ML13294A543

Audit Report Regarding Seismic Walkdowns to Support Implementation of Near-Term Task Force Recommendation 2.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident

ML13294A543
Person / Time
Site:	Cook
Issue date:	11/21/2013
From:	Thomas Wengert Plant Licensing Branch III
To:	Weber L Nuclear Generation Group
Wengert T
References
TAC MF0114, TAC MF0115
Download: ML13294A543 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 21, 2013 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group .

One Cook Place Bridgman, Ml 49106

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 -AUDIT REPORT REGARDING SEISMIC WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS.

MF0114 AND MF0115)

Dear Mr. Weber:

On March 12, 2012, the U.S. Nuclear Regulatory Commission staff (NRC or the staff) 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 T6hoku Earthquake and subsequent tsLmami. 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, as supplemented by letter dated September 13, 2013, Indiana Michigan Power Company (I&M) submitted Seismic Walkdown Report as requested per of the 50.54(f) letter for the Donald C. Cook Nuclear Plant, Units 1 and 2. From July 17 to July 19, 2013, an NRC audit team conducted an on-site audit to gain a better understanding of the methods and procedures used by I&M to conduct the seismic walkdowns and facilitate the NRC staff review of the walkdown report. The audit report is enclosed.

L. Weber If you have any questions, please contact me at 301-415-4037 or by e-mail at Thomas.Wengert@nrc.gov.

Sincerely, Thomas J. Wengert, . Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosure:

Audit Report .

cc w/encl: Distribution via Listserv

SEISMIC WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT AUDIT REPORT INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316 BACKGROUND On March 12, 2012, the U.S. Nuclear Regulatory Commission staff (NRC or the staff) issued a request for information letter per Title 10 of the Code of Federal Regulations, Subpart 50.54(f)

(50.54(f) letter) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340)." 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 26, 2012 (ADAMS Accession No. ML14340A442), as supplemented by letter dated September 13, 2013:(ADAMS Accession No. ML13267A315), Indiana Michigan Power Company (I&M, the licensee) submitted a Seismic Walkdown Report as requested per of the 50.54(f) letter for the Donald C. Cook Nuclear Plant (CNP), Units 1 and 2.

From July 17 to July 19, 2013, an NRC audit team conducted an on-site regulatory audit to gain a better understanding of the methods and procedures used by I&M to conduct the seismic walkdowns at CNP, Units 1 and 2, and facilitate NRC staff review of the walkdown reports.

REGULATORY AUDIT BASIS The guidance for performing the seismic walkdowns was developed by the Electric Power Research Institute (EPRI) with extensive review and input from NRC staff in numerous public meetings, webinars, and public conference calls during its development. The EPRI submitted EPRI-1 025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic" (ADAMS Accession No. ML12164A181) (walkdow~

guidance) for endorsement, which the staff subsequently endorsed by letter dated May 31, 2012 (ADAMS Accession No. ML12145A529). By letter dated June 29, 2012 (ADAMS Accession No. ML121910348), I&M confirmed that they would utilize the walkdown guidance in the performance of the walkdowns at CNP, Units 1 and 2.

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

AUDIT ACTIVITIES The NRC audit team consisted of James lsom (NRC/NRR), Nilesh Chokshi (NRC/NRO),

Tze-Jer Chuang (NRC/NRO), and Luissette Candelario (NRC/NRO). The audit was performed from July 17 to July 19, 2013.

The audit team reviewed the following types of information:

• CNP Unit 1 and 2 in-field seismic walkdown and area walk-by checklists completed by the licensee and its contractor (Stevenson & Associates).

• Licensee's pre-audit self-assessment evaluation.

• CNP Unit 1 and 2 additional information such as tables and summaries provided on the personnel involved in the seismic walkdowns, peer review process, checklist completion, overall seismic walkdown process and the roles and responsibilities of the lead reviewer.

• CNP Unit 1 and 2 "Owners acceptance review" (identified by the licensee as its management review).

• CNP Unit 1 list detailing the date, disposition and finding of the walkdowns performed for the deferred items in spring 2013.

• CNP Unit 1 and 2 seismic walkdown equipment lists (SWEL 1 and 2), Revision 0.

• CNP Unit 1 and 2 Individual Plant Examination ofExternal Events (IPEEE) summary reports and IPEEE findings list that included: description/outliner, resolution, status, identification of walkdown SWEL item or Area Walk-by S\1\/EL item.

• Action requests (ARs) and work orders for several items (i.e., Unit 1 Pump 12-ACA-CW-1, AR 2012-11715, Unit 2 Equipment ID 2-PP-4, AR 2012-11936 and Unit 2 Area 33-AB2, AR 2012-11212 and subsequent Work Order #55410959).

• PMP-5020-RTM-001, Rev. 5,* "Restraint of Transient Material," dated May 31, 2013, Section 3.8, "Seismic Interaction Evaluation Process," page 12 of 16.

