ML13192A032

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Wolf Creek, Request for Notice of Enforcement Discretion for Technical Specification Limiting Condition for Operation (LCO) 3.0.3, TS 3.8.4, DC Sources - Operating, TS 3.8.7, Inverters - Operating, and TS 3.8.9, Distribution Systems - Opera
ML13192A032
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 06/19/2013
From: Smith R A
Wolf Creek
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
WO 13-0050
Download: ML13192A032 (20)
v • d • e


Text

W0ELF CREEK'NUCLEAR OPERATING CORPORATION Russell A. SmithSite Vice President and Chief Nuclear Operating OfficerJune 19, 2013WO 13-0050U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555

Subject:

Docket No. 50-482: Request for Notice of Enforcement Discretion forTechnical Specification Limiting Condition for Operation (LCO) 3.0.3, TS3.8.4, "DC Sources -Operating,"

TS 3.8.7, "Inverters

-Operating,"

andTS 3.8.9, "Distribution Systems -Operating" Gentlemen:

This letter confirms the results of the teleconference that was conducted between Wolf CreekNuclear Operating Corporation (WCNOC) and Nuclear Regulatory Commission (NRC) Staffrepresentatives at 1607 hours0.0186 days <br />0.446 hours <br />0.00266 weeks <br />6.114635e-4 months <br /> Central Daylight Time (CDT) on June 17, 2013 in which WCNOCrequested the NRC to exercise enforcement discretion for the Wolf Creek Generating Station(WCGS), regarding the requirements of Technical Specification Limiting Condition forOperation (LCO) 3.0.3, TS 3.8.4, "DC Sources -Operating,

" TS 3.8.7, "Inverters

-Operating,"

and TS 3.8.9, "Distribution Systems -Operating."

With the plant operating in MODE 1 at 100%Rated Thermal Power, the request was made in order to provide additional time to repair andtest the 'A' Class 1E electrical equipment air conditioning (A/C) unit (SGK05A) before a plantshutdown would have otherwise been required.

The events leading to WCNOC's request began at 1111 hours0.0129 days <br />0.309 hours <br />0.00184 weeks <br />4.227355e-4 months <br /> on June 17, 2013, when the 'A'Class 1 E electrical equipment air conditioning (A/C) train (SGK05A) was declared nonfunctional when it was determined that SGK05A was not capable of performing its specified function.

Since one nonfunctional Class 1 E electrical equipment A/C train renders the supported train ofaffected electrical equipment inoperable (i.e., two inverters among other affected equipment),

LCO 3.0.3 was entered in light of the limitations of the Conditions and Required Actions of TS3.8.7, "Inverters

-Operating."

LCO 3.0.3 requires action to be taken within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place theplant in MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, in MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and in MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.Therefore, absent a support system TS LCO to declare inoperable, the control room staff isrequired to enter LCO 3.0.3 anytime a Class 1 E electrical equipment A/C train is discovered tobe nonfunctional.

At 1111 hours0.0129 days <br />0.309 hours <br />0.00184 weeks <br />4.227355e-4 months <br /> a plant shutdown was initiated in accordance with LCO 3.0.3.PO. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 I vAn Equal Opportunity Employer M/F/HCNET WO 13-0050Page 2 of 2Enforcement discretion was sought to permit noncompliance with LCO 3.0.3, TS 3.8.4, TS3.8.7, and TS 3.8.9 to permit additional time to complete repairs and restoration of SGK05Abefore entry into MODE 5 was required.

An additional 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> was requested to restoreSGK05A to FUNCTIONAL status such that the action to place the plant in MODE 5 within 37hours per LCO 3.0.3 would begin at 1111 hours0.0129 days <br />0.309 hours <br />0.00184 weeks <br />4.227355e-4 months <br /> CDT on June 24. The incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) was quantified for the requested additional time for restoring SGK05A. The results ofthe quantification are within the guidance threshold in Regulatory Issue Summary 2005-01,"Changes to Notice of Enforcement Discretion (NOED) Process and Staff Guidance."

It hasbeen determined that there is no net increase in radiological risk.WCNOC will work around the clock to complete repairs and restoration of SGK05A. WCNOCunderstands that the enforcement discretion does not allow troubleshooting and that, if at anytime during the effort it becomes apparent that the allowed time will not be met, that theenforcement discretion no longer applies.At 1607 hours0.0186 days <br />0.446 hours <br />0.00266 weeks <br />6.114635e-4 months <br /> on June 17, Mr. Kriss Kennedy, Director Division of Reactor Projects, Region IV,notified WCNOC that after NRC Region IV Office consideration of WCNOC's verbal request forenforcement discretion, and in consultation with the NRR technical staff, the request for aNotice of Enforcement Discretion (NOED) was approved.

The approval was effective andwould begin at 1111 hours0.0129 days <br />0.309 hours <br />0.00184 weeks <br />4.227355e-4 months <br /> on June 17 for an additional 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />. WCNOC is required tosubmit a written request for the NOED within 2 working days of the NRC verbal approval.

The Attachments provide the information documenting WCNOC's earlier verbal request for theNOED. If you should have any questions regarding this submittal, please contact me at (620)364-4156, or Mr. Michael J. Westman at (620) 364-4009.

Sincerely, Russell A. SmithRAS/ritAttachments I -Request for Notice of Enforcement Discretion II -Top 100 Cutsetscc: A. T. Howell (NRC), w/aC. F. Lyon (NRC), w/aN. F. O'Keefe (NRC), w/aSenior Resident Inspector (NRC), w/a Attachment I to WO 13-0050Page 1 of 13Request for Notice of Enforcement Discretion (NOED) Regarding Technical Specification 3.0.3, 3.8.4, 3.8.7 and 3.8.9a. The type of NOED being requested.

A regular NOED to avoid an unnecessary transient as a result of compliance with the Technical Specifications is being requested since compliance with the Technical Specifications (TSs)would involve an unnecessary shutdown of the unit without a corresponding health and safetybenefit.b. The Technical Specification (TS) or other license conditions that will be violated.

LCO 3.0.3 requires action to be taken within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the plant in MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />,in MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and in MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. LCO 3.0.3 was entered in light ofthe limitations of the Conditions and Required Actions of TS 3.8.7, "Inverters

-Operating."

