CP-201300982, 446 Submittal of Requested Information Identified During Regulatory Audit Regarding Seismic Walkdowns at CPNPP, Units 1 & 2, to Support Implementation of Near-Term Task Force Recommendation 2.3 Related to Fukushima Dai-ichi Nuclear

446 Submittal of Requested Information Identified During Regulatory Audit Regarding Seismic Walkdowns at CPNPP, Units 1 & 2, to Support Implementation of Near-Term Task Force Recommendation 2.3 Related to Fukushima Dai-ichi Nuclear

ML13267A158
Person / Time
Site:	Comanche Peak
Issue date:	09/12/2013
From:	Madden F Luminant Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201300982, TAC MF0110, TAC MF0111, TXX-13121
Download: ML13267A158 (46)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002 0113 & Chief Nuclear Officer 6322 North FM 56 Rafael.Flores@Luminant.com Glen Rose, TX 76043 Luminant T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201300982 TXX-13121 10 CFR 50.54(f)

September 12, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001

SUBJECT:

Comanche Peak Nuclear Power Plant (CPNPP) Docket Nos. 50-445 And 50-446 Submittal of Requested Information Identified During Regulatory Audit Regarding Seismic Walkdowns At CPNPP, 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. MFO110 And MFO111)

References:

1. NRC Letter from Balwant Singal to Rafael Flores, "Plan for the Regulatory Audit Regarding Seismic Walkdowns at the Comanche Peak Nuclear Power 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", dated June 4, 2013 (ADAMS ML13143A145)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued a 10 CFR 50.54(f) letter to all power reactor licensees and holders of construction permits in active or deferred status (ADAMS ML12053A340). By letters dated November 27, 2012 (ADAMS ML13009A269), and July 1, 2013 (ADAMS ML13192A179), Luminant Generation Company LLC (Luminant Power), submitted Seismic Walkdown Reports as requested per Enclosure 3 (ML12056A049), "Recommendation 2.3: Seismic," of the 50.54(f) letter for Comanche Peak Nuclear Power Plant, Units 1 and 2 (CPNPP). The NRC conducted a regulatory audit in accordance with Reference 1 on July 9-11, 2013, to verify information and gain a better understanding of the seismic walkdowns at CPNPP.

During the regulatory audit, the NRC Regulatory Audit Team requested information regarding the seismic walkdown program. The Attachment to this letter provides the requested information and includes the following items, (1) individual description of the 94 items identified during walkdowns, (2) detailed description of the overall seismic walkdown process used at CPNPP including pre-audit review activities and support team activities that allowed for completion of the seismic walkdowns in relatively brief time period, (3) additional details on the Seismic Walkdown Engineers (SWEs) seismic experience, and (4) disposition of findings and recommendations of the pre-audit report and open items generated by the NRC audit team.

A member of the STARS Alliance Callaway

• Comanche Peak

• Diablo Canyon - Palo Verde - San Onofre " South Texas Project

• Wolf Creek

U. S. Nuclear Regulatory Commission TXX-13121 Page 2 of 2 09/12/2013 This letter contains no new regulatory commitments.

If there are any questions regarding this plan, please contact Mr. Carl B. Corbin at (254) 897-0121 carl.corbin@luminant.com.

I state under penalty of perjury that the foregoing is true and correct.

Executed on September 12, 2013.

Sincerely, Luminant Generation Company LLC Rafael Flores By:&/k 2LULL r*d W. Madder{

Director, Oversight & Regulatory Affairs

Attachment:

Overview of the Seismic Walkdown Process at Comanche Peak Nuclear Power Plant (CPNPP) c- E. J. Leeds, Director, Office of Nuclear Reactor Regulation Steve A. Reynolds, Region IV Balwant K. Singal, NRR Resident Inspectors, Comanche Peak

Attachment to TXX-13121 Page 1 of 44 Overview of the Seismic Walkdown Process at Comanche Peak Nuclear Power Plant (CPNPP)

Table of Contents (1) Purpose (2) CPNPP Plant Information (3) Seismic Walkdown Process (4) Development of Seismic Walkdown Equipment List (SWEL)

(5) Seismic Walkdown Plan (6) Seismic Walkdowns (7) Results of Seismic 2.3 Walkdowns (8) Pre-Audit Review of NTrF Seismic Program for CPNPP (9) NRC Seismic Walkdown Audit Table I - NTTF 2.3 Seismic Walkdown Team for Comanche Peak Nuclear Power Plant Table 2 - Seismic Walkdown Issues Resolution List Table 3 - CPNPP Pre-Audit Review Issues List Table 4 - Items Identified during NRC Seismic Audit on July 9-11, 2013 Table 5 - Additional experience for SWEs (1) Purpose of the CPNPP Seismic Walkdown Program:

CPNPP performed seismic walkdowns to identify and address degraded, nonconforming or unanalyzed conditions and to verify the current plant configuration with the current seismic licensing basis as requested by the NRC in Recommendation 2.3 Seismic in the 50.54(f) letter. CPNPP issued letter TXX-12108 (ML12201A095) on July 10, 2012 to the NRC to use NRC endorsed EPRI Technical Report 1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3 Seismic, dated June 2012. This Guidance Document was endorsed by the NRC on May 31, 2012 (ML12145A529).

(2) CPNPP Plant Information:

" Unit 1 and Unit 2 are PWRs, 3612 MWth

• Unit 1 commercial operation in August, 1990 and Unit 2 in August, 1993

" Safe Shutdown Earthquake (SSE) is 0.12 g peak horizontal ground acceleration and 0.08 g peak vertical ground acceleration. Operating Basis Earthquake (OBE) is 0.5 x SSE.

• Seismic Category I equipment classified according to R.G 1.29 o Electrical & Instrumentation equipment qualified to IEEE 344-75 o ASME Section III for determining strengths for mechanical components o Analysis, testing, and combination of both used to qualify the equipment

" Reduced Scope Plant for Individual Plant Examination for External Events (IPEEE) for Severe Accident Vulnerabilities (3) Seismic Walkdown Process:

The project team was comprised of individuals from CPNPP, Westinghouse, and Stevenson & Associates (Refer to Table 1) and followed the EPRI Seismic Walkdown Guidance document (EPRI Technical Report 1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic," June 2012) for performing the walkdowns and documenting the results in Reports to be submitted to the NRC. The Unit 1 and Unit 2 Submittal Reports were issued on November 27, 2012. Inaccessible Unit 1 items were identified in the Unit 1 Submittal Report. The Unit 1 Supplemental Submittal Report was issued on July 1, 2013.

Attachment to TXX-13121 Page 2 of 44 (4) Development of Seismic Walkdown Equipment List (SWEL):

• Followed the EPRI Walkdown Guidance document

• Obtained plant specific inputs - CPNPP IPEEE, Containment function equipment, modifications since IPEEE, seismic vulnerabilities from CAP (Corrective Action Program), Spent Fuel Pool (SFP) equipment

• SWEL comprised of two groups o SWEL 1-Components required to safely shutdown the reactor and maintain containment integrity o SWEL 2 - Components related to the SFP system

• Assembled Preliminary Base List 1 for SWEL 1 - over 38,000 Seismic Category I locations (tag numbers) for Unit 1 and Common (X) from the master equipment list (MEL).

o Perform Screen #1- Screened out equipment that was not installed in the plant o Perform Screen #2 - Screened out equipment that undergoes regular inspections (piping, supports, snubbers, penetrations), buildings, doors, and NSSS equipment associated with the RCS (Reactor Vessel, Steam Generator, Pressurizer, Reactor Coolant Pump) o Perform Screen #3 - Identified equipment that supports the five safety functions (reactor reactivity control, reactor coolant pressure control, reactor coolant inventory control, decay heat removal, containment function). Resulting list contained approximately 900 composite tags.

o Perform Screen #4- Selected sample based on system variety, equipment type (21 classes from NP-6041-SL), environment (M1-3000 drawings), IPEEE enhancements, modifications, recent changes, and risk significant equipment o CPNPP Senior Reactor Operator and Project Manager participated with the SWEL developers in selecting the equipment in Screens 3 and 4 based on their plant experience o Peer review of the SWEL was performed prior to commencement of the seismic walkdowns

• Final SWEL List 1 comprised a sample of 93 components for U1, 14 components for Common (X),

and 92 components for Unit 2. Components selected for SWEL List 1 came from either Train A or Train B.

• Assembled Preliminary Base List 2 for SWEL 2 - developed from the Unit 1 and Common Seismic Category I equipment currently identified in MEL for SFP system and other systems within the Fuel Building. MEL contained over 300 locations (tags). The support systems for SFP cooling are shared under the Common designator.

o Perform Screen #1 - Seismic Category I SSCs screened in o Perform Screen #2 - Equipment not appropriate for walkdown screened out (regular inspections of equipment, equipment inside the SFP or Transfer Canal, abandoned equipment, dry cask storage equipment, and equipment not supporting SFP system) Base list comprised of 38 composite tags.

o Perform Screen #3 - Sampling based from Base List 2 for system variety, equipment type, environment, accessibility, modifications, and recent changes o Perform Screen #4 - No rapid drain down components were identified

• Final SWEL List 2 comprised of 8 components

• The same process used for developing Unit 1 SWEL 1 was used to establish SWEL 1 for Unit 2, with a Unit 2 SWEL base list established for approximately 800 locations. Screen #4 was then applied based on plant systems, environments, and component enhancements, upgrades, and replacements. SWEL 1 selections for Unit 2 began by selecting components corresponding to SWEL 1 selections for Unit 1. Each sample considered for selection ensured compliance with the Guidance requirements, with 92 items selected.