• 12-MHP-5021-SCF-001, Rev.17, "Scaffolding Guidelines," dated June 26,2013, Section 4.10.11 "Tie-Down Cables."

• D. Lindley, D. Pandya and A. Khanpour, "Estimating Seismic Response of Freestanding Scaffolding", Transactions, Structural Mechanics in Reactor Technology (SMiRT) 16, Washington, DC, August 2001 (Paper No. 1027), p. 8.

The NRC audit team performed an independent review of selected items and areas within Units 1 and 2, b.ased on the licensee's walkdowns and area walk-bys checklist. The audit team observed and discussed the following conditions with the licensee to further understand .the licensee's overall walkdown processes:

• Unit 1 equipment ID 1-DGA8, described as the A8 emergency diesel generator OME-150-A8 Control. The NRC staff observed the existence of a disintegrated concrete area inside the cabinet below an anchorage bolt. The licensee determined this condition to be in compliance with its licensing basis based on previous analysis performed during the implementation of USI-A46 program.

• Unit 1 equipment ID 1-HV-AES-2, described as auxiliary building ventilation (engineered safety item). From the submittal report, the NRC staff reviewed a photograph that gave the impression there was a crack in the floor. The NRC staff viewed the item in the field and observed that in fact it was a small portion of peeling paint on the floor. The licensee judged this condition to be acceptable based on engineering judgment.

• Unit 1 equipment ID 1-HV-18W, described as the west containment spray heat exchanger. In the walkdown report, the licensee indicated that some of the anchorage was verified with pictures because it was not visible from platforms. The NRC staff walked down this item and concurred with the licensee that not all of the anchorage was visible from platforms. The NRC reviewed the photos used by the. licensee to evaluate the bolts. From the pictures, the anchorage appeared to be free of corrosion, and did not appear to be bent or broken. The licensee judged this condition to be acceptable based on engineering judgment.

• Unit 2 equipment IDs: 2-A8D-A and 2-A8D-8, described as 600 VAC motor control center A8D-A and A8D-8, respectively. From the submittal walkdown report, the NRC staff noted that, for both equipment items, the submitted pictures were exactly the same.

The NRC staff walked down these two items and realized that they are adjacent to each other. The licensee indicated that the reason of submitting the same pictures for both items was because the pictures included both items. In addition, the licensee opened the cabinet for equipment ID 2-A8D-8; the NRC staff observed the condition of the anchorage inside the cabinet and found no potential adverse issues.

• Unit 2 equipment ID 2-PP-4, described as turbine driven auxiliary feed pump. In an effort to explain the walkdown process and the licensing basis evaluation, the licensee offered to walk down this item. The licensee subsequently identified a potential adverse condition, which was then entered into the licensee's corrective action process (CAP)

(AR 2012-11936). An AR was issued for verification of a unistrut attached to the wall above the pump. The licensee indicated that the anchor of the unistrut looked as if it could be more rigidly supported. The NRC staff reviewed the AR and its evaluation.

The licensee concluded that it will tighten the bolt and weld the horizontal unistrut to the current unistrut in the wall. A work order is currently in place to correct this condition.

• Unit 1, area 33-A81, 633 foot elevation, 633 general pump 12-ACA-CW-1. The licensee identified corrosion on the casing and anchorage of this pump. A CAP item was issued

. (AR 2012-11715) to evaluate this condition. At the time the NRC staff walked down this area, the item had not been corrected. The NRC staff reviewed the AR and noted that the licensee determined that the rust will not compromise the pump's ability to perform its intended function and that .the rust could have been caused by water condensation.

The licensee recommended cleaning and painting the component to help protect it from rusting further.

• Unit 2 area 33-AB2, 650 foot elevation, room 129. The licensee identified a corroded bolt in the 2-HV ACRA-1 north control room ventilation unit, but determined it to be surface corrosion; no AR was reported in the walkdown report. During its independent walkdown, the NRC staff observed corrosion in the bolt and its surrounding area.

However, based on engineering judgment, the licensee maintained that it was surface corrosion. Notwithstanding, a CAP item was created (AR 2012-11212) and a work order was subsequently issued (#5541 0959) to correct the condition. The NRC staff reviewed the AR and work order, which recommended either cleaning or replacing the anchor bolt.

In addition, an operability review was issued that determined it to be a minor material deficiency that did not compromise its safety function.

• Unit 2 area 21-AB2, 633 foot elevation, by 2-CFI-429 and 2-WM0-716 and 2-WM0-718.

The NRC staff observed trunks and an unrestrained cart close to a pump, indicating a housekeeping issue. The Senior Reactor Operator promptly added clamps to the wheels of the cart and informed licen~ee management. The licensee subsequently indicated that a work order was created and personnel dispatched to correct the condition.

