FENOCFH F/r6,sf ,\t cl.ar Ootr,,Ug conWry

Davis-Besse Nuclear Power Sfafibn5501 North Sfafe Route 2

Oak Harbor, OH 43449

Mark B. BezillaSife Vrce President

419-321-7676Fax: 419-321-7582

August 9,2017L-17-243 10 cFR 50.54(f)

ATTN: Document Control DeskU.S. Nuclear Regulatory Commission1 1555 Rockville PikeRockville, MD 20852

SUBJECT:Davis-Besse Nuclear Power StationDocket No. 50-346, License No. NPF-3Mitigatinq Strateoies Assessment (MSA) Report for the Reevaluated Seismic HazardInformation - NEI 12-06 . Appendix H. ision 2. H.4.4 Path 4: G RS < 2xSSE(CAC No. MF3728)

The purpose of this letter is to provide the results of the MSA for Davis-Besse NuclearPower Station (DBNPS) to demonstrate that the FLEX mitigating strategies developed,implemented, and maintained in accordance with Nuclear Regulatory Commission(NRC) Order EA-12-049 can be implemented considering the impact of the reevaluatedseismic hazard. The assessment was performed in accordance with the guidanceprovided in Appendix H of Nuclear Energy lnstitute (NEI) 12-06, Revision 2(Reference 1), which was endorsed by the NRC (Reference 2).

The mitigating strategies seismic hazard information (MSSHI) is the licensee'sreevaluated seismic hazard information, developed using a probabilistic seismic hazardanalysis (PSHA). The MSSHI includes a performance-based ground motion responsespectrum (GMRS), uniform hazard response spectra (UHRS) at various annualprobabilities of exceedance, and a family of seismic hazard curves at variousfrequencies and fractiles developed at the site control point elevation. FirstEnergyNuctear Operating Company submitted the DBNPS reevaluated seismic hazardinformation including the UHRS, GMRS, and the hazard curves to the NRC inReferences 3 and 4. The NRC staff concluded that the MSSHI that was submittedadequately characterizes the reevaluated seismic hazard for the site (Reference 5).

Based upon the MSA provided in the enclosure to this letter, the mitigating strategies forDBNPS considering the impacts of the reevaluated seismic hazard can be implementedas designed with identified grating clips to be installed in one plant area.

Davis-Besse Nuclear Power StationL-17-243Page 2

There are no new regulatory commitments contained in this letter. lf there are anyquestions or if additiona! information is required, please contact Mr. Thomas A. Lentz,Manager - Fleet Licensing, at 330-315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed onAugust 1 ,2017.

B. Bezilla

EnclosureSeismic Mitigating Strategies Assessment Davis-Besse Nuclear Power $tation

References:1. NEI 12-06, Diverce and Flexibte Coping Sfrafegies (FtE)fl lmplementation Guide,

Revision 2, December 2015, Agencywide Documents Access and ManagementSystem (ADAMS) Accession Number ML1600SA6ZE.2. JLD-ISG-Z012-01, Complianm with Order EA-12-049, Order Modifuing Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events, Revision 1, dated January 22,2016, ADAMS Accession NumberM115357A163.

3. FENOC Letter, FirstEnergy Nuclear Operating Company (FENOC) Response toNRC Request for lnformation Pursuant to 10 CFR 50.54(D Regarding the SeismieAspects of Recommendation 2.1 of the Near-Term Task Force (NTTF) Review oflnsights from the Fukushima Dai-ichi Accident - 1.5 Year Response for CEUSSites, dated September 1 1,2013, ADAMS Accession Number ML132544312.4. FENOC Letter, FirstEnergy Nuclear Operating Company (FENOC) Seismic Hazardand Screening Report (CEUS Sites), Response to NRC Request for lnformationPursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-TermTask Force (NTTF) Review of lnsights from the Fukushima Dai-ichi Accident,dated March 31,2014, ADAMS Accession Number ML14092A203.5. NRC Letter, Davis-Besse Nuclear Power Station, Unit 1 - Staff Assessment oflnformation Provided Pursuant to Title 10 of the Code of Federal RegulafionsPart 50, Section 50.54(f), Seismic Hazard Reevaluations for Recommendation 2.1of the Near-Term Task Force Review of lnsights from the Fukushima Dai-ichiAccident, dated August 25, 2015, ADAMS Accession Numbers ML15230A289.

Davis-Besse Nuclear Power StationL-17-243Page 3

cc: Director, Office of Nuclear Reactor Regulation (NRR)NRC Region lll AdministratorNRC Resident lnspectorNRR Project ManagerUtility Radiological Safety Board

FIRST ENERGY I{UCI,EAR OPERATINGCOMPAIIIY

Seismic Mitigating StrategiesAsse$sment

Davis-Bes$e Fluclear Power Station

Report Name:

Dstr:

Revision No.:

APPROVALS

Seismic Mitigating Strategies AssessmentDavis-Besse Nuclear Power Station

June 12,2fr17

Revision 0

M. Andrews, Nuclear Engineer (FENOC) Date

Reviewed by:

w Senior Consulting Engineer ( FENOC) Date

Reviewed by:

2o Tur., 2.ot-I

othz-/zoxy

6*ZL-Lql?Date

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Approved by:

Timothy Nuclear Engineer (FENOC)

K. Supervisor, Nuclear Annlytical Methods Date(FENOC)

Ut

Mohamrned F. AIvi, Project Manager (FEHOC) Date

Approved by:

T A r, Corporate Functional Area Manager (FENOC) Datel'l

IIESGonsulting

Preparedfor:

FirstEnergy Nuclear Operating Gompany

27S4296-R-0{7Revision 0

#El#T-gSeismic Mitigating StrategiesAssessmentDavis-Besse Nuclear Power Station

June 12,2017

AE$G Consultirrg lnc, . 300 Cornmerce Drive, $uite 200 . lrvine, Galifomia 92602

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SEISIUIC MITIGATING STRATEGIES ASSESSMENTDAVIS-BESSE NUCLEAR POWER STATION

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ABSG CONSI.JLTING INC.RIZZO ASSOCIATES

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Report Name;

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Revision No.t

0riginatorl

IndependentVerifier:

Principal:

ProjectManager:

fr"r-@WJune I2. 2017Date

June 12.2017Date

June 1.2, 2017Date

June 12.2,017Date

June l2-.2017Date

APPROVALS

Seismic Mitigating Smategies AssessmentDavis-Besse Nuclear Power Station

June 12,2017

0

Bradley YaglaEngineering AssociateRIZZO Associates

Eddie Cuerra, P.E.Director of Structural EngineeringKIZZO Associates

-hli".,u"flNishikant R. Vaidya, Ph.D., P,E.Vice PresidentRIZZO Associates

7etrFarzin R. Beigi, P.E.ConsultantRIZZO Assosiates

R. Roche, P.E.Vice PresidentABSG Consulting Inc.

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CHANGE ITIANAGEMENT RECORI}

RnvlslouNo, I)*rn Du,scRIrrIoNs oF CHAIIGEs/AFFECTED P*c ps

0 June l2,20l7 Initial Submittal

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TABLE OF CONTENTS

2.0 ASSESSMENT TO MSSHI t2

2.1 Srep I - ScopE oF MSA Pl*ur EQutphagNT..............+..+.*.r..rr ......1 2

2,2 Srgp 2 - ESEP REvlgw !r.+r...r......*..a..r.,..r....1..+..r.....1r.,r,rrr..+..,....r.,+.*3.....,.,l2

2.1 SrEp 3 - INHURENTLy/Sunptclpt'trLy Ruccsn EQUIPMENT .........I 3

2.4 Srsp 4 - EveluATIoNs Ustuc Sscrtoht H,5 or RerpnrNcs I t3

PAGE

2.4.3 Tie-Down of FLEX Portable Equipment .21

2.4.4 AdditionalSeismiclnteractions 77

ENCLOSURE I - NEI 12.06 APPENDIX H PATH 2 HF REVIEW

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FIGURE NO.

FICURE I.I

LIST OF'FIGURES

TITLE PAGECOMPARISON OF GMRS AND SSE AT THE DBNPSC0NTROL POINT ELEVATION.r.....r..,1.. ..+r".r....r.......1I

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ABS

AC

ACIALTASCE

AUXAUX6AUXT

AUXS

AVVBDB

BDBEE

BWST

CR

CTMTCWRT

DtsNPS

DC

EFW

EFWF

EFWP

EFWST

EL

ELAP

EPRI

ESEL

ESEP

FENOC

LIST OF ACRONYMS

ABSG CONSULTING INC.

