Text

Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident
	ML15090A259
Person / Time
Site:	Limerick
Issue date:	03/31/2015
From:	Jim Barstow; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-15-038
	Download: ML15090A259 (110)
	v • d • e

10 CFR 50.54(f)

RS-15-038 March 31, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Limerick Generating Station, Unit 2 Renewed Facility Operating License No. NPF-85 NRC Docket No. 50-353

Subject:

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

References:

1. Exelon Generation Company, LLC 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 19, 2012 (RS-12-171)

2. NRC Letter, Request for Information Pursuant to Title 1O of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 In Reference 1, Exelon Generation Company, LLC (EGC) provided the Limerick Generating Station, Units 1 and 2 seismic walkdown reports in accordance with the NRC Request for Information (Reference 2). The Limerick Generating Station, Units 1 and 2 seismic walkdown reports verify current plant configuration with current licensing basis and verify the adequacies of monitoring and maintenance procedures. In Tables E-2 and E-3 of Enclosure 1 of Reference 1, EGC provided the list of the three (3) Limerick Generating Station, Unit 2 electrical items that required supplemental inspections. EGC committed to complete the walkdown inspections of these three (3) items by December 31, 2014. These inspections have been completed.

The enclosure to this letter provides the updated Limerick Generating Station, Unit 2 Seismic Walkdown Report incorporating the results of the completed walkdowns of the three (3) Limerick Generating Station, Unit 2 electrical items identified in Tables E-2 and E-3 of Enclosure 1 of Reference 1. The results of these walkdown inspections are addressed in Annex B of the enclosed report.

No additional degraded, nonconforming, or unanalyzed conditions that required either immediate or follow up actions were identified.

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Seismic March 31, 2015 Page 2 This report completes Regulatory Commitment No. 4 contained in Enclosure 3 of Reference 1.

This letter contains no new regulatory commitments.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st day of March 2015.

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Seismic Walkdown Report In Response To The 50.54(f) Information Request Regarding Fukushima Near-Term Task Force Recommendation 2.3: Seismic, Updated Transmittal # 2 (Annex B) for the Limerick Generating Station Unit 2, Correspondence No. RS-15-038 cc: Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I NRC Senior Resident Inspector - Limerick Generating Station NRC Project Manager, NRA - Limerick Generating Station Mr. Nicholas J. DiFrancesco, NRR/JLD/JHMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

U.S. Nuclear Regulatory Commission Supplemental Response to 50.54(f) Letter NTTF Recommendation 2.3: Seismic March 31, 2015 ENCLOSURE Seismic Walkdown Report In Response To The 50.54(f) Information Request Regarding Fukushima Near-Term Task Force Recommendation 2.3: Seismic, Updated Transmittal # 2 (Annex B) for the Limerick Generating Station Unit 2, Correspondence No. RS-15-038 (107 Pages)

SEISMIC WALKDOWN REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.3: SEISMIC UPDATED TRANSMITTAL# 2 (ANNEX 8) for the LIMERICK GENERATING STATION UNIT 2 3146 Sanatoga Road, Pottstown, PA 19464 Renewed Faclllty Operating License No. NPF-85 NRC Docket No. STN 50-353 Correspondence No.: RS-15-038 xelo Prepared by:

Exelon Generation Company, LLC (Exelon)

PO Box 805398 Chicago, IL 60680-5398 Printed Name Sianature .Qmt Preparer: Robe(~~:~rman "£__ ~q/-- 3 / JJ) ~

Reviewer: JoeDulllnger (Annex B} ~~ D ~ 3 /,~/,s Approver: Gregory A Wsllace 1Y*1 (Annex B) '3 lq \')° Pt/-

.:> 1111 Peer Review Team Leader: Robert B. Wehrma ? ~

(Annex 8)

Lead Responsible Engineer:

Branch Manager:

Senior Manager Design Engineering:

Corporate Acceptance:

SEISMIC WALKDOWN REPORT IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.3: SEISMIC UPDATED TRANSMITTAL# 1 for the LIMERICK GENERATING STATION UNIT 2 3146 Sanatoga Road, Pottstown, PA 19464 Facility Operating License No. NPF-85 NRC Docket No. STN 50-353 Corres dence No.: RS-13-138 Prepared by:

Exelon Generation Company, LLC (Exelon)

PO Box 805398 Chicago, IL 60680-5398 Printed Name Signature Date Joseph P. Dullinger Preparer:

(Annex A) -g/21/i.or?;,

Robert B. Wehrman Reviewer:

{Annex A} '113/JoJ) 0rl~7-fe715 Gregory A. Wallace Approver:

{Annex A}

f ,

Jagdish Narula Peer Review Team Leader:

(Annex A} '3 Jst2"f3

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Lead Responsible Engineer: Robert 8. Wehrman Branch Manager: Gregory A. Wallace 15 Senior Manager Wayne R. Lewis Design Engineering: CJJi/ZP13 Corporate Acceptance: Jeffrey S. Clark

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SEISMIC WALKDOWN REPORT IN RESPONSE TO THE 50.64(f) INFORMATION REQUEST REGARDING FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATION 2.3: SEISMIC for the LIMERICK GENERATING STATION UNIT 2 3146 Sanatoga Road, Pottstown, PA 19464 Facility Operating License No. NPF-85 NRC Docket No. STN 50-353 Correspondence No.: RS-12-171 Exelon Exelon Generation Company, LLC (Exelon)

PO Box 809398 Chicago, IL 60680-5398 Prepared by:

MPR Associates, Inc.

320 King Street, Alexandria, VA 22314 Report Number: MPR-3801, Revision 1 Printgg Name Sjgnature Date Caroline Preparer:

Schlaseman -*~~~ 11/612012 Reviewer:

Mojtaba Oghbaei H.~ 11/612012 Approver:

John Simons ~w.~ 11/612012 Peer Review Team Leader: Patrick Butler 17#DuJ/t'- 11/6/2012 Lead Responsible Engineer: Brian Wehrman ?2-°'-.J_J___

£ Branch Manager:

Greg Wallace Senior Manager Design Engineering: Wayne Lewis -

Corporate Acceptance: Jeffrey Clark 4'tt.:?J. ru 11/sft'L

Limerick Generating Station Unit 2 Correspondence No .. RS-15-038

~MPR ASSOCIATES INC.

N IN f- II NTTF 2.3 Seismic Walkdown of Limerick Generating Station Unit 2 MPR-3801 Revision 1 November 2012 QUALITY ASSURANCE DOCUMENT This document has been prepared, reviewed, and approved in accordance with the Quality Assurance requirements of 10CFR50 Appendix Band/or ASME NQA-1, as specified in the MPR Nuclear Quality Assurance Program.

Prepared by: ~,,d'~

Caroline S. Schlaseman Reviewed by: H °!"'~

Mojtaba ghbaei Approved by: ~ !Ah~

Jo n W. Simons Peer Review ~ -12..u.Jl.t Tearn Leader: iJ \.,

Patrick J. Butler Principal Contributors Mojtaba Oghbaei Craig B. Swanner James N. Wiggin Thomas C. King Prepared for Exelon Generation Company, LLC 320 KING STREET ALEXANDRIA, VA 22314-3230 703-519-0200 FAX: 703-519-0224 http:\\www.rnpr.com

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 RECORD OF REVISIONS Revision Affected Pages Description 0 All Initial Issue 1 All Added IR numbers and milestone dates to Table E-2 for three items; updated Executive Summary for this change.

Some potentially sensitive information in selected Appendix C photos was removed due to security concerns.

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Contents Tables .......................................................................................................................................... iii Executive Summary ................................................................................................................... iv 1 lntroduction ..................................................................................................................... 1-1 1.1 Background ............................................................................................................. 1-1 1.2 Plant Overview ........................................................................................................ 1-1 1.3 Approach ................................................................................................................. 1-1 2 Seismic Licensing Basis ................................................................................................ 2-1 2.1 Safe Shutdown Earthquake (SSE) .......................................................................... 2-1 2.2 Design of Seismic Category I SSCs ........................................................................ 2-1 3 Personnel Qualifications ............................................................................................... 3-1 4 Selection of SSCs ........................................................................................................... 4-1 4.1 SWEL Development Overview ................................................................................ 4-1 4.2 SWEL 1 - Sample of Required Items for the Five Safety Functions ....................... 4-1 4.3 SWEL 2 - Spent Fuel Pool Related Items .............................................................. 4-5 4.4 Composite SWEL .................................................................................................... 4-7 5 Seismic Walkdowns and Area Walk-Bys ...................................................................... 5-1 5.1 Overview ................................................................................................................. 5-1 5.2 Seismic Walkdowns ................................................................................................ 5-1 5.3 Area Walk-Bys ........................................................................................................ 5-2 6 Licensing Basis Evaluations ......................................................................................... 6-1 7 IPEEE Vulnerabilities Resolution Report ..................................................................... 7-1 8 Peer Review .................................................................................................................... 8-1 8.1 Overview ................................................................................................................. 8-1 8.2 Review of SWEL ..................................................................................................... 8-1 8.3 Review of Sample Seismic Walkdown and Area Walk-By Checklists ..................... 8-1 8.4 Review of Licensing Basis Evaluations ................................................................... 8-2 8.5 Review of Submittal Report. .................................................................................... 8-2

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Contents (cont'd.)

9 References ...................................................................................................................... 9-1 Appendices A Project Personnel Resumes and SWE Certificates .................................... Not Included B Equipment Lists ............................................................................................. Not Included C Seismic Walkdown Checklists (SWCs) ....................................................... Not Included D Area Walk-By Checklists (AWCs) ................................................................ Not Included E Plan for Walkdown of Inaccessible Equipment and Assessment of Electrical Cabinet Internal Inspections ........................................................................ Not Included F Peer Review Report ....................................................................................... Not Included ii

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Tables Table 3-1. Personnel Roles ....................................................................................................... 3-1 Table 4-1. Base List IPEEE Classes vs. EPRI Seismic Walkdown Guidance Equipment Classes ................................................................................................................... 4-4 Table 5-1. Anchorage Configuration Confirmation ..................................................................... 5-2 Table 5-2. Issues Identified during Seismic Walkdowns ............................................................ 5-2 Table 5-3. Issues Identified during Area Walk-Bys .................................................................... 5-3 Table 7-1. IPEEE Resolutions for Items with HCLPFs Below Review Level Earthquake .......... 7-2 Table B-1. SWEL for Unit 2 ......................................................................................... Not Included Table B-2. SWEL for Unit 0 (common) ....................................................................... Not Included Table B-3. Deferred to RFO: Inaccessible, or Requires Removal of Insulation to see Anchorage ................................................................................................ Not Included Table C-1. Unit 2 Seismic Walkdown Checklists (SWCs) ........................................... Not Included Table C-2. Unit 0 Seismic Walkdown Checklists (SWCs) ........................................... Not Included Table D-1. Unit 2 Area Walk-By Checklists (AWCs) ................................................... Not Included Table D-2. Unit O Area Walk-By Checklists (AWCs) ................................................... Not Included Table E-1. Summary of Inaccessible Equipment.. ...................................................... Not Included Table E-2. Assessment of Unit 2 Electrical Cabinet Internal Inspections ................... Not Included Table E-3. Assessment of Unit O Electrical Cabinet Internal Inspections ................... Not Included List of Annexes Annex A. Updated Transmittal #1 .. ......................................................................... .Ai Annex B. Updated Transmittal #2 (Annex 8) ........ ............................. ........................ Bi iii

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Executive Summary PURPOSE This report documents the seismic walkdowns performed at Limerick Generating Station Unit 2 in response to NRG 50.54(f) letter dated March 12, 2012, Enclosure 3, Recommendation 2.3: Seismic. Exelon committed to perform this work in accordance with the NRG-endorsed Seismic Walkdown Guidance document (Electric Power Research Institute (EPRI) Technical Report 1025286, Reference 1).

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

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

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

Seismic Licensing Basis Evaluations are performed for issues identified as "potentially adverse seismic conditions," and all deficiencies are included in the Corrective Action Program (CAP) so that standard plant processes can be used to address the issue. (see Section 6 of this report)

IPEEE Vulnerabilities Resolution Report is required for plants who identified seismic vulnerabilities during their IPEEE program and made commitments to resolve them. (see Section 7 of this report)

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

RESULTS The Seismic Walkdown Equipment List (SWEL) for Limerick Unit 2, including the items selected that are common to both Units 1 and 2, e.g., spray pond equipment, is comprised of 113 items. Of this list, 102 equipment items were walked down during the 180-day window of completion of the initial scope of work required by the 50.54(f) letter.

Walkdowns for the remaining 11 items were deferred to the Unit 2 Refueling Outage iv

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 (RFO) due to accessibility issues, e.g., location inside primary containment. Additionally, confirmation that equipment anchorage is consistent with plant design documentation is required for 50% of the SWEL items having anchorage (e.g., not line-mounted). A total of 55 anchorage configurations were confirmed to be installed in accordance with the design documentation.

All electrical cabinets on the SWEL require assessment of the need for inspections to address the potential for "other adverse seismic conditions" internal to the cabinet. This assessment is required due to an NRC clarification of their expectations for seismic walkdowns, which was received after the online seismic walkdowns were completed. Tables E-2 (for Unit 2) and E-3 (for common equipment) list all electrical items that require assessment. As shown in Tables E-2 and E-3, three internal inspections of electrical cabinets are required for Limerick Unit 2, which are being tracked in the plant's Corrective Action Program (CAP).

