ML13210A034

Supplemental Response to 10 CFR 50.54(f) Request for Recommendation 2.3, Seismic Information

ML13210A034
Person / Time
Site:	Ginna
Issue date:	07/25/2013
From:	Korsnick M Constellation Energy Nuclear Group, EDF Group, Ginna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13210A034 (35)

Text

Mary G. Korsnick Office 410-470-5133 Chief Nuclear Officer Fax 443-213-6739 SVP - Chief Operations Officer E-mail: Maria.Korsnick@cengllc.com CENG.

a loint venture of Conset 1.6eaf July 25, 2013 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-1 8 Docket No. 50-244 Supplemental Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic

REFERENCES:

(a) Letter from E. J. Leeds (NRC) and M. R. Johnson (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, 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, MLI2073A348 (b) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

dated November 27, 2012, Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic (c) Letter from J. A. Spina (CENG) to Document Control Desk (NRC), dated December 21, 2012, Supplemental Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, ML12362A448, ML12362A451, and ML12362A452 (d) Memo from L. M. Regner (NRC) to M. A. Mitchell (NRC), dated June 5, 2013, Summary of the May 7, 2013, Public Conference Call on the Delayed Inspection Items Associated with Japan Lessons Learned Near-Term Task Force Recommendation 2.3, Seismic Walkdowns, ML13136A003 On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Reference (a) to all power reactor licensees. The NRC letter requests further information from addressees to support the evaluation of NRC Staff Recommendation 2.3: Seismic from the Near-Term Task Force review of the accident at the Fukushima Dai-ichi nuclear facility.

Aýmf Constellation Energy Nuclear Group, LLC 100 Constellation Way, Suite 200C, Baltimore, MD 21202

Document Control Desk July 25, 2013 Page 2 Reference (b) is the R. E. Ginna Nuclear Power Plant, LLC (Ginna) response to the request in Reference (a). In that response a regulatory commitment was made to submit an updated walkdown report in December 2012. Reference (c) closed that Regulatory Commitment.

As stated in Appendix E of Attachment (1) of Reference (c), Ginna completed walkdowns for all Seismic Walkdown Equipment List (SWEL) I items except for four electrical components that required specific maintenance configurations to complete the internal inspections. Table E-1 of Reference (c) summarized the four remaining electrical components subject to supplemental internal inspections.

Two Regulatory Commitments were made in Reference (c) to submit the seismic walkdown results of the supplemental internal inspections. This letter closes the first Regulatory Commitment by providing the seismic walkdown results for the supplemental internal inspections of Diesel Generator A Exciter Cabinet (DGAEC) and FOXBORO Instrument Rack Diesel Generator KDGO 1A Day Tank Level (FOXDGA 1).

Two more components (480 VAC Motor Control Center C (MCCC) and Bus 14 480 VAC Power (BUS 14)) remain to be inspected in conjunction with maintenance as described in the second Regulatory Commitment of Reference (c).

In response to Reference (d), we are revising the second Regulatory Commitment in Reference (c) to submit the seismic walkdown results for the supplemental internal inspections of MCCC and BUS 14 by July 31, 2014. This is 18 months sooner than committed to in Reference (c). MCCC and BUS14 will now be inspected during our next refueling outage, which is scheduled for Spring 2014. Since the remaining walkdown items will be completed by the next scheduled refueling outage, the other information requested by Reference (d) is not applicable to Ginna.

Attachment (1) to this submittal is the seismic walkdown results for the supplemental internal inspections of DGAEC and FOXDGA I.

This letter contains a regulatory commitment as listed in Attachment (2).

If there are any questions regarding this submittal, please contact Everett (Chip) Perkins everett.perkins(acengllc.com at 410-470-3928.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 25, 2013.

Sincerely, Mary G. Krnc MGK/STD Attachments: (1) Supplemental Seismic Walkdown Report (2) Regulatory Commitments Contained in this Correspondence cc: B. K. Vaidya, NRC W. M. Dean, NRC M. C. Thadani, NRC Resident Inspector, Ginna N. S. Morgan, NRC

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Constellation Energy Nuclear Group, LLC July 25, 2013

