RA-13-081, Proposed Resolution for Completion of the Seismic Walkdowns Associated with NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term.

Proposed Resolution for Completion of the Seismic Walkdowns Associated with NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term.

ML13260A083
Person / Time
Site:	Dresden, Peach Bottom, Oyster Creek, Three Mile Island, Clinton, Quad Cities, LaSalle
Issue date:	09/16/2013
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-13-081, RS-13-213, TMI-13-109
Download: ML13260A083 (36)

Text

1 xelon Generation 10 CFR 50.54(f)

RS-13-213 RA-13-081 TMI-13-109 September 16, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Exelon Generation Company, LLC Proposed Resolution for Completion of the Seismic Walkdowns Associated with NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 2

References:

1. 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, ADAMS Accession Number ML12053A340

2. EPRI Technical Report 1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3:

Seismic", dated June 2012.

3. NRC Memorandum, "Summary of the May 7,2013, Public Conference Call on the Delayed Inspection Items Associated with Japan Lessons-Leamed Near-Term Task Force Recommendation 2.3 Seismic Walkdowns", dated June 5,2013

4. Exelon Generation Company, LLC's 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 27, 2012, Clinton Power Station, Unit 1 (RS-12-165)

5. Exelon Generation Company, LLC's 180-day Response to NRC Request for Information Pursuant to 10 CFA 50.54(f) Regarding Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 27,2012, Dresden Nuclear Power Station, Units 2 and 3 (RS-12-167)

6. Exelon Generation Company, LLC's 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 27, 2012, LaSalle County Station, Units 1 and 2 (RS-12-163)

7. Exelon Generation Company, LLC's 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 19, 2012, Oyster Creek Nuclear Generating Station (RS-12-177)

8. Exelon Generation Company, LLC's 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 19, 2012, Peach Bottom Atomic Power Station, Units 2 and 3 (RS-12-173)

9. Exelon Generation Company, LLC's 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 27,2012, Quad Cities Nuclear Power Station, Units 1 and 2 (RS-12-169)

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 3

10. Exelon Generation Company, LLC's 180-day Response to NRC Request for Information Pursuant to 10 CFR SO.S4(f) Regarding Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 19, 2012, Three Mile Island Nuclear Station, Unit 1 (RS- 12-17S)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a Request for Information (Reference 1) requesting licensees to provide information regarding Recommendation 2.3, Seismic, to support the evaluation of the NRC staff recommendation for the Near-Term Task Force (NTTF) review of the accident at the Fukushima Dai-ichi nuclear facility. In References 4 through 10, Exelon Generation Company, LLC (EGC) submitted the respective Station responses regarding the performance of seismic walkdowns to verify current plant configuration with current seismic licensing basis, and verify the adequacies of monitoring and maintenance procedures. References 4 through 10 contained commitments to complete the walkdowns of inaccessible equipment items, including the internals of certain electrical cabinets, which extended beyond the first refueling outage after the initial walkdowns.

These delayed seismic walkdown commitments generally result from internal cabinet inspection accessibility issues, and the commitment schedules were based on the next planned outage for inspection for this electrical equipment considering the existing plant-specific component outage maintenance schedules. EGC did not schedule additional unplanned equipment outages to support these cabinet interior inspections since NRC/industry guidance did not require circuits to be interrupted or disconnected to gain access to the interior portions of the cabinet.

Based on the May 7,2013, NRC public meeting (Reference 3) on the delayed inspection items associated with NTTF Recommendation 2.3, EGC is providing the NRC requested voluntary letter and proposal for final disposition of the Recommendation 2.3 Seismic Walkdown efforts for the EGC fleet. As described in Attachments 1-11, EGC plans to complete all walkdowns by the end of the fourth quarter 2014. The results of these final seismic walkdown reports will be provided no later than the end of the first quarter 201S.

Since the May 7, 2013, NRC public meeting, EGC has accelerated the delayed walkdown schedules by reviewing the remaining walkdown scope for opportunities where walkdowns could be done at an earlier date based on current planned activities. Additionally, the use of alternate component substitution has been evaluated. The resulting accelerated schedule changes and substitutions are documented in Attachments 1 through 11.

The following provides a summary of the current walkdown scope completion for the EGC fleet:

EGC Fleet General SWEL (Seismic Walkdown Equipment List) Item Inspection Status:

A total of 1943 SWEL items were identified for the combined EGC fleet of seventeen (17) reactor units. To date approximately 100 items remain uninspected. Of the remaining scope of items 1 component will not be inspected by the next Refueling Outage (RFO);

however, this remaining SWEL item will be completed before the end of 2014.

U.S. Nuclear Regulatory Commission NTIF Recommendation 2.3: Seismic September 16, 2013 Page 4 One substitution was made for a SWEL item for Clinton Power Station and is further described in Attachment 1.

EGC Fleet Internal Cabinet Inspection Status:

A total of approximately 525 internal electrical cabinet inspection items were identified for the combined EGC fleet of seventeen (17) reactor units. Of this total, 101 items have been dispositioned as requiring extensive disassembly and therefore, based on NRC clarification provided in the NRC public meeting on May 7,2013 (Reference 3), these items are considered exempt from the walkdown scope. A total of approximately 424 internal electrical cabinet inspections remain in scope for the combined EGC fleet. To date approximately 62 items remain uninspected. Of the remaining items, 26 will not be inspected by the next RFO; however, these remaining 26 internal electrical cabinet inspection items will be completed before the end of 2014.

A total of 18 component substitutions were made for internal electrical cabinet inspection items. These component substitutions were made at Clinton Power Station, Dresden Nuclear Power Station, Units 2 & 3, and Quad Cities Nuclear Power Station, Units 1 & 2, and are further described in Attachments 1, 2,3,9 & 10.

Additionally, for the approximately 362 internal cabinet walkdown inspections that have been performed to date across the EGC fleet, the inspection findings have been limited to non-consequential and foreign material exclusion type issues. No adverse seismic conditions have been identified throughout the EGC fleet.

Based on the summary of the status of the Exelon 2.3 Seismic Walkdowns described above, EGC has determined that the Recommendation 2.3 Seismic Walkdowns for the EGC fleet are considered complete pertaining to the expected completion status of the SWEL items and internal cabinet inspections.

EGC anticipates NRC concurrence on the approach of using substitutions to achieve closure of the Recommendation 2.3 Seismic Walkdowns for the EGC fleet. This approach is justified based on the satisfactory results of the large number of walkdown inspections completed to date and the conclusion that a representative sampling of affected components has been achieved. Therefore, EGC concludes that the intent of the NRC endorsed EPRI Guidance (Reference 2) has been met.

The detailed breakdowns by plant site and unit for expected completions for SWEL items and Internal Cabinet Inspections are provided in Attachments 1 through 11 .

This letter contains new regulatory commitments, which are identified in Attachment 12.

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

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 PageS I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th day of September 2013.

