Mary Fax E-mail: [email protected] CENG. · 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, dated December 21, 2012 (ML 12362A448) (h) Letter from J

Mary G. KorsnickActing Chief Executive OfficerChief Nuclear Officer

CENG.a pint venture of

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Office 410-470-5133Fax 443-213-6739

E-mail: [email protected]

December 2, 2013

U.S. Nuclear Regulatory Commission11555 Rockville PikeRockville, MD 20852

ATTENTION:

SUBJECT:

REFERENCES:

Document Control Desk

Calvert Cliffs Nuclear Power Plant, Units I and 2Renewed Facility Operating License Nos. DPR-53 and DPR-69Docket Nos. 50-317 and 50-318

Nine Mile Point Nuclear Station, Units I and 2Renewed Facility Operating License Nos. DPR-63 and NPF-69Docket Nos. 50-220 and 50-410

R.E. Ginna Nuclear Power PlantRenewed Facility Operating License No. DPR- 18Docket No. 50-244

Response to Request for Additional Information Associated with Near-TermTask Force Recommendation 2.3, Seismic Walkdowns

(a) Letter from R. H. Beall (NRC) to Selected Licensees, Request forAdditional Information Associated with Near-Term Task ForceRecommendation 2.3, Seismic Walkdowns, dated November 1, 2013(ML 13304B418)

(b) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),Calvert Cliffs Nuclear Power Plant, Unit 1, Response to 10 CFR 50.54(f)Request for Information, Recommendation 2.3, Seismic, datedNovember 27, 2012 (ML12349A281)

(c) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),Calvert Cliffs Nuclear Power Plant, Unit 2, Response to 10 CFR 50.54(f)Request for Information, Recommendation 2.3, Seismic, datedNovember 27, 2012 (ML 12339A349)

(d) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),R. E. Ginna Nuclear Power Plant, Response to 10 CFR 50.54(f) Request forInformation, Recommendation 2.3, Seismic, dated November 27, 2012(ML12347A104)

100 Constellation Way, Suite 200CBaltimore, MD 21202 'ýC)C))

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Document Control DeskDecember 2, 2013Page 2

(e) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),Nine Mile Point Nuclear Station, Unit 1, Response to 10 CFR 50.54(f)Request for Information, Recommendation 2.3, Seismic, datedNovember 27, 2012 (ML12342A03 1)

(f) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),Nine Mile Point Nuclear Station, Unit 2, Response to 10 CFR 50.54(f)Request for Information, Recommendation 2.3, Seismic, datedNovember 27, 2012 (ML 12348A086)

(g) Letter from J. A. Spina (CENG) to Document Control Desk (NRC),R. E. Ginna Nuclear Power Plant, Supplemental Response to10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic,dated December 21, 2012 (ML 12362A448)

(h) Letter from J. A. Spina (CENG) to Document Control Desk (NRC), NineMile Point Nuclear Station, Unit 2, Submittal of Nine Mile Point NuclearStation, Unit 2 Supplemental Seismic Walkdown Report, dated January 31,2013 (ML13037A082)

(i) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),Calvert Cliffs Nuclear Power Plant, Unit 2, Supplemental Response to10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic,dated June 28, 2013 (MLI3193A150)

(j) Letter from J. A. Spina (CENG) to Document Control Desk (NRC), NineMile Point Nuclear Station, Unit 1, Supplemental Response to10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic,dated July 12, 2013 (MLI3197A222)

(k) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),R. E. Ginna Nuclear Power Plant, Supplemental Response to10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic,dated July 25, 2013 (ML13210A034)

On November 1, 2013 (Reference a), the U. S. Nuclear Regulatory Commission (NRC) issued a requestfor additional information associated with Near-Term Task Force Recommendation 2.3, SeismicWalkdowns. The NRC requested that the selected licensees respond within 30 days of the date of theletter.

Constellation Energy Nuclear Group, LLC (CENG) submitted seismic walkdown reports for CalvertCliffs Nuclear Power Plant, LLC (CCNPP), Units 1 and 2, R. E. Ginna Nuclear Power Plant, LLC(Ginna), and Nine Mile Point Nuclear Station, LLC (NMPNS) Unit 1 (NMP1) and Unit 2 (NMP2) inReferences (b) through (k). Attachments (1) through (3) provide the CENG response to the NRC'srequest for additional information dated November 1, 2013 (Reference a) for CCNPP, Ginna, andNMPNS, respectively.

