per 14C4258-CAL-004. Block wall evaluated per SWITCHBOARD NK001 14C4258-CAL-003.

Item is ROB to NK001. Equipment capacity evaluated in FDR BKR FROM BATT 72 NK00102 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHGR NK021 TO NK001 004. Block wall evaluated per 14C4258-CAL-003.

MAIN BREAKER FOR Item is ROB to NK001. Equipment capacity evaluated in CNTRL AND DIST PNL 73 NK00104 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK041 (PART OF SWBD 004. Block wall evaluated per 14C4258-CAL-003.

NK001) 12/2/14 Page 54 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number MAIN BREAKER FOR Item is ROB to NK001. Equipment capacity evaluated in CNTRL AND DIST PNL 74 NK00105 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK051 (PART OF SWBD 004. Block wall evaluated per 14C4258-CAL-003.

NK001)

Component per se screened. Anchorage evaluated per 75 NK011 125 V BATTERY NK011 CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

Item is ROB to NK001. Equipment capacity evaluated in ISOLATION BKR FOR 76 NK00101 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-BATTERY NK011 004. Block wall evaluated per 14C4258-CAL-003.

FDR BKR FOR INVERTER Item is ROB to NK001. Equipment capacity evaluated in 77 NK00111 NN011 (PART OF SWBD CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK001) 004. Block wall evaluated per 14C4258-CAL-003.

7.5KVA INVERTER (FED Component per se screened. Anchorage evaluated per 78 NN011 FROM BATT CHARGER CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

NK021)

Class 1E AC DIST SWBD Component per se screened. Anchorage evaluated per 79 NN001 CB/CC 2016-00 0.4 Equipment Capacity NN01 (SEP GRP 1) 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 80 SA066A STATUS INDICATING SYS CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

NEUTRON FLUX MONITORING SYSTEM 81 SENY0060A AUX 2026-00 >RLGM Screened SRT disposition DETECTOR AMPLIFIER SENY 60A NEUTRON FLUX MONITORING SYSTEM 82 SENY0060B AUX 2026-00 >RLGM Screened SRT disposition DETECTOR AMPLIFIER SENY 60B W PROCESS ANALOG Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 83 SB038 PROTECTION SET CAB- CB/CC 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

01 Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 84 SE054A W NUC INSTM NIS 1 CB/CC 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

BOP INSTRUMENTATION Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 85 RP053AC CB 2047-06 0.41 Anchorage RACK (TERMINATION evaluated per 14C4258-CAL-005.

AREA)

RPV LEVEL INSTR SYS Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 86 SB078 (RVLIS) PROC PROT SYS CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

CABINET 12/2/14 Page 55 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number T/C SUBCOOLING Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 87 RP081A CB 2047-06 0.41 Anchorage MONITOR CABINET evaluated per 14C4258-CAL-005.

CNTRL & INSTR DIST Component per se screened. Anchorage evaluated per 88 NK041 SWBD NK041 (CLASS 1E CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

125 VDC)

DIESEL GEN PNL NE107 89 NE107 DGB 2000-00 >RLGM Screened SRT disposition

& FIELD FLASHING TURBINE GENERATOR Component per se screened. Anchorage evaluated per 90 RL005 CB 2047-06 0.4 Equipment Capacity AND FW CONSOLE 14C4258-CAL-004.

TURBINE GENERATOR Component per se screened. Anchorage evaluated per 91 RL006 CB 2047-06 0.4 Equipment Capacity AND FW CONSOLE 14C4258-CAL-004.

92 RP315 DC DIST PNL RP315 ESW Pumphouse 2000-00 >RLGM Screened SRT disposition TURBINE GENERATOR Component per se screened. Anchorage evaluated per 93 RL023 CB 2047-06 0.4 Equipment Capacity AND FW MCB 14C4258-CAL-004.

TURBINE GENERATOR Component per se screened. Anchorage evaluated per 94 RL024 CB 2047-06 0.4 Equipment Capacity AND FW MCB 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 95 RL017 ESF MCB CB 2047-06 0.4 Equipment Capacity 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 96 RL018 ESF MCB CB 2047-06 0.4 Equipment Capacity 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 97 RL019 ESF MCB CB 2047-06 0.4 Equipment Capacity 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 98 RL020 ESF MCB CB 2047-06 0.4 Equipment Capacity 14C4258-CAL-004.

REACTOR COOLANT Component per se screened. Anchorage evaluated per 99 RL001 CB 2047-06 0.4 Equipment Capacity AND SUPT SYS CONSOLE 14C4258-CAL-004.

REACTOR COOLANT Component per se screened. Anchorage evaluated per 100 RL002 CB 2047-06 0.4 Equipment Capacity AND SUPT SYS CONSOLE 14C4258-CAL-004.

TURBINE GENERATOR Component per se screened. Anchorage evaluated per 101 RL025 CB 2047-06 0.4 Equipment Capacity AND FW MCB 14C4258-CAL-004.

TURBINE GENERATOR Component per se screened. Anchorage evaluated per 102 RL026 CB 2047-06 0.4 Equipment Capacity AND FW MCB 14C4258-CAL-004.

FUSED 125 VDC DIST 103 RP317 UHS 2000-00 >RLGM Screened SRT disposition PNL RP317 12/2/14 Page 56 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number CNTRL & INSTR DIST Component per se screened. Anchorage evaluated per 104 NK051 SWBD NK051 (CLASS 1E CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

125 VDC)

BBPCV0455A PORV 105 BBPCV0455A SOLENOID FAILS TO RB 2070-00 >RLGM Screened SRT disposition OPEN ON DEMAND REACTOR AUX CNTRL Component per se screened. Anchorage evaluated per 106 RL021 CB 2047-06 0.4 Equipment Capacity PANEL 14C4258-CAL-004.

REACTOR AUX CNTRL Component per se screened. Anchorage evaluated per 107 RL022 CB 2047-06 0.4 Equipment Capacity PANEL 14C4258-CAL-004.

DIESEL GAUGE AND 108 KJ0121 DGB 2000-00 >RLGM Screened SRT disposition CONTROL PANEL B AUXILIARY RELAY Component per se screened. Block wall evaluated per 109 RP209 AUX 2000-00 0.4 Equipment Capacity RACK 14C4258-CAL-003.

110 RP289 DC DIST PNL RP289 AUX 2047-06 >RLGM Screened SRT disposition MISC BOP INSTRUMENT Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 111 RP068 CB 2047-06 0.41 Anchorage RACK evaluated per 14C4258-CAL-005.

112 RP330 AUX RELAY RACK RP330 AUX 2000-00 >RLGM Screened SRT disposition B AUXILIARY RELAY 113 RP332 AUX 2000-00 >RLGM Screened SRT disposition RACK EM'CY LIGHTING DIST Item is ROB to NK051. Component per se screened. Anchorage 114 NK051A SWBD NK051A (SUBPNL CB 2016-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004. Block wall evaluated per OF NK051) 14C4258-CAL-003.

125 V BATTERY Component per se screened. Anchorage evaluated per 115 NK023 CB/CC 2016-00 0.4 Equipment Capacity CHARGER NK023 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

TRANSFER SWITCH BUS Component per se screened. Block wall evaluated per 116 NK073 NK03 BATTERY CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

CHARGER NK23/NK25 Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 125 VDC BUS 117 NK003 CB/CC 2016-00 0.71 Anchorage evaluated per 14C4258-CAL-004. Block wall evaluated per SWITCHBOARD NK003 14C4258-CAL-003.

Item is ROB to NK003. Equipment capacity evaluated in FDR BKR FROM BATT 118 NK00302 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHGR NK023 TO NK003 004. Block wall evaluated per 14C4258-CAL-003.

12/2/14 Page 57 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number MAIN BREAKER FOR Item is ROB to NK003. Equipment capacity evaluated in CNTRL AND DIST PNL 119 NK00304 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK043 (PART OF SWBD 004. Block wall evaluated per 14C4258-CAL-003.

NK003)

Component per se screened. Anchorage evaluated per 120 NK013 125 V BATTERY NK013 CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

Item is ROB to NK003. Equipment capacity evaluated in ISOLATION BKR FOR 121 NK00301 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-BATTERY NK013 004. Block wall evaluated per 14C4258-CAL-003.

FDR BKR FOR INVERTER Item is ROB to NK003. Equipment capacity evaluated in 122 NK00311 NN013 (PART OF SWBD CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK003) 004. Block wall evaluated per 14C4258-CAL-003.

7.5KVA INVERTER (FED Component per se screened. Anchorage evaluated per 123 NN013 FROM BATT CHARGER CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

NK023)

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage Class 1E AC DIST SWBD 124 NN003 CB/CC 2016-00 0.71 Anchorage evaluated per 14C4258-CAL-004. Block wall evaluated per NN03 (SEP GRP 3) 14C4258-CAL-003.

BOP INSTR RACK Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 125 RP053DB CB 2047-06 0.41 Anchorage RP053DB evaluated per 14C4258-CAL-005.

W PROCESS ANALOG Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 126 SB037 PROTECTION SET CAB- CB/CC 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

03 Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 127 SE054C W NUC INSTM NIS 3 CB/CC 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

CNTRL & INSTR DIST Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 128 NK043 SWBD NK043 (CLASS 1E CB/CC 2016-00 0.71 Anchorage evaluated per 14C4258-CAL-004. Block wall evaluated per 125 VDC) 14C4258-CAL-003.

Component per se screened. Block wall evaluated per 129 AB007 Aux Relay Rack CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

FDR BKR FOR 125 V Item is ROB to NG001. Equipment capacity evaluated in 130 NG00109 SWING BATTERY CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHARGER NK025 004.

125 V BATTERY Component per se screened. Anchorage evaluated per 131 NK025 CHARGER NK025 (Swing CB 2000-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

Battery Charger) 12/2/14 Page 58 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 480 V LOAD CENTER 132 NG002 CB 2000-00 0.41 Anchorage evaluated per 14C4258-CAL-005 Block wall evaluated per NG02 14C4258-CAL-003.

FLEX 500 kW TIE IN BKR Item is ROB to NG002. Equipment capacity evaluated in 133 NG00212 from FD201 (Phase 2 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-connection point) 005.

FDR BKR FOR 125 V Item is ROB to NG002. Equipment capacity evaluated in 134 NG00203 VITAL BATTERY CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHARGER NK024 005.

125 V BATTERY Component per se screened. Anchorage evaluated per 135 NK024 CB 2016-00 0.4 Equipment Capacity CHARGER NK024 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

TRANSFER SWITCH BUS Component per se screened. Block wall evaluated per 136 NK074 NK04 BATTERY CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

CHARGER NK24/NK26 125 VDC BUS Component per se screened. Anchorage evaluated per 137 NK004 CB 2016-00 0.4 Equipment Capacity SWITCHBOARD NK004 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

FDR BKR FROM BATT Item is ROB to NK004. Component per se screened. Anchorage 138 NK00402 CB 2016-00 0.4 Equipment Capacity CHGR NK024 TO NK004 evaluated per 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 139 NK014 125 V BATTERY NK014 CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

ISOLATION BKR FOR Item is ROB to NK004. Component per se screened. Anchorage 140 NK00401 CB 2016-00 0.4 Equipment Capacity BATTERY NK014 evaluated per 14C4258-CAL-004.

FDR BKR FOR INVERTER Item is ROB to NK004. Component per se screened. Anchorage 141 NK00411 NN011 (PART OF SWBD CB 2016-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

NK004) 7.5KVA INVERTER (FED Component per se screened. Block wall evaluated per 142 NN014 FROM BATT CHARGER CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

NK024)

Class 1E AC DIST SWBD Component per se screened. Anchorage evaluated per 143 NN004 CB 2016-00 0.4 Equipment Capacity NN04 (SEP GRP 4) 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

BOP Instrumentation 144 RP147B CB 2000-00 >RLGM Screened SRT disposition Rack RP147B NEUTRON FLUX MONITORING SYSTEM 145 SENY0061A AUX 2047-00 >RLGM Screened SRT disposition DETECTOR AMPLIFIER SENY 61A 12/2/14 Page 59 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number NEUTRON FLUX MONITORING SYSTEM 146 SENY0061B AUX 2047-00 >RLGM Screened SRT disposition DETECTOR AMPLIFIER SENY 61B Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 147 SE054D W NUC INSTM NIS 4 CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

W PROCESS ANALOG Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 148 SB041 PROTECTION SET CAB- CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

04 BOP Instrumentation Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 149 RP053BC CB 2047-06 0.41 Anchorage Rack RP053BC evaluated per 14C4258-CAL-005.

RVLIS Process Cabinet Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 150 SB079 CB 2047-06 0.41 Anchorage SB079 evaluated per 14C4258-CAL-005.

Subcooling Monitor Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 151 RP081B CB 2047-06 0.41 Anchorage Cabinet evaluated per 14C4258-CAL-005.

W PROCESS 152 SB148B PROTECTION (Fire CB 2000-00 >RLGM Screened SRT disposition Isolation)

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 153 SA066B STATUS INDICATING SYS CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

Component per se screened. Block wall evaluated per 154 RP140 PANEL RP140 CB 2000-00 0.4 Equipment Capacity 14C4258-CAL-003.

