CNS-13-007, Response to Request for Additional Information Regarding the Seismic Hazard Walkdowns Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns

Response to Request for Additional Information Regarding the Seismic Hazard Walkdowns Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns

ML13338A280
Person / Time
Site:	Catawba
Issue date:	12/02/2013
From:	Henderson K Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-13-007
Download: ML13338A280 (14)

Text

Kelvin Henderson DUKE Vice President ENERGY. Catawba Nuclear Station 803-701-4251 CNS-1 3-007 Duke Energy December 2, 2013 CNO1VP I 4800 Concord Rd.

York, SC 29745 ATTN: Document Control Desk 10 CFR 50.54 (f)

U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Duke Energy Carolinas, LLC (Duke Energy)

Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Renewed License Nos. NPF-35 and NPF-52

Subject:

Response to Request for Additional Information Regarding the Seismic Hazard Walkdowns Associated With Near-Term Task Force Recommendation 2.3, Seismic Walkdowns

References:

1. NRC Letter, Request for Information Pursuantto 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-ichiAccident, dated March 12, 2012, ADAMS Accession No. ML12053A340

2. Electrical Power Research Institute (EPRI) Seismic Walkdown Guidance, For Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, EPRI Report 1025286, dated 2012, ADAMS Accession No. ML12188A031

3. Duke Energy Letter, Duke Energy Carolinas,LLC (Duke Energy) Catawba Nuclear Station (CNS), Units I and 2, Docket Nos. 50-413 and 50-414, Renewed License Nos.

NPF-35 and NPF-52, Response to NRC Request for Information Pursuantto Title 10 Code of Federal Regulations 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 27, 2012

4. Duke Energy Letter, Duke Energy Carolinas,LLC (Duke Energy) Catawba Nuclear Station (CNS), Unit 1, Docket No. 50-413, Response to NRC Request for Information Pursuantto Title 10 Code of Federal Regulations 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichiAccident, dated March 28, 2013, ADAMS Accession No. ML13162A092

5. NRC Letter, Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns dated November 1, 2013, ADAMS Accession No. ML13304B418 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued a letter requesting information per Title 10 to the Code of Federal Regulations, Section 50.54(f) (i.e., Reference 1). Ab www.duke-energy.com

United States Nuclear Regulatory Commission December 2, 2013 Page 2 The letter requested licensees to conduct seismic hazard walkdowns to verify current plant configuration with the current licensing basis (CLB).

Duke Energy Carolinas, LLC (Duke Energy) conducted the requested walkdowns using the NRC endorsed, Electric Power Research Institute (EPRI) guidance (i.e., Reference 2). Duke Energy submitted seismic walkdown reports for Catawba Nuclear Station (CNS) by letters dated November 27, 2012, and March 28, 2013, (i.e., References 3 and 4). By letter dated November 1, 2013, (i.e., Reference 5) the NRC has requested additional information related to the seismic walkdowns. The Duke Energy response for CNS is enclosed.

This letter contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Phil Barrett at (803) 701-4138.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 2, 2013.

Sincerely, Kelvin Henderson Vice President, Catawba Nuclear Station

Enclosure:

Catawba Nuclear Station Response Units 1 and 2 to the NRC Request for Additional Information Regarding Seismic Walkdowns

United States Nuclear Regulatory Commission December 2, 2013 Page 3 xc (with enclosures):

V. M. McCree, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 J. C. Paige, Project Manager (CNS & MNS)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 G. A. Hutto NRC Senior Resident Inspector Catawba Nuclear Station J. Folkwein American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453

Enclosure Catawba Nuclear Station Units 1 and 2 Response to the NRC Request for Additional Information Regarding Seismic Walkdowns E1

Enclosure Catawba Nuclear Station Units I and 2 Response to the NRC Request for Additional Information Regarding Seismic Walkdowns NRC Question 1: Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs), dispositioning of issues, and reporting As a result of the audits and walkdown report reviews, the NRC staff noted that licensees' interpretations of the seismic walkdown guidance varied, which resulted in meaningful differences in the process used to disposition identified issues and in the documentation that was provided to the NRC staff. In particular, the application of engineering judgment in determining what constituted a potentially adverse seismic condition (PASC), the threshold for conducting licensing basis evaluations (LBEs), and determining what information was to be reported to the NRC staff varied.

