ML13143A439
| ML13143A439 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/12/2013 |
| From: | Thomas Wengert Plant Licensing Branch III |
| To: | Weber L Nuclear Generation Group |
| Regner L, NRR/JLD, 415-1906 | |
| References | |
| TAC MF1648, TAC MF1649 | |
| Download: ML13143A439 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 12, 2013 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
SUBJECT:
PLAN FOR THE REGULATORY AUDIT REGARDING SEISMIC WALKDOWNS AT THE DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2, TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS. MF1648 AND MF1649)
Dear Mr. Weber:
On March 12,2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a request for information letter1 per Title 10 of the Code of Federal Regulations, Subpart SO.S4(f} (SO.S4(f) letter}. The SO.S4(f} letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great T5hoku Earthquake and subsequent tsunami. The request addressed the methods and procedures for plants to conduct seismic and flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.
By letter dated November 26, 2012, Indiana Michigan Power Company submitted a Seismic Walkdown Report as requested per Enclosure 3, "Recommendation 2.3: Seismic," of the SO.S4(f} letter for the Donald C. Cook Nuclear Plant (CNP), Units 1 and 2. The NRC staff plans to conduct a regulatory audit in accordance with the enclosed regulatory audit plan from July 17-19. 2013, to verify information and gain a better understanding of your conduct of the seismic walkdowns at CNP.
1 Located in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML12053A340.
L. Weber -2 If you have any questions, please contact me by telephone at 301-415-4037 or bye-mail at Thomas.Wengert@nrc.gov.
Sincerely, Thomas J. Wenge ,Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-315 and 50-316
Enclosure:
As stated cc w/encl: Distribution via Listserv
Audit Plan Donald C. Cook Nuclear Plant, Units 1 and 2
- 1. Background On March 12, 2012, the U.S. Nuclear Regulatory Commission staff (NRC or the staff) issued a request for information letter1 per Title 10 of the Code of Federal Regulations, Subpart SO.S4(f)
(the SO.S4(f) letter). The request addressed, in part, the conduct of seismic walkdowns to identify and address degraded, non-conforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.
- 2. Regulatory Audit Bases The NRC staff is conducting regulatory audits at a small number of operating reactors to gain a better understanding of the seismic walkdown methods and associated procedures used by licensees to prepare the Seismic Walkdown Report and to assist the staff in preparing its safety assessment.
The guidance for performing the seismic walkdowns was developed by the Electric Power Research Institute (EPRI) with extensive review and input from NRC staff in numerous public meetings, webinars, and public conference calls during its development. The EPRI submitted EPRI-102S286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic.. 2 (walkdown guidance) for endorsement, and the staff subsequently endorsed the walkdown guidance by letter dated May 31, 2012 3 .
The SO.S4(f) letter and the walkdown guidance are the basis documents for the conduct of the regulatory audit.
- 3. Regulatory Audit Scope The purpose of the seismic site audit will be to gain a better understanding of the conduct and outcomes of the seismic walkdowns and identify any need for additional information to facilitate the NRC staff's review of the licensee's walkdown report and prepare the staff assessment. If necessary, the NRC staff will request additional information using the appropriate regulatory process.
The scope of this regulatory audit is to determine if the seismic walkdowns conducted by Indiana Michigan Power Company (I&M, the licensee) to identify and address degraded, non-conforming, or unanalyzed conditions, were conducted in accordance with the SO.S4(f) letter and the walkdown guidance; and whether I&M verified the adequacy of the monitoring and maintenance procedures in compliance with the SO.S4(f) letter and the walkdown guidance.
The general process used to conduct the regulatory audit involves examination of related 1 Located in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML12053A340.
2 Located in ADAMS at Accession No. ML12164A181.
3 Located in ADAMS at Accession No. ML12145A529.
ENCLOSURE
-2 seismic walkdown documents, discussions with the seismic walkdown program participants, and examination of selected equipment or areas of the site that were walked down. This process is tailored for a site-specific audit as applicable.
