RS-13-095, Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

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Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident
ML13171A220
Person / Time
Site: LaSalle Constellation icon.png
Issue date: 06/19/2013
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-13-095
Download: ML13171A220 (5)


Text

i Generation.

10 CFR 50.54(f)

RS-13-095 June 19, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 LaSalle County Station, Unit 2 Facility Operating License No. NPF-18 NRC Docket No. 50-374

Subject:

Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

References:

1.

Exelon Generation Company, LLC 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 27, 2012 (RS-12-164) 2.

NRC Letter, 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, dated March 12, 2012 In Reference 1, Exelon Generation Company, LLC (EGC) provided the LaSalle County Station, Units 1 and 2 flooding walkdown report in accordance with the NRC Request for Information (Reference 2). The LaSalle County Station, Units 1 and 2 flooding walkdown report documented the plant walkdowns performed to verify that plant features credited in the current licensing basis for protection and mitigation from external flood events are available, functional, and properly maintained. In Table No. 5 of Reference 1, EGC provided the list of the LaSalle County Station, Units 1 and 2 plant features that were not able to be inspected due to restricted access. EGC committed to complete the inspection of the Unit 2 features classified as restricted access by the end of the LaSalle County Station, Unit 2 Refueling Outage L2R14 (Spring 2013).

rf n

ti 10 CFR 50.54(f)

RS-13-095 June 19,2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

References:

LaSalle County Station, Unit 2 Facility Operating License No. NPF-18 NRC Docket No. 50-374 Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54{f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

1. Exelon Generation Company, LLC 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 27,2012 (RS-12-164)
2. NRC Letter, 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, dated March 12, 2012 In Reference 1, Exelon Generation Company, LLC (EGC) provided the LaSalle County Station, Units 1 and 2 flooding walkdown report in accordance with the NRC Request for Information (Reference 2). The laSalle County Station, Units 1 and 2 flooding walkdown report documented the plant walkdowns performed to verify that plant features credited in the current licensing basis for protection and mitigation from external flood events are available, functional, and properly maintained. In Table NO.5 of Reference 1, EGC provided the list of the LaSalle County Station, Units 1 and 2 plant features that were not able to be inspected due to restricted access. EGC committed to complete the inspection of the Unit 2 features classified as restricted access by the end of the LaSalle County Station, Unit 2 Refueling Outage L2R14 (Spring 2013).

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding June 19, 2013 Page 2 This letter provides the results of the completed supplemental walkdown inspections performed for the LaSalle County Station Unit 2 features, classified as restricted access in Reference 1.

The enclosed tables document the walkdown results for each of the subject plant features.

As identified in Table 5 of Reference 1, fourteen (14) features were deferred to the next Unit 2 outage, L2R14. However, one (1) item that was identified on penetration drawings was not actually installed in the field, so it was deleted from the walkdown list. This was entered into the corrective action program (CAP). Two (2) penetrations that were not previously shown on penetration drawings were identified during the outage walkdowns, and thus were added to the walkdown list. This was also entered into CAP. This resulted in fifteen (15) deferred features for the Unit 2 outage. The total number of features for LaSalle was therefore increased from 185 to 186.

The results of the visual inspections during the supplemental flooding walkdowns for Unit 2 showed that eleven (11) features meet the NEI 12-07 acceptance criteria. Table 1 provides the results for the features that were inspected during the L2R14 Unit 2 refueling outage that were immediately judged as acceptable.

Table 2 provides the list of four (4) features that were not immediately judged as acceptable during the supplemental walkdowns, but after processing of the CAP entries, these features were found to be in accordance with the site current licensing basis. The table provides the references to the CAP entries of the identified conditions.

There were no features found to be deficient per the current licensing basis.

The supplemental flooding walkdown record forms document the details of all observations for all flood features inspected, and are available for on-site review. Except as noted above, LaSalle County Station Unit 2 flood protection features met the NEI 12-07 Supplemental Guidance acceptance criteria. After processing of the CAP entries, all features were found to be in accordance with the site current licensing basis. This report completes Commitment No. 2 contained in Reference 1.

This letter contains no new regulatory commitments.

Should you have any questions concerning the content of this letter, please contact Ron Gaston at (630) 657-3359.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of June 2013.

Respectfully, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding June 19, 2013 Page 2 This letter provides the results of the completed supplemental walkdown inspections performed for the LaSalle County Station Unit 2 features, classified as restricted access in Reference 1.

