ML12348A266

12Q0108.30-R-001, Rev. 1, Seismic Walkdown Report in Response to the 50.54(f) Information Request Regarding Fukushima Near-Term Task Force Recommendation 2.3: Seismic for the Dresden Nuclear Power Station, Unit 2, Part 1 of 7

ML12348A266
Person / Time
Site:	Dresden
Issue date:	11/15/2012
From:	Delaney M Exelon Generation Co, Stevenson & Associates
To:	Office of Nuclear Reactor Regulation
References
RS-12-167 12Q0108.30-R-001, Rev 1
Download: ML12348A266 (69)

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U.S. Nuclear Regulatory Commission 180-Day Response to 50.54(f) Letter NTTF Recommendation 2.3: Seismic November 27, 2012 Page 4 Enclosure 1 Seismic Walkdown Report In Response To The 50.54(f) Information Request Regarding Fukushima Near-Term Task Force Recommendation 2.3: Seismic for the Dresden Nuclear Power Station, Unit 2, Report Number: 12Q0108.30-R-001, Revision 1 (658 pages)

SEISMIC WALKDOWN REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.3: SEISMIC for the DRESDEN GENERATING STATION UNIT 2 6500 North Dresden Road, Morris, Illinois, 60450 Renewed Facility Operating License No. DPR-19 NRC Docket No. STN 50-237 Correspondence No.: RS-12-167 Exe- on.Exelon Geratn Comany, LLC (Exelon)PO Box 80s3m Chicago, IL 0080-S3 Prepared by: Stevemon & Associates 1661 Feuhwnlle Orive, Sufle 150 Mount Prqoect, IL 600M6 Repmt Nrnbar: 1200108.30-R-001, Rev. I Prmp.. Mare Dm W Reviewer Tony Piez Approver.

Tony Perz Peer Review Team Leader: Lead Rsepmue nb n L~Eul SAWm.2uil MaEngne DSeln Eg~edng Bruce Lary Bryan A-- /04, 12 1111512012 1111512012 11112012 1111512012 Co~~Cms'4- W.- -I -(% -a -4 4 of 7 Document Title: SEISMIC WALKDOWN REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.3: SEISMIC for the DRESDEN GENERATING STATION UNIT 2 Document Type: Report Report Number: 12Q0108.30-R-001 Project Name: NTTF R2.3 Seismic Walkdowns for Exelon -Dresden Job No.: 12Q0108.30 Client: .ExeLon.This document has been prepared in accordance with the S&A Quality Assurance Progqram Manual, Revision 17 and project requirements:

Initial Issue (Rev. 0)Date: 11/7/2012 Prepared by: Marlene Delaney __________Date:_11/7/201 Reviewed by: Tony Perez Date: 11/7/2012 Approved by: Tony Perez Date: 11/7/2012 Revision Record: Revision Prepared by/ Reviewed by/ Approved by/ Description of Revision No. Date Date Date 1 Marlene Tony Perez Tony Perez Replaced Table E-2.Delaney 11/15/2012 11/15/2012 11/15/2012 DOCUMENT CONTRACT NO.APPROVAL SHEET 12Q0108 Stevenson

& Associates II 12QO108.30-R-O0i, Rev. 1 Correspondence No.: RS-12-167 Contents L is t o f T a b le s .........................................................................................................

iii Executive Summary ................................................................................................

iv 1 Introduction

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I .................................................

1-1 1 ,1 P u rp o s e ...................................................................................................................

1-1 1,2 Background

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1-1 1,3 Plant Overview ........................

I ..................................

1-1, 1,4 Approach ...................................................

1-2.1 ,5 C o n c lu s io n ..............................................................................................................

1-2 2 Seism ic Licensing Basis ..................................................................................

2-2 ,1 O v e rv ie w ...............................................................

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2 -1 2,2 Safe Shutdown Earthquake (SSE) ...........

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2-1 2,3 Design of Seismic Category I SSCs ...................................................................

2-"1 2.3.1 Seismic Summary .............................................

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2-1 2.3.2 Applicable Codes ..........................................................................................

2-2 2.3.3 Seismic Qualification of Safety Related Mechanical Equipment

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2-3 2.3.4 Seismic Qualification of Class I Instrumentation and Electrical Equipment...2-3 3 Personnel Qualifications

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3-1 3.1 Overview ..........................................................................

3-1 3.2 Project Personnel

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3.2.1 Stevenson

& Associates Personnel

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3-2 33 Additional Personnel

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3-3 4 Selection of SSCs .......................................................................................................

4-1 4.1 O v e rv ie w .................................................................................................................

4 -1 4.2 SW EL Development

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4-1 4.2.1 SWEL 1 -Sample of Required Items for the Five Safety Functions

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4-1 4.2.2 SW EL 2 -Spent Fuel Pool Related Items .....................................................

4-3 5 Seism ic W alkdowns and Area Walk-Bys .................................................................

5-1 5 .1 O v e rv ie w ................................................................................................................

5 -1 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 5.2 Seism ic W alkdowns ................................................................................................

5-1 5.2.1 Adverse Anchorage Conditions

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5-2 5.2.2 Configuration Verification

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5-2 5.2.3 Adverse Seism ic Spatial Interactions

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5-3 5.2.4 Other Adverse Seismic Conditions

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5-4 5.2.5 Conditions Identification during Seism ic W alkdowns .....................................

5-4 5.3 Area W alk-Bys ........................................................................................................

5-4 5.3.1 Conditions Identification during Area W alk-bys .............................................

5-6 5.4 Supplemental Information on Electrical Cabinet Inspections

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5-6 6 Licensing Basis Evaluations

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6-1 7 IPEEE Vulnerabilities Resolution Report .................................................................

7-1 8 Peer Review ....................................................................................................................

8-1 9 References

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9-1 Appendices A Project Personnel Resumes and SWE Certificates

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A-1 B Equipm ent Lists .............................................................................................................

B-1 C Seism ic W alkdown Checklists (SW Cs) ..................................................................

C-1 D Area W alk-By Checklists (AW Cs) ...........................................................................

D-1 E Plan for Future Seismic Walkdown of Inaccessible Equipment

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E-1 F Peer Review Report ...................................................................................................

F.-1 G IPEEE Vulnerabilities

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G-1 ii 12Q.108.30-R-0 O1, Rev. 1 Correspondence No.: RS-12-167 List of Tables Table 2-1. List of Codes and Standards

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2-2 T able 3-1. P ersonnel R oles ........................

I ..............

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3-1 Table 5-1. Anchorage Configuration Confirmation

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5-3 Table 5-2. Conditions Identified during Seismic Walkdowns

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5-8 Table 5-3. Conditions Identified during Area Walk-Bys ................................................

5-10 Table B-Ia. Base List la -Items Exclusive to Unit 2 .........................

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B-3 Table B-lb. Base List lb -Items Common to Units 2 and 3 ...........................................

B-38 T a ble B -2 .S W E L 1 ...............................................................................................

B -42 Table C-1. Summary of Seismic Walkdown Checklists

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C-2 Table D-1. Summary of Area Walk-By Checklists

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I ..................................

D-2 Table E-1. Inaccessible and Deferred Equipment List ........................................

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E-2 Table E-2. Supplemental Cabinet Internal Inspection List ...............................

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E-4 Table G-1. IPEEE Improvements Status ....................................................................

G-2-iii 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Executive Summary The purpose of this report is to provide information as requested by the Nuclear Regulatory Commission (NRC) in its March 12, 2012 letter issued to all power reactor licensees and holders of construction permits in active. or deferred status. (Ref. 7) In particular, this report provides information requested to address Enclosure 3, Recommendation 2.3: Seismic, of the March 12, 2012 letter. (Ref. 7)Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the NRC established the Near Term Task Force (NTTF) in response to Commission direction.

The NTTF issued a report -Recommendations for Enhancing Reactor Safety in the 2 1 st Century: The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident -that made a series of recommendations, some of which were to be acted upon "without unnecessary delay." (Ref. 14) On March 12, 2012, the NRC issued a letter to all power reactor licensees in accordance with 10CFR50.54(f).

The 50.54(f)letter requests information to assure that certain NTTF recommendations are addressed by all U.S. nuclear power plants. (Ref. 7) The 50.54(f) letter requires, in part, all U.S.nuclear power plants to perform seismic walkdowns to identify and address degraded, non-conforming or unanalyzed conditions and to verify the current plant configuration is within the current seismic licensing basis. This report documents the seismic walkdowns performed at Dresden Generating Station Unit 2 in response, in part, to the 50.54(f)letter issued by the NRC.The Nuclear Energy Institute (NEI), supported by industry personnel, cooperated with the NRC to prepare guidance for conducting seismic walkdowns as required in the 50.54(f) letter, Enclosure 3, Recommendation 2.3: Seismic. (Ref. 7) The guidelines and procedures prepared by NEI and endorsed by the NRC were published through the Electric Power Research Institute (EPRI) as EPRI Technical Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, dated June 2012; henceforth, referred to as the "EPRI guidance document." (Ref. 1) Exelon/Dresden has utilized this NRC endorsed guidance as the basis for the seismic walkdowns and this report. (Ref. 1)The EPRI guidance document was used to perform the engineering walkdowns and evaluations described in this report. In accordance with the EPRI guidance document, the following topics are addressed in the subsequent sections of this report.* Seismic Licensing Basis* Personnel Qualifications

• Selection of Systems, Structures, and Components (SSC)* Seismic Walkdowns and Area Walk-Bys* Seismic Licensing Basis Evaluations

• IPEEE Vulnerabilities Resolution Report* Peer Review iv 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 Seismic Licensing Basis The Seismic Licensing Basis is briefly described in Section 2 of this report. The safe shutdown earthquake for the Dresden Generating Station site is 0.20g horizontal ground acceleration and 0.133g vertical ground acceleration. (Ref. 2 Section 3.8)Personnel Qualifications Personnel qualifications are discussed in Section 3 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 the EPRI guidance document.(Ref. 1) These personnel are responsible for:* Selecting the SSCs that should be placed on the Seismic Walkdown Equipment List (SWEL),* Performing the Seismic Walkdowns and Area Walk-Bys,* Performing the seismic licensing basis evaluations, as applicable,* Identifying the list of plant-specific vulnerabilities identified during the IPEEE program and describing the actions taken to eliminate or reduce them,* Performing the peer reviews Selection of SSCs Selection of SSCs is discussed in Section 4 of this report. The process used to select the items that were included in the overall Seismic Walkdown Equipment List (SWEL) is described in detail in the EPRI guidance document, Section 3: Selection of SSCs. (Ref.1) The SWEL is comprised of two groups of items, which are described at a high level in the following subsections.

Sample of Required Items for the Five Safety Functions

-SWEL 1 Screen #1 narrowed the scope of SSCs in the plant to those that are designed to Seismic Category I requirements because they have a seismic licensing basis.Screen #2 narrowed the scope of SSCs by selecting only those that do not regularly undergo inspections to confirm that their configuration continues to be consistent with the plant licensing basis.Screen #3 narrowed the scope of SSCs included on SWEL 1 as only those associated with maintaining the five safety functions.

These five safety functions include the four safe shutdown functions (reactor reactivity control, reactor coolant pressure control, reactor coolant inventory control, and decay heat removal, which includes the Ultimate Heat Sink), plus the containment functions.

Screen #4 was a process intended to result in a SWEL 1 that sufficiently represented the broader population of plant equipment and systems needed to meet the objectives of the 50.54(f) letter. The following five sample attributes were used: " A variety of types of systems" Major new or replacement equipment" A variety of types of equipment" A variety of environments v

12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Equipment enhanced due to vulnerabilities identified during the IPEEE program Spent Fuel Pool Related Items -SWEL 2 Screen #1 and Screen #2 were used to narrow the scope of spent fuel pool related SSCs to those that have a seismic licensing basis and those that are appropriate for an equipment walkdown process. Screen #3 was intended to result in a SWEL 2 that sufficiently represents the broader population of spent fuel pool Seismic Category I equipment and systems to meet the objectives of the 50.54(f) letter, and included the following sample selection attributes:

e A variety of types of systems 9 Major new or replacement equipment* A variety of types of equipment* A variety of environments Screen #4 identified items of the spent fuel pool that could potentially cause a rapid drain-down of the pool, even if such items are not Seismic Category I. 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.

Any items identified as having the potential for rapidly draining the spent fuel pool were to be added to SWEL 2.For Dresden Unit 2, the SWEL is comprised of:* SWEL 1 resulted with 103 items for walkdown." SWEL 2 resulted with no items for walkdown." No items associated with spent fuel pool rapid drain-down are included on SWEL 2.Seismic Walkdowns and Area Walk-Bys Section 5, Appendix C, and Appendix D of this report documents the equipment Seismic Walkdowns and the Area Walk-Bys.

The online seismic walkdowns for Dresden Unit 2 were performed during the weeks of July 16 and October 15, 2012. During the walkdown activities, the walkdown team consisted of two (2) Seismic Walkdown Engineers (SWEs), a station Equipment Operator, and various station personnel.

The seismic walkdowns focused on the seismic adequacy of the items on the SWEL.The walkdowns focused on the following:

• Adverse anchorage conditions

• Adverse seismic spatial interactions

• Other adverse seismic conditions (e.g., degradation, configuration, etc.)Area Walk-Bys were conducted in each area of the plant that contained an item on the SWEL (generally within 35 feet of the SWEL component).

The Area Walk-By was performed to identify potentially adverse seismic conditions associated with other SSCs located in the vicinity of the SWEL item. The key examination factors that were considered in the Area Walk-Bys included the following:

• Anchorage conditions (if visible without opening equipment) vi 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167* Significantly degraded equipment in the area* Potential seismic interaction

• A visual assessment (from the floor) of cable/conduit raceways and HVAC ducting (e.g., condition of supports or fill conditions of cable trays)* Potential adverse interactions that could cause flooding/spray and fire in the area* Other housekeeping items, including temporary installations The seismic walkdown team inspected 90 of the 103 components on the SWEL.Walkdowns for 13 components were deferred due to accessibility issues such-as being located in containment or energized equipment.

The 13 remaining items will be inspected during a unit outage or another time whenthe equipment is accessible, as required.

Anchorage verification was required for a minimum of 30 components. (Ref. 1)A total of 42 anchorage configurations were confirmed to be installed in accordance with the station documentation.

