RS-14-250, Supplemental Response to 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

Supplemental Response to 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

ML14304A223
Person / Time
Site:	Peach Bottom
Issue date:	10/31/2014
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-250
Download: ML14304A223 (97)

Text

RS-1 October 3 i,

4 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk 11 Rockville Pike Rockville, MD 20852 Peach Bottom Atomic Power Station, Unit 2 Renewed Facility Operating License No. DPR-44 NRG Docket No. 50-277 10

Subject:

Supplemental Response to NRG Request Information Pursuant to

References:

1.

10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

Regulatory to 50.54(f) Letter Page 2 commitment to these inspections completed supplemental inspections No degraded, nonconforming, or unanalyzed conditions that require either immediate or follow up actions were identified.

This report completes Regulatory Commitment No. 2 contained in Reference 1, and Regulatory Commitment Nos. 13 and 14 contained in Reference 3.

This contains no new regulatory commitments.

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

I under penalty of perjury that foregoing is true and correct. Executed on the 31 day of October 2014.

cc:

Resources S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of

SEISMIC WALKDOWN REPORT IN RESPONSE TO THE S0.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.3: SEISMIC UPDATED TRANSMITTAL # 1 (ANNEX A) for the PEACH BOTTOM ATOMIC POWER STATION UNIT 2 1848 Lay Road, Delta, PA 17314 Facility Operating License No. DPR-44 NRC Docket No. STN 50-277

-- -* Correspon enceNo~: ~S-44-250 Preparer.

Reviewer:

Exelon ~

Prepared by:

Exelon Generation Company, LLC (Exelon)

PO Box 805398 Chicago, IL 60680-5398 Printed Name Tracey Gallagher (Annex A)

Jesaelucas (Annex A)

ApN*wer:

Frank Glaco Annex A

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Peer Reviewer:

Paul Keeter (Annex A)

Lead Responsible Engineer:

Jene Lucas Branch Manager:

FrankGiaco Senior Manager Design Engineering: -~O~av~e H~en~ry!=:~;;;;~~~~:_

Corponne Acceptance:

Jeffrey s. Clark Peach Bollom Alonnc Pow9r SlallOn UnH 2 Conlpondenm No RS-, 4-250

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Contents Tables.......................................................................................................................................... iii Executive Summary................................................................................................................... iv 1

lntroduction..................................................................................................................... 1-1 1.1 Background............................................................................................................. 1-1 1.2 Plant Overview........................................................................................................ 1-1 1.3 Approach................................................................................................................. 1-1 2

Seismic Licensing Basis................................................................................................ 2-1 2.1 Safe Shutdown Earthquake (SSE).......................................................................... 2-1 2.2 Design of Seismic Class I SS Cs............................................................................. 2-1 3

Personnel Qualifications............................................................................................... 3-1 4

Selection of SSCs........................................................................................................... 4-1 4.1 SWEL Development Overview................................................................................ 4-1 4.2 SWEL 1 - Sample of Required Items for the Five Safety Functions....................... 4-1 4.3 SWEL 2 - Spent Fuel Pool Related Items.............................................................. 4-3 4.4 Composite SWEL.................................................................................................... 4-4 5

Seismic Walkdowns and Area Walk-Bys...................................................................... 5-1 5.1 Overview................................................................................................................. 5-1 5.2 Seismic Walkdowns................................................................................................ 5-1 5.3 Area Walk-Bys........................................................................................................ 5-3 6

Licensing Basis Evaluations......................................................................................... 6-1 7

IPEEE Vulnerabilities Resolution Report..................................................................... 7-1 8

Peer Review.................................................................................................................... 8-1 8.1 Overview................................................................................................................. 8-1 8.2 Review of SWEL..................................................................................................... 8-1 8.3 Review of Sample Seismic Walkdown and Area Walk-By Checklists..................... 8-1 8.4 Review of Licensing Basis Evaluations................................................................... 8-2 8.5 Review of Submittal Report..................................................................................... 8-2 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-1 4-250

Contents (cont'd.)

9 References...................................................................................................................... 9-1 Appendices A

Project Personnel Resumes and SWE Certificates.................................... Not Included B

Equipment Lists............................................................................................. Not Included C

Seismic Walkdown Checklists (SWCs)....................................................... Not Included D

Area Walk-By Checklists (AWCs)................................................................ Not Included E

Plan for Walkdown of Inaccessible Equipment and Assessment of Electrical Cabinet Internal Inspections........................................................................ Not Included F

Peer Review Report....................................................................................... Not Included Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 ii

Tables Table 3-1. Personnel Roles....................................................................................................... 3-1 Table 5-1. Anchorage Configuration Confirmation..................................................................... 5-2 Table 5-2. Issues Identified during Seismic Walkdowns............................................................ 5-2 Table 5-3. Issues Identified during Area Walk-Bys.................................................................... 5-4 Table 7-1. PBAPS Unit 2 and Common IPEEE Seismic Vulnerabilities Resolutions................ 7-2 Table 7-2. PBAPS Unit 2 and Common IPEEE Seismic Vulnerabilities Resolved by Analysis. 7-6 Table B-1. SWEL for Unit 2......................................................................................... Not Included Table B-2. SWEL for Unit O (common)....................................................................... Not Included Table B-3. Deferred to Electrical Bus Outage: Electrical Safety Concern................. Not Included Table C-1. Unit 2 Seismic Walkdown Checklists (SWCs)........................................... Not Included Table C-2. Unit 0 Seismic Walkdown Checklists (SWCs)........................................... Not Included Table D-1. Unit 2 Area Walk-By Checklists (AWCs)................................................... Not Included Table D-2. Unit 0 Area Walk-By Checklists (AWCs)................................................... Not Included Table E-1. Summary of Inaccessible Equipment........................................................ Not Included Table E-2. Assessment of Unit 2 Electrical Cabinet Internal Inspections................... Not Included Table E-3. Assessment of Unit 0 Electrical Cabinet Internal Inspections................... Not Included Annexes Annex A. Updated Transmittal #1............................................................................................ Ai Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 iii

Executive Summary PURPOSE This report documents the seismic walkdowns performed at Peach Bottom Atomic Power Station (PBAPS) Unit 2 in response to NRC 50.54(f) letter dated March 12, 2012,, Recommendation 2.3: Seismic. Exelon committed to perform this work in accordance with the NRG-endorsed Seismic Walkdown Guidance document (Electric Power Research Institute (EPRI) Technical Report 1025286, Reference 1).

SCOPE OF WORK In addition to defining the qualifications of personnel performing this work, the EPRI Seismic Walkdown Guidance identifies the following key activities:

Selection of Systems, Structures, and Components (SSC) to be included in the sample scope of the seismic walkdowns. Screening criteria are applied to obtain an informed sample of electrical and mechanical equipment that are required to perform the four reactor safety functions and containment function, and address NRC concerns about Spent Fuel Pool related equipment. (see Section 4 of this report)

Seismic Walkdowns and Area Walk-Bys are performed by trained, two-person teams of Seismic Walkdown Engineers (SWEs), who document their inspections on structured checklists included in the EPRI Guidance. (see Section 5 of this report)

Seismic Licensing Basis Evaluations are performed for issues identified as "potentially adverse seismic conditions," and all issues, whether they rise to this level or not, are included in the Corrective Action Program (CAP) so that standard plant processes can be used to address the issue. (see Section 6 of this report)

• IPEEE Vulnerabilities Resolution Report is required for plants who identified seismic vulnerabilities during their IPEEE program and made commitments to resolve them. IPEEE seismic commitments are identified, resolutions documented, and confirmatory checks made during these walkdowns are documented. (see Section 7 of this report)

Peer Review is required by a team comprised of at least two individuals for each of the key activities of this project. (see Section 8 of this report)

RESULTS The Seismic Walkdown Equipment List (SWEL) for PBAPS Unit 2, including the items selected that are common to both Units 2 and 3, e.g., emergency cooling tower equipment, is comprised of 114 items. Of this list, 113 equipment items were walked down during the 180-day window of completion of the initial scope of work required by the 50.54(f) letter. The walkdown for the remaining 1 item was deferred to a future Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 iv

electrical bus outage. Additionally, confirmation that equipment anchorage is consistent with plant design documentation is required for 50% of the SWEL items having anchorage (e.g., not line-mounted). A total of 51 anchorage configurations were confirmed to be installed in accordance with the design documentation.

All electrical cabinets on the SWEL require assessment of the need for inspections to address the potential for "other adverse seismic conditions" internal to the cabinet. This assessment is required due to an NRC clarification of their expectations for seismic walkdowns, which was received after the online seismic walkdowns were completed. Tables E-2 (for Unit 2) and E-3 (for common equipment) list all electrical items that require assessment. Accessibility of equipment, basis for accessibility determination, completion date of internal inspections, tracking number (if internal inspection has not yet been performed) and inspection results are provided in these tables.

None of the issues identified during the walkdowns of PBAPS Unit 2 equipment and nearby areas required formal seismic licensing basis evaluations because none of the issues ultimately were assessed to be adverse seismic conditions. Smaller issues, however, such as missing mounting fasteners, were identified and entered into the plant's Corrective Action Program (CAP). A total of 9 Issue Reports (I Rs) were issued, and the status of IR resolutions is provided in Tables 5-2 and 5-3 for issues identified during equipment walkdowns and area walk-bys, respectively.

All seismic vulnerabilities identified during the IPEEE (or A-46) program are summarized in Tables 7-1 and 7-2, including resolutions and confirmatory checks made during these walkdowns. All IPEEE seismic vulnerabilities for Peach Bottom Unit 2 have been resolved.

CONCLUSIONS

1.

As confirmed in the Peer Review Report (see Appendix F), all activities required by the 50.54(f) letter were conducted in accordance with the NRC-endorsed EPRI Seismic Walkdown Guidance, except for the following items:

One inaccessible equipment item will need to be walked down during an electrical bus outage.

Three (3) electrical cabinets will need to be opened for an internal inspection for "other adverse seismic conditions" in accordance with NRC expectations that were provided to industry after these walkdowns were completed. These inspections are scheduled for the next available electrical outage.

2.

None of the 113 equipment items included in the walkdowns have conditions that would prevent them from performing their safety-related functions following a licensing basis seismic event. Additionally, a sample of more than 50% of equipment with anchorage was confirmed to be consistent with design basis documentation.

3.

The nine (9) anomalies or discrepant conditions identified during the equipment walkdowns or area walk-bys have been assessed in accordance with the plant Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 v

corrective action program (CAP), and their resolutions are being tracked for timely closure.

ANNEX A

SUMMARY

To address the items deferred due to inaccessibility and the supplemental inspections of electrical cabinets, follow-on Seismic Walkdowns and Area Walk-Bys were conducted during the 3rd quarter of 2014. No degraded, nonconforming, or unanalyzed conditions that require either immediate or follow-on actions were identified.

Annex A to this report provides:

1) Additional information obtained from these follow-on inspections performed on the open items listed on Tables E-1, E-2 and E-3. (Section A9, Ref. 12)

2) Status updates on the conditions identified during the previous Walkdowns and Walk-Bys, listed on Table 5-1, 5-2 and 5-3. (Section A9, Ref. 12)

As of July 161h, 2014, follow-on activities required to complete the efforts to address of the 50.54(f) letter (Ref. 11) are now complete. With this transmittal Commitments 1 and 2 of (Ref. 12) and Commitments 13 and 14 of (Ref. 13) may be closed.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 vi

1 Introduction

1.1 BACKGROUND

In response to Near-Term Task Force (NTTF) Recommendation 2.3, the Nuclear Regulatory Commission (NRC) issued a 10CFR50.54(f) letter on March 12, 2012 requesting that all licensees perform seismic walkdowns to identify and address plant degraded, non-conforming, or unanalyzed conditions, with respect to the current seismic licensing basis. The Nuclear Energy Institute (NEI), through the Electric Power Research Institute (EPRI), prepared industry guidance to assist licensees in responding to this NRC request. The industry guidance document EPRI Technical Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, dated June 2012 (Reference 1), was endorsed by the NRC on May 31, 2012.

This report documents the technical basis for Exelon's response to the 10CFR50.54(f) request to conduct seismic walkdowns at Peach Bottom Atomic Power Station Unit 2.

1.2 PLANT OVERVIEW The Peach Bottom Atomic Power Station (PBAPS) consists of two boiling water reactor (BWR) generating units, located in southeastern Pennsylvania. Both units have GE Mark I containments, are rated at 3514 MWt power, and were designed and constructed by Bechtel (PBAPS Updated Final Safety Analysis Report (UFSAR) (Reference 2),

Section 1.1 ). PBAPS Unit 2 received its full-power license in August 1973 (Facility Operating License No. DPR-44 (Reference 9)).

1.3 APPROACH The EPRI Seismic Walkdown Guidance (Reference 1) is used for the PBAPS Unit 2 engineering walkdowns and evaluations described in this report. In accordance with Reference 1, the following topics are addressed in the subsequent sections of this report:

Seismic Licensing Basis Personnel Qualifications Selection of SSCs Seismic Walkdowns and Area Walk-Bys Licensing Basis Evaluations IPEEE Vulnerabilities Resolution Report Peer Review Peach Bottom Atomic Power Station Unit 2 Correspondence No.. RS-14-250 1-1

2 Seismic Licensing Basis 2.1 SAFE SHUTDOWN EARTHQUAKE (SSE)

The PBAPS design of Seismic Class I structures are based on a dynamic analysis using the spectrum response curves developed for the site. The structures are analyzed for the maximum credible earthquake (MCE) which considers a maximum horizontal ground acceleration of 0.12g (Reference 2, Section C.2.2). The vertical ground acceleration associated with the MCE is 2/3 of the horizontal acceleration which is 0.08g (Reference 2, Section C.2.2). Critical plant structures were designed in accordance with the response spectra based on data developed from the seismology studies performed for the site. It was concluded that the solid rock foundation is subject to only minor earthquake activity and it is expected to respond well with no adverse effects (Reference 2, Section 1.6.1.1.7).

