NRC 2013-0108, Response to 10 CFR 50.54(f) Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns

Response to 10 CFR 50.54(f) Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns

ML13331A912
Person / Time
Site:	Point Beach
Issue date:	11/27/2013
From:	Meyer L Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC 2013-0108
Download: ML13331A912 (9)

Text

NEXTera ENERGY .

POINT BEACH November 27, 2013 NRC 2013-0108 10 CFR 50 .54(f)

U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant, Units 1 and 2 Docket 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 NextEra Energy Point Beach, LLC Response to 10 CFR 50.54(f) Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns

References:

(1) NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, 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 (ML12053A340)

(2) NextEra Energy Point Beach, LLC letter to NRC, dated November 26, 2012, NextEra Energy Point Beach LLC Response to 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Seismic (ML12332A070)

(3) NextEra Energy Point Beach, LLC letter to NRC, dated October 3, 2013, Update to NextEra Energy Point Beach, LLC Response to 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Seismic (ML13277A109)

(4) NRC letter to NextEra Energy Point Beach, LLC, dated November 1, 2013, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns (ML13304B418)

On November 26, 2012, NextEra Energy Point Beach, LLC (NextEra) responded to the NRC staff's request for information pursuant to 10 CFR 50.54(f) (Reference 1). Via Reference (2),

NextEra submitted the required reports for Units 1 and 2 regarding seismic walkdowns.

Subsequent to submitting the report, NextEra determined that there were errors in the reports.

The errors were administrative in nature and had no impact on the contents of the report.

Additionally, NextEra determined that some information in the reports could have been better presented. NextEra addressed the issues by submitting updated information to the NRC via Reference (3).

Subsequently, the NRC determined that additional information was required to allow the NRC staff to complete their assessments (Reference 4) .

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 The Enclosure provides the responses to the request for additional information contained in Reference (4).

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

If you have any questions please contact Mr. Michael Millen, Licensing Manager, at 920/755-7845.

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

Executed on November 27, 2013.

Very truly yours, NextEra Energy Point Beach, LLC Larry Meyer Site Vice President Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Director, Office of Nuclear Reactor Regulation, USNRC Next Era Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

ENCLOSURE NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 NEXTERA ENERGY POINT BEACH, LLC RESPONSE TO 10 CFR 50.54(F)

REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 2.3, SEISMIC WALKDOWNS

REQUEST FOR ADDITIONAL INFORMATION Seismic Walkdowns On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a letter requesting additional information per Title 10 of the Code of Federal Regulations, Section

50. 54(f) (hereafter called the 50. 54(f) letter). The 50. 54(f) letter requested that licensees conduct seismic hazard walkdowns to verify the plant configuration with the current licensing basis (CLB). The licensees stated by letter that the seismic walkdowns would be performed in accordance with Electric Power Research Institute EPRI- 1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic" (walkdown guidance). Following the NRC staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow the staff to complete its assessments.

1. Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs), dispositioning of issues, and reporting As a result of the audits and walkdown report reviews, the NRC staff noted that licensees' interpretations of the seismic walkdown guidance varied, which resulted in meaningful differences in the process used to disposition identified issues and in the documentation that was provided to the NRC staff. In particular, the application of engineering judgment in determining what constituted a potentially adverse seismic condition (PASC), the threshold for conducting licensing basis evaluations (LBEs), and determining what information was to be reported to the NRC staff varied.

The NRC staff intended that conditions initially marked No (N) or Unknown (U) in the field by the seismic walkdown engineers (SWEs) for which an analysis or calculation was performed would be considered as PASCs and that an analysis or calculation constituted an LBE. The walkdown guidance allows for analysis as part of engineering judgment; however, the intent was to allow for only simple analyses that could be readily performed in support of engineering judgment.

Further, the walkdown activities were intended to allow for transparency in the licensee's process to demonstrate that PASCs were appropriately identified, that they were addressed in an appropriate manner, and the basis documented such that the current condition of the plant was clearly consistent with the CLB with regard to seismic capability.

During the audits, the NRC staff identified examples of field obseNations that were deemed not to be PASCs. However, the basis for the determination was not clearly recorded. In some cases, the field checklists were amplified by noting that the basis was engineering judgment.

During site audit discussions, the staff was able to trace the basis for the engineering judgments and found that in many cases they were appropriate. It is expected that these situations would not be included in the walkdown report.