ATTACHMENT 1 SUPPLEMENTAL SEISMIC WALKDOWN REPORT Table of Contents L ist o f T ab le s ......................................................................................................... i Executive Summary ................................................................................................. ii I PersonnelQualifications................................................................................................ 1-1 1.1 Ov erv iew ................................................................................................................ 1-1 1.2 W alkdown Personnel ................................................................................................ 1-1 2 Selection of SSCs .............................................................................................................. 2-1 2 .1 O v erv iew ................................................................................................................ 2 -1 3 Seismic Walkdown InternalInspections ......................................................................... 3-1 3 .1 O v erv iew ................................................................................................................ 3 -1 3.2 Electrical Cabinet Internal Inspections ........................................................................ 3-1 3.3 Status of Items Previously Entered into the CAP .......................................................... 3-2 4 Licensing Basis Evaluations.............................................................................................. 4-1 5 Peer Review ..................................................................................................................... 5-1 5.1 Peer Review Introduction .......................................................................................... 5-1 5.2 Review of checklist .................................................................................................. 5-1 5.3 Review of licensing basis evaluations ......................................................................... 5-2 5.4 Peer Review Team Process Summary ......................................................................... 5-2 5.5 Review of final submittal Report & Sign-off ............................................................... 5-2 6 References ....................................................................................................................... 6-I A SWC'sfor Supplemental InternalInspections of ElectricalCabinets ............................... A-1

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT List of Tables Table 1-1. Personnel Included in NTTF 2.3 Supplemental Walkdown ............................... Page 1-1 Table 3-1. Table of Potentially Degraded, Nonconforming or Unanalyzed Conditions for Supplemental Internal Inspection of Electrical Equipment ............................. Page 3-3 Table 3-2. Status of Open Corrective Action Program Items Identified in References I and 2.. Page 3-4 Table 5-1. Table of Peer Review Comments for SW C's .............................................. Page 5-1 Table A-I. Summary of Supplemental Internal Inspections Completed by Ginna ................. Page A-I

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Executive Summary This Supplemental Seismic Walkdown Report documents two internal inspections of electrical cabinets performed at R.E. Ginna Nuclear Power Plant (Ginna) for components that were not accessible during the initial and supplemental walkdowns and were not included in the Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic [Reference 1] or the Supplemental Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic [Reference 2]. These two internal inspections did not identify any adverse seismic conditions that required licensing basis evaluations. One issue for a potentially missing fastener was entered into the station's corrective action program.

Two (2) Seismic Walkdown Equipment List (SWEL) electrical components (480 VAC Motor Control Center C (MCCC) and Bus 14 480 VAC Power (BUSI4)) remain deferred as described in the second Regulatory Commitment of Reference 2, as they require specific maintenance configurations for the internal inspections. In response to Reference 5 we are revising the second Regulatory Commitment in Reference 2 to submit the seismic walkdown results for the supplemental internal inspections of MCCC and BUS 14 by July 31, 2014. This is 18 months sooner than committed to in Reference 2. MCCC and BUS14 will now be inspected during our next refueling outage, which is scheduled for Spring 2014.

Since the remaining walkdown items will be completed by the next scheduled refueling outage, the other information requested by Reference 5 is not applicable to Ginna.

EPRI Technical Report 1025286 [Reference 3] was used to perform the engineering walkdowns and evaluations described in this report. In accordance with Reference 3, the following topics are addressed in the subsequent sections of this report.

• Personnel Qualifications

• Selection of Systems, Structures, and Components (SSCs)

• Seismic Walkdowns

• Seismic Licensing Basis Evaluations

• Peer Review Personnel Qualifications Personnel qualifications are discussed in Section 1 of this report. The personnel who performed the key activities required to fulfill the objectives and requirements of the 50.54(f) letter are qualified and trained as required in Reference 3. These personnel were responsible for:

• Performing the Seismic Walkdowns,

• Performing the seismic licensing basis evaluations, as applicable,

• Performing the peer reviews Selection of SSCs The selection of SSCs was completed and documented within References I and 2.

ii

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT Seismic Walkdowns Section 3 of this report documents the supplemental seismic walkdown internal inspections of electrical cabinets. The supplemental seismic walkdown internal inspections for Ginna were performed during the first half of 2013. The walkdown team consisted of two Seismic Walkdown Engineers (SWE) from the station's Design Engineering group. Operations/Maintenance personnel were also available and called upon as needed.

The seismic walkdowns documented within this report focused primarily on the internal inspection of electrical components. Seismic Walkdown Checklists (SWCs) were completed for the components that were inspected.

During the internal inspections there were no adverse seismic conditions discovered that challenged the licensing basis for the plant. No formal Licensing Basis Evaluations were performed.