Item is ROB to RL002. Component per se screened. Anchorage Note 5 BGLI0104 BORIC ACID TANK A LEV CB 2047-06 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

Note 5 BGLT0104 BORIC ACID TANK A LEV AUX 1974-00 >RLGM Screened SRT disposition RWST SUPPLY TO CTMT Note 5 BNHV0003 AUX 1974-00 >RLGM Screened SRT disposition SPRAY PUMP B RWST SUPPLY TO CTMT Note 5 BNHV0004 AUX 1974-00 >RLGM Screened SRT disposition SPRAY PUMP A RWST TO SAFETY INJ Note 5 BNHV8806A AUX 1976-10 >RLGM Screened SRT disposition PUMP A SUCTION RWST TO SAFETY INJ Note 5 BNHV8806B AUX 1976-10 >RLGM Screened SRT disposition PUMP B SUCTION RWST TO RHR PUMP B Note 5 BNHV8812B AUX 1968-01 >RLGM Screened SRT disposition SUCTION Note 5 BNLT0933 RWST Level Transmitter YRD 1993-00 >RLGM Screened SRT disposition 12/2/14 Page 60 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number Equipment capacity evaluated in 14C4258-CAL-005. Anchorage LOCAL CONTROL PANEL Note 5 FC0219 AUX 2002-00 0.41 Equipment Capacity evaluated per 14C4258-CAL-005. Relay functionality evaluated FOR TD AFW PUMP per 14C4258-CAL-005.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage Note 5 NG002B MCC NG02B BUS AUX 2026-00 0.4 Relay functionality evaluated per 14C4258-CAL-004. Relay functionality evaluated per 14C4258-CAL-005.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage Note 5 NG003C MCC NG03C BUS AUX 2047-00 0.32 Relay functionality evaluated per 14C4258-CAL-005. Relay functionality evaluated per 14C4258-CAL-005.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage Note 5 NG004C MCC NG04C BUS AUX 2047-00 0.32 Relay functionality evaluated per 14C4258-CAL-005. Relay functionality evaluated per 14C4258-CAL-005.

Component per se screened. Block wall evaluated per Note 5 RP334 LOCKOUT RELAY RACK CB 2000-00 0.4 Equipment Capacity 14C4258-CAL-003.

12/2/14 Page 61 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report AMEREN MISSOURI CALLAWAY ENERGY CENTER EXPEDITED SEISMIC EVALUATION PROCESS (ESEP) REPORT December 31, 2014 Prepared by: Ameren Missouri Westinghouse Electric Company LLC Stevenson & Associates 12/1/14 Page 1 of 61

© 2014 by Westinghouse Electric Company LLC. All Rights Reserved.

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report EXPEDITED SEISMIC EVALUATION PROCESS REPORT Table of Contents 1.0 Purpose and Objective ..................................................................................................................... 4 2.0 Brief Summary of the FLEX Seismic Implementation Strategies .................................................... 5 3.0 Equipment Selection Process and ESEL ........................................................................................... 6 3.1 Equipment Selection Process and ESEL.......................................................... 6 3.1.1 ESEL Development .......................................................................................... 7 3.1.2 Power Operated Valves .................................................................................. 7 3.1.3 Pull Boxes ........................................................................................................ 8 3.1.4 Termination Cabinets ..................................................................................... 8 3.1.5 Critical Instrumentation Indicators ................................................................ 8 3.1.6 Phase 2 and Phase 3 Piping Connections ....................................................... 8 3.1.7 Relays .............................................................................................................. 9 3.2 Justification for Use of Equipment That Is Not the Primary Means for FLEX Implementation .............................................................................................. 9 4.0 Ground Motion Response Spectrum (GMRS) .................................................................................. 9 4.1 Plot of GMRS Submitted by the Licensee ...................................................... 9 4.2 Comparison to SSE ........................................................................................ 12 5.0 Review Level Ground Motion (RLGM) ........................................................................................... 13 5.1 Description of RLGM Selected ...................................................................... 13 5.2 Method to Estimate ISRS.............................................................................. 14 6.0 Seismic Margin Evaluation Approach ............................................................................................ 15 6.1 Summary of Methodologies Used................................................................ 15 6.2 HCLPF Screening Process .............................................................................. 15 6.2.1 Overview ....................................................................................................... 15 6.2.2 Generic Screening Results ............................................................................ 16 6.3 Seismic Walkdown Approach ....................................................................... 19 6.3.1 Walkdown Approach .................................................................................... 19 6.3.2 Application of Previous Walkdown Information ......................................... 19 6.3.3 Significant Walkdown Findings .................................................................... 19 12/2/14 Page 2 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 6.4 HCLPF Calculation Process ............................................................................ 23 6.5 Functional Evaluations of Relays.................................................................. 23 6.6 Tabulated ESEL HCLPF Values (Including Key Failure Modes) ..................... 23 7.0 Inaccessible Items .......................................................................................................................... 26 7.1 Identification of ESEL items inaccessible for walkdowns ............................ 26 8.0 ESEP Conclusions and Results ........................................................................................................ 26 8.1 Supporting Information ................................................................................ 26 8.2 Indication of Planned Modifications ............................................................ 28 8.3 Modification Implementation Schedule ...................................................... 29 8.4 Summary of Regulatory Commitments ....................................................... 29 9.0 References ...................................................................................................................................... 31 Attachment A Callaway ESEL................................................................................................ 34 Attachment B ESEP HCLPF Values and Failure Modes Tabulation ..................................... 50 12/2/14 Page 3 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 1.0 Purpose and Objective Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the Nuclear Regulatory Commission (NRC) established a Near-Term Task Force (NTTF) to conduct a systematic review of NRC processes and regulations and to determine if the agency should make additional improvements to its regulatory system. The NTTF developed a set of recommendations intended to clarify and strengthen the regulatory framework for protection against natural phenomena. Subsequently, the NRC issued a 50.54(f) letter on March 12, 2012 [1], requesting information to assure that these recommendations are addressed by all U.S. nuclear power plants. The 50.54(f) letter requests that licensees and holders of construction permits under 10 CFR Part 50 reevaluate the seismic hazards at their sites against present-day NRC requirements and guidance. Depending on the comparison between the reevaluated seismic hazard and the current design basis, further risk assessment may be required. Assessment approaches acceptable to the staff include a seismic probabilistic risk assessment (SPRA), or a seismic margin assessment (SMA). Based upon the assessment results, the NRC staff will determine whether additional regulatory actions are necessary.

This report describes the Expedited Seismic Evaluation Process (ESEP) undertaken for the Callaway Energy Center (CEC). The intent of the ESEP is to perform an interim action in response to the NRCs 50.54(f) letter [1] and to demonstrate seismic margin through a review of a subset of the plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events.

The ESEP is implemented using the methodologies in the NRC endorsed guidance in EPRI 3002000704, Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic [2]. The guidance discusses the use of the ongoing FLEX process [3] as a starting point for consideration.

This report examines the FLEX equipment and strategy [3] (Section 2.0) to develop the initial Expedited Seismic Equipment List (ESEL) and uses an iterative process to develop the final ESEL [4] (Section 3.0).

The ESEL is used to evaluate the listed equipment against the review level ground motion (RLGM) data (Section 5) with respect to the equipments seismic capacity based on characterization of the high confidence of a low probability of failure (HCLPF).

Equipment which has seismic capacity larger than the RLGM data can be screened from further evaluation. For equipment that has a seismic capacity below the RLGM, modifications need to be performed following the NRC endorsed guidance in EPRI 3002000704.

The objective of this report is to provide summary information describing the ESEP evaluations and results. The level of detail provided in this report is intended to enable the NRC to understand the inputs used, the evaluations performed, and the decisions made as a result of the interim evaluations.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 2.0 Brief Summary of the FLEX Seismic Implementation Strategies The Callaway FLEX strategies for Reactor Core Cooling and Heat Removal, Reactor Inventory Control/Long-term Subcriticality, and Containment Function are summarized below. This summary is derived from the Callaway Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049 [3].

Reactor core cooling and heat removal is achieved via steam release from the Steam Generators (SGs) with SG makeup from the Turbine Driven Auxiliary Feedwater Pump (TDAFP) during FLEX Phase 1 with suction from the Condensate Storage Tank (CST).

Ameren Missouri has elected to construct a new Hardened Condensate Storage Tank (HCST) [3]. The larger HCST volume would be capable of feeding the steam generators for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This extended coping duration will not require HCST make-up from the UHS before the Phase 3 off-site equipment is deployed. The TDAFP flow control valves and Main Steam Atmospheric Relief Valves (ARVs) are also required to provide reactor core heat-removal capability. Phase 2 reactor core heat removal is achieved via the new FLEX mechanical connections. The only permanent plant equipment manipulated for the Phase 2 is manual valves.

Reactor Inventory Control/Long-term Subcriticality strategy consists of reactor coolant system borated make-up via the FLEX primary make-up connections.

Reactor coolant system (RCS) inventory reduction is a result of water volume reduction due to cooldown, reactor coolant pump seal leakage, and letdown via head-vents and/or pressurizer PORVs. The reactor coolant pump seal leak-off containment isolation valve is manually isolated to conserve inventory and keep leak-off flow within the Reactor Building. To avoid adverse effects on the RCS natural circulation flow, the accumulator isolation valves are electrically closed during the cooldown to prevent nitrogen injection into the reactor coolant system.

There are no Phase 1 or Phase 2 FLEX actions required to maintain containment integrity. In fact, containment function is not expected to be challenged during all three phases.

Necessary electrical components are outlined in the Callaway FLEX OIP submittal [3],

and primarily entail the installation of a 480V generator (FLEX) to provide power to vital batteries, equipment installed to support FLEX electrical connections, and monitoring instrumentation required for core cooling, reactor coolant inventory, and containment integrity.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 3.0 Equipment Selection Process and ESEL The selection of equipment for the Expedited Seismic Equipment List (ESEL) followed the guidelines of EPRI 3002000704 [2]. The ESEL for Callaway is presented in Attachment A.

3.1 Equipment Selection Process and ESEL The selection of equipment to be included on the ESEL was based on installed plant equipment credited in the FLEX strategies during Phases 1, 2 and 3 mitigation of a Beyond Design Basis External Event (BDBEE), as outlined in the Callaway Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049 [3]. The OIP provides the Callaway FLEX mitigation strategy and serves as the basis for equipment selected for the ESEP.

The scope of installed plant equipment includes equipment relied upon for the FLEX strategies to sustain the critical functions of core cooling and containment integrity consistent with the Callaway OIP [3]. FLEX recovery actions are excluded from the ESEP scope per EPRI 3002000704 [2]. The overall list of planned FLEX modifications and the scope for consideration herein is limited to those required to support core cooling, reactor coolant inventory and subcriticality, and containment integrity functions. Portable and pre-staged FLEX equipment (not permanently installed) are excluded from the ESEL per EPRI 3002000704 [2].

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

1. The scope of components is limited to that required to accomplish the core cooling and containment safety functions identified in Table 3-2 of EPRI 3002000704. The instrumentation monitoring requirements for core cooling/containment safety functions are limited to those outlined in the EPRI 3002000704 guidance, and are a subset of those outlined in the Callaway OIP [3].

2. The scope of components is limited to installed plant equipment and the FLEX connections necessary to implement the Callaway OIP [3] as described in Section 2.

3. The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either Primary or Back-up/Alternate).

4. The Primary FLEX success path is to be specified. Selection of the Back-up/Alternate FLEX success path must be justified.

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

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report

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

[2] guidance are:

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

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

• Manual valves and rupture disks.

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

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

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

3.1.1 ESEL Development The ESEL was developed by reviewing the Callaway OIP [3] to determine the major equipment involved in the FLEX strategies. Further reviews of plant drawings (e.g., Process and Instrumentation Diagrams (P&IDs) and Electrical One Line Diagrams) were performed to identify the boundaries of the flowpaths to be used in the FLEX strategies and to identify specific components in the flowpaths needed to support implementation of the FLEX strategies.

Boundaries were established at an electrical or mechanical isolation device (e.g.,

isolation amplifier, valve, etc.) in branch circuits / branch lines off the defined strategy electrical or fluid flowpath. P&IDs were the primary reference documents used to identify mechanical components and instrumentation. The flow paths used for FLEX strategies were selected and specific components were identified using detailed equipment and instrument drawings, piping isometrics, electrical schematics and one-line drawings, system descriptions, design basis documents, etc., as necessary. The P&IDs are also used to determine the normal position of system valves and the valve positioning required in order to align the system in support of the FLEX functions.

The electrical equipment required to support the mechanical components used in the FLEX strategies evaluated for the ESEL was also evaluated for its inclusion on the ESEL using electrical drawings and guidance [2].

3.1.2 Power Operated Valves Page 3-3 of EPRI 3002000704 [2] notes that power operated valves not required to change state are excluded from the ESEL. Page 3-2 also notes that functional failure modes of electrical and mechanical portions of the installed Phase 1 equipment should be considered (e.g., RCIC/AFW trips). To address this 12/2/14 Page 7 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report concern, the following guidance is applied in the Callaway ESEL for functional failure modes associated with power operated valves:

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

• Power operated valves not required to change state as part of the FLEX mitigation strategies were not included on the ESEL. The seismic event also causes the ELAP event; therefore, the valves are incapable of spurious operation as they would be de-energized.

• Power operated valves not required to change state as part of the FLEX mitigation strategies during Phase 1, and are re-energized and operated during subsequent Phase 2 and 3 strategies, were not evaluated for spurious valve operation as the seismic event that caused the ELAP has passed before the valves are re-powered.

3.1.3 Pull Boxes Pull boxes were deemed unnecessary to add to the ESELs as these components provide completely passive locations for pulling or installing cables. No breaks or connections in the cabling are included in pull boxes. Pull boxes were considered part of conduit and cabling, which are excluded in accordance with EPRI 3002000704 [2].

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

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

3.1.6 Phase 2 and Phase 3 Piping Connections Item 2 in Section 3.1 above notes that the scope of equipment in the ESEL includes FLEX connections necessary to implement the Callaway OIP [3] as described in Section 2. Item 3 in Section 3.1 also notes that The scope of components assumes the credited FLEX connection modifications are implemented, and are limited to those required to support a single FLEX success path (i.e., either Primary or Back-up/Alternate).

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Item 6 in Section 3.1 above goes on to explain that Piping, cabling, conduit, HVAC, and their supports are excluded from the ESEL scope in accordance with EPRI 3002000704 [2].

Therefore, piping and pipe supports associated with FLEX Phase 2 and Phase 3 connections are excluded from the scope of the ESEP evaluation. However, any active valves in FLEX Phase 2 and Phase 3 connection flow path are included in the ESEL.

