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Enclosure 1 - Improved Technical Specifications (ITS) Submittal, Enclosure 3 - Licensee Identified Changes That May Require a Formal Technical Branch Review Through Enclosure 10
	ML13329A718
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Site:	Sequoyah
Issue date:	11/22/2013
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
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	NUREG-1431, Rev 4
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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Contents of the Sequoyah Nuclear Plant, Units 1 and 2, Improved Technical Specifications (ITS) Submittal

Contents Volume Titles .......................................................................................................... E1-2 Volume 1 ................................................................................................................. E1-2 Volume 2 ................................................................................................................. E1-2 Volumes 3 through 16 ............................................................................................. E1-3 Designator Category ............................................................................................... E1-4 E1-1

CONTENTS OF THE SEQUOYAH NUCLEAR PLANT IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL of the submittal for the conversion of the current Technical Specifications (CTS) to the ITS for Sequoyah Nuclear Plant consists of the following sixteen volumes:

Volume Titles

1. Application of Selection Criteria to the Sequoyah Nuclear Plant Technical Specifications

2. Generic Determination of No Significant Hazards Considerations and Environmental Assessment

3. ITS Chapter 1.0, Use and Application

4. ITS Chapter 2.0, Safety Limits

5. ITS Section 3.0, Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR) Applicability

6. ITS Section 3.1, Reactivity Control Systems

7. ITS Section 3.2, Power Distribution Limits

8. ITS Section 3.3, Instrumentation

9. ITS Section 3.4, Reactor Coolant System

10. ITS Section 3.5, Emergency Core Cooling Systems (ECCS)

11. ITS Section 3.6, Containment Systems

12. ITS Section 3.7, Plant Systems

13. ITS Section 3.8, Electrical Power Systems

14. ITS Section 3.9, Refueling Operations

15. ITS Chapter 4.0, Design Features

16. ITS Chapter 5.0, Administrative Controls Volume 1 is provided to assist the Nuclear Regulatory Commission (NRC) in the review and approval of Volumes 2 through 16. Below is a brief description of the content of each of the volumes in this submittal.

Volume 1 Volume 1 provides details concerning the application of the selection criteria to the individual Sequoyah Nuclear Plant CTS. Each CTS Specification is evaluated, and a determination is made as to whether or not the CTS Specification meets the criteria in 10 CFR 50.36(c)(2)(ii) for retention in the proposed ITS.

Volume 2 Volume 2 contains the majority of the evaluations required by 10 CFR 50.91(a), which support a finding of No Significant Hazards Consideration (NSHC). Based on the inherent similarities in the NSHC evaluations, generic evaluations for a finding of NSHC have been written for the following categories of CTS changes:

Administrative Changes

More Restrictive Changes

Relocated Specifications E1-2

Removed Detail Changes

Less Restrictive Changes - Category 1 - Relaxation of LCO Requirements

Less Restrictive Changes - Category 2 - Relaxation of Applicability

Less Restrictive Changes - Category 3 - Relaxation of Completion Time

Less Restrictive Changes - Category 4 - Relaxation of Required Action

Less Restrictive Changes - Category 5 - Deletion of Surveillance Requirement

Less Restrictive Changes - Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria

Less Restrictive Changes - Category 7 - Relaxation of Surveillance Frequency

Less Restrictive Changes - Category 8 - Deletion of Surveillance Requirement Shutdown Performance Requirements

Less Restrictive Changes - Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports For those less restrictive changes that do not fall into one of the generic Less Restrictive Changes categories, specific NSHC evaluations have been performed and are provided in the applicable Chapter, Section, or Specification in Volumes 3 through 16.

In addition, Volume 2 contains an evaluation of environmental consideration in accordance with 10 CFR 51.21. It has been determined that the proposed license amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(b), and no environmental impact statement or environmental assessment need be prepared in connection with the proposed license amendment.

Volumes 3 through 16 Volumes 3 through 16 provide the details and justification to support the proposed changes. Each volume corresponds to a Chapter, Section, or Specification of NUREG-1431, Revision 4.0. Each volume contains the required information to review the conversion to ITS, and include the following:

Individual ITS Specifications in:

o ITS Chapter (Volumes 3, 4, and 15);

o Section (Volume 5); or o Specification (Volumes 6 through 14 and 16) order.

Relocated/Deleted CTS Specifications (if applicable); and

ISTS Specifications not adopted in the Sequoyah Nuclear Plant ITS (if applicable).

The information for each of the above three types of specifications is organized as follows:

CTS Markup and Discussion of Changes (DOCs) (applicable only to Individual ITS Specifications and Relocated/Deleted CTS Specifications)

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This section contains a markup of the CTS pages, either for CTS pages associated with an Individual ITS Specification or for Relocated/Deleted CTS Specifications, and the DOCs from the CTS. CTS license amendment requests under NRC review that have been docketed as of August 10, 2012 have been incorporated in the proposed changes as described in Enclosure 6 of this submittal.

The CTS markup pages for each ITS Specification are normally in numerical order.

However, more than one CTS Specification is sometimes used in the generation of an ITS Specification. In this case, the CTS pages that are the major contributor to the ITS Specification are shown first, followed by the remaining associated CTS pages in numerical order.

The left-hand margin of the CTS markup pages includes a cross-reference to the equivalent ITS requirement. The upper right-hand comer of the CTS markup pages is annotated with the ITS Specification number to which it applies. Items on the CTS markup pages that are addressed in other proposed ITS Chapters, Sections, or Specifications are annotated with a reference to the appropriate ITS Chapter, Section, or Specification.

The CTS markup pages are annotated with an alphanumeric designator to identify the differences between the CTS and the proposed ITS. The designator corresponds to a DOC, which provides the description and justification of the change. The DOCs are located directly following the associated CTS markup for each Chapter or Section (Volumes 3, 4, 5, and 15) or each Specification (Volumes 6 through 14 and 16).

Each proposed change to the CTS is classified into one of the following categories:

Designator Category Designator Category A ADMINISTRATIVE CHANGES - Changes to the CTS that do not result in new requirements or change operational restrictions or flexibility. These changes are supported in aggregate by a single generic NSHC.

M MORE RESTRICTIVE CHANGES - Changes to the CTS that result in added restrictions or reduced flexibility. These changes are supported in aggregate by a single generic NSHC.

R RELOCATED SPECIFICATIONS - Changes to the CTS that relocate specifications that do not meet the selection criteria of 10 CFR 50.36(c)(2)(ii). These changes are supported in aggregate by a single generic NSHC.

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LA REMOVED DETAIL CHANGES - Changes to the CTS that eliminate detail and relocate the detail to a licensee-controlled document. Typically, this involves details of system design and function, or procedural detail on methods of conducting a Surveillance Requirement. These changes are supported in aggregate by a single generic NSHC. In addition, the generic type of removed detail change is identified in italics at the beginning of the DOC.

L LESS RESTRICTIVE CHANGES - Changes to the CTS that result in reduced restrictions or added flexibility. These changes are supported either in aggregate by a generic NSHC that addresses a particular category of less restrictive change, or by a specific NSHC if the change does not fall into one of the nine categories of less restrictive changes. If the less restrictive change is covered by a generic NSHC, the category of the change is identified in italics at the beginning of the DOC.

The DOCs are numbered sequentially within each letter designator for each ITS Chapter, Section, or Specification.

The CTS Bases pages are replaced in their entirety by the proposed Sequoyah Nuclear Plant ITS Bases, and markup pages are not provided in the ITS submittal.

ISTS Markup and Justification for Deviations (JFDs) (applicable only to Individual ITS Specifications and ISTS Specifications not adopted in the Sequoyah Nuclear Plant ITS)

This section contains a markup of the NUREG-1431, Revision 4.0, ISTS pages, either for ISTS pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the Sequoyah Nuclear Plant ITS, and JFDs from the ISTS. The ISTS pages are annotated with a numeric designator to identify the differences between the ISTS and the proposed ITS. The designator corresponds to a JFD, which provides the justification for the difference. The JFDs are located directly following the associated ISTS markup for each Chapter or Section (Volumes 3, 4, 5, and 15) or each Specification (Volumes 6 through 14 and 16). The ISTS markup pages are also annotated to show the incorporation of NRC approved generic changes (Technical Specification Task Force (TSTF) change travelers) that are applicable to the Sequoyah Nuclear Plant ITS.

The left-hand margin of the ISTS markup pages includes a cross-reference to the equivalent CTS requirement.

ISTS Bases Markup and JFDs (applicable only to Individual ITS Specifications and ISTS Specifications not adopted in the Sequoyah Nuclear Plant ITS)

This section contains a markup of the NUREG-1431, Revision 4.0, ISTS Bases pages, either for ISTS Bases pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the Sequoyah Nuclear Plant, and JFDs from the ISTS Bases. The ISTS Bases pages are annotated with a numeric designator to identify the differences between the ISTS Bases and the proposed ITS Bases. The designator corresponds to a JFD, which provides the justification for the difference. The JFDs are located directly following the associated ISTS Bases markup for each Chapter or Section (Volumes 3, 4, 5, and 15) or each Specification (Volumes 6 through 14 E1-5

and 16). The ISTS Bases markup pages are also annotated to show the incorporation of NRC-approved generic changes (TSTF change travelers) that are applicable to the Sequoyah Nuclear Plant ITS Bases. The volumes for ITS Chapters 1.0, 4.0, and 5.0 do not include this section, because NUREG-1431, Revision 4.0, does not include any Bases for these Chapters.

Determination of NSHC (applicable only to Individual ITS Specifications and Relocated/Deleted CTS Specifications)

This section contains the determination in accordance with 10 CFR 50.91(a)(1) using the criteria of 10 CFR 50.92(c) to support a finding of NSHC. For those changes covered by a generic NSHC, those generic NSHCs are located in Volume 2. For those less restrictive changes that do not fall into one of the generic less restrictive categories, a specific NSHC evaluation has been performed. Each evaluation is annotated to correspond to the DOC discussed in the NSHC. For those ITS Chapters, Sections, or Specifications for which the less restrictive DOCs all fall into a generic category, a statement that there are no specific NSHCs is provided.

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ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Licensee Identified Changes That May Require a Formal Technical Branch Review

LICENSEE IDENTIFIED CHANGES THAT MAY REQUIRE A FORMAL TECHNICAL BRANCH REVIEW As discussed in LIC-601, changes that may require a formal Technical Branch review are those changes included in the Improved Technical Specifications (ITS) conversion submittal that do not maintain the Current Technical Specifications (CTS) and are not the result of adopting the Improved Standard Technical Specifications (ISTS) as described in NUREG-1431, Rev. 4.0. The following is a list of changes in Enclosure 2 that may require a formal Technical Branch Review in the SQN ITS conversion submittal, but do not involve a design change to the plant:

1. CTS 4.2.2.1 states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability when the Surveillance is not met. CTS 4.2.2.2.d.1 Note *** states that during power escalation at the beginning of each cycle, power level may be increased until a power level for extended operation has been achieved and power distribution map obtained. ITS 3.2.1 has a similar note for the beginning of each cycle, however, there is no specific allowance for changing MODES at any other time with ITS LCO 3.2.1 not met. ITS LCO 3.0.4 requires, in part, that when an LCO is not met, entry into a MODE or other specified condition in the applicability shall only be made: If part a. or part b. or part c. is met. Part c allows, when an allowance is stated in the individual value, parameter or other specification. ITS 3.2.1 Surveillance Requirements Note will provide an allowance whereby, Surveillance performance is not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after an equilibrium power level has been achieved, at which a power distribution map can be obtained. (Refer to Enclosure 2, Volume 7, ITS Section 3.2.1, Discussion of Change (DOC) M04.)

2. CTS Table 3.3-1 requires Functional Unit 14.C (Main Steam Generator Water Level

- Low-Low, RCS Loop T) to be OPERABLE in MODES 1 and 2. If one channel is inoperable, the CTS Table 3.3-1 Actions require that within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , for the affected protection set, the Trip Time Delays (TS and TM) threshold power level for zero seconds time delay is adjusted to 0% RTP. ITS 3.3.1 Required Action T.2 allows an alternative of placing the Steam Generator Water Level - Low-Low channel in trip instead of adjusting the Trip Time Delays (TS and TM) threshold power level for zero seconds time delay to 0% RTP with the same Completion Time. Similarly, CTS Table 3.3-1 requires Functional Unit 14.D (Main Steam Generator Water Level

- Low-Low, Containment Pressure (EAM)) to be OPERABLE in MODES 1 and 2. If one channel is inoperable, the CTS Table 3.3-1 Actions require that within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , for the affected protection set, the Steam Generator Water Level -Low-Low (EAM) channels trip setpoint is adjusted to the same value as Steam Generator Water Level - Low-Low (Adverse). ITS 3.3.1 Required Action S.2 allows an alternative of placing the Steam Generator Water Level - Low-Low channel in trip instead of adjusting the Steam Generator Water Level - Low-Low (EAM) channels trip setpoint to the same value as Steam Generator Water Level - Low-Low (Adverse) with the same Completion Time for placing the channel in trip. Once either of these Functional Unit channels are placed in the tripped condition, the applicable circuitry is removed from the active portion of the Steam Generator Low-Low Level channel.

The action of tripping the channel provides the protection set's input to the 2/3 logic gates. (Refer to Enclosure 2, Volume 8, ITS 3.3.1, DOCs L11 and L12.)

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3. CTS Table 4.3-1, in part, requires the performance of a FUNCTIONAL TEST for Functional Unit 6 (Source Range, Neutron Flux) in MODES 2, 3, 4, 5, and with the reactor trip system breakers closed and the control rod drive system capable of rod withdrawal. When in the required MODES, the FUNCTIONAL TEST is required to be performed on a monthly basis (M) and prior to startup (S/U) if not performed in the previous 31 days. ITS Table 3.3.1-1 requires a CHANNEL OPERATIONAL TEST (COT) (SR 3.3.1.7) for Function 5 (Source Range Neutron Flux) in MODE 2 below the P-6 interlocks; and MODES 3, 4, and 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. ITS SR 3.3.1.7 is modified by a Note stating, "Not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after entry into MODE 3." The addition of the Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and for a short time in MODE 3 until the reactor trip breakers are open and SR 3.3.1.7 is no longer required to be performed. If the unit is to be in MODE 3 with the reactor trip breakers closed for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months this Surveillance must be performed prior to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after entry into MODE 3. (Refer to Enclosure 2, Volume 8, ITS 3.3.1, DOC L20.)

4. CTS Table 2.2-1 for Functional Unit 16 (Underfrequency - Reactor Coolant Pumps

[RCPs]) lists the Nominal Trip Setpoint as 56.0 Hz - each bus, and the Allowable Value as 55.9 Hz - each bus. ITS Table 3.3.1-1 for Function 12 (Underfrequency RCPs) lists the Nominal Trip Setpoint as 57.0 Hz and the Allowable Value as 56.3 Hz. The Underfrequency RCP reactor trip ensures that protection is provided against violating the Departure from Nucleate Boiling Ratio (DNBR) limit due to a loss of flow in two or more Reactor Coolant System (RCS) loops from a major network frequency disturbance. TVA has determined that to provide adequate protection changes to the Underfrequency RCP Nominal Trip Setpoint and the Allowable Value are needed. This change was previously proposed in SQN license amendment request TVA-SQN-TS-02-01, Revision 1 (ADAMS Accession No.

042430467) but later withdrawn in TVA-SQN-TS-02-01, Revision 2 (ADAMS Accession No. ML061990303) pending resolution of issues with TSTF-493. In Revision 2, TVA stated that a new TS amendment request would be submitted to the NRC once TSTF-493 receives NRC approval. As TSTF-493 has been approved by the NRC and is being adopted under this ITS Conversion submittal, TVA is proposing to change the setpoints to those proposed in the previous submittal. (Refer to Enclosure 2, Volume 8, ITS 3.3.1 DOC M24.)

5. CTS Table 3.3-3 requires Functional Units 6.c.i.c (Auxiliary Feedwater, Main Steam Generator Water Level - Low-Low, Start Motor Driven Pumps, RCS Loop T) and 6.c.ii.c (Auxiliary Feedwater, Main Steam Generator Water Level - Low-Low, Start Turbine Driven Pumps, RCS Loop T) to be OPERABLE in MODES 1, 2, and 3. If one channel is inoperable, the CTS Table 3.3-3 Actions require that within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , for the affected protection set, the Trip Time Delays (TS and TM) threshold power level for zero seconds time delay is adjusted to 0% Rated Thermal Power (RTP).

ITS 3.3.2 Required Action K.2 allows an alternative of placing the Steam Generator Water Level - Low-Low channel in trip instead of adjusting the Trip Time Delays (TS and TM) threshold power level for zero seconds time delay to 0% RTP with the same Completion Time. Similarly, CTS Table 3.3-3 requires Functional Unit 6.c.i.d (Auxiliary Feedwater, Main Steam Generator Water Level - Low-Low, Start Motor Driven Pumps, Containment Pressure (EAM)) and 6.c.ii.d (Auxiliary Feedwater, Main Steam Generator Water Level - Low-Low, Start Turbine Driven Pumps, E3-2

Containment Pressure (EAM)) to be OPERABLE in MODES 1, 2, and 3. If one channel is inoperable, the CTS Table 3.3-3 Actions require that within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , for the affected protection set, the Steam Generator Water Level -Low-Low (EAM) channels trip setpoint is adjusted to the same value as Steam Generator Water Level - Low-Low (Adverse). ITS 3.3.2 Required Action J.2 allows an alternative of placing the Steam Generator Water Level - Low-Low channel in trip instead of adjusting the Steam Generator Water Level - Low-Low (EAM) channels trip setpoint to the same value as Steam Generator Water Level - Low-Low (Adverse) with the same Completion Time for placing the channel in trip. Once either of these Functional Unit channels are placed in the tripped condition, the applicable circuitry is removed from the active portion of the Steam Generator Low-Low Level channel.

The action of tripping the channel provides the protection set's input to the 2/3 logic gates. (Refer to Enclosure 2, Volume 8, ITS 3.3.2, DOCs L12 and L13.)

