Text

SNCF164-RPT-02, Ver. 1.0, Farley Unit 2 Seismic Walkdown Report, Rer SNC432467 for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, Cover Through Page 46 of 46
	ML13004A252
Person / Time
Site:	Farley
Issue date:	11/26/2012
From:	Miktus P; Southern Nuclear Operating Co, Southern Co
To:	; Office of Nuclear Reactor Regulation
References
	NL-12-2267 SNCF164-RPT-02, Ver. 1.0
	Download: ML13004A252 (47)
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Joseph M. Farley Nuclear Plant - Unit 2 Seismic Recommendation 2.3 Walkdown Report Requested by NRC Letter, Request for Information Pursuantto Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, dated March 12, 2012 Enclosure 1 Farley Unit 2 Seismic Walkdown Report for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic

NO. SNCF164-RPT-02 PROJECT REPORT VERSION 1.0 COVER SHEET Page 1 of 46 Farley Unit 2 SEISMIC WALKDOWN REPORT, RER SNC432467 For Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic Prepared by: Date: 11/26/2012 Paul A. Miktus Reviewed by:* Date: 11/26/2012 Approved by: (ENERCON) Date:

Project Manager or Designee Bill Henne Approved by:

(SNC) Date:

Technical Lead or Designee / Melanie Brown Pear Review Team Leader Approved by:

(SNC) Date: go Projoct Manager ot Designee Davd Whitman

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 2 OF 46 TABLE OF CONTENTS Section Title Page 1.0 SC O PE AN D O BJEC TIV E ................................................................................................... 4 2.0 SEISMIC WALKDOWN PROGRAM IMPLEMENTATION APPROACH .................. 5 3.0 SEISMIC LICENSING BASIS

SUMMARY

....................................................................... 6 3.1 SAFE SHUTDOW N EARTHQUAKE ................................................................................................................... 6 3.2 DESIGN CODES, STANDARDS AND M ETHODS ........................................................................................ 8 4.0 PER SO N N EL Q U ALIFICA TIO N S ...................................................................................... 9 4.1 OVERVIEW OF PROJECT RESPONSIBILITIES ......................................................................................... 10 4.2 TEAM EXPERIENCE SUM M ARIES ................................................................................................................. 12 5.0 IPEEE VULNERABILITIES REPORTING ..................................................................... 18 6.0 SEISMIC WALKDOWN EQUIPMENT LIST DEVELOPMENT .................................. 19 6.1 DEVELOPMENT OF SW EL I ............................................................................................................................ 19 6.2 DEVELOPMENT OF SW EL 2 ............................................................................................................................ 22 7.0 SEISMIC WALKDOWNS AND AREA WALK-BYS ...................................................... 25 7.1 INACCESSIBLE ITEM S ..................................................................................................................................... 27 8.0 RE SU LTS .................................................................................................................................. 32 8.1 POTENTIALLY ADVERSE SEISM IC CONDITIONS ................................................................................. 32 8.2 EQUIPMENT OPERABILITY ............................................................................................................................ 38 8.3 PLANT CHANGES .............................................................................................................................................. 38 8.4 OTHER NON-SEISM IC CONDITIONS ............................................................................................................. 39 9.0 PEER REV IEW ........................................................................................................................ 40 9.1 PEER REVIEW PROCESS .................................................................................................................................. 40 9.2 PEER REVIEW RESULTS SUMM ARY ............................................................................................................ 40 10.0 REFEREN CE S ......................................................................................................................... 45 11.0 A TTA C H M EN TS ..................................................................................................................... 46

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 3 OF 46 EXECUTIVE

SUMMARY

The Seismic Walkdowns at Farley Unit 2 in response to the NRC 50.54(f) letter dated March 12, 2012, "Enclosure 3, Recommendation 2.3: Seismic" are not complete as all items on the SWEL have not been accessible. A supplementary report will be required. The walkdowns are being performed using the methodology outlined in the NRC endorsed "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic" (EPRI Report number 1025286).

Plant Farley Unit 2 had no significant degraded, non-conforming or unanalyzed conditions that warranted modification to the plant. Plant Farley Unit 2 had no as-found conditions that would prevent SSCs from performing their required safety functions.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 4 OF 46 1.0 SCOPE AND OBJECTIVE The objective of this report is to document the results of the Seismic Walkdowns at Farley Unit 2 in response to the NRC 50.54(f) letter dated March 12, 2012, "Enclosure 3, Recommendation 2.3:

Seismic" (Reference 10.1).

The Seismic Walkdowns followed the guidance contained in EPRI Report 1025286 (Reference 10.2),

which was endorsed by the NRC on May 31, 2012. The scope of the walkdowns was to identify potentially degraded, unanalyzed, or nonconforming conditions relative to the seismic licensing basis.

The 2.3: Seismic Walkdowns for Farley Unit 2 are not complete as all items on the SWEL have not been accessible. A supplementary report will be required. This report documents the findings from all Seismic Walkdowns and Area Walk-bys completed to date.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 5 OF 46 2.0 SEISMIC WALKDOWN PROGRAM IMPLEMENTATION APPROACH The requirements of the 50.54(f) Letter are satisfied by application of and compliance with the NRC endorsed methodology provided in EPRI Report 1025286 (Reference 10.2). In accordance with Reference 10.2, the following topics are addressed in this report:

Documentation of the seismic licensing basis for the systems, structures and components (SSCs) in the plant (Section 3.0);

Assignment of appropriately qualified personnel (Section 4.0);

Reporting of actions taken to reduce/eliminate seismic vulnerabilities identified by the Individual Plant Examination for External Events IPEEE program (Section 5.0);

Selection of SSCs to be inspected in the plant (Section 6.0);

Performance of the Seismic Walkdowns and Area Walk-bys (Section 7.0);

Evaluation of potentially adverse seismic conditions with respect to the seismic licensing bases (Section 8.0); and

" Performance of Peer Reviews (Section 9.0).

Supplemental guidance/clarification for opening cabinets to inspect for adverse conditions was received on September 18, 2012. This required the opening of cabinets, electrical boxes, and switchgear to inspect the internals for potentially adverse seismic conditions, even when opening the components was not required to inspect the anchorage. At the time of this supplemental guidance/clarification, the Farley Unit 2 walkdowns were complete with non-outage walkdowns.

However, the affected components were identified and scheduled for re-inspection with component doors opened. Further discussion is given in Section 7.0.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 6 OF 46 3.0 SEISMIC LICENSING BASIS

SUMMARY

This section provides a summary of the licensing bases for the Seismic Category I Structures, Systems, and Components (SSCs) in the plant. It includes a discussion of the Safe Shutdown Earthquake (SSE) and the codes and standards used in the design of the Seismic Category I SSCs for meeting the plant-specific seismic licensing basis requirements.

3.1 SAFE SHUTDOWN EARTHQUAKE The criteria for determining the adequacy of Seismic Category I mechanical and electrical equipment for the Farley Nuclear Plant are described in various areas of the UFSAR. In some cases the criteria are specified in general terms to require verification by tests or analyses. In other cases, more specific criteria are specified such as verification in accordance with IEEE Standard 344-1971. At the time of the original design and licensing of the plant the requirements were changing to the use of IEEE 344-1975. These two separate programs were used to verify the seismic adequacy of Farley's mechanical and electrical equipment.

It should be noted that the FNP Unit 2 seismic qualification program, i.e., IEEE 344-71 type qualification, was previously audited by the NRC's Seismic Qualification Review Team (SQRT). It was concluded in NUREG-0 117 Supplement No. 5 (dated March, 1981) Safety Evaluation Report related to the operation of Unit 2 that "the licensee's seismic qualification program provides reasonable assurance that the seismic category I mechanical and electrical equipment is adequately qualified, meets the applicable requirements of General Design Criterion 2, and is therefore acceptable for full-power operation".

Geologic and seismologic surveys of the site have been conducted to establish two "design earthquakes" with different intensities of ground motion. These are the 50 percent SSE (/ SSE) and the SSE with different intensities of ground motion. The '/2 SSE, sometimes referred to as the operating basis earthquake (OBE), is postulated to be the earthquake that could be expected to occur at the site during the operating life of the plant. The SSE represents the strongest earthquake that is hypothetically postulated to occur during an infinite period. The intensity postulated to occur at the site for both the V2 SSE and SSE is defined from the history of seismic activity in the area around the site.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 7 OF 46 The / 2 SSE and SSE are specified in terms of a set of idealized, smooth curves, called the design spectra because they specify a range of values for two of the important properties of an earthquake ground motion, i.e., the maximum ground acceleration and the frequency distribution. The SSE produces the vibratory ground motion for which Category I structures, systems and components are designed to remain functional.

The 1/2 SSE and SSE spectra are each developed for 0%, 0.5%, 1.0%, 2.0%, 3.0%, and 5.0% of critical damping, with a horizontal ground peak acceleration of 0.05 g and 0.10 g, and vertical ground acceleration of 0,033 g and 0.067 g, respectively.

