ML13078A330

Oyster Creek - Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

ML13078A330
Person / Time
Site:	Oyster Creek
Issue date:	03/19/2013
From:	Jesse M D Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-13-017, RS-13-058
Download: ML13078A330 (10)

Text

RS-13-058 RA-13-017 10 CFR 50.54(f) March 19, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

References:

Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219 Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident 1. Exelon Generation Company, LLC 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task force Review of Insights from the Fukushima Dai-ichi Accident, dated November 19, 2012 (RS-12-178)

2. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 In Reference 1, Exelon Generation Company, LLC (EGC) provided the Oyster Creek Nuclear Generating Station (OCNGS) flooding walkdown report in accordance with the NRC Request for Information (Reference 2). The OCNGS flooding walkdown report documented the plant walkdowns performed to verify that plant features credited in the current licensing basis for protection and mitigation from external flood events are available, functional, and properly maintained.

In Table NO.5 of Reference 1, EGC provided the list of the OCNGS plant features that were not able to be inspected due to inaccessibility.

EGC committed to complete the inspection of these features classified as restricted access by the end of the OCNGS Refueling Outage OCi R24 (Fall 2012).

u.s. Nuclear Regulatory Commission Supplemental Response to 50.54{f) Letter NTTF Recommendation Flooding March 19,2013 2 This letter provides the of the completed supplemental walkdown inspections performed for the features classified as restricted access in Reference

1. Additionally, 6 features (Pipe Sleeves 381-386) which do not appear on the B&R 4000 series concrete drawings were found during the walkdown of the Condenser bay and the results are attached to the tables. One feature (24" Pipe Sleeve 147) that was listed in Reference 1 as restricted access was removed, since it was determined to be connected within the intake tunnel and is not an external feature. The enclosed tables document the specific walkdown results for each of the subject plant features.

The results of the visual inspections during the supplemental flooding walkdowns showed that 95 features meet the NEI 12-07 acceptance criteria.

Table 1 provides the results for the features that were inspected during the 1 R24 Oyster Creek refueling outage immediately judged as acceptable.

Table 2 provides the list of 30 features that were not immediately judged as acceptable during the supplemental walkdowns.

The table provides the tracking mechanism for Corrective Action Program (CAP) resolution of the identified conditions.

There were no findings that were found to be deficient per the current licensing basis. The findings that were documented using the CAP will be resolved using the stations corrective action program.

No other findings challenge the current licensing basis. The supplemental flooding walkdown record forms document the details of all observations for all flood features inspected, and are available for on-site review. Except as noted above, OCNGS flood protection features met the NEI 12-07 Supplemental Guidance acceptance criteria and were found to be in accordance with the site current licensing basis. This letter contains no new regulatory commitments.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of March 2013. Respectfully, ichael D. Jess Director -Ucens'tRg egulatory Affairs Exelon Generation Company, LLC u.s. Nuclear Regulatory Commission Supplemental Response to 50.54{f) Letter NTTF Recommendation 2.3: Flooding March 19, 2013 Page 3 1 Table 1 OCNGS Supplemental List of Features Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage 1 R24) 2. Table 2 -OCNGS Supplemental List of Features Not Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage 1 R24) cc: Director, Office of Nuclear Reactor Regulation Regional Administrator