Therefore, absent a support system TS LCO to declare inoperable, the control room staff isrequired to enter LCO 3.0.3 anytime a Class 1 E electrical equipment A/C train is discovered tobe nonfunctional, resulting in an unnecessary plant transient.

Required Actions B.1 and B.2 of TS 3.8.4 would require placing the plant in MODE 3 in 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sand MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if Required Action A.1 (restore DC electrical power subsystem toOPERABLE status) and it associated Completion Time (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) is not met. Required ActionsB.1 and B.2 of TS 3.8.7 would require placing the plant in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 in36 hours if Required Action A.1 (restore one required inverter to OPERABLE status) and itassociated Completion Time (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) are not met. Required Actions E.1 and E.2 of TS 3.8.9would require placing the plant in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if RequiredActions C.1 and D.1 (restore one AC vital bus subsystem and one DC electrical powerdistribution subsystem to OPERABLE status) and its associated Completion Time (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) isnot met.The granting of a regular NOED request would avoid an unnecessary plant transient.

c. The circumstances surrounding the situation:

including likely causes; the need forprompt action; action taken in attempt to avoid the need for an NOED; andidentification of any relevant historical events.The events leading to WCNOC's request began the morning June 17, 2013, when the analysisof an oil sample taken from the 'A' Class IE electrical equipment air conditioning (A/C) train(SGK05A) showed elevated levels of aluminum.

This was discussed with the equipment manufacturer and it was concluded that the equipment could no longer be considered reliable tosupport the mission time of supported systems.

This, in conjunction with other monitoring parameters, led to the conclusion that the unit could not be relied on to meet its requiredfunction and the Shift Manager declared the unit non-functional and entered Technical Specification 3.0.3 at 1111 AM.

Attachment I to WO 13-0050Page 2 of 13Likely CauseThe unit was observed to be running with elevated Amperes which are approximately 20% lessthan the rated full load amperage of the motor (55 Amps). In addition the oil in the compressor was observed to be darker than previously noted. An oil sample was taken and sent for offsiteanalysis.

Results showed elevated levels of aluminum, approximately 86 ppm. Thecompressor's pistons and connecting rods are made of aluminum so the concern is that theseparts are damaged.

Further evidence of this are the increased vibration levels that have beennoted on the unit. The likely cause of this damage is slugging/hydraulicing of either the oil or therefrigerant.

The last maintenance performed on the equipment was on May 28, 2013, when the compressor was replaced with this unit.Identification of any Relevant Historical EventsDuring the week of May 23, 2012, a Nuclear Regulatory Commission (NRC) ProblemIdentification and Resolution team inspection identified several concerns with the incorporation of calculation GK-06-W, Revision 2, "SGK05A/B Class 1E Electrical Equipment Rooms A/CUnits, Single Unit Operation Capability,"

into plant documents.

One of the concerns related tothe calculation requirements for the use of temporary ventilation fans and the fans not beingpowered from a safety related source. On May 29, 2012, SGK05B was declared nonfunctional due to the oil pump pressure degrading.

The SGK05B unit was restored to functional statusprior to completing a prompt OPERABILITY determination.

On June 4, 2012, the compressor for SGK05A was found tripped on low oil pressure and the unit declared nonfunctional.

Duringthe Operability Determination and Functionality Assessment process it was determined thatOPERABILITY of the associated train Class 1E electrical equipment could not be maintained without additional compensatory measures and for a limited period of time. The functionality requirements imposed on the Class 1 E electrical equipment A/C trains at WCGS weregoverned by TRM TR 3.7.23, "Class 1 E Electrical Equipment Air-Conditioning (A/C)". With oneClass 1 E electrical equipment A/C train nonfunctional when the plant is in MODES 1 through 4,TR 3.7.23 allowed up to a 7-day delay period before declaring the supported Class 1 E electrical equipment inoperable (in the area served by the A/C train) and entering the applicable Conditions and Required Actions of TS 3.8.4, TS 3.8.7, and TS 3.8.9. WCNOC has revisedTRM Technical Requirement (TR) 3.7.23, "Class 1 E Electrical Equipment Air-Conditioning (A/C)," to require entry into the Conditions and Required Actions of TS 3.8.4, TS 3.8.7 and TS3.8.9 when a Class 1 E electrical equipment A/C train is nonfunctional.

Procedure SYS GK-200,"INOPERABLE CLASS 1E A/C UNIT," was utilized to provide guidance for a nonfunctional Class 1 E electrical equipment A/C train and has been deleted.

The failure of a Class 1Eelectrical equipment A/C train currently results in declaring the affected Class 1E electrical equipment inoperable and entry into the Conditions and Required Actions of TS 3.8.4, TS 3.8.7and TS 3.8.9 as well as entry into LCO 3.0.3. In addition, preventative maintenance activities that require taking the Class 1 E electrical equipment trains out of service currently require entryinto the Conditions/Required Actions of TS 3.8.4, TS 3.8.7 and TS 3.8.9 as well as entry intoLCO 3.0.3. Note that voluntary entry into LCO 3.0.3 is prohibited.

Attachment I to WO 13-0050Page 3 of 13Action Taken in Attempt to Avoid the Need for an NOEDDiscussion was held with the vendor to determine if the results of the oil analysis and otherindicators could be used to justify waiting for a planned evolution.

The vendor could not supportthis and the unit was declared non-functional.

Other alternatives pursued with respect to this unit in the past include:Since the determination that the continued use of the 7-day Completion Time in TR 3.7.23 wasnot appropriate, WCNOC has continued efforts to develop an adequate heat calculation associated to the Engineered Safety Features switchgear room components.

Additionally, WCNOC is performing analyses to re-create and update the design basis calculations for theClass 1 E electrical equipment A/C trains and evaluating plant modifications.

WCNOC has been in discussion with other utilities to determine the best course of action toresolve the issue with the Class 1E Electrical Equipment A/C System regulatory relationship with the electrical TS. The industry Technical Specification Task Force has become engagedto evaluate potential generic resolutions to this issue.The last NOED request was initiated on January 10, 2013 and verbally approved by the NRC at1300 hours. This NOED involved a broken cylinder head bolt on the 'B' diesel generator.

d. Information to show that the cause of the situation that led to the NOED request isfully understood.

It was determined that the situation leading to the NOED request resulted from likely damage tothe internal components of the compressor unit.This is believed because the motor current and vibration of the unit had both increased and,although within allowable limits, were elevated from the normal condition.

