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)

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ENCLOSURE toPNPS Letter 2.13.056Pilgrim Nuclear Power Station (PNPS)SEISMIC WALKDOWN REPORT UPDATE Engineering Report No. PNPS-CS-12-00001 Rev IPage 1 of 37-EntergyENTERGY NUCLEAREngineering Report Cover SheetEngineering Report Title:Pilgrim Station Seismic Walkdown Submittal Reportfor Resolution of Fukushima Near-Term Task Force Recommendation 2.3: SeismicEngineering Report Type:New El Revision 0 Cancelled El] Superseded

[]Superseded by:Applicable Site(s)iPi E3 IP2 ElAN01 C] AN02 C]EC No. 45081IP3 ElECH [EJAF ElGGNS FlPNPSRBS ElVY E]WF3 [:1wpo ElPLP ElReport Origin:Entergy El VendorVendor Document No.:Quality-Related:

El YesZ NoPrepared by: Laura Maclay f2 -Q QL-(P nt Name/Sign)

,,JJuan Vizcaya Reviewed by:Reviewed by:Ow$e Pn me/Sign)Fred Moaolesko iDate: (0/17/13Date: , ___Date:Date:_ _ _Date:_ _ _Peer Review Team Leader (Pnt Name/Sign)

Approved by: Thomas WDhe &Lu dk xDesign Ma me/Sign)

UApproved by: Ray Pace ;Zf4n:( '96ýrýame/Sign)

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 2 of 37Revision Description of Change0 Initial IssueReport 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 Itemsare 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 inAttachment J).* Revised Attachment E to reflect deferred scope results and currentstatus of identified seismic issues.* Revised Attachment F to include one new LBE resulting from deferredscope walkdowns.

• Revised Attachment H to include deferred scope peer reviewcomments.

• 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. 1Page 3 of 37Pilgrim Station Seismic Walkdown Reportfor Resolution of Fukushima Near-Term Task Force Recommendation 2.3: SeismicTABLE OF CONTENTSSection Title Page1.0 SCO PE A ND O BJECTIVE

.........................................................................................................................

42.0 SEISMIC LICENSING BASIS SUMMARY ...........................................................................................

52.1 SAFE SHUTDOW N EARTHQUAKE (SSE) .........................................................................................

52.2 DESIGN CODES, STANDARDS, AND METHODS 5...............................................................................

53.0 SEISMIC WALKDOWN PROGRAM IMPLEMENTATION APPROACH

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84.0 PERSONNEL QUALIFICATIONS

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94.1 EQ UIPM ENT SELECTIO N PERSO NNEL .........................................................................................

124.2 SEISM IC W A LKDO W N ENG IN EERS ................................................................................................

124.3 LIC E N S IN G BA S IS R EV IEW E R S ........................................................................................................

124 .4 IP E E E R E V IE W E R S .............................................................................................................................

124 .5 P E E R R E V IE W T E A M ..........................................................................................................................

135.0 IPEEE VULNERABILITIES REPORTING

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156.0 SEISMIC WALKDOWN EQUIPMENT LIST DEVELOPMENT

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166.1 SAMPLE OF REQUIRED ITEMS FOR THE FIVE SAFETY FUNCTIONS

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166 .2 S P E N T F U E L P O O L IT E M S .................................................................................................................

206.3 DEFERRED INACCESSIBLE ITEMS on SWEL ......................................

227.0 SEISMIC WALKDOWNS AND AREA WALK-BYS

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237 .1 S E IS M IC W A LK D O W N S ..................................................................

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2 37 .2 A R E A W A L K -B Y S .................................................................................................................................

2 48.0 LICENSING BASIS EVALUATIONS

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26CONDITON IDENTIFICATION

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26C O N D IT IO N R E S O LU T IO N .............................................................................................................................

268.1 LIC EN SING BA SIS EVA LUATIO NS ..................................................................................................

278.2 CORRECTIVE ACTION PROGRAM ENTRIES .................................................................................

278 .3 P L A N T C H A N G E S ...............................................................................................................................

8 2 89.0 PE E R R EV IEW ........................................................................................................................................

299.1 P E E R R E V IE W P R O C E S S ...................................................................................................................

299.2 PEER R EV IEW RESULTS SUM M A RY 29.............................................................................................

299.3 PEER REVIEW PROCESS -DEFERRED SCOPE ACTIVITIES

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3410.0 R EFER EN C ES .........................................................................................................................................

3611.0 A TTA C H M ENTS ......................................................................................................................................

37ATTACHMENT A -IPEEE VULNERABILTIES TABLE ..............................................................................

AlATTACHMENT B -SEISMIC WALKDOWN EQUIPMENT LISTS ....................

B..............................................

B1ATTACHMENT C -SEISMIC WALKDOWN CHECKLISTS (SWCs) .........................................................

C1ATTACHMENT D -AREA WALK-BY CHECKLISTS (AWCs) .........................................................................

D1ATTACHMENT E -POTENTIALLY ADVERSE SEISMIC CONDITIONS

..................................................

ElATTACHMENT F -LICENSING BASIS EVALUATION FORMS .................................................................

F1ATTACHMENT G -PEER REVIEW CHECKLIST FOR SWEL .................................................................

G1ATTACHMENT H -PEER REVIEW COMMENT FORM .............................................

H1ATTACHMENT I -SEISMIC WALKDOWN ENGINEER TRAINING CERTIFICATES

.....................................

I1ATTACHMENT J -DEFERRED SEISMIC WALKDOWN CHECKLISTS (SWCs) ...........................................

J1ATTACHMENT K -DEFERRED AREA WALK-BY CHECKLISTS (AWCs) ....................................................

K1 Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 4 of 371.0 SCOPE AND OBJECTIVE The Great Tohoku Earthquake of March 11, 2011 and the resulting tsunami caused anaccident at the Fukushima Dai-ichi nuclear power plant in Japan. In response to thisaccident, 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 makeadditional improvements to its regulatory system. On March 12, 2012 the NRC issued a10CFR50.54(f)

Letter [Ref. 1] requesting information from all licensees to support the NRCstaff's evaluation of several of the NTTC recommendations.

