ML13340A147

Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant - Response to RAI Associated with Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (TAC Nos. MF0116 & MF0

ML13340A147
Person / Time
Site:	Davis Besse, Perry
Issue date:	11/26/2013
From:	Belcher S L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML13340A277	List: L-13-358, Near-Term Task Force Recommendation 2.3 Seismic Walkdown Report Revision 1, Appendix B (2 of 2) ML13340A147 ML13340A155 ML13340A156 ML13340A157 ML13340A158 ML13340A159 ML13340A160 ML13340A162 ML13340A163
References
L-13-358, TAC MF0116, TAC MF0159
Download: ML13340A147 (7)

Text

FENOCFEN O C76 South Main StreetFRst EneNuclearl. .Q .Akron. Ohio 44308Samuel L. BelcherSenior Vice President and Chief Operating OfficerNovember 26, 2013L-1 3-358 10 CFR 50.54(f)ATTN: Document Control DeskU.S. Nuclear Regulatory Commission11555 Rockville PikeRockville, MD 20852SUBJECT:Davis-Besse Nuclear Power StationDocket No. 50-346, License No. NPF-3Perry Nuclear Power PlantDocket No. 50-440, License No. NPF-58Response to Request for Additional Information Associated with the Seismic Aspects ofRecommendation 2.3 of the Near-Term Task Force Review of Insights from theFukushima Dai-ichi Accident (TAC Nos. MF0116 and MF0159)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a letter titled,"Request for Information Pursuant to Title 10 of the Code of Federal Regulations50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task ForceReview of Insights from the Fukushima Dai-ichi Accident," to all power reactor licenseesand holders of construction permits in active or deferred status. Enclosure 3 of the10 CFR 50.54(f) letter contains specific Requested Actions, Requested Information, andRequired Responses associated with Recommendation 2.3 for Seismic Walkdowns. Byletter dated November 27, 2012 (Agencywide Documents Access and ManagementSystem (ADAMS) Package Accession No. ML130080030), FirstEnergy NuclearOperating Company (FENOC) submitted the 180-day response to the 10 CFR 50.54(f)letter. The required seismic walkdown reports were provided as Enclosures A, B, C,and D for Beaver Valley Power Station, Unit No. 1 (BVPS-1); Beaver Valley PowerStation, Unit No. 2 (BVPS-2); Davis-Besse Nuclear Power Station (DBNPS); and PerryNuclear Power Plant (PNPP), respectively.By letter dated November 1, 2013 (ADAMS Accession No. ML13304B418), the NRCstaff requested additional information to allow the staff to complete its assessments ofthe seismic walkdown reports for DBNPS and PNPP. The response to the request forinformation is provided in Attachment 1.

Davis-Besse Nuclear Power StationPerry Nuclear Power PlantL-1 3-358Page 2Updated seismic walkdown reports for DBNPS and PNPP are provided in electronicformat on the enclosed CD-ROM. As requested by NRC guidance for electronicsubmissions, Attachment 2 provides a listing of document components that make up theenclosed CD-ROM.No new regulatory commitments are made in this letter. If there are any questions or ifadditional information is required, please contact Mr. Thomas A. Lentz, Manager -FleetLicensing, at 330-315-6810.I declare under penalty of perjury that the foregoing is true and correct. Executed onNovember ; , 2013.Sincerely,Samuel L. BelcherAttachment:1 Response to Request for Additional Information2 Document Components on CD-ROMEnclosures on CD-ROM:Davis-Besse Nuclear Power Station Near-Term Task Force Recommendation 2.3Seismic Walkdown Report Revision 1Perry Nuclear Power Plant Near-Term Task Force Recommendation 2.3 SeismicWalkdown Report Revision 1cc: Director, Office of Nuclear Reactor Regulation (NRR) (w/o Enclosures)NRC Region III Administrator (w/o Enclosures)NRC Resident Inspector (DBNPS) (w/o Enclosures)NRC Resident Inspector (PNPP) (w/o Enclosures)NRR Project Manager (DBNPS) (w/o Enclosures)NRR Project Manager (PNPP) (w/o Enclosures)Utility Radiological Safety Board (w/o Enclosures)