Respectfully,

~ r./~

Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Clinton Power Station, Unit 1 Seismic Walkdown Delayed Inspection Evaluation

2. Dresden Nuclear Power Station, Unit 2 Seismic Walkdown Delayed Inspection Evaluation

3. Dresden Nuclear Power Station, Unit 3 Seismic Walkdown Delayed Inspection Evaluation

4. LaSalle County Station, Unit 1 Seismic Walkdown Delayed Inspection Evaluation

5. LaSalle County Station, Unit 2 Seismic Walkdown Delayed Inspection Evaluation

6. Oyster Creek Nuclear Generating Station Seismic Walkdown Delayed Inspection Evaluation

7. Peach Bottom Atomic Power Station, Unit 2 Seismic Walkdown Delayed Inspection Evaluation

8. Peach Bottom Atomic Power Station, Unit 3 Seismic Walkdown Delayed Inspection Evaluation

9. Quad Cities Nuclear Power Station, Unit 1 Seismic Walkdown Delayed Inspection Evaluation

10. Quad Cities Nuclear Power Station, Unit 2 Seismic Walkdown Delayed Inspection Evaluation

11. Three Mile Island Nuclear Power Station, Unit 1 Seismic Walkdown Delayed Inspection Evaluation

12. Summary of Regulatory Commitments

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 6 cc: Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector

• LaSalle County Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Ms. Jessica A. Kratchman, NRRlJLD/PMB, NRC Mr. Eric E. Bowman, NRRlDPRlPGCB, NRC or Ms. Eileen M. McKenna, NRO/DSRAlBPTS, NRC Ms. Lisa Regner, NRR/JLD/JPMB Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Manager, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Attachments 1 through 12 (29 pages)

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 1 of 29 ATTACHMENT 1 Clinton Power Station, Unit 1 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage Clinton Power Station (CPS), Unit 1 evaluated component availability to determine opportunities where the equipment could be accessible, as well as to determine viable substitutions that could be made allowing earlier access. As a result of this evaluation, nine (9) component substitutions were made. One (1) substitution was made for a Seismic Walkdown Equipment List (SWEL) item, and eight (8) substitutions for the internal cabinet inspection items scheduled for completion after the next unit refueling outage. With these substitutions all SWEL items and internal cabinet inspection items will be completed by the end of 2014. Following refueling outage scheduled for Fall 2013 (C1 R14), these nine (9) items will be completed within the completion schedule discussed in the NRC public meeting of May 7, 2013 (Reference 3).

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I % Complete Items Number I % Complete 124 124 I 100% 29 29 I 100%

Justification for substitutions:

All electrical cabinet substitutions were made using other safety related or seismically designed cabinets. Substitutions were made within the power block at various locations similar to the original electrical cabinets to be inspected. Therefore, the environmental and location diversity remains similar. The substituted items include a 4kV switchgear breaker for the one SWEL item. The internal cabinet inspection items include six (6) motor control centers (MCCs), a battery charger and a control panel. All SWEL and internal cabinet inspection items are being substituted with control panel items. Though these are different classes of equipment in most cases they represent seismically designed electrical equipment being maintained using similar plant procedures and personnel. Therefore the conditions in these panels with respect to configuration and degradation are expected to be similar and representative of the original SWEL items. Additionally, the overall SWEL with the substitutions continues to have representation from every equipment class as the original SWEL.

Notwithstanding the one (1) substituted item; of the 124 SWEL items, there remain several other electrical cabinets that have been inspected. The remaining electrical cabinets have similar configurations that are representative of the expected conditions that would be found for the substituted 1E22S004, 4kV switchgear breaker based on the common maintenance practices and procedures that are applied to all electrical cabinets.

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 2 of 29 For the internal cabinet walkdown inspections that have been performed to date, the inspection findings have been limited to non-consequential and foreign material exclusion type issues. No adverse seismic conditions have been identified.

Based on the satisfactory results and a majority of the walkdown inspections having been completed, EGC concludes that a representative sampling of affected components has been achieved; and thereby) the intent of the NRC endorsed EPRI Guidance (Reference 2) has been met.

Walkdown commitment items 1 and 2 of Enclosure 2 of the CPS submittal dated November 27, 2012 (Reference 4) are expected to be completed by the end of the refueling outage C1 R 14 with exception of the substituted items discussed above and contained in the Tables below, which will be completed by the end of 2014.

Current Status of Delayed* Walkdowns Items:

Current Status of Delayed* Walkdowns Items as identified in the November 2012 Report for SWEL Items (Table E-1) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

Ta bl e A - InaccesslObi e Inspeclon f Items Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. ID Description ID Description Date Required?

480 VOLT UNIT C1R14 1 OAP05E N/A N/A Yes SUBSTATION A (Fall 2013) 480 VOLT UNIT C1R14 2 1AP11E N/A N/A Yes SUBSTATION 1A (Fall 2013) 4160 VOLT C1R14 3 1AP07E N/A N/A Yes SWITCHGEAR 1A1 (Fall 2013) 4160 VAC METALCLAD Yes Control Panel 4 1E22S004 SWITCHGEAR 1C1 1PL65JC 3/31/14 (System (Div 3)

BREAKER Outage)

MAIN STEAM INBOARD C1R14 5 1B21 F022A ISOLATION VALVE- N/A N/A Yes (FaIl2013) 1B21-F022A MAIN STEAM C1R14 6 1B21F028A OUTBOARD ISOLATION N/A N/A Yes (Fall 2013)

VALVE MAIN STEAM C1R14 7 1B21 F041A N/A N/A Yes SAFETY/RELIEF VALVE (Fall 2013)

MAIN STEAM C1R14 8 1B21 F041 D N/A N/A Yes SAFETY/RELIEF VALVE (Fall 2013)

DRYWELL AMBIENT C1R14 9 1E31N017A TEMPERATURE N/A N/A Yes (FaIl2013)

DETECTOR

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 3 of 29 1B21 F041 0 55 GALLON C1R14 10 1B21A003D ACCUMULATOR FOR PR N/A N/A (Fall 2013)

Yes VALVE 1B21F041A 16 GALLON C1R14 11 1B21A004A ACCUMULATOR FOR PR N/A N/A (Fall 2013)

Yes VALVE 1B21F047D 16 GALLON C1R14 12 1B21A004L ACCUMULATOR FOR PR N/A N/A (Fall 2013)

Yes VALVE SRV F041 A DUMP TO C1R14 13 1B21N004A SUP POOL TAILPIPE N/A N/A (Fall 2013)

Yes TEMPERATURE SRV F041 0 DUMP TO C1R14 14 1B21 N004D SUP POOL TAILPIPE N/A N/A (Fall 2013)

Yes TEMPERATURE Current Status of Delayed* Walkdowns Items as identified in the November 2012 Report for Internal Cabinet Inspection Items (Table E-2) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

Ta bl e B - interna Ieab"met Ins pee f Ion Items Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. 10 Description 10 Description Date Required?