The NRC staff intended that conditions initially marked No (N) or Unknown (U) in the field by the seismic walkdown engineers (SWEs) for which an analysis or calculation was performed would be considered as PASCs and that an analysis orl calculation constituted an LBE. The walkdown guidance allows for analysis as part of engineering judgment; however, the intent was to allow for only simple analyses that could be readily performed in support of engineering judgment.

Further, the walkdown activities were intended to allow for transparency in the licensee's process to demonstrate that PASCs were appropriately identified, that they were addressed in an appropriate manner, and the basis documented such that the current condition of the plant was clearly consistent with the CLB with regard to seismic capability.

During the audits, the NRC staff identified examples of field observations that were deemed not to be PASCs. However, the basis for the determination was not clearly recorded. In some cases, the field checklists were amplified by noting that the basis was engineering judgment.

During site audit discussions, the staff was able to trace the basis for the engineering judgments and found that in many cases they were appropriate. It is expected that these situations would not be included in the walkdown report.

There were other situations that a PASC and LBE were not reported; however, the NRC staff found during the audit that a calculation, analysis (more than just simple), or evaluation was conducted but informally. An example is a confirmatory calculation performed to demonstrate that six anchor bolts out of eight was not a seismically adverse condition. Another example would be an analysis to demonstrate that an existing, slightly short weld was as seismically sound as the prescribed weld length in the plant design documentation. The staff expected these types of conditions and evaluations to be captured in the licensee's normal plant processes (e.g., condition report or corrective action program (CAP)), and also reported in the walkdown report, since they were potentially adverse seismic conditions that required more than applying judgment or simple analysis to address.

The NRC staff also found that the process that was used to deal with a field observation that was deemed to be a PASC was also not completely described or captured in the report. In many cases, the licensee reported that an LBE was not performed. However, during the audits, it was clear that an LBE (or an equivalent determination method) was performed and used in E2

Enclosure Catawba Nuclear Station Units I and 2 Response to the NRC Request for Additional Information Regarding Seismic Walkdowns determining whether a PASC should be entered into the CAP. The staff expects that these conditions would be reported in the walkdown report.

On the whole, through the audits, the NRC staff found that it was able to conclude that the intent of the guidance was met when the licensee's overall process was completely explained, the information was updated to reflect the actual process, and results were updated. The self-assessments conducted by the licensees of the audited plants also identified the lapse in the description of the process used by the licensee to identify a PASC and disposition it.

Therefore, in order to clarify the process that was followed, please provide a description of the overall process used by the licensee (and its contractors) to evaluate observations identified in the field by the SWEs. The process should include how a field observation was determined to be a PASC or not and how the bases for determinations were recorded. Once a determination was made that an observation was a PASC, describe the process for creating a condition report (or other tracking mechanism), performing the LBE (or other determination method), and the resultant action, such as entering it into the CAP, or documenting the result and basis.

Also, in order to confirm that the reported information supports concluding that the plant meets the CLB, please follow one of the following three acceptable alternatives:

(a) Provide a supplement to the table or text from the original walkdown report, if needed, to include similar conditions as the above examples and situations and for conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination. The supplement should include a short description of each condition, how it was dispositioned and the basis for the disposition, as follows: 1) for each condition that was entered into the CAP, provide the CAP reference number, initiation date, and (if known) the planned completion date, or 2) for all other conditions, provide the result of the LBE (or other determination method), the basis for the result, and how (or where) the result was captured in the plant's documentation or existing plant process.

(b) Following the plant's standard procedures, confirm that a new CAP entry has been made to verify if appropriate actions were taken when reporting and dispositioning identified PASCs (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination). The eventual CAP closeout, including the process followed and actions taken, should be in sufficient detail to enable NRC resident inspectors to follow up.

(c) If no new conditions are identified for addition to the supplement or the CAP entry mentioned above is deemed not necessary, provide a statement of confirmation that all potentially seismic adverse conditions (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination) identified during the walkdowns and walk-bys were addressed and included in the report to the NRC.

