ML13312A911

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Audit Report Regarding Seismic Walkdowns to Support Implementation of the Fukushima Lessons Learned NTTF Recommendation 2.3
ML13312A911
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 11/25/2013
From: Beltz T
Plant Licensing Branch III
To: Meyer L
Nextera Energy
Lisa Regner 415-1906
References
TAC MF0161, TAC MF0162
Download: ML13312A911 (7)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 25, 2013 Mr. Larry Meyer Site Vice President NextEra Energy Point Beach, LLC Point Beach Nuclear Plant 6610 Nuclear Road Two Rivers, WI 54241-9516

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 -AUDIT REPORT REGARDING SEISMIC WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS. MF0161 AND MF0162)

Dear Mr. Meyer:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) 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 arid 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, and as supplemented by letter dated October 3, 2013, NextEra Energy Point Beach, LLC (NextEra) submitted its seismic walkdown report as requested in Enclosure 3 of the 50.54(f) letter for the Point Beach Nuclear Plant, Units 1 and 2.

On June 17-19, 2013, the NRC staff conducted an on-site audit to gain a better understanding of the methods and procedures used by NextEra to conquct the seismic walkdowns and facilitate the NRC staff review of the walkdown report.

The audit report is enclosed.

L. Meyer If you have any questions, please contact Terry Beltz at 301-415-3049 or by e-mail at Terry.Beltz@nrc.gov.

Sincerely, Terry Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosure:

Audit Report cc w/encl: Distribution via Listserv

REPORT FOR REGULATORY AUDIT CONDUCTED ON JUNE 17 - 19. 2013 SEISMIC WALKDOWNS NEXTERA ENERGY POINT BEACH. LLC POINT BEACH NUCLEAR PLANT, UNITS 1 & 2 DOCKET NOS. 50-266 AND 50-301 TAC NOS. MF0161.AND MF0162 BACKGROUND On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a request for information letter per Title 10 of the Code of Federal Regulations, Subpart 50.54(f)

(50.54(f) letter). 1 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, nor-tconforming, 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, 2 as supplemented by letter dated October 3, 2013, 3 NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted a seismic walkdown report as requested per Enclosure 3 of the 50.54(f) letter for the Point Beach Nuclear Plant, Units 1 arid 2. On June 17-19, 2013, an NRC audit team conducted an on-site audit to gain a better understanding of the methods and procedures used by NextEra to conduct the seismic ~,

walkdowns and facilitate the NRC staff review of the walkdown report.

REGULATORY AUDIT BASIS The guidance for performing the seismic walkdowns was developed by the Electric Power Research Institute (EPRI) with review and input from the NRC staff in numerous public meetings, webinars, and public conference calls during its development. EPRI submitted EPRI-1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic" (walkdown guidance) 4 for endorsement, and the staff 1

Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340 2

ADAMS Accession No. ML12332A070 3

ADAMS Accession No. ML13277A109 4

ADAMS Accession No. ML12164A181

subsequently endorsed the walkdown guidance by letter dated May 31, 2012. 5 By letter dated July 9, 2012, 6 NextEra indicated that they would utilize the NRC endorsed guidance in the performance of the walkdowns at tne Point Beach Nuclear Plant, Units 1 and 2.

The 50.54(f) letter and the walkdown guidance are used as the basis documents upon which the regulatory audit was performed.

AUDIT ACTIVITIES The NRC audit team consisted of George Wilson (Office of Nuclear Reactor Regulation (NRR)/Japan Lessons-Learned Project Directorate (JLD)), James lsom (NRC/NRR), Annie Kammerer (NRC/Office of Regulatory Research (RES)), Pravin Patel (NRC/Office of New Reactors (NRO)), Frankie Vega (NRC/NRO), and Meghan Tharpe-Kavanaugh (NRC/Region Ill). The audit was performed from June 17-19, 2013.

/

The audit team reviewed the following types of information:

  • Point Beach Nuclear Plant, Units 1 and 2, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities reports and A46 reports.
  • Detailed responses for several questions that were asked during audit discussions. The responses provided details on the personnel involved in the seismic review team, peer review process, checklist completion, overall walkdown process and the roles and responsibilities of the lead reviewer.
  • A typed version of the walkdown checklist as completed in the field for C-022, "Battery Room HVAC Control Panel."
  • In-field walkdowns checklists for all the seismic walkdowns and area walk-bys .
  • Digital copies of the signed checklists with additional information, which were reviewed and compared with the original (in-field) checklists.
  • Anchorage configurations, drawings and IPEEE Screening E~aluation worksheet.
  • Base List 1 and 2. These lists were not included as part of the updated report .
  • Licensee's presentation on the overview of the Fukushima Seismic Walkdowns .