To support NTTFRecommendation 2.3, Enclosure 3 to the 50.54(f)

Letter requested that all licensees performseismic 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 NuclearEnergy Institute (NEI), published industry guidance for conducting and documenting theseismic 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 ofNTTF Recommendation 2.3: Seismic.The objective of this report is to document the results of the seismic walkdown effortundertaken for resolution of NTTF Recommendation 2.3: Seismic in accordance with theGuidance, and provide the information necessary for responding to Enclosure 3 to the50.54(f)

Letter.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 5 of 372.0 SEISMIC LICENSING BASIS SUMMARYPilgrim Nuclear Power Station (PNPS) is a boiling water reactor (BWR) located in Plymouth, Massachusetts.

The Nuclear Steam Supply System (NSSS) was originally designed by GEand PNPS began commercial operation in December of 1972, and is currently rated at 688MWe 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 SeismicWalkdown program.2.1 SAFE SHUTDOWN EARTHQUAKE (SSE)In accordance with Criterion 2, "Design Bases for Protection Against Natural Phenomena",

of10 CFR 50, Appendix A, structures,

systems, and components important to safety aredesigned to withstand the effects of natural phenomena such as earthquakes without loss ofthe capability to perform those safety functions necessary to cope with appropriate margin toaccount 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 groundacceleration with vertical accelerations equal to 2/3 of the horizontal ground acceleration

[Ref3].The seismic input motion is considered to be applied at "estimated foundation depths" whichcorresponds 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 dampingvalues are the lower limits of commonly accepted ranges for the stress levels associated withthe respective earthquakes based on recommendations by Newmark and Hall inNUREG/CR-0098.

2.2 DESIGN CODES, STANDARDS, AND METHODSSeismic Input to Structures and Equipment PNPS was designed to withstand the effects of seismic events applicable to Class Isystems.

The Final Safety Analysis Report (FSAR) [Ref. 3] describes Class I SSCs asthose structures, equipment, and components whose failure or malfunction mightcause or increase the severity of an accident which would endanger the public healthand 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. 1Page 6 of 37the responses of the two horizontal seismic motions are considered to be appliedsimultaneously and in combination with all other applicable design loads. The largercombination, 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 orSeismic Category II depending on the safety-related function.

None of the structures at PNPS have classifications that are partially Seismic Category I and partially SeismicCategory 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 inaccordance with Section 12.2 and Appendix C of the FSAR and TDBD118 TopicalDesign 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 theamplified floor response spectra corresponding to the support elevations of theequipment.

Conservatively, peak values of the applicable floor response spectrumwere used in calculating the earthquake loads. For the replacement piping valves andpumps, the equipment was analyzed as part of the piping system.Piping systems were dynamically analyzed or reanalyzed using the responsespectrum method of analysis.

For each of the piping systems, a mathematical modelconsisting of lumped masses at discrete joints was constructed.

Valves were alsoconsidered as lumped masses in the pipe.There are many Class I components and equipment that are not typically designed orsized directly by stress analysis techniques.

These components and equipment areusually designed by tests and empirical experience.

Detailed stress analysis iscurrently not practical for evaluation of the components.

Examples include valves,pumps and electrical equipment.

Field experience and testing are used to support thedesign.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 7 of 37Seismic Interaction (Spatial, Fire, and Flood)Seismically induced fire interactions include inadequately stored flammable andhazardous

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 ortied 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 systemshave empty pipes. In these systems, the water is controlled (i.e., held out) by aseparate heat detection system. Deluge systems have "open" sprinkler heads or waterspray nozzles and pre-action have "closed" automatic heads or nozzles.

Wet pipesystems have pressurized water in their pipes and "closed" sprinkler heads. Dry pipesystems have pressurized air in their pipes and automatic "closed" sprinkler heads.Sprinkler heads that are near equipment or conduit in the overhead are designed withcovers or by rigid connections to prevent spatial interactions that could lead to floodingor spray hazards.An extensive list of design codes, standards,

methods, studies and tests utilized forseismic design is provided in the PNPS FSAR. A summary of the more relevantreferences 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 B0 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 inBuilding 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. 1Page 8 of 373.0 SEISMIC WALKDOWN PROGRAM IMPLEMENTATION APPROACHEntergy PNPS has committed to conduct and document seismic walkdowns for resolution ofNTTF Recommendation 2.3: Seismic in accordance with the EPRI Seismic WalkdownGuidance

[Ref. 2]. Entergy developed procedure EN-DC-168 "Fukushima Near-Term TaskForce Recommendation 2.3 Seismic Walk-down Procedure" outlining the guidelines, processes and required documentation to generate during the walkdowns.

The approachprovided in the Guidance for addressing the actions and information requested in Enclosure 3to the 50.54(f)

Letter includes the following activities, the results of which are presented in thesections 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 respectto 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 Entergycorporate leadership, which provided guidance to each Entergy site throughout the seismicwalkdown

program, including PNPS. Entergy contracted with an outside nuclear servicescompany to provide engineering and project management resources to supplement andassist each individual site. PNPS had dedicated engineering contractors, supported by theirown project management and technical oversight, who worked closely with plant personnel.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 9 of 374.0 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 theirproject responsibilities and provides brief experience summaries for each. Trainingcertificates of those qualified as Seismic Walkdown Engineers are included in Attachment I.Table 4-1 summarizes the names and responsibilities of personnel seismic walkdowns.

Experience summaries of each person follow.used to conduct theTable 4-1Equipment Seismic Licensing IPEEEName Selection Walkdown BasisPersonnel Engineer ReviewerPaul Smith (Consultant)

X1David Heard (Consultant)

XDavid Small (Entergy) x2Laura Maclay (ENERCON)

X X XGary Sweder (ENERCON)

XHalie Aroz (ENERCON)

X XNotes:1.2.Plant operations representative Designated lead SWEPaul SmithMr. Smith is an engineer with over 45 years of experience in the nuclear power industry.