None of the issues identified during the walkdowns of Limerick Unit 2 equipment and nearby areas required formal seismic licensing basis evaluations because none of the issues ultimately were assessed to be adverse seismic conditions. Smaller issues, however, such as one of twenty-two anchor bolts in a control cabinet had a loose nut, were identified and entered into the plant's CAP. A total of 5 Issue Reports (IRs) were issued, and the status of IR resolutions is provided in Tables 5-2 and 5-3 for issues identified during equipment walkdowns and area walk-bys, respectively.

As described in Section 7 of this report, no IPEEE seismic vulnerabilities were identified for Limerick Unit 2 due to the conservatism of its original design. As part of the assessment of seismic margins during the IPEEE program, one of the RAI responses identified some items that did not meet the Review Level Earthquake (RLE) screening criteria (which is twice the design basis safe shutdown earthquake) and the subsequent analyses which resolved these margin evaluations are included in Table 7-1.

CONCLUSIONS

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

Eleven (11) inaccessible equipment items are scheduled to be walked down during the next Unit 2 RFO in 2013.

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

2. None of the 102 equipment items included in the walkdowns have conditions that would prevent them from performing their safety-related functions following a licensing basis seismic event. Additionally, a sample of more than 50% of equipment with anchorage was confirmed to be consistent with design basis documentation.

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038

3. The five (5) anomalies or discrepant conditions identified during the equipment walkdowns or area walk-bys have been assessed in accordance with the plant corrective action program (CAP), and their resolutions are being tracked for timely closure.

4. To address the items deferred due to inaccessibility and the supplemental inspections of electrical cabinets, follow-on Seismic Walkdowns and Area Walk-Bys were conducted during Li2R12 (Spring 2013). A single potentially adverse seismic condition was identified during Area Walk-Bys, noted in Table A5-3, and was resolved during Li2R12. No additional degraded, nonconforming, or unanalyzed conditions that required either immediate or follow-on actions were identified.

Annex A to this report provides:

a) Additional information obtained from these follow-on inspections performed on the open items listed on Table E-1 and E-2.

b) Status updates on the conditions identified during the previous Walkdowns and Walk-Bys, listed on Table 5-2 and Table 5-3.

As of May 20, 2013, follow-on activities required to complete the efforts to address Enclosure 3 of the 50.54(f) letter include inspection of two items deferred due to inaccessibility, as listed on Table AE-2 of Annex A.

5. To address the items deferred due to the supplemental inspections of electrical cabinets, follow-on Supplemental Seismic Walkdowns were performed. No potentially adverse seismic conditions were identified during the follow-on Supplemental Seismic Walkdowns. No additional degraded, nonconforming, or unanalyzed conditions that required either immediate or follow-on actions were identified.

Annex B to this report provides:

a) Additional information obtained from these follow-on inspections performed on the open items listed on Table E-2(Ref. B1, Section B9).

As of December 31, 2014, follow-on activities required to complete the efforts to address Enclosure 4 of the 50.54(f) letter include inspection of three items deferred due to inaccessibility, as listed on Table E-2 (Ref. B1, Section B9). Completion of these walkdowns closes Commitment No. 4 of Reference B 1.

vi

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 1

Introduction

1.1 BACKGROUND

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

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

1.2 PLANT OVERVIEW The Limerick Generating Station (LGS) consists of two boiling water reactor (BWR) generating units, located in southeastern Pennsylvania. Both units have GE Mark II containments, are rated at 3515 MWt power, and were designed and constructed by Bechtel (LGS Updated Final Safety Analysis Report (UFSAR) (Reference 2), Section 1.1 ). Limerick Unit 2 received its full-power license in June 1989 (Facility Operating License No. NPF-85 (Reference 21 )).

1.3 APPROACH The EPRI Seismic Walkdown Guidance (Reference 1) is used for the Limerick 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 SSCs

Seismic Walkdowns and Area Walk-Bys

Licensing Basis Evaluations

IPEEE Vulnerabilities Resolution Report

Peer Review 1-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 2

Seismic Licensing Basis 2.1 SAFE SHUTDOWN EARTHQUAKE (SSE)

The LGS site design response spectra for the SSE are normalized to a maximum horizontal ground acceleration of 15% of gravity. The values for the vertical component of the design response spectra are 2/3 of the horizontal design response spectra. The response spectra are based on data developed from records of previous earthquake activity and represent an envelope of motion expected at a sound rock site from a nearby earthquake (Reference 2, Section 3.7.1.1).

2.2 DESIGN OF SEISMIC CATEGORY I SSCs Generic Letter 87-02 issued on February 19, 1987 and Supplement No. 1 issued May 22, 1992, do not list Limerick Unit 2 as an USI A-46 Plant because seismic qualification was addressed during initial operating licensing review (Reference 2, Section 1.12.3).

Seismic Category I mechanical and electrical equipment were originally qualified according to the criteria in IEEE 344-1971, but the qualification methods and procedures for qualification were re-assessed to Standard Review Plan (SRP) 3.10 Seismic Qualification Review Team (SQRT) requirements including IEEE 344-1975, and Reg.

Guides 1.100 and 1. 92. The SQRT reassessment concluded that the seismic and dynamic qualification program meets the intent of IEEE 344-1975 and Reg. Guides 1.100 and 1.92 (Reference 2, Sections 3.9.2.2 and 3.10.2.1 ).

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 3

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

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

T. King x x x x C. Swanner x x x<note 1)

M. Oghbaei x x J. Wiggin x x C. Schlaseman x P. Butler x<note 2)

B. Shultz x (Exelon)

Notes:

1. Peer Review Team member for SWEL review only.

2. Peer Review Team Leader.

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

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

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

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

In addition to the MPR personnel listed above, Exelon Plant Operations, Brandon Shultz, reviewed the SWEL. Mr. Shultz is currently a licensed Senior Reactor Operator (SRO) at Limerick Station. Station personnel also provided support to the SWEL preparer in 3-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 identifying major equipment or system modifications, equipment and systems located in different environments, and equipment and systems that would be accessible for inspection during the plant walkdowns, in accordance with Reference 1.

3-2

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 4

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

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

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

2. SWEL 2 is a list of spent fuel pool related items 4.2 SWEL 1 - SAMPLE OF REQUIRED ITEMS FOR THE FIVE SAFETY FUNCTIONS The Limerick Unit 2 Seismic Individual Plant Examination for External Events (IPEEE)

Success Path Component Lists (SPCL) (Reference 3) and the common equipment from the Limerick Unit 1 and Common Seismic IPEEE SPCL (Reference 4) are considered the "Base List" and are provided in Appendix B of this report. To ensure the SPCL Base List meets the EPRI Seismic Walkdown Guidance, the SPCL was compared with the screens described in the following sections.

4.2.1 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. The seismic classification was identified for each item on the IPEEE SPCL, and items that were not Seismic Category I were removed from consideration for inclusion in SWEL 1. Seismic classification was determined through a review of current design and licensing basis documentation.

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

4-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 4.2.3 Screen #3 - Support for the 5 Safety Functions This screen narrowed the scope of items included on the SWEL 1 to only those associated with maintaining the following five safety functions:

1. Reactor Reactivity Control

2. Reactor Coolant Pressure Control

3. Reactor Coolant Inventory Control

4. Decay Heat Removal

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

As described in References 3 and 4, the safety function for each item on the SPCL was identified. Items on SWEL 1 which perform a specific safety function(s) are considered frontline systems. Items with a safety function described in the SPCL as 'Auxiliary &

Support,' 'Electrical Systems,' or 'Racks & Panels' are considered either a frontline or support system.

4.2.4 Screen #4 - Sample Considerations The items selected from the Base List SPCL for inclusion in SWEL 1 are shown in Tables B-1 through B-3 of this report. As described in Reference 1, Screen #4 is intended to result in a SWEL 1 that sufficiently represents a broad population of plant Seismic Category I equipment and systems to meet the objectives of the NRC 50.54(f)

Letter. The following attributes were considered in selecting items from the SPCL for inclusion in SWEL 1:

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

Systems to Support Safety Function(s). Examples include Emergency Diesel Generators and related systems, Emergency Core Cooling systems (Residual Heat Removal, Reactor Core Isolation Cooling, Core Spray, High Pressure Coolant Injection), power systems (125 VDC, 120 VAC, 480 VAC), and Ultimate Heat Sink (Spray Pond). Note, however, that the Reference 1 Appendix E table of generic BWR safety function systems includes some systems that are not applicable for Limerick Unit 2 because the IPEEE SPCL was not required to include all potential shutdown paths, and some systems, e.g., Isolation Condenser, do not exist at Limerick.

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038

2. Major new and replacement equipment The equipment included on SWEL 1 includes some items that have been modified or replaced over the past several years. Each item on SWEL 1 that is new or replaced is identified. Due to the plant vintage, Limerick Unit 2 has not made significant modifications to Seismic Category I equipment. Accordingly, there is not a large number of new and replacement components.

3. A variety of types of equipment The equipment class is identified for each item on SWEL 1. The equipment included on SWEL 1 is a representative sample from each of the classes of IPEEE equipment used in the Base List, which are based on the equipment classes from EPRI NP-6041-SL "A Methodology for Assessment of Nuclear Power Plant Seismic Margin (Revision 1)"(Reference 5). The IPEEE classes used in the Base List can be correlated to the classes of equipment cited in Reference 1, Appendix B. Table 4-1 at the end of this section shows the correlation between the two equipment classification systems. As shown in Table 4-1, at least one piece of equipment from each IPEEE class is included on SWEL 1, except for Class 11, "Motor Generators."

No Seismic Category I motor generators were included in the IPEEE SPCL, and none have been identified that support the five Safety Functions included in this project.

4. A variety of environments The location for each item is identified on SWEL 1. The equipment included on SWEL 1 is a representative sample from a variety of environments (locations) in the station. These environments include the Spray Pond Pump House (common to both units), Diesel Oil Storage Tank Underground Structure, Reactor Building, Control Structure and Drywell.

5. Equipment enhanced due to vulnerabilities identified during the IPEEE program As discussed in Section 7 of this report, no IPEEE seismic-related plant improvements were implemented, or were committed to be implemented, for Limerick Unit 2.

6. Contribution to risk In selecting items for SWEL 1 that met the attributes above, some items with similar attributes were selected based on their higher risk-significance. To determine the relative risk-significance, the Risk Achievement Worth (RAW) and Fussell-Vesely (F-V) importance for a Loss of Off-Site Power (LOOP) scenario, Reference 17, from the internal plant PRA were used. The LOOP scenario from the internal plant PRA includes those pieces of equipment and events that result in either a F-V importance greater than 1 E-3 or a RAW greater than 2.0. Additionally, the list of risk-significant components for the LOOP PRA, Reference 17, were compared with the draft SWEL 1 to confirm that a reasonable sample of risk-significant components (relevant for a seismic event) were included on SWEL 1.

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

4-3

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Table 4-1. Base List IPEEE Classes vs. EPRI Seismic Walkdown Guidance Equipment Classes Total U2 & UO Base List IPEEE EPRI Seismic SWEL Items per Equipment Class Name Equipment Walkdown EPRI Guidance Class Guidance Class Class Other; Not Specifically Identified 0 0 3 Motor Control Centers 1 1 4 Low Voltage Switchgears 1 2 2 Medium Voltage Switchgears 1 3 1 Transformers 2 4 3 Horizontal Pumps 3 5 3 Vertical Pumps 4 6 5 Fluid (Air/Hyd.) Operated Valves 5 7 9 Motor Operated Valves 6 8 10 Solenoid Operated Valves 7 8 1 Fans 8 9 3 Air Handlers 8 10 10 Chillers 9 11 1 Air Compressors 10 12 1 Motor Generators 11 13 0 Distribution Panels 12 14 3 Battery and Racks 13 15 3 Battery Chargers and Inverters 14 16 3 Engine Generators 15 17 1 Instrument on Racks 16 18 9 Local Instrument (not on rack) 17 18 9 Temperature Sensors 17 19 2 Control Panels and Cabinets 18 20 16 Vertical Tanks or Heat Exchangers 19 21 5 Horizontal Tanks or Heat 20 21 6 Exchangers Total: 113 4-4

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 4.3 SWEL 2 - SPENT FUEL POOL RELATED ITEMS In accordance with Reference 1, four screens are used to select the SSCs to be included on the second Seismic Walkdown Equipment List (SWEL 2), as described in the following sections.

4.3. 1 Screen #1 - Seismic Category I Only Seismic Category I SSCs, or SSCs that could result in rapid drain-down of the SFP (see Screen #4 below), are to be considered for inclusion in SWEL 2. As described in Reference 1, the adequacy of SFP structures is assessed by analysis and is not included in the scope of these walkdowns.

The review of the design and licensing basis documentation for the SFP identified no Seismic Category I equipment for Limerick Unit 2, except for the Residual Heat Removal (RHR) cross-tie, Emergency Service Water (ESW) make-up supply line, and the Spent Fuel Pool Skimmer Tank. Considerations for these components are discussed below.

1. RHR Cross-Tie The RHR cross-tie is separated from the Fuel Pool Cooling and Clean-up (FPCC)

System via valves 051-2007 and 051-2023 per References 7 through 9. Valves 051-2007 and 051-2023 are manual valves which are line mounted in Seismic Category I piping. Additionally, the interconnecting piping between the RHR system and FPCC system is provided via one of two spool pieces: either one with blind flanges for normal operation, or one open spool piece for when the cross-tie is required (Reference 2, Section 9.1.3.2.3).

2. ESW Make-Up Supply Line The ESW make-up supply line is separated from the FPCC System via valve 053-2093. Per Reference 7, this is a manual valve located in Seismic Category I piping.

