ML12056A049

Enclosure 3 - Recommendation 2.3: Seismic

ML12056A049
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Quad Cities, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle
Issue date:	03/12/2012
From:	Office of New Reactors, Office of Nuclear Reactor Regulation
To:
Gratton C
Shared Package
ML12056A046	List: ML12053A340 ML12056A047 ML12056A048 ML12056A049 ML12056A050 ML12056A051 ML12056A052
References
Download: ML12056A049 (6)

Text

RECOMMENDATION 2.3: SEISMIC PURPOSE The U.S. Nuclear Regulatory Commission (NRC or Commission) is issuing this information request for the following purposes:

• To gather information with respect to Near-Term Task Force (NTTF) Recommendation 2.3, as amended by staff requirements memorandum (SRM) associated with SECY-11-0124 and SECY-11-0137,

• To request licensees to develop a methodology and acceptance criteria for seismic walkdowns to be endorsed by the NRC staff,

• To request licensees to perform seismic walkdowns using the NRC-endorsed walkdown methodology, as defined herein,

• To identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and

• To verify the adequacy of licensee monitoring and maintenance procedures.

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f), addressees are required to submit a written response to this information request.

BACKGROUND Structures, systems, and components (SSCs) important to safety in operating nuclear power plants are designed either in accordance with, or meet the intent of, Appendix A to 10 CFR Part 100 and Appendix A to 10 CFR Part 50, General Design Criteria (GDC) 2. GDC 2 states that SSCs important to safety at nuclear power plants must be designed to withstand the effects of natural phenomena such as earthquakes, tornados, hurricanes, floods, tsunami, and seiches without loss of capability to perform their intended safety functions. The design bases for these SSCs are to reflect appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area. The design bases are also to reflect sufficient margin to account for the limited accuracy, quantity, and period of time in which the historical data have been accumulated.

In response to the accident at the Fukushima Dai-ichi nuclear power plant caused by the March 11, 2011, Tohoku earthquake and subsequent tsunami, the Commission established the NTTF to conduct a systematic review of NRC processes and regulations and to make recommendations to the Commission for its policy direction. The NTTF developed a set of recommendations that are intended to clarify and strengthen the regulatory framework for protection against natural phenomena. The purpose of this letter is to gather information with respect to NTTF Recommendation 2.3 for seismic hazards. Recommendation 2.3, and the SRMs associated with SECY-11-0124 and SECY-11-0137, instructs the NRC staff to issue requests for information to licensees pursuant to 10 CFR 50.54(f). This information request is for licensees to develop a methodology and acceptance criteria for seismic walkdowns to be endorsed by the staff following interaction with external stakeholders. It is requested that licensees perform the seismic walkdowns to identify and address plant-specific vulnerabilities (through its corrective action program) and verify the adequacies of monitoring and maintenance procedures.

Enclosure 3

In developing Recommendation 2.3, the NTTF recognized the need to verify the adequacy of features that play an integral role in the defense-in-depth approach for protection from natural phenomena. NTTF Recommendation 2.3 and SECY-11-0124 and SECY-11-0137 states that recent plant inspections have been conducted by NRC staff and industry in response to the Fukushima Dai-ichi accident and that these activities should be used to inform the implementation of this recommendation. Ongoing inspections of the Fukushima Dai-ichi and Dai-ni nuclear power stations may also provide insights useful for this recommendation.

Furthermore, recent lessons learned from the earthquake near the North Anna Power Station should also be used to inform the development of the walkdown procedure(s).

APPLICABLE REGULATORY REQUIREMENTS

• Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, GDC 2, Design Bases for Protection against Natural Phenomena

• 10 CFR 50.54, Conditions of Licenses

• 10 CFR 50.34(a)(1), (a)(3), (a)(4), (b)(1), (b)(2), and (b)(4)

• Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants, to 10 CFR Part 100, Reactor Site Criteria The seismic design bases for currently operating nuclear power plants were either developed in accordance with, or meet the intent of, GDC 2 and 10 CFR Part 100, Appendix A. Appendix A requires that safety-related SSCs remain functional if the safe shutdown earthquake (SSE) occurs.

DISCUSSION The NTTF recommended that the Commission direct several actions to ensure adequate protection from natural phenomena. The actions should be taken to prevent fuel damage, ensure containment integrity and the functionality of SSCs that support the spent fuel pool (SFP). In particular, NTTF Recommendation 2.3 states that the Commission should Order licensees to perform seismic and flood protection walkdowns to identify and address plant-specific vulnerabilities and verify the adequacy of monitoring and maintenance for protection features such as water tight barriers and seals in the interim period until longer term actions are completed to update the design basis for external events. However, in the context of this letter, the NRC staff is focusing on degraded, nonconforming, or unanalyzed conditions.