• Unit 1 and Unit 2 SWEL were submitted via Westinghouse project letters for approval by CPNPP. Revisions to the SWEL were handled in a similar manner.

Attachment to TXX-13121 Page 3 of 44

• Peer reviews for the development of SWEL and components identified for seismic walkdowns, were performed prior to the walkdowns, with initial peer reviews documented in checklists that were submitted by Westinghouse project letters to CPNPP for approval. An additional CPNPP Senior Reactor Operator participated in the peer reviews.

• Changes to the SWEL that evolved during seismic walkdowns were reviewed and accepted by the peer review team, as indicated in the revised SWEL revisions 1 and 2 for both Unit 1 and for Unit 2.

a Project kick-off meetings, site visits, routine conference calls, and site component selection meetings were held among the multi-disciplined team members during the development of the SWEL.

(5) Seismic Walkdowns Plan:

• Seismic Walkdown Plan was developed and submitted via Westinghouse project letter for approval by CPNPP. The Plan followed the NRC approved EPRI Seismic Walkdown Guidance document.

• Walkdowns were conducted to work orders generated at power and during refueling outages for each Unit per Train A or B. Work Orders provided a means to track, schedule, and document the required walkdowns, with component information contained on spread sheets in the work orders.

• As a contingency, SWEL Base List 1 and cognizant Westinghouse engineers were available for supporting the walkdowns if SWEL components were not accessible during seismic walkdowns and substitutions were required.

" Any issues identified during the seismic walkdowns, including those issues that were not identified on walkdown checklists as potentially adverse seismic conditions, were entered into the Corrective Action Program (CAP) for identification and resolution (see Table 2 "Seismic Walkdown Issues Resolution List).

" One walkdown team was established and was comprised of two SWEs from Stevenson &

Associates, accompanied by an experienced CPNPP seismic engineer (for the initial at power walkdowns) or a modification engineer (for outage walkdowns) and an Operator. Maintenance and Operations personnel assisted in the walkdowns by opening cabinets for inspections of anchorage and for components located inside of the cabinets.

• Site support team was established to interface directly with the SWEs during the walkdowns, with the team in one central location. Site support team was comprised of the Fukushima Project Manager, Fukushima Operations Lead (Senior Reactor Operator), Seismic 2.3 Project Manager, Seismic EQ Engineers, and Westinghouse Project Manager. Discipline engineers from other departments supported the initiation of CRs and provided input to operability determinations.

" Support provided by CPNPP during the seismic walkdowns o Documents, such as specifications, drawings, calculations were assembled for each item on the SWEL and were reviewed by the SWEs prior to conducting the walkdowns o Established training qualification matrix for the SWEs and Peer reviewers consistent with CPNPP requirements and verified qualifications daily.

o Daily pre and post job briefings held with personnel conducting the seismic walkdowns.

Walkdowns routes were planned, which expedited the walkdowns and provided efficiencies.

o Experienced Seismic Equipment Qualification (SEQ) engineer interfaced directly with the SWEs on the walkdowns by providing equipment information and by answering specific questions. An Operator and Maintenance personnel also supported the walkdowns o Issues identified during the walkdowns were entered into CAP, which included as a subset the issues identified as potentially adverse seismic conditions, deemed as licensing basis evaluations (LBEs). This list became the Seismic Issues List (see Table 2 "Seismic Walkdown Issues Resolution List).

Attachment to TXX-13121 Page 4 of 44 o Experienced SEQ engineers interfaced directly with the SWEs to fully understand the issues and provided resolutions to the LBEs, which were reviewed by the SWEs.

o Discussions were held with the team to address issues, such as plant procedures and interpretation of the Guidance document requirements, to improve future walkdowns.

(6) Seismic Walkdowns Walkdowns conducted by a team of two SWEs o Qualifications- Degree in Civil/Structural or Mechanical Engineering, experience in seismic engineering as it applies to nuclear power plants, and had either the EPRI or SQUG seismic walkdown training course. See Table 5 for additional experience for the two SWEs.

o Accompanied on the walkdowns by an Operator and by an experienced SEQ engineer or an engineer.

o Issues identified during the walkdowns were provided to the site support team in a timely manner that allowed the seismic walkdowns to continue, without interruptions.

Issues entered into the corrective action program and were tracked on the Seismic Walkdown Issues Resolution List (See Table 2) o Reviewed and sorted daily the walkdown documents assembled by CPNPP, including the documents required to verify anchorage o Reviewed documents for commodity clearance, scaffold, fire protection piping, IPEEE Report, and NRC Bulletin 80-11 "Masonry Wall Design" prior to conducting walkdowns o Walkdowns conducted at power for both units in August/September 2012 and during refueling outages, 2RF13 (October 2012) and 1RF16 (April 2013).

o Assembled day-to-day packages for the seismic walkdowns, which included the field checklists for the seismic walkdowns of components and the area-walk-bys.

o For each component/ area, the seismic walkdown engineers performed their inspections independently, reviewing different aspects of each item based on the order of the checklist questions. This was to ensure that none of the questions were overlooked. When both finished reviewing the component, they discussed the inspection outcome to ensure that they agreed on the results.

o At the end of the day, the checklists were scanned and then emailed to another engineer in the Phoenix office who would enter the information into a database program called "Sultan." The SWEs also uploaded the photos to the office server to be entered into Sultan. Once the checklists were entered into Sultan, the Sultan database was considered the controlled copy of the information.

o The SWEs individually reviewed the electronic checklists to ensure consistency with the handwritten checklists. Before any non-editorial (spelling, grammar corrections) changes were made to the Sultan database, they were reviewed and agreed upon by the SWEs.

Any changes to the checklists/database were approved by both SWEs prior to being incorporated. This includes updates to outstanding unknowns and incorporation of relevant CR's into the checklists. Changes were predominantly made to checklist questions marked "U" for which additional documentation led to a final determination -

that is, "Yes" or "No." Before the report was issued, both SWEs reviewed the electronic checklists along with the handwritten copies prior to signing the final checklist versions.

The typed versions of the checklists appear in the Seismic Walkdown Reports for Unit 1 and Unit 2.

o Component walkdowns done for 93 Unit 1 and 14 Common (SWEL 1) +8 (SWEL 2) +92 Unit 2 (SWEL 1) components, with greater than 50% anchorage verified for applicable components

• Anchorage was inspected for non-conforming or degraded conditions, such as loose/missing bolts, oxidized anchors

Attachment to TXX-13121 Page 5 of 44

" Spatial interactions with other commodities exhibiting small clearances, overhead concerns, and flexibility of attached lines

" Results were documented on component and area walk-by field walkdown checklists, with pictures taken supporting the walkdowns o 55 Unit 1 and 48 Unit 2 Area Walk-bys were performed

• Encompassed a 35 foot radius around each SWEL component or the containing room

• Identify potential hazards from spray, flood, and fire

• Additional interaction concerns that could affect safety related equipment o NRC accompanied the seismic walkdown team on a sample of the initial walkdowns and performed some walkdowns on their own, following Temporary Instructions TI-188. The NRC identified issues, such as missing or loose fasteners, that were not identified by the SWEs in the area walk-bys. CPNPP entered these issues into CAP and reviewed them with the SWEs for awareness during future walkdowns. Further discussions with the team led to differences between the NRC and industry in the interpretation of the Seismic Walkdown Guidance (SWG) and the SWG training provided by EPRI for information to be identified during the area walk-bys.

o Licensing Basis Evaluations (LBEs)

" Identified as a potentially seismic adverse condition that could not be readily determined in the field to meet the current licensing basis for CPNPP

" SWEs were the LBE reviewers. CPNPP engineers received this information, entered into CAP, performed the evaluations, and shared the results, which were reviewed by the SWEs and the seismic walkdown lead peer reviewer.

o NRC questioned why electrical cabinets were not always opened to inspect the components located within the cabinets. The SWG was not clear on this subject. Industry developed a position through the principal author of the SWG that cabinets had only to be opened to visually inspect the anchorage, if the anchorage could not be seen externally. Furthermore, earthquake experience had shown that components located inside cabinets were not vulnerable to failures during earthquakes. Frequently Asked Question (FAQ) 4.20 was initiated. The NRC disagreed with the industry position and formulated a position that if a cabinet could be easily opened, had doors, or easily removable plates, components located within should be inspected for other seismic adverse conditions during the component walkdowns. This lead to supplemental re-inspections of specific electrical cabinets that were required to be opened for inspections.

Peer Reviewers o Team of at least 2 experienced individuals for each peer review activity, independent, who were not SWEs nor involved in the development of the SWEL o Conducted an observation of the SWEs by accompanying them on the seismic walkdowns the first day to ensure compliance with the Seismic Walkdown Guidance (SWG).

o SWEs were interviewed by the Peer Reviewers that same day o Approximately 20% of the component walkdown checklists and area walk-by checklists were reviewed and found compliant with the SWG requirements. (Refer to Tables 6.1 and 6.2 of the Seismic Walkdown Reports) o Additional oversight provided by another peer reviewer, who accompanied the team on the walkdowns during 2RF13.

o Peer reviewers concluded that the SWEs were performing the walkdowns in compliance with the SWG

Attachment to TXX-13121 Page 6 of 44 (7) Results of the Seismic 2.3 walkdowns 0 All of the component walkdowns identified in the SWEL and resulting area walk-bys have been completed.