3. Spent Fuel Pool Skimmer Tanks The Spent Fuel Pool Skimmer Tanks are located in 24 ft deep, narrow pits between the reactor cavity and the spent fuel pool on the 352 ft elevation (References 10, 11 and 12). The skimmer tanks are 6 ft in diameter, and the clearance around each tank varies between one and three feet. According to Limerick Station personnel, these tanks are in a high radiation field and are not accessible during normal operation or during RFOs.

4.3.2 Screen #2 - Equipment or Systems This screen considers only those items from Screen #1 that are appropriate for an equipment walkdown process. Specifically,

1. Manual Valves and Spool Pieces--These components are inherently rugged, do not have active safety functions, and are included within their safety-related, ASME Code piping systems.

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038

2. SFP Skimmer Tanks--These tanks are in an extremely high radiation field, and the only way to view the anchorage of the tanks would be with a remote camera due to physical constraints of the tank location. Even if a remote, camera-based inspection were performed, significant dose would be involved in getting access for the camera.

Therefore, no Seismic Category I items are included in SWEL 2.

4.3.3 Screen #3 - Sample Considerations Sample considerations do not apply because no Seismic Category I items were selected in Screen #2.

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

Based on review of the Limerick Unit 2 SFP design information, the following penetrations were identified:

Skimmer surge tank intakes to the Spent Fuel Pool Cooling System are less than 2 feet below the normal surface level of the SFP (Reference 10).

RHR return line penetrations are less than 4 feet below the normal surface level of the SFP (Reference 2, Section 9.1.3.3, and Reference 12).

FPCC System Return line penetrations are less than 2 feet below the normal surface level of the SFP (Reference 12).

There is approximately 23 feet of water above the fuel during normal operation (Reference 2, Section 9.1.2.2.2.1 ), and a minimum of 19 feet of water between the top of the fuel and the penetrations. Therefore, there is no penetration within 1Oft above the top of the SFP fuel assemblies, and consistent with Reference 1, a rapid drain-down evaluation is not required.

In addition to penetration locations, the possibility of siphoning through piping that runs down into the SFP below the water level was evaluated. The FPCC return lines are non-safety related piping that enter the SFP at an elevation of 351'. After entering the SFP, both FPCC return lines run vertically, to an elevation of 328'-0.5", where the pipe ends (References 15 and 16). During normal operation, and with an SFP level of approximately 38', the terminations of these pipes are within 10 feet of the top of the fuel.

To prevent lowering of the SFP resulting from siphoning, two 1-1/4 inch anti-siphoning holes have been drilled in the pipes approximately 2 feet below the elevation where the pipe enters the SFP (References 15 and 16), which is not within 1O feet of the top of the 4-6

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 fuel. As a result, no siphoning effect would occur that could cause rapid drain down of the SFP, and no items need to be included in SWEL 2 for Limerick Unit 2.

4.4 COMPOSITE SWEL As described in Section 4.1 above, the final Seismic Walkdown Equipment List (SWEL) for Limerick Unit 2 is the combined SWEL 1 and SWEL 2. For Limerick Unit 2, there are no items of equipment in SWEL 2, so the composite SWEL is the same as SWEL 1.

Appendix B includes the composite SWEL.

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 5 Seismic Walkdowns and Area Walk-Bys 5.1 OVERVIEW Seismic Walkdowns and Area Walk-Bys were conducted by 2-person teams of trained Seismic Walkdown Engineers, in accordance with the EPRI Seismic Walkdown Guidance (Reference 1). The Seismic Walkdowns and Area Walk-Bys are discussed in more detail in the following sections.

5.2 SEISMIC WALKDOWNS An overview of the Seismic Walkdowns is shown on the Limerick Unit 2 SWEL and Unit 0 (common equipment with Unit 1) SWEL in Appendix B, Tables B-1 and B-2, respectively. A Seismic Walkdown Checklist (SWC) from Appendix C of Reference 1 was completed for each item on the SWEL, except for the deferred items identified at the end of the SWEL. Additionally, photos are included with each SWC to provide a visual record of the item and any significant comment noted on the SWC. Drawings and other plant design documents are cited in most of the SWCs, but they are not included with the SWCs because they are readily available in the plant's electronic document management system. Seismic Walkdowns were completed for 87 of the 98 items on the Limerick Unit 2 SWEL, plus all 15 items on the Unit 0 (common) SWEL, for a total of 102 items, not including the 11 deferred.

5.2.1 Anchorage Configuration Confirmation As required by Reference 1 (page 4-3), the anchorage for at least 50% of the items were confirmed to be consistent with design drawings. The second to last column of Tables C-1 and C-2 in Appendix C document the anchorage confirmation. Specifically, items that are line-mounted (and therefore do not count in the anchorage confirmation total) are marked "N/A," items that were confirmed to be consistent with design drawings are marked "Y," and items for which anchorage drawings were not identified are marked "N.". See Table 5-1 below for the accounting of the 50% anchorage configuration confirmations, and the individual SWC forms in Appendix C for the specific drawings used in each confirmation.

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Table 5-1. Anchorage Configuration Confirmation No. of SWEL Required to Unit 2 or Unit 0 N/A Items Items Items Confirm?

(Common)? (B) Confirmed (A) (A-8)/2 2 87 16 36 49 0 15 6 5 6 Totals 102 22 41 55 5.2.2 Issue Identification None of the anomalies or issues identified by the SWEs during the equipment walkdowns was ultimately judged to be "Potentially Adverse Seismic Conditions" because in all cases it was concluded the anomaly or issue would not prevent the equipment from performing its safety-related function. Additionally, based on the IRs for each issue, all equipment affected by the as-found condition was determined to be functional. Table 5-2 provides a summary of the issues identified during the Seismic Walkdowns as provided in Reference 22.

Table 5-2. Issues Identified during Seismic Walkdowns Action Actions Complete Item ID Description of Issue Y/N(Notes 1, 2)

Request ID 2AC208 One of the 22 bolts in the rear left of the IR 01398147 No cabinet was loose.

OOB519 A gap of approximately 1/8 to 1/4 inch was IR 01395937 Yes identified in the base plate for a lateral brace for an MCC.

Notes:

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

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

5.3 AREA WALK-BYS In accordance with Reference 1, Area Walk-bys were performed for each room or area which included one or more items on the SWEL. The last column of Tables C-1 and C-2 show the number of unique Area Walk-By Checklists (AWCs) completed during the walkdowns for Limerick Unit 2 and Unit 0 (common). AWC identifiers with asterisks(*)

indicate the second or subsequent SWEL item included with a specific Area Walk-By.

All completed AWCs are included in Appendix 0. Photos are not included with the AWC forms because they are part of the SWC package of the identified equipment item. A total of 49 AWCs were completed for Unit 2, plus 9 for Unit O (common).

None of the anomalies or issues identified by the SWEs during the Area Walk-Bys were judged to be "Potentially Adverse Seismic Conditions" because in all cases the anomaly 5-2

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 or issue would not prevent surrounding equipment from performing its safety-related function. Additionally, based on the IRs for each issue, all equipment affected by the as-is condition was determined to be operable.

Table 5-3 at the end of this section provides a summary of the issues identified in the Area Walk-Bys as provided in Reference 22.

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

ID/Area Request ID AWC-U0-02 A terminal box was identified with only one IR 01395982 No bolt securing its door when there were supposed to be three. Further the single bolt was loose.

AWC-U2-26 A gap was identified between the rack and IR 01397583 No retaining bar in 2A-5924 bottle rack.

AWC-U2-9 S-hooks of fluorescent light fixtures were IR 01397686 No

& found not clamped as required in some AWC-U2-13 areas.

Notes:

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

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

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 6

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

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 7

IPEEE Vulnerabilities Resolution Report The Individual Plant Examination of External Events (IPEEE) report for Limerick Generating Station (Reference 13) and the NRC Safety Evaluation on the IPEEE report (Reference 14), do not identify any seismic vulnerabilities. This was attributed to the conservative nature of the original design, which is a reflection of the relatively new vintage of the plant. Therefore, no seismic-related plant improvements were implemented, or were committed to be implemented, for Limerick Unit 2.

Although there were no equipment-related modifications, the IPEEE report (Reference

13) did commit to improve the seismic housekeeping of the plant. A station housekeeping procedure (Reference 19) and a guidance procedure for storage and housekeeping (Reference 20) are both active to ensure good housekeeping practices at the site.

As noted above, there are no Design Basis vulnerabilities identified for Limerick Generating Station Unit 2 and Unit O (common). Some equipment, however, did not meet the IPEEE Review Level Earthquake (RLE) screening criterion of 0.3 g peak ground acceleration (PGA). The RLE is twice the design basis earthquake of 0.15 g.

Table 7-1 identifies the equipment that did not initially meet the RLE High Confidence of Low Probability of Failure (HCLPF) value of 0.3 g. As shown in the table, each component has margin above the seismic licensing basis.

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Table 7-1. IPEEE Resolutions for Items with HCLPFs Below Review Level Earthquake Description of Concern IPEEE Report Proposed Actual Resolution Resolution Equipment ID Resolution of Condition of Condition Date (per Reference 18)

HV-051-2F041A Potential seismic spatial Reported in RAI Response Resolved by analyses which 1102197 and interaction between conduit (Ref. 18), but not in IPEEE assigned a HCLPF of 0.3g (i.e.,

HV-051-2F041C inlet to limit switch and Report twice the design basis SSE).

structural member 2AD160 Existing thick shims may Reported in RAI Response Resolved by analyses which 1/02/97 and result in unacceptable (Ref. 18), but not in IPEEE assigned a HCLPF of 0.2 g 280160 bending of anchor bolts Report (i.e., which exceeds the design under lateral seismic loading basis SSE).

Diesel Generator Lack of flexibility in attached Reported in RAI Response Resolved by analyses which 1102197 Starting Air Tanks safety valve line. (Ref. 18), but not in IPEEE assigned a HCLPF of greater (all 8 tanks for Unit 2) Report than 0.3g (i.e., more than twice the design basis SSE).

20NAD 160 and Transfer switches are Reported in RAI Response Acceptable because 1/02/97 20NBD160 laterally supported by (Ref. 18), but not in IPEEE considered to have the same inverters 2AD160 and Report HCLPF as 2AD160 & 280160, 280160, which have a which is 0.2g, per calculation HCLPF less than 0.3g. LS-0174 (and which still exceeds the design basis SSE).

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Limerick Generating Station Unit 2 Correspondence No.* RS-15-038 8 Peer Review 8.1 OVERVIEW In accordance with the EPRI Seismic Walkdown Guidance (Reference 1), a peer review of this project was performed during the preparation of the Seismic Walkdown Equipment List (SWEL), during implementation of the seismic walkdowns and area walk-bys, and following completion of the issue resolutions. Specifically, the peer review addresses the following activities:

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

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

Walk-Bys,

Review of any licensing basis evaluations,

Review of the decisions for entering the potentially adverse conditions in to the plant's Corrective Action Program (CAP), and

Review of the final submittal report.

The complete Peer Review Report is included in Appendix F.

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

8.3 REVIEW OF SAMPLE SEISMIC WALKDOWN AND AREA WALK-BY CHECKLISTS Approximately 25% of the Seismic Walkdown packages, i.e., SWC forms, photographs, and drawings (where applicable) were reviewed by the peer review team. Additionally, interviews were conducted with both teams of Seismic Walkdown Engineers to ensure that the seismic walkdowns and area walk-bys were performed in accordance with Reference 1.

The peer review team recommended that some clarifications be added to the SWC and AWC forms reviewed.

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 8.4 REVIEW OF LICENSING BASIS EVALUATIONS As discussed in Sections 5 and 6 of this report, the issues identified during the seismic walkdowns and area walk-bys did not threaten the ability of Seismic Category I equipment for perform its safety functions. The specific items that have been entered in the Limerick Corrective Action Program (CAP) were reviewed, and no concerns with the assessments or proposed resolutions were identified.

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

8-2

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

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

2. Limerick Generating Station Updated Final Safety Analysis Report (UFSAR),

Revision 16.

3. PECO Document No. N-OOE-117-00009, Success Path Components List (SPCL) for Limerick Generating Station Unit 2, Revision 0.

4. PECO Document No. N-OOE-117-00010, Success Path Components List (SPCL) for Limerick Generating Station Unit 1 and Common, Revision 0.

5. EPRI NP-6041-SL, A Methodology for Assessment of Nuclear Power Plant Seismic Margin (Revision 1), dated August 1991.

6. L-S-52, Spent Fuel Pool Cooling and Cleanup System, Revision 4.

7. Drawing 8031-M-53, Sheet 3, P&ID Fuel Pool Cooling & Cleanup (Unit 2), Revision 16.

8. Drawing 8031-M-53, Sheet 4, P&ID Fuel Pool Cooling & Cleanup (Unit 2), Revision 16.

9. Drawing 8031-M-51, Sheet 5, P&ID Residual Heat Removal (Unit 2), Revision 30.

10. Drawing No. C-246, Sheet 1, Reactor Building Units 1 & 2 Pool Liners and Accessories Surge Tank Section & Details, Revision 13.

11. Drawing No. M-137, Equipment Location Reactor Enclosure Unit 2 Plan At EL. 352'-

0", Revision 15.

12. Drawing No. C-0235, Reactor Building Unit 2 Pool Liners and Accessories Spent Fuel Pool Wall Liner Elevations, Revision 15.