The staff reviewed the licensee's walkdown report and compared it with the requested information in the 50.54(f) letter and the walkdown guidance. The factors that the NRC staff considered in choosing sites to audit were based, in part, on one or more of the following:
- Questions concerning whether the walkdown was performed consistent with the guidance
- Consideration of feedback and information gained during performance of regional inspections (e.g., Temporary Instruction 2515/188)
- Consideration of apparent seismicity relative to the current design basis or margins identified in the Individual Plant Examination for External Event (IPEEE) reviews Sections 4, 8, and 9 provide additional details regarding needed documentation, schedule, and specific focus areas.
- 4. Information Needs The licensee is requested to have the following information available on site for the audit team.
The information could be provided electronically or by paper copies. If provided electronically, the licensee is requested to have at least three computers available for the audit team, with a printer attached.
- Engineering reports and procedures that contain requirements or guidelines for the implementation of the seismic walkdown guidance, including current seismic licensing basis.
- Description of the process used for the peer review and the peer review report.
- Implementing procedures for the 10 CFR 50.54(f) letter, Enclosure 3, Seismic Walkdowns, including procedures for the seismic walkdowns themselves.
- Procedure for development of the seismic walkdown base lists and equipment lists (i.e., SWEL 1 and SWEL 2).
- Drawings of equipment anchorages for equipment selected for anchorage verifications.
- Discussion of training and qualifications (per Section 2 of the walkdown guidance) for personnel associated with seismic walkdown activities.
- Description of the process for licensing basis evaluations (per Section 5 of the walkdown guidance) and entry into the corrective action program, including condition report number, title, and brief summary of the issue or observation and its disposition.
- 3
- The list of seismic vulnerabilities that were identified during the IPEEE program, as discussed in Section 7 of the guidance document.
- The original walkdown and walk-by checklists The NRC staff also requests the licensee to make personnel that performed the walkdowns (including site staff and contractors) accessible upon request (either in person or by telephone).
Additional information needs identified during the audit will be communicated to the licensee's designated point of contact.
- 5. NRC Audit Team Team Lead James Isom (NRC)
Technical Lead Annie Kammerer (NRC)
Technical Support Luissette Candelario (NRC)
Technical Support John Ellegood (NRC, SRI)
- 6. Logistics The audit will be conducted at Donald C. Cook Nuclear Plant (CNP), Units 1 and 2, from July 17-19, 20.13. Entrance and exit briefings will be held with the licensee at the beginning and end of this audit, respectively, as well as daily debriefings of team activities. A more detailed proposed audit schedule is provided below.
- 7. Deliverables The NRC staff plans to issue an audit report/summary to the licensee within 90 days from the end of the audit. Additionally, the results of the audit will be utilized to focus the scope of any requests for additional information issued in the course of this review.
- 8. Proposed Seismic Walkdown Audit Schedule Wednesday, July 17 7:30 a.m. Arrival of audit team members and site badging 10:00 a.m. Entrance Meeting 10:30 a.m. Walkdown Process Orie.ntation with licensee 11:30 a.m. -12:15 p.m. LUNCH 12:15 p.m. - 4:00 p.m. Discussions with licensee, NRC document review, or plant walkdowns
- 4 4:00 p.m. Team meeting 5:30 p.m. Team Lead daily debrief with licensee Thursday. July 18 7:30 a.m. Team meeting 8:30 a.m. Continue discussions with licensee, plant walkdowns, etc.
11:30 a.m. -12:15 p.m. LUNCH 12: 15 p.m. - 4:00 p.m. Discussions with licensee, plant walkdowns, etc.
4:00 p.m. Team meeting 5:30 p.m. Team Lead daily debrief with licensee Friday, July 19 7:30 a.m. Team meeting 8:30 a.m. Continue discussions with licensee, plant walkdowns, etc.
11:30 a.m. - 12:15 p.m. LUNCH 12:15 p.m. - 3:00 p.m. Discussions with licensee, plant walkdowns, etc.
