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{{#Wiki_filter:DUKESco L. BatsonDUKE Vice President ENERGYao446)ENE G~eOconee Nuclear StationDuke EnergyONO1VP 1 7800 Rochester HwySeneca, SC 29672o: 864.873.3274 F. 864.873.4208 Scott.Batson@duke-energy.com July 1, 2013 10 CFR 50.54(f)U. S. Nuclear Regulatory Commission (NRC)ATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852
==Subject:==
Duke Energy Carolinas, LLC (Duke Energy)Oconee Nuclear Station (ONS), Units 1, 2 and 3Docket Nos. 50-269, 50-270, and 50-287ONS Unit 1 Update to the ONS Seismic Walkdown Information Submitted November 27, 2012 (Reference 3 below).
==Reference:==
: 1) NRC Letter, Request for Information Pursuant to Title 10 of the Code of FederalRegulations 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, datedMarch 12, 20122) EPRI 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, Final, dated June 20123) Duke Energy Letter to NRC, Seismic Walkdown Information Requested by NRCLetter...,
dated November 27, 2012The NRC staff issued a Request for Information (Reference
: 1) on March 12, 2012. In responseto Recommendation 2.3 of that request, Duke Energy submitted Seismic Walkdown information for Oconee Nuclear Station (ONS). The information submitted followed an NRC endorsedindustry guideline, EPRI 1025286 (Reference 2).The EPRI guidance recognized that the walkdown scope would not be fully completed due toinaccessibility of some of the components initially selected.
Therefore, a provision in theguideline allowed for the inaccessible items to be completed at a later date. A list ofinaccessible components and a schedule for completing the walkdown scope was included inthe November 27, 2012 submittal (Reference 3). This submittal provides an update to theUnit 1 walkdown report (designated as Enclosure 1 of Reference 3).The update is designated as Enclosure Ia to this submittal.
It revises text in the body of thereport, and provides new attachments documents the walkdown data for the completed scope,and an associated Peer Review Report. This update can be combined with Enclosure 1 fromReference 3 to compose a final walkdown report for ONS Unit 1.This update satisfies Commitment No. 1 in Reference 3 by addressing inaccessible equipment associated with ONS Unit 1 and equipment common to all three units.Attachment 5a to Enclosure la contains Security-Sensitive Information
-Dwithhold from public disclosure pursuant to 10 CFR 2.390(d)(1)
(Upon removal of Attachment 5a, Enclosure 1 a and the letter becomes uncontrolled; upon removal of Enclosure 1 a the letter becomes uncontrolled)
United States Nuclear Regulatory Commission First Update to Seismic Walkdown ReportJuly 1, 2013Page 2Enclosure la includes Attachment 5a, which contains Security-Sensitive information.
Attachment 5a is requested to be withheld from public disclosure in accordance with 10CFR2.390(d)(1).
Should you have any questions concerning this letter, or require additional information, pleasecontact David Haile at (864) 873-4742.
I declare under penalty of perjury that the foregoing is true and correct.
Executed onJuly 1, 2013.Sincerely, Scott L. Batson, Vice President, Oconee Nuclear StationEnclosure I a -Update to Unit 1 Seismic Walkdown Report -NRC 50.54 (f) NTTF Recommendation 2.3Attachment 5a to Enclosure la contains Security-Sensitive Information
-withhold from public disclosure pursuant to 10 CFR 2.390(d)(1)
(Upon removal of Attachment 5a, Enclosure 1 a and the letter becomes uncontrolled; upon removal of Enclosure 1 a the letter becomes uncontrolled)
United States Nuclear Regulatory Commission Seismic Walkdown ReportJuly 1, 2013Page 3xc:Mr. Victor M. McCree, Administrator, Region IIU.S. Nuclear Regulatory Commission Marquis One Tower245 Peachtree Center Ave., NE, Suite 1200Atlanta, GA 30303-1257 Mr. Eric J. Leeds, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 13-H16M11555 Rockville PikeRockville, MD 20852-2738 Mr. John P. Boska, Project Manager (ONS)(By electronic mail only)U. S. Nuclear Regulatory Commission One White Flint North, M/S O-8G9A11555 Rockville PikeRockville, MD 20852Mr. Ed CroweNRC Senior Resident Inspector Oconee Nuclear Station Update to Oconee Unit 1Seismic Walkdown ReportJuly 1, 2013Enclosure la(Update to Enclosure I from November 27, 2012 Submittal)
Update to Unit 1 Seismic Walkdown ReportAttachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Enclosure laUpdate to Unit 1 Seismic Walkdown ReportExecutive SummaryElectric Power Research Institute (EPRI) Report 1025286, Seismic Walkdown Guidance forResolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic was issued inJune 2012. This Document provides guidance and procedures to perform seismic walkdowns asrequired by the U.S. Nuclear Regulatory Commission's (NRC's) 50.54(f) letter regarding Near-Term Task Force (NTTF) Recommendation 2.3: Seismic.
The EPRI guidance covers selection of personnel; selection of a sample of structures,
: systems, and components (SSCs) thatrepresent diversity of component types and assures inclusion of components from criticalsystems / functions; conduct of the walkdowns; evaluation of potentially adverse conditions against the plant seismic licensing basis; and reporting requirements.
It also includes check liststo be used by the Seismic Walkdown Engineers (SWEs) in performing the seismic walkdowns and walk-bys.
Duke Energy committed to implement resolution of Near-Term Task Force(NTTF) Recommendation 2.3: Seismic using EPRI Report 1025286 in a letter to the NRC dated7/9/2012.
[ONS made a previous submittal, dated November 27, 2012, which documented thewalkdown results for accessible components, designated as Enclosure I to the Novembersubmittal.
This is an update to Enclosure I (designated as Enclosure Ia) which will addressthe inaccessible components.
This additional data completes the ONS Unit lwalkdown scope.* This update provides the following:A revision of the original report (changes indicated bybracketed and italicized text)" New walkdown data related to the inaccessible scope -Attachment 5a to Enclosure la(this supplements Attachment 5 to Enclosure I from the November submittal)
" Documentation of the PEER review of the new walkdown data -Attachment 6a toEnclosure la (this supplements Attachment 6 to Enclosure 1 from the Novembersubmittal)]
: 1. Seismic Licensing BasisThe seismic design basis for SSCs at Oconee nuclear station are defined in Section 3.7 of theUFSAR. Due to the vintage of Oconee nuclear station, some seismic terminology is notconsistent with current terminology.
The Operating Basis earthquake (OBE) is also referred toas the Design Basis earthquake (DBE) and the Safe Shutdown earthquake (SSE) is alsoreferred to as the Maximum Hypothetical Earthquake (MHE).1.1. Response SpectraThe seismic spectrum response curves for Oconee were generated by the time historytechnique of seismic analysis.
The sample earthquake utilized is that recorded at El Centro,California, N-S, May 18, 1940. The Peak Ground Acceleration (PGA) for the Design Basisearthquake (DBE) is 0.05g. The PGA for the Maximum Hypothetical earthquake (MHE) forClass 1 Structures founded on rock is 0.1g. The PGA for the Maximum Hypothetical Earthquake (MHE) for Class 1 Structures founded on overburden is 0.15g.Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Page 2 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report1.2. Seismic Qualification 1.2.1. Seismic Qualification of Safety-Related Mechanical Equipment When the response spectra at each elevation in the building have been determined, theg-loadings imposed on a component may then be determined.
These loads areevaluated by the equipment supplier and in the case of complex components such asheat exchangers, the design calculations performed by the supplier are reviewed byB&W Engineering or Duke Energy, as applicable.
The supplier has the freedom to useeither of two alternate analytical methods to evaluate the equipment or he may chooseto test it. Components maybe tested by either shaker or impact tests or a certification ofthe test results are required.
In a few cases, a manufacturer's certification that theequipment would withstand seismic conditions is acceptable based on tests of similarequipment, an example of this would be similar type pumps. Analytically the evaluation can be made by calculating the natural frequency of the component, entering theappropriate damping curve and determining the amplification factor from the responsespectrum curve. The equipment is then evaluated using these g-loadings.
As analternative, the component may be evaluated without calculating the natural frequency by using the peak amplification factor from the appropriate damping curve to determine the equipment loads. This latter approach is conservative.
Special attention is given tofoundation and nozzle loadings for equipment such as tanks, pumps, heat exchangers, demineralizers and filters.
Loads imposed by connecting piping on a given component are included and in some cases, component nozzles have had to be reinforced toaccommodate these loads. Components which are most likely to require specialreinforcement due to seismic loads, are long, horizontal, saddle mounted tanks, verticaltanks, mounted on legs, and stacked heat exchangers.
These have all been evaluated and appropriately designed for the seismic conditions.
An alternate method of seismicqualification for mechanical equipment (within the applicable equipment classes) wouldbe an experience based approach.
Seismic adequacy can be established using methodsdescribed in the Generic Implementation Procedure (GIP) for Seismic Verification ofNuclear Plant Equipment, Revision 3A, developed by the Seismic Qualification UtilityGroup (SQUG). This method is also commonly known as SQUG.1.2.2. Seismic Qualification of Safety-Related Electrical Equipment The seismic design basis for instrumentation and electrical equipment is that theelectrical devices considered essential in performing Reactor Protection and Engineered Safeguards functions and in providing emergency power shall be designed to assurethat they will not lose their capability to perform intended safety functions during andfollowing the Safe Shutdown Earthquake (SSE). This basic criterion has remainedunchanged since the issuance of the operating license;
: however, the seismicqualification techniques and documentation requirements for various plant modifications have in many instances followed the advances in the state of the art.The seismic adequacy of all electrical cable tray supports is established by the methodsand criteria established for cable tray supports in the Generic Implementation Procedure (GIP-3A) for Seismic Verification of Nuclear Plant Equipment, Rev 3A, developed by theSeismic Qualification Utility Group (SQUG).In order to meet the seismic design objectives defined in UFSAR Section 3.10.1, thefollowing seismic evaluation methods were employed consistent with the applicable licensing commitment.
TestingAttachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Page 3 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportDevices may be qualified by either shaker or impact tests. A certification of the testresults or copies of the test results are required.
Additionally, a manufacturer's certification that a certain type of equipment would withstand the seismic conditions isacceptable based on previous testing/experience with similar equipment.
AnalysisDevices may also be qualified by analytical methods.
For example, one evaluation method involves calculating/determining the natural frequency of the device, entering theappropriate response spectra damping curves, and determining the corresponding amplification factor. The device is then evaluated using this "g" loading value.Alternatively, the devices may be evaluated without calculating/determining its naturalfrequency by using the peak amplification factor from the appropriate response spectradamping curve to determine the "g" loading.An alternate method of seismic qualification for electrical equipment (within theapplicable equipment classes) would be an experience based approach.
Seismicadequacy can be established using methods described in the Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant Equipment, Revision 3A,developed by the Seismic Qualification Utility Group (SQUG). This method is alsocommonly known as SQUG.1.3. Response to generic letter 87-02Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating
: Reactors, Unresolved Safety Issue (USI) A-46," was issuedbecause the NRC concluded that the seismic adequacy of certain equipment in operating plants must be reviewed against seismic criteria developed during the resolution ofUnresolved Safety Issue (USI) A-46.The NRC determined that it is not feasible to require older operating plants to meet newlicensing requirements that were not in use when plants were licensed.
Therefore, analternative method was selected to verify the seismic capability of equipment.
Thisalternative method used a compilation of existing earthquake experience data supplemented by test data as the basis to verify the seismic capability of equipment.
Generic Letter 87-02allowed the seismic verification to be accomplished by utilities through a generic program,and the Seismic Qualification Utility Group (SQUG) was formed. The SQUG developed aGeneric Implementation Procedure (GIP) that documents the seismic verification process,procedures, and methodologies for verifying the seismic qualification of equipment andresolving USI A-46. Supplement 1 of Generic Letter 87-02 endorsed use of the GIP for theseismic qualification process and contained revised licensee actions.
Oconee performed theseismic qualification process in accordance with the NRC enforced version of the GIP. In aSafety Evaluation Report, the NRC concluded that Oconee met the purpose and intent ofthe seismic qualification process and that the corrective actions and modifications providesufficient basis to close the USI A-46 review at Oconee.The seismic verification process is considered part of the seismic licensing basis forOconee, so the seismic qualification criteria developed by the SQUG in response to GenericLetter 87-02 must be considered during mechanical and electrical equipment modifications Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Page 4 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report1.4. Codes and Standards The following codes, standards, and specifications were used during the design,construction, testing and in-service inspection of Class 1 Structures:
* ASME-1965
-Boiler and Pressure Vessel Code, Sections III, VIII, and IX* AISC -Steel Construction Manual, 6th ed" Regulatory Guide 1.92, Combining Responses And Spatial Components In SeismicResponse
: Analysis, Revision 1, February 1976* Regulatory Guide 1.29, Seismic Design Classification, Revision 3, September 1978* Supplement No. 1 To Generic Letter (GL) 87-02 That Transmits Supplemental SafetyEvaluation Report NO.2 (SSER NO. 2) On SQUG Generic Implementation Procedure Revision 2, As Correction On February 14, 1992 (GIP-2),
May 22, 1992* NRC Letter To SQUG Dated December 4, 1997. Supplemental Safety Evaluation Report NO. 3 (SSER NO. 3) On The Review Of Revision 3 To The GenericImplementation Procedure For Seismic Verification Of Nuclear Power PlantEquipment, Updated 5/16/97 (GIP-3)* NRC Letter To SQUG Dated 6/23/99, Review Of Seismic Qualification Utility Group'sReport on the use of Generic Implementation Procedure for New and Replacement Equipment and PartsAttachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 1OCFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Page 5 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report2. Personnel Qualifications The personnel involved in the Oconee NTTF Recommendation 2.3 Seismic Walkdown effortmet the qualification requirements of EPRI 1025286.
The personnel responsibilities andqualifications are outlined in TABLE 2.1 below. (Note: PE=Professional
: Engineer, CLB=Current License Basis, SWEL= Seismic Walkdown Equipment List)Table 2.1DereYears of RelevantE
>Personnel Degree 0.oo 0...t°Experience Qualifications E V ,,_I .2 -________~~
______ ______ 0~ (fl U 0Russell Childs PE, SCEW", SWE'z), X(3)(Duke Energy) BS/Civil Engineerng 30 IPEEE(t) /X] XRay Mc Coy BS/Civil Engineering 32 PE,SCE(1) X(DukeEnergy)__________
Bob Hester BS/Civil Engineering 36 PE,SCE(l)
X(Duke Energy)Paul Mabry BS/Nuclear 27 SRO(4), STA(5) X(Duke Energy) Engineering Tommy Loflin AS/Electrical 35+ SRO(4) X(Duke Energy) Engineering Jim Weir BS/Mechanical 31 SWE'(Duke Energy) Engineering SFC SYS ENGCharles M.Conselman BS/Civil Engineering 28 PE,SCE(1), SWE (2) X(3)(ARES)James White BS/Civil Engineering 42 PE,SCE(1), SWE (2) X(3)(ARES)John North BS/Civil Engineering 28 PE,SWE(2)
X(3)(ARES)Mike Donnelly BS/Civil Engineering 4 SWE(2) X(ARES) ________Anthony Fazio BS/Chemical 40+ SWE(2) X(Shaw) Engineering John Spizuoco BS/Mechanical 44 PE,SCE(l),
SWE(2) X(Shaw) Engineering Arthur Richert BS/Mechanical 32 PE,SWE(2)
X(Shaw) Engineering Paul Baughman BS/Civil Engineering
>40 PE,SCE(l),
SWE (2) )X3)(ARES)George Bushnell BS/Mechanical
>40 PE,SCE(l),
SWE (2) X(Shaw) Engineering Robert L. Keiser MS/Civil Engineering
>20 PE,SCE(l),
SWE (2) X(Duke Energy)Adam Johnson MS/Civil Engineering 3+ SCE(1) p](Duke Energy) IIINOTES:1) Seismic Capability Engineers (SCEs) who have successfully completed EPRI Experience Based Seismic Evaluation training.
: 2) Seismic Walkdown Engineers (SWEs) have successfully completed EPRI 1025286 2 day walkdown training course.3) Senior Team Member.4) Prior Senior Reactor Operator (SRO).5) Prior Shift Technical Advisor6) IPEEE seismic Walkdown Coordinator and current A-46/IPEE Program Owner (SQUG)Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under IOCFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Page 6 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report3. Selection of SSCsThe Oconee Unit 1 SWEL-1 and SWEL-2 equipment selection was performed in accordance with the EPRI guidance outlined in EPRI Technical Report #1025286.
SWEL-1 represents asample of items to safely shut down the reactor and maintain containment integrity.
SWEL-2represents spent fuel pool related items.The Oconee USI A-46/IPEEE Safe Shutdown Equipment List (SSEL) was used as the basis forthe Base-1 equipment list. The scope of the Seismic Walkdown Equipment List (SWEL) islimited to SSCs that are classified as Seismic Category I. This is done such that items have adefined seismic licensing basis against which to evaluate the as-installed configuration.
Oconeeis a USI A-46 plant. The purpose of the USI A-46 program was to verify the seismic adequacy ofessential equipment in older operating plants that had not been qualified in accordance withmore recent criteria.
Many of the SSC's listed in the USI A-46/IPEEE Safe Shut downEquipment List (SSEL) are not category I. However, Oconee programmatically maintains theseismic capability of these components.
Therefore, for the purpose of developing the SWEL allUSI A-46/IPEEE components are considered to have a seismic licensing basis.The A-46/IPEEE SSEL effectively represents the output of EPRI guidance equipment Screening criteria's
#1, #2 and #3. The underlying data used to generate the Base-1 list is contained in anACCESS database.
This ACCESS database was used to generate the Base-1 Equipment Listfrom which the SWEL-1 was selected.
The equipment comprising the Base-1 equipment list iscontained in Attachment
: 1. Their individual Safety Function is identified as shown below. Somecomponents support more than one safety function.
A. Reactor reactivity controlB. Reactor coolant pressure controlC. Reactor coolant inventory controlD. Decay heat removalE. Containment functionThe Base-1 Equipment List is comprised of 2264 components from Oconee Units 1, 2 & 3 &components that support all 3 Units (Common).
The Base-1 Equipment list is contained inAttachment 1.3.1. SWEL-1 Development EPRI TN- 025286 specifies that the SWEL-1 should be comprised of between 90-120components and that each unit should have its own individual SWEL-I.357 of the Base-1 components are Common components that support all 3 units. In order toaccount for these common components,
-10% (39 items) of the base-1 commoncomponents were selected as SWEL-1 components.
All of the 39 common components areconsidered to be part of each individual unit's SWEL-1.The Unit 1 SWEL-1 consists of 131 components.
Of these 131 components, 39 are commoncomponents which are also represented in each individual unit's SWEL-1. Attachment 2contains the SWEL-1 components for Unit 1. The criteria for selection of equipment to beincluded in the SWEL are described in EPRI TN-1025286 section 3.Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)
Page 7 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportScreen #4 -- Sample Considerations
-Five sample selection attributes that should be represented in SWEL 1:* A variety of types of systems" Major new and replacement equipment
" A variety of types of equipment
" A variety of environments
" Equipment enhanced due to vulnerabilities identified during the IPEEE programIn addition to the five sample considerations listed above, the equipment selected for theSWEL-1 should include considerations of the contribution to Risk for the SSC's and shouldalso include a review by appropriate Operations personnel.
SWEL-1 Systems -The SWEL-1 equipment list represents 26 systems associated with the 5 safety functions.
SWEL-1 Types of Equipment
-The SWEL-1 list contains representative equipment from all equipment classes with thefollowing exceptions:
" There are no equipment Class 11 (Chillers),
Class 12 (Air Compressors),