• WCAP Report 17685-NP revision 0 and Supplement 1 for Unit 1 and WCAP Report 17686-NP for Unit 2 document the results of the seismic 2.3 walkdowns

• 9 LBEs for Unit 1 and 4 LBEs for Unit 2 were identified during the walkdowns, have been entered into CAP, and are resolved. (Refer to Sections 4, 5, and Appendix D of the Unit 1 and Unit 2 WCAP reports)

• All 94 issues identified during the seismic walkdowns, including the 13 identified LBEs, were entered into CAP and identified other non seismic related issues, including a number of loose or missing fasteners and housekeeping issues (see Table 2 - Seismic Walkdown Issues Resolution List). A detailed listing of all 94 issues were not included in the Unit I and Unit 2 submitted seismic walkdown reports.

0 Seismic walkdowns for Unit 1 and Unit 2 addressing seismic issue 2.3 confirm the seismic adequacy of the installed equipment to meet its licensing basis requirements, with no adverse seismic conditions identified during the walkdowns that affected the operability or the qualification of the components.

(8) Pre-Audit review of NTTF 2.3 Seismic Program for CPNPP

• Purpose o Review CPNPP seismic program for strengths, weaknesses, and completeness o Identify potential issues and lessons learned

• Review Team o Principal author of the EPRI Seismic Walkdown Guidance o Two seismic peers from STARS Alliance (San Onofre and Palo Verde)

• Approach o Reviewed Program submitted documentation for Unit 1 o Interviewed program personnel o Performed in-plant walkdowns

• Overall strengths o Seismic design of the plant is robust for a low seismicity site o CPNPP personnel involved in program were experienced and knowledgeable o SWEL was comprehensive and multi-disciplinary o CPNPP preparation for seismic walkdowns was comprehensive and thorough o CPNPP entered all potential issues into Corrective Action Program

• Overall Weaknesses o Walkdowns identified issues where plant personnel were not following seismic housekeeping procedures, e.g. cart on wheels, misplaced ladders o Walkdowns identified potentially adverse seismic conditions, e.g. latches on doors not fully engaged o Portions of the submitted reports did not fully describe the extent of work completed for LBEs and Peer reviews o Some of the walkdown checklists and LBE resolutions did not fully describe the basis for engineering judgments, lacked technical rigor, and were inconsistent o Submittal report does not include Issues List nor fully describe the support provided to SWEs o Peer reviews were more comprehensive than what was described in the Reports (rev.0)

• Conclusion o Team review concludes that NTTF seismic 2.3 seismic program meets the intent of verifying seismic licensing basis for CPNPP

Attachment to TXX-13121 Page 7 of 44 o Reports submitted do not fully reflect the scope of the work completed o In some cases, plant personnel are not following seismic housekeeping and maintenance procedures o Condition Report written to capture the results of the pre-audit report CPNPP's response to the pre-audit review issues list is provided in Table 3.

(9) NRC Seismic Audit (July 9-11, 2013)

• In addition to the information request by the CPNPP NRC seismic audit plan, the following documents were provided at the start of the NRC Seismic Audit

• Overview of the CPNPP seismic walkdown program

• Matrix of the CPNPP seismic walkdown support team

• Seismic walkdown issues resolution list (from the initial walkdowns)

" List of items from the pre-audit review (June 2013)

" The NRC Seismic Audit Team noted that the pre-audit review encompassed the NRC's Seismic audit scope and therefore focused on the issues identified and CPNPP's responses.

• The NRC also identified a few other items during the seismic audit. Table 4 of this attachment is a list of the items identified by the NRC Seismic Audit Team.

• At the NRC Seismic Audit Exit meeting on July 11, 2013, additional information was requested to address the following items:

• Individual description of each of the 94 items identified during walkdowns, including those not identified to be potentially adverse on the walkdown checklists [see Table 2 of Attachment to TXX-13121]

• Detailed Description of the overall seismic walkdown process used at Comanche Peak including pre-audit review activities and support team activities that allowed for completion of the seismic walkdowns in relatively brief time period

• Additional details on the two Seismic Walkdown Engineers (SWEs) experience in the seismic area [see Table 5 of Attachment to TXX-13121]

• Disposition of findings and recommendations of the pre-audit report and open items generated by our [NRC] audit team [see Tables 3 and 4 of Attachment to TXX-13121]

Attachment to TXX-13121 Page 8 of 44 Table 1 - NTTF 2.3 Seismic Walkdown Team for Comanche Peak Nuclear Power Plant Seismic Licensing Ucensing Equipment Walkdown Plant Walkdown Basis Basis Peer Project Selection Participation/Support Operation Eng(SWEs) Review Support Review Report Manager CPNPP Team Member Steve Maier X X X Paul N Passalugo X X X X Bruce Henley X X X Devendra Ray X X Emile Zahrah X Gregory Bryan X X X Mark Kertz X x Rick Hibbler X Operations Support X X Maintenance Support X Westinghouse Team Member Leslie Bradshaw X Mike Cribbins X Gary Douglas X X Terry Keller X X Rolando Perez X Stevenson and Associates Cory Figliolini X X X Timothy Nealon X X X Paul Karavoussianis X X Walter Djordjevic X X John O'Sullivan X

Attachment to TXX-13121 Page 9 of 44 Table 2 - Seismic Walkdown Issues Resolution List Finding Unit and(1 TaCo.ponen Copnn Component tCondition Date Cnion Potential AvreIssue Adverse DescriptionCodtn Condition Item # Commona Tag No. or Description Report Seismic Report

2) Condition Code NRC questioned a 1/8" gap under anchor plate between CR-2012-the baseplate and the 008567, N beplate an cho CP1- Diesel Pre-Lube I&X MEFTPL-01 Filter 08/27/12 CR-2013- N embedded plate. Anchor 003774bolt showed good engagement and was judged to not be a seismic concern.

CP1- Some thumb screws loose, 1&X MEDGEE- Generator Control 08/27/12 CR-2012- N one missing, some tight, on 1 02B Panel 008566 generator control panel CP1-MEDGEE-02B.

NRC question: There are two fuel oil transfer pumps in the CP1/2- Fuel Oil Transfer CR-2012- pit with Fire Protection 3 1&X, 2 DOAPTP- Pump 08/27/12 008564 N piping (2") with threaded 4 01-04 connections, the FP piping could fail and flood the pit, which has no way to drain.

Attachment to TXX-13121 Page 10 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Potential Finding and C o.por Component Condition Adverse Condition Item # Common omoNo. Descriptionte Report Seismic Issue Description Report 2I Condition Code Skid mounted and vendor supplied terminal box on U2 TDAFW pump only had 5 of the 6 fasteners fastened. The last fastener's screws seem to CP2- Pump Terminal CR-2012 be mis-threaded and will not 4 2 AFA=-01 Box 008559 N tighten to provide proper restraint. The terminal box cover is about 4 inches by 6 inches in size. (This was discovered on Seismic Walk down activities by a peer reviewer).

A white chalk-like material 5 ROOM 1- n/a 08/27/12 CR-2012- N was found on the floor in the 2 I&X 099A 008563 southeast comer of Room 1-099A.

NRC question: Loose CP1- Motor Control CR-2012 hardware bolted connections 6 1&X EPMCEB-10 Center 08/27/12 008589 N found on 480V MCC CP1-EPMCEB-10 in diesel generator room.

NRC question: On the floor above the spent fuel HX, 7 &X, 2 CPX- Spent Fuel Pool 08/27/12 CR-2012- N investigate the structural 4 SFAHSF-01 Heat Exchanger 008592 adequacy of floor plugs to remain in place during a seismic event.

Attachment to TXX-13121 Page 11 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Component Potential Finding and Compon Component Date Condition Adverse Issue Description Condition Item # Common, Tag No. or Description Report Seismic Report

2) Condition Code ROOM 2-085: Flashlight was ROOM 2- found on concrete pad for 085, CR-2012- CP2-MEDGEE-02A. ROOM 8 1&X, 2 ROOM 1- n/a 08/27/12 008588 N 1-085: Two flashlights found 2 085 on concrete pad for control panel. These are not a seismic concern.

XCH-0130 Condensation on support for support on XCH-0130. Visible water 9 top of Carbon Steel 08/27/12 CR-2012- N droplets on support and 5 platform Support 008675 bolts show signs of minor near CPX- corrosions. Not a seismic VAAUSE-01 concern.

Screw on floor board on Diesel Generator diesel generator platform 10 1&X CP1- Platform near ship 08/27/12 CR-2012- N near ship stairs is missing.

MEDGEE-02 P t ars 008817 Multiple other screws in board remaining. Not a seismic concern.

A ladder in a Contaminated Area of ROOM 1-077B is upright and against a ROOM 1- CR-2012- handrail, which is not in 11 1&X 077B n/a 08/28/12 008614 N accordance with STA-661. 2 Find the responsible work organization to lay it flat or tie it off. Not a seismic concern.

Attachment to TXX-13121 Page 12 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Component Potential Finding and C omon Component Date Condition Adverse Issue Description Condition ItemTag No. or Description Report Seismic Report Room No.

2) on' RoomNo. Condition Code SpentFuelPool 0CR-2012 Spent Fuel Pool FMEA: A 12 I&X 0259 X-ROOM X- Spe uel l 08/28/12 C208612 N piece of blue latex glove was observed inside the FMEA.

Cover on abandoned 13 1&X ROOM X- n/a 08/28/12 CR-2012- N security conduit above door 0197 008616 was found open. No cables were in the conduit.

14 1&X ROOM X- n/a 08/28/12 CR-2012- N Found unrestrained ladder. 2 206 008614 N 2 Multiple T-Handle tools ROOM X- CR-2012- were found in steel plates 15 1&X 209 n/a 08/28/12 008631 N surrounding HVAC 2 duct/penetration at the floor.

Room X-249B CR-2012- Valve operator had 16 1&X X-HV-4648 CCW Return Valve 08/28/12 008618 N contacted nearby steel 7 support.