3:00 p.m. Exit Meeting
- 9. Specific Topics for Discussion The review will touch upon several key areas of the walkdown activities undertaken by CNP including:
- Qualification and training of participants
- Conduct of the walkdowns
- Process to address potential seismic issues identified in the walkdowns and current status of items identified
- The peer review process During the report review, some items of particular interest were identified.
- The seismic walkdown guidance document specifies that a separate report should be developed for each unit. However, CNP submitted a single report to the NRC. The NRC staff would like to discuss the implications of the inconSistency with this element of the guidance, including any differences between the units, including those that resulted from A46 or IPEEE commitments, which could impact the reporting or outcomes of the walkdown activities.
- The seismic walkdown guidance document provides guidance on the need for the walkdown participants to have certain specific backgrounds and qualifications to effectively carry out
- 5 their roles. The NRC staff would like to discuss the backgrounds of the team members as it relates to experience in the seismic field and walkdown training.
- The seismic walkdown guidance document provides information on the roles associated with the seismic walkdowns. The report uses terminology to describe roles that is not used in the seismic walkdown guidance document. For example, a role entitled "SWE substitute" is not provided for in the guidance, but is used in the report. The exact nature and duties of this role needs to be clarified. Also, the report lists only two seismic walkdown engineers, but refers to walkdown teams. Additionally, the report uses the terms "SWE inspection team" and "walkdown team." It is not clear if these are the same set of people. The NRC staff would like to discuss the exact roles and responsibilities of all team members.
- The seismic walkdown guidance provides instructions on the scope of peer review and the experience and independence of the peer reviewers. The peer review report is referenced in the document, but was not included in the submittal. The NRC staff would like to discuss the conduct of the peer review.
- The EPRI guidance specifies that all inaccessible items should be listed along with a schedule for completion. Appendix E provides the list of inaccessible equipment and areas but does not provide a schedule other than to state the "next scheduled outage for equipment" or "next RFO." The NRC staff would like to discuss the exact timing of the final walkdowns.
- The seismic walkdown guidance provides instructions on the reporting of the development of the SWEL, including the provision of base lists and the SWEL in the report for each unit.
The NRC staff would like to discuss the development and reporting of the base lists (1 and
- 2) and SWEL (1 and 2). The staff would also like to discuss the nature of timing of the revision to the SWEL, including the timing of review and sign-off by operations staff.
- The seismic walkdown guidance provides guidance and instructions on both the conduct and the reporting of the seismic walkdowns and area walk-bys. The NRC staff would like to discuss the conduct of the equipment walkdowns and area walk-bys, including the approach to anchorage verification, the approach to inspecting cabinets, the schedule for conducting the audits, and the treatment of the checklists.
- The seismic walkdown guidance provides guidance on the approach to addressing potential seismic issues found in the walkdowns. The NRC staff would like to discuss the approach used to disposition potential issues identified, including the time line for these activities, as well as the current status and reporting of items identified.
L Weber -2 If you have any questions, please contact me by telephone at 301-415-4037 or bye-mail at Thomas. Wengert@nrc.gov.
Sincerely, I RAJ Thomas J. Wengert, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-315 and 50-316
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsRgn1 MailCenter Resource RidsRgn2MailCenter Resource RidsRgn3MailCenter Resource RidsRgn4MailCenter Resource LPL3-1 RlF RidsAcrsAcnw MailCTR Resource RidsOpaMailCenter Resource RidsNrrLASRohrer Resource RidsNrrDorlLpl3-1 Resource RidsNrrPMDCCook Resource RidsNroDsea Resource RidsNrrDorl Resource DHuyck Jlsom SLingam ADAMS A ccesslon N 0: ML13143A439 *concurrence b)y e-mal'I r=o=FFiCE DORULPL3-1/PM DORULPL3-1/LA JLD/PMB/PM NRRlDI RSITL NAME TWengert SRohrer LRe~mer (MMitchell for) Jlsom DATE 6/07/2013 06/06/2013 06/07/2013 06/10/2013 OFFICE NROIDSEAlDD* DORULPL3-1/BC DORULPL3-1/PM NAME NChokshi RCarlson TWengert DATE 06/12/2013 06/11/2013 06/12/2013