Following the completion of the online seismic walkdowns, the industry was made aware that the NRC staff had clarified a position on opening electrical cabinets to inspect for other adverse seismic conditions.

Supplemental inspections of 32 electrical cabinets are planned and will be completed, as required, during a unit outage or another time when the equipment becomes accessible.

The list of electrical cabinets along with the milestone completion schedule is provided in Table E-2.During the seismic walkdowns at the Dresden Unit 2 ten (10) Issue Reports (IRs) were issued. After, evaluation through the CAP, it was determined that none of the conditions identified in the IRs were adverse seismic conditions.

Seismic Licensing Basis Evaluations The EPRI guidance document, Section 5: Seismic Licensing Basis Evaluation provides a detailed process to perform and document seismic licensing basis evaluations of SSCs identified when potentially adverse seismic conditions are identified.

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 Corrective Action Program (CAP). In lieu of this process, E,_xelon/Drsd,.n utilized the existing processes and procedures (Site CAP. Expectations) to identify, evaluate and document conditions identified during the Seismic Walkdowns.

In accordance with Exelon/Dresden processes and procedures, all questionable conditions identified by the SWEs during the walkdowns were entered into the station CAP to be further evaluated and addressed as required.

The SWEs provided input to support the identification and evaluation (including seismic licensing basis evaluations, as required) of the potentially adverse seismic conditions entered into the CAP. The station corrective action program is a more robust process than that provided in the EPRI guidance document; in part, ensuring each condition is properly evaluated for conformance with design and licensing bases and corrected as required.Conditions identified during the walkdowns were documented on the SWCs, AWCs, and entered into the CAP. For those conditions that required, seismic licensing basis evaluations were completed and documented within the IR. Tables 5-2 and 5-3 in the report provide the IR, a summary of the condition, and the action completion status.vii 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 IPEEE Vulnerabilities IPEEE vulnerabilities are addressed in Section 7 and Appendix G of this report. No vulnerabilities were identified as a result of the effort that addressed the Individual Plant Examination of External Events (IPEEE). (Ref. 3 and 5) However, plant improvements were identified in Section 7 of Reference

4. Table G-1 provides the list of plant improvements, the IPEEE proposed resolution, the actual resolution and resolution date.All IPEEE plant improvements and associated actions are complete.Peer Reviews A peer review team consisting 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 SSCs included on the SWEL* Review of a sample of the checklists prepared for the Seismic Walkdowns and Area Walk-Bys* Review of licensing basis evaluations, as applicable 0 Review of the decisions for entering the potentially adverse conditions into the CAP process* Review of the submittal report* Provided a summary report of the peer review process in the submittal report Section 8 of this report contains a summary of the Peer Review. The Peer Review determined that the objectives and requirements of the 50.54(f) letter are met. Further, it was concluded by the peer reviews that the efforts completed and documented within this report are in accordance with the EPRI guidance document.Summary In summary, seismic walkdowns have been performed at the Dresden Generating Station Unit 2 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.Evaluations of the identified conditions are complete and documented within the CAP.These evaluations determined the Seismic Walkdowns resulted with no adverse anchorage conditions, no adverse seismic spatial interactions, and no other adverse seismic conditions associated with the items on the SWEL. Similarly, the Area Walk-Bys resulted with no adverse seismic conditions associated with other SSCs located in the vicinity of the SWEL item(s).The Seismic Walkdowns identified ten (10) minor conditions.

Other than these minor conditions, the Seismic Walkdowns identified no degraded, nonconforming, or unanalyzed conditions that required either immediate or follow-on action. No planned or newly identified protection or mitigation features have resulted from the efforts to address the 50.54(f) letter.Follow-on activities required to complete the efforts to address Enclosure 3 of the 50.54(f) letter include inspection of 13 items deferred due to inaccessibility along with viii 12Q0108.30-R-OO1, Rev. I Correspondence No.: RS-12-167 supplemental inspections of 32 electrical cabinets.

Area Walk-Bys will be complete, as required, during these follow-on activities.

All IPEEE improvement actions are complete ix 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 I Introduction

1.1 PURPOSE

The purpose of this report is to provide information as requested by the Nuclear Regulatory Commission (NRC) in its March 12, 2012 letter issued to all power reactor licensees and holders of construction permits in active or deferred status. (Ref. 7) In particular, this report provides information requested to address Enclosure 3, Recommendation 2.3: Seismic, of the March 12, 2012 letter. (Ref. 7)

1.2 BACKGROUND

Following the accident at the Fukushima Dai-ichi nuclear power plant resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the NRC established the Near Term Task Force (NTTF) in response to Commission direction.

The NTTF issued a report -Recommendations for Enhancing Reactor Safety in the 2 1 st Century: The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident -that made a series of recommendations, some of which were to be acted upon "without unnecessary delay." (Ref. 14) On March 12, 2012, the NRC issued a letter to all power reactor licensees in accordance with 1 0CFR50.54(f).

The 50.54(f)letter requests information to assure that certain NTTF recommendations are addressed by all U.S. nuclear power plants. (Ref. 7) The 50.54(f) letter requires, in part, all U.S.nuclear power plants to perform seismic walkdowns to identify and address degraded, non-conforming or unanalyzed conditions and to verify the current plant configuration is within the current seismic licensing basis. This report documents the seismic walkdowns performed at Dresden Generating Station Unit 2 in response, in part, to the 50.54(f)letter issued by the NRC.The Nuclear Energy Institute (NEI), supported by industry personnel, cooperated with the NRC to prepare guidance for conducting seismic walkdowns as required in the 50.54(f) letter, Enclosure 3, Recommendation 2.3: Seismic. (Ref. 7) The guidelines and procedures prepared by NEI and endorsed by the NRC were published through the Electric Power Research Institute (EPRI) as EPRI Technical Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, dated June 2012; henceforth, referred to as the "EPRI guidance document." (Ref. 1) Exelon/Dresden has utilized this NRC endorsed guidance as the basis for the seismic walkdowns and this report. (Ref. 1)1.3 PLANT OVERVIEW Dresden Generating Station consists of two operating boiling water reactor (BWR)generating units, located in Morris, Illinois.

A third retired unit is also present at Dresden but will not be included in this report. Both operating units have Mark I containments, are rated at 2957 MWt power (Renewed Facility Operating License No. DPR-1 9), and were originally designed and built by GE as prime contractor for Commonwealth Edison 1-1 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 Company (ComEd). Dresden Unit 2 was completed and went in to commercial service in June of 1970. (Ref. 2 section 1.1.1).1.4 APPROACH The EPRI guidance document is used for the Dresden Generating Station 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 Systems, Structures, and Components (SSCs)* Seismic Walkdowns and Area Walk-Bys* Licensing Basis Evaluations

• IPEEE Vulnerabilities Resolution Report* Peer Review

1.5 CONCLUSION

Seismic walkdowns have been performed at the Dresden Generating Station Unit 2 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.Evaluations of the identified conditionsare complete and documented within the CAP.These evaluations determined the Seismic Walkdowns resulted with no adverse anchorage conditions, no adverse seismic spatial interactions, and no other adverse seismic conditions associated with the items on the SWEL. Similarly, the Area Walk-Bys resulted with no adverse seismic conditions associated with other SSCs located in the vicinity of the SWEL item(s).The Seismic Walkdowns identified ten (10) minor conditions.

Other than these minor conditions, the Seismic Walkdowns identified no degraded, nonconforming, or unanalyzed conditions that required either immediate or follow-on action. No planned or newly identified protection or mitigation features have resulted from the efforts to address the 50.54(f) letter.Follow-on activities required to complete the efforts to address Enclosure 3 of the 50.54(f) letter include inspection of 13 items deferred due to inaccessibility along with supplemental inspections of 32 electrical cabinets.

Area Walk-Bys will be complete, as required, during these follow-on activities.

1-2 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 2 Seismic Licensing Basis 2.1 OVERVIEW This section of the report summarizes the seismic licensing basis for the Dresden Generating Station Unit 2 and Unit 3. The safe shutdown earthquake and a summary of the codes, standards, and methods used in the design of Seismic Class I (Category I)SSCs are presented.

This section does not establish or change the seismic licensing basis of the facility and is intended to provide a fundamental understanding of the seismic licensing basis of the facility.2.2 SAFE SHUTDOWN EARTHQUAKE (SSE)The safe shutdown earthquake for the Dresden Generating Station site is 0.20g horizontal ground acceleration and 0.133g vertical ground acceleration. (Ref. 2 Section 3.8)2.3 DESIGN OF SEISMIC CATEGORY I SSCS A full description of the Safe Shutdown Earthquake along with the codes, standards, and methods used in the design of the Seismic Class I (Category I) SSCs for meeting the seismic licensing basis requirements is provided in the following Dresden Generating Station UFSAR sections:* 3.2 Classification of Structures, Components, and Systems 0 3.7 Seismic Design 0 3.8 Design of Class I Structures 0 3.9 Mechanical Systems and Components

• 3.10 Seismic Qualification of Class I Instrumentation and Electrical Equipment These UFSAR sections should be referred to for a detailed understanding of the seismic licensing basis.2.3.1 Seismic Summary The input motions used to create the seismic design of Dresden are based on the Housner-type Ground Response Spectrum (GRS) and the north-south component earthquake record of El Centro of May 18, 1940. The Dresden design basis Safe Shutdown Earthquake (SSE) ground spectra are smoothed Housner-type spectra. The design basis In-Structure Response Spectra (ISRS) were generated using a time-history method of analysis.

The El Centro 1940 earthquake N-S component, anchored to 0.10g, was used to generate the ISRS for the Dresden Operating basis Earthquake (OBE). For SSE design, the spectral values were obtained by doubling the OBE spectra. The OBE is defined in the horizontal direction by the Housner-type GRS scaled to 0.1Og peak 2-1 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 ground acceleration (PGA) and ISRS developed from the. El Centro Earthquake time history scaled to 0.10g. The OBE in the vertical direction is defined by two-thirds of the Housner-type GRS with a resulting PGA of 0.067g. The SSE is defined by multiplying the OBE acceleration by a factor of 2, resulting in a horizontal direction GRS PGA of 0.20g. (Ref. 4)2.3.2 Applicable Codes As per section 3.2 of Reference 2, Table 2-1 summarizes the codes and standards used for design of systems or components which are applicable in-whole or in-part: Table 2-1. List of Codes and Standards System, Structure, or Component Code or Standard Valves (except main steam isolation, USAS B-31.1 and ASME Section I safety, relief, and safety relief valves)Reactor Recirculation Pumps ASME Section III, Class C Main Steam Isolation, Safety, Relief, USAS B-31.1, ASME Section I, and ASME and Safety Relief Valves and Flow Section III (Safety Relief Valve)), 1971 Edition Restrictors Piping System USAS B-31.1, and ASME Section I.Batteries (Station batteries)

IEEE 308-1974; IEEE 450 Cable (new cable installations)

IEEE 384 Condenser pit level alarms IEEE 279 Containment ASME Section III, 1965 Edition, Class B Containment air monitoring (CAM) ASME III, Class 2; IEEE 323-1974; IEEE 344-1975 Containment penetrations ASME Section III, Class B Containment penetration fitting design ASME Section VIII Control rod drive ASME Section III Core spray piping USAS B31.1 Core spray pump casing ASME Section III, Class C Core spray spargers and nozzles ASME Section III Core spray vessel nozzle ASME SA 336, Code Case 1332 Fuel pool cooling heat exchanger ASME Section III Fuel pool cooling pump ASME VIII HPCI piping USAS B-31.1 and ASME Section I HPCI pumps ASME Section III Hydrogen injection system USAS B-31.1 and ASME Section VIII Isolation condenser heat exchanger ASME Section VIII shell side Isolation condenser heat exchanger ASME Section III tube side Instruments (replacement and new IEEE 344-1975 RG 1.97)LPCI pump casings ASME Section III, Class C Main steam piping USAS B-31.1; ASME Section I and III Off-gas piping USAS ASA B-31.1 Off-gas recombiner/adsorber ASME Section III, Subsection ND, Class 3 Oxygen injection tank (inner vessel) ASME Section VIII, Division I RBCCW heat exchangers ASME Section VIII 2-2 12Qo108.30-R-eo1, Rev. 1 Correspondence No.: RS-1 2-1 67 System, Structure, or Component Code or Standard Reactor protection system IEEE 279-1968 Reactor water cleanup vessels ASME Section III Class C, 1965 (Unit 2 purchased to ASME Section VIII, reconciled to ASME Section III, Class C, 1965)Shutdown cooling system ASME Ill, Class C)Suppression pool temp monitoring IEEE 279-197.1, 323-1974, 344-1971, 344-system 1975 Traversing incore probe guide tubes ASME Section VIII 2.3.3 Seismic Qualification of Safety Related Mechanical Equipment Safety-related mechanical equipment is qualified by either dynamic or static analysis methods. (Ref. 2 section 3.9.2.2)Where a dynamic analysis was not performed, the horizontal seismic coefficients for rigid equipment in the reactor-turbine building were considered to be equal to or greater than the building acceleration at the installed elevation.