-NRC Region I NRC Senior Resident Inspector

-OCNGS NRC Project Manager, NRR -OCNGS Manager, Bureau of Nuclear Engineering

-New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding March 19,2013 ENCLOSURE 1 Table 1 -OCNGS Supplemental List of Features Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage 1 R24) # Feature ID Number Building Room 1 2" Conduit Penetration 136 Turbine Building Condenser Bay 2 2" Conduit Penetration 137 Turbine Building Condenser Bay 3 2" Conduit Penetration 138 Turbine Building Condenser Bay 4 4" Conduit Penetration 139 Turbine Building Condenser Bay 5 2" Conduit Penetration 140 Turbine Building Condenser Bay 6 2" Conduit Penetration 141 Turbine Building Condenser Bay 7 2" Conduit Penetration 142 Turbine Building Condenser Bay 8 4" Conduit Penetration 143 Turbine Building Condenser Bay 9 4" Conduit Penetration 144 Turbine Building Condenser Bay 10 4" Conduit Penetration 145 Turbine Building Condenser Bay II 4" Conduit Penetration 146 Turbine Building Condenser Bay 12 2" Conduit Penetration 149 Turbine Building Condenser Bay 13 2" Conduit Penetration 150 Turbine Building Condenser Bay 14 2" Conduit Penetration 151 Turbine Building Condenser Bay 15 2" Conduit Penetration 152 Turbine Building Condenser Bay 16 4" Conduit Penetration 153 Turbine Building Condenser Bay 17 4" Conduit Penetration 154 Turbine Building Condenser Bay 18 4" Conduit Penetration 155 Turbine Building Condenser Bay 19 4" Conduit Penetration 156 Turbine Building Condenser Bay 20 4" Conduit Penetration 157 Turbine Building Condenser Bay 21 4" Conduit Penetration 158 Turbine Building Condenser Bay 22 4" Conduit Penetration 159 Turbine Building Condenser Bay 23 4" Conduit Penetration 160 Turbine Building Condenser Bay 24 4" Conduit Penetration 161 Turbine Building Condenser Bay 25 4" Conduit Penetration 162 Turbine Building Condenser Bay 26 4" Conduit Penetration 163 Turbine Building Condenser Bay 27 4" Conduit Penetration 164 Turbine Building Condenser Bay 28 4" Conduit Penetration 165 Turbine Building Condenser Bay 29 4" Conduit Penetration 166 Turbine Building Condenser Bay 30 4" Conduit Penetration 167 Turbine Building Condenser Bay 31 4" Conduit Penetration 168 Turbine Building Condenser Bay 32 4" Conduit Penetration 169 Turbine Building Condenser Bay 33 4" Conduit Penetration 170 Turbine Building Condenser Bay 34 4" Conduit Penetration 171 Turbine Building Condenser Bay 35 4" Conduit Penetration 172 Turbine Building Condenser Bay 36 4" Conduit Penetration 173 Turbine Building Condenser Bay 37 4" Conduit Penetration 174 Turbine Building Condenser Bay Page 1 of 3 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTIF Recommendation Flooding March 19, 2013 Table 1 -OCNGS Supplemental List of Features Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage lR24) # Feature ID Number Building Room 38 4" Conduit Penetration]

75 Turbine Building Condenser Bay 39 4" Conduit Penetration 176 Turbine Building Condenser Bav 40 4" Conduit Penetration 177 Turbine Building Condenser Bay 41 4" Conduit Penetration 178 Turbine Building Condenser Bay 42 4" Conduit Penetration 179 Turbine Building Condenser Bay 43 4" Conduit Penetration 180 Turbine Building Condenser Bay 2" Conduit Penetration 193 Turbine Building Condenser Bay 2" Conduit Penetration 194 Turbine Building Condenser Bay 46 2" Conduit Penetration 195 Turbine Building Condenser Bav 47 2" Conduit Penetration 196 Turbine Building Condenser Bay 48 4" Conduit Penetration 198 Turbine Building Condenser Bay 49 4" Conduit Penetration 199 Building Condenser Bay 50 4" Conduit Penetration 200 Turbine Building Condenser Bay 51 4" Conduit Penetration 20 I Turbine Building Condenser Bay 52 4" Conduit Penetration 204 Turbine Building Condenser Bay 53 4" Conduit Penetration 205 Turbine Building Condenser Bay 54 4" Conduit Penetration 206 Turbine Building Condenser Bav 55 4" Conduit Penetration 207 Turbine Building Condenser Bay 56 10" Pipe Sleeve 208 Turbine Building Condenser Bay 57 J6" Pipe Sleeve 209 Turbine Building Condenser Bay 58 3" Pipe Sleeve 210 Turbine Building Condenser Bay 59 16" Pipe Sleeve 211 Turbine Building Condenser Bay 60 16" Pipe Sleeve 212 Turbine Building Condenser Bay 61 Pipe Sleeve 381 Turbine Building Condenser Bay 62 Pipe Sleeve 382 Turbine Building Condenser Bay 63 Pipe Sleeve 383 Turbine Building Condenser Bay 64 Pipe Sleeve 384 Turbine Buildinl:!