In addition the oil inthe unit was observed to be darker than normal and was shown by analysis to contain elevatedlevels of aluminum.

Discussion with vendor indicated that piston and connecting rod in the compressor were thealuminum components and that the symptoms observed showed degradation of thesecomponents.

The vendor stated that they had seen failures of this type before and that they were typically caused by slugging/hydraulicing which is the introduction of a liquid, either oil or refrigerant, intoa system meant for gas. It was their opinion that probable sources of liquid could be either theoverfilling of these two liquids or the failure of the thermal expansion valves to operate properly.

WCNOC has been monitoring the performance of the thermal expansion valves and, becausethey appear to be operating

properly, believes that damage to the compressor caused byexcessive oil in the system is the problem.

Therefore, replacement of the compressor, usingvendor support from the manufacturer and additional post maintenance testing will return thisunit to proper functionality.

Attachment I to WO 13-0050Page 4 of 13e. Information on the proposed course of action to resolve the situation, such thatthere is a high likelihood that planned actions can be completed within theproposed NOED time frame.A timeline has been developed that will allow for the following activities to be performed withinthe time allowed by the NOED.Prior to any work being performed preparations are being made to conduct the following Compensatory Actions:Put temporary cooling in place for the spaces normally cooled by SGK05A. This will be atemporary AC unit (elephant trunk type) powered by reliable non-safety power. A second unitwill be made available in case of failure.Monitoring of room temperature will be done every two hours and if room temperatures exceedlimits the appropriate actions will be taken.A fire watch will be established to compensate for the fire barriers that will be breached by thetemporary AC units.Once these measures are in place the SGK05A unit will be shutdown and the following stepsperformed.

Hang clearance order/ Get vendor support flown inRecover refrigerant from the systemProvide Rigging support for removal of the compressor Remove compressor

-and send it off to vendor for failure analysisPrepare new compressor for installation Install new compressor

-with vendor supportRemove clearance orderPerform Post Maintenance Testing (PMT) -extended with vendor support to ensure properoperation after reinstallation Remove clearance and restore from compensatory measuresReturn SGK05A to functional status.Estimates to complete this work at T-0 have it complete within the 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> allowed by theNOED.f. Information to show that the resolution of the situation will not result in a different, unnecessary transient.

Replacement of the compressor will not result in a different unnecessary transient as the ACunit is not the initiator of any event. Performing this replacement within the time allowed by theNOED will avoid an unnecessary plant transient.

Attachment I to WO 13-0050Page 5 of 13g. Explain why there was not time to process an emergency license amendment, orthat a license amendment is not needed.Oil samples first showed unacceptable results the morning of June 17, 2013, and with thecorresponding entry into Technical Specification 3.0.3 a plant shutdown was commenced.

Inthis condition the plant would require action to be taken within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the plant inMODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, in MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and in MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. This doesnot allow time to process an emergency license amendment.

Further, a license amendment isnot needed because this is a one time request to repair the unit, not a change to a specificTechnical Specification.
h. The condition and operational status of the plant (including safety relatedequipment out of service or otherwise inoperable).

Currently the plant is operating in Mode 1 with all safety related equipment Operable.

There isone Non-Safety Related service water pump, and one Spent Fuel Pool Heat Exchanger out ofservice and being repaired.

In addition there is a small air leak on the Non-Safety side of oneEmergency Diesel Generator air start system that WCGS intends to repair during the NOED.Both air accumulators are full and the other air compressor for that EDG remains in service.i. The justification for the duration of the non-compliance.

This request is for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> (7 days) from the entry in Technical Specification 3.0.3 on June17, 2013, at 1111 AM. This duration is based on the time required to place clearances, performthe work, test the system, and remove the clearances, and return the system to service.

Thisestimate is based on similar work performed in May 2013, and has a high likelihood of beingcompleted within the requested NOED duration.

j. Detail and explain compensatory actions that have been taken and will be taken toreduce the risk associated with the specified configuration.

In order to reduce the risk during the duration of the NOED WCNOC will take the following compensatory actions.Temporary cooling will be provided to the spaces served by SGK05A to maintain desired roomtemperatures.

Room temperatures will be monitored every two hoursA fire watch will be established due to breaches necessary to establish temporary cooling.k. The status and potential challenges to off-site and on-site power sources.Currently the grid is stable with no planned switchyard or grid work that would impact gridreliability during the NOED period.Both on-site Emergency Diesel Generators are Operable with no planned maintenance orsurveillances scheduled except the starting air compressor leak described in section h above.

Attachment I to WO 13-0050Page 6 of 131. The safety basis for the request, including an evaluation of the safety significance and potential consequences of the proposed course of action.1. The WCGS Equipment Out Of Service (EOOS) zero test and maintenance Revision 6PRA model was used to establish the plant's baseline risk and the estimated risk increaseassociated with the period of enforcement discretion.

Core Damage Frequency (CDF), LargeEarly Release Frequency (LERF), Incremental Conditional Core Damage Probability (ICCDP),and Incremental Conditional Large Early Release Probability (ICLERP) values are listed belowand compared with guidance thresholds discussed above.Quantification of the plant risk for the initial plant condition has one of the two Class IEElectrical Equipment Air Conditioning Units out of service.

Additionally, the "C" Normal ServiceWater pump (1WS001PC) is reflected as out of service as it is physically removed from theplant and has been shipped offsite for maintenance.

The Top 100 cutsets for CDF with SGK05A out of service are provided in attachment II.Numerical results of the cases for the risk evaluation are provided below in Table 1. The first isthe Base Case and uses the Zero Test and Maintenance model. The second case added thenon-functional SGK05A.Table 1: EOOS ResultsEquipment OOS CDF ( LERF (/ry)3ase CDF zero T&M @ 1E-12 truncation 3.87E-06 7.11E-077.54E-06 7.43E-073ase CDF zero T&M, 1WS001 PC OOS & SGK05A FailThe ICCDP and ICLERP were calculated from data in Table 1 using Equations 1 and 2 below.Equation 1: ICCDP = (ACDF) x Duration in yearsEquation 2: ICLERP = (ALERF) x Duration in yearsThe Duration in years is defined as the additional time for the SGK05A to be out of service.This request is for an additional 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> to complete repairs on the SGK05A unit.ICCDP = (7.54E-6

-3.87E-6)

  • (168 hrs 8760 hrs/yr) = 7.038E-08 ICLERP = (7.43E-7

-7.11 E-7) * (168 hrs 8760 hrs/yr) = 6.137E-1 0The ICCDP shown above fits into Regulatory Guide 1.182, "Assessing and Managing RiskBefore Maintenance Activities at Nuclear Power Plants,"

as an activity that merits riskmanagement considerations and activities.