There are no new regulatory commitments included within this correspondence.

Document Control DeskDecember 2, 2013Page 3

If there are any questions regarding this submittal, please contact Bruce Montgomery, Manager-NuclearSafety and Security, at 443-532-6533.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 2, 2013.

Sincerely,

Mary G. KorsnickMGK/STD/EMT/bjd

Attachment (1):Attachment (2):Attachment (3):

CCNPP Response to Request for Additional InformationGinna Response to Request for Additional InformationNMPNS Response to Request for Additional Information

cc: NRC Project Manager, Calvert CliffsNRC Project Manager, GinnaNRC Project Manager, Nine Mile PointRegional Administrator, NRC Region I

Resident Inspector, Calvert CliffsResident Inspector, GinnaResident Inspector, Nine Mile PointS. Gray, DNR

ATTACHMENT (1)

CCNPP RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Constellation Energy Nuclear Group, LLCDecember 2, 2013

ATTACHMENT (1)CCNPP RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

1. Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs),dispositioning of issues, and reporting

In order to clarify the process that was followed, please provide a description of the overall processused by the licensee (and its contractors) to evaluate observations identified in the field by the seismicwalkdown engineers (SWEs). The process should include how a field observation was determined tobe a PASC or not and how the bases for determinations were recorded. Once a determination wasmade that an observation was a PASC, describe the process for creating a condition report (or othertracking mechanism), performing the licensing basis evaluations (LBEs) (or other determinationmethod), and the resultant action, such as entering it into the corrective action program (CAP) ordocumenting the result and basis.

Also, in order to confirm that the reported information supports concluding that the plant meets thecurrent licensing basis (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 includesimilar conditions as the above examples and situations and for conditions for which acalculation, analysis (if more than a simple analysis), or evaluation was used for a determination.The supplement should include a short description of each condition, how it was dispositionedand 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), thebasis for the result, and how (or where) the result was captured in the plant's documentation orexisting plant process.

(b) Following the plant's standard procedures, confirm that a new CAP entry has been made to verifyif appropriate actions were taken when reporting and dispositioning identified PASCs (includingconditions for which a calculation, analysis (if more than a simple analysis), or evaluation wasused for a determination). The eventual CAP closeout, including the process followed andactions 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 mentionedabove is deemed not necessary, provide a statement of confirmation that all potentially seismicadverse conditions (including conditions for which a calculation, analysis (if more than a simpleanalysis), or evaluation was used for a determination) identified during the walkdowns and walk-bys were addressed and included in the report to the NRC.

CCNPP Response

Calvert Cliffs Nuclear Power Plant, LLC (CCNPP) utilized an engineering contractor to provide theSWEs for performing the original seismic walkdowns. These contracted SWEs, comprising a seismicreview team, were paired with an Operations Senior Reactor Operator (SRO) for each day's walkdown,and a station engineer as needed to offer assistance where necessary. For follow-up supplemental seismicwalkdowns, CCNPP utilized in-house qualified SWEs. The station SWEs followed the same processutilized by the contract personnel. Operations and maintenance personnel were also available and calledupon as needed. The judgments and conclusions of the SWEs are reflected in the completed seismicwalkdown checklists (SWCs) and area walk-by checklists (AWCs) previously submitted.

Throughout the walkdowns observations were made by the SWEs, and were noted on the field copies ofthe walkdown checklists (e.g., seismic housekeeping, block walls, equipment vibration, and threadengagement issues). Seismic interaction issues and housekeeping issues judged to be an immediate

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concern were corrected immediately. A trend Condition Report was written for housekeeping conditionsthat were identified and corrected during the seismic walkdowns.

The final submitted checklists contain the SWE's observations as well as the basis for their disposition.The SWEs were provided information by station design engineering as needed to determine if an issuerepresented a PASC. Hand calculations performed by the SWEs, hand sketches, and the basis forresolution of PASCs, not entered into CAP, are included in the originally submitted Recommendation 2.3,Seismic Walkdowns SWCs and AWCs. If a PASC was entered into the CAP it is noted on the SWC andAWC as well as Tables 5-2 and 5-3 of the original November 27, 2012 submittal.

Following each day's walkdowns, a daily debrief was held between the seismic review team and stationpersonnel. During this debrief, observations by the SWEs were discussed. In many cases, supplementalinformation (not on hand in the field) was provided to the SWEs to disposition their field concerns. Thisinformation included, but was not limited to, existing anchorage drawings, existing anchoragecalculations, and masonry wall qualifications. Field observations recorded on field copies of SWCs andAWCs that were dispositioned with existing documentation during final report preparation are reflected inthe final checklists submitted to the NRC.