or Class 13(Motor -Generators) components on the Unit 1 SWEL-1 list because they are notrepresented in the Base-1 list.* There are no equipment Class 17 (Engine -Generators) components on the Unit 1SWEL-1. The Standby Shutdown Facility (SSF) Diesel Engine (16 Cylinder)
(OSSFDEOOOA) is listed on the Base-1 list. However, it was not selected as part of theSWEL-1 due to its inherently robust nature and the very low seismic input at its location.
SWEL-1 Equipment locations
-The SWEL-1 equipment list includes equipment located in a broad variety of areas andenvironments.
These areas comprise multiple buildings and elevations and includeequipment located both inside and outside.
The equipment areas provide a broad range ofequipment environmental conditions, which include:* Mild environmental conditions with limited temperature and humidity variations (e.g.Control Room, Cable Rooms, Equipment Rooms, SSF Electrical Room, Relay House,etc.)" Moderate environmental conditions (e.g. general areas of the Auxiliary
: Building, East &West Penetration Rooms, SSF Diesel Room, SSF Battery Room, Control RoomVentilation Rooms, etc.)* Moderate to harsh environmental conditions (e.g. LPI/BS/HPI Pump Rooms, LPI CoolerRoom, etc.)" Harsh environmental conditions (e.g. Inside RB Containment, etc.)." Partial exposure to outdoor environmental conditions (e.g. Switchyard, Intake Structure)
" Wet environments (Keowee Turbine Wheel Pit)Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 1OCFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Page 8 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportSWEL-1 Major New and Replacement Equipment
-In order to capture significant new and replacement equipment on the SWEL-1, a query waswritten which related the Base-1 equipment list to underlying data supporting Engineering Changes in the Duke Energy Nuclear Asset Suite Software (NAS). By doing this, a list EC'sassociated with all components on the Base-1 equipment list was generated.
Editorial andminor modifications were then filtered out of the list. The following New and Replacement Equipment have been included in the Unit I SWEL-I.1ASPT0117P AUX STEAM PRESSURETRANSMITTER (MS-126 & MS-129)ECO000099571 REPLACE OBSOLETE MOORE 352 CONTROLLER 1ASSS0017 WITH A SIEMENS 353 CONTROLLER 0Di002i9
-(REFURB)
DIGITAL CONTROL ROD1CRDCACC1 DCRDCS CONTROL CABINET CC-i ECO000078244 DRIVE CONTROL SOEDRIVE CONTROL SYSTEMNSM ON-13053/OO/OO/ALi
-(REFURB)1ELCASGLC1 STEAM GEN LOGIC CABINET EC0000068112 ATM FEEDWATER ISOLA Y (AFIS)AUTOMATIC FEEDWATER ISOLATION SYS (AFIS)0D50146i
-UNIT 1 & 2 SFP LEVEL INTERLOCK 1ELIRPIR UNIT 1 PNEUMATIC INSTR RACK EC0000093683 SINGLE FIURESINGLE FAILURE1ELPLPZRIB 600V PPB 1B (FOR PRESSURIZER EC0000106356 REPLACE 70 A AND 225 A PZR HTR BREAKERS INHEATERS GROUP 1B, BANK 2) REACTOR BUILDING WITH 80 A FUSESREPLACE AGASTAT 2432ABB WITH AGASTATiELTFOCT1 XFMR CT-i EC0000100369 70AB7032ABB0D100076
-(REFURB)
UNIT 1 INST LOOP1HPIFTOOO7A HPI A TRAIN INJ FLOW TRANS EC0000089821 UDES A NEW CRSUPGRADES AND NEW CRS0D100076
-(REFURB)
UNIT 1 INST LOOP11CCCA0001A UNIT 1 ICCM TRAIN A CABINET EC0000089821 UDES A NEW CRSUPGRADES AND NEW CRSLPI TRAIN 1B INJ FLOW TRANS OD100076
-(REFURB)
UNIT 1 INST LOOP1LPIFT0004P EC0000089821 UGAE N E R(Powered by ICCM) UPGRADES AND NEW CRSLPI COOLER 1A FLOW XMTR OE400391
-DETERMINE REPLACEMENT FORiLPSFT0i24 EC0000080263 ROE UNiiiTP(1iLPSW-251)
ROSEMOUNT 1151 TYPE J(EC90482)
(REFURB)
UNIT 1 RPS REPLACEMENT iPPSCAO005 RPS C/ES C1 EC0000090482 MODIFICATION OD100066
-(REFURB)
UNIT 1 ESFASPPSCAO9REPLACEMENT MODIFICATION OD100066
-(REFURB)
UNIT 1 ESFASREPLACEMENT MODIFICATION 0D100066
-(REFURB)
UNIT i ESFASiPPSCAO018 ES STATUS EVEN EC0000090423 RPAEETMDFCTO 0D100076
-(REFURB)
UNIT 1 INST LOOP1RCLTOOO4P1 PRZ LEVEL TRANSMITTER ECO000089821 UPGRADES A NEW CRSUPGRADES AND NEW CRS0Di006i3
-REPLACE SSF CONTROL CONSOLE1RCPT0226 Ui RC LOOP B PRESSURE EC0000090682 IDICATOR A RCS PTNI AINDICATORS AND RCS PTS1VSAH0011 I AHU-11 CONTROL ROOM A/C EC0000100110 REPLACE UNIT 1&2 CONTROL ROOM AHU 1-11Oconee revised the modification process at the completion of the A-46/IPEEE programs torequire plant modifications to evaluate impact to A-46/IPEEE components to ensure that theseismic capability of A-46/IPEEE components was not degraded.
Current site projects such as Protected Service Water (PSW) which are not operational andnot currently credited within the Current Licensing Basis (CLB) of Oconee are not within thescope of the SWEL-1.Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(dXl)
(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)
Page 9 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportSWEL-1 Equipment Enhanced per IPEEE -Significant IPEEE enhancements associated with the Base-1 equipment list as reported inthe IPEEE submittal dated 12/15/1997 were identified.
SWEL-1 SSCs were selected suchthat a sampling of SSCs which had been enhanced per IPEEE was included.
The following SWEL-1 SSCs were enhanced due to IPEEE.
LUN I KUL DUAKU IUUIL UNUt-1-W4.V Keiocaxe orawing SUCKS Iocaxeo oenino iuvz.240/120V 1A REGULATOR Install additional bracing to unistrut frame1ELBK1A OUTPUT BKR ONOE-14009 supportinglA/1B/SW, 1A/MCB, 1B/MCB, 1A/REG,OUTPUT__BKR_1B/REG, 1A/XFMR & 1B/XFMR1ELD11ADB ISOL DIODE ASSEMBLY 1ADB ONOE-12675 Install washer plates to three North anchors of1ADBWeld transformer section of Load Centers 1X04 to1ELLXIX4 600V IC lX04 ONOE-14369 emdedageembedded ang~le.Add shims under load center at anchors on North1ELLX1X9 600V LC 1X09 ONOE-13461 sieside.1ELMX1XC MCC 1XC ONOE-14370 Add back to back bolting to 1XC.1ELMXIXGB MCC 1XGB ONOE-14360 Add back to back bolting to the 3 South most baysof 1XGB1ELMX1XL MCC 1XL ONOE-14378 Add rigid support to cable tray above 1XL & 1XN inE-W direction.
1ELPL1DCA 125V DC 1DCA ONOE-12778 Replace back right anchor for 1DCA1ELPLPZR1B 600V PPB 1B (FOR PRESSURIZER ONOE-09290 Replace missing or broken door latch on PPB 1BHEATERS GROUP 1B BANK 2) and adjacent PPB 1A & 1D.1VSAH0011 AHU-11 CONTROL ROOM A/C ONOE-15560 Install lateral seismic restraint.
SWEL-1 RiskConsiderations
-EPRI TN-1 025286 requires that the development of SWEL 1 should include consideration ofthe importance of the contribution to risk for the SSCs.In response to IPEEE, Oconee utilized the results of seismic margin methodology walkdowns to enhance the existing seismic PRA. These results are documented inOSC-1 0225 "Seismic PRA/IPEEE Backup Calculations" and summarized in theSupplemental IPEEE submittal Report. From the conclusions presented in theSupplemental IPEEE submittal Report, PRA sequences involving loss of power and SSFresponse make up several of the most dominate PRA cut sets. SSC's supporting Keowee,the SSF, and the 230 KV switchyard are well represented in the SWEL-1.In addition, input was obtained from the General Office PRA group to determine a ranking ofthe most seismically risk significant components.
Of the 31 unscreened PRA events with a contribution to CDF of greater than 0%, 19 arerepresented in the combined SWEL-I's for Units 1, 2 & 3. This represents 61% of PRA risksignificant components and meets then intent of EPRI TN-1025286.
SWEL-1 Operations review -The SWEL-1 equipment listed was submitted to Oconee Operations for review asrecommended within EPRI TN-1025286.
Operations concurred with the equipment listed onthe SWEL-1 list. The SWEL-2 equipment list was developed within the Oconee Engineering organization by a highly experienced engineer who had previously held a Senior ReactorOperators License (SRO) and was previously an Operations Shift Technical Advisor (STA).Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under IOCFR 2.390(dXl)
(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)
Page 10 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report3.2. SWEL-2 Development The Oconee Unit 1 SWEL-2 spent fuel pool equipment list was developed in accordance with the EPRI guidance.
Seismic Category I structures, piping, and containment penetrations were specifically excluded by the EPRI guidance.
The four screening criteriaspecified were as follows:1) Seismic Category I or USI A-46 (SQUG) licensing bases,2) Spent Fuel Pool (SFP) equipment appropriate for an equipment walkdown process,3) Sample considerations represent broad population of equipment with considered sample selection attributes such as:a. represent a variety of systems,b. major new/replacement equipment,
: c. variety of equipment types,d. variety of environments
: 4) Equipment which could result in rapid drain down of the SFP (includes both seismicand non-seismic components and similar factors outlined in 3) above.The SWEL-2 equipment Base-2 (Attachment
: 3) was established based on screens #1 and#2 above. Equipment was selected from the Base-2 list based on screening criteria
#3above, and primarily included major equipment such as the spent fuel cooling systempumps, pump motor air handling units, and heat-exchangers.
The SWEL-2 list was further evaluated based on screening criteria
#4 above, to includeequipment which could result in SFP rapid drain-down, as defined by the EPRI guidance.
All three Oconee Unit's have SF Pool transfer tubes that open to the SF Pool in normaloperation.
The SSF RC Make-up and letdown lines penetrate into the SF Pool transfertubes. The SSF Make-up and Letdown lines meet Seismic Category
: 1. There were also SFPool discharge lines at valves SF22&50 and 3SF-22&50 that could meet the criteria for arapid drain down due to a siphon if the SF Cooling pump discharge piping, which meetsSeismic Category 1, were to fail outside the SF Pool. However, this vulnerability hadpreviously been identified and procedure requirements prevent system alignment andthereby remove this vulnerability.
For these reasons, there are no rapid draw down items onthe SWEL-2.The SWEL-2 components were selected based on their radiological accessibility.
Of the 3pumps identified in the SWEL-2 base list, 2 were included in the SWEL-2. Of the 7 Tanksidentified in the SWEL-2 base list, 4 were included in the SWEL-2. This sampling is inaccordance with EPRI TN-1025286.
The final SWEL-2 list is provided in Attachment 4.4. Seismic Walkdowns and Area Walk-Bys[Duke Energy contracted with the Shaw Group IARES Corporation team to perform the majorityof the NTTF 2.3 seismic walkdowns at Oconee Nuclear Station.
A summary report of theirwalkdowns along with the individual Seismic Walkdown Checklists (SWCs) and the Area Walk-By Checklists (AWCs) was designated as Attachment 5 to Enclosure 1.Duke Energy personnel have completed the walkdowns of the Unit I and common items foundto be inaccessible during the initial walkdowns.
These walkdown items are addressed belowAttachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 1OCFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Page 11 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Reportand their associated SWCs and AWCs for provided as Attachment 5a (to supplement Attachment 5 from the initial walkdown).
