Seismic Aug App - NRC comments April 2.

docx

Seismic Evaluation
Guidance
Augmented Approach for the Resolution of
Fukushima Near-Term Task Force
Recommendation 2.1: Seismic

This document does NOT meet the requirements of

10CFR50 Appendix B, 10CFR Part 21, ANSI N45.2-
1977 and/or the intent of ISO-9001 (1994).

EPRI Project Manager

J. Richards

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800.313.3774
650.855.2121
askepri@epri.com xxxxxxx
www.epri.com Draft Report, March 2013
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 Seismic Aug App - NRC comments April 2.docx

Acknowledgmen
The following organizations, under contract to the Electric
ts Power Research Institute, prepared this report:

Simpson Gumpertz & Heger Inc.

4000 MacArthur Blvd. Suite 710
Newport Beach, CA 92660

Principal Investigators
G. Hardy

ERIN Engineering & Research, Inc.

2001 N. Main Street, Suite 510
Walnut Creek, CA 94596

Principal Investigator
D. True

EPRI gratefully acknowledges the following individuals and

their companies for their support of this report.

Florin Arsene, Southern California Edison

Divakar Bhargava, Dominion Resources, Inc.
David Gambrell, Southern Nuclear Operating Company,
Inc.
Robert Kassawara, Electric Power Research Institute
Kimberly Keithline, Nuclear Energy Institute
Gregory Krueger, Exelon Corporation
Stuart Lewis, Electric Power Research Institute
Andrea Maioli, Westinghouse Electric Company
Caroline McAndrews, Southern California Edison
Donald Moore, Southern Nuclear Operating Company, Inc.
Robert Whorton, South Carolina Electric & Gas Company

 iii 
 Seismic Aug App - NRC comments April 2.docx

Product
Description Following the accident at the Fukushima Daiichi nuclear power
plant resulting from the March 11, 2011, Great Tohoku
Earthquake and subsequent tsunami, the Nuclear Regulatory
Commission (NRC) established a Near Term Task Force
(NTTF) to conduct a systematic review of NRC processes and
regulations. The NTTF was also tasked with determining if the
agency should make additional improvements to its regulatory
system.

Background
The NTTF developed a set of recommendations intended to
clarify and strengthen the regulatory framework for protection
against natural phenomena. Subsequently, the NRC issued a
50.54(f) letter that requested information to assure all U.S.
nuclear power plants address these recommendations.

EPRI 1025287 provides guidance for conducting seismic

evaluations as requested in Enclosure 1 of the 50.54(f) letter
[1], which requests that licensees and holders of construction
permits under 10 CFR Part 50 reevaluate the seismic hazards
at their sites against present-day NRC requirements and
guidance.

This report provides supplemental guidance for performing

near-term expedited seismic evaluations and applicable plant
modifications, along with a schedule for performing the
applicable risk evaluations described in EPRI 1025287.

Objectives
To provide guidance on the performance of expedited plant
seismic evaluations in support of the requirements of NTTF
Recommendation 2.1: Seismic.

Approach
The project team formulated guidance for the seismic
evaluations through a series of expert meetings, supplemented
by a number of utility trials of the proposed guidance. An
expedited seismic evaluation process is described along with
references to the screening process and complete risk
evaluation criteria from EPRI 1025287 as applicable. A
number of public meetings were also held with the NRC during
development of the guidance to discuss evaluation criteria and

 v 
to achieve acceptance of the Results and Findings
guidance and This report outlines a process and schedule for responding to
implementation schedules. the seismic evaluations requested in the NRC’s 50.54(f) letter Comment [NRC1]: Formatting issue.
[1] under Recommendation 2.1: Seismic. The process includes
a near-term expedited seismic evaluation process followed by
plant risk evaluations in accordance with EPRI 1025287. The
guidance includes a screening process for performing the near-
term evaluations, as well as equipment selection, seismic
evaluation, and modification criteria for performing the near-
term evaluations. The report also outlines how the near-term
expedited seismic evaluation process and the long-term plant
risk evaluations provide for a complete response to the NRC’s
50.54(f) letter [1] under Recommendation 2.1: Seismic.

Applications, Value, and Use

The guidance in this report is intended primarily for use by all
U.S. nuclear power plants to meet the requirements of NTTF
Recommendation 2.1: Seismic. The primary value in this
guidance is that it has been reviewed with the NRC and can be
applied by all plants to provide a uniform and acceptable
industry response to the NRC.

Keywords
Augmented Approach
ESEP
Earthquakes
Fukushima
Seismic hazard

 vi 
 List of
Acronyms
AC alternating current
ACI American Concrete Institute
ADV atmospheric dump valve
AFW auxiliary feedwater
AISC American Institute of Steel Construction
ANS American Nuclear Society
ASME American Society of Mechanical Engineers
BWR boiling water reactor
CDFM conservative deterministic failure margin
CEUS Central and Eastern United States
CST condensate storage tank
DC direct current
ECCS emergency core cooling system
EFW emergency feedwater
ESEL expedited seismic equipment list
ESEP expedited seismic evaluation process
GERS generic equipment ruggedness spectra
GMRS ground motion response spectrum
HCLPF high confidence of a low probability of failure
HPCI high pressure coolant injection
HVAC heating, ventilation, and air conditioning
IC
ISRS in-structure response spectra
MCC motor control center
NEI Nuclear Energy Institute
NPP nuclear power plant
NRC Nuclear Regulatory Commission
NSSS nuclear steam supply system
NTTF Near Term Task Force

 vii 
PGA peak ground acceleration
PORV power operated relief valve
PRA
PWR pressurized water reactor
RCIC reactor core isolation cooling
RCP reactor coolant pump
RCS reactor coolant system
RLGM review level ground motion
RPV reactor pressure vessel
SAMG
SBO
SFP spent fuel pool
SG steam generator
SMA seismic margin assessment
SPRA seismic probabilistic risk assessment
SRT seismic review team
SRV
SSC structures, systems, and component
SSE safe shutdown earthquake
SSI soil-structure interaction
TDAFW turbine driven auxiliary feedwater
TRS test response spectrum
UHRS uniform hazard response spectrum
WUS Western United States

 viii 
Table of
Contents
Section 1: Purpose and Approach ............ 1-1
1.1 Augmented Approach to Responding
to Information Request for NTTF
Recommendation 2.1 ........................ 1-1
1.2 Expedited Seismic Evaluation
Process (ESEP) ............................ 1-3

Section 2: Screening for the ESEP (SSE-

to-GMRS) ............................ 2-1
2.1 Background on Screening............. 2-1
2.2 SSE Screening Task (SSE-to-GMRS
Comparison) ............................... 2-1
2.2.1 Special Screening Considerations .. 2-1

