ML13340A147

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

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

Text

FENOC FEN O C76 South Main Street FRst EneNuclearl. .Q .Akron. Ohio 44308 Samuel L. Belcher Senior Vice President and Chief Operating Officer November 26, 2013 L-1 3-358 10 CFR 50.54(f)ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Response to Request for Additional Information Associated with the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (TAC Nos. MF0116 and MF0159)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a letter titled,"Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," to all power reactor licensees and holders of construction permits in active or deferred status. Enclosure 3 of the 10 CFR 50.54(f) letter contains specific Requested Actions, Requested Information, and Required Responses associated with Recommendation 2.3 for Seismic Walkdowns.

By letter dated November 27, 2012 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML130080030), FirstEnergy Nuclear Operating Company (FENOC) submitted the 180-day response to the 10 CFR 50.54(f)letter. The required seismic walkdown reports were provided as Enclosures A, B, C, and D for Beaver Valley Power Station, Unit No. 1 (BVPS-1);

Beaver Valley Power Station, Unit No. 2 (BVPS-2);

Davis-Besse Nuclear Power Station (DBNPS); and Perry Nuclear Power Plant (PNPP), respectively.

By letter dated November 1, 2013 (ADAMS Accession No. ML13304B418), the NRC staff requested additional information to allow the staff to complete its assessments of the seismic walkdown reports for DBNPS and PNPP. The response to the request for information is provided in Attachment

1.

Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-1 3-358 Page 2 Updated seismic walkdown reports for DBNPS and PNPP are provided in electronic format on the enclosed CD-ROM. As requested by NRC guidance for electronic submissions, Attachment 2 provides a listing of document components that make up the enclosed CD-ROM.No new regulatory commitments are made in this letter. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -Fleet Licensing, at 330-315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November ; , 2013.Sincerely, Samuel L. Belcher

Attachment:

1 Response to Request for Additional Information 2 Document Components on CD-ROM Enclosures on CD-ROM: Davis-Besse Nuclear Power Station Near-Term Task Force Recommendation

2.3 Seismic

Walkdown Report Revision 1 Perry Nuclear Power Plant Near-Term Task Force Recommendation

2.3 Seismic

Walkdown Report Revision 1 cc: Director, Office of Nuclear Reactor Regulation (NRR) (w/o Enclosures)

NRC Region III Administrator (w/o Enclosures)

NRC Resident Inspector (DBNPS) (w/o Enclosures)

NRC Resident Inspector (PNPP) (w/o Enclosures)

NRR Project Manager (DBNPS) (w/o Enclosures)

NRR Project Manager (PNPP) (w/o Enclosures)

Utility Radiological Safety Board (w/o Enclosures)

Attachment 1 L-1 3-358 Response to Request for Additional Information Page 1 of 4 By letter dated November 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13304B418), the Nuclear Regulatory Commission (NRC) staff requested additional information to allow the staff to complete its assessments of the Near-Term Task Force (NTTF) Recommendation

2.3 seismic

walkdown reports for Davis-Besse Nuclear Power Station (DBNPS) and Perry Nuclear Power Plant (PNPP). The response to the request for additional information (RAI) is provided below. The NRC staff question is presented in bold type, followed by the FirstEnergy Nuclear Operating Company (FENOC) response.RAI 1: Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs), dispositioning of issues, and reporting As a result of the audits and walkdown report reviews, the NRC staff noted that licensees' interpretations of the seismic walkdown guidance varied, which resulted in meaningful differences in the process used to disposition identified issues and in the documentation that was provided to the NRC staff. In particular, the application of engineering judgment in determining what constituted a potentially adverse seismic condition (PASC), the threshold for conducting licensing basis evaluations (LBEs), and determining what information was to be reported to the NRC staff varied.The NRC staff intended that conditions initially marked No (N) or Unknown (U) in the field by the seismic walkdown engineers (SWEs) for which an analysis or calculation was performed would be considered as PASCs and that an analysis or calculation constituted an LBE. The walkdown guidance allows for analysis as part of engineering judgment; however, the intent was to allow for only simple analyses that could be readily performed in support of engineering judgment.Further, the walkdown activities were intended to allow for transparency in the licensee's process to demonstrate that PASCs were appropriately identified, that they were addressed in an appropriate manner, and the basis documented such that the current condition of the plant was clearly consistent with the CLB with regard to seismic capability.