The calculated value for ICCDP meets theRegulatory Issue Summary 2005-01, "Changes to Notice of Enforcement Discretion (NOED)Process and Staff Guidance,"

guidance threshold of less than or equal to 5.OE-07 ICCDP and5E-08 ICLERP. The calculated ICCDP and ICLERP values reported above do not account forvarious conservatisms in place such as the various compensatory actions being taken byoperations and maintenance while under the NOED.Numerical risk reductions for avoidance of Transition and Shutdown Risk are not included in theabove results.

Wolf Creek developed a Shutdown PRA in 1999. It utilized the samemethodologies for fault tree development as the At-Power model. While it was not fullyapproved, insights from its use showed a notable risk increase transitioning in Mode 4 due tothe defeat of automatic actuations for Safety Injection.

This caused a higher reliance on the Attachment I to WO 13-0050Page 7 of 13success of Operator Actions.

By simple qualitative evaluation, the numerical insight wasreasonable.

2. Dominant Risk Contributors Initiator

% CDF Description Contributio nINIT-SWS 52.50% LOSS OF ALL SERVICE WATER INITIATING EVENTINIT-SGR 7.60% STEAM GENERATOR TUBE RUPTURE INITIATING EVENTINIT-SLBO 7.30% LARGE STEAM LINE BREAK OUTSIDE CTMT INITIATING EVENTINIT-ISL-EJ-CLI 7.30% LPSI/HPSI CL INJECTION ISLOCA INITIATING EVENTINIT-FLB 5.90% LARGE FEEDWATER LINE BREAK INITIATING EVENTINIT-TRO 5.80% TRANSIENT WITHOUT POWER CONVERSION INITIATING EVENTINIT-LSP-WI 3.00% WEATHER-INDUCED LOSS OF OFFSITE POWER INITIATING EVENTINIT-TRA 2.20% TRANSIENT WITH POWER CONVERSION INITIATING EVENTINIT-SLO 1.90% SMALL LOCA INITIATING EVENTINIT-MLO 1.20% MEDIUM LOCA INITIATING EVENTINIT-ISL-RHR-1.10% RHR SUCTION ISLOCA INITIATING EVENTSCTINIT-DC4-NK04 0.80% LOSS OF 125V DC BUS NK04 INITIATING EVENTINIT-CCW 0.70% LOSS OF COMPONENT COOLING WATER INITIATING EVENTINIT-VEF 0.50% REACTOR VESSEL FAILURE INITIATING EVENTINIT-LSP-GR 0.50% GRID-RELATED LOSS OF OFFSITE POWER INITIATING EVENTINIT-DCl-NK51 0.40% LOSS OF 125V DC BUS NK51 INITIATING EVENTINIT-DC1-NK01 0.40% LOSS OF 125V DC BUS NK01 INITIATING EVENTINIT-DC4-NK54 0.30% LOSS OF 125V DC BUS NK54 INITIATING EVENTINIT-SLBI 0.20% LARGE STEAM LINE BREAK INSIDE CTMT INITIATING EVENTINIT-LSP-SC 0.20% SWITCHYARD CENTERED LOSS OF OFFSITE POWER INITIATING EVENTINIT-VLO 0.10% VERY SMALL LOCA INITIATING EVENTINIT-LLO 0.10% LARGE LOCA INITIATING EVENTINIT-ISL-LPSI-0.10% LPSI HL INJECTION ISLOCA INITIATING EVENTHLINIT-LSP-PC 0.00% PLANT-CENTERED LOSS OF OFFSITE POWER INITIATING EVENTLERF is dominated by Interfacing System LOCA (72.1%, combined).

The only other significant contribution to LERF comes from Steam Generator Tube Rupture (24.7%).The Top 100 cutsets for CDF are provided in Attachment I1.3. Compensatory Risk Manaqement ActionsCompensatory risk management actions that were discussed with the NRC on the June 17,2013 phone call are not explicitly credited in this evaluation.

This is considered a source ofconservatism.

As an example of ongoing compensatory actions not being credited, temporary cooling is replacing the function of the out-of-service SGK05A unit. Further, room temperatures are being monitored on a regular basis.4. Extent of condition Attachment I to WO 13-0050Page 8 of 13An increase in the probability of the common cause failure terms for the SGK05A and SGK05Bunits is not considered to be appropriate.

The SGK05B unit is not showing any indication similarto that of the "A" unit. Common cause basic events "ACGK-05AB--12-R1" (fail to run) and"ACGK-05AB--1 2-S1" (fail to start) retain their respective values.5. External EventsA list of the current fire impairments was reviewed with Fire Protection personnel.

All current fireimpairments are mitigated by compensatory risk management actions.

Nothing was identified that would impact this evaluation.

The following weather forecast information for the 7-day period during which the NOED is ineffect was obtained from the National Weather Service website.

There is no mention of severeweather for the duration.

Weather ForecastHAZARDOUS WEATHER OUTLOOK...

UPDATEDNATIONAL WEATHER SERVICE TOPEKA KS541 AM CDT MON JUN 17 2013KSZ008>012-020>024-026-034>040-054>056-058-059-181045-REPUBLIC-WASH I NGTON-MARSHALL-NEMAHA-BROWN-CLOUD-CLAY-RI LEY-POTTAWATOMIE-JACKSON-JEFFERSON-OTTAWA-DICKINSON-GEARY-MORRIS-WABAUNSEE-SHAWNEE-DOUGLAS-LYON-OSAGE-FRANKLIN-COFFEY-ANDERSON-541 AM CDT MON JUN 17 2013THIS HAZARDOUS WEATHER OUTLOOK IS FOR EAST CENTRAL...NORTH CENTRAL AND NORTHEAST KANSAS..DAY ONE...TODAY AND TONIGHT.OCCASIONAL THUNDERSTORMS WILL CONTINUE THIS MORNING PRIMARILY SOUTH OF INTERSTATE

70. LOCALLY VERY HEAVY RAINFALL WILL OCCUR INSOME AREAS OF COFFEY AND ANDERSON COUNTIES WHICH COULD LEAD TOFLOODING.

THERE IS SLIGHT CHANCE FOR THUNDERSTORMS LATER THIS AFTERNOON ANDTONIGHT IN PORTIONS OF NORTH CENTRAL KANSAS..DAYS TWO THROUGH SEVEN.. .TUESDAY THROUGH SUNDAY.THERE IS A CHANCE FOR MORE THUNDERSTORMS OVER THE AREAWEDNESDAY INTO THURSDAY NIGHT..SPOTTER INFORMATION STATEMENT...

