ML13232A128

PNPS-CS-12-00001, Rev. 1, Pilgrim Station Seismic Walkdown Submittal Report for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, Cover Through Page 37 of 37

ML13232A128
Person / Time
Site:	Pilgrim
Issue date:	06/17/2013
From:	Maclay L Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation
References
2.13.056 PNPS-CS-12-00001, Rev 1
Download: ML13232A128 (38)

Text

ENCLOSURE to PNPS Letter 2.13.056 Pilgrim Nuclear Power Station (PNPS)

SEISMIC WALKDOWN REPORT UPDATE

Engineering Report No. PNPS-CS-12-00001 Rev I Page 1 of 37

-Entergy ENTERGY NUCLEAR Engineering Report Cover Sheet Engineering Report

Title:

Pilgrim Station Seismic Walkdown Submittal Report for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic Engineering Report Type:

New El Revision 0 Cancelled El] Superseded []

Superseded by:

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-(P nt Name/Sign) ,,J Reviewed by: Juan Vizcaya /* Date: , ___

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Reviewed by: Fred Moaolesko i Date:

Peer Review Team Leader (Pnt Name/Sign)

Approved by: Thomas WDhe &Lu dk x Date:_ _ _

Design Ma me/Sign) U Approved by: Ray Pace ;Zf4n: Date:_ _ _

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Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 2 of 37 Revision Description of Change 0 Initial Issue Report final issuance to include inspection of deferred items during RFO-1 9:

• Revised report body as denoted with a revision bars on Pages 22 -

27 and added new Section 9.3.

• Revised Attachment B to annotate that walkdowns of all SWEL Items are now complete.

• Revised Attachment C to remove the following SWC's: SWELl -083, SWELl -084, SWELl -095, SWELl -096, SWELl -097, SWELl -098, SWELl -099, and SWELl-100 (required follow-up internal inspection of electrical cabinets - updated/final sheets now included in Attachment J).

• Revised Attachment E to reflect deferred scope results and current status of identified seismic issues.

• Revised Attachment F to include one new LBE resulting from deferred scope walkdowns.

• Revised Attachment H to include deferred scope peer review comments.

• Added Attachment J to include the following completed SWCs:

SWELl -001, SWELl -002, SWELl -003, SWELl -004, SWELl -023, SWELl -034, SWELl -083, SWELl -084, SWELl -095, SWELl -096, SWELl-097, SWELl-098, SWELl-099, SWELl-100, SWEL2-003, SWEL2-004, SWEL2-005, SWEL2-006, SWEL2-007, SWEL2-008, SWEL2-009, SWEL2-01 0, SWEL2-01 1, SWEL2-012, SWEL2-013, SWEL2-014, SWEL2-015, and SWEL2-016.

• Added Attachment K to include the following new AWCs: AWC-033, AWC-034, AWC-035, AWC-036, AWC-037, and AWC-038.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 3 of 37 Pilgrim Station Seismic Walkdown Report for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic TABLE OF CONTENTS Section Title Page 1.0 SCO PE A ND O BJECTIVE ......................................................................................................................... 4 2.0 SEISMIC LICENSING BASIS

SUMMARY

........................................................................................... 5 2.1 SAFE SHUTDOW N EARTHQUAKE (SSE) ......................................................................................... 5 2.2 DESIGN CODES, STANDARDS, AND METHODS 5.......................

5 3.0 SEISMIC WALKDOWN PROGRAM IMPLEMENTATION APPROACH .............................................. 8 4.0 PERSONNEL QUALIFICATIONS ..................................................................................................... 9 4.1 EQ UIPM ENT SELECTIO N PERSO NNEL ......................................................................................... 12 4.2 SEISM IC W A LKDOW N ENG INEERS ................................................................................................ 12 4.3 LIC E NS ING BA S IS R EV IEW E R S ........................................................................................................ 12 4 .4 IP E E E R E V IEW E R S ............................................................................................................................. 12 4 .5 P E E R R EV IEW T EA M .......................................................................................................................... 13 5.0 IPEEE VULNERABILITIES REPORTING ........................................................................................... 15 6.0 SEISMIC WALKDOWN EQUIPMENT LIST DEVELOPMENT ........................................................... 16 6.1 SAMPLE OF REQUIRED ITEMS FOR THE FIVE SAFETY FUNCTIONS ...................................... 16 6 .2 S P E NT F UE L P O O L ITE MS ................................................................................................................. 20 6.3 DEFERRED INACCESSIBLE ITEMS on SWEL ...................................... 22 7.0 SEISMIC WALKDOWNS AND AREA WALK-BYS ............................................................................ 23 7 .1 S E IS MIC W A LK DOW NS .................................................................. ................................................... 23 7 .2 A R E A WA LK-B Y S ................................................................................................................................. 24 8.0 LICENSING BASIS EVALUATIONS .................................................................................................. 26 CONDITON IDENTIFICATION ........................ ........ . ......... ........................................ 26 C O NDITION R E S O LU T ION ............................................................................................................................. 26 8.1 LIC EN SING BASIS EVA LUATIO NS .................................................................................................. 27 8.2 CORRECTIVE ACTION PROGRAM ENTRIES ................................................................................. 27 8 .3 P LANT C HA NG E S ............................................................................................................................... 8 28 9.0 PE E R R EV IEW ........................................................................................................................................ 29 9.1 P E E R R E V IEW P R O C E S S ................................................................................................................... 29 9.2 PEER R EV IEW RESULTS SUM MA RY 29........................

29 9.3 PEER REVIEW PROCESS - DEFERRED SCOPE ACTIVITIES .................................................... 34 10.0 R EFER EN C ES ......................................................................................................................................... 36 11.0 ATTA C HMENTS ...................................................................................................................................... 37 ATTACHMENT A - IPEEE VULNERABILTIES TABLE .............................................................................. Al ATTACHMENT B - SEISMIC WALKDOWN EQUIPMENT LISTS .................... B.........................

B1 ATTACHMENT C - SEISMIC WALKDOWN CHECKLISTS (SWCs) ......................................................... C1 ATTACHMENT D - AREA WALK-BY CHECKLISTS (AWCs) ......................................................................... D1 ATTACHMENT E - POTENTIALLY ADVERSE SEISMIC CONDITIONS .................................................. El ATTACHMENT F - LICENSING BASIS EVALUATION FORMS ................................................................. F1 ATTACHMENT G - PEER REVIEW CHECKLIST FOR SWEL ................................................................. G1 ATTACHMENT H - PEER REVIEW COMMENT FORM ............................................. H1 ATTACHMENT I - SEISMIC WALKDOWN ENGINEER TRAINING CERTIFICATES ..................................... I1 ATTACHMENT J - DEFERRED SEISMIC WALKDOWN CHECKLISTS (SWCs) ........................................... J1 ATTACHMENT K - DEFERRED AREA WALK-BY CHECKLISTS (AWCs) .................................................... K1

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 4 of 37 1.0 SCOPE AND OBJECTIVE The Great Tohoku Earthquake of March 11, 2011 and the resulting tsunami caused an accident at the Fukushima Dai-ichi nuclear power plant in Japan. In response to this accident, the Nuclear Regulatory Commission (NRC) established the Fukushima Near-Term Task Force (NTTF). The NTTF was tasked with conducting a systematic and methodical review of NRC processes and regulations and determining if the agency should make additional improvements to its regulatory system. On March 12, 2012 the NRC issued a 10CFR50.54(f) Letter [Ref. 1] requesting information from all licensees to support the NRC staff's evaluation of several of the NTTC recommendations. To support NTTF Recommendation 2.3, Enclosure 3 to the 50.54(f) Letter requested that all licensees perform seismic walkdowns to gather and report information from the plant related to degraded, non-conforming, or unanalyzed conditions with respect to its current seismic licensing basis.

The Electric Power Research Institute (EPRI), with support and direction from the Nuclear Energy Institute (NEI), published industry guidance for conducting and documenting the seismic walkdowns which represented the results of extensive interaction between NRC, NEI, and other stakeholders. This industry guidance document, EPRI Report 1025286 [Ref. 2],

hereafter referred to as "the Guidance," was formally endorsed by the NRC on May 31, 2012.

Entergy Pilgrim Nuclear Power Station (PNPS) has committed to using this NRC-endorsed guidance as the basis for conducting and documenting seismic walkdowns for resolution of NTTF Recommendation 2.3: Seismic.

