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{{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 May 21,2013 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc. Innsbrook Technical Center SOOO Dominion Boulevard Glen Allen, VA 23060-6711 MILLSTONE POWER STATION, UNIT NO.2 -PLAN FOR THE REGULATORY AUDIT REGARDING FLOODING WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NO. MF0246)  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 21,2013 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center SOOO Dominion Boulevard Glen Allen, VA 23060-6711
 
==SUBJECT:==
MILLSTONE POWER STATION, UNIT NO.2 - PLAN FOR THE REGULATORY AUDIT REGARDING FLOODING WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NO. MF0246)


==Dear Mr. Heacock:==
==Dear Mr. Heacock:==
On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a request for information letter per Title 10 of the Code of Federal Regulations, Subpart SO.S4(f) (SO.S4(f) letter). The SO.S4(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great Tohoku Earthquake and subsequent tsunami. The request addressed the methods and procedures for plants to conduct seismic and flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.
On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a request for information letter per Title 10 of the Code of Federal Regulations, Subpart SO.S4(f) (SO.S4(f) letter). The SO.S4(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great Tohoku Earthquake and subsequent tsunami. The request addressed the methods and procedures for plants to conduct seismic and flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.
By letter dated November 27, 2012, Dominion Nuclear Connecticut, Inc submitted a flooding walkdown report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the SO.S4(f) letter for Millstone Power Station, Units Nos. 2 and 3 (MPS-2 and 3). The NRC staff plans to conduct a regulatory audit to gain a better understanding of the methods and procedures used by MPS to conduct the flooding walkdowns and facilitate NRC staff review of the walkdown report. The audit will be conducted at MPS-2 from July 1S-17, 2013, in accordance with the enclosed regulatory audit plan.
By letter dated November 27, 2012, Dominion Nuclear Connecticut, Inc submitted a flooding walkdown report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the SO.S4(f) letter for Millstone Power Station, Units Nos. 2 and 3 (MPS-2 and 3). The NRC staff plans to conduct a regulatory audit to gain a better understanding of the methods and procedures used by MPS to conduct the flooding walkdowns and facilitate NRC staff review of the walkdown report. The audit will be conducted at MPS-2 from July 1S-17, 2013, in accordance with the enclosed regulatory audit plan.
D. Heacock 2 If you have any questions, please contact me by telephone at or by at nadiyah.morgan@nrc.gov. Sincerely, Nadiyah S. Morgan, Project Manager Licensing Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.  
 
D. Heacock                               ~ 2 ~
If you have any questions, please contact me by telephone at   301~415~1016  or by e~mail at nadiyah.morgan@nrc.gov.
Sincerely,
                                      /J'  Nadiyah S. Morgan, Project Manager Licensing Branch 1~1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50~336


==Enclosure:==
==Enclosure:==


Audit Plan cc w/encl: Distribution via Listserv Audit Plan Flooding Walkdown Review for Millstone Power Station, Unit 2 Audit Date: July 15-17, 2013 Japan Lessons Learned Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ENCLOSURE Audit Millstone Power Station, Unit 1. Background On March 12,2012, the U.S. Nuclear Regulatory Commission staff (NRC) issued a request for information letter 1 per Title 10 to the Code of Federal Regulations, Subpart 50.54(f) (50.54(f) letter). The 50.54(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great T5hoku Earthquake and subsequent tsunami. The request addressed the methods and procedures for plants to conduct seismic and flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.
Audit Plan cc w/encl: Distribution via Listserv
By letter dated November 27,2012/ Dominion Nuclear Connecticut, Inc submitted a flooding walkdown report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the 50.54(f) letter for Millstone Power Station (MPS), Units 2 and 3. 2. Regulatory Audit Bases The NRC staff intends to conduct a regulatory audit to gain a better understanding of the methods and associated procedures used by Dominion Nuclear Connecticut, Inc to conduct the flooding walkdowns at MPS and facilitate NRC staff review of the walkdown report. Guidance for performing the flooding walkdowns was developed by the Nuclear Energy Institute (NEI) with extensive review and input from NRC staff in numerous public meetings, webinars, and public conference calls during its development.
 