Section 3: Equipment Selection ............. 3-1

3.1 Introduction and Background......... 3-1
3.2 Selection of Expedited Seismic
Equipment List (ESEL) ..................... 3-1
3.3 Format and Content of Expedited
Seismic Equipment List (ESEL) ............. 3-9

Section 4: Review Level Ground Motion

(RLGM) Spectrum Criteria............ 4-1

Section 5: SSC Capacity Criteria for the

ESEP................................ 5-1

Section 6: ESEL Modification Criteria ...... 6-1

Section 7: ESEP Report ..................... 7-1

Section 8: References ...................... 8-1

 ix 
List of
Figures
Figure 1-1 Recommended Augmented Approach
to Respond to Information Request 2.1 for
Seismic ................................... 1-3
Figure 1-2 Expedited Seismic Evaluation
Process for the Augmented Approach ........ 1-4
Figure 1-3 Detailed Flow Chart of the ESEP
for the Augmented Approach ................ 1-6
Figure 2-1 Comparison of GMRS to SSE (5%
Damping) for the ESEP ..................... 2-2
Figure 3-1 FLEX Enhances Defense in Depth
(Ref [3]) ................................. 3-1
Figure 4-1 RLGM Generated by Scaling Up SSE
Spectrum (Scenario 2 from Figure 1-3) ..... 4-2
Figure 4-2 RLGM Defined as Twice the SSE
(Scenario 3 from Figure 1-3) .............. 4-2

 xi 
List of
Tables
Table 1-1 Expedited Seismic Evaluation
Process Implementation Schedule ........... 1-5
Table 3-1 Summary of NEI 12-06 Performance
Attributes for BWR Core Cooling &
Containment Function ...................... 3-5
Table 3-2 Summary of NEI 12-06 Performance
Attributes for PWR Core Cooling &
Containment Function ...................... 3-7
Table 3-3 Representative BWR Equipment
within the Scope of ESEL .................. 3-9
Table 3-4 Representative PWR Equipment
within the Scope of ESEL .................. 3-9
Table 3-5 Example Format of ESEL Summary
Table .................................... 3-11
Table 5-1 Partial List of Fragility and
Margin References ......................... 5-1
Table 5-2 Summary of Conservative
Deterministic Failure Margin Approach for
Seismic Capacity (EPRI NP-6041-SL [9]) .... 5-2

 xiii 
Section 1: Purpose and
Approach
Following the accident at the Fukushima Daiichi nuclear power plant
resulting from the March 11, 2011 Great Tohoku Earthquake and
subsequent tsunami, the United States Nuclear Regulatory Commission
(NRC) established the Near Term Task Force (NTTF) in response to
Commission direction. The NTTF issued a report that made a series of
recommendations, some of which were to be acted upon “without
unnecessary delay.” Subsequently, the NRC issued a 50.54(f) letter that
requests information to ensure that these recommendations are
addressed by all U.S. nuclear power plants (NPPs). The principal purpose
of this report is to provide additional guidance to augment licensee
response to the request for information in the 50.54(f) Letter, Enclosure 1,
Recommendation 2.1: Seismic [1]. Specifically, this report addresses
interim evaluations of critical plant equipment to be implemented prior to
performing complete plant seismic risk evaluations.

Section 1 of this report provides a summary of the purpose and scope of

the Augmented Approach being recommended by the nuclear power
industry to fulfill Enclosure 1: Seismic of the 50.54(f) request for
information.

1.1 Augmented Approach to Responding to Information

Request for NTTF Recommendation 2.1

The approach described in this report has been developed by EPRI,

working with experts from within the nuclear industry, with the intent of
identifying reasonable measures that can be employed to accomplish an
effective seismic evaluation in an expedient manner. More specifically, the
approach was designed to constitute a specific path to focus the initial
industry efforts on short term evaluations that would lead to prompt
modifications to some of the most important components that could
improve plant seismic safety. This short term aspect of the Augmented
Approach is referred to as the Expedited Seismic Evaluation Process
(ESEP) and is described in the subsequent sections of this report. The
ESEP addresses the requested information part of the 50.54(f) Letter [1]
that requests “interim evaluations and actions taken or planned to
address the higher seismic hazard relative to the design basis, as
appropriate, prior to completion of the risk evaluation.” The seismic risk

 1-1 
evaluation portion of the Augmented Approach is documented in EPRI
Report 1025287 [2].

This approach reflects careful consideration of the NRC’s description of

an acceptable approach for the seismic elements of Recommendation 2.1
(documented in Attachment 1 to Seismic Enclosure 1 of the March 12,
2012 Request for Information [1]). In general, the approach described in
this report is intended to conform to the structure and philosophy of the
nine steps suggested by the NRC and outlined in that attachment. Key
elements of the approach have been added to provide an expedited
schedule for implementing key seismic modifications associated with
selected equipment as described in Section 3 of this report. As such, this is
an “augmented approach” being recommended by the industry that
provides additional seismic safety considerations (i.e., reviews and
potential seismic upgrades for a select set of equipment) in a more
expedited fashion than was requested in the 50.54(f) [1] request for
information.

Figure 1-1 illustrates the timeline for employing the Augmented

Approach, with a breakdown shown between the Expedited Seismic
Evaluation Process (ESEP) and the seismic risk evaluations. The
Augmented Approach response to the seismic portion of the 50.54(f)
letter is based on a progressive screening approach and is broken down
into six major task areas:
1. Seismic Hazard and Site Response Characterization
2. Ground Motion Response Spectrum (GMRS) Comparisons and
Plant Screening
3. ESEP Seismic Evaluations
4. ESEP Seismic Modifications
5. Prioritization of plants for Risk Assessments
6. Seismic Risk Evaluations

Task areas 1 and 6 are described in detail within EPRI 1025287 [2] and
the methodology will not be repeated in this report. Task 2 is partially
described in EPRI 1025287 [2] and is also discussed in Section 2 of this
report as it applies to the ESEP. Tasks 3 and 4 apply to the ESEP and are
the subject of the remaining sections of this report. Task 5 is described in
EPRI 1025287 Section 5.

