CNL-13-124, Tennessee Valley Authority - Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Watts Bar Nuclear Plant Seismic Walkdown Results of Recommendation 2.3 of the Near-Term Ta
| ML13339A334 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 12/02/2013 |
| From: | James Shea Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNL-13-124 | |
| Download: ML13339A334 (21) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-13-124 December 2, 2013 10 CFR 50.54(f)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 1 Facility Operating License No. NPF-90 NRC Docket No. 50-390
Subject:
Tennessee Valley Authority (TVA) - Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Watts Bar Nuclear Plant Seismic Walkdown Results of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident
References:
- 1. NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ML12053A340)
- 2. NRC Letter, "Endorsement of Electric Power Research Institute (EPRI)
Draft Report 1025286, "Seismic Walkdown Guidance," dated May 31, 2012 (ML12145A529)
- 3. TVA Letter to NRC, "Tennessee Valley Authority - Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Seismic Aspects for Recommendation 2.3 of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident," dated July 10, 2012 (ML12193A509)
Printed on recycled paper k_7.*
U.S. Nuclear Regulatory Commission Page 2 December 2, 2013
- 4. TVA Letter to NRC, "Tennessee Valley Authority (TVA) - Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Watts Bar Nuclear Plant Seismic Walkdown Results of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated November 27, 2012 (ML12353A250)
- 5. NRC Letter, "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns,"
dated November 1, 2013 (ML13304B418)
On March 12, 2012, the NRC issued Reference 1 to all power reactor licensees and holders of construction permits in active or deferred status. Enclosure 3 of Reference 1 contains specific Requested Actions, Requested Information, and Required Responses associated with Near Term Task Force (NTTF) Recommendation 2.3: Seismic.
The Electric Power Research Institute (EPRI) subsequently developed guidance for the performance of seismic walkdowns, and the NRC endorsed this guidance on May 31, 2012 (Reference 2). By letter dated July 10, 2012 (Reference 3), TVA provided a required response to item 1 in Enclosure 3 of Reference 1, informing the NRC that it intended to perform the seismic walkdown in accordance with the EPRI guidance.
TVA completed the seismic walkdowns in accordance with the EPRI guidance and provided the Seismic Walkdown Reports for the Watts Bar Nuclear Plant (WBN), Unit 1, to the NRC on November 27, 2012 (Reference 4). On November 1, 2013, the NRC issued a Request for Additional Information (RAI) letter related to the seismic walkdown reports (Reference 5). Reference 5 requested a response no later than 30 days from the date of the letter, which would be December 1, 2013.
The purpose of this letter is to provide a response to the RAI letter. The Enclosure to this letter provides TVA's response to the RAls for WBN, Unit 1.
There are no new regulatory commitments in this letter. If you have questions regarding this matter, please contact Kevin Casey at (423) 751-8523.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of December 2013.
Re
- ctfully, Shea icc President, Nuclear Licensing
Enclosure:
cc: See Page 3
U.S. Nuclear Regulatory Commission Page 3 December 2, 2013 Enclosure Watts Bar Nuclear Plant, Unit 1 - Response to Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns cc (Enclosure):
NRC Regional Administrator - Region II NRR Director - NRC Headquarters NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRR Project Manager - Watts Bar Nuclear Plant
ENCLOSURE WATTS BAR NUCLEAR PLANT, UNIT I RESPONSE TO ADDITIONAL INFORMATION ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 2.3: SEISMIC WALKDOWNS
REQUEST FOR ADDITIONAL INFORMATION Seismic Walkdowns On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a letter requesting additional information per Title 10 of the Code of Federal Regulations, Section 50.54(f) (hereafter called the 50.54(f) letter). The 50.54(f) letter requested that licensees conduct seismic hazard walkdowns to verify the plant configuration with the current licensing basis (CLB). The licensees stated by letter that the seismic walkdowns would be performed in accordance with Electric Power Research Institute EPRI-1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic" (walkdown guidance). Following the NRC staffs initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow the staff to complete its assessments.
RAI 1. Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs), dispositioning of issues, and reporting As a result of the audits and walkdown report reviews, the NRC staff noted that licensees' interpretations of the seismic walkdown guidance varied, which resulted in meaningful differences in the process used to disposition identified issues and in the documentation that was provided to the NRC staff In particular, the application of engineering judgment in determining what constituted a potentially adverse seismic condition (PASC), the threshold for conducting licensing basis evaluations (LBEs), and determining what information was to be reported to the NRC staff varied.