The audit team performed an independent review of selected items and areas based on the licensee's walkdowns. The team observed and discussed the following conditions with the licensee to further understand the licensee's overall walkdown processes.

  • Walkdown of C-022 "Battery Room HVAC Control Panel"- NRC staff accompanied the licensee while such walkdown was performed. This cabinet had to be de-energized in order to be walked down. It was deemed inaccessible during the original walkdown activities.

5 ADAMS Accession No. ML12145A529 6

ADAMS Accession No. ML12192A206

  • In addition to the walkdown mentioned above, the NRC staff observed several other components located in other plant areas to further understand the licensee's walkdown processes:

I

1. Support for components CV-21/P-11 and CV-21/P-11 0- included as part of AWC-05, the NRC staff observed that 2 of 4 nuts. were not fully threaded. This condition was judged to be acceptable by the licensee based on engineering judgment.
2. Masonry wall above and behind component 2CV-351 (AWC#5) -the NRC staff observed the wall's possible seismic interaction with a specific valve. The licensee entered the issue into its corrective action program to further evaluate this issue.
3. The possible interaction of a radiation monitor with a softer target that was unsecured on panel 2Y-41 (AWC#5) was noted. This was judged not to be a concern by the licensee based on engineering judgment.
4. 3ft. by 3ft. block walls (Equipment ID 1AF-04067)- the NRC staff observed the structural integrity of these walls, which were judged as acceptable by the licensee.

AUDIT

SUMMARY

The NRC staff engaged in various discussions with the licensee that led to a significant increase in the level of clarity on the processes used by the licensee when conducting the seismic walkdowns related to Fukushima Recommendation 2.3. Specifically, the staff obtained additional clarification regarding: the background and qualifications of individuals who conducted the seismic walkdown activities, participation and roles of the operations staff, scope of the peer review, experience and independence of the peer reviewers, development of the seismic walkdown equipment list (SWEL), the conduct and reporting of the seismic walkdowns and area walk-bys, and the approach used to disposition potential adverse seismic conditions identified during the walkdown activities.

By discussing in depth with the licensee these specific topics and reviewing the documentation mentioned above, the team was able to meet the objectives of the audit. This will also allow the staff to write more targeted and accurate questions that will support the development of the staff assessment.

The licensee committed to submit an updated seismic walkdciwn report.

Entrance Meeting on June 17. 2013 The NRC staff discussed the audit plan including the scope, topics of discussions and possible path forward with the licensee. The licensee stated their intension to submit updated reports for each of the units based on staff observations included I

as part of the audit report.

Exit Meeting on June 19. 2013

  • The NRC audit team summarized issues identified during the three-day audit. The issues were clearly identified and the licensee was given the opportunity to ask questions. The NRC staff described its path forward, which includes issuing additional questions and developing a formal staff assessment. The licensee committed to update its seismic walkdowri report within 60 days of the audit.

CONCLUSION The NRC staff gained a better understanding of the conduct a*nd outcomes of the seismic walkdowns and identified specific needs for additional information that, when provided, will facilitate the review of the licensee's walkdown report and development of the staff's assessment. On October 3, 2013, the licensee provided updates to the reports for Units 1 and 2. The staff reviewed these reports and noted that additional information is needed in order to complete the assessment of the walkdown reports. The NRC staff subsequently issued a request for additional information by letter dated November 1, 2013. 7 7

ADAMS Accession No. ML133048418

L. Meyer If you have any questions, please contact Terry Beltz at 301-415-3049 or by e-mail at Terry.Beltz@nrc.gov.

Sincerely,

/RAJ Terry Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosure:

Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsOgcMaiiCenter Resource RidsRgn3MaiiCenter Resource LPL3-1 R/F RidsOpaMail Resource DHuyck, EDO Rl, Rll, Rill, RIV RidsNroDsea Resource RidsNrrLAMHenderson Resource RidsAcrsAcnw MaiiCTR Resource RidsNrrDorl Resource* RidsNrrPMPointBeach Resource *RidsNrrDorllpl3-1 Resource LRegner, NRR RKaras, NRO DJackson, NRO FVega, NRO MJardaneh, NRO ADAMS Accession Number: ML13312A911

  • concurrence by email OFFICE DORULPL3-1 /PM DORULPL3-1/LA JLD/PMB/PM NRR/DIRS: TL NAME TBeltz IKing (for MHenderson) LRegner Jlsom
  • DATE 11/18/13 11/12/13 11/19/13 11/18/13 OFFICE NRO/DSEA: DD DORULPL3-1 /BC DORULPL3-1 /PM NAME RKaras RCarlson (SWall for) TBeltz DATE 10/18/13 11/21/13 11/25/13 OFFICIAL RECORD COPY