ALTERNATING CURRENT

AMERICAN CONCRETE INSTITUTE

ALTERNATEAMERICAN SOCIETY OF CIVIL ENGTNEERS

AUXILIARY BUILDING

AUXILIARY BUILDING - AREA 6

AUXILIARY BUILDINC - AREA 7

AUXILIARY BUILDINC - AREA 8

ATMOSPHERIC VENT VALVEBE,YOND DESIGN BASIS

BEYOND.DES IGN-BASI S EXTERNAL EVENT

BORATED WATER STORAGE TANK

CONDITION REPORT

CONTAINMENT BUILDING

CLEAN WASTE RECEIVER TANK

DAVIS-BESSE NUCLEAR POWER STATION

DIRECT CURRENT

EMERGENCY FEEDWATER

EMEROENCY FEEDWATER FACILITY

EMERGENCY FEEDWATER PUMP

EMERGENCY FEEDWATER STORAGE TANK

ELEVATION

EXTENDED LOSS OF AC POWER

ELECTRIC POWER RESEARCH INSTITUTE

EXPEDITED SEISMIC EQUIPMENT LIST

EXPEDITED SEISMIC EVALUATION PROCESS

FI RSTENERCY NUCLEAR OPERATING COMPAN Y

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FIP

FIRS

FLEX

FSC

ftoE

ch{RsHELB

HF

Hz

ISRS

LOCA

LP

LUHS

MCC

MSA

MSSHI

NEI

NRC

NSGSF

NTTF

OBC

OTSG

PA

FAF

PGA

PORV

PSHA

LIST OF ACRONYMS(coNTTNUED)

FINAL INTEGRATED PLANFOI.JNDATION INPUT RESPONSE SPECTRA

DIVERSE AND FLEXIBLE COPINC STRATEGIESFLEX SUPPORT GUIDELINEFEET

ACCELERATION OF GRAVITYGROI.'ND MOTION RESPONSE SPECTRA

HIGH ENERGY LINE BREAKHIGH FREQUENCY

HERTZ

TN.STRUCTURE RESPONSE SPECTRA

LOS S-OF-COOLANT ACC I DENTLOW PRESSURE

LOSS OF NORMAL ACCESS TO THE ULTIMATE HEAT SINKMOTOR CONTROL CENTER

M ITIGATTNG STRATEGI ES ASSESSMENTMITIGATTNG STRATEGIES SEISMIC HAZARD TNFORMATIONNUCLEAR ENERGY INSTITUTEI.JN ITED STATES NUCLEA R REGULATORY COM h,I I S S IONNEW STEAM CENERATOR STORAGE FACILITYNEAR.TERh{ TASK FORCE

OHIO BUILDING CODE

ONCE-THROUCH STEAM GENERATORSPROTECTED AREAPERSONNEL ACCESS FACILITYPEAK CROI.'ND ACCELERATIONPOWER OPERATED RELIEF VALVEPROBABI LISTIC SEI SMIC HAZARD ANALYSIS

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PSV

RCP

RFO

RIZZORLE

RP

SB7

SFP

SG

SFRCS

SILO

SPRA

SSCs

SSE

TURB

UBC

UHRS

USAR

VVAC

LIST OF ACRONYMS(coNTINUErl)

PRESSURIZER CODE SAFETY VALVE

REACTOR COOLANT PUMP

REFUELING OUTACE

RIZZO ASSOCIATES

REVIEW LEVEL EARTHQUAKE

RADIATION PROTECTION

SERVICE BUILDING 7

SPENT FUEL POOL

STEAM CENERATOR

STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM

SEAL-IN OR LOCK.OUT

SEISMIC PROBABILISTIC RISK ASSESSMENT

STRUCTURES, SYSTEMS, AND COMPONENTS

SAFE SHUTDOWN EARTHQUAKE

TURBINE BUILDING

LIN I FORIvI BUILDING CODE

UNIFORM HAZARD RESPONSE SPECTRA

UPDATED SAFETY ANALYSIS REPORT

VOLTS

VOLTS ALTERNATING CURRENT

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IUITIGATING STRATEGIES ASSESSMENTDAVIS-BESSE NUCLEAR POWER STATION

I.O BACKGROI-]ND

Davis-Besse Nuclear Power Station (DBNPS) has completed a mitigating strategiesassessmsnt (MSA) forthe impaets ofthe reevaluated seismic hazard to determine if themitigating (FLEX) strategies developed, implemented, and maintained in accordance withNuclear Regulatory Commission (NRC) Order EA-l 2-049 remain acceptable at the reevaluatedseismic hazard levels. The MSA was performed in accordance with the guidance provided inAppendix H ofNuclear Energy Institute (NEl) 12-06 Revision 2 (Reference llwhich wasendorsed by the NRC (Reference Z).

The Mitigating Strategies Seismic Hazard Information (MSSHI) is the reevatuated seismichazard information at DBNPS developed using the Probahilistic Seismic HazardAnalysis (PSHA). The MSSHI includes a performance-based Ground Motion ResponseSpectrum (AMRS), Uniform Hazard Response Spectra (UHRS) at various annual probabilities ofexceedaneeo and a family of seismic hazard cuwcs at various frequcncies and fractiles developedat the DBNPS control point elevation. DBNPS subrnitted the reevaluated seismic hazardinformation including thE UHRS, GMRS and the hazard curves to the NRC on March 3l, Z0l4(Reference 3). The NRC staffconcluded that the CMRS that was submitted adequatelycharacterizes the reevaluated seismic hazard for the DBNPS site (Reference 4). Section 6.1.1 ofReference 2 identifies the method described in Section H.4.4 of Reference I as applicahle toDBNPS.

Subsequent to the March 31,2014 submittal (Reference 3), the seismic hazard was updatedconsidering site specific damping in rock. The updated seismic hszard is the basis for the rccentstation Seismic Probabilistic Risk Assessment (SPRA) and also for the Expedited SeismicEvaluation Process (ESEP) Reports submitted by FirstEnergy Nuclear OperatingCompany $ENOC) on December I g, Z0l4 (Reference I 0).

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Figure /-f presents the comparison of the Safe Shutdown Earthquake (SSE), ESEP GMRS

(Reference l0) and the GMRS reported in the DBNPS March 2014 submittal (Reference 3). The

difference in the GMRS results is aftributed to the material damping used for the rock material

overthe upper 500 feet (ft). While the GMRS reported in the March 2014 submittal is based on

the low strain damping of approximately 3.2 percent over a depth of 500 ft below the

Containment Building (CTMT) foundation, the GMRS used in the ESEP limits this damping

value to the upper 100 ft where the rock is considered as weathered or fractured. Below this

depth, a low strain damping of 1.0 percent is used based on the unweathered shale dynamic

properties from Stokoe et al. (Refcrence l7).

.at0Ytrot-JIUl-o*oftt{-TEEUoca

0.50

0.50

0.40

0.30

0.20

0.10

0.001.00

Frequency (HZl10.00 100.00

coMpARrsoN oF GMRs AND ssE llt'ItlfJr'n*, coNrRoL polNr ELEvATIoN

ln a letter dated October 19, 2015 (Reference l3), the NRC staffconveyed its acceptance of the

DBNPS ESEP. Therefore, the ESEP GMRS, characterized by a peak ground acceleration (PGA)

of 0.209, is the review level earthquake (RLE) considered for the MSA.

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0.10

- GMRS [ESEP, Dec. 2014 submlttallGMRS [March 2AL4 submittall* ssE PGA

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2.0 ASSESSIVIENT TO MSSHI

Consistent with Section H.4.4 (Path 4) of Reference l, the DBNPS GMRS has spectralaccelerations greater than the SSE but no more than two times the SSE anywhere in theI Hertz (Hz) to l0 Hz frequency range. As described in the FLEX Strategy Design andEquipment Bases Detail (Reference l8), the plant equipment relied on for FLEX strategies havepreviously been evaluated as seismically robust to the SSE levels. The basic elements within theMSA of Path 4 Structures, Systems, and Components (SSCs) are described in Reference LImplementation of each of these basic Path 4 elements forthe DBNPS site is summarized below.

2.1 Srnp I - Scopu or MSA plru*r Egulrnanxr

The scope of SSCs considered for the Path 4 MSA was determined following the guidance usedfor the ESEP defined in Electric Power Research Institute (EPRI) 3002000704 (Reference g).

FLEX SSCs excluded from consideration in the ESEP were added to the MSA equipment scope.In addition, SSC fsilure modes not addressed in the ESEP that could potentially affect the FLEXstrategies were added and evaluated.

SSCs associated with the FLEX strategy that are inherently rugged or sufficiently rugged arediscussed in Section 2.J below and identifred in Section H.4.4 (Path 4) of Reference L TheseSScs were not explicitly added to the scope of MSA plant equipment.

2.2 $rsp 2 - ESEP Rsvlew

Equipment used in support of the FLEX strategies has been evaluated to demonshate seismicadequacy following the guidance in Section 5 of NEI l2-06, As stated ln Appendix H ofNEI l2-06, previous seismic evaluations should be credited to the extent that they apply for theassessment of the MSSHI. This includes the ESEP evaluations (Reference l0) forthe FLEXstrategies which wenE performed in accordance with EPRI 3002000?04 (Reference g). TheESEP evaluations remain applicable for this MSA since these evaluations directly addressed themost critical I Hz to l0 Hz part of the new seismic hazard using seismic responsss from thescaling of the design-basis analyses. Since all equipment in the Expedited Seismic EquipmentList (ESEL) satisfies the ESEP requirernents, they also meet the requirements for this MSA.

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Therefore, oily component on the ESEL requires no further evaluation to show the Ctru" capacity

is acceptable. Separate evaluations are performed to address high-frequency (HF) exceedances

under the HF sensitive equipment assessment process, as required, and are documented in

Section d.0 of this report.

2.3 SrEp 3 - Ir*IHsRENTLY/SUprlclrNTLY RUCCEU EQulpMBrrlr

The qualitative assessment of certflin SSCs not included in the ESEP was accomplished

using (l) a qualiutive screening of "inherently ruggcdo'SSCs and (2) evaluation of SSCs to

determine if they are *'sufficiently rugged." Reference I documents the process and the

justification for this ruggedness assessment. SSCs that are either inherently rugged or

sufliciently rugged are described in Reference I and no further evaluations for these rugged

SSCs are required under the MSA.