Yes DIVISION 2 DAMPERS Control Panel 1 OAP25E 1PL65JB 3/31/14 (System MCCB (Div 2)

Outage)

OAP54EB CONT ROL BU ILDING C1R14 2 N/A N/A (Fall 2013)

Yes MCCE2 1 AP30E SHUTDOWN SERVICE C1R14 3 N/A N/A (Fall 2013)

Yes WATER MCC 1B Yes AUXILIARY BUILDING Control Panel 4 1AP41E 1PL65JA 9/30/14 (System MCC1F (Div 1)

Outage)

Yes AUXILIARY BUILDING Control Panel 5 1AP42E 1PL62J 9/30/14 (System MCC1G (Div 1)

Outage)

Yes Control Panel 6 1AP61E DG BUILDING MCC 1B 1PL12JA 9/30/14 (System (Div 1)

Outage) 1AP73E AUXILIARY BUILDING C1R14 7 N/A N/A (Fall 2013)

Yes MCC 1A2 Yes Control Panel 8 1DC14E 125V DC MCC 1B 1PL63J 9/30/14 (System (Div 1)

Outage)

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 4 of 29 Yes Control Panel 9 1DC15E 125V DC MCC 1D 1PL43JA 9/30/14 (System (Div 1)

Outage)

Yes 125V BATTERY Control Panel 10 1DC07E 1PL43JB 3/31/14 (System CHARGER1B (Div 2)

Outage)

HPCS DIESEL-Yes GENERATOR Control Panel 11 1H22P028 1PL64J 3/31/14 (System PROTECTIVE RELAY (Div 3)

Outage)

PANEL Summary:

Inspections of the components listed above will be completed by September 30, 2014. The final seismic walkdown report documenting the results of these inspections will be submitted by December 31,2014. This new regulatory commitment replaces existing regulatory commitment items 1 and 2 of Enclosure 2 of the CPS submittal dated November 27,2012 (Reference 4).

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 5 of 29 ATTACHMENT 2 Dresden Nuclear Power Station, Unit 2 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage, Dresden Nuclear Power Station Unit 2 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made allowing earlier access. After exploring these options four (4) substitutions are planned for the internal cabinet inspection items originally scheduled for completion after the next unit refueling outage.

With these substitutions all SWEL items and internal cabinet inspection items will be completed before the next RFO and by the end of 2014.

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I %Complete 103 103 I 100% 32 32 I 100%

Justification for substitutions:

With one exception, all internal electrical cabinet inspection substitutions made are done using other same class 480 V AC electrical cabinets having similar configurations and are safety related or seismically designed. In one case a 480 V AC electrical cabinet is being substituted for a 4kV switchgear electrical cabinet. Though these are different classes of equipment both are seismically designed electrical equipment being maintained using similar plant procedures and personnel and therefore the conditions in these panels with respect to configuration and degradation are expected to be similar and representative of the original SWEL items. All substitutions are within the power block at various locations similar to the electrical cabinets being substituted for. Therefore, the environmental and location diversity remains similar.

Based on the discussion above EGC concludes that the intent of the NRC endorsed EPRI Guidance (Reference 2) has been met.

Walkdown commitment items 1 & 3 of Enclosure 3 of the Dresden Nuclear Power Station NRC Submittal dated November 27,2012 (Reference 5) are expected to be completed by the end of 2014 including the substituted items discussed above and contained in the Tables below.

Current Status of Delayed* Walkdowns Items:

There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1).

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Dresden Unit 2 RFO is D2R23 (Fall 2013).

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 6 of 29 Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Dresden Unit 2 RFO is D2R23 (Fall 2013).

Tabl e B - interna Ieab"met Ins )ecf Ion Items Substitute Current Equipment Equipment Substitute Committed Outage No. 10 Description 10 OescriQjion Walkdown Date Required?

480VAC 002-7828-7--

1

--M05 480V ACI MCC 28-7 TaO*** Electrical 3/31/14 No Cabinet 002-8302A-- 250V DCI MCC Bus #2A 2

---M05 (ROB-RB MCC #2)

N/A N/A Complete N/A D02-8302B-- 250V OCI MCC Bus #2B 3

---M05 (ROB-RB MCC #2)

N/A N/A Complete N/A 125V DCI TB Battery Bus 002-83125-4 2---P06

1. 2, Feed to Main Bus #2A- N/A N/A Complete N/A 1

002-83125--- 125V DCI RB 125V DC 5

--P06 Distribution Panel #2 N/A N/A Complete N/A Extensive 6

D02-9802-A- 24/48V DCI Distribution N/A N/A Disassembly N/A

---P06 Panel #2A Required 480VAC 002-7328----

7

--S35 480V ACI Switchgear 28 TaO*** Electrical 3/31/14 No Cabinet 480VAC 002-7329----

8

--S35 480V ACI Switchgear 29 TaO*** Electrical 3/31/14 No Cabinet 480VAC 002-6723----

9

--S35 4160V ACI Switchgear 23 TaO*** Electrical 3/31/14 No Cabinet Item Included in 002-7329---- 480V ACI Transformer 29, 10

--T10 Feed to Switchgear 29 N/A N/A error. This is a N/A transformer.

002-83250- 250V DCI Breaker to TB 11 A01-M05 MCC #2 (ROB-Battery #2)

N/A N/A Complete N/A Extensive 12 002-9802A- 24/48V OCI Breaker to N/A N/A Disassembly N/A A21-B11 Battery Charger #2A (+)

Required 13 000-83250- 250V DCI Battery Charger N/A N/A Complete N/A 0---B05 #2/3 14 002-8300-- 125V OCI Battery Charger 2A--B05 #2A N/A N/A Complete N/A 15 002-8300- 125V DCI Battery Charger

--B05 #2 N/A N/A Complete N/A

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 7 of 29 16 CONTROL PANEU OG 000-2223-Relaying and Metering N/A N/A Complete N/A 0033 Cabinet 17 000-2223- CONTROL PANEU OG N/A N/A Complete N/A 0041 Excitation Cabinet 18 002-0902- CONTROL PANELSI N/A N/A Complete N/A 0041 Control Panel 902-41 19 CONTROL PANEU OG 002-2252-Metering and Relay N/A N/A Complete N/A 0010 Cabinet 20 002-2252- CONTROL PANEU OG N/A N/A Complete N/A 0021 Excitation Cabinet 21 Item included in 002-2380---- HPCII HPCI Turbine N/A N/A error. This is a N/A

--PSH Pressure Switch switch.

22 CONTROLPANEUUn~2 002-0GCP Diesel Generator Control N/A N/A Complete N/A Panel 23 002-NGC (This is CONTROL PANEU Unit 2 assumed to N/A N/A Complete N/A Neutral Grounding Cabinet be EPN 2-6600-NGT) 24 D02-2202- INSTRUMENT RACKSI N/A N/A Complete N/A 0073A Instrument Rack 2202-73A 25 002-2252- INSTRUMENT RACKSI N/A N/A Complete N/A 0084 Instrument Rack 2252-84 26 Item Included in 002-0302- CROI West Bank SOV N/A N/A error. This is a N/A 0082A-LS Tank Level Switch switch.

• • • 480V AC electrical cabinets will be substituted for the original internal cabinet inspection items. Due to unknowns related to operational availability to inspect the 480 V AC cabinets, specific equipment IDs are TBO. In some cases partial inspections will be made. The actual equipment 10 inspected will be documented in the Final Report submitted to the NRC.