E3

Enclosure Catawba Nuclear Station Units I and 2 Response to the NRC Request for Additional Information Regarding Seismic Walkdowns Response to Question 1:

After reading the NRC's question, and reviewing the Duke Energy submittals, this response is in accordance with NRC Question 1(c), therefore, there are no new Potentially Adverse Seismic Conditions (PASC) to report because all PASC items were addressed and included in the prior submittals.

The following is the description of the process, as discussed in Section 4.0 of the Duke Energy March 28, 2013, submittal (i.e., Reference 4) and is applicable to the process used in both units:

" "The seismic walkdowns and area walk-bys were conducted in accordance with the guidance outlined in EPRI Report 1025286. The EPRI Seismic Walkdown Checklists (SWC)s were completed for each equipment item on the SWEL. The EPRI Area Walk-By Checklists (AWC)s were completed for areas/rooms associated with SWEL equipment."

• "The component seismic walkdown inspections were primarily focused on the identification of potentially degraded component anchorage conditions, and potentially adverse seismic interactions with surrounding SSCs. For the non-line mounted components, the visual inspections assessed whether the anchorage was degraded (e.g. bent, loose, broken, missing, corroded, localized concrete cracks). Additionally, for at least 50% of the non-line mounted components, the as-built field anchorage was verified to be consistent with design documentation."

" "The area walk-by inspections were performed for SWEL equipment areas. The area walk-bys assessed whether other surrounding equipment in the area/room (up to either 35' radius around SWEL component or the entire room containing the SWEL component) had potentially degraded anchorage, or whether the potential for adverse seismic interactions were present."

" "If the Seismic Walkdown Engineers (SWEs) determined a potentially adverse seismic condition existed, [using engineering judgment based on their experience and training with the EPRI Guidance (Section 5)], then the issue was entered into the corrective action program (CAP) to allow further engineering evaluation. The CAP engineering evaluation determined whether the potentially adverse seismic condition was degraded, unanalyzed, or non-conforming to the design and licensing bases."

E4

Enclosure Catawba Nuclear Station Units I and 2 Response to the NRC Request for Additional Information Regarding Seismic Walkdowns Section 5.0 of the Duke Energy March 28, 2013, submittal (i.e., Reference 4) contained the following paragraph. While the number of PASC varied, the following wording is also representative the information provided in Section 5.0 of the plant specific reports submitted in Reference 3:

" "As shown in Table 4-1 [of the submittal], a total of 40 potentially adverse seismic conditions were identified by the seismic walkdowns and area walk-bys. Also, one issue with the anchor bolts for 0YCPUCW1 was identified during the TI-1 88 walk-down inspection with the regional NRC inspector. All of the potentially adverse seismic conditions were entered into the Corrective Action Program (CAP). Engineering evaluation of each potentially adverse seismic condition concluded that the condition was in conformance with the current licensing bases. In some cases work requests or CAP ACTIONS were initiated to correct minor issues and/or to enhance field equipment clearances."

" "The potentially adverse seismic conditions and their individual Problem Investigation Process (PIP) tracking numbers are listed in the Unit 1 NTTF 2.3 Seismic Walkdown Summary Reports (Attachment 5A and Attachment 7A [Reference 4])."

NRC Question 2: Conduct of the Peer Review Process As a result of the walkdown report reviews, the NRC staff noted that some descriptions of the peer reviewers and the peer review process that was followed were varied and, in some cases, unclear. In some cases, the staff could not confirm details of the process, such as if the entire process was reviewed by the peer review team, who were the peer reviewers, what was the role of each peer reviewer, and how the reviews affected the work, if at all, described in the walkdown guidance.

Therefore, in order to clarify the peer review process that was actually used, please confirm whether the following information on the peer review process was provided in the original submittal, and if not, provide the following.

(a) Confirmation that the activities described in the walkdown guidance on page 6-1 were assessed as part of the peer review process.

(b) A complete summary of the peer review process and activities. Details should include confirmation that any individual involved in performing any given walkdown activity was not a peer reviewer for that same activity. If there were cases in which peer reviewers reviewed their own work, please justify how this is in accordance with the objectives of the peer review efforts.

Also, if there are differences from the original submittal, please provide a description of the above information. If there are differences in the review areas or the manner in which the peer reviews were conducted, describe the actual process that was used.

