LIC-13-0172, Response to Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns

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

ML13333A674
Person / Time
Site:	Fort Calhoun
Issue date:	11/27/2013
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-13-0172
Download: ML13333A674 (13)

Text

-~

jjjjjjjj Omaha Public Power Oistrict 444 South 16h Street Mall Omaha, NE 68102-2247 UC-13-0172 November 27,2013 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

References:

1. Docket No. 50-285

2. Letter from NRC (E. J. Leeds & M. R. Johnson) to OPPD (D. J. Bannister), "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 (ML12053A340) (NRC-12-0021)

3. Electric Power Research Institute (EPRI) Report "Seismic Walkdown Guidance, For Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic," EPRI, Palo Alto, CA: 2012.1025286 (ML12188A031)

4. Letter to NRC (Document Control Desk) from OPPD (L. P. Cortopassi), "OPPD 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 27, 2012 (ML12340A257) (UC 0169)

5. Letter to NRC (Document Control Desk) from OPPD (L. P. Cortopassi), "Update to EA12-021, "Seismic Walkdown Submittal Report," dated June 28, 2013 (ML13193A236) (LlC 0070)

6. Letter from NRC (R. H. Beall) "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns," dated November 1, 2013, (ML13304B418) (NRC-13-0141)

Subject:

Response to Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns On March 12,2012, the Nuclear Regulatory Commission (NRC) staff issued a letter requesting additional information per Title 10 of the Code of Federal Regulations, Section 50.54(f) (i.e., Reference 2). The letter requested licensees to conduct seismic hazard walkdowns to verify current plant configuration with the Current Licensing Basis (CLB). The NRC endorsed an Electric Power Research Institute (EPRI) guidance document that resulted from this effort (i.e., Reference 3); because the NRC staff determined that, the use of the guidance, coupled with appropriate training, would meet the objectives and requests of Reference 2.

The Omaha Public Power District (OPPD) submitted the walkdown report(s) for Fort Calhoun Station by letters dated November 27,2012 and June 28,2013 (i.e., References 4 and 5).

Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission LlC-13-0172 Page 2 Following the staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Reference 6 is a request for additional information submitted to many licensees including OPPD. The enclosed supplemental report provides additional information not requested by Reference 2 intended to assist the NRC staff in completing their review of the Seismic Hazard Walkdowns conducted at Fort Calhoun Station.

This letter contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Bill Hansher at (402) 533-6894.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 27, 2013.

ouis P. Cortopassi Site Vice President and CNO

Enclosure:

Response to Request for Additional Information, Seismic Walkdowns c: E. J. Leeds, NRC Director of the Office of Nuclear Reactor Regulation M. L. Dapas, NRC Regional Administrator, Region IV J. M. Sebrosky, NRC Senior Project Manager L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector

LlC-13-0172 Enclosure Page 3 Response to Request for Additional Information Seismic Walkdowns On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a letter requesting additional information per Title 10 of the Code of Federal Regulations, Section 50.54(1) (hereafter called the 50.54(1) letter). The 50.54(f) letter requested that licensees conduct seismic hazard walkdowns to verify the plant configuration with the current licensing basis (CLB). The licensees stated by letter that the seismic walkdowns would be performed in accordance with Electric Power Research Institute EPRI-1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic" (walkdown guidance). Following the NRC staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants.

Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow the staff to complete its assessments.

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 or calculation constituted a 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 regards 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 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

LlC-13-0172 Enclosure Page 4 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 a LBE was not performed. However, during the audits it was clear that an LBE (or an equivalent determination method) was performed and used in 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 resulted 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, 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.

OPPD Response:

Fort Calhoun Station utilized an engineering contractor in conjunction with station personnel to perform the seismic walkdowns. These SWEs, comprised of a senior engineer and a junior engineer were accompanied by a member of the operations department to facilitate in locating components and ensuring the walkdowns did not interrupt or conflict with the scheduled daily plant operations. Throughout the walkdown, several observations were made by SWEs that were noted on the field copies of the walkdown and area walk-by checklists.