Summary:

Inspections of the components listed above will be completed by March 31,2014. The final seismic walkdown report documenting the results of these inspections will be submitted by June 30, 2014. This new regulatory commitment replaces existing regulatory commitment item 3 of Enclosure 3 of the Oresden Nuclear Power Station NRC Submittal dated November 27, 2012 (Reference 5).

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 8 of 29 ATTACHMENT 3 Dresden Nuclear Power Station, Unit 3 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage, Dresden Nuclear Power Station Unit 3 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made with earlier access. After exploring these options four (4) substitutions are planned for the internal cabinet inspection items originally scheduled for completion after the next unit refueling outage. With these substitutions all SWEL items and internal cabinet inspection items will be completed before the next RFO and by the end of 2014.

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I % Complete 103 103 I 100% 33 33 I 100%

Justification for substitutions:

With one exception, all internal electrical cabinet inspection substitutions made are done using other same class 480 V AC electrical cabinets having similar configurations and are safety related or seismically designed. In one case a 480 V AC electrical cabinet is being substituted for a 4kV switchgear electrical cabinet. Though these are different classes of equipment both are seismically designed electrical equipment being maintained using similar plant procedures and personnel and therefore the conditions in these panels with respect to configuration and degradation are expected to be similar and representative of the original SWEL items. All substitutions are within the power block at various locations similar to the electrical cabinets being substituted for. Therefore, the environmental and location diversity remains similar.

Based on the discussion above EGC concludes that the intent of the NRC endorsed EPRI Guidance (Reference 2) has been met.

Walkdown commitment items 2 & 4 of Enclosure 3 of the Dresden Nuclear Power Station NRC Submittal dated November 27, 2012 (Reference 5) are expected to be completed by the end of 201 4 including the substituted items discussed above and contained in the Tables below.

Current Status of Delayed* Walkdowns Items:

There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1). All items are complete.

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Dresden Unit 3 RFO is D3R23 (4QTR2014).

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 9 of 29 Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Dresden Unit 3 RFO is D3R23 (4QTR2014).

Tabl e B - Interna Ieab"met ns~ectlon tems Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. 10 Description ID Description Date Required?

003-7838-2--

1

--M05 480V ACI MCC 38-2 N/A N/A Complete N/A 480VAC 003-7839-2--

2

--M05 480V ACI MCC 39-2 TBD*1>'It Electrical 3/31/14 No Cabinet 003-8303A-- 250V DCI MCC Bus #3A 3

---M05 (ROB-RB MCC #3)

N/A N/A Complete N/A 003-8303B-- 250V OCI MCC Bus #3B 4

---M05 (ROB-RB MCC #3)

N/A N/A Complete N/A 003-83125--- 125V OCI RB 125V DC 5

Distribution Panel #3 N/A N/A Complete N/A

--P06 Extensive 6

D03-9802-A- 24/48V DCI Distribution N/A N/A Disassembly N/A

---P06 Panel#3A Required 480VAC 003-7338----

7

--S35 480V ACI Switchgear 38 TBDI>'It* Electrical 3/31114 No Cabinet 480VAC 8

003-7339---- 480V ACI 480V Switchgear TBD*1>'It Electrical 3/31/14 No

--S35 39 Cabinet 480VAC 003-6734-1--

9

---S35 4160V ACI Switchgear 34-1 TBD*1>'It Electrical 3/31/14 No Cabinet Item Included 003-7338---- 480V ACI Transformer 38, 10

--T10 Feed to Switchgear 38 N/A N/A in error. This is N/A a transformer.

003-83250- 250V DCI Breaker to TB 11 MCC #3 (ROB-Battery #3)

N/A N/A Complete N/A A01-M05 Extensive 12 003-9802A- 24/48V OCI Breaker to N/A N/A Disassembly N/A A21-B11 Battery Charger #3A (+)

Required 003-8300-- 125V OCI Battery Charger 13 3A--B05 #3A N/A N/A Complete N/A 003-8300- 125V OCI Battery Charger 14

--B05 #3 N/A N/A Complete N/A 003-83250- 250V DCI Battery Charger 15 3---B05 #3 N/A N/A Complete N/A

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 10 of 29 CONTROL PANEU OG 000-2223-16 Cooling Pump Transfer N/A N/A Complete N/A 0109 Switch Status CONTROL PANEU Unit 2/3 17 OOO-ACP N/A N/A Complete N/A AuxiliaJY Control Panel CONTROL PANEU Unit 2/3 18 DOO-DGCP Diesel Generator Control N/A N/A Complete N/A Panel DOO-NGC (This is CONTROL PANEU Unit 2/3 19 assumed to Neutral Grounding Cabinet N/A N/A Complete N/A be EPN 2/3-6600-NGT) 003-2253- CONTROL PANEU DG 20 0010 Metering and Relay Cabinet N/A N/A Complete N/A 003-2253- CONTROL PANEU DG 21 0021 Excitation Cabinet N/A N/A Complete N/A Item included D03-2380---- HPCI/ HPCI Turbine 22 N/A N/A in error. This is N/A

--PSH Pressure Switch High a switch.

D03-7838 DISTRIBUTION PANELSI 23 1--P06 Distribution Panel 38-1-1 N/A N/A Complete N/A CONTROL PANEU Unit 3 24 D03-DGCP Diesel Generator Control N/A N/A Complete N/A Panel D03-NGC (This is CONTROL PANEU Unit 3 25 assumed to Neutral Grounding Cabinet N/A N/A Complete N/A be EPN 3-6600-NGT)

D03-2203- INSTRUMENT RACKSI 26 N/A N/A Complete N/A 0073A Instrument Rack 2203-73A D03-2253- INSTRUMENT RACKSI 27 0084 Instrument Rack 2253-84 N/A N/A Complete N/A

• • • 480V AC electrical cabinets will be substituted for the original internal cabinet inspection items. Due to unknowns related to operational availability to inspect the 480 V AC cabinets, specific equipment IDs are TBD. In some cases partial inspections will be made. The actual equipment ID inspected will be documented in the Final Report submitted to the NRC.

Summary:

Inspections of the components listed above will be completed by March 31, 2014. The final seismic walkdown report documenting the results of these inspections will be submitted by June 30, 2014. This new regulatory commitment replaces existing regulatory commitment item 4 of Enclosure 3 of the Dresden Nuclear Power Station NRC Submittal dated November 27, 2012 (Reference 5) .

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 11 of 29 ATTACHMENT 4 LaSalle County Station, Unit 1 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage laSalle County Station, Unit 1 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made with earlier access. With these efforts three (3) internal cabinet inspection items will be completed earlier, by the end of 2014.

Though after the refueling outage, these three (3) items will be completed within the NRC's overall desired completion schedule as discussed in the NRC public meeting of May 7,2013 (Reference 3).

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I % Complete 116 116 I 100% 23 23 I 100%

Walkdown commitment items 1 & 3 of Enclosure 3 of the LaSalle County Station NRC Submittal dated November 27,2012 (Reference 6) are expected to be completed by the end of 2014.