 1-2 
 2012 2013 2014 2015 2016 2017 2018 2019 2020
Seismic Evaluation ESEL ESEL

CEUS
Process (ESEP) Seismic Hazard ESEL Seismic
Seismic Mods w/
Development Modifications
Expedited

Evaluation Outages
Augmented Approach

ESEL ESEL
ESEL Seismic
WUS

Seismic Hazard Development Seismic Mods w/

Modifications
Evaluation Outages

Early Seismic Risk Evaluations

Seismic Risk Evaluations

& Lessons Learned

CEUS & WUS

Second Group of Seismic

Risk Evaluations

Note: Schedules are under review due Third Group of Seismic

Risk Evaluations
to delays in the CEUS Ground Motion
Model development and acceptance.
Figure 1-1
Recommended Augmented Approach to Respond to Information
Request 2.1 for Seismic

1.2 Expedited Seismic Evaluation Process (ESEP)

The ESEP was developed to focus initial resources on the review of a

subset of the plant equipment that can be relied upon to protect the
reactor core following beyond design basis seismic events. Figure 1-2
depicts the basic elements of the ESEP. This figure also describes where
each of the key elements is discussed within this report (see the grid on
the left of the figure).

In selecting the items to be included in an expedited seismic evaluation,

the ongoing FLEX process [3, 4, 5] offers an appropriate starting point for
consideration. As described in Section 3, the FLEX process adds an
additional layer of defense-in-depth protection for beyond design basis
events. The installed equipment and connection points associated with
FLEX are therefore considered an appropriate list of items to consider for
the expedited seismic evaluation. Section 3 in this report describes the
selection criteria for the Expedited Seismic Equipment List (ESEL). The
use of the FLEX process to obtain an equipment list for the ESEP does not
affect or change any requirements for the FLEX implementation. FLEX is
used only as an input to obtain an appropriate set of equipment for ESEP.

Operating nuclear plants in the U. S. are expected to conduct this ESEP as

described in Figures 1-1 and 1-2 on the schedule shown in Table 1-1. The
ESEP was developed to be able to promptly assess and address potential
seismic safety enhancements.

Figure 1-3 contains a more detailed flow chart of the ESEP actions. A
more complete set of actions included within the ESEP is listed. These
actions will be referenced in later sections of this report.

 1-3 
 Screen
Section 2 out based on
Site Specific GMRS
Screening GMRS vs. SSE
screening?

Yes
No

Installed FLEX
Section 3 Document Expedited
• Phase 1 Equipment
Equipment Seismic Equipment List
Selection
• Phase 2 Equipment & Connections
(ESEL)
• Phase 3 Equipment & Connections

No further
Section 4 evaluation required
RLGM for the ESEP*
RLGM
Criteria
• Scaled SSE based
& • GMRS based
HCLPF > RLGM Yes
SMA
Section 5 • CDFM
HCLPF • HCLPF
Evaluation Notes:
* The remainder of the
No EPRI 1025287
evaluations should
be performed as
• Upgrade Component applicable.
Section 6 Address ESEL
Modifications
• SPRA may justify alternate
Components That
component upgrade using
Don’t Pass
risk insights

Figure 1-2
Expedited Seismic Evaluation Process for the Augmented
Approach

Sections 2 through 7 of this report describe the elements of the ESEP.

Section 2 contains the description of the screening criteria associated with
comparisons of the ground motion response spectra (GMRS) to the safe
shutdown earthquake (SSE). Section 3 characterizes the equipment
selection criteria for the ESEP. Section 4 describes the elements of the
recommended methods to develop the review level ground motion
(RLGM). Section 5 describes the seismic capacity criteria based on
characterization of the high confidence of a low probability of failure
(HCLPF) capacity associated with the equipment reviewed as part of the
ESEP. Section 6 contains the description of the modification criteria.
Finally, Section 7 documents the submittal criteria for the ESEP.

 1-4 
Table 1-1
Expedited Seismic Evaluation Process Implementation
Schedule Comment [AK2]: This, like the other figure
covering schedule, needs to be updated.
Region Activity Schedule 1
Submit updated seismic
hazards and GMRS and September 2013
screening
Central
and Complete ESEL HCLPF
Eastern Calculations (if necessary)
September 2014
United and submit ESEP report to
States NRC
(CEUS) Complete ESEL modifications
Plants December 2016
not requiring plant outages
Complete ESEL modifications Within 2 outages
requiring plant outages of December 2014
Submit updated seismic
hazards and GMRS and March 2015
screening
Western Complete ESEL HCLPF
United Calculations (if necessary)
January 2016
States and submit ESEP report to
(WUS) NRC
Plants Complete ESEL modifications
June 2018
not requiring plant outages
Complete ESEL modifications Within 2 outages
requiring plant outages of January 2016

1Note: Schedules are under review due to delays in the CEUS Ground Motion Model
development and acceptance.

 1-5 
 Receive Updated Site-
Specific Seismic
Hazards and GMRS

GMRS < SSE Scenario 1

Between Yes Equipment Capacity
1Hz and 10Hz Acceptable.

Section 2 Only
Screening No Narrow Band No further
GMRS to SSE Yes evaluation necessary
Exceedances* for the ESEP

No Only low
Screening Notes: frequency (<2.5Hz)
Yes
* See Section 2.2.1.2 GMRS to SSE
** See Section 2.2.1.1 Exceedances**

No
Section 3 Determine Expedited Limit the Expedited
Equipment Seismic Equipment List Seismic Equipment List
Selection (ESEL) and Functional (ESEL) items to items
Requirements with fn ≤ 2.5 Hz

Scale SSE or
Compute new ISRS New GMRS
Scale SSE
using GMRS and based ISRS
EPRI 1025287

Section 4 SSE < GMRS < 2x SSE Scenario 4

Yes No RLGM = GMRS
RLGM Between
Criteria 1Hz and 10Hz

Scenario 2 Scenario 3
RLGM = Scaled SSE RLGM = 2x SSE
Based on the GMRS (not to exceed 0.75g PGA) Calculate new ISRS
using SPID guidance
for SPRA Evaluations

Section 5 Evaluate ESEL items using

HCLPF RLGM Demand and NP-6041
Evaluation and/or TR-103959 Capacities

Section 6 No further Modify ESEL item to

SSC HCLPF >
Modifications evaluation necessary Yes No achieve necessary
RLGM?
for the ESEP capacity

Figure 1-3
Detailed Flow Chart of the ESEP for the Augmented Approach
Comment [lmr3]: Remove scenario 3 box
parenthetical note – not to exceed 0.75g PGA

 1-6 
Section 2: Screening for the
ESEP (SSE-to-GMRS)
2.1 Background on Screening

Screening for application of the ESEP is based on a comparison of the SSE

with the GMRS and uses criteria from EPRI 1025287 Section 3 [2]. The
horizontal GMRS should be compared to the horizontal 5% damped SSE
as outlined in Figure 2-1. This screening process, along with examples, is
described in more detail below.