The vertical seismic coefficient was considered as two-thirds of ground acceleration, i.e., 0.067g. The input motion to the equipment was assumed to be the absolute acceleration of the structure at the points of support of the equipment. (Ref. 2 section 3.9.2.2)A reassessment of the seismic adequacy of mechanical and electrical equipment at Dresden Unit 2 was performed under the systematic evaluation program (SEP), Topic 111-6, titled, "Seismic Design Considerations." In addition, Generic Letter (GL) 87-02,"Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46," requires verification of seismic adequacy. (Ref. 2 section 3.9.2.2)2.3.4 Seismic Qualification of Class I Instrumentation and Electrical Equipment The original seismic design criteria for Dresden Units 2 and 3 were developed by John A. Blume and Associates based on the recommendation of seismologist Perry Byerly.(Ref. 2 section 3.10)Dresden Station was originally designed for a design level earthquake, equivalent to the operating basis earthquake (OBE) with a peak ground acceleration of 0.1 g. The design was reviewed to assure that the plant would resist twice the response loads for the 0.1 g earthquake without hindering the ability of the plant to be safely shut down. (Ref. 2 section 3.10)Seismic design requirements and procedures have evolved significantly since the time Dresden Station received its construction permit. Recognizing this evolution, the NRC found that it was necessary to make a reassessment of the seismic safety of older operating plants. The Dresden Unit 2 seismic reassessment was performed under the Systematic Evaluation Program (SEP), Topic 111-6, titled "Seismic Design Considerations," June 30, 1982. (Ref. 2 section 3.10)Generic letter (GL) 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46," which was issued on February 19, 1987, also addresses seismic assessment of older plants.The generic letter was issued to implement the USI A-46 resolution which concluded that the seismic adequacy of certain equipment in older operating nuclear plants must be 2-3 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 reviewed against seismic criteria not yet in use when these plants were licensed. (Ref. 2 section 3.10)Supplement No. 1 to Generic Letter 87-02 was issued on May 22, 1992. It transmitted the NRC staffs Supplemental Safety Evaluation Report No. 2 (SSER-2) on the Seismic Qualification Utility Group's (SQUG) Generic Implementing Procedure, Revision 2 as corrected on February 14, 1992 (referred to as GIP-2). The GIP-2 methodology relies primarily on the use of existing earthquake and testing experience data to verify the seismic adequacy of generic classes of equipment in contrast to seismic qualification procedures, which rely on analysis or testing of each item of equipment. (Ref. 2 section 3.10)ComEd committed to use the following as its method for responding to Generic Letter 87-02:* GIP-2 in its entirety (both SQUG commitments and implementation guidance);

• Clarifications, interpretations, and exceptions to GIP-2 identified in SSER-2;* Letter of August 21, 1992 (N.P. Smith to J.G. Partlow), SQUG Response to Generic Letter 87-02; and" Letter of October 2, 1992 (J.G. Partlow to N.P. Smith), NRC Response to Seismic Qualification Group.(Ref. 2 section 3.10)The following two clarifications apply: 1. ComEd will use previously performed anchorage evaluations to expedite and/or minimize the GIP verification efforts, provided that the anchorage evaluations previously performed meet the criteria and procedures approved by the staff in SSER-2.2. ComEd will use existing seismic qualification test reports to demonstrate operability for any equipment on its safe shutdown equipment list that was previously qualified to IEEE 344-1975.(Ref. 2 section 3.10)For new and replacement equipment, the GIP-2 methodology is applied if consistent with the licensing basis for the equipment.

In particular, each new or replacement item of equipment and parts is evaluated for any design changes that could reduce its seismic capacity from that reflected by the earthquake experience or generic testing equipment classes. This includes verification of the seismic adequacy of commercial grade equipment being dedicated for safety-related purposes. (Ref. 2 section 3.10)For Regulatory Guide 1.97 new and replacement equipment requiring seismic qualification, the requirements of IEEE 344-1975, Regulatory Guide 1.100, Revision 1, and Dresden Station will be satisfied. (Ref. 2 section 3.10)2-4 12Qo108.30-R-oo1, Rev. 1 Correspondence No.: RS-12-167 3 Personnel Qualifications

3.1 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 document.(Ref. 1) Resumes included in Appendix A provide detail on each person's qualifications.

3.2 PROJECT

PERSONNEL 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 Equipment Seismic Licensing equion Plant Walkdown cesis IPEEE Peer Name Selection Basis Engineer Operations Engineer Reviewer Reviewer (SWE) Reviewer A. Perez X K. Hull X T.K. Ram XM J. Griffith X X D. Carter X X B. Lory X(2)W. Djordjevic X(3)D. Hamilton (Exelon) X B. Weight (Exelon) X X X Notes: 1. Peer Review Team member for SWEL review only.2. Peer Review Team Leader.3. Peer Review Team Leader for SWEL.3-1 i2Qoloa..30-R-oo1, Rev. 1 Correspondence No.: RS-12-167 3.2.1 Stevenson

& Associates Personnel The following provides a synopsis of each individual's background and experiences.

Antonio Perez, P.E.: Mr. Perez is a Senior Engineer IIl and serves as the General Manager of the S&A Hudson, WI office. He earned his Bachelor of Science degree in Mechanical Engineering at Michigan Technological University and is a licensed Professional Engineer in the states of Wisconsin and Minnesota.

Mr. Perez has over 15 years of experience in project management, project engineering, equipment design, and mechanical systems design and has served in the nuclear power industry for over 11 years. He has extensive experience in Program and Design Engineering and has held positions such as MOV Engineer, Responsible Design Engineer, Design Engineering Supervisor and STA Trainee in the nuclear power industry.

Mr. Perez has successfully completed the Near-Term Task Force Recommendation 2.3 -Plant Seismic Walkdowns Training Course.Kim Hull: Mr. Hull is a Senior Engineer III in the S&A Hudson, WI office. He earned his Master of Science degree in Mechanical Engineering at Michigan State University.

Mr.Hull has over 30 years of experience in the nuclear power industry and has held *positions such as Shift Technical Advisor, Principal Engineer, Senior Instructor, and Mechanical Design Supervisor.

He has an extensive background in all aspects of nuclear power plant modifications with a thorough understanding of configuration control/management along with design and licensing basis of nuclear power plants. Mr.Hull has successfully completed the Near-Term Task Force Recommendation 2.3 -Plant Seismic Walkdowns Training Course.Tribhawan K. Ram, P.E.: Mr. Ram is a Senior Engineer Ili in the S&A Phoenix, AZ Office. He has over 28 year experience in the nuclear power industry with expertise in plant systems and design engineering.

Currently, Mr. Ram is leading the electrical engineering effort in support of Post-Fukushima Seismic Margin Analysis (SMA) for two Taiwan nuclear stations (PWR and BWR). This effort, in support of the plant Safe Shutdown Equipment List (SSEL), consists of relay list development, relay screening (using GERS, SQURTS or other available testing data), and relay chatter analysis.

Mr.Ram was involved in resolving USI A-46 relay outliers for several plants (Dresden, Quad Cities, Millstone, Palisades, and Pilgrim).

He evaluated dozens of control circuits for relay chattering issues. To replace outliers, Mr. Ram developed and/or supervised the development of modification packages including:

replacement relay selection; relay testing specification preparation; and seismic testing facility visits for relay qualification.

As a systems manager, Mr. Ram conducted periodic system walkdowns to discover and then pursue resolutions for any design, maintenance or operational issues with equipment.

He has developed test plans for circuit breaker and other electrical equipment replacement, including involvement in test plan execution during refueling outages. Mr. Ram has interfaced, with NRC in their biennial Component Design Basis Inspections (CDBI), and with INPO in their biennial evaluations.

Mr. Ram has MS degrees in Nuclear and Electrical Engineering from the University of Cincinnati, and an MBA from Bowling Green State University.

He is a licensed Professional Engineer (electrical) in Ohio. Mr. Ram has completed a six month training course in BWR systems.Jim Griffith, P.E. Mr. Griffith is a Senior Engineer III in the S&A Chicago Office. He has a Bachelor of Science degree in civil engineering and has more than 25 years of experience in the nuclear power plant industry.

He is a licensed Professional Engineer 3-2 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 in the State of Wisconsin.

He is a SQUG Qualified Seismic Capability Engineer (SCE)and has completed the NTTF Recommendation

2.3 Training

Course (SWE). In addition to his involvement in design and analysis of structures, systems, and components at nuclear power plants, Mr. Griffith has many years of experience working at numerous nuclear power plants in support of construction, design, outage, and walkdown activities including SQUG walkdowns.

David Carter, P.E., S.E. Mr. Carter is a Senior Engineer III in the S&A Chicago, IL.Office. He has a Bachelor of Science degree in civil engineering and has more than 30 years of experience in the nuclear power plant industry.

He is a licensed Structural Engineer in the State of Illinois and is a licensed Professional Engineering in several states. He is a SQUG Qualified Seismic Capability Engineer (SCE) and has completed the NTTF Recommendation

2.3 Training

Course (SWE). In addition to his involvement in design and analysis of structures, systems, and components at nuclear power plants, he has performed SQUG walkdowns at various nuclear power plants. He has worked for over ten years as a Seismic Qualification Engineer at another utility performing seismic evaluations of plant equipment, input to procurement documents, and reviewing seismic qualification reports for new plant equipment.

Bruce Lory Mr. Lory is a Senior Engineer III in the S&A Chicago, IL Office. He has a Bachelor of Science degree in mechanical engineering and has more than 30 years of experience in the nuclear power plant industry.

He is a SQUG Qualified Seismic Capability Engineer (SCE) and is the instructor of the Fundamentals of Equipment Seismic Qualification training course for EPRI, and is the co-instructor of the Fukushima Seismic Walkdown training course in response to NTTF 2.3. In addition, he has been involved with equipment modifications for Extended Power Uprates (EPU), as well as Seismic Qualification (SQ) and Environmental Qualification (EQ) of equipment/components at numerous nuclear power plants.Walter Diordievic, P.E. Mr. Djordjevic is a Senior Consultant and serves as President of S&A with specialization in the dynamic analysis and design of structures and equipment for seismic, blast, fluid, and wind loads. He has managed and led seismic walkdowns and fragility analyses of structures and components for use in probabilistic risk assessments.

Mr. Djordjevic has 37 years of seismic experience serving the nuclear industry.

Mr. Djordjevic performed and managed more than 20 USI A-46 and IPEEE projects in response to the requirements of Generic Letters 87-02 and 88-20. Mr.Djordjevic has a Master of Science in Structural Engineering from the Massachusetts Institute of Technology.

He has received industry training as a Seismic Capability Engineer (EPRI SQUG training), EPRI IPEEE Add-on, Seismic Fragility and Seismic Walkdown Engineer (SWE).3.3 ADDITIONAL PERSONNEL Exelon plant Operations staff member Mr. David Hamilton, reviewed the SWEL. Mr.Hamilton is the Manager of Operations Support at Dresden Station. He is currently a licensed SRO and has been since 2006. Mr. Hamilton has worked in the operations department at Dresden for 23 years and he is familiar with all aspects of the station operating procedures.

Various additional station personnel also provided support to the SWEL preparer to help identify 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 1.3-3 12QO108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 Exelon Engineering staff member Mr. Bryan Weight participated in the seismic walkdowns and area walk-bys as a Seismic Walkdown Engineer (SWE). He also performed the IPEEE Vulnerabilities Review based, in part, on the Dresden IPEEE submittal along with subsequent correspondence and station records. (Ref. 3, 4, and 5)Mr. Weight is a Staff Engineer in the Exelon Engineering Department.

He has over 36 years of engineering experience and has worked at Dresden for the past 5 years. Mr.Weight has completed the NTTF Recommendation

2.3 Training

Course (SWE) and the SQUG Training in 2009.3-4 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 4 Selection of SSCs 4.1 OVERVIEW This section of the report describes the process used to select structures, systems, and components, (SSCs) that were included in the Seismic Walkdown Equipment List (SWEL). The actual equipment lists that were developed in this process are found in Appendix B and are as follows:* Table B-Ia, Base List la -Items Exclusive to Unit 2" Table B-ib, Base List lb -Items Common to Units 2 and 3" Table B-2, SWEL 1 4.2 SWEL DEVELOPMENT The selection of SSCs process described in EPRI Technical Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, dated June 2012, was utilized to develop the SWEL for Dresden Generating Station Unit 2. (Ref. 1)The SWEL is comprised of two groups of items:* SWEL 1 is a sample of items to safely shut down the reactor and maintain containment integrity* SWEL 2 is a list of spent fuel pool related items 4.2.1 SWEL 1 -Sample of Required Items for the Five Safety Functions The process for selecting a sample of SSCs for shutting down the reactor and maintaining containment integrity began with the composite Seismic Individual Plant Examination for External Events (IPEEE) Success Path Equipment List (SPEL)1.(Ref. 3 and 4) The IPEEE SPEL was then subjected to the following four screens to identify the items to be included on the first Seismic Walkdown Equipment List (SWEL 1): 1. Screen #1 -Seismic Category I As described in Reference 1, only items that have a defined seismic licensing basis are to be included in SWEL 1. Each item on the IPEEE SPEL was reviewed to determine if it had a defined seismic licensing basis. All items identified as Class I, as defined in Dresden UFSAR Chapter 3, were identified as having a defined seismic licensing basis. (Ref. 2) Electrical enclosures containing Class 1E devices'Through the efforts of this project, certain equipment identification numbers listed on the IPEEE SPEL were found to be incorrect.

The equipment identification numbers have been corrected in this report to be consistent with current plant drawings and the master equipment database.4-1 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 were identified as Class I. Class I and Class 1 E determination was made through a review of current design and licensing basis documentation.

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 further reduced the IPEEE SPEL of any Class I Structures, Containment Penetrations, Class I Piping Systems, cable/conduit raceways and HVAC ductwork.3. Screen #3 -Support for the Five 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:

A. Reactor Reactivity Control (RRC)B. Reactor Coolant Pressure Control (RCPC)C. Reactor Coolant Inventory Control (RCIC)D. Decay Heat Removal (DHR)E. Containment Function (CF)The first four functions are associated with bringing the reactor to a safe shutdown condition.

The fifth function is associated with maintaining containment integrity.

As described in Appendix E of Reference 1, the safety function for each item on the IPEEE SPEL was identified.

It is noted that items on SWEL I with a specific safety function(s) are considered frontline systems. Items with a safety function of'Auxiliary

& Support', 'Electrical Systems', or 'Racks & Panels' may be a frontline or support system. Items with a safety function of 'Auxiliary

& Support', 'Electrical Systems', or 'Racks & Panels' support at least one of the five safety functions however, the specific safety function(s) is not indicated as identification of the specific safety function(s) supported is not required by Reference 1.The resultant equipment list after Screen #3 is defined in the EPRI guidance document as Base List 1 and is included in Appendix B. (Ref. 1)4. Screen #4- Sample Considerations This screen is intended to result in a SWEL 1 that sufficiently represents a broad population of plant Seismic Category 1 equipment and systems to meet the objectives of the NRC 50.54(f) letter. The following attributes were considered in the selection process for items included on SWEL 1: A. A variety of types of systems The system is identified for each item on SWEL 1. 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).

4-2 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 B. Major new and replacement equipment The equipment included on SWEL 1 includes several items that have been modified or replaced over the past several years. Each item on SWEL 1 that is new or replaced is identified.

C. 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 listed in Reference I Appendix B: Classes of Equipment.

Where appropriate, at least one piece of equipment from each class is included on SWEL 1.Screening

1. 1, #2, and #3 resulted in no equipment in the following classes:* (13) -Motor Generators

• (19) -Temperature Sensors.D. 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.E. Equipment enhanced due to vulnerabilities identified during the IPEEE program The equipment included on SWEL 1 includes several items that were enhanced as a result of the IPEEE program. Each item on SWEL 1 that was enhanced as a result of the IPEEE program is identified.