The NRC staffs assessment of NTTF Recommendation 2.3 is discussed in SECY-11-0124.

The NRC staff agreed with the NTTF Recommendation 2.3 findings and noted that various walkdown guidance exists and that recent plant inspections by staff in accordance with Temporary Instruction (TI) 2515/183, Follow-up to the Fukushima Dai-ichi Nuclear Station Fuel Damage Event, and licensees plant inspections in response to the Fukushima Dai-ichi accidents should help inform the implementation of this recommendation. Results of the NRC staffs evaluation of the recent earthquake near North Anna Power Station may also provide insights.

In its SRM to SECY-0124, the Commission approved the staffs proposed actions to implement without delay the NTTF recommendations as described in the SECY paper. With regard to Recommendation 2.3, the NRC staff-approved actions are to develop and issue a request for information to licensees pursuant to 10 CFR 50.54(f) to develop a methodology and acceptance criteria for seismic walkdowns to be endorsed by the NRC staff following interactions with external stakeholders, perform seismic walkdowns to identify and address plant-specific degraded, nonconforming, or unanalyzed conditions (through the corrective action program) and verify the adequacy of monitoring and maintenance for protective features, and inform the NRC staff of the results of the walkdowns and corrective actions taken or planned.

The TI 2515/183 was issued by the NRC on March 23, 2011. Inspection activities were completed by April 29, 2011, and NRC inspection reports were issued by May 13, 2011. The NRC developed a Summary of Observations report to encapsulate the performance of TI 2515/183 (see http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/follow-up-rpts.html). The summary report states that while individually, none of the observations posed a significant safety issue, they indicate a potential industry trend of failure to maintain equipment and strategies required to mitigate some design basis events. Regarding the licensees capability to mitigate large fires or flooding coincident with seismic activity, the report notes that some equipment used to mitigate fires or station blackout was stored in areas that were not seismically qualified or that could be flooded.

As outlined in the SECY-11-0124, the NRC staff intends to work with the industry and other stakeholders to endorse a procedure(s) to develop acceptance criteria, conduct walkdowns, and identify degraded, nonconforming, or unanalyzed conditions. It is anticipated that the walkdown procedure will be developed by modifying various existing NRC and industry processes, including the recent inspections described above in accordance with TI 2515/183. Other guidance for seismic protection walkdowns include Electric Power Research Institute (EPRI) report NP-6041-SL, Revision 1, A Methodology for Assessment of Nuclear Power Plant Seismic Margin, Seismic Qualification Utility Group procedure, Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Power Plant Equipment, and International Atomic Energy Agency NS-G-2.13, Evaluation of Seismic Safety for Existing Nuclear Installations. Additional details of attributes of a walkdown procedure are described in the Requested Action below.

The technical approach and methods used to develop the requested information should be integrated such that it accounts for design, physical barriers, procedures, temporary measures, and planned or installed mitigation measures to deal with external hazards. This type of an integrated approach will allow the NRC and industry to assess the significance of any new information related to the hazard in a systematic manner.

REQUESTED ACTIONS In response to NTTF Recommendation 2.3, the Commission requests all licensees to perform seismic walkdowns in order to identify and address plant specific degraded, nonconforming, or unanalyzed conditions and verify the adequacy of strategies, monitoring, and maintenance programs such that the nuclear power plant can respond to external events. The walkdown will verify current plant configuration with the current licensing basis, verify the adequacy of current strategies, maintenance plans, and identify degraded, nonconforming, or unanalyzed conditions.

The walkdown procedure should be developed and submitted to the NRC. The procedure may incorporate current plant procedures, if appropriate. Prior to the walkdown, licensees should develop acceptance criteria, collect appropriate data, and assemble a team with relevant technical skills. Improvements made as part of the licensees response to the individual plant examination of external events (IPEEE) program for seismic issues should be reported.

If any condition identified during the walkdown activities represents a degraded, nonconforming, or unanalyzed condition (i.e., noncompliance with the current licensing basis) for an SSC, describe actions that were taken or are planned to address the condition using the guidance in Regulatory Issues Summary 2005-20, Revision 1, Revision to NRC Inspection Manual Part 9900 Technical Guidance, Operability Conditions Adverse to Quality or Safety, including entering the condition in the corrective action program. Reporting requirements pursuant to 10 CFR 50.72 should also be considered. Additionally, these findings should be considered in the Recommendation 2.1 hazard evaluations, as appropriate.