Condenser Bay 65 Pipe Sleeve 385 Turbine Building Condenser Bay 66 Pipe Sleeve 386 Turbine Building Condenser Bay 67 4" Conduit Penetration 213 Turbine Building Condenser Bay 68 4" Conduit Penetration 214 Turbine Building Condenser Bay 69 4" Conduit Penetration 215 Turbine Building Condenser Bay 70 4" Conduit Penetration 216 Turbine Building Condenser Bay 71 4" Conduit Penetration 346 Turbine Building Condenser Bay 72 I 4" Conduit Penetration 347 Turbine Building Condenser Bay 73 4" Conduit Penetration 348 Turbine Building Condenser Bay 74 I 4" Conduit Penetration 349 Turbine Building Condenser Bay 75 Manhole Cover 243 Turbine Building Condenser Bay 76 Manhole Cover 244 Turbine Building Condenser Bay Page 2 of 3 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding March 19, 2013 Table 1 -OCNGS Supplemental List of Features Immediately Judged as Acceptable (Restricted Access Features Inspected During Ont::l(JP lR24) # Feature ID Number nuilding Room 77 4" Conduit Penetration Turbine Building Steam Jet Air EJector Room 78 4" Conduit Penetration 231 Turbine Building Steam Jet Air Ejector Room 79 4" Conduit Penetration 232 Turbine Building Steam Jet Air Ejector Room 80 4" Conduit Penetration 233 Turbine Building Steam Jet Air Ejector Room 81 4" Conduit Penetration 234 Turbine Building Steam Jet Air E:jector Room 82 4" Conduit Penetration 235 Turbine Building Steam Jet Air Ejector Room 83 4" Conduit Penetration 236 Turbine Building Steam Jet Air Ejector Room 84 4" Conduit Penetration 237 Turbine Building Steam Jet Air Ejector Room 85 4" Conduit Penetration 238 Turbine Building Steam Jet Air E:jector Room 86 4" Conduit Penetration 239 Turbine Building Steam Jet Air Ejector Room 87 4" Conduit Penetration 240 Turbine Building Steam Jet Air Ejector Room 88 4" Conduit Penetration 241 Turbine Building Steam Jet Air Ejector Room 89 Steam Jet Air Ejector/High-Low SJAE/High-Low Room East Wall Turbine Building Rooms 90 SJAE South Wall Turbine Building Steam Jet Air Ejector Room 91 40" Pipe Sleeve 00 I Turbine Building Steam Jet Air E:jector Room 92 40" Pipe Sleeve 002 Turbine Building Steam Jet Air Ejector Room 93 Rectangular Penetration 3 x 1'-6" Turbine Building Steam Jet Air Ejector 003 Room 94 3" Pipe Sleeve (plant ground Reactor Building East Wall penetrati on) 95 4" Conduit 331 Diesel Generator Building-DG2 Cable Trench DG2 Page 3 of 3 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation Flooding March 19, 2013 ENCLOSURE 2 Table 2: OCNGS Supplemeutal List of Features Not Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage lR24) # Feature II) # Description Observation Component Resolution Operability 4" Conduit 3 10 Conduit No seal could be Water that gets I (I) Penetration observed for this into the open Seal penetration conduits will 4" Conduit 311 Conduit No seal could be drain into either 2 Penetration observed for this the drain in the (I) Seal penetration cable trench. or into the Turbine Building basement.

IR Yes o 1406841 [see Documented in above] JR 01442056.

documents that See discussion water from the Conduit No seal could be in Resolution DG 1 conduits 3 4" Conduit 313 Penetration observed for this column draining into the (I) Seal penetration TB basement does not challenge plant operability.

Water in the conduits will not challenge the operability of EDG 1 4" Conduit 327 Conduit No seal could be Water that gets 4 (I) Penetration observed for this into the open Seal penetration conduits will 4" Conduit 328 Conduit No seal could be drain into either 5 Penetration observed for this the drain in the (I) Seal penetration Yes-cable trench, or Conduit No seal could be Documented in into the Turbine 6 4" Conduit 329 Penetration observed for this IR 01442053.

Building (I) Seal penetration See discussion basement.

