ML13346A011

Response to Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns

ML13346A011
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna
Issue date:	12/02/2013
From:	Korsnick M Constellation Energy Nuclear Group, EDF Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13346A011 (15)

Text

Mary G. Korsnick Acting Chief Executive Officer Chief Nuclear Officer CENG.

a pint venture of 0Carwmotlaln O nw

,., e Office 410-470-5133 Fax 443-213-6739 E-mail: Maria.Korsnick@cenglic.com December 2, 2013 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 ATTENTION:

REFERENCES:

Document Control Desk Calvert Cliffs Nuclear Power Plant, Units I and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318 Nine Mile Point Nuclear Station, Units I and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-410 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244 Response to Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns (a) Letter from R. H. Beall (NRC) to Selected Licensees, Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns, dated November 1, 2013 (ML13304B418)

(b) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Calvert Cliffs Nuclear Power Plant, Unit 1, Response to 10 CFR 50.54(f)

Request for Information, Recommendation 2.3,

Seismic, dated November 27, 2012 (ML12349A281)

(c) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Calvert Cliffs Nuclear Power Plant, Unit 2, Response to 10 CFR 50.54(f)

Request for Information, Recommendation 2.3,

Seismic, dated November 27, 2012 (ML12339A349)

(d) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

R. E. Ginna Nuclear Power Plant, Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, dated November 27, 2012 (ML12347A104) 100 Constellation Way, Suite 200C Baltimore, MD 21202

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OCAL

Document Control Desk December 2, 2013 Page 2 (e) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Nine Mile Point Nuclear Station, Unit 1, Response to 10 CFR 50.54(f)

Request for Information, Recommendation 2.3,

Seismic, dated November 27, 2012 (ML12342A031)

(f)

Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Nine Mile Point Nuclear Station, Unit 2, Response to 10 CFR 50.54(f)

Request for Information, Recommendation 2.3,

Seismic, dated November 27, 2012 (ML12348A086)

(g) Letter from J. A. Spina (CENG) to Document Control Desk (NRC),

R. E. Ginna Nuclear Power

Plant, Supplemental

Response

to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, dated December 21, 2012 (ML12362A448)

(h) Letter from J. A. Spina (CENG) to Document Control Desk (NRC), Nine Mile Point Nuclear Station, Unit 2, Submittal of Nine Mile Point Nuclear Station, Unit 2 Supplemental Seismic Walkdown Report, dated January 31, 2013 (ML13037A082)

(i) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Calvert Cliffs Nuclear Power Plant, Unit 2, Supplemental Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, dated June 28, 2013 (MLI3193A150)

(j) Letter from J. A. Spina (CENG) to Document Control Desk (NRC), Nine Mile Point Nuclear

Station, Unit 1, Supplemental

Response

to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, dated July 12, 2013 (MLI3197A222)

(k) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

R. E.

Ginna Nuclear Power

Plant, Supplemental

Response

to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, dated July 25, 2013 (ML13210A034)

On November 1, 2013 (Reference a), the U. S. Nuclear Regulatory Commission (NRC) issued a request for additional information associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns. The NRC requested that the selected licensees respond within 30 days of the date of the letter.

Constellation Energy Nuclear Group, LLC (CENG) submitted seismic walkdown reports for Calvert Cliffs Nuclear Power Plant, LLC (CCNPP), Units 1 and 2, R. E. Ginna Nuclear Power Plant, LLC (Ginna), and Nine Mile Point Nuclear Station, LLC (NMPNS) Unit 1 (NMP1) and Unit 2 (NMP2) in References (b) through (k). Attachments (1) through (3) provide the CENG response to the NRC's request for additional information dated November 1, 2013 (Reference a) for CCNPP, Ginna, and NMPNS, respectively.

There are no new regulatory commitments included within this correspondence.

Document Control Desk December 2, 2013 Page 3 If there are any questions regarding this submittal, please contact Bruce Montgomery, Manager-Nuclear Safety and Security, at 443-532-6533.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 2, 2013.

Sincerely, Mary G. Korsnick MGK/STD/EMT/bjd Attachment (1):

Attachment (2):

Attachment (3):

CCNPP Response to Request for Additional Information Ginna Response to Request for Additional Information NMPNS Response to Request for Additional Information cc:

NRC Project Manager, Calvert Cliffs NRC Project Manager, Ginna NRC Project Manager, Nine Mile Point Regional Administrator, NRC Region I Resident Inspector, Calvert Cliffs Resident Inspector, Ginna Resident Inspector, Nine Mile Point S. Gray, DNR

ATTACHMENT (1)

CCNPP RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Constellation Energy Nuclear Group, LLC December 2, 2013

ATTACHMENT (1)

CCNPP RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

1. Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs),

dispositioning of issues, and reporting 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 seismic walkdown engineers (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 licensing basis evaluations (LBEs) (or other determination method), and the resultant action, such as entering it into the corrective action program (CAP) or documenting the result and basis.