2,4 Srsp 4 - Ev*uUATloNs Uslruc SecrlON H,5 op RsrsReNCE I

Step four for Path 4 plants includes the evaluations of;

l. FLEX Equipment Storage Buildings and Non-seismic Category I Structures that couldImpact FLEX imPlementation

?. Operator Pathways

3. Tie-Down of FLEX Portable Equipment

4. Seismic lnteractions not Included in ESEP that could Affect FLEX Strategies

5. Haul Paths

The results of the reviews of each of these ftve areas are descrihed in the sections below.

In addition to the FLEX portable equipment, various anchored mechanical and electrical

equipment (diesel-driven Emergency Feedwater (EFW) Pump, motor-driven Reactor Coolant

System (RCS) FLEX Charging and Booster Purnps, Motor Control Center (MCC), fuel oil

storage tank, battery charger, panels, etc.) were installed in the Emergency Feedwater Facility

(EFWF) and the Auxiliary Building (AUX) in support of the FLEX strategy. This equipment

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was also evaluated under the GMRS level demand and found to all have Crtrzo capacities inexcess of the RLE PGA.

Forevaluations performed in accordance with $ection H.5 of Reference l, seismic demanddeveloped in support of the recent SPRA for DBNPS is used as input. As part of the SpRAseismic demand development, detailed building model analyses were performed for all SeismicCategory I structures. Using SPRA foundation input response specfia (FIRS) consistent with theGMRS as input, in-structure response spectra (ISRS) were obtained from these analyses. TheSPRA ISRS was also used to complete the ESEP analysis (Reference l0).

2,4.1 FLEX Equipment $tonnge Buildings

The EFWF and Service Building 7 (SB?) are used for FLEX equipment storage. The EFWF isdesignated for "N" FLEX equipment storage and the SB? for "N+l'n equipment storage. OtherFLEX equipment is located inside the AUX Building Area 6, Area ?, and Area B, herein referredto as AUX6, AUX7, and AUX8, respectively, or generally as AUX, typically ncar locationswhere the equipment will be used. The EFWF and the AUX locations provide protection fromall hazards - ineluding seismic events. The remainder of FLEX equipment is stored in theDBNPS Yard area.

Emergency Feedwater Facitify

DBNPS constructed a new EFWF to support the site's FLEX mitigation strategy. The EFWFis located inside the Protected Area (PA) to the west of the CTMT. The EFWF consists oftwo pails - (l) an Emergsncy Feedwater Storage Tank (EFWST) designed to holdapproximately 290,000 gallons sf sondensate quality water and (2) a facility used to house theEmergency Feedwater (EFW) system and FLEX equipment. The EFWST is at grade level,while the facility consists of three'floors. The basement of the facility, which is locatedapproximately 20 ft below grade, will store the diesel-driven EFW pump as well as a chemicalinjection skid. The first floor of the facility, situated at elevation {EL} SBd ft, houses theFLEX 'N' turbinE generator, FLEX pumps (i.e., Alternate Low Pressure EmergencyFeedwater'N' Pump, EF\ryST Replenishment 'N' Pump, Spent Fuel Spray 'N' Pump, etc.),and also provides the rneans of egress to the EFIVF. The second floor of the facility at EL 603ft stores the diesel fuel oil tank, batteries, 480VAC Main Controt Center, and other equipment.

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The roof of the building is at approximate EL 620 ft. The EFWF is rectangularwith a total

footprint of 72 ft x 54 ft.

The EFWF is a reinforced concrete structure, The 54 ft x 34 ft EFWF basement mat

foundation bears on bedrock and the EFW$T 54 ft x 36 ft mat foundation is supported by

drilled piers socketed into bedrock. The first and second floors of the structure are supported

by composite beams. The roof consists of reinforced concrete slabs spanning between the

reinforced conerete walls. The roll-up door on the north side of the EFWF is shielded with a

Kevlar outer door that swings open.

The EFWF is a non-safety-related structure, and is not required forsafe shutdown of the plant;

however, to satisff NEI l2-06 (Reference l) requiremcntsn it is designed to withstand the

loads of a Seismic Category I structure. Seismic Category I structures at DBNPS are designed

fior seismic loads due ro the site SSE characterized by a 0.15g PGA and considering applicable

load combinations. The loads are compared to the strengths determined in accordance with

American Concrete lnstitute (ACI) 3l 8.

The failure modes of the structure are evaluated consideringthe mats, floor slabs, roof slabs,

shear walls, and foundation systems. With the exception of foundation systems, the

aforementioned failure modes were evaluated under the RLE to develop a Ctero capacity in

accordance with Section H.5 of Reference t. The roof system represents the governing failure

mode of the EFWF with a calculakd Crory,capacity well in excess ofthe RLE PCA. This

result is consistent with the Refergnse I Section H.4.4 guidance for sufficiently rugged

structurcs. Liquefaction and hearing capacity failures of the soil under the EFWF are not

required to b€ considered since the structure is founded on rock, directly or via piers, as

previously descrihd. Therefore it is concluded that the DBNPS EFWF has adequate seismic

capacity to withstand the RLE and meets the requirements to satisff Reference l, Appendix H.

Auxiliary Building

The AUX Buildings are Seismic Category I structures which house equipment serving

safety-related functions and have also been purposed for FLEX equipment storage. The AUX

is an L-shaped structure that partially surrounds the CTMT. The AUX is divided in three

separate areas which are isolated from each other and supported on independent foundation

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systems' The Seismic Category I AUX buildings are designed for loads due to the DBNPSsite SSE characterized by a 0.159 pCA.

AUX6, the northeast pottion of the AUX, is 150 ftx 85 ft in plan. It is a four-story reinforcedconcrete structure. Slabs are located at ELs 585 ft, 603 ft, 623 ft, and 643 ft. The lateralresistance of the building sffucture is derived primarily by the shear walls. The walls transfervertical and shear forces as well as bending momsnts to the reinforced concrete foundationmat, which largely bears on rock. AUX6 is isolated from the adjacent CTMT, TurbineBuilding (TURB), and AUX7, through expansion joints that allow them to behave asindependent structures under gravity and seismic loads. The huilding is supported on drilledpiers embedded into compacted structural backfill. The total height of the building, includingpiers, is approximately 85 ft- The foundation piers extend through the structural fill to thebedrock, and are sscketed into rock, at EL 558 ft. The length of these piers is about 27 ft.

AUX?, the southeast pottion of the AUX, is 130 ft x 140 ft in plan. trt is a five-storyreinforced concrete structure with two levels below grade, for a total of seven floor levels.Floors are located at ELs 545 & 565 ft, 585 ft, 603 ft, 623 ft,643 ft, and 654/660 ft. It isobservsd that the lateral resistance of the building structure is derived primarily by the shearresistance of the walls. The walls transfer vertical and shear forces, as well as bendingmoments, to the reinforced concrete foundation mat construction, largely supported on anindependent mat foundation bearing on rock. AUXT is isolated from the adjacent CTMT,TURB, AUX6, and AUX8, through expansion joints that allow them to behave as independentstructures under gravity and seismic loads. Most of the AUXT is founded on rock atEL 542 ft, approximately 40 ft below grade. A small portion at the north of AUXT is foundedon drilled piers embedded into compacted backfill and socketed into rock at EL jS8 ft. Thelength of these pters is about 25 ft. The total heightof the building is approximately lA0 ft.

AUX8, the southwest portion of the AUX, is 140 ft x 140 ft in plan. lt is a five-storyreinforced concrete structure with two levels below grade, for a totfll of seven floor levels.Floors are located at ELs 545 fr 565 ft, 585 ft, 603 ft, 623 ft, 643 ft, and 654/660 ft. Thelateral resistance of the building structure is derived primarily from the shear resistance of thewalls. The walls transfer vertical and shear forces as well as hending moments to thereinforced conmete foundation mat, which largely bears on rock. AUXB is isolated from theadjacent CTMT, TURB, and AUX7, through expansion joints that allow them to behave as

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independent structures under gravity and seismic loads. Most of this building is founded on

rock at approximately EL 560 ft.

Based on the structural systems comprising the Seismic Category I AUX buildings, the

guidance sf Reference I Section H.4.4 indicates the buildings have sufficient seismic capacity

to withstand the RLE based on the EPRI NP-6041 screening uiteria and do not require

additional evaluations to demonstrate rohustness. Liquefaction and bearing capacity failures

of the soil under the AUX are not required to be considered since the structures are founded on

rock, directly or via piers, as previously described. Therefore it is concluded that the DBNPS

AUX has adequate seismic capacity to withstand the RLE and rneets the requirements to

satisfy Reference l, Appendix H.

Non-Lelsmic Cateeory I ,Structure$

Two non-Seismic Category I structures, the TURts and Service Building 7 (SB7), were

identified to serve functions related to the DBNPS FLEX strategies. The following provides

descriptions of the structures' constructionn design criteris, and FLEX funetions sered.

Turbiue Building

Several nornral operator travel paths to perform FLEX Suppon Guideline (FSG) actions are

through the non-Seismic Category I TURB per Reference t9. The TURB consists of a

concrete shear wsll structure and steel superstructurc. The concrete structure is from

EL 565 ft to EL 623 ft and the steel stnrcture is from EL 623 ft to EL 692 ft.

Perthe DBNPS Updated Safety Analysis Report (USAR) (Reference 2l)this building was

designed to the requirements of Unifornr Building Code (UBC) Code Zone l. While this

building was designed for seismic loading, the wind loading typically govems the design ofsteel frames when compared with a Zone I seismic coefficient.