3.1.7 Relays Relays essential to the FLEX strategy were explicitly addressed [5]. Relays were screened and where relay chatter was found to result in an undesirable alignment the relay, and its parent cabinet, were added to the analysis. Parent cabinets were walked down and, if needed, HCLPF estimates were performed.

3.2 Justification for Use of Equipment That Is Not the Primary Means for FLEX Implementation No equipment outside of the primary FLEX strategy is credited in the Callaway ESEP [4].

The complete ESEL for Callaway [4] is presented in Attachment A.

4.0 Ground Motion Response Spectrum (GMRS) 4.1 Plot of GMRS Submitted by the Licensee The CEC design response spectra are stated to be applied in the free field at finished grade [6].

The 1E-4 and 1E-5 Uniform Hazard Response Spectra (UHRS), along with a design factor (DF), are used to compute the GMRS at the control point as shown in the seismic hazard and GMRS submittal to the NRC [7].

Table 4-1 shows the UHRS and GMRS spectral accelerations.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Table 4-1: UHRS for 10-4 and 10-5 and GMRS at the control point for Callaway

-4 -5 Freq. (Hz) 10 UHRS (g) 10 UHRS (g) GMRS (g) 100 4.20E-01 9.88E-01 5.00E-01 90 4.24E-01 1.00E+00 5.06E-01 80 4.30E-01 1.02E+00 5.15E-01 70 4.40E-01 1.05E+00 5.30E-01 60 4.61E-01 1.11E+00 5.57E-01 50 5.12E-01 1.23E+00 6.17E-01 40 6.17E-01 1.45E+00 7.34E-01 35 6.83E-01 1.60E+00 8.12E-01 30 7.68E-01 1.82E+00 9.20E-01 25 8.70E-01 2.10E+00 1.06E+00 20 9.16E-01 2.21E+00 1.11E+00 15 9.02E-01 2.18E+00 1.10E+00 12.5 9.10E-01 2.16E+00 1.09E+00 10 9.54E-01 2.17E+00 1.11E+00 9 9.90E-01 2.21E+00 1.13E+00 8 1.02E+00 2.24E+00 1.15E+00 7 1.03E+00 2.24E+00 1.15E+00 6 1.01E+00 2.19E+00 1.12E+00 5 9.14E-01 2.00E+00 1.02E+00 4 6.74E-01 1.55E+00 7.85E-01 3.5 5.29E-01 1.25E+00 6.32E-01 3 4.00E-01 9.59E-01 4.83E-01 2.5 2.87E-01 6.81E-01 3.44E-01 2 2.31E-01 5.32E-01 2.70E-01 1.5 1.70E-01 3.75E-01 1.92E-01 12/2/14 Page 10 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report

-4 -5 Freq. (Hz) 10 UHRS (g) 10 UHRS (g) GMRS (g) 1.25 1.58E-01 3.39E-01 1.75E-01 1 1.36E-01 2.86E-01 1.48E-01 0.9 1.24E-01 2.61E-01 1.35E-01 0.8 1.12E-01 2.38E-01 1.23E-01 0.7 1.02E-01 2.19E-01 1.13E-01 0.6 9.47E-02 2.04E-01 1.05E-01 0.5 8.64E-02 1.89E-01 9.68E-02 0.4 6.91E-02 1.51E-01 7.75E-02 0.35 6.05E-02 1.32E-01 6.78E-02 0.3 5.18E-02 1.13E-01 5.81E-02 0.25 4.32E-02 9.44E-02 4.84E-02 0.2 3.45E-02 7.55E-02 3.87E-02 0.15 2.59E-02 5.66E-02 2.91E-02 0.125 2.16E-02 4.72E-02 2.42E-02 0.1 1.73E-02 3.77E-02 1.94E-02 12/2/14 Page 11 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Figure 4-1 shows the control point UHRS and GMRS.

Mean Soil UHRS and GMRS at Callaway 2.5 2.

1E-5 UHRS Spectral acceleration, g 1.5 GMRS 1E-4 UHRS 1.

0.5 0.

0.1 1 10 100 Spectral frequency, Hz Figure 4-1: Plots of 1E-4 and 1E-5 UHRS and GMRS at control point for Callaway (5%-damped response spectra) 4.2 Comparison to SSE The definition of the SSE for Callaway is discussed in Section 2.5, 3.7 and 3.7(B) of the FSAR [6]. The SSE is anchored to a 0.20g Peak Ground Acceleration (PGA) and is presented in Table 4-2.

Table 4-2: SSE for Callaway Freq (Hz) SA (g) 0.25 0.09 2.50 0.63 9.00 0.52 33.00 0.20 100.00 0.20 12/2/14 Page 12 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report As shown in Figure 4-2, the GMRS begins to exceed the SSE at around 3.5 Hz.

SSE GMRS 10.00 1.00 Acceleration (g) 0.10 0.01 0.1 1 10 100 Frequency (Hz)

Figure 4-2: Callaway SSE - GMRS Comparison 5.0 Review Level Ground Motion (RLGM) 5.1 Description of RLGM Selected The Review Level Ground Motion is derived by linearly scaling the current design basis SSE by the maximum ratio of the GMRS to the SSE between the 1 and 10 Hz range (not to exceed two times the SSE) [2]. The maximum GMRS/SSE ratio occurs at 10 Hz as seen in Figure 4-2. The In-Structure Response Spectra document provides logarithmic interpolation at 10 Hz to determine that the SSE spectral acceleration is 0.48 g [8]. Examination of Table 4-1 shows that the GMRS spectral acceleration is 1.11 g. The result is a maximum GMRS/SSE ratio between 1 - 10 Hz of 2.31 (witness 1.11 g / 0.48 g = 2.31). Since the GMRS/SSE ratio cannot exceed 2 the RGLM is scaled at 2 X SSE. The resulting RLGM is shown in Table 5-1 and Figure 5-1.

It is noted that for surface-mounted structures, systems, and components (SSC)

(TAP01, TBN01, and the CST pipe house) directly applying the GMRS for HCLPF 12/2/14 Page 13 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report determination is acceptable. Results based upon the GMRS as the seismic margins earthquake are noted where applicable herein.

Table 5-1: RLGM for Callaway Freq. (Hz) 100 33 9 2.5 0.25 RLGM (g) 0.4 0.4 1.04 1.26 0.18 SSE GMRS RLGM 10.00 1.00 Acceleration (g) 0.10 0.01 0.1 1 10 100 Frequency (Hz)

Figure 5-1: Callaway RLGM vs GMRS 5.2 Method to Estimate In-Structure Response Spectra (ISRS)

The ISRS for Callaway [10a] uses the scaled approach to estimate the ISRS. As mentioned in Section 5.1, the RLGM is scaled by a factor of 2 which is also applied to the existing ISRS curves.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 6.0 Seismic Margin Evaluation Approach It is necessary to demonstrate that the ESEL items have sufficient seismic capacity to meet or exceed the demand characterized by the RLGM. The seismic capacity is characterized as the peak ground acceleration (PGA) for which there is a high confidence of a low probability of failure (HCLPF). The PGA is associated with a specific spectral shape, in this case the 5%-damped RLGM spectral shape. The HCLPF capacity must be equal to or greater than the RLGM PGA. The criteria for seismic capacity determination are given in Section 5 of EPRI 3002000704 [2].

There are two basic approaches for developing HCLPF capacities:

1. Deterministic approach using the conservative deterministic failure margin (CDFM) methodology of EPRI NP-6041, A Methodology for Assessment of Nuclear Power Plant Seismic Margin (Revision 1) [8].

2. Probabilistic approach using the fragility analysis methodology of EPRI TR-103959, Methodology for Developing Seismic Fragilities [9].

Callaway has elected to use the deterministic approach by applying the EPRI NP-6041 screening process [8].

6.1 Summary of Methodologies Used The seismic margins methodology of EPRI report NP-6041-SL [8] was applied for this effort. Use of this methodology conforms to Section 5 of EPRI 3002000704. The primary tasks performed were:

• Generic seismic screening per NP-6041, Table 2-4.

• Performance of seismic walkdowns.

• Item-specific screening via walkdown, review of design data, and performance of screening calculations.

• Performance of HCLPF calculations for screened-in equipment 6.2 HCLPF Screening Process 6.2.1 Overview The seismic margins screening methodology of NP-6041-SL was applied. The primary steps for this screening process are:

1. Apply NP-6041-SL, Table 2-4 to determine which equipment items and failure modes may be screened-out on a generic basis.

2. For each equipment item, perform a seismic walkdown to verify generic screening may be applied and to verify the item does not have any specific seismic vulnerabilities.

3. Verify anchorage capacity.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report The generic screening criteria of Table 2-4 are dependent on the applied screening level and are applicable to equipment located within 40 feet of plant grade. For the Callaway ESEP project:

• The peak 5% spectral acceleration of the RLGM is 1.26g and occurs at 2.5 Hz. At 3.5 Hz, the RLGM decreases to 1.2g 1. From FSAR SP Table 3.7(B)-4 and SA Tables 3.7-3 and 3.7-4, all Category I structures have fundamental frequencies exceeding 3.5 Hz and can reasonably be considered to respond in the frequency range corresponding to accelerations less than 1.2g. Accordingly, the 2nd screening column (0.8 - 1.2g) screening criteria of NP-6041-SL, Table 2-4, were applied with special consideration for components with low frequencies.

• A number of components in the Auxiliary/Control Building and the Reactor Building were located above 40 from grade; all other equipment was located within 40 of plant grade. Per Appendix A of NP-6041-SL, components that are above 40 from grade and have corresponding ISRS at the base of component in exceedance of 1.5 times the bounding spectrum (equivalent to a 1.8g peak spectral acceleration) may not be screened to the 2nd screening column and require HCLPF analysis.

Table 6-1 below summarizes the application of Table 2-4 screening for the ESEP.

Applied plant grade was Elevation 2000. Per the FSAR this grade elevation is constant through-out the power block area.

After completion of the screening process, an item is either screened-out or screened-in. The presumptive seismic capacity of a screened-out item exceeds the applied screening level and no further evaluation is needed. An item that is screened-in requires a HCLPF analysis to address the failure mode cited by the seismic review team (SRT). The HCLPF capacity may or may not be above the screening level.

6.2.2 Generic Screening Results Table 6-1 summarizes the generic screening results for the ESEL. Only the relevant equipment types are listed. Based on the generic screening:

• HCLPF analyses are required for atmospheric storage tanks

• Relay chatter requires evaluation 1

The frequency where the RLGM spectra equals 1.2g is determined by logarithmic interpolation based on the control point accelerations and frequencies in Reference 8 as follows:

log(1.04 g ) log(1.26 g )

(log( X Hz ) log( 2.5 Hz ) + log(1.26 g )

log( 9 Hz ) log( 2.5 Hz )

1.2 g = 10 X = 3.46 Hz 12/2/14 Page 16 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Other generic screening requirements were addressed by walkdown, design review and anchorage verification. These assessments are documented in the screening evaluation work sheets (SEWS) [10f].

Table 6-1: Summary of generic screening per NP-6041-SL Table 2-4, 1.2g Screening Level Equipment Type Generic Screening Criteria Screening Result Active valves Note (f) applies. There are no extremely large extended motor operators on 2-inch or smaller piping.

Passive valves No evaluation required. N/A Atmospheric storage tanks Evaluation required. HCLPF analyses required for the atmospheric storage tanks.

Pressure vessels Notes (h), (i) apply For the pressurized tanks on the ESEL, anchorage and load path were verified by bounding calculations using qualification reports during screening. Potential failure modes of the vessel bodies were addressed by walkdown and design review.

Batteries and racks Note (k) applies. Batteries are braced racks and are designed for seismic loads. HCLPF analyses are required for the battery rack anchorage.

Horizontal pumps No evaluation required. Although no evaluation is required for the component per se, a HCLPF evaluation for the auxiliary feedwater turbine-driven pump is required.

Active electrical power Notes (s) and (t) apply. Note (s) was addressed by walkdown and distribution panels design review. Where bounding analysis of anchorage configurations for the RLGM could not be provided, HCLPF analyses are required.

Relays are evaluated separately per Reference 5.

Passive electrical power Note (s) applies. Note (s) was addressed by walkdown and distribution panels design review. Where bounding analysis of anchorage configurations for the RLGM could not be provided, HCLPF analyses are required.

Transformers Notes (u) and (v) apply. The ESEL includes dry-type transformers. A design review verified coil restraint. HCLPF analysis of anchorage is required.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Equipment Type Generic Screening Criteria Screening Result Battery chargers & inverters Note (w) applies. Per walkdown and design review, the items on the ESEL are solid state units. Where bounding analysis of anchorage configurations for the RLGM could not be provided, HCLPF analyses are required.

Instrumentation and control Notes (s) and (t) apply. Note (s) was addressed by walkdown and panels and racks design review. Where bounding analysis of anchorage configurations for the RLGM could not be provided, HCLPF analyses are required.

Relays are evaluated separately per Reference 5.

Temperature sensors; pressure Note (x) applies. Note (x) was addressed by walkdown and and level sensors. design review. Sensors in the scope were typically mounted in-line on piping.