6. CTS 4.3.2.1.3 requires, in part, an Engineered Safety Feature (ESF) RESPONSE TIME test of the Containment Ventilation Isolation High Radiation Function. ITS SR 3.3.6.8 requires, in part, an ESF RESPONSE TIME test of the Containment Ventilation Isolation High Radiation Function, and is modified by a Note that states the radiation detectors are excluded from response time testing. SQN License Amendment 190 and 182, for Unit 1 and Unit 2 respectively, relocated the Engineered Safety Feature Actuation System (ESFAS) response time limits to the UFSAR (ADAMS Accession No. ML013300393). UFSAR Table 7.3.1-4 contains these limits listing the information in two columns, "Initiating Signal and Function,"

and "Response Time in Seconds." The Initiating Signals listed in UFSAR Table 7.3.1-4 includes Containment Purge Air Exhaust Radioactivity - High for Function Containment Ventilation Isolation. The Response Time column in UFSAR Table 7.3.1-4 for Containment Ventilation Isolation is modified by Note (6). UFSAR Table 7.3.1-4 Note (6) states that the radiation detectors for Containment Ventilation Isolation Function may be excluded from Response Time Testing. This Note previously modified the CTS definition of an ESF RESPONSE TIME test when it was located within the CTS. This exclusion was removed when the ESFAS response time limits were relocated to the UFSAR by License Amendments 190 and 182. (Refer to Enclosure 2, Volume 8, ITS Section 3.3.6, DOC L01.)

7. CTS Table 4.3-1, in part, requires a FUNCTIONAL TEST for Functional Unit 6.B (Source Range, Neutron Flux, Shutdown) in MODES 2, 3, 4, 5, and with the reactor trip system breakers closed and the control rod drive system capable of rod withdrawal. When in the required MODES, the FUNCTIONAL TEST is required to be performed on a monthly basis (M) and prior to startup (S/U) if not performed in the previous 31 days. ITS SR 3.3.9.2 requires a CHANNEL OPERATIONAL TEST (COT) for the required Boron Dilution Monitoring Instrumentation (Source Range Neutron Flux Monitoring Channel) in MODE 3, 4, and 5. ITS SR 3.3.9.2 is modified by a note stating, "Not required to be performed prior to entering MODE 3 from MODE 2 until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after entry into MODE 3." The addition of the Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and for a short time in MODE 3 and prevents entry into Required Actions. (Refer to Enclosure 2, Volume 8, ITS Section 3.3.9, DOC L04.)

8. CTS 3.4.1.3.a and CTS 3.4.1.4.a require, in part, RCS loops to be OPERABLE in MODES 4 and 5, respectively. Each required RCS loop is required to be accompanied by its associated steam generator and reactor coolant pump. The E3-3

OPERABILITY of required steam generators is determined by verifying the secondary side water level to be greater than or equal to 10 percent (wide range indication). ITS SR 3.4.6.2 and ITS 3.4.7.2 require verification that each required steam generator has a secondary side water level 21% (narrow range indication).

The purpose of these Specifications is to ensure adequate means of decay heat removal and boron mixing. When a reactor coolant loop is used to meet the requirement, the associated steam generator OPERABILITY is required to be determined by verifying the secondary side water level is high enough to ensure the steam generator tubes are not uncovered, thereby providing the heat sink necessary for decay heat removal. A secondary side steam generator water level of 21% (narrow range indication) will ensure at least 76 inches of water above the top of the steam generators tubes in MODES 4 and 5. (Refer to Enclosure 2, Volume 9, ITS Section 3.4.6, DOC M04; and ITS Section 3.4.7, DOC M01.)

9. CTS 3.4.6.3 does not provide an LCO or ACTIONS to take when the Residual Heat Removal (RHR) System interlock function is inoperable and does not contain an explicit Surveillance Requirement to verify the RHR System interlock prevents valves from being opened to prevent exceeding RHR design pressure. ITS LCO 3.4.14, second part, has been added to ensure consistency between the LCO, ACTIONS, and Surveillance Requirements. ITS 3.4.14 ACTION C requires with an inoperable RHR System interlock function that the affected penetration is isolated by use of one closed manual or deactivated valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS SR 3.4.14.2 verifies the RHR System interlock will prevent the valves from being opened with RCS pressure signal 380 psig. The addition of the LCO, ACTIONS and Surveillance Requirement will ensure the OPERABILITY of the RHR System interlock function to prevent the failure of the low pressure portion of the RHR System. (Refer to Enclosure 2, Volume 9, ITS Section 3.4.14, DOC M01.)

10. CTS 3.5.2 requires two Emergency Core Cooling System (ECCS) trains to be OPERABLE. CTS 3.5.2 Note 1 states, in MODE 3, both Safety Injection (SI) pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform Pressure Isolation Valve (PIV) testing per SR 4.4.6.3. ITS 3.5.2 requires two ECCS trains to be OPERABLE. ITS 3.5.2 Note 1 states, in MODE 3, both ECCS pump flow paths may be isolated for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform PIV testing per SR 3.4.14.1. Surveillance testing of the PIVs requires the SI Pump and RHR Pump flow paths to be isolated. CTS 3.5.2 Note 1 allows both SI pump flow paths to be isolated for two hours provided that the flow paths are readily restorable from the control room. In addition to isolating the SI pump flow paths, ITS 3.5.2 Note 1 will allow both RHR pump flow paths to be isolated for two hours allowing for the required testing of the PIVs. This change permits the isolation of the ECCS (SI pump and RHR pump) flow paths provided that the flow paths are readily restorable from the control room. (Refer to Enclosure 2, Volume 10, ITS Section 3.5.2, DOC L01.)

11. CTS 3.6.5.3, Action b. allows continued unit power operation for up to 14 days with one of more ice condenser doors open or inoperable for reasons other than the door is physically restrained from opening, provided the ice bed temperature is verified to not exceed 27°F every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Otherwise, the ice condenser door shall be restored to its closed position or OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (as applicable), or the unit shall be in hot standby within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and cold shutdown in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . ITS 3.6.13, Condition B is entered when one of more ice condenser E3-4

doors are open or inoperable for reasons other than the door is physically restrained from opening. In this Condition, ice bed temperature is verified to not exceed 27°F once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and the inoperable ice condenser door(s) is required to be in the closed position and restored to an OPERABLE status within 14 days. If the inoperable or open ice condenser door is not closed and restored to an OPERABLE status within 14 days, the unit shall be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If ice bed temperature exceeds 27°F, Required Action C.1 requires entry into the applicable Conditions and Required Actions of LCO 3.6.12, "Ice Bed." This change removes the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowance to restore or close the ice condenser door after the 14 day allowed outage time has expired. (Refer to Enclosure 2, Volume 11, ITS Section 3.6.13, DOC M01.)

12. CTS 3.6.5.3 provides specific Actions to be taken if an ice condenser intermediate deck or top deck door is open or inoperable. ITS 3.6.13 ACTIONS Note 2 states that when an ice condenser intermediate deck or top deck door is inoperable for a short duration solely due to personnel standing on or opening the door to perform required Surveillances, minor preventative maintenance, or system walkdowns, entry into associated Conditions and Required Actions is not required. The doors must be OPERABLE to ensure the proper opening of the ice condenser in the event of a Design Basis Accident (DBA). OPERABILITY includes being free of any obstructions that would limit their opening. Surveillances and preventative maintenance are performed on the doors to improve reliability of the doors or to ensure the doors do not become inoperable. During this short duration, the ice bed temperature is normally continuously monitored to ensure that an ice bed temperature change due to an open door will be detected and appropriate actions taken. Additionally, the doors may be walked upon or opened for inspections. The number of doors walked on simultaneously (and therefore, potentially incapable of opening) is small when compared to the total number of doors. (Refer to Enclosure 2, Volume 11, ITS Section 3.6.13, DOC L02.)

13. The SQN Updated Final Safety Analysis Report (UFSAR) accident analysis describes the use of Atmospheric Relief Valves (ARVs) in the mitigation of a Steam Generator Tube Rupture event concurrent with a loss of offsite power. The accident analysis assumes the steam generator ARVs associated with the unaffected steam generators are available to cool down the RCS and terminate the primary to secondary leak. ISTS 3.7.4 ACTION A requires the restoration of the required ADV line to OPERABLE status in 7 days when one required ADV line is inoperable. ISTS 3.7.4 ACTION B requires the restoration of all but one ADV lines to OPERABLE status in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when two or more ADV lines are inoperable. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is commensurate with a loss of safety function while providing some time to effect repair and considering the low probability of an event occurring during the time that would require the ADV lines. ITS 3.7.4 ACTION A requires the restoration of the affected ARV lines to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when one or more ARV line(s) are inoperable due to one train of Auxiliary Control Air System (ACAS) being nonfunctional. ITS 3.7.4 ACTION B requires restoration of all ARV lines to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when one or more ARV lines are inoperable for reasons other than Conditon A. The ACAS system supplies essential air to the ARVs on loss of offsite power. The ACAS system consists of two trains. Train A supplies essential air to steam generator 1 and 3 ARVs and train B supplies essential air to steam generator 2 and 4 ARVs. On a loss of one train of essential air to the ARVs, alternate means are available to E3-5

operate the affected ARVs via a manual loading station and relief handwheels. The use of the alternate means for operating the ARVs allows the ARVs to be operated in the mitigation of a steam generator tube rupture event concurrent with a loss of offsite power. (Refer to Enclosure 2, Volume 12, ITS Section 3.7.4, Justification for Deviation (JFD) 4.)

14. ITS SR 3.7.10.1 requires verification that each tornado damper is in the correct position every 31 days unless they are locked, sealed, or otherwise secured in place. CTS 3.7.7 does not contain this Surveillance Requirement. This changes the CTS by requiring a verification that each tornado damper is in the correct position. The Control Room Emergency Ventilation System (CREVS) is designed to ensure that the control room environment will support the activities required of control room personnel during accident conditions and the subsequent recovery period. When activated, CREVS provides a mixture of outside air and recirculated air through devices that provide temperature, humidity, and air cleanup control. In this mode, the control room is maintained at a positive pressure (0.125 inches water gauge) above the outside atmospheric pressure and at a slightly positive pressure in relation to the adjacent areas. When the tornado dampers are closed, the flow path for pressuring air to CREVS is isolated. Therefore, CREVS is unable to maintain a positive pressure above the outside atmospheric pressure and at a slightly positive pressure in relation to the adjacent areas. Since the position of the tornado dampers is integral to the OPERABILITY of CREVS, ITS 3.7.10 a specific Surveillance Requirement (ITS SR 3.7.10.1) has been added to verify every 31 days that the tornado dampers are in the correct position, unless the dampers are locked, sealed or otherwise secured. (Refer to Enclosure 2, Volume 12, ITS Section 3.7.10, DOC M01.)

15. CTS 3.8.1.1 provides Actions to limit the time the unit can remain operating with different combinations of inoperable offsite circuits and diesel generators (DGs).

CTS 3.8.2.1 provides Actions to limit the time the unit can operate with one or more inoperable AC electrical boards, requiring restoration of inoperable listed AC electrical boards to an OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months regardless of the equipment to which it supplies power. The onsite Class 1E AC Electrical Distribution System supplies electrical power to two power trains shared between the two units. The core cooling and containment cooling system loads (e.g., Safety Injection (SI) pumps, Auxiliary Feedwater (AFW) pumps, Residual Heat Removal (RHR) pumps, Centrifugal Charging pumps, Containment Spray pumps, and Air Return System (ARS) fans) are unitized to the respective unit's 6.9 kV Shutdown Boards. However, some safety-related systems (e.g., Essential Raw Cooling Water (ERCW), Component Cooling (CCS), Emergency Gas Treatment (EGTS), Auxiliary Building Gas Treatment, (ABGTS), Control Room Emergency Ventilation (CREVs),

and Control Room HVAC (CRACS)) are shared between the units. The AC sources for the shared loads are distributed across both unit's shutdown boards.

Therefore, two qualified offsite circuits and four DGs capable of supplying the onsite Class 1E AC Electrical Distribution System are required to be OPERABLE.

However, the impacts of an inoperable offsite power source or DG on an opposite unit's 6.9 kV Shutdown Board differ from the impacts of an inoperable offsite power source or DG on an associated unit's 6.9 kV Shutdown Board, due to the loads powered from the respective board. Therefore, the CTS is being changed to provide separate Actions to declare the required features powered from the opposite unit's Class 1E AC Electrical Power Distribution System inoperable as the E3-6

remedial measures for the inoperable AC sources. (Refer to Enclosure 2, Volume 13, ITS Section 3.8.1, DOC L01; and ITS Section 3.8.9, DOC L01.)

Although considered "in-scope," TVA has identified several changes which may require a formal Technical Branch review. The following is a listing of those changes:

1. TVA is incorporating TSTF-411, Surveillance Test Interval Extensions for Components of the Reactor Protection System (WCAP-15376-P). This affects multiple Instrumentation Section Specifications.

2. TVA is incorporating TSTF-418, RPS and ESFAS Test Times and Completion Times (WCAP-14333). This affects multiple Instrumentation Section Specifications.

3. TVA is incorporating TSTF-425, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b. This affects multiple ITS Specifications.

4. TVA is incorporating TSTF-446, Rev. 3, Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP-15791). (Refer to Enclosure 2, Volume 11, ITS 3.6.3 DOC L03.)

5. TVA is incorporating TSTF-490, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec. This affects ITS 1.1, Definitions, and ITS 3.4.16, RCS Specific Activity.

6. TVA is incorporating TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions. This affects multiple Instrumentation Section Specifications.

7. TVA is incorporating TSTF-500, DC Electrical Rewrite - Update to TSTF-360. This affects the DC Electrical Specifications and the Battery Maintenance Monitoring Program in the Administrative Section.

E3-7

ENCLOSURE 5 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP-15791)

Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP-15791) 1.0 Purpose This analysis considers the Sequoyah (SQN) as-built, as-operated plant to ascertain acceptability of applying NRC endorsed topical report (TR) WCAP-15791-P-A Revision 2 "Risk-Informed Evaluation of Extensions to Containment Isolation Valve Completion Times."

The benefit of this proposed change to the Technical Specifications is that completion time (CT) extensions will provide the operator flexibility by increasing the time to perform on-line CIV testing, maintenance or repair. Currently CIV completion time is limited to four-hours for all CIVs.

2.0 References and Acronyms 2.1 References

1. NUREG/CR-5496, "CCF Parameter Estimation 2007"

2. Regulatory Guide 1.174, Rev. 2, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis"

3. Regulatory Guide 1.177, Rev. 1, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications"

4. Regulatory Guide 1.200, Rev. 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities"

5. WCAP-15791-P-A, Rev. 2 "Risk-Informed Evaluation of Extensions to Containment Isolation Valve Completion Times"

6. NRC Accession Number 10027058, Generic Issue (GI-199), "Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants," August 2010

7. MDN-000-000-2010-0200, Rev. 1 - SQN PRA - "Summary Notebook"

8. MDN-000-000-2010-0202, Rev. 1 - SQN PRA - "Data Analysis"

9. MDN-000-000-2010-0203, Rev. 1 - SQN PRA - "Internal Flooding Analysis"

10. MDN-000-000-2010-0208, Rev. 2 - SQN PRA - "Quantification Notebook"

11. 1-SI-SXV-000-201.0, Rev. 017 - Surveillance Instruction - "Full Stroking of Category A and B Valves During Operation"

12. N2-88-400, Rev. 15 System Description - "Containment Isolation"

13. MDQ-000088-2013-000072 Rev. 0 "Risk-Informed Evaluation of Extension to Containment Isolation Valve Completion Times"

14. LTR-RAM-II-11-010, "R.G. 1.200 PRA Peer Review Against the ASME/ANS PRA Standard Requirements for the Sequoyah Nuclear Plant Probabilistic Risk Assessment," March 2011

2.2 Acronyms The following acronyms are used in this analysis:

AOT - Allowed Outage Time AOV - Air Operated Valves ASME - American Society of Mechanical Engineers CAFTA - Computer Aided Fault Tree Analysis CCF - Common Cause Failure CDE - Cause Determination and Evaluation CDF - Core Damage Frequency CDFSEIS - Core Damage Frequency due to Seismic Event CDFSGTR- Core Damage Frequency due to Steam Generator Tube Rupture CDFT - Total Core Damage Frequency (Internal & External Events)

CIV - Containment Isolation Valve CKV - Check Valve CRMP - Configuration Risk Management Program CT - Completion Time FTC - Fail-To-Close ICCDP - Incremental Conditional Core Damage Probability ICLERP - Incremental Conditional Large Early Release Probability IPE - Individual Plant Examination IPEEE - Individual Plant Examination of External Events ISLOCA - Interfacing System Loss of Coolant Accident LCO - Limiting Condition for Operation LERF - Large Early Release Frequency LLRT - Local Leak Rate Testing MOV - Motor Operated Valves MGL - Multiple Greek Letter NRC - Nuclear Regulatory Commission NRR - Nuclear Reactor Regulation PBRANDOM - Pipe Break - Random PBSEIS - Pipe Break - Seismic PRA - Probabilistic Risk Assessment PWROG - Pressurized Water Reactor Owners Group RCS - Reactor Coolant System RG - Regulatory Guide SE - Safety Evaluation SG - Steam Generator SGTR - Steam Generator Tube Rupture SI - Surveillance Instruction SOV - Solenoid Operated Valve SQN - Sequoyah Nuclear Power Plant SRP - Standard Review Plan SRV - Safety Relief Valve SSE - Safe Shutdown Earthquake TR - Topical Report TS - Technical Specifications WCAP - Westinghouse Commercial Atomic Power WOG - Westinghouse Owners Group XO - Spurious (Transfers) Open

3.0 Assumptions and Analysis Basis

1. Before maintenance or repair is started on a containment isolation valve (CIV), it is assumed the other CIVs within the penetration are verified by Operations to be in their proper position(s).1

2. It is assumed that manually operated vent or drain valves located between the CIVs are verified by Operations to be in their closed position similar to assumption 1, as well as other normally closed manually operated valves connected to the penetration.

3. Manually operated vent or drains valves, if opened for LLRT (Local Leak Rate Testing),

etc., are assumed to have a completion time based on the most restrictive CIV for the penetration. This is because the vent/drain lines are less than or equal to the CIV diameter, therefore, their CT is bounded by the larger valves in the associated penetration.

4. It is assumed that containment isolation valves that are locked closed have been verified closed (and locked to prevent inadvertent opening) by operations and therefore excluded from the analysis as potential to spuriously transfer open.

5. For this analysis, it is conservatively assumed that valves that are periodically opened/closed (e.g., containment purge valves) are normally opened.

6. If a seismic event greater than a SSE (Safe-Shutdown Earthquake) were to occur, it is assumed that all non-seismically qualified piping will fail, i.e., a probability of 1.0 is given.

Sections of pipe between the containment isolation valve and the containment wall which is part of the break exclusion zone are excluded.2

7. Containment isolation valves are tested quarterly [Ref 11], additionally it is assumed there is one miscellaneous CIV actuation per year making a total of five actuations per year.3

8. Regardless of the completion time (CT) it is conservatively assumed the maintenance activity requires the entire length of the CT and is completed within that time.

9. For penetration configurations that have an "extra valve" i.e., not a CIV; the probability assigned for those non-CIV valves being in maintenance remains constant for all CTs.