SPOTTER ACTIVATION WILL NOT BE NEEDED THROUGH TONIGHT.Seismic EventSeismic considerations are treated as follows.

The seismically induced LOOP is taken fromRisk Assessment of Operational Events Volume 2 -External Events Revision 1.01 -January Attachment I to WO 13-0050Page 9 of 132008, Appendix A Frequencies of Seismically-Induced LOOP Events for SPAR Models:* 3.29E-04 Seismic Initiating Event Frequency

" 5.70E-02 Conditional Loss of Offsite Power* 1.87E-05 Seismic Induced Loss of Offsite PowerBy simple inspection, the additional

failures, such as those of Emergency Diesel Generators with fail-to-start basic event value of 2.498E-02, and the fraction of a year for the NOED(1.918E-02) results in any applicable sequence being well below 1E-07. Therefore, contribution to CDF from seismic is not considered significant.
m. Demonstrate that the NOED condition, along with any compensatory
measures, willnot result in more than a minimal increase in radiological riskThe results meet the criteria of Regulatory Issue Summary 2005-01 for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />. Continued operation of the plant during the period of enforcement discretion will not cause risk to exceedthe level determined acceptable during normal work controls and therefore there is no netincrease in radiological risk to the public. The risk metrics described by the NOED guidance areIncremental Conditional Core Damage Probability (ICCDP) less than or equal to 5.OE-07 andIncremental Conditional Large Early Release Probability (ICLERP) less than or equal to 5.OE-08.n. Discuss forecasted weather and pandemic conditions for the requested NOEDperiod and any plant vulnerabilities related to weather or pandemic conditions.

The weather forecast for the duration of the period allowed by the NOED includes no severeweather.The following weather forecast information for the 7-day period during which the NOED is ineffect was obtained from the National Weather Service website.

There is no mention of severeweather for the duration.

Weather ForecastHAZARDOUS WEATHER OUTLOOK...

UPDATEDNATIONAL WEATHER SERVICE TOPEKA KS541 AM CDT MON JUN 17 2013KSZO08>012-020>024-026-034>040-054>056-058-059-181045-REPUBLIC-WASH I NGTON-MARSHALL-NEMAHA-BROWN-CLOUD-CLAY-RI LEY-POTTAWATOMIE-JACKSON-JEFFERSON-OTTAWA-DICKINSON-GEARY-MORRIS-WABAUNSEE-SHAWNEE-DOUGLAS-LYON-OSAGE-FRANKLIN-COFFEY-ANDERSON-541 AM CDT MON JUN 17 2013THIS HAZARDOUS WEATHER OUTLOOK IS FOR EAST CENTRAL..

.NORTHCENTRAL AND NORTHEAST KANSAS..DAY ONE.. TODAY AND TONIGHT.OCCASIONAL THUNDERSTORMS WILL CONTINUE THIS MORNING PRIMARILY SOUTH OF INTERSTATE

70. LOCALLY VERY HEAVY RAINFALL WILL OCCUR INSOME AREAS OF COFFEY AND ANDERSON COUNTIES WHICH COULD LEAD TOFLOODING.

Attachment I to WO 13-0050Page 10 of 13THERE IS SLIGHT CHANCE FOR THUNDERSTORMS LATER THIS AFTERNOON ANDTONIGHT IN PORTIONS OF NORTH CENTRAL KANSAS..DAYS TWO THROUGH SEVEN...TUESDAY THROUGH SUNDAY.THERE IS A CHANCE FOR MORE THUNDERSTORMS OVER THE AREAWEDNESDAY INTO THURSDAY NIGHT..SPOTTER INFORMATION STATEMENT...

SPOTTER ACTIVATION WILL NOT BE NEEDED THROUGH TONIGHT.o. The basis for the conclusion that the noncompliance will not be of potential detriment to the public health and safety.WCNOC has evaluated whether or not a significant hazards consideration is involved with therequested enforcement discretion by focusing on the three standards set forth in10 CFR 50.92(c) as discussed below:(i) Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

NoThe proposed request does not adversely affect accident initiators or precursors nor alterthe design assumptions or the manner in which the plant is normally operated andmaintained.

The proposed request does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences ofan accident previously evaluated.

The proposed request is consistent with safety analysisassumptions, which apply when the plant is operating in compliance with LCOrequirements.

Therefore, the proposed request does not involve a significant increase in the probability or consequences of an accident previously evaluated.

(ii) Do the proposed changes create the possibility of a new or different kind of accident fromany accident previously evaluated?

Response:

NoWith respect to any new or different kind of accident, there are no proposed designchanges nor or there any changes in the method by which any safety related plant SSCperforms its specified safety function.

The proposed request will not affect the normalmethod of plant operation or change any operating parameters.

No new accidentscenarios, transient precursors, failure mechanisms, or limiting single failures will beintroduced as a result of this request.The proposed request will not alter the design or performance of the 7300 ProcessProtection System, Nuclear Instrumentation System, Solid State Protection System,Balance of Plant Engineered Safety Features Actuation System, Main Steam andFeedwater Isolation System, or Load Shedder and Emergency Load Sequencers used inthe plant protection systems.

Attachment I to WO 13-0050Page 11 of 13The request does not involve a physical modification of the plant. There are no alterations to the parameters within which the plant is normally operated.

No changes are beingproposed to the procedures relied upon to mitigate a design basis event. The requestdoes not have a detrimental impact on the manner in which plant equipment operates orresponds to an actuation signal.Therefore, the proposed request does not create a new or different kind of accident fromany accident previously evaluated.