No new potential adverse conditions were identified.]
[OUTAGE RELATED COMPONENTS:]
SWEL-1 SSCs which could only be accessed during an outage will be walked down by DukeEnergy personnel and reported on at a later date. These SSCs are listed below.[Completion of walkdowns for these SSCs:The thirteen Unit I SSCs listed below required a unit shutdown to be accessible.
Walkdowns ofthese SSCs have been completed by Duke Energy personnel and the SWC & A WC forms arecontained in Attachment 5a.]-MSVA0006 MAIN STEAM SAFETY RELIEF Complete1 AB 1MSVA0010 MAIN STEAM SAFETY RELIEF Complete1 RB 1ELPLPZRlB 600V PPB 1B (FOR PRESSURIZER CompleteRB ____ELPLP
___R__ HEATERS GROUP 1B BANK 2)1 RB 1FDWLT0082 SG 1A LEVEL TRANSMITTER Complete1 RB 1HPIPU0005 SSF RC MAKEUP PUMP Complete1 RB 1RBCAH0020A RBCU FAN 1A Complete1 RB 1RBCHXOOODAUX AUX RBCU D Complete1 RB 1RCLT0004P1 PRZ LEVEL TRANSMITTER Complete1 RB 1RCPT0166P RCS LOOP B PRESS TRANS Complete1 RB 1RCPT0226 Ul RC LOOP B PRESSURE Complete1 RB 1RCRDOOO6A Al COLD LEG RTD Complete1 RB 1RCVA0066 PRZ PORV Complete1 RB 1RCVA0159 RV VENT ISOLATION CompleteInaccessible SSCs -[Unit 1 SSCs:] Several Unit I SSC's were inaccessible
[during the initial walkdowns]
due to theirphysical location or due to personnel safety concerns.
These items are listed below.[Completion of Inaccessible Unit I SSCs walkdowns:
Walkdowns for these SSC's have been completed by Duke Energy personnel, except as statedin the substitution section below. SWC & AWC forms are contained in Attachment 5a.]1 "TB 1ELLX1X4 600V LC 1X04 Complete4 AB ___________
_ 6Q0V-G4X9 Substituted by component below[1] [AB) [IELLXIXS) f600V LC 1X08) Complete1 AB 1VSAHOO11 AHU-11 CONTROL ROOM A/C Complete[Substitution
-* 1ELLX1X9 (600V LC 1X09) replaced with 1ELLXIX8 (600V LC 1X08)A portion of the anchorage for one of the selected SSCs remained inaccessible unless both highenergy protective clothing and anti-contamination clothing were used. Due to this personnel safety concern, a more accessible SSC was substituted, as allowed by EPRI 1025286.
Thissubstitution does not affect the equipment sample considerations discussed in Section 3.1.]Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under IOCFR 2.390(dX)1)
(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)
Page 12 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report[Common SSCs:] The anchorage for one SSC was originally only partially visible due to some ofthe welds being covered by mortar spillage from an adjacent masonry wall. This Item andseveral other inaccessible items listed below are common to all 3 units[Completion of Inaccessible Common SSCs walkdowns:
Walkdowns for these SSC's have been completed by Duke Energy personnel, except as statedin the substitution section below. SWC & AWC forms are contained in Attachment 5a.10 SYD OSYDPLSYDC1 SWITCHYARD DISTRIBUTION CENTER 1 CompleteN4- WE SPEED Cr TR, L NAANTI' PIKUP &A Substituted by component below[Ku] [KEO] [KIGBOLS63TB]
[TURB GUIDE BRNG OIL LEVEL SWITCH] CompleteK2 KEO K2ELKTNO203 TERM BOX TB-203 CompleteIQ Y" 926AWXQ GEN AIR COOLER 3 Substituted by component below[K1] [KEO] [K2WLVAO011]
[GEN COOL ISOL VALVE] CompleteK2 KEO K2HPOPU88HA AC GEN HP LIFT PUMP (88HA)K2 KEO K2TSLS63SB TURB SUMP LEVEL SWITCH (2TSLS0002)
Complete[Substitution
-" K1PMGDTMPU1A (SPEED CONTROL MAGNETIC PICKUP 1A) replaced with K1GBOLS63TB (TURBGUIDE BRNG OIL LEVEL SWITCH)* K2GAHXO003 (GEN AIR COOLER 3) replaced with K2WL VAO011 (GEN COOL ISOL VALVE)Two of the above SSC's were located within the generator housing.
Duke Energy engineers performing the walkdowns did not possess the appropriate qualifications to enter the generator housing.
Therefore, a more accessible SSC was substituted, as allowed by EPRI 1025286.This substitution does not affect the equipment sample considerations discussed in Section 3.1.]5. Licensing Basis Evaluations A total of 17 potential adverse conditions were identified per the Seismic Walkdowns and theArea walk-bys.
All of these potential issues were entered into the Corrective Action Program(CAP). All potential adverse conditions were evaluated for their compliance with the seismiclicensing basis within the CAP and were found to be acceptable.
Station Work Requests werewritten for some conditions as good practice.
The potentially adverse conditions and theirindividual Problem Investigation process (PIP) tracking numbers are listed in the NTTF 2.3Seismic Walkdown Report for Unit 1 contained in Attachment
: 5. [Attachment 5a of this updatereport adds the walkdown results for the previously in-accessible components for Unit I andCommon SSCs, no new potential adverse conditions were identified.]
: 6. IPEEE Vulnerabilities Resolution ReportOconee submitted its response to IPEEE on 12/21/1995
& 12/15/1997.
In those submittals, Oconee stated that there were no underlying significant sequences (vulnerabilities) fromexternal events. There were also no plant changes identified that would significantly reduce riskfrom external events.Table 6-1 of the IPEEE Submittal dated 12/15/1997 listed 152 enhancements.
Theenhancements identified have been completed by either Station Work Request, PlantModification, or Analysis.
Oconee is a USI A-46 plant and performed the USI A-46 walkdowns in conjunction with theIPEEE walkdowns.
In Oconee's letter to the NRC dated 9/12/2002, Oconee confirmed thatoutliers associated with Generic Letter 87-02 (USI A-46) have been completed.
OconeeAttachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(dXl)
(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)
Page 13 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Reportperformed the USI A-46 seismic evaluations in conjunction with the IPEEE evaluations.
Thecriteria for both programs were conservatively enveloped such that an evaluation of a givencomponent would address all aspects of both programs.
IPEEE enhancements are a subset ofthe overall USI A-46 outliers.
Therefore, implementation of the IPEEE enhancements isconfirmed by the 9/12/2002 SQUG Outlier Resolution Completion Notice.7. Peer ReviewDuke Energy (Duke) contracted with the Shaw Group (Shaw) / ARES Corporation (ARES)Team to perform the NTTF 2.3 peer review at the Oconee Nuclear Station (ONS). The PeerReview Report [accessible components from the initial walkdown]
is contained in Attachment 6.[A supplemental Peer Review Report (Attachment
: 7) was performed for this report update, andthe walkdown results completed by Duke Energy personnel, of the Unit I and Common SSCsthat were inaccessible during the initial report.]The Peer Review Team consisted of three individuals (refer to table 2-2), all of whom haveseismic engineering experience as it applies to nuclear power plants. These individuals participated in the peer review of each of the activities.
The members of the Peer review teamand their qualifications are listed in table 2.1Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)
Page 14 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportThe Peer Review team concluded that the methodology utilized conforms to the guidance inSection 6 of EPRI 1025286.
The peer review covered the following:
" The selection of the SSCs included on the Seismic Walkdown Equipment List (SWEL).* A sample of the checklists prepared for the seismic walkdowns and area walk-bys.
" The licensing basis evaluations.
" The decisions for entering the potentially adverse conditions in the Corrective ActionProgram (CAP) process." The submittal report.The peer review process for the SWEL development and the seismic walkdowns consisted ofthe following:
* Reviewing the activity guidance in EPRI 1025286, the NEI Q&A bulletins, the NEI first-mover reports, and NRC Temporary Instruction 2515/188.
" Conducting an in-process review at the plant site, including interviews with the personnel performing the activity and reviewing in-process documentation.
* Performing an in-plant surveillance (for the walkdown activity) of a seismic walkdownand an area walk-by." Providing in-process observations and comments to the personnel performing theactivities.
" Conducting a final review of a sample of the completed documentation.
The peer review process for the licensing basis evaluations and the decisions for enteringpotentially adverse conditions into the CAP consisted of reviewing the overall review processand the licensing basis reviews.
The peer review process for the submittal report consisted ofreviewing the draft submittal prepared by Oconee Design Engineering for licensing review.The conclusion of the peer reviews for both the initially accessible and the initially inaccessible components is that the ONS NTTF 2.3 seismic walkdown effort has been conducted inaccordance with the guidance in EPRI 1025286.
Comments made during the in-process reviewof the SWEL development and the walkdowns have been addressed satisfactorily.
In-process comments on the final walkdown
: reports, the licensing basis reviews, and the submittal havealso been resolvedAttachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 1OCFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)
Page 15 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report
==REFERENCES:==
: 1) UFSAR Section 3.2.1 Seismic Classification (Rev. 21)2) UFSAR Section 2.5.1.2 Site Geology (Rev. 21)3) UFSAR Sections 2.5.2.10, 2.5.2.11 SSE/OBE (Rev. 21)4) UFSAR Section 3.7 Seismic Design (Rev. 21)5) EPRI Report 1025286, Dated May 2012, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force (NTTF) Recommendation 2.3 (ATTACHMENT 1).6) Oconee NRC Response to GL 88-20, Individual Plant Examination of External Events (IPEEE)Submittal, dated Dec. 18, 1997, W. R. McCollum Jr. to NRC.7) 7/9/12 correspondence to NRC from Ben C. Waldrep, "Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)
Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" ATTACHMENTS:
[The attachments listed below were attachments to Enclosure 1 as transmitted via the initial submittal dated 11/27/2012.
These attachments are not included with this updated submittal (Enclosure la).]1) Oconee Unit 1 SWEL-1 Base-1 List2) Oconee Unit 1 SWEL-13) Oconee Unit 1 SWEL-2 Base-2 List and Rapid Drain Down List4) Oconee Unit 1 SWEL-25) Seismic Walkdown Summary Report and Checklists
: 6) PEER Review Summary Report[The following Attachments are included as part of this report update (Enclosure la)5a) Seismic Walkdown Checklists (SWCs) and Area Walk-by Checklists (A WCs) for Initially Inaccessible Components (These data sheets supplement the information in Attachment 5 of the initial report)7) PEER Review Summary Report for walkdowns associated with Attachment 5a]Attachment 5a Contains Security-Sensitive Information
-Withhold From Public Disclosure under 10CFR 2.390(d)(1)
(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)
Page 16 of 16}}

