PLA-7106, Response to NRC Request for Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns, PLA-7106

Response to NRC Request for Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns, PLA-7106

ML13331B490
Person / Time
Site:	Susquehanna
Issue date:	11/27/2013
From:	Rausch T Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-7106
Download: ML13331B490 (7)

Text

Timothy S. Rausch Senior Vice President & Chief Nuclear Officer U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 PPLSusquehanna,LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3345 Fax 570.542.1504 tsrausch@pplweb.com SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO NRC REQUEST FOR INFORMATION ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 2.3, SEISMIC WALKDOWNS PLA-7106

References:

Docket No. 50-387 and No. 50-388

1. NRC 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," dated March 12, 2012.

2.

PPL Letter (PLA-6881), titled "120-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(!) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident," dated March 12, 2012. ",dated July 10, 2012.

3.

PPL Letter (PLA-6941), titled "Response to Request for Additional Information Pursuant to 10 CFR 50.54(f) Regarding Results of Seismic Walkdown," dated November 25, 2012.

4.

PPL Letter (PLA-7050), titled "Seismic Walkdown Report for Inaccessible Equipment - Unit 2 Regarding Fukushima Near-Term Task Force Recommendation 2.3: Seismic,"

dated July 26, 2013.

5.

NRC Letter, titled "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns," dated November 1, 2013.

The purpose of this letter is to provide PPL Susquehanna, LLC' s (PPL) response to the request for additional information contained in Reference 5. The Enclosure provides PPL's response.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Mr. John L. Tripoli at 570-542-3100.

Document Control Desk PLA-7106 I declare under penalty of perjury that the foregoing is true and correct.

Executed on:

Sincerely, T. S. Rausch

Enclosure:

Susquehanna Steam Electric Station's Response to Request for Additional Information Associated with Recommendation 2.3, Seismic Walkdowns Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP

Enclosure to PLA-7106 Susquehanna Steain Electric Station's Response to Request for Additional Information Associated with RecoiTIInendation 2.3, Seismic W alkdowns

Enclosure to PLA-7106 Page 1 of 4 Susquehanna Steam Electric Station's Response to Request for Additional Information Associated with Recommendation 2.3, Seismic Walkdowns PPL Susquehanna, LLC [PPL] stated by letter that the seismic walkdowns would be performed in accordance with Electric Power Research Institute EPRI-1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic." Following the NRC staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report review and site audits, the NRC staff identified additional information necessary to allow the staff to complete its assessments as described in "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns". PPL's responses to the request for additional information are provided below.

1.

Conduct of the walkdowns, determination of potentially adverse seismic conditions (P ASCs ), dispositioning of issues, and reporting Seismic Walkdown packages were prepared for each equipment item on the Seismic Walkdown Equipment List (SWEL). Seismic Walkdown packages included Seismic Walkdown Checklists (SWCs ), Area Walkby Checklists (AWCs), equipment laydown area drawings, applicable seismic qualification information and IPEEE documentation.

a. Approach taken by Seismic Walkdown Engineers (SWEs) for field observations that were not considered to be P ASCs (No Corrective Action Program (CAP) Entry)

1.

Most observations determined that the condition found in the field matched the current licensing basis and were marked as Yes (Y) on the SWC/AWC. No additional documentation was required.

11.

Some observations were found to be acceptable based on engineering judgment and were marked as Yes (Y) on the SWC/ A WC. The basis/rationale associated with the engineering judgment was documented on the final SWC/ A WC.

111.

When the SWEs were uncertain or did not have enough documentation to determine that a field observation was not a P ASC, then the observation would be marked as Unknown (U) on the SWC/AWC. After returning from the field, the SWE would look at existing documentation (design drawing, calculations, the IPEEE Program, etc.) to determine if the observation was acceptable. If the

Enclosure to PLA-71 06 Page 2 of 4 Susquehanna Steam Electric Station's Response to Request for Additional Information Associated with Recommendation 2.3, Seismic Walkdowns observation was determined to be acceptable and to not be a P ASC, then the disposition was documented on the final SWC/ A WC by providing a reference to the previously performed evaluation or calculation. The status on the final SWC/AWC would then be changed from (U) to (Y).

b. Approach taken by SWEs for observations that were found to be PASCs (CAP Entry)

1. P ASCs were described in the Initial Seismic W alkdown Report as potentially adverse seismic condition and issues/concerns. Refer to of Enclosures 1 and 2 of PLA -6941 and Attachment 20 of of PLA-7050 for a list of all P ASCs identified during the Seismic Walkdowns at Susquehanna Steam Electric Station (SSES)

Units 1 and 2.