The objective of this report is to document the results of the seismic walkdown effort undertaken for resolution of NTTF Recommendation 2.3: Seismic in accordance with the Guidance, and provide the information necessary for responding to Enclosure 3 to the 50.54(f) Letter.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 5 of 37 2.0 SEISMIC LICENSING BASIS

SUMMARY

Pilgrim Nuclear Power Station (PNPS) is a boiling water reactor (BWR) located in Plymouth, Massachusetts. The Nuclear Steam Supply System (NSSS) was originally designed by GE and PNPS began commercial operation in December of 1972, and is currently rated at 688 MWe power [Ref. 3]. This section summarizes the seismic licensing basis of structures, systems and components (SSCs) at PNPS which bound the context of the NTTF 2.3 Seismic Walkdown program.

2.1 SAFE SHUTDOWN EARTHQUAKE (SSE)

In accordance with Criterion 2, "Design Bases for Protection Against Natural Phenomena", of 10 CFR 50, Appendix A, structures, systems, and components important to safety are designed to withstand the effects of natural phenomena such as earthquakes without loss of the capability to perform those safety functions necessary to cope with appropriate margin to account for uncertainties in the historical data.

The Safe Shutdown Earthquake for PNPS is based on a recurrence of the largest historical earthquake in the region applied at the closest known location of faulting. It is specifically characterized by a Housner spectral shape anchored at 0.15g (SSE) peak horizontal ground acceleration with vertical accelerations equal to 2/3 of the horizontal ground acceleration [Ref 3].

The seismic input motion is considered to be applied at "estimated foundation depths" which corresponds to the elevation of the bottom of the Reactor Building basemat [Ref. 3]. Amplified response spectra have been developed for the various Class I buildings and consolidated into a controlled specification [Ref. 10] for use in the analysis and design of Class I SSCs.

The damping factors used in the seismic analysis are based on stresses of various materials.

These values are given in Table 12.2-3 of the FSAR. As described in the FSAR, the damping values are the lower limits of commonly accepted ranges for the stress levels associated with the respective earthquakes based on recommendations by Newmark and Hall in NUREG/CR-0098.

2.2 DESIGN CODES, STANDARDS, AND METHODS Seismic Input to Structures and Equipment PNPS was designed to withstand the effects of seismic events applicable to Class I systems. The Final Safety Analysis Report (FSAR) [Ref. 3] describes Class I SSCs as those structures, equipment, and components whose failure or malfunction might cause or increase the severity of an accident which would endanger the public health and safety. This category includes those structures, equipment, and components required for safe shutdown and isolation of the reactor. Both the vertical and either of

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 6 of 37 the responses of the two horizontal seismic motions are considered to be applied simultaneously and in combination with all other applicable design loads. The larger combination, typically SSE, controls the design.

The seismic classification of structures, systems and components is in accordance with Regulatory Guide 1.29, "Seismic Design Classification" (August 1973).

Structures, systems and components are classified as either Seismic Category I or Seismic Category II depending on the safety-related function. None of the structures at PNPS have classifications that are partially Seismic Category I and partially Seismic Category I1. However, portions of Seismic Category II systems are seismically supported if their failure could cause damage to Seismic Category I components.

Structures, Equipment and Components Seismic Category Class I structures and Class II structures housing Class I equipment include the Reactor Building, Turbine Building, Radwaste Building, Intake Structure and Emergency Diesel Generator Building. Seismic design of Class 1 SSCs is in accordance with Section 12.2 and Appendix C of the FSAR and TDBD118 Topical Design Basis Document for Seismic Design [Ref. 9].

Prior to installation, equipment was analyzed to determine adequacy for earthquake loading. The equivalent static coefficients for the equipment were obtained from the amplified floor response spectra corresponding to the support elevations of the equipment. Conservatively, peak values of the applicable floor response spectrum were used in calculating the earthquake loads. For the replacement piping valves and pumps, the equipment was analyzed as part of the piping system.

Piping systems were dynamically analyzed or reanalyzed using the response spectrum method of analysis. For each of the piping systems, a mathematical model consisting of lumped masses at discrete joints was constructed. Valves were also considered as lumped masses in the pipe.

There are many Class I components and equipment that are not typically designed or sized directly by stress analysis techniques. These components and equipment are usually designed by tests and empirical experience. Detailed stress analysis is currently not practical for evaluation of the components. Examples include valves, pumps and electrical equipment. Field experience and testing are used to support the design.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 7 of 37 Seismic Interaction (Spatial, Fire, and Flood)

Seismically induced fire interactions include inadequately stored flammable and hazardous material, hydrogen gas bottles and bottles containing flammable chemicals.

These items are to be adequately secured to a rigid structure by means of a support or tied to a support.

There are four types of sprinkler or water spray systems used at PNPS: (1) deluge, (2) pre-action, (3) wet pipe, and (4) dry pipe systems. Deluge and pre-action systems have empty pipes. In these systems, the water is controlled (i.e., held out) by a separate heat detection system. Deluge systems have "open" sprinkler heads or water spray nozzles and pre-action have "closed" automatic heads or nozzles. Wet pipe systems have pressurized water in their pipes and "closed" sprinkler heads. Dry pipe systems have pressurized air in their pipes and automatic "closed" sprinkler heads.

Sprinkler heads that are near equipment or conduit in the overhead are designed with covers or by rigid connections to prevent spatial interactions that could lead to flooding or spray hazards.

An extensive list of design codes, standards, methods, studies and tests utilized for seismic design is provided in the PNPS FSAR. A summary of the more relevant references for the design of Seismic Category I structures, systems and components is provided here.

0 Final Safety Analysis Report (FSAR)

• 10 CFR 50, Appendices A and B 0 Institute of Electrical and Electronics Engineers (IEEE)

• ASME Boiler and Pressure Vessel Code, various Sections

• American Concrete Institute (ACI) Building Code Requirements for Reinforced Concrete (ACI 318-63) 0 American Welding Society (AWS) Standard Code for Arc and Gas Welding in Building Construction

• American Institute of Steel Construction (AISC) Specification for the Design, Fabrication, and Erection of Structural Steel for Buildings

• Uniform Building Code (UBC)

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 8 of 37 3.0 SEISMIC WALKDOWN PROGRAM IMPLEMENTATION APPROACH Entergy PNPS has committed to conduct and document seismic walkdowns for resolution of NTTF Recommendation 2.3: Seismic in accordance with the EPRI Seismic Walkdown Guidance [Ref. 2]. Entergy developed procedure EN-DC-168 "Fukushima Near-Term Task Force Recommendation 2.3 Seismic Walk-down Procedure" outlining the guidelines, processes and required documentation to generate during the walkdowns. The approach provided in the Guidance for addressing the actions and information requested in Enclosure 3 to the 50.54(f) Letter includes the following activities, the results of which are presented in the sections shown in parenthesis:

0 Assignment of appropriately qualified personnel (Section 4.0) a Reporting of actions taken to reduce or eliminate the seismic vulnerabilities identified by the Individual Plant Examination of External Events (IPEEE) program (Section 5.0)

• Selection of structures, systems and components (SSCs) to be evaluated (Section 6.0)

• Performance of the seismic walkdowns and area walk-bys (Section 7.0)

• Evaluation and treatment of potentially adverse seismic conditions with respect to the seismic licensing basis of the plant (Section 8.0)

• Performance of peer reviews (Section 9.0)

The coordination and conduct of these activities was initiated and tracked by Entergy corporate leadership, which provided guidance to each Entergy site throughout the seismic walkdown program, including PNPS. Entergy contracted with an outside nuclear services company to provide engineering and project management resources to supplement and assist each individual site. PNPS had dedicated engineering contractors, supported by their own project management and technical oversight, who worked closely with plant personnel.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 9 of 37 4.0 PERSONNEL QUALIFICATIONS The NTTF 2.3 Seismic Walkdown program involved the participation of numerous personnel with various responsibilities. This section identifies the project team members and their project responsibilities and provides brief experience summaries for each. Training certificates of those qualified as Seismic Walkdown Engineers are included in Attachment I.

Table 4-1 summarizes the names and responsibilities of personnel used to conduct the seismic walkdowns. Experience summaries of each person follow.

Table 4-1 Equipment Seismic Licensing IPEEE Name Selection Walkdown Basis Personnel Engineer Reviewer Paul Smith (Consultant) X1 David Heard (Consultant) X David Small (Entergy) x2 Laura Maclay (ENERCON) X X X Gary Sweder (ENERCON) X Halie Aroz (ENERCON) X X Notes:

1. Plant operations representative

2. Designated lead SWE Paul Smith Mr. Smith is an engineer with over 45 years of experience in the nuclear power industry. He holds a Bachelor of Science degree in Engineering Technology from Northeastern University, and he is a previously licensed Senior Reactor Operator.