REQUESTED INFORMATION

1. The NRC requests that each addressee confirm that they will use the industry-developed, NRC-endorsed, seismic walkdown procedures1 or provide a description of plant-specific walkdown procedures that include the following characteristics:

a. Determination of the seismic walkdown scope and any combined effects

b. Consideration of NUREG-1742, EPRI Report NP-6041, GIP, and common issues and findings discussed in the responses to TI 2515/183

c. Pre-walkdown actions (e.g., data collection, review of drawings and procedures, identification of the plant licensing basis, identification of current seismic protection levels)

d. Identification of SSCs requiring seismic protection and used in the protection of the reactor and spent fuel pool, including the ultimate heat sink (UHS)

e. Description of the walkdown team composition and qualifications

f. Details of the information to be collected during the walkdown including equipment access considerations

g. Documentation and peer review requirements

2. Following the NRCs endorsement of the walkdown procedure, addresses are requested to conduct the walkdown and submit the final report which includes the following:

a. Information on the plant-specific hazard licensing bases and a description of the protection and mitigation features considered in the licensing basis evaluation

b. Information related to the implementation of the walkdown process

c. A list of plant-specific vulnerabilities (including any seismic anomalies, outliers, or other findings) identified by the IPEEE and a description of the actions taken to eliminate or reduce them (including their completion dates)

d. Results of the walkdown including key findings and identified degraded, nonconforming, or unanalyzed conditions. Include a detailed description of the 1

NRC staff are currently engaged with industry and other external stakeholders to develop NRC-endorsed procedures. The NRC staff anticipates completing this activity by May, 2012.

actions taken or planned to address these conditions using the guidance in Regulatory Issues Summary 2005-20, Revision, 1, Revision to NRC Inspection Manual Part 9900 Technical Guidance, Operability Conditions Adverse to Quality or Safety, including entering the condition in the corrective action program

e. Any planned or newly installed protection and mitigation features

f. Results and any subsequent actions taken in response to the peer review REQUIRED RESPONSE In accordance with 10 CFR 50.54(f), an addressee must respond as described below. The submission of the requested information is in stages to allow adequate time for further interactions with the stakeholders to provide clarifications, to develop implementation procedures and processes, and to develop the associated guidance as needed.

1. Within 120 days of the date of this information request, the addressee will confirm that they intend to use the NRC-endorsed seismic walkdown procedures, or provide to the NRC a description of the process that will be used to conduct the walkdowns and to develop the needed information.

2. Within 180 days of the NRCs endorsement of the walkdown process, each addressee will submit its final response. This response should include a list of any areas that are unable to be inspected due to inaccessibility and a schedule for when the walkdown will be completed.

If an addressee cannot meet the requested response date, the addressee must provide a response within 90 days of the date of this information request and describe the alternative course of action that it proposes to take, including the basis of the acceptability of the proposed alternative course of action and estimated completion dates.

The required written response should be addressed to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, 11555 Rockville Pike, Rockville, MD 20852, under oath or affirmation under the provisions of Sections 161.c, 103.b, and 182.a of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f). In addition, addressees should submit a copy of the response to the appropriate regional administrator.

Enclosure 3 Reference List SECY 11-0124, Recommended Actions to be taken without Delay from the Near-Term Task Force Report, Agencywide Documents Access and Management System (ADAMS) Accession No. ML11245A158, September 9, 2011.

SECY 11-0137, Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned, ADAMS Accession No. ML11272A111, October 3, 2011.

SRM SECY 11-0124, Recommended Action to be taken without Delay from the Near-Term Task Force Report, ADAMS Accession No. ML112911571, dated October 18, 2011.

SRM SECY 11-0137, Prioritization of Recommended Actions to Be Taken in Response to Fukushima Lessons Learned, ADAMS Accession No. ML113490055, dated December 15, 2011.

10 CFR 50.54 - Conditions of Licenses Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, GDC 2, Design Bases for Protection against Natural Phenomena 10 CFR 50.34(a)(1), (a)(3), (a)(4), (b)(1), (b)(2), and (b)(4) 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants, to 10 CFR Part 100, Reactor Site Criteria Temporary Instruction 2515/183, Follow-up to the Fukushima Dai-ichi Nuclear Station Fuel Damage Event Summary of Observations report to encapsulate the performance of TI 2515/183 (http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/follow-up-rpts.html).

Electric Power Research Institute (EPRI) report NP-6041-SL Revision 1, A Methodology for Assessment of Nuclear Power Plant Seismic Margin, August 1991.

Seismic Qualification Utility Group (SQUG) procedure: Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Power Plant Equipment, International Atomic Energy Agency (IAEA) NS-G-2.13, Evaluation of Seismic Safety for Existing Nuclear Installations.