GO2-13-157, Response to Request for Additional Information Regarding Seismic Walkdown Summary

Response to Request for Additional Information Regarding Seismic Walkdown Summary

ML13346A012
Person / Time
Site:	Columbia
Issue date:	11/27/2013
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-13-157
Download: ML13346A012 (7)

Text

A ENERGY NORTHWEST Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509-377-8555 1 F. 509-377-2354 aljavork@ energy-northwest.com November 27, 2013 G02-13-157 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC WALKDOWN

References:

1) Letter dated March 12, 2012, from E. J Leeds (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "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."

2) Letter, G02-12-165, dated November 13, 2012, from D. A. Swank (Energy Northwest) to NRC, "Seismic Walkdown Report."

3) Letter, G02-13-117, dated August 13, 2013, from D. A. Swank (Energy Northwest) to NRC, "Final Seismic Walkdown Summary Report"

4) Letter dated November 1, 2013, from R. H. Beall (NRC) to M. E.

Reddemann, Energy Northwest, et al., "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns."

Dear Sir or Madam:

Reference 1 transmitted an NRC Request for Information regarding Near-Term Task Force (NTTF) recommendations related to the accident at the Fukushima Dai-ichi nuclear plant. By References 2 and 3, Energy Northwest submitted, respectively, initial and final reports documenting the results of seismic walkdowns conducted at Columbia Generating Station in response to Reference 1. By Reference 4, the NRC requested additional information regarding the seismic walkdowns. The enclosure to this letter provides Energy Northwest's response to the request for information transmitted by Reference 4.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC WALKDOWN

SUMMARY

Page 2 of 2 This letter contains no new or revised regulatory commitments. If you have any questions or require additional information, please contact Ms. L. L. Williams at (509) 377-8148.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, A.

orik Vice President, Engineering

Enclosure:

Response to Request for Additional Information cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C AJ Rapacz - BPA/1 399

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC WALKDOWN

SUMMARY

Enclosure Page 1 of 5 This enclosure provides Energy Northwest's response to the request for information transmitted by letter dated November 1, 2013, from R. H. Beall (NRC) to M. E.

Reddemann, Energy Northwest, et al., "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns."

1. Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs), dispositioning of issues, and reporting.

The NRC requested that licensees provide the following:

Description of the overall process used by the licensee (and its contractors) to evaluate observations identified in the field by Seismic Walkdown Engineers (SWEs).

Response

The seismic walkdowns conducted at Columbia Generating Station (Columbia) were performed in accordance with Electric Power Research Institute (EPRI) document 1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic." The Columbia SWEs completed the NTTF Recommendation 2.3 Seismic Walkdown Training Course sponsored by EPRI. The training course included instruction regarding conditions that would constitute a PASC.

The Seismic Walkdown and Area Walk-by activities were documented on checklists using the format provided by EPRI 1025286. For the Seismic Walkdown, a separate checklist was used for each Seismic Walkdown Equipment List (SWEL) item. For the Area Walk-By, a separate checklist was used for each plant area. Each checklist identified specific conditions to be checked for that item of plant equipment or plant area. For each condition, check boxes were provided to document whether or not the item of plant equipment or plant area met the stated criterion ("Y" or "N"), if it was not known whether criterion was met ("U"), or in some cases, whether the criterion was not applicable ("N/A"). A "Comment" section was also provided on each checklist for walkdown personnel to document any other conditions or issues considered to constitute a PASC.

• Description of how a field observation was determined to be a PASC or not and how the bases for determinations were recorded.

Response

The SWEs used their training and the criteria specified on the checklists to determine whether a field observation was a PASC. The SWEs made hand written entries on hard-copies of the checklists to document PASCs, as well as non-PASC issues, while performing the walkdowns and walk-bys. If a PASC was identified, the appropriate box on the checklist was either marked as "N" or "U" with an explanation that described the PASC. Personnel involved

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC WALKDOWN

SUMMARY

Enclosure Page 2 of 5 report that, when a particular walkdown activity was completed (typically every shift), a post walkdown briefing was conducted with the License Basis Evaluator regardless of whether any PASCs were identified. The purpose of these briefings was not to determine if any PASCs should be changed to non-PASCs.

The briefings were typically conducted to determine if a condition should be immediately entered into the Corrective Action Program (CAP), or whether additional research was needed.

The SWEs subsequently transferred information on the hard-copies of the checklist to an electronic copy of the checklist. The electronic copies of the checklist were printed out and transmitted to the NRC as Attachment 10 to Reference 2 and Attachment 10a to Reference 3. Energy Northwest has compared the original hardcopy checklists to the electronic copies and determined that, for approximately 20% of the checklists, information was not transferred verbatim. In the majority of such cases, the changes were editorial, involved non-PASC-related observations, involved non-required anchorages, or, resulted in more conservative determinations (e.g. "Y" changed to "U" or "N").