Current Status of Delayed* Walkdowns Items:

There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1).

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For LaSalle Unit 1 RFO is L 1R15 (1 QTR2014).

Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For LaSalle Unit 1 RFO is L1R15 (1QTR2014).

Tabl e B - interna I Cab"met Inspeclon f Items Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. ID Description ID Description Date Required?

L1R15 1 1AP71E DIV I 480V MCC 135X-1 N/A N/A (Spring 2014)

Yes L1R15 2 1AP73E DIV I 480V MCC 135X-3 N/A N/A (Spring 2014)

Yes

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 12 of 29 3 1AP78E DIV II 480V MCC 136X-1 N/A N/A 6/1/14 No 4 1AP81E DIV II 480V MCC 136X-3 N/A N/A 6/1/14 No L1R15 5 1DC005E 250V MCC N/A N/A (Spring 2014)

Yes L1R15 6 1AP15E 480V SWGR 133 N/A N/A (Spring 2014)

Yes L1R15 7 1AP19E DIV I 480V SWGR 135X N/A N/A Yes (Spring 2014) 8 1AP21E DIV II 480V SWGR 136X N/A N/A 6/1/14 No N/A -

Extensive 9 1AP06E-9 TRANSFORMER, 136X N/A N/A Disassembly N/A Required 1AP19E- L1R15 10 102B TRANSFORMER, 135X N/A N/A (Spring 2014)

Yes DIV I 250VDC L1R15 11 1DC02E DISTRIBUTION BUS 1 N/A N/A (Spring 2014)

Yes 125VDC DISTRIBUTION L1R15 12 1DC12E PANEL 112X N/A N/A (Spring 2014)

Yes DIV II 125VDC L1R15 13 1DC15E DISTRIBUTION BUS 1B N/A N/A (Spring 2014)

Yes 250V DC BATTERY L1R15 14 1DC003E CHARGER NO.1 N/A N/A (Soril}g2014)

Yes 125V DC BATTERY L1R15 15 1DC16E CHARGER NO. 1B N/A N/A (Spring 2014)

Yes B/C RHR PUMP ROOM N/A N/A L1R15 16 1PL33J Yes VENTILATION PANEL (Spring 2014)

A RHR PUMP ROOM L1R15 17 1PL34J VENTILATION PANEL N/A N/A (Spring 2014)

Yes LPCS PUMP ROOM L1R15 18 1PL35J VENTILATION PANEL N/A N/A (Spring 2014)

Yes Summary:

Inspections of the components listed above will be completed by June 1, 2014. The final seismic walkdown report documenting the results of these inspections will be submitted by August 28, 2014. This new regulatory commitment replaces existing regulatory commitment item 3 of Enclosure 3 of the LaSalle County Station NRC Submittal dated November 27,2012 (Reference 6).

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 13 of 29 ATTACHMENT 5 LaSalle County Station, Unit 2 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage LaSalle County Station, Unit 2 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made with earlier access. With these efforts four (4) internal cabinet inspection items will be completed earlier, by the end of 2014.

Though after the refueling outage, these four (4) items will be completed within the NRC's overall desired completion schedule as discussed in the NRC public meeting of May 7, 2013 (Reference 3).

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I % Complete 115 115 I 100% 23 23 I 100%

Walkdown commitment items 2 & 4 of Enclosure 3 of the LaSalle County Station NRC Submittal dated November 27,2012 (Reference 6) are expected to be completed by the end of 2014.

Current Status of Delayed* Walkdowns Items:

There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1). All items are complete.

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For LaSalle Unit 2 RFO is L2R14 (1QTR2013).

Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For LaSalle Unit 2 RFO is L2R14 (1 QTR2013).

Tabl e B - Interna Ieab"!net nspectlon tems Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. ID Description ID Description Date Required?

1 2AP71E DIV 1480V MCC 235X-1 N/A N/A 6/1/14 No 2 2AP73E DIV I 480V MCC 235X-3 N/A N/A 6/1/14 No 3 2AP78E DIV II 480V MCC 236X-1 N/A N/A Complete N/A

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 14 of 29 4 2AP81E DIV II 480V MCC 236X-3 N/A N/A Complete N/A 5 2DC05E 250VDC MCC 221X N/A N/A Complete N/A 6 2AP15E 480V SWGR 233 N/A N/A 6/1/14 No 7 2AP19E DIV I 480V SWGR 235X N/A N/A 6/1/14 No 8 2AP21E DIV II 480V SWGR 236X N/A N/A Complete N/A N/A -

2AP19E- Extensive 9 TRANSFORMER, 235X N/A N/A Disassembly N/A 103B Required 2AP21 E-10 303B TRANSFORMER, 236X N/A N/A Complete N/A DIV 1250 VDC 11 2DC02E DISTRIBUTION BUS 2 N/A N/A Complete N/A DIV II 125VDC 12 2DC13E DISTRIBUTION PANEL N/A N/A Complete N/A 212Y DIV II 125VDC 13 2DC15E DISTRIBUTION BUS 2B N/A N/A Complete N/A 250VDC BATTERY 14 2DC03E CHARGER N/A N/A Complete N/A DIV II 125VDC BATTERY 15 2DC16E CHARGER 2BB N/A N/A Complete N/A ASSY - PANEL, RHR B/C N/A N/A N/A 16 2PL33J Complete CUBE VENT ASSY - PANEL, RHR A 17 2PL34J CUBE VENT N/A N/A Complete N/A ASSY - PANEL, LPCS 18 2PL35J CUBE VENT N/A N/A Complete N/A Summary:

Inspections of the components listed above will be completed by June 1, 2014. The final seismic walkdown report documenting the results of these inspections will be submitted by August 28, 2014. This new regulatory commitment replaces existing regulatory commitment item 4 of Enclosure 3 of the LaSalle County Station NRC Submittal dated November 27,2012 (Reference 6).

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 15 of 29 ATTACHMENT 6 Oyster Creek Nuclear Generating Station Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage Oyster Creek Nuclear Generating Station explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made allowing earlier access. With these efforts earlier completion of one (1) SWEL inspection item will be completed by the end of 2014.

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Totallntemal Internal Cabinet Inspection SW EL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I % Complete 117 117 I 100% 16 16 I 100%

Without exceptions taken, all walkdown commitment items 1 & 2 of Enclosure 2 of the Oyster Creek Nuclear Generating Station NRC Submittal dated November 19, 2012 (Reference 7), are expected to be completed by the end of the next refueling outage and by the end of 2014. No further justification is required.

Current Status of Delayed* Walkdowns Items:

Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Oyster Creek RFO is OC1R25 (3QTR2014 to 4QTR2014).

Tabl e A - Inaccessl'ble Inspectlon terns Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. ID Description ID Description Date Required?