Relevant notes from NP-6041-SL Table 2-4

f. Evaluation recommended for MOVs in piping lines of 2 inches diameter or less.

h. Margin evaluation only needs to consider anchorage and supports.

i. For vessels designed by dynamic analysis or equivalent static analysis enveloping vessel inertial and piping loading, only the anchorage and supports require evaluation. For vessel not meeting these criteria, all potential failure modes require evaluation.

k. Batteries mounted in braced racks designed for seismic loads or qualified by dynamic testing do not require evaluation. Rigid spacers between batteries and end restraints are required. Batteries should be tightly supported by side rails.

s. Walkdown should be conducted to verify that the instruments are properly attached to the cabinets.

t. Relays, contactors, switches, and breakers must be evaluated for chatter and trip if functionality during strong shaking is required.

u. Anchorage evaluation required.

v. Liquid-filled transformers require evaluation of overpressure safety switches. The transformer coils should be restrained within the cabinet for dry transformers.

w. Solid state units require anchorage checks. Others require evaluation.

x. Insufficient data are available for screening guidelines. Emphasis should be on attachments.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 6.3 Seismic Walkdown Approach 6.3.1 Walkdown Approach Walkdowns were performed by two-person seismic review teams (SRTs) consisting of engineers with seismic experience. Walkdowns followed the guidance of Section 5 of EPRI 3002000704 [2] and Section 2 of NP-6041-SL [8]. The SRT used NP-6041-SL, Appendix F, to evaluate item-specific equipment caveats. The SRT also recorded notes and took photographs of the items under review.

Two walkdown sessions have been performed as indicated below.

Walkdown Date SRT Plant Support Week of July 14, 2014 Hunter Young (S&A) Jim Cunningham (Callaway)

Samer El-Bahey (S&A) Steve Sampson (Callaway)

George Belchik (Callaway)

Week of November 3, 2014 Hunter Young (S&A) David Hollabaugh (Callaway)

Apostolos Karavoussianis (S&A)

The walkdown findings for each item are documented in screening evaluation work sheets (SEWS). The SEWS notes also identify evaluations and reviews performed to support screening. The SEWS are included in Appendix C of Reference 10f. Also, Appendix A [10f] provides a concise summary of screening results in tabular format.

6.3.2 Application of Previous Walkdown Information New seismic walkdowns were performed for ESEL equipment. The results of the previous seismic margin evaluation, performed for the Seismic IPEEE program [11], were reviewed and used for background purposes only.

6.3.3 Significant Walkdown Findings The walkdown and screening results are summarized in Table 6-2.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Table 6-2: Items Selected for HCLPF Analysis No. ID Description Bldg Elev Basis for Selection

1. NB001 4.16KV SWGR NB001 (Class CB 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis 1E, Train A) of anchorage.

2. NG001 480 V LOAD CENTER NG01 CB/CC 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis of anchorage.

Apply results to similar items NG002 and NG003.

3. NK011 125 V BATTERY NK011 CB/CC 2016-00 Anchorage could not be readily screened. Perform HCLPF analysis of anchorage.

Apply results to similar items NK013 and NK014.

4. NK021 125 V BATTERY CHARGER CB/CC 2016-00 Anchorage could not be readily screened. Perform HCLPF analysis NK021 of anchorage.

Apply results to similar items NK023 and NK024.

5. NK025 125 V BATTERY CHARGER CB 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis NK025 (Swing Battery of anchorage.

Charger)

6. NN001 Class 1E AC DIST SWBD CB/CC 2016-00 Anchorage could not be readily screened. Perform HCLPF analysis NN01 (SEP GRP 1) of anchorage.

Apply results to similar items NK043, NN003, NK051, NK041, NK001, NK003, NK004, and NN004.

7. NN011 7.5KVA INVERTER (FED CB/CC 2016-00 Anchorage could not be readily screened. Perform HCLPF analysis FROM BATT CHARGER of anchorage.

NK021)

Apply results to similar item NN013.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report No. ID Description Bldg Elev Basis for Selection

8. PA003 CUBICLE PT FOR RCP AUX 2026-00 Anchorage could not be readily screened. Perform HCLPF analysis MOTOR DPBB01A of anchorage.

Apply results to similar item PA004.

9. PAL02 TDAFW Pump AUX 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis of anchorage.

10. RL001 REACTOR COOLANT AND CB 2047-06 Anchorage could not be readily screened. Perform HCLPF analysis SUPT SYS CONSOLE of anchorage.

Apply results to similar items RL002, RL005, RL006, and RL017 thru RL026.

11. SB102A W CABINET FOR REACTOR AUX 2026-00 Anchorage could not be readily screened. Perform HCLPF analysis TRIP SWG TRAIN-A of anchorage.

12. TAP01 Condensate Storage Tank YARD 2000-00 Perform HCLPF analysis per Appendix H of NP-6041. In addition, evaluate block wall doghouse that is adjacent for interaction hazard.

13. TBN01 RWST YRD 2000-00 Perform HCLPF analysis per Appendix H of NP-6041.

14. XNG01 4.16-KV/480 V LOAD CB/CC 2000-00 Anchorage could not be readily screened. Perform HCLPF analysis CENTER TRANSFORMER of anchorage.

XNG01 FOR LC NG001 12/2/14 Page 21 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report No. ID Description Bldg Elev Basis for Selection

15. Generic Equipment 40 above grade AB/CB 2047-06 Equipment on the Aux/Ctrl 2047.5' elevation are 40' above grade and have ISRS spectral accelerations in both horizontal directions exceeding 1.8g (with clipping) and therefore do not screen to the 2nd screening lane. HCLPF analysis for component functionality and structure (including anchorage) are required for the associated components.

Affected components include NF039A, NF039B, NF039C, NG003C, NG004C, RP053AC, RP053BC, RP053DB, RP068, RP081A, RP081B, RP289, SA036A, SA036C, SA066A, SA066B, SA075A, SB029A, SB029D, SB030A, SB032A, SB032D, SB033A, SB037, SB038, SB041, SB078, SB079, SE054A, SE054C, and SE054D.

16. Generic BLOCK WALLS AB/ CB Var. Per NP-6041-SL Table 2-4 seismic capacity cannot be screened and HCLPF analysis is required for block wall seismic capacity.

Affected components include NB001, NK025, NG003, TAP01, NK043, NN003, NN013, NK041, NN001, NK021, NN011, NK051, NK001, NK023, NK071, NK073, NK011, NK013, AB007, NK003, RP209, NG002, NK024, NK074, NK004, NK014, NN014, NN004, RP140, and RP334.

12/2/14 Page 22 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 6.4 HCLPF Calculation Process All HCLPF values were calculated using the conservative, deterministic failure margin (CDFM) criteria of NP-6041-SL [8]. CDFM analysis criteria are summarized in NP-6041-SL, Table 2-5.

For structural failure modes, the HCLPF capacity is equal to the earthquake magnitude at which the strength limit is reached. For equipment functionality, experience data or available test response spectra (TRS) are typically used to define the HCLPF capacity.

The methods of NP-6041-SL, Appendix Q were applied for functionality evaluations.

6.5 Functional Evaluations of Relays Verification of the functional capacity for equipment mounted within 40 of grade was addressed by application NP-6041-SL, Table 2-4 generic screening criteria as described above. For equipment mounted higher than 40 above grade and for in-scope relays, the methods of NP-6041-SL, Appendix Q were applied for functionality evaluations. In those cases the seismic capacity was based upon one of the following:

• Test response spectra (TRS) from plant-specific seismic qualification reports.

• Generic equipment ruggedness spectra (GERS) from EPRI report NP-5223-SL [12].

• Experience based seismic capacity per the guidelines of EPRI TR-1019200 [13].

Screening of relays within the scope of the ESEP (in accordance with EPRI 3002000704) is conducted within 14C4258-RPT-003 [5]. Cabinets requiring HCLPF evaluation for relay functionality are noted in Table 7-2 [5] under Item 17.

6.6 Tabulated ESEL HCLPF Values (Including Key Failure Modes)

Table 6-3 lists HCLPF analysis results. The failure modes analyzed are identified.

Supporting calculation documents [10.d &e] containing the detailed HCLPF calculations are also identified.

For the following discussion, an ESEP outlier is defined as an item whose HCLPF capacity is less than the RLGM. There are currently four ESEP outliers:

• NG003C (Relay Capacity)

• NG004C (Relay Capacity)

• TAP01 (Anchorage Capacity)

• TBN01 (Anchorage Capacity)

Note that for the CST (TAP01) and RWST (TBN01), the applied ground motion and HCLPF are based on the GMRS of Reference 7. The GMRS is acceptable as an alternative RLGM per EPRI 3002000704, Section 4, Option 2. The CST and RWST are founded on a slab-on-grade in the yard. The GMRS has a horizontal PGA of 0.50g.

12/2/14 Page 23 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Relay Chatter Failure Modes NG003C and NG004C are ESEP-outliers with respect to relay chatter. Refer to 14C4258-RPT-003 [5] for specific relays. Credit for operator action may resolve the relay chatter failure modes.

Tabulated HCLPF Values In general, the HCLPF values for screened-out items equals or exceeds the RLGM.

HCLPF 0.40g The HCLPF for screened-out items and failure modes Unless justified by calculations, the above HCLPF is applicable for all screened-out items and covers the relevant failure modes.

The HCLPF values for all ESEL items are tabulated in Appendix B.

Table 6-3: HCLPF Analysis Results No. ID Description Bldg Elev HCLPF2 Failure Mode Basis Related Components (g, PGA) Analyzed

1. NB001 4.16KV SWGR NB001 CB 2000-00 0.41 Equipment 14C4258- n/a (Class 1E, Train A) capacity and CAL-005 anchorage

2. NG001 480 V LOAD CENTER CB/CC 2000-00 0.41 Equipment 14C4258- NG002, NG003 NG01 capacity and CAL-005 anchorage

3. NK011 125 V BATTERY NK011 CB/CC 2016-00 2.36 Anchorage 14C4258- NK013, NK014 CAL-004

4. NK021 125 V BATTERY CB/CC 2016-00 1.33 Anchorage 14C4258- NK023, NK024 CHARGER NK021 CAL-004

5. NK025 125 V BATTERY CB 2000-00 0.85 Anchorage 14C4258- n/a CHARGER NK025 (Swing CAL-004 Battery Charger)

6. NN001 Class 1E AC DIST SWBD CB/CC 2016-00 0.71 Anchorage 14C4258- NK043, NN003, NK051, NK041, NN01 (SEP GRP 1) CAL-004 NK001, NK003, NK004, NN004

7. NN011 7.5KVA INVERTER (FED CB/CC 2016-00 0.75 Anchorage 14C4258- NN013 FROM BATT CHARGER CAL-004 NK021)

8. PA003 CUBICLE PT FOR RCP AUX 2026-00 0.62 Anchorage 14C4258- PA004 MOTOR DPBB01A CAL-004 2

HCLPFs based upon RLGM (PGA=0.40g) as the seismic margins earthquake with the exception of TAP01, TBN01, and the CST pipe house block walls, which are based upon the GMRS (PGA=0.50g).

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report No. ID Description Bldg Elev HCLPF2 Failure Mode Basis Related Components (g, PGA) Analyzed

9. PAL02 TDAFW Pump AUX 2000-00 1.75 Anchorage 14C4258- n/a CAL-004

10. RL001 REACTOR AUX CNTRL CB 2047-06 0.71 Anchorage 14C4258- RL002, RL005, RL006, RL017 thru PANEL CAL-004 RL026

11. SB102A W CABINET FOR AUX 2026-00 0.58 Anchorage 14C4258- n/a REACTOR TRIP SWG CAL-004 TRAIN-A

12. TAP01 Condensate Storage YARD 2000-00 0.30 Equipment 14C4258- n/a Tank capacity and CAL-002 anchorage

13. TBN01 RWST YRD 2000-00 0.33 Equipment 14C4258- n/a capacity and CAL-002 anchorage

14. XNG01 4.16-KV/480 V LOAD CB/CC 2000-00 0.45 Anchorage 14C4258-CENTER TRANSFORMER CAL-004 XNG01 FOR LC NG001

15. Generic Equipment >40 SE054A NIS Cabinet CB 2047-06 0.41 Equipment 14C4258- SE054C, SE054D capacity and CAL-005 anchorage SB037 7300 Series Three Bay CB 2047-06 0.41 Equipment 14C4258- SB038, SB041, SB078, SB079 Cabinets capacity and CAL-005 anchorage SA066A STATUS INDICATING CB 2047-06 0.41 Equipment 14C4258- SA066B SYS capacity and CAL-005 anchorage RP068 BOP Instrumentation CB 2047-06 0.41 Equipment 14C4258- n/a Panel capacity and CAL-005 anchorage RP053AC BOP Instrumentation CB 2047-06 0.41 Equipment 14C4258- RP053BC, RP053DB Rack capacity and CAL-005 anchorage RP081A T/C SUBCOOLING CB 2047-06 0.41 Equipment 14C4258- RP081B MONITOR CABINET capacity and CAL-005 anchorage

16. Generic Block Wall Seismic Interaction CTRL 2000 All block walls on CTRL CB 2000-00 1.17 Seismic interaction 14C4258- NB001, NK025, NG003, RP140, 2000 elev CAL-003 and RP334.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report No. ID Description Bldg Elev HCLPF2 Failure Mode Basis Related Components (g, PGA) Analyzed CTRL 2016 All block walls on CTRL CB 2016-00 0.87 Seismic interaction 14C4258- NK043, NN003, NN004, NN013, 2016 elev CAL-003 NN014, NK041, NN001, NK021, NN011, NK051, NK001, NK023, NK071, NK073, NK074 NK011, NK013, NK014, AB007, NK003, NK004, NK024 AUX 2000 2000 elev wall on AUX 2000-00 0.67 Seismic interaction 14C4258- RP209 column line AF north of CAL-003 Stair A-2 CST House CST Pipe house YARD 2000-00 0.40 Seismic interaction 14C4258- TAP01 masonry walls CAL-003

17. Generic Cabinets containing essential relays NG003C MCC NG03C BUS CB 2047-06 0.32 Functional 14C4258- NG004C capacity and host CAL-005 component capacity NG002B MCC NG02B BUS CB 2026-00 0.40 Functional 14C4258- NG001A capacity and host CAL-005 component capacity FC0219 LOCAL CONTROL PANEL AB 2000-00 0.41 Functional 14C4258- n/a FOR TD AFW PUMP capacity and host CAL-005 component capacity 7.0 Inaccessible Items 7.1 Identification of ESEL items inaccessible for walkdowns Sufficient access was provided for all ESEL items and no additional walkdowns are planned.