Heholds 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 andSafety Analyst.

In addition, he served as an Operations Review Committee Member for 15years.Currently, Mr. Smith works for lepson Consulting Enterprises, providing technical support forPNPS. Previously, he has provided component inspection and emergency planning supportfor PNPS at Sun Technical.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 10 of 37David HeardMr. 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 Sciencedegree in Mechanical Engineering from Tufts University and a Master of Science inManagement from Lesley University.

Mr. Heard began working on the design, andconstruction of new nuclear facilities in 1970, and progressed to a career specializing in themaintenance and improvements to operating nuclear plants.Most recently Mr. Heard was involved in renewal of Entergy's PNPS. He participated in allaspects of the License Renewal process from the development of the application andmeetings with the NRC audit team, through the implementation phase, which includedprogram development, procedure

writing, field inspections, training plant personnel andLicense Renewal commitment close-out.

Mr. Heard worked 15 years at PNPS where he served as Lead Mechanical Engineer andProject Manager for major plant improvements.

He also ran the Master Surveillance TrackingProgram 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 Divisionspecializing in the modification and repair of operating nuclear plants. The clients included allnuclear plants in New England and involved diverse projects such as pipe supports at MaineYankee, a spent fuel pool liner at Yankee Rowe, a radwaste facility at Millstone and a spareparts program at Vermont Yankee.David SmallMr. 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 degreein Civil/Structural Engineering from University of Massachusetts and is a qualified SeismicWalkdown 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 theresponse to Fukushima related seismic issues. His primary duties at PNPS include technical oversight and contract management of projects developed by outside engineering firms, andserving as design engineer for projects developed in-house for a wide range ofcivil/structural/mechanical issues. Prior to joining PNPS, Mr. Small was a Senior Engineer forthe Engineering FIN Team at Vermont Yankee Nuclear Power Plant. This team responded toa wide variety of emergent plant issues, and was often called upon to resolve these issues ina short time frame. He also performed the duties of Lead Engineer and Project Manager forplant upgrades.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 11 of 37Mr. Small also worked as a Senior Structural Engineer for Sargent & Lundy. He providedengineering services to various power generating

clients, including a long-term assignment atPalisades Nuclear Plant. Mr. Small was involved in the Palisades 79-14 safety-related pipingprogram, and gained extensive experience with concrete expansion anchor analysis anddesign. His responsibilities at Sargent & Lundy also included finite element modeling, response spectrum

analysis, design of large steel and concrete structures, and preparation ofdesign change packages.

Laura MaclayMs. Maclay has over five years of experience as a structural

engineer, three years withEnercon Services.

Ms. Maclay holds a Bachelor's degree in Structural Engineering fromDrexel University and is a qualified Seismic Walkdown Engineer as stated on her EPRItraining certificate dated July 26, 2012. Her tasks have ranged from assisting with thedevelopment and preparation of design change packages to performing design calculations and markups, comment resolutions, and drawing revisions.

Ms. Maclay spent a year on siteat Turkey Point Nuclear Plant preparing structural evaluations of SSC's for an ExtendedPower Uprate (EPU). Her work included designing safety related supports for computer andelectrical equipment for the Turbine Digital Controls Upgrade package and other similarpackages.

Ms. Maclay's responsibilities also included the review of calculations, drawingsand vendor documentation for the seismic evaluation of the Unit 3 Palfinger Crane insidecontainment and new platforms in the High Pressure Turbine enclosure.

Recent work includes Fukushima flooding walkdowns at Limerick Generating Station andseismic walkdowns at Plant Farley. As a member of a two person team, Ms. Maclay wasresponsible for evaluating equipment anchorage, spatial interactions and potentially adverseconditions.

Gary SwederMr. Gary Sweder is a mechanical engineer with over six years of experience in the nuclearindustry.

Mr. Sweder is a Professional Engineer and holds a Bachelor's degree in NuclearEngineering 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 onhis EPRI training certificate dated September 13, 2012. Major tasks have included design andanalysis of mechanical

systems, calculation preparation and review, creating and revisingmechanical

drawings, and development of engineering change packages for various nuclearplants. He has worked on a broad range of projects that include:

simplified water hammeranalysis 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. 1Page 12 of 37Mr. Sweder is proficient with GOTHIC and RELAP5 thermal-hydraulic analysis software.

GOTHIC applications include robust models of the Control Area Ventilation system, CAS andSecurity 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 suchas feed water loss and transients, loss of coolant accidents and steam line breaks.Halie ArozMs. 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 acivil/structural engineer with Enercon Services and is a qualified Seismic Walkdown Engineeras stated on her EPRI training certificate dated September 13, 2012. Her major tasks haveincluded the design and analysis of pipe and cable tray supports, structural steel frames,reinforced concrete slabs and foundations, and other miscellaneous support structures.

Shehas 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 hasextensively used the program for various calculations, including a response spectrumanalysis of a safety-related HPSW pump for Peach Bottom Nuclear Station.

She has alsoqualified 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/Iconsiderations.

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. 1Page 13 of 374.5 PEER REVIEW TEAMTable 4-2 summarizes the names and responsibilities of personnel used to conduct peerreviews of the seismic walkdown program.

Experience summaries of each person follow.Table 4-2SWEL Peer Walkdown Licensing Submittal NameReviewer Peer Basis Peer Report PeerReviewer Reviewer ReviewerJeffrey Kalb x2 X x2 X1,2Fred Mogolesko X X XNotes:1. Peer Review Team Leader2. Lead peer reviewer of particular activityJeffrey KalbMr. Kalb is an engineer with 39 years of engineering experience.

He holds a Bachelor ofScience degree in Civil Engineering from University of Rhode Island, and has taken graduatecourses 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, andleading 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. Hehas 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 ofexperience 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 fromNew York University (NYU).Currently, Mr. Mogolesko is a consultant serving as a project/program manager at PilgrimNuclear Station.

