Text

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
	ML16029A336
Person / Time
Site:	Peach Bottom
Issue date:	01/29/2016
From:	Jim Barstow; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-16-012
	Download: ML16029A336 (21)
	v • d • e

Exelon Generation 10 CFR 50.54(f)

RS-16-012 January 29, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

References:

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 Supplemental Response to NRC Request for Information Pursuant to 1 O 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 1 O 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 19, 2012 (RS-12-174)

2. NRC Letter, Request for Information Pursuant to Title 1 O 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 Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3 flooding walkdown report in accordance with the NRC Request for Information (Reference 2). The PBAPS Units 2 and 3 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 5 of Reference 1, EGC provided the list of the PBAPS Units 2 and 3 plant features that could not be inspected due to restricted access. EGC committed to complete the inspection of the Units 2 and 3 features classified as restricted access in the P3R20 (Fall 2015) Refuel Outage. These inspections have been completed.

This letter provides the results of the completed supplemental flooding walkdown inspections.

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

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Page 2 The results of the visual inspections during the supplemental flooding walkdowns showed that the plant flood protection features met the NEI 12-07 Acceptance Criteria, and the Supplemental Walkdown/lnspection Guidance, Rev. 01. The results of the visual inspections are documented in Tables 1, 2, and 3 attached to this report. Table 1 lists the features that were immediately judged as acceptable, Table 2 lists the features that were not immediately judged as acceptable, and entered into the station's Corrective Action Program (CAP).

Table 3 list features that were either identified as inaccessible, or those providing a supporting function that justify the acceptability of another feature. For those features that were entered into the CAP, Tables 2 and 3 provide the tracking mechanism for resolution of the identified conditions.

There were no findings identified as deficient per the current licensing basis. The findings that were documented using CAP have been resolved or will be resolved.

No other findings challenge 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. This report completes the PBAPS Units 2 and 3 flood walkdown commitments contained in Reference 1, Enclosure 2.

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 29th day of January 2016.

Res~c=~

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosures:

1. Table 1: PBAPS Units 2 and 3, Supplemental List of Features Immediately Judged as Acceptable

2. Table 2:

PBAPS Units 2 and 3, Supplemental List of Locations Not Immediately Judged as Acceptable

3. Table 3: PBAPS Units 2 and 3, Features Classified as Inaccessible

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Page 3 cc:

Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I NRC Senior Resident Inspector-Peach Bottom Atomic Power Station NRC Project Manager, NRA - Peach Bottom Atomic Power Station Mr. Robert F. Kuntz, NRR/JLD/JHMB, NRC

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 ENCLOSURE1 Peach Bottom Atomic Power Station, Units 2 and 3 Supplemental List of Features Immediately Judged as Acceptable Table# 1-Inspected Flooding Features Meeting Acceptance Criteria Features Immediately Judged as Acceptable No.

Feature 1.0. Number CRL Description Passive/Active/Incorporated/Temporary 1

CW2-112-801-5095 8LOCKOUT for MCC E224-P-A (008061)

Passive - Incorporated 2

CW2-112-801-5095A Z82G235 - 11/2" Passive - Incorporated (Note 1) 3 CW2-112-801-5095 8 Z82G296 - 1/2" Passive - Incorporated (Note 1) 4 CW2-112-801-5095E 2A669-1" Passive - Incorporated 5

CW2-112-801-5095F Z82G178-2 1/2" Passive - Incorporated (Note 1) 6 CW2-112-801-5095G Z82G300-1" Passive - Incorporated 7

CW2-112-801-5095J Z82G259-1" Passive - Incorporated (Note 1) 8 CW2-112-801-5095L Z83G061-1" Passive - Incorporated (Note 1) 9 CW2-112-801-5095M Z82G213 - 11/2" Passive - Incorporated (Note 1) 10 CW2-112-801-5095N Z82G260-1" Passive - Incorporated (Note 1) 11 CW2-112-801-5095P 3G233 -1" Passive - Incorporated 12 CW2-112-801-5095Q Z82G276 - 11/2" Passive - Incorporated (Note 1) 13 CW2-112-801-5095R Z82G278-1" Passive - Incorporated (Note 1) 14 CW2-112-801-5095S Z82A453 - 3" Passive - Incorporated 15 CW2-112-801-5095T 2G214 - 2 1/2" Passive - Incorporated 16 CW2-112-801-5095U Z82G295 Passive - Incorporated (Note 1) 17 CW2-112-801-5095V 2G469-1" Passive - Incorporated (Note 1) 18 CW2-112-801-5095W 2G470-1" Passive - Incorporated (Note 1) 19 CW2-112-801-5095X Z82A598 - 3 1/2" Passive - Incorporated 20 CW2-112-801-5095Y Z82G279-1" Passive - Incorporated (Note 1) 21 CW2-112-801-5095Z Z83G279 - 11/2" Passive - Incorporated (Note 1) 22 CW3-112-803-5112 8LOCKOUT FOR MCC E124-P-A (008062)

Passive - Incorporated 23 CW3-112-803-5112A ZA2G237 - 11/2" Passive - Incorporated (Note 1) 24 CW3-112-803-51128 ZA2G233-1" Passive - Incorporated 25 CW3-112-803-5112E ZA2G299-1" Passive - Incorporated 26 CW3-112-803-5112G ZA2G291-11/2" Passive - Incorporated (Note 1) 27 CW3-112-803-5112J ZA2G059-1" Passive - Incorporated (Note 1) 28 CW3-112-803-5112K ZA3G059-1" Passive - Incorporated (Note 1) 29 CW3-112-803-5112M ZA3G260 - 11/2" Passive - Incorporated 30 CW3-112-803-5112N ZA3G279 - 11/2" Passive - Incorporated (Note 1) 31 CW3-112-803-5112P ZA2G277-1" Passive - Incorporated Peach Bottom Atomic Power Station Page 1

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table# 1 - Inspected Flooding Features Meeting Acceptance Criteria Features Immediately Judged as Acceptable No.