Mr. Smith worked as a PNPS employee for 37 years, starting in 1966 as an I/C Technician.

During his time at Pilgrim, he worked in positions of increasing responsibility, including Maintenance Staff Engineer, Operations Support Division Manager, and Senior Systems and Safety Analyst. In addition, he served as an Operations Review Committee Member for 15 years.

Currently, Mr. Smith works for lepson Consulting Enterprises, providing technical support for PNPS. Previously, he has provided component inspection and emergency planning support for PNPS at Sun Technical.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 10 of 37 David Heard Mr. Heard is a Professional Engineer with over 40 years of diversified engineering experience that parallels the history of the US nuclear power industry. He holds a Bachelor of Science degree in Mechanical Engineering from Tufts University and a Master of Science in Management from Lesley University. Mr. Heard began working on the design, and construction of new nuclear facilities in 1970, and progressed to a career specializing in the maintenance and improvements to operating nuclear plants.

Most recently Mr. Heard was involved in renewal of Entergy's PNPS. He participated in all aspects of the License Renewal process from the development of the application and meetings with the NRC audit team, through the implementation phase, which included program development, procedure writing, field inspections, training plant personnel and License Renewal commitment close-out.

Mr. Heard worked 15 years at PNPS where he served as Lead Mechanical Engineer and Project Manager for major plant improvements. He also ran the Master Surveillance Tracking Program which scheduled and monitored the performance of all the periodic surveillances and maintenance activities at the plant.

At Stone and Webster, Mr. Heard was a Project Manager in the Plant Services Division specializing in the modification and repair of operating nuclear plants. The clients included all nuclear plants in New England and involved diverse projects such as pipe supports at Maine Yankee, a spent fuel pool liner at Yankee Rowe, a radwaste facility at Millstone and a spare parts program at Vermont Yankee.

David Small Mr. Small is a Professional Engineer with over 20 years of structural engineering experience, with over 16 years in the power generating industry. He holds a Bachelor of Science degree in Civil/Structural Engineering from University of Massachusetts and is a qualified Seismic Walkdown Engineer as stated on his EPRI training certificate dated July 19, 2012.

Currently, Mr. Small is a Senior Engineer at PNPS, serving as Lead Engineer for the response to Fukushima related seismic issues. His primary duties at PNPS include technical oversight and contract management of projects developed by outside engineering firms, and serving as design engineer for projects developed in-house for a wide range of civil/structural/mechanical issues. Prior to joining PNPS, Mr. Small was a Senior Engineer for the Engineering FIN Team at Vermont Yankee Nuclear Power Plant. This team responded to a wide variety of emergent plant issues, and was often called upon to resolve these issues in a short time frame. He also performed the duties of Lead Engineer and Project Manager for plant upgrades.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 11 of 37 Mr. Small also worked as a Senior Structural Engineer for Sargent & Lundy. He provided engineering services to various power generating clients, including a long-term assignment at Palisades Nuclear Plant. Mr. Small was involved in the Palisades 79-14 safety-related piping program, and gained extensive experience with concrete expansion anchor analysis and design. His responsibilities at Sargent & Lundy also included finite element modeling, response spectrum analysis, design of large steel and concrete structures, and preparation of design change packages.

Laura Maclay Ms. Maclay has over five years of experience as a structural engineer, three years with Enercon Services. Ms. Maclay holds a Bachelor's degree in Structural Engineering from Drexel University and is a qualified Seismic Walkdown Engineer as stated on her EPRI training certificate dated July 26, 2012. Her tasks have ranged from assisting with the development and preparation of design change packages to performing design calculations and markups, comment resolutions, and drawing revisions. Ms. Maclay spent a year on site at Turkey Point Nuclear Plant preparing structural evaluations of SSC's for an Extended Power Uprate (EPU). Her work included designing safety related supports for computer and electrical equipment for the Turbine Digital Controls Upgrade package and other similar packages. Ms. Maclay's responsibilities also included the review of calculations, drawings and vendor documentation for the seismic evaluation of the Unit 3 Palfinger Crane inside containment and new platforms in the High Pressure Turbine enclosure.

Recent work includes Fukushima flooding walkdowns at Limerick Generating Station and seismic walkdowns at Plant Farley. As a member of a two person team, Ms. Maclay was responsible for evaluating equipment anchorage, spatial interactions and potentially adverse conditions.

Gary Sweder Mr. Gary Sweder is a mechanical engineer with over six years of experience in the nuclear industry. Mr. Sweder is a Professional Engineer and holds a Bachelor's degree in Nuclear Engineering from the University of Maryland and a Master's degree in Nuclear Engineering from the University of Tennessee. He is a qualified Seismic Walkdown Engineer as stated on his EPRI training certificate dated September 13, 2012. Major tasks have included design and analysis of mechanical systems, calculation preparation and review, creating and revising mechanical drawings, and development of engineering change packages for various nuclear plants. He has worked on a broad range of projects that include: simplified water hammer analysis in support of a steam generator replacement, lead mechanical on several radiation monitor replacements, and containment isolation valve modifications.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 12 of 37 Mr. Sweder is proficient with GOTHIC and RELAP5 thermal-hydraulic analysis software.

GOTHIC applications include robust models of the Control Area Ventilation system, CAS and Security Room heat up rates after loss of HVAC and analyses of fluid mixing in pipe systems.

RELAP5 work includes modeling of an integral reactor vessel and subsequent analyses such as feed water loss and transients, loss of coolant accidents and steam line breaks.

Halie Aroz Ms. Aroz has an M.S. degree in Structural Engineering from Georgia Institute of Technology, and a B.S. degree in Civil Engineering from UCLA. She has over a year of experience as a civil/structural engineer with Enercon Services and is a qualified Seismic Walkdown Engineer as stated on her EPRI training certificate dated September 13, 2012. Her major tasks have included the design and analysis of pipe and cable tray supports, structural steel frames, reinforced concrete slabs and foundations, and other miscellaneous support structures. She has experience in preparing and reviewing calculations, revising design change packages, and creating/revising structural drawings for various nuclear plants.

Ms. Aroz is proficient with GTSTRUDL structural design and analysis software, and has extensively used the program for various calculations, including a response spectrum analysis of a safety-related HPSW pump for Peach Bottom Nuclear Station. She has also qualified many base plates and both cast-in-place and expansion type anchor bolts, utilizing hand calculations or GTSTRUDL, and has designed several supports for seismic class Il/I considerations.

4.1 EQUIPMENT SELECTION PERSONNEL A total of two individuals served as Equipment Selection Personnel - see Table 4-1.

4.2 SEISMIC WALKDOWN ENGINEERS A total of four individuals served as Seismic Walkdown Engineers - see Table 4-1.

4.3 LICENSING BASIS REVIEWERS A total of two individuals served as Licensing Basis Reviewers - see Table 4-1.

4.4 IPEEE REVIEWERS One individual served as IPEEE Reviewer - see Table 4-1.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 13 of 37 4.5 PEER REVIEW TEAM Table 4-2 summarizes the names and responsibilities of personnel used to conduct peer reviews of the seismic walkdown program. Experience summaries of each person follow.

Table 4-2 SWEL Peer Walkdown Licensing Submittal NameReviewer Peer Basis Peer Report Peer Reviewer Reviewer Reviewer Jeffrey Kalb x2 X x2 X1,2 Fred Mogolesko X X X Notes:

1. Peer Review Team Leader

2. Lead peer reviewer of particular activity Jeffrey Kalb Mr. Kalb is an engineer with 39 years of engineering experience. He holds a Bachelor of Science degree in Civil Engineering from University of Rhode Island, and has taken graduate courses in Structural Engineering at Northeastern University. Mr. Kalb has also completed the "SQUG Walkdown Screening and Seismic Evaluation" training course, and participated extensively in the USI A-46 seismic walkdowns at PNPS.

Mr. Kalb is currently a Senior Lead Civil/Structural/Mechanical Design Engineer for PNPS.

His major responsibilities include working as lead design engineer for plant modifications, and leading the Structures Monitoring and License Renewal program.

Mr. Kalb worked for Boston Edison Company as a senior engineer for PNPS. He performed civil/structural engineering work as well as staff assignments at the site engineering office. He has also worked as a supervisor in the field of engineering consulting at Impell and Cygna, and as a structural engineer for power plant engineering and design at Stone & Webster.