These valves are mainly recognized in the Reactor Coolant System (RCS) penetrations.4 The assumption is that the CT on all non-CIV valves modeled in this analysis is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

10. Only one valve within a single containment penetration can be in maintenance at a time.

11. Maintenance on a valve can be conducted in one of two ways:

a) the valve is intact and capable of maintaining its pressure boundary function, or b) the valve is not intact and is not capable of maintaining its pressure boundary function.

12. When there are two or more valves of the same valve type in the same position (opened or closed) within a penetration, common cause failures (CCF) are included in the ICLERP and LERF calculations.5 1 This assumption eliminates the need to include the probability that the operable valves were mispositioned or transferred to the wrong position since they were last checked. This approach is consistent with WCAP-15791.

2 The piping in the break exclusion zone is more robust that the piping outside the zone. Therefore, consistent with the approach taken in WCAP 15791 it is assumed that the probability of this piping failing randomly or due to a seismic event is much lower than the piping outside the exclusion zone and is of no consequence to this analysis.

3 Same approach as taken in the WCAP.

4 The extra valve(s) provides an additional capability for the operator to isolate a penetration.

5 For cases whereby one CIV is out-of-service for repair, the second CIV of the same valve type has a dependent failure probability involving the common-cause beta factor. For cases where there are three CIVs of the same type, the dependent failure probability involves the gamma factor. The Multiple Greek Letter (MGL) common- cause methodology is used in this analysis. Note - different valve manufacturers is irrelevant to this analysis.

13. It is assumed that interfacing system LOCAs (ISLOCAs) result in core damage.

14. Similar to the Lead Plant, SQN does not have a full scope PRA; therefore, the internal and external at-power CDF is conservatively assumed to be <1.0E-4/yr. This value represents the upper bound for the total-at-power internal and external events CDF based on the acceptance guidelines in Regulatory Guide 1.174, Section 2.2.4, that indicates the plant total CDF should be less than 1.0E-04/yr if changes to a plants licensing bases are made that can result in a small increase in plant risk.

15. For all standby systems connected to the reactor coolant system (RCS):

the system is considered "closed" inside containment and not actively connected to the RCS if there is a closed valve between the RCS and the inside containment CIV.

the system is considered "closed" outside of containment if there is an extra closed valve before the outside containment CIV, and if the piping from the RCS and the extra closed valve outside containment is qualified for high RCS pressures.

16. For systems whereby closed both inside and outside containment, the probability of a non-seismic and/or ISLOCA CDF release is extremely small and therefore excluded from the analysis due to the large number of normally closed valves available to isolate the penetration. Additionally, the likelihood of a random pipe break occurring inside and outside containment simultaneously, causing both systems inside and outside of containment to open is very small and also excluded from the analysis. Note - ALL piping between the RCS and the extra closed valve outside of containment must be qualified for high RCS pressures.

17. For RCS connections, during seismic and random pipe breaks, it is assumed that the piping fails between the CIV and the extra valve. The portion of piping between the CIV and the containment wall is part of the break exclusion zone, and therefore is assumed to remain intact while non-qualified pipe is assumed to fail. This eliminates crediting the extra valves to isolate the penetration.

18. Lines connected to the RCS 3/8" in diameter or less are within the makeup capability of the plant charging systems, and therefore, are not considered small LOCAs or potential containment bypass pathways.

19. For all RCS connections, in which there are two valves of the same type (usually check valves), in series inside containment, before the RCS, common cause failure does not apply because the valves are operating under different conditions. The valve closer to the RCS is subject to a higher pressure than the downstream valve.

20. For the probability of an ISLOCA release portion of the LERF calculations, when there is a normally open valve in the penetration, the open valve is not credited in the calculation. When assessing ISLOCA, the initiating event is the frequency of the closed valves within the path of release spuriously transferring open or rupturing, thus creating a flow path directly from the RCS to the outside atmosphere.

21. For all RCS connections that are normally operating, the probability of an ISLCOA release is not considered because the valves are already open and flow is occurring.

4.0 Regulatory Acceptability and Discussion 4.1 Regulatory Acceptability The Office of Nuclear Reactor Regulation (NRR) issued a safety evaluation (SE) on WCAP-15791-P, Revision 2. The SE considers Technical Specification (TS) Limiting Conditions for Operation (LCO) that state the primary containment isolation valves (CIVs) must be operable for a given reactor mode of operation.

The SE concluded:

1. The TR (topical report) provides guidance including generic and plant-specific analyses to assist licensees in evaluating changes to CIV completions times (CTs).

2. The guidance is complementary to NRC Staff guidance provided in -

Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" [Ref. 2]

Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decision Making: Technical Specifications" [Ref.3]

Therefore, NRR stated the TR provides an acceptable basis to evaluate the proposed CIV CTs when used in conjunction with the RGs. Furthermore, with respect to the acceptance criteria associated with RG 1.177, the TR addresses Tiers 1 (Probabilistic Risk Assessment Capability and Insights) and 2 (Avoidance of Risk-Significant Plant Configurations). Tier 3 (Risk-Informed Configuration Risk Management) is not addressed by the TR and must be addressed in the plant-specific application.

4.2 Discussion The TR provides a risk-informed justification for extending CIV CTs from 4-hours up to 168-hours for Westinghouse pressurized water reactors. For CIVs that do not demonstrate acceptable results for 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months , shorter CTs were evaluated in the report. A deterministic approach was used to determine the minimum containment hole size that would result in a large release from the containment atmosphere. These flow-paths are automatically given the 168-hours CT. All other penetrations were evaluated in the report using a PRA evaluation to verify what CT (i.e., less than 168-hours) is justified.

4.3 Regulatory Criteria 4.3.1 Standard Review Plan (SRP) 19.2 In accordance with SRP 19.2 a risk-informed application should be evaluated to ensure that the proposed changes meet the following key principles:

1. The proposed change meets current regulations, unless it explicitly relates to a requested exemption or rule change.

2. The proposed change is consistent with the defense-in-depth philosophy.

3. The proposed change maintains sufficient safety margins.

4. When proposed changes increase risk (i.e., core damage frequency (CDF) or large early release frequency (LERF)), the increase(s) should be small and consistent with the intent of the Commissions Safety Goal Policy Statement.

5. The impact of the proposed change should be monitored using performance measurement strategies.

4.3.2 Regulatory Guide 1.177 RG 1.177 provides an approach for plant-specific, risk-informed decision making for changes to the technical specifications. A three-tiered approach for evaluation of the risk associated with the proposed TS change follows:

Tier 1 - an evaluation of the plant-specific risk associated with the proposed TS change, as shown by the change in:

Change in the Core Damage Frequency (CDF)

Incremental Conditional Core Damage Probability (ICCDP)

Change in Large Early Release Frequency (LERF)

Incremental Conditional Large Early Release Probability (ICLERP)

Tier 2 - identifies and evaluates, with respect to defense-in-depth, any potential risk-significant plant equipment outage configurations associated with the proposed change.

Tier 3 - provides for the establishment of an overall configuration risk management program (CRMP) and confirmation that its insights are incorporated into the decision making process before taking equipment out-of-service prior to or during the CT.

4.4 Generic Assessment (From WCAP-15791)

WCAP-15791, "Risk-Informed Evaluation of Extensions to Containment Isolation Valve Completion Times" documents the generic analysis performed by Westinghouse for the PWR Owners Group (PWROG). The generic assessment of impact on risk is documented in section 8 of the WCAP.

The penetration configurations used in the analysis were developed to be as generic as possible. Some of the configurations may not exist within all plants, and/or some of the maintenance situations may or may not be viable for all plants. For plant-specific implementation of the generic analysis, the expectation of the WCAP is that all utilities determine the applicability of the CT in practice.

In the generic analysis, Table 8-1 provides the list of input parameters. The majority of the inputs used were obtained from PRA data; however, to make the analysis as generic as possible, the most limiting (e.g., highest failure rate) values were chosen from a plant-to-plant comparison. The approach used both deterministic and probabilistic inputs. A deterministic approach was used to determine the minimum containment hole size (>2 inches) that will result in a large release from the containment atmosphere. All other penetrations are evaluated on a probabilistic basis to demonstrate if a CT of 7-days is acceptable or to determine an appropriate lesser CT.

4.5 Methodology The lead Plant followed the generic analysis, as does the SQN specific analysis. The implementation procedure followed consisted of five steps. For penetration configurations whereby completion times were less than the maximum allowable value of 168-hrs, a plant specific analysis is performed. Not all SQN penetration configurations were addressed by the WCAP of which a plant specific analysis is performed.

4.5.1 Step 1 Containment Penetration Data Collection6 This data was provided to the PRA Engineer and documented in calculation MDQ-000088-2013-000072. [Ref. 13]

4.5.2 Step 2 Confirmation of Analysis Input Parameters The generic analysis documented in WCAP-15791 used a set of input parameters that were obtained from industry PRA data. To make the analysis generic, the most limiting values were chosen. A review is performed to confirm that parameters used in the SQN PRA are bounded by the generic analysis inputs. For those that are not bounded the calculation is re-performed using the SQN parameter.

4.5.3 Step 3 Grouping Penetrations are grouped based on whether it is an open or closed system and the following attributes:

Connected to Containment Atmosphere (Class I)

Connected to the Reactor Coolant System (Class II)

Connected to the Steam Generators (Class III) 4.5.4 Step 4 Identification of Small Lines Small lines is a characterization based on the size of a hole in the primary containment that is the threshold for accident condition radionuclide large release to the environment. Note that the "Small Lines" characterization is applicable only to those penetrations connected to the containment atmosphere, i.e., Class I.

4.5.5 Step 5 Generic Match For those penetrations that did not screen from further consideration in step 4 (i.e., 168-hr CT), a comparison of the generic penetrations/flow paths listed in sections 8.2.2 through 8.2.4 of the WCAP is made.

4.5.6 Guidelines The ICLERP and/or LERF (depending on which is more limiting) was recalculated using SQN specific parameters for CIVs with CTs less than 168-hours. The inputs were used in the appropriate ICLERP and LERF equation based on the penetration Class and Group.

Similar to the lead plant (Wolf Creek) analysis, two guidelines are to be followed:

For penetrations having one normally open CIV - when more than one valve type is present, use the CT for the normally open valve. All valves in the penetration will be represented by this valve type.

6 Steps 1, 3 and 4 are documented in Calculation MDQ-000088-2013-000072. [Ref. 13]

For penetrations that have more than one normally open CIV - use the CT for the normally open valve with the highest probability of failing-to-close. All valves in the penetration will be represented by this valve type.

4.6 SQN Inputs / Specific and Generic 4.6.1 Discussion The analysis involved replacing generic parameters with SQN specific parameters or updated industry data, and recalculating the probabilistic evaluation. The reason for this analysis is to determine which CIVs could be justified for longer CT relaxations in addition to those justified under the generic analysis. The approach taken in the generic analysis was conservative, and therefore, applicable to all Westinghouse Owners Group (WOG) plants, including SQN. Where appropriate, the plant-specific analysis removes over-conservatisms.

The SQN CIVs that were unable to meet the full 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months CT extension under the generic analysis are identified in calculation MDQ-000088-2013-000072 [Ref. 13]. The methodology, terminology, basis and assumptions that were applicable in the generic analysis are all applicable to the SQN specific analysis. The only difference is that the SQN input parameters were used in combination with generic parameters. The analyses in WCAP sections 8.2 and 8.3 were repeated using the SQN specific-parameters to calculate ICLERP and LERF. For penetration configurations that differ from the WCAP, equations were developed. The purpose of this analysis is to determine CIVs that can be justified for longer completion time (CT) relaxations (>4-hrs <168-hrs) in addition to those justified under the generic analysis.

Total CDF Similar to the Lead Plant, SQN does not have a full scope PRA; therefore, the internal and external at-power CDF is conservatively assumed to be 1.0E-4/yr. This value represents the upper bound for the total-at-power internal and external events CDF based on the acceptance guidelines in Regulatory Guide 1.174, Section 2.2.4, that indicates the plant total CDF should be less than 1.0E-04/yr if changes to a plants licensing bases are made that can result in a small increase in plant risk.

Seismic SQN does not have a seismic PRA; therefore, the results documented in Table D-1, "Seismic Core-Damage Frequencies Using 2008 USGS Seismic Hazard Curves" in Generic Issue-199, Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants" was used.[Ref 6] For SQN Units 1 &

2, the limiting frequency (5.1E-05/yr) was based on the Weakest Link Model using PGA (peak ground acceleration).

Containment Isolation Valve Treatment For all normally-closed valves, the probability of the valve spuriously transferring open is considered. For all normally-open valves, the valves have the probability of a) failing-to-close, and b) spuriously transferring open after it has closed.

The limiting (bounding) valve in the SQN PRA for a spurious open or transfer open are the Safety Relief Valves. The SRVs provide for a steam release with a distribution rate of 2.12E-7/hr. Therefore, to determine the bounding probability that a valve will spuriously transfer open follows:

Ptopre = 2.12E-07/hr

4 hr CT = 8.48E-07 Pto = 2.12E-07/hr

168 hrs CT = 3.56E-05 The SQN PRA does not explicitly model SOVs, therefore, SOV-FTC (9.54E-04) is used.

Taken from NUREG/CR-6928.

The CIV corrective maintenance frequency (m) is derived from the highest valve failure rate used in this analysis (SOV FTC)7 which is approximately 9.54E-04 per demand, meaning the component is expected to approximately fail every 1000 actuations [(1)/(9.54E-4) ~

1000]. Each CIV is tested quarterly [Ref 6], and in addition it is assumed that there is one8 miscellaneous CIV actuations per year. Therefore, giving a total of five CIV actuations per year. Dividing 1000 actuations by five actuations per year yields an approximate 200 year period per failure, or a corrective maintenance frequency of 0.005 per year. Therefore, the probability that a CIV is unavailable due to maintenance during a CT of 4 and 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months is calculated as follows:

Current CT 4 hrs Pm1 = [(4-hrs /8760-hrs/yr) * (0.005)] = 2.28E-06 Extra Valve Assumed CT 72-hrs PmE = [(72-hrs/8760-hr/yr)*(0.005)] = 4.11E-05 Extended CT 168 hrs Pm2 = [(168-hrs / 8760-hrs/yr) * (0.005)] = 9.59E-05 Containment Hole Size [Ref 5 Section 8.3]

Penetration flow paths connected to the containment atmosphere (this excludes RCS and SG connections) that have piping diameters smaller than a minimum value are an insufficient size to result in a large release. These penetrations automatically default to the 168-hour CT. Based on discussion with the NRC, the WOG applies a greater than 2-inch containment hole size for a large release.

4.6.2 Confirmation of Analysis Input Parameters Table 4-1 Core Damage Frequencies Generic Input Parameter SQN-1 SQN-2 Analysis Total Core Damage 1.00E-CDFT 1.00E-04[Note 1] 1.00E-04[Note 1]

Frequency/yr 04 Core Damage Frequency Due to CDFSEIS 4.41E-05 5.1E-05[Note 2] 5.1E-05[Note 2]

Seismic Event/yr 7

For SOV CIVs the generic values from the WCAP are used. SRV - Water relief are also treated independently from the generic analysis.

8 The Lead Plant analysis assumed only one additional actuation per year for a total of five. The SQN analysis applies the same assumption.

Table 4-1 Core Damage Frequencies Generic Input Parameter SQN-1 SQN-2 Analysis Core Damage Frequency/yr Due to 1.75E-08[Ref 7 Tbl CDFSGTR 9.44E-06 6] 1.78E-08[Ref 7 Tbl 6]

Steam Generator Tube Rupture Note 1: The SQN Internal Events + Internal Flooding Rev. 6 model quantifies a CDF of 1.59E-05 and 1.48E-05 [Ref 1] for Units 1 and 2, respectively. Similar to the generic analysis and lead plant analysis SQN does not have a full scope PRA; therefore, a generic value of 1.00E-04/yr is used in the analysis to represent the total CDF from internal and external events.

Note 2: The generic core damage frequency due to a seismic event (CDFSEIS) per year was obtained from the results of GI-199. [Ref 6]

The seismic frequency used in the plant specific analysis is greater than that used in the generic analysis. Therefore, generic calculations that required the large release due to seismic CDF calculation are recalculated for SQN to ascertain the CT.

4.6.3 Valve Failure Probabilities, Pftc (Per Demand)

Table 4 Valve Fail-To-Close and Fail-To-Reseat Probabilities Generic Valve Type Failure Mode Parameter SQN[Note 1]

Analysis AOV[Note 2] Fail-To-Close AOVftc-aov 1.81E-02 5.76E-04 CKV Fail-To-Close CKVftc-ckv 3.44E-02 1.04E-04 MOV Fail-To-Close MOVftc-mov 1.09E-02 2.77E-04 SOV Fail-To-Close SOVftc-Sov 1.81E-02 9.54E-04 SRV - Steam[Note 3] Fail-To-Reseat SRVftc-srvs 2.50E-02 6.76E-05 SRV - Water Fail-To-Reseat SRVftc-srvw 2.50E-02 6.25E-02 As indicated in Table 4-2, the SQN inputs for valve failures (with exception of SRV-Water) are bounded by the generic analysis. Generic calculations that included water release SRVs are re-analyzed for the CT applicable to SQN.

Note 1: PRA model of Record, rev. 1, CAFTA .rr file. SOV-FTC (9.54E-04) is from NUREG/CR-6928 as SQN does not model this valve/mode in the PRA.

Note 2: AOVs are grouped into three categories, the most restrictive value is used for this analysis.

Note 3: SRVs are split into two categories, steam release (6.76E-05) and water release (6.25E-02). Table 8-1 from the WCAP [Ref 5] does not differentiate between water and steam. Judging from the value used in the generic analysis the steam and water relief SRVs may have been treated together.

4.6.4 Valve Failure Probabilities, Beta and Gamma Factors Table 4 Generic and SQN Specific Beta, Gamma Factors Generic Analysis SQN [Note 1]

Valve Parameter (Valve fail-to-close, (Valve fail-to-close, Type betaftc) betaftc)

AOV betaftc-aov 0.1 1.63E-02 CKV betaftc-ckv 0.1 8.50E-03 MOV betaftc-mov 0.088 1.54E-02 SOV betaftc-sov 0.1 0.1 [Note 2]

SRV-betaftc-srvS 0.22 7.19E-02 Steam SRV-betaftc-srvW 0.22 0.22 [Note 2]

Water Due to Valve all valve Transferring Open, 0.1 0.1 [Note 2]

types betato Due to Valve all valve Transferring Open, 0.5 0.5 [Note 2]

types gammato Note 1 - The conservative generic valves for SOVs and SRV-Water failure-to-close is used in the SQN analysis.