2.2 DESIGN OF SEISMIC CLASS I SSCs Generic Letter 87-02 issued on February 19, 1987 and Supplement No. 1 issued May 22, 1992, list PBAPS Unit 2 as an USI A-46 Plant (Table A, Category 3). Seismic Class I mechanical and electrical equipment at PBAPS are qualified using rational stress analysis, empirical methods, or the Seismic Qualification User's Group (SQUG) Generic Implementation Plan (GIP) methodology (Reference 2, Section C.5.1). The use of the SQUG method is limited to the listed equipment classes and cannot be used for equipment PBAPS has specifically committed to the NRC to qualify to IEEE 344-75 (Reference 2, Section C.5.1.3).

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 2-1

3 Personnel Qualifications Table 3-1 below summarizes the names and corresponding roles of personnel who participated in the NTTF 2.3 Seismic Walkdown effort.

Table 3-1. Personnel Roles Seismic Equipment Licensing Plant Walkdown IPEEE Peer Name Selection Basis Engineer Operations Engineer Reviewer Reviewer Reviewer (SWE)

B. Frazier x

x x

x C. Swanner x

x X(Note 1)

M. Oghbaei x

x J. Wiggin x

x K. Gantz x

x C. Schlaseman x

P. Butler X(Note 2)

J. Hanley x

(Exelon)

Notes:

1.

Peer Review Team Member for SWEL review.

2.

Peer Review Team Leader.

A description of the responsibilities of each Seismic Walkdown participant's role(s) is provided in Section 2 of the EPRI Seismic Walkdown Guidance (Reference 1).

Resumes provided in Appendix A provide detail on each person's qualifications for his or her role.

The SWEL preparer, Ben Frazier, does not have prior experience with the IPEEE program, which was performed during the 1990s. The Peer Reviewers, however, do have experience with IPEEE. For SWEL preparation, Mr. Frazier was provided with the plant's IPEEE submittal report and NRC requests for additional information (RAI) responses, as well as the NRC Safety Evaluation (SE) on the IPEEE program.

Mr. Frazier's review of these documents, combined with the reviews by the Peer Reviewers, was sufficient to meet the intent of the guidance in Reference 1 that Equipment Selection Personnel "should also have knowledge of the IPEEE program."

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 3-1

In addition to the MPR personnel listed above, Exelon Plant Operations, J. Hanley, reviewed the SWEL. Mr. Hanley is a former licensed Senior Reactor Operator (SRO) at another station, currently holds an SRO Certification at PBAPS, and currently supports operator training. Station personnel also provided support to the SWEL preparer in identifying major equipment or system modifications, equipment and systems located in different environments, and equipment and systems that would be accessible for inspection during the plant walkdowns, in accordance with Reference 1.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 3-2

4 Selection of SSCs 4.1 SWEL DEVELOPMENT OVERVIEW The EPRI Seismic Walkdown Guidance (Reference 1) defines the process used to develop the Seismic Walkdown Equipment List (SWEL) for PBAPS Unit 2.

In accordance with Reference 1, a SWEL is comprised of two groups of items:

1.

SWEL 1 is a sample of items needed to safely shut down the reactor and maintain containment integrity

2.

SWEL 2 is a list of spent fuel pool related items 4.2 SWEL 1 - SAMPLE OF REQUIRED ITEMS FOR THE FIVE SAFETY FUNCTIONS The PBAPS Safe Shutdown Equipment List (SSEL) (Reference 3) is considered the "Base List 1" and is provided in Appendix B of this report. To ensure the SSEL Base List 1 meets the EPRI Seismic Walkdown Guidance, the SSEL was compared with the screens described in the following sections. It is noted that the PBAPS SSEL does not specifically address the containment function. Therefore the SSEL was reviewed for components having at least one safety-related containment function. The number of SSEL components with a containment function was considered sufficient for selecting a sample of equipment representing the containment function.

4.2. 1 Screen #1 - Seismic Class I As described in Reference 1, only items that have a defined seismic licensing basis are to be included in SWEL 1. The seismic classification was identified for each item on the SSEL, and items that were not Seismic Class I were removed from consideration for inclusion in SWEL 1. Seismic classification was determined through a review of current design and licensing basis documentation.

4.2.2 Screen #2 - Equipment or Systems This screen narrowed the scope of items to include only those that do not regularly undergo inspections to confirm that their configuration is consistent with the plant licensing basis. This screen removed Seismic Class I Structures, Containment Penetrations, and Seismic Class I Piping Systems from consideration for inclusion in SWEL 1. Cable/conduit raceways and HVAC ductwork are addressed in area walkbys and not as discrete components in SWEL 1.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 4-1

4.2.3 Screen #3 - Support for the 5 Safety Functions This screen narrowed the scope of items included on the SWEL 1 to only those associated with maintaining the following five safety functions:

1.

Reactor Reactivity Control

2.

Reactor Coolant Pressure Control

3.

Reactor Coolant Inventory Control

4.

Decay Heat Removal

5.

Containment Function The first four functions are associated with bringing the reactor to a safe shutdown condition. The fifth function is associated with maintaining containment integrity.

Reference 3 (Page 5) identifies the primary and backup systems that are applicable to each of the first four safety function. Reference 3 also identifies the support systems for those safety functions (e.g., emergency diesel generators). Components on the SSEL that are essential to the containment function were identified as part of this project because, as noted above, the SSEL did not specifically include equipment for containment function.

4.2.4 Screen #4 - Sample Considerations The items selected from the Base List 1 SSEL for inclusion in SWEL 1 are shown in Tables 8-1 (Unit 2) and 8-2 (Unit 0, common equipment for both Units 2 and 3) of this report. As described in Reference 1, Screen #4 is intended to result in a SWEL 1 that sufficiently represents a broad population of plant Seismic Class I equipment and systems to meet the objectives of the NRC 50.54(f) Letter. The following attributes were considered in selecting items from the SSEL for inclusion in SWEL 1:

1.

A variety of types of systems The equipment included on SWEL 1 is a representative sample of several systems that perform one or multiple safety functions. Further, the systems represented include both frontline and support systems as listed in Reference 1, Appendix E:

Systems to Support Safety Function(s). Examples include Emergency Diesel Generators and related systems, Emergency Core Cooling systems (Residual Heat Removal, Reactor Core Isolation Cooling, Core Spray, High Pressure Coolant Injection), power systems (125 VDC, 120 VAC, 480 VAC), and Ultimate Heat Sink (High Pressure Service Water System and Emergency Service Water System).

Note, however, that the Reference 1 Appendix E table of generic BWR safety function systems includes some systems that are not applicable for PBAPS Unit 2 because the SSEL was not required to include all potential shutdown paths, and some systems do not exist at PBAPS (e.g., Isolation Condenser).

2.

Major new and replacement equipment The equipment included on SWEL 1 does not include items that have been recently modified or replaced. Due to the amount of modifications performed in the 1990's Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 4-2

as part of SQUG and IPEEE programs, PBAPS Unit 2 has not made significant modifications to Seismic Class 1 equipment recently.

3.

A variety of types of equipment The equipment class is identified for each item on SWEL 1. The equipment included on SWEL 1 is a representative sample from each of the classes of equipment used in the SSEL, which are the same as the equipment classes used in Reference 1. At least one piece of equipment from each class is included on SWEL 1, except for Class 11, "Chillers;" Class 12, "Air Compressors," and Class 13, "Motor Generators." There is no Class 2 Low Voltage Switchgear (LVS) equipment in the Unit 2 SWEL, but there is one Class 2 LVS in the Unit 0 (common) SWEL.

No Seismic Class I chillers, air compressors, or motor generators were included in the SSEL, and none have been identified that support the five Safety Functions included in this project.

4.

A variety of environments The location for each item is identified on SWEL 1. The equipment included on SWEL 1 is a representative sample from a variety of environments (locations) in the station. These environments include the Screen House, Pump Structure, Diesel Generator Structure (common to both units), Emergency Cooling Tower (common to both units), Turbine Building, Reactor Building, and Drywall.

5.

Equipment enhanced due to vulnerabilities identified during the IPEEE program As discussed in Section 7 of this report, a significant number of IPEEE seismic-related plant improvements were implemented, or were committed to be implemented for PBAPS Unit 2. Table 7-1 shows that all committed changes were made and identifies the sample of this equipment that was included in the SWEL.

6.

Contribution to risk In selecting items for SWEL 1 that met the attributes above, some items with similar attributes were selected based on their higher risk-significance. To determine the relative risk-significance, the Risk Achievement Worth (RAW) and Fussell-Vesely (F-V) importance for a Loss of Off-Site Power (LOOP) scenario from the internal plant PRA were used (Reference 5, Tables 2 and 4). The LOOP scenario from the internal plant PRA includes lists of the 20 pieces of equipment for Unit 2 with the highest F-V risk ranking (0.017 and above) and highest RAW risk ranking (23.6 and above). The lists of risk-significant components for the LOOP PRA (Reference 5) were compared with the draft SWEL 1 to confirm that a reasonable sample of risk-significant components (relevant for a seismic event) were included on SWEL 1.

In accordance with Reference 1, equipment access was considered when selecting the sample components. Equipment in lower dose areas were selected for the walkdown sample instead of the same component in a different train, but located in a higher dose area.

4.3 SWEL 2 - SPENT FUEL POOL RELATED ITEMS In accordance with Reference 1, four screens are used to select the SSCs to be included on the second Seismic Walkdown Equipment List (SWEL 2), as described in the following sections.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 4-3

4.3.1 Screen #1 - Seismic Class I Only Seismic Class I SSCs, or SSCs that could result in rapid drain-down of the SFP (see Screen #4 below), are to be considered for inclusion in SWEL 2. As described in Reference 1, the adequacy of SFP structures is assessed by analysis and is not included in the scope of these walkdowns.

The review of the design and licensing basis documentation for the SFP identified no Seismic Class I equipment for PBAPS Unit 2 (Reference 2, Appendix C and Reference 6). Therefore, no Seismic Class I items are included in SWEL 2.

It is noted that the spent fuel pool cooling and clean-up system is cross-connected to the RHR system (Reference 6, E-2, 3). This is done with a spool piece and does not result in any spent fuel pool cooling and clean-up components being safety-related.

4.3.2 Screen #2 - Equipment or Systems This screen considers only those items from Screen #1 that are appropriate for an equipment walkdown process. Since no Seismic Class I items are included in SWEL 2, no items meet the Screen #2 requirement.

4.3.3 Screen #3 - Sample Considerations Sample considerations do not apply because no Seismic Class I items meet the Screen #1 requirement.

4.3.4 Screen #4 - Rapid Drain-Down This screen identifies items that could allow the spent fuel pool to drain rapidly. Rapid drain-down is defined as lowering of the water level to the top of the fuel assemblies within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the earthquake. Consistent with Reference 1, the scope of items included in this screen is limited to the hydraulic lines connected to the SFP and the equipment connected to those lines. For the purposes of this program, the SFP gates are considered to be installed and the SFP cooling system is in its normal alignment for power operations. The SFP gates are passive devices that are integral to the SFP. As such, they are considered capable of withstanding a design basis earthquake and do not allow for a rapid drain-down of the SFP.

Based on review of the PBAPS Unit 2 SFP design information, there are no connections to the fuel storage pool which could allow the fuel pool to be drained below 1 O feet above the top of active fuel (Reference 2, Section 10.3.4.2 and Reference 6). The spent fuel pool cooling and clean-up return lines are the only lines that extend below this level but are equipped with siphon breaker holes to prevent inadvertent pool drainage (Reference 6, Note 3). Therefore, no items are required to be added to SWEL 2 to address rapid drain down.

4.4 COMPOSITE SWEL As described in Section 4.1 above, the final Seismic Walkdown Equipment List (SWEL) for PBAPS Unit 2 is the combined SWEL 1 and SWEL 2. For PBAPS Unit 2, there are Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 4-4

no items in SWEL 2, so the composite SWEL is the same as SWEL 1. Appendix B includes the composite SWEL.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 4-5

5 Seismic Walkdowns and Area Walk-Bys 5.1 OVERVIEW Seismic Walkdowns and Area Walk-Bys were conducted by 2-person teams of trained Seismic Walkdown Engineers, in accordance with the EPRI Seismic Walkdown Guidance (Reference 1). The Seismic Walkdowns and Area Walk-Bys are discussed in more detail in the following sections.

5.2 SEISMIC WALKDOWNS An overview of the equipment included in the Seismic Walkdowns is shown on the PBAPS Unit 2 SWEL and Unit 0 (common equipment with Unit 3) SWEL in Appendix B.