The NRC staff intended that conditions initially marked No (N) or Unknown (U) in the field by the seismic walkdown engineers (SWEs) for which an analysis or calculation was performed would be considered as PASCs and that an analysis or calculation constituted an LBE. The walkdown guidance allows for analysis as part of engineering judgment; however, the intent was to allow for only simple analyses that could be readily performed in support of engineering judgment. Further, the walkdown activities were intended to allow for transparency in the licensee's process to demonstrate that PASCs were appropriately identified, that they were addressed in an appropriate manner, and the basis documented such that the current condition of the plant was clearly consistent with the CLB with regard to seismic capability.
During the audits, the NRC staff identified examples of field observations that were deemed not to be PASCs. However, the basis for the determination was not clearly recorded. In some cases, the field checklists were amplified by noting that the basis was engineering judgment.
During site audit discussions, the staff was able to trace the basis for the engineering judgments and found that in many cases they were appropriate. It is expected that these situations would not be included in the walkdown report.
There were other situations that a PASC and LBE were not reported; however, the NRC staff found during the audit that a calculation, analysis (more than just simple), or evaluation was conducted but informally. An example is a confirmatory calculation performed to demonstrate that six anchor bolts out of eight was not a seismically adverse condition. Another example would be an analysis to demonstrate that an existing, slightly short weld was as seismically sound as the prescribed weld length in the plant design documentation. The staff expected these types of conditions and evaluations to be captured in the licensee's normal plant E-1 of 17
processes (e.g., condition report or corrective action program (CAP)), and also reported in the walkdown report, since they were potentially adverse seismic conditions that required more than applying judgment or simple analysis to address.
The NRC staff also found that the process that was used to deal with a field observation that was deemed to be a PASC was also not completely described or captured in the report. In many cases, the licensee reported that an LBE was not performed. However, during the audits, it was clear that an LBE (or an equivalent determination method) was performed and used in determining whether a PASC should be entered into the CAP. The staff expects that these conditions would be reported in the walkdown report.
On the whole, through the audits, the NRC staff found that it was able to conclude that the intent of the guidance was met when the licensee's overall process was completely explained, the information was updated to reflect the actual process, and results were updated. The self-assessments conducted by the licensees of the audited plants also identified the lapse in the description of the process used by the licensee to identify a PASC and disposition it.
Therefore, in order to clarify the process that was followed, please provide a description of the overall process used by the licensee (and its contractors) to evaluate observations identified in the field by the SWEs. The process should include how a field observation was determined to be a PASC or not and how the bases for determinations were recorded. Once a determination was made that an observation was a PASC, describe the process for creating a condition report (or other tracking mechanism), performing the LBE (or other determination method),
and the resultant action, such as entering it into the CAP, or documenting the result and basis.
Also, in order to confirm that the reported information supports concluding that the plant meets the CLB, please follow one of the following three acceptable alternatives:
(a) Provide a supplement to the table or text from the original walkdown report, if needed, to include similar conditions as the above examples and situations and for conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination. The supplement should include a short description of each condition, how it was dispositioned and the basis for the disposition, as follows: 1) for each condition that was entered into the CAP, provide the CAP reference number, initiation date, and (if known) the planned completion date, or 2) for all other conditions, provide the result of the LBE (or other determination method), the basis for the result, and how (or where) the result was captured in the plant's documentation or existing plant process.
(b) Following the plant's standard procedures, confirm that a new CAP entry has been made to verify if appropriate actions were taken when reporting and dispositioning identified PASCs (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination). The eventual CAP closeout, including the process followed and actions taken should be in sufficient detail to enable NRC resident inspectors to follow up.
(c) If no new conditions are identified for addition to the supplement or the CAP entry mentioned above is deemed not necessary, provide a statement of confirmation that all potentially seismic adverse conditions (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination) identified during the walkdowns and walk-bys were addressed and included in the report to the NRC.
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TVA Response The walkdowns and walk-bys performed at Watts Bar Nuclear Plant (WBN) were conducted in accordance with EPRI 1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic" (hereafter "Seismic Walkdown Guidance") and TVA procedure CTP-SWD-100 which included the full scope of the Seismic Walkdown Guidance along with some supplemental TVA specific procedures (i.e. TVA CAP procedures).