8.0 ESEP Conclusions and Results 8.1 Supporting Information Callaway has performed the ESEP as an interim action in response to the NRCs 50.54(f) letter [1]. It was performed using the methodologies in the NRC endorsed guidance in EPRI 3002000704 [2].

The ESEP provides an important demonstration of seismic margin and expedites plant safety enhancements through evaluations and potential near-term 12/2/14 Page 26 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report modifications of plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events.

The ESEP is part of the overall Callaway response to the NRCs 50.54(f) letter [1].

On March 12, 2014, NEI submitted to the NRC results of a study [14] of seismic core damage risk estimates based on updated seismic hazard information as it applies to operating nuclear reactors in the Central and Eastern United States (CEUS). The study concluded that "site-specific seismic hazards show that there

[...] has not been an overall increase in seismic risk for the fleet of U.S. plants" based on the re-evaluated seismic hazards. As such, the "current seismic design of operating reactors continues to provide a safety margin to withstand potential earthquakes exceeding the seismic design basis."

The NRCs May 9, 2014 NTTF 2.1 Screening and Prioritization letter [15]

concluded that the fleetwide seismic risk estimates are consistent with the approach and results used in the Gl-199 safety/risk assessment. The letter also stated that, As a result, the staff has confirmed that the conclusions reached in Gl-199 safety/risk assessment remain valid and that the plants can continue to operate while additional evaluations are conducted.

An assessment of the change in seismic risk for Callaway was included in the fleet risk evaluation submitted in the March 12, 2014 NEI letter [14] therefore, the conclusions in the NRCs May 9 letter [15] also apply to Callaway.

In addition, the March 12, 2014 NEI letter [14] provided an attached "Perspectives on the Seismic Capacity of Operating Plants," which: (1) assessed a number of qualitative reasons why the design of SSCs inherently contain margin beyond their design level, (2) discussed industrial seismic experience databases of performance of industry facility components similar to nuclear SSCs, and (3) discussed earthquake experience at operating plants.

The fleet of currently operating nuclear power plants was designed using conservative practices, such that the plants have significant margin to withstand large ground motions safely. This has been borne out for those plants that have actually experienced significant earthquakes. The seismic design process has inherent (and intentional) conservatisms which result in significant seismic margins within SSCs. These conservatisms are reflected in several key aspects of the seismic design process, including:

• Safety factors applied in design calculations

• Damping values used in dynamic analysis of SSCs

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

• Broadening criteria for in-structure response spectra

• Response spectra enveloping criteria typically used in SSC analysis and testing applications 12/2/14 Page 27 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report

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

• Bounding requirements in codes and standards

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

• Bounding testing requirements, and

• Ductile behavior of the primary materials (that is, not crediting the additional capacity of materials such as steel and reinforced concrete beyond the essentially elastic range, etc.).

These design practices combine to result in margins such that the SSCs will continue to fulfill their functions at ground motions well above the SSE.

The intent of the ESEP is to perform an interim action in response to the NRCs 50.54(f) letter [1] to demonstrate seismic margin through a review of a subset of the plant equipment that can be relied upon to protect the reactor core following beyond design basis seismic events. In order to complete the ESEP in an expedited amount of time, the RLGM used for the ESEP evaluation is a scaled version of the plants SSE rather than the actual GMRS. To more fully characterize the risk impacts of the seismic ground motion represented by the GMRS on a plant specific basis, a more detailed seismic risk assessment (SPRA or risk-based SMA) is to be performed in accordance with EPRI 1025287 [16]. As identified in the Callaway Seismic Hazard and GMRS submittal [7], Callaway screens in for a risk evaluation. The complete risk evaluation will more completely characterize the probabilistic seismic ground motion input into the plant, the plant response to that probabilistic seismic ground motion input, and the resulting plant risk characterization. Callaway will complete that evaluation in accordance with the schedule identified in NEIs letter dated April 9, 2013 [17]

and endorsed by the NRC in their May 7, 2013 letter [2].

8.2 Indication of Planned Modifications This report presents the seismic evaluation results for the ESEP as applied to Callaway Energy Center. A primary goal of the ESEP is to demonstrate that HCLPF seismic capacities of ESEL items exceed the RLGM seismic demand. For Callaway, the RLGM is equal to the SSE scaled-up by a 2.0 factor. The RLGM has a PGA of 0.40g at grade. Exceptions to this include the CST (TAP01) and RWST (TBN01),

which apply the GMRS (PGA of 0.50g) for HCLPF evaluation [10b].

Insights from the ESEP identified the following items (Table 8-1) where the HCLPF is below the RLGM and plant modifications will be made in accordance with EPRI 3002000704 [2] to enhance the seismic capacity of the plant.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Table 8-1: Equipment with HCLPF Capacities below the RLGM Requiring Modification 3

HCLPF Capacity ID Description (g, PGA) Failure Mode NG003C MCC NG03C BUS 0.32 Relay functionality NG004C MCC NG04C BUS 0.32 Relay functionality TAP01 Condensate Storage Tank 0.30 Anchorage TBN01 RWST 0.33 Anchorage 8.3 Modification Implementation Schedule Plant modifications will be performed in accordance with the schedule identified in NEI letter dated April 9, 2013 [15], which states that plant modifications not requiring a planned refueling outage will be completed by December 2016 and modifications requiring a refueling outage will be completed within two planned refueling outages after December 31, 2014.

Section 8.4 contains the regulatory commitment dates to complete planned plant modifications as a result of ESEP. Referencing Section 8.4, Actions 1 and 2 do not require a refueling outage and will be completed by December 31, 2016.

Action 3 requires a refueling outage and will be completed by the end of RF21, Spring 2016, as required to support FLEX implementation. Action 4 requires a refueling outage and will be completed no later than the end of the second refueling outage after 12/31/14, currently RF22 scheduled for Fall 2017.

8.4 Summary of Regulatory Commitments The following actions will be performed as a result of the ESEP.

Completion Action # Equipment ID Equipment Description Action Description Date 1 Modify FLEX Support Guidelines December 31, to include operator actions to 2016 reset relays with HCLPF values NG003C MCC NG03C BUS less than the RLGM.

2 Modify FLEX Support Guidelines December 31, to include operator actions to 2016 reset relays with HCLPF values NG004C MCC NG04C BUS less than the RLGM.

3 Install a new hardened End of RF21, TAP01 Condensate Storage Tank Condensate Storage Tank. Spring 2016 3

All HCLPFs based upon RLGM (PGA=0.40g) as the seismic margins earthquake with the exception of TAP01, TBN01, and the CST pipe house block walls, which are based upon the GMRS (PGA=0.50g).

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Completion Action # Equipment ID Equipment Description Action Description Date 4 Three step response in order of No later than priority: 1) Re-evaluate FLEX the end of the response strategies to eliminate second the need for the tank. 2) Re- refueling analyze the tank with the more outage after realistic median-centered 12/31/14, structural response based on the currently RF22 new GMRS which will be scheduled for generated once the Seismic PRA Fall 2017 starts, 3) Upgrade/replace the TBN01 RWST tank.

12/2/14 Page 30 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report 9.0 References

1. Letter from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, March 12, 2012.

ADAMS Accession No. ML12053A340.

2. Letter from E. J. Leeds, USNRC, to J. E. Pollock, NEI, Electric Power Research Institute Final Draft Report XXXXXX, Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic, as an Acceptable Alternative to the March 12, 2012, Information Request for Seismic Reevaluations, May 7, 2013.

3002000704; ADAMS Accession No. ML13106A331.

3. Callaway Overall Integrated Plan (OIP) in Response to the March 12, 2012, Commission Order EA-12-049.

a. Callaway Letter ULNRC-05962, Docket No. 50-483: Callaway Plant Unit 1 Union Electric Co. Facility Operating License NPF-30 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), February 18, 2013, (ADAMS Accession Number ML13063A459).

b. Callaway Letter ULNRC-06024, Docket No. 50-483: Callaway Plant Unit 1 Union Electric Co. Facility Operating License NPF-30 First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), August 29, 2013, (ADAMS Accession Number ML13242A239).

c. Callaway Letter ULNRC-06087, Docket No. 50-483: Callaway Plant Unit 1 Union Electric Co. Facility Operating License NPF-30 Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), February 26, 2014, (ADAMS Accession Number ML14057A770).

d. Callaway Letter ULNRC-06135, Docket No. 50-483: Callaway Plant Unit 1 Union Electric Co. Facility Operating License NPF-30 Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-12/2/14 Page 31 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Design-Basis External Events (Order Number EA-12-049), August 28, 2014, (ADAMS Accession Number ML13063A459).

4. SCP-14-82, Transmittal of Updated Callaway ESEL for ESEP Report, December 2014.

5. S&A report 14C4258-RPT-003 Rev. 0, Callaway ESEL Relay Assessment, December 2014.

6. CEC FSAR, Rev. OL-20, Callaway Energy Center Final Safety Analysis Report (FSAR). December 2013.

7. Callaway Seismic Hazard and GMRS submittal, dated March 31, 2014.

8. Electric Power Research Institute Report, NP-6041-SLR1, Revision 1, A Methodology for Assessment of Nuclear Power Plant Seismic Margin, 1991.

9. Electric Power Research Institute Report, TR-103959, Methodology for Developing Seismic Fragilities, 1994.

10. S&A Calculations:

a) 14C4258-CAL-001 Rev. 0, Generation of Scaled In-Structure Response Spectra for Callaway, December 2014.

b) 14C4258-CAL-002 Rev. 0, Seismic Capacity of CST (TAP01) and RWST (TBN01), December 2014.

c) 14C4258-CAL-003 Rev. 0, HCLPF Analyses for Block Walls, December 2014.

d) 14C4258-CAL-004 Rev. 0, HCLPF Seismic Capacity Evaluations for Selected Equipment, December 2014.

e) 14C4258-CAL-005 Rev. 0, HCLPF Analysis of Components Based on Seismic Test Data, December 2014.

f) 14C4258-RPT-002, Revision 1, Seismic Evaluation of Equipment at CEC for the Expedited Seismic Evaluation Process, December 2014.

11. ULNRC-3232, Callaway Plant Individual Plant Examination of External Events (IPEEE), June 1995.

12. Electric Power Research Institute Report, NP-5223-SL, Revision 1, Generic Seismic Ruggedness of Power Plant Equipment, 1991.

13. Electric Power Research Institute Technical Report, TR-1019200, Seismic Fragility Applications Guide Update, 2009.

14. Letter from A. R. Pietrangelo, NEI, to D. L Skeen, USNRC, Seismic Risk Estimates for Plants in the Central and Eastern United States, March 12, 2014. ADAMS Accession No. ML14083A584.

15. NRC (E Leeds) Letter to All Power Reactor Licensees et al., Screening and Prioritization Results Regarding Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(F) Regarding Seismic Hazard Re-Evaluations for 12/2/14 Page 32 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Recommendation 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-Ichi Accident, May 9, 2014.

16. Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic. EPRI, Palo Alto, CA: February 2013. 1025287.

17. Letter from A. R. Pietrangelo, NEI, to D. L. Skeen, USNRC, Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations, April 9, 2013.

ADAMS Accession No. ML13107B386.

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to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Attachment A Callaway ESEL 12/2/14 Page 34 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State Mechanical ESEL Items 1 TAP01 Condensate Storage CST provides AFW suction for Tank Operable Operable the first 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> 2 PAL02 TDAFW Pump Not TDAFW provides pump power Operating Operating to move AFW to SG 3 ALHV0034 MOV MOV required to isolate flow Open Closed path 4 ALHV0035 MOV MOV required to isolate flow Open Closed path 5 ALPI0029 Suction Pressure Indicator 6 ALFE0049 TDAFWP Miniflow Flow Element 7 ALFI0049 TDAFWP Miniflow Flow Indicator 8 APLV0002 Level Control Valve Open Closed Fail closed valve 9 ALPI0020 TDAFW Pump Discharge Pressure Indicator 10 ALHV0012 Air Operated Valve Valve may be operated to Open Open throttle AFW flow to SG 11 ALFE0004 Flow Element AFW flow related hardware 12 ALFT0004 Flow Transmitter AFW flow related hardware 13 ALFT0011 Flow Transmitter AFW flow related hardware 14 AEFV0041 Feedwater Isolation Valve Open Closed Fail closed valve 15 ALHV0010 Air Operated Valve Valve may be operated to Open Open throttle AFW flow to SG 16 ALFE0003 Flow Element 17 ALFT0003 Flow Transmitter AFW flow related hardware 18 ALFT0009 Flow Transmitter AFW flow related hardware 19 AEFV0040 Feedwater Isolation Valve Open Closed Fail closed valve 20 ALHV0008 Air Operated Valve Valve may be operated to Open Open throttle AFW flow to SG 21 ALFE0002 Flow Element AFW flow related hardware 22 ALFT0002 Flow Transmitter AFW flow related hardware 23 ALFT0007 Flow Transmitter AFW flow related hardware 12/2/14 Page 35 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 24 AEFV0039 Feedwater Isolation Valve Open Closed Fail closed valve 25 ALHV0006 Air Operated Valve Valve may be operated to Open Open throttle AFW flow to SG 26 ALFE0001 Flow Element AFW flow related hardware 27 ALFT0001 Flow Transmitter AFW flow related hardware 28 AEFV0042 Feedwater Isolation Valve Open Closed Fail closed valve 29 ABHV0005 Air Operated Valve TDAFW controls and steam Closed Fail Open flow controls. Fails open.

30 ABHV0048 Air Operated Valve Fail TDAFW controls and steam Open Closed flow controls. Fails closed.

31 ABHV0006 Air Operated Valve TDAFW controls and steam Closed Fail Open flow controls. Fails open.

32 ABHV0049 Air Operated Valve Fail TDAFW controls and steam Open Closed flow controls. Fails closed.

33 FCPI0311 Pressure Indicator 34 FCLT0010 Level Indicator Needed to prevent water intrusion in TDAFWP 35 FCFV0310 Level Control Valve Needed to prevent water Fail intrusion in TDAFWP. Valve Open Closed fails closed.