13. PECO Energy Company, Limerick Generating Station Units 1 and 2, Individual Plant Examination for External Events, June 1995.

14. NRC Letter (B. C. Buckley) to PECO (J. A. Hutton), Review of Individual Plant Examination of External Events (IPEEE) Submittal, Limerick Generating Station, Units 1 and 2, (TAC NOS. M83636 AND M83637), dated February 23, 2000.

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15. Drawing HCC-201-6, Sheet 1, Isometric - Reactor Building Fuel Pool Cooling, Clean-up & Filter Demin. - Unit 2, Revision 13.

16. Drawing HCC-201-7, Sheet 1, Isometric - Reactor Building Fuel Pool Cooling, Clean-up & Filter Demin. - Unit 2, Revision 10.

17. Limerick Generating Station Document No. LG-MISC-008, Limerick Risk Importance Listings to Support Development of the Seismic Walkdown Equipment List (SWEL),

Revision 0.

18. PECO Letter (G. A. Hunger, Jr.) to NRC, Limerick Generating Station, Units 1 and 2, Response to Request for Additional Information Regarding Review of Individual Plant Examination of External Events, dated July 24, 1997.

19. Procedure MA-AA-716-026, Station Housekeeping/Material Condition Program, Revision 10.

20. Procedure MA-LG-716-026-1001, Additional Guidance for In-Plant/Yard Storage and Housekeeping at Limerick, Revision 15.

21. Facility Operating License No. NPF-85.

22. Email from R. Wehrman (Exelon) to C. Schlaseman (MPR), Subj: Limerick Walkdown I Rs, 9/28/12, 11 :34 AM.

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Annex A Updated Transmittal #1 Ai

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Contents of Annex A A1 Introduction .................................................................................................................. A1-1 A1.1 Purpose ............................................................................................................. A1-1 A 1.2 Background ......................................................................................................... A 1-2 A 1. 3 Plant Overview .................................................................................................... A 1-2 A 1.4 Approach ............................................................................................................ A 1-2 A1.5 Conclusion ........................................................................................................... A1-2 A2 Seismic Licensing Basis ............................................................................................ A2-1 A3 Personnel Qualifications ............................................................................................ A3-1 A3.1 Overview .............................................................................................................. A3-1 A3.2 Project Personnel ................................................................................................. A3-1 A4 Selection of SS Cs ....................................................................................................... A4-1 A5 Seismic Walkdowns and Area Walk-Bys ................................................................... A5-1 A5.1 Overview .............................................................................................................. A5-1 A5.2 Seismic Walkdowns ............................................................................................. A5-1 A5.2.1 Anchorage Configuration Confirmation .................................................... A5-2 A5.2.2 Issue Identification .................................................................................... A5-2 A5.3 Area Walk-Bys ..................................................................................................... A5-2 A5.3.1 Issue Identification during Area Walk-bys ................................................. A5-3 A5.4 Supplemental Information on Electrical Cabinet Inspections ............................... A5-3 A6 Licensing Basis Evaluations ...................................................................................... A6-1 A7 IPEEE Vulnerabilities Resolution Report ................................................................. A7-1 AB Peer Review ................................................................................................................. AB-1 A9 References .................................................................................................................. A9-1 Aii

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Appendices AA Project Personnel Resumes and SWE Certificates .................................... not included AC Seismic Walkdown Checklists (SWCs) ........................................................ not included AD Area Walk-By Checklists (AWCs) ................................................................. not included AE Plan for Future Seismic Walkdown of Inaccessible Equipment ............................. AE-1 AF Peer Review Report ........................................................................................not included Tables Table A3-1. Personnel Roles .......................................................................... ......... A3-1 Table A5-2. Conditions Identified during Seismic Walkdowns ........................................ A5-4 Table A5-3. Conditions Identified during Area Walk-Bys ............................................... A5-4 Table AC-1. Summary of Seismic Walkdown Checklists ..................................... not included Table AD-1. Summary of Area Walk-By Checklists ............................................. not included Table AE-2. Inaccessible and Deferred Equipment List.. .............................................. AE-1 A iii

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A 1 introduction A1.1 PURPOSE This updated transmittal report is being provided in compliance with the requirements contained in the NRG 50.54(f) letter dated March 12, 2012, Enclosure 3, Recommendation 2.3: Seismic. This new report section, Annex A, contains the results of the follow-on inspection activities that have been completed to address commitments contained in Exelon letter to the NRG, "180-day Response to NRG Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated November 19, 2012 (RS-12-171). Annex A includes follow-on Seismic Walkdown results associated with NRG Commitment Nos. 3 and 4 listed in Enclosure 3 of the above Exelon letter. Additionally, the update includes the current status of the resolution of conditions found during the initial Seismic Walkdowns and Area Walk-Bys as documented in Tables 5-2 and Table 5-3, respectively, from Enclosure 2 of the above Exelon letter.

Commitment No. 3, for the completion of the eleven (11) remaining inspection (SWEL) items previously deferred due to inaccessibility listed in Table E-1, has been completed.

All eleven (11) inspection items were completed by the commitment date of Li2R12 (Spring 2013) and the results are documented in this update.

Commitment No. 4, for the completion of the three (3) remaining internal electrical cabinet inspections listed in Table E-2, remains open. The remaining three (3) inspection items will be completed by the original December 31, 2014 commitment date.

A subsequent NRG transmittal will be issued to document results of this inspection and the completion of Commitment No. 4.

The initial NRG Transmittal report documented that one (1) condition identified during the seismic walkdowns, and listed in Table 5-2, remained open. This update documents that this condition is now resolved with all follow-on actions complete.

The initial NRG Transmittal report documented that three (3) conditions identified during the area walk-bys, and listed in Table 5-3, remained open. This update documents that all three (3) conditions are now resolved with all follow-on actions complete.

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

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Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A

1.2 BACKGROUND

See Section 1. 1 A 1.3 PLANT OVERVIEW See Section 1.2 A 1.4 APPROACH See Section 1. 3 A

1.5 CONCLUSION

As of Li2R12 (Spring 2013), Seismic Walkdowns have been performed at the Limerick Generating Station Unit 2 on 11 of the 11 items deferred due to inaccessibility in accordance with the NRG endorsed walkdown methodology. Area Walk-Bys were also completed, as required, during these follow-on activities. A potentially adverse seismic condition, AWC-U2-50, was identified during Area Walk-Bys, noted in Table A5-3, and actions were taken during Li2R12 to correct the potentially adverse seismic condition.

No additional degraded, nonconforming, or unanalyzed conditions that required either immediate or follow-on actions were identified.

Additional follow-on activities required to complete the efforts to address Enclosure 3 of the 50.54(f) letter include inspection of two (2) items deferred due to inaccessibility, as listed in Table AE-2 of this Annex A.

As of May 20, 2013, all conditions identified during the Seismic Walkdowns and Area Walk-Bys as documented in IRs listed in Table 5-2 and Table 5-3 have been corrected.

IR 01496015 was generated during the follow-on walkdowns and can be found in Table A5-3 and has been corrected. The updated completion status for the previous and recently generated I Rs is shown in Table A5-2 and Table A5-3 in Section A5 of this Annex A.

A1-2

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A 2 Seismic Licensing Basis See Section 2, no new licensing basis evaluations resulted from the follow-on walkdown activities.

A2-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A 3 Personnel Qualifications A3.1 OVERVIEW This section of the report identifies the personnel that participated in the NTTF 2.3 Seismic Walkdown efforts for follow-on activities. A description of the responsibilities of each Seismic Walkdown participant's role(s) is provided in Section 2 of the EPRI guidance document. Resumes provided in Appendix AA of this Annex A, provide detail on each person's qualifications for his or her role.

A3.2 PROJECT PERSONNEL Table A3-1 below summarizes the names and corresponding roles of personnel who participated in the NTTF 2.3 Seismic Walkdown effort for follow-on activities. See Table 3-1 for names and corresponding roles of personnel who participated in the initial NTTF 2.3 Seismic Walkdown effort.

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

T. Gallagher x

(Exelon)< 2 l J. Lucas x

(Exelon) <2 l J. Narula x<1i (Exelon) <2l R. Wehrman x (Exelon)

Notes:

1. Peer Review Team Leader

2. Personnel for follow-on activities only. Resumes provided in Appendix AA.

A3-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A 4 Selection of SSCs See Section 4, no changes were made to the SWEL for the follow-on walkdowns.

A4-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A 5 Seismic Walkdowns and Area Walk-Bys A5.1 OVERVIEW Follow-on Seismic Walkdowns and Area Walk-Bys were conducted by a two (2) person team of trained Seismic Walkdown Engineers (SWEs), in accordance with the EPRI guidance document during Li2R12 (Spring 2013). 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.

A5.2 SEISMIC WALKDOWNS These follow-on Seismic Walkdowns focused on the seismic adequacy of the items previously deferred due to inaccessibility listed on Table E-1 of the initial report submitted in November 2012. The Seismic Walkdowns also evaluated the potential for nearby SSCs to cause adverse seismic interactions with the items being inspected. The Seismic Walkdowns focused on the following adverse seismic conditions associated with the subject item of equipment:

Anchorage Configuration Confirmation

Issue Identification The results of the follow-on Seismic Walkdowns were documented in Appendix AC of this Annex A, using the Seismic Walkdown Checklist (SWC) template provided in the EPRI guidance document. Seismic Walkdowns were performed and SWCs were completed for 11 of the 11 items identified on Table E-1 of the initial report submitted in November 2012. Additionally, photos have been included with the 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.

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.

A5-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A5.2.1 Anchorage Configuration Confirmation See Section 5.2.1, no additional anchorage configuration confirmation was required and none was performed during the follow-on walkdowns.

A5.2.2 Issue Identification No issues were identified during the follow-on seismic walkdowns.

Per Section 5.2.2 and Table 5-2, during the previous seismic walkdowns two (2) conditions were identified and entered into the Corrective Action Program. Corrective actions were completed to address one (1) of the two (2) conditions. Subsequent to the issuance of the last report corrective actions were completed to address the remaining one (1) condition. Table A5-2 of this Annex A provides an updated summary of the conditions and the status of the corrective actions to address these conditions.

AS.3 AREA WALK-BYS The purpose of the Area Walk-Bys is to identify potentially adverse seismic conditions associated with other SSCs located in the vicinity of the items being inspected. Vicinity is generally defined as the room containing the 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 item. Additional vicinity associated with these follow-on Seismic Walkdowns but not covered in Appendix D, is described on the Area Walk-By Checklist (AWC), shown in Appendix AD of this Annex A. A total of six (6) additional AWCs were completed for Limerick Generating Station Unit 2 as a result of these follow-on walkdowns.

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

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 in 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 MA-AA-796-024, Scaffold Installation, Inspection, and Removal 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. 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.

A5-2

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 The results of the Area Walk-Bys were documented on the AWCs included in Appendix AD of this Annex A. A separate AWC was filled out for each area inspected. A single AWC was completed for areas where more than one 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 Section 5.3 of this report.

A5.3.1 Issue Identification during Area Walk-Bys One ( 1) "Potentially Adverse Seismic Condition" was identified during the Area Walk-Bys associated with the follow-on area walk-bys. See Table A5-3 for a description of the condition identified.

Per Section 5.3 and Table 5-3, during the previous area walk-bys three (3) conditions were identified and entered into the Corrective Action Program. Corrective actions were completed to address zero (0) of the three (3) conditions. Subsequent to the issuance of the last report corrective actions were completed to address three (3) of the three (3) conditions. One (1) condition was identified during the follow-on area walk-bys and entered into the Corrective Action Program and Corrective Actions for this condition were completed. Table A5-3 of this Annex A provides an updated summary of the conditions and the status of the corrective actions to address these conditions.

A5.4 SUPPLEMENTAL INFORMATION ON ELECTRICAL CABINET INSPECTIONS See Section E.2, these follow-on walkdowns completed the supplemental internal inspections of 20-0103. No potentially adverse seismic conditions were identified. Two (2) open items on Table E-2 remain and are documented in table AE-2.

The Seismic Walkdown Checklist (SWC) for this component will be documented in a later update of Table E-2 open items to indicate the results of the internal inspection.

A5-3

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Table A5-2. Conditions Identified during Seismic Walkdowns Action Request ID Actions Complete Item ID Description of Issue Yes/No(Notes 1,2)

(IR)

One of the 22 bolts in the rear left of the Yes 2AC208 01398147 cabinet was loose.

A gap of approximately 1/8 to 1/4 inch 008519 was identified in the base plate for a 01395937 Yes lateral brace for an MCC.

Notes:

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

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

Table A5-3. Conditions Identified during Area Walk-Bys Action Actions Item ID Description of Issue Request Complete ID (IR) Yes/No A terminal box was identified with only one bolt securing AWC-U0-02 its door when there were supposed to be three. Further, 01395982 Yes the single bolt was loose.

A gap was identified between the rack and retaining bar 01397583 Yes AWC-U2-26 in 2A-5924 bottle rack.

AWC-U2-9 S-hooks of fluorescent light fixtures were found not 01397686 Yes clamped as required in some areas.

AWC-U2-13 A scaffold knuckle was found attached to the structural AWC-U2-50* steel near the X-59A penetration above the SRVs on 01496015 Yes elevation 295.

Notes:

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

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

3. "*"indicates conditions identified during follow-on Area Walk-Bys (Li2R12)

AS-4

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A 6 Licensing Basis Evaluations See Section 6, no new licensing basis evaluations were performed as a result of conditions identified during the follow-on Walkdowns or Area Walk-Bys.