Feature 1.0. Number CRL Description Passive/ Active/Incorporated/Temporary 32 CW3-112-803-5112Q ZA2G622-3" Passive - Incorporated 33 CW3-112-803-5112R ZA2G441-2" Passive - Incorporated 34 CW3-112-803-5112S ZA3G001-1" Passive - Incorporated (Note 1) 35 CW3-112-803-5112T ZA2G471-1" Passive - Incorporated (Note 1) 36 CW3-112-803-5112U ZA2G472-1" Passive - Incorporated (Note 1) 37 CW3-112-803-5112V ZA2A634 - 3 1/2" Passive - Incorporated 38 CW3-112-803-5112W ZA2G537 - 2 1/2" Passive - Incorporated (Note 1) 39 TBC-091-017-40023B 6" COE Passive - Incorporated 40 TBC-091-017-40023C 6" COE W/O PG W/O CABLE Passive - Incorporated 41 TBC-091-017-400230 6" COE W/O PG W/0 CABLE Passive - Incorporated 42 TBC-091-017-40023E 6" COE Passive - Incorporated 43 TBC-091-017-40023F 11/2" COE W/O PG W/O CABLE Passive - Incorporated 44 RW2-116-105-2001A 1" c Passive - Incorporated 45 RW2-116-105-2001B 1" c Passive - Incorporated 46 RW2-116-105-2019A 1/2" c Passive - Incorporated 47 RW2-116-105-2030A 11/2" C ZC2L1071 Passive - Incorporated 48 RW2-116-105-2030B 11/2" C ZD2L1080 Passive - Incorporated 49 RW2-116-108-2010A 1" C 2L750 Passive - Incorporated so TBC-116-126-4001C 11/2" c Passive - Incorporated 51 TBC-116-126-4007 A 11/2" c Passive - Incorporated 52 TBC-116-126-4038A 11/2" C #2B1547 Passive - Incorporated 53 RW3-116-162-2012B 11/2" c Passive - Incorporated 54 RW3-116-162-2012C 3/4" c Passive - Incorporated 55 RW3-116-162-2019A 2" C #ZA3PS01 Passive - Incorporated 56 RB3-116-ST22-2002A 3/4" c Passive - Incorporated 57 RB3-116-ST22-2002B 3/4" c Passive - Incorporated 58 CW2-112-801-2001A 3/4" c Passive - Incorporated 59 CW2-112-801-2002A 3/4" c Passive - Incorporated 60 CW2-112-801-2008A 3/4" c Passive - Incorporated 61 CW2-112-801-5003A 1" C#ZGOS9 Passive - Incorporated 62 CW2-112-801-5004A 1" C#ZG061 Passive - Incorporated 63 CW2-112-801-5009A 1" c Passive - Incorporated 64 CW2-112-801-5010A 1" c Passive - Incorporated 65 CW2-112-801-5011A 1" c Passive - Incorporated 66 CW2-112-801-5013A 3/4" c Passive - Incorporated 67 CW2-112-801-5014A 3/4" c Passive - Incorporated 68 CW2-112-801-501SA S" C Passive - Incorporated Peach Bottom Atomic Power Station Page 2

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table# 1 - Inspected Flooding Features Meeting Acceptance Criteria Features Immediately Judged as Acceptable No.

Feature l.D. Number CRL Description Passive/ Active/Incorporated/Temporary 69 CW2-112-801-5016A 1" C#2G456 Passive - Incorporated 70 CW2-112-801-5017A 1" CZA2G468 Passive - Incorporated (Note 1) 71 CW2-112-801-5018A 1" c Passive - Incorporated 72 CW2-112-801-5030A 1" c Passive - Incorporated 73 CW2-112-801-5031A 1" c Passive - Incorporated 74 CW2-112-801-5032A 1" c Passive - Incorporated 75 CW2-112-801-5033A 1" c Passive - Incorporated 76 CW2-112-801-5034A 1" c Passive - Incorporated 77 CW2-112-801-5035A 2" c Passive - Incorporated 78 CW2-112-801-5036A 1" c Passive - Incorporated 79 CW2-112-801-5037A 3/4" c Passive - Incorporated 80 CW2-112-801-5038A 1" c Passive - Incorporated 81 CW2-112-801-5039A 1" c Passive - Incorporated 82 CW2-112-801-5048A 1" C#ZG452 Passive - Incorporated 83 CW2-112-801-5049A 1" C #ZG467 Passive - Incorporated (Note 1) 84 CW2-112-801-5051A 6" c Passive - Incorporated 85 CW2-112-801-5058A 6" c Passive - Incorporated 86 CW2-112-801-5060A 1" c Passive - Incorporated (Note 1) 87 CW2-112-801-5061A 1" c Passive - Incorporated (Note 1) 88 CW2-112-801-5064A 11/2" C #2AG610 Passive - Incorporated 89 CW2-112-801-5077A 4" c Passive - Incorporated 90 CW2-112-801-5078A 6" c Passive - Incorporated 91 CW2-112-801-5079A 2" C#ZG272 Passive - Incorporated 92 CW2-112-801-5087A 6" c Passive - Incorporated 93 CW2-112-801-5092A 1" c Passive - Incorporated 94 CW2-112-145-3004A 3/4" c Passive - Incorporated 95 CW2-112-145-3015A 11/2" C #2G802 Passive - Incorporated 96 CW2-112-145-3016A 3/4" C #2G678 Passive - Incorporated 97 CW2-112-145-3017A 11/2" C #2G677 Passive - Incorporated 98 CW3-112-803-5010A 3" C #2G537 Passive - Incorporated (Note 1) 99 CW3-112-803-5035A 1" c Passive - Incorporated 100 CW3-112-803-5038A 6" c Passive - Incorporated 101 CW3-112-803-5039A 11/2" c Passive - Incorporated 102 CW3-112-803-5043A 6" c Passive - Incorporated 103 CW3-112-803-5044A 11/2" c Passive - Incorporated 104 CW3-112-803-5051A 3/4" C.O.E. W/PLUG Passive - Incorporated Peach Bottom Atomic Power Station Page 3

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table# 1-Inspected Flooding Features Meeting Acceptance Criteria Features Immediately Judged as Acceptable No.

Feature l.D. Number CRL Description Passive/ Active/Incorporated/Temporary 105 CW3-112-803-5052A 4" C #ZB2A460 Passive - Incorporated 106 CW3-112-803-5053A 4" C #ZB2A809 Passive - Incorporated 107 CW3-112-803-5054A 3A667 - 11/2" Passive - Incorporated 108 CW3-112-803-5078A 1" C#3G061 Passive - Incorporated (Note 1) 109 CW3-112-803-5079A 11/2" C #3G297 Passive - Incorporated (Note 1) 110 CW3-112-803-5088A 2A611 - 11/2" Passive - Incorporated 111 CW2-112-144-3008A 1" C #ZB2-G039 Passive - Incorporated 112 CW3-112-143-1017 A 3/4" c Passive - Incorporated Note 1: Feature has been inspected as acceptable. Subsequently it was determined that an external flood seal is not required at this location because:

1) the conduit is internal to the protected structure and does not penetrate the building envelope; or 2) this flood seal is downstream of another flood seal that protects the same conduit at the building envelope. The Component Record List (CRL) for this feature has been updated to indicate an external flood seal is not required.