Under this supplemental inspection One (1) Condition Report (CR) was issued to address a potentially missing fastener. This issue was identified in the Seismic Walkdown Checklists (SWCs) of this report.

Disposition of the identified issue was completed within the station's corrective action process.

The status of previously identified issues that were entered into the Corrective Action Program (CAP) in References I and 2 (with outstanding actions) is updated in Section 3.

Seismic Licensing Basis Evaluations Reference 3, Section 5: Seismic Licensing Basis Evaluation provides a detailed process to perform and document seismic licensing basis evaluations of SSCs when potentially adverse seismic conditions are identified during the equipment Seismic Walkdowns. The process provides a means to identify, evaluate and document how the identified potentially adverse seismic condition meets a station's seismic licensing basis without entering the condition into a station's CAP. Further, the process directs that if a condition cannot be readily shown to meet the seismic licensing basis, then the identified condition should be entered into the station's CAP where it will be determined that the condition does or does not meet the seismic licensing basis.

Constellation Energy Group/Ginna staff did not utilize the process provided in Reference 3 to perform and document seismic licensing bases evaluations of SSCs with potentially adverse seismic condition.

Instead, all questionable conditions identified by the SWEs during the equipment Seismic Walkdowns were entered into the station CAP to be further evaluated and addressed as required. Therefore, no seismic licensing basis evaluations were completed in accordance with the process documented in Reference 3, Section 5: Seismic Licensing Basis Evaluation. Table 3-1 of Section 3 of this report lists the condition identified during the Seismic Walkdowns.

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT Peer Reviews A peer review team consisting of two qualified individuals, one of whom has seismic engineering experience as it applies to nuclear power plants, was assembled and peer reviews were performed in accordance with Reference 3, Section 6: Peer Reviews. The Peer Review process included the following activities:

• Review of the SWCs

• Review of Licensing basis evaluations, as applicable

• Review of the decisions for entering the potentially adverse conditions into the CAP process

• Review of the submittal report

• Provide a summary report of the peer review process in the submittal report Section 5 of this report contains the Peer Review summary report. The Peer Review determined that the objectives and requirements of the 50.54(f) letter [Reference 4] are met. Further, the efforts completed and documented within this report are in accordance with Reference 3.

Summary In summary, the supplemental seismic walkdown internal inspections were performed in accordance with the NRC-endorsed walkdown methodology. All potentially degraded, nonconforming, or unanalyzed conditions identified as a result of the seismic walkdowns have been entered into the corrective action program to be addressed.

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT I Personnel Qualifications 1.1 OVERVIEW This section of the report identifies the personnel that participated in the supplemental inspections for the NTTF 2.3 Seismic Walkdown effort. A description of the responsibilities of each Seismic Walkdown participant's role(s) is provided in Section 2 of Reference 3. Note that for this report the only roles required were for the walkdown team, licensing basis reviewer, and peer reviewer. Personnel responsible for equipment selection and IPEEE review are noted within Section 3 of Reference 1.

1.2 WALKDOWN PERSONNEL Table 1-1 below summarizes the names and corresponding roles of personnel who participated in this NTTF 2.3 Seismic Walkdown effort. These are the same personnel with the corresponding roles as provided in Reference 2. A short synopsis of each individual's qualifications is provided in Reference 2.

Table 1-1 Personnel Included in NTTF 2.3 Supplemental Walkdown Personnel . "

Mr. Jeffrey Gardiner x x Mr. Francis Peterson x x Mr. Mark Fitzsimmons X Mr. John Traynor x Notes:

I. Peer Review Team Leader.

1-1

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT 2 Selection of SSCs 2.1 OVERVIEW Selection of SSCs was completed and documented within References 1 and 2.

2-1

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT 3 Seismic Walkdown Internal Inspections 3.1 OVERVIEW Seismic Walkdown Internal Inspections were conducted by a two-person team of Seismic Walkdown Engineers trained in accordance with Reference 3. Each engineer has completed the 5-day SQUG Walkdown Training course, a recognized equivalent to the NTTF 2.3 Seismic Walkdown Training Course per Section 2 of Reference 3.

3.2 ELECTRICAL CABINET INTERNAL INSPECTIONS The initial walkdowns at Ginna were completed prior to NRC direction to perform internal inspections of electrical cabinets. During this supplemental inspection Ginna personnel opened and inspected electrical cabinets DGAEC and FOXDGA 1.