The walkdowns and walk-bys were conducted in accordance with the Seismic Walkdown Guideline and each was given a final status. Each walkdown or walk-by was completed by a team of 2 seismic walkdown engineers (SWEs) that met experience and training requirements per the Seismic Walkdown Guidance and were accompanied by operations personnel.
Walkdown packages were assembled prior to each walkdown and included the seismic walkdown checklists (SWCs), area walk-by checklists (AWCs), and anchorage verification drawings as necessary.
If no potentially adverse seismic conditions were noted during a walkdown or walk-by, a "YES" status was given to the selected piece of equipment or area. If a potentially adverse seismic condition was noted, a "NO" status was given and a CAP entry was written. If any equipment was inaccessible, or if a portion of an item of equipment was unobservable, an "UNKNOWN" status was given.
The walkdown teams performed the inspections and any questionable observations were compared to the design basis documentation or, in some cases, engineering judgment was used to determine if an observation qualified as a PASC. The engineering judgments were documented on the SWCs and AWCs. Those observations that could not be justified with existing documentation or sound engineering judgment were entered into the WBN CAP. With the assistance of WBN engineering CAP entries were pre-screened into two categories:
housekeeping only with no potential impacts to safety related equipment or PASC. The pre-screening was intended to aid in the disposition and correction of the observations.
When a PASC was identified at WBN, the condition was entered into the WBN CAP. No licensing basis evaluations were performed by the walkdown team per TVA expectations to communicate any potential operability concerns as soon as they were identified. All licensing basis determinations were performed by WBN engineering on each CAP entry.
The CAP Process at TVA is defined in TVA NPG Standard Program and Processes SPP-22.300, "Corrective Action Program." The CAP program at all TVA nuclear facilities consists of five key phases:
Initiation Screening Analysis Implementation Monitoring E-3 of 17
To confirm that the reported information supports concluding that the plant meets the CLB, TVA submits the following response using acceptable alternative (a) listed above for WBN Unit 1 as described below:
Multiple CAP entries were generated during the seismic walkdown process at WBN.
There were a total of eleven CAP entries for Unit 1 that were considered PASCs.
These CAP entries and their status are summarized in Table 1. Additionally seven CAP entries were generated to address general housekeeping issues which did not represent PASCs (per the criteria established in the Seismic Walkdown Guidance and EPRI SWE training). These CAP entries and their status are summarized in Table 2.
No conditions outside the licensing basis were found during the course of this walkdown process.
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Table-Watts Bar Nuclear Plant Unit 1: Potentially Adverse Seismic Conditions No.
Component ID & Description Identified Condition PER Action Taken Planned Status OR Completion Area Walk-by Date WBN-1-TANK-082-0160-A, During the walkdown for WBN 582519 WBN civil engineering support 06/06/2014 OPEN Diesel Gen Engine 1A1, Start TANK-082-0160-A, it was found contractors evaluated the Air Receiver A that the bottom connection on condition and determined the the south U-bolt connection to capacity of the starting air tank the support saddle is not tight to anchorage, in its current the restraint. On the north U-bolt configuration, is sufficient to connection to the support side, resist the demand during a the bottom connection is missing design basis earthquake. No the washer.
further evaluation necessary.
Work order scheduled to tighten the U-bolt connection.
2 WBN-WB-001 Diesel During the area walk-by for the 582523 WBN civil engineering evaluated 06/06/2014 OPEN Generator 1A-A, Room D104 Diesel Generator Room D104 the condition and determined (WBN-WB-001) a problem with that the capacity of the air the 1A-A Air Receiver Tank was receiver tank anchorage, in its noted. Of the two inboard current configuration, is anchor plates, the south anchor sufficient to resist the demand plate on the tank is installed during a design basis such that it is resting inside the earthquake. No further saddle. This limits it ability to evaluation necessary.
function properly.
A work order is scheduled to restore the configuration of the south anchor plate.
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Table-1 Watts Bar Nuclear Plant Unit 1: Potentially Adverse Seismic Conditions No.
