ML12333A275
| ML12333A275 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/16/2012 |
| From: | Patel D Entergy Operations |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML123330366 | List: |
| References | |
| W3F1-2012-0100 WF3-CS-12-00003 | |
| Download: ML12333A275 (48) | |
Text
Potentially Adverse Seismic Conditions LB # SW C/AWC # I DENTI FI E D COND ITI ON L IC E N S IN G BASIS E V A L UA TI ON C ON C LU S I ON RE SOLUT I ON S T A T US L B-01 AWC-00 1 An a nchor bolt o n SI S R-8 8 3 is m issi n g (1 o f 4). Cond i t i o n m ee ts t h e L ic en s i n g B a s i s. Calc u lati on S ISR8 8 3 sh o ws that o n ly 3 b olts are req uired o n t h is b asep l at e. N/A N/A L B-02 AWC-00 7 One c o n ta m i n ati o n prot e cti o n dis p osal bin is n o t se c ured to the o thers. Condition meets the Licensing Basis.
The b i ns are l o cat e d a w ay fr o m t h e E m erge ncy Feedwat e r P u m p and other safe t y r elated S SCs in the room. T h e l oo se b in d o es n o t p o se a n y s e is mic ha zard a n d wo u ld n o t i m p act the safety r e lated S SCs w it h in t h e room. N/A N/A L B-03 AWC-00 9 An a nchor b o lt is missi n g o n pi p e su p p o rt C D RH4 00 2. Condition meets the Licensing Basis.
The b ase plate a n d su pp o rt ass ociated with it are n o n-safety and n o n-seis mic. D rawi n g 4305-1 193 8 d o es n ot show t h e b olt detai l and gi v es n o in f o r m ati o n o n t h e nu m b er of anc h ors. Th is is c o n cl uded to n o t b e a s e is m ic c o n cern. N/A N/A N/A AWC-01 1 The following is a list of seismic concerns documented in AWC-011: Se v ere c o rr o si o n o f t ub e st eel su pp o rti n g c o nduits C o ndu it 30819D-S B is c o rr oded S tr u ts su p p o rti n g lar g e b o re p i p es (bel o w a n d a b ov e) are corroded
, A n g le s t e e l m e m b er su p p o rti n g ov erhead s t ai r s are corroded O ther m ild c o rr o si o n was f o un d t h r ough o u t the ar e a N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action:
Initiate CR
-WF3-2012-05729. CR Suggested Action: Close CR to WRs 288661, 288662, and 288663.
Operability Review:
EC-40681 has been approved which concludes that the corrosion identified in this CR does not present any immediate Operability concern for the CCW System. The surface corrosion on support CCRR378 is only minor surface corrosion. The conduits identified do not require the supports to be in place to meet the minimum span requirements for Operability. Support CCRR395 on line 3CC20
-3B (CCW DRY TOWER B OUTLET TO CCW HT EXCH B) has more than minor surface corrosion. With the current corrosion, Engineering has determined that there is adequate load margin for these two supports.
CR-WF3-2012-05719 Initiated Potentially Adverse Seismic Conditions LB # SW C/AWC # I DENTI FI E D COND ITI ON L IC E N S IN G BASIS E V A L UA TI ON C ON C LU S I ON RE SOLUT I ON S T A T US N/A AWC-01 4 The following is a list of adverse conditions identified in AWC-014: M issi n g b olt o n su pp o rt near valve S PM V A A A 328 S PM V A A A 32 7 s everely c o rr o d ed S ev ere c o rr o si o n o n base plate S e v ere c o rr o si o n o n pi pe su p p o rt M o derate c o rr o si o n o n valve SP M V A A A 32 6 B N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action: Initiate CR-WF3-2012-04956. CR Suggested Action: Close CR to WR s 286031, 286033, 188404, 138259, 286034, and 286035.
Operability Review:
No structural or seismic issues were found that could impact safety related equipment. The amount and severity of the corrosion found does not challenge the operation of the DCT/WCT Train B fans and therefore, Train B Ultimate Heat Sink remains operable.
CR-WF3-2012-04956 I n itiated N/A AWC-01 4 The c onduit h o u si n g near v alve SP M V A A A 33 0 is s everely c o rr o d ed. N o Licens in g Basis E v al uati o n was perf o r med. T h is o bser ved c o nd iti o n was alrea d y d ocumented in t h e C AP with a CR. Initial Action: Identified previously initiated Condition Report CR
-WF3-2011-07679. CR Suggested Action: Replace flex conduit.
Operability Review: Examination of exposed cabling exiting the conduit shows no sign of insulation degradation. There is also no indication of water contact with electrical conductors and no indication of a ground on any electrical buses. Visual inspection revealed no indication of water in the subject conduit
. CR-WF3-2011-07679 Initiated L B-04 AWC-01 4 B o lts m issi n g o n p u m p base plate.
Condition meets the Licensing Basis.
SQ-MN-198 specifies that four bolts are required for anchorage. Four bolts are installed on the base plate. Extra h oles are p res e n t in t h e b ase plate. N/A N/A Potentially Adverse Seismic Conditions LB # SW C/AWC # I DENTI FI E D COND ITI ON L IC E N S IN G BASIS E V A L UA TI ON C ON C LU S I ON RE SOLUT I ON S T A T US N/A AWC-01 8 A t em p o ra r y e n cl o su r e has been i nstalled in the Swit c hgear B Room. It h as t h e p o t e ntial to i m pact p a nels near it.
T h e walls are b olted t o g e t h er, bu t there are no anc h ors b o lti n g t h e encl o su r e to t h e flo o r. T h ere is o n ly a 7 cleara n ce fr o m L C P-6 2 and o n e si d e o f t h e encl o su r e. N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P, a CR was i n itiated, a nd chang es w e re i mm ed i at e ly m a d e in t h e fiel d. Initial Action: Initiated CR
-WF3-2012-05172. CR Immediate Action: Recommended that the enclosure be braced to surrounding steel or it be removed until an analysis can be done.