POWER GENERATION DESIGN BASIS Seismic Category 1 structures, systems and components are designed so that stresses remain within normal code allowable limits during the V2 SSE and to ensure they will perform their required safety-related functions during and after an SSE.

MAJOR COMPONENT DESIGN BASIS The horizontal and vertical OBE and SSE in-structure response spectra curves form the basis for the seismic qualification and design of Category I SSCs and for demonstrating the structural integrity of Seismic Category 11 SSCs, where required. In addition, systems running between structures shall be designed to withstand the seismic relative displacements.

The seismic analysis of safety related systems, equipment and components is based on the response spectra method, time-history method, or equivalent static method.

All Seismic Category I safety-related instrumentation and mechanical and electrical equipment meet the requirements and recommendations of IEEE 344-1975. Damping values are provided in FSAR Table 3.7-1.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 8 OF 46 3.2 DESIGN CODES, STANDARDS AND METHODS The design codes and standards for seismic qualification are listed throughout Section 3.0 of the Farley UFSAR. Examples of the pertinent codes, standards, and methods used in the original design of Farley Unit 2 are listed below.

ACI 318-71, Building Code Requirements for Reinforced Concrete

" American Institute of Steel Construction (AISC), Manual of Steel Construction, 7 th Edition

ASME III Boiler and Pressure Vessel Code, 1968 Edition

" ASME Boiler and Pressure Vessel Code for Pumps and Valves for Nuclear Power.

" ASME VIII Boiler and Pressure Vessel Code, 1968 Edition

ANSI B31.1 Power Piping

ANSI B31.7 Nuclear Power Piping

BC-TOP-4, Seismic Analysis of Structures and Equipment for Nuclear Power Plants, September, 1972

" IEEE 317-1976, Standard for Electric Penetration Assemblies in Containment Structures for Nuclear Power Generating Stations

IEEE 323-1974, Std for Qualifying Class IE Equipment for Nuclear Power Generating Stations

IEEE 344-1971 Recommended Practice for Seismic Qualification of Class IE Equipment for Nuclear Power Generating Stations. Methods include both analysis and testing.

IEEE 344-1975 Recommended Practice for Seismic Qualification of Class I E Equipment for Nuclear Power Generating Stations. Methods include both analysis and testing.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 9 OF 46 4.0 PERSONNEL QUALIFICATIONS Table 4-1 identifies the project team members and their project responsibilities per the EPRI Report 1025286 (Reference 10.2). Table 4-2 identifies the Peer Review Team members and responsibilities.

Section 4.1 provides an overview of the project responsibilities. Section 4.2 includes brief experience summaries for all project personnel in alphabetical order.

Table 4-1 Project Team Members and Responsibilities Site Equipment Seismic Licensing Name Point of Selection / Plant Walkdown Basis Contact IPEEE Operations Engineer Reviewer (POC) Reviewer (SWE)

William Arens X X Maggie Farah X X Ryan Harlos X X X X Crystal Lovelady X X I Laura Maclay X X Paul Miktus* X X Ronald Miranda* X X Alan Mullenix X X Scott Walden* X X Robert Wood X X Taylor Youngblood X X X Stephen Yuan X X

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUS1I4MA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE10OF46 Table 4-2 Peer Review Team Members and Responsibilities Peer SWEL Walkdown Licensing Submittal Name Review Peer Peer Basis Peer Report Peer Team Reviewer Reviewer Reviewer Reviewer Leader Robert Ashworth* X X X X Melanie Brown* X X X X Richard Starck* X X Kenneth Whitmore* X X X X Notes (Table 4-1 and Table 4-2):

1)

Indicates Seismic Capability Engineer

2) As stated in Section 7.0, all potentially adverse conditions were entered into the plant Corrective Action Program (CAP) system. However, as part of the process of entering the condition into the CAP, the SWEs made a preliminary assessment of the condition with respect to the plant licensing basis. Further licensing basis reviews were performed as discussed in Section 8.0 as part of the CAP resolution process by personnel not directly involved in the walkdowns.

4.1 OVERVIEW OF PROJECT RESPONSIBILITIES The Site Point of Contact (POC) is a site engineer from Southern Nuclear that has experience with the site equipment, site procedures, plant operations, and overall personnel organization. The site POC coordinated site access for walkdown personnel and any resources required for the walkdowns such as inspection equipment and support from plant operations. The POC was responsible for development of the walkdown schedule and any updates to the schedule based equipment availability.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 11 OF 46 Equipment Selection Personnel (ESP) were responsible for identifying the sample of SSCs for the Seismic Walkdowns. The ESP have knowledge of plant operations, plant documentation, and associated SSCs. The ESP also have knowledge of the IPEEE program. For this project, site engineers and plant operations personnel participated in the equipment selection. The ESP also performed the responsibilities of the IPEEE Reviewers. The IPEEE Reviewers also ensured that the walkdown scope included a sample of equipment that had IPEEE seismic vulnerabilities.

Plant Operations Personnel provided detailed review of the sample of SSCs Seismic Walkdown Equipment List (SWEL) and Base List) to ensure the walkdown scope included equipment located in a variety of environments, equipment in a variety of systems, and equipment accessible for a walkdown.

Plant Operations Personnel also assisted in obtaining access to components and component internals and helped to coordinate with plant maintenance. For the Farley Unit 2 project, the Plant Operations Personnel were either former or currently licensed Senior Reactor Operators.

The SWEs were trained on the NTTF Recommendation 2.3: Seismic, and on the material contained in the EPRI Report 1025286 (Reference 10.2). SWEs who had previously completed the Seismic Walkdown Training Class developed by the SQUG were not required to complete training on the NTTF Seismic recommendations but were trained on the differences between SQUG activities and activities associated with the NTTF Seismic recommendations.

The Licensing Basis Reviewers were responsible for determining whether any potentially adverse seismic conditions identified by the SWEs met the plant seismic licensing basis. The Licensing Basis Reviewers have knowledge of and experience with the seismic licensing basis and documentation for the SSCs at Farley.

A Peer Review Team was formed for this project to provide both oversight and review of all aspects of the walkdowns. The Peer Review Team members have extensive experience in seismic design and qualification of structures, systems and components as well as extensive field experience. The Peer Review Team for this project interfaced with the ESP and SWEs to ensure that the walkdown program satisfied the guidance in the EPRI Report 1025286 (Reference 10.2).

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE12OF46 4.2 TEAM EXPERIENCE SUMMARIES William Arens (SNC)

Mr. Arens is a Shift Supervisor assigned to the Operations staff at Farley Nuclear Plant. He earned a B.S. in Mechanical Engineering from the University of Oklahoma in 1980. Mr. Arens served for eight years as an officer in the U.S. Navy nuclear submarine force. He has been employed at Farley Nuclear Plant since 1988, obtaining a Senior Reactor Operator License in 1991. His experience at Farley includes serving as a MOV engineer, Shift Support Supervisor, Shift Supervisor, Operations Superintendent, and Shift Manager.

Robert Ashworth, SCE (MPR)

Mr. Ashworth is a structural engineer with MPR and has more than six years of experience with providing engineering solutions for a wide variety of nuclear power plant components and systems.

His experience includes equipment walkdowns at industrial facilities to assess material condition, structural modeling and analyses, and seismic qualification in accordance with current industry standards for mechanical and electrical equipment in nuclear power plants. Mr. Ashworth has completed the training course for the EPRI Seismic Walkdown Guidance and is also a Seismic Capability Engineer (SCE) as defined in the SQUG GIP for resolution of US] A-46.

Melanie Brown, SCE (SNC)

Ms. Brown has over 31 years of experience with Southern Company, the majority of which has been serving the nuclear fleet. Ms. Brown's most recent assignment was as a Seismic Qualification Engineer in the Fleet Design Department, where she was responsible for performing activities associated with the Governance, Oversight, Support, and Perform (GOSP) Model including:

" Management of the seismic design bases,

Seismic equipment qualification,

Seismic evaluation of plant structures and components,

Design documentation and configuration management.

She is currently serving as the Southern Nuclear Seismic Technical Lead for the Fukushima Near-Term Task Force (NTTF) 2.3 Seismic Walkdowns for all three Southern Nuclear plants.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 13OF 46 Maggie Farah, SWE (ENERCON)

Ms. Farah is a Structural Engineer with a B.S. in Civil Engineering from the New Jersey Institute of Technology and currently pursuing a Master's degree in Structural Engineering. Ms. Farah has been employed as a structural engineer at ENERCON for more than four years and has extensive experience in performing seismic equipment evaluations and structural analysis. She has performed numerous plant walkdowns as part of seismic design and modifications and had extensive on-site experience at Humboldt Bay and at the Metropolis Works fuel processing plant. She has been involved in various plant modifications, including design of dry fuel storage installations. Ms. Farah completed the NTTF 2.3 Seismic Walkdown Training Course and was qualified as a SWE.