The enclosed tables document the walkdown results for each of the subject plant features.

As identified in Table 5 of Reference 1, fourteen (14) features were deferred to the next Unit 2 outage, L2R14. However, one (1) item that was identified on penetration drawings was not actually installed in the field, so it was deleted from the walkdown list. This was entered into the corrective action program (CAP). Two (2) penetrations that were not previously shown on penetration drawings were identified during the outage walkdowns, and thus were added to the walkdown list. This was also entered into CAP. This resulted in fifteen (15) deferred features for the Unit 2 outage. The total number of features for LaSalle was therefore increased from 185 to 186.

The results of the visual inspections during the supplemental flooding walkdowns for Unit 2 showed that eleven (11) features meet the NEI 12-07 acceptance criteria. Table 1 provides the results for the features that were inspected during the L2R 14 Unit 2 refueling outage that were immediately judged as acceptable.

Table 2 provides the list of four (4) features that were not immediately judged as acceptable during the supplemental walkdowns, but after processing of the CAP entries, these features were found to be in accordance with the site current licensing basis. The table provides the references to the CAP entries of the identified conditions.

There were no features found to be deficient per the current licensing basis.

The supplemental flooding walkdown record forms document the details of all observations for all 'flood features inspected, and are available for on-site review. Except as noted above, LaSalle County Station Unit 2 flood protection features met the NEI 12-07 Supplemental Guidance acceptance criteria. After processing of the CAP entries, all features were found to be in accordance with the site current licensing basis. This report completes Commitment No.2 contained in Reference 1.

This letter contains no new regulatory commitments.

Should you have any questions concerning the content of this letter, please contact Ron Gaston at (630) 657-3359.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of June 2013.

Respectfully, Gd'f;i.¥ Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding June 19, 2013 Page 3

Enclosures:

1. Table 1 - LaSalle County Station, Unit 2 Supplemental List of Features Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage L2R1 4)
2. Table 2 - LaSalle County Station, Unit 2 Supplemental List of Features Not Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage L2R14) cc:

Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region III NRC Senior Resident Inspector - LaSalle County Station NRC Project Manager, NRR - LaSalle County Station Illinois Emergency Management Agency - Division of Nuclear Safety U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding June 19, 2013 Page 3

Enclosures:

1. Table 1 - LaSalle County Station, Unit 2 Supplemental List of Features Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage L2R14)
2. Table 2 - LaSalle County Station, Unit 2 Supplemental List of Features Not Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage L2R14) cc:

Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region III NRC Senior Resident Inspector - LaSalle County Station I\\IRC Project Manager, I\\IRR - LaSalle County Station Illinois Emergency Management Agency - Division of Nuclear Safety

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding June 19, 2013 ENCLOSURE1 Table 1 - LaSalle County Station, Unit 2 Supplemental List of Features Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage L2R14)

Table #1: Inspected Flooding Features Meeting Acceptance Criteria Features Immediately Judged as Acceptable Feature ID #

Description Passive/Active Incorporated/Temporary 1

Off Gas Pipe 1 Penetration Passive - Incorporated 2

Off Gas Pipe 2 Penetration Passive - Incorporated 3

Off-Gas Filter Building row AA.5 to AD and column 12.5 Passive - Incorporated Basement Floor Slab 2 to 14 4

Off-Gas Filter Building AD-line from 12.5 to 14 and 14-Passive - Incorporated Upper Basement Wall line from AB to AD 22 5

Unit 2 Turbine Building column 19 to 24 and S to V.

Passive - Incorporated Basement Floor Slab 2

- Condenser Pit 6

Unit 2 Turbine Building V-line from 23 to 25, 25-line from Passive - Incorporated Upper Basement Wall 2 S.5 to U.5, and S-line from 21 to 25 (Upper Condenser Pit) and 22-line from R to S (El. 704.5')

and HP Heater room 7

OB-168 Penetration Passive - Incorporated 8

OB-71 Penetration Passive - Incorporated 9

OB-72 Penetration Passive - Incorporated 10 6" Floor Drain Pipe 1 Penetration Passive - Incorporated 11 6" Floor Drain Pipe 2 Penetration Passive - Incorporated Stainless U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding June 19, 2013 ENCLOSURE 1 Table 1 - LaSalle County Station, Unit 2 Supplemental List of Features Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage L2R14)

Table #1: Inspected Flooding Features Meeting Acceptance Criteria Features Immediately Judged as Acceptable Feature 10#

Description Passive/Active Inc rary 1

Off Gas Pipe 1 Penetration Passive -Incorporated 2

Off Gas Pipe 2 Penetration Passive Incorporated Off-Gas Filter Building row AA.5 to AD and column 12.5 Passive Incorporated Basement Floor Slab 2 to 14 4

Off-Gas Filter Building AD-line from 12.5 to 14 and 14-Passive Incorporated Upper Basement Wall line from AB to AD 2 2 5

Unit 2 Turbine Building column 19 to 24 and 5 to V.