SAFETY RELIEF VALVE 1 V-1-160 N/A N/A Complete N/A NR28D (SOUTH HEADER)

SAFETY RELIEF VALVE 2 V-1-164 N/A N/A Complete N/A NR28H (NORTH HEADER)

ELECTROMATIC RELIEF 3 V-1-173 VALVE NR108-A(SOUTH N/A N/A Complete N/A HEADER)

ELECTROMATIC RELIEF 4 V-1-175 VALVE NR108-C(NORTH N/A N/A Complete N/A HEADER)

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 16 of 29 ELECTROMATIC RELIEF 5 V-1-177 VALVE NR108-E(SOUTH N/A N/A Complete N/A HEADER)

CU INLET ISOLATION 6 V-16-1 VALVE FROM REACTOR N/A N/A Complete N/A VESSEL MAIN STEAM LINE 'A' 7 V-1-106 DRAIN VALVE N/A N/A Complete N/A MAIN STEAM L1NE'A' 8 V-1-7 OUTLET ISOLATION N/A N/A Complete N/A VALVE(NS03-A)

MSIV'S SOLENOID AIR 9 RK-411-1 VALVE & EQUIPMENT N/A N/A Complete N/A MOUNTING RACK MAIN STEAM LlNE'B' 10 V-1-10 OUTLET ISOLATION N/A N/A Complete N/A VALVE(NS04-B)

MCC 1A21 11 1A21-460V 460V,3PH,3W,60HZ FOR N/A N/A Complete N/A TURBINE BUILDING MCC 1A21B 12 1A21B-460V 460V,3P,3W,60HZ FOR N/A N/A Complete N/A REACTOR BUILDING MeC 1A23 13 1A23-460V 460V,3PH,3W,60HZ FOR N/A N/A Complete N/A REACTOR BUILDING 460V UNIT SUBSTATION 14 1A2-460V 1A2 FOR REACTOR N/A N/A Complete N/A BUILDING 4160V BUS 1C 15 1C N/A N/A Complete N/A SWITCHGEAR 125VDC POWER PANEL Bus 16 DC-C 125V DC-C CENTER 'C' N/A N/A 12/31/14 Outage There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2). All items are complete.

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Oyster Creek RFO is OC1R25 (3QTR2014 to 4QTR2014).

Summary:

Inspections of the components listed above will be completed by December 31, 2014. The final seismic walkdown report documenting the results of these inspections will be submitted by March 31, 2015. This new regulatory commitment replaces existing regulatory commitment item 1 of Enclosure 2 of the Oyster Creek Nuclear Generating Station NRC Submittal dated November 19, 2012 (Reference 7) .

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16,2013 Page 17 of 29 ATTACHMENT 7 Peach Bottom Atomic Power Station, Unit 2 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage Peach Bottom Atomic Power Station, Unit 2 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made with earlier access. With these efforts one (1) internal cabinet inspection item will be completed earlier, by the end of 2014.

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I % Complete 114* 114* I 100% 33 33 I 100%

• including common unit items Walkdown commitment items 1 & 2 of Enclosure 3 of the Peach Bottom Atomic Power Station NRC Submittal dated November 19, 2012 (Reference 8) are expected to be completed by the end of the next Unit 2 refueling outage and by the end of 2014.

Current Status of Delayed* Walkdowns Items:

There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1). All items are complete.

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Peach Bottom Unit 2 RFO is P2R20 (40TR2014).

Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Tables E-2 and E-3) are given in the Table below:

• Scheduled to complete after the un irs first refueling outage after the November 2012 NRC transmittal.

For Peach Bottom Unit 2 RFO is P2R20 (40TR2014).

Table B -Internal Cabinet Items Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. 10 Description ID Description Date Required?

Yes 1 2AD003 Battery Charger 2A N/A N/A 5/25/1 4 (Bus Outage)

Yes 2 200003 Battery Charger 20 N/A N/A 7/31/14 (Bus Outage)

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 18 of 29 Diesel Generator OAG12 3 OAC097 Control Panel N/A N/A 12131/13 No Summary:

Inspections of the components listed above will be completed by September 30, 2014. The final seismic walkdown report documenting the results of these inspections will be submitted by December 31 ,2014. This new regulatory commitment replaces existing regulatory commitment item 2 of Enclosure 3 of the Peach Bottom Atomic Power Station NRC Submittal dated November 19, 2012 (Reference 8).

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 19 of 29 ATTACHMENT 8 Peach Bottom Atomic Power Station, Unit 3 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage Peach Bottom Atomic Power Station, Unit 3 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made with earlier access. With these efforts one (1) internal cabinet inspection item will be completed earlier, by the end of 2014. Two (2) internal cabinet inspections will be completed after the current refueling outage, but before the end of 2014. Though after the refueling outage, these two (2) items will be completed within the NRC's overall desired completion schedule discussed in the NRC public meeting of May 7,2013 (Reference 3).

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SW EL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I % Complete 122* 122* I 100% 39 39 I 100%

• including common unit items Walkdown commitment items 3 & 4 of Enclosure 3 of the Peach Bottom Atomic Power Station NRC Submittal dated November 19, 2012 (Reference 8) are expected to be completed by the end of 2014.

Current Status of Delayed* Walkdowns Items:

There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1).

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Peach Bottom Unit 3 RFO is P3R19 (4QTR2013).

Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Peach Bottom Unit 3 RFO is P3R19 (4QTR2013).

Tabl e B - nterna I CabOmet nspectlon terns Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. ID Description ID Description Date Required?

MO-3-23-01S Motor Control P3R19 1 30B324 N/A N/A Yes Power Transfer Switch (Fall 2013)

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 20 of 29 MO-3-13-15 Motor Control P3R19 2 30B325 Starter Panel N/A N/A (Fall 2013)

Yes 120V Inst. Panel 30Y035 Yes 3 30S703 Transfer Switch N/A N/A 7/31/14 (Bus Outage) 4 3CD003 Battery Charger 3C N/A N/A Complete N/A 5 3DD003 Battery Charger 3D N/A N/A Complete N/A Diesel Generator OAG 12 6 OAC097 Control Panel N/A N/A 12131/13 No Summary:

Inspections of the components listed above will be completed by September 30, 2014. The final seismic walkdown report documenting the results of these inspections will be submitted by December 31, 2014. This new regulatory commitment replaces existing regulatory commitment item 4 of Enclosure 3 of the Peach Bottom Atomic Power Station NRC Submittal dated November 19, 2012 (Reference 8).

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 21 of 29 ATTACHMENT 9 Quad Cities Nuclear Power Station, Unit 1 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage Quad Cities Nuclear Power Station, Unit 1 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made with earlier access. After exploring these options, a substitution was found for an internal cabinet inspection that could be performed prior to the end of the next unit refueling outage. Bus 19 will be substituted for Switchgear 13-1 .

Additionally, several internal cabinet inspection item schedules have been improved to now all complete by April 26, 2014. Currently, three (3) remain that will complete after the last Unit 1 refueling outage, by April 26, 2014 (Table B). Though after the refueling outage, these three (3) items will be completed within the NRC's overall desired completion schedule, by the end of 2014, discussed in the NRC public meeting of May 7,2013 (Reference 3).

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I % Com~ete Items Number I % Complete 104 104 I 100% 23 23 1 100%

Justification for Substitution:

Although Switchgear 13-1 and Bus 19 are not in the same equipment class, the cabinets have similar configurations in the mounting of internal components. Both are safety related and seismically designed. The equipment is located in the near vicinity of one another. Therefore, the environmental and location diversity remains similar.