Operability Review: ECR 40448 states that: "Scaffold bars have now been securely attached to the structural angle members in the wall panels using scaffold clamps. These scaffold bars are attached with scaffold clamps to HVAC duct supports that happen to be adjacent to and above the enclosure. These braces are set in such a way that the enclosure will not be able to move during a seismic event and strike any of the surrounding safety related equipment. This will ensure that the enclosure can be considered to be seismically restrained." Therefore, the above described condition has been resolved and the temporary enclosure is not a seismic threat to any of the surrounding equipment.
Closed LB-05 AWC-03 0 Bar rels near c o l u m n 10 A, l in e N are n o t p r o perly se c u red. Cond i t i o n m ee ts t h e L ic en s i n g B a s i s. It is clear from photos of these unsecured barrels that no Safety Related SSCs are within striking range of the barrels if they were to fall over. Also, the barrels are light and have a low center of gravity making them unlikely to fall over, roll, and damage equipment in the area.
N/A N/A N/A AWC-03 7 There is se v ere c o rr o si o n o n valve CHWMV A A A121 A. N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action: Initiated CR
-WF3-2012-06472. CR Suggested Action: Close CR to WO 196829.
Operability Review: Civil Design Engineering reports that none of this corrosion is considered to be severe and none of the identified corrosion affects the operation or structural
/seismic capacity of the valve.
CR-WF3-2012-06472 I n itiated Potentially Adverse Seismic Conditions LB # SW C/AWC # I DENTI FI E D COND ITI ON L IC E N S IN G BASIS E V A L UA TI ON C ON C LU S I ON RE SOLUT I ON S T A T US N/A AWC-03 7 Se v ere c o rr o si on was found o n v alve CHWMV A A A 788 A and CHWMV A A A 127 B. N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action: Initiated CR-WF3-2012-05372. CR Suggested Action: Close CR to WRs 287812 and 287813.
Operability Review: Civil Design Engineering reports that none of this corrosion is considered to be severe. None of the identified corrosion affects the operation of the identified valves.
CR-WF3-2 012-0 5372 I n itiated N/A AWC-03 7 Se v ere c o rr o si o n and lea k a g e o n v alv e s CHW M V A A A436 and C H W M V A A A 88 1 N o Licens in g Basis E v al uati o n was perf o r med. T h is o b ser ved c o nd iti o n was alrea d y d ocumented in t h e C AP with a CR. Initial Action: Identified existing Condition Report CR-WF3-2012-05089. CR Suggested Action: Close CR to WRs 286898 and 286900.
Operability Review: CHWMVAAA436 and CHWMVAAA881 are 4 inch (normally locked open
) manually operated butterfly valves which have a passive safety function of being open to ensure Chilled Water flow to essential air handling units. These valves are not containment isolation valves. These valves can be closed to isolate the supply header for system maintenance, but serve no safety function in the closed position in a post
-accident situation. EC Reply 40355 addresses that with the amount of corrosion identified, the structural integrity of the gland follower bolts and nuts is such that there is no challenge to the pressure boundary based on the amount of material remaining.
CR-WF3-201 2-05089 I n itiated L B-06 AWC-03 7 A c h ain fr o m a cra n e has the potential to interact with a nearby panel or piping.
Cond i t i o n m ee ts t h e L ic en s i n g B a s i s. The o n ly eq u i p m ent t h at the c h ain c o u ld i m p act is p an el PMCIMUXRA4 601. This is a n o n-safety and n o n-seis mic p a nel. A f t er re ev al uati o n, it was d e t er m i ned that the p i p i n g c o u ld n o t b e i m pact e d fr o m t h e ch a i n. N/A N/A Potentially Adverse Seismic Conditions LB # SW C/AWC # I DENTI FI E D COND ITI ON L IC E N S IN G BASIS E V A L UA TI ON C ON C LU S I ON RE SOLUT I ON S T A T US N/A AWC-04 1 There is d egr ad ati o n of the c o n cre t e p ad near em b ed ded p l at e s t o w h ich the legs o f t a n k N G-MACC-00 5 are w e l ded, and there are cracks in c o ncre t e near em b ed ded p l at e s to which the legs o f t a n k N G-MACC-00 6 are w e l d ed. N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action:
Initiate CR
-WF3-2012-0527 8. CR Suggested Action: Close CR to WR 287650.
Operability Review: The loose grout underneath NG MACC0005 is from around the embed plates to which the tank is welded. This loose grout does not affect the seismic or structural capacity of these embedded plates since they are held into the concrete with cast
-in-place anchors. The embed plate details are shown on drawing G663 at coordinate D14 on the drawing. This loose grout is treated as a cosmetic coating for the pad. CR-WF3-2 012-0 527 8 I n itiated N/A AWC-04 1 There is se vere c o rr o si o n o n the su pp o rt f or c onduit li n es 32095 G-N B and 32095 F-N B. N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action: Initiate CR
-WF3-2012-0520 3. CR Suggested Action: Close CR to WR 287462.
Operability Review:
The se conduit supports are not safety
-related, are not the subject of any Technical Specifications or the Technical Requirements Manual , and do not perform a necessary support function for the purpose of ensuring accident prevention/mitigation, safe plant shutdown or reactor coolant pressure boundary integrity. This condition report describes a condition of a Structure, System or Component (SSC) that is not within the scope of the Operability Determination Process.