The conmete shear walls and diaphragms of the TURB are sufliciently rugged per Reference I

Section H.4.4 guidance. For the steel frame superstructure, considering the scvere wind

loading and the fact that steel frame buildings exhibit large inelastic absorption capacity, it is

expected thatthe Cl0%seismic capacity is in exccss of the RLE PGA. Therefore it is

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reasonnblc to conclude that, under the RLGM, the TURB may sustain limited inelasticdisplacements to allow a safe pathway.

ln the event the normal operator travel paths through the TURB are not available after theRLE, multiple backup travel paths are available through ths Seismic Category I AUX. Thus,the integrity of the TURB and its operator pathways is not essential to implementing theFLEX strategies. Further discussion of operator pathways is provided in Section 2.i,2.

Service Building 7

In accordance with the FLEX diversity requirements, the FLEX Storage Building SB? housesthe *'N+1" FLEX portahle equipment such as a turbine generator, transcube fuet tank, debrisremoval truck, and Godwin purnps Brflong other portable items. During the walkdowns it wasnoted that none of the portable equipment was securely tied to the floor.

Per the DBNPS Final Integrated Plan (FlP) (Reference l4), SB? is a non-seismic Category I

commercial grade building that was used prior to and during I ERFO to store the newOnce-Tfuough Steam Cenerators (OTSGs). The structure, previously designated as the NewSteam Generator Storage Facility (NSCSF), is designed in accordance with the 201I OhioBuilding Code (OBC). The 201I OBC uses American Society of CivilEngineers (ASCE) 7-05 Es the basis for design loads- The superstructune is constructed ofpremanufrctured frames with roof and wall purlins to support the metfll siding and roofing.The substructure consists of a slab-on-grade, a perimeter grade wall with strip footingextending below the frost line and spread footings at the building frames. The finish floorelevation of SB7 is 584 ft-7 l/4 inches. Ths lateral resistance for SB? is provided by steelmoment frames in the transverse direction and steel tension rods in the longitudinal direction.The SB7 is separated in distance from the EFIVF.

Per Referencs l, Section H.4, equipment required to support an alternative means toaccomplish a function is not required to be included in the MSA and therefore no furtherreview is required for the SB7 and the FLEX equipment stored within it.

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2.4.2 OperatorPathways

DBNPS has reviewed the operator pathways and verified that the operator pathways are not

impacted by the MSSHI. Considerations for this review included:

r Multiple available pathways or multiple FLEX components

. Pathway includes only Seismic Category I structures with previous reviewsfor seismic ruggedness - an exception is the TURB which is a non-SeismicCategory I building with available travel paths which is discussed below

r Debris removal capabilities for moderate to smaller seismic interac,tions

I Available time for operator actions

r Operator pathways were reviewed during a walkdown to asscss seismicinteractions associated with a GMRS level seismic event

A review of the operator pathways to perfornr the FSGs' actions (Reference l9) indicates normal

travel paths often are through the TURB which is non-Seismic Category I structure. However,

multiple backup travel paths are available through the Seismic Category I AUX to the locations

of the FSG actions. In the eventthe normal travel paths through the TURB are unavailable, the

paths through the AUX result in changes in response times mnging from potential time savings

to an addition of approximately three minutes (Reference I9).

Operator pathways from the Control Room to the EF\UF and equipment haul paths related to

FLEX implementation were walked down. Many of the preferred operator pathways at DBNPS

transit through the TURB or through areas of the AUX Building where housekeeping is a

potential concern, such as Radiation Protection (RP) storage areas with unrestrained file cabinets

and storage lockers. Nevertheless, the walkdown team identified a pathway located entirely

within Category I structures and free of potential seismic interactions. The operator can exit the

back door of the Control Room, walk west through Room 500 and down the stairs to EL 585 to

the roll-up door in the Fuel Handling Area and finally be outside next to the EFIUF.

Potential impairments to required access are: ( I ) doors and gates, and (2) site debris blocking

personnel or equipment access. The coping strategy to rnaintain site accessibility through doors

and gates is applicable to all phases of the FLEX coping strategies, but is immediately required

as part of the immediate activities required during Phase I.

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Doors and gates serve a variety of barrier functions on the site, One primary function is securityand is discussed below. However, other barrier functions include fire, flood, radiation, prsssureboundary, tornado, and high Energy line break (HELB). As barriers, these doors and gates arprypically administratively controlled to maintain their function as barriers during normaloperations. Following a Beyond-Design-Basis Extemal Event (BDBEE) and subsequentExtended Loss of AC Power (ELAP) event, FLEX coping strategies require the routing of hosesand cables to be run through various barriers in order to connect beyond-design-basis (BDB)equipment to station fluid and electric systems. For this reason, certain barriers (gates and doors)will be opened in response to the evcnts and remain open. This violation of normaladministrative controls is acknowledged and is acceptable during the implementarion of FLEXcoping strategies.

The ability to open doors for ingress and egress, ventilation, or temporary cable#hoses routing isnecessary to implement the FLEX coping strategics. Operators responsible for implementingFLEX strategies have keys in their possession that provide access to all rcquired areas. Keyswill be tumed over between individuals as part of the Shift Relief and Turnover Process.

Access into the PA through the normal entrance (PA sally port) is protected by a security barrier.This barrier can be manually op€rated during a loss of all AC power. The ability to open thebanier during a loss of AC power event is achieved through Security Shift Supervisor trainingand the requirement of maintaining a minimum number of individuals qualified as Security ShiftSupervisors.

Two Heavy Duty Pickup Trucks will be used as debris removal and towing vehicles- They areequipped with snow plows to remove snow from travel paths as necessflry" One truck is stored inSB7 and the second is parked inside the PA on the north side of the plant such thar prevailingtornado path and width should not impact both debris removal trucks (diverse locations). Thetruck parked in the PA is not located near any structures which could fall on it and render itunavailable" Ice augers and chain saws are stnged in the trucks to create openings in the ice toacsess water during cold weather events if necessary.

Given the number and variety of potential paths, verification that multiple backup paths are inSeismic Category I structures, debris removal capability, available time for operator actions, and

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walkdown observations, it is prohable operators will be able to gain access to the locations of the

FSC actions after the RLE.

2.4.3 Tie-Down of FLEX Portable Equipment

All portable equipment staged for use in the FLEX strategy is stored in either EFWF or AUX.

The trruo structures are described in.fectlon 2.4.1 The following portable equipment arE staged

in one of the two structures and are included in the FLEX strategy:

r FLEX ALT LP EFW 'N' Pump

r FLEX Replenishment'No Pump

r FLEX Spray *N' Pump

r FLEX -N' 480 Volt Turbine Generator

Descriptions forwhere each of thesE fits into the FLEX strategy can be found in the FIP

(Reference l4).

In addition, several other minor items are stored in these buildings. These items include:

. Ice Auger

I Fans

. Portable Generators (120 volt AC)

. Portable Generator Fuel Caddies

l Lighting

t Hand tools (saws, screwdrivsrs, wrenches, etc.)

Stored equipment were evaluated (for stability and restraint as required/necsssary) and protected

from seismic interactions to the SSE level as part of the FLEX design process to ensure that

unsecured and/or non-seismic components do not damage the FLEX equipment. ln addition,

large FLEX equipmsnt such as pumps and power supplies weFB secured as nesessary to protect

them during a SSE seismic event.

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For the purposes of satisffing this MSA, all essential equipment is reevaluated to the RLE inaccordance with Section H.5 of Reference l. The 4160 breakerconnection cafts are light weightand restrained to straps and consequently are judged to have Cruuo capacities well in excess of theRLE PGA. The Trailer Caddy (not specifically FLEX equipment but used to supportmaintenance and stored in the EF\ryF) has a low weight and a low center of gravity and also has

a Ctoor" capacity in excess of the RLE PGA, Forthe rest of the essential portable equipment, it isconservatively assumed in the evaluation that no tie downs are installed and that all equipmentrelies solely on self-resistance. The evaluation demonstrates that, even with the veryconsetryative assumption, all essential portable equipment staged in the EFWF and AUXstructures has a Crtrro capacity greater than the RLE.

DBNPS has reviewed the stcrags requirements (including any tie-doffi or restraint devices) ineffect for FLEX portable cquiprnent and verified that the equipment has no adverse interactionsor significant damage that could irnpair the ability sf the equipment to perform its mitigatingstrategy function during or following the RLE using the methods described in Section H.5 ofReference l.

Having satisfied all requirements, there are no plans to modiff any tie downs or plant proceduresregarding the staging of the portable equipment in the EF1VF and AUX structures.

2.4.4 Additionnl Seismic Interactions

Seismic interactions that could potcntially affect the FLEX strategies and were not previouslyreviewed as part of the ESEP program (e.g., flooding from non-seismically robust tanks,interactions to distributed systems associated with the ESEP equipment list, etc.) were reviewedfor DBNPS.

A detailed walkdown was performed for this MSA to identift any potential interactions that wetre

not previously captured by the ESEP program. This walkdown included the EFWF structure, allnew equipment staged/installed within the EFWF stnrcture, AUX and Yard, and operator andhaul pathways. A sampling walkdown of FLEX piping connections and isolation valvessupporting the FLEX strategy was considered adequate due to the rugged nature and absence ofpotential interactions of the sample of connections walked down. Potential interactions foundduring the walkdown are discussed in detail below.

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EL 586 ft in the EFWF is mostly used as storage for FLEX 'N' turbine generator, Godwin

pumps, panel enclosures, piping connections, and miscellaneous items such as hoses, carts, and

ladders. Larger items such as the turbine generator and Godwin pump$ are tied down with

ratchet straps csnnected to concrete expansion anchors. On the other hand, miscellaneous items

are unrestrained and there is no plan for the plant to restrain them, These unrestrained items are

at least I ft from the nearest trailer-mounted FLEX equipment. lt is judged that any potential

interaction would not impact the operability of the equipment. A CartCaddy and a portable fan

were observed to be in close proximity and it is judged that the interaction, if probable, would be

non-damaging.

