IR 05000259/2011009

NRC Temporary Instruction 2515/183 Inspection Report 05000259/2011009, 05000260/2011009, 05000296/2011009

ML111330509
Person / Time
Site:	Browns Ferry
Issue date:	05/13/2011
From:	Eugene Guthrie Division Reactor Projects II
To:	Krich R Tennessee Valley Authority
References
IR-11-009
Download: ML111330509 (25)

Text

UNITED STATES May 13, 2011

SUBJECT:

BROWNS FERRY NUCLEAR PLANT - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000259/2011009, 05000260/2011009, 05000296/2011009

Dear Mr. Krich:

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Browns Ferry Nuclear Plant using Temporary Instruction 2515/183, Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event. The enclosed inspection report documents the inspection results which were discussed on May 06, 2011, with Mr. Gannon and other members of your staff.

The objective of this inspection was to assess the adequacy of actions taken at Browns Ferry Nuclear Plant in response to the Fukushima Daiichi Nuclear Station fuel damage event. The results from this inspection, along with the results from similar inspections at other operating commercial nuclear plants in the United States, will be used to evaluate the U.S. nuclear industrys readiness to respond to a similar event. These results will also help the NRC to determine if additional regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter

TVA 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eugene Guthrie, Branch Chief Division of Reactor Projects Docket Nos.: 50-259, 50-260, 50-296 License Nos.: DPR-33, DPR-52, DPR-68

Enclosure:

Inspection Report 05000259/2011009, 05000260/2011009, 05000296/2011009

REGION II==

Docket Nos: 50-259, 50-260, 50-296 License Nos: DPR-33, DPR-52, DPR-68 Report No: 05000259/2011009, 05000260/2011009, 05000296/2011009 Licensee: Tennessee Valley Authority (TVA)

Facility: Browns Ferry Nuclear Plant, Units 1, 2, and 3 Location: Corner of Shaw and Nuclear Plant Roads Athens, AL 35611 Dates: April 1, 2011 - April 29, 2011 Inspectors: T. Ross, Senior Resident Inspector C. Stancil, Resident Inspector P. Niebaum, Resident Inspector L. Pressley, Resident Inspector Approved by: Eugene F. Guthrie, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000259/2011009, 05000260/2011009, 05000296/2011009; 04/01/2011 - 04/29/2011;

Browns Ferry Nuclear Plant, Units 1 and 2, Temporary Instruction 2515/183 - Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event This report covers an announced Temporary Instruction inspection. The inspection was conducted by resident inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the TI is to provide a broad overview of the industrys preparedness for events that may exceed the current design basis for a plant. The focus of the TI was on

(1) assessing the licensees capability to mitigate consequences from large fires or explosions on site, (2)assessing the licensees capability to mitigate station blackout (SBO) conditions,

(3) assessing the licensees capability to mitigate internal and external flooding events accounted for by the stations design, and

(4) assessing the thoroughness of the licensees walk downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site.

If necessary, a more specific follow-up inspection will be performed at a later date.

INSPECTION RESULTS

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), Section 02.03 and 03.03 as a guideline. If IP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

a. Verify through test or inspection The licensee identified and verified that active and passive Browns Ferry (BFN) equipment that equipment is available and meeting Extensive Damage Mitigating Guidelines (EDMG) and Severe Accident functional. Active equipment Management Guidelines (SAMG) requirements were available. In addition, the licensee shall be tested and passive verified other equipment (ground and aerial ladders) useful for, but not required to support equipment shall be walked down EDMG strategies was available. The licensee verified that the required equipment were and inspected. It is not part of the onsite preventive maintenance (PM) program, or incorporated as necessary.

expected that permanently The licensee also reviewed surveillances/tests and performance frequencies for the installed equipment that is identified equipment, and reviewed the results of recent tests. Active EDMG and SAMG tested under an existing equipment that did not have recent test results were tested. Passive equipment was walked regulatory testing program be down and inspected. The licensee initiated PERs for any identified gaps.

retested.

Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, This review should be done for a reviewed test results, discussed actions, reviewed records, etc.).

reasonable sample of mitigating The licensees actions as discussed above were completed prior to the issuance of NRC TI strategies/equipment.

2515/183. The inspectors assessed the licensees capabilities by conducting a review of the licensees walkdown activities. In addition, the inspectors independently walked down and verified all major EDMG equipment staged throughout the site. .

Discuss general results including corrective actions by licensee.

The EDMG and SAMG equipment on site was determined to be available and functional with two exceptions which were captured by the licensee in their corrective action program (CAP).

The portable diesel-driven fire pump and Fire Engine #2 would not draft from the river, but would pump when connected to a low pressure hydrant on the outside fire main. Fire Engine #2 was successfully capacity tested on the outside fire main. Fire Engine #1 successfully drafted from the river and met its required capacity, therefore, supporting all applicable fire fighting strategies. This was captured in the licensees CAP as Problem Evaluation Report (PER) 342251.

The licensee also initiated PER 341654 to ensure PM tasks were established for the hand-held tachometers and portable battery carts used to support three EDMG strategies.

Describe the licensees actions to verify that procedures are in place and can be executed Licensee Action (e.g. walkdowns, demonstrations, tests, etc.)

b. Verify through walkdowns or The licensee reviewed five EDMGs that contain 39 strategies as well as 15 SAMG demonstration that procedures procedures. Operations staff walked down the EDMGs and SAMGs procedures to ensure to implement the strategies all procedures were executable as written. Additionally, the licensee verified two site associated with B.5.b and 10 security procedures and an Abnormal Operating Instruction could be performed as written.

CFR 50.54(hh) are in place and The licensee initiated Procedure Change Requests (PCRs) for various procedure are executable. Licensees may enhancements identified during the walkdowns.

choose not to connect or operate permanently installed equipment during this verification.

This review should be done for a reasonable sample of mitigating strategies/equipment.

Describe inspector actions and the sample strategies reviewed. Assess whether procedures were in place and could be used as intended.

The licensees actions discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capabilities by conducting a review of the licensees walkdown activities. In addition, the inspectors independently walked down several EDMG strategies to verify the licensees conclusions. As discussed in section 03.01(a) above, although two portable fire pumps would not draft from the river, the inspectors determined that sufficient redundant capability remained to support the EDMG strategies that require use of a portable fire pump.

Discuss general results including corrective actions by licensee.

The licensee reviewed EDMG and SAMG strategies and did not identify any issues that would prevent execution of the procedures as written. Operations staff walked down the procedures to ensure actions taken in the field could be performed. The licensee initiated PCRs to enhance procedures as necessary. Appropriate issues identified by the licensee were entered into the CAP. Specific PERs are listed in section 03.01(e) below.

Describe the licensees actions and conclusions regarding training and qualifications of Licensee Action operators and support staff.

c. Verify the training and The licensee verified that qualifications and training requirements were current for qualifications of operators and Operations staff that implement the EDMG strategies and SAMG procedures. The licensee the support staff needed to also verified that emergency response Technical and Operations Support Center training implement the procedures and was conducted and included an overview of the EDMG strategies. Emergency Response work instructions are current for Organization (ERO) personnel from the engineering support group received EDMG training activities related to Security that was verified to be current.

Order Section B.5.b and severe Describe inspector actions and the sample strategies reviewed to assess training and accident management qualifications of operators and support staff guidelines as required by 10 CFR 50.54 (hh).

The licensees actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors independently reviewed and verified the licensees training and qualification materials and records related to B.5.b and SAMG event response.

Discuss general results including corrective actions by licensee.

The training requirements, qualifications, and associated records needed for Operations and Fire Operations personnel for implementation of EDMG and SAMGs were reviewed by the licensee. The training requirements, qualifications, and associated records needed for ERO command and support staff for the implementation of actions needed to mitigate a B.5.b event or implement the EDMG strategies were also reviewed. All ERO command and support staff training requirements were verified as current by the licensee.

