ML13266A297

Audit Report Regarding Flooding Walkdowns to Support Implementation of Near-Term Task Force Recommendation 2.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident

ML13266A297
Person / Time
Site:	Hope Creek
Issue date:	11/18/2013
From:	John Hughey Plant Licensing Branch 1
To:	Joyce T Public Service Enterprise Group
Hughey J
References
Download: ML13266A297 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 18, 2013 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236, N09 Hancocks Bridge, NJ 08038

SUBJECT:

HOPE CREEK GENERATING STATION- AUDIT REPORT REGARDING FLOODING WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NO. MF0236)

Dear Mr. Joyce:

On March 12, 2012, the U.S. Nuclear Regulatory Commission staff (NRC or the staff) issued a request for information letter per Title 10 of the Code of Federal Regulations, Subpart 50.54(f)

(50.54(f) letter). The 50.54(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 Tohoku 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, as supplemented by letter dated April 12, 2013, PSEG Nuclear, LLC (PSEG) submitted a Flooding Walkdown Report as requested per Enclosure 4 of the 50.54(f) letter for the Hope Creek Generating Station. On June 25, 2013, an NRC audit team completed the on-site audit to gain a better understanding of the methods and procedures used by PSEG to conduct the flooding walkdowns. The information gained during the audit will facilitate the NRC staff review of the walkdown report and allow for more concise requests for information if needed. The NRC staff appreciates your support of the audit. The final audit report has been included as an enclosure to this letter.

T.Joyce If you have any questions, please contact me at 301-415-3204 or by e-mail at john. hughey@nrc.gov.

po Sincerely, John D. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

Audit Report cc w/encl: Distribution via Listserv

REPORT OF REGULATORY AUDIT ON JUNE 25 TO JUNE 27, 2013 FLOODING WALKDOWNS PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354

1. Introduction This document provides a summary of the United States Nuclear Regulatory Commission (NRC) audit of the flooding walkdowns performed by Hope Creek Generating Station, Unit 1.

The walkdowns were performed in response to NRC's request for information contained in the March 12, 2012, 50.54(f) letter, 1 Enclosure 4.

1.1 Background By letter dated March 12, 2012, NRC issued a request for information to all power reactor licensees and holders of construction permits in active or deferred status, pursuant to Title 10 of the Code of Federal Regulations, Section 50.54(f) (hence referred to as the 50.54(f) letter). The request was issued as a part of implementing lessons-learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 4 of the 50.54(f) letter requested that licensees plan and perform flooding walkdowns to identify degraded, nonconforming, or unanalyzed conditions related to the licensing bases of structures, systems, and components (SSCs) important to safety and to verify the adequacy of monitoring and maintenance procedures.

By letter dated November 26, 2012, 2 PSEG Nuclear, LLC (PSEG) submitted a report documenting the flooding walkdowns for Hope Creek Generating Station, Unit 1, as requested per Enclosure 4 of the 50.54(f) letter. By letter dated April 12, 2013, 3 PSEG submitted a supplement to the original report.

1.2 Regulatory Audit Basis The NRC staff conducted a regulatory audit to gain a better understanding of the methods and associated procedures used by PSEG to conduct the flooding walkdowns at Hope Creek Generating Station, Unit 1, and facilitate the assessment of the licensee's report documenting site walkdowns.

The Nuclear Energy Institute (NEI) developed guidance for performing the flooding walkdowns with extensive review and input from NRC staff in numerous public meetings, webinars, and 1

Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340.

2 ADAMS under Accession No. ML12334A452.

3 ADAMS under Accession No. ML13106A066.

Enclosure

public conference calls. NEI submitted NEI 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features,"4 for endorsement. The NRC staff subsequently endorsed the walkdown guidance by letter dated May 31, 2012. 5 By letter dated June 7, 2012, 6 PSEG confirmed that it will follow the NRC endorsed guidance for performance of the flooding walkdowns at Hope Creek Generating Station, Unit 1.