Ryan Harlos, SWE (SNC)

Mr. Harlos is a mechanical engineer in the Farley Engineering Systems Department at Southern Nuclear Operating Company and has a B.S. in Mechanical Engineering from Auburn University. He has been employed in the nuclear industry for approximately three years and has extensive experience in the design, operation, and monitoring of systems with respect to their applicable design bases. His primary experience is with SSCs on the Primary Side of PWR nuclear operating plants. Mr. Harlos also worked as a co-op employee for Southern Company for more than a year, while in college, prior to joining the staff at Farley Nuclear Station as a full-time employee. Mr. Harlos completed the EPRI training on Near Term Task Force Recommendation 2.3 - Plant Seismic Walkdowns.

Crystal Lovelady, SWE (SNC)

Ms. Lovelady is a civil engineer in the Fleet Design Engineering Mechanical/Civil group at Southern Nuclear Operating Company. She has a B.S. in Civil Engineering from the University of Alabama, Huntsville. She has more than five years of experience in structural analysis and design of structures in the power industry. She has additional experience as a member of the structural monitoring team at Plant Hatch and Plant Farley. Ms. Lovelady completed training on Near Term Task Force Recommendation 2.3 -Seismic Walkdowns to qualify as a SWE.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 14OF 46 Laura Maclay, SWE (ENERCON)

Ms. Maclay has over three years of experience as a structural engineer with ENERCON. Her tasks have ranged from assisting with the development and preparation of design change packages to performing design calculations and markups, comment resolutions, and drawing revisions. She worked on-site at Turkey Point Nuclear Plant for a year preparing structural evaluations of SSCs for an Extended Power Uprate (EPU). She designed safety related supports for computer and electrical equipment for the Turbine Digital Controls Upgrade package and other similar packages. Her responsibilities also included the review of calculations, drawings and vendor documentation for the seismic evaluation of the Unit 3 Palfinger Crane inside containment and new platforms in the High Pressure Turbine enclosure. Recent work includes Fukushima flooding walkdowns at Limerick Generating Station. Ms. Maclay recently completed the NTTF 2.3 Seismic Walkdown Training Course and was qualified as a SWE.

Paul Miktus, SCE (ENERCON)

Mr. Miktus, P.E., has over 35 years of Civil/Structural experience in the design, construction and operation of nuclear power plants and process/industrial facilities retrofits. Mr. Miktus held positions of responsibility in a number of supervisory and management positions for ENERCON for clients including Florida Power and Light, Southern Company and Entergy. His design experience includes structural steel design (including anchorages); suspended systems (piping, ductwork, raceways) supports; seismic qualification of equipment, parts and structures; rigging and scaffolds; piping stress analysis; and concrete slabs, beams and foundations. At River Bend Station, while with Entergy, Mr.

Miktus was Engineering Supervisor for many large projects and completed the SQUG Walkdown Screening and Seismic Evaluation Training and the Seismic IPEEE Add-On Training Courses.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 15 OF 46 Ronald Miranda, SCE (ENERCON)

Mr. Miranda is a member of the ENERCON Senior Technical and Management staff with 40 years of experience in the Nuclear Power Generation industry. He has held various engineering and management positions in the industry, holds a MS degree in Civil Engineering and is a. SCE certified by the SQUG. Mr. Miranda is experienced in structural steel and reinforced concrete design, anchorage to concrete, identification and assessment of degraded structural conditions, evaluations using SQUG methodologies, and the management of large, complex, and high-visibility projects. Mr. Miranda is currently the ENERCON Dry Fuel Storage Product Line Manager responsible for the development and the design of Independent Spent Fuel Storage Installations at power generating facilities under static, dynamic, and flooding conditions compliant with 10 CFR 50 and 10 CFR 72 regulations and industry standards. Mr. Miranda is recognized as an expert within the dry fuel storage industry.

Alan Mullenix, SWE (ENERCON)

Mr. Mullenix is a Registered Professional Engineer with over five years of Civil/Structural experience.

He has a B.S. in Civil Engineering and a Master of Science degree in Structural Engineering. His primary responsibilities include structural design, seismic design, and Design Change Package development. Mr. Mullenix assisted with 10 CFR 73.55 Nuclear Plant Security upgrades, Independent Spent Fuel Storage Installations, and other design changes at Plant Farley, Plant Hatch, Brunswick, Crystal River, and Fort Calhoun Nuclear Stations. Mr. Mullenix completed his training on Near Term Task Force Recommendation 2.3 - Seismic Walkdowns as a SWE.

Richard Starck, SCE (MPR)

Mr. Starck is a registered Professional Engineer with more than 30 years of experience in seismic qualification of nuclear plant equipment. He is the principal author of the EPRI Seismic Walkdown Guidance Document (Reference 10.2) and developed and taught the six sessions of the NTTF 2.3 Seismic Walkdown Training Course to over 200 engineers. He provided technical oversight of work for various SQUG projects aimed at resolving USI A-46. Mr. Starck developed for SQUG the generic guidelines, criteria, and procedure for identifying safe shutdown equipment for resolution of USI A-46, is the editor and principal author of the SQUG GIP, and has interfaced with the NRC Staff and the SQUG Steering Group to resolve open issues on several revisions of the GIP. Mr. Starck is a SCE and has performed Seismic Walkdowns and evaluations of nuclear plant electric and mechanical equipment as part of the NRC required USI A-46 program. This work included equipment qualification, anchorage evaluation, seismic interaction review, outlier resolution, and operability determination.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE16OF46 Scott Walden, SCE (SNC)

Mr. Walden is a senior engineer in the Fleet Design Analysis / Civil department at SNC. He has a B.S.

in Civil Engineering from Mississippi State University. Mr. Walden has more than 33 years of experience in structural analysis and design of structures for electric utilities, including extensive experience in seismic analysis of nuclear power plant structures and seismic qualification of equipment. He has extensive experience in the area of analysis of supports and also worked in developing the response spectra curves for Plant Hatch. He also has extensive experience in the Structure Monitoring Program (SMP) for Maintenance Rule and is responsible for oversight of the SMP for Plant Farley. He successfully completed the SQUG training course, is a Seismic Capability Engineer and participated in the original IPEEE/SQUG walkdown for Plant Farley and the conduit/cable tray SQUG walkdowns for Plant Hatch. He is a registered Professional Engineer is the states of Alabama and Mississippi.

Kenneth Whitmore, SCE (ENERCON)

Mr. Whitmore is a Registered Professional Engineer with more than 30 years of experience in seismic design and seismic equipment qualification in nuclear power plants. Mr. Whitmore is a Seismic Capability Engineer that was involved in the development of the SQUG methodology for verification of nuclear plant components. Specifically, Mr. Whitmore served on the sub-committee that developed the SQUG methodology for evaluation of raceways and on the sub-committee that performed the peer review of the SQUG walkdown training class. Mr. Whitmore performed A-46 and IPEEE walkdowns at Oyster Creek and Three Mile Island and has subsequently performed SQUG evaluations at numerous nuclear power plants. Mr. Whitmore served as both Chairman and Technical Chairman of the Seismic Qualification Reporting and Testing Service (SQRTS), has witnessed numerous seismic tests and is a recognized industry expert in seismic qualification of components. Mr. Whitmore has significant experience in all aspects of structural analysis and design and has extensive experience in performing plant walkdowns associated with seismic issues. Mr. Whitmore completed his EPRI training on Near Term Task Force Recommendation 2.3 - Seismic Walkdowns as a Seismic Walkdown Engineer (SWE) in June 2012.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE17OF46 Robert Wood (SNC)

Mr. Wood is the Farley Severe Accident Management Program Manager. He holds BS degrees in Physical Science, Mathematics, and Chemistry from Troy State University. Mr. Wood has over 37 years of experience at operating nuclear plants, was licensed as a SRO and served seven years on shift as Shift Support Supervisor and Unit Shift Supervisor. He has supervisory experience in chemistry, work management, strategic analysis and major project management.

Taylor Youngblood, SWE (SNC)

Mr. Youngblood is a Site Projects Lead at Plant Farley working primarily in major projects. He has a BS in Civil Engineering from the University of Alabama at Birmingham. Mr. Youngblood has 12 years of civil engineering experience with more than four of those years spent at Plant Farley in the areas of civil/structural design. His design experience includes evaluations and calculations for seismically qualifying various supports and structures. His specialties are in the areas concrete and earthwork and has developed an expertise in lifting and rigging evaluations. Mr. Youngblood is a registered Professional Engineer in the State of Alabama. Mr. Youngblood completed the EPRI training on Near Term Task Force Recommendation 2.3 - Plant Seismic Walkdowns in June 2012.

Stephen Yuan, SWE (ENERCON)

Mr. Yuan, P.E., is a Senior Civil Engineer in ENERCON's New Jersey office. He has over 20 years of experience in structural modeling, design, upgrading, electrical facility structure analyses and maintenance of industrial installations and nuclear power plants, including significant experience at Perry, Pilgrim and Vermont Yankee Plant. Mr. Yuan was one of the key civil engineers in support of the transformer replacement project at Perry Nuclear Power Plant. He holds a M.S. in Civil Engineering from the City University of New York. Mr. Yuan recently completed the NTTF 2.3 Seismic Walkdown Training Course and was qualified as a Seismic Walkdown Engineer (SWE).