Revision as of 22:45, 4 July 2018

Oconee Nuclear Station Units 1, 2 & 3 - Update to Seismic Walkdown Information Submitted in November 27, 2012
ML13192A155
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 07/01/2013
From: Batson S L
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13192A155 (19)


Text

DUKESco L. BatsonDUKE Vice President ENERGYao446)ENE G~eOconee Nuclear StationDuke EnergyONO1VP 1 7800 Rochester HwySeneca, SC 29672o: 864.873.3274 F. 864.873.4208 Scott.Batson@duke-energy.com July 1, 2013 10 CFR 50.54(f)U. S. Nuclear Regulatory Commission (NRC)ATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852

Subject:

Duke Energy Carolinas, LLC (Duke Energy)Oconee Nuclear Station (ONS), Units 1, 2 and 3Docket Nos. 50-269, 50-270, and 50-287ONS Unit 1 Update to the ONS Seismic Walkdown Information Submitted November 27, 2012 (Reference 3 below).

Reference:

1) NRC Letter, Request for Information Pursuant to Title 10 of the Code of FederalRegulations 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, datedMarch 12, 20122) EPRI 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, Final, dated June 20123) Duke Energy Letter to NRC, Seismic Walkdown Information Requested by NRCLetter...,

dated November 27, 2012The NRC staff issued a Request for Information (Reference

1) on March 12, 2012. In responseto Recommendation 2.3 of that request, Duke Energy submitted Seismic Walkdown information for Oconee Nuclear Station (ONS). The information submitted followed an NRC endorsedindustry guideline, EPRI 1025286 (Reference 2).The EPRI guidance recognized that the walkdown scope would not be fully completed due toinaccessibility of some of the components initially selected.

Therefore, a provision in theguideline allowed for the inaccessible items to be completed at a later date. A list ofinaccessible components and a schedule for completing the walkdown scope was included inthe November 27, 2012 submittal (Reference 3). This submittal provides an update to theUnit 1 walkdown report (designated as Enclosure 1 of Reference 3).The update is designated as Enclosure Ia to this submittal.

It revises text in the body of thereport, and provides new attachments documents the walkdown data for the completed scope,and an associated Peer Review Report. This update can be combined with Enclosure 1 fromReference 3 to compose a final walkdown report for ONS Unit 1.This update satisfies Commitment No. 1 in Reference 3 by addressing inaccessible equipment associated with ONS Unit 1 and equipment common to all three units.Attachment 5a to Enclosure la contains Security-Sensitive Information

-Dwithhold from public disclosure pursuant to 10 CFR 2.390(d)(1)

(Upon removal of Attachment 5a, Enclosure 1 a and the letter becomes uncontrolled; upon removal of Enclosure 1 a the letter becomes uncontrolled)

United States Nuclear Regulatory Commission First Update to Seismic Walkdown ReportJuly 1, 2013Page 2Enclosure la includes Attachment 5a, which contains Security-Sensitive information.

Attachment 5a is requested to be withheld from public disclosure in accordance with 10CFR2.390(d)(1).

Should you have any questions concerning this letter, or require additional information, pleasecontact David Haile at (864) 873-4742.

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

Executed onJuly 1, 2013.Sincerely, Scott L. Batson, Vice President, Oconee Nuclear StationEnclosure I a -Update to Unit 1 Seismic Walkdown Report -NRC 50.54 (f) NTTF Recommendation 2.3Attachment 5a to Enclosure la contains Security-Sensitive Information

-withhold from public disclosure pursuant to 10 CFR 2.390(d)(1)

(Upon removal of Attachment 5a, Enclosure 1 a and the letter becomes uncontrolled; upon removal of Enclosure 1 a the letter becomes uncontrolled)

United States Nuclear Regulatory Commission Seismic Walkdown ReportJuly 1, 2013Page 3xc:Mr. Victor M. McCree, Administrator, Region IIU.S. Nuclear Regulatory Commission Marquis One Tower245 Peachtree Center Ave., NE, Suite 1200Atlanta, GA 30303-1257 Mr. Eric J. Leeds, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 13-H16M11555 Rockville PikeRockville, MD 20852-2738 Mr. John P. Boska, Project Manager (ONS)(By electronic mail only)U. S. Nuclear Regulatory Commission One White Flint North, M/S O-8G9A11555 Rockville PikeRockville, MD 20852Mr. Ed CroweNRC Senior Resident Inspector Oconee Nuclear Station Update to Oconee Unit 1Seismic Walkdown ReportJuly 1, 2013Enclosure la(Update to Enclosure I from November 27, 2012 Submittal)

Update to Unit 1 Seismic Walkdown ReportAttachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Enclosure laUpdate to Unit 1 Seismic Walkdown ReportExecutive SummaryElectric Power Research Institute (EPRI) Report 1025286, Seismic Walkdown Guidance forResolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic was issued inJune 2012. This Document provides guidance and procedures to perform seismic walkdowns asrequired by the U.S. Nuclear Regulatory Commission's (NRC's) 50.54(f) letter regarding Near-Term Task Force (NTTF) Recommendation 2.3: Seismic.

The EPRI guidance covers selection of personnel; selection of a sample of structures,

systems, and components (SSCs) thatrepresent diversity of component types and assures inclusion of components from criticalsystems / functions; conduct of the walkdowns; evaluation of potentially adverse conditions against the plant seismic licensing basis; and reporting requirements.

It also includes check liststo be used by the Seismic Walkdown Engineers (SWEs) in performing the seismic walkdowns and walk-bys.

Duke Energy committed to implement resolution of Near-Term Task Force(NTTF) Recommendation 2.3: Seismic using EPRI Report 1025286 in a letter to the NRC dated7/9/2012.

[ONS made a previous submittal, dated November 27, 2012, which documented thewalkdown results for accessible components, designated as Enclosure I to the Novembersubmittal.

This is an update to Enclosure I (designated as Enclosure Ia) which will addressthe inaccessible components.

This additional data completes the ONS Unit lwalkdown scope.* This update provides the following:A revision of the original report (changes indicated bybracketed and italicized text)" New walkdown data related to the inaccessible scope -Attachment 5a to Enclosure la(this supplements Attachment 5 to Enclosure I from the November submittal)

" Documentation of the PEER review of the new walkdown data -Attachment 6a toEnclosure la (this supplements Attachment 6 to Enclosure 1 from the Novembersubmittal)]

1. Seismic Licensing BasisThe seismic design basis for SSCs at Oconee nuclear station are defined in Section 3.7 of theUFSAR. Due to the vintage of Oconee nuclear station, some seismic terminology is notconsistent with current terminology.

The Operating Basis earthquake (OBE) is also referred toas the Design Basis earthquake (DBE) and the Safe Shutdown earthquake (SSE) is alsoreferred to as the Maximum Hypothetical Earthquake (MHE).1.1. Response SpectraThe seismic spectrum response curves for Oconee were generated by the time historytechnique of seismic analysis.

The sample earthquake utilized is that recorded at El Centro,California, N-S, May 18, 1940. The Peak Ground Acceleration (PGA) for the Design Basisearthquake (DBE) is 0.05g. The PGA for the Maximum Hypothetical earthquake (MHE) forClass 1 Structures founded on rock is 0.1g. The PGA for the Maximum Hypothetical Earthquake (MHE) for Class 1 Structures founded on overburden is 0.15g.Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Page 2 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report1.2. Seismic Qualification 1.2.1. Seismic Qualification of Safety-Related Mechanical Equipment When the response spectra at each elevation in the building have been determined, theg-loadings imposed on a component may then be determined.

These loads areevaluated by the equipment supplier and in the case of complex components such asheat exchangers, the design calculations performed by the supplier are reviewed byB&W Engineering or Duke Energy, as applicable.

The supplier has the freedom to useeither of two alternate analytical methods to evaluate the equipment or he may chooseto test it. Components maybe tested by either shaker or impact tests or a certification ofthe test results are required.

In a few cases, a manufacturer's certification that theequipment would withstand seismic conditions is acceptable based on tests of similarequipment, an example of this would be similar type pumps. Analytically the evaluation can be made by calculating the natural frequency of the component, entering theappropriate damping curve and determining the amplification factor from the responsespectrum curve. The equipment is then evaluated using these g-loadings.

As analternative, the component may be evaluated without calculating the natural frequency by using the peak amplification factor from the appropriate damping curve to determine the equipment loads. This latter approach is conservative.

Special attention is given tofoundation and nozzle loadings for equipment such as tanks, pumps, heat exchangers, demineralizers and filters.

Loads imposed by connecting piping on a given component are included and in some cases, component nozzles have had to be reinforced toaccommodate these loads. Components which are most likely to require specialreinforcement due to seismic loads, are long, horizontal, saddle mounted tanks, verticaltanks, mounted on legs, and stacked heat exchangers.

These have all been evaluated and appropriately designed for the seismic conditions.

An alternate method of seismicqualification for mechanical equipment (within the applicable equipment classes) wouldbe an experience based approach.

Seismic adequacy can be established using methodsdescribed in the Generic Implementation Procedure (GIP) for Seismic Verification ofNuclear Plant Equipment, Revision 3A, developed by the Seismic Qualification UtilityGroup (SQUG). This method is also commonly known as SQUG.1.2.2. Seismic Qualification of Safety-Related Electrical Equipment The seismic design basis for instrumentation and electrical equipment is that theelectrical devices considered essential in performing Reactor Protection and Engineered Safeguards functions and in providing emergency power shall be designed to assurethat they will not lose their capability to perform intended safety functions during andfollowing the Safe Shutdown Earthquake (SSE). This basic criterion has remainedunchanged since the issuance of the operating license;

however, the seismicqualification techniques and documentation requirements for various plant modifications have in many instances followed the advances in the state of the art.The seismic adequacy of all electrical cable tray supports is established by the methodsand criteria established for cable tray supports in the Generic Implementation Procedure (GIP-3A) for Seismic Verification of Nuclear Plant Equipment, Rev 3A, developed by theSeismic Qualification Utility Group (SQUG).In order to meet the seismic design objectives defined in UFSAR Section 3.10.1, thefollowing seismic evaluation methods were employed consistent with the applicable licensing commitment.

TestingAttachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Page 3 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportDevices may be qualified by either shaker or impact tests. A certification of the testresults or copies of the test results are required.

Additionally, a manufacturer's certification that a certain type of equipment would withstand the seismic conditions isacceptable based on previous testing/experience with similar equipment.

AnalysisDevices may also be qualified by analytical methods.

For example, one evaluation method involves calculating/determining the natural frequency of the device, entering theappropriate response spectra damping curves, and determining the corresponding amplification factor. The device is then evaluated using this "g" loading value.Alternatively, the devices may be evaluated without calculating/determining its naturalfrequency by using the peak amplification factor from the appropriate response spectradamping curve to determine the "g" loading.An alternate method of seismic qualification for electrical equipment (within theapplicable equipment classes) would be an experience based approach.