General Note: In addition to (original report) flood seals listed above, the following flood seal was inspected, and immediately judged as acceptable:

1.

CW3-112-803-2009 (1" C #3GOS9)

Peach Bottom Atomic Power Station Page 4

1 2

3 4

5 6

7 8

9 10 11 12 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 ENCLOSURE 2 Peach Bottom Atomic Power Station, Units 2 and 3 Supplemental List of Locations Not Immediately Judged as Acceptable Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria Feature ID#

CRL Description Observation Component Resolution Operability CW2-112-801-5095C ZB2G060 - 11/2" Not sealed and Yes Unnecessary: this is a redundant, internal seal not required.

Issue Report (IR) and not required for flood protection.

The CRL error.

1505254 conduit is sealed at the building envelope by CW2-112-801-2013. CRL updated.

CW2-112-801-5095D ZB3G060 - 11/2" Not sealed and Yes Unnecessary: these are redundant, internal seals not required.

IR 1505221 and and not required for flood protection.

The CW3-112-803-5071A ZB3G060 -11/2" CRL errors.

IR 1557577 conduit is sealed at the building envelope by CW2-112-801-2023. CRL updated.

CW2-112-801-5095H ZB2G061-1" Not sealed and Yes Unnecessary: this is a redundant, internal seal not required.

IR 1505254 and and not required for flood protection.

The CRL error.

IR 1515787 conduit is sealed at the building envelope by CW2-112-801-2011. CRL updated.

CW2-112-801-5095K ZB2G062-1" Not sealed and Yes Unnecessary: this is a redundant, internal seal not required.

IR 1505254 and not required for flood protection.

The CRL error.

conduit is sealed at the building envelope by CW2-112-801-2009. CRL updated.

CW3-112-803-5112C ZA2G058 - 11/2" Not sealed and Yes Unnecessary: these are redundant, internal seals not required.

IR 1579311 and not required for flood protection.

The CW3-112-803-5075A 2" c CRL errors.

conduit is sealed at the building envelope by CW3-112-803-2020. CRL updated.

CW3-112-803-5112D ZA3G058 - 11/2" Not sealed Yes Inspected, no seal present. Seal will be installed IR 1515805 per Action Request (AR) A1909861.

CW3-112-803-5112F ZA3G178-2 1/2" Not sealed and Yes Unnecessary: this conduit stays within the not required.

JR 1515787 Emergency Pump Structure and therefore does CRL error.

not require an external flood seal. CRL updated.

CW3-112-803-5112H 1" (OEV062)

Does not exist.

Yes Floor penetration does not exist and is not CRL error.

IR 1515787 required. The conduit exits through the top of MCC E124-P-A to Fan OEV062. CRL updated.

CW3-112-803-5112L ZA3G259-1" Not sealed and Yes Unnecessary: these are redundant, internal seals not required.

IR 1595057 and not required for flood protection.

The CW3-112-803-5076A 11/2" C #ZA2G058 CRL errors.

conduit is sealed at the building envelope by CW3-112-803-2019. CRL updated.

Peach Bottom Atomic Power Station Page 5

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria Feature ID#

CRL Description Observation Component Resolution Operability RB3-091-037-2002A 1" c Not required and Yes Unnecessary: these are internal, embedded not inspected.

IR 1579300 conduits between elevations of the Reactor RB3-091-037-2002B 1" c CRL errors.

Building; from electrical panels at an upper elevation, to lighting and outlet loads at a lower RB3-091-037-2002C 1" c elevation.

They are not external penetrations through Reactor Building walls.

They are not RB3-091-037-2003A 1" c exposed to potential external flooding, and not required to have flood seals. CRL updated.

RB3-091-037-2003B 1" c RB3-091-037-2004A 1" c RB3-091-037-2004B 1" c RB3-091-037-2005A 3/4" c RB3-091-037-2006A 3/4" c RB3-091-043-2005A N/ A, penetrations Do not exist; Yes Penetrations do not exist and are not required.

do not exist in CRL drawing is IR 1571732 The penetration numbers appear on drawing PS-RB3-091-043-2005B misleading 43 only, and are not in CRL. Walkdown showed only a solid cover plate, screwed in place.

No RB3-091-043-2005C conduits penetrate through the plate into the U3 Core Spray Pump Room, and no conduits penetrate the exterior wall.

RB3-116-160-2015A 3/4" CONDUIT Does not exist.

Yes Penetration does not exist, is not required, and is CRL error.

IR 1557577 not shown on drawing. CRL updated.

RB3-116-ST22-2001A 3/4" c Not required and Yes These are internal, embedded conduits between not inspected; IR 2406298 elevations of the Reactor Building; labeled DNP RB3-116-ST22-2001B 3/4" c error on initial (does not penetrate). CRL identifies as external report.

water seal = N.

They are not external penetrations through Reactor Building walls, are not exposed to potential external flooding, and not required to have flood seals.

CW2-112-801-5002A 2" C #ZB2C060 Not sealed and Yes Unnecessary: this is a redundant, internal seal not required.

IR 1515787 and not required for flood protection.

The CRL error.

conduit is sealed at the building envelope by CW2-112-801-2013A. CRL updated.

CW2-112-801-5005A 11/2" C #ZB2G259 Not required and Yes Unnecessary: this is a redundant, internal seal not inspected.

IR 1515787 and not required for flood protection.

The CRL error.

conduit is sealed at the building envelope by CW2-112-801-2010A. CRL updated.

CW2-112-801-5007A 1" C #ZB2G062 Not required and Yes Unnecessary: this is a redundant, internal seal not inspected.

IR 1515787 and not required for flood protection.

The CRL Error.

conduit is sealed at the building envelope by CW2-112-801-2009A. CRL updated.

Peach Bottom Atomic Power Station Page 6

31 32 33 34 35 36 37 38 39 40 41 42 43 44 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria Feature ID#

CRL Description Observation Component Resolution Operability CW2-112-801-5022A 2" c Not sealed.

Yes Inspected, no seal present.

Seal was installed IR 1563505 per AR A1925566.

CW2-112-801-5029A 11/2" C #ZB2G213 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1515787 Emergency Pump Structure (OOX140 from E224-CRL Error.

P-A) and does not require an external flood seal.