CR-WF3-2 012-0 520 3 I n itiated N/A SWEL 1-0 0 3 L i gh t swit c h ins id e w eather e n cl o su r e is not se c ured. N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action:
Initiate CR
-WF3-2012-0574 3. CR Suggested Action: Add a step to Task 07 of WO 290744 to reinstall light switch to MCC 315B weather enclosure.
Operability Review: CCW/ACCW Train B is currently out of service per EOS 12-0433. The plant is currently in MODE 6.
Although work on MCC
-315B is not yet completed and CCW/ACCW Train B is out of service, the condition identified in this CR does not affect the operation of any of the breakers in MCC
-315B and does not affect the Operability of CCW/ACCW Train B.
CR-WF3-2 012-0 574 3 I n itiated Potentially Adverse Seismic Conditions LB # SW C/AWC # I DENTI FI E D COND ITI ON L IC E N S IN G BASIS E V A L UA TI ON C ON C LU S I ON RE SOLUT I ON S T A T US N/A SWEL 1-0 2 0 B olts do n o t h a v e su fficient t hread interacti o n (nu ts are also m issi ng) o n plate that c o nn ec t s s o le n o id t o valve. N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action: Initiate CR
-WF3-2012-04905 CR Suggested Action: Implement WR 285749.
Operability Review: EC 40135 documents the seismic qualification of the solenoid mounting plate is not affected by the current configuration. It also documents the corrosion is not severe enough to cause any structural concerns.
CR-WF3-2 012-0 4905 I n itiated L B-07 SWEL 1-0 6 4 Cracks f o un d near s everal a nchors. Cond i t i o n m ee ts t h e L ic en s i n g B a s i s. A nchors are cast-i n-place, n o t w e dg e a nchors. T he cracks in t h e su rface a pp ear t o be cracks ass ociated with either a su rface patch aft e r p l ace m ent or a gr o u t pad p o u red und er the e qu i p ment o n ce it was s e t in pl ace. This g r o u t will b e b eari n g o n ly. N/A N/A N/A SWEL 2-0 2 1 One o f t h e f o u r 3/4 di a m e t er anchor b o lts is l oo se. N o Licens in g Basis E v al uati o n was perf o r med. T his was enter e d di r ec t ly i n to t h e C A P and a CR w as i nitiated. Initial Action: Initiate CR-WF3-2012-0569 8. CR Suggested Action: Tighten nut fully down on the baseplate using proper plant procedure.
Operability Review:
The seismic qualification of this heat exchanger is shown in SQRT file SQ
-NSSS-PE-56. The analysis for the anchors is on pd f pages 57 and 58 of the SQRT File. The tensile stress in the bolts on this end of the heat exchanger is 32,357 psi. The shear stress is 6491 psi. The allowable tensile stress is 43,316 psi. Even with the gap under the nut on one of the anchors, the shear will still be carried by all four of the bolts on this end of the heat exchanger. The tensile load will begin to be carried by the three fully tightened nuts, but the one with the gap will begin to take the tensile load as the other three begin to stretch with the load.
Based on EC 40666, there is no operability impact to the Spent Fuel Pool or the Spent Fuel Pool Cooling System.
CR-WF3-2 012-0 569 8 I n itiated
Licensing Basis (LB) Evaluation Form LB Evaluation No.
LB-01 Originating SWC/AWC AWC-001 Equipment ID No. SISR-883 Equip. Class N/A Equipment Description Pipe Support Location: Bldg.
RAB Floor El. -35 Room, Area Safeguards Roo m B Condition On pipe support SISR
-883, one of the four anchor bolts was found to be missing.
Documents Reviewed
Calculation SISR883
Licensing Basis
Anchor bolts and base plate stresses shall be within allowable limits. Evaluation
Review of calcu lation SISR883 shows that only 3 anchor bolts are required for this base plate. Conclusion Condition Meets the Licensing Basis: Yes No Prepared by: Dinesh Patel Date 10-27-2012 Licensing Basis Reviewer Reviewed by:
Greg Ferguson Date 11-10-2012 Peer Reviewer
Licensing Basis (LB) Evaluation Form LB Evaluation No. LB-02 Originating SWC/AWC AWC-007 Equipment ID No. N/A Equip. Class N/A Equipment Description Contamination Protection Disposal Bins Location: Bldg. RAB Floor El. -35 Room, Area Emergency Feedwater Pump Area Condition A series of contaminati on protection disposal bins has one of five bins loose and not secured to other bins.
Documents Reviewed N/A Licensing Basis Loose items may not interact with Safety Related SSCs.
Evaluation The bins are located away from the Emergency Feedwater Pump and other safety related SSCs in the room. The loose bin does not pose any seismic hazard and would not impact the safety related SSCs within the room.
Conclusion Condition Meets the Licensing Basis:
Yes No Prepared by: Dinesh Patel Date 10-27-2012 Licensing Basis Reviewer Reviewed by: Greg Ferguson Date 11-10-2012 Peer Reviewer
Licensing Basis (LB) Evaluation Form LB Evaluation No.
LB-03 Originating SWC/AWC AWC-009 Equipment ID No. CDRH4002 Equip. Class N/A Equipment Description Pipe Support Location: Bldg. CTB Floor El.
-35 Room, Area B59A, Wet Cooling Tower B Condition Pipe support CDRH4002 has one of its four anchor bolts missing.
Documents Reviewed
Drawing 4305-11938 Licensing Basis
Anchor bolts and base plate stresses shall be within allowable limits. Evaluation
The base plate and support associated with it are non
-safety and non
-seismic. Drawing 4305
-11938 does not show the bolt detail, and gives no information on the number of anchors. This is concluded to not be a seismic concern.