Describe the licensees actions and conclusions regarding applicable agreements and Licensee Action contracts are in place.

d. Verify that any applicable The licensee identified all applicable contracts and agreements committed to be in place for agreements and contracts are in the mitigation of a B.5.b related event. The licensee verified that the contracts and place and are capable of agreements were current, and documented the availability of required offsite equipment to meeting the conditions needed support the mitigation strategy.

to mitigate the consequences of For a sample of mitigating strategies involving contracts or agreements with offsite entities, these events.

describe inspector actions to confirm agreements and contracts are in place and current (e.g., confirm that offsite fire assistance agreement is in place and current).

This review should be done for a The licensees actions as discussed above were completed prior to the issuance of NRC TI reasonable sample of mitigating 2515/183. The inspectors assessed the licensees capabilities by conducting a review of strategies/equipment.

the licensees fire protection services agreements with the Clements Volunteer Fire Dept.,

the City of Athens Fire and Rescue Dept., the City of Decatur, and the City of Huntsville-Madison County Airport Authority. The inspectors verified the agreements were current and adequate for meeting the licensees mitigation strategy.

Discuss general results including corrective actions by licensee.

The licensee verified all current agreements and required offsite equipment were available for interface with the above off site fire departments and/or local government entities. The licensee initiated PER 344210 to verify that the current memorandums of understanding and agreements meet their current standards of excellence.

Document the corrective action report number and briefly summarize problems noted by the Licensee Action licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open corrective The following PERs were written during the licensees review of the EDMG strategies and action documents to assess SAMG procedures:

problems with mitigating strategy implementation

• PER 342251, Engine #2 and the portable diesel-powered fire pump would not draft identified by the licensee.

from the river when tested.

Assess the impact of the

• PER 341654, Establish PM tasks for the EDMG battery carts and hand-held problem on the mitigating tachometers capability and the remaining

• PER 342310, Perform a functional test of the BFN oscillating monitor nozzles.

capability that is not impacted.

03.02 Assess the licensees capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, Loss of All Alternating Current Power, and station design, is functional and valid. Refer to TI 2515/120, Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22 as a guideline. It is not intended that TI 2515/120 be completely reinspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Describe the licensees actions to verify the adequacy of equipment needed to mitigate an Licensee Action SBO event.

a. Verify through walkdowns and The licensee, in their industry response, documented that no gaps were identified, and that inspection that all required no pre-staged equipment nor materials were required by station SBO analysis or materials are adequate and procedures.

properly staged, tested, and maintained.

Specifically, the licensee assigned a non-licensed operator to walkdown all SBO response procedure steps outside of the control rooms, but only for the ability to perform the actions concurrent with the site design basis flood of 578 above sea level.

Describe inspector actions to verify equipment is available and useable.

The licensees actions discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capabilities by conducting a review of the licensees walkdown activities. In addition, the inspectors walked down the licensees SBO abnormal operating instruction (AOI), to independently verify the licensees conclusions.

Discuss general results including corrective actions by licensee.

As discussed in section 03.02(a) above, the licensee identified no gaps, and that no pre-staged equipment or materials were required by station SBO analysis or procedures.

However, the inspectors identified two longstanding licensee identified issues associated with SBO mitigation capabilities that have not been completely resolved to date. These issues were associated with installed plant equipment invoving safety related Emergency Diesel Generators (EDG) and the non-safety related 4KV Bus-Tie Board.