A Seismic Walkdown Checklist (SWC) from Appendix C of Reference 1 was completed for each item on the SWEL, except for the deferred item identified at the end of the SWEL. Additionally, photos are included with each SWC to provide a visual record of the item and any significant comment noted on the SWC. Drawings and other plant design documents are cited in most of the SWCs, but they are not included with the SWCs because they are readily available in the plant's electronic document management system. Seismic Walkdowns were completed for all 84 items on the PBAPS Unit 2 SWEL, plus 29 of the 30 items on the Unit O (common) SWEL, for a total of 113 items, not including the 1 deferred.

5.2.1 Anchorage Configuration Confirmation As required by Reference 1 (page 4-3), the anchorage for at least 50% of the items were confirmed to be consistent with design documentation. The second to last column of Tables C-1 and C-2 show which items are line-mounted and therefore do not count in the anchorage confirmation total (marked "N/A"). Items evaluated for consistency with design documentation are marked "Y"; those that were not compared with design documentation are marked "N". See Table 5-1 below for the accounting of the 50%

anchorage configuration confirmations, and the individual SWC forms in Appendix C for the specific documents used in each confirmation.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 5-1

Table 5-1. Anchorage Configuration Confirmation Unit 2 or Unit O No. of SWEL NIA Items Required to Items (Common)?

Items (B)

Confirm?

Confirmed (A)

(A-8)12 2

84 17 34 34 O (Common) 29 4

13 17 Unit 2 and 113 21 47 51 Common 5.2.2 Issue Identification None of the anomalies or issues identified by the SWEs during the equipment walkdowns were ultimately judged to be "Potentially Adverse Seismic Conditions" because in all cases it was concluded the anomaly or issue would not prevent the equipment from performing its safety-related function. Additionally, based on the IRs for each issue, all equipment affected by the as-found condition was determined to be functional. Table 5-2 provides a summary of the issues identified during the Seismic Walkdowns.

Table 5-2. Issues Identified during Seismic Walkdowns Component ID Description of Issue

20C003, The MCR ceiling's restraint system is

20C004C, consistent with design documentation

20C005A, but the design basis Calculation G-20C006C, Ll2 106-1 could not be located from 3-113, Ll2-3-86, records management or Iron Ll-8027, LR/TR-Mountain. This issue is to 81238, (also re-constitute design analysis to AWC-U0-7) supplement existing calculation 26-5/Z-12, specifically at MCR ceiling perimeter, during NTTF 2.1 seismic re-evaluation.

20C003 There is a missing panel screw, inside the bottom of the first panel. Judged acceptable for seismic as-is, but inconsistent with design documentation.

2BE055, Anchorage for ECCS room coolers 2BE056, 2GE058 does not match drawings but does match calculation.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Action Request ID IR 01428651 IR 01425673 IR 01437853 (Note 3)

Actions Complete YIN(Notes 1, 2)

No No No 5-2

Table 5-2. Issues Identified during Seismic Walkdowns Action Actions Component ID Description of Issue Request Complete ID Y/N(Notes 1, 21 2AC065, 2BC065 Inconsistency between as-built IR 01429745 No configuration of 2AC065 and 2BC065 instrument racks and calculation PS-0930.

OAG12, OBG12, Inconsistency between the OAG12, IR 01438055 No OCG12, ODG12 OBG 12, OCG 12, and ODG 12 anchor bolt size and vendor document E-5-155.

Notes:

1.

"Yes" indicates that corrective actions resulting from the issue are complete.

2.

"No" indicates that corrective actions resulting from the issue are NOT complete. Actions are tracked by the IR number in the station Corrective Action Program.

3.

IR 01411581 was originally identified on the SWCs as being applicable to this issue. Upon further investigation IR 01437853 was written to fully capture the issue.

5.3 AREA WALK-BYS In accordance with Reference 1, Area Walk-bys were performed for each room or area within a large room which included one or more items on the SWEL. The last column of Tables C-1 and C-2 show the number of unique Area Walk-By Checklists (AWCs) completed during the walkdowns for PBAPS Unit 2 and Unit O (common). All completed AWCs are included in Appendix D. Photos are not included with the AWC forms because they are part of the SWC package of the identified equipment item. A total of 31 AWCs were completed for Unit 2, plus 13 for Unit O (common).

None of the anomalies or issues identified by the SWEs during the Area Walk-Bys were judged to be "Potentially Adverse Seismic Conditions" because in all cases the anomaly or issue would not prevent surrounding equipment from performing its safety-related function. Additionally, based on the IRs for each issue, all equipment affected by the as-found condition was determined to be functional.

Table 5-3 at the end of this section provides a summary of the issues identified in the Area Walk-Bys.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 5-3

Table 5-3. Issues Identified during Area Walk-Bys Component Action Actions Description of Issue Request Complete ID/Area ID Y/N(Notes 1, 2)

AWC-U0-1 Open S-hook noted on light fixture above IR 01413285 Yes battery charger panel 380003.

AWC-U2-2 There is a missing base screw (notes in IR 01425994 No AWC-U2-2 documents it as "anchorage mounting bolt") inside panel 20C032.

Judged acceptable for seismic as-is but missing bolt should be replaced.

AWC-U2-27 Fire protection pipe support near HPCI IR 01425997 Yes pump missing one of four bolts. Judged acceptable for seismic as-is, but missing bolt should be replaced.

AWC-U2-22 Seismic housekeeping, unrestrained ladder IR 01406272 Yes Notes:

1.

"Yes" indicates that corrective actions resulting from the issue are complete.

2.

"No" indicates that corrective actions resulting from the issue are NOT complete. Actions are tracked by the IR number in the station Corrective Action Program.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 5-4

6 Licensing Basis Evaluations As noted in Sections 5.2.2 and 5.3, the issues identified during the Seismic Walkdowns and Area Walk-Bys were not determined to be "Potentially Adverse Seismic Conditions" because in all cases the anomaly or issue would not prevent the equipment from performing its safety-related function. Therefore, no formal Licensing Basis Evaluations were necessary and none were performed.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 6-1

7 IPEEE Vulnerabilities Resolution Report The Individual Plant Examination of External Events (IPEEE) report for PBAPS (Reference 7) and the NRC Safety Evaluation on the IPEEE report (Reference 8),

identified a number of seismic vulnerabilities. This occurs since the IPEEE reviews were performed in parallel with the original SQUG seismic verification of various equipment.

Each of the seismic vulnerabilities identified in Reference 7 were verified to be implemented and closed out per AR No. A1056479 (Reference 10). Additionally many of the identified IPEEE vulnerabilities were verified to be implemented during the seismic walkdowns. Table 7-1 below lists identified IPEEE (and A-46) vulnerabilities, indicates how each one was resolved, and identifies the specific items that were verified in the field during the walkdowns. Table 7-2 lists the PBAPS Unit 2 and Common IPEEE seismic vulnerabilities that were previously resolved by analysis. There are no outstanding IPEEE vulnerabilities and all previously identified IPEEE vulnerabilities have been resolved.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 7-1

Component ID 00897 00898 00899 2Q910/11/12/13 00894195196 20A15/16/17/18 20X133/150 20X30131/32/33 OOX103 Pe1U:t18ctttim.Atc:m1<:PCWC1"Sto'.:00U:Jll:!

c.orros~r<<:i RS.14~50 Table 7~1. PBAPS Unit 2 and Common IPEEE Seismic Vulnerabilities Resolutions Issue Planned Resolution Resolution from AJR

1. A1056479 Interaction concerns Breaker hoist will be restrained or V!Jork completed under work order C018807 4 on removed August 1, 2000.

Some cubicles missing plug welds to embedded Add missing plug welds Wofk completed for plug welds under work orde1s angle.

Breaker hoist wilt be restrained or C0181066, and C0181068 on August 1, 2000, removed and under work orders C0181067 and C0181069 Breaker hoists are interaction concern, not on October 16, 2000.

prevented from tipplng.

Modification will replace with ventilated dry Work completed for breaker hoist under work Adjacent oll filled transformers ere unanchored type transformers that are properly order C0182465 on August 1, 2000 anchored.

A walkdown was performed on April 24, 1997 to verify that all of the new transformers were installed for MOO 5099.

Unanchored switchgear end transformers.

SWitchgeer will be anchored.

Work completed for anchorage under work orders C0189242 end C0189243 on August 1, 2000, and Interaction concern with bleaker hoist.

Hoist wrn be restrained or removed C0189244 on October 16, 2000 Work completed for bleaker hoist under work orders C0188074 on August 1, 2000 Door latching mechanisms are only engaged at Latches v.;11 be fastened end neoprene Work completed under work order C0179957 on center ot door. Latching bolts at top and bottom pads may be provided.

August 1, 2000 end work order C0183982 on are not engaged.

October 16, 2000.

Spare breakers wNI be remOYed or 20A16, 17,18 have spare breakers which are not secured.

Per Item 4, p. 17 of A1056479, as of August 1, adequatety secured.

2000, spare breakers removed and will not be stored in s'Mtchgear rooms per procedure SO 54.7.C. No PIMS wotk recorded for removal of so.are breakers 30KVA transformer coils are missing 2 of 4 Perform evaluation of coil anchorage and ECR PB 97-02258 hes been completed. CALC holding bolts mocify tt required.

PS-0947 reviewed the transformers and conduded that the outlier con<fitlons are selsmicallv acceotable fSeolember 29 1997l.

Oil filled transformers are unanchored.

Replace "1th ASS 1000KVA VPE A walkdown was performed on April 24, 1997 to ventilated dry type transformer properly verify that all of the new translormers were anchored.

installed for MOO 5099.

Anchorage of transformer coifs to encfosure Vendor drawings will be reviewed and ECR PB 97-02258 hos been completed. CALC support surface Indeterminate.

evaluated and if necessary anchorage will PS.0947 reviewed the transformers and be reworked to comply conduded that the outlier conditions are seismicallv acceotable IS.member 29. 1997l.

Sample Component Walkdown Resolution None None None 20A15 end 20A16 included in walkdown sample.

Confirmed door latch issue resotved NIA - no need for field confirmation.

20X30, 20X032, end 20X033 included in walkdovm sample Confirmed issue resolved.

None 7-2

Component ID OAX26/0BX26/0CX26 2AP42/2BP42/2CP42/20P42 OAP57 /0BP57 M0-33-0498 A02-03-33 M02-13-4487 OAV035136 OBV035136 OOF043 OAV034 P02-0223-1 P02-0223-3 Pooch Bd:tom Atomic POIM Station Urnl 2 Cones~No RS.14250 Table 7 -1. PBAPS Unit 2 and Common IPEEE Seismic Vulnerabilities Resolutions Issue Planned Resolution Resolution from AJR

1. A1056479 Anchorage could not be verified.

Transformer will be anchored Work completed under mrk order C0189169 on Aunust 1. 2000.

Pump casing and shaft are greater than 20 ft.

Analytic evaluation proved pump casings Analysis completed as of IPEEE submittal May Non-tied down yard gantry crank could fall on and shafts acceptable 1996 pump house Yard crane will be restrained when not in Work completed under MR A1188705 on August use.

1,2000.

Valve has interaction concern with radiation Support for iadiation element outlet will be Work completed under work order C0182155 on element outlet.

modified August 1, 2000.

Distances from pipe centerline to top of valve Review documentation and perform ECR PB 97-02258 hes been completed. CALC operator is outside of experience database analysis if required to demonstrate seismic PS-0947 reviewed the valve end conduded that capacity.

the outlier condition is seismically acceptable

'Se"'ember 29. 19971.

Valve operator weights and/or centerline Review documentation and perform ECR PB 97-02258 has been completed. CALC distances are outside of the experience analysis if required to demonstrate seismic PS-0947 reviewed the MOV and concluded that database adequacy.

the outlier conditions ere seismically acceptable tSentember 29, 19971.

Overhead ducts need to be reviewed as part of Evaluate overhead systems and modify as ECR 97-00992 was taken to approved (and the IPEEE for seismic adequacy.

required or develop suita"'e operator complete) status on July 24, 1997. The required actions.

physical (MOD) work In the plant was tracked by A1056479-12.

Overhead ducts are an interaction concern.

Evaluate overhead systems and modtfy as ECR 97-00992 was taken to approved (and required or develop suitable operator complete) status on July 24, 1997. The required actions.

physical (MOD) work in the plant was tracked by A1056479-12 Attached heating piping at upper nozzles is Evaluate steam piping and modify if ECR 97-00992 was taken to approved (end poorly supported.

required. Evaluate overhead systems end complete) status on July 24, 1997. The required modify as required or develop suitable physical (MOD) work in the plant was tracked by Overhead ducts are an interaction concern.

orvorator actions.

A1056479-12.

Tubing from Delta P switches may be impacted Conduit will be supported by method which VVork completed under work order C0193836 on by conduit. Conduit is supported by beam does not rely on friction to transfer vertical August 1, 2000.

clamps load.

Sample Component Walkdown Resolution None 2CP042 and OBP057 Included In walkdown sam~e Confirmed issue resolved.

M0-0-33-0498 included In walkdown sampfe Confirmed issue resolved.

NIA - no need for field confirmation.

None OAV036, OBV035, and OBV036 included in walkdown sample.

No issues identified with overhead ductina.

None None P02-0223-3 included in walkdown sample.

Confirmed tssue resolved.