Note 2 - The conservative generic values for the beta and gamma values are used in the SQN analysis.

The SQN parameters listed in Table 4-3 are bounded by those used in the generic analysis.

4.6.5 Spurious (Transfer) Open Probabilities and Beta Factors Table 4-4 Spurious Open and Beta Factor Values Parameter Component Description Value Source Probability AOV AOV XO spuriously opens per 1.82E-07 NUREG/CR-hour 5496 (Section Beta factor - AOV 2.4)

AOVBETA 1.63E-02 Air- spuriously opens Operated Probability AOV Ptopre-aov Valve spuriously opens during 7.28E-07 Calculated 4-hr CT Probability AOV Pto-aov spuriously opens during 3.06E-05 Calculated 168-hr CT Probability CKV NUREG/CR-Check CKV XO spuriously opens per 2.96E-08 6928 (Table 5-1)

Valve hour (Leakage)

Parameter Component Description Value Source Beta factor - CKV Fails NUREG/CR-CKVBETA 3.0E-02 5496 (2.5.1.2) to Remain Closed Probability CKV Ptopre-ckv spuriously opens during 1.18E-07 Calculated 4-hr CT Probability CKV Pto-ckv spuriously opens during 4.97E-06 Calculated 168-hr CT Probability MAN NUREG/CR-MAN XO spuriously opens per 6.67E-08 6928 (Table 5-1) hour (Leak)

Beta factor - MAN WCAP (Generic)

MANBETA 0.1 spuriously opens Manual Probability MAN Valve Ptopre-man spuriously opens during 2.67E-07 Calculated 4-hr CT Probability MAN Pto-man spuriously opens during 1.12E-05 Calculated 168-hr CT Probability MOV NUREG/CR-MOV XO spuriously opens per 4.45E-08 6928 (Table 5-1) hour Beta factor - MOV NUREG/CR-MOVBETA 2.67E-02 Motor- spuriously opens 5496 (2.3.1.2)

Operated Probability MOV Ptopre-mov Valve spuriously opens during 1.78E-07 Calculated 4-hr CT Probability MOV Pto-mov spuriously opens during 7.48E-06 Calculated 168-hr CT Probability SRV (Water or Steam Release)

SRV XO 2.12E-07 Calculated spuriously opens per hour Beta factor - SRV-Water SRVBETA-W fails to reseat after 0.22 WCAP opening Safety Beta factor - SRV-Water SRVBETA-S Relief Valve fails to reseat after 0.22 WCAP opening Probability SRV-Water Ptopre-srv or Steam spuriously 8.48E-07 Section 4.6.1 opens during 4-hr CT Probability SRV-Water Pto-srv or Steam spuriously 3.56E-05 Section 4.6.1 opens during 168-hr CT Solenoid Probability SOV NUREG/CR-SOV XO Operated spuriously opens per 9.23E-08 6928 (Table 5-1)

Valve hour

Parameter Component Description Value Source Beta factor - SOV WCAP (Generic)

SOVBETA 0.1 spuriously opens Probability SOV Ptopre-sov spuriously opens during 3.69E-07 Calculated 4-hr CT Probability SOV Pto-sov spuriously opens during 1.55E-06 Calculated 168-hr CT The values listed in Table 4-4 are bounded by those used in the generic analysis.

4.6.6 Additional Inputs Table 4-5 Additional Inputs Generic Parameter Description Value Source Value Seismic Pipe Break Probability for PBSEIS 1.0 1.0 Assumed Non-Seismically Qualified Pipe Random Pipe Break Frequency Ref. 9 Table E-PBRANDOM 1.10E-03 3.14E-03 (per year)1 1 Probability that Valve Spuriously Calculated Ptopre Transfers Open During 4-Hr CT 4.00E-06 8.48E-07 Section 4.6.1 (most limiting valve)

Probability that Valve Spuriously Calculated Pto Transfers Open During 168-Hr CT 1.68E-04 3.56E-05 Section 4.6.1 (most limiting valve)

Probability that a CIV is Disabled Calculated Pm1 due to Maintenance (per demand) 4.00E-06 2.28E-06 Section 4.6.1 during a 4-hr CT Probability that Extra Valve is Disabled due to Maintenance (per Calculated PmE Any Valve 4.11E-05 demand) [assume extra valve Section 4.6.1 currently has 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months CT]

Probability that a CIV is Disabled Calculated Pm2 due to Maintenance (per demand) Any Valve 9.59E-05 Section 4.6.1 during a 168-hr CT Note 1 - The random (passive) pipe break frequency is based on the most limiting frequency used in the SQN internal flooding analysis.

The values listed in Table 4-5 are bounded by those used in the generic analysis with exception to the random pipe break frequency. Therefore, the generic analysis that include the random pipe break frequency are reanalyzed for SQN to determine the applicable CT.

4.7 Application Tiers 1, 2 and 3 4.7.1 Tier 1 PRA Applicability and Insights The SQN PRA was subjected to a full scope Peer Review in accordance with R.G. 1.200

[Ref 4] requirements in 2011. The conclusions of the peer review team follow: [Ref 13]

The overall model structure is robust and well-developed, but needs refinement,

Documentation is thorough, detailed and well-organized such that comparison with the standard is facilitated,

The process and tools utilized are at the state-of-technology and generally consistent with Capability Category II, and

The PRA maintenance and update program includes all necessary processes and does a very good job of tracking pending changes.

The following areas are addressed:

1. Assurance that the plant-specific PRA reflects the as-built, as-operated plant.

A key attribute to the ASME/ANS Standard is to assess how the PRA modeled the as-built as-operated plant. The Data Analysis technical element addresses this. The PRA model at the time of the Peer Review was judged to meet this requirement, and HLR-MU-B stated that a PRA configuration control process is in place, and governed by procedure which provides a reasonable assurance that the as-built, as-operated planted is reflected through routine maintenance and upgrades to the PRA.

2. Assurance that the applicable PRA updates include the findings from the individual plant evaluation (IPE) and the IPE for External Events.

The SQN PRA has been updated multiple times since the completion of the IPE and IPEEE from the 1990s. The technical adequacy of the PRA was established by Peer Review in early 2011. The current model of record represents a significantly more mature PRA as compared to the IPE and IPEEE.

3. Assurance that conclusions from the peer review, including facts and observations that are applicable to this application have been resolved.

For areas, whereby the Peer Review determined work was necessary to meet Capability Category II a Facts & Observation (F&O) was initiated. The resolutions to the F&Os are documented in the PRA Summary Notebook. [Ref 7]

4. Assurance that there is PRA configuration control and updating, including PRA quality assurance programs, associated procedures, and PRA revision schedules.

TVA procedure NPG-SPP-09.11, Probabilistic Risk Assessment (PRA) Program, covers the management of PRA applications and periodic PRA updates. Periodic changes made to the base plant-specific PRA model are required to incorporate system, structure, component and operating philosophy changes, and new plant-specific data.

5. Assurance that there is PRA adequacy, completeness, and applicability with respect to evaluating the risk associated with the proposed CIV CT extensions.

SQN specific parameters and PRA results applicable to the proposed risk-informed application of CIV completion time extensions are well documented in references 7 through 10. The PRA has been subjected to a Peer Review in early 2011 that assessed the technical adequacy of the SQN PRA.

6. Assurance that plant design or operational modifications that are related to or could impact the proposed CT extensions are reflected in the PRA revision used in the plant-specific application, or a justification for not including those modifications in the PRA.

In accordance with TVA procedure NPG-SPP-09.11, "Probabilistic Risk Assessment (RPA) Program," plant modifications or design changes that result in new configurations, alignments, and capabilities of plant system are assessed for inclusion in model updates. Furthermore TVA procedure NEDP-26 "Probabilistic Risk Assessment (PRA)" provides the requirements for the cumulative impact of plant configuration changes, including plant-specific design, procedure and operational changes that require an update to the Model of Record.

4.7.2 Tier 2 Avoidance of Risk-Significant Plant Configurations The process SQN uses to avoid risk-significant plant configurations is governed by TVA procedure NPG-SPP-07.1, "On-Line Risk Management." The procedure applies to all work activities that affect or have the potential to affect a plant component, system, or unit configuration. A risk assessment methodology is used for on-line maintenance and shutdown operations. For on-line maintenance, a risk assessment is performed prior to implementation and emergent work is evaluated against the assessed scope. Shutdown risk is assessed in accordance with TVA procedure NPG-SPP-07.2, "Outage Management." Furthermore, TVA procedure NPG-SPP-07.3, "Work Activity Risk Management Process" provides an integrated process for assessing and reducing the likelihood and/or consequences of an adverse event.

SQN employs a work management process that utilizes Functional Equipment Groups (FEGs).

The grouping qualitatively assessed work activities and components and made logic ties that prevent certain risk-significant plant configurations for being scheduled simultaneously.

4.7.3 Tier 3 Risk-Informed Configuration Risk Management In accordance with the requirements of 10CFR50.65(a)(4) SQN assesses and manages plant configurations prior to taking the maintenance configuration. The proposed plant configuration is modeled in the computer code EOOS (Equipment Out Of Service) to determine the change in the core damage frequency (CDF) and the large early release frequency (LERF). The initial risk assessment is performed six - nine weeks prior to implementation to allow for risk-informed sequencing of activities as necessary and for other actions determined based on risk insights gleaned from the initial assessment. The well defined process is governed by TVA procedure NPG-SPP-07.1, "On-Line Risk Management." The quantified change in risk is used as one input with respect to configuration risk management. Furthermore, the process prescribes successive higher levels of management approval for plant configurations resulting in an increase in risk at various levels. Although not quantified, work management compensatory measures are prescribed as the risk level increases to limit the likelihood of entering an unplanned configuration (i.e., protected trains/equipment) or to limit the consequences of an

unattended action. Outage Risk Management is controlled in accordance with TVA procedure NPG-SPP-7.2.11.

4.8 SQN Specific Analysis 4.8.1 Fault Trees and Applicable Penetrations The following fault trees were developing to calculate the given penetration configuration.

Table 4-6 Class I Classification and Penetrations:

Class / Group SQN FT ID Calculation Applicable Penetrations Number I_A-1_4 I, A#1 I,B#3 I,C#3 X-79A X-79B X-80 X-82 X-83 I_A-1_168 X-4 X-5 X-6 X-7 X-9A X-9B X-10A X-I_A-3_4 10B X-11 I,A#3 I,B#5 I, X-29 X-43A X-43B X-43C X-43D X-47A X-47B X-C#5 I_A-3_168 50A X-52 X-57 X-58 X-59 X-60 X-61 X-62 X-63 I_A-4-4 I,A#4 X-42 X-50B X-51 X-78 X-111 X-112 X-113 I_A-4-168 I_B-1-4 I,B#1 X-35 X-88 X-117 X-118 I_B-1-168 I_B-4-4 I,B#4 X-40D(U1) X-40D(U2) X-48A X-48B X-49A X-49B I_B-4-168 I_B-5-4 I,B#5 X-46 I_B-5-168 I_B-6-4 I,B#6 X-53 I_B-6-168 I_C-1-4 I,C#1 X-19A X-19B I_C-1-168

Table 4-7 Class II Classification and Penetrations:

Class / Group SQN FT ID Calculation Applicable Penetrations Number II_A-6-4 II,A#6 X-20A X-20B II_A-6-168 II_A-17-4 II,A#17 X-17 X-21 X-32 II_A-17-168 II_B-2-4 II,B#2 X-15 II_B-2-168 II_B-X44-4 II,B#X44 X-44 II_B-X44-168 II-Type A -

N/A X-22 X-33 X-107 Bounding II-Type B -

N/A None Bounding Table 4-8 Class III Classification and Penetrations:

Class / Group SQN FT ID Calculation Applicable Penetrations Number III_A-X12-4 III,A#X12 X-12B X-12C III_A-X12-8 III_A-X13-4 III,A#X13 X-13A X-13B X-13C X-13D III_A-X13-8 III_A-X14-4 III,A#14 X-14A X-14B X-14C X-14D III_A-X14-8 III-Type A - X-12A X-12D N/A Bounding III-Type B - None N/A Bounding Table 4-9 All Classes - Penetrations With CT Extensions Based on WCAP Generic Analyses Applicable Penetrations X-16 X-24 X-25C X-26C X-27D X-86A X-86B X-86C X-102 X-104

Table 4-10 Penetrations with One or More Valves Crediting the Small Line Exclusion Applicable Penetrations X-4 X-5 X-6 X-7 X-9A X-9B X-10A X-10B X-11 X-15 X-16 X-17 X-19A X-19B X-20A X-20B X-21 X-22 X-23 X-24 X-25A(U1) X-25A(U2) X-25B(U1) X-25B(U2) X-25D(U1) X-25D(U2)

X-26A X-26B(U1) X-26B(U2) X-27A X-27B X-27C X-29 X-30 X-32 X-33 X-34(U1)

X-34(U2)

X-35 X-39A X-39B X-41 X-42 X-43A X-43B X-43C X-43D X-45 X-46 X-47A X-47B X-48A X-48B X-49A X-49B X-50A X-50B X-51 X-52 X-56 X-57 X-58 X-59 X-60 X-61 X-62 X-63 X-64 X-65 X-66 X-67 X-68(U2) X-69(U2) X-70(U2) X-71(U2) X-72(U2) X-73(U2)

X-74(U2)

X-75(U2) X-76(U1) X-76(U2) X-77 X-78 X-80 X-82 X-83 X-84A X-85B X-85C X-87B X-87D X-90(U1) X-90(U2) X-91 X-92A(U1) X-92A(U2) X-92B(U1) X-92B(U2) X-93(U1) X-93(U2)

X-94A X-94B X-94C X-95A X-95B X-95C X-96C(U1) X-96C(U2) X-97 X-98 X-99(U1) X-99(U2)

X-100(U1) X-100(U2) X-101 X-102 X-103 X-104 X-106 X-107 X-111 X-112 X-113 X-114 X-115 X-116A Table 4-11 Penetrations with No Generic Fit - Not Analyzed By PRA Applicable Penetrations X-40A X-40B X-108 X-109 4.8.2 Calculations / Inputs Two calculations are performed to determine the acceptability of the extended CT. The Incremental Conditional Large Early Release Probability (ICLERP) is based on R.G. 1.177 [Ref 3] acceptable criteria of <5.0E-08. The change in the large early release frequency (LERF) is based on the R.G. 1.174 [Ref 2] acceptance criteria of <1.0E-07/yr.

a) Class I - penetrations connected to the containment atmosphere; a failure to isolate a penetration would result in a release path to the environment. Four types:

Type A - Flow paths connected directly to containment atmosphere and the outside environment.

Type B - Flow paths closed inside containment and connected directly to the outside environment.

Type C - Flow paths connected directly to containment atmosphere and closed outside containment.

Type D - Flow paths closed inside containment and closed outside containment.

Class I Penetrations - Flow Paths Connected to the Containment Atmosphere Release Details Comment Input(s)

Type Release due to an internal For open systems a direct event CDF. If core damage Non-

CDFT connection from inside to occurs simultaneous with a seismic

CT outside containment is failure to isolate (spurious CDF

Valve Failure possible given a failure to open, fail-to-close, etc.) the Release Probability isolate the penetration. penetration a large release could occur.

Closed systems - seismic For closed systems (either event breaches both sides of inside or outside of

CDFseis containment. If this were to Seismic containment), a seismic-

CT occur simultaneous with CDF induced core damage

PBSEIS failure to isolate the Release event, the assumption is

Valve Failure penetration, an open pathway made that the closed loop Probability to the environment would system piping fails.

exist.

Release due to an internal event and a random pipe Random The configuration would be

CDFT break. A random pipe break Pipe based on the system being

CT of the closed system Break open on one side of

PBRANDOM simultaneous with a failure to CDF containment and the other

Valve Failure isolate the penetration would Release closed. Probability present a flow path to the environment.

b) Class II - penetration flow paths connected to the reactor coolant system. Two types:

Type A - Standby system flow paths.

Type B - Normally operating system flow paths.

Class II Penetrations - Flow Paths Connected to the Reactor Coolant System Release Details Comment Input(s)

Type Release due to an internal Non- event CDF. Core damage

CDFT seismic Connected to the RCS and simultaneous with CIV failure

CT CDF open outside containment. to isolate (spurious open, fail-

Valve Failure Release to-close, etc.) the penetration Probability a large release could occur.

Release due to seismic event For system connected to resulting in core damage

CDFSEIS the RCS and open outside whereby all closed loop Seismic

CT it is assumed that a piping fails both inside and CDF

PBSEIS seismic event results in outside containment Release

Valve Failure core damage. simultaneous with CIV failure creating an opening to the Probability environment.

Release Details Comment Input(s)

Type Release due to an internal event and a random pipe break. If core damage were Random to occur simultaneous with a

CDFT Pipe For systems connected to random pipe break inside

CT Break the RCS and open outside containment and a failure to

PBRANDOM CDF containment. isolate the penetration, the

Valve Failure Release system would no longer be Probability connected to the RCS, therefore, allowing an open flow path to the environment.

Interfacing Release due to containment System For standby systems bypass, if the CIVs fail (CIV Loss of

Valve Failure connected to the RCS and failure is the initiator), an Coolant Probability open outside containment. ISLOCA would occur Accident resulting in core damage.

(ISLOCA) c) Class III - penetrations with flow paths connected to the steam generators. Two types:

Type A - Flow paths connected to the steam generator secondary side and open to the outside environment.

Type B - Flow paths connected to the steam generator secondary side and closed to the outside environment.

Class III Penetrations - Flow Paths Connected to the Steam Generator Secondary Side Release Details Comment Input(s)

Type Release due to seismic event resulting in core damage For systems connected to

CDFSEIS whereby all closed loop Seismic the SG secondary side and

CT piping fails both inside and CDF open or closed outside

PBSEIS outside containment Release containment.

Valve Failure simultaneous with CIV failure creating an opening to the Probability environment.

Release due to an internal event and a random pipe break. If core damage were to occur simultaneous with a Random

CDFT random pipe break inside Pipe For systems connected to

CT containment and a failure to Break the SG secondary side and

PBRANDOM isolate the penetration, the CDF open outside containment.

Valve Failure system would no longer be Release Probability connected to the SGs, therefore, allowing an open flow path to the environment.

Release Details Comment Input(s)

Type Release due to SGTR Steam For systems connected to simultaneous with a core

CDFSGTR Generator the steam generator damage event and failure to

Valve Failure Tube secondary side and open isolate the penetration which Probability Rupture to the outside atmosphere. would result in an open

CT (SGTR) pathway to the environment Steam Generator Tube Random pipe break outside

CDFSGTR For systems connected to Rupture of containment followed by a

PBRANDOM the SG secondary side and (SGTR) SGTR and CIV failure would

Valve Failure a closed systems outside With result in an open path to the Probability containment.