3.2.1 Supplemental Internal Inspection Checklists Supplemental internal inspections of the electrical cabinets are documented with Appendix A of this report. These internal inspections concentrated on adverse internal mounting and missing fasteners.

Table 3-1 lists the issue identified during the supplemental internal inspections.

The SWCs are denoted to identify that anchorage inspection and interaction effects were documented under previous seismic walkdowns. To avoid conflict, the checklists identify criteria that have already been evaluated under the previous walkdowns submitted within Reference 1.

The supplemental internal inspections were performed during maintenance activities. Digital photography was utilized to document internal cabinet conditions. All photographs taken were reviewed by the SWEs to ensure the intent of the guidance was met. These criteria included identifying:

" Degraded Internal Anchorage: The internal anchors of cabinets are not credited in the anchorage analysis of these components. Internal anchors were not verified nor inspected.

" Loose or missing fasteners, to the extent possible. Wiring and internal components were not moved or relocated to verify underlying fastener condition in accordance with PPE and qualification requirements.

" Large, heavy components mounted to a cabinet not typically included by the original equipment manufacturer.

• Cabinet doors or panels not latched or fastened: All of the access doors are secured with a latching mechanism, lock or supplemental bolting hardware required by specific engineering analysis.

" Other adverse conditions 3-1

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT 3.2.2 Issues Identification duringSupplemental Internal Inspections There were no issues identified that were ultimately judged to be a "Potentially Adverse Seismic Condition." Table 3-1 lists the issue identified during the Seismic Walkdowns.

3.3 STATUS OF ITEMS PREVIOUSLY ENTERED INTO THE CAP The current status of open CAP items identified in References I and 2 is listed in Table 3-2.

3-2

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT Table 3-1: Table of Potentially Degraded, Nonconforming or Unanalyzed Conditions for Supplemental Internal Inspection of Electrical Equipment Component ID Potentially Adverse Seismic Condition Action Taken to Address the Current Status Condition DGAEC, Diesel During performance of supplemental internal Team was able to view blind side Hands-on trouble shooting Generator A inspection of DGAEC for Fukushima seismic mounting of TS-6 through vents performed under CA-2013-000913 Exciter Cabinet walkdown, the seismic walkdown team identified an of cabinet and conferred with confirmed that TS-6 is affixed to empty mounting hole immediately below and to the electricians to the design of the backing board by blind-right of terminal strip TS-6. Team questioned the terminal strip, providing mounting hardware covered by the mounting configuration of terminal strip TS-6 given reasonable assurance that terminal terminal strip blocks. The exposed hole and mounting bracket. The mounting strip was reasonably affixed to additional hole next to the terminal configuration of the terminal strip TS-6 is below the the cabinet mounting plate. strip appears to be an original error level of detail of available design drawings. CR-2013-001808 was written to leftover from original cabinet CR-213-0188 wa wrtte to construction. Current perform hands-on trouble shooting to verify terminal strip configuration is acceptable.

was affixed to mounting plate.

3-3

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT Table 3-2: Status of Open Corrective Action Program Items Identified in References 1 and 2 Component ID Identified Condition Action Taken to Address the Current Status Condition PCHOIA, Charging Anchor bolt thread engagement issues identified on CR-2012-005522 was issued. Enhancement CA-2012-002262 Pump A 2 bolts. One anchor bolt about half way through nut Documentation within CR has been issued to revise SEWS

- Previously identified in SQUG evaluation, One presented basis for anchorage form (PCHO1A SEWS) to clarify other bolt not completely through nut (about 2/3rds remaining within design as-built thread engagement of the of bolt engaged). allowable limits while anchor bolt. This administrative discrediting the 2 bolts. documentation corrective action has no effect on the operability of the system.

As a corrective action the SEWS sheet will be updated to reflect the margin change. This anchorage change will be documented within the on-going charging pump upgrade project.

P1HOI-A, Three ladders leaning against wall adjoining pump. CR-2012-006918 was issued. Ginna has initiated work order PACO IB,. Residual No ladder station provided. Potential for ladders to Team laid ladders down on C91044795 to install ladder racks Heat Removal fall and impact pumps. Inspection team laid ladders ground to remove interaction to prevent recurrence Pump on ground to remove interaction concern, concern.

(Typographic error within Table 4-2 of Reference 2.

This condition was identified during the inspection of Confirmed on 11/12/2012 that the PACO 1B not PCHO IA. Walkdown sheet provided ladders were properly staged within Reference 2 for PACO 1B correctly identifies against floor this condition, which was also identified within area walk-by.)