Any potentially adverse seismic conditions or other adverse seismic conditions were documented with a No (N) on the checklist for the appropriate question. Any item that was viewed to pose a PASC for the station was determined using the questions listed on the walkdown checklist in accordance with the SWE's seismic experience and training (NTTF 2.3 Training or Seismic Oualification Utility Group (SOUG)). A PASC was listed as a No (N) on the walkdown checklist. If any of the items marked No (N) on the checklist were deemed to be an immediate concern for the operability of the station by the SWE's or the accompanying member of operations, the walkdowns would be stopped and a condition report written for each issue with the item for immediate action. None of the PASC's discovered were considered to be immediate operability concerns by the SWE's or the accompanying member of operations department. In addition, conditions related to general housekeeping that were deemed not detrimental to plant operations, were identified on the PASC table and a condition report was written for resolution in CAP.

The SWE's viewed various items (such as light oxidation on bolts, surface shrinkage cracks in the concrete) and deemed them not a PASCo For each of these conditions the SWE's provided a thorough write-up on the checklist in the pertinent section explaining the specific condition of the issue and the justification for why the issue was not considered to be a PASCo If there was significant deliberation on an issue or a

LlC-13-0172 Enclosure Page 5 signification disagreement between the SWE's, the team conservatively erred on the side of caution and listed the item as a No (N) on the checklist for the appropriate question.

When a component on a walkdown checklist required an anchorage configuration verification (question number 5 on the seismic walkdown checklist), and the correct licensing documentation relating to the anchorage of the component in question was not available in the field, the checklist was marked with a No (N) and documented as a PASCo The SWEs then took extensive photographs; recorded anchorage dimensions and sizes, and took down a detailed sketch of the configuration for later verification through the License Basis Evaluation (LBE) process.

After the walkdowns were completed, the items on the walkdown and area walk-by checklists marked No (N) were documented on a PASC table. A post-job brief was held each day between the SWE's and station personnel. During this post-job brief, observations by the SWEs were discussed. This information included but not limited to items listed as a No (N) on the walkdown checklist or the area walk-by checklist, seismic housekeeping, and previous walkdown experience. For the PASCs pertaining to anchorage configuration verification, current licensing documentation was obtained and compared to the walkdown field sketches and photographs to determine if the anchorage configuration verification matched its licensing basis. A LBE was then performed and noted in the PASC table.

All items, excluding the anchorage configuration documentation discussed above, were entered into CAP for each of their respective issues (if not done so already) at the conclusion of each days post-job brief.

CAP items were generated for any PASC that could not be dispositioned by the SWEs based on their training, engineering judgment and existing station documentation available to them. The CAP process was utilized to track resolution of all identified PASCo If calculations or drawing updates were required, the resolution was tracked and captured via the corrective action process.

As noted above, CAP items were generated for any PASC that could not be dispositioned by the SWEs with existing documentation available to them. The station personnel and the SWE's both agreed to take a cautious approach of a seismic walkdown and entered items into CAP for all issues that both SWE's could not disposition with a simple documented resolution and a high degree of confidence. These potentially adverse conditions were logged onto a PASC table which identified the CAP reference number (if applicable), identified condition and resolution.

NRC Question 1 (continued):

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.

LlC-13-0172 Enclosure Page 6 OPPD Response As described in References 4 and 5, Attachment 11 .4 is the PASC table (which satisfies item (a) 1) of NRC question. This table provides a description of each PASC, the CAP (or CR) reference number associated with resolving the PASC (if entered into the CAP), identified condition and resolution (if not entered into the CAP). Each of these CAP entries initiation and completion dates are as follows in the CAP table provided which was updated in Reference 5, and an update to the CR status is provided in the Table attached herein.

As described in References 4 and 5, Attachment 11.5 includes every LBE performed for all the PASCs not entered into the CAP. These LBEs demonstrate how each individual PASC was dispositioned, the methodology used to disposition the PASCs, the result of each LBE, and the basis for each result.

All observations judged by the SWEs to be a potentially adverse seismic condition have been addressed and are included in References 4 and 5, which have been submitted to the NRC.

LlC-13-0172 Enclosure Page 7 Seismic Walkdown Condition Report Tracking List CR Issue Description Action Initiated Status Closed Date Date CR 2012-10195 Tool stored in the Missile Shield room near instrument Removed and disposed of item. 8/14/2012 Closed 8/21/2012 air supply filterlregulator assembly.

CR 2012-10198 Missing pipe support clamp for a support. A new pipe clamp has been reinstalled. 8/14/2012 Closed 4/30/2013 CR 2012-10367 Potential missing clips for protective screen on jacket Grating does not have any safety-related purpose 8/15/2012 Closed 2/19/2013 I

water radiator and procedure does not specify minimum and is not a 2 over 1 seismic concern. There are number of clips. no minimum requirements for the number of fasteners used to secure the screen.