F. 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 importance for a Loss of Off-Site Power (LOOP) scenario from the internal plant PRA were used. Additionally, the list of risk-significant components for the LOOP PRA 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. (Ref. 8)4.2.2 SWEL 2- Spent Fuel Pool Related Items The process for selecting a sample of SSCs associated with the spent fuel pool (SFP)began with a review of the station design and licensing basis documentation for the SFP and the interconnecting SFP cooling system. (Ref. 2 section 9.1 and Ref. 9, 10, 11, 12, 13, and 15) The following four screens narrowed the scope of SSCs to be included on*the second Seismic Walkdown Equipment List (SWEL 2): 1. Screen #1 -Seismic Category 1 Only those items identified as Class I (having defined seismic licensing basis) are to be included on SWEL 2 with exception to the SFP structure.

As described in Reference 1, the adequacy of the SFP structure is assessed by analysis as a Seismic Category 1 structure.

Therefore, the SFP structure is assumed to be 4-3 12Q0108.30-R-oo1, Rev. 1 Correspondence No.: RS-12-167 seismically adequate for the purposes of this program and is not included in the scope of items included on SWEL 2.The review of design and licensing basis documentation for the SFP revealed no Class I equipment for Dresden Generating Station Unit 2. (Ref. 2 section 9.1 and Ref. 9, 10, 11, 12, 13, and 15)Screen #1 identified no items to be added to SWEL 2. Therefore, Screens #2 and#3 below were not performed.

However, Screens #2 and #3 are provided for completeness as they are part of the equipment selection process.2. Screen #2- Equipment or Systems This screen was to consider only those items associated with the SFP that were appropriate for an equipment walkdown process. This screen was not performed as Screen #1 added no items to SWEL 2.3. Screen #3 -Sample Considerations This screen represents a process that was intended to result in a SWEL 2 that sufficiently represented a broad population of SFP Seismic Category 1 equipment and systems that met the objectives of the NRC 50.54(f) letter. (Ref. 1) The following attributes were to have been considered in the development of SWEL 2: A. A variety of types of systems B. Major new and replacement equipment C. A variety of types of equipment D. A variety of environments This screen was not performed as Screen #1 added no items to SWEL 2.4. Screen #4- Rapid Drain-Down This screen identifies items that could allow the spent fuel pool to drain rapidly.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 it is assumed the SFP gates are 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 without failure and do not allow for a rapid drain-down of the SFP.The SSCs identified in this screen are not limited to Seismic Category 1 (having defined seismic licensing basis) items, but is limited to those items that could allow rapid drain-down of the SFP. 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.

An assessment of the Dresden Generating Station Unit 2 spent fuel pools and their cooling systems was performed and found no SFP penetrations below 10 feet above the top of the fuel assemblies. (Ref. 2 section 9.1 and Ref. 9, 10, 11, 12,13, &15) As such,'and consistent with Reference 1, there is no potential for rapid drain-down and no items were added to SWEL 2 for Unit 2.No items were identified to be included in the scope of SWEL 2 for Dresden Generating Station Unit 2.4-4 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 5 Seismic Walkdowns and Area Walk-Bys 5.1 OVERVIEW Seismic Walkdowns and Area Walk-Bys were conducted by two (2) person teams of trained Seismic Walkdown Engineers (SWEs), in accordance with the EPRI guidance document during the weeks of July 16 and October 15, 2012. The Seismic Walkdowns and Area Walk-Bys are discussed in more detail in the following sub-sections.

Consistent with the EPRI guidance document, Section 4: Seismic Walkdowns and Area Walk-Bys, the SWEs used their engineering judgment, based on their experience and training, to identify potentially adverse seismic conditions.

Where needed, the engineers were provided the latitude to rely upon new or existing analyses to inform their judgment.The SWEs conducted the Seismic Walkdowns and Area Walk-Bys together as a team.During the evaluations, the SWEs actively discussed their observations and judgments with each other. The results of the Seismic Walkdowns and Area Walk-Bys reported herein are based on the comprehensive agreement of the SWEs.5.2 SEISMIC WALKDOWNS The Seismic Walkdowns focused on the seismic adequacy of the items on the SWEL as provided in Appendix B of this report. It is noted, as discussed in Section 4 above, there were no items included on SWEL 2 for Dresden Unit 2. The Seismic Walkdowns also evaluated the potential for nearby SSCs to cause adverse seismic interactions with the SWEL items. The Seismic Walkdowns focused on the following adverse seismic conditions associated with the subject item of equipment:

• Adverse anchorage conditions" Adverse seismic spatial interactions" Other adverse seismic conditions The results of the Seismic Walkdowns have been documented on the Seismic Walkdown Checklist (SWC) provided in the EPRI guidance document.

Seismic Walkdowns were performed and a SWC completed for 90 of the 103 items identified on the Dresden Unit 2 SWEL. The completed SWCs are provided in Appendix C of this report. Additionally, photos have been included with most SWCs to provide a visual record of the item along with any comments noted on the SWC. Drawings and other plant records are cited in some of the SWCs, but are not included with the SWCs because they are readily retrievable documents through the station's document management system. Information on anchorage that was obtained from the previously performed Seismic Qualification Utility Group (SQUG) walkdowns are included in the SWCs since this information, in part, was used for the anchorage verification.

5-1 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Seismic Walkdowns are deferred for the remaining 13 items to a unit outage or appropriate time when the equipment is accessible.

These items could not be walked down during the 180-day period following the issuance of the 10CFR50.54(f) letter due to their being inaccessible.

Inaccessibility of this equipment was either based on the location of the equipment (environment that posed personnel safety concerns while the unit is operating) or due to the electrical safety hazards posed while the equipment is operating.

Appendix E of this report identifies the inaccessible equipment along with the plan for future Seismic Walkdowns.

The following subsections describe the approach followed by the SWEs to identify potentially adverse anchorage conditions, adverse seismic interactions, and other adverse seismic conditions during the Seismic Walkdowns.

5.2.1 Adverse

Anchorage Conditions Guidance for identifying anchorage that could be degraded, non-conforming, or unanalyzed relied on visual inspections of the anchorage and verification of anchorage configuration.

Details for these two types of evaluations are provided in the following two subsections.

The evaluation of potentially adverse anchorage conditions described in this subsection applies to the anchorage connections that attach the identified item of equipment to the civil structure on which it is mounted. For example, the welded connections that secure the base of a Motor Control Center (MCC) to the steel embedment in the concrete floor would be evaluated in this subsection.

Evaluation of the connections that secure components within the MCC is covered later in the subsection "Other Adverse Seismic Conditions." Visual Inspections The purpose of the visual inspections was to identify whether any of the following potentially adverse anchorage conditions were present:* Bent, broken, missing, or loose hardware* Corrosion that is more than mild surface oxidation" Visible cracks in the concrete near the anchors* Other potentially adverse seismic conditions Based on the results of the visual inspection, the SWEs judged whether the anchorage was potentially degraded, non-conforming, or unanalyzed.

The results of the visual inspection were documented on the SWC, as appropriate.

If there was clearly no evidence of degraded, nonconforming, or unanalyzed conditions, then it was indicated on the checklist and a licensing basis evaluation was not necessary.

However, if it was not possible to judge whether the anchorage was degraded, nonconforming, or unanalyzed, then the condition was entered into the Corrective Action Program as a potentially adverse seismic condition.

5.2.2 Configuration

Verification In addition to the visual inspections of the anchorage as described above, the configuration of the installed anchorage was verified to be consistent with existing plant documentation for at least 50% of the items on the SWEL.5-2 12Q.108.30-R-O0i, Rev. I Correspondence No.: RS-12-167 Line-mounted equipment (e.g., valves mounted on pipelines without separate anchorage) was not evaluated for anchorage adequacy and was not counted in establishing the 50% sample size.Examples of documentation that was considered to verify that the anchorage installation configurations are consistent with the plant documentation include the following: " Design drawings* Seismic qualification reports of analyses or shake table tests" IPEEE or USI A-46 program documentation, as applicable The Table C-1 of Appendix C indicates the anchorage verification status for components as follows: N/A: components that are line-mounted and/or are not directly anchored (with separate anchorage) to the civil structure and therefore do not count in the anchorage confirmation total.Y: components that are anchored to the civil structure which were confirmed to be consistent with design drawings and/or other plant documentation.

N: components that are anchored to the civil structure for which anchorage drawings were not identified and/or retrieved.

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 drawings used for each anchorage verification confirmation.

Table 5-1. Anchorage Configuration Confirmation No. of SWEL NIA Items Required to SWEL Items Confirm? Items Confirmed (A) (B) (A-B)/2 Total 103 44 30 42 5.2.3 Adverse Seismic Spatial Interactions An adverse seismic spatial interaction is the physical interaction between the SWEL item and a nearby SSC caused by relative motion between the two during an earthquake.

An inspection was performed in the area adjacent to and surrounding the SWEL item to identify any seismic interaction conditions that could adversely affect the capability of that SWEL item to perform its intended safety-related functions.

The three types of seismic spatial interaction effects that were considered are as follows:* Proximity* Failure and falling of SSCs (Seismic II over I)" Flexibility of attached lines and cables 5-3 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Detailed guidance for evaluating each of these types of seismic spatial interactions is described in Appendix D: 'Seismic Spatial Interaction' of the EPRI guidance document.The Seismic Walkdown Engineers exercised their judgment to identify seismic interaction hazards. Section 5.2.5 provides a slimmary of issues identified during the Seismic Walkdowns.

5.2.4 Other

Adverse Seismic Conditions In addition to adverse anchorage conditions and adverse seismic interactions, described above, other potentially adverse seismic conditions that could challenge the seismic adequacy of a SWEL item could have been present. Examples of the types of conditions that could pose potentially adverse seismic conditions include the following:

• Degraded conditions

• Loose or missing fasteners that secure internal or external components to equipment* Large, heavy components mounted on a cabinet that are not typically included by the original equipment manufacturer

• Cabinet doors or panels that are not latched or fastened" Other adverse conditions Any identified other adverse seismic conditions are documented on the items' SWC, as applicable.

5.2.5 Conditions

Identification during Seismic Walkdowns Table 5-2 provides a summary of conditions identified during the equipment Seismic Walkdowns.

The equipment Seismic Walkdowns resulted with a total of seven (7)conditions identified and each of these was entered into the station's CAP. All of the identified conditions were assessed and it was concluded that the condition would not prevent the associated equipment from performing its safety-related function(s).

None of the conditions identified by the SWEs during the equipment Seismic Walkdowns were concluded to be adverse seismic conditions.

5.3 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 SWEL items. Vicinity is generally defined as the room containing the SWEL item. If the room is very large (e.g., Turbine Hall), then the vicinity is identified based on judgment, e.g., on the order of about 35 feet from the SWEL item. This vicinity is described on the Area Walk-By Checklist (AWC), shown in Appendix D of this report. A total of 34 AWCs were completed for Dresden Unit 2.The key examination factors that were considered during Area Walk-Bys include the following:

• Anchorage conditions (if visible without opening equipment)

• Significantly degraded equipment in the area 5-4 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167* A visual assessment (from the floor) of cable/conduit raceways and HVAC ducting (e.g., condition of supports or fill conditions of cable trays)* Potentially adverse seismic interactions including those that could cause flooding, spray, and fires iri the area" Other housekeeping items that could cause adverse seismic interaction (including temporary installations and equipment storage)" Scaffold construction was inspected to meet Exelon Procedure NES-MS-04.1 Seismic Prequalified Scaffolds* Seismic housekeeping was examined to meet station procedure DAP 03-20, Restraint of Portable Equipment The Area Walk-Bys are intended to identify adverse seismic conditions that are readily identified by visual inspection, without necessarily stopping to open cabinets or taking an extended look. Therefore, the Area Walk-By took significantly less time than it took to conduct the Seismic Walkdowns described above for a SWEL item. If a potentially adverse seismic condition was identified during the Area Walk-By, then additional time was taken, as necessary, to evaluate adequately whether there was an adverse condition and to document any findings.The results of the Area Walk-Bys are documented on the AWCs included in Appendix D of this report. A separate AWC was filled out for each area inspected.

A single AWC was completed for areas where more than one SWEL item was located.Additional details for evaluating the potential for adverse seismic interactions that could cause flooding, spray, or fire in the area are provided in the following two subsections.

Seismically-Induced Flooding/Spray Interactions Seismically-induced flooding/spray interactions are the effect of possible ruptures of vessels or piping systems that could spray, flood or cascade water into the area where SWEL items are located. This type of seismic interaction was considered during the IPEEE program. Those prior evaluations were considered, as applicable, as information for the Area Walk-Bys.One area of particular concern to the industry is threaded fire protection piping with long unsupported spans. If adequate seismic supports are present or there are isolation valves near the tanks or charging sources, flooding may not be a concern. Numerous failures have been observed in past earthquakes resulting from sprinkler head impact.Less frequent but commonly observed failures have occurred due to flexible headers and stiff branch pipes, non-ductile mechanical couplings, seismic anchor motion and failed supports.Examples where seismically-induced flooding/spray interactions could occur include the following:

• Fire protection piping with inadequate clearance around fusible-link sprinkler heads* Non-ductile mechanical and threaded piping couplings can fail and lead to flooding or spray of equipment* Long, unsupported spans of threaded fire protection piping" Flexible headers with stiffly supported branch lines 5-5 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167* Non-Seismic Category I tanks The SWEs exercised their judgment to identify only those seismically-induced interactions that could lead to flooding or spray.Seismically-Induced Fire Interactions Seismically-induced fire interactions can occur when equipment or systems containing hazardous/flammable material fail or rupture. This type of seismic interaction was considered during the IPEEE program. Those prior evaluations were considered, as applicable, as information for the Area Walk-Bys.Examples where seismically-induced fire interactions could occur include the following:

• Hazardous/flammable material stored in inadequately anchored drums, inadequately anchored shelves, or unlocked cabinets* Natural gas lines and their attachment to equipment or buildings* Bottles containing acetylene or similar flammable chemicals* Hydrogen lines and bottles Another example where seismically-induced fire interaction could occur is when there is relative motion between a high voltage item of equipment (e.g., 4160 volt transformer) and an adjacent support structure when they have different foundations.

