ML13127A455

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

ML13127A455
Person / Time
Site:	Salem
Issue date:	05/20/2013
From:	John Hughey Plant Licensing Branch 1
To:	Joyce T Public Service Enterprise Group
Miller E, NRR/JLD, 415-2481
References
TAC MF0276, TAC MF0277
Download: ML13127A455 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 20,2013 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236, NOS Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 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 NOS. MF0276 AND MF0277)

Dear Joyce:

On March 12, 2012, the U.S. Nuclear Regulatory Commission staff (NRC) issued a request for information letter per Title 10 of 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 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 26, 2012, PSEG Nuclear LLC submitted a Flooding Walkdown Report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the 50.54(f) letter for Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem). The NRC staff plans to conduct a regulatory audit to gain a better understanding of the methods and procedures used by PSEG Nuclear LLC to conduct the flooding walkdowns and facilitate NRC staff review of the walkdown report. The audit will be conducted at Salem from June 25-27, 2013, in accordance with the enclosed regulatory audit plan.

T. Joyce -2 If you have any questions, please contact me by telephone at 301-415-3204 or bye-mail at john.hughey@nrc.gov.

Sincerely,

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John D. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

Audit Plan cc w/encl: Distribution via Listserv

Audit Plan Flooding Walkdown Review for Salem Nuclear Generating Station, Unit Nos. 1 and 2 Audit Date: June 25-27,2013 Japan Lessons Learned Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure

Audit Plan Salem Nuclear Generating Station, Unit Nos. 1 and 2

1. Background On March 12, 2012, the U.S. Nuclear Regulatory Commission staff (NRC) issued a request for information letter1 per Title 10 of 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 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 26, 2012,2 PSEG Nuclear LLC submitted a Flooding Walkdown Report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the 50.54(f) letter for Salem.

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 PSEG Nuclear LLC to conduct the flooding walkdowns at Salem 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. NEI submitted NEI 12-07, "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 7,2012,5 PSEG Nuclear LLC indicated that they would utilize the NRC endorsed guidance in the performance of the walkdowns at Salem.

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 Salem is to examine relevant flooding walkdown documents, interview flooding walkdown participants, observe areas of the plant walked down, and examine other relevant materials used to conduct the flooding walkdowns. This will assist the NRC staff in identifying whether the flooding walkdowns were conducted in accordance with 1 The 50.54(f) letter is available in the Agencywide Document Access and Management System (ADAMS) under Accession No. ML12053A340.

2 The licensee's letter is available in ADAMS under Accession No. ML12334A450 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 licensee's letter is available in ADAMS under Accession No. ML12160A292.

-2 the walkdown guidance and the 50.54(f) letter. The NRC staff will request additional information using the appropriate regulatory process.

The staff reviewed the walkdown report for Salem 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 the 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.

• 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, PSEG Procedure ER-AA-31 0-1009, Rev. 2, "Condition Monitoring of Structures").

• Flood-specific procedures that are part of flooding protection and mitjgation strategy and hazardous weather response that were reviewed as part of the flooding walkdowns, including, but not limited to, OP-AA-1 08-111-1001, Rev. 7, "Severe Weather and Natural Disaster Guidelines," and SC.OP-AB.ZZ-0001(Q),

Rev. 14, "Adverse Environmental Conditions."

• Listing of entries into the corrective action program resulting from the performance of the flooding walkdowns, including condition report number, title, and brief summary of the issue or observation and its disposition.

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.

- 3

5. Team Assignments

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Team Lead Stephen Campbell (NRC)

Flooding Walkdown Technical Lead Nebiyu Tiruneh (NRC)

Flooding Technical Support Jake Philip (NRC)

Flooding Technical Support Ed Miller (NRC)

Technical Support Phil McKenna (NRC)

Flooding Technical Support John Quinn (ANL)

6. Logistics The audit will be conducted at Salem from June 25 until June 27,2013. 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 schedule is attached.

7. Deliverables An audit report/summary 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 Salem Nuclear Generating Station, Unit Nos. 1 and 2 Flooding Walkdown Audit Schedule June 25 - 27,2013 June 25, 2013 A.M.

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

and setup for entrance meeting.

• 9:00 a.m. Entrance Meeting - introductions, audit activities and goals, and audit logistics.

• 9:30 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 the licensee on flooding walkdown methodology

• 3:30 p.m. Audit Team Caucus

• 5:00 p.m. NRC/Licensee Interim Meeting

• 6:00 p.m. Audit Team Daily Closeout June 26, 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 as low as reasonably achievable (ALARA)).

P.M.

• 1 :30 p.m. Discussion(s) with Salem flooding walkdown team members and contractors

• 4:00 p.m. Audit Team Caucus

• 5:00 p.m. NRC/Licensee Interim Meeting

• 6:00 p.m. Audit Team Daily Closeout

June 27. 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 Salem flooding walkdown team members and contractors

• 4:00 p.m. Audit Team Caucus

• 5:00 p.m. NRC/Licensee Exit Meeting

T. Joyce -2 If you have any questions, please contact me by telephone at 301-415-3204 or bye-mail at john.hughey@nrc.gov.

Sincerely, Ira! (RB Ennis for)

John D. Hughey, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

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

PUBLIC RidsRgn1 MailCenter LPL 1-2 R/F RidsOpaMailCenter DHuyck, EDO RI, RII, Rill, RIV RidsNroDsea RidsN rrLAABaxter RidsAcrsAcnw MailCTR RidsNrrDorl RidsNrrPMSalem RidsNrrDorlLpl1-2 J. Whited, NRR ADAMS Accession Number: ML13127A455 *via email OFFICE DORULPLI-2/PM JLD/PMB/PM DORULPLI-2/LA* DSEAlRHMB NAME JWhited GEMiller ABaxter PChaput*

DATE 5/10/2013 5/20/2013 5/10/2013 5/912013 OFFICE DSEAlRHMB/BC DORULPLI-2/BC DIRS/IRIB DORULPLI-2/PM DATE CCook MKhanna SCampbeli JHughey (REnnis for)

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