CRL updated.

CW2-112-801-5040A 11/2" C #ZA2G236 Not required and Yes Unnecessary: this feature stays within the not inspected.

IR 1515787 Emergency Pump Structure (2AV060 from E124-CRL Error.

P-A) and does not require an external flood seal.

CRL updated.

CW2-112-801-5041A 11/2" C #ZB2G234 Not required and Yes Unnecessary: this feature stays within the not inspected.

IR 1515787 Emergency Pump Structure (2BV060 from E224-CRL Error.

P-A) and does not require an external flood seal.

CRL updated.

CW2-112-801-5043A 1" c Not sealed.

Yes Inspected, no seal present. Seal was installed per IR 1567736 AR A1926905.

CW2-112-801-5044A 11/2" c Not sealed.

Yes Inspected, no seal present. Seal was installed per IR 1567731 AR A1926906.

CW2-112-801-5045A 1" C #ZG152 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1515787 Emergency Pump Structure (between PT-2330A CW2-112-801-5063A 1" C#ZG152 CRL errors.

and PT-2330C) and does not require external flood seals. CRL's have been updated.

CW2-112-801-5046A 1" c Not sealed.

Yes Inspected, no seal present. Seal was installed per IR 1571706 AR A1928251.

CW2-112-801-5054A 2 1/2" C #ZB2G278 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1515787 Emergency Pump Structure (20C139 from E224-CRL error.

P-A) and does not require an external flood seal.

CRL updated.

CW2-112-801-5057A 2 1/2" C #2G301 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1515787 Emergency Pump Structure (20C139 from CW3-112-803-5022A 3" C #2G301 CRL error.

30C139) and does not require an external flood seal. CRL updated.

CW2-112-801-5065A 3/4" C #ZB2G279 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1515787 Emergency Pump Structure (M0-2344 from CRL error.

E224-P-A, abandoned) and does not require an external flood seal. CRL updated.

CW2-112-801-5069A 11/2" C #2A612 Not sealed.

Yes Inspected, no seal present. Seal was installed per IR 1571709 AR A1928250.

Peach Bottom Atomic Power Station Page 7

4S 46 47 48 49 so Sl S2 S3 S4 SS S6 S7 S8 S9 60 61 62 63 64 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria Feature ID#

CRL Description Observation Component Resolution Operability CW2-112-801-S070A 3/4" C #2G6S9 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1S6104S Emergency Pump Structure {PT-23308 from PT-CW2-112-801-S091A 3/4" C #2G6S9 CRL errors.

23300) and does not require an external flood seal. CRL updated.

CW2-112-801-S071A 1" C #2G46S Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1S20797 Emergency Pump Structure (2BP042 and 2DP042, CW2-112-801-S072A 1" C #2G466 CRL errors.

daisy-chain) and do not require external flood seals. CRL updated.

CW2-112-801-S089A 1" C#ZG46S CW2-112-801-S07SA 3/4" c Not sealed.

Yes Inspected, no seal present.. Seal was installed IR 1S48621 per AR A192070S.

CW2-112-801-S080A 11/2" C #ZB2G276 Not required and Yes Unnecessary: this feature stays within the not inspected.

IR 1S1S787 Emergency Pump Structure (OOXOS8 from E224-CRL error.

P-A) and does not require an external flood seal.

CRL updated.

CW2-112-801-S081A 3/4" c Not sealed.

Yes Inspected, no seal present. Seal was installed per IR 1S48624 AR A1920704.

CW2-112-801-S082A 1" c Not sealed.

Yes Inspected, no seal present. Seal was installed per IR 1S48626 AR A1920703.

CW2-112-801-S090A 2 1/2" C #ZG214 Does not exist.

Yes Penetration does not exist and is not required.

CRL error.

IR 1S6104S CRL updated.

CW2-112-14S-3003A 3" C #2G749 Not required to Yes Not required to be inspected. CRL identifies be inspected.

IR 1S6104S external water seal= No. This feature should not CW3-112-143-1019A 3" C#2G749 Report error.

be on the list to be inspected. Conduit only passes through, remains solid, and does not open, in the Emergency Pump Structure.

CW3-112-803-S006A 11/2" C #3A623 Not sealed.

Yes Inspected, no seal present. Seal was installed per IR 1S2407S AR A1912490.

CW3-112-803-S007 A 3/4" c Not sealed.

Yes Inspected, no seal present. Seal was installed per IR 1S20797 AR A1911266.

CW3-112-803-S008A 3/4" c Not sealed and Yes Unnecessary: these conduits stay within the not required. CRL IR 1S20797 Emergency Pump Structure {3AP042, 3BP042, CW3-112-803-S040A 3/4" c error.

3CP042 and 3DP042 daisy-chain) and do not require an external flood seal. CRL updated.

CW3-112-803-S041A 3/4" c CW3-112-803-S04SA 3/4" c CW3-112-803-S046A 3/4" c CW3-112-803-S049A 1" CW/PLUG Peach Bottom Atomic Power Station Page 8

65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria CRL Description Observation Component Resolution Feature ID#

Operability CW3-112-803-5009A 11/2" C #ZB2G297 Not sealed and Yes Unnecessary: this conduit stays within the not required.

IR 1515787 Emergency Pump Structure {3BV060 from E224-CRL error.

P-A) and does not require an external flood seal.

CRL updated.

CW3-112-803-5011A 3/4" c Not sealed Yes Inspected, no seal present. Seal was installed IR 2415032 per AR A1978S89.

CW3-112-803-5012A 3/4" c Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1557577 Emergency Pump Structure (OOC125 from CW3-112-803-5026A CRL error.

OOY044) and does not require an external flood seal. CRL updated.

CW3-112-803-5015A 11/2" C #ZA3A665 Not sealed Yes Inspected, no seal present. Seal was installed IR 1545697 per AR A1919702.

CW3-112-803-5016A 11/2" C #3A017 Not sealed Yes Inspected, no seal present. Seal was installed IR 1545687 per AR A1919703.

CW3-112-803-5017 A 11/2" C #ZC3A634 Not sealed Yes Inspected, no seal present. Seal was installed IR 1545597 per AR A1919684.

CW3-112-803-5018A 11/2" C #3A638 Not sealed Yes Inspected, no seal present. Seal was installed IR 1567713 per AR A1926908.

CW3-112-803-5019A 11/2" C #3A637 Not sealed Yes Inspected, no seal present. Seal was installed IR 1567719 per AR A1926907.

CW3-112-803-5023A 3" C #ZA3G001 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1515787 Emergency Pump Structure {30C139 from E124-CRL error.