(iii) Do the proposed changes involve a significant reduction in a margin of safety?Response:

NoThere will be no effect on those plant systems necessary to assure the accomplishment ofprotection functions associated with reactor operation or the Reactor Coolant System.The will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR)limits, heat flux hot channel factor, nuclear enthalpy rise hot channel factor, loss of coolantaccident peak cladding temperature, peak local power density, or any other limit andassociated margin of safety. Required shutdown margins in the CORE OPERATING LIMITS REPORT will not be changed.The proposed request does not eliminate any surveillances or alter the Frequency ofsurveillances required by the TSs.Therefore, the proposed changes do not involve a significant reduction in the margin ofsafety.Based on the above evaluations, WCNOC concludes that the activities associated with theabove described enforcement discretion request present no significant hazards consideration under the standards set forth in 10 CFR 50.92 and as such, would not be a potential detriment to the public health and safety.p. The basis for the conclusion that the noncompliance will not involve adverseconsequences to the environment.

WCNOC has determined that the proposed amendment would not change requirements withrespect to the installation or use of a facility component located within the restricted area, asdefined in 10 CFR 20, or would change an inspection or surveillance requirement.

Thisrequest for enforcement discretion meets the eligibility criteria for categorical exclusion set forthin 10 CFR 51.22(c)(9) as specified below:(i) Involves no significant hazards consideration.

As demonstrated in Section h above, this request does not involve any significant hazardsconsideration.

(ii) There is no significant change in the types of or significant increase in the amounts of anyeffluents that may be released offsite,The request does not involve a change to the facility or operating procedures that would causean increase in the amounts of effluents or create new types of effluents.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

Attachment I to WO 13-0050Page 12 of 13The request would not adversely affect the operation of the reactor and would not affect anysystem that would affect occupational radiation exposure.

The proposed request does notcreate additional exposure to utility personnel nor affect radiation levels that are present.

Therequest will not result in any increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forthin 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b),

an environmental assessment of the proposed change is not required.

q. A statement that the request has been approved by the facility organization thatnormally reviews safety issues (Plant Safety Review Committee).

This request has been approved by the WCNOC Plant Safety Review Committee.

r. A commitment is required that the written NOED request will be submitted within 2working days and the follow-up amendment will be submitted within 4 workingdays of verbally granting the NOED. State if the NRC has agreed during theteleconference that a follow-up amendment is not needed.This submittal is the written NOED request following the verbal approval granted on June 17,2013.This request for enforcement discretion is a one-time only extension of the Completion Time tocomplete restoration activities on the 'A' Class IE Air Conditioning System (SGK05A).

As such,a follow-up license amendment is not required.

This was agreed to during the June 17, 2013Teleconference.

s. If the NOED request is a natural event NOED, provide the following additional information:
1. List the name, organization, and telephone number of the official in the government or independent entity who made the emergency determination, if applicable.

Ifdeemed necessary, the staff may contact the appropriate official to independently verify the information the licensee provided before making a NOED determination.

2. Include details of the basis and nature of the emergency including, but not limited to,its effect on the following:

(a.) on-site and off-site emergency preparedness, (b.) plant and site ingress and egress,(c.) off-site and on-site power sources,(d.) plant security, (e.) grid stability, and(f.) actions taken to avert or alleviate the emergency situation (e.g., coordinating with other utilities and the load dispatcher organization for buying additional Attachment I to WO 13-0050Page 13 of 13power or for cycling loads, or shedding interruptible industrial or non-emergency loads)3. Identify and discuss the potential consequences of compliance with existing licenserequirements (e.g., plant trip, controlled shutdown).

4. Discuss the potential adverse effects on public health and safety from enforcing compliance with specific license requirements during the emergency.
5. Discuss the impact of the emergency on plant safety, including any limitations of theUHS.6. For a grid instability NOED, assure the NRC that all reasonable opportunities forpurchasing replacement power have been exhausted, and the NOED shall not last anylonger than replacement power becomes available, if applicable.

Not applicable, this is not a natural event NOED request.

Attachment II to WO 13-0050Page 1 of 51. 1.34E-06 ETHER*2. 2.08E-07 INIT-SWS BUPA ----- PA02-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR OTH-ESWAB-EXE-DF3. 2.08E-07 INIT-SWS BUSL ---- SL-41-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---PAL02-PR OTH-ESWAB-EXE-DF4. 2.08E-07 INIT-SWS BUSL ----- SL-4-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---PAL02-PR OTH-ESWAB-EXE-DF5. 1.53E-07 INIT-SWS BUPA ----- PA02-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB-EXE-DF6. 1.53E-07 INIT-SWS BUSL ---- SL-41-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB-EXE-DF7. 1.53E-07 INIT-SWS BUSL ----- SL-4-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB-EXE-DF8. 1.42E-07 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS PA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR TRSL -.-- XSL41-FA OTH-ESWAB-EXE-DF9. 1.04E-07 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TRSL ---- XSL41-FA OTH-ESWAB-EXE-DF10. 1.01E-07 INIT-SWS BUPA ----- PA02-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS OTH-ESWAB-EXE-DF11. 1.01E-07 INIT-SWS BUSL ---- SL-41-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS OTH-ESWAB-EXE-DF12. 1.01E-07 INIT-SWS BUSL ----- SL-4-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS OTH-ESWAB-EXE-DF13. 8.76E-08 INIT-ISL-EJ-CLI CF-PTOF CVBB8948A

ICO CVEJ8118A--

--ICO RUPTURE1 SOKCC2T14. 8.76E-08 INIT-ISL-EJ-CLI CF-PTOF CVBB8948B

ICO CVEJ8118B--

--ICO RUPTURE1 SOKCC2T15. 8.76E-08 INIT-ISL-EJ-CLI CF-PTOF CVBB8948C

ICO CVEJ8118C--

--ICO RUPTURE1 SOKCC2T16. 8.76E-08 INIT-ISL-EJ-CLI CF-PTOF CVBB8948D

ICO CVEJ8118D--

--ICO RUPTURE1 SOKCC2T17. 8.48E-08 INIT-SWS BUPA ----- PA02-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX OTH-ESWAB-EXE-DF18. 8.48E-08 INIT-SWS BUSL ---- SL-41-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX OTH-ESWAB-EXE-DF19. 8.48E-08 INIT-SWS BUSL ----- SL-4-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS Attachment II to WO 13-0050Page 2 of 5OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX OTH-ESWAB EXE-DF20. 6.86E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS TRSL -.-- XSL41-FA OTH-ESWAB EXE-DF21. 6.34E-08 PA-ODI-EXE OPA-OD2-EXE SGRASSV-SUCCESS