This relative motion can cause high voltage busbars, which pass between the two, to short out against the grounded bus duct surrounding the busbars and cause a fire.The Seismic Walkdown Engineers exercised their judgment to identify only those seismically-induced interactions that could lead to fires.5.3.1 Conditions Identification during Area Walk-bys Table 5-3 provides a summary of conditions identified during the Area Walk-bys.

Three (3) conditions were identified during the Area Walk-Bys and entered into the station CAP. No potentially adverse seismic conditions were identified that resulted in a seismic licensing basis evaluation.

No seismically-induced flooding or spray interactions were identified during the Area Walk-Bys.

No seismically-induced fire interactions were identified during the Area Walk-Bys.5.4 SUPPLEMENTAL INFORMATION ON ELECTRICAL CABINET INSPECTIONS Following the completion of the online seismic walkdowns, the industry was made aware that the NRC staff had clarified a position on opening electrical cabinets to inspect for other adverse seismic conditions.

The purpose for opening these cabinets is to inspect for evidence of:* internal components not being adequately secured,* whether fasteners securing adjacent cabinets together are in place, and* other adverse seismic conditions.

Appendix E of this report includes Table E-2 which identifies components in the specified equipment classes that would be considered as electrical cabinets: 1. Motor Control Centers and Wall-Mounted Contactors 5-6 12Q0108.30-R-OO1, Rev. I Correspondence No.: RS-12-167 2. Low Voltage Switchgear and Breaker Panels 3. Medium Voltage, Metal-Clad Switchgear

4. Transformers

14. Distribution Panels and Automatic Transfer Switches 16. Battery Chargers and Inverters 20. Instrumentation and Control Panels Components that are identified on Table E-1 (inaccessible and deferred components) are not listed on Table E-2 to avoid redundancy.

Table E-2 indicates internal accessibility of each cabinet. Cabinets that have been identified as requiring these supplemental internal inspections are those with doors or panels with latches or thumbscrews and can be readily opened during normal maintenance activities.

Also provided for each cabinet is a proposed milestone schedule for performing these internal inspections and the associated station tracking number (IR number).The Seismic Walkdown Checklists (SWC) for the components identified in Table E-2 that can be opened for internal inspections will be revised at the time of the supplemental walkdown to indicate the results of these internal inspections.

5-7 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 Table 5-2. Conditions Identified during Seismic Walkdowns Actions Action Complete Item ID Description of Issue Request (Yes/No, ID (IR) See Notes 1 &2)Several loose bolts with missing nuts in the conduit clamps above the 902-36 back panel in the main control room. The 902-36 back panel enclosure top D02-0902-prevents the bolts from falling into that panel.0036 However, if the bolts fall, their trajectory could cause 1389209 Yes them to land in an adjacent panel. Design ERRT SQ Structural Engineer notes that bolts are unlikely to fall due to their as-found orientation in a downward position.D02-0902-Loose wireway in back panel. 1389213 No 0015 DOO-83250-Two lights above U2 and U2/3 250VDC battery 1389329 Yes 0---B05 chargers with open S-hooks.Portable eyewash station not secured and did not D02-83250-meet distance requirements of DAP 03-20, 1389735 Yes A01-M05 "Restraint of Portable Equipment." Eyewash station relocated to comply with DAP 03-20, Step F.3.Damaged lighting and support above instrument rack 2202-19A:

one fluorescent light bulb in the fixture is broken with only a piece left in the socket*and the other bulb appears to be loose enough to fall. This fall could potentially affect the vibration D02-1501-sensitive equipment below. In addition, the support 1389874 Yes 0058A-FT members for the lighting fixture appear to be bent at the channel fitting connection.

Loose bulb and broken bulb have been removed from light fixture.Station engineering verified that light fixture will not fall and poses no seismic interaction concern for instrument rack below.Light fixture above 2-1501-21A valve supported by chain connected to a cantilevered channel via a beam clamp. The beam clamp appears to rely solely D02-1501 -on the slip capacity of the beam clamp bolt to resist the dead load of the light fixture, which could be 1390318 Yes inadequate in a seismic event. Valve 2-1501-21A operator is robust. Thus, there is no adverse seismic interaction concern due to the subject light fixture above.5-8 12Qo108.30-R-No1, Rev. 1 Correspondence No.: RS-1 2-1 67 1) Light fixture hanging above the 250 VDC MCC 2B has open S-hooks. However, the fixture is hardwired to the ceiling at one end and the other end is above a lateral bracing member, therefore, D02-8302B-impact to the equipment would be minimal if there M05 & D02- were a fall. 1390863 Yes 2252-0084

2) Light fixture hanging above Instrument Rack 2252-84 has an open S-hook on the east end of the fixture. However, lateral bracing for Bus 24-1 would prevent contact with instrument rack in the case of a fall.Notes: 1) "Yes" indicates that any corrective actions resulting from the issue are complete.2) "No" indicates that any corrective actions resulting from the issue are NOT complete.Actions are tracked by the IR number in the station Corrective Action Program.5-9 12QO108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Table 5-3. Conditions Identified during Area Walk-Bys Actions Item Action Complete ID Description of Issue Request (Yes/No, ID (IR) See Notes 1 &2)Cart staged for maintenance work in control room back AWC- panel area did not meet distance requirements of DAP 03- 1389231 Yes U2-1 20, "Restraint of Portable Equipment." Moved cart to comply with DAP 03-20.Bent fire piping hanger that is in the area above the Unit 2 LEFM panel. FP System Engineer and ERRT Structural AWC- Engineer came to the area to investigate.

They stated that 1389712 Yes U2-32 the bend does not pose a threat to any equipment and is not preventing the hanger from holding the fire system piping in any manner..The Fukushima Seismic walkdown team inspected the U2 HPCI room as part of the scope for area walk-by inspections to satisfy the NRC request for information.

There is a ladder rack on the wall at the back of the room.AWC- The ladder rack does not have any "fingers" on the ends 1390584 Yes U2-12 of the rack that would keep the ladders on the rack during a seismic event. There were two ladders stored on the rack that needed to be shifted to one side to prevent the ladders from contacting seismically sensitive equipment in case of an event. The ladders were repositioned.

Notes: 1) "Yes" indicates that any corrective actions resulting from the issue are complete.2) "No" indicates that any corrective actions resulting from the issue are NOT complete.Actions are tracked by the IR number in the station Corrective Action Program.5-10 2Q01-08.30-R-001, Rev. 1 Correspondence No.: RS-12-167 6 Licensing Basis Evaluations The EPRI guidance document, Section 5: Seismic Licensing Basis Evaluation provides a detailed process to perform and document seismic licensing basis evaluations of SSCs identified when potentially adverse seismic conditions are identified.

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 Corrective Action Program (CAP). In lieu of this process, Exelon/Dresden utilized the existing processes and procedures (Site CAP Expectations) to identify, evaluate and document conditions identified during the Seismic Walkdowns.

In accordance with Exelon/Dresden processes and procedures, all questionable conditions identified by the SWEs during the walkdowns were entered into the station CAP to be further evaluated and addressed as required.

The SWEs provided input to support the identification and evaluation (including seismic licensing basis evaluations, as required) of the potentially adverse seismic conditions entered into the CAP. The station corrective action program is a more robust process than that provided in the EPRI guidance document; in part, ensuring each condition is properly evaluated for conformance with design and licensing bases and corrected as required.Conditions identified during the walkdowns were documented on the SWCs, AWCs, and entered into the CAP. For those conditions that required, seismic licensing basis evaluations were completed and documented within the IR. Tables 5-2 and 5-3 in the report provide the IR, a summary of the condition, and the action completion status.6-1 12Q0108.30-R-001, Rev. I Correspondence No.: RS-12-167 7 IPEEE Vulnerabilities Resolution Report Per the Individual Plant Examination of External Events (IPEEE) Submittal for Dresden and the NRC Staff Evaluation Report of IPEEE submittal for the Dresden Station, an explicit definition of vulnerability was not provided and no vulnerabilities with respect to potential severe accidents related to external events were identified. (Ref. 3, 4, & 5)However, plant improvements and previously identified SQUG outliers were identified in Sections 3 and 7 of Reference

4. Table G-1, in Appendix G, lists the plant improvements, the IPEEE/SQUG proposed resolution, the actual resolution and resolution date. No open items exist as a result of the seismic portion of the IPEEE program.7-1 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167 8 Peer Review A peer review team consisting 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 SSCs included on the SWEL* Review of a sample of the checklists prepared for the Seismic Walkdowns and Area Walk-Bys* 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 The peer reviews were performed independently from this report and the summary Peer Review Report is provided in Appendix F of this report.8-1 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 9 References Reference drawings related to SWEL items are provided in the Seismic Walkdown Checklists and if applicable, in the Area-Walkdown Checklists.

1. EPRI Technical Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, dated June 2012.2. Dresden Power Station Updated Final Safety Analysis Report (UFSAR), Revision 9 3. ComEd PSLTR #00-0068, Request for Additional Information Regarding Individual Plant Examination of External Events, dated March 30, 2000 4. Letter from J.M. Heffley (ComEd) to U. S. NRC, "Final Report -Individual Plant Examination of External Events (IPEEE) Generic Letter 88-20, Supplement 4," dated December 30, 1997 5. Staff Evaluation Report of Individual Plant Examination of External Events (IPEEE)submittal of Dresden Nuclear Power Station, Units 2 and 3 dated September 28, 2001 6. ComEd Letter to U.S. Nuclear Regulatory Commission dated May 18, 1999"Response to Request for Additional Information Regarding Unresolved Safety Issue (USI) A-46 7. 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(0 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 3,"Recommendation 2.3: Seismic," dated March 12, 2012 8. Exelon Nuclear Memorandum from Larry Lee to John Steinmentz, dated July 3, 2012,

Subject:

Dresden Risk Importance Listings to Support Development of Seismic Walkdown Equipment List (SWEL)9. Drawing M-31, Rev. BL, Diagram of Fuel Pool Cooling Piping 10. Drawing B-251, Rev. E, Reactor Building Pool Plan 11. Drawing B-252, Rev. D, Reactor Building Pool Sections & Details 12. Drawing B-253, Rev. E, Reactor Building Pool Sections & Details 13. Drawing B-254, Rev. F, Reactor Building Pool Sections & Details 14. "Recommendations for Enhancing Reactor Safety in the 2 1 st Century: The Near-term Task Force Review of Insights from the Fukushima Dai-ichi Accident," ADAMS Accession No. ML111861807, July 12, 2011 15. Drawing M-50, Rev. AM, Diagram of Fuel Pool Filter & Demineralizing Piping 9-1 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 A Project Personnel Resumes and SWE Certificates Resumes and certificates (where applicable) for the following people are found in Appendix A: A. Perez, Equipm ent Selection Engineer .........................................................

A-2 K. Hull, Equipm ent Selection Engineer ............................................................

A-6 J. Griffith, SW E, Licensing Basis Reviewer ........................................................

A-9 D. Carter, SW E, Licensing Basis Reviewer .......................................................

A-1 3 T. Ram , SW EL Peer Reviewer .....................................................................

A-16 B. Lory, Peer Review Team Leader ........................................

....................

A-18 W. Djordjevic, Peer Reviewer ......................................

A-22 B. Weight, SWE, Licensing Basis Reviewer, IPEEE Reviewer ............................

A-26 A-1 Stev 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 fenson & Associates Antonio J. Perez, P.E.

SUMMARY

Mr. Perez has over 15 years of experience in project management, project engineering, equipment design, and mechanical systems layout for nuclear and industrial facilities.

EDUCATION B.S. -Mechanical Engineering Michigan Technological University, Houghton, MI Magna cum Laude LICENSES Professional Engineer, Wisconsin:

September 2002 Minnesota:

December 2010 PROFESSIONAL EXPERIENCE Stevenson

& Associates, Green Bay, WI General Manager October 2010 -Present* Responsible for interfacing with clients with a focus on continuously improving relationships.

• Responsible for managing staff resources to meet or exceed clients' needs.* Responsible for recruiting and hiring staff necessary to meet resource requirements while effectively increasing capacity." Responsible for providing Engineering Consultation services to clients.Project Manager March 2007 -October 2010" Performing Project Management tasks including development of project plans, identification of resource needs, estimating task durations, developing project schedules, and monitoring budgets.* Lead design team efforts at the Kewaunee Power Station on multiple projects that include two separate Auxiliary Feedwater flow control modifications, Auxiliary Feedwater flow monitoring instrumentation modifications, and Auxiliary Building roof modifications.

• Supported the Calculation Reconstitution and Improvement Project at the Prairie Island Nuclear Generating Plant by mapping calculations associated with the RHR system.Dominion Energy Kewaunee (formerly Nuclear Management Company 2001 -2005)Kewaunee Power Station, Kewaunee, WI Shift Technical Advisor (trainee)

January 2006 -,March 2007* Trainee in a Senior Reactor Operator Certificate training program.Page 1 of 3 A-2 Stev 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167'enson & Associates Antonio J. Perez, P.E.Engineering Supervisor

-ME/CE/SE Design May 2004 -January 2006" Supervised a staff of 12 to 15 engineers (mechanical, civil, and structural design) who were charged with developing design changes, maintaining design and licensing basis documentation and supporting maintenance.

• Integrated the civil/structural engineering group and the mechanical engineering group into a cohesive unit that resulted in gained efficiency and a net reduction of one full time equivalent engineer.* Substantially increased the quality of engineering products developed and published by the ME/CE/SE Design Engineering group through coaching and feedback as a result of increased supervisory oversight of engineering products.* Developed a work management system for the group that provided a means for prioritizing activities, estimating the level of effort, and scheduling of activities.

This system allowed for an increased understanding of workload and became an invaluable tool for prioritizing work and managing resources.

• Increased communications within the group by holding daily 15 minute meetings where station messages were delivered and where the group's resources were assessed and redirected as necessary to meet commitments.

This resulted in an increase in morale and an increase in commitments met." Increased communications with other departments by establishing a central point of contact for the group and by assuring that the ME/CE/SE Design Engineering group was represented at Planning and Scheduling meetings.Motor Operated Valve Engineer June 2001 -May 2004* Established a project plan and led the implementation effort that re-organized the Motor-Operated Valve Program at KPS. This effort consisted of developing a Program Manual, developing controlled calculations, performing Design Basis Reviews, and compiling and/or establishing plant positions on known industry issues.The result of this effort was a reduction of full time equivalent engineers, from 3 to 1, required to maintain the Program." Performed and reviewed MOV safety related calculations including Minimum Required Stem Thrust, Weak Link Analysis, and Available Margin.* Assisted in MOV testing by, providing engineering support to maintenance personnel.