CR 2012-10368 Two tool boxes that were located near an instrument air Per PED-GEI-34, room 65 is a permitted storage 8/15/2012 Closed 5/30/2013 line are on wheels that do not have locking mechanisms area. As noted in the CR, C-Clamps were installed on the wheels. The concern is that the tool boxes could on the wheels of the toolbox and a 6 inch tall inadvertently move and rupture the air line. concrete curb located at the intersection of the floor and wall would have prevented the cabinet from striking the instrument air line.

CR 2012-10369 Insulation located on the exhaust line of DG-2, whether The DNC found that the seismic loading for the 8/15/2012 Closed 1/412013 or not the extra weight has been evaluated from a insulation has been evaluated in calculation seismic standpoint. FC04292.

CR 2012-10423 Lighting does not have a bulb covering and light bulbs There will not be any effect on electrical equipment 8/16/2012 Closed 1/30/2013 could cause electrical issues when collapsing onto inside of cabinets or damage to the exterior of ,

cabinets during seismic events. cabinets.

CR 2012-10425 Large metal carts on wheels are not restrained against The storage and placement of transient equipment 8/16/2012 Ready to Pending lateral motion and could possibly contact and damage and materials is controlled per procedures. Close I nearby cabinets. I CR 2012-10427 3/8" Gap between non-adjacent cabinet that could lead Reviewed A-46 program for the cabinets in the 8/16/2012 Closed 1/30/2013 to physical interaction during an out-of-phase movement switchgear room. The cabinets are acceptable.

induced by a seismic event.

CR 2012-10553 Four anchor bolts for RAW WATER STRAINER have Only the one strainer had the issue where the bolts 8/17/2012 Maintain Plan to close by less than full thread engagement with their respective were not fully engaged. The crafts were contacted Action 1/812014 nut. and will have to develop work instructions for replacing the strainers and add a note to ensure that the washers are installed on the anchors so that the thickness allows sufficient thread engagement.

CR 2012-10628 Portable work light hanging unsecured above the sump. 8/17/2012 Closed 8/31/2012 Light moved. No other actions are required.

CR 2012-10629 Light bulb with no safety cover hanging above the RW WR 183237 written. 8/17/2012 Closed 9/17/2012 pump pressure indicator.

LlC-13-0172 Enclosure Page 8 Seismic Walkdown Condition Report Tracking List CR Issue Description Action Initiated Status Closed Date Date CR 2012-10630 Loose Chicago fittings in the vicinity of the Diesel fire Properly stored and are no longer just laying loose. 8/1712012 Closed 8/2812012 protection pump.

CR 2012-10631 Bent light fixture resting against an instrument air line to WO 456244 corrected the identified condition. 8/17/2012 Closed 4/312013 the RW pump isolation valve.

CR 2012-10672 Rope with a metal attachment hanging right next to Rope, with metal attached, was removed. 8/18/2012 Closed 9/612012 manifold valves and could potentially free-swing into those components.

CR 2012-10676 Mounting plate for structural steel in the southeast corner Engineering review determined that the load profile 8/18/2012 Closed 4/17/2013 of Room 72 there are slotted holes for the anchor bolts does not result in a moment on the base plate and parallel to the dead load. This could possibly put a does not induce tension in the anchor bolts.

bending moment on the bolts.

CR 2012-10684 The fuel position status board and the water cooler are The bottle can roll around because there are no 8/18/2012 Closed 6/16/2013 unrestrained. During a seismic event those items could targets that are low. FIN has cut the status board potentially fall (status board) or roll (water cooler) into frame, removed it from the control room, and control panels and other sensitive components. placed it into the 3rd floor service fan housing room until it can be modified to fit under the door of the control room to bring in during core reload.

CR 2012-10915 0.5 inch gap approximately between a horizontal lateral Review of EA96-041 and FC05056 show the 8/20/2012 Closed 218/2013 angle 2 inch by 2 inch (steel) and the block wall (the mid predicted seismic accelerations for FCS would not height lateral), and it was noted that it had a sag in the overcome the coefficient of friction between the center of the horizontal length of the lateral. blocks.

CR 2012-10916 A cart with wheels in the contaminated area that The cart located is properly stored outside the safe 8/20/2012 Closed 5/30/2013 contained tools and miscellaneous items could shutdown area. All procedures were adequately potentially move during a seismic event if not restrained followed.

or wheels locked in place.

