ML13151A052

Plan for the Regulatory Audit Regarding Seismic Walkdowns at Beaver Valley, to Support Implementation of Near-Term Task Force Recommendation 2.3, Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident

ML13151A052
Person / Time
Site:	Beaver Valley
Issue date:	06/17/2013
From:	Peter Bamford Plant Licensing Branch 1
To:	Emily Larson FirstEnergy Nuclear Operating Co
Regner L, NRR/JLD, 415-1906
References
TAC MF0092, TAC MF0093
Download: ML13151A052 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 17,2013 Mr. Eric A. Larson, Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - PLAN FOR THE REGULATORY AUDIT REGARDING SEISMIC WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS. MF0092 AND MF0093)

Dear Mr. Larson:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued a request for information letter1 per Title 10 of the Code of Federal Regulations, Subpart 50.54(f) (50.54(f) letter). The 50.54(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staffs evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great T5hoku Earthquake and subsequent tsunami. The request addressed the methods and procedures for plants to conduct seismic and flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.

By letter dated November 27, 2012,2 FirstEnergy Nuclear Operating Company submitted a Seismic Walkdown Report as requested per Enclosure 3, "Recommendation 2.3: Seismic," of the 50.54(f) letter for Beaver Valley Power Station, Units 1 and 2 (Beaver Valley). By letter dated April 29, 2013,3 FirstEnergy Nuclear Operating Company submitted a supplement to the Seismic Walkdown Report. The NRC staff plans to conduct a regulatory audit in accordance with the enclosed regulatory audit plan from July 23 - July 25, 2013, to verify information and gain a better understanding of your conduct of the seismic walkdowns at Beaver Valley.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340.

2 ADAMS Accession No. ML13008A029.

3 ADAMS Accession No. ML13135A539.

E. Larson -2 If you have any questions, please contact me by telephone at 301-415-2833 or bye-mail at Peter. Bamford@nrc.gov.

Sincerely, Peter J. Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

Beaver Valley Power Station Audit Plan cc w/encl: Distribution via Listserv

Audit Plan Beaver Valley Power Station, Units 1 and 2

1. Background On March 12,2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued a request for information letter1 per Title 10 of the Code of Federal Regulations, Subpart 50.54(f) (50.54(f) letter). The request addressed, in part, the conduct of seismic walkdowns to identify and address degraded, non-conforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures.

2. Regulatory Audit Bases The NRC staff is conducting regulatory audits at a small number of operating reactors to gain a better understanding of the seismic walkdown methods and associated procedures used by licensees to prepare the Seismic Walkdown Report and to assist the NRC staff in preparing its safety assessment.

The guidance for performing the seismic walkdowns was developed by the Electric Power Research Institute (EPRI) with extensive review and input from NRC staff in numerous public meetings, webinars, and public conference calls during its development. The EPRI submitted EPRI-1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic,,,2 (walkdown guidance) for endorsement, and the NRC staff subsequently endorsed the walkdown guidance by letter dated May 31, 2012.3 The 50.54(f) letter and the walkdown guidance are the basis documents for the conduct of the regulatory audit.

3. Regulatory Audit Scope The purpose of the seismic site audit will be to gain a better understanding of the conduct and outcomes of the seismic walkdowns and identify any need for additional information to facilitate the NRC staff's review of the licensee's walkdown report and prepare the NRC staff assessment. If necessary, the NRC staff will request additional information using the appropriate regulatory process.

The scope of this regulatory audit is to determine if the seismic walkdowns conducted by FirstEnergy Nuclear Operating Company (FENOC, the licensee) to identify and address degraded, non-conforming, or unanalyzed conditions, were conducted in accordance with the 50.54(f) letter and the walkdown guidance; and whether FENOC verified the adequacy of the monitoring and maintenance procedures in compliance with the 50.54(f) letter and the walkdown guidance.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340.

2 ADAMS Accession No. ML12164A181.

3 ADAMS Accession No. ML12145A529.

Enclosure

-2 The general process used to conduct the regulatory audit involves examination of related seismic walkdown documents, discussions with the seismic walkdown program participants, and examination of selected equipment or areas of the site that were walked down. This process is tailored for a site-specific audit, as applicable.

The NRC staff reviewed the licensee's walkdown report and compared it with the requested information in the 50.54(f) letter and the walkdown guidance. The factors that the NRC staff considered in choosing sites to audit were based, in part, on one or more of the following:

• Questions concerning whether the walkdown was performed consistent with the guidance.

• Consideration of feedback and information gained during performance of regional inspections (e.g., Temporary Instruction 2515/188).

• Consideration of apparent seismicity relative to the current design basis or margins identified in the Individual Plant Examination for External Event (IPEEE) reviews.

Sections 4, 8, and 9 provide additional details regarding needed documentation, schedule, and specific focus areas.

4. Information Needs The licensee is requested to have the following information available on site for the audit team.

The information could be provided electronically or by paper copies. If provided electronically, the licensee is requested to have at least three computers available for the audit team, with a printer attached.