P-A)) and does not require an external flood seal.

CRL updated.

CW3-112-803-5024A 1" c Not required, and Yes Unnecessary: this is a redundant, internal seal not inspected IR 2414988 and and not required for flood protection. The CW3-112-803-5069A 1" c

{5024A), or not IR 2406613 conduit is sealed at the building envelope by sealed {5069A).

CW3-112-801-2024. CRL updated.

CRL Error.

CW3-112-803-5025A 1" c Not required, and Yes Unnecessary: this is a redundant, internal seal not inspected IR 2414988 and and not required for flood protection. The CW3-112-803-5068A 1" c

{5025A), or not IR 2406617 conduit is sealed at the building envelope by sealed {5068A).

CW3-112-801-2025. CRL updated.

CRL Error.

CW3-112-803-5027 A 2" C#3G272 Not sealed Yes Inspected, no seal present. Seal was installed IR 1598696 per AR A1935778.

CW3-112-803-5028A 2" C #ZA2G291 Not sealed and Yes Unnecessary: this conduit stays within the not required.

IR 1515787 Emergency Pump Structure (OOX144 from El24-CRL error.

P-A) and does not require an external flood seal.

CRL updated.

Peach Bottom Atomic Power Station Page 9

81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria Feature ID#

CRL Description Observation Component Resolution Operability CW3-112-803-5029A 1" c Not sealed Yes Inspected, no seal present. Seal was installed IR 2415049 per AR A1978589.

CW3-112-803-5030A 2" c Not sealed Yes Inspected, no seal present. Seal was installed IR 1560943 per AR A1924773.

CW3-112-803-5031A 1" c Not sealed Yes Inspected, no seal present. Seal was installed IR 1560949 per AR A1924772.

CW3-112-803-5032A 1" c Not sealed Yes Inspected, no seal present. Seal was installed IR 1560957 per AR A1924771.

CW3-112-803-5033A 1" C#2G962 Not sealed Yes Inspected, no seal present. Seal was installed IR 2415060 per AR A1978589.

CW3-112-803-5034A 1" c Not sealed Yes Inspected, no seal present. Seal was installed IR 1560963 per AR A1924770.

CW3-112-803-5036A 1" c Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1557577 Emergency Pump Structure (OOY044 from E124-CRL error.

P-A, empty) and does not require an external flood seal. CRL updated.

CW3-112-803-5048A 11/2" c Not sealed Yes Inspected, no seal present. Seal was installed IR 1525637 per AR A1912873.

CW3-112-803-5055A 3G152-1" Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1563489 Emergency Pump Structure (PT-3330A from PT-CW3-112-803-5104A 1" C #3G152 CRL error.

3330C) and does not require an external flood seal. CRL updated.

CW3-112-803-5056A 11/2" c Not sealed Yes Inspected, no seal present. Seal was installed IR 1579307 per AR A1930723.

CW3-112-803-5061A 2A638 - 11/2" Not sealed Yes Inspected, no seal present. Seal was installed IR 1525639 per AR A1912872.

CW3-112-803-5062A 1" CZA2G468 Not sealed and Yes Unnecessary: this conduit stays within the not required.

IR 1520797 Emergency Pump Structure (OAP057 from CRL error.

OBP057) and does not require an external flood seal. CRL updated.

CW3-112-803-5066A 1" C #2G293 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1563489 Emergency Pump Structure (PS-0240B from CW3-112-803-5087 A CRL errors.

unnumbered J-box) and does not require an external flood seal. CRL updated.

Peach Bottom Atomic Power Station Page 10

96 97 98 99 100 101 102 103 104 105 106 107 108 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria Feature ID#

CRL Description Observation Component Resolution Operability CW3-112-803-5067 A 1" C #2G292 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1563489 Emergency Pump Structure (PT-236B from CRL error.

TB0091) and does not require an external flood seal. CRL updated.

CW3-112-803-5073A 2" c Not sealed and Yes Unnecessary: this is a redundant, internal seal not required.

IR 15S7577 and not required for flood protection.

The CRL error.

conduit is sealed at the building envelope by CW2-112-801-2022. CRL updated.

CW3-112-803-507 4A 1" c Not sealed and Yes Unnecessary: this is a redundant, internal seal not required.

IR 1563489 and not required for flood protection.

The CRL error.

conduit is sealed at the building envelope by CW2-112-801-2021. CRL updated.

CW3-112-803-S077 A 11/2" C #3A620 Not sealed and Yes Unnecessary: this is a redundant, internal seal not required.

IR 2406590 and not required for flood protection.

The CRL error.

conduit is sealed at the building envelope by CW2-112-801-2018. CRL updated.

CW3-112-803-5092A 1" C #3G059 Not sealed and Yes Unnecessary: this is a redundant, internal seal not required.

IR 1557577 and not required for flood protection.

The CRL error.

conduit is sealed at the building envelope by feature CW3-112-803-2009. CRL updated.

CW3-112-803-5095A 3/4" C #3G233 Not sealed and Yes The conduit is sealed by feature CW2-112-801-not required.

IR 1561045 5095P.

CW3-112-803-5099A 1" C #ZA3G212 Not sealed and Yes Unnecessary: this conduit stays within the not required.

IR 2414988 Emergency Pump Structure (NOB6254 to 30P031)

CRL error.

and does not require an external flood seal. CRL updated.

CW3-112-803-5105A 11/2" C #ZB3A610 Not sealed Yes Inspected, no seal present. Seal was installed IR 2406587 per AR A1899858.

CW2-112-801-5106A 11/2" C #ZA3G279 Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1515787 Emergency Pump Structure (M0-3344 from CRL Error.

E124-P-A) and does not require an external flood seal. CRL updated.

CW3-112-803-5108A 3A608-11/2" Not sealed.

Yes Inspected, no seal present. Seal was installed IR 1561028 per AR A1924776.

CW3-112-803-5109A 3A612 - 11/2" Not sealed.

Yes Inspected, no seal present. Seal was installed IR 1563498 per AR A1925565.

CW3-112-803-5 llOA 3G153 -1" Not required and Yes Unnecessary: this conduit stays within the not inspected.

IR 1563489 Emergency Pump Structure (PT-3330B from PT-CW3-112-803-5111A 3G153 -1" CRL errors.

3330D) and does not require an external flood seal. CRL updated.

Peach Bottom Atomic Power Station Page 11

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #2: Inspected Features Not Immediately Judged as Acceptable Flood Features Not Meeting Acceptance Criteria Feature ID#

CRL Description Observation Component Operability Resolution General In addition to Not sealed Yes Inspected, no seal present.