A6-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A 7 IPEEE Vulnerabilities Resolution Report See Section 7, no changes to the IPEEE vulnerabilities resolution were made for this Annex A A?-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 A 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, if the SWEL has been revised. The SWEL was not revised; therefore a review of the selection of SSCs was not required.

Review of a sample of the checklists prepared for the Seismic Walkdowns and Area Walk-Bys.

Review of Licensing basis evaluations, as applicable. No new licensing basis evaluations were performed; therefore a review of licensing basis evaluations was not required.

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 AF of this Annex A.

A8-1

Limerick Generating Station Unit 2 Correspondence No .. RS-15-038 A 9 References See Section 9, no new references were added for this Annex A.

A9-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Appendix AE Plan for Future Seismic Walkdown of Inaccessible Equipment Two (2) items were not accessible during the follow-on walkdowns. These items will be walked down during a time when the equipment is accessible. Table AE-2 summarizes the reasons these items are inaccessible during normal plant operation and notes the Limerick Generating Station Issue Report IR that has been written to track completion of the Seismic Walkdown for this item.

Per Section E.2, supplemental internal inspections of certain cabinets are required due to clarification provided by the NRC after the online seismic walkdowns were completed.

Therefore the items identified on Table AE-2 requires a complete inspection, including internal inspection for other adverse seismic conditions.

The Area Walk-By of the vicinity of this equipment was completed previously and was documented in Appendix D of this report.

Table AE-2. Inaccessible and Deferred Equipment List Action Component Reason for Resolution/ Milestone Description Request ID Inaccessibility Status Completion ID (IR)

A RPS & UPS Equipment December 2A-D160 Distribution Panel normally 1436078 Scheduled 2014 Static Inverter eneri;:iized 8 RPS & UPS Equipment December 28-D160 Distribution Panel normally 1436081 Scheduled 2013 Static Inverter eneri;:iized AE-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Annex B Updated Transmittal #2 Bi

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Contents of Annex B B1 Introduction .................................................................................................................. B1-1 B1.1 Purpose ............................................................................................................ B1-1 B1 .2 Background ......................................................................................................... B1-2 B1 .3 Plant Overview .................................................................................................... B1-2 B 1.4 Approach ............................................................................................................. B1-2 B1 .5 Conclusion ........................................................................................................... B1-2 B2 Seismic Licensing Basis ............................................................................................ B2-1 B3 Personnel Qualifications ............................................................................................ B3-1 B3.1 Overview .............................................................................................................. B3-1 B3.2 Project Personnel ................................................................................................. B3-1 B4 Selection of SSCs ....................................................................................................... B4-1 B5 Seismic Walkdowns and Area Walk-Bys ................................................................... B5-1 B5.1 Overview .............................................................................................................. B5-1 B5.2 Seismic Walkdowns ............................................................................................. B5-1 B5.3 Area Walk-Bys ..................................................................................................... B5-1 B5.4 Supplemental Information on Electrical Cabinet Inspections ............................... B5-1 B6 Licensing Basis Evaluations ...................................................................................... B6-1 B7 IPEEE Vulnerabilities Resolution Report ................................................................. B7-1 BB Peer Review ................................................................................................................. BB-1 B9 References .................................................................................................................. B9-1 Bii

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Appendices BA Project Personnel Resumes and SWE Certificates ................................................. BA-1 BC Seismic Walkdown Checklists (SWCs) .....................................................................BC-1 BF Peer Review Report ..................................................................................................... BF-1 Tables Table 83-1. Personnel Roles .......................................................................... ......... 83-1 Table 8C-1. Summary of Seismic Walkdown Checklists .............................................. 8C-1 Bi ii

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 B 1 introduction 81 .1 PURPOSE This updated transmittal report is being provided in compliance with the requirements contained in the NRC 50.54(f) letter dated March 12, 2012, Enclosure 3, Recommendation 2.3: Seismic (Ref. 83, Section 89). This new report section, Annex 8, contains the results of the follow-on inspection activities that have been completed to address commitments contained in Exelon letter to the N RC, "180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated November 19, 2012 (RS-12-171, Ref. 81, Section 89). Annex 8 includes follow-on Seismic Walkdown results associated with NRC Commitment No. 4 listed in Enclosure 3 of the above Exelon letter.

Commitment No. 4, for the completion of the three (3) remaining supplemental internal electrical cabinet inspections items previously deferred due to inaccessibility listed in Table E-2, has been completed. All three (3) inspection items were completed by the commitment date of December 31, 2014 and the results are documented in this update.

Annex 8 includes updates to each report section where the status has changed or new information is available.

81-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 81 .2 BACKGROUND See Section 1.1 81 .3 PLANT OVERVIEW See Section 1. 2 81.4 APPROACH See Section 1.3 81 .5 CONCLUSION As of December 31, 2014, Seismic Walkdowns have been performed at the Limerick Generating Station Unit 2 on 3 of the 3 internal electrical cabinet items deferred due to inaccessibility in accordance with the NRC endorsed walkdown methodology. No degraded, nonconforming, or unanalyzed conditions that required either immediate or follow-on actions were identified. No IRs were generated. No new Area Walk-Bys were performed since all Area Walk-Bys had previously been completed and reported.

With the conclusion of these inspections, the walkdowns of all SWEL items are complete. Completion of these walkdowns and report transmittal closes NRC Commitment #4 (Ref. B1, Section B9).

B1-2

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 B2 Seismic Licensing Basis See Section 2, no new licensing basis evaluations resulted from the follow-on walkdown activities.

82-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 83 Personnel Qualifications 83.1 OVERVIEW This section of the report identifies the personnel that participated in the NTTF 2.3 Seismic Walkdown efforts for follow-on activities. A description of the responsibilities of each Seismic Walkdown participant's role(s) is provided in Section 2 of the EPRI guidance document. Resumes provided in Appendix BA of this Annex B, provide detail on each person's qualifications for his or her role.

83.2 PROJECT PERSONNEL Table 83-1 below summarizes the names and corresponding roles of personnel who participated in the NTTF 2.3 Seismic Walkdown effort for follow-on activities. See Table 3-1 and A3-1 for names and corresponding roles of personnel who participated in the initial NTTF 2.3 Seismic Walkdown effort.

Table 83-1. Personnel Roles Seismic Equipment Licensing Plant Walkdown IPEEE Peer Name Selection Basis Operations Engineer Reviewer Reviewer Engineer Reviewer (SWE)

T. Gallagher (Exelon)(2l x

J. Lucas 2l x (Exelon) <

J. Narula 2l x (Exelon) <

Juan Lopez 2l x (Exelon) <

David Yerkes 2l x (Exelon) <

R. Wehrman x<1)

(Exelon)

J. Dullinger x (Exelon)

M. O'Brien x (Exelon)

Notes:

1. Peer Review Team Leader

2. Personnel for follow-on activities only. Resumes provided in Appendix BA.

83-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 84 Selection of SSCs See Section 4, no changes were made to the SWEL for the follow-on walkdowns.

84-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 85 Seismic Walkdowns and Area Walk-Bys 85.1 OVERVIEW Follow-on Seismic Walkdowns were conducted by a two (2) person team of trained Seismic Walkdown Engineers (SWEs), in accordance with the EPRI guidance document. The Seismic Walkdowns are discussed in more detail in the following sub-sections.

Consistent with the EPRI guidance document (Ref. 1, Section 9), 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.

85.2 SEISMIC WALKDOWNS No additional seismic walkdowns per Table E-1 of Ref. B1 (Section B9) were required for this effort. Only supplemental walkdowns for internal cabinet inspections were required for this report. See Section B5.4 for details.

85.3 AREA WALK-BYS Per Section 5. 3 and A5. 3, all Area Walk-Bys had previously been completed and documented. No new area Walk-Bys were performed for this update.

85.4 SUPPLEMENTAL INFORMATION ON ELECTRICAL CABINET INSPECTIONS The follow-on internal electrical cabinet Seismic Walkdowns focused on the seismic adequacy of the items previously deferred due to inaccessibility listed on Table E-2 of the initial report submitted in November 2012 (Ref. B1, Section B9).

The results of the follow-on internal electrical cabinet Seismic Walkdowns were documented in Appendix BC of this Annex B, using the Seismic Walkdown Checklist (SWC) template provided in the EPRI guidance document (Ref. 1, Section 9). Seismic Walkdowns were performed and SWCs were completed for 3 of the 3 supplemental internal electrical cabinet items identified on Table E-2 of the initial report submitted in November 2012 (Ref. B1, Section B9). 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.

B5-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 No adverse seismic conditions nor any degraded, non-conforming, or unanalyzed conditions that required either immediate or follow-on actions were identified during the follow-on electrical cabinet internal seismic walkdowns.

85-2

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 B 6 Licensing Basis Evaluations See Section 6 and Section A6. No conditions were identified during the follow-on internal electrical cabinet inspections. Therefore, no new licensing basis evaluations were performed.

86-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 B 7 IPEEE Vulnerabilities Resolution Report See Section 7, no changes to the IPEEE vulnerabilities resolution were made for this Annex 8.

87-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 B 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 (Ref. 1, Section 9). The Peer Review process included the following activities:

Review of the selection of SSCs included on the SWEL, if the SWEL has been revised. The SWEL was not revised; therefore a review of the selection of SSCs was not required.

Review of a sample of the checklists prepared for the Seismic Walkdowns and Area Walk-Bys.

Review of Licensing basis evaluations, as applicable. No new licensing basis evaluations were performed; therefore a review of licensing basis evaluations was not required.

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 BF of this Annex B.

B8-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 B 9 References See Section 9 and Section A9 for additional references.

81. Exelon Generation Company, LLC 180-day Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 19, 2012 (RS-12-171).

82. Exelon Generation Company, LLC Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated October 7, 2013 (RS-13-138).

83. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012.

89-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Appen dix BA Project Personnel Resumes and SWE Certificates Resumes and certificates (where applicable) for the following people are found in Appendix BA of this Annex B:

D. Yerkes......... ................... ................... ................... ................... ....... BA-2 J. Lucas.......... ................... ................... ................... ................... ........ BA-5 R. Wehrman..... ................... ................... ................... ................... ....... BA-8 J. Narula. .. . . . .. . . .. .. . . . . . .. . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . .. . .. . . . .. . .. . . . . . . . . . . . . . . . . .. . .. . BA-9 T. Gallagher.... ................... ................... ................... ................... ......... BA-13 J. Lopez.......... ................... ................... ................... ................... ........ BA-17 J. Dullinger...... ................... ................... ................... ................... ........ BA-21 M. O'Brien........ ................... ................... ................... ................... ....... BA-23 BA-1

Limerick Generating Station Unit 2 Appendix BA Correspondence No. RS-15-038 TMI I

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Limerick Generating Station Unit 2 Appendix BA Correspondence No.: RS-15-038 Jesse Lucas, P.E Senior Engineer Exelon Generation EDUCATION Texas Christian University - MBA Finance - 1991 Pennsylvania State University - B.S. Nuclear Engineering - 1986 REGISTRATIONS Professional Engineer - Delaware (Mechanical Engineering)

EXPERTISE

Project Engineering and Task Management

Design Engineering and Plant Modifications

Equipment Reliability, Equipment Lifecycle Management Mr. Lucas is a Senior Engineer with more than 20 years experience in engineering and client management. He has experience in system and design engineering at nuclear power stations. He has experience in oversight of engineering contracts, and preparation of the long-term asset management plan.

RESPONSIBILITIES Mr. Lucas is the Lead Responsible Engineer for the Fukushima Project at the Peach Bottom Atomic Power Station. Mr. Lucas is responsible for engineering aspects of individual projects including external flooding feature inspections, seismic inspections, severe accident containment vent modifications, spent fuel pool instrumentation installation, and FLEX response modifications.

Mr. Lucas is responsible for determining scope, selecting vendor engineering support, and reviewing all vendor technical submittals. Mr. Lucas is responsible for site review and approval of regulatory reports prior to NRC submittal, including technical accuracy and compliance with guidance and orders.

Mr. Lucas is responsible for oversight of vendors performing inspection walkdowns for conformance with external flooding and seismic requirements. Mr. Lucas has completed Training on NTTF 2.3 for Plant Seismic Walkdowns.

June,2013 BA-5

Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 Jesse Lucas, P.E Senior Engineer Exelon Generation EXPERIENCE Exelon Generation 2004 - Present Prior to serving as Lead Responsible Engineer for Peach Bottom Fukushima, Mr.

Lucas served as the Equipment Reliability (ER) Engineer. Mr. Lucas had responsibility for weekly report-out to Senior Management team on plant system status, proposed improvements, program status, and work activities. Mr. Lucas prepared the semi-annual ER and asset management plan reports to the corporate senior leadership team. Mr. Lucas had overall responsibility for department budget, including contractual relationships with engineering service providers. Mr. Lucas represents the engineering department at daily station ownership committee (SOC) meetings, and weekly station budget meetings.

Responsible for department and station performance in long-range planning and asset management, engineering budget, critical component performance, obsolescence process, system performance monitoring, seasonal readiness work scheduling, and system health reporting.

2012 INPO E&A- Strength in ER program for Margin Management

2012 INPO E&A- Beneficial Practice for Long Term Planning Prior to work as ER and SOC Engineer, Mr. Lucas was a design engineer in the Electrical Engineering group. Mr. Lucas was responsible for technical evaluations and plant modifications. Modifications included replacement of condenser level controllers, high voltage line connectors, transformer sudden pressure relays, and Hydrogen Water Chemistry PLC and UPS.