Conclusion Condition Meets the Licensing Basis: Yes No Prepared by: Dinesh Patel Date 10-27-2012 Licensing Basis Reviewer Reviewed by:
Greg Ferguson Date 11-10-2012 Peer Reviewer
Licensing Basis (LB) Evaluation Form LB Evaluation No. LB-04 Originating SWC/AWC AWC-014 Equipment ID No. SP MPMP0014 A and SP MPMP0014 B Equip. Class N/A Equipment Description Sump Pump Location: Bldg. RAB Floor El. -35 Room, Area B59A, Wet Cooling Tower B Condition An anchor bolt was found missing on a sump pump cover base plate.
Documents Reviewed SQ-MN-198
Licensing Basis Anchor bolts and base plate stresses shall be within allowable limits.
Evaluation Review of SQ-MN-198 indicates that only four anchor bolts are required for anchoring the sump cover plate. Presently four anchor bolts are installed.
This indicates that the sump pump cover plate has extra holes drilled into the plate. No anchor bolts are missing, and this meets the Licensing Basis.
Conclusion Condition Meets the Licensing Basis:
Yes No Prepared by: Dinesh Patel Date 10-27-2012 Licensing Basis Reviewer Reviewed by: Greg Ferguson Date 11-14-2012 Peer Reviewer
Licensing Basis (LB) Evaluation Form LB Evaluation No. LB-05 Originating SWC/AWC AWC-030 Equipment ID No. N/A Equip. Class N/A Equipment Description Disposal Barrels Location: Bldg. RB Floor El. -4 Room, Area Col. 10A, Line N Condition Disposal/Storage barrels are not secured to each other.
Documents Reviewed N/A Licensing Basis Loose items may not interact with Safety Related SSCs.
Evaluation It is clear from photos of thes e unsecured barrels that no Sa fety Related SSCs are within striking range of the barrels if they were to fall over. Also, the barrels are light and have a low center of gravity making them unlikely to fall over, roll, and damage equipment in the area. This condition meets the Licensing Basis.
Conclusion Condition Meets the Licensing Basis:
Yes No Prepared by:
Brian Pace Date 11-14-2012 Licensing Basis Reviewer Reviewed by: Greg Ferguson Date 11-14-2012 Peer Reviewer
Licensing Basis (LB) Evaluation Form LB Evaluation No.
LB-06 Originating SWC/AWC AWC-037 Equipment ID No. N/A Equip. Class N/A Equipment Description Hanging Chain from Crane Location: Bldg.
RAB Floor El. +46 Room, Area Northwest RAB +46 Area Condition A chain hanging from a crane in the room has the potential to impact nearby panels and piping. Documents Reviewed Asset Suite Equipment Database Licensing Basis Loose items may not interact with Safety Related SSCs.
Evaluation The chain for the overhead chainfall cannot strike or cause damage to any equipment that is safety related.
The panel, PMCIMUXRA4601, that is nearby is non-safety and non-seismic according to Asset Suite. After reevaluation, it was determined tha t the piping and valves nearby are higher than the main mass of the chain making it doubtful the chain could damage the equipment.
Conclusion Condition Meets the Licensing Basis:
Yes No Prepared by: Brian Pace Date 11-07-2012 Licensing Basis Reviewer Reviewed by: Greg Ferguson Date 11-10-2012 Peer Reviewer
Licensing Basis (LB) Evaluation Form LB Evaluation No. LB-07 Originating SWC/AWC SWEL1-064 Equipment ID No. HVCMAHU0009-A Equip. Class Air Handlers Equipment Description Control Room Emergency Filtration Unit A Location: Bldg. RAB Floor El. +46 Room, Area Room 314, Col. 9A, Line K Condition Cracks found near several anchors (adverse condition for Question #4).
Documents Reviewed IPEEE Seismic Report page E-76
Licensing Basis Anchor bolts and base plate stresses shall be within allowable limits
Evaluation On page E-76 of the IPEEE Seismic Report, it states that the unit has twelve 7/8" diameter cast in place bolts. The cracks in the surface appear to be cracks associated with either a
surface patch after placement or a grout pad poured under the equipment once it was set in place. This grout will be bearing only. Therefore, this meets the licensing basis.
Conclusion Condition Meets the Licensing Basis:
Yes No Prepared by:
Brian Pace Date 10-29-2012 Licensing Basis Reviewer Reviewed by: Greg Ferguson Date 11-10-2012 Peer Reviewer
Sheet 1 of 3 Peer Review Checklist for SWEL Instructions for Completing Checklist This peer review checklist may be used to document the review of the Seismic Walkdown Equipment List (SWEL) in accordance with EPRI 1025286, Section 6: Peer Review. The space below each question in this checklist should be used to describe any findings identified during the peer review process and how the SWEL may have changed to address those findings. Additional space is provided at the end of this checklist for documenting other comments. 1. Were the five safety functions adequately represented in the SWEL 1 selection? The SWEL1 contains 94 components and addresses all five safety functions. Many components provide safety functions for multiple systems, and/or are part of frontline support systems consistent with the guidelines provided in EPRI Report 1025286, Section 6.2.
Y N 2. Does SWEL 1 include an appropriate representation of items having the following sample selection attributes: a.Various types of systems? Components included in the SWEL1 comprise a variety of systems such as Reactivity Control System, Reactor Pressure Control, Reactor Inventory Control, Decay Heat Removal System, Emergency Desiel Generator,Vital A/C and D/C systems. Y N b.Major new and replacement equipment? Some New and/or replacement components are included in SWEL 1.
Y Nc.Various types of equipment? SWEL1 includes at least one example of each of the 21 classes of equipment with the exception of class 13 (Motor Generators). WF3 does not have any Class 13 equipment that is seismic class 1. All classes of equipment are well represented. In general, the number of components in each class is proportional to the number of safety-related components of that class in the plant as a whole.