Note (original report) flood seals listed above, the following flood seals were inspected, not immediately judged as acceptable, and reworked:

CW3-112-803-2016 11/2" C #3G297 IR 1477876 Seal was installed per AR A1896750.

CW3-112-803-2017 1" C #3G061 IR 1477876 Seal was installed per AR A1896750.

CW3-112-803-2018 11/2" C #3A620 IR 2406590 Seal was installed per AR A1975943.

CW3-112-803-2019 11/2" C #ZA3G259 IR 1595707 Seal was installed per AR A1934707.

CW3-112-803-2020 2" C #ZA2G058 IR 1579311 Seal was installed per AR A1930722.

CW3-112-803-2021 1" C SPARE IR 2406599 Seal was installed per AR A1975940.

CW3-112-803-2022 2" C#2G441 IR 2406607 Seal was installed per AR A1975935.

CW3-112-803-2023 ZB3G060 11/2" C IR 1505221 Seal was installed per AR A1905735.

CW3-112-803-2024 1" c IR 2406613 Seal was installed per AR A1975934.

CW3-112-803-2025 1" C SPARE IR 2406617 Seal was installed per AR A1975933.

General Note: Each feature Not Immediately Judged as Acceptable was entered into the Corrective Action Program (CAP) for resolution. All deficiencies were addressed, either by further review that determined an external flood seal is not required, or by creating an action tracking item to rework the deficiency. Each CAP Issue Report (IR) contains an immediate assessment of equipment operability. There were no cases of inoperability. At Peach Bottom, degraded flood seals typically have redundant seals installed at the conduit endpoint equipment or in manholes. This does not meet the NEI 12-07 requirements, and therefore work orders were created to rework features at the structure boundary. However, the redundant seals do provide reasonable assurance that the equipment is operable.

Peach Bottom Atomic Power Station Page 12

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 ENCLOSURE 3 Peach Bottom Atomic Power Station, Units 2 and 3 Features Classified as Inaccessible Table #3: Features Classified as Inaccessible No.

Feature l.D. Number CRL Description Reason Resolution 1

TB2-102-016-4001A 6" C #ZA2L001 Pull box disassembly would be required IR 1579300. Acceptable because for inspection of internal conduit seal, equipment disassembly is not in scope including scaffolding, and removal/re-for inspections, and no known or 2

TB2-102-016-4002A 6" C #ZA2L004 application of thermo-lag fire-proofing.

evidence of leakage.

3 RB3-091-043-2004A 3/4" c These penetration seals are at light IR 1571732. Acceptable because fixtures, which do not have inspection equipment disassembly is not in scope 4

RB3-091-043-2004B 3/4" c ports. Light fixture disassembly would be for inspections, and no known or required for inspection of internal evidence of leakage.

5 RB3-091-043-2004C 3/4" c conduit seal, including de-energizing power and temporary lighting.

6 RB3-091-ST22-2001A 3/4" c 7

RW3-088-046-2010A 4" C #ZA3L014 w/ OZ Conduit through turbine building I IR 1571732. Acceptable because of BUSHING (B-SIDE) reactor building wall, 26 feet above the amount of scaffolding work and related floor. Seal is an OZ bushing, which is risk associated with inspection 26 feet visible (from the floor), in a large, open J-off the floor, and no known or evidence box, which appears to have no function.

of leakage.

There are no visible cables in the J-box, only the conduit. Inspection at 26 feet would require scaffolding.

8 RB3-091-ST23-2001A 4" C. ZD3L004 Conduit from turbine building to reactor IR 1571732. Acceptable because of building passes though stairway 23. Seal disassembly to remove (and replace) was approved and installed per ECR 99-Darmatt. The seal is well-documented 01679. Conduit is wrapped in Darmatt per ECR 99-01679. There is no known or Fire Wrap.

evidence of leakage.

9 RW2-116-105-2002A 3/4" c Conduit is located behind the card IR 1557577. Acceptable because reader in the U2 RBCCW Room. Card equipment disassembly is not in scope reader removal would be required for for inspections, and no known or inspection of internal conduit seal.

evidence of leakage.

10 RW2-116-105-2026A 1" C#2B144 Conduit is located through U2 RBCCW IR 2406298. Acceptable because of Room west wall, 14 feet above floor.

inaccessibility, location, and no known Conduit is not accessible due to conduits or evidence of leakage.

and pipes. Interferences and tight access do not allow for ladders or movement in the inspection area.

11 RW2-116-105-4018A 3" C #2A1405 Conduit is located through U2 RBCCW IR 1557577. Acceptable because of Room west wall, 14 feet above floor.

amount of scaffolding work and related 12 RW2-116-105-4018B 3" C#2A1427 Near wall, conduits have 45-degree bend risk associated with inspection 14 feet fittings with connection fittings to off the floor, and no known or evidence 13 RW2-116-105-4018C 3" C#2A1428 straight pipe runs. Inspection in this area of leakage.

would require scaffolding.

Peach Bottom Atomic Power Station Page 13

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #3: Features Classified as Inaccessible No.

Feature l.D. Number CRL Description Reason 14 RB2-116-107-2003A 2" c Penetration seals are in conduits located through U2 B/D Core Spray Triangle 15 RB2-116-107-2003B 3/4" c Room, 12 feet above floor. Conduits are through a block-out, behind RB HVAC Duct. Duct removal and scaffolding would be required for inspection.

16 RB2-116-108-3001C 1" c Penetration seals are in conduits located through U2 A/C Core Spray Triangle 17 RB2-116-108-3001D 11/2" c Room, 14 feet above floor. Conduits are behind 14" A/C Core Spray Pump Suction from CST. Vacuum breaker is directly underneath penetration and suction pipe. Due to interference from pipe and vacuum breaker, these seals are inaccessible for inspection.

18 TBC-116-126-4011H 2" X2" IT 2" x 2" IT connection, material is square, reinforced aluminum screwed together.

19 RW3-116-156-4001A 5" C #3L068 Penetration seals are in conduits located through U3 A RHR Room, 13 feet above 20 RW3-116-156-4002A 5" C#3L066 floor. This is a high radiation area, adjacent to 3A RHR Heat Exchanger.

21 RW3-116-156-4003A 5" C#3L064 Inspection cannot be performed without ladders or scaffolding, above shielding 22 RW3-116-156-4004A 5" C #3L065 around 3A RHR HX.