Fred Mogolesko Mr. Mogolesko is a project manager with an engineering background and over 35 years of experience in the nuclear power industry. He holds a B.S. degree in Aerospace Engineering/Applied Mechanics and an M.S. degree in Applied Mechanics from Polytechnic Institute of Brooklyn. He also holds an M.S. and a Ph.D. in Meteorology/Oceanography from New York University (NYU).

Currently, Mr. Mogolesko is a consultant serving as a project/program manager at Pilgrim Nuclear Station. His responsibilities include proposing and managing strategies, programs,

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 14 of 37 and processes in support of economic and competitive generation of electrical power. He has evaluated and assessed known natural hazard impacts for Pilgrim including full seismic reverification (USI-A46), soil-structure interaction, probabilistic fire and seismic risk assessments, hurricane and site flooding accidents under the IPE and IPEEE Programs.

Prior to his current position, Mr. Mogolesko was a Senior Project Manager, principal engineer and division manager of environmental sciences at PNPS. His responsibilities included environmental risk assessments and developing the foundations for the severe accident management program, shutdown risk tools, and integrated plant risk models. Mr. Mogolesko has also worked as a lead engineer for Stone and Webster, a geophysical sciences laboratory research scientist at NYU, and a senior aerospace engineer at Grumman Aerospace.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 15 of 37 5.0 IPEEE VULNERABILITIES REPORTING During the IPEEE program in response to NRC Generic Letter 88-20 [Ref. 4], plant-specific seismic vulnerabilities were identified at many plants. In this context, "vulnerabilities" refers to conditions found during the IPEEE program related to seismic anomalies, outliers, or other findings.

IPEEE Reviewer (see Section 4.4) reviewed the IPEEE final report [Ref. 5] and supporting documentation to identify items determined to present a seismic vulnerability by the IPEEE program. IPEEE Reviewers then reviewed additional plant documentation to identify the eventual resolutions to those seismic vulnerabilities not resolved via the completion of the IPEEE program.

The seismic vulnerabilities identified for PNPS during the IPEEE program are reported in Attachment A. A total of four seismic vulnerabilities were identified by the PNPS IPEEE program. For each identified seismic vulnerability, the table in Attachment A includes three pieces of information requested by Enclosure 3 of the 50.54(f) Letter:

" a description of the action taken to eliminate or reduce the seismic vulnerability

• whether the configuration management program has maintained the IPEEE action (including procedural changes) such that the vulnerability continues to be addressed

" when the resolution actions were completed.

The list of IPEEE vulnerabilities provided in Attachment A was used to ensure that some equipment enhanced as a result of the IPEEE program were included in SWELl (see Section 6.1.2). Documents describing these equipment enhancements and other modifications initiated by identification of IPEEE vulnerabilities were available and provided to the SWEs during the NTTF 2.3 Seismic Walkdowns.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 16 of 37 6.0 SEISMIC WALKDOWN EQUIPMENT LIST DEVELOPMENT This section summarizes the process used to select the SSCs that were included in the Seismic Walkdown Equipment List (SWEL) in accordance with Section 3 of the EPRI Guidance. A site team of equipment selection personnel with extensive knowledge of plant systems and components was selected to develop the SWEL. The SWEL is comprised of two groups of items:

SWEL 1 consists of a sample of equipment required for safe shutdown of the reactor and to maintain containment integrity (i.e., supporting the five safety functions). SWEL 1 is a representative sampling of equipment previously walked down as the SSEL

• SWEL 2 consists of items related to rapid drain down of the spent fuel pool The final SWEL is the combination of SWEL 1 and SWEL 2. The development of these two groups is described in the following sections.

6.1 SAMPLE OF REQUIRED ITEMS FOR THE FIVE SAFETY FUNCTIONS Safe shutdown of the reactor involves four safety functions:

• Reactor reactivity control

• Reactor coolant pressure control

• Reactor coolant inventory control

• Decay heat removal Maintaining containment integrity is the fifth safety function

• Containment function The overall process for developing a sample of equipment to support these five safety functions is summarized in Figure 1-1 of the Guidance. Figure 1-1 of the Guidance provides a screening method for selecting SSCs, starting with all of the plant SSCs and reducing the number based on a series of screening criteria.

6.1.1 Base List 1 Based on Figure 1-1 and Section 3 of the Guidance, Base List 1 should represent a set of Seismic Category (SC) I equipment or systems that support the five safety functions. USI-A46 identified the following Safe Shutdown Functions and Supporting Systems:

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 17 of 37 Safe Shutdown Preferred Path Backup Path Function Control Rod Drive Reactivity Control (CRD) insertion by N/A, single failure proof Hydraulic Control Unit Reactor Pressure Safety Relief Valve Safety Relief Valves in Contol Control (SRV) in relief mode to ShtonCoigsafety afety mode Re Shutdown Cooling Reactor Core Isolation High Pressure Coolant Reactor Inventory Cooling (RCIC) Injection transition to Core Control transition A to Core Spray Spray B Spray B Decay Heat Removal Suppression Pool Suppression Pool Cooling Cooling A B Containment Function Shutdown Cooling A Shutdown Cooling B The USI-A46 report resulted in the Safe Shutdown Equipment List (SSEL) which is the equipment needed to support the preferred path, and backup path.

The Components on the list were inspected, and/or evaluated in accordance with the Seismic Qualification Utility Group (SQUG) Generic Implementation Procedure (GIP).

An equipment list was developed for one preferred and one alternate "success path" capable of achieving and maintaining a safe shutdown condition for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a SSE event. Some components provide multiple functions including support of containment integrity. This equipment list of SSCs on the success paths is consistent with the requirements of Screens #1 through #3 of the Guidance. In accordance with EPRI Seismic Walkdown Guidance 2012, Pilgrim has reviewed the SSEL for Pilgrim USI-A46 including approximately 1100 seismically rugged components that support safe shutdown following a seismic event. As the SSEL was a 1996 product, Asset Suite and other supporting documentation was reviewed to identify any equipment that was modified to date. Base List 1 is presented as Table 9.4.1 in Attachment B.

6.1.2 Development of SWEL 1 Based on Figure 1-1 and Section 3 of the Guidance, SWEL 1 should represent a diverse population of items on Base List 1 including representative items from some of the variations within each of five sample selection attributes. Additionally, the selection of SWEL 1 items includes consideration of the importance of the contribution to risk for the SSCs. Equipment Selection Personnel (see Section 4.1) developed SWEL 1 using an iterative process. The following paragraphs describe how the equipment selected for inclusion on the final SWEL 1 are representative with respect

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 18 of 37 to each of the five sample selection attributes while also considering risk significance.

In general, preference for inclusion on SWEL 1 was given to items that are accessible during full plant operation and have visible anchorage while still maintaining the sample selection attributes. SWEL 1 is presented as Table 9.4.2 in Attachment B, and has 104 total items.

The EPRI guidance specifies five safety functions for consideration as described above. The following steps/ screens were taken to select the SWEL items from the SSEL list.

1. Screen # 1 scope reduction; Identify Seismic Category SC 1 components;

2. Screen #2 scope reduction; Identify components not routinely inspected;

3. Screen #3 scope reduction; sorted by five (5) EPRI safety Functions;

4. Screen #4 is the SWEL 1, Component list, and it includes;

• Instrumentation needed to provide indication for parameter controls is provided by the Post Accident Monitoring panel.

" The selected systems considered lessons-learned from Fukushima event. Of special importance under an extended station blackout, the following components were identified to be of value in fulfilling the five safety functions.

• CRD, utilizing HCU valves

" Multiple SRVs operating in "safety" mode

" RCIC, including mechanical and electrical support systems

" Direct Torus Vent, including mechanical, and electrical support systems

• Outboard Primary Containment connections, mechanical, and electrical support. Passive portions of the pressure boundary are routinely inspected, and excluded from the walkdown.

Also included SSEL components that perform the same safety functions, using different systems:

• CRD, depressurizing the pneumatic supply header with back-up scram valves

• SRVs operating in "relief' mode, with local, extended pneumatic supply

• Core Spray, with mechanical and electrical support systems

• RHR in Suppression Pool Cooling/Containment Spray

• Inboard Primary Containment connections, mechanical, and electrical support

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 19 of 37 The total SWEL population 118 components (SWEL 1 and SWEL 2) includes representational components, using the EPRI component selection process, considering:

Variety of Types of Systems Items were selected from Base List 1 ensuring that each of the five safety functions was well represented. Additionally, components from a variety of frontline and support systems, as listed in Appendix E of the Guidance, were selected. The system type of each item on SWEL 1 is listed on Table 9.4.2 of Attachment B.