22. 6.34E-08 PA-ODI-EXE OPA-OD2-EXE SGRBSSV-SUCCESS
23. 6.34E-08 OPA-OD1-EXE OPA-OD2-EXE SGRCSSV-SUCCESS
24. 6.34E-08 MOPA-OD1-EXE OPA-OD2-EXE SGRDSSV-SUCCESS
25. 5.77E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS PA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX TRSL ---- XSL41-FA OTH-ESWAB EXE-DF26. 4.17E-08 INIT-SWS BUSL ----- SL4A-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR TZSW---DEBRIS-PL OTH-ESWAB-EXE-DF

27. 4.05E-08 CRSF-MECHBINDING FG-AMS-SUCCESS MFA-FAILS X -UET ------ MTC28. 4.03E-08 FG-AFW OPA-OFB-EXE XXALSTMBD-123-F329. 3.28E-0830. 3.17E-08 INIT-SWS CBPA---PA0209-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR OTH-ESWAB-EXE-DF31. 3.17E-08 INIT-SWS CBSL ---- 13-34-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR OTH-ESWAB-EXE-DF32. 3.17E-08 INIT-SWS CBSL ---- 13-37-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---PAL02-PR OTH-ESWAB-EXE-DF33. 3.17E-08 INIT-SWS CBSL ----- 4-16-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR OTH-ESWAB-EXE-DF34. 3.13E-08 INIT-ISL-RHR-SCT CF-PTOF MVBB8702A

IO0 MVEJ8701A--

---IL RUPTURE435. 3.13E-08 INIT-ISL-RHR-SCT CF-PTOF MVBB8702B

.IOO MVEJ8701B--

---IL RUPTURE336. 3.07E-08 INIT-SWS BUSL ----- SL4A-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TZSW---DEBRIS-PL OTH-ESWAB-EXE-DF

37. 2.89E-08 FG-AFW FG-AFW-AUTO-STRT FG-SW-ISLN-OCCRS RESB-525AB-12-Cl SLBA TPAL ---- PAL02-PR38. 2.89E-08

--FG-AFW FG-AFW-AUTO-STRT FG-SW-ISLN-OCCRS RESB-525AB-12-Cl SLBB TPAL ---- PAL02-PR39. 2.89E-08 FG-AFW FG-AFW-AUTO-STRT FG-SW-ISLN-OCCRS RESB-525AB-12-Cl SLBC TPAL ---- PAL02-PR40. 2.89E-08 FG-AFW FG-AFW-AUTO-STRT FG-SW-ISLN-OCCRS RESB-525AB-12-Cl SLBD TPAL ---- PAL02-PR41. 2.83E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS PA-WOPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR TRSL ---- XSL4A-FDEBRIS-PL OTH-ESWAB-EXE-DF

42. 2.59E-08 FG-SW-ISLN-OCCRS MFGL-10AB--12-RI STOESWA-EXE A TZSW---

Attachment II to WO 13-0050Page 3 of 543. 2.34E-08 INIT-SWS CBPA---PA0209-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB-EXE-DF44. 2.34E-08 INIT-SWS CBSL ---- 13-34-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB-EXE-DF45. 2.34E-08 INIT-SWS CBSL ---- 13-37-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB-EXE-DF46. 2.34E-08 INIT-SWS CBSL ----- 4-16-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB-EXE-DF47. 2.33E-08 ESNFLOCASEQ12SF1 FG-AFW FG-AFW-AUTO-STRT FG-SW-ISLN-OCCRS SLBA TPAL ---- PAL02-PR48. 2.33E-08 ESNFLOCASEQ12SF1 FG-AFW FG-AFW-AUTO-STRT FG-SW-ISLN-OCCRS SLBB TPAL ---- PAL02-PR49. 2.33E-08 ESNFLOCASEQ12SF1 FG-AFW FG-AFW-AUTO-STRT FG-SW-ISLN-OCCRS SLBC TPAL ---- PAL02-PR50. 2.33E-08 ESNFLOCASEQ12SF1 FG-AFW FG-AFW-AUTO-STRT FG-SW-ISLN-OCCRS SLBD TPAL ---- PAL02-PR51. 2.09E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB

-FAILS OPA- SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TRSL ---- XSL4A-FA TZSW- --DEBRIS-PL OTH-ESWAB-EXE-DF

52. 2.02E-08 INIT-SWS BUSL ----- SL4A-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS

-- _OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS TZSW- --DEBRIS-PL OTH-ESWAB-EXE-DF

53. 1.85E-08 FG-SW-ISLN-OCCRS OPA-BNLB-MISC-LD PVBB ---- 8010A-00 RESB-713AB-12-Cl
54. 1.85E-08 FG-SW-ISLN-OCCRS OPA-BNLB-MISC-LD PVBB----8010B-00 RESB-713AB-12-Cl
55. 1.85E-08

ý ýFG-SW-ISLN-OCCRS OPA-BNLB-MISC-LD PVBB ---- 801OC-00 RESB-713AB-12-Cl

56. 1.85E-08 INIT-SWS BUPA ----- PA02-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS MVFC--- HV0312-CC OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB EXE-DF57. 1.85E-08 INIT-SWS BUSL ---- SL-41-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS MVFC---HV0312-CC OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB EXE-DF58. 1.85E-08 INIT-SWS BUSL ----- SL-4-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS MVFC--- HV0312-CC OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-ESWAB EXE-DF59. 1.76E-08 CRF DGNE -NE01-PR DGNE -----NE02-PR OPA-NSAFW OTH-INIT-LSP-N SBOSDS-SUCCESS RACR1F2W60. 1.70E-08 1PA- BNLB-MISC-LD61. 1.70E-08 INIT-SWS BUSL ----- SL4A-FA FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX TZSW---DEBRIS- PL OTH-ESWAB-EXE-DF
62. 1.55E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS MPWS-1WS01PA-GPR OPA-IWSIPABC-EXE OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR OTH-WS2-ESWAB-DF63. 1.55E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS MPWS-IWS01PB-GPR OPA-1WSIPABC-EXE Attachment II to WO 13-0050Page 4 of 5OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPALT---