36 FCHV0312 Trip and Throttle Valve TDAFW controls and steam flow controls. Operation of this manual valve should be accounted for in operating Closed Operating procedures.

37 Speed Speed Governor TDAFW controls and steam Governor Standby Operating flow controls.

38 FCFV0313 Speed Governor Valve TDAFW controls and steam Open Operating flow controls.

39 KFC02 AFW Pump Turbine Not TDAFW controls and steam Operating Operating flow controls.

40 BBPV8702A RHR TO RCS Closed Open 41 EMHV8803B MOTOR-OPERATED Primary flow path, can be VALVE EMHV8803B Closed Open operated manually 42 EMHV8801B MOTOR-OPERATED Primary flow path, can be VALVE EMHV8801B Closed Open operated manually 12/2/14 Page 36 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 43 EMFE0924 ECCS FLOW TO RCS COLD-LEG 1 44 EMFE0925 ECCS FLOW TO RCS COLD-LEG 2 45 EMFE0926 ECCS FLOW TO RCS COLD-LEG 3 46 EMFE0927 ECCS FLOW TO RCS COLD-LEG 4 47 TBN01 RWST Secondary source for core makeup after BAT exhausted 48 BNLT0930 RWST Level Transmitter Monitor RWST level 49 EJHCV0606 RHR Heat Exchanger A Outlet Isolation Valve Fail Open Closed Can be operated manually 50 TBG03A Boric Acid Tank 51 BGLT0102 BORIC ACID TANK A LEV Monitor BAT level 52 BGLI0102 BORIC ACID TANK A LEV Local level indicator 53 EJFCV0610 RHR Pump A miniflow Valve Open Closed 54 EJFCV0610 RHR Pump A miniflow Valve Open Closed 55 EJFCV0610 RHR Pump A miniflow Valve Open Closed Electrical ESEL Items 56 NB001 4.16KV SWGR NB001 This component is powered by (Class 1E, Train A) the FLEX DG in Phase 3 as stated in Sec. 8 of the Callaway N/A N/A Plant FLEX Integrated Plan 57 NB00101 4.16 kV FDR BKR FOR This component is powered by RHRP-A DPEJ01A the FLEX DG in Phase 3 as (Residual Heat stated in Sec. 8 of the Callaway Removal Pump A)

N/A N/A Plant FLEX Integrated Plan 58 NB00107 4.16 kV FDR BKR FOR This component is powered by CCWP-A DPEG01A the FLEX DG in Phase 3 as (Component Cooling stated in Sec. 8 of the Callaway Water Pump A)

N/A N/A Plant FLEX Integrated Plan 12/2/14 Page 37 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 59 NB00109 4.16 kV FLEX GEN (Phase 3) TIE-IN POINT This breaker position is the tie-(BKR) FOR TRAIN A in point for the Phase 3 FLEX N/A N/A diesel generator 60 NB00113 4.16 kV FDR BKR FOR This component is powered by XFMR XNG01 (4160 V the FLEX DG in Phase 3 as to 480 V for LC stated in Sec. 8 of the Callaway NG001)

N/A N/A Plant FLEX Integrated Plan 61 XNG01 4.16-KV/480 V LOAD This component is powered by CENTER the FLEX DG in Phase 3 as TRANSFORMER stated in Sec. 8 of the Callaway XNG01 FOR LC NG001 N/A N/A Plant FLEX Integrated Plan 62 NG001 480 V LOAD CENTER This component is powered by NG01 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 63 NG00101 MAIN BKR FOR LC This component is powered by NG01 the FLEX DG in Phase 3 as stated in Sec. 8 of the Callaway N/A N/A Plant FLEX Integrated Plan 64 NG00103 FDR BKR FOR 125 V This component is powered by VITAL BATTERY the FLEX DG, first Phase 2, CHARGER NK021 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 65 NG00112 FLEX 500 kW TIE IN This component is powered by BRK (Phase 2 the FLEX DG in Phase 2 as connection point) stated in Sec. 8 of the Callaway N/A N/A Plant FLEX Integrated Plan 66 NG00116 TIE BKR (CONNECTS This component is powered by NG01 AND NG03) the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 67 NG003 480 V LOAD CENTER This component is powered by NG03 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 12/2/14 Page 38 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 68 NG00303 FDR BKR FOR 125 V This component is powered by VITAL BATTERY the FLEX DG, first Phase 2, CHARGER NK023 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 69 NK021 125 V BATTERY This component is powered by CHARGER NK021 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 70 NK071 TRANSFER SWITCH This component is powered by BUS NK01 BATTERY the FLEX DG, first Phase 2, CHARGER NK21/NK25 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 71 NK001 125 VDC BUS This component is powered SWITCHBOARD NK001 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 72 NK00102 FDR BKR FROM BATT This component is powered by CHGR NK021 TO the FLEX DG, first Phase 2, NK001 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 73 NK00104 MAIN BREAKER FOR This component is powered CNTRL AND DIST PNL during ALL phases of the FLEX NK041 (PART OF strategy as stated in Sec. 8 of SWBD NK001) the Callaway Plant FLEX N/A N/A Integrated Plan 74 NK00105 MAIN BREAKER FOR This component is powered CNTRL AND DIST PNL during ALL phases of the FLEX NK051 (PART OF strategy as stated in Sec. 8 of SWBD NK001) the Callaway Plant FLEX N/A N/A Integrated Plan 75 NK011 125 V BATTERY NK011 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 39 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 76 NK00101 ISOLATION BKR FOR This component is powered BATTERY NK011 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 77 NK00111 FDR BKR FOR This component is powered INVERTER NN011 during ALL phases of the FLEX (PART OF SWBD strategy as stated in Sec. 8 of NK001) the Callaway Plant FLEX N/A N/A Integrated Plan 78 NN011 7.5KVA INVERTER This component is powered (FED FROM BATT during ALL phases of the FLEX CHARGER NK021) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 79 NN001 Class 1E AC DIST This component is powered SWBD NN01 (SEP GRP during ALL phases of the FLEX

1) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 80 SA066A STATUS INDICATING This component is powered SYS during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 81 SENY0060A NEUTRON FLUX This component is powered MONITORING SYSTEM during ALL phases of the FLEX DETECTOR AMPLIFIER strategy as stated in Sec. 8 of SENY 60A the Callaway Plant FLEX N/A N/A Integrated Plan 82 SENY0060B NEUTRON FLUX This component is powered MONITORING SYSTEM during ALL phases of the FLEX DETECTOR AMPLIFIER strategy as stated in Sec. 8 of SENY 60B the Callaway Plant FLEX N/A N/A Integrated Plan 83 SB038 W PROCESS ANALOG This component is powered PROTECTION SET CAB- during ALL phases of the FLEX 01 strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 40 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 84 SE054A W NUC INSTM NIS 1 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 85 RP053AC BOP This component is powered INSTRUMENTATION during ALL phases of the FLEX RACK (TERMINATION strategy as stated in Sec. 8 of AREA) the Callaway Plant FLEX N/A N/A Integrated Plan 86 SB078 RPV LEVEL INSTR SYS This component is powered (RVLIS) PROC PROT during ALL phases of the FLEX SYS CABINET strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 87 RP081A T/C SUBCOOLING This component is powered MONITOR CABINET during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 88 NK041 CNTRL & INSTR DIST This component is powered SWBD NK041 (CLASS during ALL phases of the FLEX 1E 125 VDC) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 89 NE107 DIESEL GEN PNL This component is powered NE107 & FIELD during ALL phases of the FLEX FLASHING strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 90 RL005 TURBINE GENERATOR This component is powered AND FW CONSOLE during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 91 RL006 TURBINE GENERATOR This component is powered AND FW CONSOLE during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 41 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 92 RP315 DC DIST PNL RP315 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 93 RL023 TURBINE GENERATOR This component is powered AND FW MCB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 94 RL024 TURBINE GENERATOR This component is powered AND FW MCB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 95 RL017 ESF MCB This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 96 RL018 ESF MCB This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 97 RL019 ESF MCB This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 98 RL020 ESF MCB This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 99 RL001 REACTOR COOLANT This component is powered AND SUPT SYS during ALL phases of the FLEX CONSOLE strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 42 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 100 RL002 REACTOR COOLANT This component is powered AND SUPT SYS during ALL phases of the FLEX CONSOLE strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 101 RL025 TURBINE GENERATOR This component is powered AND FW MCB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 102 RL026 TURBINE GENERATOR This component is powered AND FW MCB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 103 RP317 FUSED 125 VDC DIST This component is powered PNL RP317 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 104 NK051 CNTRL & INSTR DIST This component is powered SWBD NK051 (CLASS during ALL phases of the FLEX 1E 125 VDC) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 105 BBPCV0455A BBPCV0455A PORV This component is powered SOLENOID FAILS TO during ALL phases of the FLEX OPEN ON DEMAND strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 106 RL021 REACTOR AUX CNTRL This component is powered PANEL during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 107 RL022 REACTOR AUX CNTRL This component is powered PANEL during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 43 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 108 KJ0121 DIESEL GAUGE AND This component is powered CONTROL PANEL during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 109 RP209 B AUXILIARY RELAY This component is powered RACK during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 110 RP289 DC DIST PNL RP289 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 111 RP068 MISC BOP This component is powered INSTRUMENT RACK during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 112 RP330 AUX RELAY RACK This component is powered RP330 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 113 RP332 B AUXILIARY RELAY This component is powered RACK during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 114 NK051A EM'CY LIGHTING DIST This component is powered SWBD NK051A during ALL phases of the FLEX (SUBPNL OF NK051) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 115 NK023 125 V BATTERY This component is powered by CHARGER NK023 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 12/2/14 Page 44 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 116 NK073 TRANSFER SWITCH This component is powered by BUS NK03 BATTERY the FLEX DG, first Phase 2, CHARGER NK23/NK25 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 117 NK003 125 VDC BUS This component is powered SWITCHBOARD NK003 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 118 NK00302 FDR BKR FROM BATT This component is powered by CHGR NK023 TO the FLEX DG, first Phase 2, NK003 then in Phase 3, as stated in Sec. 8 of the Callaway Plant N/A N/A FLEX Integrated Plan 119 NK00304 MAIN BREAKER FOR This component is powered CNTRL AND DIST PNL during ALL phases of the FLEX NK043 (PART OF strategy as stated in Sec. 8 of SWBD NK003) the Callaway Plant FLEX N/A N/A Integrated Plan 120 NK013 125 V BATTERY NK013 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 121 NK00301 ISOLATION BKR FOR This component is powered BATTERY NK013 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 122 NK00311 FDR BKR FOR This component is powered INVERTER NN013 during ALL phases of the FLEX (PART OF SWBD strategy as stated in Sec. 8 of NK003) the Callaway Plant FLEX N/A N/A Integrated Plan 123 NN013 7.5KVA INVERTER This component is powered (FED FROM BATT during ALL phases of the FLEX CHARGER NK023) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 12/2/14 Page 45 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 124 NN003 Class 1E AC DIST This component is powered SWBD NN03 (SEP GRP during ALL phases of the FLEX

3) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 125 RP053DB BOP INSTR RACK This component is powered RP053DB during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 126 SB037 W PROCESS ANALOG This component is powered PROTECTION SET CAB- during ALL phases of the FLEX 03 strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 127 SE054C W NUC INSTM NIS 3 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 128 NK043 CNTRL & INSTR DIST This component is powered SWBD NK043 (CLASS during ALL phases of the FLEX 1E 125 VDC) strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 129 AB007 Aux Relay Rack This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Plant FLEX N/A N/A Integrated Plan 130 NG00109 FDR BKR FOR 125 V SWING BATTERY This component provides CHARGER NK025 power to NK025 and, in turn, N/A N/A Separation Group 1.

131 NK025 125 V BATTERY CHARGER NK025 The A-Train swing charger will (Swing Battery be used to power Separation Charger)

N/A N/A Group 1.

132 NG002 480 V LOAD CENTER This component is powered by NG02 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 12/2/14 Page 46 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 133 NG00212 FLEX 500 kW TIE IN This component is powered by BKR from FD201 the FLEX DG, first Phase 2, (Phase 2 connection then in Phase 3, as stated in point) Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 134 NG00203 FDR BKR FOR 125 V This component is powered by VITAL BATTERY the FLEX DG, first Phase 2, CHARGER NK024 then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 135 NK024 125 V BATTERY This component is powered by CHARGER NK024 the FLEX DG, first Phase 2, then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 136 NK074 TRANSFER SWITCH This component is powered by BUS NK04 BATTERY the FLEX DG, first Phase 2, CHARGER NK24/NK26 then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 137 NK004 125 VDC BUS This component is powered SWITCHBOARD NK004 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 138 NK00402 FDR BKR FROM BATT This component is powered by CHGR NK024 TO the FLEX DG, first Phase 2, NK004 then in Phase 3, as stated in Sec. 8 of the Callaway N/A N/A Integrated FLEX Plan 139 NK014 125 V BATTERY NK014 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 140 NK00401 ISOLATION BKR FOR This component is powered BATTERY NK014 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 12/2/14 Page 47 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 141 NK00411 FDR BKR FOR This component is powered INVERTER NN011 during ALL phases of the FLEX (PART OF SWBD strategy as stated in Sec. 8 of NK004) the Callaway Integrated FLEX N/A N/A Plan 142 NN014 7.5KVA INVERTER This component is powered (FED FROM BATT during ALL phases of the FLEX CHARGER NK024) strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 143 NN004 Class 1E AC DIST This component is powered SWBD NN04 (SEP GRP during ALL phases of the FLEX

4) strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 144 RP147B BOP Instrumentation This component is powered Rack RP147B during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 145 SENY0061A NEUTRON FLUX This component is powered MONITORING SYSTEM during ALL phases of the FLEX DETECTOR AMPLIFIER strategy as stated in Sec. 8 of SENY 61A the Callaway Integrated FLEX N/A N/A Plan 146 SENY0061B NEUTRON FLUX This component is powered MONITORING SYSTEM during ALL phases of the FLEX DETECTOR AMPLIFIER strategy as stated in Sec. 8 of SENY 61B the Callaway Integrated FLEX N/A N/A Plan 147 SE054D W NUC INSTM NIS 4 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 148 SB041 W PROCESS ANALOG This component is powered PROTECTION SET CAB- during ALL phases of the FLEX 04 strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 12/2/14 Page 48 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Equipment Operating State Item Normal Desired Notes/Comments[1]

ID Description Num State State 149 RP053BC BOP Instrumentation This component is powered Rack RP053BC during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 150 SB079 RVLIS Process Cabinet This component is powered SB079 during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 151 RP081B Subcooling Monitor This component is powered Cabinet during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 152 SB148B W PROCESS This component is powered PROTECTION (Fire during ALL phases of the FLEX Isolation) strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 153 SA066B STATUS INDICATING This component is powered SYS during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 154 RP140 PANEL RP140 This component is powered during ALL phases of the FLEX strategy as stated in Sec. 8 of the Callaway Integrated FLEX N/A N/A Plan 12/2/14 Page 49 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Attachment B ESEP HCLPF Values and Failure Modes Tabulation HCLPF values are listed in Table B-1. These notes are applicable:

1. The listed HCLPF value is for comparison to the horizontal PGA at the bedrock surface.

2. Items covered by the NP-6041-SL rule of the box (ROB) are identified in Table A-2 [9].

In each case, the HCLPF value for the parent item applies.