I\IEI submitted NE112-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features" (walkdown guidance)3 for endorsement, and the staff subsequently endorsed the walkdown guidance by letter dated May 31,2012.4 By letter dated June 11, 2012,5 Dominion Nuclear Connecticut, Inc indicated that they would utilize the NRC endorsed guidance in the performance of the walkdowns at MPS. The 50.54(f) letter and the walkdown guidance are used as the basis documents upon which this regulatory audit is to be performed.
Audit Plan Flooding Walkdown Review for Millstone Power Station, Unit 2 Audit Date: July 15-17, 2013 Japan Lessons Learned Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ENCLOSURE
: 3. Regulatory Audit Scope The scope of this regulatory audit for MPS is to examine relevant flooding walkdown documents, interview flooding walkdown participants, observe areas of the plant walked down, review and understand how the reasonable simulations were performed as part of the 1 The 50.54(f) letter is available in the Agencywide Document Access and Management System (ADAMS) Accession No. ML 2 The licensees letter in response to "Recommendation 2.3: Flooding" flooding walkdown report is available ADAMS under Accession No. ML 3 NEI 12-07 is available ADAMS under Accession No. ML 4 The NRC endorsement of NE112-07 is available in ADAMS under Accession No. ML 5 The licensees letter is available in ADAMS under Accession No. ML 
 
-2 walkdowns (if applicable), and examine other relevant materials used to conduct the flooding walkdowns.
Audit Plan Millstone Power Station, Unit 2
This will assist the staff in identifying whether the flood walkdowns were conducted in accordance with the walkdown guidance and the 50.54(f) letter. The NRC staff will request additional information using the appropriate regulatory process. The NRC staff reviewed the walkdown report for MPS and compared it with the requested information in the 50.54(f) letter and the walkdown guidance.
 