Component ID & Description Identified Condition PER Action Taken Planned Status OR Completion Area Walk-by Date 3
WBN-0-PNL-278-M012, During the walkdown for WBN 583573 WBN civil engineering evaluated 05/23/2014 OPEN Radiation Monitoring MCR PNL PNL-278-M026A-A and WBN the condition and determined PNL-278-MO1 2, it was found that the capacity of the panels, WBN-0-PNL-278-M026A-A, that one of the four visible in their current configuration, is D.G. 1A-A MCR PNL connecting bolts on the south sufficient to resist the demand side of the bolted joint between during a design basis WBN-0-PNL-278-M026D-B, MCR panels WBN-0-PNL-278-earthquake.
D.G. 28-B MCR PNL M012 and WBN-0-PNL-278-MO15 was sheared off and one Work order scheduled to repair was missing. Two bolts were damaged bolt and replace the missing between panels WBN missing bolts.
PNL-278-M012 and WBN PNL-278-M026D-B on the south side.
4 WBN-WB-010, ERCW Pump During the area walk-by for room 588895 The scaffold was removed from CLOSED Room A, Room 1105 1105 of the Intake Pumping the area and crews briefed on Station (WBN-WB-010) it was WBN scaffolding construction found that temporary scaffolding procedures for general seismic near ERCW pump 0-PMP-67-32 qualification and horizontal is not adequately restrained to restrain requirements.
prevent interaction with the pump motor during a seismic event. Lateral restraint was not provided in one direction at a sufficient height to prevent tipping towards the pump motor.
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.Table-1 Watts Bar Nuclear Plant Unit 1: Potentially Adverse Seismic Conditions No.
Component ID & Description Identified Condition PER Action Taken Planned Status OR Completion Area Walk-by Date 5
WBN-1-MCC-232-B-B, Reactor During the walkdown for WBN 592225 WBN craft performed an CLOSED Vent Board 1 B-B MCC-232-B-B, it was found that additional walkdown of the a cap plate on a tube steel cable identified condition and tray support was in direct determined that the conduit contact with a conduit collar on collar was not in contact with the the MCC. The conduit number in cable tray support. This was question was not legible.
verified by sliding a piece of paper between the conduit collar and the cable tray support. Per WBN civil engineering this is acceptable as long as there is no contact between the tray support and the conduit collar.
No further action or evaluation necessary.
6 WBN-WB-030, 480V Board During the area walk by in the 592249 The fire protection piping was CLOSED Room 1A, Room A851 480V Board Room 1A (WBN-rerouted to eliminate the contact WB-030) a fire protection between the sprinkler head sprinkler head deflector was deflector and the four inch found to be in direct contact with conduit.
a four inch conduit. The conduit in question is PLC-1709, which runs into 1-JB-282-1770, and is located behind panel 10 of WBN-1-MCC-213- 001-A.
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.-Table I
Watts Bar Nuclear Plant Unit 1: Potentially Adverse Seismic Conditions No.
Component ID & Description Identified Condition PER Action Taken Planned Status OR Completion Area Walk-by Date 7
WBN-0-DBD-238-0003, During the walkdown for WBN 595936 Both the printer and drawing CLOSED Distribution BD PNL 3 120V AC DBD-238-0003, in the Main table located in the control room Preferred Control Room, a copier was were evaluated by WBN civil observed in close proximity of engineering per site procedures the breaker side of the panel.
for temporary equipment control The copier is not restrained and and accepted. No further does not meet the overturn evaluation or action required.
criteria that would indicate it would be safe from tipping during a seismic event.
Additionally, there is a drawing table in the area that is not restrained but would not cause a risk to the panel.
8 WBN-WB-032, Mechanical During the area walk by in the 596514 WBN civil engineering evaluated 05/27/2014 OPEN Equipment Room 1 B, Room Mechanical Equipment Room the single sheared anchor bolt A924 A924 (WBN-WB-032) a sheared and determined it does not anchor bolt was observed on the invalidate the seismic capability 480V Board Room Condenser of the 480V Board Room B-B. All remaining anchor bolts Condenser B-B.
appear to be in good condition with only minor to moderate Work order scheduled to replace surface corrosion.
damaged anchor bolt.
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Table I Waits Bar Nuclear Plant Unit 1: Potentially Adverse Seismic Conditions No.