Random environment.

CT Pipe Break 5.0 Results The results of the generic analysis and the SQN specific analysis are recorded in Attachment 1.

Many CIVs were justified at 168-hr CTs based on application of the generic analysis.

Justification could not be made for some CIVs, therefore their CTs remain at 4-hrs.

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-4 30-56 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-57 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-555TP No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

X-5 30-58 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-59 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-554TP No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

X-6 30-50 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

Page 1 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 30-51 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

X-6 30-558TP No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

X-7 30-52 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-53 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-557TP No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

X-9A 30-8 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-7 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30- No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs 563TP smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

Page 2 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-9B 30-10 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

X-9B 30-9 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-562TP No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

X-10A 30-15 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-14 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-561TP No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

X-10B 30-17 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

Page 3 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 30-16 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30- No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs 560TP smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

X-11 30-20 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-19 This valve is normally closed but is I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs intermittently opened to provide for System pressure boundary compromised 168-hrs 168-hrs 168-hrs containment min-purge during power operation. Assume more limiting condition of valve open. Same valve type IC and OC.

30-559TP No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release. Normally closed valve.

X-12A 3-33 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.3, MFIV.

3-164 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.5, AFW.

3-164A THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.5, AFW.

3-174 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.5, AFW.

Page 4 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 3-904 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-903 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-857 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-12A 3-889 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs (cont) Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-849 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-853 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

U2 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs ONLY Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs 2-3-504 Normally closed valve OC.

X-12B 3-47 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.3, MFIV.

3-502 Direct connection to Steam Generator. III-A-12BC System pressure boundary maintained 8-hrs 8-hrs 8-hrs Closed system IC to open system OC. System pressure boundary compromised 8-hrs 8-hrs 8-hrs Normally closed valve OC. Drain valve assume same CT as 3-47.

X-12C 3-87 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.3, MFIV.

Page 5 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 3-500 Direct connection to Steam Generator. III-A-12BC System pressure boundary maintained 8-hrs 8-hrs 8-hrs Closed system IC to open system OC. System pressure boundary compromised 8-hrs 8-hrs 8-hrs Normally closed valve OC. Drain valve assume same CT as 3-87.

X-12D 3-100 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.3, MFIV.

3-171 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.5, AFW.

3-171A THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.5, AFW.

X-12D 3-175 THIS VALVE IS NOT COVERED BY ITS N/A (cont) SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.5, AFW.

3-907 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-906 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-858 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-890 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-850 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

3-854 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

Page 6 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

UNIT 2 Direct connection to Steam Generator. III,A System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs ONLY Closed system IC to open system OC. Bounding System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs 2-3-506 Normally closed valve OC.

X-13A 1-5 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.4, ARV.

1-4 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.2, MSIV.

1-147 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-13A 1-15 THIS VALVE IS NOT COVERED BY ITS N/A (cont) SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.5, AFW.

1-522 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-523 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-524 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-525 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-526 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-922 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

Page 7 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 1-536 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-13B 1-12 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.4, ARV.

1-11 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.2, MSIV.

1-148 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-13B 1-517 THIS VALVE IS NOT COVERED BY ITS N/A (cont) SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-518 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-519 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-520 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-521 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-923 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

1-534 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

Page 8 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-13C 1-23 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.4, ARV.

1-22 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.2, MSIV.

1-149 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

1-512 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

X-13C 1-513 THIS VALVE IS NOT COVERED BY ITS N/A (cont) SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-514 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-515 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-516 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-924 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

1-532 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-13D 1-30 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.4, ARV.

Page 9 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 1-16 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.3, MFIV.

1-150 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

1-29 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.2, MSIV.

1-527 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

X-13D 1-528 THIS VALVE IS NOT COVERED BY ITS N/A (cont) SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-529 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-530 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-531 THIS VALVE IS NOT COVERED BY ITS N/A SECTION 3.6.3. IT IS COVERED BY ITS SECTION 3.7.1, MSSV.

1-925 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

1-538 Direct connection to Steam Generator. III-A-13 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-14A 1-182 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve IC.

Page 10 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 1-14 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve OC.

43-58 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve OC.

1-825 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-14B 1-184 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve IC.

X-14B 1-32 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs (cont) Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve OC.

43-64 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve OC.

1-827 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-14C 1-183 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve IC.

1-25 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve OC.

43-61 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve OC.

1-826 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

Page 11 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-14D 1-181 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve IC.

1-7 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve OC.

43-55 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally open valve OC.

1-824 Direct connection to Steam Generator. III-A-14 System pressure boundary maintained 8-Hrs 8-Hrs 8-Hrs Closed system IC to open system OC. System pressure boundary compromised 8-Hrs 8-Hrs 8-Hrs Normally closed valve OC.

X-15 62-72 Normally operating system; RCS II-B-2 System pressure boundary maintained 168-Hrs 168-Hrs 168-Hrs connection. 3 Valves IC, 1 normally open, 2 System pressure boundary compromised 168-Hrs 168-Hrs 168-Hrs normally closed. 1 Valves OC, normally open. All Valves the same type. This valve normally closed IC.

62-73 Normally operating system; RCS II-B-2 System pressure boundary maintained 168-Hrs 168-Hrs 168-Hrs connection. 3 Valves IC, 1 normally open, 2 System pressure boundary compromised 168-Hrs 168-Hrs 168-Hrs normally closed. 1 Valves OC, normally open. All Valves the same type. This valve normally open IC.

62-74 Normally operating system; RCS II-B-2 System pressure boundary maintained 168-Hrs 168-Hrs 168-Hrs connection. 3 Valves IC, 1 normally open, 2 System pressure boundary compromised 168-Hrs 168-Hrs 168-Hrs normally closed. 1 Valves OC, normally open. All Valves the same type. This valve normally closed IC.

Page 12 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)62-662 Normally operating system; This valve is a Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs PRESSURE RELIEF VALVE, WHICH Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs RELIEVES TO THE PRESSURIZER RELIEF TANK INSIDE CONTAINMENT and is not directly connected to the RCS, Given this scenario, flow path is also smaller in size than that required to result in a large release.

62-77 Normally operating system; RCS II-B-2 System pressure boundary maintained 168-Hrs 168-Hrs 168-Hrs connection. 3 Valves IC, 1 normally open, 2 System pressure boundary compromised 168-Hrs 168-Hrs 168-Hrs normally closed. 1 Valves OC, normally open. All Valves the same type. This valve normally open OC.62-707 This is a normally closed test valve which Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs communicates with containment atmosphere Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs not RCS for flow thru valve from IC to OC.

Therefore flow path is smaller in size than that required to result in a large release.

X-16 62-543 Normally operating system; RCS II,B #3 System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection. 1 CIV IC normally open - 1 CIV System pressure boundary compromised 168 hrs 168 hrs 168 hrs OC, normally open - different valve types (The normally open check valve IC has another normally open check valve in series between it and the RCS) (The normally open CIV OC has another normally open valve downstream of it, same valve type) 62-90 Normally operating system; RCS II,B #3 System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection. 1 CIV IC normally open - 1 CIV System pressure boundary compromised 168 hrs 168 hrs 168 hrs OC, normally open - different valve types (The normally open check valve IC has another normally open check valve in series between it and the RCS) (The normally open CIV OC has another normally open valve downstream of it, same valve type)

Page 13 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)62-709 Normally operating system; RCS Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs connection. Continues to operate during Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs accident, therefore not considered a path for release directly from RCS since flow continues to be forced into RCS; therefore, release scenario is from containment atmosphere, flow path is smaller in size than that required to result in a large release.62-544 This is a normally closed test valve which Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs communicates with containment atmosphere Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs not RCS for flow thru valve from IC to OC.

Therefore flow path is smaller in size than that required to result in a large release.

X-17 63-640 RCS connection; standby system. Open II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs system IC. Closed system OC. Normally System pressure boundary compromised 4-hrs 4-hrs 4-hrs closed valve IC.63-643 RCS connection; standby system. Open II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs system IC. Closed system OC. Normally System pressure boundary compromised 4-hrs 4-hrs 4-hrs closed valve IC.

X-17 63-158 No direct connection to RCS piping; flow Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) path smaller in size than that required to Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs result in a large release.63-172 RCS connection; standby system. Open II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs system IC. Closed system OC. Normally System pressure boundary compromised 4-hrs 4-hrs 4-hrs closed valve IC.63-637 No direct connection to RCS piping; flow Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs path smaller in size than that required to Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs result in a large release.63-636 No direct connection to RCS; Only release Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs path is from containment atmosphere to Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs environment via RHA. Flow path smaller in size than that required to result in a large release.

Page 14 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)63-642 No direct connection to RCS; Only release Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs path is from containment atmosphere to Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs environment via RHA. Flow path smaller in size than that required to result in a large release.63-870 No direct connection to RCS; Only release Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs path is from containment atmosphere to Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs environment via RHA. Flow path smaller in size than that required to result in a large release.

X-19A 63-72 Standby system. Containment atmosphere I-C-1 System pressure boundary maintained 168-hrs 168-hrs 168-hrs at sump. Closed system OC. 1 valve - Pressure Boundary Compromised 4-hrs 4-hrs 4-hrs normally closed (OC or IC)63-593 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-591 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-19B 63-73 Standby system. Containment atmosphere I-C-1 System pressure boundary maintained 168-hrs 168-hrs 168-hrs at sump. Closed system OC. 1 valve - Pressure Boundary Compromised 4-hrs 168-hrs 4-hrs normally closed (OC or IC)63-592 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-590 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-20A 63-112 No direction connection to RCS piping; Line Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs isolated by 2 normally closed valves. Valve Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs is IC; only release path is from containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

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ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)63-635 RCS connection; standby system. 2 check II-A-6 System pressure boundary maintained 168-hrs 168-hrs 168-hrs valves IC each have another normally System pressure boundary compromised 168-hrs 168-hrs 168-hrs closed check valve in series. 2 valves OC in parallel. 1 normally open and 1 normally closed.

RCS connection; standby system. 2 check valves IC each have another normally System pressure boundary maintained 168-hrs 168-hrs 168-hrs63-633 closed check valve in series. 2 valves OC in II-A-6 System pressure boundary compromised 168-hrs 168-hrs 168-hrs parallel. 1 normally open and 1 normally closed.

RCS connection; standby system. 2 check valves IC each have another normally System pressure boundary maintained 168-hrs 168-hrs 168-hrs 63-94 closed check valve in series. 2 valves OC in II-A-6 System pressure boundary compromised 168-hrs 168-hrs 168-hrs parallel. 1 normally open and 1 normally closed.

RCS connection; standby system. 2 check valves IC each have another normally System pressure boundary maintained 168-hrs 168-hrs 168-hrs63-631 closed check valve in series. 2 valves OC in II-A-6 System pressure boundary compromised 168-hrs 168-hrs 168-hrs parallel. 1 normally open and 1 normally closed.

X-20A 63-667 No direction connection to RCS piping; valve Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) is IC; only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-661 No direction connection to RCS piping; valve Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs is IC; only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

Page 16 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)63-833 No direction connection to RCS piping; valve Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs is IC; only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

X-20B 63-111 No direction connection to RCS piping; Line Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs isolated by 2 normally closed valves. Valve Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs is IC; only release path is from containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-632 RCS connection; standby system. 2 check II-A-6 System pressure boundary maintained 168-hrs 168-hrs 168-hrs valves IC each have another normally System pressure boundary compromised 168-hrs 168-hrs 168-hrs closed check valve in series. 2 valves OC in parallel. 1 normally open and 1 normally closed.63-634 RCS connection; standby system. 2 check II-A-6 System pressure boundary maintained 168-hrs 168-hrs 168-hrs valves IC each have another normally System pressure boundary compromised 168-hrs 168-hrs 168-hrs closed check valve in series. 2 valves OC in parallel. 1 normally open and 1 normally closed.

X-20B 63-93 RCS connection; standby system. 2 check II-A-6 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) valves IC each have another normally System pressure boundary compromised 168-hrs 168-hrs 168-hrs closed check valve in series. 2 valves OC in parallel. 1 normally open and 1 normally closed.63-630 RCS connection; standby system. 2 check II-A-6 System pressure boundary maintained 168-hrs 168-hrs 168-hrs valves IC each have another normally System pressure boundary compromised 168-hrs 168-hrs 168-hrs closed check valve in series. 2 valves OC in parallel. 1 normally open and 1 normally closed.

Page 17 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)63-413 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-659 No direction connection to RCS piping; valve Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs is IC; only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-660 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

X-21 63-167 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-547 RCS connection; standby system; normally II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs closed check valve IC; another check valve System pressure boundary compromised 4-hrs 4-hrs 4-hrs upstream IC.63-549 RCS connection; standby system; normally II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs closed check valve IC; another check valve System pressure boundary compromised 4-hrs 4-hrs 4-hrs upstream IC.

X-21 63-157 No Direct connection to RCS; Open system II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) IC to closed system OC; Normally closed System pressure boundary compromised 4-hrs 4-hrs 4-hrs valve OC.63-648 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

Page 18 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)63-649 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-650 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-862 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-313A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-314A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

X-21 63-317A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-318A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

Page 19 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-22 63-174 Connected to RCS accumulators thru Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs another normally closed FCV. Not directly Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs connected to RCS.63-581 RCS connection; standby system. Open Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs system IC and closed system OC. Normally Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs closed valve OC.

63-25 RCS connection; standby system. Open Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs (FCV) system IC and closed system OC. Normally Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs closed valve OC.

63-26 RCS connection; standby system. Open Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs (FCV) system IC and closed system OC. Normally Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs closed valve OC.

Unit 2 Not directly connected to RCS. Drain or Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Only vent valve. Flow path smaller in size than Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs 2-63-816 that required to result in a large release.

63-25 Not directly connected to RCS. Open Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (FSV) system IC to closed system OC. Normally Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs closed valve OC.

63-26 Not directly connected to RCS. Open Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (FSV) system IC to closed system OC. Normally Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs closed valve OC.

X-23 43-310 Lines connected to the RCS 3/8" in diameter Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs or less are within the makeup capability of Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs plant's charging systems and therefore, are not considered small LOCAs or potential containment bypass pathways. (Sec 8.2.3 of WCAP)43-309 Lines connected to the RCS 3/8" in diameter Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs or less are within the makeup capability of Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs plant's charging systems and therefore, are not considered small LOCAs or potential containment bypass pathways. (Sec 8.2.3 of WCAP)

Page 20 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)43-492 Test valve connected to containment Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs atmosphere IC. Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the sampling system. Source piping is 3/8" and smaller than minimum size required for a large release.

X-24 68-559 No direct connection to RCS; penetration I,A#6 System pressure boundary maintained 168 hrs 168 hrs 168 hrs flow path connects open system IC to closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system OC. Normally closed valve IC & OC.

Different valve types. This valve IC.62-505 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-512 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-513 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-511 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-24 63-536 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-535 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-534 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 21 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)63-626 No direct connection to RCS; penetration I,A#6 System pressure boundary maintained 168 hrs 168 hrs 168 hrs flow path connects open system IC to closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system OC. Normally closed valve IC & OC.

Different valve types. This valve OC.63-627 No direct connection to RCS; penetration I,A#6 System pressure boundary maintained 168 hrs 168 hrs 168 hrs flow path connects open system IC to closed System pressure boundary compromised 168 hrs 168 hrs 168 hrs system OC. Normally closed valve IC & OC.

Different valve types. This valve OC.68-560 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.68-561 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-517 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-518 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-638 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-25A 43-2 Lines connected to the RCS 3/8" in diameter Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs or less are within the makeup capability of Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs plant's charging systems and therefore, are not considered small LOCAs or potential containment bypass pathways. (Sec 8.2.3 of WCAP)

Page 22 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 43-3 Lines connected to the RCS 3/8" in diameter Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs or less are within the makeup capability of Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs plant's charging systems and therefore, are not considered small LOCAs or potential containment bypass pathways. (Sec 8.2.3 of WCAP)

X-25B - THE DP SENSORS ARE CLOSED Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs SYSTEMS OUTSIDE OF CONTAINMENT Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs THAT ARE ATTACHED DIRECTLY TO CONTAINMENT. NO ISOLATION VALVES ARE EMPLOYED FOR THESE SENSORS AS THEY USE A DOUBLE DIAPHRAGM SYSTEM FOR DP MEASUREMENT. THE DIAPHRAGMS ARE QUALIFIED FOR POST-LOCA USE. NO DIRECT CONNECTION TO RCS. FLOW PATH SMALLEER THAN THAT REQUIRED TO RESULT IN A LARGE RELEASE.

30-311Y No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

30-311X No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.30-44Y No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-25B 30-44X No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 23 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-25C - THIS LINE TRANSMITS PRESSURE FROM II,A#9 System pressure boundary maintained 168 hrs 168 hrs 168 hrs THE PRIMARY SYSTEM TO PRESSURE System pressure boundary compromised 168 hrs 168 hrs 168 hrs INSTRUMENTATION. THE LINE IS FLUID FILLED AND DOUBLE DIAPHRAGMED TO PREVENT COMMUNICATION BETWEEN THE PRIMARY SYSTEM FLUID AND THE AUXILIARY BUILDING. NO PRIMARY SYSTEM FLUID TRAVELS THROUGH THE PENETRATION SINCE THE INNER DIAPHRAGM IS LOCATED NEAR THE REACTOR VESSEL. SINCE DOUBLE DIAPHRAGMS ARE EMPLOYED FOR CONTAINMENT ISOLATION, NO CONTAINMENT ISOLATION VALVES ARE USED.

X-25D 43-11 Lines connected to the RCS 3/8" in diameter Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs or less are within the makeup capability of Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs plant's charging systems and therefore, are not considered small LOCAs or potential containment bypass pathways. (Sec 8.2.3 of WCAP) 43-12 Lines connected to the RCS 3/8" in diameter Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs or less are within the makeup capability of Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs plant's charging systems and therefore, are not considered small LOCAs or potential containment bypass pathways. (Sec 8.2.3 of WCAP)

Page 24 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-26A - THE DP SENSORS ARE CLOSED Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs SYSTEMS OUTSIDE OF CONTAINMENT Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs THAT ARE ATTACHED DIRECTLY TO CONTAINMENT. NO ISOLATION VALVES ARE EMPLOYED FOR THESE SENSORS AS THEY USE A DOUBLE DIAPHRAGM SYSTEM FOR DP MEASUREMENT. THE DIAPHRAGMS ARE QUALIFIED FOR POST-LOCA USE. NO DIRECT CONNECTION TO RCS. FLOW PATH SMALLEER THAN THAT REQUIRED TO RESULT IN A LARGE RELEASE.