Seismicadequacy can be established using methods described in the Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant Equipment, Revision 3A,developed by the Seismic Qualification Utility Group (SQUG). This method is alsocommonly known as SQUG.1.3. Response to generic letter 87-02Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating

Reactors, Unresolved Safety Issue (USI) A-46," was issuedbecause the NRC concluded that the seismic adequacy of certain equipment in operating plants must be reviewed against seismic criteria developed during the resolution ofUnresolved Safety Issue (USI) A-46.The NRC determined that it is not feasible to require older operating plants to meet newlicensing requirements that were not in use when plants were licensed.

Therefore, analternative method was selected to verify the seismic capability of equipment.

Thisalternative method used a compilation of existing earthquake experience data supplemented by test data as the basis to verify the seismic capability of equipment.

Generic Letter 87-02allowed the seismic verification to be accomplished by utilities through a generic program,and the Seismic Qualification Utility Group (SQUG) was formed. The SQUG developed aGeneric Implementation Procedure (GIP) that documents the seismic verification process,procedures, and methodologies for verifying the seismic qualification of equipment andresolving USI A-46. Supplement 1 of Generic Letter 87-02 endorsed use of the GIP for theseismic qualification process and contained revised licensee actions.

Oconee performed theseismic qualification process in accordance with the NRC enforced version of the GIP. In aSafety Evaluation Report, the NRC concluded that Oconee met the purpose and intent ofthe seismic qualification process and that the corrective actions and modifications providesufficient basis to close the USI A-46 review at Oconee.The seismic verification process is considered part of the seismic licensing basis forOconee, so the seismic qualification criteria developed by the SQUG in response to GenericLetter 87-02 must be considered during mechanical and electrical equipment modifications Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Page 4 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report1.4. Codes and Standards The following codes, standards, and specifications were used during the design,construction, testing and in-service inspection of Class 1 Structures:

  • ASME-1965

-Boiler and Pressure Vessel Code, Sections III, VIII, and IX* AISC -Steel Construction Manual, 6th ed" Regulatory Guide 1.92, Combining Responses And Spatial Components In SeismicResponse

Analysis, Revision 1, February 1976* Regulatory Guide 1.29, Seismic Design Classification, Revision 3, September 1978* Supplement No. 1 To Generic Letter (GL) 87-02 That Transmits Supplemental SafetyEvaluation Report NO.2 (SSER NO. 2) On SQUG Generic Implementation Procedure Revision 2, As Correction On February 14, 1992 (GIP-2),

May 22, 1992* NRC Letter To SQUG Dated December 4, 1997. Supplemental Safety Evaluation Report NO. 3 (SSER NO. 3) On The Review Of Revision 3 To The GenericImplementation Procedure For Seismic Verification Of Nuclear Power PlantEquipment, Updated 5/16/97 (GIP-3)* NRC Letter To SQUG Dated 6/23/99, Review Of Seismic Qualification Utility Group'sReport on the use of Generic Implementation Procedure for New and Replacement Equipment and PartsAttachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 1OCFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Page 5 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report2. Personnel Qualifications The personnel involved in the Oconee NTTF Recommendation 2.3 Seismic Walkdown effortmet the qualification requirements of EPRI 1025286.

The personnel responsibilities andqualifications are outlined in TABLE 2.1 below. (Note: PE=Professional

Engineer, CLB=Current License Basis, SWEL= Seismic Walkdown Equipment List)Table 2.1DereYears of RelevantE

>Personnel Degree 0.oo 0...t°Experience Qualifications E V ,,_I .2 -________~~

______ ______ 0~ (fl U 0Russell Childs PE, SCEW", SWE'z), X(3)(Duke Energy) BS/Civil Engineerng 30 IPEEE(t) /X] XRay Mc Coy BS/Civil Engineering 32 PE,SCE(1) X(DukeEnergy)__________

Bob Hester BS/Civil Engineering 36 PE,SCE(l)

X(Duke Energy)Paul Mabry BS/Nuclear 27 SRO(4), STA(5) X(Duke Energy) Engineering Tommy Loflin AS/Electrical 35+ SRO(4) X(Duke Energy) Engineering Jim Weir BS/Mechanical 31 SWE'(Duke Energy) Engineering SFC SYS ENGCharles M.Conselman BS/Civil Engineering 28 PE,SCE(1), SWE (2) X(3)(ARES)James White BS/Civil Engineering 42 PE,SCE(1), SWE (2) X(3)(ARES)John North BS/Civil Engineering 28 PE,SWE(2)

X(3)(ARES)Mike Donnelly BS/Civil Engineering 4 SWE(2) X(ARES) ________Anthony Fazio BS/Chemical 40+ SWE(2) X(Shaw) Engineering John Spizuoco BS/Mechanical 44 PE,SCE(l),

SWE(2) X(Shaw) Engineering Arthur Richert BS/Mechanical 32 PE,SWE(2)

X(Shaw) Engineering Paul Baughman BS/Civil Engineering

>40 PE,SCE(l),

SWE (2) )X3)(ARES)George Bushnell BS/Mechanical

>40 PE,SCE(l),

SWE (2) X(Shaw) Engineering Robert L. Keiser MS/Civil Engineering

>20 PE,SCE(l),

SWE (2) X(Duke Energy)Adam Johnson MS/Civil Engineering 3+ SCE(1) p](Duke Energy) IIINOTES:1) Seismic Capability Engineers (SCEs) who have successfully completed EPRI Experience Based Seismic Evaluation training.

2) Seismic Walkdown Engineers (SWEs) have successfully completed EPRI 1025286 2 day walkdown training course.3) Senior Team Member.4) Prior Senior Reactor Operator (SRO).5) Prior Shift Technical Advisor6) IPEEE seismic Walkdown Coordinator and current A-46/IPEE Program Owner (SQUG)Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under IOCFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Page 6 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report3. Selection of SSCsThe Oconee Unit 1 SWEL-1 and SWEL-2 equipment selection was performed in accordance with the EPRI guidance outlined in EPRI Technical Report #1025286.

SWEL-1 represents asample of items to safely shut down the reactor and maintain containment integrity.

SWEL-2represents spent fuel pool related items.The Oconee USI A-46/IPEEE Safe Shutdown Equipment List (SSEL) was used as the basis forthe Base-1 equipment list. The scope of the Seismic Walkdown Equipment List (SWEL) islimited to SSCs that are classified as Seismic Category I. This is done such that items have adefined seismic licensing basis against which to evaluate the as-installed configuration.

Oconeeis a USI A-46 plant. The purpose of the USI A-46 program was to verify the seismic adequacy ofessential equipment in older operating plants that had not been qualified in accordance withmore recent criteria.

Many of the SSC's listed in the USI A-46/IPEEE Safe Shut downEquipment List (SSEL) are not category I. However, Oconee programmatically maintains theseismic capability of these components.

Therefore, for the purpose of developing the SWEL allUSI A-46/IPEEE components are considered to have a seismic licensing basis.The A-46/IPEEE SSEL effectively represents the output of EPRI guidance equipment Screening criteria's

  1. 1, #2 and #3. The underlying data used to generate the Base-1 list is contained in anACCESS database.

This ACCESS database was used to generate the Base-1 Equipment Listfrom which the SWEL-1 was selected.

The equipment comprising the Base-1 equipment list iscontained in Attachment

1. Their individual Safety Function is identified as shown below. Somecomponents support more than one safety function.

A. Reactor reactivity controlB. Reactor coolant pressure controlC. Reactor coolant inventory controlD. Decay heat removalE. Containment functionThe Base-1 Equipment List is comprised of 2264 components from Oconee Units 1, 2 & 3 &components that support all 3 Units (Common).

The Base-1 Equipment list is contained inAttachment 1.3.1. SWEL-1 Development EPRI TN- 025286 specifies that the SWEL-1 should be comprised of between 90-120components and that each unit should have its own individual SWEL-I.357 of the Base-1 components are Common components that support all 3 units. In order toaccount for these common components,

-10% (39 items) of the base-1 commoncomponents were selected as SWEL-1 components.

All of the 39 common components areconsidered to be part of each individual unit's SWEL-1.The Unit 1 SWEL-1 consists of 131 components.

Of these 131 components, 39 are commoncomponents which are also represented in each individual unit's SWEL-1. Attachment 2contains the SWEL-1 components for Unit 1. The criteria for selection of equipment to beincluded in the SWEL are described in EPRI TN-1025286 section 3.Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)

Page 7 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportScreen #4 -- Sample Considerations

-Five sample selection attributes that should be represented in SWEL 1:* A variety of types of systems" Major new and replacement equipment

" A variety of types of equipment

" A variety of environments

" Equipment enhanced due to vulnerabilities identified during the IPEEE programIn addition to the five sample considerations listed above, the equipment selected for theSWEL-1 should include considerations of the contribution to Risk for the SSC's and shouldalso include a review by appropriate Operations personnel.

SWEL-1 Systems -The SWEL-1 equipment list represents 26 systems associated with the 5 safety functions.

SWEL-1 Types of Equipment

-The SWEL-1 list contains representative equipment from all equipment classes with thefollowing exceptions:

" There are no equipment Class 11 (Chillers),

Class 12 (Air Compressors),

or Class 13(Motor -Generators) components on the Unit 1 SWEL-1 list because they are notrepresented in the Base-1 list.* There are no equipment Class 17 (Engine -Generators) components on the Unit 1SWEL-1. The Standby Shutdown Facility (SSF) Diesel Engine (16 Cylinder)

(OSSFDEOOOA) is listed on the Base-1 list. However, it was not selected as part of theSWEL-1 due to its inherently robust nature and the very low seismic input at its location.

SWEL-1 Equipment locations

-The SWEL-1 equipment list includes equipment located in a broad variety of areas andenvironments.

These areas comprise multiple buildings and elevations and includeequipment located both inside and outside.

The equipment areas provide a broad range ofequipment environmental conditions, which include:* Mild environmental conditions with limited temperature and humidity variations (e.g.Control Room, Cable Rooms, Equipment Rooms, SSF Electrical Room, Relay House,etc.)" Moderate environmental conditions (e.g. general areas of the Auxiliary

Building, East &West Penetration Rooms, SSF Diesel Room, SSF Battery Room, Control RoomVentilation Rooms, etc.)* Moderate to harsh environmental conditions (e.g. LPI/BS/HPI Pump Rooms, LPI CoolerRoom, etc.)" Harsh environmental conditions (e.g. Inside RB Containment, etc.)." Partial exposure to outdoor environmental conditions (e.g. Switchyard, Intake Structure)

" Wet environments (Keowee Turbine Wheel Pit)Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 1OCFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Page 8 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportSWEL-1 Major New and Replacement Equipment

-In order to capture significant new and replacement equipment on the SWEL-1, a query waswritten which related the Base-1 equipment list to underlying data supporting Engineering Changes in the Duke Energy Nuclear Asset Suite Software (NAS). By doing this, a list EC'sassociated with all components on the Base-1 equipment list was generated.