ROOM X- n/a 08/28/12 Gaitronic XT249A faceplate 1 249B 008647 was missing 1 of 4 screws CP1- Spray Hazard from threaded 18 1&X ECPRLV-01 Remote Shutdown 08/28/12 CR-2012- N fire protection piping?

and CP2- Panels 008717 ECPRLV-01 ROOM X- CR-2012- T-handle valve tool was not 19 1&X 208 n/a 08/28/12 008631 N in support rack. Potential to 2 03 tip over.

Attachment to TXX-13121 Page 13 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 CPotential C ompon Component Condition Adverse Condition Finding and Tag No. or Description Report Seismic Report Item # Common, Dae ReotoesmcIsu esrptooRpr

2) Condition Code Junction box JB1FP-147 20 1&X ROOM 1- n/a 08/28/12 above LCS-1-HS-5370 is 1 088 008640 missing two of four faceplate screws.

ROOM 1- CR-2012- Pipe wrench found inside 21 1&X 088 n/a 08/28/12 008631 N vent chiller water line, 1-CH- 2 0075.

22 I&X ROOM-i- n/a 08/28/12 CR-2012- N Ladder not properly 096 008614 restrained in the rack Found ladders on boric acid 23 1&X ROOM X- n/a 08/28/12 tank room. Not in the 2 206 008597 approved storage location or tied down NRC Question: Three sets of cable penetrations on the wall from Room X-244 to X-245 are on the same cable 24 1&X ROOM X- Cable Penetration 08/29/12 CR-2012- N tray. Two are filled with 4 244 Sealant 008700 sealant going into the wall and one is not. This is conduit #C13K72395. Above CPX-EPMPNB-40 disconnect switch.

A scaffold in Room 2-088 was observed to have an ROOM 2- CR-2012- unsafe tag. There was no 25 2 088 Scaffold 08/29/12 008636 N workdate order The on listed the tagonwas the tag. 6 07/13/11, which was called into question.

Attachment to TXX-13121 Page 14 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Potential Finding and Component Component Date Condition Adverse Issue Description Condition FItemn#

Item mn' Common, Tag No. or Description Report Seismic Report Reporto

2) Condition Code Concrete Pedestal Approximately 1/8" ROOM X- below Ventilation below244 VEnhation 08/29/12 CR-2012-008651 N cracking was found concrete pedestal forinCPX- 3 4Room Exhaust Fan VAFNAV-28.

Nuclear staff area not labeled 27 1&X FB 860' n/a 08/29/12 CR-2012- N in accordance with STA-661. 2 008633 N. Terrell's name was crossed out.

A white board was found hanging from conduit by ty-28 1&X FB 860' n/a 08/29/12 CR-2012- N wraps. The pens were not 2 008634 tethered to the dry erase board, but the caps were tethered to the pens.

ROOM X- Junction box on ceiling in the 29 1&X 244, Junction Box 08/29/12 CR-2012- middle of room X-244 is JBEAB11 008648 missing a screw.

(11-7-9-18)

Wrench found inside square 30 2 ROOM 2- n/a 08/29/12 CR-2012- N tube pipe support and on air 2 088 008631 line support. Not a seismic concern.

Pendant light approximately PRT 2-01 VNT CR-2012- 4" from operator support.

31 2 2-8027-AO ORC ISOL VALVE 08/29/12 008681 N May impact support, but will 9 AO not damage valve/AO. Not a seismic concern.

Attachment to TXX-13121 Page 15 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Potential Finding and Component Component Date Condition Adverse Issue Description Condition Item # Common, Tag No. or Description Report Seismic Report

2) Condition Code A) N A) Cap for compressed CR-2012- nitrogen stored on tank ROOM 2- 008683 Chicago fitting on floor 32 2 100 n/a 08/29/12 EV-CR- support. 2 2012- B) Y B)Hydrazine barrel tied to 005095-12 support and contacting junction box JB25S385G.

CR-2012- Wheeled Tool cabinet 33 2 ROOM 2- n/a 08/29/12 008736, y approximately 10" from 100 CR-2012- JB25-13-G. (see STA-661) 008688 CR-2012- FP sprinkler on long rod ROOM 2- n/a 08/29/12 008740, N hung pipe can impact 2109B CR-2012- conduit support. Potential to 008692 shear off sprinkler head.

CR-2012- Barrel with spill kit less than 35 1&X ROOM 1- na0/91 08/29/12 008739, 1' from CP1-EPTSEB-14, 2 100 CR-2012- which is in violation of STA-008688 661.

CR-2012- Two drums with chemicals ROOM 1- 008683 in tanks that are too close to 36 1&X 100 n/a 08/29/12 EV-CR- Y duct work and CP1- 2 2012- VADPGC-24. Violates STA-005095-11 661.

JB-1MS-887 is missing a screw. This JB is located just 37 ROOM 1- JB-1MS-887 08/29/12 CR-2012- N outside the door to room X- 1 107 008694 244. It associates with non-safety which feeds to the magstrip on the door.

Attachment to TXX-13121 Page 16 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Potential Finding and Tag No. or Component Condition Adverse Issue Descrption Condition Item # Common, 2 RomN.Condition Description o Report Seismic Report Code A) Tools on the side of a airlock near CP2-MEMEPA-38M - R201-01.2 38ROOM 2- 2BS-0025 08/29/12 CR2012 N B) T 095B 008819 B) There was also an unrestrained ladder which was corrected on the spot.

ROOM 2- CR-2012- Local Control Station, LSC-39 39095B 2 LS-H-05 LSC-2HS-4075D 82/2 08/29/12 008698N N 2H-05haloscve 2HS-4075D has loose cover 1 latch.

40 1&X XEB3-2/5M- Breaker 08/29/12 CR-2012- N Loose screw on breaker. 1 BKR 008876 Room X-241: Rain guard CPX- CR-2012- atop MCC was cut to 41 1&X EPMCEB-01 XEB1-2 480V MCC 08/29/12 008874 N provide clearance with cable 5 tray node T13OACPS3 support lagging.

CP2- Cover Plates along front and 42 1&X VAAUPR-02 Emergency Fan 08/30/12 CR-2012- N back sides have missing 1 ROOM X- Coil Unit (EFCU) 008735 screws.

118 CP1- Stripped screws on cover 43 I&X EPSWED-04 08/30/12 CR-2012- N plate. 1 ROOM X- 008964 118 CPX- Missing closure screw on 44 ELBPCB-16 08/30/12 CR-2012- N emergency lighting CPX- 1 ROOM X- 008820 ELBPCB-161.

134

Attachment to TXX-13121 Page 17 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Potential Finding and Component Component Date Condition Adverse Issue Description Condition Item # Common, Tag No. or Description Report Seismic Report Room No.

2) Condition Code Conduit #C24G32736 in the Control Room has a loose 45 &X ROOM X- Conduit 08/30/12 CR-20120 N LBD fitting which is hanging 135 #C24G32736 008749 by one screw. This conduit is located on the East Wall behind CP2-ECPRCV-04.

JB-1PA-893 in the Control 46 I&X ROOM X- Junction Box 08/30/12 CR-2012- N Room is missing two screws.

135 008980 It is located on the South wall near the treadmill.

Top of CP2-EPSWED-04 is 3/4" from cable tray support CR-2012- plate. CPES-S-1021 specifies 47 Room X-118 CP2-EPSWED-04 08/30/12 008968 Y that the component is 7 flexible, therefore the required clearance is 1.5 inches.

Top of CP1-EPSWED-02/04 is 3/4" from cable tray CP1-EPSWED-02 CR-2012- support plate. CPES-S-1021 48 Room X-119 CP1-EPSWED-04 08/30/12 008969 Y specifies that these 7 components are flexible, therefore the required clearance is 1.5 inches.

Rear doors to control board C00894 CP2-ECPRCB-10 were found 008944 49 not entirely latched. Light X-135 08/30/12 and 2Room CR- Y sheet metal door. Nothing 2012-9 within the swing arc of the 011489door.

Attachment to TXX-13121 Page 18 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Component Potential Finding and C ompon Component Date Condition Adverse Issue Description Condition Item # Common, Tag No. or Description Report Seismic Report

2) Condition Code CR-2012- Step ladder on wheels was 50 Room X-135 08/30/12 008907 Y within 1 ft of box 2-NY- 2 0 0050B-2 51 Room X-135 08/30/12 CR-2012- An unsecured table was < 11 2 51 Room X-135__ 08/30/12_ 008751 from TBX-ESELAM-01.

CR-2012- Junction Box JB-1FP-34 was 52 Room X-275 08/30/12 008994 N found missing two of four 1 screws Room X-275 Several metal hatch covers Outside CR-2012- were found missing screws 53 Area Near 08/30/12 008823 N on the steel platform 1 Traveling Screens Three screws not fully seated 54 1&X 135 TBX-XIELRK-02 08/30/12 009017 N on inside panel located 1 behind the back middle door TBX-XIELRK-01, Missing cover screw on the X135 TBX-XIELRK-03, 08/30/12 CR-2012- N mounting panels1 55X-1 CP1-EIPRCI-02, 008952 TBX-XIELSS-50X Address the potential U1- seismic interaction between 56 1&X AFAPTD Seismic CR-2012- N the valve operator and the Room interactions 009000 instrument tubing line. The valve appears to be non-safety.