30-310Y No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

30-310X No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.30-43Y No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.30-43X No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-26B 32-102 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 1 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.32-297 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.32-295 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 25 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-26B 32-292 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 1 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

(cont)

X-26B 32-103 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.32-348 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.32-341 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.32-345 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-26C - THIS LINE TRANSMITS PRESSURE FROM II,A#9 System pressure boundary maintained 168 hrs 168 hrs 168 hrs THE PRIMARY SYSTEM TO PRESSURE System pressure boundary compromised 168 hrs 168 hrs 168 hrs INSTRUMENTATION. THE LINE IS FLUID FILLED AND DOUBLE DIAPHRAGMED TO PREVENT COMMUNICATION BETWEEN THE PRIMARY SYSTEM FLUID AND THE AUXILIARY BUILDING. NO PRIMARY SYSTEM FLUID TRAVELS THROUGH THE PENETRATION SINCE THE INNER DIAPHRAGM IS LOCATED NEAR THE REACTOR VESSEL. SINCE DOUBLE DIAPHRAGMS ARE EMPLOYED FOR CONTAINMENT ISOLATION, NO CONTAINMENT ISOLATION VALVES ARE USED.

Page 26 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-27A - THE DP SENSORS ARE CLOSED Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs SYSTEMS OUTSIDE OF CONTAINMENT Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs THAT ARE ATTACHED DIRECTLY TO CONTAINMENT. NO ISOLATION VALVES ARE EMPLOYED FOR THESE SENSORS AS THEY USE A DOUBLE DIAPHRAGM SYSTEM FOR DP MEASUREMENT. THE DIAPHRAGMS ARE QUALIFIED FOR POST-LOCA USE. NO DIRECT CONNECTION TO RCS. FLOW PATH SMALLEER THAN THAT REQUIRED TO RESULT IN A LARGE RELEASE.

30-30CX No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

30-30CY No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-27B - THE DP SENSORS ARE CLOSED Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs SYSTEMS OUTSIDE OF CONTAINMENT Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs THAT ARE ATTACHED DIRECTLY TO CONTAINMENT. NO ISOLATION VALVES ARE EMPLOYED FOR THESE SENSORS AS THEY USE A DOUBLE DIAPHRAGM SYSTEM FOR DP MEASUREMENT. THE DIAPHRAGMS ARE QUALIFIED FOR POST-LOCA USE.30-42Y No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.30-42X No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 27 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-27C 52-504 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-27C 52-505 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.52-510 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-27D - THIS LINE TRANSMITS PRESSURE FROM II,A#9 System pressure boundary maintained 168 hrs 168 hrs 168 hrs THE PRIMARY SYSTEM TO PRESSURE System pressure boundary compromised 168 hrs 168 hrs 168 hrs INSTRUMENTATION. THE LINE IS FLUID FILLED AND DOUBLE DIAPHRAGMED TO PREVENT COMMUNICATION BETWEEN THE PRIMARY SYSTEM FLUID AND THE AUXILIARY BUILDING. NO PRIMARY SYSTEM FLUID TRAVELS THROUGH THE PENETRATION SINCE THE INNER DIAPHRAGM IS LOCATED NEAR THE REACTOR VESSEL. SINCE DOUBLE DIAPHRAGMS ARE EMPLOYED FOR CONTAINMENT ISOLATION, NO CONTAINMENT ISOLATION VALVES ARE USED.

X-29 70-89 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC.70-698 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

70-92 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC.

Page 28 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)70-735 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-30 63-71 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

63-84 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

63-23 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-537 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

63-344A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-32 63-21 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.63-545 RCS connection; standby system; normally II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs closed check valve IC; another check valve System pressure boundary compromised 4-hrs 4-hrs 4-hrs upstream IC.63-543 RCS connection; standby system; normally II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs closed check valve IC; another check valve System pressure boundary compromised 4-hrs 4-hrs 4-hrs upstream IC.63-156 No Direct connection to RCS; Open system II-A-X17 System pressure boundary maintained 168-hrs 168-hrs 168-hrs IC to closed system OC; Normally closed System pressure boundary compromised 4-hrs 4-hrs 4-hrs valve OC.

Page 29 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)63-541 No direct connection to RCS; isolated from Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs RCS by double check valves. Open system Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs IC to closed system OC. Normally closed valve OC. Drain or vent valve. Assume same CT as the shortest CT of other valves in the penetration.

X-32 63-823 No direct connection to RCS piping; Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) IC; Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-657 No direct connection to RCS piping; Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs IC; Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-658 No direct connection to RCS piping; Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs IC; Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-864 No direct connection to RCS piping; Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs IC; Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-315A No direct connection to RCS piping; Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs IC; Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

Page 30 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 63-316A No direct connection to RCS piping; Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs IC; Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-311A No direct connection to RCS piping; Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs IC; Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

X-32 63-612A No direct connection to RCS piping; Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) IC; Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

X-33 63-551 RCS connection; standby system; open Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs system IC to closed system OC. Normally Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs closed valve IC.63-553 RCS connection; standby system; open Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs system IC to closed system OC. Normally Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs closed valve IC.63-555 RCS connection; standby system; open Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs system IC to closed system OC. Normally Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs closed valve IC.63-557 RCS connection; standby system; open Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs system IC to closed system OC. Normally Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs closed valve IC.63-121 No direction connection to RCS, standby Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs system. Isolated from RCS by at least 2 Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs normally closed valves. Open system IC to closed system OC. Normally closed valve IC. Flow path is smaller than minimum size required for a large release.

Page 31 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 63-22 Penetration flow path connects OPEN Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs system IC to closed system OC. Normally Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs open valve OC.63-653 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

X-33 63-654 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-655 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-836 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-656 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.63-831 No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

Page 32 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 63-325A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-326A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

X-33 63-319A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-320A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-321A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-322A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

63-323A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

Page 33 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 63-324A No direction connection to RCS piping; Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Valve is IC; Only release path is from Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs containment atmosphere to environment via the SIS system. Flow path is smaller than minimum size required for a large release.

X-34 32-377 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 1 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.32-110 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-34 32-375 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 1 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

(cont)32-373 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-34 32-387 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.32-111 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.32-385 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.32-383 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-35 70-85 No direct connection to RCS; penetration I-B-1 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects closed system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC.70-703 No direct connection to RCS; penetration I-B-1 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects closed system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC.

Page 34 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 70-702C No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.70-762 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

70-702F No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.70-764 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-35 Unit 2 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) Only smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs 2-70-759 a large release.

X-39A 77-868 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

63-64 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.77-867 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-39B 77-849 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.68-305 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.77-848 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 35 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-40A 3-156 THIS VALVE IS NOT COVERED BY TECH N/A SPEC 3.6.3. IT IS COVERED BY TECH SPEC SECTION 3.7.5, AFW.

3-156A THIS VALVE IS NOT COVERED BY TECH N/A SPEC 3.6.3. IT IS COVERED BY TECH SPEC SECTION 3.7.5, AFW.

3-173 THIS VALVE IS NOT COVERED BY TECH N/A SPEC 3.6.3. IT IS COVERED BY TECH SPEC SECTION 3.7.5, AFW.

3-860 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

X-40A 3-899 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs (cont) Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-900 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-852 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-848 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-888 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-901 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

Page 36 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-40B 3-148 THIS VALVE IS NOT COVERED BY TECH N/A SPEC 3.6.3. IT IS COVERED BY TECH SPEC SECTION 3.7.5, AFW.

3-148A THIS VALVE IS NOT COVERED BY TECH N/A SPEC 3.6.3. IT IS COVERED BY TECH SPEC SECTION 3.7.5, AFW.

3-172 THIS VALVE IS NOT COVERED BY TECH N/A SPEC 3.6.3. IT IS COVERED BY TECH SPEC SECTION 3.7.5, AFW.

3-859 Flow thru this valves is from containment Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs atmosphere IC to OC. Flow path smaller in Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs size than that required to result in a large release.

X-40B 3-842 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs (cont) Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-897 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-896 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-855 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-847 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

3-851 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

Page 37 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 3-887 Direct connection to Steam Generator. Not System pressure boundary maintained 4 hrs 4 hrs 4 hrs Closed system IC to open system OC. Analyzed System pressure boundary compromised 4 hrs 4 hrs 4 hrs Normally closed drain/vent valve OC.

X-40D BLF No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC.

X-41 77-127 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.77-128 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-42 81-502 No direct connection to RCS; penetration I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally open valve IC & OC.

Different valve type. This valve IC.

X-42 81-12 No direct connection to RCS; penetration I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally open valve OC & IC.

Different valve type. This valve OC.81-529 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-43A 62-563 Direct connection to the RCS. Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system and continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore release scenario is from containment atmosphere. Open system IC to Closed system OC. Normally open valve IC.62-550 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 38 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)62-549 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.62-546 No direct connection to RCS; flow path I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs smaller in size than that required to result in System pressure boundary compromised 168-hrs 168-hrs 168-hrs a large release.62-578 Direct connection to the RCS. Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system and continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore release scenario is from containment atmosphere. Open system IC to Closed system OC. Normally open valve IC.62-555 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-43A 62-571 No direct connection to RCS; Connected to Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) containment atmosphere. Flow path smaller Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs in size than that required to result in a large release.62-575 No direct connection to RCS; Connected to Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs containment atmosphere. Flow path smaller Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs in size than that required to result in a large release.

X-43B 62-561 Direct connection to the RCS. Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system and continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore release scenario is from containment atmosphere. Open system IC to Closed system OC. Normally open valve IC.

Page 39 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)62-550 No direct connection to RCS; Normally Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs operating system, continues to operate Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore, release scenario is from containment atmosphere. Flow path is smaller in size than that required to result in a large release. flow path smaller in size than that required to result in a large release.62-549 No direct connection to RCS; Normally Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs operating system, continues to operate Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore, release scenario is from containment atmosphere. Flow path is smaller in size than that required to result in a large release. Flow path smaller in size than that required to result in a large release.

X-43B 62-546 No direct connection to RCS; Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) operating system, continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident. Therefore, not considered a path for release directly for RCS since flow continues to be forced into RCS; therefore release scenario is from containment atmosphere.62-577 Direct connection to the RCS. Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system and continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore release scenario is from containment atmosphere. Open system IC to Closed system OC. Normally open valve IC.

Page 40 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)62-555 No direct connection to RCS; Normally Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs closed vent/drain valve. Isolated from RCS Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs by double check valves. Flow path smaller in size than that required to result in a large release.62-569 No direct connection to RCS; Vent/Drain Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs connected to containment atmosphere. Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Flow path smaller in size than that required to result in a large release.62-573 No direct connection to RCS; Vent/Drain Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs connected to containment atmosphere. Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Flow path smaller in size than that required to result in a large release.

X-43C 62-562 Direct connection to the RCS. Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system and continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore release scenario is from containment atmosphere. Open system IC to Closed system OC. Normally open valve IC.

X-43C 62-550 No direct connection to RCS; Normally Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) operating system, continues to operate Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore, release scenario is from containment atmosphere. Flow path is smaller in size than that required to result in a large release. Flow path smaller in size than that required to result in a large release.

Page 41 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)62-549 No direct connection to RCS; Normally Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs operating system, continues to operate Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore, release scenario is from containment atmosphere. Flow path is smaller in size than that required to result in a large release. flow path smaller in size than that required to result in a large release.62-546 No direct connection to RCS; flow path I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs smaller in size than that required to result in System pressure boundary compromised 168-hrs 168-hrs 168-hrs a large release.62-579 Direct connection to the RCS. Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system and continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore release scenario is from containment atmosphere. Open system IC to Closed system OC. Normally open valve IC.62-555 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-43C 62-570 No direct connection to RCS; Connected to Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) containment atmosphere. Flow path smaller Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs in size than that required to result in a large release.62-574 No direct connection to RCS; Connected to Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs containment atmosphere. Flow path smaller Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs in size than that required to result in a large release.

Page 42 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-43D 62-560 Direct connection to the RCS. Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system and continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore release scenario is from containment atmosphere. Open system IC to Closed system OC. Normally open valve IC.62-550 No direct connection to RCS; Normally Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs operating system, continues to operate Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore, release scenario is from containment atmosphere. Flow path is smaller in size than that required to result in a large release. flow path smaller in size than that required to result in a large release.62-549 No direct connection to RCS; Normally Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs operating system, continues to operate Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore, release scenario is from containment atmosphere. Flow path is smaller in size than that required to result in a large release. Flow path smaller in size than that required to result in a large release.

X-43D 62-546 No direct connection to RCS; Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) operating system, continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident. Therefore, not considered a path for release directly for RCS since flow continues to be forced into RCS; therefore release scenario is from containment atmosphere.

Page 43 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)62-576 Direct connection to the RCS. Normally I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system and continues to operate System pressure boundary compromised 168-hrs 168-hrs 168-hrs during accident, therefore not considered a path for release directly for RCS since flow continues to be forced into RCS. Therefore release scenario is from containment atmosphere. Open system IC to Closed system OC. Normally open valve IC.62-555 No direct connection to RCS; Normally Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs closed vent/drain valve. Isolated from RCS Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs by double check valves. Flow path smaller in size than that required to result in a large release.62-568 No direct connection to RCS; Vent/Drain Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs connected to containment atmosphere. Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Flow path smaller in size than that required to result in a large release.62-572 No direct connection to RCS; Vent/Drain Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs connected to containment atmosphere. Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Flow path smaller in size than that required to result in a large release.

X-44 62-61 Direct connection to RCS; Normally II-B-X44 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system, penetration flow path System pressure boundary compromised 168-hrs 168-hrs 168-hrs connects open system IC to open system OC; normally open valve IC.62-639 Direct connection to RCS; Normally II-B-X44 System pressure boundary maintained 168-hrs 168-hrs 168-hrs operating system, penetration flow path System pressure boundary compromised 168-hrs 168-hrs 168-hrs connects open system IC to open system OC; normally closed check valve IC.

X-44 62-63 Direct connection to RCS; Normally II-B-X44 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) operating system, penetration flow path System pressure boundary compromised 168-hrs 168-hrs 168-hrs connects open system IC to open system OC; normally open valve OC.

Page 44 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-45 77-18 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

77-19 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

77-20 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.77-984 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-46 77-9 Normally operating system; RCS I-B-5 System pressure boundary maintained 168-hrs 168-hrs 168-hrs connection, however b/c of relief valve on System pressure boundary compromised 168-hrs 168-hrs 168-hrs RC drain tank and pump discharge pressure IC (SQN Dwg 47E8330-1), extremely unlikely to reach RCS pressure, therefore considered as containment atmosphere connection from open system IC to open system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve.

77-10 Normally operating system; RCS I-B-5 System pressure boundary maintained 168-hrs 168-hrs 168-hrs connection, however b/c of relief valve on System pressure boundary compromised 168-hrs 168-hrs 168-hrs RC drain tank and pump discharge pressure IC (SQN Dwg 47E8330-1), extremely unlikely to reach RCS pressure, therefore considered as containment atmosphere connection from open system IC to open system OC. Normally open valve IC & OC.

Same valve type. This is an OC valve.

Page 45 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-46 84-511 Normally operating system; RCS Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) connection, however b/c of relief valve on Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs RC drain tank and pump discharge pressure IC (SQN Dwg 47E8330-1), extremely unlikely to reach RCS pressure, therefore given this scenario, flow path is also smaller in size than that required to result in a large release X-47A 61-191 No connection to RCS; penetration flow path I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs connects open system IC to open system System pressure boundary compromised 168-hrs 168-hrs 168-hrs OC; normally open valve OC & IC. Same valve type. This is an OC valve.61-192 No connection to RCS; penetration flow path I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs connects open system IC to open system System pressure boundary compromised 168-hrs 168-hrs 168-hrs OC; normally open valve IC & OC. Same valve type. This is an IC valve.61-533 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.61-532 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-47B 61-193 No connection to RCS; penetration flow path I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs connects open system IC to open system System pressure boundary compromised 168-hrs 168-hrs 168-hrs OC; normally open valve OC & IC. Same valve type. This is an OC valve.61-194 No connection to RCS; penetration flow path I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs connects open system IC to open system System pressure boundary compromised 168-hrs 168-hrs 168-hrs OC; normally open valve IC & OC. Same valve type. This is an IC valve.61-680 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

Page 46 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)61-681 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-48A 72-547 No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC & OC.

Different valve type. This is an IC valve.

72-39 No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC & OC.

Same valve type. This is an OC valve. .

72-545 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-543 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-48B 72-548 No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC. & OC.

Different valve type. This is an IC valve.

72-2 No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC & OC.

Different valve type. This is an OC valve.

72-546 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-544 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-49A 72-556 No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC & OC.

Different valve type. This is an IC valve.

Page 47 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 72-40 No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (FCV) flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC & OC.

Different valve type. This is an OC valve.

X-49A 72-215E No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-216E No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-215F No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-216F No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-40 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (RFV) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-552 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-49B 72-555 No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC & OC.

Different valve type. This is an IC valve.

72-41 No direct connection to RCS; penetration I-B-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (FCV) flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC & OC.

Different valve type. This is an OC valve.

72-217E No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 48 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 72-218E No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-217F No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-49B 72-218F No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-41 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (RFV) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

72-551 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-50A 70-87 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an IC valve.70-687 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

70-90 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system. OC & IC. Same valve type. This is an OC valve.70-737 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-50B 70-679 No direct connection to RCS; penetration I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Different valve type. This is an IC valve.

Page 49 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)70-134 No direct connection to RCS; penetration I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Different valve type. This is an OC valve.

70-678B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-51 26-1260 No direct connection to RCS; penetration I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally closed valve IC. NO valve OC. Different valve types. This is an IC valve.26-240 No direct connection to RCS; penetration I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to closed System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC; normally open valve OC.

Normally closed IC. Different valve types.

This is an OC valve.

26-1258 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-52 70-791 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.70-140 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve.70-141 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve.

70-691B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 50 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-53 70-143 No direct connection to RCS; penetration I-B-6 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects closed system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC.70-703 No direct connection to RCS; penetration I-B-6 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects closed system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC.70-760 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-53 70-702B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.70-765 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

70-702E No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-54 BLF No direct connection to RCS; penetration I-A-1 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 72-hrs 168-hrs 72-hrs system OC. Assume blind flanges to be normally closed valves. Same type.

X-56 67-1523D No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-83 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve.

67-89 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve..

Page 51 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)67-772 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-561D No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-57 67-575D No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-57 67-111 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an IC valve.67-112 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve..

X-58 67-1523A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.67-107 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve.67-106 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve.67-778 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-561A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 52 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-59 67-575A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-87 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve. .

67-88 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve. .

X-60 67-1523B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-90 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve.

67-91 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve.67-774 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-561B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-61 67-575B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.67-103 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve.

Page 53 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)67-104 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve.

X-62 67-1523C No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-99 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve.

X-62 67-105 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs (cont) flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve.67-776 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-561C No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-63 67-575C No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-95 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve IC & OC.