E5

Enclosure Catawba Nuclear Station Units 1 and 2 Response to the NRC Request for Additional Information Regarding Seismic Walkdowns Response to Question 2:

The Peer Review Team was independent of the seismic walkdown-related activities.

Section 7.0 of References 3 and 4 contain a description of the peer review process. Additionally, these submittals included a separate peer review report organized to emphasize activities identified in Section 6 (Page 6-1) of Reference 2 and was given as Attachment 6 of Reference 3 and Attachment 8 of Reference 4. A complete summary of the peer review activities is contained in those attachments.

While reviewing the reports (References 3 and 4) it was noted that Table 2-1 and Section 7.0 of each report contained information that was inconsistent with the full peer report. Attachment 1 to this enclosure provides revised pages for each of the walkdown reports.

Table 2-1 of each report is being corrected to show that Mr. Robert N. Pryce was not a member of the Peer Review Team. The full peer review report lists the four members of the team and does not include Mr. Pryce.(Attachment 1, pages 1 and 3)

Table 2-1 is also being corrected to show that Mr. Tom Baumgardner was not part of SWEL development. The full peer review report shows that Mr. Baumgardner only performed the peer review of the SWEL, not its development.(Attachment 1, pages 1 and 3)

The second paragraph of Section 7.0 is revised to show there were four members of the peer review team, not three. The full peer review report list the names of the four members.(Attachment 1, pages 2 and 4)

E6 Attachment 1, Page 1 Fukushima Near-Term Task Force (NTTF) Recommendation 2.3:

NRC Submittal report for Seismic Walk-downs Catawba Unit 1 Page 3 of 15 2.0 Personnel Qualifications The personnel involved in the Catawba NTTF Recommendation 2.3 Seismic Walkdown effort satisfactorily met the qualification requirements of EPRI 1025286. The personnel responsibilities and qualifications are outlined in TABLE 2-1 below. Additional Peer Review Team experience is outlined within the Peer Review Summary Report (ATTACHMENTS 6A and 8A).

TABLE 2-1 Personnel Qualifications C2 :E- C M E r,., Q SW .2 0PBi SWR X i' 522 w MarK ei0 bht (ARES) BS/Civil Engineering SQUG 1)

Mar Ei ARS)32 SWE (2)(3) X David Kulla P.E. (Duke) BS/Civil Engineering 37 X X Bryan Hanna, P.E., (ARES) BS/CivilEngin~ering 12 S X Kevin Rubriht, (ARES ES/CjEivl Engineering 30 SWE X Johfi North, P.E., (ARES) BS/Qivil.Engihe6Hnn 28 SWT X - -__ __

Philip Berdos, (Shaw) Engineering BS/Mechannical W

• James Pappas, P.E., MS/Energy 31 SWE t2) X (Shaw) Engineering James Adam, P.E., (Shaw) Eng~ineering MS/Nuclear 44 W (2)

SWE 2 X Tom R Leitch, P.E., (Duke) BS/Civil Engineering 35 SWE 12) X X X X J David Kennedy (Duke) B/Cigil Engineering 22 SWE TZZ X Michael F Medlin, P.E. g 3

- m SWESvEn T_ -_- --

BS/Civil Engineering 31 X (Duke)

Raymond C Fung, P.E., MS/Civil Engineering 32 X X (Duke) MCEien 3__

Robert L. Keiser P.E., MS/Civil Engineering SQUG I')

(Duke) >20 SWE (2) X Charles M. Conselman, P.E. BS/Civil Engineering 28 SWE (21)()

(ARES) 28ISWE X Paul.Baughman P.E., E/il EUG 12 (ARES) BS/Civil Engineering >40 SWE )

RobeitN Pryce (Duke) BS/Mech Engineering 28 PSRO1 4, X X Tom'Baumgardner (Duke)

Fred Willis P.E., Duke) n/a BS/Civil Engineering 45 32 PSRO(4 T X

X IL&z Mark Shutt P E., (Duke) BS/Civil Engineerin 32 X George Bushnell P.E., ES/Civil Engineering 40+ SQUG()

(Shaw) 0 SWiEl(n)eeig SE2 NOTES:

1) SQUG Seismic Capability Engineers (SCEs) have successfully completed SQUG training.