23 RW3-116-156-4005A S" C #3L067 24 RW3-116-156-4006A 5" C #3L069 25 RB3-116-161-2002A 1" FLEX C Penetration seals are in conduits located through east wall of U3 A/C Core Spray 26 RB3-116-161-2003 3/4" c Triangle Room, 10 to 13 feet above floor.

Conduits 2003A and 2004A are above a 27 RB3-116-161-2004A 3/4" c duct, the other 5 conduits are behind the duct. Inspection of 2003A and 2004A 28 RB3-116-161-2005A 3/4" c cannot be performed without scaffolding. Due to interference from 29 RB3-116-161-2006A 1" c duct, these seals are inaccessible for inspection.

30 RB3-116-161-2010A 3/4" c 31 RB3-116-161-2011A 1" C #3L258 32 RW3-116-162-2012A 1" C #ZB3R203 Conduit is located through U2 RBCCW Room wall, 12 feet above floor. Seal is installed on TB side of wall. However, it is not accessible due to pipes and ducts.

Interferences and tight access do not allow for ladders or movement in the inspection area.

Peach Bottom Atomic Power Station Resolution IR 1557577. Acceptable because of scaffolding work 12 feet above floor, equipment disassembly is not in scope for inspections, and no known or evidence of leakage.

IR 1557577. Acceptable because of interference from other equipment, and no known or evidence of leakage.

IR 1557577. Acceptable because penetration was inspected in August 2012, per a Surveillance Test.

IR 1557577. Acceptable not to inspect because of high radiation area, and no known or evidence of leakage.

IR 1557577. Acceptable because of interference from other equipment, and no known or evidence of leakage.

IR 2406298. Acceptable because of inaccessibility, and no known or evidence of leakage.

Page 14

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #3: Features Classified as Inaccessible No.

Feature l.D. Number CRL Description Reason 33 RW3-116-162-2024A 1" C (CARD READER)

Conduit is located behind the card reader in the U3 RBCCW Room. Card reader removal would be required for inspection of internal conduit seal.

34 RW3-116-162-2028A 11/2" c Conduit is located through U3 RBCCW Room wall, 12 feet above floor. Seal is 35 RW3-116-162-2028B 11/2" c installed on TB side of wall. However, it is not accessible due to interferences.

36 CW2-112-801-5012A 3" c Conduit is solid, without inspection fitting or pull box, from floor to Fire System Terminal Cabinet TC #06 located approximately five feet above floor. Seal is Inaccessible because its inspection would require cabinet disassembly.

37 CW2-112-801-5023A 2" c Conduit is solid from floor to an unlabeled box approximately 10 feet 38 CW2-112-801-5024A 3/4" c above the floor. Seals are Inaccessible because its inspection would require equipment (box) disassembly. This equipment is proximate to the two-foot zone of E224-P-A.

39 CW2-112-801-5050A 2" c Penetration seal at EYS-type condulets.

Previous inspection broke condulet lip 40 CW2-112-801-5059A 1" C #ZG2A631 during attempted smaller port plug removal (IR 01524075). There is a 41 CW2-112-801-5073A 11/2" c concern with potential breaking and needing to replace condulet.

42 CW2-112-801-5088A 11/2" C #ZD2A619 43 CW2-112-801-5052A C #2A480 IN 12" X Conduit is embedded in thermos-lag fire 32" X 3" METAL proofing with adjacent raceway.

FRAME 44 CW2-112-801-5055A 11/2" C #2A688 Penetration seal at EYS-type condulets.

Previous inspection broke lip during attempted smaller port plug removal (IR 01524075). There is a concern with potential breaking and needing to replace condulet.

45 CW2-112-801-5056A 3/4" c Conduit is solid, without inspection fitting or pull box, from floor to 20C139 located approximately three feet above floor. Seal is Inaccessible because its inspection would require panel.

disassembly.

Peach Bottom Atomic Power Station Resolution IR 1571732. Acceptable because equipment disassembly is not in scope for inspections, and no known or evidence of leakage.

IR 1571732. Acceptable because no known or evidence of leakage. Recently (2008), work was performed on this penetration, and CRL reflects configuration as documented in A1440412 Evaluation 04.

IR 1561045. Acceptable because equipment disassembly is not in scope for inspections, and no known or evidence of leakage.

IR 01524075. Acceptable because equipment disassembly is not in scope of for inspections, and no known or evidence of leakage.

IR 1561045. Acceptable because of disassembly to remove (and replace) thermo-lag. There is no known or evidence of leakage.

IR 01561045. Acceptable because equipment disassembly is not in scope of for inspections, and no known or evidence of leakage.

IR 1561045. Acceptable because equipment disassembly is not in scope for inspections, and no known or evidence of leakage.

Page 15

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #3: Features Classified as Inaccessible No.

Feature l.D. Number CRL Description Reason 46 CW2-112-801-5067A 1" C #2A167 Penetration seal at EYS-type condulets.

Previous inspection broke lip during attempted smaller port plug removal (IR 0152407S). There is a concern with potential breaking and needing to replace condulet.

47 CW2-112-801-S076A 3/4" c Conduit is solid, without inspection fitting or pull box, from floor to 76L panel located approximately five feet above floor. Seal is Inaccessible because its inspection would require panel disassembly.

48 CW3-112-143-1001A 11/2" C #2GS36 Conduits are located through U3 (EYS FTG. B-SIDE)

Emergency Pump Structure north wall, lS - 16 feet above floor. Conduits are 49 CW3-112-143-1002A 11/2" C #2GS3S not accessible due to pipes.

(EYS FTG. B-SIDE)

Interferences and tight access do not allow for ladders or movement in the so CW3-112-143-1003A 2 1/2" C #2GS34 inspection area.

(EYS FTG. B-SIDE)

Sl CW3-112-803-S014A 3" C#3A492 Conduit is solid, without inspection fitting, from floor to J-2219. Seal is Inaccessible because its inspection would require panel disassembly.

S2 CW3-112-803-S020A 11/2" C #3A668 Penetration seal at EYS-type condulets.

Previous inspection broke lip during S3 CW3-112-803-S021A 11/2" c attempted smaller port plug removal (IR 01524075). There is a concern with potential breaking and needing to replace condulet.

S4 CW2-112-144-3002A 2" C #ZA1376 (EYS Conduits are located through U2 FTG.)

Emergency Pump Structure south wall, 16 feet above floor. Inspection would SS CW2-112-144-3003A 2" C #ZG1374 (EYS require ladders on top of doorway FTG.)

vestibule and tools to open EYS fittings.