• Engineering reports and procedures that contain requirements or guidelines for the implementation of the seismic walkdown guidance, including current seismic licensing basis.

• Description of process used for the peer review and the peer review report.

• Implementing procedures for the 50.54(f) letter, Enclosure 3, Seismic Walkdowns, including procedures for the seismic walkdowns themselves.

• Procedure for development of the seismic walkdown base lists and equipment lists (Le.,

SWEL [seismic walkdown equipment list] 1 and SWEL 2).

• Drawings of equipment anchorages for equipment selected for anchorage verifications.

• Discussion of training and qualifications (per Section 2 of the walkdown guidance) for personnel associated with seismic walkdown activities.

• Description of the process for licensing basis evaluations (per Section 5 of the walkdown guidance) and entry into the corrective action program, including condition report number, title, and brief summary of any issues or observations and their disposition.

• The list of seismic vulnerabilities that were identified during the IPEEE program, as discussed in Section 7 of the guidance document.

- 3

• The original walkdown and walk-by checklists The NRC staff also requests the licensee to make personnel that performed the walkdowns (including site staff and contractors) accessible upon request (either in person or by phone).

Additional information needs identified during the audit will be communicated to the designated point of contact.

5. NRC Audit Team James Isom (NRC)

Technical Lead Annie Kammerer (NRC)

Technical Support Erin Carfang (NRC)

Technical Support Yu Tang (contractor)

6. Logistics The audit will be conducted at Beaver Valley from July 23 - July 25, 2013. Entrance and exit briefings will be held with the licensee at the beginning and end of this audit, respectively, as well as daily de briefings of team activities. A more detailed proposed audit schedule is provided below.

7. Deliverables An audit report/summary should be issued to the licensee within 90 days from the end of the audit. Additionally, the results of the audit will be utilized to focus the scope of any requests for additional information issued in the course of this review.

8. Proposed Seismic Walkdown Audit Schedule Tuesday, July 23 7:30 a.m. Arrival of audit team members and site badging 10:00 a.m. Entrance Meeting 10:30 a.m. Walkdown Process Orientation with licensee 11:30 a.m. -12:15 p.m. LUNCH 12: 15 p.m. - 4:00 p.m. Discussions with licensee, NRC document review, or plant walkdowns 4:00 p.m. Team meeting 5:30 p.m. Team Lead daily debrief with licensee

-4 Wednesday, July 24 7:30 a.m. Team meeting 8:30 a.m. Continue discussions with licensee, plant walkdowns, etc.

11 :30 a.m. - 12:15 p.m. LUNCH 12: 15 p.m. - 4:00 p.m. Discussions with licensee, plant walkdowns, etc.

4:00 p.m. Team meeting 5:30 p.m. Team Lead daily debrief with licensee Thursday, July 25 7:30 a.m. Team meeting 8:30 a.m. Continue discussions with licensee, plant walkdowns, etc.

11:30 a.m. -12:15 p.m. LUNCH 12:15 p.m. - 3:00 p.m. Discussions with licensee, plant walkdowns, etc.

3:00 p.m. Exit Meeting

9. Specific Topics for Discussion The review will touch upon several key areas of the walkdown activities undertaken by FENOC including:

• Qualification and training of participants.

• Development of SWEL 1 and SWEL 2.

• Conduct of the walkdowns.

• Process to address potential seismic issues identified in the walkdowns and current status, if items identified.

• The peer review process.

During the report review, some items of particular interest were identified:

• The seismic walkdown guidance document provides guidance on the need for participants to have certain specific backgrounds and qualifications to effectively carry out their roles. The NRC staff would like to discuss the backgrounds of the team members as it relates to experience in the seismic field and walkdown training.

• The seismic walkdown guidance provides clear instructions on the scope of peer review and the experience and independence of the peer reviewers. The NRC staff would like to discuss the conduct of the peer review.

• The seismic walkdown guidance provides guidance and instructions on both the conduct and the reporting of the seismic walkdowns and area walk-bys. The NRC staff would like to discuss the conduct of the equipment walkdowns and area walk-bys, including the

- 5 approach to anchorage verification, the approach to inspecting cabinets, the schedule for conducting the audits, and the treatment of the checklists.

• The seismic walkdown guidance provides clear guidance on the approach to addressing potential seismic issues found in the walkdowns. The NRC staff would like to discuss the approach used to disposition potential issues identified, including the reporting of issues not shown to be in compliance with the licensing basis, the timeline for these activities, as well as the current status and reporting of items entered into the corrective action program.

E. Larson - 2 If you have any questions, please contact me by telephone at 301-415-2833 or bye-mail at Peter.Bamford@nrc.gov.

Sincerely, IRAJ Peter J. Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosure:

Beaver Valley Power Station Audit Plan cc w/enc\: Distribution via Listserv DISTRIBUTION:

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