Component ID & Description Identified Condition PER Action Taken Planned Status OR Completion Area Walk-by Date 9
WBN-0-CHR-031-0036/2-A, During the walkdown for WBN 596521 WBN civil engineering evaluated 04/28/2014 CLOSED Shutdown Board Room Chiller CHR-031-0036/2-A, significant the partial degradation of the 3/4 A-A corrosion was observed on the inch bolt and determined south pedestal baseplate and sufficient material exists to meet anchor bolts. The amount of seismic demand. No further material reduction was evaluation necessary.
approximately 1/8" or less. The north pedestal had significant corrosion as well.
10 WBN-0-CHR-031-0049/2-B, During the walkdown for WBN 596525 WBN civil engineering evaluated CLOSED Shutdown Board Room Chiller CHR-031-0049/2-B, significant the partial degradation of the 3/4 B-B corrosion was observed on the inch bolt and determined south pedestal baseplate and sufficient material exists to meet anchor bolts. The amount of seismic demand. No further material reduction was in excess evaluation necessary.
of 1/8". The north pedestal had significant corrosion as well.
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Table I -
Watts Bar Nuclear Plant Unit 1: Potentially Adverse Seismic Conditions No.
Component ID & Description Identified Condition PER Action Taken Planned Status OR Completion Area Walk-by Date 11 WBN-0-INV-235-0001-D, 120V During the walkdown for WBN 597122 WBN civil engineering evaluated CLOSED AC Vital Inverter 0-1 INV-235-0001-D, the spacing the as-constructed configuration tolerance of +/- 3" is violated and qualified the anchorage WBN-1-INV-235-0003-F, 120V between the third and fourth spacing as is. Both the design AC Vital Inverter 1-111 anchor bolts on the front of the basis calculation and drawings inverter. The field measured were revised to document the spacing between these bolts is as-constructed configuration. No 9-3/4". Per plant documentation, further evaluation or action this spacing should be 1' required.
3/16", which is 3-7/16" greater than the as-installed anchor spacing.
The as built dimension for one anchor bolt on the front of WBN-1-INV-235-0003-F does not match plant documentation. Per plant documentation, the first anchor spacing on the right side of the cabinet should be 15-5/8".
The dimension in the field was measured to be 18-1/4".
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Table 2-Watts Bar Nuclear Plant Unit 1: Other (Non-PASC) Walkdown Observations No.
Component ID &
Identified Condition PER Action Taken Planned Status Description Completion OR Date Area Walk-by 1
WBN-WB-001, Diesel Generator 1A-A, Room D104
- 1) On the north end of Diesel Generator 1A-A, room D104, pipe support 1082-586-2-2-3 has loose double nuts on one side of the trapeze support, indicating that the support is not properly supporting the pipe as designed.
- 2) On the south end of Diesel Generator 1A-A, room D104, there is a bent finger clamp on the air crosstie pipe between the starting air receivers.
- 3) On the south end of Diesel Generator 1A-A, room D104, a temporary eyewash station is restrained with nylon rope, which is not acceptable per WBN temporary equipment control procedures.
- 4) On the east side of Diesel Generator 1A-A, room D104, the end panel of 1-PNL-82-A/1 is missing approximately 50% on the bolts.
- 5) In the lube oil storage room, prior to entering the Diesel Generator hallway, there are both full and empty 50-gal drums that are not restrained per WBN temporary equipment control procedures.
584046 WBN civil engineering evaluated conditions 1 and 2 and determined the conditions pose no immediate seismic concern.
Work order scheduled to correct the identified conditions.
- 3) The eyewash station is exempted from temporary equipment control, and does not pose a seismic threat/risk or other safety concern in its location.
- 4) 1-PNL-82-A/1 is missing 50% of the bolts however the panel is secure and FME is installed on the bolt holes.
- 5) The 50 gallon drums located in the lube oil storage room were properly restrained per WBN temporary equipment control procedures.
06/09/2014 OPEN E-11 of 17
Table 2 Watts Bar Nuclear Plant Unit 1: Other (Non-PASC) Walkdown Observations No.
Component ID &
Identified Condition PER Action Taken Planned Status Description Completion OR Date Area Walk-by 2
WBN-WB-014, During the walkdown of Auxiliary Building 588403 The scaffold was modified and CLOSED Auxiliary Building, El. 772, 480V Board Room 1 B (Room there is no longer a concern for 480V Board Room A852), the following issue was observed potential impact against the 1B, Room A852 and noted:
flexible conduit.