11. If the SWE could not determine via direct observation or through follow-up investigation of existing documentation that the anchorage, any interaction effect or any other adverse condition was not a P ASC, then the item was entered into CAP for further evaluation.

111. Observations determined to be a P ASC were entered into the CAP by creating a condition report (CR). The process for creating a CR followed plant procedure NDAP-QA-0702. All CRs generated were included in a table in the Initial Walkdown Reports.

IV. Some CRs were evaluated without a need for a Licensing Basis Evaluation (LBE). The evaluation is documented in the CR under the CAP.

v. A LBE was performed for all observations that could not be evaluated by existing documentation, engineering judgment, or simple analysis.

Licensing Basis Evaluations were performed within the CAP and documented therein.

v1. For the conditions that required LBEs, plant documents such as calculations and drawings were updated as appropriate. Changes to plant equipment were tracked by an action item until the condition was resolved.

Enclosure to PLA-7106 Page 3 of 4 Susquehanna Steam Electric Station's Response to Request for Additional Information Associated with Recommendation 2.3, Seismic Walkdowns

c. Review effort performed in response to this Request for Additional Information is as follows:

1. A review was performed to ensure that the methodology described herein to handle field observations was the method that was used. The review effort consisted of the following two activities:

1) Verification that the basis for any status change (Y/N/U) between the field SWC and final SWC was properly documented.

2) Verification that if the basis was the result of a new analysis (other than that considered to be simple), that the analysis was properly captured in CAP.

11. CR-2013-03407 was generated to document the results of this review.

d. Conclusions No new conditions were identified that warrant CAP entry or a supplement to the submitted reports for NTTF 2.3. PPL has confirmed that all PASCs were addressed and included in the reports to the NRC. Details for the review effort performed in response to this Request for Additional Information are documented in Condition Report (CR) CR-2013-03407.

2.

Conduct of the Peer Review Process

a. Confirmation that the activities described in the walkdown guidance on page 6-1 were assessed as part of the peer review process.

All peer review activities described on page 6-1 of the Seismic Walkdown Guidance were assessed as part of the peer review process and included in the Initial Seismic Walkdown Reports. This information is contained in Attachments 11, 12, and 13 for Enclosure 1 of PLA -6941, Attachments 11, 12, and 13 for Enclosure 2 of PLA-6941, and Attachments 21 and 22 for of PLA-7050.

b. A complete summary of the peer review process and activities. Details should include confirmation that any individual involved in performing any

Enclosure to PLA-7106 Page 4 of 4 Susquehanna Steam Electric Station's Response to Request for Additional Information Associated with Recommendation 2.3, Seismic Walkdowns 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.

A complete summary of the peer review process and activities was included in the Initial Seismic Walkdown Reports. This information is contained in Attachments 11, 12, and 13 for Enclosures 1 and 2 of PLA-6941 and Attachments 21 and 22 for Enclosure 1 of PLA-7050. The following two items are clarifications to the responsibilities of the individuals involved in the seismic walkdown activities and peer review process as described in Enclosures 1 and 2 of PLA-6941 and Enclosure 1 of PLA-7050.

1. In Attachment 11 of Enclosures 1 and 2 of PLA -6941, there are three peer reviewers listed for the SWEL; Ross D. Gardner, Grant J. Fernsler, Jr., and Jonathan M. Seek. Attachment 11 should note that Mr. Fernsler provided the operations peer review for SWEL 1 and Mr. Seek provided the operations peer review for SWEL 2.

ii.

In Attachment 22, page 4, item 3 of Enclosure 1 of PLA-7050, Todd Swoyer and Grant Fernsler were listed as the Equipment Selection Personnel for the changes made to the SWEL during the Inaccessible Equipment Item Seismic Walkdowns. Grant Fernsler was incorrectly listed. Todd Swoyer and Tim Charles were the Equipment Selection Personnel as indicated by their signatures on Attachment 14 of of PLA-7050. Ross Gardner and Grant Fernsler were the peer reviewers for the changes made to the SWEL during the Inaccessible Equipment Item Seismic Walkdowns.

Based on the information contained in Enclosures 1 and 2 of PLA-6941, of PLA-7050, and the two clarifications noted above, no individuals involved in performing any given walkdown activity were a peer reviewer for that same activity.