Also, in order to confirm that the reported information supports concluding that the plant meets the current licensing basis (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.

CCNPP Response Calvert Cliffs Nuclear Power Plant, LLC (CCNPP) utilized an engineering contractor to provide the SWEs for performing the original seismic walkdowns. These contracted SWEs, comprising a seismic review team, were paired with an Operations Senior Reactor Operator (SRO) for each day's walkdown, and a station engineer as needed to offer assistance where necessary. For follow-up supplemental seismic walkdowns, CCNPP utilized in-house qualified SWEs. The station SWEs followed the same process utilized by the contract personnel. Operations and maintenance personnel were also available and called upon as needed. The judgments and conclusions of the SWEs are reflected in the completed seismic walkdown checklists (SWCs) and area walk-by checklists (AWCs) previously submitted.

Throughout the walkdowns observations were made by the SWEs, and were noted on the field copies of the walkdown checklists (e.g., seismic housekeeping, block walls, equipment vibration, and thread engagement issues).

Seismic interaction issues and housekeeping issues judged to be an immediate I of 3

ATTACHMENT (1)

CCNPP RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION concern were corrected immediately. A trend Condition Report was written for housekeeping conditions that were identified and corrected during the seismic walkdowns.

The final submitted checklists contain the SWE's observations as well as the basis for their disposition.

The SWEs were provided information by station design engineering as needed to determine if an issue represented a PASC.

Hand calculations performed by the SWEs, hand sketches, and the basis for resolution of PASCs, not entered into CAP, are included in the originally submitted Recommendation 2.3, Seismic Walkdowns SWCs and AWCs. If a PASC was entered into the CAP it is noted on the SWC and AWC as well as Tables 5-2 and 5-3 of the original November 27, 2012 submittal.

Following each day's walkdowns, a daily debrief was held between the seismic review team and station personnel. During this debrief, observations by the SWEs were discussed. In many cases, supplemental information (not on hand in the field) was provided to the SWEs to disposition their field concerns. This information included, but was not limited to, existing anchorage drawings, existing anchorage calculations, and masonry wall qualifications. Field observations recorded on field copies of SWCs and AWCs that were dispositioned with existing documentation during final report preparation are reflected in the final checklists submitted to the NRC.

Condition Reports were generated for any adverse condition that could not be dispositioned by the SWEs based on their training, engineering judgment and existing station documentation available to them. Most of these Condition Report were generated during the final report generation. The Condition Reports generated included the necessary information for operations personnel to make the operability determination.

Where required, seismic licensing basis evaluations were completed and documented within the CAP. The November 27, 2012 Seismic Walkdown Report Tables 5-1 and 5-2, the Unit 2 Supplemental Walkdown Report Tables 3-1 and 3-2, submitted on June 30, 2013, provide the CR numbers, a summary of the condition and the action completion status. Unit 1 Condition Reports will be updated in the Unit 1 supplement that is scheduled to be submitted by June 30, 2014.

Condition Reports generated from the walkdowns were dispositioned within the CAP and the bases for these dispositions are contained therein. Examples of dispositions resulting from the evaluations include drawing changes, calculation changes, calculation generation, work orders, and operability assessments.

For any condition where degradation or non-conformance with design was identified, corrective actions were initiated for restoration of the item to its proper design configuration. All resulting actions are traceable through the initiated Condition Reports.

CCNPP Statement of Confirmation A 100% audit of the original field copy walkdown sheets and the final submitted walkdown sheets has been completed, and no new conditions have been identified requiring supplemental information or entry into the CAP. All such conditions were previously identified in the original and supplemental seismic walkdown reports.

Therefore, response alternative (c) was followed to confirm that the reported information supports concluding that CCNPP meets its current licensing basis (CLB).

All PASCs (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 initial and subsequent supplemental seismic walkdown reports to the NRC.

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ATTACHMENT (1)

CCNPP RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

2. Conduct of the Peer Review Process 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.

CCNPP Statement of Confirmation The activities described on Page 6-1 of the Seismic Walkdown Guidance, EPRI 1025286, June 2012, were assessed as part of the CCNPP peer review process in the original and supplemental seismic walkdown submittals. A complete summary of the peer review process and activities was provided in the original and supplemental seismic walkdown submittals. Individuals involved in performing any given walkdown activity were not a peer reviewer for that same activity for either the original or supplemental seismic walkdown submittals. There are no cases in which peer reviewers reviewed their own work.

There are no differences from the original submittal in the review areas or the manner in which the peer reviews were conducted.

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ATTACHMENT (2)

GINNA RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Constellation Energy Nuclear Group, LLC December 2,2013

ATTACHMENT (2)

GINNA RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

1. Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs),

dispositioning of issues, and reporting 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 seismic walkdown engineers (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 licensing basis evaluations (LBEs) (or other determination method), and the resultant action, such as entering it into the corrective action program (CAP) or documenting the result and basis.