There were other situations that a PASC and LBE were not reported; however, the NRC staff found during the audit that a calculation, analysis (more than just simple), or evaluation was conducted but informally. An example is a confirmatory calculation performed to demonstrate that six anchor bolts out of eight was not a seismically adverse condition. Another example would be an analysis to demonstrate that an existing, slightly short weld was as seismically sound as the prescribed weld length in the plant design documentation. The staff expected these types of conditions and evaluations to be captured in the licensee's normal plant Page 1 of 6

processes (e.g., condition report or corrective action program (CAP)), and also reported in the walkdown report, since*they were potentially adverse seismic conditions that required rriore than applying judgment or simple analysis to address.

The NRC staff also found that the process that was used to deal with a field observation that was deemed to be a PASC was also not completely described or captured in the report. In many cases, the licensee reported that an LBE was not performed. However, during the audits, it was clear that an LBE (or an equivalent determination method) was performed and used in determining whether a PASC should be entered into the CAP. The staff expects that these conditions would be reported in the walkdown report.

On the whole, through the audits, the NRC staff found that it was able to conclude that the intent of the guidance was met when the licensee's overall process was completely explained, the information was updated to reflect the actual process, and results were updated. The self-assessments conducted by the licensees of the audited plants also identified the lapse in the description of the process used by the licensee to identify a PASC and disposition it.

Therefore, in order to clarify the process that was followed, please provide a description of the overall process used by the licensee (and its contractors) to evaluate observations identified in the field by the SWEs. The process should include how a field observation was determined to be a PASC or not and how the bases for determinations were recorded. Once a determination was made that an observation was a PASC, describe the process for creating a condition report (or other tracking mechanism), performing the LBE (or other determination method), and the resultant action, such as entering it into the CAP, or documenting the result and basis.

Also, in order to confirm that the reported information supports concluding that the plant meets the CLB, please follow one of the following three acceptable alternatives:

(a) Provide a supplement to the table or text from the original walkdown report, if needed, to include similar conditions as the above examples and situations and for conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination. The supplement should include a short description of each condition, how it was dispositioned and the basis for the disposition, as follows: 1) for each condition that was entered into the CAP, provide the CAP reference number, initiation date, and (if known) the planned completion date, or 2) for all other conditions, provide the result of the LBE (or other determination method), the basis for the result, and how (or where) the result was captured in the plant's documentation or existing plant process.

(b) Following the plant's standard procedures, confirm that a new CAP entry has been made to verify if appropriate actions were taken when reporting and dispositioning identified PASCs (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination). The eventual CAP closeout, including the process followed and actions taken, should be in sufficient detail to enable NRC resident inspectors to follow up.

(c) If no new conditions are identified for addition to the supplement or the CAP entry mentioned above is deemed not necessary, provide a statement of confirmation that all potentially seismic adverse conditions (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination) identified during the walkdowns and walk-bys were addressed and included in the report to the NRC.

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NextEra Response NextEra Energy has extracted the NRC's information requests and paraphrased them below with the NextEra Energy response .

1. Conduct of walkdowns, determination of potentially adverse seismic conditions (PASCs), dispositioning of issues and reporting Provide a description of the overall process used by the licensee (and its contractors) to evaluate observations identified in the field by the SWEs. The process should include how a field observation was determined to be a PASC or not and how the bases for determinations were recorded.

During performance of the Fukushima Seismic Walkdowns (FSWD), the Seismic Walkdowns Engineers (SWE) had heightened awareness for PASC. In accordance with the EPRI Guidance Document, walkdown teams were made up of a minimum of two SWEs. Discussions were summarized on the checklists, briefly explaining why the condition does not present a PASC.

PBNP is a Unresolved Safety Issue (USI) A-46 plant. The PBNP Final Safety Analysis Report allows the use of the Seismic Qualification Utility Group (SQUG) Generic Implementation Procedure (GIP) to show that existing, modified and new structures, systems and components (SSCs) are capable of surviving a plant Safe Shutdown Earthquake (SSE) and remain functional during and after the seismic event.

Appendix D of the GIP allows the use of engineering judgment to decide if adjacent, non-seismic SSCs will interact with seismic SSCs. The GIP states that it is not necessary to assume that non-seismic SSCs fail on the basis that evaluation of the non-seismic SSCs does not exist.

All engineers participating in the Fukushima Seismic Walkdowns, including contractors, have attended the five day SQUG training class. Additionally, some of those engineers are also qualified to perform SQUG activities at PBNP- meaning they have a SQUG certificate, at least five years of seismic nuclear experience and have been qualified to the PBNP site specific requirements.