CR 2012-10917 Multiple chains wrapped around a restraint. The chains When not in use, secure suspended chains and 8/20/2012 Closed 7/24/2013 are from the overhead crane and trolley. The chains are buckets to nearby structural elements by an not secured or tied off, and during a seismic event could appropriate attachment device.

potentially unwrap.

CR 2012-10919 Pitting in the floor concrete near some anchors. Appears the spalling occurred during installation of 8/20/2012 Closed 9/312013 the expansion anchors. WR-1844770 to install new anchors written. This WR created WO 457861-01 to rework tubing supports.

LlC-13-0172 Enclosure Page 9 Seismic Walkdown Condition Report Tracking List CR Issue Description Action Initiated Status Closed Date Date CR 2012-11039 Concrete was missing on four corners of each concrete Calculation FC07235 analyzes this anchorage. 8/21/2012 Closed 3/8/2013 pedestal. Concrete was removed or spalled so that the The concrete was chipped out original anchor bolts provide no mechanical anchorage. to install bolts from below. This is the plant design One side of the heat exchanger is on wheeled supports basis configuration.

with no mechanical anchorage.

CR 2012-11041 Two hoist chains were suspended from two separate When not in use, secure suspended chains and 8/21/2012 Ready to Pending trolleys, and the chains were hanging down and the ends buckets to nearby structural elements by an Close of the chains were placed in buckets unsecured near a appropriate attachment device.

compressed air line.

CR 2012-11277 One of four bolts was missing from the baseplate for a MECHANICAL SNUBBER is operable. Reference 8/23/2012 Maintain Plan to close by vertical pipe support suspended from ceiling on the Low IR-950050 Reel 4782. Per Calculation FC02843, Action 3/2112014 Pressure Safety Injection Pump discharge line -5 feet the As-Built design (4 holes, 3 anchor bolts) is downstream of the discharge valve. capable of performing its design function and snubber drawing 7138 reflects the current 3 anchor bolt installation.

Identify the design basis and determine if 3 anchor bolts is capable of performing its design function documented in Calculation FC02843.

CR 2012-11879 Anchor bolts through the base plate for the posts appear WR194758 was initiated to allow the anchor bolts 8/27/2012 Ready to Pending to be corroded and possibly need to be replaced . to be replaced and baseplate to be cleaned by Close following the normal work management process.

CR 2012-11880 No tag for scaffolding that was erected around tank. Based on referenced procedures there is already a 8/27/2012 Maintain Plan to close by Scaffolding could cause seismic interaction issues with method in place to show that a Temporary Shield Action 1/24/2014 adjacent equipment. structure has been properly evaluated for seismic concerns and what to do if shielding is found with out a tag. No further action is required.

CR 2012-11973 A hanging light fixture is suspended from a flexible rod in The maximum displacement of the light fixture is 8/27/2012 Closed 1/3/2013 close proximity to an indicator. less than the available distance between hanging light fixture and the indicator. The 3/8 inch steel rod vertical light fixture is also has a horizontal double unistrut rigidly support. This horizontal double unistrut support keeps light fixture in place. There is no seismic interaction concern for the light fixture installation.

LlC-13-0172 Enclosure Page 10 Seismic Walkdown Condition Report Tracking List CR Issue Description Action Initiated Status Closed Date Date CR 2012-12399 Scaffolding is constructed very close to existing piping This issue could not be investigated. The scaffold 8/30/2012 Closed 114/2013 and is only anchored at one location. This could lead to has been removed. The only activity that would be potentially large deflections away from the support point useful is to reinforce to the scaffold inspectors during a seismic event causing interaction issues (DEN civil engineers) to be diligent in reviewing between the scaffolding and the nearby piping. scaffolds and enforcing the criteria specified in PED-CSS-12.

CR 2012-12400 Oily looking substance found accumulated that could WR186128 for cleaning oily substance found on 8/30/2012 Closed 7/18/2013 potentially be a fire-hazard. pump base is scheduled for cleaning while plant is online. I CR 2012-12401 Tools laying out unsecured and a ladder located outside All items have been stowed away properly. It was 8/30/2012 Closed 5/2212013 of the red tape (possibly deemed non storage area). The not possible to identify the responsible individuals tools were located on the table in the center of the room. so no coaching was performed.

CR 2012-12402 Potential spatial interaction observed between a pipe Spatial interaction in the horizontal direction was 8/30/2012 Closed 4/9/2013 and Junction Box where a gap less than 2" is observed determined to be acceptable, and interaction with between the two items. the CCW piping is not a concern.