Editorial andminor modifications were then filtered out of the list. The following New and Replacement Equipment have been included in the Unit I SWEL-I.1ASPT0117P AUX STEAM PRESSURETRANSMITTER (MS-126 & MS-129)ECO000099571 REPLACE OBSOLETE MOORE 352 CONTROLLER 1ASSS0017 WITH A SIEMENS 353 CONTROLLER 0Di002i9

-(REFURB)

DIGITAL CONTROL ROD1CRDCACC1 DCRDCS CONTROL CABINET CC-i ECO000078244 DRIVE CONTROL SOEDRIVE CONTROL SYSTEMNSM ON-13053/OO/OO/ALi

-(REFURB)1ELCASGLC1 STEAM GEN LOGIC CABINET EC0000068112 ATM FEEDWATER ISOLA Y (AFIS)AUTOMATIC FEEDWATER ISOLATION SYS (AFIS)0D50146i

-UNIT 1 & 2 SFP LEVEL INTERLOCK 1ELIRPIR UNIT 1 PNEUMATIC INSTR RACK EC0000093683 SINGLE FIURESINGLE FAILURE1ELPLPZRIB 600V PPB 1B (FOR PRESSURIZER EC0000106356 REPLACE 70 A AND 225 A PZR HTR BREAKERS INHEATERS GROUP 1B, BANK 2) REACTOR BUILDING WITH 80 A FUSESREPLACE AGASTAT 2432ABB WITH AGASTATiELTFOCT1 XFMR CT-i EC0000100369 70AB7032ABB0D100076

-(REFURB)

UNIT 1 INST LOOP1HPIFTOOO7A HPI A TRAIN INJ FLOW TRANS EC0000089821 UDES A NEW CRSUPGRADES AND NEW CRS0D100076

-(REFURB)

UNIT 1 INST LOOP11CCCA0001A UNIT 1 ICCM TRAIN A CABINET EC0000089821 UDES A NEW CRSUPGRADES AND NEW CRSLPI TRAIN 1B INJ FLOW TRANS OD100076

-(REFURB)

UNIT 1 INST LOOP1LPIFT0004P EC0000089821 UGAE N E R(Powered by ICCM) UPGRADES AND NEW CRSLPI COOLER 1A FLOW XMTR OE400391

-DETERMINE REPLACEMENT FORiLPSFT0i24 EC0000080263 ROE UNiiiTP(1iLPSW-251)

ROSEMOUNT 1151 TYPE J(EC90482)

(REFURB)

UNIT 1 RPS REPLACEMENT iPPSCAO005 RPS C/ES C1 EC0000090482 MODIFICATION OD100066

-(REFURB)

UNIT 1 ESFASPPSCAO9REPLACEMENT MODIFICATION OD100066

-(REFURB)

UNIT 1 ESFASREPLACEMENT MODIFICATION 0D100066

-(REFURB)

UNIT i ESFASiPPSCAO018 ES STATUS EVEN EC0000090423 RPAEETMDFCTO 0D100076

-(REFURB)

UNIT 1 INST LOOP1RCLTOOO4P1 PRZ LEVEL TRANSMITTER ECO000089821 UPGRADES A NEW CRSUPGRADES AND NEW CRS0Di006i3

-REPLACE SSF CONTROL CONSOLE1RCPT0226 Ui RC LOOP B PRESSURE EC0000090682 IDICATOR A RCS PTNI AINDICATORS AND RCS PTS1VSAH0011 I AHU-11 CONTROL ROOM A/C EC0000100110 REPLACE UNIT 1&2 CONTROL ROOM AHU 1-11Oconee revised the modification process at the completion of the A-46/IPEEE programs torequire plant modifications to evaluate impact to A-46/IPEEE components to ensure that theseismic capability of A-46/IPEEE components was not degraded.

Current site projects such as Protected Service Water (PSW) which are not operational andnot currently credited within the Current Licensing Basis (CLB) of Oconee are not within thescope of the SWEL-1.Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(dXl)

(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)

Page 9 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportSWEL-1 Equipment Enhanced per IPEEE -Significant IPEEE enhancements associated with the Base-1 equipment list as reported inthe IPEEE submittal dated 12/15/1997 were identified.

SWEL-1 SSCs were selected suchthat a sampling of SSCs which had been enhanced per IPEEE was included.

The following SWEL-1 SSCs were enhanced due to IPEEE.

LUN I KUL DUAKU IUUIL UNUt-1-W4.V Keiocaxe orawing SUCKS Iocaxeo oenino iuvz.240/120V 1A REGULATOR Install additional bracing to unistrut frame1ELBK1A OUTPUT BKR ONOE-14009 supportinglA/1B/SW, 1A/MCB, 1B/MCB, 1A/REG,OUTPUT__BKR_1B/REG, 1A/XFMR & 1B/XFMR1ELD11ADB ISOL DIODE ASSEMBLY 1ADB ONOE-12675 Install washer plates to three North anchors of1ADBWeld transformer section of Load Centers 1X04 to1ELLXIX4 600V IC lX04 ONOE-14369 emdedageembedded ang~le.Add shims under load center at anchors on North1ELLX1X9 600V LC 1X09 ONOE-13461 sieside.1ELMX1XC MCC 1XC ONOE-14370 Add back to back bolting to 1XC.1ELMXIXGB MCC 1XGB ONOE-14360 Add back to back bolting to the 3 South most baysof 1XGB1ELMX1XL MCC 1XL ONOE-14378 Add rigid support to cable tray above 1XL & 1XN inE-W direction.

1ELPL1DCA 125V DC 1DCA ONOE-12778 Replace back right anchor for 1DCA1ELPLPZR1B 600V PPB 1B (FOR PRESSURIZER ONOE-09290 Replace missing or broken door latch on PPB 1BHEATERS GROUP 1B BANK 2) and adjacent PPB 1A & 1D.1VSAH0011 AHU-11 CONTROL ROOM A/C ONOE-15560 Install lateral seismic restraint.

SWEL-1 RiskConsiderations

-EPRI TN-1 025286 requires that the development of SWEL 1 should include consideration ofthe importance of the contribution to risk for the SSCs.In response to IPEEE, Oconee utilized the results of seismic margin methodology walkdowns to enhance the existing seismic PRA. These results are documented inOSC-1 0225 "Seismic PRA/IPEEE Backup Calculations" and summarized in theSupplemental IPEEE submittal Report. From the conclusions presented in theSupplemental IPEEE submittal Report, PRA sequences involving loss of power and SSFresponse make up several of the most dominate PRA cut sets. SSC's supporting Keowee,the SSF, and the 230 KV switchyard are well represented in the SWEL-1.In addition, input was obtained from the General Office PRA group to determine a ranking ofthe most seismically risk significant components.

Of the 31 unscreened PRA events with a contribution to CDF of greater than 0%, 19 arerepresented in the combined SWEL-I's for Units 1, 2 & 3. This represents 61% of PRA risksignificant components and meets then intent of EPRI TN-1025286.

SWEL-1 Operations review -The SWEL-1 equipment listed was submitted to Oconee Operations for review asrecommended within EPRI TN-1025286.

Operations concurred with the equipment listed onthe SWEL-1 list. The SWEL-2 equipment list was developed within the Oconee Engineering organization by a highly experienced engineer who had previously held a Senior ReactorOperators License (SRO) and was previously an Operations Shift Technical Advisor (STA).Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under IOCFR 2.390(dXl)

(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)

Page 10 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report3.2. SWEL-2 Development The Oconee Unit 1 SWEL-2 spent fuel pool equipment list was developed in accordance with the EPRI guidance.

Seismic Category I structures, piping, and containment penetrations were specifically excluded by the EPRI guidance.

The four screening criteriaspecified were as follows:1) Seismic Category I or USI A-46 (SQUG) licensing bases,2) Spent Fuel Pool (SFP) equipment appropriate for an equipment walkdown process,3) Sample considerations represent broad population of equipment with considered sample selection attributes such as:a. represent a variety of systems,b. major new/replacement equipment,

c. variety of equipment types,d. variety of environments
4) Equipment which could result in rapid drain down of the SFP (includes both seismicand non-seismic components and similar factors outlined in 3) above.The SWEL-2 equipment Base-2 (Attachment
3) was established based on screens #1 and#2 above. Equipment was selected from the Base-2 list based on screening criteria
  1. 3above, and primarily included major equipment such as the spent fuel cooling systempumps, pump motor air handling units, and heat-exchangers.

The SWEL-2 list was further evaluated based on screening criteria

  1. 4 above, to includeequipment which could result in SFP rapid drain-down, as defined by the EPRI guidance.

All three Oconee Unit's have SF Pool transfer tubes that open to the SF Pool in normaloperation.

The SSF RC Make-up and letdown lines penetrate into the SF Pool transfertubes. The SSF Make-up and Letdown lines meet Seismic Category

1. There were also SFPool discharge lines at valves SF22&50 and 3SF-22&50 that could meet the criteria for arapid drain down due to a siphon if the SF Cooling pump discharge piping, which meetsSeismic Category 1, were to fail outside the SF Pool. However, this vulnerability hadpreviously been identified and procedure requirements prevent system alignment andthereby remove this vulnerability.

For these reasons, there are no rapid draw down items onthe SWEL-2.The SWEL-2 components were selected based on their radiological accessibility.

Of the 3pumps identified in the SWEL-2 base list, 2 were included in the SWEL-2. Of the 7 Tanksidentified in the SWEL-2 base list, 4 were included in the SWEL-2. This sampling is inaccordance with EPRI TN-1025286.

The final SWEL-2 list is provided in Attachment 4.4. Seismic Walkdowns and Area Walk-Bys[Duke Energy contracted with the Shaw Group IARES Corporation team to perform the majorityof the NTTF 2.3 seismic walkdowns at Oconee Nuclear Station.

A summary report of theirwalkdowns along with the individual Seismic Walkdown Checklists (SWCs) and the Area Walk-By Checklists (AWCs) was designated as Attachment 5 to Enclosure 1.Duke Energy personnel have completed the walkdowns of the Unit I and common items foundto be inaccessible during the initial walkdowns.

These walkdown items are addressed belowAttachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 1OCFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Page 11 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Reportand their associated SWCs and AWCs for provided as Attachment 5a (to supplement Attachment 5 from the initial walkdown).

No new potential adverse conditions were identified.]