His responsibilities include proposing and managing strategies,

programs, Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 14 of 37and processes in support of economic and competitive generation of electrical power. He hasevaluated and assessed known natural hazard impacts for Pilgrim including full seismicreverification (USI-A46),

soil-structure interaction, probabilistic fire and seismic riskassessments, hurricane and site flooding accidents under the IPE and IPEEE Programs.

Prior to his current position, Mr. Mogolesko was a Senior Project Manager, principal engineerand division manager of environmental sciences at PNPS. His responsibilities includedenvironmental risk assessments and developing the foundations for the severe accidentmanagement

program, shutdown risk tools, and integrated plant risk models. Mr. Mogolesko has also worked as a lead engineer for Stone and Webster, a geophysical scienceslaboratory research scientist at NYU, and a senior aerospace engineer at GrummanAerospace.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 15 of 375.0 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" refersto conditions found during the IPEEE program related to seismic anomalies,

outliers, or otherfindings.

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 IPEEEprogram.

IPEEE Reviewers then reviewed additional plant documentation to identify theeventual resolutions to those seismic vulnerabilities not resolved via the completion of theIPEEE program.The seismic vulnerabilities identified for PNPS during the IPEEE program are reported inAttachment A. A total of four seismic vulnerabilities were identified by the PNPS IPEEEprogram.

For each identified seismic vulnerability, the table in Attachment A includes threepieces 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 someequipment enhanced as a result of the IPEEE program were included in SWELl (see Section6.1.2). Documents describing these equipment enhancements and other modifications initiated by identification of IPEEE vulnerabilities were available and provided to the SWEsduring the NTTF 2.3 Seismic Walkdowns.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 16 of 376.0 SEISMIC WALKDOWN EQUIPMENT LIST DEVELOPMENT This section summarizes the process used to select the SSCs that were included in theSeismic Walkdown Equipment List (SWEL) in accordance with Section 3 of the EPRIGuidance.

A site team of equipment selection personnel with extensive knowledge of plantsystems and components was selected to develop the SWEL. The SWEL is comprised oftwo groups of items:SWEL 1 consists of a sample of equipment required for safe shutdown of thereactor and to maintain containment integrity (i.e., supporting the five safetyfunctions).

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 poolThe final SWEL is the combination of SWEL 1 and SWEL 2. The development of these twogroups 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 removalMaintaining containment integrity is the fifth safety function* Containment functionThe overall process for developing a sample of equipment to support these five safetyfunctions is summarized in Figure 1-1 of the Guidance.

Figure 1-1 of the Guidance providesa screening method for selecting SSCs, starting with all of the plant SSCs and reducing thenumber based on a series of screening criteria.

6.1.1 Base List 1Based on Figure 1-1 and Section 3 of the Guidance, Base List 1 should represent aset of Seismic Category (SC) I equipment or systems that support the five safetyfunctions.

USI-A46 identified the following Safe Shutdown Functions and Supporting Systems:

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 17 of 37Safe Shutdown Preferred Path Backup PathFunctionControl Rod DriveReactivity Control (CRD) insertion by N/A, single failure proofHydraulic Control UnitReactor Pressure Safety Relief Valve Safety Relief Valves inContol (SRV) in relief mode to afety ReControl ShtonCoigsafety modeShutdown CoolingReactor Core Isolation High Pressure CoolantReactor Inventory Cooling (RCIC) Injection transition to CoreControl transition to Core Spray Spray BA Spray BDecay Heat Removal Suppression Pool Suppression Pool CoolingCooling A BContainment Function Shutdown Cooling A Shutdown Cooling BThe USI-A46 report resulted in the Safe Shutdown Equipment List (SSEL) which is theequipment needed to support the preferred path, and backup path.The Components on the list were inspected, and/or evaluated in accordance with theSeismic 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 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />sfollowing a SSE event. Some components provide multiple functions including supportof containment integrity.

This equipment list of SSCs on the success paths isconsistent with the requirements of Screens #1 through #3 of the Guidance.

Inaccordance with EPRI Seismic Walkdown Guidance 2012, Pilgrim has reviewed theSSEL for Pilgrim USI-A46 including approximately 1100 seismically ruggedcomponents that support safe shutdown following a seismic event. As the SSEL was a1996 product, Asset Suite and other supporting documentation was reviewed toidentify any equipment that was modified to date. Base List 1 is presented as Table9.4.1 in Attachment B.6.1.2 Development of SWEL 1Based on Figure 1-1 and Section 3 of the Guidance, SWEL 1 should represent adiverse population of items on Base List 1 including representative items from some ofthe variations within each of five sample selection attributes.

Additionally, theselection 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 theequipment selected for inclusion on the final SWEL 1 are representative with respect Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 18 of 37to 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 thesample selection attributes.

SWEL 1 is presented as Table 9.4.2 in Attachment B, andhas 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 theSSEL 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 isprovided by the Post Accident Monitoring panel." The selected systems considered lessons-learned from Fukushima event. Ofspecial 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, usingdifferent systems:* CRD, depressurizing the pneumatic supply header with back-up scramvalves* 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. 1Page 19 of 37The total SWEL population 118 components (SWEL 1 and SWEL 2) includesrepresentational components, using the EPRI component selection process,considering:

Variety of Types of SystemsItems 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 supportsystems, as listed in Appendix E of the Guidance, were selected.

The system type ofeach 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 itemson Base List 1 which are either major new or replacement equipment installed withinthe past 15 years, or have been modified or upgraded recently.

These items aredesignated as such on Base List 1 on Table 9.4.1 of Attachment B. A sampling ofthese items is represented on SWEL 1.Variety of Equipment TypesAccording to Appendix B of the Guidance, there are 22 classes of mechanical andelectrical equipment.

The equipment class of each item on SWEL 1 is listed on Table9.4.2 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, andelevations.