3-4

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT Table 3-2: Status of Open Corrective Action Program Items Identified in References 1 and 2 Component ID Identified Condition Action Taken to Address the Current Status Condition BYCAI, Battery Original design calculation specified Maxi-bolts. CR-2012-005089 written to Engineering has issued ECP Charger Al Hilti bolts were specified per ECPCN-09-000001; document lack of design 000131 with details to install however no design calculations could be located to documentation. Calculation supplemental brackets for BYCA1 justify change. This condition was also noted on perfonned within CR provides and BYCB I. These brackets BYCB I, Battery Charger B I. basis for operability of restore anchorage demand to component. within design allowable limits.

The supplemental bracket for BYCB I has been installed under WO C91963484.

The supplemental bracket for BYCAI will be installed under WO C92158209. This work will be completed within the T-week scheduling process.

PT-2027, Left anchor plate on rack has surface rust. CR-2012-005003 was issued to WO C91962133 initiated to Discharge Pressure address concern. correct condition.

Transmitter for Service Water Pumps A and B 3-5

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Table 3-2: Status of Open Corrective Action Program Items Identified in References 1 and 2 Component ID Identified Condition Action Taken to Address the Current Status Condition EACO0A, Seismically unqualified block walls could result in a CR-2012-007447 was issued to This outlier will be addressed as Component seismic interaction with safety related equipment. address concern. The redundant part of the NTTF Cooling Water CCW Hx B, EACO IB, is located Recommendation 2.1 Seismic Heat Exchanger A on a platform above the height to response and is tracked by action During the IPEEE submittal to the NRC, the block be potentially impacted by a AI-2013-00735-001.

wall interaction relative to the CCW HX "A" was not block wall and is expected to be identified. This occurred due to a change in scope available after a design basis between SQUG (safe shutdown) and IPEEE (small ground motion event. The CCW break LOCA). This is a beyond design basis system is designed such that assessment. IPEEE evaluates a 0.3g review level either CCW Pump can be aligned earthquake, vs. Ginna's design basis 0.2g safe to EACOIB so that the shutdown earthquake. This should have been listed as Component Cooling function an IPEEE vulnerability, remains available if EAC01A is impacted by a design basis ground motion event coincident with a small break LOCA.

CB, Control Room Cabinet not anchored near PLP PRESSZR P&L - CR-2012-005136 written. PLP WO C91979567 initiated to evaluate or anchor. determined not to contain any anchor cabinet in the control essential relays room.

AB, Auxiliary Corrosion on conduit supports for conduit routed CR-2012-008409 was issued. WO C91239307 was initiated to Building, Residual along Sub-basement floor Team judged that conduit track replacement of conduit Heat Removal Sub- supports were still capable of supports.

basement performing their function 3-6

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Table 3-2: Status of Open Corrective Action Program Items Identified in References 1 and 2 Component ID Identified Condition Action Taken to Address the Current Status Condition AB, Auxiliary Switch gear accessories mounted to BUS 14 (can CR-2012-005002 written. Engineering has issued ECP Building, Operating rattle) are seismic interaction concern. Justification for as-found 000038 with design outputs to Floor East End configuration provided. relocate switchgear accessories.

WO C91985686 is currently WO C91985686 initiated to tracking implementation via the relocate tools for BUS 14. online-scheduling process.

AB, Auxiliary Switch gear accessories mounted to BUS16 (can CR-2012-005002 written. Engineering has issued ECP Building, rattle) are seismic interaction concern. Justification for as-found 000038 with design outputs to Intermediate Level configuration provided. relocate switchgear accessories.

East End WO C91985686 is currently WO C91985686 initiated to tracking implementation via the relocate tools for BUS16. online-scheduling process.

AB, Auxiliary Fire hose reel threads on bolts not completely CR-2012-005522 initiated, WO C91962134 replaced bolts Building, engaged. evaluation determined with correct length bolts to achieve Intermediate Level configuration was acceptable as- required thread engagement.

West End found. Work completed 5/6/2013 3-7

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT 4 Licensing Basis Evaluations There were no issues identified during the supplemental Seismic Walkdown Internal Inspections determined to be a "Potentially Adverse Seismic Condition" that could have potentially challenged the site's licensing basis.