EL 603 ft of the EFWF housesuitical electrical FLEX equipment such as MCCs, transformers,

panels, switchgears, and battery racks. This level also houses an exhaust fan and fuel oil storage

rank. During the walkdowns, it was observed that the grating at EL 603 ft is not restrained with

clips. This grating could potentially uplift and fall onto the FLEX pumps below. This concern

was communicated to plant personnel during the walkdowns and it was resommended to add

grating clips as identified on dcsign drawings. In response, DBNPS has generated an Order to

install rcstraints for the grating (CR 2016-14033).

Also on the EL 603 ft level of thc EFWF, #long ladder is loosely tied offto the handrail, but the

otherend of the ladder is frce to move and can potentially impactanearby MCC- Although

DBNPS housekeeping requirements only require the ladder to be tied offat one point, the

walkdown team recommended to tie it at several points to avoid rattling md contact behueen

MCC and ladder. Upon fumher review, the potenlial interaction between the ladder and IvICC is

indeed judged to be credible but noJ significant. The intenaction is not significant on the bases

that (l) the ladder lies on its side and a potential interaction would be with the sheet metal rear ofMCC which would not be damaging and (2) there are no chatter sensitive devices of concern

within MCC. In general, FLEX items at this level possess good anchorage design and are free ofseismic vulnerabi lities.

DBNPS has reviewed the additional seismic interactions and verified that the mitigation strategy

is not adversely impacted by the RLE.

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2.4.5 Haul Path

DBNPS FLEX storage is designed to minimize the deployment routes to the operations areas(designed areas where FLEX equipment is operated). In additionn the DBNPS FLEX strategiesare intended to minimize the impact of debris by installing equipment in robust locations such asinside the AUX or the EFWF that minimize the number of activities the operators must performoutside.

Pre-determined, preferred haul paths have been identified and documented in theFSGs DB-OP-02705,lnitial Assessment, and FLEX Equipment Staging (Reference 20). Thepreferred haul path uses the normal vehicle entrance into the PA located adacent to thePersonnel Access Facility (PAF) at the southwcst comer of the PA. An altemate haul path intothe PA uses "Gate 10" which is the former main entry point in the Protected Area located at thenortheast comer of the PA. The current configuration of Gate l0 includes security features andbarriers that can be manually opened. The size of the pathway through each barrier is adequatefor the FLEX equipment deployment. Removal of the sccurity features and barrier would beperformed with security notification and is within the capability of debris removal equipment.

Once in the PA, the preferred haul path to FLEX staging Arca I and Area 2 tums north-northeastand continues along the PA west boundary. FLEX staging Area I is located adjacent the EFWF.From there, the haul path continues to the north to FLEX staging Area 2 located near the stationtransformers" From the PA Primary Access, the preferred haul path to FLEX staglng Area 3 andArea 4 continues to the east. FLEX staging Area 3 is outside the CAF. Frorn there, the haul pathcontinues east and then to the noftheast and eventually terminating at FLEX staging Area 4 nearthe Intake Suucture.

Additionally, the preferred haul paths attempt to avoid areas with tr€es, power lines, narrowpassages, etc. when practical- If debris interferes with planncd haul paths, two Heavy DutyPickup Trucks will be used as debris removal vehicles. One truck is stored on the north side ofthe plant inside the PA and the other in SB7 where prevailing tornado path and width should notimpact both debris removal trucks.

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By procedure, all haul paths are kept clear during all operation modes. That is, no laydown areas

for refueling outages are permitted in areas that would impede implementation of the FLEX

strategy.

Haul paths were walked down for the RLE. Equipment haul paths are gsnerally within the PA,

and are free of potential seismic vulnerabilities. Two of the alternate haul paths cross small

bridges over the cooling tower basin discharge channel. One of the bridges is located just north

of the TURB and carries heavy industrial traffic, as a tankertruck was obserued driving over it

during the walkdown. These bridges are judged to be sufficiently rugged and do no-t present a

seismic concern. It is judged that the bridges will remain functional after an earthquake.

As described in the FIP (Reference I4), it is concluded that the subsurface soils and man-made

fill deposits encountered below the anticipated haul paths aro not considered to be susceptible to

liquefaction during seismic events.

DBHPS has reviewed the haul parhs and verified that the haul paths are not adversely impacted

by thc MSSHI.

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3.0 SPENT FUEL POOL COOLING REVIEW

3.I SreNr Funl Poot Coot trrrc EvALUATtoN

The evaluation of spent fuel pool (SFP) cooling for DBNPS was perfonrred based on the initialconditions established in HEI l2-06 (Reference I ) for spent fuel cooling coping in the event ofan ELAP / Loss of normal access to the Ultimate Heat Sink (LUHS)" The evaluation also usedthc results of pool heat-up analyses from the ELAP evaluation as input.

The FLEX strategy for SFP cooling utilizes $FP level monitoring and make-up capability asdescribed in the DBNPS FIP(Reference l4). SFP make-upcapability is provided usingtheDiesel-Driven Emergency Feedwater Pump (EFWP) taking suction though a portable flexiblehose. The hose csnnection for the permanent, seismically designed primary cmcrgency SFPmake-up connection is located on an inside wall of the Fuel Handling Area. This new make-upheader for the FLEX SFP Cooling allows for connection of flexible hoses from the EFW systemto the new SFP make*up piping installed in the SFP area and finally to rhe SFP. This isaccomplished by routing hoses from FLEX connection EF48, EFW TO SFP Make-Up ThrottleValve (located in Mechanical Penetration Room 3), to Primary SFP Make*up Header (SFP TrainBay southeast comer 585 ft level)" Once connected, throttle valve EF48 is opened, as nscessflryto maintain SFP level. The source of make-upwatsr forthe EFW system isthe EFWST.

The permanently installed plant equipment relied on for the implementation of the SFP CoolingFLEX strategy has been designed and installed, or evaluated to remain functional, in accordancewith the pl*nt design basis to the SSE loading conditions. The SFP integrity evaluationsdemonstrated inherent margins of the SFP structure and interfacings plant equipment above theSSE to a peak spectral accelerfltion of 0.Bg (Refercnce l6),

If needed, the Alternate Low Pressure Emergency Feedwatcr *N' Pump, the EFWSTReplenishment 'N' PumP, or the Spent Fuel Spray 'N' Pump, all located in the EFWF, may beused as alternate SFP make sourcss. The portable FLEX equipment availability, including itsstorage and deployment pathways, and the permanently installed plant equiprnent needed toaccomplish SFP cooling have subsequently been evaluated under the RLE.

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4.0 HIGH-FREQUENCY REVIEW

A HF revisw consistent with Reference l, Sections H.4.2 and H.4.4, was performed. The scope

of the HF review consists of devices with the potential to affect the following functions: Reactor

Trip / SCRAM, RCS Inventory, RCS Pressurrn Phase I FLEX, and Phase 2 FLEX.

Reactor Trip / SCRAM, RCS Pressure, nrd RCS inventory are overlapping $cope items between

the NTTF 2.1 HF confirmation performed in accordance with EPRI 3002004396 (Reference 7)

and the NEI l2-06 (Reference l) Appendix H MSA Path 4 HF evaluation; however, rcview is

not necessary for the former two system functions. HF sensitive devices with the potential to

affect RCS inventory have already heen evaluated as part of the NTTF 2.1 HF confirmations and

these evaluations can serve as the capacity bases f-or these deviees for MSA Path 4 HF revisw.

HF sensitive devices supporting Phase I FLEX and Phase 2 FLEX are scope items unique to the

MSA. A review ofthe equipment which cnsompa$ses the FLEX Phase I strategy indisates the

NTTF 2.1 HF confirmation has evaluated all potentially high-frequency sensitive devices ofconcern. FLEX Phase 2 equipment is installed such that they will nst automatically start and

connect to the plant and consequently there are no potentially HF sensitive devices of concern.

The DBNPS NTTF 2.1 HF confirmation (Reference 5) results show that the Croea capacities ofall devices evaluated exceed the CMRS PGA of 0.209. The HF review concludes that

potentially HF sensitive devices will not adversely impact the success of the FLEX strategy via

relay chatter for the RLE.

See Eaclosurc I for details of the High-Fnequency Review.

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5.0 CONCLUSION

The FLEX strategies for DBNPS as described in the FIP (Reference I4) ane acceptable as

specified with the grating clips to bt installed per CR 2016-14033 as discussed above.

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2.

3

6.0 REFERENCES

NEI 12-06, Revision 2, Diverse and Flexible Coping Strategies (FLEX) lmplementation

Guide, December 2015, ADAMS Accession Number ML160054625.

JLD-ISG-20| 2-01 , Revision I , Compliance with Order EA-l 2-049, Order Modifying

Licenses with Regard to Requirernents for Mitigation Strategies for

Beyond-Design-Basis External Events, ADAMS Accession Number ML I 53 57A I 63,

FirstEnergy Nuclear Operating Company (FENOC) Seismic Hazard and Screening

Report (CEUS Sites), Response to NRC request for Information Pursuant to

l0 CFR 50.54(0 Regarding Recommendation 2.1 of the Near-Term Task Force (NTTF)

Review of Insights from the Fukushima Dai-ichi Accident, dated March 31, 20t4,

ADAMS Accession Number ML I 40924203.