The factors that the NRC staff considered in choosing sites to audit were: Lack of clarity as to how the walkdown was consistent with the guidance based on the review of the walkdown report. Plant specific areas of interest identified during review of the walkdown report. Feedback and information gained during performance of regional inspections (e.g., Temporary Instruction 2515/187). Information needs The licensee is requested to have the following documentation available on site for the audit team. The documentation could be provided electronically or by paper copies. If provided electronically, the licensee is requested to have at least three computers available for the audit team, with a printer attached. Walkdown record forms (as described in Appendix B of NEI 12-07) and other supplemental forms and worksheets used to document observations from performance of the walkdowns, including the full walkdown packages for both physical plant features and procedures for both units. Supplemental guidelines or procedures used, in addition to NEI 12-07, for the implementation of the flooding walkdowns, including industry, fleet, or site-specific guidelines or procedures (this includes, but is not limited to, Fleet GARD, BDB-1002, "Beyond Design Basis Project -Walkdowns of Flood Protection and Mitigation Features, " Rev. 0 and Millstone Procedure ER-MP-BDB-FLD-001, "Walkdown of Flood Protection Features," Rev. 0). Flood-specific procedures that are part of flood protection and mitigation strategy and hazardous weather response that were reviewed as part of the flood walkdowns, including, but not limited to, Dominion Procedure HRP-NUCLEAR, "Hurricane Response Plan (Nuclear)," Rev. 11 and Millstone Procedure C OP 200.6, "Storms and Other Hazardous Phenomena (Preparation and Recovery)," Rev. 002-07. Listing of entries into the corrective action program resulting from the performance of the flood walkdowns, including condition report number, title, and brief summary of the issue or observation and its disposition. Documentation of the basis that there is reasonable assurance that inaccessible features are available and will perform credited functions, including the following
===1. Background===
-features:
On March 12,2012, the U.S. Nuclear Regulatory Commission staff (NRC) issued a request for information letter1 per Title 10 to the Code of Federal Regulations, Subpart 50.54(f) (50.54(f) letter). The 50.54(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great T5hoku Earthquake and subsequent tsunami. The request addressed the methods and procedures for plants to conduct seismic and flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.
the separation wall between units 1 and 2 and the recessed section of the wall in the unit 2 enclosure building.
By letter dated November 27,2012/ Dominion Nuclear Connecticut, Inc submitted a flooding walkdown report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the 50.54(f) letter for Millstone Power Station (MPS), Units 2 and 3.
Additional information needs identified during the audit will be communicated to the designated point of contact. The NRC staff also requests the licensee to make personnel who performed the walkdowns (including site staff and contractors) accessible upon request (either in person or by phone). The personnel should be able to answer questions about how the visual inspections and reasonable simulations were performed.
: 2. Regulatory Audit Bases The NRC staff intends to conduct a regulatory audit to gain a better understanding of the methods and associated procedures used by Dominion Nuclear Connecticut, Inc to conduct the flooding walkdowns at MPS and facilitate NRC staff review of the walkdown report.
how available physical margin (APM) values were determined.
Guidance for performing the flooding walkdowns was developed by the Nuclear Energy Institute (NEI) with extensive review and input from NRC staff in numerous public meetings, webinars, and public conference calls during its development. I\IEI submitted NE112-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features" (walkdown guidance)3 for endorsement, and the staff subsequently endorsed the walkdown guidance by letter dated May 31,2012. 4 By letter dated June 11, 2012,5 Dominion Nuclear Connecticut, Inc indicated that they would utilize the NRC endorsed guidance in the performance of the walkdowns at MPS.
and discuss engineering analyses that were developed in support of the walkdown.
The 50.54(f) letter and the walkdown guidance are used as the basis documents upon which this regulatory audit is to be performed.
: 5. Team Assignments  
: 3. Regulatory Audit Scope The scope of this regulatory audit for MPS is to examine relevant flooding walkdown documents, interview flooding walkdown participants, observe areas of the plant walked down, review and understand how the reasonable simulations were performed as part of the 1 The 50.54(f) letter is available in the Agencywide Document Access and Management System (ADAMS) under Accession No. ML12053A340.
'. ,k;i;fea
2 The licensees letter in response to "Recommendation 2.3: Flooding" flooding walkdown report is available in ADAMS under Accession No. ML12334A445.
'.".i, .;0";;*'.*.* . Asslg Team Lead Stephen Campbell (NRC) Flooding Walkdown Technical Lead Michelle Bensi (NRC) Flooding Technical Support Nebiyu Tiruneh (NRC) Regulatory Support Ken Erwin (NRC) Management Support George Wilson (NRC) Technical Support James Krafty (NRC) Flooding Technical Support Lance Vail (PNNL) 6. Logistics The audit will be conducted at MPS from July 15 to July 17. 2013. Entrance and exit briefings will be held at the beginning and end of this audit. respectively.
3 NEI 12-07 is available ADAMS under Accession No. ML12144A401.
The licensee is requested to provide a room for the use of the audit team. A more detailed proposed audit schedule is attached 7. Deliverables An audit reporUsummary will be issued to the licensee within about 90 days from the end of the audit. Additionally, the results of the audit will be utilized to focus the scope of any requests for additional information issued in the course of this review.
4 The NRC endorsement of NE112-07 is available in ADAMS under Accession No. ML12144A142.
July 15, 2013 A.M. P.M. July 16,2013 A.M. P.M. July 17, 2013 A.M. Proposed Millstone Power Flooding Walkdown Audit July 15 8:30 a.m. Check-in at site -receive badges, meet licensee contact(s), and setup for entrance meeting. 9:30 a.m. Entrance Meeting -introductions, audit activities and goals, and audit logistics. 10:30 a.m. NRC Team Breakout -staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown. 1 :00 p.m. Discussion with MPS on flooding walkdown methodology 3:30 p.m. Audit Team Caucus 5:00 p.m. NRC I Licensee Interim Meeting 6:00 p.m. Audit Team Daily Closeout 8:00 a.m. NRC Team Breakout -staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown. 10:00 a.m. Plant walkdown -(as reasonably accessible and in accordance with ALARA). 1 :30 p.m. Discussion(s) with MPS flooding walkdown team members and contractors 4:00 p.m. Audit Team Caucus 5:00 p.m. NRC I Licensee Interim Meeting 6:00 p.m. Audit Team Daily Closeout 9:00 a.m. NRC I Licensee Exit Meeting.
5 The licensees letter is available in ADAMS under Accession No. ML12171A006.
D. Heacock -If you have any questions, please contact me by telephone at 301-415-1016 or bye-mail at nadiyah.morgan@nrc.gov. Sincerely, /ra! Nadiyah S. Morgan, Project Manager Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-336  
 