DISTRIBUTION PLANNING, INC., Grandville, MI Systems Mechanical Engineer 2000- 2001* Integrated mechanical systems and designed equipment for material handling systems.* Procured equipment and coordinated delivery schedules with vendors.Page 2 of 3 A-3 Stev 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 fenson & Associates Antonio J. Perez, P.E.SMS SANDMOLD SYSTEMS, INC., Newaygo, MI Project Engineer /Manager 1998 -2000" Led multi-discipline project design teams for several projects that ranged in size from a few thousand dollars up to $2.2 million.* Coordinated efforts with engineering, manufacturing, and installation groups to establish and maintain project schedules that met or exceeded the client's expectations.

• Procured equipment and coordinated delivery schedules with vendors.* Acted as the company's liaison with clients to work through issues that arose during projects.

Provided project status updates to clients and management.

• Designed equipment such as sand storage bins -up to 540-ton live load capacity, bucket elevators, belt conveyors, screw conveyors, and mixers. Most of this equipment was for handling of bulk solids (foundry sand)." Analyzed and designed structural support members for various types of equipment such as vibratory conveyors, mixers, and conveyors.

Designed access structures such as stair towers, service platforms and catwalks." Calculated foundation loads and point loads of equipment support points.LIFT-TECH INTERNATIONAL, Muskegon, MI Project Engineer 1997 -1998 o Performed engineering analyses, wrote critiques, and recommended design modifications of structural members for the purpose of upgrading bridge cranes and hoists.* Implemented engineering design changes to enhance product development.

Page 3 of 3 A-4 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 A-5 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 KIM L. HULL BACKGROUND

SUMMARY

Accomplished Lead Engineer/

Project Manager with significant experience in commercial nuclear power industry.

Demonstrated ability to lead and contribute on cross-functional project teams. Possess strong analytical, problem resolution, collaboration, and communication skills when interacting with diverse audiences including regulatory inspectors, internal inspectors, management, and employees.

Respected trainer with ability to develop and present information and measure effectiveness through evaluation-techniques.

Strengths include: Project Management Design Modifications Plant Operational Support Procurement Management/Leadership Regulatory Compliance Training/Coaching Auditing Inspections KEY ACCOMPLISHMENTS

• Served as KNPP Lead Engineer/

Project Supervisor for approximately 125 plant design changes.* Experienced in all aspects of nuclear power plant modification packages including development of calculations, design, engineering, and procurement specifications.

• Thorough understanding of configuration control, management, and preparation of IOCFR50.59 analyses.* Participated in several regulatory and industry audits, including CDBI and INPO assessments.

• Experienced as a Technical Specialist performing NUPIC Audits.* Well-developed communication skills for preparing technical presentations including lesson plans, project reports, and meetings in support of regulatory activities and inspections.

• Qualified Shift Technical Advisor for KNPP Operations Group (1980s).PROFESSIONAL EXPERIENCE STEVENSON

& ASSOCIATES

-Project Manager 2010 -Current National consulting engineering firm specializing in civil, structural and mechanical engineering for power, industrial and advanced technology facilities.

Project Manager* Development of plant specific Seismic Walkdown Equipment Lists for multiple Units in response to NRC 50.54(f) requirements 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."* Onsite at Kewaunee Power Station Consultant support to resolve Q-list Open Items* On-site at Kewaunee Power Station Consultant support for Auxiliary Feedwater Flow Control Modification including preparation and review of design documentation.

WISCONSIN PUBLIC SERVICE RESOURCES

/ Nuclear Management Company DOMINION ENERGY -Kewaunee, WI 1982 to 2010 Senior Instructor (Maintenance)

(2009 -2010)* Developed lesson plans and taught Basic Systems and Continuing Training Topics for Engineering and Technical Support training program.Engineer III/Principal Engineer (2004 -2009)* Responsible for modifications and emergent issues including Steam Exclusion Boundaries, Fuel Transfer Carriage, Frazil Ice development on the KPS Circulating Water Intake, and NRC 96-06 Two Phase flow." Member of Dominion Fleet Calculation Quality Review Team and Mentor for Calculation training.* Outage nightshift Lead Mechanical Design Engineer/Back-up Supervisor.

• KPS Engineering representative on the Independent Review Team developed to address CDBI A-6 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 inspection findings.

Assigned to review all calculations, modification packages, IOCFR 50.59 screenings, evaluations, and procurement packages.* Technical Instructor for Administrative Process training for new engineers.

Mechanical Design Supervisor (2002 -2004)* Supervised nine engineers, analysts, and technicians assigned to the KNPP Mechanical Design Group.* Provided Mechanical Design Oversight for all vendor activities impacting KNPP Mechanical Design Bases.* Provided support for emergent plant issues, NRC Inspections, and Physical Change Packages.* Subject Matter Expert Instructor for 1OCFR 50.59 process training for new engineers.

Principal Engineer (Analytical Group SGR Project) (1998 -2002)* Contract Manager for Steam Generator Replacement (SGR).* Responsible for coordination of SGE design, fabrication and installation contracts.

• Provided outage schedule development, coordination, and work process integration between Bechtel and KNPP.* Coordinated contractor mobilization, badging, and plant specific training.* Technical Specialist for Quality Assurance audits of vendors.* SGR Shift Manager for night shift* Responsible Engineer for SGR related Physical Change Packages.* Responsible for SGR budget development up to 1998.* Prepared, reviewed, and awarded Bechtel Installation contract.* Participated in review and award of Ansaldo Fabrication contract.* Served on team to review and award Westinghouse Design contract.* Selected to work at Arkansas Nuclear One for their steam generator installation.

Senior Engineer (Analytical Group) (1994-1998)

• Responsible Engineer for Physical Change Packages.* Member KNPP Engineering Reorganization Team.* Recognized Technical Expert for KNPP systems.Senior Project Supervisor (1992-1994)" Provided project management and engineering services for KNPP DCR packages.* Supervisor of KNPP NPM Project Attendants responsible for modification package organization and close out.Nuclear Services Supervisor (1991-1992)

• Supervised initial Steam Generator replacement project effort.* Provided specification development for services and major plant components.

Prior to 1992 -Held engineering positions from Associate Engineer to Nuclear Design Engineering Supervisor.

EDUCATION Masters Program Coursework

-Mechanical Engineering; Michigan State University

-E. Lansing, MI B.S. -Mechanical Engineering

-Michigan State University

-E. Lansing, MI B.A. -Biology -Albion College -Albion, MI A-7 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 A-8 12QO108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 STEVENSON

& ASSOCIATES JAMES D. GRIFFITH QUALIFICATIONS Knowledgeable professional with over 23 years of diverse experience in structural engineering.

Thorough, results-oriented problem solver with excellent communication skills. Works well independently or as part of a team. Highly skilled in all project phases from design through construction and specializes in field problem resolution.

PROFESSIONAL EXPERIENCE Proiect En-gineer (Stevenson

& Associates, 2000 to present)Responsible for all aspects of civil structural design. Also provides interface between clients, vendors, constructors and Stevenson

& Associates.

Decommissioning Design Engineer (ComEd, 1998 to 2000)Responsible for structural design work during conversion from generating to storage facility.

Gathered design information during conceptual field walkdowns and prepared design calculations and drawings.Provided field support during construction." Designed all component supports and concrete foundations for various new indoor equipment." Managed construction during installation of new roof-mounted HVAC system." Designed structural steel support framing and access gallery for new outdoor cooling towers.Maintenance Engineer (ComEd, 1995 to 1998)Responsible for the design of structural repairs to station equipment and facilities.

Interfaced with maintenance and construction personnel and performed evaluations of rigging, lead shielding, and scaffolding.

Investigated and developed solutions for structural problems in the field and provided field support during installation of modifications.

• Designed and supervised field installation of heavy-duty rigging apparatus for replacement of large overhead crane motor.* Performed conceptual design and supervised field construction of 60 foot high scaffold work platform for valve replacement.

• Prepared and reviewed calculations to justify structural acceptability of station equipment during successful completion of Seismic Qualification Utility Group (SQUG) evaluation program.* Acted as engineering liaison to other station departments (Maintenance, Operations, Radiation Protection, etc) to resolve emergent problems regarding:

• Rigging for lifting various plant equipment* Placement and support of temporary lead shielding* Storage of equipment in safety related seismic areas of the plant* Structural repairs and improvements to plant buildings and equipment Structural Engineer (Sargent and Lundy, 1983 to 1995)Responsible for design of structural modifications to various components of power generating facilities.

Prepared and reviewed design calculations and drawings* Designed numerous modifications to existing structural steel framing members and end connections.

1 A-9 12Q.108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167" Supported field installation of modifications and provided solutions to problems encountered in the field." Designed and monitored field installation of new access galleries for various pieces of equipment.

EDUCATION B.S., Civil and Environmental Engineering, University of Wisconsin, Madison, Wisconsin Continuing Education"Concrete Evaluation and Repair Seminar", Portland Cement Association, Skokie, Illinois, 1996"STAAD III Program Training", Sargent and Lundy Engineers, Chicago, Illinois, 1995"Piping Design, Analysis and AUTOPIPE Training" Vectra Technologies, Inc., Zion, Illinois, 1995"SQUG Walkdown Screening and Seismic Evaluation Training Course", Seismic Qualification Utility Group through CoinEd, Downers Grove, Illinois, 1994 PROFESSIONAL REGISTRATIONS Licensed Professional Engineer in State of Wisconsin 2 A-10 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 A-11 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 A-12 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Stevenson

& Associates DAVID N. CARTER PROFESSIONAL EXPERIENCE April, 1998-Present Wisconsin Electric, Point Beach Nuclear Plant (On loan from Stevenson

&Associates)

Point Beach Nuclear Plant is located in Wisconsin between Milwaukee and Green Bay on Lake Michigan.Worked as Seismic Qualification Engineer responsible for performing seismic evaluations of plant equipment as well as providing input to procurement documents and reviewing seismic qualification reports for new plant equipment.

Also worked as Design Engineer preparing and managing various plant modifications.

Modifications included reinforcement of RWST anchorage, new HELB barriers and vent paths, new firewall, platform and foundation modifications.

The modification preparations included preparing design change documents, 50.59 safety evaluations and calculations as well as assisting in resolution of installation problems.December, 1997-April, 1998 Stevenson

& Associates Stevenson

& Associates is a consulting engineering firm. Work includes design and analysis of building structures and components.

April, 1995-December, 1997 ComEd, Zion Station Zion Station is a nuclear power plant that is owned and operated by CornEd, an electric utility serving northern Illinois.

Member of design engineering group as a Senior Structural Engineer.

Work included the scoping, cost estimating, design and preparation of design documents for various plant modifications.

Prepared 50.59 safety evaluations for various plant modifications.

Member of the Zion Seismic Review Team that implemented the SQUG program. Performed SQUG walkdowns and assessments.

Proposed and implemented upgrades to SQUG outliers.

Attended and completed the SQUG SCE Training.April, 1984-April, 1995 Sargent & Lundy Engineers Sargent & Lundy is a consulting engineering firm that specializes in the design and modification of power plants. Work included the design and analysis of building structures and support components on fossil and nuclear power plants. Assignment highlights include the following:

• Member of modification design project team at Zion Station.* Member of Zion project team in Sargent and Lundy Chicago office for approximately two years.Worked on various modifications for Zion Station as a Senior Engineer in the Structural Engineering Division.

Design activities included preparation, review or approval of design calculations, design documents such as engineering change notices and design criteria documents.

Supervised up to four other engineers.

• Member of a design team working on the design of two new nuclear units located in Korea (Yonggwang 3&4). The design was done in the offices of Korea Power Engineering Corporation located in Seoul, Korea. Responsibilities included the design of the structural steel for the turbine building.

The assignment involved working with and providing guidance for engineers from the Korean engineering company. The work also involved the preparation of design procedures, procurement specifications, and design calculations as well as the review of design drawings and shop drawings.

The length of this assignment was approximately four years.1 A-13 12Q-108.30-R-OO1, Rev. 1 Correspondence No.: RS-12-167" Member of a group of engineers that worked on a weld evaluation program at Watts Bar Nuclear Power Station. The assignment included the evaluation of various weld discrepancies on structural steel connections and component supports.

This assignment lasted one year." Member of various project teams which worked on the design of modifications for fossil and nuclear power plants. Projects include Dresden, Quad Cities, Byron, Braidwood Stations (Commonwealth Edison Co.), and Parish Station (Houston Lighting and Power). Work included the assessment of masonry walls, design of component supports, design of hot air ducts, evaluation of structural steel framing for final loads and preparation of study and design reports. Responsibilities also included the preparation and review of design documents, letters, supervising other engineers, and meeting with clients.September, 1980-March 1984 American Bridge Division -United States Steel Corp.American Bridge was a consulting engineering firm whose main client was U.S. Steel. They specialized in the design and modification of steel mill buildings.

Assignments included the following:

• Design of various modifications to blast furnaces.* Member of group of engineers whose function was to inspect existing mill buildings, prepare a report of findings and recommend repairs. Included in this assignment was the preparation of design drawings showing the recommended repairs. This assignment lasted approximately one year.* Loaned to Sargent and Lundy Engineers to assist in the design of component supports and the final load evaluation on Byron Nuclear Power Station. This assignment totaled approximately 16 months.EDUCATION Syracuse University, L. C. Smith College of Engineering; Bachelor of Science Degree in Civil Engineering.