7-3

Component ID 20D21122123 2AD0112BD0112CD0112DD01 20D37 OAG12/0BG12/0CG12/0DG12 DPS-20224-1 DPS-20224-3 OAG13/0BG13IOCG13/0DG13 OAC097/0BC097/0CC097 ODC097 OOC29NBICID 20C124 Peodl Balom Atonm;: Power S:!tiai Unit 2 Cooesp:inaoncu No RS.14 250 Table 7 *1. PBAPS Unit 2 end Common IPEEE Seismic Vulnerabilities Resolutions Issue Planned Resolution Resolutlon from AJR

1. A1056479 Depth of panels are less then that which is Top supports will be provided and existing Work com~eted under work order C0190182 on Included in earthquake experience database floor anchorage will be evaluated and December 14, 2000 modified as required Anchor bolts have 2 114" eccentricity and in addition, corner plates are too flexible and do not orovide an edeauate load oath.

Batteries are more than 450 lbs (actual weight Review of existing data showed that the Work com~eted under work order C0193n3 on 700 lbs.) which is outside experience database.

batteries are qualified to IEEE-323 (1974)

August 1, 2000.

Also, end rails ere not snug with batteries. Also and IEEE-344 (1975) overhead nuorescent llghts ere suspended with chains having open S.hooks A snug fit will be provided at end rails and the $-hooks will be closed.

Interaction concerns Drip shield.,;11 be Installed.

Work completed under work order C0184003 on August 1, 2000.

These are housekeeping issues: large number of Area 'Mii be cleaned up and any material drums, eye wash on wooden table, liquid that must remain 'Mii be rest1ained

/4s of on August 1, 2000, loose items 1emoved processing equipment and roof pipe v.;th vlctaulic No PIMS record of work.

joints in the vicinity. Also, Inverter 20037 does not have drio shield installed.

Interaction concerns with overhead crane Overhead crane controller will be tied Work completed on crane controller under work controller.

down when not in used order C0193768 on August 1, 2000.

Local panel on vibration isolators without lateral Vibration Isolators will be mo~fied to Work completed on vibration isolators under wo1k capacity.

preclude dislodging in SSE orders C0181161, C0181153, C0181159, and C0179951 on Auaust 1. 2000.

Interaction with tubing to sensor on duct.

Condu~ will be supported by method which VVork completed under work order C0193836 on does not rely on friction to transfer vertical August 1, 2000.

load.

Interaction concerns exist regarding overhead Overhead crane controller will be tied Work compfeted under work order C0193768 on crane controller.

down when not in use.

August 1, 2000.

Interaction concerns with housekeeping issues in Items will be removed or restrained.

Work completed under work order C0183590 on the Control Room August 1, 2000.

Sample Component Walkdown Resolutlon None 2AD01 and 28001 included in walkdown sample.

Confirmed issue resolved.

20D37 included In welkdown sample.

Confi1med issue resolved.

OAG012 and ODG012 included in walkdown sample.

Confirmed issue resolved.

None OAC097 included In walkdown sampfe Confirmed issue resolved.

OOC29B Included In walkdown sample Confirmed issue resolved.

7.4

Component ID 20C32/33 20C722AIB 20CB1B 20CB19 20C139 Pipe stanchion supports Rx Bldg. 195' RW Bldo. 165' El. 165' Mech. Equipment Room HVAC ducting Pa::idl Bdk:m Alom.c P°"C' ~

Un:t 2 C<<RlSpot'KICnaJHo RS-14:'50 Table 7-1. PBAPS Unit 2 and Common IPEEE Seismic Vulnerabilities Resolutions Issue Planned Resolutlon Resolution from AJR Sample Component Walkdown

1. A1056479 Resolution Cabinets are not bolted to the adjacent cabinet.

Adjacent cabinets will be tied together front Wo1k completed unde1 wo1k 01de1 C0190182 on 20C722A induded In wolkdown Interaction concerns exist with adjacent non-and back.

Decembe1 14, 2000.

sample.

safety cabinets Tobie wiH be blocked and located so Confirmed issue resolved tipping will not cause Impact.

Cushioning wilt be p1ovlded between adjacent non-safety cabinet and impact loadina will be evaluated.

Interaction concern with attached procedure Coble wilt be lengthened so ii book falls, it Work completed under work order C0193836 on None boo~

will not hit oanel Auoust 1, 2000.

Lateral load criteria not met.

Install knee brace at top of stanchion at Work completed under work orders C0189101, None - issue not applicable to midspan of raceway and attach to floor or C0189160, and C0190050 on August 1, 2000 this walkdown.

Install lateral supports.

Various duct and Interaction issues including aux.

Perform evaluation of overhead systems Work completed under work orders C0190892, None steam piping.

and modify as required or develop suitable C0187741, C0191039, and C01824BB on August operator actions 2, 2000, and under work order C0195436 on Decembe1 18. 2000.

7.5

Component ID 20636 00653 00654 00655 00656 A02-01*060A/BIC/D A02-01*066A/BIC/D M02* 1 ().01 SA/BIC/D M02-23-019 M02-23-025 M02* 1 ().025A/B M02-13-027 M02*13-131 M02*3().2233A/B SV-61306 2AC65/2BC65 2AE24/26E24/2CE24/2DE24 Pso:n 8cl1an Afc:lmc F'Of,V Sa'~ori ~

2 CO'res;cnOenco Ua RS.1.1 250 Table 7 *2. PBAPS Unit 2 and Common IPEEE Seismic Vulnerabilities Resolved by Analysis Issue Planned Resolutlon Actual Resolution of Condition Resolutlon Date Anchorage evaluation requlred.

Evaluate anchorage Anchoiage evaluation completed and anchorage 5/1997 of MCCs ere adequate Distance from pipe centerline to top of valve Evaluate centerline distance of valve Calculations show valves have acceptable 2/1996 operator is outside of experience database operators.

seismic capacities.

Valve operator -weights and/or centerline Evaluate weight and centerline distance of Existing documentatlon review indicates valves 5/1996 distances are outside of the experience database.

valve operators.

ere qualified to an acceptable seismic acceleration.

Cast iron yoke Evaluate suitability of cast iron yoke.

Existing documentation was reviewed end 511996 components were determined to be seismically adequate.

Component colid not be localed, therefore the Evaluate component.

Drawing review was performed end component 5/1996 caveats and interaction effects could not be determined to be seismically adequate.

verified Anchorage does not screen Evaluate anchorage.

Evaluation of anchorage was perfDfmed end 511997 documented In calculatlon number PS-0930.

Rev. o. During the field walkdown, the es-found configuration for 2AC65 end 2BC65 was found to be inconsistent with calculation, bl.I! determined to be acceptable. See Section 5.2 2 of this report.

Heat exchanger anchorage evaluation is Evaluate anchorage Review of RHR Heat Exchanger modfication 112004 unknown.

calculations evaluated anchorage capacity for the RHR Heat Exchangers and found them to be seismically adequate.

8 Peer Review 8.1 OVERVIEW In accordance with the EPRI Seismic Walkdown Guidance (Reference 1), a peer review of this project was performed during the preparation of the Seismic Walkdown Equipment List (SWEL), during implementation of the seismic walkdowns and area walk-bys, and following completion of the issue resolutions. Specifically, the peer review addresses the following activities:

Review of the selection of the structures, systems, and components, (SSCs) that are included in the Seismic Walkdown Equipment List (SWEL),

Review of a sample of the checklists prepared for the Seismic Walkdowns &

Walk-Bys, Review of any licensing basis evaluations, Review of the decisions for entering the potentially adverse conditions in to the plant's Corrective Action Program (CAP), and Review of the final submittal report.

The complete Peer Review Report is included in Appendix F.

8.2 REVIEW OF SWEL The peer review checklist for SWEL is included as an attachment to the Peer Review Report. This checklist was used to ensure that the SWEL 1, SWEL 2, and composite final SWEL meet the criteria of Reference 1. All peer review comments on the SWEL were resolved.

8.3 REVIEW OF SAMPLE SEISMIC WALKDOWN AND AREA WALK-BY CHECKLISTS Approximately 31% of the Seismic Walkdown packages, i.e., SWC forms, photographs, and drawings (where applicable) were reviewed by the peer review team. Additionally, interviews were conducted with both teams of Seismic Walkdown Engineers to ensure that the seismic walkdowns and area walk-bys were performed in accordance with Reference 1.

The peer review team did not require any clarifications be added to the SWC and AWC forms reviewed.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 8-1

8.4 REVIEW OF LICENSING BASIS EVALUATIONS As discussed in Sections 5 and 6 of this report, the issues identified during the seismic walkdowns and area walk-bys did not threaten the ability of Seismic Class I equipment to perform their safety functions. The specific items that have been entered in the PBAPS Corrective Action Program (CAP) were reviewed, and no concerns with the assessments or proposed resolutions were identified.

8.5 REVIEW OF SUBMITTAL REPORT The signature of the Peer Review Team Leader on the cover of this report indicates a satisfactory review and resolution of any comments and confirms that all necessary elements of the peer review were completed.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 8-2

9 References Reference drawings related to the walkdown of SWEL items are documented on the Seismic Walkdown Checklists (SWCs) in Appendix C, and if applicable, on the Area Walk-By Checklists (AWCs) in Appendix D.

1.

EPRI Technical Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, dated June 2012.

2.

Peach Bottom Atomic Power Station Updated Final Safety Analysis Report (UFSAR), Revision 23.

3.

PECO Document No. NE-117-51, Safe Shutdown Equipment List (SSEL) for Peach Bottom Atomic Power Station, Revision 0.

4.

Not used.

5.

Exelon Document No. PB-MISC-009, Risk Ranking to Support NTTF 2.3 Seismic Walkdowns, Revision 0.

6.

PBAPS Drawing No. M-363, P & I Diagram - Fuel Pool Cooling and Clean-up, Sheet 1, Revision 40.

7.

PECO Energy Company, Peach Bottom Atomic Power Station Units 2 and 3, Individual Plant Examination for External Events, May 1996.

8.

NRC Letter (B. C. Buckley) to PECO (J. A. Hutton), Review of Peach Bottom Atomic Power Station, Units 2 and 3, Individual Plant Examination of External Events Submittal (TAC NOS. M83657 AND M83658), dated November 22, 1999.

9.

Facility Operating License No. DPR-44, NRC Docket No. 50-277, Amendment No. 268, Dated August 8, 2007.

10. PBAPS Action Request A1056479, Last updated 12/20/2000.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 9-1

Annex A Updated Transmittal # 1 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Ai

Contents of Annex A Tables....................................................................................................................................... Aiv A1 Introduction.................................................................................................................. A1-1 A1.1 Purpose................................................................................................................ A1-1 A 1. 2 Background.......................................................................................................... A 1-2 A1.3 Plant Overview.................................................................................................. A1-2 A1.4 Approach.............................................................................................................. A1-2 A1.5 Conclusion........................................................................................................... A1-2 A2 Seismic Licensing Basis............................................................................................. A2-1 A3 Personnel Qualifications............................................................................................ A3-1 A3.1 Overview.............................................................................................................. A3-1 A3.2 Project Personnel................................................................................................. A3-1 A.3.2.1 MPR Associates Personnel..................................................................... A3-2 A.3.2.2 Additional Personnel................................................................................ A3-2 A4 Selection of SSCs........................................................................................................ A4-1 A5 Seismic Walkdowns and Area Walk-Bys.................................................................. A-5-1 A5.1 Overview.............................................................................................................. A5-1 A5.2 Seismic Walkdowns............................................................................................. A5-1 A.5.2.1 Anchorage Configuration Confirmation.................................................... AS-1 A.5.2.2 Issue Identification................................................................................... A5-2 A5.3 Area Walk-Bys..................................................................................................... A5-4 A6 Licensing Basis Evaluations...................................................................................... A6-1 A7 IPEEE Vulnerabilities Resolution Report.................................................................. A7-1 AB Peer Review................................................................................................................. AB-1 A9 References................................................................................................................... A9-1 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Aii

Appendices AA Project Personnel Resumes and SWE Certificates.................................................. AA-1 AB Equipment Lists......................................................................................... AB-1 AC Seismic Walkdown Checklists (SWCs)..................................................................... AC-1 AD Area Walk-By Checklists (AWCs).............................................................................. AD-1 AE Plan for Walkdown of Inaccessible Equipment and Assessment of Electrical Cabinet Internal Inspections....................................................................... AE-1 AF Peer Review Report...................................................... :.............................................. AF-1 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Ai ii

Tables Table A3-1. Personnel Roles.................................................................................... A3-1 Table AS-1. Anchorage Configuration Confirmation...................................................... AS-1 Table AS-2. Issues Identified during Seismic Walkdowns............................................... AS-2 Table AS-3. Issues Identified during Area Walk-Bys...................................................... AS-4 Table AC-1. Summary of Seismic Walkdown Checklists (SWCs).................................... AC-1 Table AC-2. Summary of Supplemental Internal Cabinet Inspections............................... AC-1 Table AD-2. Unit 0 Area Walk-By Checklists (AWCs).................................................. AD-1 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Aiv

A 1 introduction A 1.1 PURPOSE This updated transmittal report is being provided in compliance with the requirements contained in Enclosure 3 of the NRC 50.54(f) letter dated 3/12/12 (Ref. 11 ). This new report section, Annex A, contains the results of the follow-on activities that have taken place since the initial NRC Transmittal sent by Exelon for Peach Bottom Atomic Power Station Unit 2, under letter number RS-12-173 on November 19, 2012 (Ref. 12). Annex A, includes follow-on seismic walkdown results associated with NRC Commitments 1 and 2 listed in Enclosure 3 of the letter (Ref. 12). The inspection results of Commitment 1 are also documented under letter number RS-14-001 submitted on March 25, 2014 (Ref. 14) which provided an update to the Unit 3 report since this specific item is common to PBAPS Units 2 and 3. Additionally, the update includes the current status of the resolution of conditions found during the initial seismic walkdowns and area walk-bys as documented in Tables 5-2 and Table 5-3, respectively (Ref. 12).