                                                  -2 walkdowns (if applicable), and examine other relevant materials used to conduct the flooding walkdowns. This will assist the staff in identifying whether the flood walkdowns were conducted in accordance with the walkdown guidance and the 50.54(f) letter. The NRC staff will request additional information using the appropriate regulatory process.
The NRC staff reviewed the walkdown report for MPS and compared it with the requested information in the 50.54(f) letter and the walkdown guidance. The factors that the NRC staff considered in choosing sites to audit were:
* Lack of clarity as to how the walkdown was consistent with the guidance based on the review of the walkdown report.
* Plant specific areas of interest identified during review of the walkdown report.
* Feedback and information gained during performance of regional inspections (e.g.,
Temporary Instruction 2515/187).
: 4. Information needs The licensee is requested to have the following documentation available on site for the audit team. The documentation could be provided electronically or by paper copies. If provided electronically, the licensee is requested to have at least three computers available for the audit team, with a printer attached.
* Walkdown record forms (as described in Appendix B of NEI 12-07) and other supplemental forms and worksheets used to document observations from performance of the walkdowns, including the full walkdown packages for both physical plant features and procedures for both units.
* Supplemental guidelines or procedures used, in addition to NEI 12-07, for the implementation of the flooding walkdowns, including industry, fleet, or site-specific guidelines or procedures (this includes, but is not limited to, Fleet GARD, CM-AA BDB-1002, "Beyond Design Basis Project - Walkdowns of Flood Protection and Mitigation Features, " Rev. 0 and Millstone Procedure ER-MP-BDB-FLD-001, "Walkdown of Flood Protection Features," Rev. 0).
* Flood-specific procedures that are part of flood protection and mitigation strategy and hazardous weather response that were reviewed as part of the flood walkdowns, including, but not limited to, Dominion Procedure HRP-NUCLEAR, "Hurricane Response Plan (Nuclear)," Rev. 11 and Millstone Procedure C OP 200.6, "Storms and Other Hazardous Phenomena (Preparation and Recovery)," Rev. 002-07.
* Listing of entries into the corrective action program resulting from the performance of the flood walkdowns, including condition report number, title, and brief summary of the issue or observation and its disposition.
* Documentation of the basis that there is reasonable assurance that inaccessible features are available and will perform credited functions, including the following
 
                                                    - 3 features: the separation wall between units 1 and 2 and the recessed section of the wall in the unit 2 enclosure building.
Additional information needs identified during the audit will be communicated to the designated point of contact.
The NRC staff also requests the licensee to make personnel who performed the walkdowns (including site staff and contractors) accessible upon request (either in person or by phone).
The personnel should be able to answer questions about how the visual inspections and reasonable simulations were performed. how available physical margin (APM) values were determined. and discuss engineering analyses that were developed in support of the walkdown.
: 5. Team Assignments
                                                                              .
          '.         ,k;i;fea '9f.Re~i~~i*'i~.".  '.".i, .;0";;*'.*.* Asslg ru!~Acidltor Team Lead                             Stephen Campbell (NRC)
Flooding Walkdown Technical Lead                       Michelle Bensi (NRC)
Flooding Technical Support                         Nebiyu Tiruneh (NRC)
Regulatory Support                               Ken Erwin (NRC)
Management Support                             George Wilson (NRC)
Technical Support                               James Krafty (NRC)
Flooding Technical Support                           Lance Vail (PNNL)
: 6. Logistics The audit will be conducted at MPS from July 15 to July 17. 2013. Entrance and exit briefings will be held at the beginning and end of this audit. respectively. The licensee is requested to provide a room for the use of the audit team. A more detailed proposed audit schedule is attached
: 7. Deliverables An audit reporUsummary will be issued to the licensee within about 90 days from the end of the audit. Additionally, the results of the audit will be utilized to focus the scope of any requests for additional information issued in the course of this review.
 
Proposed Millstone Power Station Flooding Walkdown Audit Schedule July 15 -17,2013 July 15, 2013 A.M.
* 8:30 a.m. Check-in at site - receive badges, meet licensee contact(s),
and setup for entrance meeting.
* 9:30 a.m. Entrance Meeting - introductions, audit activities and goals, and audit logistics.
* 10:30 a.m. NRC Team Breakout - staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown.
P.M.
* 1:00 p.m. Discussion with MPS on flooding walkdown methodology
* 3:30 p.m. Audit Team Caucus
* 5:00 p.m. NRC I Licensee Interim Meeting
* 6:00 p.m. Audit Team Daily Closeout July 16,2013 A.M.
* 8:00 a.m. NRC Team Breakout - staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown.
* 10:00 a.m. Plant walkdown - (as reasonably accessible and in accordance with ALARA).
P.M.
* 1:30 p.m. Discussion(s) with MPS flooding walkdown team members and contractors
* 4:00 p.m. Audit Team Caucus
* 5:00 p.m. NRC I Licensee Interim Meeting
* 6:00 p.m. Audit Team Daily Closeout July 17, 2013 A.M.
* 9:00 a.m. NRC I Licensee Exit Meeting.
 