RCM Technologies 1993 - 2004 Mr. Lucas was Client Manager for design services to Exelon, responsible for business development. Also reviewed and approved technical deliverables.

ABB lmpell 1991 - 1993 Mr. Lucas wrote design baseline documents, and prepared calculations for nuclear HVAC systems.

Stone & Webster Engineering (engineer at Comanche Peak Station) 1986 - 1990 PP&L (co-op at Susquehanna Steam Electric Station) 1984 - 1985 June,2013 2 BA-6

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Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 Robert Brian Wehrman 621 Highland Ave (814)360-0934 (Cell)

Boyertown, PA 19512 (610)718-3597 (Work) robe rt. wehrman(ii)exe loneorp.eom EXPERIENC E ;\,/ovemher 2011. Fxelon Nuclear-Limerick Generutiny, Station, Umerick. PA Mechanical Design Engineer - Prqjects

Fukushima Lead Responsible Engineer o Lead for both 2.3 Seismic and Flooding Walkdowns o Lead Engineer for Hardened Vents and FLEX October 2006-November 2011 Exelon Nuclear-Quad Cities Generating Station, Cordova, II Mechanical Design Engineer

Performed several calculations supporting the design basis of the plant including:

o Several of the ECCS Suction and Discharge Pressure Requirement Calculations o Diesel Fuel Oil Volume and Consumption o V01iexing Calculations for CCSTs and Fuel Oil tanks o Fire Protection Design Basis Flow for all plant areas o CCST and Well Water Tanks Time to Freeze with reduced or no internal heaters

Cognizant Engineer on several modifications including:

o Lead Engineer on the 1A and 2B Reactor Recirc Pump and Motor Replacement Project o Lead Mechanical Engineer on both Unit 1 and Unit 2 ASD Projects o Unit I Turbine Extraction Steam Bellows Replacement (Part of Turbine Retrofit) o Floor Drain Surge Tank Sample Line Modification o Diesel Generator Heat Exchanger Replacement

Coating Program Owner for Safety Related Service Level 1 Coatings. Responsibilities include:

o Performing walkdowns of Service Level I Coatings (All of Primary Containment) with qualified inspector o Prepared License Renewal Binder for Quad Cities

Calculation Improvement Plan Owner o Prepared and Developed list of Key Calculations for Quad Cities Station o Ensure reviews of calculations are completed as required (30 per year at Quad Cities) o Update station management of progress through PHC presentations

Mentor to new engineers in Mechanical Design Group

Part of the Exelon Emerging Leader Program

Qualifications Include:

o Engineering Calculations, Configuration Change, Reviewer, EP Mechanical Eng.

o 50.59 BWR Sereener, VT-1, -2, and -3 Level II EDUCATION The Pennsylvania State University University Park, PA Masters of Science in Mechanical Engineering GPA: 3.40/4.00 Thesis Title ""Flow and Heat-Transfer Characteristics in the Simulated Fin-Slot Region of the Space Shuttle Booster..

Anticipated Graduation: August 2006 The Pennsylvania State University University Park, PA Bachelor of Science in Mechanical Engineering GPA: 3.30/4.00 August 2003-Current The Pennsylvania State University University Park, PA Graduate Research - High Pressure Combustion Laboratory

Participated in an integrated rocket ramjet design project which included programming a perfonnance code that incorporated pre-made chemical equilibrium and trajectory codes using Power Basic.

111

Designed modifications to a 1/10 scale "fin slot" test rig of the Space Shuttle booster rockets.

Performed a heat transfer analysis of the fin area with a team of three students.

AWARDS Two Best papers awarded by the AIAA Hybrid Rocket Committee, 2002 and 2004 A third place prize in the 2002 graduate research exhibition.

REFERENCE S Available upon request.

BA-8

Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 JAGDISH NARULA Senior Engineer, Exelon Nudear 610-718-3581 Jagdish.narula@exeloncorp.com

SUMMARY

Registered Professional Civil Structural Engineer with extensive experience in design, construction, project engineering management related to Nuclear Power Plants, Fossil power Plants, Refineries, Petrochemical Plants, Industrial and commercial facilities.

Core Competencies include: Seismic Qualification of Nuclear Power Plant Equipment, Seismic analysis and design of Nuclear Plant structures, systems and components, development of modification packages, Technical Evaluations, safety analysis reports, supervision and oversight of contracts and contract project personnel, Evaluation and development of Design Criteria, supervision of Technical personnel, leading projects from conceptual to completion and teaching.

EXPERIENCE Exelon Corporation (Limerick Generating Station)- senior Engineer (Present)

Working as a Lead Civil Structural Engineer at the plant, I have supported and provided guidance to almost every seismic issue at the plant over the years. Performed Seismic qualification of safety related plant equipment, structures, systems and components, determining and evaluating seismic requirements for safety related electrical and mechanical components, reviewing vendor seismic testing and analysis reports. Have performed numerous seismic 11/1 evaluations in the plant, prepared modification packages, guided and performed seismic interface review of numerous plant modifications as well as being an Engineering lead on various projects.

Prepared lesson plans and delivered lectures on seismic qualification of equipment on various occasions to engineering population in the plant. Attended and participated in EPRI (SQURTS) meetings.

Recently attended and satisfactorily completed NRC approved EPRI Training on Fukushima Near-Term Task Force Recommendation 2.3 "Plant Seismic Walkdowns" in 2012.

As a seismic SME at Limerick, provided plant related Geotechnical input for development of updated GMRS in support of Fukushima "Near-Term Task Force Recommendation 2.1: Seismic" and BA-9

Limerick Generating Station Unit 2 Appendix BA Correspondence No. RS-15-038 JAGDISH NARULA (Continued) performed Limerick review on EPRI document "Guidelines for Nuclear Plant Response to an Earthquake" developed in response to North Anna Project.

As an SME on Heavy Loads at limerick, I provided guidance on "heavy load" lifts. Prepared lesson plans and delivered lecture on Heavy Loads (NUREG 612).

Performed numerous technical structural evaluations and provided structural interface on numerous plant modifications.

Bechtel Corporation (Senior Engineer) - 4 years Lead Civil/Structural Engineer for capital projects involved in the upgrading of Chevron USA1s Philadelphia Refinery and was also the Civil/Structural group supervisor. Developed project estimate & schedule input for the projects, prepared designs and calculations for structural steel & concrete structures as well as foundation design for piping, equipment, the process columns & buildings. Prepared and wrote specification for procurement of materials and construction. Prepared the "Civil/Structural Design Criteria" for Chevron USA1s Philadelphia Refinery. Performed inspection of existingrefinerystructures and bridges etc. on request. Prepared design for site development, paving, grading and drainage for the project site.

United Engineers&Constructors (Senior Engineer) - 2 years As a Senior Structural Engineer on projects for Savannah River Site, I was responsible for preparing project estimates and was also responsible for structural steel design for the "Replacement High Level Waste Evaporator" project. Earlier, I worked on Allegheny Power project and was responsible for design of reinforced concrete and soil stabilized catchment basins in addition to other civil jobs on the project.

Stone& Webster Engineering Corp. (Senior Engineer - Design) - 2 1/2 Years Responsible for design and analysis of plant structures and pipe supports for Texas Utilities Generating Co.1s Comanche Peak Steam Electric Station Unit 1.

United Engineers&Constructors (Senior Engineer) - 6 years Group Leader and responsible for design of various support structures for Public Service Co. of New Hampshire's Seabrook Station. Was closely associated and actively engaged in creating "clamping criteria" for I &c tubing. Earlier, worked as a design engineer on Delmarva Power & light's Coal conversion project and was responsible for design of pressurized structural steel ducts for flue gases & their support structures. I was responsible for the design of support structure for the precipitator and other equipments for the station.

BA-10

Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 JAGDISH NARULA (Continued)

All-states Design & Engineering Co. (Design Engineer) - 1 year Assigned to DuPont's Maydown & Victoria Plant Projects, I was engaged in structural design of process buildings and foundation design of process columns/tanks & building structures. I was also involved in design of under-ground piping and surface run-off calculations.

International Airports Authority (Executive Engineer) - 2 years As Executive Engineer (Structural Design) in the planning division of International Airports Authority of India, I was intimately involved in the design of cargo buildings, hangers, additions and alterations to terminal buildings, office complexes and residential buildings.

Delhi College of Engineering (Assistant Professor) - 10 years In this span of 10 years in teaching at Delhi College of Engineering, Ihave taught various CM/Stn.K::tl.lrl Enpjneering courses to BS. and M.S. leiel students and offered oonsultaocyto construction companies. Iwas also the department in-dlargeoftherollege CXJl10'ete lab.

EDUCATION:

B.S. Civil Engineering M.S. Structural Engineering PROFESSIONAL AFFILIATIONS:

Registered Professional Civil Engineer, Pennsylvania BA-11

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Limerick Generating Station Unit 2 Appendix BA Correspondence No. RS-15-038 Tracey L. Gallagher EDUCATION Pennsylvania State University, B.S. Civil Engineering, 2007 EXPERTISE

Steel Design and Analysis

Concrete Design and Analysis

Foundation Design and Analysis

Nuclear Design Requirements

Seismic Analysis of New and Existing Structures

Evaluation of Underground Commodities

Blast Analysis Requirements

Design Basis Programs: STAAD Pro., GTStrudl, PCA Column, APlan, MathCAD, Visio, Excel, AutoCAD EXPERIENCE Exelon Generation (7/2012 - Present)

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

Responsible for oversight of vendors performing the seismic walkdowns in the plant.

Reviewed reports prepared by vendors for technical accuracy prior to NRC submittal.

Completed design change packages for the Control Rod Blade (CRB) Rack Installation in the Unit 3 Spent Fuel Pool at PBAPS. Reviewed design drawings and calculations submitted by vendors. Responsible for ensuring that the lifting devices were in compliance with the station heavy load procedures, NUREG 0612 and ANSI N14.6-1978. Provided installation support and interfaced with multiple vendors to support the fast tracked schedule.

Completed design change package for the NETCO rack inserts in the Unit 2 Spent Fuel Pool rack cells as part of the implementation process to resolve the degraded boraflex issue. Responsible for reviewing test results and calculations that evaluate the structural and seismic aspects of the inserts as well as the associated impacts on the existing storage racks and structures. Interfaced with Regulatory Assurance to revise the UFSAR licensing basis to document the neutron absorbing capability of the new inserts after the receipt of the NRC approval of the license amendment.

Lead Structural Engineer on the Adjustable Speed Drive (ASD) project. Completed structural review for fatal flaws of ASD conceptual design submitted by vendor.

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

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

Duke Power Company

Provided design engineering and onsite installation support for the Protected Service Water (PSW) Building Project associated with Oconee Nuclear Station's BA-13

Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 Tornado and High Energy Line Break (HELB) Mitigation License Amendment.

Performed calculations for seismic equipment mounting, pipe supports and embedded plates.

PSE&G (Salem & Hope Creek Power Stations)

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

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

Design and Analysis of various lifting lugs/steel structures to meet the regulatory requirements of NUREG 0612 and ANSI 14.6 "Special Lifting Devices"

Lead Engineer on the Feedwater Heater Tube Bundle Replacement Project.

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

Lead Engineer on the replacement of the Reactor Pressure Vessel (RPV) Head Strongback and Carousel. Completed the analysis of the existing RPV Head Pedestals to meet seismic II/I requirements. Knowledge of safe load path requirements for equipment on the refueling floor of the reactor building.

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

Dominion Power Company

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

Evaluated underground commodities in support of the heavy haul path and performed the evaluation of the existing Turbine Bldg. steel for the additional lifted load of the new generator which exceeded the allowable load in the original design calculation.

Exelon

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

Engineering Intern, Public Works Dept PENNDOT- District 5-0 -Allentown, PA (5/2005 - 8/2005)

Engineering Intern QUALIFICATIONS AND TRAINING EPRI Seismic Walkdown Engineer (SWE) training, 2012 BA-14

Limerick Generating Station Unit 2 Appendix BA Correspondence No. RS-15-038 MEMBERSHIPS Member, Phi Sigma Rho - National Engineering Sorority Member, Women in Nuclear (WIN)

Member, North American Young Generation in Nuclear (NAYGN)

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Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 at Civil of BA-18

Limerick Generating Station Unit 2 Appendix BA Correspondence No RS-15-038 er=1211 >' H Certificate of Completion Juan Lopez Ferrer Training on Near Term Task Force Recommen dation 2.3

- Plant Seismic Walkdowns June 21, 2012

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Robert K. Kassawara EPRI Manager, Structural Reliability & Integrity BA-19

Limerick Generating Stati on Unit 2 Appendix BA Correspondence No .. RS-15-038

<Presents tnis Cettificate ofJlchievement IJ'o Certify <Jliat BA-20

Limerick Generating Station Unit 2 Correspondence No .. RS-15-038 Appendix BA Joseph P. Dullinger, P.E.

PROFESSIONAL

SUMMARY

gained from Well-versed and enthusiastic Structural Engineer with great attention to detail

Extensive knowledge with peers to provide both hands-on experience and relevant industry experience

Ability to work collaborat ively

Positive mentor for Junior high quality, innovative, safe and cost effective designs using a variety of materials Engineers PROFESSIONAL EXPERIENCE Engineer - Novembe r 2012 - Present Exelon Corporati on - Limerick Generatin g Station, Pottstown , PA Power Plant Lead Responsible Engineer (LRE) responsible for major capital modificatio ns (> $1M) to Nuclear and systems, structures and components. Civil/Structural/Seismic Engineer responsible for defending maintainin g the design basis of the plant.

technical

Structural LRE for Fukushima FLEX Equipment Storage Buildings. Responsible for the adequacy, vendor oversight, project schedule and budget. Buildings designed to withstand wind, earthquake, tornado driven missiles, tornado winds, tornado differentia l pressure, extreme snow and temperatu res.

technical

Seismic LRE for Fukushima NTIF 2.1 Seismic Hazard Evaluation. Responsible for the Limerick adequacy, vendor oversight, project schedule and budget for the seismic hazard reanalysis of newly developed EPRI Seismic GMRS Hazard Curves.