Y N Sheet 2 of 3 Peer Review Checklist for SWEL d.Various environments? The SWEL1 contains components in mild, harsh, indoor, and outdoor environments. The components are located in different buildings, rooms, and/or on different builidng elevations. The SWEL1 also includes components located inside Reactor Building.
Y N e.Equipment enhanced based on the findings of the IPEEE (or equivalent) program?
The SWEL1 includes components that we re identified during the IPEEE as being potentially vulnerable to a seismic event. This includes adding component 4KVESWGR3B to the SWEL1 walkdown list since a modification was done to a station air pipe to avoid an interference. For the control room cabinets, all of the bookcases, filing cabinets, etc, in the control room were walked down as part of the area walk-by for other components.
Y N f.Were risk insights considered in the development of SWEL 1? SWEL 1 includes high risk components based on risk significance in the plant Probabilistic Risk Assessment (PRA) models.
Y N 3. For SWEL 2: a.Were spent fuel pool related items considered, and if applicable included in SWEL 2? SWEL 2 includes components for maintaining cooling of the SFP, which are Seismic Category I components.
Y N b.Was an appropriate justification documented for spent fuel pool related items not included in SWEL 2? Justification was provided in the Process used to determine the SWEL 2 listing for WF3 Y N
Table 1 - SWEL Review Seismic Walkdown Submittal Report Review Comments and Resolutions Form Engineering Report Number WF3-CS-12-00003 Rev. Title: WF3 SWEL 1 and SWEL 2 Quality Related:
Yes No Special Notes or Instructions:
Comment Number Section/Page No. Review Comment SWEL1 COMMENTS Response/Resolution Reviewer's Accept Initials 1 S.R equipment spread sheet How did you determine whether or not the component is "Undergoes Regular Configuration Inspections" under column Screen 2?
The BL indicates the all components are NOT Undergo Regular Configuration Inspections with the exception of 2 that are (those are SI MPOL0001 and CMUMPOL0001). Is this true? I looked in Asset Suite, under PMID for these two components; it indicates that the PM tasks for these two components have been RETIRED?
The two items described in the Review Comment #1 are both pools inside our RAB. These are considered structures, not equipment. However, they are inspected as part of our Maintenance Rule for Structures in procedure EN
-DC-150. If you look at this procedure and look at the equipment for WF3, the RWSP and the CSP are both listed separately in the list. The PM tasks were RETIRED, but new tasks are being created now. The creation of these tasks is being tracked in CR
-WF3-2011-08140 CA 25. HG 10-23-12 2 S.R equipment spread sheet Screen 1 Column should be filled in either "
Yes" or "No" for whether the component is Seismic Cat. 1 or not.
Corrected.
HG 10-23-12 3 S.R equipment spread sheet Screen 4, under Temperature and Humidity column should be filled in either "T" for Hi gh Temp. or "H" for H i Humidity of "T, H" for both conditions.
Corrected.
HG 10-23-12 4 S.R equipment spread sheet Please refer to procedure EN
-DC-168 , Rev. 0, Attachment 9.4, Table 9.4.1 for format and instructions to fill out Base List 1. Corrected.
HG 10-23-12 5 Table 9.4.2 Column titles do not match Attachment 9.4 of procedure EN-DC-168 , Rev. 0, Table 9.4.2. Additional columns are ok for additional information but should be hidden or moved such that the final table will have all columns match the Table in the procedure.
(i.e. The Table should only Corrected.
HG 10-23-12 Table 1 - SWEL Review have one Environment column, and the two untitled columns to the right of Equipment ID do not need to be part of this Table)
. 6 Table 9.4.2 Drawings for each component need to be provided in the appropriate column
. Drawings provided.
HG 10-23-12 7 Table 9.4.2 The first column, the SWEL number should be "SWEL 1-001". The "1" after SWEL was missing.
Corrected.
HG 10-23-12 8 Table 9.4.2 Under System Type column, it would be helpful if the systems identified Asset Suite is provided for the associated components in the SWEL 1.
Corrected.
HG 10-23-12 9 Table 9.4.2 Are there reasons for not including two classes of Equipment (class 12 - Air Compressor and 13 - Motor Generators
)? Need to add class 12 to items SWEL1
-095 and 096. This has been corrected. Class 12 was added to the list. WF3 does not have any Class 13 equipment that is seismic class
- 1. Incorporated.
See additional comment.
HG 10-24-12 10 Table 9.4.2 Does the SWEL 1 include any equipment enhanced based on the findings of the IPEEE.
Page 3-45 of the WF3 IPEEE Reduced scope Seismic Margins Assessment Report, Section 3.1.6 identifies some CRs for resolution of outlier concerns (CR 1019 and CR-94-1111), the components associated with these CRs should be included in the SWEL1 so that a walk down can be conducted on these equipment to confirm that modifications have been completed to resolve these concerns. No. WF3 did not have to do any equipment modifications due to IPEEE.
Added 4KVESWGR3B to the SWEL1 walkdown list since a modification was done to a station air pipe to avoid an interference. For the control room cabinets, all of the bookcases, filing cabinets, etc, in the control room were walked down as part of the area walk
-by for other components. This would be all of the items from our IPEEE.
See additional comment. HG 10-23-12 1 1 Table 9.4-2 Under Column "ROOM/COL" several column lines are missing, e.g. SWEL
-002, 212/10A
-? SWEL-018 "421/?", SWEL-019 "420/?", SWEL-061 "?/9A-l, SWEL-084 "304/9A-? etc. Complete the missing information.
Corrected. The location identifications came directly from Asset Suite as shown.
However, the column lines were removed. Some items do not have any rooms or columns identified as they are not identified in Asset Suite.
SD 10-23-12 1 2 Table 9.4-2 The anchorage configuration verification is not provided in Corrected.
SD 10-23-12 Table 1 - SWEL Review Column "ANC" for any of the equipment. Enter "Yes" or "No" as applicable.