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE18OF46 5.0 IPEEE VULNERABILITIES REPORTING Information on the seismic vulnerabilities identified during the IPEEE program is reported in . Within this context, "vulnerabilities" is used to mean seismic anomalies, outliers, or other findings. For each vulnerability, Attachment 5 also provides a description of the action taken to eliminate or reduce the seismic vulnerability.

Plant Farley completed modifications for all non-relay items on or before December 31, 1995, and all relays on or before December 31, 1996. The Equipment Selection/IPEEE Reviewers (see Table 4-1) reviewed the IPEEE implementation documents and final report to determine the list of items identified as having vulnerabilities and the required modifications.

The SWEL for Farley Unit 2 included 17 components for which seismic vulnerabilities were previously identified during the IPEEE program. During the walkdowns, the walkdown teams verify that the recommended resolutions to the IPEEE vulnerabilities associated with these 17 items are implemented.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 19oF 46 6.0 SEISMIC WALKDOWN EQUIPMENT LIST DEVELOPMENT A team of individuals with extensive knowledge of Plant Farley systems and components developed the SWEL. Qualifications of the personnel responsible for developing the SWEL are provided in Section 4.0. The equipment selection personnel used a SNC-template to ensure compliance with the EPRI Report 1025286 (Reference 10.2) and consistency across the fleet.

Two SWELs were developed (SWEL I and SWEL 2) consistent with the guidance in the EPRI Report 1025286 (Reference 10.2). SWEL I consists of a sample of equipment related to safe shutdown of the reactor and maintaining containment integrity as described in Section 3.0 of the EPRI Report 1025286 (Reference 10.2). SWEL 2 consists of items related to the spent fuel pool as described in Section 3.0 of the EPRI Report 1025286 (Reference 10.2). The two SWELs form the overall SWEL for the plant. provides the final SWEL I and SWEL 2.

In some cases, components listed on the SWEL were removed from the SWEL or were replaced with equivalent components. These changes were made when it was determined during the Seismic Walkdown that access to the equipment on the original SWEL would be impractical to achieve for a walkdown. For example, components located very high in the overhead were replaced with equivalent items that could be seen without erecting scaffolding. All such changes meet the provisions of the EPRI Report 1025286 (Reference 10.2). The SWELs provided in Attachment I reflect the final SWELs with all changes incorporated.

6.1 DEVELOPMENT OF SWEL I SWEL 1 was developed using the four screens described in EPRI Report 1025286 (Reference 10.2).

Screens 1 through 3 These screens were used to select Seismic Category I equipment that does not undergo regular inspection but support the five safety functions described in the EPRI Report 1025286 (Reference 10.2). Page 3-1 of the EPRI Report 1025286 (Reference 10.2) lists three screens for use in selecting the Base List I if a utility was to not start from an existing equipment list used in previous plant evaluations. Applying these three screens would result in an acceptable base list that was comprised of Seismic Category I SSCs associated with maintaining the five safety functions listed in the EPRI Report 1025286 (Reference 10.2).

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 20 OF 46 In accordance with the EPRI Report 1025286 (Reference 10.2), page 3-3, Screens I through 3 were satisfied using previous equipment lists developed for the IPEEE program. Consequently, the Safe Shutdown Equipment List (SSEL) developed for the Farley IPEEE Report for Unit 2 (Reference 10.6),

Appendix A-Seismic Report, was used as the base list for the development of SWEL 1.

The intent of the Base List 1 was to provide an equipment list of the SSCs used to safely shut down the reactor and maintain containment integrity following a SSE. The specific guidance used to create the IPEEE Seismic SSEL was EPRI Report NP-6041, "A Methodology for Assessment of Nuclear Power Plant Seismic Margin", (Reference 10.13). The Seismic SSEL from IPEEE - Seismic was checked and verified to meet the intentions set forth in the EPRI Report 1025286 (Reference 10.2).

As stated in EPRI Report 1025286, the equipment on the SWEL must include equipment required to perform the following five safety functions:

Reactor reactivity control

Reactor coolant pressure control

Reactor coolant inventory control

Decay heat removal, and

Containment function.

The criteria used in selection of the Seismic SSEL are detailed in Section 3.0.2 of the IPEEE - Seismic Report. Specifically, one preferred and one alternate path capable of achieving and maintaining a safe-shutdown condition for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a Plant Farley Safe Shutdown Earthquake was selected for each unit. Further, it was assumed that a Small Break Loss of Coolant Accident (SBLOCA) had occurred and as such, the paths were also selected as being capable of mitigating a SBLOCA following an SSE. Plant Operations' input resulted in the inclusion of swing components not listed on the original IPEEE SSEL. Other suggestions by Plant Operations for inclusion in the SWEL, such as instrumentation stanchions and piping components, were determined to be covered by existing plant programs. Based on this, samples of those component types were not required to be added to the SWEL.

Therefore, based upon the review of the Base List, it was determined that the list did satisfy the requirements as specified in the EPRI Report 1025286 (Reference 10.2) which is a list comprised of Seismic Category I SSCs associated with maintaining the aforementioned five safety functions that are used to safely shut down the reactor and maintain containment cooling integrity.

Base List 1 is presented in Attachment 1.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 21 OF 46 Screen 4 Screen 4 is the sample considerations used to select components that make up the SWEL from the components contained in Base List 1. The selection of components for SWEL I was developed through an iterative process that ensured a representative sample of components was included in the SWEL. Various drafts of SWEL I were provided to Farley licensed Senior Reactor Operators (SROs) for review and input. The SROs identified and recommended inclusion of additional equipment important to plant operations.

The following list summarizes the sample considerations used to develop SWEL 1:

Variety of systems

Major new or replacement equipment

Classes of equipment

Variety of environments

Equipment enhanced due to vulnerabilities identified during the IPEEE program

" Risk Significance Variety of Systems - The EPRI Report 1025286 (Reference 10.2) specifies that equipment from a variety of plant systems must be included on the SWEL 1. The systems represented in the Base List were reviewed and components from a majority of these systems are included on the SWEL.

Major New and Replacement Equipment - Major new or replacement equipment installed within the previous 15 years was identified through a search of work order (WO) histories for selected equipment from input from plant personnel familiar with plant modifications and from the Probabilistic Risk Assessment (PRA) group on equipment changes to components that are included in the PRA.

Variety of Equipment Classes - A list of the 21 Classes of Equipment that should be included on the SWEL is provided in Appendix B of the EPRI Report 1025286 (Reference 10.2). The final SWEL contains a wide variety of components and includes a representative sample of components from each equipment class except classes 11, 13 and 19. The SWEL does not contain Class 11 or 13 components since it was developed from the SSEL associated with the IPEEE as described previously which does not contain Class II or 13 equipment. This is consistent with the EPRI Report 1025286 (Reference 10.2) for development of the SWEL.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 22 OF 46 Equipment Class 19 is not in scope for SWEL 1. The only Class 19 components on the Base List are Reactor Coolant System (RCS) RTDs installed on the RCS Piping. This is also consistent with the EPRI Report 1025286 (Reference 10.2) which states, "The major pieces of equipment in the NSSS that are located inside the containment are excluded from the scope of this program. Also excluded are the supports for this equipment along with all the components mounted in or on this NSSS equipment".

Variety of Environments - The EPRI Report 1025286 specifies that the SWEL contains components located in various plant environments, including environments subject to corrosion and high temperatures. SWEL I includes equipment in three environment types. These include Harsh (e.g.

Containment Building, Main Steam Valve Room), Mild (e.g. Control Room, Auxiliary Building), and Outdoors/Intake Structures (e.g. Valve Boxes, Service Water Intake Structure).

IPEEE Vulnerabilities - SWEL I includes equipment identified as having seismic vulnerabilities as reported in Farley IPEEE Report for Unit 2 (Reference 10.6).

Risk Significance - Information from the Farley Unit 2 PRA and the Maintenance Rule implementation documentation were used to determine whether items were risk significant. A representative sample of Risk Significant items are included on the SWEL. As stated, plant SROs reviewed the SWEL to ensure that equipment important to plant operation were included on the list.

6.2 DEVELOPMENT OF SWEL 2 SWEL 2 is developed using four screens described in the EPRI Report 1025286 (Reference 10.2).

SWEL 2 is presented in Attachment I.

Screens 1 through 2 The equipment selected through Screens I and 2 provide Seismic Category I components associated with the Spent Fuel Pool (SFP) that are also accessible for a walkdown. For Farley Unit 2, the only Seismic Category I equipment associated with the SFP is the Spent Fuel Cooling and Purification System. The Seismic Category I SSCs in the Spent Fuel Cooling and Purification System that are accessible and available for a walkdown comprise Base List 2.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE23OF46 Screen 3 Screen 3 is the sample considerations that ensure that a broad category of equipment included in SWEL 2. These considerations include:

" Variety of systems

" Major new or replacement equipment

Classes of equipment

Variety of environments Using the Base List 2 developed from the SFP System, the following criteria were used to select a sample of the SFP Seismic Category I equipment and systems:

" Variety of systems - Only one system comprises Base List 2

Major new or replacement equipment - No major new or replacement equipment installations with the past 15 years.