These item locations included environments that were both inside andoutside, as well as having high temperature and/or elevated humidity and withincontainment.

The location and environment of each item on SWEL 1 is listed on Table9.4.2 of Attachment B.IPEEE Enhancements There are only three IPEEE items for the plant, none of which appear on the SSEL. Inthis case, one of the items, A8, was added to the SWEL 1 list to provide an IPEEEcomponent.

This component is linked to powering the Emergency busses andtherefore was considered to be important to plant safety.Risk Siqnificance Information from the plant Seismic Probabilistic Risk Analysis (SPRA) model and thePNPS SPRA was developed in accordance with the guidance in NUREG-1407 andNUREG/ CR-2300 [Ref. 4]. It followed a five step process investigating the seismichazard, the fragility of plant components, and the response of the plant to the seismichazard. The following three elements were used as the approach, as discussed in theoverall methodology section of the IPEEE report:

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 20 of 37* Plant walkdowns made by Seismic Review Teams, trained by EPRI in thescreening methodology, to identify components and structures to be modeled" Development of fragility values for components and structures in the PNPSSPRA based on structural capacity computations and a determination of instructure demand using soil structure interaction analysis* Risk qualification by fault tree analysis, and the integration of the plant logicmodel with the seismic hazard curveThe major findings of the SPRA are described in Attachment A, IPEEE Vulnerabilities Table.6.2 SPENT FUEL POOL ITEMSThe 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 1-2of the Guidance.

The equipment of Screen #2 and entering Screen #3 is defined as BaseList 2. The items of Screen #4 are the items that could potentially cause the SFP to drainrapidly.

The items of either Screen #3 or Screen #4 are the second Seismic WalkdownEquipment List, or SWEL 2. Development of these lists is described in the following sections.

6.2.1 Base List 2Based on Figure 1-2 and Section 3 of the Guidance, Base List 2 should represent theSeismic Category I equipment or systems associated with the SFP. To develop BaseList 2, Equipment Selection Personnel (see Section 4.1) reviewed plant design andlicensing 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 30total items.6.2.2 Rapid Drain-Down Based on the approach defined in the 50.54 (f) letter, (Reference

1) the seismicadequacy of Equipment and Systems connected to the Spent Fuel Pool (SFP), whichif ruptured or malfunction could rapidly drain the SFP should be confirmed bywalkdown.

The purpose of the Failure Modes analyses for the Spent Fuel Pool is toidentify vulnerabilities resulting in rapid draining; that is providing a leak path that couldexpose 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 islimited 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. 1Page 21 of 37from the SS liner. The SFP has been designed to withstand earthquake loading as aClass I structure.

The passage between the SFP and the Refueling cavity is provided with twoprocedurally 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 intothe SFP are provided with siphon breaking

devises, to prevent backflow in the event ofa supply system rupture.

Normal makeup water is automatically provided by thecondensate transfer system. Additional makeup water is available via Condensate orDemineralized water, from any combination of the Condensate

Storage, orDemineralized water Tanks, from five pumps (P-109A/B, P-111, P-108A/B),

andthrough three flow paths ( Skimmer Surge tank inlet, SFP system, service waterboxes). In the event of a LOOP event, additional sources include the Fire WaterProtection

Systems, or the RHR Systems powered by multiple independent diesels.6.2.3 Development of SWEL 2Based on Figure 1-2 and Section 3 of the Guidance, SWEL 2 is a broad population ofitems on Base List 2 including representative items from some of the variations withineach 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 thepopulation of items on Base List 2 being much smaller than Base List 1, the samplingattributes are satisfied differently for SWEL 2 than for SWEL 1. The following paragraphs describe how the equipment selected from Base List 2 for inclusion onSWEL 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 SystemsRapid drain down vulnerability would only be possible with failure of the SFP gateswith cavity drained, failure of multiple lines penetrating a flooded cavity, or with thesiphon breaker failure combined with a SFP discharge pipe failure.

The constantly pressurized SFP discharge piping is the subject of routine operator tours, and basedon leak before break philosophy, and water chemistry control program, would providereasonable assurance of continued availability.

The cavity penetration piping, andsiphon 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 shouldbe 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. 1Page 22 of 37There is one system associated with SFP cooling, the Fuel Pool Cooling andDemineralizing System.Maior New and Replacement Equipment There have been no major new or replacement equipment installations within the past15 years associated with the SFP. The only significant changes are the new fuelracks, which are passive structural components and are outside of the scope of thisprogram.

Therefore, this sampling attribute is not applicable.

Variety of Equipment TypesThe 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 ReactorBuilding.

These item locations included environments that were inside as well ashaving high temperature and within containment.

The location and environment ofeach item on SWEL 2 is listed on Table 9.4.5 of Attachment B.6.3 DEFERRED INACCESSIBLE ITEMS on SWELEach item on the SWEL is to be walked down as part of the NTTF 2.3 Seismic Walkdownprogram.

In order to perform the seismic walkdowns of these items, it is necessary to haveaccess to them and to be able to view their anchorage.

In some cases, it was not feasible togain access to the equipment or view its anchorage because PNPS was in operation duringthe 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 theRFO19 outage and incorporated into revision 1 of this report. The additional and updatedSWEL items are in Attachment J and the new AWCs are in Attachment K.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 23 of 377.0 SEISMIC WALKDOWNS AND AREA WALK-BYSThe NTTF 2.3 Seismic Walkdown program conducted in accordance with the Guidance, involves two primary walkdown activities:

Seismic Walkdowns and Area Walk-Bys.

Theseactivities were conducted at PNPS by teams of two trained and qualified Seismic WalkdownEngineers (SWEs) (see Section 4.1). Each team included one engineer with at least severalyears of experience in seismic design and qualification of nuclear power plant SSCs. A totalof 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. Inaddition, an operations representative accompanied the teams on days when cabinets werescheduled to be opened.The seismic walkdowns and area walk-bys were conducted over the course of three weeksduring October of 2012. Each morning, a pre-job brief with all personnel involved wasconducted.