Graduated Cum Laude..PROFESSIONAL AFFILIATIONS Licensed Professional Engineer in State of Minnesota Licensed Structural Engineer in State of Illinois Licensed Professional Engineer in State of Wisconsin 2 A-14 12Q0108.30-R-OO1, Rev. 1 Correspondence No.: RS-1 2-1 67ý ý : : ý : ý I ! I I I I 1ý I , : , 1 1 1 1, 1 ý ; ý ý : 1 : 1 ! 1 ý , ý ý : ; ýA A : ý I , IRev. 1 Correspondence No.: RS-12-167-------------------------

W V 19/ AL LA7AYLALAL AVL ~~4I '4~Fýq Certificate of Completion Dave Carter Successfu1ly Completed Training on Near Term Task Force Recommendation 2.3 -Plant Seismic Walkdowns 6 E-ý11Z.0,010 Date: 06126112 Bruce M. Lodf -Instructor NTTF 2.3 Seismic Walkdown Course A AA A A A A A AVI vvvvvvvvvvv~vvvv

'~A-15 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Tribhawan Ram EDUCATION:

B.S. -Electrical Engineering, Punjab University, India, 1972 MS.'- Electrical Engineering, University of Cincinnati, 1977 M.S. -Nuclear Engineering, University of Cincinnati, 1982 M.B.A. -Bowling Green State University, 1996 PROFESSIONAL REGISTRATION:

State of Ohio PROFESSIONAL HISTORY: Stevenson

& Associates, Inc., Senior Engineer, 2011 -present Public Service Electric & Gas Co., Senior Plant Systems Engineer, Hancock Bridge, NJ, 2007 -2011 Entergy Corporation, Plymouth, Massachusetts, Senior Design Engineer, 2002-2007 Various Companies, Contract Consulting Project Engineer, 1996 -2002 Public Service Electric & Gas Co., Senior Staff Engineer, Hancock Bridge, NJ, 1983-1990 Toledo Edison Co., Toledo, Ohio, Senior Assistant Engineer, Associate Engineer, 1978-1983 PROFESSIONAL EXPERIENCE: " Electrical and Controls Design Engineering" Plant Systems Engineering" Transformer and Relay(s) Spec Developer" Plant Modification Engineering" Systems and Component Test Engineering

• Factory Testing Witness" 6 Month BWR Systems Engineering Training* ETAP Trained* Arc Flash IEEE 1584 Trained Mr. Ram has over 28 years of electrical project, design and systems engineering experience in US nuclear plants. As part of the Seismic Margin Analysis (SMA) team, in 2012, Mr. Ram is leading the electrical engineering EPRI methodology effort to perform Post-Fukushima relay list development and evaluation to support Safe Shutdown Equipment List (SSEL), including relay functional screening and chatter analysis, for Taiwan nuclear plants (both PWR and BWR). In this effort, he is preparing the final reports including recommendations to replace any bad actor relays. Mr. Ram is preparing proposals to replace these bad actors including modification package development for field replacement of these relays. He has prepared proposals to lead similar forthcoming relay evaluation efforts for several Westinghouse plants in the USA. Mr. Ram has either prepared or peer reviewed the Seismic Walkdown Equipment Lists (SWEL 1 & 2) for several Exelon Plants.A-16 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 As a senior plant systems engineer, Mr. Ram has: 1. Developed several test plans for modification packages for the replacement of low and medium voltage circuit breakers (ABB K-Line to Square D Masterpact; GE Magneblast to Wyle Siemens) and for the replacement of the entire Pressurizer Heater Bus switchgear;

2. Personally been involved in execution of these test plans during refueling outages;3. Witnessed factory testing of Pressurizer Heater Bus Switchgear;

4. Interfaced with NRC in their biennial Component Design Basis Inspections (CDBI); Interfaced with INPO in their biennial evaluations;

5. Developed and executed Performance Centered Maintenance (PCM) strategies for Motor Control Centers (MCCs) and low and medium voltage circuit breakers and switchgear; 6.Developed and executed margin improvement strategies for pressurizer heater busses, for twin units, through obtaining funds and then equipment replacement;

7. Developed refueling outage scoping for low and medium voltage circuit breakers and MCCs through working with outage group, maintenance, operations, and work MGMT; 8. Resolved breaker grease hardening issue for ABB K-Line breakers, over a two year period, through working with maintenance and work MGMT.in implementing accelerated overhauls with better grease; 9. Trained operations and engineering personnel in the Engaging People and Behavior Change process, as part of a case study team and; 10.Resolved day to day operations and maintenance issues with systems of responsibility (low and medium voltage systems)Mr. Ram has regularly participated in the EPRI annual circuit breaker user group conferences; at the 2011 meeting, he made a presentation on circuit breaker as found testing vis-a-vis protection of equipment, cables, and containment penetrations, and selective coordination preservation.

As a Senior Design Engineer, Mr. Ram has: 1. Developed specifications and procured 345/4.16/4.16 kV and 23/4.16/4.16 kV transformers (ranging up to $1.25 million);

2. Prepared a modification package to install the 23 kV/4.16 kV/4.16 kV transformer, including leading the project team to get this transformer successfully installed, tested, and placed in service; 3. Developed ETAP scenarios and performed load flow studies to successfully support the 2006 INPO evaluation;

4. Performed arc flash calculations per IEEE 1584 methodology for 4 kV, 480V Load Centers, and MCCs, enabling a justification of reduced arc flash rated clothing, thereby allowing conversion of OUTAGE PMs into ONLINE PMs and; 5. Performed single point system vulnerability analysis.As a Consulting Lead Project Engineer, Mr. Ram was heavily involved in resolution of the USI A-46 for several plants. He performed an extensive review of dozens of control circuits for relay chattering issues. To replace bad relay actors, Mr. Ram developed and/or supervised the development of many modification packages including:

selection of replacement relays (both protective and auxiliary);

preparation of relay testing specification with civil engineering input; working with and visiting seismic testing facilities for relay qualification and; developing pre and post installation instructions including test procedures.

He worked closely with teams consisting of maintenance, operations, and work MGMT during the development and implementation of these projects.

Besides the A-46 issue, Mr. Ram first developed and then was personally involved in the implementation of modification packages consisting of Cable, Conduit, Circuit Breaker and motor starter (contactor) replacements.

The following provides a list of USI A-46 resolution projects: Northeast Utilities

-Millstone Station Consumers Power Co. -Palisades Nuclear Station Boston Edison Co. -Pilgrim Nuclear Power Station Commonwealth Edison Company- Dresden Station, Quad Cities Station Tribhawan Ram Page 2 SA A-17 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 STEVENSON

& ASSOCIATES 4350 DiPaolo Center, Suite H, Glenview, IL 60025 Tel: 847.795.0500 Fax: 847.795.0501 Bruce M. Lory blory@vecsa.com EDUCATION AND PROFESSIONAL AFFILIATIONS

• B.S., Mechanical Engineering, State University of New York at Buffalo, Buffalo, NY -1982* Exelon-certified instructor

-1992* ASME Training certification

-"Design and Repair of ASME Section I, IV, and VIII, Division 1 Pressure Vessels" -2000 o Instructor of EPRI "Fundamentals of Equipment Seismic Qualification" course* Member of 2003-11 IEEE Subcommittee-2 on Equipment Qualification

• Member of 2003-11 IEEE 323 Working Group (Environmental Qualification)

• Member of 2003-11 IEEE 344 Working Group (Seismic Qualification)

QUALIFICATIONS Degreed Mechanical Engineer with over 30 years experience in the nuclear industry, with specific technical expertise in the field of overseeing equipment modifications for Extended Power Uprates (EPU), as well as Seismic Qualification (SQ) and Environmental Qualification (EQ) of equipment/components.

Also possesses technical proficiency in design verification and project management for installation of single failure-proof cranes.PROFESSIONAL EXPERIENCE

-EPU PROJECTS Provided staff augmentation services as utility responsible engineer, overseeing engineering activities necessary for developing engineering modifications packages for various EPU projects, including:

• Generator rewinds (LaSalle, Clinton, & Dresden), and associated GE support system modifications (SLMS package, flux probe, generator temperature monitoring, rotor torsional vibration monitoring system)" HP Turbine replacement with new ADSP advanced GE turbine design* RWCU pump replacements

• Reactor Feed Pump, Recirc Valve, and FW Reg. Valve replacements

• Stator Cooling system improvements (heat exchangers, filters, strainer)* Replacement of entire IA system with 3 independent system trains in new building.Activities included interface with Project Manager, Field Engineer; Work Planning, Construction, and Work Week Manager, as modification packages were developed, followed by implementation.

Worked within INDUS PassPort program for populating ADL, AEL, loading engineering deliverables in PassPort, ECN processing.

Performed owner's review of design descriptions, calculations, construction drawings.

etc. Reviewed FAT test plans, as well as witnessed FAT activities at OEM locations, assisted supply chain oversight of OEM milestones and auditing OEM facilities and generating nonconformances.

Provided technical interface with OEM as designs developed from mechanical

& structural engineering perspectives.

Reviewed resulting work order tasks in PassPort to get WO tasks to approved status. Produced CCNs in accordance with station procedures during installation phase to develop quick solution to engineering issues.A-18 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Bruce M. Lory PROFESSIONAL EXPERIENCE

-SEISMIC QUALIFICATION Over 18 years of experience in Seismic Qualification of equipment and components, including seismic stress analyses, equipment foundation load analyses, equipment nozzle secondary stress analyses, and selection of vendors for replacement of seismically qualified Class 1 E components.

Well versed in requirements of IEEE 344-1975 for seismic qualification of Class 1 E components, and use of SQUG methodology for demonstrating seismic adequacy of equipment.

Excellent verbal/writing skills in field of SQ and EQ testing/analyses; responds well to organizational challenges, and relationship building.

Member/Chairperson of numerous EPRI EQ and SQ technical committees (see below). Proficient in PC software applications:

Microsoft Word, Excel, MS Projects and PowerPoint as well as INDUS PassPort database.Special expertise in preparation of SQ test plans, and witnessing of SQ tests; having witnessed over 100 seismic tests for numerous utilities.

Excellent knowledge of seismic and environmental testing facilities, including Wyle (Norco and Huntsville), NLI, Southern Testing Services, Nutherm, NTS Acton, EGS, and Qualtech.Served as CoinEd (now Exelon) corporate subject matter expert in SQ, providing SQ guidance and policy for all five ComEd generating stations, including on-site SQ engineers.

Developed.and implemented ComEd ownership of SQ program by authoring corporate procedure and SQ review checklists in 1993. Also created existing ComEd SQ standards used at all sites.Also served as subject matter expert for ComEd Corporate Engineering, providing technical guidance to Dresden, Quad Cities, and Zion sites required to complete the SQUG project. EPRI SQUG-certified Seismic Capability Engineer, and participated in all SQUG walkdowns at the three CoinEd SQUG sites. Served on EPRI G-STERI, and SQURTS committees, as ComEd employee.Specific SQ experience and special SQ projects includes:* Designed temporary fix to broken auxiliary switch mounting on Merlin Gerin 4KV circuit breakers in support of restarting Dresden 2 & 3 and Quad Cities 1 & 2 after extended shutdown to investigate issue. Coordinated and witnessed expedited seismic testing of temporary design fix that resulted in NRC approval to restart affected units. Received "Engaging in Excellence" award from ComEd for solving problem (1997)." Member of EPRI SQUG mock-NRC audit team which performed 1 week inspection of TMI SQUG program at TMI in preparation for formal NRC SQUG inspection (1998)." Expedited SQ test procedure preparation and witnessed SQ testing and HELB (EQ) testing of Magnetrol level switch needed to replace Dresden HPCI Glo-SLO obsolete level switch, allowing Dresden to exit 14 day LCO (1999)." Coordinated response to NRC resident inspector inquiry at Byron regarding SQ status of a racked out Westinghouse 4KV circuit breaker, reviewed third party calculation justifying the configuration as seismically qualified, interfaced with Resident Inspector at Byron, and consulted industry on the issue (2000)." Chairman of 1 day EPRI technical workshop on issue of "racked out" circuit breakers, attended by over 30 utilities and contractors, EPRI NDE Center -Charlotte, NC (1997) ," Coordinated with Quad Cities SQ engineer the response to NRC concern regarding potential contact of 125VDC batteries against hard spot on associated battery racks under seismic loading. Solution involved SQ testing of non-conforming condition, SQ test procedure reviewed and SQ test witnessed as well (1998).* Member of the special root cause investigative team formed in response to NRC audit concern on seismic qualification status of commercial grade-dedicated protective relays on Quad Cities EDGs (1999).Page 2 of 4 A-19 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Bruce M. Lory PROFESSIONAL EXPERIENCE

-ENVIRONMENTAL QUALIFICATION Possess over 15 years of EQ experience, in consulting services and in utility positions.

Prepared and reviewed over 100 EQ Binders to meet requirements station-specific EQ licensing basis requirement.).

Knowledgeable in EQ requirements for satisfying the different levels of EQ licensing basis, (10CFR50.49, NUREG 0588 -Category I and II, or DOR Guideline).

Prepared, reviewed over 20 EQ test procedures, and witnessed numerous EQ tests as part of licensee's initial EQ program origination or EQ component replacement objectives.

Well versed in EQ requirements contained in IEEE Standards 323, 382, 282, 317, and 649. Understands differentiation between Arrhenius and Regression Line analysis methodologies for calculating thermal qualified life.Have performed many FMEAs (Failure Mode Effects Analysis) on EQ components down to part level to determine applicable failure mode and appropriate corresponding activation energy/regression line slope and intercept for calculating thermal qualified life of a given material.Have used Digital Engineering and Wyle Materials databases to assist FMEAs in selection of most applicable Arrhenius material properties for failure mode/part use.Member of Corporate EQ group at Commonwealth Edison (ComEd) Downers Grove, IL overseeing EQ program compliance of all 6 nuclear stations (1991-1995).

Served as backup EQ Engineer for ComEd Corporate Engineering office (1998-2000).

Specific EQ experience and special EQ projects includes: " Prepared or reviewed over 100 EQ binders over entire six site ComEd EQ program (1983-1993)" Project Engineer overseeing staff of 5 EQ engineers prepare 88 EQ binders for Fort St.,Vrain EQ program creation from scratch. Numerous technical challenges due to high temperature MSLB profile, necessitating thermal lag analyses and design of thermal, protection modifications.