Classes of equipment - There are only 3 types of equipment in Base list 2: manual valves, I pump per train, and 1 heat exchanger per train. Additionally, one heat exchanger was included on SWEL 1 and therefore this selected heat exchanger was not chosen on SWEL 2 but applies to the SWEL 2 variety of equipment to prevent duplicates. The reason for the inclusion on SWEL I is due to Component Cooling Water (CCW) being the cooling medium for the SPF Heat Exchanger which requires the heat exchanger to maintain structural integrity during a seismic event for both SFP Cooling and CCW.

" Variety of environments - All SFP components are located in a mild environment and are not submerged.

The Farley SFP System has a very basic system design with very limited component types and the system contains only one active component in each train; the SFP Cooling Pump. Since 3 of the 4 objectives for selecting the sample consideration of items for SWEL 2 did not have any variance, the only remaining criteria to satisfy the sample objectives was to ensure that a component from each category was chosen and these selected equipment varieties were used to comprise SWEL 2.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE24OF46 Screen 4 Screen 4 identifies any items that could potentially lead to rapid drain down of the SFP. These include any penetrations in the SFP that are below 10 feet above the top of the fuel assemblies.

For Farley Unit 2, the SFP Cooling and Purification System contains three penetrations; two SFP pump suctions and one pump discharge. Neither the discharge line nor the suction line penetrations are located within 10 feet of the top of the fuel assemblies. However, the SFP discharge piping terminates approximately 6 feet above the top of the fuel assemblies in the SFP. Due to this, the discharge piping has a 1/2" hole on the bottom side of a 180' bend at elevation 152'-0". This hole acts as a siphon breaker and is located approximately 23 feet above the top of the fuel assemblies. Since there are no penetrations within 10 feet of the fuel and since the design of the anti-siphon hole in the SFP discharge piping prevents water from being siphoned through this piping, no rapid drain-down of the pool can occur.

Therefore, there are no components associated with rapid drain down of the Spent Fuel Pool included on SWEL 2.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 25 OF 46 7.0 SEISMIC WALKDOWNS AND AREA WALK-BYS Walkdowns were performed for all components on the (combined) SWEL, except for those that were inaccessible (see Section 7.1). A Seismic Walkdown Checklist (SWC) was completed for each component and an Area Walk-by Checklist (AWC) was completed for each area containing equipment on the SWEL. Copies of the SWCs and AWCs are provided in Attachments 3 and 4, respectively.

The personnel performing walkdowns received training on the NTTF 2.3 Seismic Walkdown guidance.

Prior to the walkdown teams arriving onsite, walkdown packages were assembled into folders that contained the SWCs and AWCs and other pertinent information (e.g., calculations, test reports, IPEEE walkdowns, equipment location, and layout drawings). Each walkdown team consisted of two SWEs.

The walkdown teams spent the first week on site obtaining unescorted plant access and organizing for the walkdowns. Organization included assignment of specific components to the walkdown teams, review of the walkdown packages, development of a process for tracking the Seismic Walkdowns and Area Walk-bys and familiarization with the plant.

The second week began with the peer reviewers (Mr. Whitmore and Mr. Ashworth) providing an overview on the information contained in the EPRI Report 1025286 (Reference 10.2). Expectations for the walkdowns were discussed and questions answered. After this overview, each walkdown team performed an initial Seismic Walkdown and Area Walk-by in the presence of the other teams and at least one peer reviewer. The purpose of this initial walkdown was to ensure consistency between the teams, to reinforce the expectations for identifying potential adverse seismic conditions and to allow team members to ask questions and provide and obtain feedback.

Following the initial walkdowns, the walkdown teams began performing the Seismic Walkdowns and Area Walk-bys. Support from plant personnel (operators, electricians and engineering) was obtained, as required, to access equipment and to assist in locating and identifying components. All Component Walkdowns and Area Walk-bys were documented on the SWCs and AWCs, respectively. The final status of all SWCs and AWCs indicates one of the following statuses:

" "Y" - Yes, the equipment is free from potentially adverse seismic conditions,

"N" - No, the equipment is not free from at least one potentially adverse seismic condition, or

"U" - Undetermined, a portion(s) of the walkdown could not be completed due to equipment inaccessibility and the condition is not known.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 26 OF 46 The walkdown focused on anchorage and seismic spatial interactions but also included inspections for other potentially adverse seismic conditions. Anchorage in all cases was considered to be anchorage to the structure. This included anchor bolts to concrete walls or floors, structural bolts to structural steel and welds to structural steel or embedded plates. For welds, the walkdown team looked for cracks and corrosion in the weld and base metal. Other bolts such as flange bolts on in-line components were not considered to be anchorage. These connections were evaluated and any potentially adverse seismic concerns were documented under "other adverse seismic conditions."

As part of the walkdown, the anchorage of at least 50% of the anchored components was evaluated to verify if the anchorage was consistent with plant documentation. The document that provides the anchorage configuration was identified on the SWC and the anchorage in the field was compared to the information on this referenced document. In cases where the anchorage could not be observed (e. g.

where the anchorage is inside a cabinet that could not be opened at the time of the walkdown), the items related to anchorage were marked as "U" (Undetermined) and deferred until the piece of equipment was available for inspection. However, all other possible inspections associated with that item were completed and the results were documented on the SWC. These items were considered to be incomplete at that time and deferred to a time when they would be available for inspection.

In cases where the Seismic Walkdown team members identified a potential adverse condition, the condition was noted on the SWC or on the AWC and a condition report (CR) was written to document and evaluate/resolve the condition. As part of the process of generating the CR, preliminary licensing basis evaluations were performed by the SWEs during the walkdowns. Additionally, detailed licensing basis reviews were conducted as part of the resolution of the CR, as required. Conditions that were not obviously acceptable were documented on the checklists and a basis was provided for why the observed condition was determined to be acceptable.

Area Walk-bys were performed in the rooms containing the SSCs for walkdowns. For cases in which the room where a component was located was large, the extent of the area encompassed by the Area Walk-by was clearly indicated on the AWCs. For large areas, the walk-by included all structures, systems and components within a 35-foot radius of the equipment being walked down, as described on the AWC. The AWCs are included in Attachment 4.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 27 OF 46 SWEL I Walkdowns A total of 103 of 110 SWEL 1 component walkdowns were performed prior to the additional guidance/clarification on opening cabinets to inspect for other adverse conditions was received on September 18, 2012. Of those 110 component walkdowns, 32 need to be revisited based on the guidance. Seven components were originally deemed inaccessible. The schedule for performing the remaining 39 components walkdowns is presented in Table 7-1. All areas of the plant that contain items on the SWEL were included in the Area Walk-bys.

SWEL 2 Walkdowns A total of four of four component walkdowns were performed. All areas of the plant that contain items on the SWEL were included in the Area Walk-bys.

7.1 INACCESSIBLE ITEMS Table 7-1 identifies the components originally determined to be inaccessible for walkdowns. These items are located throughout the plant and the required Seismic Walkdowns and Area Walk-bys were not completed for these items during the initial phase of walkdowns.

Inaccessibility of equipment or plant areas occurred due to one of two conditions: (l) plant operating conditions, or (2) component inspections required the opening of cabinet/panel doors which was not conducted, or not permitted by plant Operations personnel during the time of the walkdowns. Items listed in Table 7-1 associated with Item 2 above include those that require walkdowns in accordance with the supplemental guidance to open cabinets to inspect for other adverse conditions as discussed in Section 2.0.

Based on the above, 39 components were determined to be inaccessible. These items are located throughout the plant and the required Seismic Walkdowns and Area Walk-bys for these items are scheduled to be performed before or during the next Unit 2 outage, 2R22, scheduled for April 2013.