4-1

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT 5 Peer Review 5.1 PEER REVIEW INTRODUCTION 5.1.1 Overview The peer review was performed in accordance with Reference 3. Scope of the Peer Review was limited to the following activities as the SWEL development process was peer reviewed by the original peer review team and the peer review team is the same as the peer review team documented in Reference 2:

• Review of all the checklists completed for the Seismic Walkdown Internal Inspections

• Review of any licensing basis evaluations

• Review of the decisions for entering the potentially adverse conditions in to the plant's Corrective Action Plan (CAP)

• Review of the final submittal report

• The inclusion of a summary of the peer review process in the submittal report 5.2 REVIEW OF CHECKLIST 5.2.1 Walkdown Review and Review of Checklists Mr. Fitzsimmons and Mr. Traynor completed a peer review of all SWC's completed by the team. The peer review comments shown are those provided to the SWE walkdown team at the time of the review.

All comments have been addressed in the final SWCs.

Table 5-1: Table of Peer Review Comments for SWC's Component Equipment Walkdown Item Location Observations ID. (GIP) Class DGAEC 20 DIESEL DG-253 Team properly identified empty GENERATOR A mounting hole, evaluated design EXCITER requirements and confirmed CABINET acceptance through trouble shooting, including documentation.

FOXDGAI 20 FOXBORO DG-253 Team properly questioned empty INSTRUMENT mounting hole on card. Agree with RACK DIESEL team's evaluation of condition based GENERATOR on manufacturer's "as-supplied" KDGO 1A DAY configuration of mounting hardware TANK LEVEL for the card.

5-1

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT 5.2.2 Evaluationof Findings The issue identified in Table 3-1 would not prevent the equipment from performing its safety-related function. The peer review team has reviewed the identified issue and associated disposition and agree with the conclusions of Section 3.

5.3 REVIEW OF LICENSING BASIS EVALUATIONS 5.3.1 Overview of Licensing Basis Evaluations The issue identified during the Seismic Walkdowns as shown in Table 3-1 was determined not to be a "Potentially Adverse Seismic Condition" in that the issue identified would not prevent the equipment from performing its safety-related function or the plant from achieving safe shutdown. Therefore, no additional formal Licensing Basis Evaluation was required.

5.4 PEER REVIEW TEAM PROCESS

SUMMARY

" No Licensing Basis Evaluations were performed so peer review was not applicable.

• Provided review and comments to final report submittal.

• The qualification of team personnel reflected experience and great familiarity with the Ginna nuclear power block. Walkdown data sheets were thoroughly filled out and completed. Corrective actions were employed using the Corrective Action Program. Documentation was developed and compiled such that it is recorded and retrievable.

5.5 REVIEW OF FINAL SUBMITTAL REPORT & SIGN-OFF The supplemental inspection report has been reviewed by Mark Fitzsimmons and John Traynor and is found to meet the requirements of the EPRI 1025286 - Seismic Walkdown Guidance [Reference 3] and the objectives and requirements of the 50.54(f) letter [Reference 4].

5-2

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT 6 References

1. Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC) dated November 27, 2012, Response to 10 CFR 50.54(f) Request for Information, Recommendation, Seismic

2. Letter from J. A. Spina (CENG) to Document Control Desk (NRC) dated December 21, 2012, Supplemental Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic

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

4. NRC (E Leeds and M Johnson) Letter to All Power Reactor Licensees et al., "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," Enclosure 2.3, "Recommendation 2.3: Seismic."

5. Letter from L. M. Regner (NRC) to M. A. Mitchell (NRC) dated June 5, 2013, Summary of the May 7, 2013, Public Conference Call on the Delayed Inspection Items Associated with Japan Lessons Learned Near-Term Task Force Recommendation 2.3, Seismic Walkdowns, ML13136A003 6-1

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT A SWC's for Supplemental Internal Inspections of Electrical Cabinets Table A-i: Summary of Supplemental Internal Inspections Completed by Ginna Equipment Component ID Description Class 20 DGAEC DIESEL GENERATOR A EXCITER CABINET FOXBORO INSTRUMENT RACK DIESEL GENERATOR KDGO1A DAY TANK LEVEL A-1

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y E] N Z U rD Seismic Walkdown Checklist (SWC)

Equipment ID No.: DGAEC Equipment Class: (20) Instrumentation and Control Panels and Cabinets Equipment

Description:

DIESEL GENERATOR A EXCITER CABINET Project: Ginna SWEL 1 (Supplemental Internal Inspection of Cabinet)

Location (Bldg, Elev, Room/Area): Diesel Generator Building, 253.00 ft, Area 09 Manufacturer/Model:

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

1. Is anchorage configuration verification required (i.e., is the item one of the 50% YDN [

of SWEL items requiring such verification)?