Passive -Incorporated Basement Floor Slab 2

- Condenser Pit 6

Unit 2 Turbine Building V-line from 23 to 25, 2S-line from Passive - Incorporated Upper Basement Wall 2 5.5 to U.S, and S-iine from 21 to 25 (Upper Condenser Pit) and 22-line from R to S (EI. 704.5')

and HP Heater room 7

OB-168 Penetration Passive -Incorporated 8

OB-71 Penetration Passive -Incorporated 9

OB-72 Penetration Passive Incorporated 10 6" Floor Drain Pipe 1 Penetration Passive - Incorporated 6" Floor Drain Pipe 2 Penetration Passive Incorporated Stainless

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding June 19, 2013 ENCLOSURE2 Table 2: LaSalle County Station, Unit 2 Supplemental List of Features Not Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage L2R14)

Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria, Not Designated as Deficient Through CAP Feature ID #

Description Observation Component Resolution Operability 1

Off-Gas Filter Row AA.5 to AD Minor Yes, documented Minor issue requires no Building and Column 12.5 to efflorescence.

in IR 1476976.

follow-up. This wall Basement Wall 14 No sign of active continues to be

_2 leak.

monitored per the Structures Monitoring Program.

2 Unit 2 Auxiliary 21.1-line from R to Signs of past Yes, documented Monitor this location on Building Upper S (E I. 687')

water seepage, in IR 1476383.

the wall for further Basement Wall -

efflorescence.

degradation per the team Tunnel Structures Monitoring Program.

3 Unit 2 Heater Bay Y-line from 19 to Efflorescence Yes, documented Minor issue requires no Upper Basement 3 and 23-line from observed. No in IR 1477490.

follow-up. This wall Exterior Wall (HDT V to Y sign of active continues to be Room) and leak.

monitored per the djacent Wall Structures Monitoring I

Program.

4 Unit 2 Turbine Column 19 to 24 Concrete Yes, documented Engineering action to Building and S to V.

degradation.

in IR 1481478.

continue to monitor this Basement Wall 2 Rebar exposed.

concrete and prepare a Condenser Pit plan (and initiate appropriate actions) to address the condition through the Structures Monitoring program.

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding June 19, 2013 ENCLOSURE 2 Table 2: laSalle County Station, Unit 2 Supplemental list of Features Not Immediately Judged as Acceptable (Restricted Access Features inspected During Outage L2R14)

Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria, Not Designated as Deficient Through CAP Feature ID #

Description Observation Component Resolution Operability 1

Off-Gas Filter Row AA.S to AD Minor Yes, documented Minor issue requires no Building

!and Column 12.5 to efflorescence.

in IR 1476976.

follow-up. This wall Basement Wall 14 No sign of active continues to be f_2 leak.

monitored per the Structures Monitoring Program.

2 nit 2 Auxiliary 21.1-Une from R to Signs of past Yes, documented Monitor this location on uilding Upper S (EI. 687')

water seepage, in IR 1476383.

the wall for further

JsementWali efflorescence.

degradation per the eam Tunnel Structures Monitoring Program.

3 Jnit 2 Heater Bay ~Y-line from 19 to Efflorescence Yes, documented Minor issue requires no Jpper Basement 3 and 23-line from observed. No in IR 1477490.

follow-up. This wall xterior Wall (HO Vto Y sign of active continues to be Room) and leak.

monitored per the Adjacent Wall Structures Monitoring Program.

4 Unit 2 Turbine Column 19 to 24 Concrete Yes, documented Engineering action to Building and S to V.

degradation.

in IR 1481478.

continue to monitor this Basement Wall 2 Rebar exposed.

concrete and prepare a r-Condenser Pit plan (and initiate appropriate actions) to address the condition through the Structures Monitori ** !) "'. V!)' am.