Magor New and Replacement Equipment With assistance from plant operations, Equipment Selection Personnel identified items on Base List 1 which are either major new or replacement equipment installed within the past 15 years, or have been modified or upgraded recently. These items are designated as such on Base List 1 on Table 9.4.1 of Attachment B. A sampling of these items is represented on SWEL 1.

Variety of Equipment Types According to Appendix B of the Guidance, there are 22 classes of mechanical and electrical equipment. The equipment class of each item on SWEL 1 is listed on Table 9.4.2 of Attachment B. Note that SWEL 1 does not include Class 13 components, because these are not represented on Base List 1.

Variety of Environments Items were selected from Base List 1 located in a variety of buildings, rooms, and elevations. These item locations included environments that were both inside and outside, as well as having high temperature and/or elevated humidity and within containment. The location and environment of each item on SWEL 1 is listed on Table 9.4.2 of Attachment B.

IPEEE Enhancements There are only three IPEEE items for the plant, none of which appear on the SSEL. In this case, one of the items, A8, was added to the SWEL 1 list to provide an IPEEE component. This component is linked to powering the Emergency busses and therefore was considered to be important to plant safety.

Risk Siqnificance Information from the plant Seismic Probabilistic Risk Analysis (SPRA) model and the PNPS SPRA was developed in accordance with the guidance in NUREG-1407 and NUREG/ CR-2300 [Ref. 4]. It followed a five step process investigating the seismic hazard, the fragility of plant components, and the response of the plant to the seismic hazard. The following three elements were used as the approach, as discussed in the overall methodology section of the IPEEE report:

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 20 of 37

• Plant walkdowns made by Seismic Review Teams, trained by EPRI in the screening methodology, to identify components and structures to be modeled

" Development of fragility values for components and structures in the PNPS SPRA based on structural capacity computations and a determination of in structure demand using soil structure interaction analysis

• Risk qualification by fault tree analysis, and the integration of the plant logic model with the seismic hazard curve The major findings of the SPRA are described in Attachment A, IPEEE Vulnerabilities Table.

6.2 SPENT FUEL POOL ITEMS The overall process for developing a sample of SSCs associated with the spent fuel pool (SFP) is similar to that of the screening process for SWEL 1 and is summarized in Figure 1-2 of the Guidance. The equipment of Screen #2 and entering Screen #3 is defined as Base List 2. The items of Screen #4 are the items that could potentially cause the SFP to drain rapidly. The items of either Screen #3 or Screen #4 are the second Seismic Walkdown Equipment List, or SWEL 2. Development of these lists is described in the following sections.

6.2.1 Base List 2 Based on Figure 1-2 and Section 3 of the Guidance, Base List 2 should represent the Seismic Category I equipment or systems associated with the SFP. To develop Base List 2, Equipment Selection Personnel (see Section 4.1) reviewed plant design and licensing basis documentation and plant drawings for the SFP and its associated cooling system. Base List 2 is presented as Table 9.4.3 in Attachment B, and has 30 total items.

6.2.2 Rapid Drain-Down Based on the approach defined in the 50.54 (f) letter, (Reference 1) the seismic adequacy of Equipment and Systems connected to the Spent Fuel Pool (SFP), which if ruptured or malfunction could rapidly drain the SFP should be confirmed by walkdown. The purpose of the Failure Modes analyses for the Spent Fuel Pool is to identify vulnerabilities resulting in rapid draining; that is providing a leak path that could expose the top of the fuel assemblies in less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The review of the SFP is limited to ruptures and failures capable of rapid draining.

The SFP is a reinforced concrete structure, completely lined with Stainless Steel (SS) plates, with drainage channels imbedded in the concrete to monitor and direct leakage

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 21 of 37 from the SS liner. The SFP has been designed to withstand earthquake loading as a Class I structure.

The passage between the SFP and the Refueling cavity is provided with two procedurally controlled, double sealed gates, with a monitored drain line in between, as per drawing M231. There are no penetrations below the safe-storage level (Approximately 10 feet > top of active fuel) in the SFP. Supply lines which extend into the SFP are provided with siphon breaking devises, to prevent backflow in the event of a supply system rupture. Normal makeup water is automatically provided by the condensate transfer system. Additional makeup water is available via Condensate or Demineralized water, from any combination of the Condensate Storage, or Demineralized water Tanks, from five pumps (P-109A/B, P-111, P-108A/B), and through three flow paths ( Skimmer Surge tank inlet, SFP system, service water boxes). In the event of a LOOP event, additional sources include the Fire Water Protection Systems, or the RHR Systems powered by multiple independent diesels.

6.2.3 Development of SWEL 2 Based on Figure 1-2 and Section 3 of the Guidance, SWEL 2 is a broad population of items on Base List 2 including representative items from some of the variations within each of four sample selection attributes (using sample process similar to SWEL 1),

plus each item that could potentially cause rapid-drain down of the SFP. Due to the population of items on Base List 2 being much smaller than Base List 1, the sampling attributes are satisfied differently for SWEL 2 than for SWEL 1. The following paragraphs describe how the equipment selected from Base List 2 for inclusion on SWEL 2 are representative with respect to each of the four sample selection attributes.

SWEL 2 is presented as Table 9.4.5 in Attachment B, and has 16 total items; of these, all items are selected from Base List 2, which is also the rapid drain-down list.

Variety of Types of Systems Rapid drain down vulnerability would only be possible with failure of the SFP gates with cavity drained, failure of multiple lines penetrating a flooded cavity, or with the siphon breaker failure combined with a SFP discharge pipe failure. The constantly pressurized SFP discharge piping is the subject of routine operator tours, and based on leak before break philosophy, and water chemistry control program, would provide reasonable assurance of continued availability. The cavity penetration piping, and siphon breakers are not routinely observed, and should be the subject of inspection.

The SFP gates and the piping from the cavity to the valves, including the valves; 19-HO-149, 150,159, 160, 161, 162, 163, 164, 170, 171, 172, 173, 177, and 179 should be the subject of a seismic walk down. The siphon breakers on the SFP discharge spargers will be visually inspected as part of the area walk-by for the SFP gates.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 22 of 37 There is one system associated with SFP cooling, the Fuel Pool Cooling and Demineralizing System.

Maior New and Replacement Equipment There have been no major new or replacement equipment installations within the past 15 years associated with the SFP. The only significant changes are the new fuel racks, which are passive structural components and are outside of the scope of this program. Therefore, this sampling attribute is not applicable.

Variety of Equipment Types The equipment types for SWEL2 consist of multiple manual drain valves associated with the drywell cavity. Therefore, this sampling attribute is not applicable.

Variety of Environments Items selected from BL2 are located in a variety of areas, both Drywell and Reactor Building. These item locations included environments that were inside as well as having high temperature and within containment. The location and environment of each item on SWEL 2 is listed on Table 9.4.5 of Attachment B.

6.3 DEFERRED INACCESSIBLE ITEMS on SWEL Each item on the SWEL is to be walked down as part of the NTTF 2.3 Seismic Walkdown program. In order to perform the seismic walkdowns of these items, it is necessary to have access to them and to be able to view their anchorage. In some cases, it was not feasible to gain access to the equipment or view its anchorage because PNPS was in operation during the entire 180-day response period of Enclosure 3 to the 50.54(f) Letter. For these cases, walkdowns of the items were deferred until the refueling outage (RFO) in April of 2013.

Twenty eight SWEL items and six AWCs, previously deferred, were inspected during the RFO19 outage and incorporated into revision 1 of this report. The additional and updated SWEL items are in Attachment J and the new AWCs are in Attachment K.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 23 of 37 7.0 SEISMIC WALKDOWNS AND AREA WALK-BYS The NTTF 2.3 Seismic Walkdown program conducted in accordance with the Guidance, involves two primary walkdown activities: Seismic Walkdowns and Area Walk-Bys. These activities were conducted at PNPS by teams of two trained and qualified Seismic Walkdown Engineers (SWEs) (see Section 4.1). Each team included one engineer with at least several years of experience in seismic design and qualification of nuclear power plant SSCs. A total of two SWE teams were used. The teams periodically "shuffled" personnel to cross-check consistency between the SWE's and to ensure that lessons learned were being shared. In addition, an operations representative accompanied the teams on days when cabinets were scheduled to be opened.