Note that the majority of the checklists associated with the components determined to be inaccessible based on condition 2 currently indicate that the walkdowns of these components are complete. The supplemental guidance on opening cabinets was received after these walkdowns/checklists were complete. Since the anchorage of these components was accessible without opening the cabinets, cabinet internals were not included in the inspections performed during the walkdowns. Therefore, those checklists will need to be revised/supplemented during later walkdowns. Completion of these checklists is tracked under CR numbers 520511, 520818, 521821 and 530517.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE28OF46 Table 7-1. Inaccessible Equipment per Original Walkdown Scope (see Note 1)

Reason for Remaining Schedule Item No. Description Inaccessibility Walkdown for (Note 2) Scope Completion (1) SWC and AWC Outage 2R22 Pressurizer Power Relief Q2B3 IMOV8000B Iso Valve for Containment el. 175' (1) SWC and AWC Outage 2R22 Pressurizer Power Relief 2 Q2B331 PCV0445A Valve for Containment el. 173' (1) SWC and AWC Outage 2R22 CTMT Sump Level 3 Q2EI 1LT3594B Transmitter for Containment el. 80' (1) SWC and AWC Outage 2R22 4 Q2EI 1MOV8702A RHR Inlet Isolation Valve for Containment el. 105' (1) SWC and AWC Outage 2R22 RCP Seal Water Return 5 Q2E21MOV8112 Isolation for Containment el. 105' Accumulator B Disch (1) SWC and AWC Outage 2R22 6 Q2E2IMOV8808B Valve for Containment el. 105' Aux Safeguards Cabinet D (2) Inspect panel Outage 2R22 7 Q2HI I NGASC2506D internals BOP Instrumentation (2) Inspect panel Outage 2R22 Cabinet K internals NIS Excore Detector (2) Inspect panel Outage 2R22 Cabinet internals Process Protection Cab CH (2) Inspect panel Outage 2R22 10 Q2H4 4 iNGPrC2505D internals

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 29 OF 46 Table 7-1. Inaccessible Equipment per Original Walkdown Scope (see Note 1)

Reason for Remaining Schedule

Item No. Description Inaccessibility Walkdown for (Note 2) Scope Completion 11 Q2HI INGPIC2505I- Process Control Cab (2) Inspect panel Outage 2R22 Channel 4 internals Solid State Protection Test (2) Inspect panel Outage 2R22 12 Q2H IINGSSP2506N Cab internals 4.16KV Swgr 2G Local (2) Inspect panel Outage 2R22 Cnt Panel internals 4.16KV Swgr 2J Local (2) Inspect panel Outage 2R22 Cont Panel internals 4.16KV Swgr 2L Local (2) Inspect panel Outage 2R22 Cont Panel internals Q2H22LOOID Multiplying Relay Cabinet (2) Inspect panel Outage 2R22 16 2D internals Q2H22L003 Transfer Relay Cabinet 2 (2) Inspect panel Outage 2R22 17 internals 18 Q2H22L503 Diesel Local2 Relay Panel (2) Inspect nenlpanel Outage 2R22 2B internals 19 Q2P16L002 SW Disch Valve 2 Relay Cab (2) Inspect nenlpanel Outage 2R22 2B internals (1) SWC and AWC Outage 2R22 20 Q2P17MOV3046 CCW Return from RCPS for Containment el. 129' 21 Q2R1 6B007 600V Load Center 2E (2) Inspect panel Outage 2R22 internals Q2R17B5]0 MCC 2T (2) Inspect panel Outage 2R22 22 internals

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 30 OF 46 Table 7-1. Inaccessible Equipment per Original Walkdown Scope (see Note 1)

Reason for Remaining Schedule

Item No. Description Inaccessibility Walkdown for (Note 2) Scope Completion Q2R18B030 Power Disconnect Switch (2) Inspect panel Outage 2R22 23 internals Q2RI8B032 Circuit Breaker Box (2) Inspect panel Outage 2R22 24 internals Q2RI 8B034 Power Disconnect Switch (2) Inspect panel Outage 2R22 25 internals 26 Q2R 18B043 MOV Power Disconnect (2) Inspect panel Outage 2R22 Switch internals 27 Q2R21B001D 120V Reg Panel 2Fineal (2) Inspect panel Outage 2R22 internals Q2R21E009D Inverter 2D (2) Inspect panel Outage 2R22 28 internals Vital AC Distribution Panel (2) Inspect panel Outage 2R22 2D internals 4.16KV Swgr 2K Surge (2) Inspect panel Outage 2R22 Arrestor internals 125VDC Distribution Panel (2) Inspect panel Outage 2R22 31 Q2R41L00IA 2A internals 32 Q2R42EOO1A Battery Charger 2A (2) Inspect panel Outage 2R22 internals Q2R43EOOIB Sequencer B2G (2) Inspect panel Outage 2R22 33 internals Q2R43E02A Sequencer B32F Aux Panel (2) Inspect panel Outage 2R22 34 internals Sequencer B2G Aux Relay (2) Inspect panel Outage 2R22 Panel internals

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 31 OF 46 Table 7-1. Inaccessible Equipment per Original Walkdown Scope (see Note 1)

Reason for Remaining Schedule

Item No. Description Inaccessibility Walkdown for (Note 2) Scope Completion Q2R16B006-A 600V Load Center 2D (2) Inspect panel Outage 2R22 36 internals Q2RI7BOOI-A MCC 2A (2) Inspect panel Outage 2R22 37 internals Q2R17B98-A MCC 2CC (2) Inspect panel Outage 2R22 38 internals Q2RI7B002-B3 MCC 2B (2) Inspect panel Outage 2R22 39 internals Table notes:

1) Farley Unit 2 has one transformer (Equipment Class 4) in the SWEL 1. It was inspected to the extent practical. All visible anchors, hardware and surfaces were inspected. The anchorage for the transformer was visible without opening the component. To inspect the transformer further would require disassembly and therefore would not be considered part of a normal electrical inspection. The inspection of this transformer meets the requirements of the guidance document and the 50.54(f)

Letter. The subject transformer is:

MPL #Q2R1 I B507 LC TRANSFORMER IS

2) Entries in Table 7-1 under column heading: "Reason for Inaccessibility" refer to the condition for inaccessibility discussed in Section 7.1

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE32OF46 8.0 RESULTS This section discusses the results of the Seismic Walkdowns that were performed in response to the NRC 50.54(f) letter dated March 12, 2012, "Enclosure 3, Recommendation 2.3: Seismic". As potentially adverse conditions were identified, condition reports were initiated in the Plant CAP program and evaluated. The sections below discuss the results of these walkdowns and evaluations.

8.1 POTENTIALLY ADVERSE SEISMIC CONDITIONS All potentially adverse conditions were conservatively entered into the site Corrective Action Program (CAP) per Southern Nuclear expectations in a timely fashion. While some preliminary licensing basis evaluations were performed by the SWEs as part of the generation of the CAP entries, the items did not first undergo a detailed seismic licensing basis review as described in EPRI Report 1025286.

Consequently, the as-found conditions in Table 8-1 below do not necessarily indicate that SSCs are deficient or not in conformance with their seismic licensing basis. Instead, it is an indication that Southern Nuclear has a very low threshold for CRs and actively uses the system.

SNC personnel familiar with the Plant Farley Seismic Licensing basis, Plant Farley seismic qualification methods and documentation, and Southern Nuclear requirements and procedures for entering items into the CAP reviewed and dispositioned all of the potentially adverse seismic conditions as part of the CAP process. The subsections below summarize the key findings from the CAP reviews that pertain to equipment operability, SSC conformance with the seismic licensing basis, and any required plant changes.

During the course of the seismic walkdowns, a total of 8 Unit 2 Potentially Adverse Conditions were identified and entered into the Corrective Action Program. In addition, another 3 were entered that are Common to both Units I and 2. Table 8-1 provides additional details on the SSCs that were identified during the walkdowns and entered into the CAP as degraded, nonconforming, or unanalyzed relative to their seismic licensing basis.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 33 OF 46 Table 8-1. Potentially Adverse Conditions Comp/ Brief Description of Potentially CR # Brief discussion of Action Taken/Planned to Status Area Adverse Condition Analysis/Conclusion Address/Resolve the (Open/Clsd)

Condition Component A heavy metal breaker racking 504952 Seismic walkdown personnel The breaker racking tool was Closed Q2R43E001B tool was identified to be hanging determined damage to the cabinet removed from its location to from a four inch long rod would not occur if the tool struck the remove the existing adverse approximately three feet from cabinet. However, Q2R43E0001B is seismic condition.

the Sequencer for Bus 2G marked as sensitive equipment and (Q2R43EOOOIB) in Room 2229. as such, the effect of the impact on During a seismic event the tool the components in the cabinet (e.g.

has the potential to fall from the relays) must be evaluated or the tool currently staged location and relocated or adequately secured if strike the sequencer. any adverse impacts are suspected.

Area Room A "fiberglass hot stick" was 504965 The hot stick would not cause Relocated the hot stick to Closed 2233, identified to be hanging from a physical damage to the cabinet itself, resolve the adverse seismic El. 121' pipe support. The stick has the The concern is an adverse effect to concem. CR 539958 written potential to strike Q2RI8AO03B internal subcomponents (e.g. relays). based off trends to evaluate and Q2RI5BKRDG04, 05, and extent of condition and put 06 during a seismic event, long term corrective actions in place.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 34 OF 46 Table 8-1. Potentially Adverse Conditions Comp/ Brief Description of Potentially CR # Brief discussion of Action Taken/Planned to Status Area Adverse Condition Analysis/Conclusion Address/Resolve the (Open/CIsd)

Condition Component Test cable N2RI5GOOID is 504967 It was determined that the equipment The breaker testing Closed Q2H2 I E005 wrapped around a junction box will not damage the cabinet in the attachment was unwrapped in Room 2233 as documented by event the cabinet is impacted. and place on the ground -

Deficiency Report 565268 on However, Q2H21E005 is identified seismic interaction no longer 4/7/2005. The cable and attached as sensitive equipment and should be exists.

piece of equipment have the evaluated for any adverse impacts potential to impact panel that could occur as a result of impact Q2H21E005 during a seismic (e.g. effects on internal relays) or the event, test cable and equipment needs to be secured such that an impact cannot occur during a seismic event.