Condition Reports were generated for any adverse condition that could not be dispositioned by the SWEsbased on their training, engineering judgment and existing station documentation available to them. Mostof these Condition Report were generated during the final report generation. The Condition Reportsgenerated included the necessary information for operations personnel to make the operabilitydetermination. Where required, seismic licensing basis evaluations were completed and documentedwithin the CAP. The November 27, 2012 Seismic Walkdown Report Tables 5-1 and 5-2, the Unit 2Supplemental Walkdown Report Tables 3-1 and 3-2, submitted on June 30, 2013, provide the CRnumbers, a summary of the condition and the action completion status. Unit 1 Condition Reports will beupdated in the Unit 1 supplement that is scheduled to be submitted by June 30, 2014.

Condition Reports generated from the walkdowns were dispositioned within the CAP and the bases forthese dispositions are contained therein. Examples of dispositions resulting from the evaluations includedrawing changes, calculation changes, calculation generation, work orders, and operability assessments.For any condition where degradation or non-conformance with design was identified, corrective actionswere initiated for restoration of the item to its proper design configuration. All resulting actions aretraceable through the initiated Condition Reports.

CCNPP Statement of Confirmation

A 100% audit of the original field copy walkdown sheets and the final submitted walkdown sheets hasbeen completed, and no new conditions have been identified requiring supplemental information or entryinto the CAP. All such conditions were previously identified in the original and supplemental seismicwalkdown reports. Therefore, response alternative (c) was followed to confirm that the reportedinformation supports concluding that CCNPP meets its current licensing basis (CLB).

All PASCs (including conditions for which a calculation, analysis (if more than a simple analysis), orevaluation was used for a determination) identified during the walkdowns and walk-bys were addressedand included in the initial and subsequent supplemental seismic walkdown reports to the NRC.

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2. Conduct of the Peer Review Process

In order to clarify the peer review process that was actually used, please confirm whether thefollowing 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 aspart of the peer review process.

(b) A complete summary of the peer review process and activities. Details should includeconfirmation that any individual involved in performing any given walkdown activity was not apeer reviewer for that same activity. If there were cases in which peer reviewers reviewed theirown 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 aboveinformation. If there are differences in the review areas or the manner in which the peer reviews wereconducted, describe the actual process that was used.

CCNPP Statement of Confirmation

The activities described on Page 6-1 of the Seismic Walkdown Guidance, EPRI 1025286, June 2012,were assessed as part of the CCNPP peer review process in the original and supplemental seismicwalkdown submittals. A complete summary of the peer review process and activities was provided in theoriginal and supplemental seismic walkdown submittals. Individuals involved in performing any givenwalkdown activity were not a peer reviewer for that same activity for either the original or supplementalseismic walkdown submittals. There are no cases in which peer reviewers reviewed their own work.There are no differences from the original submittal in the review areas or the manner in which the peerreviews were conducted.

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ATTACHMENT (2)

GINNA RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Constellation Energy Nuclear Group, LLCDecember 2,2013

ATTACHMENT (2)GINNA RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION





(b) Following the plant's standard procedures, confirm that a new CAP entry has been made to verifyif appropriate actions were taken when reporting and dispositioning identified PASCs (includingconditions for which a calculation, analysis (if more than a simple analysis), or evaluation wasused for a determination). The eventual CAP closeout, including the process followed andactions taken, should be in sufficient detail to enable NRC resident inspectors to follow up.


Ginna Response

R. E. Ginna Nuclear Power Plant, LLC (Ginna) utilized an engineering contractor to provide the SWEsfor performing the original seismic walkdowns. These contracted SWEs, comprising a seismic reviewteam, were paired with a station engineer with the same qualification, whose responsibility was to clarifythe site's design basis and assist in the identification of Seismic Walkdown Equipment List (SWEL)components. For follow-up supplemental seismic walkdowns, Ginna utilized in-house qualified SWEs.The station SWEs followed the same process utilized by the contract personnel. Operations andmaintenance personnel were also available and called upon as needed. The judgments and conclusions ofthe SWEs are reflected in the completed seismic walkdown checklists (SWCs) and area walk-bychecklists (AWCs) previously submitted.