D. Heacock                                 - 2 If you have any questions, please contact me by telephone at 301-415-1016 or bye-mail at nadiyah.morgan@nrc.gov.
Sincerely,
                                              /ra!
Nadiyah S. Morgan, Project Manager Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-336


==Enclosure:==
==Enclosure:==


Audit Plan cc w/encl: Distribution via Listserv DISTRIBUTION:
Audit Plan cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsOgcMailCenter RidsRgn1 MailCenter LPL 1-1 RlF RidsOpaMailCenter DHuyck, EDO RI, RII, Rill, RIV RidsNroDsea RidsNrrLAKGoldstein RidsAcrsAcnw MailCTR RidsNrrDorl RidsN rrPMMillstone RidsNrrDorlLpl1-1 DSchroeder, RI SKennedy, RI ETorres, RI ADAMS Accession No: ML13127A143  
PUBLIC                 RidsOgcMailCenter                     RidsRgn1 MailCenter LPL1-1 RlF             RidsOpaMailCenter                     DHuyck, EDO RI, RII, Rill, RIV RidsNroDsea           RidsNrrLAKGoldstein                   RidsAcrsAcnw MailCTR RidsNrrDorl           RidsN rrPMMillstone                   RidsNrrDorlLpl1-1 DSchroeder, RI         SKennedy, RI                           ETorres, RI ADAMS Accession No: ML13127A143                                     *via e-mail OFFICE     DORLILPLI-1/PM         JLD/PMB/PM           DORLILPLI-1/LA       DSEAlRHMB NAME       NMorgan               GEMilier             KGoldstein           PChaput*
*via e-mail OFFICE DORLILPLI-1/PM JLD/PMB/PM DORLILPLI-1/LA DSEAlRHMB NAME NMorgan GEMilier KGoldstein PChaput* DATE 5/10/2013 5/21/2013 5/912013 5/9/2013 OFFICE DSEAlRH MB/BC DORLILPLI-1/BC DIRS/IRIB DATE CCook* SMeighan SCampbell NAME 5/22/2013 5115/2013 5/21/2013 OFFICIAL RECORD COpy}}
DATE       5/10/2013             5/21/2013           5/912013             5/9/2013 OFFICE     DSEAlRH MB/BC         DORLILPLI-1/BC       DIRS/IRIB DATE       CCook*                 SMeighan             SCampbell NAME       5/22/2013             5115/2013           5/21/2013 OFFICIAL RECORD       COpy}}

Revision as of 19:43, 4 November 2019

Plan for the Regulatory Audit Regarding Flooding Walkdowns to Support Implementation of Near-Term Task Force Recommendation 2.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident
ML13127A143
Person / Time
Site: Millstone Dominion icon.png
Issue date: 05/21/2013
From: Nadiyah Morgan
Plant Licensing Branch 1
To: Heacock D
Dominion Nuclear Connecticut
Miller E, NRR/JLD, 415-2481
References
TAC MF0246
Download: ML13127A143 (8)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 21,2013 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center SOOO Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO.2 - PLAN FOR THE REGULATORY AUDIT REGARDING FLOODING WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NO. MF0246)

Dear Mr. Heacock:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a request for information letter per Title 10 of the Code of Federal Regulations, Subpart SO.S4(f) (SO.S4(f) letter). The SO.S4(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great Tohoku Earthquake and subsequent tsunami. The request addressed the methods and procedures for plants to conduct seismic and flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.

By letter dated November 27, 2012, Dominion Nuclear Connecticut, Inc submitted a flooding walkdown report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the SO.S4(f) letter for Millstone Power Station, Units Nos. 2 and 3 (MPS-2 and 3). The NRC staff plans to conduct a regulatory audit to gain a better understanding of the methods and procedures used by MPS to conduct the flooding walkdowns and facilitate NRC staff review of the walkdown report. The audit will be conducted at MPS-2 from July 1S-17, 2013, in accordance with the enclosed regulatory audit plan.

D. Heacock ~ 2 ~

If you have any questions, please contact me by telephone at 301~415~1016 or by e~mail at nadiyah.morgan@nrc.gov.