Area The DEH Log Printer and stand 506338 The wheels have been removed and The adverse seismic Closed Main Control represent a seismic concern, the stand has been ty-wrapped to the condition has been eliminated Room DEH cabinet to prevent tipping. The as documented in the CR.

U2 printer has been moved to a lower shelf for increased stability.

Misc parts and the wheels were moved to the light bulb/chart paper cabinet until the decision is made to throw them away. A deficiency report tag was hung on the DEH printer stand. An evaluation should be made for a permanent solution.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 35 OF 46 Table 8-1. Potentially Adverse Conditions Comp/ Brief Description of Potentially CR # Brief discussion of Action Taken/Planned to Status Area Adverse Condition Analysis/Conclusion Address/Resolve the (Open/Clsd)

Condition Component The actual support anchorage 506365 The Seismic Walkdown team The drawing discrepancy Open Pump 2B from Pump 2B does not match performing the walkdown of RHR needs to be corrected so that Due drawings: D206723 Ver. 10, Pump 2B concluded that the the design documentation 11/27/2013 D206725 Ver. 9, D206593 Ver. robustness of the support structure is matches the drawings. TE

12. The actual conditions for sufficient to withstand a seismic 507862 exists to correct the Pump 2B match the details event and that the configuration does drawing issues. This is no shown on the above referenced not affect the operability of the longer an adverse seismic drawings for Pump 2A. pump. This condition was also concern following evaluated against the SEWS which verification of adequacy showed that the same anchorage through comparison against existed and was evaluated during the SEWS.

previous IPEEE-A-46 walkdown.

Area Unrestrained or unanchored 506373 Control room operators relocated/ The one condition was Open Main Control equipment near safety related modified the carts and book case already corrected in CR Due Room equipment in the Main Control (CR 506338 was written on August 506338. The remaining 11/27/12 Room. The unrestrained pieces 23, 2012 to address the cart adverse conditions were of equipment included two filing modification to prevent adverse shown in a quick evaluation cabinets (approximately five feet impact). An evaluation performed that demonstrated the filing tall), two carts, and one book demonstrated that the two filing cabinets would remain stable.

case. cabinets would remain stable and not CR 539942 has been written overturn during a seismic event, to have an evaluation be Therefore there is no impact to the performed.

nearby safety related equipment.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 36 oF 46 Table 8-1. Potentially Adverse Conditions Comp/ Brief Description of Potentially CR1# Brief discussion of Action Taken/Planned to Status Area Adverse Condition Analysis/Conclusion Address/Resolve the (Open/Clsd)

Condition Component The Seismic Walkdown Team 509362 It has been determined that no There is no impact on Safe Closed N2RI5A002 observed breaker racking tools Seismic Safe Shutdown Equipment shutdown equipment.

hanging from a four inch long is located within the impact zone of rod approximately three feet the breaker racking tools but this is a from N2R 15A002-N (4160 VAC common condition which has been Switchgear 2B) which is not identified throughout the plant where included in the Seismic Safe breaker racking tools are staged. As Shutdown Equipment in Room such, the Seismic Team recommends 2343. There is no equipment in the plant investigate removing or the proximity of the swinging providing more adequate means of radius however during a seismic storage for all wall mounted staged event the tools have the potential tooling with the potential to fall to interact with the switchgear during a seismic event and impact cabinet. The need for the tools to nearby electrical cabinets and be relocated or adequately equipment needed during a safe secured to eliminate the potential shutdown event.

of any potential adverse seismic interactions should be evaluated.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 37 oF 46 Table 8-1. Potentially Adverse Conditions Corn p/ Brief Description of Potentially CR # Brief discussion of Action Taken/Planned to Status Area Adverse Condition Analysis/Conclusion Address/Resolve the (Open/CIsd)

Condition Component While performing SAM NTTF 515556 Evaluation is open but is to be The corrosive material should Open Q2P16PS502 2.3 for Farley Units 1 & 2 in completed prior to 11/27/12. be removed as soon as Due 2VB- 1B, walkdown team The evaluation is being performed practical within the T-week identified corrosion on anchor under TE 540860. process and the nuts and bolts bolts for pressure switch support. should be cleaned and painted (Q2PI6PS502). This condition to prevent further was also written up in the latest degradation. A work order Unit 2 Structural Monitoring should be written to clean and Program report which can be paint this anchorage and grout found in CR 366963. should be placed beneath the base plate. WO SNC432761 created - clean and coat the bolts.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 38 OF 46 During the course of the walkdowns the team identified issues that, while not rising to the level of a seismic concern, warranted evaluation to determine if programmatic enhancements are warranted.

These issues have been entered into the SNC corrective action program.

CR 539958: While performing a review of the Condition Reports resulting from the SAM NTTF 2.3 Seismic Walkdowns, an adverse trend was identified with regards to storing tools and equipment throughout the plant. Several events were documented where tools and equipment (e.g. breaker racking tools, hot sticks) were stored in such a way that they had the potential to fall and strike nearby equipment (e.g. Switchgears) during a seismic event. The extent of condition should be investigated by the groups that use the tooling, all further conditions corrected, and actions put in place to prevent future recurrences.

CR 539961: While performing a review of the Condition Reports resulting from the SAM NTTF 2.3 Seismic Walkdowns, an adverse trend was identified with regards to maintaining the coating on components subject to corrosive environments. Several events were documented where anchorage and associated supports were corroded due to a lack of coatings and preventive maintenance to protect the material. The extent of the damage varied from minor surface corrosion to more significant wastage of the components. The extent of condition should be investigated and appropriate corrective actions put in place to promote the long-term sustainability of anchorage, support, and components subject to corrosive environments.

CR 539962: While performing a review of the Condition Reports resulting from the SAM NTTF 2.3 Seismic Walkdowns, an adverse trend was identified with regards to maintaining the housekeeping of cable trays and their cables. Several events were documented where cable trays had damaged panels or cables overhanging the cable tray. The extent of condition should be investigated and appropriate corrective actions, as needed, put in place.

8.2 EQUIPMENT OPERABILITY Plant Farley Unit 2 had no as-found conditions that would prevent SSCs from performing their required safety functions.

8.3 PLANT CHANGES There were no plant changes that resulted from the as-found conditions. Plant changes are any planned or newly installed protection and mitigation features (i.e., plant modifications) that result from the Seismic Walkdowns or Area Walk-bys.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE39OF46 8.4 OTHER NON-SEISMIC CONDITIONS Housekeeping items were identified during walkdowns and walk-bys that were not potentially seismic adverse conditions. All such items were brought to the attention of plant personnel and CRs were generated as necessary. These issues included water on the floor and loose items (small tools, trash, etc.) stored in the plant areas. These items were processed through the site CAP process and are not specifically documented in this report though are available in the Plant CAP database.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE40OF46 9.0 PEER REVIEW 9.1 PEER REVIEW PROCESS The peer review for the NTTF Recommendation 2.3 Seismic Walkdowns was performed in accordance with Section 6 of the EPRI Report 1025286 (Reference 10.2). The peer review included an evaluation of the following activities:

" review of the selection of the structures, systems, and components (SSCs) that are included in the Seismic Walkdown Equipment List (SWEL);

review of a sample of the checklists prepared for the Seismic Walkdowns and Area Walk-bys;

review of licensing basis evaluations and decisions for entering the potentially adverse seismic conditions in to the plant's Corrective Action Plan (CAP); and

review of the final submittal report.

This report provides results of the review process for each review activity as well as the results of the peer review.

9.2 PEER REVIEW RESULTS

SUMMARY

9.2.1 Seismic Walkdown Equipment List Development The selection of items for the SWEL underwent peer review according to Section 3 of the EPRI Report 1025286 (Reference 10.2). The SSCs to be evaluated during the seismic walkdown were selected as described in Section 6.0 of this report. The list of components was provided to the members of the Peer Review Team, which consisted of all four peer reviewers listed in Section 4.0. The Peer Review Team members independently provided comments to the personnel who selected the components on the SWEL. All comments were addressed and the Peer Review Team reviewed the changes made to the SWEL and the final SWEL, to ensure all recommendations from Reference 10.2 were met. Specifically, the Peer Reviewers confirmed that all SSCs in SWEL I and 2 were Seismic Category I components that do not undergo regular inspections. Specific considerations for the peer review process are described below for SWEL I and SWEL 2. The peer review check sheet of the SWEL is provided in Attachment 2.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 41 OF 46 For SWEL 1, the Peer Review Team verified that the list of SSCs represented a diverse sample of the equipment required to perform the following five safety functions, as specified in the EPRI Report 1025286 (Reference 10.2):

Reactor Reactivity Control;

" Reactor Coolant Pressure Control;

Reactor Coolant Inventory Control;

" Decay Heat Removal; and

Containment Function.