1.3 Audit Logistics An audit plan was issued to PSEG on May 20, 2013. 7 The audit plan included a proposed audit schedule and a list of information that NRC requested that the licensee make available for review during the audit. The audit plan also requested that the personnel (licensee staff and contractors) who performed the walkdowns be available for interviews.

The NRC staff performed an audit of Hope Creek Generating Station, Unit 1 on June 25-27, 2013. The audit was performed in accordance with the Office of Nuclear Reactor Regulation Office Instruction, LIC-111, "Regulatory Audits." 8 The Hope Creek Generating Station audit team, consisting of NRC staff and contractors, is listed in Table 1. It is noted that, because the audit of Hope Creek Generation Station, Unit 1, was performed concurrent with the audit of Salem Nuclear Generating Station, there was considerable interaction between the site audit teams for both sites.

An entrance meeting was held on June 25, 2013, to convey to the licensee background information and the purpose of the audit. An exit meeting was held on June 27, 2013, to convey to the licensee observations from the audit, including: (1) observations related to whether the walkdowns were performed in accordance with NEI 12-07, and (2) observations forwarded to the resident inspectors for additional action, if appropriate.

Table 1: NRC Audit Team Audit team member Affiliation Audit Role Stephen Campbell NRC/NRRIDIRS/IRIB Audit lead Michelle Bensi NRC/NRO/DSEA/RHMB Technical lead Sherlyn lbarrola NRC/R-1/DRP/PB3/HCRO Resident inspector George Wilson NRC/NRR Management support Terri Patton Argonne National Laboratory Flooding technical support 4

ADAMS Accession No. ML12144A401.

5 ADAMS Accession No. ML12144A142.

6 ADAMS Accession No. ML12160A292.

7 ADAMS Accession No. ML13127A116.

8 ADAMS Accession No. ML082900195.

2. Audit Scope The audit provides support for the ongoing NRC staff assessment of the licensee-submitted walkdown report. The audit scope included review of information and documents available onsite and interviews of licensee staff and contractors to aid NRC staff understanding of:

( 1) how the licensee performed the flooding walkdowns, and (2) whether the walkdowns were performed in accordance with NEI 12-07.

The audit also helped to identify additional information that will require docketing to support the staff conclusions related to the staff assessment. Observations made by the audit team that were not within the scope of the audit were transferred to the resident inspector for additional action, if appropriate.

3. Audit Activities and Remarks The NRC staff prepared a preliminary list of questions, which were communicated to the licensee prior to the arrival of the team on site. The preliminary list of questions addressed the following topical areas:

• Evaluation and disposition of available physical margin (APM) information in light of statements made by the licensee in the walkdown report regarding flood heights and flood protection elevations at the intake structure

• Assessment and disposition of flood protection features identified in the walkdown report as having "documentation insufficient for determining hydrostatic rating"

• Disposition via the corrective action program (CAP) of potential deficiencies identified in Attachment A of the licensee's walkdown report

• Computation of APM for barriers and penetration seals

• Identification and disposition of flood protection features associated with small or negative margin

• Disposition of observations of cracking, missing seals, leakage (or signs of historical leakage), rust, calcification, or seal degradation Throughout the audit, the licensee addressed the staff questions related to the above topics and provided clarification with regard to the processes used to: compute APM, identify and address potential deficiencies, assess and disposition observations not immediately judged to be acceptable, and address instances of small (or potentially negative) margin.