Commitment 1, for the supplemental inspection of the one (1) PBAPS Unit 2 item identified in Enclosure 3 (Ref. 12), deferred due to inaccessibility has been completed and the results are included in this update since this specific item is common to PBAPS Units 2 and 3.

Commitment 2, for the completion of the 3 remaining internal electrical cabinet inspections listed in Table E-2 and E-3 (Ref. 12), is now complete. Exelon provided a revised Commitment 13 (Ref. 13) to complete these three (3) items by July 31, 2014.

These inspections have been completed by the commitment date and the results are documented in this update. Therefore, Commitment 14 (Ref. 13) for the final report is completed by this transmittal.

The initial anchorage configuration confirmation shown in Table 5-1 (Ref. 12) is updated with new totals in Table A5-1 to include the deferred items.

The initial NRC Transmittal report documented that 5 conditions identified during the seismic walkdowns, and listed in Table 5-2, remained open. This update documents that 4 out of the 5 conditions are resolved with the follow-on actions complete, and the final item is tracked in the Corrective Action Program under IR 1428651.

The initial NRC Transmittal report documented that one (1) out of four (4) conditions identified during the area walk-bys, and listed in Table 5-3, remained open. This update documents that the 1 remaining condition is now resolved.

Annex A, includes updates to each report section where the status has changed or new information is available in accordance with Section 8 of EPRI 1025286, "Seismic Walkdown Guidance - For Resolution of Fukushima Near Term Task Force Recommendation 2.3 Seismic" (Ref. 1).

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A1-1

A

1.2 BACKGROUND

See Section 1.1.

A 1.3 PLANT OVERVIEW See Section 1.2.

A 1.4 APPROACH See Section 1.3.

A

1.5 CONCLUSION

As of July 16, 2014, all Seismic Walkdowns have been completed at Peach Bottom Atomic Power Station Unit 2. Including the 1 item deferred due to inaccessibility along with all 3 of the remaining supplemental electrical cabinet inspections. The walkdowns were performed in accordance with the NRC endorsed walkdown methodology. Area Walk-Bys were also completed, as required, during these follow-on activities. No degraded, nonconforming, or unanalyzed conditions that require either immediate or follow-on actions were identified.

There are no additional follow-on activities to complete the efforts to address Enclosure 3 of the 50.54(f) letter.

No deficiencies were generated during the follow-on walkdowns. The updated completion status for the previous I Rs is shown in Table A5-2 and Table A5-3 in Section AS of this Annex A.

With completion of these walkdowns and this report transmittal, Commitments 1 & 2 (Ref. 12) and Commitments 13 & 14 (Ref. 13) may be closed.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A1-2

A 2 Seismic Licensing Basis See Section 2, no new licensing basis evaluations resulted from the follow-on walkdown activities.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A2-1

A 3 Personnel Qualifications A3.1 OVERVIEW This section of the report identifies the personnel that participated in the NTTF 2.3 Seismic Walkdown efforts. A description of the responsibilities of each Seismic Walkdown participant's role(s) is provided in Section 2 of the EPRI Guidance (Reference 1 ). Resumes provided in Appendix A, and Appendix AA in this Annex A, provide detail on each person's qualifications for his or her role.

A3.2 PROJECT PERSONNEL Table A3-1 below summarizes the names and corresponding roles of personnel who participated in the NTTF 2.3 Seismic Walkdown effort.

Table A3-1. Personnel Roles Equipment Seismic Licensing Plant Walkdown IPEEE Peer Name Selection Operations Engineer Basis Reviewer Reviewer Engineer (SWE)

Reviewer B. Frazier x

(MPR)

K. Gantz x

(MPR)

B. Birmingham x

(Exelon)

T. Gallagher x

X (Note 3)

X (Note 1, 2)

(Exelon)

J. Lucas x

(Exelon)

P. Kester X(Note2)

(Exelon)

Notes:

1.

Site Lead Structural Engineer for 2.1 & 2.3 Seismic, therefore acted as Peer Review Team Leader for this Annex A. Peer Reviewer of the Annex A walkdowns remained independent and did not review any of the work they performed.

2.

SQUG Qualified.

3.

Performed role for initial walkdowns only.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A3-1

A3.2.1 MPR Associates Personnel See Section 3, no new MPR Associates participated in the follow-on activities.

A3.2.2 Additional Personnel The following additional personnel participated in the follow-on activities:

Ms. Gallagher is the Exelon Site Structural LRE for the 2.1 Seismic Hazard Evaluations and 2.3 Seismic Walkdowns. She has a BS degree in Civil Engineering from the Pennsylvania State University and has over 7 years of nuclear power experience. She has been trained as an EPRI Seismic Walkdown Engineer and is SQUG Qualified. She has been involved with all aspects of plant modification/configuration change activities at Peach Bottom and at other various nuclear power plants.

Mr. Kester is an Exelon Site Senior Design Engineer with over 20 years of experience at Peach Bottom. He has a BS degree in Mechanical Engineering from Princeton University and a MS degree in Civil Engineering from Drexel University. Mr. Kester is a Seismic Capability Engineer (SQUG Qualified) and is the Program Manager for Structural Maintenance Rule Structures Monitoring here at Peach Bottom. He is involved with all aspects of plant modification/configuration change activities. Other activities include penetration seals, hazard barrier control, heavy load rigging evaluations, lead shielding, scaffolding and other support activities.

Mr. Lucas is an Exelon Site Senior Design Engineer with over 25 years of industry experience. He has a BS.degree in Nuclear Engineering from Pennsylvania State University and an MBA from Texas Christian University.

Mr. Lucas is a licensed Professional Engineer in the State of Delaware. He is the Site LRE for the Peach Bottom Response to NTTF Orders and Recommendations resulting from Fukushima.

Mr. Birmingham is a Contractor Operations Representative with over 32 years of industry experience in the field of Nuclear Power Plant Operations, Management, Training and Procedure Writing. He has been assigned to perform as the Operations Representative for the MSO, ASD and Fukushima Projects at Peach Bottom. He was a Nuclear Senior Reactor Operator (SRO),

On Shift Control Room Supervisor for 17 years.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A3-2

A 4 Selection of SSCs See Section 4, no changes were made to the SWEL for the follow-on walkdowns.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A4-1

A 5 Seismic Walkdowns and Area Walk-Bys A5.1 OVERVIEW The follow-on Seismic Walkdowns and Area Walk-Bys were conducted by 2-person teams of trained Seismic Walkdown Engineers, in accordance with the EPRI Seismic Walkdown Guidance (Reference 1). The Seismic Walkdowns and Area Walk-Bys are discussed in more detciil in the following sections.

A5.2 SEISMIC WALKDOWNS The results of the follow-on Seismic Walkdowns were documented in Appendix AC of this Annex A, using the Seismic Walkdown Checklist (SWC) template provided in the EPRI guidance document. Seismic Walkdowns were performed and the SWC's were completed for 1 of 1 item identified in Table E-1 and 3 of 3 items identified in Tables E-2 and E-3. Additionally, photographs have been included with most SWC's to provide a visual record of the item along with any significant comments noted on the SWC.

The Seismic Walkdown Checklists (SWC's) for these four (4) components are documented in Appendix AC of this Annex A to indicate the results of these deferred and supplemental electrical cabinet internal inspections.

A5.2.1 Anchorage Configuration Confirmation No additional configuration verification was required as shown in Table A5-1 below. The number of SWEL items increased to include the 1 deferred item. The 3 supplemental internal cabinet inspection items were already included in the original Table 5-1.

Table A5-1. Anchorage Configuration Confirmation Unit 2 or Unit O No. of SWEL (Common)?

Items (A) 2 84 O (Common) 30 Unit 2 and 114 Common Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 N/A Items Required to (B)

Confirm?

(A-B)/2 17 34 4

13 21 47 Items Confirmed 34 17 51 A5-1

AS.2.2 Issue Identification No adverse seismic conditions were identified during the follow-on walkdown activities.

Per Section 5.2.2 and Table 5-2, during the previous Seismic Walkdowns five (5) conditions were identified and entered into the Corrective Action Program. Corrective actions were completed for 4 of the 5 items. Table A5-2 of this Annex A provides an updated summary of the conditions and the status of the corrective actions to address these conditions.

Table AS-2. Issues Identified during Seismic Walkdowns Component ID Description of Issue

20C003, The MCR ceiling's restraint system is

20C004C, consistent with design documentation

20C005A, but the design basis Calculation G-20C006C, L12-2 106-1 could not be located from 113, L12-3-86, LI-records management or Iron 8027, LR/TR-Mountain. This issue is to 81238, (also re-constitute design analysis to AWC-U0-7) supplement existing calculation 26-5/Z-12, specifically at MCR ceiling perimeter, during NTTF 2.1 seismic re-evaluation.

20C003 There is a missing panel screw, inside the bottom of the first panel.

Judged acceptable for seismic as-is, but inconsistent with design documentation. (Note 4l Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Action Request ID IR 01428651 IR 01425673 Actions Action Complete Taken Y/N(Notes 1, 2)

No Yes Fl N replaced missing hardware.

A5-2

Table A5-2. Issues Identified during Seismic Walkdowns Action Actions Action Component ID Description of Issue Request Complete Taken ID y /N(Notes 1, 2) 2BE055, 2BE056, Anchorage for ECCS room coolers IR Yes Drawings S-970, S-2GE058 does not match drawings but does 01437853 971, S-972, S-973, match calculation.

(Note 3)

S-975, S-977 are posted against ECR 12-00027 2AC065, 2BC065 Inconsistency between as-built IR No ECR 13-00498 was configuration of 2AC065 and 2BC065 01429745 prepared. Work to instrument racks and calculation PS-install missing 0930.

anchors is scheduled to be performed during P2R20 (scheduled start date:

11/03/14).

OAG12, OBG12, Inconsistency between the OAG12, IR Yes Vendor document OCG12, ODG12 OBG12, OCG12, and ODG12 anchor 01438055 E-5-155 and new bolt size and vendor document calculation PS-E-5-155.

1091 are posted against ECR 13-00459. PS-1091 reconstitutes the engine generator skid assembly calculation to reflect the as-built configuration.

Notes:

1.

"Yes" indicates that corrective actions resulting from the issue are complete.

2.

"No" indicates that corrective actions resulting from the issue are NOT complete. Actions are tracked by the IR number in the station Corrective Action Program.

3.

IR 01411581 was originally identified on the SWCs as being applicable to this issue. Upon further investigation IR 01437853 was written to fully capture the issue.

4.

Description changed from original submittal.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A5-3

A5.3 AREA WALK-BYS The purpose of the Area Walk-Bys is to identify potentially adverse seismic conditions associated with other SSCs located in the vicinity of the items being inspected. The results of the Area Walk-Bys were documented on the AWCs included in Appendix AD.

A separate AWC was filled out for each area inspected. A single AWC was completed for areas where more than one item was located.

No adverse conditions were identified during the Area Walk-Bys associated with the follow-on walkdowns.

Per Section 5.3.1 and Table 5-3, during the previous seismic walkdowns four (4) conditions were identified and entered into the Corrective Action Program. Table A5-3 of this Annex A provides an updated summary of the conditions and the status of the corrective actions to address these conditions. Corrective actions were completed for all 4 of the 4 conditions identified.

Table A5-3. Issues Identified during Area Walk-Bys Component Action Actions Action Description of Issue Request Complete Taken ID/Area ID Y/N(Notes 1, 2)

AWC-U0-1 Open S-hook noted on light fixture IR Yes S-hook closed.

above battery charger panel 3BD003.

01413285 (Note 3)

AWC-U2-2 There is a missing base screw (notes IR Yes FIN - tapped in AWC-U2-2 documents it as 01425994 hole and inserted "anchorage mounting bolt") inside 5/8" bolt.

panel 20C032. Judged acceptable for seismic as-is but missing bolt should be replaced. (Note 3l AWC-U2-27 Fire protection pipe support near HPCI IR Yes Upon further pump missing one of four bolts.

01425997 inspection of pipe Judged acceptable for seismic as-is, support, no bolt but missing bolt should be replaced.

was missing and no work performed.

AWC-U2-22 Seismic housekeeping, unrestrained IR Yes Operations ladder 01406272 returned ladder to proper storage location.

Notes:

1.

"Yes" indicates that corrective actions resulting from the issue are complete.

2.

"No" indicates that corrective actions resulting from the issue are NOT complete. Actions are tracked by the IR number in the station Corrective Action Program.

3.