Extensive effort for safety and other S6 CW3-112-144-3004A 2" C #ZG773 (EYS planned activities is beyond scope of FTG.)

internal seal inspections.

S7 CW2-112-144-3005A 11/2" C #ZG812 (EYS Conduits are located through U2 FTG.)

Emergency Pump Structure south wall, 14 feet above floor. Conduit is not accessible due to duct and pipes.

Interferences and tight access do not allow for ladders or movement in the inspection area.

Peach Bottom Atomic Power Station Resolution IR 01563489. Acceptable because equipment disassembly is not in scope of for inspections, and no known or evidence of leakage.

IR 1S6104S. Acceptable because equipment disassembly is not in scope for inspections, and no known or evidence of leakage.

IR 1S79300. Acceptable because of inaccessibility, location, and no known or evidence of leakage.

IR 1571732. Acceptable because equipment disassembly is not in scope for inspections, and no known or evidence of leakage. Also conduit is known to originate from Manhole-26, and photos show all conduits are sealed in the manhole.

IR 01S63489. Acceptable because equipment disassembly is not in scope of for inspections, and no known or evidence of leakage.

IR 1S61045. Acceptable because of location, and no known or evidence of leakage.

IR 2406298. Acceptable because of inaccessibility, location, and no known or evidence of leakage.

Page 16

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #3: Features Classified as Inaccessible No.

Feature l.D. Number CRL Description Reason 58 CW2-112-144-3006A 2" C (EYS FTG.)

Penetration seal at EYS-type condulets.

Previous inspection broke lip during attempted smaller port plug removal (IR 01524075). There is a concern with potential breaking and needing to replace condulet.

59 CW2-112-144-3007A 2" c Conduits have penetration seals that are type PS-3, for which the conduit cover is 60 CW2-112-144-4002A 1 Y," c part of the penetration seal, and therefore cannot be opened without a barrier breach permit. Opening these covers would require disassembly, work order permit, barrier breach permit, and contingencies.

61 CW2-112-144-3016A 5" C #ZB2A474 W/

Conduits are located through U2 O.Z. BUSHING AT JB Emergency Pump Structure south wall, 12 feet above floor Conduits are not 62 CW2-112-144-3017A 11/2" C #2G967 accessible due to interferences and tight (EYS FTG.)

access, which does not allow for ladders or movement in the inspection area.

63 CW2-112-144-3018A 2" C #2G719 (EYS FTG.)

64 CW2-112-144-3019A 2" C #2G720 (EYS FTG.)

65 CW2-112-144-3020A 11/2" C (EYS FTG.)

66 CW2-112-144-3023A 3/4" C (CARD Conduits are located behind the card READER) readers in the Emergency Pump Structure. Card reader removal would 67 CW2-112-144-3026A 1" C (CARD READER) be required for inspection of internal conduit seals.

68 CW3-112-143-1031A 3/4" C (CARD READER) 69 CW3-112-143-1004A 11/2" C (EYS FTG. B-Conduits are located through U3 SIDE)

Emergency Pump Structure north wall, 15 - 16 feet above floor Conduits are not 70 CW3-112-143-1005A 11/2" C #3G1008 accessible due to interferences and tight

{EYS FTG. B-SIDE) access, including circulating pump lube pipe and heating steam pipe, which does 71 CW3-112-143-1005B 2" C #3G848 (EYS not allow for ladders or movement in the FTG. B-SIDE) inspection area.

72 CW3-112-143-1006A 2" C #3G847 (EYS FTG. B-SIDE) 73 CW3-112-143-1007A 2" C #3G1000 (EYS FTG. B-SIDE) 74 CW3-112-143-1008A 1" C (EYS FTG. B-SIDE) 75 CW3-112-143-1011A 3" C#3G006 Peach Bottom Atomic Power Station Resolution IR 01579300. Acceptable because equipment disassembly is not in scope of for inspections, and no known or evidence of leakage.

IR 01579300. Acceptable because equipment disassembly is not in scope of for inspections, and no known or evidence of leakage.

IR 1561045. Acceptable because of location, and no known or evidence of leakage.

IR 1524075. Acceptable because equipment disassembly is not in scope for inspections, and no known or evidence of leakage.

IR 1563489. Acceptable because of location, and no known or evidence of leakage.

Page 17

76 77 78 79 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 29, 2016 Table #3: Features Classified as Inaccessible No.

Feature 1.0. Number CRL Description Reason C\\N3-112-143-1020A 5" C#ZG1022 Conduits are located through U3 Emergency Pump Structure north wall, C\\N3-112-143-1021A 5" C#2G1023 \\N/O 14 - 16 feet above floor Conduits are not CABLE accessible due to interferences and tight access, including chlorination water pipe, C\\N3-112-143-1022A 2" c which does not allow for ladders or movement in the inspection area.

C\\N3-112-143-1033A 3/4" c Conduit is located behind the receptacle in Emergency Pump Structure.

Resolution IR 1563489. Acceptable because of location, and no known or evidence of leakage.

IR 1571732. Acceptable because equipment disassembly is not in scope 80 C\\N3-112-143-1033B 3/4" c Receptacle removal would be required of for inspections, and no known or for inspection of internal conduit seal.

evidence of leakage.

General Note: Items classified as Inaccessible are consistent with NEI 12-07 that excludes inspections of items that are: significant personnel safety hazard, in very high radiation areas, require major equipment disassembly, and have no reasonable means of access. Peach Bottom Inaccessible features that are located at significant height above floor are personnel safety hazards because they would necessitate inspection while leaning off scaffolding and working around interferences.

Inaccessible items have defense-in-depth Reasonable Assurance that the external flood features are available and will perform their external flood protection or mitigation function for the full duration of the flood. The first layer of reasonable assurance is that the Component Record list (CRL) identifies the flood seals and contains design-qualification information. Flood seal information identifies the seal type and reference to the design parameters (ratings, size, % fill, and pressure resistance). Approximately 78% of the inaccessible features have this level of design detail documented in the CRL. The second layer of reasonable assurance is that 70% of inaccessible flood features are Appendix R fire seals as well as flood seals. listing under the Appendix R program is additional evidence that the seals were installed and are able to perform their intended flood protection function. All inaccessible features were walked down to meet Peach Bottom Station's commitment. The third layer of reasonable assurance is that no inaccessible feature showed any water marks or other evidence of leakage and had no historic issue reports for leakage. All inaccessible items were documented in CAP and closed.

Peach Bottom Atomic Power Station Page 18