During the audits, the NRC staff identified examples of field observations that were deemed not to be PASCs. However, the basis for the determination was not clearly recorded.

In some cases, the field checklists were amplified by noting that the basis was engineering judgment.

During site audit discussions, the staff was able to trace the basis for the engineering judgments and found that in many cases they were appropriate.

It is expected that these situations would not be included in the walkdown report.

Attachment 1 L-1 3-358 Page 2 of 4 There were other situations that a PASC and LBE were not reported; however, the NRC staff found during the audit that a calculation, analysis (more than just simple), or evaluation was conducted but informally.

An example is a confirmatory calculation performed to demonstrate that six anchor bolts out of eight was not a seismically adverse condition.

Another example would be an analysis to demonstrate that an existing, slightly short weld was as seismically sound as the prescribed weld length in the plant design documentation.

The staff expected these types of conditions and evaluations to be captured in the licensee's normal plant processes (e.g., condition report or corrective action program (CAP)), and also reported in the walkdown report, since they were potentially adverse seismic conditions that required more than applying judgment or simple analysis to address.The NRC staff also found that the process that was used to deal with a field observation that was deemed to be a PASC was also not completely described or captured in the report. In many cases, the licensee reported that an LBE was not performed.

However, during the audits, it was clear that an LBE (or an equivalent determination method) was performed and used in determining whether a PASC should be entered into the CAP. The staff expects that these conditions would be reported in the walkdown report.On the whole, through the audits, the NRC staff found that it was able to conclude that the intent of the guidance was met when the licensee's overall process was completely explained, the information was updated to reflect the actual process, and results were updated. The self-assessments conducted by the licensees of the audited plants also identified the lapse in the description of the process used by the licensee to identify a PASC and disposition it.Therefore, in order to clarify the process that was followed, please provide a description of the overall process used by the licensee (and its contractors) to evaluate observations identified in the field by the SWEs. The process should include how a field observation was determined to be a PASC or not and how the bases for determinations were recorded.

Once a determination was made that an observation was a PASC, describe the process for creating a condition report (or other tracking mechanism), performing the LBE (or other determination method), and the resultant action, such as entering it into the CAP, or documenting the result and basis.Also, in order to confirm that the reported information supports concluding that the plant meets the CLB, please follow one of the following three acceptable alternatives: (a) Provide a supplement to the table or text from the original walkdown report, if needed, to include similar conditions as the above examples and situations and for conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a Attachment 1 L-1 3-358 Page 3 of 4 determination.

The supplement should include a short description of each condition, how it was dispositioned and the basis for the disposition, as follows: 1) for each condition that was entered into the CAP, provide the CAP reference number, initiation date, and (if known)the planned completion date, or 2) for all other conditions, provide the result of the LBE (or other determination method), the basis for the result, and how (or where) the result was captured in the plant's documentation or existing plant process.(b) Following the plant's standard procedures, confirm that a new CAP entry has been made to verify if appropriate actions were taken when reporting and dispositioning identified PASCs (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination).

The eventual CAP closeout, including the process followed and actions taken, should be in sufficient detail to enable NRC resident inspectors to follow up.(c) If no new conditions are identified for addition to the supplement or the CAP entry mentioned above is deemed not necessary, provide a statement of confirmation that all potentially seismic adverse conditions (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination) identified during the walkdowns and walk-bys were addressed and included in the report to the NRC.Response: In July 2013, the NRC staff conducted an audit of the Beaver Valley Power Station, Unit Nos. 1 and 2, NTTF Recommendation

2.3 seismic

walkdown report process. Proposed changes to the seismic walkdown reports were discussed in an audit follow-up telephone call held on September 4, 2013 between NRC staff and FENOC. As discussed during this call, the seismic walkdown reports for Beaver Valley Power Station, Unit Nos. 1 and 2, were changed to address the items resulting from the NRC audit and the items resulting from an internal FENOC self-assessment.