Once on site, the audit team reviewed documents related to the licensee's performance of the flooding walkdowns, including:

• Walkdown record forms and other supplemental forms and worksheets generated by the licensee to document observations associated with the walkdowns

• Flood-specific procedures that are part of flood protection strategy and severe weather response that were reviewed or used by the licensee as part of the flood walkdowns

• Listing of entries into the CAP resulting from the performance of the flood walkdowns

• The "Check-in Self-Assessment Report" generated by the licensee to evaluate the status of Hope Creek Generating Station's flooding walkdowns

• Site plans and maps, as well as relevant plant drawings

• Procedures and logs relevant to plant response to Hurricane Sandy

• Relevant sections of the updated final safety analysis report (UFSAR) for the site The audit team also interviewed site personnel and walkdown participants to inquire about: (1) performance of visual inspections (e.g., to discuss criteria used to determine flood protection feature acceptability), (2) calculation of APM and consideration of safety consequences associated with any instances of small margin, and (3) estimation of time required to perform manual actions.

All audit team members participated in a site familiarization tour. As necessary, staff also participated in additional field visits to observe areas of the site that are associated with plant flood response or were examined by the licensee as part of flooding walkdowns.

The licensee made presentations to provide an overview of the site walkdowns and describe the format used by the licensee to document the walkdown. The walkdown record forms at Hope Creek Generating Station were comprised of two parts: (1) a copy of the walkdown record form contained in Appendix B of NEI 12-07 that was generically populated for each class of flood protection features (e.g., penetration seals, flood doors, structural walls), and (2) a detailed spreadsheet containing information on each individual flood protection feature included in the walkdown scope (e.g., the spreadsheet contained an entry for each individual penetration seal, flood door, and credited structural wall). As part of the audit, a sample of entries from the spreadsheet was reviewed for the reactor buildings, auxiliary building, service water intake structure, and rad waste building.

Audit review responsibilities associated with flood protection features were generally divided among audit team members based on plant building or area. In addition, one audit team member focused on the review of reasonable simulations performed as part of the walkdowns.

Another audit team member reviewed walkdown record forms for a sample of structures (walls),

doors, and seals in Room 202 of the service water structure, Room 4304 of the Unit 1 reactor building, and Room RB2 of the Unit 2 reactor building. The audit team members reviewed information related to: material condition; critical design characteristics; whether equipment can be operated as expected; APM (including flood height at locations of flood protection features and capacity/rating of the features); whether features with small margin were entered into the CAP; and associated CAP notifications. The audit team members noted the following as a result of the review:

• Flood heights used to calculate APM for some features were not consistent with the design-basis flood height for the site. In response to NRC staff questions, the licensee explained that the reason for this difference was that the evaluation of APM for some walls and doors considered a limiting flood height that was relevant to defining the structural capacity of the feature rather than being based on the design-basis flood elevation. Consequently, the evaluation of APM for these walls and doors considered

structural capacity, but the licensee did not consider the potential for overtopping of barriers due to feature height.

• The licensee completed Question 27 (related to identification of whether small margin and significant consequences appear to exist) of the walkdown record form from Appendix B of NEI 12-07 on a generic basis (e.g., for each "class" of flood protection features) rather than on a feature-specific basis. As a result, individual flood protection features with small margin were not associated with a resulting evaluation of safety consequences or entrance into the CAP for any individual feature.

• While APM was systematically evaluated at the site on a feature-specific basis (e.g., for each individual seal or door), the limiting APM associated with composite barriers (e.g.,

a flood barrier comprised of structural components, flood doors, and penetration seals) was not identified.

An audit team member reviewed the walkdown records for at least one flood protection feature in each of the following rooms in the rad waste building: waste collector tank room, waste neutralizer room, cable tray area, electric penetration room, rad waste control room, and Rooms 3114, 3124, 3145, and 3167. In addition, the audit team member reviewed walkdown records for at least one flood protection feature in each of the following rooms in the auxiliary building:

electrical equipment area, diesel fuel storage tank rooms and corridors, battery room, access area, diesel generator room, corridor, electrical access room, and Rooms 5220 and 5228. The audit team member reviewed information in the walkdown records related to: observed material condition; the seal capacity rating relative to flood level; the reported flood level relative to the elevation maps (if specified) or the UFSAR; and the APM calculations. For those flood protection features with notification numbers, the audit team member also verified their status in the CAP program. The audit team member noted the following, as part of the review:

• Notifications were initiated for flood protection features that were inaccessible or restricted access, when the material condition was unacceptable, and, in some cases, when the APM was zero. All of the notifications that were reviewed were still in process at the time of the audit.