Attachment

1L-1 3-358Response to Request for Additional InformationPage 1 of 4By letter dated November 1, 2013 (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML13304B418), the Nuclear Regulatory Commission(NRC) staff requested additional information to allow the staff to complete itsassessments of the Near-Term Task Force (NTTF) Recommendation 2.3 seismicwalkdown reports for Davis-Besse Nuclear Power Station (DBNPS) and Perry NuclearPower Plant (PNPP). The response to the request for additional information (RAI) isprovided below. The NRC staff question is presented in bold type, followed by theFirstEnergy Nuclear Operating Company (FENOC) response.RAI 1: Conduct of the walkdowns, determination of potentially adverse seismicconditions (PASCs), dispositioning of issues, and reportingAs a result of the audits and walkdown report reviews, the NRC staff noted thatlicensees' interpretations of the seismic walkdown guidance varied, whichresulted in meaningful differences in the process used to disposition identifiedissues and in the documentation that was provided to the NRC staff. Inparticular, the application of engineering judgment in determining whatconstituted a potentially adverse seismic condition (PASC), the threshold forconducting licensing basis evaluations (LBEs), and determining what informationwas to be reported to the NRC staff varied.The NRC staff intended that conditions initially marked No (N) or Unknown (U) inthe field by the seismic walkdown engineers (SWEs) for which an analysis orcalculation was performed would be considered as PASCs and that an analysis orcalculation constituted an LBE. The walkdown guidance allows for analysis aspart of engineering judgment; however, the intent was to allow for only simpleanalyses that could be readily performed in support of engineering judgment.Further, the walkdown activities were intended to allow for transparency in thelicensee's process to demonstrate that PASCs were appropriately identified, thatthey were addressed in an appropriate manner, and the basis documented suchthat the current condition of the plant was clearly consistent with the CLB withregard to seismic capability.During the audits, the NRC staff identified examples of field observations thatwere deemed not to be PASCs. However, the basis for the determination was notclearly recorded. In some cases, the field checklists were amplified by notingthat the basis was engineering judgment. During site audit discussions, the staffwas able to trace the basis for the engineering judgments and found that in manycases they were appropriate. It is expected that these situations would not beincluded in the walkdown report.

Attachment

1L-1 3-358Page 2 of 4There were other situations that a PASC and LBE were not reported; however, theNRC staff found during the audit that a calculation, analysis (more than justsimple), or evaluation was conducted but informally. An example is aconfirmatory calculation performed to demonstrate that six anchor bolts out ofeight was not a seismically adverse condition. Another example would be ananalysis to demonstrate that an existing, slightly short weld was as seismicallysound as the prescribed weld length in the plant design documentation. The staffexpected these types of conditions and evaluations to be captured in thelicensee's normal plant processes (e.g., condition report or corrective actionprogram (CAP)), and also reported in the walkdown report, since they werepotentially adverse seismic conditions that required more than applyingjudgment or simple analysis to address.The NRC staff also found that the process that was used to deal with a fieldobservation that was deemed to be a PASC was also not completely described orcaptured in the report. In many cases, the licensee reported that an LBE was notperformed. However, during the audits, it was clear that an LBE (or an equivalentdetermination method) was performed and used in determining whether a PASCshould be entered into the CAP. The staff expects that these conditions would bereported in the walkdown report.On the whole, through the audits, the NRC staff found that it was able to concludethat the intent of the guidance was met when the licensee's overall process wascompletely explained, the information was updated to reflect the actual process,and results were updated. The self-assessments conducted by the licensees ofthe audited plants also identified the lapse in the description of the process usedby the licensee to identify a PASC and disposition it.Therefore, in order to clarify the process that was followed, please provide adescription of the overall process used by the licensee (and its contractors) toevaluate observations identified in the field by the SWEs. The process shouldinclude how a field observation was determined to be a PASC or not and how thebases for determinations were recorded. Once a determination was made that anobservation was a PASC, describe the process for creating a condition report (orother tracking mechanism), performing the LBE (or other determination method),and the resultant action, such as entering it into the CAP, or documenting theresult and basis.Also, in order to confirm that the reported information supports concluding thatthe plant meets the CLB, please follow one of the following three acceptablealternatives:(a) Provide a supplement to the table or text from the original walkdownreport, if needed, to include similar conditions as the above examplesand situations and for conditions for which a calculation, analysis (ifmore than a simple analysis), or evaluation was used for a