As also discussed during this call, similar changes were made to the seismic walkdown reports for DBNPS and PNPP. These changes include the information requested by the NRC staff in this RAI. Revision 1 of the DBNPS and PNPP seismic walkdown reports are provided on the enclosed CD-ROM.Alternative (a) as described above was utilized to ensure the reported information supports concluding that the plants meet their current licensing basis (CLB). As such, alternatives (b) and (c) are not required.

Each condition report entered into the CAP has either had corrective actions closed or has been closed to another action tracking process, such as a notification in the work order process. The CAP allows the use of these notifications for conditions determined to not be a condition adverse to quality.

Attachment 1 L-1 3-358 Page 4 of 4 RAI 2: Conduct of the Peer Review Process As a result of the walkdown report reviews, the NRC staff noted that some descriptions of the peer reviewers and the peer review process that was followed were varied and, in some cases, unclear. In some cases, the staff could not confirm details of the process, such as if the entire process was reviewed by the peer review team, who were the peer reviewers, what was the role of each peer reviewer, and how the reviews affected the work, if at all, described in the walkdown guidance.Therefore, in order to clarify the peer review process that was actually used, please confirm whether the following information on the peer review process was provided in the original submittal, and if not, provide the following.(a) Confirmation that the activities described in the walkdown guidance on page 6-1 were assessed as part of the peer review process.(b) A complete summary of the peer review process and activities.

Details should include confirmation that any individual involved in performing any given walkdown activity was not a peer reviewer for that same activity.

If there were cases in which peer reviewers reviewed their own work, please justify how this is in accordance with the objectives of the peer review efforts.Also, if there are differences from the original submittal, please provide a description of the above information.

If there are differences in the review areas or the manner in which the peer reviews were conducted, describe the actual process that was used.Response: In July 2013, the NRC staff conducted an audit of the Beaver Valley Power Station, Unit Nos. 1 and 2, NTTF Recommendation

2.3 seismic

walkdown report process. Proposed changes to the seismic walkdown reports were discussed in an audit follow-up telephone call held on September 4, 2013 between NRC staff and FENOC. As discussed during this call, the seismic walkdown reports for Beaver Valley Power Station, Unit Nos. 1 and 2, were changed to address the items resulting from the NRC audit and the items resulting from an internal FENOC self-assessment.

As also discussed during this call, similar changes were made to the seismic walkdown reports for DBNPS and PNPP. These changes include the information requested by the NRC staff in this RAI. Section 9.2 of the reports describe details of the peer review process in accordance with the walkdown guidance on page 6-1 as noted in (a) above.Revision 1 of the DBNPS and PNPP seismic walkdown reports are provided on the enclosed CD-ROM.

Attachment 2 L-1 3-358 Document Components on CD-ROM Page 1 of I File Name 001 DBNPS Seismic Walkdown Rpt Revl.pdf 002 DBNPS Seismic Rpt Revl App A.pdf 003 DBNPS Seismic Rpt Revl App B (1 of 2).pdf 004 DBNPS Seismic Rpt Revl App B (2 of 2).pdf 005 DBNPS Seismic Rpt Revl App C to App G.pdf 006 PNPP Seismic Walkdown Rpt Revl .pdf 007 PNPP Seismic Rpt Revl App A.pdf 008 PNPP Seismic Rpt Revl App B (1 of 2).pdf 009 PNPP Seismic Rpt Revl App B (2 of 2).pdf 010 PNPP Seismic Rpt Revl App C to App F.pdf Size 19,798 KB 17,570 KB 31,334 KB 27,711 KB 19,559 KB 17,304 KB 16,991 KB 33,402 KB 49,479 KB 26,915 KB