PAL02-PR OTH-WS2-ESWAB-DF64. 1.54E-08 INIT-SWS CBPA---PA0209-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS OTH-ESWAB-EXE-DF65. 1.54E-08 INIT-SWS CBSL ---- 13-34-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS OTH-ESWAB-EXE-DF66. 1.54E-08 INIT-SWS CBSL ---- 13-37-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS OTH-ESWAB-EXE-DF67. 1.54E-08 INIT-SWS CBSL ----- 4-16-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS OTH-ESWAB-EXE-DF68. 1.48E-08 OFG-SW-ISLN-OCCRS MVEG-1012-12-HOl

69. 1.44E-08 FG-SW-ISLN-OCCRS MFGL-10AB--12-SI
70. 1.43E-08 INIT-CCW BUNB ----- NB02-FA BUNK ----- NK01-FA FG-AFWFG-CCWA-FAILS FG-FW FG-NO-DC1LOSS FG-OSP-NB01-AVAL FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS PAVAIL TPAL ---- PAL02-PR71. 1.40E-08 M FG-SW-ISLN-OCCRS MFGL-10AB--12-XI
72. 1.37E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PS TRSL ---- XSL4A-FA TZSW---DEBRIS-PL OTH-ESWAB-EXE-DF
73. 1.35E-08 FG-NB01-PWR-AVAL FG-SW-ISLN-OCCRS FLBA OPA-MSISOL-EXE OPA-RHR-EXE OSC-FLB74. 1.35E-08 FG-NB01-PWR-AVAL FG-SW-ISLN-OCCRS FLBD OPA-MSISOL-EXE OPA-RHR-EXE OSC-FLB75. 1.33E-08 CR1F DGNE ----- NE01-PR DGNE -----NE02-PR DGNSAFP -------PS OTH-INIT-LSP-N SBOSDS-SUCCESS RACR1F2W76. 1.32E-08 FG-SW-ISLN-OCCRS MPEJ-01AB-12-BS1
77. 1.29E-08 INIT-SWS CBPA---PA0209-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL----

PAL02-PX OTH-ESWAB-EXE-DF78. 1.29E-08 INIT-SWS CBSL ---- 13-34-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX OTH-ESWAB-EXE-DF79. 1.29E-08 INIT-SWS CBSL ---- 13-37-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX OTH-ESWAB-EXE-DF80. 1.29E-08 INIT-SWS CBSL ----- 4-16-CO FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX OTH-ESWAB-EXE-DF81. 1.26E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS FC---HV0312-CC OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL TRSL ---- XSL41-FA OTH-ESWAB-EXE-DF82. 1.18E-08 FG-SW-ISLN-OCCRS MFGL-10AB--12-R1 MWPVBB----8010A-O0 RESB-713AB-12-Cl

83. 1.18E-08

.... .. FG-SW-ISLN-OCCRS MFGL-10AB--12-RI mPvBB----801OB-00 RESB-713AB-12-Cl

84. 1.18E-08 FG-SW-ISLN-OCCRS MFGL-10AB--12-R1 PVBB ---- 8010C-OO RESB-713AB-12-Cl
85. 1.15E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS OPA-WSTOESWA-EXE Attachment II to WO 13-0050Page 5 of 5OPA-WSTOESWB-EXE PAVAIL TPAL ---- PAL02-PX TRSL ---- XSL4A-FA TZSW---DEBRIS-PL OTH-ESWAB-EXE-DF
86. 1.14E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS MPWS-1WS01PA-GPR OPA-1WS1PABC-EXE OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-WS2-ESWAB-DF87. 1.14E-08 INIT-SWS FG-AFW FG-NO-SIS-NO-LSP FG-RCP-COOL-LOSS FG-TRAINA-FAILS FG-TRAINB-FAILS MPWS-IWS01PB-GPR OPA-1WS1PABC-EXE OPA-SGOVERFL-COG OPA-WSTOESWA-EXE OPA-WSTOESWB-EXE PAVAIL OTH-WS2-ESWAB-DF88. 1.12E-08
  • ESSB515AB-F12VF1 FG-NO-DC1LOSS MFA-CONTINUES OPA-MANUALRT-COG OPA-MRT-COG
89. 1.IIE-08 PA-ABV-ISOLATED SGRA SSV-SUCCESS 90 I.IIE-08 1PA-ABV-ISOLATED SGRB SSV-SUCCESS
91. 1.11E-08 PA-ABV-ISOLATED SGRC SSV-SUCCESS
92. 1.11E-08 PA-ABV-ISOLATED SGRD SSV-SUCCESS
93. 1.09E-08 FGL-10AB--12-RI
94. 1.08E-08 FG-SW-IS FLBA OPA-RHR-EXE OPA-SLB-EXE OSC-FLB95. 1.08E-08 0FG-SW-ISLN-OCCRS FLBB OPA-RHR-EXE OPA-SLB-EXE OSC-FLB96. 1.08E-08 FG-SW-ISLN-OCCRS FLBC OPA-RHR-EXE OPA-SLB-EXE OSC-FLB97. 1.08E-08 MFG-SW-ISLN-OCCRS FLBD OPA-RHR-EXE OPA-SLB-EXE OSC-FLB98. 1.07E-08 FG-NB01-PWR-AVAL FG-SW-ISLN-OCCRS OPA-MSISOL-EXE RESB-525AB-12-Cl SLBA99. 1.07E-08 F&G-NB01-PWR-AVAL FG-SW-ISLN-OCCRS OPA-MSISOL-EXE RESB-525AB-12-Cl SLBD100. 1.01E-08 FG-NB0l-PWR-AVAL FLBA OPA-MSISOL-EXE OPA-OF2-EXE OSC-FLB101. 1.01E-08 FG-NB01-PWR-AVAL FLBDOPA-MSISOL-EXE OPA-OF2-EXE OSC-FLB*NOTE: The "ETHER" cutest, listed as the first cutest, is a summation of all the cutsets not retained by the cutest file following quantification.

In order to utilize storage space and memoryeffectively, the number of cutsets recorded in the cutest file islimited to 1000. This can be overridden if necessary, however itresults in large file sizes. Therefore, the EOOS program sums up thevalues of all cutsets below the top 1000 into the "ETHER" event.

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