Also, in order to confirm that the reported information supports concluding that the plant meets the current licensing basis (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.

Ginna Response R. E. Ginna Nuclear Power Plant, LLC (Ginna) utilized an engineering contractor to provide the SWEs for performing the original seismic walkdowns. These contracted SWEs, comprising a seismic review team, were paired with a station engineer with the same qualification, whose responsibility was to clarify the site's design basis and assist in the identification of Seismic Walkdown Equipment List (SWEL) components. For follow-up supplemental seismic walkdowns, Ginna utilized in-house qualified SWEs.

The station SWEs followed the same process utilized by the contract personnel.

Operations and maintenance personnel were also available and called upon as needed. The judgments and conclusions of the SWEs are reflected in the completed seismic walkdown checklists (SWCs) and area walk-by checklists (AWCs) previously submitted.

Throughout the walkdowns observations were made by the SWEs, and were noted on the field copies of the walkdown checklists (e.g., seismic housekeeping, block walls, equipment vibration, and thread I of 3

ATTACHMENT (2)

GINNA RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION engagement issues).

Seismic interaction issues and housekeeping issues judged to be an immediate concern were corrected immediately. A trend Condition Report was written for housekeeping conditions that were identified and corrected during the seismic walkdowns. Checklists noted the conclusion of the SWEs when identified conditions were judged in the field to not be a PASC.

Following each day's walkdowns, a daily debrief was held between the seismic review team and station personnel. During this debrief, observations by the SWEs were discussed. In many cases supplemental information (not on hand in the field) was provided to the SWEs to disposition their field concerns. This information included, but was not limited to, existing anchorage drawings, existing anchorage calculations, and masonry wall qualifications. Field observations recorded on field copies of SWCs and AWCs that were dispositioned with existing documentation are not reflected in the final checklists submitted to the NRC.

Condition Reports were generated for any adverse condition that could not be dispositioned by the SWEs based on their training, engineering judgment, and existing station documentation available to them. The CAP was utilized to track resolution of all identified potentially adverse conditions not dispositioned by the SWEs. If calculations or drawing updates were required, the resolution was tracked and captured in the CAP. Condition Reports were typically generated the day they were discovered. The Condition Reports generated included the necessary information for operations personnel to make the operability determination.

Where required, seismic licensing basis evaluations were completed and documented within the CAP.

The November 27, 2012 Seismic Walkdown Report Tables 5-1 and 5-2, the December 21, 2012 Supplemental Seismic Walkdown Report Tables 4-2, 4-3, and 4-4, and the July 25, 2013 Supplemental Seismic Walkdown Report Table 3-1 provide the Condition Report numbers, a summary of the condition, and the action completion status.

Condition Reports generated from the walkdowns were dispositioned within the CAP and the bases for these dispositions are contained therein. Examples of dispositions resulting from the evaluations include documentation updates, calculation changes, calculation generation, work orders, modifications and operability assessments. Condition Report dispositions also document the bases for whether or not the conditions were an adverse seismic condition or required a LBE. All identified conditions where any actual analyses or calculations were performed are documented in the CAP. For any condition where degradation or non-conformance with design was identified, corrective actions were initiated for restoration of the item to its proper design configuration. All resulting actions are traceable through the initiated Condition Reports. Table 3-2 in the July 25, 2013 Supplemental Seismic Walkdown Report provided the current Condition Report status of open Condition Reports from the previous two submittals.

Ginna Statement of Confirmation Based on the process of our walkdowns, and the reported information, it was determined that supplemental information was not necessary. Therefore, alternative (c) was chosen for confirming that Ginna meets its current licensing basis (CLB).

No new conditions have been identified requiring supplemental information or entry into the CAP. All such conditions were previously identified in the original and supplemental seismic walkdown reports.

All conditions where PASCs (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination) were identified resulted in generation of a Condition Report and entry into the CAP. These Condition Reports are listed in the November 27, 2012 Seismic Walkdown Report Tables 5-1 and 5-2, the December 21, 2012 Supplemental Seismic Walkdown Report Tables 4-2, 4-3, and 4-4, and the July 25, 2013 Supplemental Seismic Walkdown Report Table 3-1.

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ATTACHMENT (2)

GINNA RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

2. Conduct of the Peer Review Process 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.

Ginna Statement of Confirmation The activities described on Page 6-1 of the Seismic Walkdown Guidance, EPRI 1025286, June 2012, were assessed as part of the Ginna peer review process in the original and supplemental seismic walkdown submittals. A complete summary of the peer review process and activities was provided in the original and supplemental seismic walkdown submittals. Individuals involved in performing any given walkdown activity were not a peer reviewer for that same activity for either the original or supplemental seismic walkdown submittals. There are no cases in which peer reviewers reviewed their own work.