2.2 SSE Screening Task (SSE-to-GMRS Comparison)

The SSE is the plant licensing basis earthquake as identified in EPRI

1025287 Section 2 [2]. Similar to Reference 2, the first step in the SSE Comment [lmr4]: Revise footnote to delete
second sentence. The max RLGM is described
screening process is to compare the SSE to the GMRS in the 1 to 10 Hz in Section 4.
region of the response spectrum. If the SSE envelopes the GMRS between
1 and 10 Hz, then the plant screens out of the ESEP 2.

If the initial comparison of the SSE to GMRS does not demonstrate that
the SSE envelops the GMRS in the 1 to 10 Hz region, then the licensees
may consider two special screening considerations described below.

2.2.1 Special Screening Considerations

Consistent with EPRI 1025287 Section 3.2.1 [2], there are two special
screening considerations:
 GMRS Comparisons and Screening of Plants at Low Seismic Hazard
Sites, and
 Narrow Band Exceedances in the 1 to 10 Hz Range.

2For Diablo Canyon, the Double Ddesign Earthquake/licensing (DDE) should be used as
the SSE for screening. The more recent 0.75g basis earthquake (i.e. Hosgri 0.75 g) should
be appropriate for this evaluation earthquake and its associated ISRS are appropriate for
the upper bound for this evaluation.

 2-1 
 Receive Updated Site-
Specific Seismic
Hazards and GMRS

GMRS < SSE Scenario 1

Between Yes Equipment Capacity
1Hz and 10Hz Acceptable.

No

Only
Narrow Band No further
GMRS to SSE Yes evaluation necessary
Exceedances* for the ESEP

No

Limit the Expedited

Low Seismic Seismic Equipment List
Yes
Hazard screen met** (ESEL) items to items
with fn ≤ fL ≤ 2.5 Hz**

No

Screening Notes:
Perform HCLPF * Section 2.2.1.2
Evaluations
** Section 2.2.1.1

Figure 2-1
Comparison of GMRS to SSE (5% Damping) for the ESEP

2.2.1.1 GMRS Comparisons and Screening of Plants at

Low Seismic Hazard Sites

The screening process described in EPRI 1025287 Section 3.2.1.1 [2] can
be used to determine if the plant can be screened out as a low seismic
hazard plant.

Low-frequency GMRS exceedances (below 2.5 Hz) at low seismic hazard

sites do not require a plant to perform a full ESEP. Instead, it is sufficient
to first identify the Expedited Seismic Equipment List (ESEL, see Section
3) items that are potentially susceptible to damage from spectral
accelerations at frequencies below which the highest frequency fL (fL < 2.5

 2-2 
Hz) acceleration exceeds the SSE spectral acceleration. Examples of ESEL
items and failure modes potentially susceptible to damage from spectral
accelerations at low frequencies are:

1) Liquid sloshing in atmospheric pressure storage tanks

2) Sliding and rocking of unanchored components

After identifying the ESEL items that are potentially susceptible to lower
frequency accelerations, the ESEL can be limited to items whose natural
frequency is below the highest frequency fL (fL < 2.5 Hz) where the GMRS
spectral acceleration exceeds the SSE spectral acceleration. Other than
this limitation, the ESEP should be completed as shown in Figures 1-3
and 2-1.

2.2.1.2 Narrow Band Exceedances in the 1 to 10 Hz

Range

The screening process described in EPRI 1025287 Section 3.2.1.2 [2] can
be used to determine if the plant can be screened out as having only
narrow banded GMRS exceedances between 1 and 10 Hz. If the plant
passes this criterion, then the plant screens out of the ESEP.

 2-3 
Section 3: Equipment Selection
3.1 Introduction and Background

In response to Order EA 12-049 [4], all U.S. plants are required to create
mitigating strategies for beyond design basis events. Industry has
prepared a guidance document [3] that governs the requirements for this
diverse and flexible coping capability, referred to by the industry as FLEX.
Figure 3.1, below, illustrates how FLEX supplements the existing
capabilities to add an additional layer of defense in depth against severe
natural events. The ESEP will focus on a subset of key installed equipment
using FLEX as a vehicle to develop this equipment list.

Emergency
Plans

Emergency
SAMGs
Plans
Emergency Diverse & Flexible
Response SAMGs Coping Strategy
(FLEX)
Increased
Prevention of SBO Coping Defense-in- SBO Coping
Fuel Damage Capability Depth Capability

Protection of Design Basis Design Basis

Plant Equipment External Events External Events

Current Current plus FLEX

Figure 3-1
FLEX Enhances Defense in Depth (Ref [3])

3.2 Selection of Expedited Seismic Equipment List

(ESEL)

The selection of the Expedited Seismic Equipment List (ESEL) will be

derived from equipment identified in the plant-specific FLEX
implementation strategy. In responding to EA 12-049, each plant will
have defined an essentially indefinite coping capability for scenarios
involving an extended loss of alternating current (AC) power condition.
Loss of alternating current (AC) power has been found to be an important

 3-1 
contributor to seismic risk in many seismic probabilistic risk assessments
(SPRAs). Thus, by considering the selected FLEX equipment as the source
for the ESEL, plant capabilities to mitigate an important contributor to
seismic risk are being enhanced.

The underlying strategies for coping with these conditions involve a three-
phase approach:
1. Initially cope by relying on installed plant equipment.
2. Transition from installed plant equipment to on-site FLEX
equipment.
3. Obtain additional capability and redundancy from off-site
equipment until power, water, and coolant injection systems are
restored or commissioned.

Plant-specific evaluations for FLEX will determine the specific equipment

and strategies to be employed in these three phases. The scope of the
ESEL is limited to installed plant equipment and FLEX equipment
connections. As described above, Phase 1 relies upon equipment that is
installed in the plant. Phases 2 and 3 rely on portable on-site or off-site
equipment to supplement installed equipment, but these capabilities tie
into and utilize installed plant equipment. Per NEI 12-06 [3], installed
plant equipment relied upon to respond to an earthquake as part of FLEX
must be seismically robust. NEI 12-06 defines “robust” as “the design of
an SSC either meets the current plant design basis” or “has been shown by
analysis or test to meet or exceed the current design basis”. The purpose
of the ESEP is to demonstrate or provide additional seismic margin for
ESEL items. It does not redefine any of the terms or criteria in NEI 12-06.