Based on the discussion above EGC concludes that the intent of the NRC endorsed EPRI Guidance (Reference 2) has been met.

Walkdown commitment items 1 & 3 of Enclosure 3, of the Quad Cities Nuclear Power Station NRC Submittal dated November 27, 2012 (Reference 9) are expected to be completed by the end of 2014.

Current Status of Delayed* Walkdowns Items:

There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1). All items are complete.

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Quad Cities Unit 1 RFO is Q1 R22 (1 QTR2013) .

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 22 of 29 Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Quad Cities Unit 1 RFO is Q1 R22 (1 QTR2013).

Ta bl e B - interna Iea b"met Inspeclon f Items Current Substitute Committed Equipment Substitute Walkdown Outage No. Equipment ID Description ID Description Date Required?

1 1-7800-18195 MCC -MCC 18/19-5 N/A N/A Complete N/A 2 1-7800-18-1 B MCC - MCC 18-1 B N/A N/A Complete N/A 3 1-7800-18-2 MCC - MCC 18-2 N/A N/A Complete N/A 4 1-7800-19-1 MCC - MCC 19-1 N/A N/A Complete N/A 250VDC MCC 5 MCC N/A N/A Complete N/A 1

250VDC MCC 6 MCC N/A N/A Complete N/A 1A 7 1-7100-18 SWGR 18 N/A N/A Complete N/A 8 1-6705-13-1 SWGR 13-1 1-7200-19 Bus 19* 4/26/14 No 9 901-61 PNL, CONTROL N/A N/A Complete N/A 10 901-62 PNL, CONTROL N/A N/A Complete N/A 11 1-8300-1 CHRGR #1, 125V N/A N/A Complete N/A 12 1-8350 CHRGR #1, 250V N/A N/A Complete N/A RACK, AUTO 13 2201-32 N/A N/A Complete N/A BLOWDOWN 14 2201-73A RACK N/A N/A Complete N/A RACK, U-1 DG RELAY 15 2251-10 N/A N/A Complete N/A

& METERING RACK, DG ENGINE 16 2251-113 N/A N/A Complete N/A CONTROL 17 2251-86 RACK N/A N/A 4/26/14 No 18 2251-87 RACK N/A N/A 4/26/14 No

• Accessible cubicles will be inspected.

Summary:

Inspections of the components listed above will be completed by April 26, 2014. The final seismic walkdown report documenting the results of these inspections will be submitted by July 30, 2014. This new regulatory commitment replaces existing regulatory commitment item 3 of Enclosure 3, of the Quad Cities Nuclear Power Station NRC Submittal dated November 27, 2012 (Reference 9).

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 23 of 29 ATT ACHMENT 10 Quad Cities Nuclear Power Station, Unit 2 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage Quad Cities Nuclear Power Station, Unit 2 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made with earlier access. After exploring these options, a substitution was found for an internal cabinet inspection that could be performed prior to the end of the next unit refueling outage. Switchgear 24-1 will be substituted for Switchgear 23-1.

Additionally, several internal cabinet inspection item schedules have been improved to now all complete by April 26, 2014. Currently, three (3) delayed items remain that will complete by the end of the next refueling outage, and are listed in Table B.

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I % Complete 102 102 I 100% 23 23 I 100%

Justification for Substitution:

Both Switchgear 24-1 and Switchgear 23-1 are in the same equipment class and have similar configurations in the mounting of internal components. Both are safety related and seismically designed. The equipment is located in the near vicinity of one another. Therefore, the environmental and location diversity remains similar.

Based on the discussion above EGC concludes that the intent of the NRC endorsed EPRI Guidance (Reference 2) has been met.

All walkdown commitment items 2 & 4 of Enclosure 3, of the Quad Cities Nuclear Power Station NRC Submittal dated November 27,2012 (Reference 9) are expected to be completed by the end of the next Unit 2 refueling outage with the one switchgear substitution described above.

No further justification is required.

Current Status of Delayed* Walkdowns Items:

There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1).

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Quad Cities Unit 2 RFO is Q2R22 (2QTR201 4).

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 24 of 29 Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For Quad Cities Unit 2 RFO is Q2R22 (2QTR2014).

Tabl e B - it n erna Ieab'met Inspeclon f It ems Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. ID Description ID Description Date Required?

250VDC 1 MCC N/A N/A Complete N/A MCC2 250VDC 2 MCC N/A N/A Complete N/A MCC2A 2-7800 3 MCC - MCC 28-18 N/A N/A Complete N/A 18 4 2-7800-28-2 MCC - MCC 28-2 N/A N/A Complete N/A 2-7800-5 MCC - MCC 28/29-5 N/A N/A Complete N/A 28295 6 2-7800-29-1 MCC - MCC 29-1 N/A N/A Complete N/A 7 2-7100-28 SWGR 28 N/A N/A Complete N/A Q2R22 Yes 8 2-6705-23-1 SWGR 23-1 2-6706-24-1 SWGR 24-1 (Spring 2014) 9 902-61 PNL, CONTROL N/A N/A Complete N/A 10 902-62 PNL, CONTROL N/A N/A Complete N/A 11 2-8300-2 CHRGR #2, 125V N/A N/A Complete N/A 12 2-8350 CHRGR #2, 250V N/A N/A Complete N/A RACK,AUTO 13 2202-32 N/A N/A Complete N/A 8LOWDOWN 14 2202-73A RACK, ANALOG TRIP N/A N/A Complete N/A RACK, 1/2 DG ENGINE 15 2212-125 N/A N/A Complete N/A CONTROL 16 2212-32 Wall mounted Panel DG N/A N/A Complete N/A 17 2252-86 RACK N/A N/A 4/26/14 No 18 2252-87 RACK N/A N/A 4/26/14 No Summary:

Inspections of the components listed above will be completed by April 26, 2014. The final seismic walk down report documenting the results of these inspections will be submitted by July 30, 2014. This new regulatory commitment replaces existing regulatory commitment item 4 of Enclosure 3, of the Quad Cities Nuclear Power Station NRC Submittal dated November 27, 2012 (Reference 9).

u.s. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 25 of 29 ATTACHMENT 11 Three Mile Island Nuclear Station, Unit 1 Seismic Walkdown Delayed Inspection Evaluation In an effort to complete the subject walkdowns by the next unit refueling outage Three Mile Island Nuclear Station, Unit 1 explored options by looking for earlier opportunities where the equipment might be accessible as well as viable substitutions that could be made allowing earlier access.

The efforts described above have resulted in the expected completion of all SWEL and internal cabinet inspection walkdown items by the end of 2014 as summarized in the table below.

Total Internal Internal Cabinet Inspection SWEL Items to Complete Total SWEL Cabinet Items to Complete by End of 2014 Items Inspection by End of 2014 Number I  % Complete Items Number I % Complete 106 106 I 100% 32 32 J 100%

Without exceptions taken, all walkdown commitment items 1 & 2 of Enclosure 2 of the Three Mile Island Nuclear Station NRC Submittal dated November 19, 2012 (Reference 10), are expected to be completed by the end of the next Unit 1 refueling outage and before the end of 2014. No further justification is required.