NRC Letter, Davis*Besse Nuclear Power Station, Unit I - StaffAssessment ofInformation provided Pursuant to Title l0 of the Code of Federal Regulations Part 50,

Section 50"54(f), Seismic Hazard Reevaluations for Recommendation 2.1 of the

Near-Term Task ForEe Review of lnsights from the Fukushima Dai-ichi Accident, dated

August 25,2015, ADAMS Accession Number MLI5230A289.

Davis-Besse Nuclear Power Station High Frequency Supplement to Seismic Hazard

Screening Repon, Response to NRC Request for Information Pursuant to

l0 CFR 50.54(0 Regarding Recommendation 2.1 of the Near-Term Task Force Review

of Insights from the Fukushima Dai-ichi Accident.

6. Not used.

EPRI 3002004396, Flnal Report, July 2015, High Frequency Program Application

Cuidance for Functional Conflrmation and Fragility Evaluation, ADAMS Accession

Number ML 152234102.

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4

tl

7

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8. NRC Letter, Endorsement of Electric Power Research Institute Final DraftReport 3002004396, "High Frequency Program: Application Guidance for FunctionalConfirmation and Fragility", dated September 17,201S, ADAMS AccessionNumber MLl52l84569.

EPRI, "Seismic Evaluation Guidance: Augmented Approach for the Resolution ofFukushima Near-Term Task Force Recommendation Z.l: Seismic", ReportNumber 3002000704, Palo Alto, CA, April, 2013,

FirstEnergy Nuclear Operating Company (FENOC) Expedited Seismic EvaluationProcess (ESEP) Reports, Response to NRC Request for Information Pursuant tol0 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force NTTF)Review of lnsights from the Fukushima Dai-ichi Accident: Enclosure C-ExpeditedSeismic Evaluation Process (ESEP) Report for Davis-Besse Nuclear Power Station datedDecember I 9, 2014, ADAMS Accession Number ML 143i3A059.

EPRI, "Seismic Evaluation Guidance: Scrcening, Prioritization and ImplementationDetails (SPID) for the Resolution of Fukushima Near-Term Task ForceRecommendation 2.1: Seismic", ReportNumber 102528?, Palo Alto, CA,November 201?.

EPRI, *EPRI NP-6041-SL Revision l: A Methodology for Assessment of Nuclear PlantSeismic Margin, Revision I", Palo Alto, CA, August, lggl.

NRC Lettern Davis-Besse Huclear Power Station, Unit I - StEff Review of InterimEvaluation Associated with Reevaluated Seismic Hazard Implementing Near-Term TaskForce Recommendation 2.1, dated october lg,20ls, ADAMS AccessionNumber MLI 5273A237.

Davis-Besse Nuclear Power Station, "Davis-Besse FLEX Final tntegrated Plan,"NORM-LP-7203, Revision 0, I 0/l 0/l 6.

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I

10.

il.

12.

t3.

14.

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t5.

r6.

17.

r8.

t9.

2t.

20

Davis-Besse Nuclear Power Station, Unit I - Safety Evaluation Regarding

Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation

Related to Orders EA- l 2-051 and EA- l 2-049 (CAC Nos. MF0960 and MF096l ),

January 31, 2017, ADAMS Accession Number MLl70l7A340

FirstEnergy Nuclear Operating Company Spent Fuel Pool Evaluation Supplenrental

Report, Response to NRC Request for Information Pursuant to I0 CFR 50.54(l)

Regarding Recommendation 2.1 of the Near-Term Task Force Review of lnsights from

the Fukushima Dai-ichi Accident, Davis-Besse Nuclear Power Station, dated

December 9, 2016, ADAMS Accession Nurnber MLl6344A0l0.

$tokoe, K. H., W. K. Choi, and F-Y Menq,2003, "Summary Report: Dynamic

Laboratory Tests: Unweathered and lUeathered Shale Proposed Site of Building 9720-82

Y-12 National Security Complex, Oak Ridge, Tennessec", Depaftment of CivilEngineering, The University of Texas at Austin, Austin, Texas, 2003.

Davis-Besse Nuclear Power Station, "Davis-Besse FLEX Strategy Design & Eauipment

Bases Detail,'n NORM-LP-7204, Revision 0, 8/5/16.

Davis-Besse Nuclear Power Station, "Davi$-Besse FLEX Validation Process Repofln"

NORM-LP-7201, Revision 0, 7/7/16.

Davis-Besse Nuclear Power Station, "FLEX Support Guideline, Initial Assessment and

FLEX Equipment Staging," DB-OP-02705, Revision 0, 7 17 116.

Davis-Besse Nuclear Power Station Updated Safety Analysis Report (USAR),

Revision 30.

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ENCLOSURE 1

NEI I.2-06 APPENDIX H PATH 2 HF REVIEW

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ENCLOSURE I - NEI 12-06 APPENDIX H PATH 2 HF REVIEW

I.O INTROI}UCTION

A high-frequency (HF) review consistent with Reference I Sections H.4.2 and H.4.4 was

performed. Nuclear Energy Institute (NEI) l2-06 {Reference I ), Appendix H Section H.4.2

refers to Electric Power Research Institute (EPRI) 3002004396 (Refenence 7) for the

high-frequency contact device analysis approach" Reference 7 is used for the Davis-Besse

Nuclear Power Station (DBNPS) engineering evaluations described in this report. Acceptance

criteria for the evaluatlons are found in Reference I, Appendix H, Section H.5. Note that a

previous High-Freqilency Confirmation, based on EPRI 3002004396, was suhmitted to the

Nuclear Regulatory Commission (NRC) (Reference 9). This Enclosure referc back to thal

suhmittal where possible.

T.ll SELECTION OF COMPONENTS

The fundamental objective of the MSA evaluation is to determine whether the FLEX strategies

developed, implemented and maintained in accordallce with NRC Order EA-|2-049

{Referenm 8) can be implemented considering the impacts of the reevaluated seismic hazard.

Within the applicable functions identified in Section H.4.2 (Path 2) (Refenence I ), the

components that woutrd need a high-frequency evaluation arc contact control devices subject to

intermittent states in seal-in or lock-out (SILO) circuits. Plants in Psth 2 are required to evaluate

SILO devices in the control systems of four specific categories: (l) Reactor Trip/Scram,

(2) Reactor Vessel Coolant Inventory leakage pathways, (3) FLEX Phase I Components, and

(4) Automatically Operated FLEX Phase 2 Components to ensure those functions perform as

nesessary in the FLEX slrategies. The equipment selection process for each of those categories

is described beXow. Note that categories (l) and (2) were addressed in the high-frequcncy

evaluation (Reference 9). Additionally, category (3) components were addressed in the

high-frequency evaluation, although not explicitly identified as FLEX Phase I components in

that submittal.

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2.1 Relcron TnlpISCRAM

Section H.4.2 ofNEl l2-06 Appendix H (Reference l) identifies the reactortrip/SCRAMfunction as a function to be considered in the high-frequency evaluation, and was included inReference 9. The EPRI guidance for High-Frequency Confirmation (Reference ?) notes that *.the

design requirements preclude the applisation of seal-in or lock-out circuits that prevent reactortrip/SCRAM firnctions" and that no high-frequency review of the renctor trip/$CRAM systems isnectrssary. Therefore, no additional evaluations are nccessary for the reactor trip/SCRAMfunction.

2.2 RelcroR vnssul, fi{vnr{roRy ANI} pnBssunE coNTBoL

The equipment in the Reactor Vessel Inventory Control funetion are ths same equipmentevaluated in the DBNPS NTTF 2.1 High-Frequency Confirmation, and was included inReference 9. The primary concem fsrboth theNTTF 2.1 and MSA programs is theactuation ofvalves that have the potential to cau$e a loss-of-coolant accident (LOCA). A LOCA following aseismic event could provide a challenge to the mitigation strategies and lead to cop damage. perReference 3, Reactor Coolant System (RCS) Pressure control is accomplished through the use ofthe pressurizer heaters to nraintain saturation temperature and pressure within the pressurizer andpressurB reduction can be accomplished through the use of the PowerOperated Relief Valve(PORV) in venting steam to the pressurizer quench tank. RCS Overpressure protection is alsoafforded by means of the prcssurizer code safety valves (PSVs) that vent to the Containmentatmosphere.

Control circuits for the PORV as welt as other RCS valves and pressurizer heater controls wgrranalyzed as partof the DBNPS submiual to addressNTTF 2.1 resommendations (Reference g).The cornponents covered in this category are the same as those covered in the Rcs/ReastorVessel Inventory Control category of EPRI 3002004396 DBNPS submittal (Reference g).

HF sensitive devices with the potential to affect RCS inventory have already been evaluated aspart of the NTTF 2'l HF confinnations and these evaluations can serye as the capacity bases forthese devices for MSA Fath 4 HF review. A number of relays were identified in the HF review,which are identified in Tshle A-L

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2.3 FLEX PHffie I

Section H.4.2 of NEI l2-06 Appendix H (Reference l) requires the analysis of relays and

contactors that may lead to circuit SILO that could impede the Phase I FLEX capabilities,

including vital buses fed by station batteries through inverters. Phase I of the FLEX Strategy is

defined in NEI l2-06 (Reference I ) as the initial respon$e period where a plant is relying solely

on installed plant equipment. During this phase, the plant has no AC power and is relying on

batteries, $team, and air accumulators to provide the motive force necessary to operate the

critical pumps, valves, instrumentation, and control circuits.