3. For the CST and RWST only (TAP01 and TBN01, respectively), the applied ground motion was based on the GMRS (PGA = 0.50g).

4. Where an anchorage HCLPF is performed but the component per se is screened, the equipment capacity is assigned based upon the 1.2g peak spectral acceleration coinciding with the 2nd screening lane of NP-6041-SL. Since the Callaway RLGM has a peak spectral acceleration of 1.2g in the building frequency range of interest (see Section 6.2.1) and PGA of 0.40g [Ref. 7], the equipment capacity is assigned as 0.40g PGA.

5. As a result of the relay chatter evaluation, additional items were added to the ESEL list for evaluation.

12/2/14 Page 50 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report Table B-1: ESEL HCLPF Values ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number Condensate Storage Tank capacity evaluated in 14C4258-CAL-002. Block wall 1 TAP01 YARD 2000-00 0.3 Anchorage Tank evaluated per 14C4258-CAL-003.

Component per se screened. Anchorage evaluated per 2 PAL02 TDAFW Pump AUX 2000-00 0.4 Equipment Capacity 14C4258-CAL-004.

3 ALHV0034 MOV AUX 1988-00 >RLGM Screened SRT disposition 4 ALHV0035 MOV AUX 1988-00 >RLGM Screened SRT disposition Suction Pressure 5 ALPI0029 AUX 2000-00 >RLGM Screened SRT disposition Indicator TDAFWP Miniflow Flow 6 ALFE0049 AUX 2000-00 >RLGM Screened SRT disposition Element TDAFWP Miniflow Flow 7 ALFI0049 AUX 2000-00 >RLGM Screened SRT disposition Indicator 8 APLV0002 Level Control Valve YARD 2000-00 >RLGM Screened SRT disposition TDAFW Pump Discharge 9 ALPI0020 AUX 2000-00 >RLGM Screened SRT disposition Pressure Indicator 10 ALHV0012 Air Operated Valve AUX 2004-07 >RLGM Screened SRT disposition 11 ALFE0004 Flow Element AUX 2000-00 >RLGM Screened SRT disposition 12 ALFT0004 Flow Transmitter AUX 2016-01 >RLGM Screened SRT disposition 13 ALFT0011 Flow Transmitter AUX 2000-00 >RLGM Screened SRT disposition Feedwater Isolation 14 AEFV0041 AUX 2028-00 >RLGM Screened SRT disposition Valve 15 ALHV0010 Air Operated Valve AUX 2002-09 >RLGM Screened SRT disposition 16 ALFE0003 Flow Element AUX 2000-00 >RLGM Screened SRT disposition 17 ALFT0003 Flow Transmitter AUX 2016-00 >RLGM Screened SRT disposition 18 ALFT0009 Flow Transmitter AUX 2000-00 >RLGM Screened SRT disposition Feedwater Isolation 19 AEFV0040 AUX 2027-10 >RLGM Screened SRT disposition Valve 20 ALHV0008 Air Operated Valve AUX 2004-00 >RLGM Screened SRT disposition 12/2/14 Page 51 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number 21 ALFE0002 Flow Element AUX 2000-00 >RLGM Screened SRT disposition 22 ALFT0002 Flow Transmitter AUX 2016-00 >RLGM Screened SRT disposition 23 ALFT0007 Flow Transmitter AUX 2000-00 >RLGM Screened SRT disposition Feedwater Isolation 24 AEFV0039 AUX 2028-00 >RLGM Screened SRT disposition Valve 25 ALHV0006 Air Operated Valve AUX 2001-06 >RLGM Screened SRT disposition 26 ALFE0001 Flow Element AUX 2000-00 >RLGM Screened SRT disposition 27 ALFT0001 Flow Transmitter AUX 2015-00 >RLGM Screened SRT disposition Feedwater Isolation 28 AEFV0042 AUX 2027-10 >RLGM Screened SRT disposition Valve 29 ABHV0005 Air Operated Valve AUX 2027-10 >RLGM Screened SRT disposition 30 ABHV0048 Air Operated Valve AUX 2027-10 >RLGM Screened SRT disposition 31 ABHV0006 Air Operated Valve AUX 2027-10 >RLGM Screened SRT disposition 32 ABHV0049 Air Operated Valve AUX 2027-10 >RLGM Screened SRT disposition 33 FCPI0311 Pressure Indicator AUX 2000-00 >RLGM Screened SRT disposition 34 FCLT0010 Level Indicator AUX 2000-00 >RLGM Screened SRT disposition 35 FCFV0310 Level Control Valve AUX 1988-00 >RLGM Screened SRT disposition 36 FCHV0312 Trip and Throttle Valve AUX 2000-00 >RLGM Screened SRT disposition Item is ROB to PAL02. Component per se screened. Anchorage 37 Speed Governor Speed Governor AUX 2000-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

Item is ROB to PAL02. Component per se screened. Anchorage 38 FCFV0313 Speed Governor Valve AUX 2000-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

Item is ROB to PAL02. Component per se screened. Anchorage 39 KFC02 AFW Pump Turbine AUX 2000-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

40 BBPV8702A RHR TO RCS RB 2007-09 >RLGM Screened SRT disposition MOTOR-OPERATED 41 EMHV8803B AUX 1975-08 >RLGM Screened SRT disposition VALVE EMHV8803B MOTOR-OPERATED 42 EMHV8801B AUX 2002-00 >RLGM Screened SRT disposition VALVE EMHV8801B 12/2/14 Page 52 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number ECCS FLOW TO RCS 43 EMFE0924 RB 1998-06 >RLGM Screened SRT disposition COLD-LEG 1 ECCS FLOW TO RCS 44 EMFE0925 RB 1998-06 >RLGM Screened SRT disposition COLD-LEG 2 ECCS FLOW TO RCS 45 EMFE0926 RB 1998-06 >RLGM Screened SRT disposition COLD-LEG 3 ECCS FLOW TO RCS 46 EMFE0927 RB 1998-06 >RLGM Screened SRT disposition COLD-LEG 4 47 TBN01 RWST YRD 2000-00 0.33 Anchorage Tank capacity evaluated in 14C4258-CAL-002.

48 BNLT0930 RWST Level Transmitter YRD 1993-00 >RLGM Screened SRT disposition RHR Heat Exchanger A 49 EJHCV0606 AUX 2001-06 >RLGM Screened SRT disposition Outlet Isolation Valve 50 TBG03A Boric Acid Tank AUX 1974-00 >RLGM Screened SRT disposition 51 BGLT0102 BORIC ACID TANK A LEV AUX 1968-01 >RLGM Screened SRT disposition Item is ROB to RL001. Component per se screened. Anchorage 52 BGLI0102 BORIC ACID TANK A LEV CB 2047-06 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

RHR Pump A miniflow 53 EJFCV0610 AUX 1968-01 >RLGM Screened SRT disposition Valve Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 4.16KV SWGR NB001 56 NB001 CB 2000-00 0.41 Anchorage evaluated per 14C4258-CAL-005 Block wall evaluated per (Class 1E, Train A) 14C4258-CAL-003.

4.16 kV FDR BKR FOR Item is ROB to NB001. Equipment capacity evaluated in RHRP-A DPEJ01A 57 NB00101 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-(Residual Heat Removal 005. Block wall evaluated per 14C4258-CAL-003.

Pump A) 4.16 kV FDR BKR FOR Item is ROB to NB001. Equipment capacity evaluated in CCWP-A DPEG01A 58 NB00107 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-(Component Cooling 004. Block wall evaluated per 14C4258-CAL-003.

Water Pump A) 4.16 kV FLEX GEN Item is ROB to NB001. Equipment capacity evaluated in 59 NB00109 (Phase 3) TIE-IN POINT CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-(BKR) FOR TRAIN A 004. Block wall evaluated per 14C4258-CAL-003.

4.16 kV FDR BKR FOR Item is ROB to NB001. Equipment capacity evaluated in 60 NB00113 XFMR XNG01 (4160 V to CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-480 V for LC NG001) 004. Block wall evaluated per 14C4258-CAL-003.

12/2/14 Page 53 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number 4.16-KV/480 V LOAD Component per se screened. Anchorage evaluated per 61 XNG01 CENTER TRANSFORMER CB/CC 2000-00 0.4 Equipment Capacity 14C4258-CAL-004.

XNG01 FOR LC NG001 480 V LOAD CENTER Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 62 NG001 CB/CC 2000-00 0.41 Anchorage NG01 evaluated per 14C4258-CAL-005.

Item is ROB to NG001. Equipment capacity evaluated in 63 NG00101 MAIN BKR FOR LC NG01 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-004.

FDR BKR FOR 125 V Item is ROB to NG001. Equipment capacity evaluated in 64 NG00103 VITAL BATTERY CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHARGER NK021 004.

FLEX 350 kW TIE IN BRK Item is ROB to NG001. Equipment capacity evaluated in 65 NG00112 (Alternate Phase 2 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-connection point) 004.

Item is ROB to NG001. Equipment capacity evaluated in TIE BKR (CONNECTS 66 NG00116 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NG01 AND NG03) 005.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 480 V LOAD CENTER 67 NG003 CB/CC 2000-00 0.41 Anchorage evaluated per 14C4258-CAL-005. Block wall evaluated per NG03 14C4258-CAL-003.

FDR BKR FOR 125 V Item is ROB to NG003. Equipment capacity evaluated in 68 NG00303 VITAL BATTERY CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHARGER NK023 005. Block wall evaluated per 14C4258-CAL-003.

125 V BATTERY Component per se screened. Anchorage evaluated per 69 NK021 CB/CC 2016-00 0.4 Equipment Capacity CHARGER NK021 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

TRANSFER SWITCH BUS Component per se screened. Block wall evaluated per 70 NK071 NK01 BATTERY CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

CHARGER NK21/NK25 Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 125 VDC BUS 71 NK001 CB/CC 2016-00 0.71 Anchorage evaluated per 14C4258-CAL-004. Block wall evaluated per SWITCHBOARD NK001 14C4258-CAL-003.

Item is ROB to NK001. Equipment capacity evaluated in FDR BKR FROM BATT 72 NK00102 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHGR NK021 TO NK001 004. Block wall evaluated per 14C4258-CAL-003.

MAIN BREAKER FOR Item is ROB to NK001. Equipment capacity evaluated in CNTRL AND DIST PNL 73 NK00104 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK041 (PART OF SWBD 004. Block wall evaluated per 14C4258-CAL-003.

NK001) 12/2/14 Page 54 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number MAIN BREAKER FOR Item is ROB to NK001. Equipment capacity evaluated in CNTRL AND DIST PNL 74 NK00105 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK051 (PART OF SWBD 004. Block wall evaluated per 14C4258-CAL-003.

NK001)

Component per se screened. Anchorage evaluated per 75 NK011 125 V BATTERY NK011 CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

Item is ROB to NK001. Equipment capacity evaluated in ISOLATION BKR FOR 76 NK00101 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-BATTERY NK011 004. Block wall evaluated per 14C4258-CAL-003.

FDR BKR FOR INVERTER Item is ROB to NK001. Equipment capacity evaluated in 77 NK00111 NN011 (PART OF SWBD CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK001) 004. Block wall evaluated per 14C4258-CAL-003.

7.5KVA INVERTER (FED Component per se screened. Anchorage evaluated per 78 NN011 FROM BATT CHARGER CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

NK021)

Class 1E AC DIST SWBD Component per se screened. Anchorage evaluated per 79 NN001 CB/CC 2016-00 0.4 Equipment Capacity NN01 (SEP GRP 1) 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 80 SA066A STATUS INDICATING SYS CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

NEUTRON FLUX MONITORING SYSTEM 81 SENY0060A AUX 2026-00 >RLGM Screened SRT disposition DETECTOR AMPLIFIER SENY 60A NEUTRON FLUX MONITORING SYSTEM 82 SENY0060B AUX 2026-00 >RLGM Screened SRT disposition DETECTOR AMPLIFIER SENY 60B W PROCESS ANALOG Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 83 SB038 PROTECTION SET CAB- CB/CC 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

01 Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 84 SE054A W NUC INSTM NIS 1 CB/CC 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

BOP INSTRUMENTATION Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 85 RP053AC CB 2047-06 0.41 Anchorage RACK (TERMINATION evaluated per 14C4258-CAL-005.