Field observations were first discussed between at least two SWEs to determine if there was agreement that there was a degraded condition. Once agreement was reached that a degraded condition existed, the condition was noted on the checklist. Additional discussions which may have included Subject Matter Experts (SME), simple calculations, review of drawings, or other types of design basis investigation, were then performed to determine if a degraded condition was a PASC.

Degraded conditions that were not PASC were identified on the checklists and submitted to the CAP. The CAP number is cross-referenced on the checklists.

Once a determination was made that an observation was a PASC, describe the process for creating a condition report, perlorming the license basis evaluation (or other determination method), and the resultant action, such as entering it into the corrective action program or documenting the result and basis.

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After a degraded condition was identified to be a PASC, a determination was made whether or not physical work was required to correct the condition. If there was physical work required, a Work Request (WR) was submitted. Initiation of a WR automatically initiates a Condition Report (CR). The CR is automatically entered into the site's CAP for completion of the license basis evaluation, if required.

If no physical work was performed, the PASC was entered directly into the plant's CAP for completion of the license basis evaluation, if required .

All PASCs identified were determined to be in conformance with the license basis.

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 wa/kdowns and walk-bys were addressed and included in the report to the NRC.

PBNP meets alternative 1(c), and provides the following statement of confirmation :

All potentially adverse seismic 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 (References 2 and 3, Tables 5-2 and 5-3). As no new items were identified as part of this review, there are no additional CAP items to report.

2. Conduct of the Peer Review Process As a result of the walkdown report reviews, the NRC staff noted that some descriptions of the peer reviewers and the peer review process that was followed were varied and, in some cases, unclear. In some cases, the staff could not confirm details of the process, such as if the entire process was reviewed by the peer review team, who were the peer reviewers, what was the role of each peer reviewer, and how the reviews affected the work, if at all, described in the walkdown guidance.

Therefore, in order to clarify the peer review process that was actually used, please confirm whether the following information on the peer review process was provided in the original submittal, and if not, provide the following.

(a) Confirmation that the activities described in the walkdown guidance on page 6-1 were assessed as part of the peer review process.

(b) A complete summary of the peer review process and activities. Details should include confirmation that any individual involved in performing any given walkdown activity was not a peer reviewer for that same activity. If there were cases in which peer reviewers reviewed their own work, please justify how this is in accordance with the objectives of the peer review efforts.

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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.

NextEra Response

2. 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 The requested information can be found in the Table in Section 3.1, Peer Review Team of Appendix F of reference 3. As a clarification to this information, the following table lists the activities found on page 6-1 of the EPRI guidance document and the Peer Reviewer(s) for the activity:

Page 6-1 Activity Peer Reviewer Peer Reviewer Role Review the selection of the SSCs R. Severson Peer Reviewer #1 included on the SWEL T. K. Ram Peer Reviewer #2 Review a sample of the checklists D. N. Carter prepared for the Seismic Walkdowns N. Juryadini and Area Walk-Bys D. J. Nuttall C. A. McDonald S.D. Kahl R. L. LaPlante M. C. Nielsen J. Buboltz D.P. Brown Review the licensing basis evaluations M. C. Nielsen (LBE) D. J. Nuttall Review the decisions for entering the M. C. Nielsen potentially adverse conditions into the D. J. Nuttall CAP process Review the submittal report D.P. Brown Peer Review Report Preparer S. E. Guokas Peer Review Report Reviewer Summarize the results of the peer D.P. Brown Peer Review Report review process in the submittal report Preparer S. E. Guokas Peer Review Report Reviewer The Peer Review of a sample of Seismic Walkdown Checklists (SWC) and Area Walk-by Checklists (AWC) was performed, as a group, by all Seismic Walkdown Engineers (SWE). In order to avoid conflict, the SWE that performed the SWC and AWC were excluded from the peer review discussion.

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Based on the above table, PBNP has followed the EPRI guidance for performing peer reviews with regard to qualifications, tasks performed and roles. *

(b) Provide 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.

A description of the Peer Review process and activities can be found in Appendix F of the PBNP submittal reports, reference 2 and reference 3.

The RAI requests 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.

As shown in the table above, Mr. D. P. Brown served as Team Leader of the Peer Review Team. During the Peer Review of the completed submittal report, Mr. Brown did Peer Review some of the walkdown activities that he performed. However, each activity in which Mr. Brown participated had a separate Peer Review of the individual activity.

There are no activities for which Mr. Brown was the sole Peer Reviewer of his own work.

If there are differences from the original submittal, please provide a description of the above information.

There are no differences from the original submittal in regard to the Peer Review process.

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