As stated in Reference 3, during Plant Modes l-4, Reactor Core Cooling and Heat Remsval is

maintained through natural circulation heat removal from the RCS via the Steam Generators

(SA). Natural circulation is maintained by ensuring adequate RCS inventory and preventing

voids at the top of the RCS hot legs. RCS inventory is maintained initially in Phase I by limitingleakage (isolating letdown and RCP Seal Return from the Control Room and crediting the actual

demonstrated RCP seal perforrnance during testing) to minimize RCS losses. Heat rejection

through the SGs is maintained by manually starting (from the Main Control Room) the

diesel-driven Emergency Feedwater Pump (EFWP) taking a suction on the Emergency

Feedwater Storage Tank (EFI[/ST) and providing inventory initially to SCI and later withoperator action to include SG2. Reactor Decay Heat (post trip) will be released via steam to the

atmosphere through the Main Steam Safbty Valvcs and later with manual operator action, via the

Atmospheric Vent Valves (AVVs) using the installed remote hand wheels.

DC bus load shedding will ensure 2P battery life is extended to I4.6 hours as described incalculation C-EE-002.01-016, Station Battery Discharge Analysis for Beyond-Design-Basis

Events. The FLEX 480V Generator will be used to repower installed station battery chargers

prior to bauery depletion. In addition, in the event the station DC or I20V AC Instrurment Bus

powcr distribution is damaged, FSC DB-OP-02707, Loss of DC Power, provides direction to use

portable meters to obtain key pararmeter information during a loss of all AC and DC power. RCS

makeup and boron addition from the Boratcd lUater Storage Tank (BVfST) or from the Clean

Waste Receiver Tank (CWRT) will be initiated within 4.5 hours to ensure natural circulation,

reactivity controi, and boron mixing is maintained.

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A HF review of the Steam Driven Feedwater System and the newly installed Diesel-DrivenFeedwater System were performed in the High-Frequency Confirmation (Reference g), as part ofthe Section 2.4 Core Cooling evaluation. Because the Steam and Feedwater Rupture ControlSystem (SFRCS) is de-energized to actuate, many of the valves in the Steam Driven Feedwaterline that had a potential to reposition due to relay chatter would be placed in the desired positiondue to successful SFRCS f,ctuation.

Instrumentation is dependent on the availability of Essential DC power. Disfibution to the DChuses was also included in the HF review performed in Reference 9, as part of the Section 2.5AC/DC Power Support Systems evaluation. Relays were identified that could prevent powerdistribution to the battery chargers frorn the 4160VAC Buses. Those relays are identified inTahle A-1. The FLEX strategy is to perform a load shed to keep cssential londs prior toinitializing the FLEX Phase 2 480V Generators. It should be noted that there were no devicessubject to chatter that would prevent power disribution below 480VAC and no devices suhjectto chatter that would prevent power distribution from the l25VDC.

Finally, a comparison betrueen the equipment identified in Reference 3 and Reference g wasperformed, to conftrm that the HF component selection appropriately covered all the FLEXPhase I equipment. No additional equipment was identified during the review.

2.4 FLEX PH*ss 2 AuromATtc OpgRArloN

The DBNPS Phase 2 sfiategy includes sontinuation of the Phase I srategy. lf the SGs areavailable then no Containment Cooling is needed and Containment Isolation is sonfirmed as

resources permit. If the SGs are not available, the RCS is vented to Containment andContainment is vented to the atmosphere through the Emergency Hatch. This will ensureContainment pressure and temperature remain acceptable with no further action.

NEI I2-06 Appcndix H (Refereilce l) requires the inelusion of SILO relays and contactors thatcould impede FLEX capabilities for mitigation of seismic events in permanently installedPhase 2 SSCs that have the capability to begin operation without operator manual actions.

Witlt the loss of AC power, Phase 2 SSCs to be evaluated are llmited to any permanentlyinstalled FLEX genenator and, if allowed to autornatically start, any electrical components

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powered by the FLEX generator and relied upon for Phase 2 of the FLEX Strategy. DBNPS

does not have any ptrrmanently installed Phase 2 equipment that would automatically stalt.

DBNPS credits a portable FLEX generator, FLEX RCS Charging Pumps, and other portable

pump$ as neccs$ary for Phase 2 response, and the operator actions necessary to install and

initiate the equipment. Since operator actions are necessary no devices subject to high frequency

were identified.

2.5 Surrrnnany oF SSLBCTSD CoMPoNENTS

A list of the contact devises requiring evaluation as pafi of the NTTF 2.1 High Frequency

Confirmation (Reference 9) is provided in Table A-1. The HF Relay Groups which also required

evaluation as part of the NEI l2-06Appendix H Path 2 High Frequency Confinnation are

identified in the table by a note. In total, two groups comprising six components were identified

for NEI 12-06 Appendix H Path 2 High Frequency Confirmation.

3.0 SEISMIC EVALUATION

The generation of the high-frequency seismic demand on the subject components is documented

in Sectisn 3 of the high-frequency evaluation (Refercnce 9).

4.0 CONTACT DEVICES EVALUATIONS

The perforrnnncs of the seismic evaluations is documented in Section 4 of the high-frequcncy

evaluation (Reference 9). No additional cornponcnts were identified in this asses$ment.

A summary of the high-frequency evaluation results is provided in Tahle A-1.

5,0 CONCLUSIONS

The high-frequency capacity of each device was evaluated in Reference L These components

and the results of the individual component evaluations are provided in Tshle A-1, below. A

total of six components are identified thatrequiredNEl l2-06 Appendix H Path 2

High-Frequency Confirmation evaluation. The six components are grouped into two main

groups based on device type and capacity and enclosure dynamic characteristics and location'

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The two HF Relay groups in the scope of the NEt l2-06 Appendix H Path 2 are identified by anote in Tahle A-1.

As shown in Tuhle A*I,l I components out of a total of 80 components requiring evaluation aspartof the NTTF 2-l High Frequency Confirmation have Capacity lessthan Demand whenevaluated in accordance with Reference g guidance. These components were then reevaluatedthrough mitigation strategies included in Appendix H of Referense I and shown to be adequate(i.e', HCLPFctop/oF PGAar'ans) and do not impactthe credited path formitigation strategies.

5.I GnnnmL CoNCLUsIoNs

DBNPS completed the evaluation of potentially sensitive contact devices in accordance withNEI 12-06 (Reference I ), Appendix H Section H.4.2 and EPRI 3002004396 (Reference 7). Theresults of the evaluation confirm that the FLEX strategies for DBNPS can be implemented asdesigned and no further seismic evaluations are necessary.

5.2 IpprurInCATToN oF FoLLow-UP AcTIoNs

For DBNPS, all the identified components have adequate seismic capacity and no follow-upactions were identified.

6.0 REFERENCES

NEI l2-06, Revision 2, Diverse and Flexible Coping Strategies (FLEX) Implementationcuide, December 2015, ADAMS Accession Number MLl600iA6z5.

JLD-ISG-2OI2-01 , Revision I , Compliance with Order EA- I 2-A49, Order hlodifyingLicenses with Regard to Requirements for Mitigation Srategies forBeyond-Design-Basis External Events, February 2016, ADAMS AccessionNumber MLl5357A 163.

Completion of Required Action by NRC Order EA- 12-049, Onder Modifoing Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External

fifiGuurdffngriRtzzo

2

3

2734296-R-017Rcuisr'or 0

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4

Events (TAC No. MF096l ), Septernber 23,2016, ADAMS Accession

Number MLI 6267 A471.

Davis-Besse Nuclear Power Station, Unit I - Safety Evaluation Regarding

lmplementation of Mitigating Strategies and Reliable $pent Fuel Pool lnstrumentation

Related to Orders EA- l 2-05 I and EA- l 2-049 (CAC Nos. MF0960 and MF096l ),

January 31, 2017, ADAMS Accessisn Number MLl70l7A340.

Davis-Besse Nuclear Power Station, Unit I - StaffAssessment of Information Provided

Pursuant to Title l0 of the Code of Federal Regulations Part 50, $ection 50.54(f), Seismic

Hazard Reevaluations fsr Recommendation 2.1 of the Near-Term Task Force Review ofInsights From the Fukushima Dai-ichi Accident (TAC NO. MF3728), dated August 25,

2015, ADAMS Accession Number MLl5230A289.

NRC (W. Dean) Letter to the Power Reactor Licensees on the Enclosed List, "Final

Determination of Licensee Seismic Probabilistie Risk Assessments Under ths Request for

Information Pursuant to Title l0 of the Code of Federal Regulations 50.5a(fl Regarding

Recommendation 2.1 "Seismic" of the Near-Term Task Force Review of Insights fium

the Fukushima Dai-ichi Accident." October ?'1,201 5.

EPRI 3002004396, "High Frequency Program: Application Cuidance for Functional

Confirmation and Fragility Evaluation." July 2015'

NRC (E. Leeds) Letter to All Power Reactor Licensees and Holders of Construction

Permits in Active or Deferred Status. EA-N2-049. "lssuance of Order to ModitrLicenses with Regard to Requirements for Mitigation Strategies for

Beyond-Design-Basis Extemal Events." March l?,2012

Davis-Besse Nuclear Power Station High Frequency Supplement to Seismic Hazard

Screening Report, Response to NRC Request fon Information Pursuant to

t0 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Terrn Task Force Review

of tnsights from the Fukushima Dai-ichi Accident.

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5

6

1

8.

I

2734296-R-$77Rrlrtision 0

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EPRI 3002002997. "High Frequency Program: High Frequemcy Testing Summary."September 2014.