2) Seismic Walkdown Engineers (SWEs) have successfully completed EPRI 1025286 2 day walkdown training course.

3) Senior Team Member

4) Prior Senior Reactor Operator (SRO).

CNC-1206.03-00-0203 Rev 2 Page 5 of 30

Attachment 1, Page 2 Fukushima Near-Term Task Force (NTTF) Recommendation 2.3:

NRC Submittal report for Seismic Walk-downs Catawba Unit 1 Page 13 of 15 The potentially adverse seismic conditions and their individual Problem Investigation Process (PIP) tracking numbers are listed in the Unit i NTTF 2.3 Seismic Walkdown Summary Reports (Attachment 5A and Attachment 7A).

6.0 IPEEE Vutnerabilities The Catawba IPEEE NRC submittal of 6/21/94 (Reference 8) concluded that there were no seismic vulnerabilities from external events. Thus, there were no identified plant changes which would significantly reduce the risk from seismic external events. Table 3-3 of the IPEEE NRC submittal identified one enhancement to resolve minor field walk-down issues. This enhancement is described inTable 6-1.

TABLE 6-1 IPEEE Enhancements Equipment Deficiency Identified Resolution Date Resolved Installed missing spacers, added Unit 1 EDG battery racks were missing dummy batteries, stiffened side spacers. rails.

racks Later replaced with new design.batteries and 09/28/2005 (EC12956) 7.0 Peer Review Duke Energy (Duke) contracted with the Shaw Group (Shaw) I ARES Corporation (ARES) Team to perform the NTTF 2.3 peer review at the Catawba Nuclear Station (CNS). The Peer Review Report is contained in ATTACHMENT 6A.

The Peer Review Team consisted of four individuals, three of whom have seismic engineering experience as it I applies to nuclear power plants. These individuals participated in the peer review of each of the activities. The peer review team is Identified in Table 2-1 and their qualifications are provided in ATTACHMENT 6A.

The Shaw/ARES methodology conforms to the guidance In Section 6 of EPRI 1025286. The peer review covered the following:

• The selection of the SSCs included on the Seismic Walkdown Equipment List (SWEL).

, A sample of the checklists prepared for the seismic walkdowns and area walk-bys.

• The licensing basis evaluations.

• The decisions for entering the potentially adverse conditions in the Corrective Action Program (CAP) process.

" The submittal report.

The peer review process for the SWEL development and the seismic walkdowns consisted of the following:

CNC-1206.03-00-0203 Rev 2 Page 15 of 30IJ*

Attachment 1, Page 3 Fukushima Near-Term Task Force (NTTF) Recommendation 2.3:

NRC Submittal report for Seismic Walk-downs Catawba Unit 2 Page 3 of 13 2.0 Personnel Qualifications The personnel involved in the Catawba NTTF Recommendation 2.3 Seismic Walkdown effort satisfactorily met the qualification requirements of EPRI 1025286. The personnel responsibilities and qualifications are outlined in TABLE 2-1 below. Additional Peer Review Team experience is outlined within the Peer Review Summary Report (ATTACHMENT 6B).

TABLE 2.1 Personnel Qualifications U) a)W

0. C cU . OE O cu C ~ X-U)

W u)CD

>- 00 C

0 a) _ >3 Mark Eli (ARES) BS/Civil Engineering 32 SQUG SWE ý2)(3) X David Kulla P.E.(Duke) BS/Civil Engineering 37 _ X Bryan Hanna, P..E., (ARES) B.S/Civil Engirieering 12 SWE X Kevin RUbright, (ARES) BS/Civil Engineering 30 S-WE VV) X John North, P.E., (ARES) BS./Civil Engineering 28 SWE X -

Anthony Fazio, (Shaw) BS/gherical >40 SWE 2 Engineinng >2)

Philip Berdos, (Shaw) BS/Mechainical 6 SWE x Engireering 6 _SWE (2)_X James Pappas, P.E., (Shaw) MS/Energy Engineering 31 SWE (2) X James Adam, P.E., (Shaw) MS/Nuclear Engineering 4 SWE (2) X Tom R Leitch, P.E., (Duke) BS/Civil Engineering 35 SWE (2) X X X X J David Kennedy (Duke) B/Civil Engineering 22 SWE 'z -