• The walkdown record spreadsheet did not address Question 2 (related to preventative maintenance programs) and Question 3 (related to periodic testing) from the walkdown record form in Appendix B of NEI 12-07, but the audit team member was able to review general documentation identifying concrete structures and components that are inspected and maintained. The document did not describe how seals are inspected and maintained, but further discussions with plant personnel indicated seals are inspected periodically and any deficiencies found are addressed through the CAP.

In addition, an audit team member reviewed the reasonable simulations performed of the procedures, OP-AA-1 08-11-1001, Revision 7, "Severe Weather and Natural Disaster Guidelines," and HC.OP-AB.MISC-0001(Q), Revision 21, "Acts of Nature." The staff conducted field walkdowns and interviewed licensee personnel on the implementation of the procedures.

The audit team member noted the following as part of the review:

• Prior to the performance of the flood walkdowns, the licensee recently executed the flood-specific procedure for an actual event. Therefore no reasonable simulation was

performed during the walkdowns and conclusions made regarding manual actions were based on actual performance data.

• A review of the logs and procedures from previous events verified the ability of the licensee to perform required activities within the associated timelines (e.g., shut and "dog" a series of watertight doors within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).

• The licensee did not perform reasonable simulation of activities that they identified as asset protection (e.g., placement of sand bag walls around several door openings).

An audit team member also noted that the UFSAR indicates that "all roof openings are watertight and provided with either metal sleeves or concrete curbs of sufficient height to exceed any possible pending levels," and also describes roof drainage systems and scuppers.

The licensee did not include the roofs of structures within the walkdown scope. The licensee indicated that a walkdown of the roof was out of scope.

Based on the audit team's reviews, the NRC staff has several observations directly related to whether the licensee performed the audit in accordance with NEI 12-07. Those observations are described in Section 4.1 of this audit summary.

4. Audit Summary As described in Section 2, the goal of the audit was to support the development of the staff assessment of the licensee's walkdown report. Observations made by the audit team during the audit were compiled and conveyed to the licensee during the exit meeting. These observations are neither findings nor potential violations; however, they will be used to inform the NRC staff assessment of the licensee's walkdown report.

4.1 Observations related to NEI12-07 The audit team made observations during the audit directly related to the scope of the audit.

These observations are described below.

Section 5.8, "Documentation of Available Physical Margin," of NEI 12-07 states that information on APM should be collected and documented in the walkdown record forms. In addition, if the APM of a flood protection feature appears to be small and the consequences of flooding at that location appear to be significant, the condition should be entered into the CAP. The CAP disposition should consider the size of the margin and the consequences of flooding the area affected by the flood protection. Once entered into the CAP, licensees are to take appropriate actions. In consultation with licensee staff, NRC staff learned that there were three "classes" of small margin characterized by the licensee:

1. "Administratively small (or zero)" margin: During the walkdowns, the licensee encountered challenges associated with documentation of capacity for some flood protection features. While the licensee believes that these features are capable of withstanding flood events larger than the design-basis flood, existing documentation is only available to demonstrate that flood protection features are capable of withstanding the design basis flood. These features were thus assigned an APM of zero and

classified as having "administratively small (or zero)" margin. The licensee has initiated a "margin recovery effort" to better quantify available margin to supplement existing documentation.

2. Seals of unknown capacity: The site has flood protection seals for which the seal capacity is unknown (typically due to documentation issues). The licensee assigned an APM of zero to such seals given that design control or similar processes are intended to assure flood protection features are able to meet the licensing basis.

3. Verified small margin: This classification is used to identify flood protection features that are capable of withstanding the design-basis flood, but with small margin available to withstand larger floods.