I l. EPRI NP-?147-SL. "seismic Ruggedness of Relay$." August lggl.

12. EPRI NP-7147 SQUG Advisory 2004-02. "Relay GERS Corrections." September 10,2004.

r0.

r3.

14.

r5.

t6.

17.

FirstEnergy Nuclear Operating Company (FENOC) Expedited Seismic EvaluationProcess (ESEP) Reports, Response to NRC Request for Information Pursuant tol0 CFR 50.54(0 Regarding Recommendation 2.1 of the Near-Term Task Force (NTTF)Review of lnsights from the Fukushima Dai-ichi Accident: Enclosure C-ExpeditedSeismic Evaluation Process (ESEP) Report for Davis-Besse Nuclear Power Sution datedDecember 19, 2014, ADAMS Accession Number MLl43s3A0sg.

NRC Letter, Davis-Besse Nuclear Power Station, Unit I - Staff Review of lnterimEvaluation Associated With Reevaluated Seismic Hazard Implementing Near-Term TaskForce Recommendation 2.1 (Tac No. MF5238), October 19, 2015, AccessionNumber MLI 5273A237.

ABS Consulting and Paul C. Rizzo Associates, Ins., "Probabilistic Seismic HazardAnalysis and Ground Motion Response Spectra, Davis-Besse Nuclear Power Station,Seismic PRA Project'o 2734296-R-003 (RIZZO Report R3 124?3?l,Revision I,2014.

McGuire, R.K, Silv4 lil.J., and Costsntino, C.J.,200ln "Technical Basis forRevision ofRegulatory Guidanse on Design Ground Motions: Hazard- and Rlsk-Consistent GroundMotion Spectra Cuidelines," NUREG ICR-6?28, U.S. Nuclear Regularory Commission,October 2001.

ABS Consulting/Rizzo Associatesn "Building Seismic Analysis of Davis-Besse NuclearPower Station: Seismic PRA Projecg" Rev. I. ABS Report 2'134296-R-005 (RizzoReport R7- I 2-4737) 2014.

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21.

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EPRI NP-6041-SL, *'A Methodology for Assessment of Nuclear Power Plant Seismic

Margin," Rev. l, Electric Power Research lnstitute, June 1994.

Procedure for Evaluating Nuclear Power Plant Relay Seismic Functionality EPRI,'Palo

Alto, CA: 1990, NP-7148.

EPRI NP-6041-SL, "A Methodology for Assessment ofNuclear Power Plant Seismic

Margin,o' Rev. I , Electric Power Research lnstitute, June 1994.

EPRI, Seismic Evaluation Guidance: Augmented Approach for the Resolution ofFukushima Near-Term Task Force Recommendation 2.1 - Seismic, Palo Alto, CA:

May 2013, 3002000704.

DBNPS Overall Integrated Plan (OIP) in Responseto the March 12,2012, Commission

Order EA- 12-049, First Energy Corp., Letter No. L- l 4*257 ,"FirstEnergy Nuclear

Operating Company's Third Six-Month Status Report in Response to March 12,2012

Commission Order Modifying Licenses with Regard to Requirements for MitigationStrategies for Beyond-Design-Basi s Extemal Events (Order Number EA - I 2-049)(TAC Nos. MF084l, MF0842, MF096l, and MF0962)," dated August 28,2014.

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Table A-1, below, contains the results of the NTTF 2.1 High Frequency Confirmation fromReference 9. All components were identified and assessed in Reference g. No new componentswere identified from thisNEI l2-06 Appendix H MSA Path 2 High Frequency Confirmarion.The components which are in the scope of the MSA Path 2 High Frequency Confirmation rcvisware identified by a note in Tahle A-1. All of the components which are in the scope of the MSAPath 2 High Frequency Confirmation have a seismic capacity greater than the seismic demand.

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Abu Dhati, Unitod Arab En*ratesTdephonc 971.2S912000

Dubri, United lrrb EmiatesTelephona 9?14+306116

ABS GROUP OF COlr{PA1{lE$,lHC.tEE55 Horfifiase Drive

Houston. TX 77CI60

Td+lmne ?81.673-?S00Far lEt{I3.1801

EUROPE

Sofu, BulgariaTel€phone 359-2-9632049

Pirsfirs, GreeceTffione 30"210.{?94046

Genoa,ltdyTdephone 39{10.2512090

llatrturg, CrarmanyTslafiofle 194e300.92-2?-2I

Las Arenar, SpainTolephone 34-94"{64{444

Roflerdam. The HshsrlandsTelephone 31-10.106{778

Amaterdam, Iha HeBrerlandsTdephone 3t-205-?07-917

Got€borg, $wsdenTd+hone 40-?&283-0131

ffitn, NmrayTd€ptrdr€ {7-iS55- t 0-90

Osh,l-fonrayTdephone 1767-5?-27{0

Stavangcr, tfuiuayTehphone 47-E 1-93-92-20

Tmdhdm,l,luuayTdcplsle 17-7$900.500

ASIA+ACrFrC

Almsd$ad.lndiaTrhphone 07910009595

tlrri llumbri,lndiaTelsphone 91.2?-757+?80

Hes Di[ri, lndiaTsl€f,hone 91 -l l-{5631738

Yokoharu, JapanTolefiffio 81-{Sl$0-1e50

K'uala Lump*r, lrtdaysiaTCoptrcne 60I79E2?{55ttde Lflrpur, lldaytisTdtphme 60$?161-5755

B€if,rp, PR ChinrTo|#lrffio 86-til58l 1?92.|

Slffghfl- PRChinaTdephone 86-l I {0IFg?66Busr, KoresTdophone 8I-51{52-46S1

Seuil, l(seaTCopftone E2-2.552-|SG 1

Alerendn Point, fiingr+oreTeleptmne 654270{663lfuotrsiurrg, Tsiwan, RepuHb of ChinaTdrpfrono 6E6.7.27 1"3463

Bngk*, ThdtrrdTrloshoo€ 66?-399-2{?0

West Perh, WA6005Tolophon€ 01{-9186-9909

HTERilET

Addlimal office hftrmation can be furnd 0tr*u.absarorp.cul

$OUTH AI'EREA

?t00 Space Park Driw, Suite I00I'louston, TX 77058Tdephone 713-929{800

Enetgy Crmsing ll. E. Butding15011 Katy Fremay, Suite 100Houslm, TX 77091

1525 Wrlson Barhrard, Srile 625Aiirytoo, VA 22209Tdephone 703{82J373Far 703682-737a

10301 Tr$nologf DriyeKnoxvile, TH 3793?Tdeptmne 865-96S5232Fax 865-96G5287

1745 Shea Cefiler DriuE, Suite {S0Highland Randr, CO E0129Tdrohofl+ 303{7+29901390 Piccard Drirc, $uitr 350Rodryile,lrc 20850Tdephone 301-907-9100Far 301-990J1E5

3115 Emt Lion Lgte, &rile 160Salt L*s City, UT 81121Tdephone 801-33$7676Fax E0I-13L76?7

140 Hsirngr ffoad, $uite 3r0{lSrn tubnio. TX ?8232Tehphone 2f0.{95"5195Far ?10.195.5134

823 Corryras AvEtrlr/€, Suih 1510Auslin, TX 78701Telephone 512-732+??3Fex 512-?33-?210

55 llbs$trt Plaza. Suilr 700St Luris. l'l0 63116TCsphonr 311.819-1550Fax 314{t9-1551One Chebe S:FaetIthrr Lffidflr, CT 06320Telsphone 860-70I{60El00DatunyRosd, &fre 105Ridgefi€ld, CT 068nTol€phon€ 203-{31{28IFar 203-{31-3613

13'60 Truxtun Arffitre, Suitg 103ilorft Chrlestm. SC ?9105Tdafione E43"29?{690

152 Bhdss Lrne. SuiU HGhn Bumie. HD 21060Tdophone 110{1{{}450

TEXEO

liacaO, BrazilTelephone 55-22-2763"7018

Rio de.ianeiro, BrazilTtlephone 55-?1'3179.3182

$ao Paub, BrazilTelephone S5-1 1-3707-1055

Mils dd Mar, ChileTe$ophme 5F3t"2381780

Bogotr,ColombiaTel+hone 571-29S071t

Chuao, VenezudaTdephme 5E-ltA-959.7442

Lima, PsruT€lephorie 5 1 -1437.7430

I'Jauw, BrarilTd€ph€n€ 5ts92-3213-951 1

lfuntevftleo, UnrguayTdopftont 59E2-2-90I -8F33

ulrrTEtltff{GDou

EOE llouss, Tho B+rconsIt/aningtm EoadBirfiffiod, Wan*ngtonChtshire |YA3 6WJTCqhmc 11-192S287300

3 Pridc PlaoePride PorkDcrby DE24 80RTdephone {'[+ I 332-251{ 1 0

Unil 3b Drmsry Wod(sWoodfu.d, BcrldolGhumctmhke GL13 9JRTCsphono 14+115+269"100,dBS House1 Fryhg Psr f,lryLondm El IHRTdryhme 4+207-377442IAbsdaanABZS 1X0Tdephme 4{+122+392100London WtT {TQTCoptlffie 14{l-20}30r-5900

MDDLE EAST

Ciudad d6l Corrr€r', ilrlsricoTdefhone 5 2.938-3S2-1530

iferico City, lrrhximTdephoae 5?-55-551 1-1210

lvlonteney. $ierioTdephone 52{l{319{?90Reynosa, ilrrilFTdephone 52S99.920-?61?

Verasuz. t'te$mTd$rone 52-2eg-g80{1 33