The description was revised from the original submittal.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A5-4

A 6 Licensing Basis Evaluations See Section 6, no new licensing basis evaluations were performed as a result of conditions identified during the follow-on Walkdowns or Area Walk-Bys.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A6-1

A 7 IPEEE Vulnerabilities Resolution Report See Section 7, no changes of the IPEEE vulnerabilities resolutions were made for this Annex A.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A?-1

A 8 Peer Review A peer review team consisted of at least two individuals, was assembled and peer reviews were performed in accordance with Section 6: Peer Reviews of the EPRI guidance document. The Peer Review process included the following activities:

• Review of the selection of SS Cs included in the follow-on walkdowns

• Review the checklists of items completed during the follow-on Seismic Walkdowns and Area Walk-Bys

• Review of Licensing basis evaluations, as applicable

• Review of the decisions for entering the potentially adverse conditions identified during the follow-on walkdowns into the CAP process

• Review of the final submittal report

• Provide a summary report of the peer review process in the submittal report A peer review was performed independently from this report and the summary Peer Review Report is provided in Appendix AF of this Annex A.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A8-1

A 9 References See Section 9 for references 1 - 10. The following new references were added for this Annex A:

11. 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

12. Exelon Generation Company, LLC 180-day Response to 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, dated November 19, 2012 (RS-12-173)

13. 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, dated September 16, 2013 (RS-13-213)

14. Supplemental Response to 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, dated March 25, 2014 (RS-14-001)

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 A9-1

Appendix AA Project Personnel Resumes and SWE Certificates Resumes and certificates (where applicable) for the following people are found in Appendix AA of this Annex A:

T. Gallagher,........................................................................................... AA-2 P. Kester,............................................................................................... AA-6 J. Lucas,.................................................................................................. AA-8 R. Birmingham........................................................................................ AA-10 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AA-1

~

=:r Exelon.

Tracey L. Gallagher EDUCATION Pennsylvania State University, B.S. Civil Engineering, 2007 EXPERTISE Steel, Concrete, Foundation Design and Analysis Seismic Analysis of New and Existing Structures Design Programs: STAAD Pro., GTStrudl, PCA Column, APlan, MathCAD, Visio, Excel, AutoCAD EXPERIENCE Exelon Generation (7/2012 - Present)

Lead Structural Engineer for the Fukushima 2.1 and 2.3 NTTF at Peach Bottom Atomic Power Station. Completed the EPRI Seismic Walkdown Engineer (SWE) Training.

Lead Structural Engineer on the Adjustable Speed Drive (ASD) project.

Sargent & Lundy, LLC -Wilmington, DE (7/2007 - 6/2012)

Structural Associate 3 - Design Engineering in the nuclear power industry.

Duke Power Company Provided design engineering and onsite installation support for the Protected Service Water (PSW) Building Project associated with Oconee Nuclear Station's Tornado and High Energy Line Break (HELB) Mitigation License Amendment.

PSE&G (Salem & Hope Creek Power Stations)

Worked on a team which performed a Site Extent of Condition Assessment for the Unattended Openings Program (Security).

Design of concrete and steel Blast Proof Enclosures for Security Upgrades.

Design and Analysis of lifting lugs/steel structures to meet the regulatory requirements of NUREG 0612 and ANSI 14.6 "Special Lifting Devices" Lead Structural Engineer on the Feedwater Heater Tube Bundle Replacement Project.

Responsible for the analysis of the Turbine Building structure and sub grade concrete vaults for heavy load paths associated with the Rigging Plan. Provided field installation/outage support.

Lead Engineer on the replacement of the Reactor Pressure Vessel (RPV) Head Strongback and Carousel.

Seismic analysis of proposed and existing pipe supports, conduit supports and cabinets/panels for new loads.

Dominion Power Company Provided installation support for refueling outages at North Anna and Surry Power Stations. These consisted of major capacity up-rate projects which included the replacement of the Feedwater Heater Tube Bundles and the Generator Stator/Rotor.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AA-2

=:' Exelon.

Responsible for the heavy haul path analysis and the re-evaluation of the Turbine Building structure for the increased weight of the new generator.

Exelon Peach Bottom Fall 2007 outage support Borough of State College - State College, PA (5/2006 - 8/2006)

Engineering Intern, Public Works Dept.

PENN DOT - District 5 Allentown, PA (6/2006 - 8/2006)

Engineering Intern QUALIFICATIONS AND TRAINING EPRI Seismic Walkdown Engineer (SWE) training, 2012 Exelon Qualified Structural Engineer SQUG Qualified, 2014 MEMBERSHIPS Member, Women in Nuclear (WIN)

Member, Phi Sigma Rho - National Engineering Sorority Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AA-3

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~*-*~ RESEARCH INSllTUH Certificate of Completion Tracey Gallagher Training on Near Term Task Force Recommendation 2.3

- Plant Seismic Walkdowns July 27, 2012 Date Ill!~

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Paul R. Kester EDUCATION Princeton University 1987 - 8. S. In Mechanical Engineering Drexel University 1995 - M. S. In Civil Engineering PROFESSIONAL EXPERIENCE 1993 - present EXELON Nuclear I PECO Energy - Peach Bottom Atomic Power Station Senior Design Engineer

• Program manager for structural Maintenance Rule implementation

• Program manager for penetration seals and hazard barrier control

• Responsible for station seismic designs and equipment qualification

• Responsible for heavy load rigging evaluations

• Responsible for design of plant structural modifications 1990 - 1993 Philadelphia Electric Company - Nuclear Group Headquarters Design Engineer

• Program manager for penetration seals and hazard barrier control

• Responsible for design of plant structural modifications

• Responsible for writing design and purchase specifications 1987 - 1990 Philadelphia Electric Company - Peach Bottom Atomic Power Station Construction Engineer

• Responsible for resolution of field design and installation problems

• Responsible for conceptual design idea development

• Responsible for developing installation and testing procedures for new equipment

• Responsible for final acceptance inspections for new equipment QUALIFICATIONS

• SQUG Seismic Walkdown and Evaluation Qualified Engineer (5 day course)

• EXELON Maintenance Rule Structures Monitoring I Program Coordinator

• Peach Bottom Structural System Manager Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AA-6

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Jesse Lucas, P.E., MBA Relevant Qualifications:

BS Nuclear Engineering, 7 years Exelon, 25 years industry experience MBA and understanding of Exelon Nuclear Project Authorization Process Employment History:

Exelon Generation 2004 - Present Design Engineer - responsible for various modifications and evaluations Engineering Services Engineer - responsible for department engineering budget, department self-assessments, and representing Engineering at the Station Ownership Committee.

Lead Responsible Engineer (LRE) - Peach Bottom Response to NTTF Orders and Recommendations resulting from Fukushima

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Site LRE for Flood Feature Walkdowns in accordance with NEI 12-07

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Site LRE for Flood Reevaluations in accordance with CR-7046

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Site Engineer for Seismic Walkdowns - completed EPRI Training on NTTF Recommendation 2.3 - Plant Seismic Walkdowns

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Site Engineer for Spent Fuel Pool Instrumentation

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Site LRE for Hardened Containment Vent System

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Site LRE for FLEX Modifications - Mechanical and Electrical RCM Technotogies 1 Inc.

1993 - 2004 Client Manger for of design services contracts with power industry clients lmpell - ABB Corporation 1991 -1993 Stone & Webster Inc.

1986 - 1989 Education:

Texas Christian University MBA - Finance Pennsylvania State University BS - Nuclear Engineering Licenses and Associations:

Professional Engineer - State of Delaware Registration Number 9586 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AA-8

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Robert Steele Birmingham 1218 Furnace Road Airville, Pa 17302 Email n2fix@aol.com (717) 858-4144 Career Summary A disciplined, goal oriented professional with over 32 years experience in the field of Nuclear Power Plant Operations, Management, Training, Procedure Writing, Major strengths are organization, attention to detail, problem solving, and change management.

Over 33 years experience as a volunteer fire fighter. Certified scuba diver with over 25 yrs experience.

Work Experience 10/2010 -

12-2013 9/1992 -

9/2009 04/1996 -

5/1998 Westwind Group LLC, Wrightsville Beach, North Carolina.

Assigned to perform as the Operations Representative for the MSO, ASD and Fukushima projects at the Peach Bottom Atomic Power Station for Exelon Nuclear, Delta, Pennsylvania.

Exelon Nuclear, Delta, Pennsylvania Nuclear Senior Reactor Operator, On shift Control Room Supervisor Performed nuclear fuel element handling activities including transfer, core loading and unloading and fuel pool operations. Directed reactor operators and equipment operators during transient and emergency situations, in accordance with abnormal operating, off normal, operational transient and emergency operating procedures. Conducted operations and inspections outside of the control room. Provided oversight during system electrical switching and electric sub station activities. Authorized maintenance activities on units and changes in system and equipment status. Authorized the performance of surveillance testing and reviewed testing upon completion. Approved and authorized system and equipment blocking under the clearance e and tagging process. Provided training to EO, RO and SRO trainees while on shift. Administered EO plant walk around exams for qualification. Coordinated the performance of the plant schedule for plant and equipment testing, equipment blocking and other work activities.

Reviewed all documented plant deficiencies for regulatory and tech spec compliance, and for overall plant impact.

Exelon Nuclear, Delta, Pennsylvania Initial Licensed Operator Instructor Qualified as a classroom and control room simulator instructor and as a simulator operator. conducted classroom, simulator and in-plant training sessions for a class of initial reactor and senior reactor operator trainees. Conducted classroom and in-plant training for a class of initial equipment operator trainees. Maintained an active SRO license while an instructor, performing control room shift supervisor duties during weekends and load drops.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AA-10

8/1991 -

9/1992 7/1988 -

9/1991 8/1987-7/1988 11/1981 8/1987 4/1977 -

5/1981 Exelon Nuclear, Delta, Pennsylvania Trainee, Senior Reactor Operator Exelon Nuclear, Delta, Pennsylvania Reactor Operator, On shift Control Room RO Responded to unit, system or equipment abnormalities, diagnosing the cause and recommending or taking action as required. Recorded data from control room indicators during rounds. Identified malfunctions of equipment, instruments or controls and reported the conditions to the supervisor. Monitored and operated turbines, generators, pumps and auxiliary power plant equipment.

Implemented operational procedures during normal operations and during startups and shutdowns. Dispatched instructions to personnel through radio or telephone systems to coordinate auxiliary equipment operation. Adjusted reactor controls to position control rods and adjust recirc pump speed to regulate flux level, reactor period, coolant temperature and rate of power change in accordance with operating procedures. Performed plant surveillance testing in the control room and coordinated performance of testing outside of the control room. Develop and write system and equipment safety blocking permits under the clearance and tagging process.

Exelon Nuclear, Delta, Pennsylvania Trainee, Reactor Operator Exelon Nuclear, Delta, Pennsylvania Floor Operator Responded as directed to unit, system or equipment abnormalities and reporting observations to the control room, and taking corrective actions as directed.

Recorded data from plant indicators during performance of rounds. Monitored in plant equipment and identify malfunctions of equipment, instruments or controls and report the condition to the control room. Implemented operational procedures as directed during normal and during startups and shutdowns.

Coordinated activities with the control room or other equipment operators using the radio or telephone systems to operate plant auxiliary equipment. Performed surveillance testing as directed by the control room. Removed equipment from service and applied system and equipment safety blocking permits under the clearance and tagging process. Returned equipment to service after completion of maintenance. Acted and a member of the plant fire brigade and medical safety team.

United States Coast Guard Machinery Technician Served on the cutter POINT ROBERTS, Mayport, Florida and at Training Center Cape May, New Jersey. Attained the rank of Machinery Technician Fist Class MKl (E-6). Duties on the cutter POINT ROBERTS were maintaining the diesel engines and generators, performing Engineer of the Watch duties in the engine room and standing bridge watches performing helm and navigation duties.

Assigned responsibilities included #1 rescue swimmer and starboard machine gunner. Qualified as a Boarding Officer and participated in the arrest and seizure Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AA-11

6/1972 -

7/1976 Education 1972 of over 200 tons of illegal drugs. Served as armed escort to the President of the United States.

Duties at Training Center Cape May were operating the base steam heating plant, qualifying to the same standard as a New Jersey State Certified Boiler Operator. Maintenance of boiler plant included boiler cleaning and refractory repair, rebuild of plant valves, replacement of system piping and operation of the demineralized water system.

Later responsibilities were managing the base motor pool of over 40 vehicles including cranes, construction equipment, bucket trucks and fire equipment.

Maintained the base deep well fresh water pumps, backup emergency generators, and coordination of all base fuel, oil and water deliveries. Qualified as operator for a 25 ton crane, backhoe and loader, fork lift, and other various equipment. Additional duties were operation of fire equipment to provide backup to the base fire department for structural and aircraft crash fire and rescue and provided mutual aid to the towns of Cape May, Wildwood and Wildwood Crest during major fires.

Extensive experience with diesel engine maintenance, auxiliary boiler operation and aircraft and structural fire fighting.

Central Sports Cars, Holmes, Pa.

Technician Responsibilities included managing a two-three person automobile rebuilding shop. Duties were rebuilding body, electrical and mechanical component of wrecked English automobiles, including welding and painting. Coordinated deliveries of automobile parts to other repair facilities in the area. Maintained racing car for SCCA E-Production sports car racing.

Penncrest High School, Media, Pa.

Graduated Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AA-12

Appendix AB Equipment List See Appendix B. No changes were made to the Unit 2 and Unit 0 Equipment Lists (SWEL's) for this Annex A.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AB-1

Appendix AC Seismic Walkdown Checklist (SWC's)

Table AC-1 provides a description of each item (1 item), anchorage verification confirmation, a list of Area Walk-By Checklists associated with each item and comments of each Seismic Walkdown Checklist. All items in Table AC-1 were deferred items listed in Table E-1 of this report, and were accessible during the follow-on walkdowns.