IR Conduit No seal could be in Resolution 01405765 [see 7 4" Conduit 330 Penetration observed for this column above] (1) Seal penetration documents that 4" Conduit 332 Conduit No seal could be water from the 8 Penetration observed for this DG I conduits (I) Seal penetration draining into the Page 1 of 4 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding March 19, 2013 Table 2: OCNGS Supplemental List of Features Not Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage lR24) # Feature ID # Description Observation Component Resolution Operability TB basement Yes does not Documented in challenge plant 4" Conduit 334 Conduit No seal could be IR 01442053.

operability.

9 (I) Penetration observed for this See discussion Water in the Seal penetration in Resolution conduits will not column challenge the operability of EDG2 Work Order W 0 M2313037 was amended to seal this pipe sleeve Due to an obstructed Yes See on the inside of 6" Pipe Sleeve Pipe view, an internal seal discussion in the plant. A 10 Penetration walkdown on 135 (l) Seal for this pipe sleeve Resolution

\111612012 could not be verified.

column. verified that the new seal is in place and meets NEI and CLB criteria.

4" Conduit Conduit 11 Penetration 181 Penetration (I ) Seal 4" Conduit Conduit 12 Penetration 182 Penetration These penetrations are (1) Seal corroded.

and have 4" Conduit Conduit staining on the wall 13 Penetration 185 Penetration below them. Trend will be (I) Seal 4" Conduit Conduit Yes tracked in 14 Penetration 186 Penetration Documented in ongoing ER-OC-(I) Seal IR 01441159 450 Structural 4" Conduit Conduit Monitoring 15 Penetration 183 Penetration walkdowns. (I) Seal 4" Conduit Conduit There is staining on the 16 Penetration 184 Penetration wall below these (I) Seal penetrations.

4" Conduit Conduit 17 Penetration 187 Penetration (1) Seal Page 2 of 4 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation Flooding March 1 2013 Table 2: OCNGS Supplemental List of Features Not Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage lR24) #

ID # Description Observation Component Resolution Operabilitv 4" Conduit Conduit 18 Penetration 188 Penetration (I) Seal 4" Conduit Conduit 19 Penetration 189 Penetration (I) Seal 4" Conduit Conduit 20 Penetration 190 Penetration (I) Seal 4" Conduit Conduit 21 Penetration 191 Penetration ( I ) Seal 4" Conduit Conduit Trend will be Penetration 192 Penetration Yes tracked in (I) Seal Documented in ongoing ER-OC-18" Pipe Sleeve Pipe Corrosion on IR 01441159 450 Structural 23 Penetration penetration and of Monitoring 197 (1) Seal water seepage on wall. walkdowns.

4" Conduit Conduit These two penetrations 24 Penetration 202 Penetration (1) Seal are covered by a catch 4" Conduit Conduit and inaccessible.

There 25 Penetration 203 Penetration is staining on the wall (I) Seal below the catch. 20" Pipe Sleeve Pipe Staining on penetration 26 Penetration and signs of water 217(1) Seal seepage on wall. Trend will be Rectangular There is staining at the Yes tracked in 27 Penetration 3 x Penetration construction joints of Documented in ongoing ER-OC-1 '-6" 148 (I) Seal this penetration, and IR 01441129 450 Structural immediately below Monitoring walkdowns.

There are cracks greater Trend will be Rectangular than 0.04" wide in the Yes tracked in 28 Penetration 3'6" Penetration grout sealing this Documented in ongoing ER-OC-x 3'6" 218 (I) Seal penetration, and there is IR 01442048 450 Structural slight staining below Monitoring various pipes. walkdowns.

Trend will be There are cracks greater Yes tracked in 29 Condenser Bay Wall than 0.04" in width in Documented in ongoing ER-OC-floor (I) the structural concrete IR 01441118 450 Structural floor slab. Monitoring walkdowns.

Page 3 of 4 U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Flooding March 19, 2013 Table 2: OCNGS Supplemental List of Features Not Immediately Judged as Acceptable (Restricted Access Features Inspected During Outage lR24) # Feature ID # Description Observation Component Resolution Operability Trend will be West Wall There are cracks greater Yes tracked in 30 Turbine Building floor Slab than 0.04" in width in Documented in ongoing ER-OC-Condenser Bay the structural concrete IR 01441116 450 Structural (I) wall. Monitoring walkdowns.

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