AREA)

RPV LEVEL INSTR SYS Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 86 SB078 (RVLIS) PROC PROT SYS CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

CABINET 12/2/14 Page 55 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number T/C SUBCOOLING Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 87 RP081A CB 2047-06 0.41 Anchorage MONITOR CABINET evaluated per 14C4258-CAL-005.

CNTRL & INSTR DIST Component per se screened. Anchorage evaluated per 88 NK041 SWBD NK041 (CLASS 1E CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

125 VDC)

DIESEL GEN PNL NE107 89 NE107 DGB 2000-00 >RLGM Screened SRT disposition

& FIELD FLASHING TURBINE GENERATOR Component per se screened. Anchorage evaluated per 90 RL005 CB 2047-06 0.4 Equipment Capacity AND FW CONSOLE 14C4258-CAL-004.

TURBINE GENERATOR Component per se screened. Anchorage evaluated per 91 RL006 CB 2047-06 0.4 Equipment Capacity AND FW CONSOLE 14C4258-CAL-004.

92 RP315 DC DIST PNL RP315 ESW Pumphouse 2000-00 >RLGM Screened SRT disposition TURBINE GENERATOR Component per se screened. Anchorage evaluated per 93 RL023 CB 2047-06 0.4 Equipment Capacity AND FW MCB 14C4258-CAL-004.

TURBINE GENERATOR Component per se screened. Anchorage evaluated per 94 RL024 CB 2047-06 0.4 Equipment Capacity AND FW MCB 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 95 RL017 ESF MCB CB 2047-06 0.4 Equipment Capacity 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 96 RL018 ESF MCB CB 2047-06 0.4 Equipment Capacity 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 97 RL019 ESF MCB CB 2047-06 0.4 Equipment Capacity 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 98 RL020 ESF MCB CB 2047-06 0.4 Equipment Capacity 14C4258-CAL-004.

REACTOR COOLANT Component per se screened. Anchorage evaluated per 99 RL001 CB 2047-06 0.4 Equipment Capacity AND SUPT SYS CONSOLE 14C4258-CAL-004.

REACTOR COOLANT Component per se screened. Anchorage evaluated per 100 RL002 CB 2047-06 0.4 Equipment Capacity AND SUPT SYS CONSOLE 14C4258-CAL-004.

TURBINE GENERATOR Component per se screened. Anchorage evaluated per 101 RL025 CB 2047-06 0.4 Equipment Capacity AND FW MCB 14C4258-CAL-004.

TURBINE GENERATOR Component per se screened. Anchorage evaluated per 102 RL026 CB 2047-06 0.4 Equipment Capacity AND FW MCB 14C4258-CAL-004.

FUSED 125 VDC DIST 103 RP317 UHS 2000-00 >RLGM Screened SRT disposition PNL RP317 12/2/14 Page 56 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number CNTRL & INSTR DIST Component per se screened. Anchorage evaluated per 104 NK051 SWBD NK051 (CLASS 1E CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

125 VDC)

BBPCV0455A PORV 105 BBPCV0455A SOLENOID FAILS TO RB 2070-00 >RLGM Screened SRT disposition OPEN ON DEMAND REACTOR AUX CNTRL Component per se screened. Anchorage evaluated per 106 RL021 CB 2047-06 0.4 Equipment Capacity PANEL 14C4258-CAL-004.

REACTOR AUX CNTRL Component per se screened. Anchorage evaluated per 107 RL022 CB 2047-06 0.4 Equipment Capacity PANEL 14C4258-CAL-004.

DIESEL GAUGE AND 108 KJ0121 DGB 2000-00 >RLGM Screened SRT disposition CONTROL PANEL B AUXILIARY RELAY Component per se screened. Block wall evaluated per 109 RP209 AUX 2000-00 0.4 Equipment Capacity RACK 14C4258-CAL-003.

110 RP289 DC DIST PNL RP289 AUX 2047-06 >RLGM Screened SRT disposition MISC BOP INSTRUMENT Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 111 RP068 CB 2047-06 0.41 Anchorage RACK evaluated per 14C4258-CAL-005.

112 RP330 AUX RELAY RACK RP330 AUX 2000-00 >RLGM Screened SRT disposition B AUXILIARY RELAY 113 RP332 AUX 2000-00 >RLGM Screened SRT disposition RACK EM'CY LIGHTING DIST Item is ROB to NK051. Component per se screened. Anchorage 114 NK051A SWBD NK051A (SUBPNL CB 2016-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004. Block wall evaluated per OF NK051) 14C4258-CAL-003.

125 V BATTERY Component per se screened. Anchorage evaluated per 115 NK023 CB/CC 2016-00 0.4 Equipment Capacity CHARGER NK023 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

TRANSFER SWITCH BUS Component per se screened. Block wall evaluated per 116 NK073 NK03 BATTERY CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

CHARGER NK23/NK25 Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 125 VDC BUS 117 NK003 CB/CC 2016-00 0.71 Anchorage evaluated per 14C4258-CAL-004. Block wall evaluated per SWITCHBOARD NK003 14C4258-CAL-003.

Item is ROB to NK003. Equipment capacity evaluated in FDR BKR FROM BATT 118 NK00302 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHGR NK023 TO NK003 004. Block wall evaluated per 14C4258-CAL-003.

12/2/14 Page 57 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number MAIN BREAKER FOR Item is ROB to NK003. Equipment capacity evaluated in CNTRL AND DIST PNL 119 NK00304 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK043 (PART OF SWBD 004. Block wall evaluated per 14C4258-CAL-003.

NK003)

Component per se screened. Anchorage evaluated per 120 NK013 125 V BATTERY NK013 CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

Item is ROB to NK003. Equipment capacity evaluated in ISOLATION BKR FOR 121 NK00301 CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-BATTERY NK013 004. Block wall evaluated per 14C4258-CAL-003.

FDR BKR FOR INVERTER Item is ROB to NK003. Equipment capacity evaluated in 122 NK00311 NN013 (PART OF SWBD CB 2016-00 0.71 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-NK003) 004. Block wall evaluated per 14C4258-CAL-003.

7.5KVA INVERTER (FED Component per se screened. Anchorage evaluated per 123 NN013 FROM BATT CHARGER CB/CC 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

NK023)

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage Class 1E AC DIST SWBD 124 NN003 CB/CC 2016-00 0.71 Anchorage evaluated per 14C4258-CAL-004. Block wall evaluated per NN03 (SEP GRP 3) 14C4258-CAL-003.

BOP INSTR RACK Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 125 RP053DB CB 2047-06 0.41 Anchorage RP053DB evaluated per 14C4258-CAL-005.

W PROCESS ANALOG Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 126 SB037 PROTECTION SET CAB- CB/CC 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

03 Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 127 SE054C W NUC INSTM NIS 3 CB/CC 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

CNTRL & INSTR DIST Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 128 NK043 SWBD NK043 (CLASS 1E CB/CC 2016-00 0.71 Anchorage evaluated per 14C4258-CAL-004. Block wall evaluated per 125 VDC) 14C4258-CAL-003.

Component per se screened. Block wall evaluated per 129 AB007 Aux Relay Rack CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

FDR BKR FOR 125 V Item is ROB to NG001. Equipment capacity evaluated in 130 NG00109 SWING BATTERY CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHARGER NK025 004.

125 V BATTERY Component per se screened. Anchorage evaluated per 131 NK025 CHARGER NK025 (Swing CB 2000-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

Battery Charger) 12/2/14 Page 58 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 480 V LOAD CENTER 132 NG002 CB 2000-00 0.41 Anchorage evaluated per 14C4258-CAL-005 Block wall evaluated per NG02 14C4258-CAL-003.

FLEX 500 kW TIE IN BKR Item is ROB to NG002. Equipment capacity evaluated in 133 NG00212 from FD201 (Phase 2 CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-connection point) 005.

FDR BKR FOR 125 V Item is ROB to NG002. Equipment capacity evaluated in 134 NG00203 VITAL BATTERY CB 2000-00 0.41 Anchorage 14C4258-CAL-005. Anchorage evaluated per 14C4258-CAL-CHARGER NK024 005.

125 V BATTERY Component per se screened. Anchorage evaluated per 135 NK024 CB 2016-00 0.4 Equipment Capacity CHARGER NK024 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

TRANSFER SWITCH BUS Component per se screened. Block wall evaluated per 136 NK074 NK04 BATTERY CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

CHARGER NK24/NK26 125 VDC BUS Component per se screened. Anchorage evaluated per 137 NK004 CB 2016-00 0.4 Equipment Capacity SWITCHBOARD NK004 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

FDR BKR FROM BATT Item is ROB to NK004. Component per se screened. Anchorage 138 NK00402 CB 2016-00 0.4 Equipment Capacity CHGR NK024 TO NK004 evaluated per 14C4258-CAL-004.

Component per se screened. Anchorage evaluated per 139 NK014 125 V BATTERY NK014 CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

ISOLATION BKR FOR Item is ROB to NK004. Component per se screened. Anchorage 140 NK00401 CB 2016-00 0.4 Equipment Capacity BATTERY NK014 evaluated per 14C4258-CAL-004.

FDR BKR FOR INVERTER Item is ROB to NK004. Component per se screened. Anchorage 141 NK00411 NN011 (PART OF SWBD CB 2016-00 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

NK004) 7.5KVA INVERTER (FED Component per se screened. Block wall evaluated per 142 NN014 FROM BATT CHARGER CB 2016-00 0.4 Equipment Capacity 14C4258-CAL-003.

NK024)

Class 1E AC DIST SWBD Component per se screened. Anchorage evaluated per 143 NN004 CB 2016-00 0.4 Equipment Capacity NN04 (SEP GRP 4) 14C4258-CAL-004. Block wall evaluated per 14C4258-CAL-003.

BOP Instrumentation 144 RP147B CB 2000-00 >RLGM Screened SRT disposition Rack RP147B NEUTRON FLUX MONITORING SYSTEM 145 SENY0061A AUX 2047-00 >RLGM Screened SRT disposition DETECTOR AMPLIFIER SENY 61A 12/2/14 Page 59 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number NEUTRON FLUX MONITORING SYSTEM 146 SENY0061B AUX 2047-00 >RLGM Screened SRT disposition DETECTOR AMPLIFIER SENY 61B Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 147 SE054D W NUC INSTM NIS 4 CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

W PROCESS ANALOG Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 148 SB041 PROTECTION SET CAB- CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

04 BOP Instrumentation Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 149 RP053BC CB 2047-06 0.41 Anchorage Rack RP053BC evaluated per 14C4258-CAL-005.

RVLIS Process Cabinet Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 150 SB079 CB 2047-06 0.41 Anchorage SB079 evaluated per 14C4258-CAL-005.

Subcooling Monitor Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 151 RP081B CB 2047-06 0.41 Anchorage Cabinet evaluated per 14C4258-CAL-005.

W PROCESS 152 SB148B PROTECTION (Fire CB 2000-00 >RLGM Screened SRT disposition Isolation)

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage 153 SA066B STATUS INDICATING SYS CB 2047-06 0.41 Anchorage evaluated per 14C4258-CAL-005.

Component per se screened. Block wall evaluated per 154 RP140 PANEL RP140 CB 2000-00 0.4 Equipment Capacity 14C4258-CAL-003.

Item is ROB to RL002. Component per se screened. Anchorage Note 5 BGLI0104 BORIC ACID TANK A LEV CB 2047-06 0.4 Equipment Capacity evaluated per 14C4258-CAL-004.

Note 5 BGLT0104 BORIC ACID TANK A LEV AUX 1974-00 >RLGM Screened SRT disposition RWST SUPPLY TO CTMT Note 5 BNHV0003 AUX 1974-00 >RLGM Screened SRT disposition SPRAY PUMP B RWST SUPPLY TO CTMT Note 5 BNHV0004 AUX 1974-00 >RLGM Screened SRT disposition SPRAY PUMP A RWST TO SAFETY INJ Note 5 BNHV8806A AUX 1976-10 >RLGM Screened SRT disposition PUMP A SUCTION RWST TO SAFETY INJ Note 5 BNHV8806B AUX 1976-10 >RLGM Screened SRT disposition PUMP B SUCTION RWST TO RHR PUMP B Note 5 BNHV8812B AUX 1968-01 >RLGM Screened SRT disposition SUCTION Note 5 BNLT0933 RWST Level Transmitter YRD 1993-00 >RLGM Screened SRT disposition 12/2/14 Page 60 of 61

to ULNRC-06161 Westinghouse Non-Proprietary Class 3 Callaway Energy Center ESEP Final Report ESEL Item ID Description Bldg Elev HCLPF Failure Mode Basis Number Equipment capacity evaluated in 14C4258-CAL-005. Anchorage LOCAL CONTROL PANEL Note 5 FC0219 AUX 2002-00 0.41 Equipment Capacity evaluated per 14C4258-CAL-005. Relay functionality evaluated FOR TD AFW PUMP per 14C4258-CAL-005.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage Note 5 NG002B MCC NG02B BUS AUX 2026-00 0.4 Relay functionality evaluated per 14C4258-CAL-004. Relay functionality evaluated per 14C4258-CAL-005.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage Note 5 NG003C MCC NG03C BUS AUX 2047-00 0.32 Relay functionality evaluated per 14C4258-CAL-005. Relay functionality evaluated per 14C4258-CAL-005.

Equipment capacity evaluated in 14C4258-CAL-005. Anchorage Note 5 NG004C MCC NG04C BUS AUX 2047-00 0.32 Relay functionality evaluated per 14C4258-CAL-005. Relay functionality evaluated per 14C4258-CAL-005.

Component per se screened. Block wall evaluated per Note 5 RP334 LOCKOUT RELAY RACK CB 2000-00 0.4 Equipment Capacity 14C4258-CAL-003.

12/2/14 Page 61 of 61