Attachment

1L-1 3-358Page 3 of 4determination. The supplement should include a short description ofeach condition, how it was dispositioned and the basis for thedisposition, as follows: 1) for each condition that was entered into theCAP, provide the CAP reference number, initiation date, and (if known)the planned completion date, or 2) for all other conditions, provide theresult of the LBE (or other determination method), the basis for theresult, and how (or where) the result was captured in the plant'sdocumentation or existing plant process.(b) Following the plant's standard procedures, confirm that a new CAPentry has been made to verify if appropriate actions were taken whenreporting and dispositioning identified PASCs (including conditionsfor which a calculation, analysis (if more than a simple analysis), orevaluation was used for a determination). The eventual CAP closeout,including the process followed and actions taken, should be insufficient detail to enable NRC resident inspectors to follow up.(c) If no new conditions are identified for addition to the supplement orthe CAP entry mentioned above is deemed not necessary, provide astatement of confirmation that all potentially seismic adverseconditions (including conditions for which a calculation, analysis (ifmore than a simple analysis), or evaluation was used for adetermination) identified during the walkdowns and walk-bys wereaddressed and included in the report to the NRC.Response:In July 2013, the NRC staff conducted an audit of the Beaver Valley Power Station, UnitNos. 1 and 2, NTTF Recommendation 2.3 seismic walkdown report process. Proposedchanges to the seismic walkdown reports were discussed in an audit follow-uptelephone call held on September 4, 2013 between NRC staff and FENOC. Asdiscussed during this call, the seismic walkdown reports for Beaver Valley PowerStation, Unit Nos. 1 and 2, were changed to address the items resulting from the NRCaudit and the items resulting from an internal FENOC self-assessment. As alsodiscussed during this call, similar changes were made to the seismic walkdown reportsfor DBNPS and PNPP. These changes include the information requested by the NRCstaff in this RAI. Revision 1 of the DBNPS and PNPP seismic walkdown reports areprovided on the enclosed CD-ROM.Alternative (a) as described above was utilized to ensure the reported informationsupports concluding that the plants meet their current licensing basis (CLB). As such,alternatives (b) and (c) are not required. Each condition report entered into the CAPhas either had corrective actions closed or has been closed to another action trackingprocess, such as a notification in the work order process. The CAP allows the use ofthese notifications for conditions determined to not be a condition adverse to quality.

Attachment

1L-1 3-358Page 4 of 4RAI 2: Conduct of the Peer Review ProcessAs a result of the walkdown report reviews, the NRC staff noted that somedescriptions of the peer reviewers and the peer review process that was followedwere varied and, in some cases, unclear. In some cases, the staff could notconfirm details of the process, such as if the entire process was reviewed by thepeer review team, who were the peer reviewers, what was the role of each peerreviewer, and how the reviews affected the work, if at all, described in thewalkdown 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 wasprovided in the original submittal, and if not, provide the following.(a) Confirmation that the activities described in the walkdown guidanceon page 6-1 were assessed as part of the peer review process.(b) A complete summary of the peer review process and activities. Detailsshould include confirmation that any individual involved in performingany given walkdown activity was not a peer reviewer for that sameactivity. If there were cases in which peer reviewers reviewed theirown work, please justify how this is in accordance with the objectivesof the peer review efforts.Also, if there are differences from the original submittal, please provide adescription of the above information. If there are differences in the review areasor the manner in which the peer reviews were conducted, describe the actualprocess that was used.Response:In July 2013, the NRC staff conducted an audit of the Beaver Valley Power Station, UnitNos. 1 and 2, NTTF Recommendation 2.3 seismic walkdown report process. Proposedchanges to the seismic walkdown reports were discussed in an audit follow-uptelephone call held on September 4, 2013 between NRC staff and FENOC. Asdiscussed during this call, the seismic walkdown reports for Beaver Valley PowerStation, Unit Nos. 1 and 2, were changed to address the items resulting from the NRCaudit and the items resulting from an internal FENOC self-assessment. As alsodiscussed during this call, similar changes were made to the seismic walkdown reportsfor DBNPS and PNPP. These changes include the information requested by the NRCstaff in this RAI. Section 9.2 of the reports describe details of the peer review processin accordance with the walkdown guidance on page 6-1 as noted in (a) above.Revision 1 of the DBNPS and PNPP seismic walkdown reports are provided on theenclosed CD-ROM.

Attachment

2L-1 3-358Document Components on CD-ROMPage 1 of IFile Name001 DBNPS Seismic Walkdown Rpt Revl.pdf002 DBNPS Seismic Rpt Revl App A.pdf003 DBNPS Seismic Rpt Revl App B (1 of 2).pdf004 DBNPS Seismic Rpt Revl App B (2 of 2).pdf005 DBNPS Seismic Rpt Revl App C to App G.pdf006 PNPP Seismic Walkdown Rpt Revl .pdf007 PNPP Seismic Rpt Revl App A.pdf008 PNPP Seismic Rpt Revl App B (1 of 2).pdf009 PNPP Seismic Rpt Revl App B (2 of 2).pdf010 PNPP Seismic Rpt Revl App C to App F.pdfSize19,798 KB17,570 KB31,334 KB27,711 KB19,559 KB17,304 KB16,991 KB33,402 KB49,479 KB26,915 KB