Sincerely,

/J' Nadiyah S. Morgan, Project Manager Licensing Branch 1~1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50~336

Enclosure:

Audit Plan cc w/encl: Distribution via Listserv

Audit Plan Flooding Walkdown Review for Millstone Power Station, Unit 2 Audit Date: July 15-17, 2013 Japan Lessons Learned Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ENCLOSURE

Audit Plan Millstone Power Station, Unit 2

1. Background

On March 12,2012, the U.S. Nuclear Regulatory Commission staff (NRC) issued a request for information letter1 per Title 10 to the Code of Federal Regulations, Subpart 50.54(f) (50.54(f) letter). The 50.54(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great T5hoku Earthquake and subsequent tsunami. The request addressed the methods and procedures for plants to conduct seismic and flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.

By letter dated November 27,2012/ Dominion Nuclear Connecticut, Inc submitted a flooding walkdown report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the 50.54(f) letter for Millstone Power Station (MPS), Units 2 and 3.

2. Regulatory Audit Bases The NRC staff intends to conduct a regulatory audit to gain a better understanding of the methods and associated procedures used by Dominion Nuclear Connecticut, Inc to conduct the flooding walkdowns at MPS and facilitate NRC staff review of the walkdown report.

Guidance for performing the flooding walkdowns was developed by the Nuclear Energy Institute (NEI) with extensive review and input from NRC staff in numerous public meetings, webinars, and public conference calls during its development. I\IEI submitted NE112-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features" (walkdown guidance)3 for endorsement, and the staff subsequently endorsed the walkdown guidance by letter dated May 31,2012. 4 By letter dated June 11, 2012,5 Dominion Nuclear Connecticut, Inc indicated that they would utilize the NRC endorsed guidance in the performance of the walkdowns at MPS.

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

3. Regulatory Audit Scope The scope of this regulatory audit for MPS is to examine relevant flooding walkdown documents, interview flooding walkdown participants, observe areas of the plant walked down, review and understand how the reasonable simulations were performed as part of the 1 The 50.54(f) letter is available in the Agencywide Document Access and Management System (ADAMS) under Accession No. ML12053A340.

2 The licensees letter in response to "Recommendation 2.3: Flooding" flooding walkdown report is available in ADAMS under Accession No. ML12334A445.

3 NEI 12-07 is available ADAMS under Accession No. ML12144A401.

4 The NRC endorsement of NE112-07 is available in ADAMS under Accession No. ML12144A142.

5 The licensees letter is available in ADAMS under Accession No. ML12171A006.

-2 walkdowns (if applicable), and examine other relevant materials used to conduct the flooding walkdowns. This will assist the staff in identifying whether the flood walkdowns were conducted in accordance with the walkdown guidance and the 50.54(f) letter. The NRC staff will request additional information using the appropriate regulatory process.

The NRC staff reviewed the walkdown report for MPS and compared it with the requested information in the 50.54(f) letter and the walkdown guidance. The factors that the NRC staff considered in choosing sites to audit were:

  • Lack of clarity as to how the walkdown was consistent with the guidance based on the review of the walkdown report.
  • Plant specific areas of interest identified during review of the walkdown report.
  • Feedback and information gained during performance of regional inspections (e.g.,

Temporary Instruction 2515/187).

4. Information needs The licensee is requested to have the following documentation available on site for the audit team. The documentation could be provided electronically or by paper copies. If provided electronically, the licensee is requested to have at least three computers available for the audit team, with a printer attached.
  • Walkdown record forms (as described in Appendix B of NEI 12-07) and other supplemental forms and worksheets used to document observations from performance of the walkdowns, including the full walkdown packages for both physical plant features and procedures for both units.
  • Supplemental guidelines or procedures used, in addition to NEI 12-07, for the implementation of the flooding walkdowns, including industry, fleet, or site-specific guidelines or procedures (this includes, but is not limited to, Fleet GARD, CM-AA BDB-1002, "Beyond Design Basis Project - Walkdowns of Flood Protection and Mitigation Features, " Rev. 0 and Millstone Procedure ER-MP-BDB-FLD-001, "Walkdown of Flood Protection Features," Rev. 0).
  • Flood-specific procedures that are part of flood protection and mitigation strategy and hazardous weather response that were reviewed as part of the flood walkdowns, including, but not limited to, Dominion Procedure HRP-NUCLEAR, "Hurricane Response Plan (Nuclear)," Rev. 11 and Millstone Procedure C OP 200.6, "Storms and Other Hazardous Phenomena (Preparation and Recovery)," Rev. 002-07.
  • Listing of entries into the corrective action program resulting from the performance of the flood walkdowns, including condition report number, title, and brief summary of the issue or observation and its disposition.
  • Documentation of the basis that there is reasonable assurance that inaccessible features are available and will perform credited functions, including the following

- 3 features: the separation wall between units 1 and 2 and the recessed section of the wall in the unit 2 enclosure building.