This pre-job brief was used to outline the components and areas that would bewalked 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 teammembers to ask questions and share lessons learned in the field. The SWE teams broughtcameras, tape measures, flashlights, binoculars and calipers into the field to assist with theseismic 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 designengineering management and the NRC Senior Resident Inspector provided input to the postjob briefs in addition to walkdown oversight.

7.1 SEISMIC WALKDOWNS Seismic walkdowns were performed in accordance with Section 4 of the Guidance for allitems on the SWEL (SWEL 1 plus SWEL 2). To document the results of the walkdown, aseparate Seismic Walkdown Checklist (SWC) with the same content as that included inAppendix C of the Guidance was created for each item. Additionally, photographs weretaken of each item, and included on the corresponding SWC.Prior to performance of the walkdowns, documentation packages were developed thatcontained the pre-filled out SWC and other pertinent information including the locationdrawings, response spectra information, previous IPEEE seismic walkdown documentation, and anchorage drawings where applicable.

These documentation packages were broughtwith the SWE teams into the plant during the seismic walkdowns.

Walkdown inspections focused on anchorages and seismic spatial interactions, but alsoincluded inspections for other potentially adverse seismic conditions.

Anchorage, in all cases, Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 24 of 37was considered to specifically mean anchorage of the component to the structure.

Thisincluded anchor bolts to concrete walls or floors, structural bolts to structural steel and weldsto structural steel or embedded plates. For welds, the walkdown team looked for cracks andcorrosion 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 forpotentially adverse seismic conditions.

All cabinets/panels on the SWEL that could be reasonably opened without presenting safetyor operational hazard were opened during the walkdown.

This allowed visual observation ofinternal anchorage to the structure (where present),

as well as inspection for "other adverseseismic conditions" related to internal components if it could be observed without breakingthe 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, orsimilar),

it was excluded from internal inspection.

This applied to only one of theapproximately 25 panels on the SWEL. Further discussion of the specific configuration ofpanel 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 havinganchorage required confirmation that the anchorage configuration was consistent with plantdocumentation.

Of the 118 SWEL items, 68 were considered to have anchorage (i.e.,removing in-line/line-mounted components).

Of these 68 anchored components, thewalkdowns 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 inAttachments 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-BYSSeismic area walk-bys were performed in accordance with Section 4 of the Guidance for allplant areas containing items on the SWEL (SWEL 1 plus SWEL 2). A separate Area Walk-ByChecklist (AWC) with the same content as that included in Appendix C of the Guidance wasused 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. 1Page 25 of 37In cases where the room or area containing a component was very large, the extent of thearea encompassed by the area walk-by was limited to a radius of approximately 35 feetaround the subject equipment.

The extent of the areas included in the area walk-bys isdescribed on the AWC for that area. Because certain areas contained more than one SWELitem, there are fewer total area walk-bys conducted than seismic walkdowns.

A total of 38area 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 AWCsare included in Attachments D and K.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 26 of 378.0 LICENSING BASIS EVALUATIONS During the course of the seismic walkdowns and area walk-bys, the objective of the SWEteams was to identify existing

degraded, non-conforming, or unanalyzed plant conditions withrespect to PNPS current seismic licensing basis. This section summarizes the process usedto handle conditions identified, what conditions were found, and how they were treated foreventual resolution.

CONDITON IDENTIFICATION When an unusual condition was observed by a SWE team in the field, the condition wasnoted on the SWC or AWC form and briefly discussed between the two SWEs to agree uponwhether it was a potentially adverse seismic condition.

These initial conclusions were basedon experience, conservative engineering

judgment, and the criteria presented in the EPRISWE qualification training course.For conditions that were reasonably judged by the SWE team as insignificant to seismicresponse, the disposition was included on the SWC or AWC checklist and the appropriate question was marked "Y", indicating that no potentially adverse seismic condition wasobserved.

Unusual or uncertain conditions that could not be readily dispositioned by the SWE team inthe 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 thenature of the identified condition, it was then either addressed via the Licensing BasisEvaluation (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 thesewere considered to have some degree of seismic significance and are documented inAttachment E of this report. Three of the 17 seismic conditions were resolved via the LBEprocess.

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 AWCchecklists.

CONDITION RESOLUTION Conditions observed during the seismic walkdowns and area walk-bys determined to bepotentially adverse seismic conditions are summarized in Attachment E, including how eachcondition has been addressed and its current status. Each potentially adverse seismic Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 27 of 37condition is addressed either with a Licensing Basis Evaluation (LBE) to determine whether itrequires entry into the CAP, or by entering it into the CAP directly.

The decision to conduct aLBE or enter the condition directly into the CAP was made on a case-by-case basis, basedon 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 2.3Seismic 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 Walkdownprogram may be evaluated by comparison to the current licensing basis of the plant as itrelates to the seismic adequacy of the equipment in question, as is described in Section 5 ofthe 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 cannotreadily be shown to be consistent with existing seismic documentation, or no seismicdocumentation exists, then the condition is entered into the CAP.Of the 17 identified potentially adverse seismic conditions, 4 LBEs were performed.

EachLBE performed is documented consistently, and included in Attachment F. The results ofthese LBEs with respect to the associated potentially adverse seismic conditions aresummarized in Attachment E. All four potentially adverse seismic conditions evaluated usinga LBE were dispositioned or resolved by way of a work order and require no further action.8.2 CORRECTIVE ACTION PROGRAM ENTRIESConditions identified during the seismic walkdowns and area walk-bys that required furtherresolution were entered into the plant's CAP. These were reviewed in accordance with theplant'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 NTTF2.3 Seismic Walkdown program.

Of those, the majority (51) were from seismically insignificant unusual conditions.

A total of 14 CRs were written relative to potentially adverseseismic conditions identified.

Six of the 14 CRs were related to open s-hooks on hanginglight fixtures.