Throughout the walkdowns observations were made by the SWEs, and were noted on the field copies ofthe walkdown checklists (e.g., seismic housekeeping, block walls, equipment vibration, and thread

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engagement issues). Seismic interaction issues and housekeeping issues judged to be an immediateconcern were corrected immediately. A trend Condition Report was written for housekeeping conditionsthat were identified and corrected during the seismic walkdowns. Checklists noted the conclusion of theSWEs when identified conditions were judged in the field to not be a PASC.

Following each day's walkdowns, a daily debrief was held between the seismic review team and stationpersonnel. During this debrief, observations by the SWEs were discussed. In many cases supplementalinformation (not on hand in the field) was provided to the SWEs to disposition their field concerns. Thisinformation included, but was not limited to, existing anchorage drawings, existing anchoragecalculations, and masonry wall qualifications. Field observations recorded on field copies of SWCs andAWCs that were dispositioned with existing documentation are not reflected in the final checklistssubmitted to the NRC.

Condition Reports were generated for any adverse condition that could not be dispositioned by the SWEsbased on their training, engineering judgment, and existing station documentation available to them. TheCAP was utilized to track resolution of all identified potentially adverse conditions not dispositioned bythe SWEs. If calculations or drawing updates were required, the resolution was tracked and captured inthe CAP. Condition Reports were typically generated the day they were discovered. The ConditionReports generated included the necessary information for operations personnel to make the operabilitydetermination. Where required, seismic licensing basis evaluations were completed and documentedwithin the CAP. The November 27, 2012 Seismic Walkdown Report Tables 5-1 and 5-2, theDecember 21, 2012 Supplemental Seismic Walkdown Report Tables 4-2, 4-3, and 4-4, and the July 25,2013 Supplemental Seismic Walkdown Report Table 3-1 provide the Condition Report numbers, asummary of the condition, and the action completion status.

Condition Reports generated from the walkdowns were dispositioned within the CAP and the bases forthese dispositions are contained therein. Examples of dispositions resulting from the evaluations includedocumentation updates, calculation changes, calculation generation, work orders, modifications andoperability assessments. Condition Report dispositions also document the bases for whether or not theconditions were an adverse seismic condition or required a LBE. All identified conditions where anyactual analyses or calculations were performed are documented in the CAP. For any condition wheredegradation or non-conformance with design was identified, corrective actions were initiated forrestoration of the item to its proper design configuration. All resulting actions are traceable through theinitiated Condition Reports. Table 3-2 in the July 25, 2013 Supplemental Seismic Walkdown Reportprovided the current Condition Report status of open Condition Reports from the previous two submittals.

Ginna Statement of Confirmation

Based on the process of our walkdowns, and the reported information, it was determined thatsupplemental information was not necessary. Therefore, alternative (c) was chosen for confirming thatGinna meets its current licensing basis (CLB).

No new conditions have been identified requiring supplemental information or entry into the CAP. Allsuch conditions were previously identified in the original and supplemental seismic walkdown reports.All conditions where PASCs (including conditions for which a calculation, analysis (if more than asimple analysis), or evaluation was used for a determination) were identified resulted in generation of aCondition Report and entry into the CAP. These Condition Reports are listed in the November 27, 2012Seismic Walkdown Report Tables 5-1 and 5-2, the December 21, 2012 Supplemental Seismic WalkdownReport Tables 4-2, 4-3, and 4-4, and the July 25, 2013 Supplemental Seismic Walkdown Report Table3-1.

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Ginna Statement of Confirmation

The activities described on Page 6-1 of the Seismic Walkdown Guidance, EPRI 1025286, June 2012,were assessed as part of the Ginna peer review process in the original and supplemental seismicwalkdown submittals. A complete summary of the peer review process and activities was provided in theoriginal and supplemental seismic walkdown submittals. Individuals involved in performing any givenwalkdown activity were not a peer reviewer for that same activity for either the original or supplementalseismic walkdown submittals. There are no cases in which peer reviewers reviewed their own work.There are no differences from the original submittal in the review areas or the manner in which the peerreviews were conducted.

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ATTACHMENT (3)

NMPNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Constellation Energy Nuclear Group, LLCDecember 2, 2013

ATTACHMENT (3)NMPNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION





(b) Following the plant's standard procedures, confirm that a new CAP entry has been made to verifyif appropriate actions were taken when reporting and dispositioning identified PASCs (includingconditions for which a calculation, analysis (if more than a simple analysis), or evaluation wasused for a determination). The eventual CAP closeout, including the process followed andactions taken should be in sufficient detail to enable NRC resident inspectors to follow up.