Current Status of Delayed* Walkdowns Items:

Current Status of Delayed* Walkdowns Items as identified in the November 2012 Reports for SWEL Items (Table E-1) are given in the Table below:

• Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal .

For TMI RFO is T1 R20 (4QTR2013).

Tabl e A - InaccesslObi e Inspeclon f Items Current Substitute Committed Equipment Equipment Substitute Walkdown Outage No. ID Description ID Description Date Required?

T1R20 1 DH-T-001 BWST N/A N/A (Fall 2013)

Yes 480V ENGINEERED T 1R20 2 1B-480V-ES SAFEGUARDS MCC 1 B N/A N/A (Fall 2013)

Yes 1B ENGINEERED 1B-480V- SAFEGUARDS VALVES & T1R20 3

ESV HEATING N/A N/A (Fall 2013)

Yes CONTROL CENTER 480V SCREEN HOUSE 1B-480V- T1R20 4 ENGINEERED N/A N/A (Fall 2013)

Yes SHES SAFEGUARDS MCC 1B

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 26 of 29 5 SF-P-1B-BK 1B ES MCC UNIT 6A N/A N/A Complete N/A 1S-480V-ES- 480V ENGINEERED T1R20 6

SAFEGUARDS BUS 1S N/A N/A (Fa1l2013)

Yes SWGR 1T-480V- 480V ENGINEERED T1R20 7 SHES- SAFEGUARDS SCREEN N/A N/A (Fall 2013)

Yes SWGR HOUSE BUS 1T 1E-4160V- 4160V ENGINEERED 8 N/A N/A Complete N/A ES SAFEGUARDS BUS 1E 1S-480V-ES- 1S 480V ES SWGR T1R20 9

4160/480V XFMR N/A N/A (Fa1l2013)

Yes XFMR 1T-480V- 1T 480V SCREEN HOUSE T1R20 10 SHES- ES SWGR 4160/480V N/A N/A (Fall 2013)

Yes XFMR XFMR 125/250V DC ES DIST 11 1F-DC PANEL1F N/A N/A Complete N/A 125/250VDC DIST PANEL 12 1Q-DC N/A N/A Complete N/A FOR EDG 1B DIESEL GEN 1B - ENGINE N/A 13 1B DG CNPL CONTROL RELAY PANEL N/A N/A Complete CONTROL RM CONSOLE 14 CC CENTER CONTROL N/A N/A Complete N/A PANEL 125/250V DC DIST PANEL N/A 15 EED-PNL-1B N/A N/A Complete 18 There are no Delayed* Walkdowns Items as identified in the November 2012 Reports for Internal Cabinet Inspection Items (Table E-2). All items are complete.

"Scheduled to complete after the unit's first refueling outage after the November 2012 NRC transmittal.

For TMI RFO is T1 R20 (4QTR2013).

Summary:

Inspections of the components listed above will be completed by December 31, 2013. The final seismic walkdown report documenting the results of these inspections will be submitted by March 31, 2014. This new regulatory commitment replaces existing regulatory commitment item 1 of Enclosure 2 of the Three Mile Island Nuclear Station NRC Submittal dated November 19, 2012 (Reference 10).

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 27 of 29 ATTACHMENT 12

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE"

.(Yes/No1 .(Yes/No)

1. EGC will complete the inspections of the September 30, Yes No Clinton Power Station, Unit 1 components 2014 listed in Attachment 1.

2. EGC will submit the Clinton Power Station, Unit 1 final seismic walkdown report December 31, Yes No documenting the results of the Attachment 1 2014 inspections.

3. EGC will complete the inspections of the Dresden Nuclear Power Station, Unit 2 March 31, 2014 Yes No components listed in Attachment 2.

4. EGC will submit the Dresden Nuclear Power Station, Unit 2 final seismic walkdown report June 30, 2014 Yes No documenting the results of the Attachment 2 inspections.

5. EGC will complete the inspections of the Dresden Nuclear Power Station, Unit 3 March 31,2014 Yes No components listed in Attachment 3.

6. EGC will submit the Dresden Nuclear Power Station, Unit 3 final seismic walkdown report June 30, 2014 Yes No documenting the results of the Attachment 3 inspections.

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 28 of 29 COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Ves/No) eVes/No)

7. EGC will complete the inspections of the LaSalle County Station, Unit 1 components June 1,2014 Yes No listed in Attachment 4.

8. EGC will submit the LaSalle County Station, Unit 1 final seismic walkdown report August 28, 2014 Yes No documenting the results of the Attachment 4 inspections.

9. EGC will complete the inspections of the LaSalle County Station, Unit 2 components June 1,2014 Yes No listed in Attachment 5.

10. EGC will submit the LaSalle County Station, Unit 2 final seismic walkdown report August 28, 2014 Yes No documenting the results of the Attachment 5 inspections.

11. EGC will complete the inspections of the December 31 ,

Oyster Creek Nuclear Generating Station Yes No 2014 components listed in Attachment 6.

12. EGC will submit the Oyster Creek Nuclear Generating Station final seismic walkdown March 31, 2015 Yes No report documenting the results of the Attachment 6 inspections.

13. EGC will complete the inspections of the Peach Bottom Atomic Power Station, Unit 2 July 31,2014 Yes No components listed in Attachment 7.

14. EGC will submit the Peach Bottom Atomic October 31 , 2014 Yes No Power Station, Unit 2 final seismic walkdown report documenting the results of the

U.S. Nuclear Regulatory Commission NTTF Recommendation 2.3: Seismic September 16, 2013 Page 29 of 29 COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No) (Yes/No)

Attachment 7 inspections.

15. EGC will complete the inspections of the Peach Bottom Atomic Power Station, Unit 3 July 31,2014 Yes No components listed in Attachment 8.

16. EGC will submit the Peach Bottom Atomic Power Station, Unit 3 final seismic walkdown October 31, 2014 Yes No report documenting the results of the Attachment 8 inspections.

17. EGC will complete the inspections of the Quad Cities Nuclear Power Station, Unit 1 April 26, 2014 Yes No components listed in Attachment 9.

18. EGC will submit the Quad Cities Nuclear Power Station, Unit 1 final seismic walkdown July 30, 2014 Yes No report documenting the results of the Attachment 9 inspections.

19. EGC will complete the inspections of the Quad Cities Nuclear Power Station, Unit 2 April 26, 2014 Yes No components listed in Attachment 10.

20. EGC will submit the Quad Cities Nuclear Power Station, Unit 2 final seismic walkdown July 30, 2014 Yes No report documenting the results of the Attachment 10 inspections.

21. EGC will complete the inspections of the December 31, Three Mile Island Nuclear Station, Unit 1 Yes No 2013 components listed in Attachment 11.

22. EGC will submit the Three Mile Island Nuclear Station, Unit 1 final seismic March 31 , 2014 Yes No walkdown report documenting the results of the Attachment 11 inspections.