Four changes were identified as involving a simple evaluation. Energy Northwest identified no instances in which there was a failure to identify and document a PASC.

Description of the process used for creating a condition report (or other tracking mechanism), performing the licensing bases evaluation (or other determination method), and the resultant action, such as entering it into the CAP, or documenting the result and basis, once a determination was made that an observation was a PASC.

Response

Personnel involved report that, during the post walkdown briefing noted above, the SWEs and the License Basis Evaluator discussed all the non-PASC issues and PASCs discovered in the walkdowns and walk-bys, and documented on the checklists. During the briefings, the SWEs and License Basis Evaluator discussed the significance of the non-PASC issues and PASCs and made determinations as to how the issue or PASC would be dispositioned.

Non-PASC issues or PASCs that concerned housekeeping or other items that did not involve the design configuration of the plant were entered into the CAP, with work orders generated as applicable to resolve the issue or PASC.

A PASC that concerned the design configuration of the plant (e.g. missing fasteners, missing anchor bolts), or a condition controlled by a plant procedure (e.g. storage permit areas, unrestrained objects) were evaluated by the License Basis Evaluator. For these PASCs, the License Basis Evaluator reviewed calculations, drawings, and procedures, etc. to determine if the PASC under consideration was consistent with the plant design configuration. If the PASC under consideration was consistent with plant design configuration, then it was

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC WALKDOWN

SUMMARY

Enclosure Page 3 of 5 considered that the plant license basis was met and no further action was taken.

If the PASC under consideration was not consistent with plant design configuration, then the item was entered into the CAP for resolution.

The License Basis Evaluator developed a table, similar to the table provided in 3 of the report transmitted by Reference 3, in order to document and organize the area walk-by and walkdown activities. The table developed by the License Basis Evaluator identified each area walk-by performed and coupled each SWEL item contained in the area walk-by. A column was provided to describe the issues or PASC found in the area walk-by or walkdown. These issues or PASCs correspond to the issues or PASCs that are documented on each walkdown and area walk-by checklist. A column labeled "Licensing Basis Evaluation" was provided to describe the justification and documentation reviewed while making the license basis evaluation. If an issue or PASC was entered directly into the CAP, then this column was filled out with that indication.

A column was provided to record any Condition Report (CR) that was generated as a result of entering into the CAP and another column provided to track the status of the CR.

The table contained in Attachment 13 of the report transmitted by Reference 3 provided a modified version of the table developed by the License Basis Evaluator. In Attachment 13, the License Basis Evaluation column was modified to remove specific calculation, drawing, and procedure numbers identified by the License Basis Evaluator, and refer to them more generically as "plant calculations," "plant drawings," and "plant procedures," respectively. Therefore, 3 of the report transmitted by Reference 3 documented all the PASCs identified by the walkdowns and area walk-bys. Attachment 13 also provides the evaluations of the PASCs and provides the associated CAP entries by CR number. The tables developed by the License Basis Evaluator containing specific calculation, drawing, and procedure numbers remain available on site.

• Confirmation that the reported information supports concluding that the plant meets the Current Licensing Basis, following one of three acceptable alternatives.

Energy Northwest considers that the alternative applicable to Columbia is alternative (c) which states:

"(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."

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC WALKDOWN

SUMMARY

Enclosure Page 4 of 5

Response

Energy Northwest confirms that all PASCs (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. This confirmation is supported by the training, processes, and reviews described above.

2. Conduct of the Peer Review Process The NRC requested that licensees:

"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."

Response

Energy Northwest confirms that the activities described in the walkdown guidance on page 6-1 of EPRI Report 1025286 were assessed as part of the peer review process. Performance of these activities was documented in 4 to Reference 2, and Attachment 14A to Reference 3.

(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."

Response: 4 to Reference 2, and Attachment 14A to Reference 3 provided summaries of the peer review process and activities conducted at Columbia. As documented in Section 3.2 of Reference 2 and Section 3.2 of Reference 3, the two individuals performing the peer reviews performed no other walkdown related activity.

"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."

Response

There are no differences in the peer review areas or the manner in which the peer reviews were conducted from those described in Reference 2 and Reference 3.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING SEISMIC WALKDOWN

SUMMARY

Enclosure Page 5 of 5 References

1. Letter dated March 12, 2012, from E. J Leeds (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "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."

2. Letter, G02-12-165, dated November 13, 2012, from D. A. Swank (Energy Northwest) to NRC Document Control Desk, "Seismic Walkdown Report."

3. Letter, G02-13-117, dated August 13, 2013, from D. A. Swank (Energy Northwest) to NRC, "Final Seismic Walkdown Summary Report."