CR-2012_ Two steel bars behind three 57 1&X X-135 08/30/12 009798 N vertical conduits, near 2 exercise area

Attachment to TXX-13121 Page 19 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 CPotential Finding and Tag No. or Component Date Condition Adverse Issue Description Condition Item # Common, Room No. Description Report Seismic Report Rom o.Condition __________ Code U-1 Fluorescent CR-2012- Fluorescent Lighting 58 1 AFAPTD- Lighting Fixtures 08/30/12 008857 N Fixtures 9 Room On side of SI Pump Motor, Unlabelled CR-2012- unlabelled junction box has a 59 Room 1-062 junction Box J&X 09/04/12 008858 N missing screw. 3 out of 4 1 screws installed on cover plate.

Power supply junction box 60 I&X Room 1-062 Power Supply 09/04/12 CR-2012- N1 to SI motor 1-01 has 1 of 12 Junction Box 008859 screws missing on the cover I _plate CR-2012- Banding strap for insulation 61 1&X Room 1-075 Banding Strap 09/04/12 008861 N has slipped down to the root 1 valve for valve 1-SW-0022 Fire protection support inside the door is attached to 62 1&X Room X-175 FP Pipe support 09/04/12 008901 N an abandoned pipe support, 5 CC-1-0190997-A33K, as noted in DCA-46690 Room 1-053 Chains on chain fall for 63 1&X RHR Pump CP1-MEMHCH-14 09/04/12 009003 N overhead hoist are not 5 Room bagged or tethered.

64 I&X Room X- CP1CHCICEO5 09/04/12 CR-2012- N Leaking oil observed on 115A 008991 south side of chiller 65 1&X Room 1-083 CP1-EPTRET-01 09/04/12 CR-2012- Loose 1/4" fasteners on back 1 009001 N @top of cabinet CR-2012- Loose cover screw (1 of 4) on 66 I&X Room X-200 JB S-59 09/04/12 008863 N Gaitronics Junction Box S-59 1

Attachment to TXX-13121 Page 20 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Potential Finding and C o.por Component Date Condition Adverse Issue Description Ron t Item # Common, Room No. Description Report Seismic Report Door latches on Fire 67 1&X Room 1-083 CP1-EIPRLV-33 CR-2012- N Protection Panels, CP1-and -33A 009002 EIPRLV-33 and -33A are not tight and installed properly 68 1&X Room X-120 CPX-ELBPCB-189 09/05/12 CR-2012- N Missing 1 of 4 cover screws 1 on CPX-ELBPCB-189.

Mii008978 69 1&X Room X-120 CPX-ELBPCB-97 09/05/12 CR-2012- N Missing 1 of 4 cover screws 1 008978 on CPX-ELBPCB-97.

70 1&X Room X-121 CPX-ELBPCB-90 09/05/12 CR-2012- N Missing 1 of 2 cover screws 1 008978 on CPX-ELBPCB-90.

71 1&X Room X-121 CPX-ELBPCB-82 09/05/12 CR-2012- N Missing 2 of 4 cover screws 1 008978 on CPX-ELBPCB-82.

Missing 1 of 3 screws SWIS CR-2012- holding hand switch cover 72 1&X ROOM X- CP1-EPMCEB-07 09/05/12 009009 N ring in breaker of 1EB3- 1 275 3/2J/BKR of CP1-EPMCEB-07.

SWIS CR-2012- 5' long piece of C6 structural 73 1&X ROOM X- CP1-EPMCEB-07 09/05/12 009019 Y steel found behind CP1- 2 275 EPMCEB-02..

CR-2012- Insulation on pipe near 1CC-74 I&X Room X-150 1CC-0208 09/05/ 12 009007 N 0208 in X-150 damaged.

NRC questioned the 75 Gen - - 09/05/12 008829 N adequacy of the seismic 4 008829 walkdown.

Attachment to TXX-13121 Page 21 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Component Potential Finding and Compon Component Date Condition Adverse I D Condition Item # Common, Tag No. or Description Report Seismic Issue Descripton Report

2) Condition Code NRC Question: presented to the Fukushima response Seismic Walkdown team by the NRC Resident. In room Room 2- CR-2012 2-109B, the Resident 76 2 109B 2MS-0134-RO 09/06/12 008942 N questioned the fact that one 4 anchor bolt for the support of 2MS-0134-RO extended noticeably above the nut while the other anchor bolt did not.

NRC: Resident Inspector discovered a gap of at least 1/2" on pipe support MS CR-2012- 003-417-S72R in room 2-77 2 ROOM 2- 2-03 MSIV 09/06/12 108H with the 2-03 MSIV 3 108H CR-2012- and presented it to the 009918 Fukushima response Seismic Walkdown team. Note: This item was not in the scope of the area walk-by

Attachment to TXX-13121 Page 22 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 CPotential Finding and Component Component Date Condition Adverse Issue Description Condition Item # Common, Tag No. or Description Report Seismic Report

2) Condition Code NRC: 2MS-0134-RO support bar thrust bearing baseplate area has minor scrapes likely from the nearby cotter pin securing the remote operator linkage. The cotter pin 78 2 2-109B 2MS-0134-RO SG 2-04 09/06/12 CR-2012-008939 N should rue ringbeper replaced design with a drawing 6MO31ME sh 1 of 1 which provides a reduced silhouette to eliminate any contact with the other parts of the remote operator assembly.

NRC questioned the cables CR-2012- entering the panel for 79 Yard Cables for Alt DG 09/06/12 008956 N Alternate Power Supply 4 Diesel Generator located on the North Island Conduit cover was missing 80 2 X-135 Conduit 09/06/12 CR-2012- N from conduit #C2Y32741 for

1. C2Y32741 008962 the Gamma Metrics channel 2-NY-0050-B2 Question from NRC about the seismic adequacy of the Pendant style 0CR-2012 pendant style lighting.

81 22-109B Penan 2s2-109i tig lighting 09/06/12 R-00 9 009809 N Noticed that restrained bysome lights aircraft are cables.

There are none on these lights.

Attachment to TXX-13121 Page 23 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Component Potential Finding and Component Condition Adverse Condition Item # Common, No.Issue Description Report Room No.

2) Condition Code CP2- 120V Distribution CR-2012- Breaker Cover #6 has a ECDPEC-06 Panel 10/18/12 010853 missing screw A) UPS far right A) One missing screw door 2-EQ-3017, E126760B) Missing 2 screws B) Train A wire in coverC) Missing a screw CP2- channel cover in coverD) Missing 2 screws 83 2 ECPRLV-01, RCTR, 10/18/12 CR-2012- N in cover 1 C) Cover to 010845 2LV01 giatronics LCTR compt, andD)

Cover to wire channel far left CPX- Wireway cover Stripped screw to wireway 84between breaker CR-2012- cover. Total 26 screws, one 1 3M/BKR and 010815 is stripped.

MEB-0, 4M/BKR Cover plate screw missing 125 Volt DC CR-2012- from next breaker 4, 6, 7 CP1 85 1 ECDPED-03 distribution panel 10/17/12 010813 N (Blank cover on 3 spaces 1 1ED1-2 missing screws) held in place by at least one screw Handle for switch CR-2012- Switch handle hits face of 86 1 1-LCS-5691B 1-HS-5691B-3 10/18/12 010868 N gauge 1-PIS-5693B when 5 door is fully open Missing screw on terminal CP1- CR-2012- block cover. The cover is 87 1 ECCPEC-02 Relay panel 10/17/12 010817 N light weight about 1/4 lbs 1 electrically insulated material

Attachment to TXX-13121 Page 24 of 44 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Component Potential Finding and Tag No. or Component Date Condition Adverse Issue Description Condition Item # Commono Description Report Seismic Report 2 R Condition Code Two screws on terminal Local Control 1 2 CR2012 block cover are loose. The 88 X X-LCS-5350 Station 10/17/12 010811 N cover is light weight about 1/4 lbs electrically insulated material C'P2- CR-2012- Internal standoff support for 89 2 ECDPED-03 Distribution panel 10/18/12 010871 N breaker mtg plate missing 1 screw out of 26 screws.

SCR-2012- The clearance between 480V 90 1 EPMCEB-03 480V AC MCC 10/18/12 011287 Y AC MCC and conduit on the 7 back wall is 3/4inch CP2- Embedded plate under CP2-91 2 EPTRET-04 6.9Kva/480V 10/20/13 CR-2012- y EPTRET-04 appears to be Room 2-103 Transformer 011886 curved at one end and is not flush with concrete SWEs questioned procedure Procedure STA-690 STA-690, which did not 92 1,2 n/a and scaffold 10/20/13 CR-2012- N address the timeliness of 6 erection 012406 inspections of scaffolds for use after the scaffolds were erected..

RHR PUMP 1-02 Gap between motor of valve 93 HL 1-04 RECIRC CR-2013- operator and square tube OMB ISOL VALVE 003796 support is 1/8" MO 1-HV-2403A location 1-HV-2403A and 1-941-HV-2403A and 1- CR-2013- HV-2403A-AO were 2403A 1-HV-2403A-An 004960 identified with the wrong 2403A-2403A-AO 04/30/ 13

~room 004960 number and elevation ____

Attachment to TXX-13121 Page 25 of 44 1 Table 2 - Seismic Walkdown Issues Resolution List Unit (1 Condition Finding and Report Issue Description Item # Common,

2) Code Notes A. Condition Report Codes 1 Poor Workmanship including loose or missing screws 2 Housekeeping issues (STA-661) 3 Design vs. As-Built Discrepancies 4 NRC Design Questions 5 General Observation/Questions. No Seismic Impact 6 Scaffolding Issue 7 Commodity Clearance 8 FMEA 9 Interaction with Lighting Fixtures B. Licensing Bases Evaluation (LBE) for CP2-EPSWEB-02 is not required because documentation to verify walkdown anchorage was found in Design Change Authorization (DCA) 93781. As-built anchorage matched the drawing. Therefore, no condition report was required and this issue is not included above in Table 2.