Generating Station with incorporat ion of Responsible for developm ent of the hazard report submittal to the NRC.

Structural Engineer - July 2011- October 2012 RETTEW Associates, Lancaster, PA buildings, Structural Engineer responsible for the analysis and design of new and existing structures involving unication frames, and other miscellane ous overhead cranes, lifting devices, retaining walls, tanks, telecomm structures for industrial, energy, commercial, institutiona l, and municipal clients.

capacity,

Responsible for design calculations and details, assessment of existing structural and/or replaceme nt of existing structural steel framing and recommendations for reinforcem ent structural inspections at an active steel mill.

mill to

Investigated and determine d what caused part of an existing bag house structure at a steel and collapse and was responsible for the design of temporary supports and strengthen ing of framing did not collapse further. Discovered design flaws that did connections to ensure that the structure not meet strength criteria which was determine d to be one of the causes of the structure collapse.

three-

Responsible for the design and detailing of various below the hook-liftin g devices using dimensional building informatio n modeling and finite element analysis software.

they were

Review of design drawings for a $60 million reheat furnace addition to determine if modificatio ns to existing designed and detailed according to code. Designed and detailed stairs, crane stops, and modificatio n of building bracing for new furnace addition.

early

Inspected crane runways in the steel-making mill building that was built in the late 1800s and 1900s. The inspection included crane columns, crane girders, column bases, and all associated connections. Assisted writing a report that detailed the defects and classified their severity.

BA-21

Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 JOSEPH P. DULLINGER, P.E.

PAGE 2 OF 2 Structural Engineer - February 2009 - May 2011 Zug & Associates, Ltd., Lititz, PA Served as a Structural Engineer to deliver practical, constructible analysis and design services to architects, contractors, facility owners and homeowners throughout the Northeast United States; gained vast knowledge and experience from senior engineer and owner with 30 +years experience in Structural Engineering.

Structural analysis and design of new and existing institutional, commercial, industrial, residential and municipal facilities using steel, masonry, timber, precast and cast-in-place concrete

Performed gravity analysis and design, lateral analysis and design, and foundation design

Structural building surveys, adaptive reuse analysis and design, and historic renovation

Shop drawing review, construction observation and prepared structural specifications Structural Engineer - December 2007 - February 2009 Dutch/and Inc., Gap, PA Served leading precast concrete tank manufacturer as a Structural Engineer to provide practical, constructible and cost effective products.

Structural analysis and design of precast and cast-in-place concrete treatment plants

Designed precast post-tensioned reinforced concrete tanks (rectangular & circular)

Innovative designs to reduce cost and increase product performance

Plan review, plan submittal, design review and construction observation EDUCATION B.S. in Structural Design and Construction Engineering Technology (Design Option)

Penn State University - Capital Campus, Middletown, PA Coursework in Electrical Engineering Penn State University - Capital Campus, Middletown, PA Professional Engineer (P.E.)

Commonwealth of Pennsylvania - No. PE083228 BA-22

Limerick Generating Station Unit 2 Appendix BA Correspondence No. RS-15-038 Madalin O'Brien Civil/Structural Senior Engineer Civil/structural engineer with twenty plus years of experience in the nuclear power industry and two years in the commercial construction industry.

Experience 2012 - Present Civil/Structural Senior Engineer, Exelon Nuclear Corporation, Pottstown, Pennsylvania Limerick Generating Station.

Senior Structural Engineer working in design engineering and currently in major plant modifications branch as the lead responsible engineer on large projects.

2003-2009 Civil/Structural Senior Engineer, BCP Engineering & Consulting Technical Services, Welsh, Minnesota & Monticello, Minnesota.

Xcel Energy, Prairie Island Nuclear Power Plant and Monticello Nuclear Power Plant.

Lead Civil/Structural Engineer on the License Renewal Project responsible for originating and or reviewing all civil/structural sections of the License Renewal Application (LRA) in accordance with Title 1O of the "Code of Federal Regulations" Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants". Reviewed plant documents including structural drawings, specifications, design bases documents (DBDs), safety analysis reports (SARs),

plant procedures, equipment databases, and vendor submittals, using criteria outlined in license renewal guidance documents (e.g., NUREG-1800, NUREG-1801, and NEI 95-10) to identify structures that performed a design function important to plant safety. Performed evaluations to determine structural aging effects utilizing industry documents on aging (e.g., EPRI and ACI), and based on material and environmental factors, determined if aging management was required for the extended period of operation. Created technical reports identifying plant specific aging effects for the various components, materials, and plant environments that could cause structures to degrade. Generated Scoping and Screening Reports (SSR) and Aging Management Review Reports (AMR),

and originated and revised plant drawings to document the relicensing process.

Enhanced existing plant inspection procedures or developed new procedures focusing on aging effects to be monitored, methods of inspection, inspection frequencies, acceptance criteria, and processes to evaluate degraded structural conditions. Generated Aging Management Programs (AMP) namely, structures monitoring, masonry walls, water-control structures, cranes and hoists, pressure-retaining components (IWE and IWF), and plant coatings. Provided the contents for structural sections of the LRA. Responded to questions (RAls) raised by the Nuclear Regulatory Commission Staff during project audits. Generated addendums, commitments, and changes to the LRA. Other duties included structural walkdowns, developing and maintaining component databases, scheduling activities to meet milestones, coordinating with mechanical and electrical disciplines, and attending project meetings.

Page 1 of 4 BA-23

Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 Madalin O'Brien Civil/Structural Senior Engineer Resume 1999 - 2003 Civil/Structural Senior Engineer, Parsons E&C, Reading, Pennsylvania.

Progress Energy Carolinas. Designed equipment concrete foundations on grade, retaining walls, piers, and other miscellaneous structural components using computer program based design applications.

Tennessee Valley Authority, Browns Ferry Nuclear Power Plant; Pennsylvania Power & Light, Susquehanna Steam Electric Station; and Exelon Corporation, Dresden Nuclear Power Plant, Quad Cities Nuclear Power Plant, and, Peach Bottom Atomic Power Station.

License renewal engineer responsible for relicensing nuclear power plants.

As part of the relicensing process (Title 1O of the "Code of Federal Regulations" Part 54), reviewed numerous plant documents to identify structures that perform a function important to plant safety. Reviewed plant inspection results for evidence of age-related degradation. Performed structural evaluations to determine plant specific aging effects based on environmental stressors and materials of construction and determined if aging management was needed. Created technical reports identifying all aging effects that could degrade plant structures, and generated Aging Management Review Reports (AMR) to document the aging effect evaluations. Evaluated plant inspection procedures to determine if structures are adequately managed for degradation due to aging. Enhanced existing plant procedures or generated new procedures to manage the aging effects. Generated License Renewal programs (AMP) including the Structures Monitoring Program, Masonry Wall Program, and RG 1.127 Program. Reviewed AMR Reports on fire protection, containment internals, structural steel, and cranes and hoists. Technical reviewer for the civil/structural sections of the LRA.

Other duties included maintaining component databases, scheduling activities to meet milestones, coordinating with other disciplines, and attending project meetings.

1997 - 1999 Civil/Structural Engineer, Sargent & Lundy, Lusby and Prince Frederick, Maryland.

Baltimore Gas & Electric Company, Calvert Cliffs Nuclear Power Plant.

Generated proposals for the independent spent fuel storage facility. As part of the heat exchanger replacement project under the guidance in NUREG-0612, "Control of Heavy Loads at NPP", analyzed existing structural steel flooring for the installation of new plate and shell heat exchangers. As a result of the analysis, redesigned connections, beams, and columns, and generated new fabrication/installation drawings. Developed an engineered rigging package including detailed instructions for the removal and installation of all components associated with the heat exchanger replacement project. Generated calculations to evaluate existing structures for anticipated rigging loads, and designed new wood and steel support structures and scaffolding to facilitate heavy load movement. Generated modification packages requiring 50.59 screening, design instructions, design input requirements, nuclear significance screening, specifications, bill-of-materials, and design calculations for the new saltwater Page 2 of 4 BA-24

Limerick Generating Station Unit 2 Appendix BA Correspondence No.: RS-15-038 Madalin O'Brien Civil/Structural Senior Engineer Resume chemical addition system. Packages included the design of equipment concrete foundations, plastic and metal piping, equipment and HVAC supports, catwalks, and the system housing structure. Provided unit outage coverage.

1991 - 1995 Civil/Structural Engineer, Bechtel Corporation, Decatur, Alabama.

Tennessee Valley Authority, Browns Ferry Nuclear Power Plant. Performed computer aided finite element analysis of structural building steel, HVAC systems, piping systems, and the design of support systems for electrical and mechanical components. Prepared Design Change Packages (DCP) requiring field inspections, design calculations, drawing development, and cost analyses.

Prepared and reviewed design calculations and drawings. Worked with the following design standards, AWS, ANSI, AISC, ACI, ASME, ASTM, and AISI.

Trained engineers to used computer programs for various structural design applications. Worked to re-establish plant design configuration (Design Bases Document evaluations) entailing engineering walkdowns, calculations, and drawing updates.

1990 - 1991 Project Engineer/Project Manager, Charles H. Tompkins Company, Washington, D.C.; College Park, Maryland.

1310 G. Street office building and library at the University of Maryland.

Utilized commercial building contracts, specifications, scheduling sequencing, and engineering principals to engineer and manage the construction of a new thirteen story office building (1310 G. Street, Washington, D.C.) and the renovation of an existing library (McKeldin Library, University of Maryland). Provided cost engineering work-ups. Generated change proposals and change orders. Liaison between the architect and contractors. Scheduled and tracked construction activities. Participated in meetings with architect, owner, and tradesmen.

Resolved drawing discrepancies, interpreted specifications, and resolved contractor questions. Responsible for quality and safety engineering duties.

1979 - 1989 Civil/Structural Engineer, Bechtel Corporation, Gaithersburg, Maryland; Lusby, Maryland; Buckeye, Arizona; Waynesboro, Georgia.

Baltimore Gas & Electric Company, Calvert Cliffs Nuclear Power Plant; Arizona Public Service Company, Palo Verde Nuclear Generating Station; Georgia Power Company, Vogtle Electric Nuclear Generating Station.

Performed seismic analysis of structural steel, welded and bolted connections, ductwork (HVAC), duct supports, electrical equipment cabinets, control panels, and conduit and cable tray supports. Designed pipe supports to include pipe anchors, hydraulic and mechanical snubbers, sway struts, guides, spring supports, and rigid supports. Performed equipment qualification evaluations and reviewed vendor qualification reports for adherence to project criteria and industry standards. Prepared design change notice (DCN) packages requiring feasibility walkdowns. Evaluated building sites for excavation/backfill, and analyzed masonry block walls for new penetrations. Generated field information requests Page 3 of 4 BA-25

Limerick Generating Station Unit 2 Appendix BA Correspondence No .. RS-15-038 Madalin O'Brien Civil/Structural Senior Engineer Resume (FIR), and field change notices (FCN). Liaison between engineering and construction, resolved drawing discrepancies, and responded to questions on design specifications during construction. Designed heavy equipment concrete foundations and slabs. Analyzed underground corrugated piping and ductbanks.

Supervised tests on concrete fasteners (expansion anchors) for strength requirements and documented the results. Inspected structural steel bolted and welded connections for compliance to design documents. Provided classroom instruction for trade personnel on drawing interpretation. Performed inspections on the containment structure for crack propagation during pressurization testing.

Education and Skills

A.S., Architectural Engineering, Delaware Technical Community College, 1977

B.S., Civil Engineering, Pennsylvania State University, 1979

Graduate Program, Structural Engineering, George Washington University, 1981

Structural Design Programs: Strudl, STAAD, SAP, BASEPLATE II, ME210, CONN1, CONAN, MathCAD, RISA, and Generic CAD

Word Processing Programs: MS Word, MS Excel, MS Access, MS Outlook, and MS PowerPoint Page 4 of 4 BA-26

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Appen dix BC Seismic Walkdown Checklists (SWCs)

Table 8C-1 provides a description of each supplemental internal cabinet inspection item.

All items in Table 8C-1 were deferred items listed in Table E-2 of the initial report submitted in November 2012 (Ref. 81, Section 89), and were accessible during the follow-on supplemental walkdowns.