AUDIT

SUMMARY

The NRC staff engaged in various discussions with the licensee that led to a better understanding of the processes used by the licensee when conducting the seismic walkdowns related to Fukushima Recommendation 2.3. The licensee pre-audit assessment identified a number of documentation issues similar to those identified by the NRC seismic audit team. The NRC staff performed independent seismic walkdowns and area walk-bys .of some of the items documented in the submittal report. The licensee provided clarifications and additional documentation that supported its work. The NRC staff performed interviews with CNP personnel that led to a better understanding of: 1) the seismic walk down equipment list (SWEL) development, 2) the conduct and reporting of the seismic walkdowns and area walk-bys, and 3) items identified in the submittal report. Items identified in the submittal report for which the NRC staff obtained additional clarification include:

• the background and qualifications of individ~als who conducted the seismic walkdown activities;

• participation and roles of the operations staff and seismic walkdown engineers;

• scope of the peer review;

• experience and independence of the peer reviewers;

• conduct of licensee management review;

• identification of the SWEL items that were IPEEE enhanced;

• opening of cabinets;

• inclusion of Base List 2; and

• the approach used to disposition potential adverse seismic conditions identified during the walkdown activities.

By discussing these specific topics in depth with the licensee, reviewing th~ documentation mentioned above, and performing independent seismic walkdowns and area walk-bys, the team was able to meet the objectives of the audit.

The NRC staff observed the following while performing the independent seismic walkdowns and area walk-bys: potential block wall cracks, housekeeping issues, vertical interaction in scaffolding and potential spatial interaction between 2-LRV-245 (upper valve gear lube oil regulator) and a pipe line. The NRC resident inspectors will follow-up on these observations.

Two other issues were also discussed during the seismic audit. These issues were related to the process used to perform licensing basis evaluations and to evaluate conditions identified in the licensee's corrective action program.

During the audit, the licensee committed to submit an update to the seismic walkdown report by September 13, 2013. The licensee was requested to include information on observations addressed during the NRC site audit, observations identified in its self-assessment, as well as information related to its deferred walkdown items for Unit 1. Specifically, the licensee agreed to update the following areas: walkdown activities, seismic walkdown and area walk-by teams, operations personnel, creation of ARs, licensing basis evaluations, seismic walkdown and area walk-by checklists, CAP items and peer review information.

The NRC team discussed with the licensee the areas where the licensee's process differed from the walkdown guidance (e.g., conduct of peer reviews, separate reports for two units, walkdown checklist, and timeliness for entering items into the CAP). Conclusions as to acceptability of the walkdowns will be discussed in the staff assessment.

Entrance Meeting (July 17, 2013)

The NRC staff discussed the audit plan with the licensee, including the scope and expectations, topics of discussions, and possible path forward. The licensee provided a presentation

• regarding its self-assessment and stated its intention to submit a combined updated report by providing individual information of the key items for each unit.

Exit Meeting (July 19, 2013)

The NRC staff briefed the licensee's management on the results and observations encountered during the three day audit. The issues were clearly identified, and the licensee was given the opportunity to ask questions. The licensee committed to submit a revision of the report by September 13, 2013, including all of the observations addressed in the NRC Site Audit, observations identified in its self-assessment, as well as all of the information related to its deferred items for Unit 1.

POST-AUDIT CLARIFICATIONS The NRC staff conducted a conference call with the licensee on September 3, 2013, to provide clarification on the requested modific,ations to the updated seismic walkdown report that were discussed during the staff's audit. The licensee provided a. table with a high level description of the expected changes for each section of the walkdown report. The licensee confirmed it understood the request .and would submit an updated supplement to support the .staff's review of the licensee's walkodwn report and the development of the NRC staff assessment. The licensee provided an updated walkodwn report by letter dated September 13, 2013 (ADAMS Accession No. ML13267A315).

CONCLUSION During the audit, the NRC staff gained a better understanding of the methods and procedures used by I&M when conducting seismic walkdown activities at CNP, Units 1 and 2. Specific clarifications and additional information needed by the NRC staff regarding the licensee's seismic walkdown report were discussed. In response, the licensee submitted a revised report by letter dated September 13, 2013.

• Based on the information collected during the audit and, in conjunction with the original submittal and supplemental information submitted by the licensee, the NRC staff has sufficient information to complete its assessment of the licensee's response to Enclosure 3 of the 50.54(f) letter.

L. Weber If you have any questions, please contact me at 301-415-4037 or by e-mail at Thomas. Wengert@ nrc.gov.

Sincerely,

/RAJ Thomas J. Wengert, Sr. Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosure:

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• concurrence b1y e-mar'I OFFICE DORULPL3-1/PM DORULPL3-1 /LA NRO/DSEA/BC* JLD/PMB/PM NAME TWengert MHenderson DJackson LRegner DATE 10/31/13 10/29/13 10/07/13 11/19/13 OFFICE NRR/DIRS/TL* NRO/DSEA: DO* DORULPL3-1/BC I DORULPL3-1/PM I NAME Jlsom NChokshi RCarlson (SWall for) I TWengert I DATE 11/18/13 11/07/13 11/21/13 111/21/13 I OFFICIAL RECORD COPY