CR 2012-12403 Electrical cords plugged in and loosely hanging on a pipe The cords have been strapped together and are 8/30/2012 Closed 1/212013 support that could be a possible fire hazard. not hanging loosely on the piping.

CR 2012-12404 There is a gap less than 2" between a pipe and an An analysis was prepared to check the maximum 8/30/2012 Closed 2/5/2013 unrelated vertical pipe support, this could be a spatial horizontal (z-direction) deflection on the frame interaction issue during a seismic event. support. This shows that the adequate gap will be maintain during a deSign basis seismic event.

CR 2012-12405 Bent hanger rod supporting line, this mayor may not be Based on the allowable load and 8/30/2012 Closed 2/5/2013 detrimental to the intended design function of the imposed load on the hanger rod it is concluded that support. the existing configuration is not degraded. The hanger rod will perform its intended design function in the seismic event.

CR 2013-00522 Inside the cabinet was a wood shim. Maintenance on the Wood shim was removed. Storing the wood shim 1/8/2013 Closed 2/5/2013 breakers was being performed. I do not think that in the breaker cubicle is a violation of SO-G-91.

flammable material should be stored inside the safety The additional combustible load is negligible and related breakers switchgear and this should be bounded by the load assumed in the combustible evaluated by the fire protection program engineer. load calculation, FC05814. No additional actions required.

LlC-13-0172 Enclosure Page 11 Seismic Walkdown Condition Report Tracking List CR Issue Description Action Initiated Status Closed Date Date CR 2013-07194 Door hinge on one cubical was missing 2 bolts on a door Did prompt evaluation which resulted in door hinge 3/30/2013 Closed 8/7/2013 hinge. There are spaces for 5 total. Three bolts are being acceptable.

installed. Each has a capacity of 500 pounds tension.

This is sufficient to hold the door in place. The two bolts missing were due to final fit up and the holes for the bolts did not line up. The bolts do not need to be installed and will be noted in the 1B4A seismic qualification report (SEWS).

CR 2013-08401 An interior bolt was missing inside the cabinet on the WR 195204 was written to replace bolt. Created 4/16/2013 Closed 8/23/2013 plate that separates the cubicles. This was identified as task to replace missing bolt. Assigned task to EM.

a non structural bolt and does not reduce the capacity of the cabinet and does not affect the seismic rating of the cabinet.

An abbreviated list was provided as part of LlC-13-0070 Enclosure 2

LlC-13-0172 Enclosure Page 12 NRC Question 1 (continued):

(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.

OPPD Response:

No new CR entries have been entered to report or disposition PASCs since Reference 5. The table attached is a status update of the CRs previously documented in References 4 and 5.

(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.

OPPD Response:

OPPD confirms that all PASCs have been previously identified in the Corrective Action Program as a result of the NTTF 2.3 Seismic Walkdown and reported to the NRC in References 4 and 5.

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, 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.

LlC-13-0172 Enclosure Page 13 OPPD Response:

The peer reviews completed for the Fort Calhoun Station, NTTF Recommendation 2.3: Seismic submittal, Reference 4 and updated in Reference 5 were completed in accordance with Reference 3. As noted above, Fort Calhoun Station utilized a combination of vendor and station seismic walkdown teams. Due to the timing of these walkdowns, a Peer Review team comprised of 6 individuals was utilized.

The names of the peer review team are provided in Section 4.2 of Reference 4 and updated in Reference 5.

The peer reviewer role is provided in Table 1 of References 4 and 5.

The lead peer reviewer, is identified in Section 4.2 of References 4 and 5. The scope of lead peer reviewer:

• Peer reviewed the SWEL

• Performed interviews of the seismic walkdown engineers via electronic communications

• Peer reviewed a sample of the checklists prepared for the Seismic Walkdowns and Area Walk-8ys

• Peer reviewed the submittal report in its entirety Aside from the scope of the peer review as defined in Reference 3 and listed above, Lead peer reviewer was not involved with the SWEL preparation or disposition of any corrective actions. Lead peer reviewer acted as a Seismic Walkdown Engineer for a small portion of the SWEL items.

There are no differences between the information contained in the original submittal, References 4 and 5, and the information provided in this supplemental report.

The peer reviews and inspections were completed in accordance with Reference 3 as is consistent with the statements provided in References 4 and 5.