1 3 S.R equipment spread sheet Item # 14 requires "X" in the applicable safety function supported by the equipment in lieu of "Yes" or "No".
The spread sheet is no longer being used. The Word file is now being used for the full table.
SD 10-23-12 14 S.R equipment spread sheet What column "None" after "Support" column stands for?
The spread sheet is no longer being used. The Word file is now being used for the full table. However, the column "None" was being used to show equipment that did not meet any of the 5 system functions.
This has now been changed and the function in the 5 system functions is not checked. SD 10-23-12 15 S.R equipment spread sheet What is the title of column for abbreviations GE, JJ, DC, DM etc? These are the initials of the team members that helped document the 5 safety functions. If one of the individuals stated that they believed that piece of equipment met one of the functions, then their initials were added to that list.
However, the spread sheet is no longer being used. The Word file is now being used for the full table.
Table 1 - SWEL Review 16 Table 9.4.4 Inclusion of pipe on the RDD list is different than other plants in the industry.
We (ENERCON) are awaiting a response to a question posed to the NEI Seismic Task Force. Periodic inspection on piping should be confirmed. Keep the documentation of walkdowns completed of the piping system. Final decision for inclusion on the RDD will be made pending resolution of the above. Because of the way the piping is connected to the fuel pool at WF3, the lines that are included could result in a rapid drain down. The water in the pool could get to right at the top of the fue l assemblies in the pool.
HG 10-23-12 17 Tables 9.4.3 and 9.4.4 Per procedure EN
-DC-168, page 48 of 80 item 34 states: "Format the corresponding BS2 and RDD line item to be selected for SWEL2 as bold in Tables 9.4.3 and 9.4.4".
Please bold the items that were selected for SWEL2 in Tables 9.4.3 and 9.4.4. The same should apply for SWEL1 as well (items selected for SWEL1 should be bolded in Table 9.4.1).
Corrected.
HG 10-23-12 18 Table 9.4.3 Need to add components for SWEL2
-012, 013 and 014 (FS EMTR314A 5M, FS EMTR314B 5M, and FS EMTR314B 6F respectively) to the Base List 2 (Table 9.4.3).
Corrected.
HG 10-23-12 19 Table 9.4.3 Please fill in the "TRAIN" column for components that have train specific based on Equipment ID (i.e. items 2006, 2007, 2010, 2019-2029-.) These items do not have the train defined in Asset Suite. The ones that are completed are directly from Asset Suite.
HG 10-23-12 20 Table 9.4.5 Last column "RDD", should replace "N/A" with "N" and the last 5 items should be "Y".
No changes are required.
I withdraw this comment. T he column is OK as is. HG 10-23-12 Table 1 - SWEL Review 21 Table 9.4.5 All SWEL Numbers SWEL2
-001 thru SWEL2
-005 are identified as CKTBRK under Equipment ID Column.
SWEL Numbers SWEL2
-004 and SWEL2
-005 are listed as Class 14 while SWEL2
-001 thru SWEL001 thru SWEL2
-003 and several other are listed as Class 1. Clarify the distinction.
The three FS breakers are 100 amp frame breakers and are located inside a motor control center. The two CC breakers are both 5 amp breakers and
are located inside a power distribution panel. SD 10-23-12 22 Table 9.4.5 Under Equipment Column, Equipment IDs are listed which are consistent with AS. What are the additional subsets, i.e. 5D, 5M, 6F and CKTBRK etc.? Provide subtitles for these two columns. This is the way our IDs are presented in Asset Suite. There are no subtitles for these two columns. Having them in 3 columns makes it easier to find the equipment, plus makes it easier to enter and read. This is a presentation preference and the grid lines will not be visible in the final document.
SD 10-23-12 23 Table 9.4.3 Under Equipment Column, Equipment IDs are listed which are consistent with AS. What are the additional subsets, i.e. 10F, 5D, 5M, 6F and CKTBRK etc.? Provide subtitles for these two columns.
See response to comment 22.
SD 10-23-12 Reviewed By:
Heidi Graf / Sada Dhingra Date 10/2 4/12 Resolved By:
G. N. Ferguson Site/Department:
ENERCON/MECH Ph.770-792-6936 /916-293-9801 Date: Ph. 504-739-6538 Table 2 - SWC/AWC Review Seismic Walkdown Submittal Report Review Comments and Resolutions Form Engineering Report Number WF3-CS-12-00003 Rev. Title WF3 Seismic Walkdown Submittal Report
- SWCs and AWCs Quality Related:
Yes No Special Notes or Instructions:
Comment Number Section/Page No. Review Comment Response/Resolution Reviewer's Accept Initials 1
2
3
4
5 General, SWC+AWC
- General, SWC+AWC
General, SWC+AWC
General, SWC
General, SWC Where potential conditions are identified, it would be highly beneficial to include CR numbers generated (as available)
. This assists with cross
-referencing.
If comments include miscellaneous issues (i.e., missing clips, housekeeping issues, etc.), the "other seismic condition" question should be marked "N" unless disposition of conditions are included.
This is true for any identified condition - either mark "N" or provide justification/disposition that identified condition is seismically insignificant.
Anytime "N/A" is marked, a brief explanation/justification should be provided. (For line
-mounted items with common justification for anchorage questions, can be provided once on SWC). This includes anchorage, flexibility of lines, etc.
SWC Questions 2
-4 require response, even if answer is "Y" to include brief description (see EN
-DC-168 Att. 9.6 p. 7). This could include general description of hardware condition, overall configuration, corrosion, etc. (including for line-mounted items), specific to each question.
SWC Question 5 should include the document number used to evaluate the configuration (if Q. 1 is "Y"), and CRs and WRs written have been included in all SWCs and AWCs.