Each plant should review their FLEX implementation approach to

identify the installed plant equipment and portions of systems required to
accomplish the reactor and containment safety functions identified in NEI
12-06 Tables C-1 and C-2 for Boiling Water Reactors (BWRs) and Tables
D-1 and D-2 for Pressurized Water Reactors (PWRs). Tables 3-1 and 3-2
identify these safety functions and provide a summary of the typical
equipment and portions of systems that would be included in the ESEL.
In addition to the stressphysically-based failures (load path and
anchorage) of specific pieces of installed equipment, functional failure
modes of electrical and mechanical portions of the installed Phase 1
equipment should be considered (e.g. RCIC/AFW trips). Additional
guidance on the specific scope of failure modes is provided in Section 5.
The selection process for the ESEL should assume the FLEX strategies
(modifications, equipment, procedures, etc.) have been implemented.

FLEX strategies necessarily rely upon operator actions for

implementation. The operator actions that are included in plant’s base
implementation should be considered in determining the scope of
equipment to be included in the ESEL. The primary means of
accomplishing implementation of the FLEX strategies should be used. If
 3-2 
an alternate means is used, the basis for its selection should be
documented. All installed equipment necessary for successful
implementation should be included, (e.g., required control cabinets,
governors for turbine-driven pumps).

Some equipment relied upon for implementation of FLEX capabilities

need not be included in the ESEL:
 Only a single success path is required for the safety functions
identified in Tables 3-1 and 3-2. Equipment required to support an
alternative means to accomplish a function is not required to be
included in the ESEL.
1. NEI 12-06 requires primary and alternate connection points for
portable equipment. Only one connection point needs to be
included, provided the required function can still be accomplished.
Justification should be provided for any cases where the primary
connection point is not selected.
2. Limiting instrumentation to one indication per key parameter is
acceptable, provided the required function can still be
accomplished.
3. Plants may have identified additional resources that may be
beneficial, but are not required (e.g. multiple water sources
available for CST makeup). Only the minimum set of sources to
perform the required function needs to be considered.
 Some specific SSCs normally considered in SPRAs are excluded. These
will be addressed by plants as part of the longer-term seismic risk
evaluations, if required.
1. The following types of SSCs are excluded from the ESEP.
- Structures (, e.g., containment, reactor building, control
building auxiliary building, etc.)
- Piping, cabling, conduit, HVAC, and their supports
- Manual valves, check valves, and rupture disks
- Power operated valves not required to change state as part of
the FLEX mitigation strategies
- NSSS components (e.g. RPV and internals, RCPs and seals,
etc.)
 Portions of SSCs that are not directly relied upon in the FLEX strategy
may be excluded, such as:
1. Portions of systems that are not used as transport mechanisms for
delivering required flows are excluded (e.g. components beyond
boundary valves).
2. Electrical equipment components not specifically relied upon to
perform the FLEX functions are excluded (e.g. power sources and
distribution not directly supporting FLEX active components).

 3-3 
 Controls for which plant procedures provide instructions for manual
operation (in the event of control system, component, permissive, or
interlock failures) that ensure performance of the required FLEX
function are excluded.
 Phase 3 portions of installed equipment (and FLEX connections) that
are not relied upon in the FLEX strategy to sustain the critical
functions of core cooling and containment integrity may be excluded.
Recovery strategies in Phase 3 are excluded.

 3-4 
 Table 3-1
Summary of NEI 12-06 Performance Attributes for BWR Core Cooling & Containment Function
Typical Installed Typical Installed ESEL
Safety Function Method Baseline Capability
ESEL Equipment Support Equipment
Reactor Core • RCIC/HPCI/IC • Use of installed equipment for • RCIC pump, gland • DC Power
Cooling initial coping condenser, & lube oil cooler • Plant batteries
• RCIC valves • DC distribution panels,
MCCs & switchgear, as
required
• Depressurize RPV • Diverse connection points for • ECCS injection valves • Selected electrical
for Injection with portable pump components, if required
Portable Injection
Source
Core Cooling

• Multiple means to depressurize • SRVs • Portions of DC power

RPV
• Sustained Source of • Use of alternate water supply • Onsite water storage tanks, • Level instrumentation
Water up to support core and SFP heat if required
removal
Key Reactor • RPV Level • (Re-)Powered instruments • Selected Instruments • DC Power and/or
Parameters • RPV Pressure • Vital AC Power,
• Selected Vital AC
distribution panels
• Inverters
• Instrument racks
• Instrument panels
Containment • Containment • For Mk I and II a venting • Containment vent system, if • DC power
Function Venting or capability and, if desired, an applicable • Pneumatic supplies
Alternative alternative capability • Selected suppression pool
• For others, a reliable, hardened cooling equipment
vent or other capability.
Containment

Containment • Hydrogen igniters • Re-powering of hydrogen • Igniter glow plugs • Distribution panels required to
Integrity igniters with a portable power supply power, if any
(BWR Mark III supply.
Only)
Key Containment • Containment • (Re-)Powered instruments • Selected Instruments • DC Power and/or
Parameters Pressure • Vital AC Power,
• Suppression Pool • Selected Vital AC

 3-5 
 Typical Installed Typical Installed ESEL
Safety Function Method Baseline Capability
ESEL Equipment Support Equipment
Temperature distribution panels
• Suppression Pool • Inverters
Level • Instrument racks
• Instrument panels

 3-6 
 Comment [AK5]: The first column has
Table 3-2 something in the box under core cooling in the
Summary of NEI 12-06 Performance Attributes for PWR Core Cooling & Containment Function printout handed out at the meeting, but is
missing from the clean copy

Safety Function Method Baseline Capability Typical Equipment Typical Support Equipment
Reactor Core • AFW/EFW • Use of installed equipment • AFW/EFW pump • DC Power
Cooling & Heat for initial coping • AFW/EFW valves • Plant batteries
Removal (steam • DC distribution panels,
MCCs & switchgear, as
generators
required
available)
• Depressurize SG for • Connection for portable • SG ADVs/PORVs • None, typically
Makeup with Portable pump
Injection Source
• Sustained Source of Water • Use of alternate water • Onsite water storage tanks, • None
supply up to support core e.g., Condensate Storage
and SFP heat removal Tank or equivalent, if
required
RCS Inventory • Low Leak RCP Seals and/or • Site analysis required to • Injection path valves • None
borated high pressure RCS determine RCS makeup • Letdown path valves
Core Cooling

Control/Long-
Term makeup required requirements
• Boration and/or letdown
Subcriticality
path may be required
Core Cooling and • All Plants Provide Means to • Diverse makeup connections • Injection path valves (May • None
Heat Removal Provide Borated RCS to RCS for long-term RCS be same as above)
(Modes 5 and 6 Makeup makeup and residual heat
removal to vented RCS
with SGs not
available)
• Source of borated water • Onsite tank, if required. • None
required
Key Reactor • SG Level • (Re-)Powered instruments • Selected Instruments • DC Power and/or
Parameters • SG Pressure • Vital AC Power,
• RCS Pressure • Selected Vital AC
• RCS Temperature distribution panels
• Inverters
• Instrument racks
• Instrument panels
Containment • Containment Spray • Connection to containment • Containment spray valves • None
inme
nt