Attachment to TXX-13121 Page 26 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 1.1. Was overall purpose and intent met for Based on the limited check performed by the Pre-conducting the NTTF 2.3 seismic Audit Review Team, it appears that the overall program at CPNPP? purpose and intent of the NTTF 2.3 seismic program was met at CPNPP. Nevertheless, a number of elements of the program could have been improved as described below.

2.1. Do the Equipment Selection Personnel Yes. Those involved had significant experience in --

have adequate experience? systems engineers and plant operations. See the resumes for the Seismic Walkdown Equipment List (SWEL) Development Team in the submittal reports.

2.2. Do the Plant Operations Personnel Yes. See the resume for Greg Bryan in the submittal involved in the program have adequate reports.

experience? II

Attachment to TXX-13121 Page 27 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 2.3. Do the two Seismic Walkdown Yes. The two SWEs meet the SWG minimum Engineers (SWEs) who conducted the requirements. Because their level of experience was seismic walkdowns and evaluations somewhat limited prior to the CPNPP walkdowns have adequate qualifications and (one was out of college for about 8 months and the experience? other about 2 years), we specifically evaluated their competency and the extent of oversight and support they received by more experienced seismic engineers before and during the walkdowns at CPNPP. As discussed during our interviews with SWEs and those whom they interfaced with during the program, it appears they were competent and capable to perform the seismic walkdowns. Further we note that they received appropriate support and guidance from other, more experienced seismic engineers. See Attachment 5 for a summary of our interviews with Walter Djordjevic, Cory Figliolini, Timothy Nealon, and Bruce Henley.

Although the Pre-Audit Review Team concluded that the SWEs had sufficient background and experience to meet the minimum requirements of the SWG, the submittal report did not fully describe how more experienced seismic engineers provided support to the SWEs.

Enhancement:

1. Augment the submittal reports to include a fuller - Additional experience for the description of how the SWEs received guidance, Seismic Walkdown Engineers is support, and mentoring from more experienced described above in Section (6) seismic engineers before and during the CPNPP "Seismic Walkdowns"and in seismic walkdowns. Table 5 2.4. Do the Licensing Basis Reviewers have Yes. See the summary of those involved in the adequate experience? licensing basis reviews in Section 2.3 of the submittal reports.

Attachment to TXX-13121 Page 28 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit ConclusionVEnhancement/Deficiency CPNPP Response 2.5. Do the IPEEE Reviewers have adequate Yes. See the summary of those involved in the IPEEE experience? reviews in Section 2.4 of the submittal reports.

2.6. Do the Peer Reviewers have adequate Yes. See the summary of the Peer Review Team in -

experience? .. Section 2.5 of the submittal reports.

3.1. Were the guidelines in the SWG applied Although the selection of the SSCs was not reviewed --

when selecting the SSCs to be included in detail by the Pre-Audit Review Team, it appears in the SWELs? from a brief review of the extensive discussion in the submittal report that the SWG process was followed.

3.2. How was the sample of SSCs selected by CPNPP used the entire Master Equipment List as the Additional information is provided which the plant could safely shut down starting point for generating the SWEL. This large list in Sections (4) and (5) above.

the reactor and maintain containment of SSCs was paired down to a sample in the SWEL integrity? using the criteria in the SWG. This approach was more comprehensive than the minimum methods defined in the SWG, which allowed use of the IPEEE safe shutdown equipment list as the starting point.

4.1. Were the SWG guidelines applied for Overall, it appears that the SWG was followed by the conducting the seismic walkdowns and SWEs while in conducting the seismic walkdowns area walk-bys? and area walk-bys. However, several improvements could have been made as described below.

4.2. How were the Seismic Walkdown The SWEs carried paper copies of the Seismic Additional information is provided Checklists (SWCs) completed by the Walkdown Checklists (SWCs) into the plant. These in Section (6) above.

SWEs? SWCs were pre-filled in with equipment identification information. While in the field, they made notes on the SWCs and took photographs of the equipment. They also photographed issues and concerns they identified. This raw data was used later to generate typed versions of the SWCs.

Attachment to TXX-13121 Page 29 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 4.3. How long did it take to complete the It was reported that the SWEs completed 20 to 30 seismic walkdowns at CPNPP? items per day outside of the containment. The bulk of the walkdowns was completed in about 2 weeks.

Although this walkdown pace was relatively quick, it was noted that CPNPP was well prepared for these walkdowns so that it was possible to quickly complete the work. For example, the following aspects of the walkdown at CPNPP were in place:

- Two separate file cabinets were filled with copies of all the available design documentation for each item of equipment on the SWEL.

- Plant personnel carefully planned the seismic walkdown route each day.

- An experienced plant operator and an experienced seismic engineer accompanied the SWEs on all the walkdowns so that they could quickly answer questions on the operation of and seismic design basis for the equipment on the SWEL. When they did not have the answer, they immediately made an information request to others in the control room and engineering offices/

- Appropriate personnel (OPS and maintenance) were made available as necessary to support the walkdowns and minimize wasted time.

- CPNPP quickly provided supplemental documentation when requested by the SWEs.

- CPNPP engineers worked alongside the SWEs to identify issues for which CRs were to be written.

The CPNPP engineers then initiated CRs for every issue identified while the SWEs continued the walkdowns.

Enhancement:

2. Augment the submittal reports to include a fuller - Additional information is description of how the SWEs received guidance, provided in Sections (5), (6), and support, and mentoring from more experienced (7) above seismic engineers.

Attachment to TXX-13121 Page 30 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 4.4. How long after completing the The initial walkdowns were completed in August, walkdowns were the SWCs finalized and September, and October. However, the typed SWCs signed? were finalized and signed in November. The SWEs reported that they reviewed the typed SWCs to confirm that they accurately reflected the information on their hand-written SWCs, included the appropriate photographs, and other information they obtained after leaving the field (e.g., which CRs were written against concerns identified).

The Pre-Audit Team had three concerns with this process. First, memories fade with time so it become harder to confirm that all the appropriate information is included on the final, signed SWCs. Second, the program records do not describe the above process.

And third, the CPNPP did not have copies of the paper SWCs used in the field to show as objective evidence that notes were taken during the walkdowns.

Although the guidelines in the SWG were met, several recommended enhancements are provided.

Enhancements:

3. Obtain copies of the paper SWCs used during the - Copies of the handwritten walkdowns to keep as a part of the plant record of records were available for review seismic walkdowns. during the NRC Audit..

4. Describe in the submittal reports the process for - Copies of handwritten SWCs generating the final typed SWCs and the steps have been captured by CR-2012-taken to assure that the walkdown data were 005095 accurately copied from the field notes onto the - Additional information is typed, final SWCs. provided in See Sections (7) and (8) above.

Attachment to TXX-13121 Page 31 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 4.5. The criteria in the plant seismic These questions were discussed with the calculation housekeeping procedure (STA-661) were author (Bruce Henley).

used during the seismic walkdowns to assess the possibility of tipping and Enhancement.

sliding of commodities near safety 5. Address each of these questions and update the - This issue is addressed in CR-related equipment. A review of the calculation that supports the tipping and sliding 2013-006544.

CPNPP calculation CS-CA-0000-3340, criteria in the seismic housekeeping procedure.

which established the tipping and sliding criteria in STA-661, was reviewed by a member of the Pre-Audit Review Team. The following questions on this calculation were identified:

- What is the basis for using 7%

damping?

- Were other checked to verify that there were not higher pseudo spectral velocities at other frequencies?

- Was the duration of the earthquake considered in establishing the criteria for sliding distance?

4.6. Numerous seismic housekeeping and It appears that there is a continuing problem with maintenance issues were identified adherence to the plant seismic housekeeping during the NTTF 2.3 seismic walkdowns. procedure (STA-661) and maintenance procedures Additional seismic housekeeping and that were not resolved following the seismic maintenance issues were also identified walkdowns conducted in 2012.

during the limited (1/2-day) seismic walkdowns conducted by the Pre-Audit Enhancement:

Review Team. Examples of such 6. Improve plant knowledge and awareness of This issue is addressed in CR-2013-conditions found by the Pre-Audit requirements in plant procedures for seismic 006303 for resolution as well as the Review Team are described in detail in housekeeping and maintenance work practices. CRs identified in Column 1.

Attachment 7 and listed below:

- Missing Fastener on TBX-XIELRK-03 in Main Control Room (CR-2013-

Attachment to TXX-13121 Page 32 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency I CPNPP Response 006417)

- Unanchored Table Against TBX-ESELAM-01 in Main Control Room (CR-2013-006541)

- Chair on Wheels Near CP1-ECPRCV-03 in Main Control Room (CR-2013-006541) (Also applies to TBX-ESELAM-01)

- Unanchored Cabinets Near CP2-EIPRCI-10 in Main Control Room (CR-2013-006544)

- Upside-Down Table Near SR Conduit in Main Control Room (Generate new CR-2013-006958)

- Latches Do Not Secure Doors on Cabinets in Main Control Room (CR-2013-006435 and CR-2013-6558)

- Unsecured Instrument Cart in Main Control Room (CR-2013-006541)

- Missing Fastener on Cover Plate for MCC CP1-EPMCEB-07 in the Service Water Intake Structure (CR-2013-006501)

- Missing Baseplate Nut for Pipe Support Structure at Valve 2SW-0076 in the Service Water Intake Structure (CR-2013-6562)

- Loose Pendant for Service Water Intake Structure Overhead Crane (Valve is NSR, No CR required, on Issues List)

- Missing Panel Fastener in the UPS Room Fan Coil Unit CO1-VAAUPR-01 (CR-2013-006956)

Attachment to TXX-13121 Page 33 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 4.7. When engineering judgment is used to Deficiency:

justify a condition, the SWG on page D-1 7. Update the SWCs and AWCs in the report with For resolution of this item see states that the basis for reaching such a justifications that provide the basis for engineering Topic/Question 4.15.

conclusion should be documented. judgments made during seismic walkdowns and However, some of the Area Walk-By area walk-bys.