The seismic walkdowns and area walk-bys were conducted over the course of three weeks during October of 2012. Each morning, a pre-job brief with all personnel involved was conducted. This pre-job brief was used to outline the components and areas that would be walked down that day, to ensure consistency between the teams, to reinforce expectations, to identifying potential personnel safety issues specific to that day, and to allow team members to ask questions and share lessons learned in the field. The SWE teams brought cameras, tape measures, flashlights, binoculars and calipers into the field to assist with the seismic walkdowns and area walk-bys.

PNPS design engineering management was involved in pre job briefs and performed significant field observations and provided real time coaching to the teams. Both design engineering management and the NRC Senior Resident Inspector provided input to the post job briefs in addition to walkdown oversight.

7.1 SEISMIC WALKDOWNS Seismic walkdowns were performed in accordance with Section 4 of the Guidance for all items on the SWEL (SWEL 1 plus SWEL 2). To document the results of the walkdown, a separate Seismic Walkdown Checklist (SWC) with the same content as that included in Appendix C of the Guidance was created for each item. Additionally, photographs were taken of each item, and included on the corresponding SWC.

Prior to performance of the walkdowns, documentation packages were developed that contained the pre-filled out SWC and other pertinent information including the location drawings, response spectra information, previous IPEEE seismic walkdown documentation, and anchorage drawings where applicable. These documentation packages were brought with the SWE teams into the plant during the seismic walkdowns.

Walkdown inspections focused on anchorages and seismic spatial interactions, but also included inspections for other potentially adverse seismic conditions. Anchorage, in all cases,

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 24 of 37 was considered to specifically mean anchorage of the component to the structure. This included anchor bolts to concrete walls or floors, structural bolts to structural steel and welds to structural steel or embedded plates. For welds, the walkdown team looked for cracks and corrosion in the weld and base metal. Other bolts or connections, such as flange bolts on in-line components were not considered as equipment anchorage. These bolts and connections were evaluated by the SWEs and any potential adverse seismic concerns were documented under "other adverse seismic conditions" rather than under "anchorage". Thus, components with no attachments to the structure are considered as not having anchorage. Nevertheless, the attachment of these components to other equipment was evaluated and inspected for potentially adverse seismic conditions.

All cabinets/panels on the SWEL that could be reasonably opened without presenting safety or operational hazard were opened during the walkdown. This allowed visual observation of internal anchorage to the structure (where present), as well as inspection for "other adverse seismic conditions" related to internal components if it could be observed without breaking the plane of the equipment opening. Where opening the cabinet/panel required extensive disassembly (e.g., doors or panels were secured by more than latches, thumbscrews, or similar), it was excluded from internal inspection. This applied to only one of the approximately 25 panels on the SWEL. Further discussion of the specific configuration of panel D7 is provided on Seismic Walkdown Checklist SWELl-080 in Attachment C.

In addition to the general inspection requirements, at least 50% of the SWEL items having anchorage required confirmation that the anchorage configuration was consistent with plant documentation. Of the 118 SWEL items, 68 were considered to have anchorage (i.e.,

removing in-line/line-mounted components). Of these 68 anchored components, the walkdowns of 38 included anchorage configuration verification, which is greater than 50%.

When anchorage configuration verification was conducted, the specific plant documentation used for comparison to the as-found conditions was referenced on the SWC.

The SWC for each SWEL item where a seismic walkdown has been performed is included in Attachments C and J. A total of 118 SWCs are attached with the completion status marked "Y". Therefore, the 118 completed SWCs represent the completed walkdowns SWEL items, while also meeting the 50% anchorage verification.

7.2 AREA WALK-BYS Seismic area walk-bys were performed in accordance with Section 4 of the Guidance for all plant areas containing items on the SWEL (SWEL 1 plus SWEL 2). A separate Area Walk-By Checklist (AWC) with the same content as that included in Appendix C of the Guidance was used to document the results of each area walk-by performed.

One area walk-by was conducted for each plant area containing one or more SWEL items.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 25 of 37 In cases where the room or area containing a component was very large, the extent of the area encompassed by the area walk-by was limited to a radius of approximately 35 feet around the subject equipment. The extent of the areas included in the area walk-bys is described on the AWC for that area. Because certain areas contained more than one SWEL item, there are fewer total area walk-bys conducted than seismic walkdowns. A total of 38 area walk-bys were necessary to cover all plant areas containing at least one accessible SWEL item.

The AWC for each area walk-by completed is included in Attachment D. A total of 38 AWCs are included in Attachments D and K.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 26 of 37 8.0 LICENSING BASIS EVALUATIONS During the course of the seismic walkdowns and area walk-bys, the objective of the SWE teams was to identify existing degraded, non-conforming, or unanalyzed plant conditions with respect to PNPS current seismic licensing basis. This section summarizes the process used to handle conditions identified, what conditions were found, and how they were treated for eventual resolution.

CONDITON IDENTIFICATION When an unusual condition was observed by a SWE team in the field, the condition was noted on the SWC or AWC form and briefly discussed between the two SWEs to agree upon whether it was a potentially adverse seismic condition. These initial conclusions were based on experience, conservative engineering judgment, and the criteria presented in the EPRI SWE qualification training course.

For conditions that were reasonably judged by the SWE team as insignificant to seismic response, the disposition was included on the SWC or AWC checklist and the appropriate question was marked "Y", indicating that no potentially adverse seismic condition was observed.

Unusual or uncertain conditions that could not be readily dispositioned by the SWE team in the field were photographed, summarized on the SWC or AWC checklist, and communicated to the Lead Engineer, Operations Team Member, and Peer Review Lead. Based on the nature of the identified condition, it was then either addressed via the Licensing Basis Evaluation (LBE) process or entered into the Corrective Action Program (CAP) for resolution.

This process resulted in a total of 68 conditions requiring disposition. Seventeen of these were considered to have some degree of seismic significance and are documented in Attachment E of this report. Three of the 17 seismic conditions were resolved via the LBE process. Fourteen of 17 potential seismic issues were entered into the CAP. The remaining 51 conditions were considered to have no seismic significance but required some attention and were therefore entered into the CAP for resolution. These were generally housekeeping type issues or instances of minor degradation of structures or equipment. The Condition Reports for the 51 miscellaneous conditions are referenced in the associated SWC or AWC checklists.

CONDITION RESOLUTION Conditions observed during the seismic walkdowns and area walk-bys determined to be potentially adverse seismic conditions are summarized in Attachment E, including how each condition has been addressed and its current status. Each potentially adverse seismic

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 27 of 37 condition is addressed either with a Licensing Basis Evaluation (LBE) to determine whether it requires entry into the CAP, or by entering it into the CAP directly. The decision to conduct a LBE or enter the condition directly into the CAP was made on a case-by-case basis, based on the perceived efficiency of each process for eventual resolution of each specific condition.

Unusual conditions that were not seismically significant were entered into the CAP directly.

Further resolution of these conditions is not tracked or reported as part of the NTTF 2.3 Seismic Walkdown program, except by noting the CR numbers generated on the applicable SWCs and AWCs.

8.1 LICENSING BASIS EVALUATIONS Potentially adverse seismic conditions identified as part of the NTTF 2.3 Seismic Walkdown program may be evaluated by comparison to the current licensing basis of the plant as it relates to the seismic adequacy of the equipment in question, as is described in Section 5 of the Guidance. If the identified condition is consistent with existing seismic documentation associated with that item, then no further action is required. If the identified condition cannot readily be shown to be consistent with existing seismic documentation, or no seismic documentation exists, then the condition is entered into the CAP.

Of the 17 identified potentially adverse seismic conditions, 4 LBEs were performed. Each LBE performed is documented consistently, and included in Attachment F. The results of these LBEs with respect to the associated potentially adverse seismic conditions are summarized in Attachment E. All four potentially adverse seismic conditions evaluated using a LBE were dispositioned or resolved by way of a work order and require no further action.

8.2 CORRECTIVE ACTION PROGRAM ENTRIES Conditions identified during the seismic walkdowns and area walk-bys that required further resolution were entered into the plant's CAP. These were reviewed in accordance with the plant's existing processes and procedures for an eventual disposition.

A total of 65 Condition Reports (CRs) were generated from the CAP as a result of the NTTF 2.3 Seismic Walkdown program. Of those, the majority (51) were from seismically insignificant unusual conditions. A total of 14 CRs were written relative to potentially adverse seismic conditions identified. Six of the 14 CRs were related to open s-hooks on hanging light fixtures. Five of the CRs were associated with unsecured miscellaneous items located in proximity to safety-related equipment and not meeting the requirements of the plant's seismic interaction hazard procedure. The remaining three CRs involved: an electrical conduit in contact with the motor operator of a safety-related valve, a sheet metal cover for a safety-related cable tray not securely fastened in place, and a degraded small-bore non-safety-related pipe support located in proximity to safety-related equipment. The CR

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 28 of 37 numbers, current status, and resolution (where applicable and available) are summarized for these potentially adverse seismic conditions in Attachment E.