Table AC-2 provides a description of each item (3 items) subject to supplemental internal inspections. All items in Table AC-2 of this report were listed in Table E-2 and E-3, and were accessible without safety and operational hazard.

The "Anchorage Configuration Confirmation" column is described in Section 5.2.1 of this report. The last column in Tables AC-1 and AC-2 provides the corresponding Area Walk-By Checklist (AWC). There are a total of 1 AWC included in Appendix AD of this Annex A.

Table AC-1. Summary of Seismic Walkdown Checklists Anchor Component ID Description Configuration AWC-Ux-YY Confirmed?

E13A4 480V Bus E13A4 (OOB094)

N U0-14 Table AC-2. Summary of Supplemental Internal Inspections Component ID 2AD003 200003 OAC097 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Description Battery Charger 2A Battery Charger 20 Diesel Generator OAG12 Control Panel Anchor Configuration AWC-Ux-YY Confirmed?

y U2-23 y

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Status: Y~ NO UO Equipment ID No.

~o,...oa.... 0'°"'9""'~----- Equip. Class1 (021 Low Voltage Switchqears Equipment Description..... 4=8;::..0V.::.....::B;.=:u=s-=E'-""1"""3A'-'-'-4-----------------------

Location: Bldg. ECT-3 Floor El. 153'-0" Room, Area Switch Gear Rooms Manufacturer, Model, Etc. (optional but recommended) 1005 ITE Circuit Breaker LTD. 33*44640 Instructions for Completing Checklist This checklist may be used to document the results of the Seismic Walkdown of an item of equipment on the SWEL. The space below each of the following questions may be used to record the results of judgments and findings. Additional space is provided at the end of this checklist for documenting other comments.

Anchorage I. Is the anchorage configuration verification required (i.e., is the item one YO Ni;zl of the 50% of SWEL items requiring such verification)?

2. Is the anchorage free of bent, broken, missing or loose hardware?

Y~ NO UO N/AO

3. Is the anchorage free of corrosion that is more than mild surface Y~ NO UO N/AO oxidation?

4. Is the anchorage free of visible cracks in the concrete near the anchors?

Yf$J NO UO N/AO

5. Is the anchorage configuration consistent with plant documentation?

YO ND UO N/Ap!I (Note: This question only applies if the item is one of the 50% for which an anchorage configuration verification is required.)

6. Based on the above anchorage evaluations, is the anchorage free of Y~ NO UD potentially adverse seismic conditions?

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Status: Y~ NO UO Equipment ID No.

"""OO.... B...,0'"""9...... 4 _____ Equip. Class1 (02) Low Voltage Switchgears Equipment Description ~4~80~V~B~us~E~13=~~4..__ _____________________ _

Interaction Effects

7. Are soft targets free from impact by nearby equipment or stmctures?

YO NO UO N/A~

8. Are overhead equipment, distribution systems, ceiling tiles and lighting, Yigl" NO UO N/AO and masonry block walls not likely to collapse onto the equipment?

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9. Do attached lines have adequ~ flexibility to avoid damage?

YO NO UO N/A~

ft) 0 e v-tr h.-ud aHo,J, J /;,,rs

10. Based on the above seismic interaction evaluations, is equipment free of potentially adverse seismic interaction effects?

Other Adverse Conditions YpfNO UO

11. Have you looked for and found no other seismic conditions that could Y!Bl NO UO adversely affect the safety functions of the equipment?

Comments (Additional pages may be added as necessary)

Evaluated by: __..~

• '"""-'"'""'A'-~+-~---------------- Date:

I r-

. / c

.&'~

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AC-3

Seismic Walkdown Checklist (SWC)

Sheet 3 of 5 Stah1s: Y[gj ND uD Equipment ID No. ""O"""OB----..09._4..._____ Equip. Class1 (02) Low Voltage Switchqears Equipment Description...:.4.::.BO=-V.:....::B:.:u.::.s-=E:...:.1..:o3A:....:....:.4 ______________________ _

Photo ra >hs Note:

Note:

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Note:

Note: East Bay AC-4

Seismic Walkdown Checklist (SWC)

Equipment ID No.

""O""'OB"'"0.-9.... 4.__ __ _

Sheet 4 of s Stahrs: Y[gl ND UO Equip. Class (02) Low Voltage Switchqears Equipment Description -.4""'"80""'"V"-=B""'u""'"s"""E'""'1-"-3A~4 ______________________ _

Photographs 06 24 2013 Note: East Bay Note: Center Bay Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Note: East Bay Note: Center Bay AC-5

Seismic Walkdown Checklist (SWC)

Sheet 5 of 5 Status: Yigj NO UO Equipment ID No.

""'OO'""'B..... 0"""9"""4 _____ Equip. Class (02) Low Voltage Switchgears Equipment Description...:..48=0:...;V::...=B=us=--=E...:..1=3A'"-'-4-'-------------------------

Photographs Note: Center Bay Note: West Bay Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Note: Center Bay Note: West Bay AC-6

Seismic Walkdown Checklist (SWC) SUPPLEMENTAL CABINET INSPECTION Equipment ID No.:

2AD003 (SEE APPENDIX C PAGE C-136)

Equipment Class:

(16) Battery Chargers and Inverters Equipment

Description:

BATTERY CHARGER*

Project:

Peach Bottom Unit 2 SWEL Location (Bldg, Elev, Room/Area):

TB El. 135' (T2-170)

Sheet 1of4 Status:~ N U

Man u fact u re r /Mode I:

Thomas & Betts Power Solutions Instructions for Completing Checklist This checklist may be used to document the results of the Seismic Walkdown of an item of equipment on the SWEL The space below each of the following questions may be used to record the results of judgments and findings. Additional space is provided at the end of this checklist for documenting other comments.

Anchorage---------------

ls ancl:lorage configuration 1Jerificati~uired (i.e., is tAe-itemHO*A*0H0*f-flthMeiheBIGoP~i'tt"------------

---

ofSWELitems requinng such verfficaUO-n)?,--------------**----------------*---*---*----------

2.

Is the anchorage free of bent, broken, missing or loose hardware?

3.

Is the anchorage free of corrosion that is more than mild surface oxidation?

4.

Is the anchorage free of visible cracks in the concrete near the anchors?

5.

Is the anchorage configuration consistent with plant documentation? (Note:

This question only applies if the item is one of the 50% for which an anchorage configuration verification is required.)

6.

Based on the above anchorage evaluations, is the anchorage free of potentially adverse seismic conditions?

SEE SWC IN APPENDIX C FOR RESPONSES Interaction Effects

7.

Are soft targets free from impact by nearby equipment or structures?

8.

Are overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls not likely to collapse onto the equipment?

9.

Do attached lines have adequate flexibility to avoid damage?

10.

Based on the above seismic interaction evaluations, is equipment free of potentially adverse seismic interaction effects?

SEE SWC IN APPENDIX C FOR RESPONSES Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AC-7

Seismic Walkdown Checklist (SWC) SUPPLEMENT AL CABINET INSPECTION Equipment ID No.:

2AD003 (SEE APPENDIX C PAGE C-136)

Equipment Class:

(16) Battery Chargers and Inverters Equipment

Description:

BATTERY CHARGER Other Adverse Conditions (SUPPLEMENTAL CABINET INSPECTION)

11.

Have you looked for and found no adverse seismic conditions that could adversely affect the safety functions of the equipment?

a.

Internal components secured? (i.e. no loose or missing fasteners)

b.

Are adjacent cabinets secured together?

c.

No other adverse seismic conditions?

Sheet 2 of 4 Status: IT] N U

!YI N U y ~ u

~/rt

!YI N U Gomments------------** ----------*-------------*-----------**-*-**---..

SeismicWalkdown Team T. Gallagher & J. Lucas on 07/16/14.

FIN team personnel opened the front of the panel to allow for the visual inspection of the internal anchorage.

No missing bolts or degraded conditions were found. Photos were taken to document the adequate Configuration of the internal components.

Evaluated by:

T. Gallagher J. Lucas Photos See sheets 3 -4.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Date:

07/16/14 07/16/14 AC-8

Seismic Walkdown Checklist (SWC)

Equipment ID No.

.::2"-"A=D-"'0"""0"°"3 ____

Sheet 3 of 4 Status: Y~ ND UD Equip. Class* (16) Battery Chargers and Inverters Equipment Description _a=a=tte=rv'""-'C::;.:.h.:.::a""rq=e=r------------------------

Photo ra hs Note:

Note:

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Note:

Note:

AC-9

Seismic Walkdown Checklist (SWC)

Sheet 4 of 4 Status: Y~ ND UD Equipment ID No. =2,..,,A:D..::;0-=.03=------ Equip. Class2 (16) Battery Chargers and Inverters Equipment Description =B=a=tte=ry,..L...;C:..:..h.:..::a:..:..orq=e:..:..r _______________________ _

Note:

Note:

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Note:

Note:

AC-10

Seismic Walkdown Checklist (SWC) SUPPLEMENT AL CABINET INSPECTION Equipment ID No.:

2DD003 (SEE APPENDIX C PAGE C-183)

Equipment Class:

(16) Battery Chargers and Inverters Equipment

Description:

BATTERY CHARGER Project:

Peach Bottom Unit 2 SWEL Location (Bldg, Elev, Room/Area):

TB El. 135' (T2-172)

Sheet 1of4 Status: CIJ N U

---

~

Manufacturer/Model:

Thomas & Betts Power Solutions Instructions for Completing Checklist This checklist may be used to document the results of the Seismic Walkdown of an item of equipment on the SWEL. The space below each of the following questions may be used to record the results of judgments and findings. Additional space is provided at the end of this checklist for documenting other comments.

Anchorage-----------------------**--------------------*----------*

Is anchorage configuration verification required (i.e., is the item one of the 60%

• ----*--------6f-SWEL1temfiequinng sucn verff1cafi0nY.

2.

Is the anchorage free of bent, broken, missing or loose hardware?

3.

Is the anchorage free of corrosion that is more than mild surface oxidation?

4.

Is the anchorage free of visible cracks in the concrete near the anchors?

5.

Is the anchorage configuration consistent with plant documentation? (Note:

This question only applies if the item is one of the 50% for which an anchorage configuration verification is required.)

6.

Based on the above anchorage evaluations, is the anchorage free of potentially adverse seismic conditions?

SEE SWC IN APPENDIX C FOR RESPONSES Interaction Effects

7.

Are soft targets free from impact by nearby equipment or structures?

8.

Are overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls not likely to collapse onto the equipment?

9.

Do attached lines have adequate flexibility to avoid damage?

10.

Based on the above seismic interaction evaluations, is equipment free of potentially adverse seismic interaction effects?

SEE SWC IN APPENDIX C FOR RESPONSES Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AC-11

Seismic Walkdown Checklist (SWC) SUPPLEMENT AL CABINET INSPECTION Equipment ID No.:

2DD003 (SEE APPENDIX C PAGE C-183)

Equipment Class:

(16) Battery Chargers and Inverters Equipment

Description:

BATTERY CHARGER Other Adverse Conditions (SUPPLEMENTAL CABINET INSPECTION)

11.

Have you looked for and found no adverse seismic conditions that could adversely affect the safety functions of the equipment?

Sheet 2 of 4 Status: IT] N U

a.

Internal components secured? (i.e. no loose or missing fasteners)

ISj N U

b.

Are adjacent cabinets secured together?

c.

No other adverse seismic conditions?

"I' l&J u,..J/,:J, ISj N U

• --Comments--------*--*-**-* ------------------------*---------**-* *-*

• ---------~-------**

--seiSrilicwarKaawnT*eam-r : Ga11agher & J. Lucas on 07/16/14.

FIN team personnel opened the front of the panel to allow for the visual inspection of the internal anchorage.

No missing bolts or degraded conditions were found. Photos were taken to document the adequate Configuration of the internal components.

Evaluated by:

T.Gallagher-~ ~

J.Lucas

~~

Photos See sheets 3 - 4.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Date:

07 /16/14 07/16/14 AC-12

Seismic Walkdown Checklist (SWC)

Sheet 3 of 4 Stah1s: Y[8j NO uD Equipment ID No. =20:;.=.D""'"0.=;...03"------ Equip. Class1 (16) Battery Chargers and Inverters Equipment Description.-B=a=tte=rv~C""'"h"""a....

rq.._.e..... r _______________________ _

Photo ra hs Note:

Note:

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Note:

Note:

AC-13

Seismic Walkdown Checklist (SWC)

Sheet 4 of 4 Status: YIZ! ND uD Equipment ID No.

=2=0=0....::;0"""0"'-3 _____ Equip. Class2 (16) Battery Chargers and Inverters Equipment Description =B=a=tte=ry..........,.C.... h'""a....

rg""'e:;.;..r _______________________ _

Photographs Note:

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Note:

AC-14

Sheet 1of3 Status: [!] N U Seismic Walkdown Checkllat (SWC) SUPPLEMENT AL CABINET INSPECTION Equipment ID No.:

OAC097 (SEE APPENDIX C PAGES C-347 (Unit 2) and C-310 (Unit 3)

Equipment Class:

(20) Control Panels & Cabinets Equipment

Description:

STBY. DIESEL GEN. OAG12 CONTROL PANEL Project:

Peach Bottom Unit 2 & 3 SWEL Location (Bldg, Elev, Room/Area):

Diesel Generator Bldg, 121*-0*, D/G-3 (Bay E-1)

Manufacturer/Model:

Fairbanks Morse Engine/Colt Instructions tor Completing Checkllat This checklist may be used to document the results of the Seismic Walkdown of an item of equipment on the SWEL. The space below each of the following questions may be used to record the results of judgments and findings. Additional space is provided at the end of this checklist for documenting other comments.