Checklists (AWCs) in Appendix B of the Unit 1 submittal report show conclusions without any basis (i.e., Yes/No responses are given with only conclusions written as a note). Example of this include the following:

- Question 1 on page B-122, "double nut on Rod Hanger not engaged, no seismic concern."

- Question 3 on page B-122, "Overhead pendant lights, judged not a concern."

- Questions 4 on page B-161, "Pendant lights overhead. No seismic concern."

- Question 7 on page B-172, "Noted unrestrained ladder lying on floor, not a seismic concern."

4.8. On page A-38 of the Unit 1 submittal Deficiency:

report, the SWC states there is a 1/8" gap 8. Provide a more rigorous basis on the SWC on page This issue is addressed in CR-between components. This condition A-38 that a 1/8" gap is not a seismic concern. 2013-007545.

was judged to be sufficient and not a seismic concern. However, accepting a gap this small, based solely on judgment, may be questioned. Was the potential for thermal growth of the piping system considered as required by the SWG on page D-2?

Attachment to TXX-13121 Page 34 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 4.9. On page A-52 of the Unit 1 submittal Deficiency:

report, the SWC states that there is a 1/2" 9. Provide a more rigorous basis on the SWC on page This issue is addressed in CR-gap between components, which is A-52 that the 1/2" gap is not a seismic concern. 2013-007545.

judged to be sufficient and not a seismic concern. Was thermal growth of the piping system considered in concluding that the gap is sufficient as required by the SWG on page D-2?

4.10. On page A-134 of the Unit 1 submittal Deficiency:

report, the SWC states that a valve is 10. Provide an approximate a distance between the - Defining distance not necessary "close" to an adjacent support. Being components and/or provide additional details on since SWEs judged that the valve "close" is a relative term and not the potential for seismic interaction, is well enough supported to definitive, preclude closing the gap.

- No additional action necessary.

4.11. On page A-273 of the Unit 1 submittal Deficiency:

report, the SWC states that an 11. Provide a technical basis for the conclusion that an This issue is addressed in CR-unanchored bookcase not a hazard. The unanchored bookcase is not a seismic hazard. 2013-007545.

basis for this conclusion is not provided, as required on page D-1 of the SWG.

4.12. On page B-20 of the Unit 1 submittal Deficiency:

report, the AWC states that items are in 12. Provide a technical basis for this conclusion, since - Based on view of photo #2680 on contact but they are not a seismic it is based on engineering judgment. AWC, the congested overhead concern. The basis for this conclusion is contains rugged components. It not provided, is judged that any incidental contact between the HVAC ducting and nearby supports will not adversely affect seismic performance of such components.

- No Action necessary.

Attachment to TXX-13121 Page 35 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit ConclusionVEnhancement/Deficiency CPNPP Response 4.13. On page B-75 of the Unit 1 submittal Deficiency:

report, the AWC states that there is a 1" 13. Update the AWC on page B-75 to provide a This issue is addressed in CR-gap between components and that the clearer, more complete discussion of the noted 1" 2013-007545.

clearance should be verified. It does not gap.

appear that the clearance was verified but the clearance consider sufficient based on similarity to another component. However, the AWC appears to accept the condition because it was judged that the light will not damage the adjacent cabinet. There are two concerns with these entries on the AWC. First, why does the AWC state, "Verify clearance" if there is no potential for damage from a collision? Second, was the potential for adverse relay chatter considered if interaction were to occur as required in the SWG on page D-6?

4.14. On page B-128 of the Unit 1 submittal Deficiency:

report, the AWC states that there is a 14. Provide an approximate distance between the This issue is addressed in CR-

"small" clearance to an adjacent support. components and/or provide additional details on 2013-007545.

A "small" clearance is a relative term the potential for seismic interaction.

and is not definitive.

4.15. On several AWCs in the Unit 1 submittal Deficiency:

report, there are instances where 15. Provide a technical basis for the conclusions based conclusions are provided without a on engineering judgment. Question I on page B-122:

basis. For example, see the following: - This issue is addressed in CR-

- Question 1 on page B-122 2013-007545.

- Question 3 on page B-122

- Question 4 on page B-161 Question 3 on page B-122:

- Question 7 on page B-172 - Agree that pendant light swinging into nearby, well-supported raceway is not a seismic concern. No further action is necessary.

Attachment to TXX-13121 Page 36 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response Question 4 on page B-161:

- View of photos show that pendant lights can only interact with piping and their supports which will not be adversely impacted. See photos: 2559, 2660, 2661, and 2662. No further action needed.

Question 7 on page B-172:

- CR-2012-008614 resolves issue by tying ladder to railing.

- No further action needed.

5.1. Section 5 of the Unit 1 submittal report Enhancements:

describes eight (8) licensing basis 16. Augment the submittal reports to mention that - Table 2 was prepared by CPNPP evaluation (LBEs) identified during the CPNPP wrote CRs against every issue identified to record all the issues and CRs seismic walkdowns and areas walk-bys. during the seismic walkdown, even if the SWEs that were written during the Although some of the SWCs and AWCs concluded that a licensing basis evaluation was seismic walkdowns. Note that included comments and discussions of not necessary. In most cases the SWEs recorded some of the CRs were for non-potentially adverse seismic conditions such observations on the SWCs and AWCs. seismic issues.

for which CRs were written, some of the - No further action needed.

other checklists failed to mention that CRs had been prepared to address the 17. Augment the submittal reports to mention that - Table 2 was prepared by CPNPP issues. These CRs were also not many more issues were identified during the to record all the issues and CRs mentioned in the submittal report. walkdowns for which CRs were written than are that were written during the Examples include the following: identified in the submittal report as LBEs. seismic walkdowns. Note that

- Question 6 on page A-349, "Noted a some of the CRs were for non-slight gap under anchorage plate seismic issues. No further action supporting prelube filter. Prelube needed.

filter is adequately restrained.

Judged not to be a seismic concern."

Attachment to TXX-13121 Page 37 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency  : CPNPP Response However, CR-2012-008559 was generated on this topic and not noted on SWC or in report.

- Question 9 on page A-229, "Noted well supported welded fire piping, not a concern." However, CR-2012-008564 was generated on this topic and not noted on SWC or in report.

- CR 2012-008566 describes an NRC concern identified during an Area Walk-By in the diesel generator room that some thumb screws loose, one missing, some tight, on generator control panel CP1-MEDGEE-02B. However, neither this potential seismic concern nor the CR written against it was noted on the AWC (see Question 8 on page B-180 for area SG, 810, 1-085) or in the report.

There may be other checklists that have issues identified for which a CR was written. Although it is not required to identify non-seismic issues, it is noted that 94 CRs were written in conjunction with this program but the Unit 1 submittal report only acknowledges 8 LBEs.

Attachment to TXX-13121 Page 38 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question I Pre-Audit Conclusion/Enhancement/Deficiency I CPNPP Response 5.2. The licensing basis evaluation in CR- Enhancements:

2012-008739 has two omissions related to 18. Update CR-2012-008739 to (1) add data on height - CR is closed. The barrel was the potential for tipping of a barrel. diameter of the commodity barrel in room 1-100 confirmed to be a 55 gal drum.

- Height and Diameter of Barrel. A and (2) address center of gravity of the barrel. - Prepare another CR to state that licensing basis evaluation described drum is a 55 gal drum and meets in the submittal report (on page 5-2) the stability criteria of STA-661.

concluded that a chemical spill kit barrel located about 8 inches from a This issue is addressed in CR-transfer switch would not cause an 2013-007227.

adverse seismic interaction because the required separation distance was 19. Have the SWEs review the updated CR as the - One of the SWEs reviewed the 6 inches, as required by the plant basis for resolving this potentially adverse seismic above conclusion and agreed seismic housekeeping procedure condition. with the conclusion.

STA-661. However, neither the - No additional action required.

AWC for room 1-100 (where this barrel was located) nor CR-2012- 20. Have the peer reviewers review adequacy of the - The Lead Peer Reviewer agreed 008739 records the height and CR and note that an earlier version of the CR with the above conclusion.

diameter of the barrel. omitted relevant information as an example of an - No additional action required.

- CG of Barrel. Further, during issue identified by the peer reviewers.

interviews it was noted that the barrel was nearly empty. Because there was piping and hoses on the top of the barrel, as shown in the figure on page B-203, the barrel center of gravity may have been higher than its geometric center.

Therefore, the stability criteria may not be directly applicable.

Because neither the CR nor the AWC recorded the height and diameter of the barrel and did not address the effective CG of the barrel, this CR appears to have weaknesses in the evaluations for concluding that the barrel is stable.

Attachment to TXX-13121 Page 39 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Toi/usinPre-Audit Conclusioir/Enhancement/Defic~iency CPNPP Response 6.1. SWG states on page 6-1 that the peer Enhancement:

review process should include "review 21. Update the submittal report to identify any issues - No issues were identified by the

[of] the decisions for entering the the peer reviewers found during their review of peer reviewers. The topics potentially adverse conditions into the the LBEs and how those issues were resolved or covered during the peer review CAP process." Section 6.4 of the Unit 1 state that no issues were identified during their are addressed in the WCAP-submittal report states that such a peer peer review. 17685-NP, Supplemental 1 in reviewer was performed: Sections 6.1.5 and 6.4 and in Tables 6-1 and 6-2.