N/A Supplemental inspectionof cabinet internals. Anchorage is external to the cabinet and was inspected underprevious Seismic Walkdown Report

2. Is the anchorage free of bent, broken, missing or loose hardware Y El N E U E N/A EII N/A Supplemental inspection of cabinet internals.

3. Is the anchorage free of corrosion that is more than mild surface Y El N [-I UEl N/A El oxidation?

N/A Supplemental inspection of cabinet internals.

4. Is the anchorage free of visible cracks in the concrete near the Y El N El U [I N/A [LI anchors?

N/A Supplemental inspection of cabinet internals.

5. Is the anchorage configuration consistent with plant documentation? Y [I N [LI UELI N/A ELI (Note: This question only applies if the item is one of the 50% for which an anchorage configuration verification is required.)

N/A Supplemental inspection of cabinet internals.

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

N/A Supplemental inspection of cabinet internals.

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SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y [1N EU F-Seismic Walkdown Checklist (SWC)

Equipment ID No.: DGAEC Equipment Class: (20) Instrumentation and Control Panels and Cabinets Equipment

Description:

DIESEL GENERATOR A EXCITER CABINET Interaction Effects

7. Are soft targets free from impact by nearby equipment or structures? Y F1 N El U D N/A ED N/A Supplemental inspection of cabinet internals.

8. Are overhead equipment, distribution systems, ceiling tiles and lighting, Y [-] N [-] U F1 N/A F1 and masonry block walls not likely to collapse onto the equipment?

N/A Supplemental inspection of cabinet internals.

9. Do attached lines have adequate flexibility to avoid damage? Y [] N I U El N/A L[I N/A Supplemental inspection of cabinet internals.

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

N/A Supplemental inspection of cabinet internals.

Other Adverse Conditions

11. Have you looked for and found no adverse seismic conditions that could Y E] N E U n]

adversely affect the safety functions of the equipment?

Supplemental internalinspection: Several relays are mounted to the door of the cabinet. Walkdown confirmed that supplemental stiffeners and bolting were installed on the interiorof the door. Team noted that the bottom of terminalstrip TS-6 appearedto have a missing mounting bolt (See attached photos), CR-2013-001808 written.

Comments Supplemental internalinspection: Neat cabinet,free of FME.

Evaluated by: Date: 3/14/2013 3/14/2013 A-3

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y E] N Z U Z]

Seismic Walkdown Checklist (SWC)

Equipment ID No.: DGAEC Equipment Class: (20) Instrumentation and Control Panels and Cabinets Equipment

Description:

DIESEL GENERATOR A EXCITER CABINET Photos DGAEC Internal Cabinet Inspection, Top-Front A-4

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: YL1NHUL Seismic Walkdown Checklist (SWC)

Equipment ID No.: DGAEC Equipment Class: (20) Inst rumentation and Control Panels and Cabinets Equipment

Description:

DIESEL GENERATOR A EXCITER CABINET DGAEC Internal Cabinet Inspection, Bottom-Front A-5

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y F] N 0 U R Seismic Walkdown Checklist (SWC)

Equipment ID No.: DGAEC Equipment Class: (20) Instrumentation and Control Panels and Cabinets Equipment

Description:

DIESEL GENERATOR A EXCITER CABINET DGAEC Intemal Cabinet Inspection, TS-6 and Missing Mounting A-6

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y El N [K UL]

Seismic Walkdown Checklist (SWC)

Equipment ID No.: DGAEC Equipment Class: (20) Instrumentation and Control Panels and Cabinets Equipment

Description:

DIESEL GENERATOR A EXCITER CABINET TS-6 and Missing Mounting A-7

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y IZ N Z U F1 Seismic Walkdown Checklist (SWC)

Equipment ID No.: DGAEC Equipment Class: (20) Instrumentation and Control Panels and Cabinets Equipment

Description:

DIESEL GENERATOR A EXCITER CABINET DGAEC Door Mounted Relays and Supplemental DoorStiffeners A-8

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y 0 N El UF]

Seismic Walkdown Checklist (SWC)

Equipment ID No.: FOXDGA1 Equipment Class: (20) Instrumentation and Control Panels and Cabinets FOXBORO INSTRUMENT RACK DIESEL GENERATOR KDG01A DAY Equipment

Description:

TANK LEVEL Project: Ginna SWEL 1 (Supplemental Internal Inspection of Cabinet)

Location (Bldg, Elev, Room/Area): Diesel Generator Building, 253.00 ft, Area 09 Manufacturer/Model:

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

1. Is anchorage configuration verification required (i.e., is the item one of the 50% Y [D N [

of SWEL items requiring such verification)?