Function spray header or alternate

 3-7 
Safety Function Method Baseline Capability Typical Equipment Typical Support Equipment
capability or Analysis

Containment • Hydrogen igniters • Re-powering of hydrogen • Igniter glow plugs • Distribution panels required
Integrity igniters with a portable to supply power, if any
(Ice Condenser power supply.
Containments
Only)
Key Containment • Containment Pressure • (Re-)Powered instruments • Selected Instruments • DC Power and/or
Parameters • Vital AC Power,
• Selected Vital AC
distribution panels
• Inverters
• Instrument racks
• Instrument panels

 3-8 
A summary of the anticipated types of equipment expected to be on an
ESEL are provided in the tables below:

Table 3-3
Representative BWR Equipment within the Scope of ESEL
Mechanical Equipment Electrical Equipment
 RCIC pump and valves  Batteries
 RCIC lube oil and gland  DC distribution panels
condenser  DC MCCs
 Safety relief valves (SRVs)  DC switchgear
 SRV accumulators  Vital AC distribution panels
 RPV injection valves  Battery charger(s)
 Reliable hardened vent valves  Inverter(s)
 Instrument racks
 Transmitters

Table 3-4
Representative PWR Equipment within the Scope of ESEL
Mechanical Equipment Electrical Equipment
 Turbine driven AFW pump and  Batteries
valves  DC distribution panels
 SG Power Operated Relief Valves  DC MCCs
(PORVs)  DC switchgear
 Condensate Storage Tank  Vital AC distribution panels
 SG injection valves  Battery charger(s)
 RCS injection valves  Inverter(s)
 Instrument racks
 Transmitters

Finally, similar to seismic equipment lists for SPRAs, it is acceptable for

the ESEL to be iterative. That is, if during the ESEP process, it is
determined that an SSC has a seismic capacity below the RLGM, it may be
appropriate to supplement the FLEX implementation to provide an
alternative capability. For example, if an installed air accumulator relied
upon to supply air for an air-operated valve is determined to have seismic
capacity below the RLGM, it is acceptable to provide an alternative supply
of air (e.g., air bottles) with a higher seismic capacity provided that
capability fits within the overall performance requirements of NEI 12-06.

3.3 Format and Content of Expedited Seismic Equipment

List (ESEL)

In order to support the appropriate evaluation of the seismic capacity, the

ESEL must include additional information beyond the list of equipment.
The needed information includes:
 The unique equipment ID
 A description of the equipment

 3-9 
 The normal and desired operating state of the equipment as evaluated
in the site specific FLEX strategies, and
 Other information that may be useful to the evaluation of seismic
capacity.

An example of a recommended format for the ESEL is provided in Table

3-5. Additional information may be included useful to the evaluation such
as building, elevation, location, etc.

 3-10 
 Table 3-5
Example Format of ESEL Summary Table

ESEL Equipment Equipment

Item # Equipment ID Description Normal State Desired State Notes
1 XT15-C001 TDAFW Turbine Standby Operating AB10000

Notes for Table 3-5:

The column headings are explained below:

 ESEL Item #: This is a record number for each ESEL item on the list.
This is typically a unique sequential number that allows ease of
reference to a particular SSC.
 Equipment ID: This is a unique equipment identification number for
the SSC. This would generally be taken from the plant master
equipment list or other common data system used at the plant.
 Description: This is a text description of the SSC. This would generally
be taken from the plant master equipment list or other common data
system used at the plant.
 Equipment Normal State: This column identifies the normal state of
the SSC (e.g., normally energized/de-energized, normally
closed/open, normally standby/running, etc.) based on the initial
plant conditions defined in the baseline coping capability of NEI 12-
06.
 Equipment Desired State: This column identifies the desired state of
the equipment evaluated in the site specific FLEX mitigation strategy.
For some equipment this will be different than the normal state. For
example, a valve that is normally closed during plant operations may
need to be opened to support a required function.
 Notes: This is a column field to provide notes and/or comments
(reference drawings, specific room location, etc.). Codes may also be
defined and used to provide a variety of information (e.g., failure
mode of interest).

 3-11 
 3-12 
Section 4: Review Level Ground
Motion (RLGM) Spectrum
Criteria
This section of the Expedited Seismic Evaluation Process (ESEP) for the
Augmented Approach consists of addressing those plants which cannot be
screened out based on the comparisons of the GMRS to the SSE (as
described in Section 2 of this report). Plants whose GMRS exceeds the
SSE in the 1 to 10 Hz range require further seismic evaluation beyond the
design basis. The further seismic evaluation is conducted to a Review
Level Ground Motion (RLGM) level, which consists of a response
spectrum above the SSE level. Figure 1-3 contains a flowchart that shows
how the development of the RLGM fits into the ESEP.

If a plant does not screen out from the ESEP as described in Section 2,
then a RLGM would be computed using one of the following criteria:
1. The RLGM will be derived by linearly scaling the SSE by the
maximum ratio of the GMRS/SSE between the 1 and 10 Hz range
(not to exceed 2 x SSE and 0.75g PGA). In-structure RLGM Comment [lmr6]: A RLGM cap of 0.75g, PGA
is not needed. Just use 2 x SSE.
seismic motions would be derived using existing SSE-based in-
structure response spectra (ISRS) scaled with the same factor. Comment [lmr7]: For DC and SONGS, the
RLGM should bound the GMRS or justification
2. Alternatively, licensees who have developed appropriate should be provide for a lower RLGM. Using a
cap of 0.75g, PGA for SONGS is only the
structural/soil-structure interaction (SSI) models capable of SSE x 1.12.
calculating ISRS based on site GMRS/uniform hazard response
spectrum (UHRS) input may opt to use these ISRS in lieu of scaled
SSE ISRS. In this case, the GMRS would represent the RLGM.
EPRI 1025287 [2] and the ASME/ANS PRA Standard [10] give
guidance on acceptable methods to compute both the GMRS and
the associated ISRS.