Initially, the licensee indicated to the audit team that the only instances of small margin at the site were either: ( 1) "administratively small (or zero)" margin (i.e., class 1 above), or (2) associated with seals of unknown capacity (i.e., class 2 above). For this reason, the licensee did not believe that it was necessary to evaluate safety consequences of small margin for any flood protection features. However, as a result of NRC staff questions during the audit, the licensee identified 10 penetration seals at the site with verified small margin (i.e., class 3 above) for which safety consequences were not considered. In accordance with NEI 12-07, instances of small margin should have been documented in Question 27 of Part E of the walkdown record form. The licensee initiated a CAP notification in response to NRC observations.

As described above, Section 5.8 of NEI 12-07 provided guidance on the need to calculate APM.

This calculation relies heavily on design and licensing basis flood heights. During the audit, NRC staff found multiple and varying flood heights for flood protection features (e.g., flood doors) used to evaluate APM. Initially, the licensee could not readily provide a basis for the flood heights. After further questioning, NRC staff was provided with an explanation of these values, which were based on the limiting flood height for evaluating structural loading (see section 3 of this report for additional explanation). For this reason, the evaluation of APM for these flood protection features did not consider their susceptibility to overtopping. At the time of the audit it was not clear to NRC staff if these values were appropriate or sufficient for calculating APM and NRC staff may request additional information (See Section 5 for further discussion).

4.2 Observations communicated to resident inspectors The audit team made observations related to the plant response to flooding hazards that were not directly related to the scope of the audit:

• During the audit team's site familiarization tour, NRC staff observed several outside watertight doors that are normally open. This practice exposes the seals to the environment, thereby potentially degrading seals more rapidly than normally closed watertight doors. This degradation may impact the flood sealing capability of these doors and therefore may require an increased preventative maintenance frequency.

• While reviewing the licensee's flood protection procedures that were implemented during Hurricane Sandy that were common to Hope Creek Generating Station and Salem Nuclear Generating Station, (i.e., OP-AA-108-11-1001, Revision 7, "Severe Weather and

Natural Disaster Guidelines") the NRC staff noted inconsistencies in the documentation of the implementation of the procedures between the sites.

These observations were forwarded to the site resident inspectors for additional action, if appropriate.

5. Potential additional information needs In response to the observations described in Section 4.1 of this audit summary, and to support the staff assessments of the licensee walkdown reports, the NRC staff may require additional information from the licensee regarding the methodology used to evaluate APM and responses to Question 27 for the walkdown record form in Appendix B of NEI 12-07 for flood protection features with small or zero APM. In addition, the NRC staff may require additional information regarding the flood heights used to calculate APM for certain flood protection features.

Moreover, the NRC staff may require additional information to clarify whether deficiencies were identified during the site walkdowns. Section 5.9, "Documenting Possible Deficiencies," of NEI 12-07, states all flooding observations identified as deficiencies by the licensee's CAP (and other items identified during the walkdowns but awaiting final disposition by the CAP) must be reported to the NRC as part of the licensee's walkdown report. In Section 5, of the Hope Creek Generating Station Walkdown report, the licensee stated that attachment A to the report includes both deficiencies and observations awaiting disposition. However, during the audit, the licensee indicated that, upon further review, there are no deficiencies identified for the site.

NRC staff may require additional information to clarify whether deficiencies were in fact identified at the site.

6. Conclusions The audit provided the NRC staff and contractors with information that is relevant to the staff assessment of the licensee's walkdown report. The audit team identified two observations during the audit related to NEI 12-07; two additional observations were forwarded to the Hope Creek Generating Station Resident Inspectors. In response to the audit, the NRC may require additional information as described in Section 5. This audit summary will be used as an input to the staff assessment of the licensee's walkdown report.

T. Joyce If you have any questions, please contact me at 301-415-3204 or by e-mail at john.hughey@nrc.gov.

Sincerely, Ira/

John D. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

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