For SWEL 1, the Peer Review Team also verified that the SSCs included an appropriate representation of items having the following sample selection attributes:

Various types of systems;

Major new and replacement equipment;

Various types of equipment;

Various environments;

Equipment enhanced based on the findings of the IPEEE; and

Risk insight consideration.

The final SWEL 1 contains items that perform each of the five safety functions specified in the EPRI Report 1025286 (Reference 10.2). Numerous components perform more than one of the safety functions and all five safety functions are well represented by the components on the list.

SWEL 1 contains components from all applicable classes of equipment listed in Appendix B of the EPRI Report 1025286 (Reference 10.2), except for equipment classes 11, 13 and 19, and in cases where there are no safety-related components at the plant that fall into that specific equipment class. The list contains major new and replacement items, and items enhanced based on the IPEEE as well as equipment located in various environments and areas of the plant. All major safety-related systems are represented and risk factors were considered in development of the list.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE42OF46 For SWEL 2, the Peer Review Team determined that the process to select spent fuel pool related items complied with the EPRI Report 1025286 (Reference 10.2). Portions of the spent fuel pool cooling system at Farley Unit 2 are Seismic Category I and all different types of components are represented on the SWEL 2. No items that could cause rapid drain down of the Spent Fuel Pool for Farley Unit 2 were identified. Therefore, SWEL 2 does not contain any components associated with potential rapid drain down of the pool. The Peer Review Team concluded that the bases for including/excluding items associated with the spent fuel pool were well documented and that the final SWEL 2 complies with the EPRI Report 1025286 (Reference 10.2).

In summary, all of the peer review comments made during development of SWEL I and SWEL 2 were resolved by the team that prepared the SWELs. The resolutions were reviewed by the Peer Review Team and it was determined that all comments were adequately addressed. The SWEL was determined to incorporate all comments made by the Peer Review Team during the process.

During the walkdowns, a small number of isolated components that were not accessible were removed from the list and, in some cases, equivalent items that were determined to be accessible were added. The Peer Review Team reviewed all changes made to the SWELs and determined that these changes had no impact on the adequacy of the SWELs with respect to the provisions contained in the EPRI Report 1025286 (Reference 10.2). The Peer Review Team concludes that the team that developed the SWELs appropriately followed the SWEL development process described in Section 3 of the EPRI Report 1025286 (Reference 10.2).

The Peer Review Checklist for development of the SWEL is provided in Attachment 2.

9.2.2 Seismic Walkdowns and Area Walk-Bys The Peer Review Team was on-site and very involved with the Seismic Component Walkdowns and Area Walk-bys. The Peer Review was performed as follows:

Each of the walkdown teams performed an initial equipment Seismic Walkdown and an Area Walk-by while being observed by the other teams and at least one member of the walkdown Peer Review Team. The Peer Review Team provided comments and suggestions and answered questions raised by the team performing the walkdown and the other walkdown teams.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE43OF46 During the first week of walkdowns, a member of the walkdown Peer Review Team individually accompanied each of the SWE walkdown teams and observed the SWE team conducting the Seismic Walkdowns and Area Walk-bys. The Peer Review Team confirmed first-hand that the SWE walkdown teams performed the Seismic Walkdowns and Area Walk-bys as described in Section 4 of the EPRI Report 1025286 (Reference 10.2). A member of the Peer Review Team accompanied each of the four walkdown teams on at least one full day of walkdowns. SWE walkdown teams were encouraged and expected to carry a copy of Section 4 of the EPRI Report 1025286 (Reference 10.2) and refer to it, as necessary, during conduct of the Seismic Walkdowns and Area Walk-bys.

" Finally, the walkdown Peer Review Team reviewed the Seismic Walkdown and Area Walk-by packages completed during the first week to ensure that the checklists were completed in accordance with the EPRI Report 1025286 (Reference 10.2). The walkdown Peer Review Team confirmed that the Seismic Walkdown and Area Walk-by packages were consistent, thorough, and the packages accurately reflected the results of the Seismic Walkdowns and Area Walk-bys as witnessed during the first week of walkdowns.

The Peer Review Team concluded that the SWE teams were familiar with the process for Seismic Equipment Walkdowns and Area Walk-bys. The SWE teams adequately demonstrated their ability to identify potentially adverse seismic conditions such as adverse anchorage, adverse spatial interaction, and other adverse conditions related to anchorage, and perform anchorage configuration verifications, where applicable. The SWEs also demonstrated the ability to identify seismically-induced flooding interactions and seismically-induced fire interactions. The SWEs documented the results of the Seismic Walkdowns and Area Walk-bys on the appropriate checklists from Appendix C of the EPRI Report 1025286 (Reference 10.2).

The Peer Review Team inspected all the checklists completed during the first week of walkdowns, representing approximately 40% of the total number of checklists. Peer review of the Seismic Walkdowns and Area Walk-bys identified minor editorial errors and also some instances where comments in the checklists required additional explanation and information.

Mr. Ashworth and Mr. Whitmore provided verbal feedback to the SWEs to adjust these entries accordingly. The SWEs understood the comments and incorporated the recommendations and updates from the Peer Review Team.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE 44 OF 46 Since the peer review occurred at the start of the walkdowns, the peer reviewers were able to provide comments at the early stages of the walkdown process to ensure consistency in the reporting for all packages. Subsequently, the Peer Review Team considered the number of completed walkdown packages reviewed to be appropriate. In addition, all members of the Peer Review Team, including Mr. Ashworth, Ms. Brown, Mr. Starck and Mr. Whitmore were available by phone as necessary during the entire Walkdown process.

9.2.3 Licensing Basis Evaluations All potentially adverse seismic conditions identified were immediately entered into the plant CAP for further review and disposition as discussed in Section 8.1 of this report. Therefore, the Seismic Walkdown teams did not perform licensing basis evaluations apart from evaluations performed for the CAP. The Peer Review Team considers this CAP process approach fully comprehensive and acceptable for addressing the potentially adverse seismic conditions observed during the Seismic Walkdowns.

9.2.4 Submittal Report The Peer Review Team was provided with drafts of the submittal report. This allowed the Peer Review Team to verify that the submittal report would meet the objectives and requirements of the EPRI Report 1025286 (Reference 10.2).

The Peer Review Team provided both verbal and written comments on the draft reports and was active in ensuring the report was thorough, complete and accurate. The final version of the submittal report includes all necessary elements of the Peer Review and meets the requirements of the 50.54(f) letter.

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE45OF46

10.0 REFERENCES

10.1 10 CFR 50.54(f) 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 10.2 EPRI Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, June 2012 10.3 Generic Letter No. 88-20, Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities 10.4 Generic Letter No. 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 10.5 Not used.

10.6 Joseph M. Farley Nuclear Plant, Unit 1 and Unit 2, Individual Plant Examination of External Events - Seismic.

10.7 RER SNC432467, SAM NTTF 2.3: Seismic, Unit I and 2 Walkdowns at Plant Farley, (Recommendation) 2.3 - Seismic 10.8 Generic Letter No. 87-02, Supplement 1 to Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 10.9 NUREG- 1211, Regulatory Analysis for Resolution of Unresolved Safety Issue A-46, Seismic Qualification of Equipment in Operating Plants 10.10 NUREG-0 117 Supplement No. 5 dated March, 1981 Safety Evaluation Report 10.11 Not used 10.12 Not used 10.13 EPRI Report NP-6041, A Methodology for Assessment of Nuclear Power Plant Seismic Margin 10.14 Farley Nuclear Plant Updated Final Safety Analysis Report (UFSAR), Rev. 24, August 2012.

10.15 NMP-GM-033-GLOI Ver. 1.0, SAM NTTF Seismic Walkdowns Guide

FARLEY UNIT 2 SEISMIC WALKDOWN REPORT NO. SNCF164-RPT-02 FOR RESOLUTION OF FUKUSHIMA NEAR-TERM VERSION 1.0 TASK FORCE RECOMMENDATION 2.3: SEISMIC PAGE46OF46 11.0 ATTACHMENTS ATTACHMENT 1 - SEISMIC WALKDOWN EQUIPMENT LISTS ATTACHMENT 2 - PEER REVIEW CHECKLISTS FOR SWEL I AND 2 ATTACHMENT 3 - SEISMIC WALKDOWN CHECKLISTS ATTACHMENT 4- AREA WALK-BY CHECKLISTS ATTACHMENT 5 - IPEEE VULNERABILITIES INFORMATION ATTACHMENT 6 - SEISMIC WALKDOWN ENGINEER CERTIFICATIONS

NL-12-2267, SNCF164-RPT-02, Ver. 1.0, Farley Unit 2 Seismic Walkdown Report, Rer SNC432467 for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, Cover Through Page 46 of 46

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