A scaffolding support Was identified to be in close proximity to a flexible electrical conduit located on the south face of charger cabinet, O-CHGR-236-1.
3 WBN-WB-019, While conducting Seismic walk-downs in 588404 The top railing was stabilized.
CLOSED Auxiliary Building, the Aux Bldg, EL. 772 in the 480v 480V Transformer Transformer Room 1 B (Room A855), the Room 1 B, Room following issue was observed:
A855
- The top railing of a temporary scaffold was observed to not be very stable.
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Table 2 Watts Bar Nuclear Plant Unit 1: Other (Non-PASC) Walkdown Observations No.
Component ID &
Identified Condition PER Action Taken Planned Status Description Completion OR Date Area Walk-by 4
WBN-WB-009 While conducting Seismic walk-downs in 588924 All identified conditions were CLOSED Intake Pumping the Intake Pumping Station, ERCW Pump immediately corrected in Station, ERCW Room B, Room 1109, the following issues compliance with WBN procedures.
Pump Room B, were observed and noted:
Room 1109
- 1) Two trash cans in area not restrained.
- 2) One trash can is partially obstructing access to a Fire Extinguisher. (This trash can was removed from the immediate vicinity of the fire extinguisher).
- 3) Ladder on floor not properly restrained.
- 4) Temporary rolling scaffolding with wheel stops engaged and tied off with rope which is not allowable per WBN temporary equipment control procedures.
5 WBN-WB-008 While conducting Seismic walk-downs in 588928 The temporary lifting device was CLOSED
'Auxiliary Building, the Aux Bldg, El. 713, the following issue removed from the area.
Elevation 713, Area was observed:
Bounded by Column Lines A1-T/A5-R A temporary lifting device adjacent to instrument rack 0-L-155 is restrained with rope to a pipe support which is not allowable per WBN temporary equipment control procedures.
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Table 2 Watts Bar Nuclear Plant Unit 1: Other (Non-PASC) Walkdown Observations No.
Component ID &
Identified Condition PER Action Taken Planned Status Description Completion OR Date Area Walk-by 6
WBN-WB-024, Housekeeping issues in Spent Fuel Pit 592213
- 1) Job Box removed from the area CLOSED Auxiliary Building, Pumps area:
- 2) Rolling cart restrained per WBN Elevation 737,
- 1) Job Box not restrained per WBN temporary equipment control Spent Fuel Pit Heat temporary equipment control procedures procedures.
Exchanger and near Component Cooling System Thermal
WBN temporary equipment control B.
procedures.
- 4) Scaffold storage opposite the
- 2) Rolling cart not restrained per WBN Spent Fuel Pit Circulation pumps temporary equipment control procedures restrained per WBN temporary equipment control procedures -
- 3) 50 Gallon drums with loose chain
- 5) Bulbs replaced in Spent Fuel around base not restrained per WBN Pit area.
temporary equipment control procedures.
- 4) Scaffold storage opposite the Spent Fuel Pit Circulation pumps has items not restrained per WBN temporary equipment control procedures.
- 5) Bulbs burnt out in Spent Fuel Pit area.
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-Table 2
Watts Bar Nuclear Plant Unit 1: Other (Non-PASC) Walkdown Observations No.
Component ID &
Identified Condition PER Action Taken Planned Status Description Completion OR Date Area Walk-by 7
WBN-WB-026, While conducting Seismic walk-downs in 592215
- 1) Portable fire extinguisher cart CLOSED Auxiliary Building, the Aux Bldg, El. 757, in the Refueling restrained per WBN temporary Elevation 757, Room (Room A813), the following equipment control procedures.
Refueling Room, housekeeping issues were observed in the
- 2) Two (2) portable flammable Room A813 immediate area of Aux Control Air storage cabinets restrained per Compressor B-B:
WBN temporary equipment control procedures.
- 1) Portable fire extinguisher cart are not
- 3) Four (4) 50-gal drums in area properly restrained per WBN temporary restrained per WBN temporary equipment control procedures equipment control procedures.
- 2) Two (2) portable flammable storage
- 4) Two (2) 50-gal drums in area cabinets not properly restrained per WBN restrained per WBN temporary temporary equipment control procedures.
equipment control procedures.