Five of the CRs were associated with unsecured miscellaneous items locatedin proximity to safety-related equipment and not meeting the requirements of the plant'sseismic 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 asafety-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. 1Page 28 of 37numbers, current status, and resolution (where applicable and available) are summarized forthese potentially adverse seismic conditions in Attachment E.8.3 PLANT CHANGESThe CAP entries (CRs) generated by the NTTF 2.3 Seismic Walkdown program are beingresolved 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 ornon-functional.

None of the identified conditions resulted in the requirement for a plant designchange. Work requests were initiated for required maintenance/repairs for each of the CRsthat could not be dispositioned or closed based on the immediate actions taken.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 29 of 379.0 PEER REVIEW9.1 PEER REVIEW PROCESSThe peer review for the NTTF Recommendation 2.3 Seismic Walkdowns was performed inaccordance with Section 6 of the Guidance.

The peer review included an evaluation of thefollowing activities:

review of the selection of the structures,

systems, and components, (SSCs) thatare included in the Seismic Walkdown Equipment List (SWEL);* review of a sample of the checklists prepared for the Seismic Walkdowns andarea walk-bys; review of licensing basis evaluations and decisions for entering the potentially adverse conditions in to the plant's Corrective Action Plan (CAP); andreview of the final submittal report.The peer review team (see Section 4.5) was involved in the peer review of each activity, theteam member with the most relevant knowledge and experience taking the lead for thatparticular activity.

A designated overall Peer Review Team Leader provided oversight relatedto the process and technical aspects of the peer review, paying special attention to theinterface between peer review activities involving different members of the peer review team.9.2 PEER REVIEW RESULTS SUMMARYThe 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 safetyfunctions:

A) Reactor Reactivity

Control, B) Reactor Coolant PressureControl, C) Reactor Coolant Inventory

Control, D) Decay Heat Removal andE) Containment Function.

The SWEL 1 for PNPS was developed by in-house Contractors and operations staffknowledgeable and experienced with PNPS systems and components, using PNPSUSI A-46 Safe Shutdown Equipment List (SSEL) as the base list. It was subject toreview and approval by PNPS Operations department.

Based on discussion

/decisions between the Equipment Selection Personnel and the Peer Reviewers theSWEL 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 thePNPS system number for each component.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 30 of 37A 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 PeerReview Comment Form [Ref. Attachment H]. All comments were later resolved andthe SWEL 1(EN-DC-168 Attachment 9.4) was signed by the Peer Reviewer on9/27/12.In summary the SWEL 1 contains:

14 components associated with Reactor Reactivity Control46 components associated with Reactor Coolant Pressure Control71 components associated with Reactor Coolant Inventory Control48 components associated with Decay Heat Removal15 components associated with Containment FunctionNote: this adds up to more than the 102 components on SWEL 1 because manycomponents 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 thePeer Reviewers' components were added from Class 2, 9 and 19 to the SWEL 1.Based on discussion

/ decisions between the Equipment Selection Personnel and thePeer 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 ofthese systems.

In addition, the SSEL contains 21 equipment classes and the SWEL 1contains components from 19 of these equipment classes.SWEL 1 components are located throughout the plant including the Reactor BuildingEI.23' east and west sides, Reactor Building E1.51' east and west sides, ReactorBuilding 51' RWCU Heat Exchanger Room, "A" Valve Room, "A" RHR Quad, RCICQuad, Control Room, SSW Pump Room, Cable Spreading Room, "A" and "B"Switchgear Rooms, "A" and "B" Battery Rooms. "A" and "B" EDG Rooms, MG SetRoom (El. 23'), Drywell, and Steam Tunnel. These represent a variety ofenvironments.

Based on discussion

/ decisions between the Equipment Selection Personnel and thePeer Reviewers two "Major New or Replacement Equipment":

transformer X55 (SWEL1-083) and pump P203A (SWEL 1-010) were added.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 31 of 37Based on discussion

/ decisions between the Equipment Selection Personnel and thePeer Reviewers, one vulnerability identified during the IPEEE Program:

the A8Switchgear hold-down bolts (SWEL 1-014) was added.Therefore it is concluded that the SWEL 1 adequately represents a diverse samplingof components for the seismic walkdowns.

SWEL 2: The SWEL associated with the sample of items related to the Spent FuelPoolThe SWEL 2 for PNPS was developed by in-house Contractors and Operations knowledgeable and experienced with PNPS systems and components using thescreens 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 PeerReview 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-BysPeer review of the seismic walkdowns and area walk-bys was conducted by two peerreviewers.

The Peer Review Team Leader is qualified to SQUG Methodology (SQUGWalkdown Screening and Seismic Evaluation Training Course) and a qualified SWE(EPRI Training on NTTF 2.3-Plant Seismic Walkdowns).

The other Peer Reviewerwas involved in the response to Generic Letter 87-02, Verification of SeismicAdequacy of Mechanical and Electrical Equipment in Operating

Reactors, Unresolved Safety Issue (USI) A-46 and has broad knowledge of seismic engineering applied tonuclear power plants. The peer reviews were conducted at the Pilgrim Nuclear PowerStation (PNPS) concurrent with the conduct of walkdowns.

The peer review wasperformed as follows:The peer review team lead reviewed the walkdown packages (including checklists, photos, drawings, etc.) for SWEL items already completed to ensurethat the checklists were completed in accordance with the Guidance.

A total of63 SWC and 16 AWC forms were reviewed, each representing approximately

[61% and 50%] of their respective totals. In the context of the Guidance, thepeer review team considered the number of walkdown packages reviewed to be Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 32 of 37appropriate.

The packages reviewed represent a variety of equipment types invarious 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 AWCforms 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 informalinterviews of the SWEs and asked clarifying questions to verify that they wereconducting walkdowns and area walk-bys in accordance with the Guidance.

• The peer review team held a meeting with the SWE teams daily to providefeedback on the walkdown and walk-by packages reviewed and the informalinterviews, and discuss potential modifications to the documentation packages inthe context of the Guidance.