Same valve type. This is an IC valve.

67-96 No direct connection to RCS; penetration I-A-3 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC & IC.

Same valve type. This is an OC valve.

X-64 31C-752 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 54 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 31C-223 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

31C-222 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-65 31C-734 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

31C-225 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-65 31C-224 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-66 31C-715 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

31C-230 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

31C-229 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-67 31C-697 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

31C-232 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

31C-231 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 55 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-68 67-580D No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.67-141 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-578D No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-69 67-580A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.67-130 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-69 67-579A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

(cont)

X-70 67-585B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.67-297 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.67-139 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-71 67-585C No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.67-296 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 56 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)67-134 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-72 67-585D No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.67-298 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.67-142 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-73 67-585A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

X-73 67-295 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

(Cont)67-131 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-74 67-580B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.67-138 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-579B No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-75 67-580C No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

Page 57 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)67-133 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

67-579C No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-76 33-704 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 1 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.33-740 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.33-212 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-76 33-722 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

(cont)33-739 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.33-211 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-77 59-633 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.59-522 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.59-529 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 58 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)59-704 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.59-651 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-78 26-1296 No direct connection to RCS; penetration I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC.26-243 No direct connection to RCS; penetration I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Normally open valve OC.

26-1293 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-79A BLF No direct connection to RCS; penetration I-A-1 System pressure boundary maintained 72-hrs 168-hrs 72-hrs flow path connects open system IC to open System pressure boundary compromised 72-hrs 168-hrs 72-hrs system OC. 1 flange IC and 1 flange OC used to isolate the penetration and analyze as normally closed valves of the same type.

X-79B BLF No direct connection to RCS; penetration I-A-1 System pressure boundary maintained 72-hrs 168-hrs 72-hrs flow path connects open system IC to open System pressure boundary compromised 72-hrs 168-hrs 72-hrs system OC. 1 flange IC and 1 flange OC used to isolate the penetration and analyze as normally closed valves of the same type.

X-80 30-40 No direct connection to RCS. This valve is I-A-1 System pressure boundary maintained 168-hrs 168-hrs 168-hrs normally closed but is intermittently opened System pressure boundary compromised 168-hrs 168-hrs 168-hrs to provide for containment min-purge during power operation. Open system IC to open system OC. Normally closed valve IC & OC.

Same valve type. This is an IC valve.

Page 59 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 30-37 No direct connection to RCS. This valve is I-A-1 System pressure boundary maintained 168-hrs 168-hrs 168-hrs normally closed but is intermittently opened System pressure boundary compromised 168-hrs 168-hrs 168-hrs to provide for containment min-purge during power operation. Open system IC to open system OC. Normally closed valve OC & IC.

Same valve type. This is an OC valve.

30-556TP No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-82 78-560 No direct connection to RCS; Penetration I-A-1 System pressure boundary maintained 72-hrs 168-hrs 72-hrs flow path connects open system IC to open System pressure boundary compromised 72-hrs 168-hrs 72-hrs system OC. Normally closed valve IC & OC.

Same valve type. This is an IC valve.78-561 No direct connection to RCS; Penetration I-A-1 System pressure boundary maintained 72-hrs 168-hrs 72-hrs flow path connects open system IC to open System pressure boundary compromised 72-hrs 168-hrs 72-hrs system OC. Normally closed valve OC & IC.

Same valve type. This is an OC valve.

78-228A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-83 78-558 No direct connection to RCS; Penetration I-A-1 System pressure boundary maintained 72-hrs 168-hrs 72-hrs flow path connects open system IC to open System pressure boundary compromised 72-hrs 168-hrs 72-hrs system OC. Normally closed valve IC & OC.

Same valve type. This is an IC valve.78-557 No direct connection to RCS; Penetration I-A-1 System pressure boundary maintained 72-hrs 168-hrs 72-hrs flow path connects open system IC to open System pressure boundary compromised 72-hrs 168-hrs 72-hrs system OC. Normally closed valve OC & IC.

Same valve type. This is an OC valve.

78-226A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-84A 68-308 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 60 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)68-307 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-85B THE DP SENSORS ARE CLOSED Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs SYSTEMS OUTSIDE OF CONTAINMENT Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs THAT ARE ATTACHED DIRECTLY TO CONTAINMENT. NO ISOLATION VALVES ARE EMPLOYED FOR THESE SENSORS AS THEY USE A DOUBLE DIAPHRAGHM SYSTEM FOR DP MEASUREMENT. THE DIAPHGRAMS ARE QUALIFIED FOR POST-LOCA USE. NO DIRECT CONNECTION TO RCS. FLOW PATH SMALLER IN SIZE THAN THAT REQUIRED TO RESULT IN A LARGE RELEASE.30-45Y No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.30-45X No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 61 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-85C - THIS LINE TRANSMITS PRESSURE FROM Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs THE PRIMARY SYSTEM TO PRESSURE Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs INSTRUMENTATION. THE LINE IS FLUID FILLED AND DOUBLE DIAPHRAGMED TO PREVENT COMMUNICATION BETWEEN THE PRIMARY SYSTEM FLUID AND THE AUXILIARY BUILDING. NO PRIMARY SYSTEM FLUID TRAVELS THROUGH THE PENETRATION SINCE THE INNER DIAPHRAGM IS LOCATED NEAR THE REACTOR VESSEL. SINCE DOUBLE DIAPHRAGMS ARE EMPLOYED FOR CONTAINMENT ISOLATION, NO CONTAINMENT ISOLATION VALVES ARE USED. FLOW PATH SMALLER IN SIZE THAN THAT REQUIRED TO RESULT IN A LARGE RELEASE.

X-86A - THIS LINE TRANSMITS PRESSURE FROM II,A#9 System pressure boundary maintained 168 hrs 168 hrs 168 hrs THE PRIMARY SYSTEM TO PRESSURE System pressure boundary compromised 168 hrs 168 hrs 168 hrs INSTRUMENTATION. THE LINE IS FLUID FILLED AND DOUBLE DIAPHRAGMED TO PREVENT COMMUNICATION BETWEEN THE PRIMARY SYSTEM FLUID AND THE AUXILIARY BUILDING. NO PRIMARY SYSTEM FLUID TRAVELS THROUGH THE PENETRATION SINCE THE INNER DIAPHRAGM IS LOCATED NEAR THE REACTOR VESSEL. SINCE DOUBLE DIAPHRAGMS ARE EMPLOYED FOR CONTAINMENT ISOLATION, NO CONTAINMENT ISOLATION VALVES ARE USED.

Page 62 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-86B - THIS LINE TRANSMITS PRESSURE FROM II,A#9 System pressure boundary maintained 168 hrs 168 hrs 168 hrs THE THIS LINE TRANSMITS PRESSURE System pressure boundary compromised 168 hrs 168 hrs 168 hrs FROM THE PRIMARY SYSTEM TO PRESSURE INSTRUMENTATION. THE LINE IS FLUID FILLED AND DOUBLE DIAPHRAGMED TO PREVENT COMMUNICATION BETWEEN THE PRIMARY SYSTEM FLUID AND THE AUXILIARY BUILDING. NO PRIMARY SYSTEM FLUID TRAVELS THROUGH THE PENETRATION SINCE THE INNER DIAPHRAGM IS LOCATED NEAR THE REACTOR VESSEL. SINCE DOUBLE DIAPHRAGMS ARE EMPLOYED FOR CONTAINMENT ISOLATION, NO CONTAINMENT ISOLATION VALVES ARE USED.

X-86C - THIS LINE TRANSMITS PRESSURE FROM II,A#9 System pressure boundary maintained 168 hrs 168 hrs 168 hrs THE THIS LINE TRANSMITS PRESSURE System pressure boundary compromised 168 hrs 168 hrs 168 hrs FROM THE PRIMARY SYSTEM TO PRESSURE INSTRUMENTATION. THE LINE IS FLUID FILLED AND DOUBLE DIAPHRAGMED TO PREVENT COMMUNICATION BETWEEN THE PRIMARY SYSTEM FLUID AND THE AUXILIARY BUILDING. NO PRIMARY SYSTEM FLUID TRAVELS THROUGH THE PENETRATION SINCE THE INNER DIAPHRAGM IS LOCATED NEAR THE REACTOR VESSEL. SINCE DOUBLE DIAPHRAGMS ARE EMPLOYED FOR CONTAINMENT ISOLATION, NO CONTAINMENT ISOLATION VALVES ARE USED.

Page 63 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-87B 52-502 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.52-503 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-87D 52-500 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.52-501 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-88 BLF No direct connection to RCS; penetration I-B-1 System pressure boundary maintained 168-hrs 168-hrs 168-hrs flow path connects open system IC to open System pressure boundary compromised 168-hrs 168-hrs 168-hrs system OC. Assume normally closed valve IC and OC. Same valve type.

X-90 32-287 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 1 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

32-80 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.32-285 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.32-281 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-90 32-358 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

32-81 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 64 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-90 32-353 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Unit 2 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Only a large release.

(cont)32-354 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-91 43-251 Direct connection to RCS; flow path smaller Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs in size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.43-250 Direct connection to RCS; flow path smaller Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs in size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.43-497 Direct connection to RCS; flow path smaller Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs in size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-92A,43-207 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs X-92B smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Unit 1 a large release.

Only 43-452 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-424 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-208 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-453 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-423 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 65 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-92A,43-207 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs X-92B smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Unit 2 a large release.

Only 43-210A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-525 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-417 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-208 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

43-210I No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-424 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-421 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-93 43-34 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

43-35 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-94A 90-109 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 66 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)90-107 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-94B 90-108 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.90-107 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-94C 90-110 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.90-111 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-95A 90-115 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.90-113 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-95B 90-114 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.90-113 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-95C 90-116 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.90-117 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 67 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-96C 43-22 Direct connection to RCS; Flow path smaller Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs in size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

43-23 Direct connection to RCS; flow path smaller Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs in size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-97 30-134 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.30-135 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-98 52-506 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.52-507 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.52-508 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-99,43-202 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs X-100 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Unit 1 a large release.

Only 43-451 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-425 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-201 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 68 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)43-450 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-426 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-99,43-202 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs X-100 smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs Unit 2 a large release.

Only 43-200I No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-426 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-423 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-201 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

43-200A No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-427 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-419 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-101 43-319 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

Page 69 of 75

ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)43-318 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-474 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-102 3-352C This line joins to the secondary side of the III,A #1 System pressure boundary maintained 8 hrs 72 hrs 8 hrs steam generator inside containment and is System pressure boundary compromised 8 hrs 72 hrs 8 hrs considered a closed system inside containment. Direct connection Closed system IC to open system OC. Normally closed valve OC.

Unit 2 This valve is normally isolated from SG by Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Only valves 352A and 352B. Therefore flow is Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs 2-3-972 from containment atmosphere inside IC to OC. Open system IC to open system OC.

Normally closed valve IC.

X-103 43-461 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-317 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-341 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-464 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-104 3-351C This line joins to the secondary side of the III,A #1 System pressure boundary maintained 8 hrs 72 hrs 8 hrs steam generator inside containment and is System pressure boundary compromised 8 hrs 72 hrs 8 hrs considered a closed system inside containment. Direct connection Closed system IC to open system OC. Normally closed valve OC.

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ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

Unit 2 This valve is normally isolated from SG by Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs Only valves 352A and 352B. Therefore flow is Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs 2-3-970 from containment atmosphere inside IC to OC. Open system IC to open system OC.

Normally closed valve IC.

X-104 Unit 2 This valve is normally isolated from SG by Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) Only valves 352A and 352B. Therefore flow is Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs 2-3-971 from containment atmosphere inside IC to OC. Open system IC to open system OC.

Normally closed valve IC.

X-106 43-460 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-325 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-307 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.43-469 No direct connection to RCS; flow path Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs smaller in size than that required to result in Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs a large release.

X-107 74-2 RCS connection; standby system. Open Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs system IC and OC. Normally closed valve IC Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs downstream of another normally closed IC valve.

74-1 RCS connection; standby system. Normally Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs closed valve IC downstream of another Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs normally closed IC valve.74-505 Standby system, no direct RCS connection. Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs Relief valve discharges to the pressurizer Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs relief tank which does not reach RCS pressure. Therefore, flow path is smaller than minimum size required for a large release.

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ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)74-504 No direct connection to RCS piping. Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs IC. Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system. Flow path is smaller than minimum size required for a large release.

X-107 74-503 No direct connection to RCS piping. Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) IC. Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system. Flow path is smaller than minimum size required for a large release.74-549 No direct connection to RCS piping. Valve is Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs IC. Only release path is from containment Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs atmosphere to environment via the RHR system. Flow path is smaller than minimum size required for a large release.

X-108 BLF No connection to RCS; penetration flow path Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs connects open system IC to open system Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs OC.

X-109 BLF No connection to RCS; penetration flow path Not System pressure boundary maintained 4-Hrs 4-Hrs 4-Hrs connects open system IC to open system Analyzed System pressure boundary compromised 4-Hrs 4-Hrs 4-Hrs OC.

X-111 30-46 No RCS connection. The containment I-A-4 Pressure Boundary Maintained 168-hrs 168-hrs 168-hrs vacuum relief isolation butterfly valve is Pressure Boundary Compromised 168-hrs 168-hrs 168-hrs located in series with the vacuum relief valve (spring loaded check valve) all outside of the containment. Open system IC and OC.

Normally open valve OC.30-571 No RCS connection. The containment I-A-4 Pressure Boundary Maintained 168-hrs 168-hrs 168-hrs vacuum relief isolation butterfly valve is Pressure Boundary Compromised 168-hrs 168-hrs 168-hrs located in series with the vacuum relief valve (spring loaded check valve) all outside of the containment. Open system IC and OC.

Normally open valve OC.

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ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1) 30-46AX No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

30-46AY No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-111 30-46BY No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-112 30-47 No RCS connection. The containment I-A-4 Pressure Boundary Maintained 168-hrs 168-hrs 168-hrs vacuum relief isolation butterfly valve is Pressure Boundary Compromised 168-hrs 168-hrs 168-hrs located in series with the vacuum relief valve (spring loaded check valve) all outside of the containment. Open system IC and OC.

Normally open valve OC.30-572 No RCS connection. The containment I-A-4 Pressure Boundary Maintained 168-hrs 168-hrs 168-hrs vacuum relief isolation butterfly valve is Pressure Boundary Compromised 168-hrs 168-hrs 168-hrs located in series with the vacuum relief valve (spring loaded check valve) all outside of the containment. Open system IC and OC.

Normally open valve OC.

30-47AX No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

30-47AY No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

30-47BY No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

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ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-113 30-48 No RCS connection. The containment I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs vacuum relief isolation butterfly valve is System pressure boundary compromised 168-hrs 168-hrs 168-hrs located in series with the vacuum relief valve (spring loaded check valve) all outside of the containment. Open system IC and OC.

Normally open valve OC.30-573 No RCS connection. The containment I-A-4 System pressure boundary maintained 168-hrs 168-hrs 168-hrs vacuum relief isolation butterfly valve is System pressure boundary compromised 168-hrs 168-hrs 168-hrs located in series with the vacuum relief valve (spring loaded check valve) all outside of the containment. Open system IC and OC.

Normally open valve OC.

X-113 30-48AX No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

30-48AY No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

30-48BY No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-114 61-122 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.61-745 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.61-110 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.61-746 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

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ATTACHMENT 1 SQN Containment Isolation Valve Completion Time Results Group &

SQN SQN ICLERP LERF Justified Grouping Explanation Calc # Maintenance Activity Type Pent # Valve @ CT: @ CT: CT (Note 1)

X-115 61-97 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.61-692 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

61-96 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.61-691 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-116A 43-288 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-116A 43-287 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs (cont) size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.43-477 No connection to RCS; flow path smaller in Small System pressure boundary maintained 168 hrs 168 hrs 168 hrs size than that required to result in a large Line System pressure boundary compromised 168 hrs 168 hrs 168 hrs release.

X-117 BLF No connection to RCS; penetration flow path I-B-1 System pressure boundary maintained 72-hrs 168-hrs 72-hrs connects open system IC to open system System pressure boundary compromised 72-hrs 168-hrs 72-hrs OC.

X-118 BLF No connection to RCS; penetration flow path I-B-1 System pressure boundary maintained 72-hrs 168-hrs 72-hrs connects open system IC to open system System pressure boundary compromised 72-hrs 168-hrs 72-hrs OC.

Note 1 - Group/Calc # such as I,A#6, II,A#9, II,B#3, etc. match the generic configurations and use the CT times from the generic calculations for WCAP-15791-P-A, Revision

2. Group/Clac# such as I-A-1, I-B-3, II-B-2, etc. match the generic configurations of the WCAP but the CT times were determined by calculations using SQN specific PRA values. Group/Calc # III-A-12BC, III-A-13, III-A-14, II-A-X17, II-B-X44, II-A-BOUNDING do not match generic configurations of the WCAP and have been analyzed and CT times determined using SQN specific configurations and SQN specific PRA values. The evaluations for the CTs for all the CIVs are documented in TVAs PRA Evaluation Response, SQN-0-13-072. The CIVs marked as Not Analyzed either did not match the generic configurations and it was not advantageous to perform a specific SQN analysis that would increase the CT times greater than the original 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or generic configurations did not yield a CT greater than the original 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Page 75 of 75

ENCLOSURE 6 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Disposition of Existing License Amendment Requests

DISPOSITION OF EXISTING LICENSE AMENDMENT REQUESTS The following License Amendment Requests are under NRC review. The following table describes the request, and its affect on the ITS conversion, and its disposition.

DISPOSITION OF EXISTING LICENSE AMENDMENT REQUESTS Submittal Description of Affected ITS Affected Disposition Date Change Submittal CTS Sections/ Pages Specifications August 10, Application to Revise None None This is currently with 2012 Sequoyah Nuclear the NRC for review.

Plant Units 1 and 2 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, (SQN-TS-12-02)

January 7, Sequoyah Nuclear None None This is currently with 2013 Plant, Units 1 and 2 the NRC for review.

License Renewal July 3, Application to Modify ITS: 3.6.12 Unit 1 Proposed changes are 2013 Ice Condenser 3/4 6-26, already reflected in this Technical 3/4 6-27 ITS submittal.

Specifications to Changes are Address Revisions in Unit 2 annotated with an A Westinghouse Mass 3/4 6-27, DOC referencing the and Energy Release 3/4 6-28 previously submitted Calculation LAR. See ITS 3.6.12 (SQN-TS-12-04) DOC A02.

October 2, Sequoyah Nuclear ITS: 3.7.9 Units 1 Proposed changes are 2013 Plant (SQN), Units 1 and 2 already reflected in this and 2 - Proposed 3/4 7-14 ITS submittal.

