ML13176A364
| ML13176A364 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/21/2013 |
| From: | Plant Licensing Branch 1 |
| To: | |
| Hughey J | |
| Shared Package | |
| ml13176a208 | List: |
| References | |
| Download: ML13176A364 (3) | |
Text
Preliminary questions for discussion at Salem flooding walkdown audit 6/25-6/27/2013
- Background/issue description Questions 1 Appendix D of NEI 12-07 states that the walkdown report should include the - Did the CAP identify any deficiencies from the following: Description of all deficiencies as determined by the CAP. Observations list of potential deficiencies included in the that are entered into the CAP and not dispositioned as deficiencies do not need to Salem walkdown report?
be reported. In addition, NEI 12-07 states: All flooding walkdown observations identified as deficiencies by the Corrective Action Program (CAP) and other items - Why did the walkdown report only report identified during the walkdowns, but awaiting final disposition by the CAP, must be potential deficiencies rather than identified reported to the NRC in the walkdown report. deficiencies?
NEI 12-07 defines a deficiency as follows: a deficiency exists when a flood - Were any deficiencies identified at the time protection feature is unable to perform its intended flood protection function when the walkdown report was submitted?
subject to a design basis flooding hazard. This condition may also lead to compromising the overall ability to provide protection or mitigation.
Page 36 of the walkdown report for Salem indicates that a review of potential deficiencies was (or will be) performed as part of the CAP process to determine whether potential deficiencies should be classified as deficiencies. Potential deficiencies are described in attachments A and D to the Salem walkdown report.
The walkdown report does not list identified deficiencies.
2 Footnote 4 on pg. 35 of the Salem walkdown report indicates that the total number - What features were identified as having of potential/actual deficiencies identified at the site (512) includes features with negative margin?
apparent negative margin. The licensee indicates that a notification exists to investigate actual margin for these features. - How were these issues dispositioned (and using what criteria) as part of the CAP?
- Do these features represent deficiencies (per definition in NEI 12-07) or instances of small margin and significant consequences (per question 27 of the walkdown record form in NEI 12-07)?
- How was available physical margin (APM) measured for these features?
3 Attachment A, p. 10 and Attachment D, p. 4 states the following: There are several - Does the site have seals that are unable to
Preliminary questions for discussion at Salem flooding walkdown audit 6/25-6/27/2013 penetration seals throughout the plant [that] do not have a hydrostatic rating that withstand the required hydrostatic loads?
is sufficient for the licensing basis flood level. These seals require further investigation to determine if there is an error in the documentation or if the seals - How were these issues dispositioned (and are credited external flood boundaries. This issue is common for both Salem units. using what criteria) as part of the CAP?
The attachments also state the following: There are several penetration seals - Do these features represent deficiencies (per throughout the plant that do not have sufficient documentation to determine their definition in NEI 12-07) or instances of small hydrostatic rating. Further investigation is required to ensure the hydrostatic margin and significant consequences (per rating is sufficient to provide protection from an external flood. This issue is question 27 of the walkdown record form in common for both Salem units. NEI 12-07)?
4 NEI 12-07, Attachment A provides examples of inspection considerations. For - What features (e.g., seals) were associated penetration seals, the following consideration is included for wall, ceiling, and floor with these observations?
seals (e.g., penetration seals): Penetration sleeves, link seals, piping, and conduit should have an absence of corrosion on the exposed steel surface. Conduit seal - How were these issues dispositioned (and material should have an absence of water stains below the penetrations. using what criteria) as part of the CAP?
Attachments A and D to the Salem walkdown report describe a large number of - Do these features represent deficiencies (per conditions in which heavy corrosion, missing foam, leakage (or signs of historical definition in NEI 12-07) or instances of small leakage), rust streaks, standing water, calcification, or seal degradation was margin and significant consequences (per observed. The report does not identify features types, but rather indicates a feature question 27 of the walkdown record form in ID. NEI 12-07)?
- Was in-leakage (i.e., amount of water leaking through barriers) measured?
5 The Salem walkdown report references two procedures related to flood - Were reasonable simulations performed for preparation: any procedures besides SC.OP-AB.ZZ-0001(Q),
"Adverse Environmental Conditions"? If not, OP-AA-108-111-1001, "Severe Weather and Natural Disaster Guidelines" what is the justification that reasonable
[Ref. 17], which provides guidelines for actions to be taken in preparation simulation is not required for any other for potential flooding events procedures?
SC.OP-AB.ZZ-0001(Q), "Adverse Environmental Conditions [Ref. 18] - What methodology (physical simulations or tabletop exercises) was used for reasonable The walkdown report states the following: A reasonable simulation was simulation?
performed at SGS which confirmed that the actions described within the implementing procedure SC.OP-AB.ZZ-0001(Q), "Adverse Environmental
Preliminary questions for discussion at Salem flooding walkdown audit 6/25-6/27/2013 Conditions" [Ref. 18] can be performed within the required period of time, and - What adverse weather conditions were sufficient resources are allocated and staged to perform those actions. considered as part of reasonable simulations (e.g., did the licensee determine it was NEI 12-07 states that reasonable simulation should consider issues such as appropriate to consider high winds? If so, how adverse weather conditions. In addition, reasonable simulation should consider were high winds factored in?)?
the time required for detection, recognition, and communication (e.g., mechanisms for receiving warnings of a flood event). - How was warning time factored into reasonable simulations to determine the time available to perform required activities?
- What procedure enhancements were identified (as indicates on p. 32 of the Salem walkdown report)?
6 The Salem walkdown report references the shoreline protection and dike system. - What criteria (inspection considerations) were used in the walkdown of the shoreline Appendix A of NEI 12-07 provides examples of inspection considerations for the protection dike?
flooding walkdowns. For earthen features (e.g., flood protection berms), Appendix A of NEI 12-07 includes the following considerations: - Were any potential deficiencies (or deficiencies) observed for the shoreline Verify that earthen features are in place as designed to the correct height protection dike? How were these issues (with no allowance for dimensional tolerances that reduce its protection dispositioned (and using what criteria) as function) and width. Verify that rip-rap or other erosion protection features part of the CAP?
are installed and in place if included.
No signs of leakage