BSEP 13-0063, Supplemental Information Regarding Recommendation 2.3 Flooding Walkdown of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

Supplemental Information Regarding Recommendation 2.3 Flooding Walkdown of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

ML13261A291
Person / Time
Site:	Brunswick
Issue date:	09/10/2013
From:	Hamrick G Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 13-0063
Download: ML13261A291 (4)

Text

DUKE ViceT. President George Hamrick ENERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 September 10, 2013 Serial: BSEP 13-0063 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324 Supplemental Information Regarding Recommendation 2.3 Flooding Walkdown of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

References:

1. 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, ADAMS Accession Number ML12053A340

2. Letter from M. Annacone (CP&L) to the U.S. Nuclear Regulatory Commission, Recommendation 2.3 Flooding Walkdown of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichiAccident, dated November 27, 2012, ADAMS Accession Number ML12340A074 Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a Request for Information (i.e., Reference 1) requesting licensees to provide information regarding Recommendation 2.3, Flooding, to support the evaluation of the NRC staff recommendation for the Near-Term Task Force (NTTF) review of the accident at the Fukushima Dai-ichi nuclear facility. In a letter dated November 27, 2012 (i.e., Reference 2), Duke Energy Progress, Inc.,

formerly known as Carolina Power & Light Company (CP&L), provided the response to Reference 1 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

This submittal provides updated information regarding the BSEP Flood Protection Features Walkdown Report included in Enclosure 1 of Reference 2. Specifically, clarifications are being made to information provided regarding the effectiveness of flood protection features at BSEP.

The enclosure to this letter provides the affected pages of the BSEP Flood Protection Features Walkdown Report with the revised content.

No regulatory commitments are contained in this submittal. Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

Awoi

U.S. Nuclear Regulatory Commission Page 2 of 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on September 10, 2013.

Sincerely, George T. Hamrick

Enclosure:

Revised Page for BSEP Flood Protection Features Walkdown Report (i.e., Enclosure 1 of ADAMS Accession Number ML12340A074) cc (with enclosure):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Christopher Gratton (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Mr. Robert J. Fretz, Jr. (Mail Stop OWFN 4A15A) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Mr. Robert L. Dennig (Mail Stop OWFN 10A1) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

Revised Page for BSEP Flood Protection Features Walkdown Report (i.e., Enclosure I of ADAMS Accession Number ML12340A074)

of concrete/metal manhole cover. For the manhole structure: no signs of damage (e.g.,

leakage, surface cracks) that would cause the wall to be non-functional, or signs of structural degradation or opening, apparent degradation in structural members, water strains emanating from surface, leakage on interior surface or surface cracks greater than 0.04 in.

in width are present.

Flood Mitigation Procedures: Procedures that exist for the operation, positioning, or installation of flood protection features will work under the conditions expected during a licensing basis flood, and the steps can be completed within the time available. Procedures that include a process for obtaining the credited warnings have sufficient time to perform the necessary actions. The instructions in the procedure are accurate and any needed support equipment is staged, available, and appropriate for completing the function. Training on the procedures is appropriate.

B. Effectiveness of Flood Protection Features at BSEP The deficiencies at BSEP include degraded or missing penetration seals, gaps in weather stripping on doors, a spectacle flange not in design configuration whose current configuration would allow flooding, and a transfer switch box that could allow flooding. The completed evaluations demonstrate that the individual deficiencies resulted in no operability concerns. An evaluation of the cumulative effect of these deficiencies is in-progress.

Reasonable simulations were scheduled for seventeen activities. Fifteen of the seventeen reasonable simulations demonstrated that the incorporated active features, temporary active features, and passive features are available, functional, and implementable. The completed activities consisted of closing severe weather doors, installing rattlespace contingency flood barriers, constructing a sandbag dike at the DG Building rollup door, checking railroad track door seals, staging portable air sump pumps, and securing a service water pump bay and a screenwash pump bay temporary penetration. Deficiencies were identified in some implementing procedures. These deficiencies consisted of a lack of detail, such as: missing or unclear direction on storage location of equipment, prestaging locations, weight indication for sandbags, and amount and type of sealant to be used. However, personnel completed the simulations within the required time indicating operator actions are feasible. Two reasonable simulations were not performed. The reasonable simulation for closing seal openings for the DG Building and the FOTCs, was not performed because the guidance lacked clarity as to which seals were specifically intended to be closed. The reasonable simulation for reinstalling a screenwash pump or service water pump casing could not be performed, since all pumps are installed and in-service. Reinstalling a pump casing is a contingency procedural action in the event that a pump was removed from service (i.e., for maintenance), and a PMH was a possibility. Both examples of the simulations that were not performed have been entered into the Corrective Action Program.

Condition reports have been issued, in the Corrective Action Program, addressing the identified deficiencies to ensure that the features will be able to effectively perform their credited flood protection function.

Additionally, flood protection features were reviewed to ensure that their flood protection function is adequately maintained. BSEP Technical Report OBNP-TR-019; External Event Protection Features, identifies the scope and maintenance strategy for all external event protection features, including flooding protection features. All plant features with the functions to prevent or mitigate the effects of external events, including flooding, will be periodically inspected in accordance with the Preventive Maintenance Program. Thus, the maintenance and monitoring programs for the credited flood protection features will be adequate to ensure the features will effectively perform their function.

Page 6