N/A Supplemental inspection of cabinet internals. Anchorage is external to the cabinet and was inspected under previous Seismic Walkdown Report

2. Is the anchorage free of bent, broken, missing or loose hardware Y [L N LI U [_ N/A LI N/A Supplemental inspection of cabinet internals.

3. Is the anchorage free of corrosion that is more than mild surface Y El N El U El N/A [L oxidation?

N/A Supplemental inspection of cabinet internals.

4. Is the anchorage free of visible cracks in the concrete near the Y El N LI U El N/A E]

anchors?

N/A Supplemental inspectionof cabinet internals.

5. Is the anchorage configuration consistent with plant documentation? Y E] N E] U LI N/A El (Note: This question only applies if the item is one of the 50% for which an anchorage configuration verification is required.)

N/A Supplemental inspection of cabinet internals.

6. Based on the above anchorage evaluations, is the anchorage free of Y [] N E] U E]

potentially adverse seismic conditions?

N/A Supplemental inspectionof cabinet internals.

A-9

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y 0 N EI U []

Seismic Walkdown Checklist (SWC)

Equipment ID No.: FOXDGA1 Equipment Class: (20) Instrumentation and Control Panels and Cabinets FOXBORO INSTRUMENT RACK DIESEL GENERATOR KDG01A DAY Equipment

Description:

TANK LEVEL Interaction Effects

7. Are soft targets free from impact by nearby equipment or structures? Y El N El U [I N/A El N/A Supplemental inspection of cabinet internals.

8. Are overhead equipment, distribution systems, ceiling tiles and lighting, Y El N El U El N/A El and masonry block walls not likely to collapse onto the equipment?

N/A Supplemental inspection of cabinet internals.

9. Do attached lines have adequate flexibility to avoid damage? Y [: N [] U [] N/A El N/A Supplemental inspection of cabinet internals.

10. Based on the above seismic interaction evaluations, is equipment free Y [] N [] U El of potentially adverse seismic interaction effects?

N/A Supplemental inspection of cabinet internals.

Other Adverse Conditions

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

Supplemental internalinspection: Team questioned open mounting hole for card LC-2050A/LC-205OA-2 (See photos). Team pulled spare duplex card from stock and determined that this mounting hole was left open by manufacturer. All mounting hardware as provided by the manufactureris capturedby retaining pins and cannot be removed from the card. Team concluded the mounting hole was open by design, no adverse conditions noted.

Comments Supplemental internalinspection: Neat cabinet, free of FME, no components mounted to door.

Evaluated by: 4/17/2013 4/17/2013 A-10

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: YONLj Un Seismic Walkdown Checklist (SWC)

Equipment ID No.: FOXDGAl Equipment Class: (20) Instrumentation and Control Panels and Cabinets FOXBORO INSTRUMENT RACK DIESEL GENERATOR KDG01A DAY Equipment

Description:

TANK LEVEL Photos FOXDGA 1 Internal Cabinet Inspection A-1 1

ATTACHMENT (1)

SUPPLEMENTAL SEISMIC WALKDOWN REPORT Status: Y ON El U M Seismic Walkdown Checklist (SWC)

Equipment ID No.: FOXDGA1 Equipment Class: (20) Instrumentation and Control Panels and Cabinets FOXBORO INSTRUMENT RACK DIESEL GENERATOR KDG01A DAY Equipment

Description:

TANK LEVEL FOXDGA 1 Internal Cabinet Inspection, Open Mounting Hole A-12

ATTACHMENT (2)

REGULATORY COMMITMENTS CONTAINED IN THIS CORRESPONDENCE Constellation Energy Nuclear Group, LLC July 25, 2013

ATTACHMENT (2)

REGULATORY COMMITMENTS CONTAINED IN THIS CORRESPONDENCE The following table identifies actions committed to in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Regulatory Commitment Date Submit seismic walkdown results to the NRC for supplemental internal July 31, 2014 inspections of MCCC and BUS 14 as part of the response to the Fukushima recommendation 2.3 Request for Information.

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