- 3) Four (4) 50-gal drums in area not
- 5) Other miscellaneous temporary properly restrained per WBN temporary equipment stored under stairs equipment control procedures.
restrained per WBN temporary
- 4) Two (2) 50-gal drums in area not equipment control procedures.
properly restrained per WBN temporary equipment control procedures stored under stairs.
- 5) Other miscellaneous temporary equipment stored under stairs that are not properly restrained per WBN temporary equipment control procedures.
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RAI 2 Conduct of the Peer Review Process As a result of the walkdown report reviews, the NRC staff noted that some descriptions of the peer reviewers and the peer review process that was followed were varied and, in some cases, unclear. In some cases, the staff could not confirm details of the process, such as if the entire process was reviewed by the peer review team, who were the peer reviewers, what was the role of each peer reviewer, and how the reviews affected the work, if at all, described in the walkdown guidance.
Therefore, in order to clarify the peer review process that was actually used, please confirm whether the following information on the peer review process was provided in the original submittal, and if not, provide the following.
(a) Confirmation that the activities described in the walkdown guidance on page 6-1 were assessed as part of the peer review process.
(b) A complete summary of the peer review process and activities. Details should include confirmation that any individual involved in performing any given walkdown activity was not a peer reviewer for that same activity. If there were cases in which peer reviewers reviewed their own work, please justify how this is in accordance with the objectives of the peer review efforts.
Also, if there are differences from the original submittal, please provide a description of the above information. If there are differences in the review areas or the manner in which the peer reviews were conducted, describe the actual process that was used.
TVA Response A peer review was performed in accordance with the March 12, 2012, 50.54(f) letter and the Seismic Walkdown Guidance. The peer review process involved considerable interaction with the review teams, and was performed throughout all phases of the effort including the following:
Review of the Structures, Systems, and Components (SSCs) included on the Seismic Walkdown Equipment List (SWEL)
In-plant walkdown observations and review of completed checklists for the Seismic Walkdowns and Area Walk-Bys Review of potentially adverse seismic conditions, utilization of the CAP process, and associated licensing basis evaluations Review of submittal report A summary of the activities performed by the Peer Review Team is shown in Table 3. The listed functions are taken from Section 6 of the Seismic Walkdown Guidance and are consistent with the complete peer review report which is included as Appendix G of the WBN Unit 1, seismic "walkdown reports.
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Table 3 Activity Description Activity Performed by Notes/Comments Peer Review Team?
(YES/NO)
Review the selection of YES As noted in the Peer Review Report, the peer the SSCs included on review team evaluated the SWEL to ensure a the SWEL diverse sample of the equipment required to perform the five safety functions outlined in Section 4.1, including items previously identified as IPEEE outliers. The peer review team also provided needed clarification regarding equipment class designation for SWEL items (regarding instrument racks, temperature sensors, distribution panels, and medium voltage switchgear).
Review a sample of the YES As noted in the Peer Review Report, in total, the checklists (10% to 25%
peer review team performed documentation required) prepared for the review for over 50% of the checklists completed Seismic Walkdowns and by the SWEs. Review of the SWCs and AWCs Area Walk-Bys included substantial interface with the SWEs, observation of the SWEs during performance of walkdowns / walk-bys, and independent field investigation of individual equipment components. Peer review team efforts related to this activity are summarized in the Peer Review Report.
Review the licensing YES As noted in the Peer Review Report, all basis evaluations potentially adverse seismic conditions were reviewed in detail to address seismic licensing basis and operability issues.
Review the decisions for YES As noted in the Peer Review Report, all entering the potentially potentially adverse seismic conditions were adverse conditions into reviewed in detail to address seismic licensing the CAP process basis and operability issues. The peer review team is in full concurrence with the entry of confirmed potentially adverse seismic conditions into the CAP.
Review the submittal YES As noted in the Peer Review Report, the peer report review team reviewed the submittal report and is in full concurrence with the documented observations and findings.
Summarize the results of YES Results of the peer review process are the peer review process in summarized in the Peer Review Report the submittal report In summary, the peer review results are confirmatory and fully supportive of the evaluations and findings as described in the WBN Unit 1, walkdown reports. The peer reviews met the intent of the Seismic Walkdown Guidance and were effective in providing technical oversight and review of all required aspects of the process herein described.
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