8.3 PLANT CHANGES The CAP entries (CRs) generated by the NTTF 2.3 Seismic Walkdown program are being resolved in accordance with the plant CAP and work control process. None of the conditions identified by this program resulted in the associated equipment being declared inoperable or non-functional. None of the identified conditions resulted in the requirement for a plant design change. Work requests were initiated for required maintenance/repairs for each of the CRs that could not be dispositioned or closed based on the immediate actions taken.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 29 of 37 9.0 PEER REVIEW 9.1 PEER REVIEW PROCESS The peer review for the NTTF Recommendation 2.3 Seismic Walkdowns was performed in accordance with Section 6 of the Guidance. The peer review included an evaluation of the following activities:

review of the selection of the structures, systems, and components, (SSCs) that are included in the Seismic Walkdown Equipment List (SWEL);

• review of a sample of the checklists prepared for the Seismic Walkdowns and area walk-bys; review of licensing basis evaluations and decisions for entering the potentially adverse conditions in to the plant's Corrective Action Plan (CAP); and review of the final submittal report.

The peer review team (see Section 4.5) was involved in the peer review of each activity, the team member with the most relevant knowledge and experience taking the lead for that particular activity. A designated overall Peer Review Team Leader provided oversight related to the process and technical aspects of the peer review, paying special attention to the interface between peer review activities involving different members of the peer review team.

9.2 PEER REVIEW RESULTS

SUMMARY

The following sections summarize the process and results of each peer review activity.

9.2.1 Seismic Walkdown Equipment List Development SWEL 1: The SWEL associated with the sample of items that support the 5 safety functions: A) Reactor Reactivity Control, B) Reactor Coolant Pressure Control, C) Reactor Coolant Inventory Control, D) Decay Heat Removal and E) Containment Function.

The SWEL 1 for PNPS was developed by in-house Contractors and operations staff knowledgeable and experienced with PNPS systems and components, using PNPS USI A-46 Safe Shutdown Equipment List (SSEL) as the base list. It was subject to review and approval by PNPS Operations department. Based on discussion /

decisions between the Equipment Selection Personnel and the Peer Reviewers the SWEL list Table 9.4.2 added a column (System Type) to identify which components are associated with the five safety functions. Also a column was added to identify the PNPS system number for each component.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 30 of 37 A preliminary SWEL 1 was available for review by the Peer Review Team on 9/13/12.

Reviews were performed and comments entered on EN-DC-1 68 Attachment 9.11 Peer Review Comment Form [Ref. Attachment H]. All comments were later resolved and the SWEL 1(EN-DC-168 Attachment 9.4) was signed by the Peer Reviewer on 9/27/12.

In summary the SWEL 1 contains:

14 components associated with Reactor Reactivity Control 46 components associated with Reactor Coolant Pressure Control 71 components associated with Reactor Coolant Inventory Control 48 components associated with Decay Heat Removal 15 components associated with Containment Function Note: this adds up to more than the 102 components on SWEL 1 because many components serve dual safety functions.

Both "A" and "B"trains were well represented in SWEL 1.

Based on discussion / decisions between the Equipment Selection Personnel and the Peer Reviewers' components were added from Class 2, 9 and 19 to the SWEL 1.

Based on discussion / decisions between the Equipment Selection Personnel and the Peer Reviewers, three HPCI (System 23) components were added to the SWEL.

PNPS has 17 Systems on the SSEL and the SWEL 1 contains components from 13 of these systems. In addition, the SSEL contains 21 equipment classes and the SWEL 1 contains components from 19 of these equipment classes.

SWEL 1 components are located throughout the plant including the Reactor Building EI.23' east and west sides, Reactor Building E1.51' east and west sides, Reactor Building 51' RWCU Heat Exchanger Room, "A" Valve Room, "A" RHR Quad, RCIC Quad, Control Room, SSW Pump Room, Cable Spreading Room, "A" and "B" Switchgear Rooms, "A" and "B" Battery Rooms. "A" and "B" EDG Rooms, MG Set Room (El. 23'), Drywell, and Steam Tunnel. These represent a variety of environments.

Based on discussion / decisions between the Equipment Selection Personnel and the Peer Reviewers two "Major New or Replacement Equipment": transformer X55 (SWEL 1-083) and pump P203A (SWEL 1-010) were added.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 31 of 37 Based on discussion / decisions between the Equipment Selection Personnel and the Peer Reviewers, one vulnerability identified during the IPEEE Program: the A8 Switchgear hold-down bolts (SWEL 1-014) was added.

Therefore it is concluded that the SWEL 1 adequately represents a diverse sampling of components for the seismic walkdowns.

SWEL 2: The SWEL associated with the sample of items related to the Spent Fuel Pool The SWEL 2 for PNPS was developed by in-house Contractors and Operations knowledgeable and experienced with PNPS systems and components using the screens in EPRI 1025286.

A preliminary SWEL 2 was available for review by the Peer Review Team on 9/13/12.

Reviews were performed and comments entered on EN-DC-1 68 Attachment 9.11 Peer Review Comment Form. All comments were later resolved and the SWEL 2 (EN-DC-168 Attachment 9.4) was signed by the Peer Reviewer on 9/27/12.

The peer review checklist of the SWEL is provided in Attachment G.

9.2.2 Seismic Walkdowns and Area Walk-Bys Peer review of the seismic walkdowns and area walk-bys was conducted by two peer reviewers. The Peer Review Team Leader is qualified to SQUG Methodology (SQUG Walkdown Screening and Seismic Evaluation Training Course) and a qualified SWE (EPRI Training on NTTF 2.3-Plant Seismic Walkdowns). The other Peer Reviewer was involved in the response to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46 and has broad knowledge of seismic engineering applied to nuclear power plants. The peer reviews were conducted at the Pilgrim Nuclear Power Station (PNPS) concurrent with the conduct of walkdowns. The peer review was performed as follows:

The peer review team lead reviewed the walkdown packages (including checklists, photos, drawings, etc.) for SWEL items already completed to ensure that the checklists were completed in accordance with the Guidance. A total of 63 SWC and 16 AWC forms were reviewed, each representing approximately

[61% and 50%] of their respective totals. In the context of the Guidance, the peer review team considered the number of walkdown packages reviewed to be

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 32 of 37 appropriate. The packages reviewed represent a variety of equipment types in various plant areas. Specific SWC forms reviewed are SWELl-005, 006, 010, 011, 012, 013, 015, 017, 018, 020, 021, 022, 026, 027, 028, 029, 030, 031, 032, 033, 035, 036, 037, 039, 040, 041,042, 043, 044, 045, 048, 049, 050, 051,052, 053, 054, 055, 056, 057, 058,059, 060, 061,062,065, 066, 067, 068, 069,070, 073, 077, 083, 085, 086, 089, 090, 091, 092, 097, 101, and 103. Specific AWC forms reviewed are AWC-001, 003, 004, 005, 006, 007, 008, 016, 017, 018, 019, 020, 021, 029, 031 and 032.

• While reviewing the walkdown packages, the peer reviewers conducted informal interviews of the SWEs and asked clarifying questions to verify that they were conducting walkdowns and area walk-bys in accordance with the Guidance.

• The peer review team held a meeting with the SWE teams daily to provide feedback on the walkdown and walk-by packages reviewed and the informal interviews, and discuss potential modifications to the documentation packages in the context of the Guidance.

• The peer review team leader accompanied SWE teams into the field and observed them perform a walkdown of a SWEL component and its associated area walk-by. During these observations, the peer reviewer asked clarifying questions to verify the walkdown and walk-by process being followed was in accordance with the Guidance. The items walked down under the observation of a peer reviewer are SWELl-005, 026, 027, 028, 029, 030, 031, 032, 033, 036, 037, 040,041,042, 043, 044, 045, 052, 053, 065, 066, 067, 068, 073, 085,086, 091, 092, 101and 103. The associated area walk-bys performed under the observation of a peer reviewer are AWC-001, 006, 008, 016 and 029.

• The peer review team held a meeting with the SWE teams daily to provide feedback on the walkdown and walk-by observations, and discuss how lessons learned from review of the walkdown packages had been incorporated into the walkdown process.