Michael F Medlin (Duke) BS/Civil Engineering 31 S X X Raymond (Duke) C Fung, P.E., SCv Engineering MS/Civil Egneng 32 3 SWE - X X x X Robert L. Keiser P.E. MS/Civil Engineering >20 SWE (2 X (Duke) SWE Charles M. Conselman, P.E. BS/Civil Engineering 28 SWE (2)(3) X (ARES)

Paul Baughman P.E. SQUG° Xt3)

(ARES) BS/Civil Engineering >40 SWE (2)

Robert N Pryce (Duke) BS/Mechanical 28 PSRO( 4 ) X X Engineering 2 PS__X Tom Baumgardner (Duke) n/a 45 PSROt x Fred Willis P.E. (Duke) BS/Civil Engineering 32 X Mark Shutt P.E. (Duke) BS/Civil Engineering 32 X SO.UG11 )

George Bushnell (Shaw) BS/Civil Engineering 40+ SWE (2) X NOTES:

1) SQUG Seismic Capability Engineers (SCEs) have successfully completed SQUG training.

2) Seismic Walkdown Engineers (SWEs) have successfully completed EPRI 1025286 2 day walkdown training course.

3) Senior Team Member.

4) Prior Senior Reactor Operator (SRO).

CNC-1206.03-00-0203 Rev 2 Page 2..0 of 30

Attachment 1, Page 4 Fukushima Near-Term Task Force (NTTF) Recommendation 2.3:

NRC Submittal report for Seismic Walk-downs Catawba Unit 2 Page 12 of 13 TABLE 6-1 IPEEE*E nhancements Equipment Deficiency Identified R*i/Ctldn Date Resolved Installed mi"sing Icra, added

• 091200B (CN-21447)

Unit 2 EDG battery racks were missing durnmii aterrel aces, atterd side spacers. racksLiter.

raill. replaced"Batteries and with newýdeslgn.

(CN-214471 Prior to June 1994.

Rod hung (non-GA Condition) pipe In Minor modification Implemented to 6ontact dhn(ontactAth eeCtrionndition) with electrical toe connection toin relocate June the Instrument. (Pridr to lg*4) planned for"2013 Seismicwalkdown instrument 2CFLT5560. refellng outage.

Potential Seismic spatial Interaction September 2012 Seismic bitween valve 2RN225B and nearby Problem eliminated by replacement Wi4iown found no SientiFuel Cooling ('KF)line of Valve. Issu eVvh this valve.

7.0 Peer Review Duke Energy (Duke) contracted with the Shaw Group (Shaw) / ARES Corporation (ARES) Team to perform the NTTF 2.3 peer review at the Catawba Nuclear Station (CNS). The Peer Review Report is contained In ATTACHMENT 6B.

The Peer Review Team consisted of four individuals, three of whom have seismic engineering experience as it applies to nuclear power plants. These individuals participated in the peer review of each of the activities. The peer review team is identified in Table 2.1 and their qualifications are provided in ATTACHMENT 6B.

The Shaw/ARES methodology conforms to the guidance in Section 6 of EPRI 1025286. The peer review covered the following:

" The selection of the SSCs included on the Seismic Walkdown Equipment List (SWEL).

" A sample of the checklists prepared for the seismic walkdowns and area walk-bys.

" The licensing basis evaluations.

" The decisions for entering the potentially adverse conditions In the Corrective Action Program (CAP) process.

" The submittal report.

The peer review process for the SWEL development and the seismic walkdowns consisted of the following:

o Reviewing the activity guidance in EPRI 1025286, the NEI Q&A bulletins, the NEI first-mover reports, and NRC Temporary Instruction 25151188.

" Conducting an in-process review at the plant site, including interviews with the personnel performing the activity and reviewing in-process documentation.

" Performing an in-plant surveillance (for the walkdown activity) of a seismic walkdown and an area walk-by.

" Providing in-process observations and comments to the personnel performing the activities.

CNC-1206.03-00-0203 Rev 2 Page 29 of 30