"The peer reviewers performed a 22. Have the Peer Reviewers state in the submittal - John O'Sullivan reviewed the review of all completed licensing report whether they agree that none of the other other CRs in October 2012 in basis evaluations and the walkdown CRs written during the seismic walkdowns (i.e., Section 6.1.1.

team's decisions. The peer review of those for which LBEs were not performed by the - Wally Djordjevic reviewed Table Sections 4.3 and 5, and Appendix D SWEs, as discussed in Topic/Question 5.1) 2, which described all the CRs of this report lead the peer reviewers warrant a LBE. generated during the seismic to conclude that the licensing basis walkdown.

evaluations carefully compared the - No further actions required.

actual as-found plant configurations to the current licensing basis documentation in order to assess configuration compliance with the Comanche Peak Unit 1 design basis."

[Unit 1 Submittal Report, page 6-9]

SWG states on page 6-3 that a summary of the peer review process should be described in the submittal report including "a discussion of the peer review activities, peer review findings, and resolution of peer review comments." The Unit 1 submittal report does not mention any peer review findings (or lack thereof) nor any associated resolution of peer review comments.

Attachment to TXX-13121 Page 40 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response During an interview with Paul Passalugo, CPNPP lead engineer for NTTF 2.3 seismic program, he stated that every CR generated for this project was sent to S&A for review and comment.

However, no comments, corrections, or statements of acceptability were returned for any of the CRs. As noted above in Topic/Question 5.2, the LBE in CR-2012-008739 states that the barrel would not tip over, but the LBE did not include the data needed to apply the seismic housekeeping criteria to come to that conclusion (i.e., the height/ diameter ratio of the barrel).

6.2. SWG states on page 6-3 that the "peer Enhancement:

review should include a review of the 23. Modify the submittal report to include a statement - CPNPP generated Table 2, which licensing basis evaluations developed, that a CR was written for every concern identified identifies all the CRs written including the decisions for entering during the seismic walkdowns and walk-bys and during the seismic walkdowns.

potentially adverse seismic conditions that it was not necessary to decide which issues - No further action necessary.

into the plant's CAP." It is recognized should be entered into the CAP since they were all that every one of the issues identified entered.

during the seismic walkdowns and walk-bys was entered into the plant CAP by creating CRs. However, the Unit 1submittal report is silent on how the decisions were made for entering potentially adverse seismic conditions into the plant's Corrective Action Program (CAP).

Attachment to TXX-13121 Page 41 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 6.3. Pages 6-2 and 6-5 of the Unit 1 submittal Since the two SWEs had relatively limited seismic report state that there was a peer review walkdown experience at the time of the CPNPP of the walkdowns and that an interview seismic walkdowns (one had been out of school only to discuss the conduct of the walkdowns a few months and the other out of school only about was performed. However, the peer two years), it would be beneficial if the additional reviewers went above and beyond the oversight and peer review provided on August 27, minimum SWG guidelines by also 2012 would have been described in the submittal accompanying the SWEs in the field to report.

observe their performance. During interviews it was noted that the peer Enhancement.

observed the performance of the SWEs 24. Describe in the submittal report the additional Section 6.1.1, Bullet #2 and on August 27, 2012 and later that day oversight and peer review provided to the two Section 6.1.4 of the submittal discussed their observations. The Unit I SWEs during the start of the CPNPP seismic report state that the peer submittal report does not discuss the walkdowns on August 27, 2012. reviewers joined the walkdown additional level of review and guidance. team for a portion of the day's planned walkdowns.

- No further action necessary.

7.1. No comments were identified on the IPEEE vulnerabilities section of the submittal report.

8.1. Does the Unit 1 submittal report describe As described in the comparison of the submittal See options described above and how the guidelines from the SWG were report to the SWG (Attachment 6) and in the below.

addressed in the NTTF 2.3 seismic summary of the interviews conducted (Attachment 5),

program? the Unit I submittal report includes the appropriate descriptions for most of the elements of the NTTF 2.3 program at CPNPP. However, the Pre-Audit Review Team identified some areas where the SWG guidelines were not adequately described and also noted a few places with apparent errors in the report.

These omissions and errors are summarized above and below.

Attachment to TXX-13121 Page 42 of 44 Table 3 - CPNPP Pre-Audit Review Issues List (See Notes at end of Table)

Topic/Question Pre-Audit Conclusion/Enhancement/Deficiency CPNPP Response 8.2. Page 2-1 of submittal report notes that Enhancement.

Greg Bryan (a licensed SRO) led the 25. Augment the reports to mention that Operations - Section 4.1 of the Supplement 1 to effort for Operations involvement, participated in all of the seismic walkdowns and submittal report describes the However, the report fails to note that areas walk-bys. involvement of OPS in the OPS also participated in all of the walkdowns.

walkdowns and walk-bys. This level of - No further action necessary.

support is above the minimum requirements in the SWG.

8.3. First paragraph of page 5-1 and Section Deficiency:

6.1.5 of the Unit 1 submittal report 26. Fix the incorrect counts of LBEs in the Unit 1 - Corrected in Supplement 1 to the incorrectly states that seven (7) licensing submittal report. submittal report to report nine (9) basis evaluations (LBEs) were performed LBEs.

whereas in other places in the report - No further action necessary.

eight (8) LBEs are identified.

Notes:

Options to Address Pre-Audit Review Issues This table lists the issues identified during the June 10-14, 2013 Pre-Audit Review of the NTTF 2.3 seismic program at the Comanche Peak Nuclear Power Plant (CPNPP).

Column 1 in the following table is based on the topics covered and questions asked during the Pre-Audit Review. These topics/questions parallel the topics covered in the Seismic Walkdown Guidance (SWG) included in EPRI Report 1025286. Additional attention was given to those areas identified by the NRC auditors in their audit plan for Comanche Peak (ML13143A145).

Column 2 in the following table is based on the Pre-Audit Review Team's conclusions, recommended enhancements, and deficiencies that were identified by the Pre-Audit Review Team and described in the Pre-Audit Review report. These evaluations were based on a limited review of CPNPP Unit 1. Those items identified as "deficiencies" are issues that did not appear to comply with the guidelines in the Seismic Walkdown Guidance (EPRI Report 1025286).

Column 3 in the following table provides CPNPP's response to the issue.

Attachment to TXX-13121 Page 43 of 44 Table 4 - Items Identified during NRC Seismic Audit on July 9-11, 2013

Response

Item Number Item Description (Condition Report Number entered into Corrective Action Program)

No CR initiated entered into CAP. CPNPP program owner discussed items 41 (component) 1 Requested for two area field walkdown checklists and two component field and 56 (area field walkdown) from Table 2 walkdown checklists. "Seismic Walkdown Issues Resolution List".

Related documentation was provided and discussed.

2 Housekeeping issues seem to be a recurring issue - what are plans to CR-2013-006303 address programatically By Thursday morning NRC would like status of CPNPP plans to address 3 issues identified in the pre-audit review, this may reduce or eliminate need CR-2013-007246 for RAIs STA-661 indicates 6" clearance between non-plant equipment and safety 4 related plant equipment. Need to evaluate justification for this CR-2013-007242 requirement.

Misplaced ladder on Elev 852 in Unit 2 Train B Switchgear Room 2-103 CR-2013-007194 (standing on floor leaning up against wall) 6 Missing screws, Unit 2 Train B UPS Room Fan Cooling / Room X-118 / CR-2013-007204 CP2-VAAUPR-02 Unit 1 cable spread room cabinet - clearance to steel column (CP1-7 ECPRTC-26). Evaluation of dynamic response of the steel frame during the CR-2013-007277 design basis seismic event

Attachment to TXX-13121 Page 44 of 44 Table 5 - Additional Experience for SWEs SWE - additional seismic experience for Cory Figliolini o Attended the SQUG training course at Point Beach.

o Performed Palo Verde Nuclear Generating Station (PVNGS) S-PRA Walkdowns.

o Performed various simplified and detailed High Confidence Low Probability of Failure (HCLPF) calculations for PVNGS S-PRA (mostly mechanical and electrical).

o Reviewed HCLPF calculations for Chinshan SMA.

o Performed HCLPF calculations for Kuosheng SMA.

o Performed seismic tip-over calc for Railcar with cask for ANO DFS Seismic Review.

o Performed 1 unit of seismic 2.3 walkdowns at PVNGS. Supported remaining 2 units of Seismic 2.3 walkdowns at PVNGS.

o Performed 2 Units of NT1F Recommendation 2.3 Walkdowns at Calvert Cliffs.

o Attended an ASME B31.1 training course and worked on various piping.

SWE - additional seismic experience for Tim Nealon o Palo Verde Nuclear Generation Station Units 1 and 3, performed seismic 2.3 walkdowns in July & August, 2012 o SOCA Realignment (basic design work, detailing some slabs for transformers and other equipment to be anchored into) o CST Piping Non-Linear Analysis (assisted in validation and verification of the model for the Condensate Storage Tank piping) o PVNGS- Fragilities for Non-Seismic Systems Structures and Components (Responsible for Calculations 1-3, 5, and 6. Reviewed Calculation 4. This was actually the project I was part of the walkdowns for- Walkdowns done on 2/16 of the Fire pump house, FP tanks and corresponding piping.)

o ANO Stackup Analysis (Reviewed Calculation for task 8, responsible for calculation of cask tip o Perry MSR Drain Tank Mod (produced new drawings of several tanks with added attachments.)

o Containment Concrete Beam Deficiencies (worked on reconstitution of Steam Generator Compartment walls (RPT-006))