RS-14-005, 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
| ML14013A356 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/13/2014 |
| From: | Kaegi G Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-14-005 | |
| Download: ML14013A356 (6) | |
Text
Exelon Generation, 10 CFR 50.54(f)
RS- 14-005 January 13, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457
Subject:
Supplemental Response to NRC Request for Information Pursuant to, 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident
References:
- 1. Exelon Generation Company, LLC 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 27, 2012 (RS-12-160)
- 2. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 In Reference 1, Exelon Generation Company, LLC (EGC) provided the Braidwood Station, Units 1 and 2 flooding walkdown report in accordance with the NRC Request for Information (Reference 2). The Braidwood Station, Units 1 and 2 flooding walkdown report documented the plant walkdowns performed to verify that plant features credited in the current licensing basis for protection and mitigation from external flood events are available, functional, and properly maintained. In Table 2 of Reference 1, EGC provided the list of the Braidwood Station, Unit 1 plant features that were not able to be inspected due to restricted access. EGC committed to complete the inspection of the Unit 1 Auxiliary Feedwater tunnel feature classified as restricted access in the Al R17 (Fall 2013) Refuel Outage. These inspections have been completed.
Additionally, this report provides the results of the Braidwood Station, Unit 2 Auxiliary Feedwater tunnel walkdown inspection. This inspection had been performed in October 2012 but the evaluation of the inspection results had not been completed in time to incorporate into Reference 1.
U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 13, 2014 Page 2 This letter provides the results of the completed supplemental flooding walkdown inspections of plant features located in the Braidwood Station, Units 1 and 2 Auxiliary Feedwater Tunnel areas. The enclosed tables document the specific walkdown results for each of the subject plant features.
The results of the visual inspections during the supplemental flooding walkdowns for Braidwood Station, Units 1 and 2 showed that the Auxiliary Feedwater Tunnel areas meet the NEI 12-07 acceptance criteria. Table 1 provides the list of the two (2) features that were immediately judged to be acceptable; however, certain locations within these features required additional evaluation as noted below.
Although the Braidwood Station, Units 1 and 2 Auxiliary Feedwater Tunnel areas satisfied the NEI 12-07 criteria, several locations within the tunnels were noted where minor conditions were identified and further evaluated. Table 2 provides the list of these locations that were not immediately judged as acceptable during the supplemental walkdowns and further evaluated.
The table provides the tracking mechanism for Corrective Action Program (CAP) 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 using the station's Corrective Action Program. 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. Except as noted above, flood protection features met the NEI 12-07 Supplemental Guidance acceptance criteria and were found to be in accordance with the site current licensing basis. This report completes the Braidwood Station, Units 1 and 2 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 13th day of January 2014.
Respectfully, Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC
U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 13, 2014 Page 3
Enclosure:
- 1. Table 1: Braidwood Station, Units 1 And 2, Auxiliary Feedwater Tunnels Supplemental List of Features Immediately Judged as Acceptable
- 2. Table 2: Braidwood Station, Units 1 And 2, Auxiliary Feedwater Tunnels Supplemental List of Locations Not Immediately Judged as Acceptable cc: Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Project Manager, NRR - Braidwood Station Illinois Emergency Management Agency - Division of Nuclear Safety
U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 13, 2014 ENCLOSURE1 Braidwood Station, Units 1 and 2 Auxiliary Feedwater Tunnels Supplemental List of Features Immediately Judged as Acceptable Table 1 - Braidwood Station, Units 1 and 2 Auxiliary Building Supplemental List of Features Immediately Judged as Acceptable
- Feature ID Number Building Room BRW-18 Unit 1 Auxiliary 1 Feedwater Tunnel Floors and Auxiliary Building Areas 1 & 2 N/A Walls 2 BRW-19 Unit 2 Auxiliary Feedwater Auxiliary Building Areas 4, 5 & 6 N/A Tunnel Floors and Walls
U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 13, 2014 ENCLOSURE 2 Braidwood Station, Units 1 and 2 Auxiliary Feedwater Tunnels Supplemental List of Locations Not Immediately Judged as Acceptable Table 2 - Braidwood Station, Units 1 and 2 Auxiliary Building Supplemental List of Locations Not Immediately Judged as Acceptable IR Subject (from Proposed IR Number Feature ID Status/Resolution CAP) Resolution Clean and re-seal the concrete wall as noted in Issue Report (IR) condition description as Closed - Completed Work required.
Order (WO) 01535804-01 (OSP) Groundwater 01557124 in-leakage (10/17/2013) and WO BRW-18 Clean and paint (9 locations) 01535804-02 (10/17/2013).
walkdown/inspect affected WO did not require sealing.
Ul AF Tunnel components as Components were cleaned noted in IR and painted.
description.
Component Operability - Yes, Documented in IR 01557124.
Close to actions taken and Fukushima trending.
01559422 flooding walkdown Closed, references IR BRW-18 (34 locations) inactive leaks in U1 Component 01557124 above.
AF Tunnel Operability --- Yes, Documented in IR 01559422.
U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding January 13, 2014 Table 2 - Braidwood Station, Units 1 and 2 Auxiliary Building Supplemental List of Locations Not Immediately Judged as Acceptable IR Subject (from Proposed IR Number Feature i1113 Status/Resolution CAP) Resolution Close to actions taken and Close to documentation in the Fukushima trending.
01428041 IR- This issue is for evidence flooding walkdown BRW-19 of previous leaks and is not (31 locations) inactive leaks in U2 Component active.
AF Tunnel Operability - Yes, Documented in IR 01428041.
Open - WO 01586010-01 opened to remove puddle and clean groundwater in-leakage deposits, including Items 1 &
2 from IR 01427471.
Remove the (Scheduled for A2R17) puddle, clean and paint the areas as Groundwater in noted in the IR. Open - WO 01586010-03 01427471 leakage Fukushima BRW-19 planned to mitigate the in-(3 locations) Walkdown U2 AF Tunnel Component leakage per IR 01427471.
Tunnel Operability - Yes, (Scheduled for A2R17)
Documented in IR 01427471. Note: Feature BRW-19 References IR 01426707, which then directs to actions in IR 01427471 generated specifically for the Fukushima walkdown.
Determine applicable repair, if any, and create Fukushima WO for the repair.
flooding walkdown Closed - Completed WO 01427832 BRW-19 identified 01585678-01 for cleaning (1 location) Component deficiency tag with and coating. (11/03/2013)
Operability - Yes, no WO Documented in IR 01427832.