As a result of the peer review activities, the SWE teams modified their documentation process to include additional clarifying details, particularly related to checklist questions marked "N/A" and where conditions were observed but judged as insignificant. Peer review identified some generic deficiencies (i.e. floor elevation discrepancies on SWEL Checklist; identification of cabinets that could not be opened; missing references to adjacent masonry block walls; anchorage of components on racks). The peer review team felt these modifications would be of benefit for future reviews of checklists incorporated into the final report. These modifications were recommended following review of the walkdown and area walk-by packages, and the observation walkdowns and area walk-bys demonstrated that the SWEs understood

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 33 of 37 the recommendations and were incorporating them into the walkdown and area walk-by process. Previously completed checklists were revised to reflect lessons learned from the peer review process.

Based on completion of the walkdown and walk-by peer review activities described, the peer review team concluded that the SWE teams were familiar with and followed the process for conducting seismic walkdowns and area walk-bys in accordance with the Guidance. The SWE teams adequately demonstrated their ability to identify potentially adverse seismic conditions such as adverse anchorage, adverse spatial interaction, and other adverse conditions related to anchorage, and perform anchorage configuration verifications, where applicable. The SWEs also demonstrated the ability to identify seismically-induced flooding interactions and seismically-induced fire interactions such as the examples described in Section 4 of the Guidance. The SWEs demonstrated appropriate use of self checks and peer checks. They discussed their observations with a questioning attitude, and documented the results of the seismic walkdowns and area walk-bys on appropriate checklists.

9.2.3 Licensing Basis Evaluations The Lead Peer Reviewer reviewed, on a daily basis, the Condition Reports (CR) written each day as a result of potential adverse conditions identified during the seismic walkdowns and agreed with the decisions to enter the CAP (Corrective Action Process). The threshold for entering the corrective action process was very low as evidenced by the 59 CRs written during the walkdowns. No assumptions were made by the SWE teams that the potentially adverse conditions would be or had been identified by some other workgroup or area owner.

Three Licensing Basis (LB) Evaluations were written by the walkdown teams. LB Evaluation No. 001 for SWEL 1-55, 56; LB Evaluation No. 002 for SWEL 1-13,17,18; and LB Evaluation No. 003 for SWEL 1-82. These were reviewed, found to be satisfactory, and signed by the Lead Peer Reviewer. No other Licensing Basis Evaluations were judged to be required.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 34 of 37 9.2.4 Submittal Report A draft (90 % complete) submittal Report was made available to the Peer Reviewers on 10/31/12. The Peer Reviewers reviewed the Report (including all attachments) and provided comments. The Peer Review Team Leader reviewed the report for compliance with the requirements of the EPRI Guidance document and Entergy Procedure EN-DC-168, Rev. 0. Team Leader comments were provided to the report preparer on 11/6/12 on Attachment 9.11 Peer Review Comment Form. On 11/14/12 the Peer Review Team Leader reviewed the revised Report (including attachments) and was satisfied that all comments were adequately addressed.

9.3 PEER REVIEW PROCESS - DEFERRED SCOPE ACTIVITIES This section addresses the peer review effort associated with the Fukushima NTTF 2.3 Seismic Walkdown activities that were deferred due to plant accessibility restrictions during the initial walkdown phase performed in October 2012. All of the deferred scope seismic walkdowns and area walk-bys were completed as of the end of the PNPS Refueling Outage (RFO19) in May 2013. As a point of reference, it is estimated that the initial phase activities (Rev.0 of this report) represented approximately 80% of the overall project scope with the remaining 20% completed as deferred scope (Rev.1 of this report).

The deferred scope specifically included:

• Seismic Walkdown Checklists (28 SWEL items)

• Area Walkby Checklists (6 Plant Areas)

" Licensing Basis Evaluation (1 issue evaluated)

• Development of Revision 1 of the submittal report There were no changes that affected the IPEEE Vulnerabilities Evaluations and no changes to the equipment originally selected for inspection (SWEL). Therefore, no additional peer review associated with these two topics is required.

Dr. Fred Mogolesko (bio in Section 4.5) served as overall Peer Review Team Lead for the deferred scope activities. Dr. Mogolesko reviewed the Revision 1 submittal report for overall completeness, quality, and procedural/regulatory compliance. He was supported by additional team members as described below:

Seismic Walkdown Checklists and Area Walk-by Checklists:

Peer Review of the SWCs and AWCs was performed by Laura Maclay of Enercon Services (bio in Section 4.0). Ms. Maclay is a qualified Seismic Walkdown Engineer who participated directly in the initial scope plant walkdowns at PNPS as well as other sites but was not

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 35 of 37 involved in the performance of the PNPS deferred scope walkdowns. Review comments were incorporated into the SWCs and AWCs as appropriate (see Attachment H).

Licensing Basis Evaluation (LBE):

Peer review of the one new Licensing Basis Evaluation was performed by Jeffrey Kalb of PNPS (bio in Section 4.5) who previously served as Peer Review Team Lead for the initial phase of the project. Review comments regarding pressure transient effects on the unrestrained shielding blocks were incorporated into LBE-004 (see Attachments F & H).

Submittal Report Revision 1:

David Small of PNPS (bio in Section 4.0) and Juan Vizcaya of Enercon Services performed the peer review of this Revision 1 of the submittal report. The resulting miscellaneous editorial and formatting comments have been incorporated into the final product as appropriate (see Attachment H).

Summary of Overall Effectiveness of Peer Review Effort:

The peer review effort for the deferred scope activities did not identify any significant process-type weaknesses. This was to be expected given that this involved a continuation of an established program that had been refined via lessons learned at PNPS, the Entergy fleet during the initial (much larger) phase of the project, and industry. The peer review comments tended to be editorial in nature and/or related to effectively incorporating the new information into the existing report structure. The peer review effort is considered to have been effective in ensuring that the standards and expectations established during the initial project phase were maintained and ultimately resulted in a high quality and well integrated final submittal report.

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 36 of 37

10.0 REFERENCES

1. 10CFR50.54(f) Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 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-lchi Accident, dated March 12, 2012

2. EPRI 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, June 2012

3. Pilgrim Nuclear Power Station Final Safety Analysis Report (FSAR) Sections 2, 12 and Appendix C, Revision # 28

4. Generic Letter No. 88-20, Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities

5. PNPS Seismic Individual Plant Examination of External Events (IPEEE) Submittal Report GL88-20, Revision 0, June 1994

6. Generic Letter No. 87-03, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46

7. Seismic Qualification Utility Group (SQUG) Procedure: Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Power Plant Equipment, Revision 3A, December 2001

8. EN-DC-168, Fukushima Near-Term Task Force Recommendation 2.3 Seismic Walk-down Procedure, Revision 0

9. TDBD 118, Topical Design Basis Document for Seismic Design, Revision 1

10. Specification C-114-ER-Q-E1, Seismic Response Spectra, Revision 1

11. Uniform Building Code (UBC), 1967

12. American Institute of Steel Construction (AISC) Specification for the Design, Fabrication, and Erection of Structural Steel for Buildings, 6 th edition to current

13. American Concrete Institute (ACI) Building Code Requirements for Reinforced Concrete, ACI 318-63

14. American Welding Society (AWS) Standard Code for Arc and Gas Welding in Building Construction, AWS D.1.0-66

15. ASME Boiler and Pressure Vessel Code,Section III, Class B, current edition

Engineering Report No. PNPS-CS-12-00001 Rev. 1 Page 37 of 37 11.0 ATTACHMENTS ATTACHMENT A - IPEEE VULNERABILTIES TABLE ATTACHMENT B - SEISMIC WALKDOWN EQUIPMENT LISTS ATTACHMENT C - SEISMIC WALKDOWN CHECKLISTS (SWCs)

ATTACHMENT D - AREA WALK-BY CHECKLISTS (AWCs)

ATTACHMENT E - POTENTIALLY ADVERSE SEISMIC CONDITIONS ATTACHMENT F - LICENSING BASIS EVALUATION FORMS ATTACHMENT G - PEER REVIEW CHECKLIST FOR SWEL ATTACHMENT H - PEER REVIEW COMMENT FORM ATTACHMENT I - SEISMIC WALKDOWN ENGINEER TRAINING CERTIFICATES ATTACHMENT J - DEFERRED SEISMIC WALKDOWN CHECKLISTS (SWCs)

ATTACHMENT K - DEFERRED AREA WALK-BY CHECKLISTS (AWCs)