• The peer review team leader accompanied SWE teams into the field andobserved 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 inaccordance 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 theobservation 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 providefeedback on the walkdown and walk-by observations, and discuss how lessonslearned from review of the walkdown packages had been incorporated into thewalkdown 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 asinsignificant.

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 onracks). The peer review team felt these modifications would be of benefit for futurereviews of checklists incorporated into the final report. These modifications wererecommended following review of the walkdown and area walk-by packages, and theobservation walkdowns and area walk-bys demonstrated that the SWEs understood Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 33 of 37the recommendations and were incorporating them into the walkdown and area walk-by process.

Previously completed checklists were revised to reflect lessons learnedfrom 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 followedthe process for conducting seismic walkdowns and area walk-bys in accordance withthe Guidance.

The SWE teams adequately demonstrated their ability to identifypotentially adverse seismic conditions such as adverse anchorage, adverse spatialinteraction, and other adverse conditions related to anchorage, and performanchorage 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.

TheSWEs demonstrated appropriate use of self checks and peer checks. They discussed their observations with a questioning

attitude, and documented the results of theseismic 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 theseismic walkdowns and agreed with the decisions to enter the CAP (Corrective ActionProcess).

The threshold for entering the corrective action process was very low asevidenced by the 59 CRs written during the walkdowns.

No assumptions were madeby the SWE teams that the potentially adverse conditions would be or had beenidentified by some other workgroup or area owner.Three Licensing Basis (LB) Evaluations were written by the walkdown teams. LBEvaluation 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 besatisfactory, and signed by the Lead Peer Reviewer.

No other Licensing BasisEvaluations were judged to be required.

Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 34 of 379.2.4 Submittal ReportA 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) andprovided comments.

The Peer Review Team Leader reviewed the report forcompliance with the requirements of the EPRI Guidance document and EntergyProcedure EN-DC-168, Rev. 0. Team Leader comments were provided to the reportpreparer on 11/6/12 on Attachment 9.11 Peer Review Comment Form. On 11/14/12the 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 2.3Seismic Walkdown activities that were deferred due to plant accessibility restrictions duringthe initial walkdown phase performed in October 2012. All of the deferred scope seismicwalkdowns 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 theremaining 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 reportThere were no changes that affected the IPEEE Vulnerabilities Evaluations and no changesto the equipment originally selected for inspection (SWEL). Therefore, no additional peerreview associated with these two topics is required.

Dr. Fred Mogolesko (bio in Section 4.5) served as overall Peer Review Team Lead for thedeferred scope activities.

Dr. Mogolesko reviewed the Revision 1 submittal report for overallcompleteness,

quality, and procedural/regulatory compliance.

He was supported byadditional 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. 1Page 35 of 37involved in the performance of the PNPS deferred scope walkdowns.

Review comments wereincorporated 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 ofPNPS (bio in Section 4.5) who previously served as Peer Review Team Lead for the initialphase of the project.

Review comments regarding pressure transient effects on theunrestrained 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 asappropriate (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 anestablished program that had been refined via lessons learned at PNPS, the Entergy fleetduring the initial (much larger) phase of the project, and industry.

The peer review commentstended 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 phasewere maintained and ultimately resulted in a high quality and well integrated final submittal report.

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

10.0 REFERENCES

1. 10CFR50.54(f)

Letter, Request for Information Pursuant to Title 10 of the Code ofFederal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3 and 9.3 of theNear-Term Task Force Review of Insights from the Fukushima Dai-lchi

Accident, dated March 12, 20122. EPRI 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, June 20123. Pilgrim Nuclear Power Station Final Safety Analysis Report (FSAR) Sections 2, 12 andAppendix C, Revision

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

5. PNPS Seismic Individual Plant Examination of External Events (IPEEE) Submittal Report GL88-20, Revision 0, June 19946. Generic Letter No. 87-03, Verification of Seismic Adequacy of Mechanical andElectrical Equipment in Operating

Reactors, Unresolved Safety Issue (USI) A-467. Seismic Qualification Utility Group (SQUG) Procedure:

Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Power Plant Equipment, Revision3A, December 20018. EN-DC-168, Fukushima Near-Term Task Force Recommendation 2.3 Seismic Walk-down Procedure, Revision

09. TDBD 118, Topical Design Basis Document for Seismic Design, Revision 110. Specification C-114-ER-Q-E1, Seismic Response

Spectra, Revision 111. Uniform Building Code (UBC), 196712. American Institute of Steel Construction (AISC) Specification for the Design,Fabrication, and Erection of Structural Steel for Buildings, 6th edition to current13. American Concrete Institute (ACI) Building Code Requirements for Reinforced

Concrete, ACI 318-6314. American Welding Society (AWS) Standard Code for Arc and Gas Welding in BuildingConstruction, AWS D.1.0-6615. ASME Boiler and Pressure Vessel Code,Section III, Class B, current edition Engineering Report No. PNPS-CS-12-00001 Rev. 1Page 37 of 3711.0 ATTACHMENTS ATTACHMENT A -IPEEE VULNERABILTIES TABLEATTACHMENT B -SEISMIC WALKDOWN EQUIPMENT LISTSATTACHMENT C -SEISMIC WALKDOWN CHECKLISTS (SWCs)ATTACHMENT D -AREA WALK-BY CHECKLISTS (AWCs)ATTACHMENT E -POTENTIALLY ADVERSE SEISMIC CONDITIONS ATTACHMENT F -LICENSING BASIS EVALUATION FORMSATTACHMENT G -PEER REVIEW CHECKLIST FOR SWELATTACHMENT H -PEER REVIEW COMMENT FORMATTACHMENT I -SEISMIC WALKDOWN ENGINEER TRAINING CERTIFICATES ATTACHMENT J -DEFERRED SEISMIC WALKDOWN CHECKLISTS (SWCs)ATTACHMENT K -DEFERRED AREA WALK-BY CHECKLISTS (AWCs)