Approach number 1 above, where the RLGM is developed based on the

SSE, is a much more expedient approach (both in terms of schedule and
resources) for developing the floor spectra in the structures housing ESEL
items since it involves a simple linear scaling of existing SSE-based floor
spectra. Two example cases of implementing approach 1 are depicted in
Figures 4-1 and 4-2.
 Figure 4-1 depicts the case where the GMRS exceeds the SSE but is
less than twice the SSE in the 1 to 10 Hz range. The RLGM for this
 4-1 
 case is developed by linearly scaling up the SSE by the maximum ratio
of the GMRS/SSE between the 1 to 10 Hz range. For this example, that
maximum ratio occurs at 10 Hz.
 Figure 4-2 depicts the case where the RLGM would be set at the
maximum of two times the SSE. In this case, the maximum ratio of
the GMRS to the SSE over the 1 to 10 Hz range exceeds a value of 2.

Figure 4-1
RLGM Generated by Scaling Up SSE Spectrum (Scenario 2 from
Figure 1-3)

Scenario 3: RLGM = 2x SSE

1.10

1.00 2x SSE

Scaled SSE B
0.90
GMRS B
0.80
SSE
0.70
Acceleration (g)

0.60

0.50

0.40

0.30

0.20

0.10

0.00
0.10 1.00 10.00 100.00
Frequency (Hz)

Figure 4-2
RLGM Defined as Twice the SSE (Scenario 3 from Figure 1-3)

 4-2 
Section 5: SSC Capacity
Criteria for the ESEP
The ESEP consists of first the GMRS/SSE screening assessments (Section
2), followed by generating the scope of equipment (Section 3) and
subsequently followed by the development of the RLGM (Section 4).
Those plants required to perform the beyond design basis review as part
of the ESEP are then required to demonstrate that ESEL items have
sufficient seismic capacity to meet or exceed the demand characterized by
the RLGM. The criteria for the seismic capacity of the components
included within the ESEL consists of calculating a HCLPF seismic
capacity and comparing that level to the seismic demand of the RLGM.

Demonstration that the HCLPF capacity exceeds the RLGM for the
components within the ESEL will verify adequate seismic ruggedness for
this program and would indicate that no further action would be required,
as shown in Figures 1-2 and 1-3. Conversely, Section 6 of this report
discusses the process for the resolution of those components which
cannot demonstrate this margin over the RLGM. The detailed criteria for
the development of the HCLPF capacity, along with many examples of the
methods used to perform the calculation, are well documented in
technical literature and will not be repeated in this document. Several
references for HCLPF procedures are listed in Table 5-1.

Table 5-1
Partial List of Fragility and Margin References

SPRA Topic Document Title Reference

Seismic Fragility EPRI Report 1019200
Applications Guide Update (Dec 2009)[6]
Seismic Fragility EPRI 1002988 (Dec 2002)
Seismic Application Guide [7]
Fragility & Methodology for Developing EPRI TR-103959
Margin Seismic Fragilities (June 1994) [8]
A Methodology for
EPRI NP 6041 (Oct 1988)
Assessment of Nuclear
[9]
Plant Seismic Margin

There are two basic approaches for developing the HCLPF values:
 Deterministic Approach

 5-1 
 Probabilistic Approach – generated based on a seismic fragility
calculation

The deterministic approach is typically considered to be the easiest to

apply, and there are more practitioners with experience with its
implementation. As such, a brief summary of some of the salient features
of the deterministic approach are provided herein. The deterministic
approach to defining the HCLPF of essential components is commonly
referred to as the Conservative Deterministic Failure Margin (CDFM)
approach.

For the ESEP, the response is specified as described in Section 4 of this

report, and the capacity is generated based on CDFM methods. EPRI NP-
6041-SL [9] contains a detailed description of the CDFM process. The
basic elements of the CDFM capacity development are summarized in
Table 5-2 below.

Table 5-2
Summary of Conservative Deterministic Failure Margin
Approach for Seismic Capacity (EPRI NP-6041-SL [9])
Load Combination: Normal + Seismic
Material Strength: Code-specified minimum strength or
95% exceedance actual strength if
test data are available.
Static Capacity Equations: Code ultimate strength (ACI),
maximum strength (AISC), Service
Level D (ASME), or functional
limits. If test data are available
to demonstrate excessive
conservatism of code equations,
then use 84% exceedance of test
data for capacity equation.
Inelastic Energy For non-brittle failure modes and
Absorption: linear analysis, use 80% of
computed seismic stress in capacity
evaluation to account for ductility
benefits, or perform nonlinear
analysis and go to 95% exceedance
ductility levels.

For those structural failure modes which can be evaluated by analysis, a

seismic capacity estimate requires an estimate of:
1. material strength,
2. static capacity or failure equation, and
3. inelastic energy absorption capability.

Each of these parameters should be conservatively estimated to achieve

the above-recommended level of capacity conservatism.

 5-2 
Material strengths used in the CDFM approach should be the
approximately 95% exceedance probability strengths from material test
data. Otherwise, code- or design-specified minimum strengths should be
used. These values represent the approximately 95% exceedance
probability strengths of all materials meeting the code specifications. As
discussed in EPRI NP-6041-SL [9] a higher exceedance probability is
needed for brittle failure modes.

Functional failure modes cannot typically be evaluated solely by analysis

and have to be assessed using test data or generic equipment ruggedness
spectra (GERS). The GERS are always set lower than the lowest test
response spectrum (TRS) for which failures were observed, if any such
failure test data exist. If either the component-specific test data or the
applicable GERS are to be considered to demonstrate operability, then a
margin factor is needed between the computed seismic response and the
TRS in order to achieve a HCLPF capacity. Recommendations are
provided in [9] for the calculation approaches for CDFM capacities for
functional failure modes.

Seismic Capacity Screening Guidelines

The EPRI seismic margins report [9] contains a set of screening criteria
tables frequently used in both SPRAs and SMAs, including Table 2-4
titled “Summary of Equipment and Subsystems Screening Criteria for
Seismic Margin Evaluation.”

The criteria documented in this table were based primarily on

information from SPRA/SMA studies and on available seismic experience
data (both actual earthquake experience and testing experience). The
NRC-sponsored "Expert Panel" on the Quantification of Seismic Margins
developed a consensus seismic capacity screening criterion, which was the
starting point for the table. The EPRI Seismic Margin Program reviewed
additional data and refined and expanded the NRC Expert Panel
recommendations, which resulted in Tables 2-4 [9]. The guidelines are
intended to provide generic conservative estimates of the ground motion
below which it is generally not necessary to perform a seismic margin
review for particular elements. Thus, for a given ground motion level, the
guidelines list the equipment which should, in general, be "screened out"
from margin review because of their generically good performance in
earthquakes or seismic simulation tests at or above this level. These
guidelines are to be used only in conjunction with a walkdown of plant-
specific elements by the seismic review team (SRT). The guidelines are
intended to assist the SRT in "screening out" components during their
walkdown, but the SRT must exercise its own collective experience and
judgment in the use of these guidelines for any specific component.