Technical Changes are Specification (TS) annotated with an A Change, Ultimate DOC referencing the Heat Sink (UHS) previously submitted Temperature LAR. See ITS 3.7.9 Limitations DOC A02.

Supporting Alternate Essential Raw Cooling Water (ERCW) Loop Alignments (TS-SQN-13-01 and 13-02)

E6-1

ENCLOSURE 7 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Disposition of Generic Changes to NUREG-1431, Revision 4.0

DISPOSITION OF GENERIC CHANGES TO NUREG-1431, REVISION 4.0 Contents TSTF's Adopted ...................................................................................................................... E7-2 TSTF's Approved - Not Adopted ............................................................................................ E7-3 TSTF's Under NRC Review - Adopting .................................................................................. E7-4 E7-1

DISPOSITION OF GENERIC CHANGES TO NUREG-1431, REVISION 4.0 The following Nuclear Regulatory Commission (NRC)-approved (as of October 4, 2013) Technical Specification Task Force (TSTF) changes are adopted in whole or in part in the Sequoyah Nuclear Plant (SQN) Improved Technical Specifications (ITS) submittal:

TSTF's Adopted TSTF Description of TSTF ITS Location TSTF-490-A, Deletion of E Bar Definition and Revision to RCS 1.1 and 3.4.16 Rev. 0 Specific Activity Tech Spec TSTF-510-A, Revision to Steam Generator Program Inspection 3.4.17 and 5.5.7 Rev. 2 Frequencies and Tube Sample Selection TSTF-522-A, Revise Ventilation System Surveillance Requirements 3.6.10, 3.7.10, and 3.7.12 Rev. 0 to Operate for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per Month E7-2

DISPOSITION OF GENERIC CHANGES TO NUREG-1431, REVISION 4.0 The following NRC-approved (as of October 4, 2013) TSTF changes have not been included in the SQN ITS submittal:

TSTF's Approved - Not Adopted TSTF Description of TSTF Reason for Not Adopting TSTF-432-A, Change in Technical Specifications End States TVA has decided not to incorporate this Rev. 1 (WCAP-16294) allowance.

TSTF-505-A, Provide Risk-Informed Extended Completion Times - TVA has decided not to incorporate this Rev. 1 RITSTF Initiative 4b allowance.

E7-3

DISPOSITION OF GENERIC CHANGES TO NUREG-1431, REVISION 4.0 The following TSTFs are under NRC review, not approved as of the date of this submittal, but TVA is proposing to adopt into SQN ITS:

TSTF's Under NRC Review - Adopting TSTF Description of TSTF ITS Specification None E7-4

ENCLOSURE 8 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Regulatory Commitments

REGULATORY COMMITMENTS No. Commitments for TSTF-411/418 Due Date/Event 1 Activities that degrade the availability of the AFW system, Reactor Coolant System (RCS) pressure relief system (pressurizer PORVs and safety valves), Upon Implementation AMSAC, or Turbine Trip should not be scheduled when a logic cabinet is unavailable.

2 One complete Emergency Core Cooling System (ECCS) train that can be actuated automatically Upon Implementation must be maintained when a logic cabinet is unavailable.

3 Activities that cause analog channels to be unavailable should not be scheduled when a logic Upon Implementation cabinet is unavailable.

4 Activities on electrical systems (e.g., AC and DC power) and cooling systems (e.g., Essential Raw Cooling Water System (ERCW) and Component Cooling Water System (CCS) that support the systems or functions listed in the three commitments Upon Implementation above (AFW, RCS pressure relief systems, AMSAC, Turbine Trip, or ECCS) should not be scheduled when a logic cabinet is unavailable. That is, one complete train of a function that supports a complete train of a function noted above must be available.

5 Activities that degrade the availability of the auxiliary feedwater system, RCS pressure relief system (pressurizer PORVs and safety valves), AMSAC, or Upon Implementation turbine trip should not be scheduled when a RTB is out of service.

6 Activities that degrade other components of the RPS, including master and slave relays, and activities that cause analog channels to be Upon Implementation unavailable should not be scheduled when a RTB is unavailable.

No. Commitments for TSTF-427 Due Date/Event 7 Sequoyah Unit 1 & Unit 2 will incorporate the guidance of NUMARC 93-01 Section 11, which Upon Implementation provides guidance and details on the assessment and management of risk during maintenance.

8 Sequoyah Unit 1 & Unit 2 will revise procedures to ensure that the risk assessment and management process described in NEI 04-08 is used whenever a barrier is considered unavailable and the requirements of LCO 3.0.9 are to be applied, in Upon Implementation accordance with an overall configuration risk management program (CRMP) to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified and avoided E8-1

No. Commitments for TSTF-446 Due Date/Event 9 Sequoyah Unit 1 & Unit 2 will implement the capability to assess the effect on incremental large early release probability when using the extended completion times for containment isolation valves in Upon Implementation the program for managing risk in accordance with 10 CFR 50.65(a)(4) and the plant-specific configuration risk management program.

No. Commitments for TSTF-493 Due Date/Event 10 Sequoyah will revise the UFSAR to include the methodologies used to determine the as-found and Upon Implementation as-left tolerances for Limiting Safety Setting System (LSSS) instrument channel setpoints.

11 Sequoyah will develop a monitoring program to adequately track the performance of Master Relays, Slave Relays, Logic Cabinets, Universal Logic Upon Implementation Cards, Undervoltage Driver Cards, Safeguards Driver Cards, and Reactor Trip Breakers. (Reference Westinghouse Reports Section 3.2 and 3.5)

The above table identifies 11 commitments by TVA in Enclosure 8 for the SQN conversion to Improved Technical Specifications license amendment request (LAR).

Any other statements in this LAR submittal are provided for informational purposes and are not considered regulatory commitments.

E8-2

ENCLOSURE 9 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 List of Required Final Safety Analysis Report (FSAR) Descriptions For TSTF-500

LIST OF REQUIRED FINAL SAFETY ANALYSIS REPORT (FSAR) DESCRIPTIONS FOR TSTF-500 The following table identifies FSAR descriptions for the Diesel Generator and Vital Batteries required by Sequoyah Nuclear Plant, Units 1 and Unit 2, as part of the adoption of TSTF-500, Revision 2. These changes will be included with the required implementation date in the Issuance of Amendment letter.

REQUIRED FSAR DESCRIPTION DUE DATE/EVENT Sequoyah will change or verify that the FSAR: Upon implementation

1. Describes how a 5 percent design margin for the 125V Vital (applies to all) batteries corresponds to a 2 amp float current value indicating that the battery is 98 percent charged.

2. Describes how a 5 percent design margin for the Diesel Generator batteries corresponds to a 1 amp float current value indicating that the battery is 98 percent charged.

3. States that long term battery performance is supported by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to 2.13 V per connected cell and that there are 60 connected cells in the battery, which corresponds to 127.8 V at the battery terminals.

4. Describes how the batteries are sized with correction margins that include temperature and aging and how these margins are maintained.

5. States the minimum established design limit for battery terminal float voltage.

6. States the minimum established design limit for electrolyte level.

7. States the minimum established design limit for electrolyte temperature.

8. Describes how each battery is designed with additional capacity above that required by the design duty cycles to allow for temperature variations and other factors.

9. Describes normal DC system operation (i.e., powered from the battery chargers) with the batteries floating on the system, and a loss of normal power to the battery charger describing how the DC load is automatically powered from the station batteries.

E9-1

10. Describes the availability of a means to charge the Vital Batteries and a description that the battery charger is capable of being supplied power from a power source that is independent of the offsite power supply. Specification 3.8.4, Required Action A.3 E9-2

ENCLOSURE 10 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Relocate Surveillance Frequencies to Licensee Control RITS-TF Initiative 5b (TSTF-425)

RELOCATE SURVEILLANCE FREQUENCIES TO LICENSEE CONTROL RITS-TF INITIATIVE 5b (TSTF-425)

PRA Write-Up Purpose:

Risk-Informed Technical Specification (TS) initiative 5b proposes to relocate the control of surveillance requirement test frequencies for the majority of surveillance requirements from TS to an owner controlled program.

Scope:

Relocation of surveillance test frequencies outside of the technical specifications allows the licensee to use a risk-informed approach to determine the periodicity for performance of a given surveillance without having to make a change to the Sequoyah operating license. Initially the scope of this initiative, for Sequoyah, is to relocate the surveillance frequencies from TS, then at a later date risk-inform the frequencies on a case-by-case basis.

References:

1. TSTF-IG-10-01, Implementation Guidance for TSTF-425 Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b, July 2010

2. TSTF-425 Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b

3. NEI 04-10 Revision 1, Risk-Informed Method for Control of Surveillance Frequencies

4. R.G. 1.174 Revision 2, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant Specific Changes to the Licensing Basis

5. R.G. 1.200 Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities

6. ASME/ANS RA-Sa-2009, Addenda to ASME/ANS RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, American Society of Mechanical Engineers, New York, NY, February 2009. Parts 2 and 3

7. Westinghouse LTR_RAM-II-11-010 , RG 1.200 PRA Peer Review Against the ASME/ANS PRA Standard Requirements for the Sequoyah Nuclear Plant Probabilistic Risk Assessment (Dated March 18, 2011)1

8. NUC-SQN-MEB-MDN-000-000-2010-0200 Revision 1, SQN Probabilistic Risk Assessment - Summary Document

9. NUC-SQN-MEB-MDN-000-000-2010-0208 Revision 2, SQN Probabilistic Risk Assessment - Quantification Notebook

10. NUC-SQN-MEB-MDN-000-000-2010-0209 Revision 0, SQN Probabilistic Risk Assessment - Uncertainty and Sensitivity Analysis

11. NPG-SPP-09.3 Revision 13, Plant Modifications and Engineering Change Control

12. NPG-SPP-09.11 Revision 2, Probabilistic Risk Assessment (PRA) Program 1

Task PA-RMSC-0386

13. NEDP-26 Revision 6 - Probabilistic Risk Assessment (PRA)

Requirements:

In accordance with RG 1.200, the NRC expects licensees to demonstrate that the technical adequacy of the PRA used to support a risk-informed application is of sufficient quality. The regulator expects the following information to be submitted.2 To characterize the quality of the PRA the follow questions must be addressed:

1. [Assurance that] the PRA model represents the as-designed or as-built, as-operated plant.

The Sequoyah PRA has procedural requirements including processes and controls designed to ensure the PRA model and data represent the as-built, as-operated plant.[Ref. 13] Supporting peer review analysis and other information follows:

The ASME Standard[Ref. 6] High Level Requirements (HLRs) that address the PRA with respect to representing the as-built, as-operated plant, are HLR-DA-B and HLR-MU-B. There are a total of six supporting level requirements for these sub-elements, of which the 2011 Peer Review characterization [Ref. 7 App B] is that the Sequoyah PRA meets these requirements with a capability category I/II/III. [Ref. 7 App A]

Additional Information:

To ensure the PRA model is maintained to represent the as-built, as-operated plant, NEDP-26 Section 3.3 states: Various information sources shall be monitored by the Corporate/Site PRA Specialist on an ongoing basis to determine changes or new information that will affect the model, model assumptions, or quantification. Information sources include Operating Experience, Technical Specification changes, plant modifications, Maintenance Rule changes, engineering calculation revisions, procedure changes, industry studies, NRC information and PERs3.

2. Identification of permanent plant changes (such as design or operational practices) that have an impact on those things modeled in the PRA but have not been incorporated in the baseline PRA model. If a plant change has not been incorporated, the licensee provides a justification of why the change does not impact the PRA results used to support the application. This justification should be in the form of a sensitivity study that demonstrates the accident sequences or contributors significant to the application decision were not adversely impacted (remained the same).

Nuclear Power Group (NPG) procedure Plant Modifications and Engineering Change Control [Ref. 11] governs the process for making changes across the TVA fleet. This procedure has check lists that require the engineer to assess the potential impact on PRA criteria. If there 2

Previously submitted documentation may be Referenced if it is adequate for the subject submittal. Reference R.G. 1.200 Revision 2, Section 4.2 Licensee Submittal Documentation.

3 PER - Problem Evaluation Report, i.e., corrective action program.

is a yes response to any of the questions, an interface with the PRA group is required, and a review of the proposed design modification is performed in accordance with the PRA Program.[Ref. 12] As of this submittal, there are no outstanding plant changes that necessitate a change to the Model of Record (MOR) dated June 3, 2011.

3. Documentation that the parts of the PRA required to produce the results used in the decision are performed consistently with the standard as endorsed in the appendices of this regulatory guide. If a requirement of the standard (as endorsed in the appendix to this guide) has not been met, the licensee is to provide a justification of why it is acceptable that the requirement has not been met. This justification should be in the form of a sensitivity study that demonstrates the accident sequences or contributors significant to the application were not impacted (remained the same).

To appropriately evaluate the change in risk associated with a change in the periodicity of a given surveillance frequency all technical elements for a Level 1 and Level 2 PRA must be met to a minimum of Capability Category II as determined by a peer review team.4 The Peer Review Team determined that of the 325 supporting requirements (SRs) 313 were applicable to the Sequoyah PRA. Of these, all but 19 where met at capability II or higher (i.e., CC-II, CC-III, CC-I/II, CC-II/III). The 19 SRs are further divided as 11 not met, and 8 met at CC-I.[Ref. 7]

The proposed resolutions for the Facts & Observations (F&Os) associated with these 19 SRs were resolved and incorporated as recommended by the Peer Team with a few exceptions as described as follows. [Ref. 8]

One aspect of F&O 1-15 (SRs AS-B1, AS-A10, and SC-B3) regarding not having explicit treatment of SBO in the accident scenario analysis (e.g., event trees). The reason has been provided to NRC via RAI 7.a.viii.4 (for the Sequoyah SAMA). The TVA response was that to model the SBO accident would have no appreciable enhancement to the PRA insights. The inclusion of the SBO system failures post power recovery have a negligible effect on the CDF; therefore, there would be insignificant impact on the calculations to risk-informed surveillance frequencies.

F&O 4-1 proposes revising tables in the flooding analysis. This was not done because the flooding analysis already had the proposed information in tables provided in Section 5.2 of the SQN Internal Flooding Analysis, MDQ-000-000-2010-0203, and the recommendation would have added an unnecessary redundancy. [Ref. 8]

F&O 4-13 with respect to SR DA-C8 which suggests using plant-specific operational records to determine the time components are configured in their standby status. The change in risk associated with a change in the periodicity of surveillance frequencies is not expected to be 4

It is recognized that a PRA may not satisfy each technical requirement to the same degree (i.e., capability category as used in the ASME/ANS PRA standard); that is, the capability category achieved for the different technical requirements may vary. The capability category needed to be met for each technical requirement is dependent o n the specific application. In general the staff [NRC] anticipates that current good practice, i.e., Capability Category II of the SAME/ANS PRA Standard, is the level of detail that is adequate for the majority of applications. [Ref.. 5 §2.1]

impacted by the use of split-fractions for systems with a normally operating train/pump, and another in standby.

4. A summary of the risk assessment methodology used to assess the risk of the application, including how the base PRA model was modified to appropriately model the risk impact of the application and results. (Note that this is the same as that required in the application-specific regulatory guides.)

The Sequoyah PRA approach uses computer aided fault tree analysis (CAFTA) and provides a quantitative assessment of the identified risk in terms of scenarios that result in undesired consequences (e.g., core damage and/or large early release) and their frequencies, and is comprised of specific technical elements (e.g., data, HRA, initiators, etc.) in performing the quantification.[Ref. 9] The current phase of this application is to document the technical adequacy of the Sequoyah PRA to support risk-informed changes to surveillance frequencies; however, actual changes will be made at a later date on a case-by-case basis in accordance with the NRC endorsed methodology defined in NEI 04-10. [Ref. 3]

5. Identification of the key assumptions and approximations relevant to the results used in the decision-making process. Also, include the peer reviewers assessment of those assumptions. These assessments provide information to the NRC staff in their determination of whether the use of these assumptions and approximations is appropriate for the application, or whether sensitivity studies performed to support the decision are appropriate.

For RITS initiative 5b the analyses will quantify the change in risk (including cumulative changes) associated with the change in time between performance of a given surveillance test.

In this application, the decision is based on the confidence that the quality of the PRA model meets the requirements to support quantification and characterization of the change in risk due to a change in the frequency surveillances are performed.

The Peer Review Team characterized the internal events supporting requirements (SRs) associated with key assumptions and approximations and graded these at capability category II or I/II/III. Technical elements included initiating events (IE), accident sequence analysis (AS), success criteria (SC), data analysis (DA), systems analysis (SY), human reliability (HRA), quantification (QU) and large early release (LE). Additionally the rare event approximation received a CC I/II/III in the quantification (QU) technical element.

6. A discussion of the resolution of the peer review (or self-assessment, for peer reviews performed using the criteria in NEI 00-02) findings and observations that are applicable to the parts of the PRA required for the application. This decision should take the following forms:

a. a discussion of how the PRA model has been changed

b. a justification in the form of a sensitivity study that demonstrates the accident sequences or contributors significant to the application decision were not adversely impacted (remained the same) by the particular issue The Peer Review Team reviewed an initial revision of the PRA model using CAFTA. The CAFTA model replaced the RiskMan model previously used at Sequoyah. Since the Team reviewed a draft model, their recommendations did not make a change to the model, but rather supplemented the completion of the model to a rev. 0 status.

Standard sensitivity analyses [Ref. 10] were performed on the following:

All human Error Probabilities set to their 5th percentile value,

All Human Error Probabilities set to their 95th percentile value,

All CCF probabilities set to their 5th percentile value,

All CCF probabilities set to their 95th percentile value,

and, All maintenance terms set to zero.

Model specific sensitivity analyses [Ref. 10] were performed on the following:

Grid reliability and loss of offsite power (LOOP) modeling,

LOOP frequency, recovery, consequential LOOP, timing,

Post-LOOP equipment recovery,

Credit for non-safety related equipment,

and, Battery depletion.

7. The standards or peer review process documents may recognize different capability categories or grades that are related to level of detail, degree of plant specificity, and degree of realism. The licensees documentation is to identify the use of the parts of the PRA that conform to capability categories or grades lower than deemed required for the given application (Section 1-3 of ASME/ANS RA-Sa-2009 )

RITS initiative 5b requires a quality level of Capability Category II. The Peer Review team stated the Sequoyah PRA does meet the ASME/ANS Standard, and concluded the PRA uses processes and tools that are at the state of the technology and generally consistent with Capability Category II.

==

Conclusion:==

The Sequoyah PRA exhibits the technical adequacy to risk-inform (i.e., make changes) surveillance test intervals (STI) in accordance with the licensee-controlled program (once approved by NRC). These analyses will follow the NRC approved process and methodology as described in NEI 04-10. [Ref. 3]

ML13329A718

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