If the condition was deemed seismically insignificant, the question was marked "Y" it was clearly stated that there was no seismic concern.
All N/A items now have an explanation of why it has been marked that way.
All SWCs now have a response in questions 2
-4.
Document number has been included along with brief discussion.
BDK BDK
BDK
BDK
BDK Table 2 - SWC/AWC Review 6
7
8
9
10
General, SWC
SWEL1-003
General, SWC
AWC-014
SWEL1-008 should include a brief description of the results of that evaluation (see. EN
-DC-168 Att. 9.6 p. 7)
Question 6 should be answered, regardless of the responses to Questions 1
-5. If an inline component without anchorage, can indicate "Y" and add note of "Inline component - N/A" or similar.
Question 3 is marked "N" due to "mild corrosion" although the Question 6 is marked "Y". Question 6 is asking for an aggregate response to all anchorage questions (i.e., mark "N" if at least one of 2
-5 is marked "N"). If the "mild corrosion" is judged insignificant, that should be explained in Question 2, and should be marked as "Y".
If the "mild corrosion" is not insignificant, then Question 6 should be "N".
Please confirm that all cabinet/panel doors were opened (i.e., MCC cubicles). If not, the SWC should include justification for how the goals of the inspection are still being met without opening the cabinet (see FAQ 4.20),
or should be marked as incomplete pending deferral to when the cabinets will be able to be opened (i.e., outage).
Adding notes/comments to reference photos to identified conditions would be helpful, especially since multiple conditions are identified.
Questions 7 and 8 are marked "N" but include no explanation. Add explanation of conditions. Include photo of each condition identified.
Question 6 has been answered for all SWCs.
If question 1
-5 has been checked "No," question 6 will be checked "No" for all SWCs.
In all cases, if a SWEL item involving a panel or cabinet could not have all of its doors opened, then it was deferred until the next available time that all doors could be opened. If the SWEL item was not deferred then, all doors were opened unless otherwise explicitly stated on the SWC.
Comment Incorporated.
Comment Incorporated.
BDK BDK
BDK
BDK
BDK
Table 2 - SWC/AWC Review 11
12
13 14
SWEL1-010
SWEL1-012
AWC-002 AWC-042
Is oil/fluid leak under pump not an "other seismic condition" for answering Question 11 with "N"? How was the leak addressed when identified?
Photo shows pump foundation anchor very close to column baseplate anchor. Is this anchor spacing acceptable?
Photo of "tubes lying around" would be helpful.
Is this flex tube, or something more substantial?
Area walk-by identified water pooling at base of pipe support. Is this strut support baseplate intended to be recessed below slab surface?
This was previously identified in CR
-WF3-2011-05119 and WR -243506 and has been stated in the comments section of the SWC.
Yes it is acceptable.
These were only flex tubes. They posed no seismic concern and have been stated as such on the SWC.
This was discussed with site engineers and determined to be acceptable.
BDK
BDK
BDK BDK Reviewed By:
Benjamin D. Kosbab Date 10/8/12 Resolved By:
Brian Pace Site/Department:
ENERCON/Civil Ph. 770-590-2179 Date: 11-09-2012 Table 2 - SWC/AWC Review EN-DC-168 REV 0 Seismic Walkdown Submittal Report Review Comments and Resolutions Form Engineering Report Number WF3-CS-12-00003 Rev. Title WF3 Seismic Walkdown Submittal Report
- SWCs and AWCs Quality Related:
Yes No Special Notes or Instructions:
Comment Number Section/Page No. Review Comment Response/Resolution Reviewer's Accept Initials 1 2
3
4
SWEL1-082 SWEL1-082
SWEL1-087
SWEL1-087
Question 5: Provide the document number used to confirm anchorage configuration (dwg G574S05?)
Question 9: Add note as to why flexibility of attached lines is N/A.
Provide justification for N/A items. Please confirm cabinet was opened to inspect internals and weld conditions; from N/A responses and photo, it is not evident that the intent of NRC Guidance 4.20 for opening cabinets. Welds (including internal) still need to be checked as "anchorage" for adverse conditions, corrosion, etc. Need to answer question 6 especially to come to a firm conclusion.
Question 8: Answer says yes, but statement about fluorescent lights is open ended. Need to have firm conclusion for 'Y' that cages are not needed or marked as 'U' until verification is complete, at which point 'Y' or
'N' could be firmly justified.
Comment Incorporated.
A drawing that specifies the use of rigid connections has been identified and referenced on the SWCs that identified rigid connections. Comment Incorporated.
All fl uorescent lights have been changed to non-seismic concerns. It was determined after extensive conversation with site personnel that falling bulbs could not impact equipment in the area.
No bulbs were present over sensitive relays for example. SWCs or AWCs that identified florescent lights still have discussion about them on its respective checklist, but include a statement saying MPW MPW
MPW
MPW
Table 2 - SWC/AWC Review EN-DC-168 REV 0 5
6
7
8
9
10
11 12
13 1 4 SWEL1-087 SWEL1-089
SWEL1-089
SWEL1-016 AWC-005 (SWEL-016, -040, -089)
AWC-023 (SWEL-090)
SWEL1-092 SWEL1-092
SWEL1-092 AWC-006 Question 9: Add note as to why flexibility of attached lines is N/A.
Photo appears to show vertical conduits entering panel.
Provide justification for N/A items. See comments regarding SWEL1
-087. Justify N/A for attached lines.
Question 11 and general: If you conclude that there are no other seismic conditions, then you need to make it clear that the missing insulation cover bolt, missing insulation clips, and mild corrosion are not a seismic concern.
See generic comment regarding question 6. Make a firm conclusion in the 'Comments' section that there is no seismic impact with the corrosion noted.