Several important considerations associated with the use of this table

include:

 5-3 
 Separate criteria are listed depending on the 5% damped peak spectral
acceleration associated with the ground motion.
 Caveats and restrictions associated with each specific system, or
component type are required to be met. These are documented as
notes to the table.
 The table is applicable to equipment up to 40 ft above grade.

It is important to recognize that a major part of an SMA is investigation of

equipment anchorage. The screening table values given in this report are
for the capacity of the element per se, and do not include consideration of
anchorage, which varies from plant to plant. Thus anchorage must be
considered in addition to the guidance given in the screening tables. This
anchorage evaluation should include any specific load path and support
configurations that would not have been included within the experience
data (earthquake, testing, and analysis) that went into the development of
the EPRI NP-6041-SL screening tables. Thus cComponents that are
anchored to sub-structural elements that may not have the same capacity
as the main structural system (e.g., block walls, frames, stanchions, etc.)
that are not typical of those within the experience data should also be
reviewed as part of the ESEP process for calculating the HCLPF. A
justification should be provided if the load paths for components
anchored to sub-structural elements are not reviewedEquipment
anchored to these sub-structural components are not typical of those
within the experience database upon which the screening tables are
based.

Nearby block walls should be identified during walkdowns and

subsequently evaluated. In addition, piping attached to tanks should be
reviewed to address the possibility of failures due to differential
displacements. Other potential seismic interaction evaluations will be
deferred to the full seismic risk evaluations performed in accordance with
EPRI 1025287 [2].

Reference [6] is an update to the EPRI fragility methodology and contains

a description of the criteria for application of these screening tables at
elevations beyond 40 ft above grade and should be used as part of this
evaluation.

 5-4 
Section 6: ESEL Modification
Criteria
Demonstration that the HCLPF capacity for any ESEL item exceeds the
RLGM verifies that the item has adequate seismic ruggedness for the
ESEP and that no further action would be required, as shown in Figures 1-
2 and 1-3. Conversely, if the ESEL item HCLPF does not exceed the
RLGM, modifications should be performed as described below.

Any ESEL item whose HCLPF capacity is less than the RLGM should be
modified such that the HCLPF meets or exceeds the RLGM. This criterion
applies for ESEL items identified in Section 2.2.1.1, as well as items
identified in Section 5. These modifications are intended to provide a
near-term improvement of plant safety. They do not impose a long-term
commitment to maintain the improved plant conditions beyond the point
where the long-term plant risk evaluations are completed in accordance
with NRC 50.54(f) letter [1] and EPRI 1025287 [2].

Modifications should be completed within 2 years of submitting the plant

specific ESEP summary report to the NRC (Section 7). Additionally, if a
plant outage is required to implement the ESEL item modification, the
modifications should be completed within 2 outages of submitting the
ESEP summary report to the NRC.

Consideration of the ESEL modifications may be revised based on insights

from a completed SPRA. The results of a completed SPRA may show that
alternate modifications would produce more effective safety
enhancements. In that case, the more beneficial modifications identified
by the SPRA could be implemented rather than the ESEL modifications.
Those alternate modifications would have the same implementation
schedule described above. The results of these alternate plant
modifications would be expected to provide more beneficial, long-term
plant safety improvements.

 6-1 
Section 7: ESEP Report
A report should be prepared summarizing the ESEP evaluations and
results. The report should be submitted to the NRC for review following
completion of the evaluations (see Table 1-1). The level of detail provided
in the report should be sufficient to enable NRC to understand the inputs
used, the evaluations performed, and the decisions made as a result of the
interim evaluations. It is not necessary to submit HCLPF calculations.
Relevant documentation should be cited in the submittal, and be available
for NRC review on-site in easily retrievable form.

The report should include the following information.

 A brief summary of the FLEX seismic implementation strategies,
including functions to be achieved and how the selected equipment
achieves those functions
 A list of the selected equipment (ESEL) and a justification for any
ESEL equipment that is not the primary means for FLEX
implementation for seismic events
 A plot of the GMRS submitted by the licensee in accordance with the
50.54(f) letter and EPRI 1025287 [2] and comparison to the SSE
 A description of the RLGM selected and the process to estimate ISRS
 A summary of the methodologies used to perform the HCLPF
calculations and the results including:
- the HCLPF screening process used (e.g. NP 6041)
- the HCLPF calculation process (s) used
- tabulated ESEL HCLPF values including the key failure modes
 Identification of any ESEL items that were inaccessible for walkdown
along with the planned walkdown and evaluation schedule, including
specific dates for completion.
 Description of the ESEP results including:
- identification of required modifications
- modification implementation schedule

 7-1 
Section 8: References
1. NRC (E Leeds and M Johnson) Letter to All Power Reactor
Licensees et al., “Request for Information Pursuant to Title 10 of
the Code of Federal Regulations 50.54(f) Regarding
Recommendations 2.1, 2.3 and 9.3 of the Near-Term Task Force
Review of Insights from the Fukushima Dai-Ichi Accident,” March
12, 2012.
2. EPRI 1025287, Seismic Evaluation Guidance: Screening,
Prioritization and Implementation Details (SPID) for the
Resolution of Fukushima Near-Term Task Force Recommendation
2.1: Seismic EPRI, Palo Alto, CA: 2012.
3. NEI 12-06, “Diverse and Flexible Coping Strategies (FLEX)
Implementation Guide”, Revision 0, August 2012
(ML12242A378).
4. Order EA-12-049, “Order Modifying Licenses with Regard to
Requirements for Mitigation Strategies for Beyond-Design-Basis
External Events,” March 12, 2012 (ML12054A736)
5. Japan Lessons-Learned Project Directorate, JLD-ISG-2012-01,
“Compliance with Order EA-12-049, Order Modifying Licenses
with Regard to Requirements for Mitigation Strategies for Beyond-
Design-Basis External Events,” Interim Staff Guidance Revision 0,
August 29, 2012,(ML12229A174)
6. EPRI 1019200, “Seismic Fragility Applications Guide Update,”
December 2009.
7. EPRI 1002988, “Seismic Fragility Application Guide,” December
2002
8. EPRI TR-103959, “Methodology for Developing Seismic
Fragilities,” July 1994.
9. EPRI NP-6041-SL, “A Methodology for Assessment of Nuclear
Plant Seismic Margin, Revision 1”, Electric Power Research
Institute, August 1991.
10. American Society of Mechanical Engineers/American Nuclear
Society (ASME/ANS) RA-Sa-2009.

 8-1 
 8-2 