Additional information needs identified during the audit will be communicated to the designated point of contact.

The NRC staff also requests the licensee to make personnel who performed the walkdowns (including site staff and contractors) accessible upon request (either in person or by phone).

The personnel should be able to answer questions about how the visual inspections and reasonable simulations were performed. how available physical margin (APM) values were determined. and discuss engineering analyses that were developed in support of the walkdown.

5. Team Assignments

.

'. ,k;i;fea '9f.Re~i~~i*'i~.". '.".i, .;0";;*'.*.* Asslg ru!~Acidltor Team Lead Stephen Campbell (NRC)

Flooding Walkdown Technical Lead Michelle Bensi (NRC)

Flooding Technical Support Nebiyu Tiruneh (NRC)

Regulatory Support Ken Erwin (NRC)

Management Support George Wilson (NRC)

Technical Support James Krafty (NRC)

Flooding Technical Support Lance Vail (PNNL)

6. Logistics The audit will be conducted at MPS from July 15 to July 17. 2013. Entrance and exit briefings will be held at the beginning and end of this audit. respectively. The licensee is requested to provide a room for the use of the audit team. A more detailed proposed audit schedule is attached
7. Deliverables An audit reporUsummary will be issued to the licensee within about 90 days from the end of the audit. Additionally, the results of the audit will be utilized to focus the scope of any requests for additional information issued in the course of this review.

Proposed Millstone Power Station Flooding Walkdown Audit Schedule July 15 -17,2013 July 15, 2013 A.M.

  • 8:30 a.m. Check-in at site - receive badges, meet licensee contact(s),

and setup for entrance meeting.

  • 9:30 a.m. Entrance Meeting - introductions, audit activities and goals, and audit logistics.
  • 10:30 a.m. NRC Team Breakout - staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown.

P.M.

  • 1:00 p.m. Discussion with MPS on flooding walkdown methodology
  • 3:30 p.m. Audit Team Caucus
  • 5:00 p.m. NRC I Licensee Interim Meeting
  • 6:00 p.m. Audit Team Daily Closeout July 16,2013 A.M.
  • 8:00 a.m. NRC Team Breakout - staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown.
  • 10:00 a.m. Plant walkdown - (as reasonably accessible and in accordance with ALARA).

P.M.

  • 1:30 p.m. Discussion(s) with MPS flooding walkdown team members and contractors
  • 4:00 p.m. Audit Team Caucus
  • 5:00 p.m. NRC I Licensee Interim Meeting
  • 6:00 p.m. Audit Team Daily Closeout July 17, 2013 A.M.
  • 9:00 a.m. NRC I Licensee Exit Meeting.

D. Heacock - 2 If you have any questions, please contact me by telephone at 301-415-1016 or bye-mail at nadiyah.morgan@nrc.gov.

Sincerely,

/ra!

Nadiyah S. Morgan, Project Manager Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosure:

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

PUBLIC RidsOgcMailCenter RidsRgn1 MailCenter LPL1-1 RlF RidsOpaMailCenter DHuyck, EDO RI, RII, Rill, RIV RidsNroDsea RidsNrrLAKGoldstein RidsAcrsAcnw MailCTR RidsNrrDorl RidsN rrPMMillstone RidsNrrDorlLpl1-1 DSchroeder, RI SKennedy, RI ETorres, RI ADAMS Accession No: ML13127A143 *via e-mail OFFICE DORLILPLI-1/PM JLD/PMB/PM DORLILPLI-1/LA DSEAlRHMB NAME NMorgan GEMilier KGoldstein PChaput*

DATE 5/10/2013 5/21/2013 5/912013 5/9/2013 OFFICE DSEAlRH MB/BC DORLILPLI-1/BC DIRS/IRIB DATE CCook* SMeighan SCampbell NAME 5/22/2013 5115/2013 5/21/2013 OFFICIAL RECORD COpy

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