[OUTAGE RELATED COMPONENTS:]

SWEL-1 SSCs which could only be accessed during an outage will be walked down by DukeEnergy personnel and reported on at a later date. These SSCs are listed below.[Completion of walkdowns for these SSCs:The thirteen Unit I SSCs listed below required a unit shutdown to be accessible.

Walkdowns ofthese SSCs have been completed by Duke Energy personnel and the SWC & A WC forms arecontained in Attachment 5a.]-MSVA0006 MAIN STEAM SAFETY RELIEF Complete1 AB 1MSVA0010 MAIN STEAM SAFETY RELIEF Complete1 RB 1ELPLPZRlB 600V PPB 1B (FOR PRESSURIZER CompleteRB ____ELPLP

___R__ HEATERS GROUP 1B BANK 2)1 RB 1FDWLT0082 SG 1A LEVEL TRANSMITTER Complete1 RB 1HPIPU0005 SSF RC MAKEUP PUMP Complete1 RB 1RBCAH0020A RBCU FAN 1A Complete1 RB 1RBCHXOOODAUX AUX RBCU D Complete1 RB 1RCLT0004P1 PRZ LEVEL TRANSMITTER Complete1 RB 1RCPT0166P RCS LOOP B PRESS TRANS Complete1 RB 1RCPT0226 Ul RC LOOP B PRESSURE Complete1 RB 1RCRDOOO6A Al COLD LEG RTD Complete1 RB 1RCVA0066 PRZ PORV Complete1 RB 1RCVA0159 RV VENT ISOLATION CompleteInaccessible SSCs -[Unit 1 SSCs:] Several Unit I SSC's were inaccessible

[during the initial walkdowns]

due to theirphysical location or due to personnel safety concerns.

These items are listed below.[Completion of Inaccessible Unit I SSCs walkdowns:

Walkdowns for these SSC's have been completed by Duke Energy personnel, except as statedin the substitution section below. SWC & AWC forms are contained in Attachment 5a.]1 "TB 1ELLX1X4 600V LC 1X04 Complete4 AB ___________

_ 6Q0V-G4X9 Substituted by component below[1] [AB) [IELLXIXS) f600V LC 1X08) Complete1 AB 1VSAHOO11 AHU-11 CONTROL ROOM A/C Complete[Substitution

-* 1ELLX1X9 (600V LC 1X09) replaced with 1ELLXIX8 (600V LC 1X08)A portion of the anchorage for one of the selected SSCs remained inaccessible unless both highenergy protective clothing and anti-contamination clothing were used. Due to this personnel safety concern, a more accessible SSC was substituted, as allowed by EPRI 1025286.

Thissubstitution does not affect the equipment sample considerations discussed in Section 3.1.]Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under IOCFR 2.390(dX)1)

(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)

Page 12 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report[Common SSCs:] The anchorage for one SSC was originally only partially visible due to some ofthe welds being covered by mortar spillage from an adjacent masonry wall. This Item andseveral other inaccessible items listed below are common to all 3 units[Completion of Inaccessible Common SSCs walkdowns:

Walkdowns for these SSC's have been completed by Duke Energy personnel, except as statedin the substitution section below. SWC & AWC forms are contained in Attachment 5a.10 SYD OSYDPLSYDC1 SWITCHYARD DISTRIBUTION CENTER 1 CompleteN4- WE SPEED Cr TR, L NAANTI' PIKUP &A Substituted by component below[Ku] [KEO] [KIGBOLS63TB]

[TURB GUIDE BRNG OIL LEVEL SWITCH] CompleteK2 KEO K2ELKTNO203 TERM BOX TB-203 CompleteIQ Y" 926AWXQ GEN AIR COOLER 3 Substituted by component below[K1] [KEO] [K2WLVAO011]

[GEN COOL ISOL VALVE] CompleteK2 KEO K2HPOPU88HA AC GEN HP LIFT PUMP (88HA)K2 KEO K2TSLS63SB TURB SUMP LEVEL SWITCH (2TSLS0002)

Complete[Substitution

-" K1PMGDTMPU1A (SPEED CONTROL MAGNETIC PICKUP 1A) replaced with K1GBOLS63TB (TURBGUIDE BRNG OIL LEVEL SWITCH)* K2GAHXO003 (GEN AIR COOLER 3) replaced with K2WL VAO011 (GEN COOL ISOL VALVE)Two of the above SSC's were located within the generator housing.

Duke Energy engineers performing the walkdowns did not possess the appropriate qualifications to enter the generator housing.

Therefore, a more accessible SSC was substituted, as allowed by EPRI 1025286.This substitution does not affect the equipment sample considerations discussed in Section 3.1.]5. Licensing Basis Evaluations A total of 17 potential adverse conditions were identified per the Seismic Walkdowns and theArea walk-bys.

All of these potential issues were entered into the Corrective Action Program(CAP). All potential adverse conditions were evaluated for their compliance with the seismiclicensing basis within the CAP and were found to be acceptable.

Station Work Requests werewritten for some conditions as good practice.

The potentially adverse conditions and theirindividual Problem Investigation process (PIP) tracking numbers are listed in the NTTF 2.3Seismic Walkdown Report for Unit 1 contained in Attachment

5. [Attachment 5a of this updatereport adds the walkdown results for the previously in-accessible components for Unit I andCommon SSCs, no new potential adverse conditions were identified.]
6. IPEEE Vulnerabilities Resolution ReportOconee submitted its response to IPEEE on 12/21/1995

& 12/15/1997.

In those submittals, Oconee stated that there were no underlying significant sequences (vulnerabilities) fromexternal events. There were also no plant changes identified that would significantly reduce riskfrom external events.Table 6-1 of the IPEEE Submittal dated 12/15/1997 listed 152 enhancements.

Theenhancements identified have been completed by either Station Work Request, PlantModification, or Analysis.

Oconee is a USI A-46 plant and performed the USI A-46 walkdowns in conjunction with theIPEEE walkdowns.

In Oconee's letter to the NRC dated 9/12/2002, Oconee confirmed thatoutliers associated with Generic Letter 87-02 (USI A-46) have been completed.

OconeeAttachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(dXl)

(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)

Page 13 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Reportperformed the USI A-46 seismic evaluations in conjunction with the IPEEE evaluations.

Thecriteria for both programs were conservatively enveloped such that an evaluation of a givencomponent would address all aspects of both programs.

IPEEE enhancements are a subset ofthe overall USI A-46 outliers.

Therefore, implementation of the IPEEE enhancements isconfirmed by the 9/12/2002 SQUG Outlier Resolution Completion Notice.7. Peer ReviewDuke Energy (Duke) contracted with the Shaw Group (Shaw) / ARES Corporation (ARES)Team to perform the NTTF 2.3 peer review at the Oconee Nuclear Station (ONS). The PeerReview Report [accessible components from the initial walkdown]

is contained in Attachment 6.[A supplemental Peer Review Report (Attachment

7) was performed for this report update, andthe walkdown results completed by Duke Energy personnel, of the Unit I and Common SSCsthat were inaccessible during the initial report.]The Peer Review Team consisted of three individuals (refer to table 2-2), all of whom haveseismic engineering experience as it applies to nuclear power plants. These individuals participated in the peer review of each of the activities.

The members of the Peer review teamand their qualifications are listed in table 2.1Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)

Page 14 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown ReportThe Peer Review team concluded that the methodology utilized conforms to the guidance inSection 6 of EPRI 1025286.

The peer review covered the following:

" The selection of the SSCs included on the Seismic Walkdown Equipment List (SWEL).* A sample of the checklists prepared for the seismic walkdowns and area walk-bys.

" The licensing basis evaluations.

" The decisions for entering the potentially adverse conditions in the Corrective ActionProgram (CAP) process." The submittal report.The peer review process for the SWEL development and the seismic walkdowns consisted ofthe following:

" Conducting an in-process review at the plant site, including interviews with the personnel performing the activity and reviewing in-process documentation.

  • Performing an in-plant surveillance (for the walkdown activity) of a seismic walkdownand an area walk-by." Providing in-process observations and comments to the personnel performing theactivities.

" Conducting a final review of a sample of the completed documentation.

The peer review process for the licensing basis evaluations and the decisions for enteringpotentially adverse conditions into the CAP consisted of reviewing the overall review processand the licensing basis reviews.

The peer review process for the submittal report consisted ofreviewing the draft submittal prepared by Oconee Design Engineering for licensing review.The conclusion of the peer reviews for both the initially accessible and the initially inaccessible components is that the ONS NTTF 2.3 seismic walkdown effort has been conducted inaccordance with the guidance in EPRI 1025286.

Comments made during the in-process reviewof the SWEL development and the walkdowns have been addressed satisfactorily.

In-process comments on the final walkdown

reports, the licensing basis reviews, and the submittal havealso been resolvedAttachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 1OCFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure 1 a, the Enclosure is uncontrolled)

Page 15 of 16 Enclosure laUpdate to Unit 1 Seismic Walkdown Report

REFERENCES:

1) UFSAR Section 3.2.1 Seismic Classification (Rev. 21)2) UFSAR Section 2.5.1.2 Site Geology (Rev. 21)3) UFSAR Sections 2.5.2.10, 2.5.2.11 SSE/OBE (Rev. 21)4) UFSAR Section 3.7 Seismic Design (Rev. 21)5) EPRI Report 1025286, Dated May 2012, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force (NTTF) Recommendation 2.3 (ATTACHMENT 1).6) Oconee NRC Response to GL 88-20, Individual Plant Examination of External Events (IPEEE)Submittal, dated Dec. 18, 1997, W. R. McCollum Jr. to NRC.7) 7/9/12 correspondence to NRC from Ben C. Waldrep, "Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)

Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" ATTACHMENTS:

[The attachments listed below were attachments to Enclosure 1 as transmitted via the initial submittal dated 11/27/2012.

These attachments are not included with this updated submittal (Enclosure la).]1) Oconee Unit 1 SWEL-1 Base-1 List2) Oconee Unit 1 SWEL-13) Oconee Unit 1 SWEL-2 Base-2 List and Rapid Drain Down List4) Oconee Unit 1 SWEL-25) Seismic Walkdown Summary Report and Checklists

6) PEER Review Summary Report[The following Attachments are included as part of this report update (Enclosure la)5a) Seismic Walkdown Checklists (SWCs) and Area Walk-by Checklists (A WCs) for Initially Inaccessible Components (These data sheets supplement the information in Attachment 5 of the initial report)7) PEER Review Summary Report for walkdowns associated with Attachment 5a]Attachment 5a Contains Security-Sensitive Information

-Withhold From Public Disclosure under 10CFR 2.390(d)(1)

(Upon removal of Attachment 5a from Enclosure la, the Enclosure is uncontrolled)

Page 16 of 16