NMPNS Response

Nine Mile Point Nuclear Station, LLC (NMPNS) Unit 1 (NMPI) and Unit 2 (NMP2) utilized anengineering contractor to provide the SWEs for performing the original seismic walkdowns. Thesecontracted SWEs, comprising a seismic review team, were paired with a station engineer with the samequalification, whose responsibility was to clarify the site's design basis and assist in the identification ofSeismic Walkdown Equipment List (SWEL) components. For follow-up supplemental seismicwalkdowns, NMPNS utilized in-house qualified SWEs. The station SWEs followed the same processutilized by the contract personnel. Operations and maintenance personnel were also available and calledupon as needed. The judgments and conclusions of the SWEs are reflected in the completed seismicwalkdown checklists (SWCs) and area walk-by checklists (AWCs) previously submitted.

Throughout the walkdowns observations were made by the SWEs, and were noted on the field copies ofthe walkdown checklists (e.g., seismic housekeeping, block walls, missing fastener, and bolting corrosion

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issues). Seismic interaction issues and housekeeping issues judged to be an immediate concern werecorrected immediately. A Condition Report was written for adverse housekeeping conditions that wereidentified and corrected during the seismic walkdowns. Checklists noted the conclusion of the SWEswhen identified conditions were judged in the field to not be a PASC.

Following each day's walkdowns, a daily debrief was held between the seismic review team and stationpersonnel. During this debrief observations by the SWEs were discussed. In many cases supplementalinformation (not on hand in the field) was provided to the SWEs to disposition their field observations.This information included, but was not limited to, existing anchorage drawings, existing anchoragecalculations, and masonry wall qualifications.

Condition Reports were generated for adverse conditions that could not be dispositioned by the SWEsbased on their training, engineering judgment, and existing station documentation available to them.Most of these Condition Reports were generated during the final report generation. The CAP was utilizedto track resolutions of all identified potentially adverse conditions not dispositioned by the SWEs. TheCondition Reports generated included the necessary information for operations personnel to make theoperability determination. Where required, seismic licensing basis evaluations were completed anddocumented within the CAP. The November 27, 2012 Seismic Walkdown Report Tables 5-1 and 5-2,provide the Condition Report numbers, a summary of the condition, and the action completion status.Supplemental seismic walkdowns performed and documented in Seismic Walkdown Reports submittedJanuary 31, 2013 for NMP2, and July 12, 2013 for NMPI did not identify any potential adverse seismicconditions during the walkdowns.

Condition Reports generated from the walkdowns were dispositioned within the CAP and the bases forthese dispositions are contained therein. Examples of dispositions resulting from the evaluations includedocumentation updates, calculation changes, work orders, and operability assessments. For any conditionwhere degradation or non-conformance with design was identified, corrective actions were initiated forrestoration of the item to its proper design configuration. All resulting actions are traceable through theinitiated Condition Reports.

NMPNS Statement of Confirmation

Based on the process of our walkdowns, and the reported information, it was determined thatsupplemental information was not necessary. Therefore, alternative (c) was chosen for confirming thatthe NMPI and NMP2 meet their current licensing basis (CLB).

No new conditions have been identified requiring supplemental information or entry into the CAP. Allsuch conditions were previously identified in the original and supplemental seismic walkdown reports.All conditions where PASCs (including conditions for which a calculation, analysis (if more than asimple analysis), or evaluation was used for a determination) were identified resulted in generation of aCondition Report and entry into the CAP. These Condition Reports are listed in the November 27, 2012Seismic Walkdown Report Tables 5-1 and 5-2.

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NMPNS Statement of Confirmation

The activities described on Page 6-1 of the Seismic Walkdown Guidance, EPRI 1025286, June 2012,were assessed as part of the NMPNS peer review process in the original and supplemental seismicwalkdown submittals. A complete summary of the peer review process and activities was provided in theoriginal and supplemental seismic walkdown submittals. Individuals involved in performing any givenwalkdown activity were not a peer reviewer for that same activity for either the original or supplementalseismic walkdown submittals for the respective unit. There are no cases in which peer reviewersreviewed their own work. There are no differences from the original submittal in the review areas or themanner in which the peer reviews were conducted.

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Documents

Mary Fax E-mail: [email protected] CENG. · 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Seismic, dated December 21, 2012 (ML 12362A448) (h) Letter from J