Anchorage

1.

Is anchorage configuration verification required (I.e., is the item one of the 500.4 of SWEL items requiring such verification)?

2.

Is the anchorage free of bent, broken, missing or loose hardware?

3.

Is the anchorage free of corrosion that is more than mild surface oxidation?

4.

Is the anchorage free of visible cracks in the concrete near the anchors?

5.

Is the anchorage configuration consistent with plant documentation? (Note:

This question only applies if the item is one of the 50% for which an anchorage configuration verification is required.)

6. Based on the above anchorage evaluations, is the anchorage free of potentially adverse seismic conditions?

SEE SWC IN APPENQlX C FOR RESPONSES lnteqctlon Etttctt

7.

Are soft targets free from impact by nearby equipment or structures?

8.

Are overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls not likely to collapse onto the equipment?

9.

Do attached lines have adequate flexibility to avoid damage?

1 O.

Based on the above seismic interaction evaluations, is equipment free of potentially adverse seismic interaction effects?

SEE SWC IN APPENDIX C FOR RESPONSES Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AC-15

Sheet 2of3 Status:[!] N U Seismic Walkdown Checldlllt (SWC) SUPPLEMENT AL CABINET INSPECTION Equipment ID No.:

OAC097 (SEE APPENDIX C PAGES C-347 (Unit 2) and C-310 (Unit 3)

Equipment Class:

(20) Control Panels & Cabinets Equipment

Description:

STBY. DIESEL GEN. OAG12 CONTROL PANEL Other Ady"" CondltloQI <SUPPLEMENTAL CABINET IN§PECJIONl

11. Have you looked for and found no adverse seismic conditions that could adversely affect the safety functions of the equipment?

a. lntemal components secured? (i.e. no loose or missing fasteners)

b. Are adjacent cabinets secured together?

c. No other adverse seismic conditions?

Comment!

Seismic Walkdown Team T. Gallagher and J. Lucas 09/16113.

~NU

~NU

~NU Operations opened the back panel to allow for the visual Inspection of the Internal anchorage. No degraded or missing anchorages were found. Photos were taken to document the secure configuration of the internal components. Equipment has external anchorage.'

Evaluated by:

_T._G_a1......:1ag..._he_r~~-l~~

........ ~-(J...,t.-~"'-'~

... ~"'"'---- oate:

09116113 J.Lucas

~~

~

Photo!

SeeSheet3.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 09/16/13 AC-16

Sheet 3 of 3 Seismic Walkdown Checklist (SWC) SUPPLEMENTAL CABINET INSPECTION Equipment ID No.:

OAC097 (SEE APPENDIX C PAGES C-347 (Unit 2) and C-310 (Unit 3)

Equipment Class:

(20) Control Panels & Cabinets Equipment

Description:

STBY. DIESEL GEN. OAG12 CONTROL PANEL Note: Diesel Generator Control Panel OAC097 Note: Internal mounting Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Note: Mounting to adjacent cabinet Note: Internal mounting AC-17

Appendix AD Area Walk-By Checklist (AWC's)

Table AD-1 and AD-2 provides the location of each walk-by area that was previously inaccessible and deferred, as well as a list of walkdown items associated with each area.

Table AD-1. Unit 2 Area Walk-By Checklists (AWCs)

No new AWC's for the Unit 2 follow-on walkdowns.

Table AD-2. Unit O Area Walk-By Checklists (AWCs)

AWC-Ux-Building yy U0-14 Emerg. Cooling Tower Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Elevation Location 153 ECT-3 Component ID E13A4 (00B094)

AD-1

Area Walk-By Checklist (AWC)

Location: Bldg. C... l Floor El.

I ?'-3 Instructions for Completing Checklist r.{

Sheet 1 of.2:'

Status:@N U This checklist may be used to document the results of the Area Walk-By near one or more SWEL items. The space below each of the following questions may be used to record the results of judgments and findings.

Additional space is provided at the end of this checklist for documenting other comments.

l. Does anchorage of equipment in the area appear to be free of potentially adverse seismic conditions (if visible without necessarily opening cabinets)?

YpJ ND UD N/AD

2. Does anchorage of equipment in the area appear to be free of significant Y~ ND UO N/AO degraded conditions?

3. Based on a visual inspection from the floor, do the cable/conduit Y~ ND UD N/AD raceways and HV AC ducting appear to be free of potentially adverse seismic conditions (e.g., condition of supports is adequate and fill conditions of cable trays appear to be inside acceptable limits)?

4. Does it appear that the area is free of potentially adverse seismic spatial YI/( NO UO N/ AO interactions with other equipment in the area (e.g., ceiling tiles and lighting)?

ll lf the room in which the SWEL item is located is very large (e.g., Turbine Hall), the area selected should be described. This selected area should be based on judgment, e.g., on the order of about 35 feet from the SWEL item.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250

< C-5 >

AD-2

Area Walk-By Checklist (AWC)

Sheet2 of,2" Location: Bldg. e c... I Floor El.

/S3 Room,Area 13 flsrm V£} 00/309'1 {EnAti) 11\\G 6/Zf/17

5. Does it appear that the area is free of potentially adverse seismic interactions that could cause flooding or spray in the area?

6. Does it appear that the area is free of potentially adverse seismic interactions that could cause a fire in the area?

~ND UD N/AD Yl;XJ ND UD N/AD

7. Does it appear that the area is free of potentially adverse seismic Yf,a ND UD N/AD interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding)? f=rf&n loo-if It) ~Je1/~e,,{'t. fa-tA.rd Iv~

9re.Jl.Vl fwt~/-

A6'.;~ 1t'C.c..*rd Iv~

8. Have you looked for and found no other seismic conditions that could adversely affect the safety functions of the equipment in the area?

YJ& ND UD Comments (Additional pages may be added as necessary)

Evaluated by: ___ ~-~,£-:£_'1---="---------------- Date:

7L::;

r-~ !i=

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250

<C-6 >

tfl /; S/2.L)/.3 AD-3

Area Walk-By Checklist (AWC)

Location: Bldg. ECT-3 Floor El. 153'-0" Photo ra hs Note:

Note: Breaker Hoist Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Room, Area1 Switchgear Room Note:

Note:

Sheet 3 of 4 Status: Y~ NO UO AD-4

Area Walk-By Checklist (AWC)

Location: Bldg. ECT-3 Floor El.153'-0" Photographs Note:

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Room, Area Switchgear Room Sheet 4of4 Status: Y~ NO UO AD-5

AppendixAE Plan for Walkdown of Inaccessible Equipment and Assessment of Electrical Cabinet Internal Inspections No additional follow-on walkdowns resulting from this Annex A.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AE-1

Appendix AF Peer Review Report This appendix includes the Peer Review Team's report on the follow-on Seismic Walkdowns and Walk-Bys.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AF-1

Peer Review Report for Near Term Task Force (NTTF) Recommendation 2.3 Seismic Walkdown of Peach Bottom Unit 2 Peer Reviewers:

Tracey Gallagher (Team Leader)

Paul Kester Tracey Gallagher Peer Review Team Leader Signatur Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 1 Date 10/02/2014 AF-2

Contents AF.1 Introduction..................................................................................................... AF-4 AF.1.10verview................................................................................................ AF-4 AF.1.2 Peer Reviewers..................................................................................... AF-4 AF.1.3 SWEL Development.............................................................................. AF-5 AF.1.4 Seismic Walkdown................................................................................ AF-5 AF.2 Peer Review - Selection of SS Cs................................................................... AF-6 AF.2.1 Purpose................................................................................................. AF-6 AF.3 Review of Follow-on Seismic Walkdown & Area Walk-By Checklists....... AF-7 AF.3.1 Overview............................................................................................... AF-7 AF.3.2 Follow-on Seismic Walkdown Checklists.............................................. AF-7 AF.3.3 Evaluation of Findings........................................................................... AF-9 AF.4 Review of Licensing Basis Evaluations...................................................... AF-10 AF.5 References.................................................................................................... AF-11 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AF-3

AF.1 Introduction AF.1.1 OVERVIEW This report documents the independent peer review for the Near Term Task Force (NTTF) Recommendation 2.3 Seismic Walkdowns performed by Exelon Engineering Department for Unit 2 of Peach Bottom Atomic Power Station (PBAPS). The peer review addresses the following activities:

Review the selection of the structures, systems, and components (SSCs) included in the follow-on walkdowns, Review the checklists of the items completed during the follow-on Seismic Walkdowns & Area Walk-Bys, Review of any licensing basis evaluations, Review of the decisions for entering the potentially adverse conditions identified during the follow-on walkdowns into the plant's Corrective Action Program (CAP), and Review of the final submittal report.

Summarize the results of the peer review process in the final submittal report.

AF.1.2 PEER REVIEWERS The Peer Reviewers are Tracey Gallagher and Paul Kester. Ms. Gallagher is the Peer Review Team Leader, per the EPRI Seismic Walkdown Guidance (Reference 1). As Peer Review Team Leader, she was responsible for the entire peer review process, including completion of the final peer review documentation in this report. The Peer Reviewers' qualifications are briefly summarized as follows:

Ms. Gallagher is a degreed civil/structural engineer and has over 7 years of nuclear power experience. She has been trained as an EPRI Seismic Walkdown Engineer and is SQUG qualified.

Mr. Kester is a degreed mechanical engineer with a master's degree in civil engineering and has over 20 years of nuclear power experience at Peach Bottom. Mr. Kester and has been trained as a Seismic Capability Engineer (EPRI SQUG training) for the use of the SQUG Generic Implementation Procedure (GIP) for new and replacement components and equipment.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AF-4

AF.1.3 SWEL DEVELOPMENT No changes were made to the SWEL for the follow-on walkdown activities.

AF.1.4 SEISMIC WALKDOWN The peer review of the seismic walkdowns was performed by Ms. Gallagher and Mr.

Kester on October 02, 2014. The review included the SWCs for the (2) Unit 2 supplemental internal cabinet inspections completed, including checklists, photos, and drawings where applicable. There were no new AWCs for this Annex A. All common unit SWCs and AWCs were peer reviewed in the Unit 3 updated submittal report (Ref.

14). Interviews were conducted with SWEs to assess conduct of the walkdowns and adherence to the EPRI Seismic Walkdown Guidance (Reference 1).

No issues (IR's) were identified which challenged the current licensing basis.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AF-5

AF.2 Peer Review - Selection of SSCs AF.2.1 PURPOSE The purpose of this section is to describe the process to perform the peer review of the selected structures, systems, and components, (SSCs) that were included in the Seismic Walkdown Equipment List (SWEL).

However, this peer review is performed for the SSC's that were previously inaccessible and were completed during the follow-on Seismic Walkdowns and Area Walk-Bys. There are no changes to the SWEL, so the selection of new SSCs does not apply in this case.

This peer review is based on an interview with the seismic walkdown engineers (SWE) subsequent to performance of those activities.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AF-6

AF.3 Review of Follow-on Seismic Walkdown &

Area Walk-By Checklists AF.3.1 OVERVIEW The peer review of the remaining follow-on walkdowns for Annex A was performed on October 02, 2014 by Ms. Gallagher and Mr. Kester. The Peer Review Team reviewed Seismic Walkdown Checklists (SWC) that were performed for Peach Bottom Unit 2 and interviewed the walkdown team members regarding details in checklists.

AF.3.2 FOLLOW-ON SEISMIC WALKDOWN CHECKLISTS Peach Bottom Unit 2 equipment inspected during the follow-on walkdowns is included in the peer review; see the follow-on Seismic Walkdown and Area Walk-By Checklists presented below:

Table AF.3-1. Follow-on Seismic Walkdown Checklists Equipment ID Description (Applicable Area Walkby) 2A0003 Battery Charger (AWC U2-23) 2A 200003 Battery Charger (AWC U2-13) 20 Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 Equipment Class (16) Battery Chargers and Inverters (16) Battery Chargers and Inverters Location Observations No issues with the Turbine Bldg SWC orAWC T2-170 applicable to this El. 135' equipment or its conclusions were identified.

No issues with the SWC orAWC Turbine Bldg applicable to this T2-172 equipment or its El. 135' conclusions were identified.

AF-7

Table AF.3-2. Follow-on Area Walk-By Checklists No additional AWCs were performed for the follow-on walkdown activities.

AF.3.3 EVALUATION OF FINDINGS There were no issues that challenged the licensing bases. The outcome of the walkdowns indicated that there were no major concerns from the inspections conducted, and the peer reviewers considered the engineering judgments made by the inspectors as appropriate and acceptable, per the EPRI Seismic Walkdown Guidance.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AF-8

AF.4 Review of Licensing Basis Evaluations There were no issues that challenged the licensing basis for the follow-on items, therefore no assessments were required. The peer reviewers concur with this outcome.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AF-9

AF. 5 References

1.

EPRI Technical Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, dated June 2012.

Peach Bottom Atomic Power Station Unit 2 Correspondence No.: RS-14-250 AF-10