Included lead role of defending EQ program in mock-NRC audit followed by successful NRC audit.* Assisted in EQ impact evaluation for high drywell temperature excursion that occurred at ComEd Dresden Nuclear Station, assessing EQ life consequences on Class 1 E components (1988).* Assisted in preparation of EQ test procedure and witnessed EQ HELB testing of non-conforming Raychem NMCK and WCSF-N electrical splices for ComEd LaSalle County Nuclear Station in support of JCO (1986)" Member of EQ inspection team performing mock-NRC audit of Quad Cities EQ program with respect to compliance to R.G. 1.97, including EQ walkdown discovery of Class 1E terminal blocks epoxy glued to junction boxes involving R.G. 1.97 instrumentation circuitry (1991).* Member of EQ assessment team performing technical review of Consumers Energy -Palisades EQ program for compliance to DOR Guidelines and R.G. 1.97 (1990)." Performed special EQ impact assessment of potentially non-EQ components installed in Class 1 E 480VAC MCCs at ComEd Braidwood Nuclear Station, reviewed over 150 NWRs for Stores Item # used for installation." Lead 5 EQ engineers on independent EQ assessment of ComEd LaSalle County Nuclear Station EQ program re-baseline initiative to determine remaining weaknesses in EQ program and identify corrective actions needed in EQ analyses and component replacements (1997)Page 3 of 4 A-20 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Bruce M. Lory PROFESSIONAL EXPERIENCE

-SINGLE FAILURE-PROOF CRANE DESIGN VERIFICATION Performed utility owner's (CMS Energy -Big Rock Restoration Project) design review of all crane manufacturer's design stress analyses for use of single failure-proof Containment Building Crane for dry cask activities.

Activities included assisting project manager in resolving design issues which arose during seismic qualification analyses by crane vendor, resolving crane manufacturer (Ederer)NCRs, and establishing protocol for identification of critical characteristics for commercial grade dedication of crane for safety related use. Crane expertise includes owner's review of manufacturer's design stress calculations for all operating load conditions per CMAA Spec. #70, and compliance with NUREG 0554.Project highlights included: " Visited crane manufacturer facility (Ederer) and vendor facility (Bigee) numerous times to resolve owner review comments on design stress calculations, attend project status meetings, and work with crane/vendor engineering staff towards final design resolutions.

• Reviewed over 30 design stress calculations for Ederer "X-SAM" single failure-proof crane trolley and hoist, including vendor bridge, column, and end truck design. Review resulted in three design changes to crane in order to comply with CMAA Spec. #70 and NUREG 0554 design margin requirements.

• Attended NRC meeting at NRR headquarters (Washington D.C.) with client to answer NRC and independent review team technical review questions on crane design and Ederer topical report." Assisted utility project manager in related engineering activities of commercial grade dedication, QA program establishment, and seismic qualification interface with Bigee Rigging.EMPLOYMENT HISTORY Stevenson

& Associates

-2008 to present EMS Inc. -2000 -2007 Commonwealth Edison, 1991-2000 ABB Impell, 1989 -1991 Sargent & Lundy Engineers, 1979- 1989 SPECIAL ACHIEVEMENTS

& AFFILIATIONS

• Presented ComEd C-Team facility design for LOCA test chamber system to NUGEQ -1991* Inaugural Technical Program Chairman of EPRI -SQURTS program, 1993-95* Member of EPRI -G-STERI program, 1995-98* "Engaging in Excellence" award from ComEd for designing and seismically qualifying emergency fix to broken auxiliary switch mounting on Merlin-Gerin 4KV circuit breakers -1997* "Certificate of Appreciation", ASME PVP Division for being Technical Program Representative of the OAC Committee for the 2000 ASME PVP Division International Conference

-2000* Instructor of EPRI "Fundamentals of Equipment Seismic Qualification" training course -2011 Page 4 of 4 A-21 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Walter Djordjevic EDUCATION:

B.S. -Civil Engineering, University of Wisconsin at Madison, 1974 M.S. -Structural Engineering, Massachusetts Institute of Technology, 1976 PROFESSIONAL REGISTRATION:

State of California, State of Wisconsin, Commonwealth of Massachusetts, State of Michigan, State of Arizona, State of Missouri PROFESSIONAL HISTORY: Stevenson

& Associates, Inc., President 1996 -present; Vice President and General Manager of the Boston area office, 1983 -1995 URS/John A. Blume & Associates, Engineers, Boston, Massachusetts, General Manager, 1980 -1983;San Francisco, California, Supervisory Engineer, 1979 -1980 Impell Corporation, San Francisco, California, Senior Engineer, 1976 -1979 Stone & Webster Engineering Corporation, Boston, Massachusetts, Engineer, 1974 -1976 PROFESSIONAL EXPERIENCE: " Structural Engineering

• Structural Dynamics* Seismic Engineering

• Construction

• Vibration Engineering" Expert Witness" Committee Chairman Mr. Djordjevic founded the Stevenson

& Associates Boston area office in 1983 and serves as President and General Manager. Mr. Djordjevic is expert in the field of structural engineering

-more specifically, in the areas of structural vulnerabilities to the effects of seismic and other extreme loading phenomena.

As a structural dynamicist, Mr. Djordjevic also heads the Vibration Engineering Consultants corporate subsidiary of Stevenson

& Associates for which he has overseen numerous designs of vibration sensitive microelectronics facilities for such clients as IBM, Intel, Motorola and Toshiba. He has personally been involved in such projects as resolving vibration problems due to construction activities for the Central Artery Project (Big Dig) in Boston for which he was retained by Massport.

Finally, Mr.Djordjevic has been personally retained as an Expert Witness a number of times relating to cases involving construction, structural and mechanical issues.He has performed over a thousand hours of onsite seismic and other natural phenomena (including tornados, hurricanes, fire, and flooding) inspection walkdowns to assess structural soundness and vulnerabilities.

He has inspected microelectronics fabrication facilities, power facilities, and hazardous material government and military reservations.

He is one of the most experienced seismic walkdown af A-22 12Q0108.30-R-0O1, Rev. 1 Correspondence No.: RS-12-167 inspection screening and verification engineers having personally participated in seismic walkdowns at over 50 U.S. nuclear units.In recent years, he has concentrated on screening inspection walkdowns and assessments for resolution ofthe USI A-46 and seismic IPEEE issues, on numerous facilities.

The following provides a partial list of recent projects: American Electric Power -D.C. Cook Station Boston Edison Co. -Pilgrim Nuclear Power Station (SPRA)Commonwealth Edison Company- Braidwood Station" M , Byron Stationp M , Dresden Stationp M , Quad Cities StationPM Consumers Power Co. -Palisades Nuclear StationPM Entergy -Arkansas Nuclear One Florida Power & Light -Turkey Point Station New York Power Authority

-James A. Fitzpatrick Nuclear Power Plant Niagara Mohawk Power Corporation

-Nine Mile Point Station PM Northern States Power Co. -Monticello Nuclear Generating Plant Northern States Power Co. -Prairie Island Nuclear Generating Plant Omaha Public Power District -Fort Calhoun Station (SPRA)Public Service Electric & Gas -Salem Nuclear Station Rochester Gas & Electric -R.E. Ginna Station Wisconsin Electric -Point Beach Nuclear StationPM (SPRA)Wisconsin Public Service -Kewaunee Nuclear Power PlantPM (SPRA)PM Indicates projects where Mr. Djordjevic served as Project Manager Hanford Reservation Savannah River Plant Reservation Rocky Flats Reservation Tooele US Army Depot Anniston US Army Reservation Umatilla US Army Reservation Newport US Army Reservation Aberdeen US Army Reservation He is a member of the IEEE 344 Standards Committee, Chairman of the ASCE Working Group for Seismic Evaluation of Electrical Raceways, and Chairman of the IES Committee for Microelectronics Cleanroom Vibrations Representative projects include overseeing the SEP shake-table testing of electrical raceways, in-situ testing of control panels and instrumentation racks at various nuclear facilities, equipment anchorage walkdowns and evaluations at various nuclear facilities.

He is the principal author of the CERTIVALVE software package to evaluate nuclear service valves, and contributing author in the development of the ANCHOR and EDASP software packages commercially distributed by S&A.Mr. Djordjevic is expert in the area of seismic fragility analysis and dynamic qualification of electrical and mechanical equipment.

He has participated in and managed over twenty major projects involving the evaluation and qualification of vibration sensitive equipment and seismic hardening of equipment.

As demonstrated by his committee work and publications, Mr. Djordjevic has participated in and contributed steadily to the development of equipment qualification and vibration hardening methodology.

Walter Djordjevic Page 2 A-23 12oo108.30-R-O01, Rev. I Correspondence No.: RS-12-167 PROFESSIONAL GROUPS Member, Institute of Electrical and Electronics Engineers, Nuclear Power Engineering Committee Working Group SC 2.5 (IEEE-344)

Chairman, American Society of Civil Engineers Nuclear Structures and Materials Committee, Working Group for the Analysis and Design of Electrical Cable Support Systems Member, American Society of Mechanical Engineers Operation, Application, and Components Committee on Valves, Working Group SC-5 Chairman.

Institute of Environmental Sciences, Working Group foe Standardization of Reporting and Measuring Cleanroom Vibrations PARTIAL LIST OF PUBLICATIONS 1979 ASME PVP Conference, San Francisco, California, "Multi-Degree-of-Freedom Analysis of Power Actuated Valves", Paper No. 79-PVP-106.

1983 ASME PVP Conference, Portland, Oregon, "A Computer Code for Seismic Qualification of Nuclear Service Valves", Paper No. 83-PVP-81.

1983 ASME PVP Conference, Portland, Oregon, "Qualification of Electrical and Mechanical Equipment at Rocky Flats Reservation Using Prototype Analysis".

1984 ANS Conference, "Qualification of Class 1E Devices Using In-Situ Testing and Analysis." 1986 Testing of Lithography Components for Vibration Sensitivity, Microelectronics, Cahners Publishing 1990 Nuclear Power Plant Piping and Equipment Conference, "Development of Generic Amplification Factors for Benchboard and Relay Cabinet Assemblies", Paper No. 106, Structures and Components Symposium, held by North Carolina State University 1991 Electric Power Research Institute, "Development of In-Cabinet Response Spectra for Benchboards and Vertical Panels," EPRI Report NP-7146 Walter Djordjevic Page 3 A-24 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167 Certificate of Completion Walter Djordjevic Siuccessfull Completed Training on Near Term Task Force Recommendation 2.3 -Plant Seismic Walkdowns A /., lee tllneow)Date: 06/26/12 Bruce M. Lor(- Instructor NTTF 2.3 Seismic Walkdown Course A-25 12Q0108.30-R-001, Rev. 1 Correspondence No.: RS-12-167~ Exelon Generation, BRYAN Y WEIGHT EDUCATION BRIGHAM YOUNG UNIVERSITY Bachelor of Science, Civil Engineering (structural emphasis)EXPERIENCE EXELON CORPORATION, Morris, IL: Currently 5 years Dresden Generation Station (DGS -nuclear power)Engineering Design / Proiects / Staff Engineer" Performed owners acceptance reviews of civil and structural engineering vendor supplied products for DGS* Completed various plant modifications

-Project Engineer* Specialty projects:

Heavy loads per NUREG 0612, Post-Fukushima Earthquake Task Force, NRC audits, etc PT&C FORENSIC CONSULTING SERVICES, P.A., Chicago, IL: 1.5 years Engineering Manager / Senior Forensic Engineer* Marketing

-established new accounts with Insurance Companies* Executed inspections and managed consulting services related to insurance claims and associated reports, invoices, client interface* Managed personnel and work assignments in the Midwest region BW INSPECTION ENGINEERS, INC., Wilsonville, OR: 18 years EIFS & STUCCO CONSULTANTS, INC., Wilsonville, OR: Concurrent President

& Owner" Managed consulting services in Oregon & Washington

• Experienced in forensic engineering, construction defect litigation, cause &origin insurance claims, engineering design, construction management, and surveyed the physical condition of residential and commercial properties

• Marketing NORTHWEST INSPECTION ENGINEERS, INC., Renton, WA: 1.5 years Inspection Engineer* Performed inspections, forensics, engineering, expert witness, and construction management services A-26 12Q.108.30-R-OO1, Rev. I Correspondence No.: RS-12-167 Bryan Y Weight Page 2 of 2 BECHTEL POWER & BECHTEL CONSTRUCTION CORPORATIONS:

10 years Assistant Project Administrator

-- San Onofre Nuclear Generation Stations 2 & 3* Responsible for construction work procedures, quality control, and documentation during refueling operations in accordance with NRC code of Federal Regulations 10CFR50; managed various personnel groups Construction Management

-- Intermountain Power Project, Delta, UT-Managed multi-million dollar contracts in the civil and mechanical disciplines

-Authorized progress payments, change orders, settled claims, contractor audits-Completed quality control (QC) inspections, specification compliance

& reports-ANSI inspector:

concrete, steel, soils, pipe & mechanical equipment Construction Engineer -- Springerville Arizona Generating Station-Worked as field liaison, provided technical guidance, recommended design changes, was advisor to construction Design Engineer -- Los Angeles Power Division, Norwalk, CA* Involved in the design of concrete; steel; supports for instrumentation, HVAC, pipe and electrical cable tray systems of various nuclear and fossil fuel projects including:

Korea Nuclear Generation Stations 5 & 6; Palo Verde Nuclear Generation Station 2 & 3; San Onofre Nuclear Generation Station 2 & 3;Springerville Arizona Generating Station PROFESSIONAL LICENSES: Professional Engineer:

CA 33679 Professional Engineer:

IL 62059873 Professional Structural Engineer:

UT 170291-2203 Lapsed P.E. licenses:

IA, MI, MN, OR, WA OTHER PROFESSIONAL QUALIFICATIONS I TRAINING BWR Plant Systems Engineering Configuration Change Responsible Engineer (Plant Modifications) 10 Code of Federal Regulations (CRF) 50.59 BWR Screener EPRI Near Term Task Force Recommendation 2.3 -Plant Seismic Walkdowns SQUG Walkdown Screening and Seismic Evaluation Training Site Materials Expert (SME) for movement of Heavy Loads Certified Building Moisture Analyst Certified Infrared Thermographer A-27 12Q0108.30-R-001, Rev. 1 Cnrff ,nnn,4,n,, hin- R ..-1 R7ELECTRIC POWER RESEARCH INSTITUTE Certificate of Completion Bryan Weight i raining on Near ierm IaSK r(orce Recommendation 2.3-Plant Seismic Walkdowns June 27, 2012 iO. 4,, Date Robert K. Kassawara EPRI Manager, Structural Reliability

& Integrity i A-ZtJ U I SQUG L Presents this Certfica te of chi'evement To Certify Ihat has Compfetedthe andSeismic E'SQ'UG vafuati(feldA ugust 44&.a Richard G. Starck ", MPR Associates, Inc.SQUG Instructor Pa on