Table BC-1. Summary of Internal Electrical Cabinet Inspection Checklists Anchorage Area Component Configuration Walk- Comments Description ID Confirmed? By Anchorage Configuration and A RPS & UPS Distribution Confirmation and Area Walk-2A-D160 NIA NIA By is shown in Appendix C of Panel Static Inverter Ref B1 (Section B9)

Anchorage Configuration and B RPS & UPS Distribution Confirmation and Area Walk-28-D160 NIA NIA By is shown in Appendix C of Panel Static Inverter Ref B1 (Section B9)

Anchorage Configuration and Confirmation and Area Walk-2D-D103 125V DC Battery Charger NIA NIA By is shown in Appendix C of Ref B1 (Section B9) 8C-1

Limerick Generating Station Unit 2 Appendix BC Correspondence No. RS-15-038 Sheet 1of2 Status: (I] N U Seismic Walkdown Checklist (SWC) SUPPLEMENTAL CABINET INSPECTION Equipment ID No.: 2A-D160 (SEE APPENDIX C PAGE C-170)

Equipment Class: (16) Battery Chargers and Inverters Equipment

Description:

A RPS & UPS DISTRIBUTION PANEL STATIC INVERTER Project: Limerick Unit Limerick Unit 2 SWEL Location (Bldg, Elev, Room/Area): Control Building, 254 ft Elevation, Unit 2 Inverter Roomnit 2 Inverter Room Manufacturer/Model: THOMAS & BETTS POWER SOLUTIONS/2401301FC1 Instructions for Completing Checklist This checklist may be used to document the results of the Seismic Walkdown of an item of equipment on the SWEL. The space below each of the following questions may be used to record the results of judgments and findings. Additional space is provided at the end of this checklist for documenting other comments.

Anchorage

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

of SWEL items requiring such verification)?

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

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

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

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

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

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

SEE SWC IN APPENDIX C FOR RESPONSES Interaction Effects

7. Are soft targets tree from impact by nearby equipment or structures?

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

9. Do attached lines have adequate flexibility to avoid damage?

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

SEE SWC IN APPENDIX C FOR RESPONSES Page BC-2

Limerick Generating Station Unit 2 Appendix BC Correspondence No .. RS-15-038 Sheet 2 of 2 Status: (YJ N U Seismic Walkdow n Checklis t (SWC) SUPPLEMENT AL CABINE T INSPECTION Equipment ID No.: 2A-D160 APPENDIX C PAGE C*1

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A RPS & UPS DISTRIBUTION PANEL STATIC INVERTER Other Adverse Conditio ns (SUPPLEMENTAL CABINE T INSPECTION)

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

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

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Limerick Generating Station Unit 2 Appendix BC Correspondence No .. RS-15-038 Sheet 1of2 Status: IT] N U Seismic Walkdown Checklist (SWC) SUPPLEME NT AL CABINET INSPECTION Equipment ID No.: 2B-D160 (See Appendix C Page C-222)

Equipment Class: (16) Battery Chargers and Inverters Equipment

Description:

B RPS & UPS DISTRIBUTION PANEL STATIC INVERTER Project: Limerick U2 SWEL Location (Bldg, Elev, Room/Area): Control, 254 ft, 453

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Manufacturer/Model: THOMAS & BETTS POWER SOLUTIONS/ Model 2401301FC1 Instructions for Completing Checklist This checklist may be used to document the results of the Seismic Walkdown of an item of equipment on the SWEL. The space below each of the following questions may be used to record the results of judgments and findings. Additional space is provided at the end of this checklist for documenting other comments.

Anchorage

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

of SWEL items requiring such verification)?

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

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

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

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

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

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

SEE SWC IN APPENDIX C FOR RESPONSES Interaction Effects

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

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

9. Do attached lines have adequate flexibility to avoid damage?

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

SEE SWC IN APPENDIX C FOR RESPONSES Page BC-4

Limerick Generating Station Unit 2 Appendix BC Correspondence No .. RS-15-038 Sheet 2 of 2 Status: IT] N U Seismic Walkdown Checklist (SWC) SUPPLEMENTAL CABINET INSPECTION Equipment ID No.: 2B-D160 (See Appendix C Page C-222)

Equipment Class: (16) Battery Chargers and Inverters Equipment

Description:

B RPS & UPS DISTRIBUTION PANEL STATIC INVERTER Other Adverse Conditions (SUPPLEMENTAL CABINET INSPECTION)

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

a. Internal components secured? (i.e. no loose or missing fasteners) G)N U~

b. Are adjacent cabinets secured together? YNU\!U

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Limerick Generating Station Unit 2 Appendix BC Correspondence No .. RS-15-038 Status:~ N U Seismic Walkdown Checklist (SWC) SUPPLEMENTAL CABINET INSPECTION Equipment ID No.: 2DD103 (2BCD) (SEE APPENDIX C PAGE C-289)

Equipment Class: (16) Battery Chargers and Inverters Equipment

Description:

125V DC BATTERY CHARGER 2DD103 (1E-D)

Project: Limerick 2 SWEL Location (Bldg, Elev, Room/Area): Control, 217 ft, 360

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Man ufact ure r/ModeI: C & D BATTERIES (ELTRA CORP)/ Model ARR130HK75F3 Instructions for Completing Checklist This checklist may be used to document the results of the Seismic Walkdown of an item of equipment on the SWEL. The space below each of the following questions may be used to record the results of judgments and findings. Additional space is provided at the end of this checklist for documenting other comments.

Anchorage

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

of SWEL items requiring such verification)?

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

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

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

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

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

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

SEE SWC IN APPENDIX C FOR RESPONSES Interaction Effects

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

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

9. Do attached lines have adequate flexibility to avoid damage?

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

SEE SWC IN APPENDIX C FOR RESPONSES Page BC-6

Limerick Generating Station Unit 2 Appendix BC Correspondence No. RS-15-038 Seismic Walkdown Checkllst (SWC) SUPPLEMENTAL CABINET INSPECTION Status: m N U Equipment ID No.: 2DD103 (2BCD) (SEE APPENDIX C PAGE C-289)

Equipment Class: (16) Battery Chargers and Inverters Equipment

Description:

125V DC BATTERY CHARGER 2DD103 (1E-D)

Other Adverse Conditions (SUPPLEMENT AL CABINET INSPECTION)

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

a. Internal components secured? (i.e. no loose or missing fasteners) f:?j N U

b. Are adjacent cabinets secured together? Y~U

c. No other adverse seismic conditions? NU Comments Temporary cabling was connected to the DC terminal block in support of the battery/battery charge PM under WO R1194235. This will be removed at completion of the PM and is acceptable.

Evaluated by: __:_Tr:..::a=.:ce:t..y-=G=a=lla~g.:..:.:he:..:..r-"""111!:..1£!!~~-ld~~~~--- Date: <t/fl /LJ Jesse Lucas '-1/1 /11 Photos None Page BC-7

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Append ix BF Peer Review Report This appendix includes the Peer Review Team's report on the follow-on seismic Walkdowns and Walk-Bys.

BF-1

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Peer Review Report

-for Near Term Task Force (NTTF} Recommendation 2.3 Seismic Walkdown Inspection

-Of Limerick Generating Station Unit 2 Annex B March 9, 2015 Peer Reviewers:

Robert B. Wehrman (Team Leader)

Joseph Dullinger Madalin O'Brien Robert B. Wehrman I 311/!S-Peer Review Team Leader Signature Date BF-2

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 Contents 1 Introduction ........................................................................................................ BF-4 1.1 Overview ..................................................................................................................... BF-4 1.2 Peer Reviewers ........................................................................................................... BF-4 1.3 SWEL Development.. .................................................................................................. BF-5 1.4 Seismic Walkdown ...................................................................................................... BF-5 2 Peer Review - Selection of SSCs ...................................................................... BF-6 2.1 Purpose ....................................................................................................................... BF-6 3 Review of Sample Checklist & Area Walk-Bys ................................................ BF-7 3.1 Overview ..................................................................................................................... BF-7 3.2 Follow-on Seismic Walkdown Checklists .................................................................... BF-7 3.3 Evaluation of Findings ................................................................................................. BF-8 4 Review of Licensing Basis Evaluations ........................................................... BF-9 5 Review Final Submittal Report & Sign-off ..................................................... BF-10 6 References ....................................................................................................... BF-11 BF-3

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 1 Introduction 1.1 OVERVIEW This report documents the independent peer review for the Near Term Task Force (NTTF) Recommendation 2.3: Seismic Walkdown, Annex 'B' follow-on activities performed by Exelon Limerick Generating Station Engineering Department for Unit 2 of Limerick Generating Station (LGS). This peer review includes review of pages iv through vi of Report RS-12-171 as updated to reflect Annex 'B'. The peer review addresses the following activities:

Review of the selection of the structures, systems, and components, (SSCs) included in this follow-on Seismic Walkdown. The SWEL was not revised; therefore a review of the selection of SSCs was not required.

Review the checklists of the items completed during the follow-on Seismic Walkdowns.

Review of any licensing basis evaluations. No new licensing basis evaluations were performed; therefore a review of licensing basis evaluations was not required.

Review of the decisions for entering the potentially adverse seismic conditions identified during the follow-on walkdowns into the plant's Corrective Action Program (CAP).

Review of the final submittal report.

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

1.2 PEER REVIEWERS The Peer Reviewers for LGS, Unit 2 are Robert Wehrman, Joseph Dullinger, and Madalin O'Brien are all Exelon engineers. Mr. Wehrman is the Peer Review Team Leader, per the EPRI Seismic Walkdown Guidance (Reference 1, Section 9). As Peer Review Team Leader, he was responsible for the entire peer review process, including completion of the final peer review documentation in this report. The Peer Reviewers' qualifications are briefly summarized as follows:

Mr. Wehrman is a degreed mechanical engineer and has over 6 years of nuclear power experience, and is knowledgeable in seismic/structural design.

Mr. Dullinger is a degreed structural engineer and has 3 years of nuclear experience, and is knowledgeable in seismic/structural design.

Mrs. O'Brien is a degreed structural engineer and has over 20 years of nuclear power experience, and is knowledgeable in seismic/structural design.

BF-4

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 All peer reviewers are familiar with the EPRI Walkdown Guidance Document 1025286.

This peer review covered information provided in Annex B. A selection of Unit 2 Seismic Walkdown Checklists (SWCs) were reviewed by B. Wehrman and J. Dullinger.

Observations of walkdowns were performed by B. Wehrman. Review of the final report was performed by M. O'Brien and verified to include the required information for Annex B. No issues were identified which challenged the current licensing basis.

1.3 SWEL DEVELOPMENT See Section 84 of Annex B, no changes were made to the SWEL for the follow-on walkdowns.

1.4 SEISMIC WALKDOWN The peer review of the follow-on seismic walkdowns was performed by Mr. Wehrman and Mr. Dullinger. The review included Seismic Walkdown Checklists (SWCs) applicable to the equipment including checklists, photos, and drawings where applicable.

Interviews were conducted with SWE team to assess conduct of the walkdowns and adherence to the EPRI Seismic Walkdown Guidance (Reference 1, Section 9). The discussion of the review of the SWCs is provided in Section 3.

The assessment of condition reports (I Rs) with respect to current licensing basis is provided in Section 4. There were no conditions found during the follow-on walkdowns and therefore no licensing basis evaluations to determine if equipment complied with current seismic licensing basis requirements were required.

BF-5

Limerick Generating Station Unit 2 Corresponden ce No.: RS-15-038 2 Peer Review - Selection of SSCs 2.1 PURPOSE The purpose of this section is to describe the process to perform the peer review of the selected structures, systems, and components, (SSCs) that were included in the Seismic Walkdown Equipment List (SWEL).

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

BF-6

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 3 Review of Follow-On Seismic Walkdown & Area Walk-By Checklists 3.1 OVERVIEW A peer review of the remaining (Annex 'B') Seismic Walkdowns was performed by Mr.

Robert Wehrman and Mr. Joseph Dullinger. The Peer Review Team reviewed Seismic Walkdown Checklists (SWCs) and interviewed the walkdown team members regarding details in checklists.

3.2 FOLLOW-ON SEISMIC WALKDOWN CHECKLISTS Greater than 25% of the Limerick Generating Station Unit 2 equipment inspected during the follow-on walkdown are included in the peer review. See follow-on Seismic Walkdowns presented below:

Table BF3-1. Follow-On Seismic Walkdown Checklists Component ID Description Observations A RPS & UPS Distribution No issues or concerns 2A-D160 identified.

Panel Static Inverter B RPS & UPS Distribution No issues or concerns 2B-D160 identified.

Panel Static Inverter No issues or concerns 2D-D103 125V DC Battery Charger identified.

BF-7

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 3.3 EVALUATION OF FINDINGS There were no issues that challenged the licensing basis.

The outcome of the walkdowns indicated that there were no major concerns from the inspections conducted. No adverse conditions were found during the follow-on supplemental electrical equipment walkdowns performed.

BF-8

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 4 Review of Licensing Basis Evaluations There were no instances identified during the follow-on walkdowns where evaluated components could not readily be shown to meet the plant seismic licensing basis.

Accordingly, no licensing basis evaluations to determine if equipment complied with current seismic licensing basis requirements were required.

BF-9

Limerick Generating Station Unit 2 Correspond ence No.: RS-15-038 5 Review Final Submittal Report & Sign-o ff The entire final supplement al report of Annex B has been reviewed by Mr. Robert Wehrman and Mr. Joseph Dullinger and found to meet the requiremen ts of EPRI Seismic Walkdown Guidance, 11 submittal.

EPRI Report 1025286( . Annex B covers the necessary open items from the original 21 letter are The Peer Review determined that the objectives and requiremen ts of the 50.54(f)l met for Annex B. Additionally, the efforts completed and documente d within the final submittal report are in accordance with the EPRI guidance document.

BF-10

Limerick Generating Station Unit 2 Correspondence No.: RS-15-038 6 References

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

2. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012, ADAMS Accession Number ML12053A340 BF-11

RS-15-038, Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

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Text

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1.1 BACKGROUND

1.2 BACKGROUND

1.5 CONCLUSION

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RS-15-038, Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

Text

Subject:

References:

Enclosure:

1.1 BACKGROUND

1.2 BACKGROUND

1.5 CONCLUSION

SUMMARY

SUMMARY

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