There are no differences from the original submittal in the review areas or the manner in which the peer reviews were conducted.

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ATTACHMENT (3)

NMPNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Constellation Energy Nuclear Group, LLC December 2, 2013

ATTACHMENT (3)

NMPNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

1. Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs),

dispositioning of issues, and reporting 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 seismic walkdown engineers (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 licensing basis evaluations (LBEs) (or other determination method), and the resultant action, such as entering it into the corrective action program (CAP) or documenting the result and basis.

Also, in order to confirm that the reported information supports concluding that the plant meets the current licensing basis (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.

NMPNS Response Nine Mile Point Nuclear Station, LLC (NMPNS) Unit 1 (NMPI) and Unit 2 (NMP2) utilized an engineering contractor to provide the SWEs for performing the original seismic walkdowns.

These contracted SWEs, comprising a seismic review team, were paired with a station engineer with the same qualification, whose responsibility was to clarify the site's design basis and assist in the identification of Seismic Walkdown Equipment List (SWEL) components.

For follow-up supplemental seismic walkdowns, NMPNS utilized in-house qualified SWEs. The station SWEs followed the same process utilized by the contract personnel. Operations and maintenance personnel were also available and called upon as needed. The judgments and conclusions of the SWEs are reflected in the completed seismic walkdown checklists (SWCs) and area walk-by checklists (AWCs) previously submitted.

Throughout the walkdowns observations were made by the SWEs, and were noted on the field copies of the walkdown checklists (e.g., seismic housekeeping, block walls, missing fastener, and bolting corrosion I of 3

ATTACHMENT (3)

NMPNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION issues). Seismic interaction issues and housekeeping issues judged to be an immediate concern were corrected immediately. A Condition Report was written for adverse housekeeping conditions that were identified and corrected during the seismic walkdowns. Checklists noted the conclusion of the SWEs when identified conditions were judged in the field to not be a PASC.

Following each day's walkdowns, a daily debrief was held between the seismic review team and station personnel. During this debrief observations by the SWEs were discussed. In many cases supplemental information (not on hand in the field) was provided to the SWEs to disposition their field observations.

This information included, but was not limited to, existing anchorage drawings, existing anchorage calculations, and masonry wall qualifications.

Condition Reports were generated for adverse conditions that could not be dispositioned by the SWEs based on their training, engineering judgment, and existing station documentation available to them.

Most of these Condition Reports were generated during the final report generation. The CAP was utilized to track resolutions of all identified potentially adverse conditions not dispositioned by the SWEs. The Condition Reports generated included the necessary information for operations personnel to make the operability determination. Where required, seismic licensing basis evaluations were completed and documented within the CAP. The November 27, 2012 Seismic Walkdown Report Tables 5-1 and 5-2, provide the Condition Report numbers, a summary of the condition, and the action completion status.

Supplemental seismic walkdowns performed and documented in Seismic Walkdown Reports submitted January 31, 2013 for NMP2, and July 12, 2013 for NMPI did not identify any potential adverse seismic conditions during the walkdowns.

Condition Reports generated from the walkdowns were dispositioned within the CAP and the bases for these dispositions are contained therein. Examples of dispositions resulting from the evaluations include documentation updates, calculation changes, work orders, and operability assessments. For any condition where degradation or non-conformance with design was identified, corrective actions were initiated for restoration of the item to its proper design configuration. All resulting actions are traceable through the initiated Condition Reports.

NMPNS Statement of Confirmation Based on the process of our walkdowns, and the reported information, it was determined that supplemental information was not necessary. Therefore, alternative (c) was chosen for confirming that the NMPI and NMP2 meet their current licensing basis (CLB).

No new conditions have been identified requiring supplemental information or entry into the CAP. All such conditions were previously identified in the original and supplemental seismic walkdown reports.

All conditions where PASCs (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination) were identified resulted in generation of a Condition Report and entry into the CAP. These Condition Reports are listed in the November 27, 2012 Seismic Walkdown Report Tables 5-1 and 5-2.

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ATTACHMENT (3)

NMPNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

2.

Conduct of the Peer Review Process 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.

NMPNS Statement of Confirmation The activities described on Page 6-1 of the Seismic Walkdown Guidance, EPRI 1025286, June 2012, were assessed as part of the NMPNS peer review process in the original and supplemental seismic walkdown submittals. A complete summary of the peer review process and activities was provided in the original and supplemental seismic walkdown submittals. Individuals involved in performing any given walkdown activity were not a peer reviewer for that same activity for either the original or supplemental seismic walkdown submittals for the respective unit.

There are no cases in which peer reviewers reviewed their own work. There are no differences from the original submittal in the review areas or the manner in which the peer reviews were conducted.

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