What is the overall conclusion regarding all the comments identified (i.e., seismic concerns)
? See Kosbab general comments.
Make a firm conclusion regarding comments.
Add reference document to Question 5.
Explain N/A for Question 7 (either conclude 'Y' or explain there are no soft targets with 'N/A').
Explain reasoning for N/A for flexibility of attached lines (piping connections only, or piping is per design)
See generic comments regarding 'Comments'.
that falling bulbs pose no seismic concern for the equipment in the area.
See resolution to comment #2 above.
See resolution to comment #2 above.
Comment Incorporated.
Comment Incorporated.
These are not seismic concerns. They have been identified however with CRs and WRs as well.
Comment Incorporated.
Comment Incorporated.
Comment Incorporated.
Comment Incorporated.
Comment Incorporated.
MPW MPW
MPW
MPW MPW
MPW
MPW MPW
MPW MPW Table 2 - SWC/AWC Review EN-DC-168 REV 0 15
16
17
18
19
20
21
(SWEL1-092) SWEL1-094
AWC-021 (SWEL1-094)
SWEL1-044
SWEL1-044
SWEL1-060
AWC-010 SWEL1-066 See generic comments regarding N/A's for welded connections (Q2 and Q3), no answer for Q6, and open question related to fluorescent light (Q8).
See general comment (SWEL1
-087 comments on question 8) regarding fluorescent light.
For valves and in
-line components, it would be helpful to mention in Q5 and/or Q6 that the item is line
-mounted to support your N/As. It is also valuable to apply the guidance in EN
-DC-168, "Anchorage" and "Other Adverse Conditions" to a general inspection of flange bolts, exposed connections, etc. and note the condition found. See general comments regarding mild corrosion statement.
See comment above regarding N/As for valves and various connections of valve components.
Need firm conclusion on corrosion issue.
Was the entire fan assembly inspected? Give justification for N/A responses-components appear to be bolted to structure. Photo shows flexible cables coming into fan motor, so please review N/A response to Q9. Is the identified "moderate
-severe corrosion" a problem?
Check the status box on first page. Explain any N/A responses, specifically attached line flexibility question. Were connections of AHU to support steel evaluated from ladder or platform? Welded connection questions have been answered with either "Y" or "N" on all checklists. See comment resolution
- 4 above for fluorescent lights.
Comment Incorporated.
Comment Incorporated.
Comment Incorporated.
Comment Incorporated.
Identified as no seismic concern and a WR has been initiated.
Comment Incorporated.
Conditions were observed from the floor.
MPW
MPW
MPW
MPW
MPW
MPW MPW
Table 2 - SWC/AWC Review EN-DC-168 REV 0 2 2
23 24
25 26
27 AWC-004 (SWEL1-066)
SWEL1-069 SWEL1-070
SWEL1-070
SWEL1-071
SWEL1-072 Large displacement of lights during seismic event still needs to be verified, but all answers are 'Y'. Need to change to a 'U' or have a firm conclusion.
What is the conclusion with the bolts that were not completely visually inspected?
Wraparound bracing and spacers need to exist for individual batteries to ensure they fit snugly in their position.
Are the area block walls seismically qualified (IE Bulletin 80-11)? Provide reference for Question 5. What is the conclusion with lights in vicinity (Q8)?
Provide reference for Question 5. What is the conclusion with fluorescent lights (Q8)?
See comment resolution #4 above.
Comment resolved. Comment resolved.
Yes. This has been confirmed with site documentation.
See comment resolution #4 above.
See comment resolution #4 above.
MPW
MPW MPW
MPW
MPW
MPW Reviewed By:
Matt Wilkinson Date 10/8/12 Resolved By:
Brian Pace Site/Department:
ENERCON Ph. Date: 11-09-2012 Table 3 - LBE Review Seismic Walkdown Submittal Report Review Comments and Resolutions Form Engineering Report Number WF3-CS-12-00003 Rev. 0 Title: WF3 LBEs Quality Related:
Yes No Special Notes or Instructions: Comment Number Section/Page No. Review Comment Response/Resolution Reviewer's Accept Initials 1 General, LBE The first step of an LBE, per EPRI Guidance Section 5, is to determine the current licensing basis for the plant as it relates to the seismic adequacy of the equipment. Specifically, this should be done in the context of the identified potentially adverse seismic condition being evaluated. In several cases, this summarized "Licensing Basis" in the LBEs could be improved for clarity of intent.
LBE "Licensing Basis" summaries have been revised for clarity where possible, concisely stating the contextual licensing basis to allow the "Evaluation" to transparently conclude whether the licensing basis is met or not.
BK 11-15-12 2 General , LBE Recall that the LBE tool is specific for the NTTF 2.3: Seismic program, and is intended to document whether existing documentation regarding the plant licensing basis provides justification for acceptance of potentially adverse seismic conditions identified in the field. Documentation of SWE judgment about whether a condition is potentially seismically significant or not is not an appropriate use of the LBE tool; rather, use of judgment should be documented on the SWC/AWC forms based on SWE discussion in the field.
Disposition and eventual resolution of conditions not justified by an LBE should be done through the plant CAP to ensure appropriate tracking/trending and extent
-of-condition evaluations (where necessary).
Use of the LBE tool has been adjusted to better align with EPRI Guidance Section
BK 11-15-12 Reviewed By:
Ben Kosbab Date 10/30/12 Resolved By:
Dinesh Patel Site/Department:
ENERCON/CIVIL Ph.770-590-2179 Date: 11/12/12 Ph. 770-792-6975
Certjflcate of Completion Greg Ferguson Training on Near Term Task Force Recommendation 2.3-Plant Seismic Walkdowns June 21, 2012 Date Robert K.Kassawara EPRI Manager, Structural Reliability
&Integrity
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