• The EDG parallel function has never been fully tested with two Residual Heat Removal (RHR) pumps loaded onto the same bus supplied from two paralleled EDGs. The licensees design basis LOCA with a concurrent LOOP required the onsite electrical system to be capable of powering two RHR subsystems (two RHR and two RHR Service Water pumps) on each unit, which per the licensees loss of offsite power and SBO procedure, required paralleling the Unit 1/2 and Unit 3 DGs for long term suppression pool cooling. The EDG parallel function was partially tested once in October 1988, with only one RHR Pump loaded onto the 4KV Shutdown Board. In response to this previously identified issue by the inspectors, the licensee performed a functional evaluation (PER 178142), and based on existing voltage regulator surveillance testing, Based on EDG cross-tie breaker and cable preventive maintenance , and electric governor controller and relay logic and controls testing, the licensee concluded there was reasonable assurance that the EDG system parallel with unit function would perform as designed. The inspectors noted that as part of design change DCN 69532 to replace the existing EDG governors, the licensee was developing a post-modification test (PMT) that may include paralleling an EDG with the new governor with an EDG with the old governor. Additionally, the licensee was also considering to use this PMT to fully verify the capability of paralleling two EDGs to the same 4KV Shutdown Board while loaded with two RHR pumps. This issue was already captured in the licensees CAP.

• The non-safety related 4KV Bus-Tie Board remains untested with respect to full energization of the board to prove that the system can carry design current and that all connections are tight with no thermal hot spots which could lead to an adverse condition. The non-safety related 4KV Bus-Tie Board PM was cancelled by the licensee for many years, and then upon discovery of the lapsed PMs in July, 2009, the PMs were re-established. Work orders (WO) were completed for board cleaning and inspection, and breaker refurbishment. The refurbished breakers were sent back to the site, but were not installed in the Tie-Board. Upon discussion with the licensee, PER 359621 was initiated and the breakers reinstalled to restore the capability of the Bus Tie-Board for an SBO event. Additionally, the Bus Tie-Board has not been energized for many years, and the licensee did not intend to energize the Bus Tie-Board as part of PMT following the PMs. In response to inspectors concerns, the licensee initiated PER 339840 to determine if the Bus Tie-Board should be loaded for PMT. The licensees SBO procedure currently provides guidance to use the non-safety related 4KV Bus-Tie Board as an optional method to cross-connect power to mitigate the SBO event. (Three of eight diesels are assumed to remain available during the licensing basis SBO event.)

Additional corporate licensing recommendations to be evaluated by the licensee:

• Increase capability of DC power for reactor pressure and level instruments (carts or chargers)

• Increase capability of DC power for safety relief valves (carts or chargers)

• Update simulator modeling for loss of all AC, DC power drainage, core parameters, temperature increase, radiation fields, and reactor core isolation cooling (RCIC) loss due to reduced net positive suction head (NPSH)

Licensee Action Describe the licensees actions to verify the capability to mitigate an SBO event.

b. Demonstrate through The licensee, in their industry response, documented that no gaps were identified and that walkdowns that procedures for the Abnormal Operating Instruction (AOI) that governs response to an SBO was walked response to an SBO are down and demonstrated to be executable.

executable.

Specifically, the licensee assigned a non-licensed operator to walkdown all SBO response procedure steps outside of the control rooms, but only for the ability to perform the actions concurrent with the site design basis flood of 578 above sea level.

Additionally, on March 21, 2011, the licensee performed a Unit 3 simulator scenario with both an onsite and offsite loss of all AC (i.e. no diesel generators available). This was conducted by licensee training personnel with one licensed SRO and corporate representatives observing, including emergency planning.

Describe inspector actions to assess whether procedures were in place and could be used as intended.

The licensees actions discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capabilities by conducting a review of the licensees walkdown activities and observing simulator performance. In addition, the inspectors walked down the licensees SBO abnormal operating instruction (AOI), to independently verify the licensees conclusions.

Discuss general results including corrective actions by licensee.

The inspectors determined that the licensee did not adequately verify the stations capability to mitigate SBO conditions. The AOI that governs response to an SBO was not completely walked down, and therefore, was not demonstrated to be executable. Specifically, control room operator actions were not walked down. Additionally, a non-licensed operator was assigned to walkdown all SBO response procedure steps outside of the control rooms, but only for the ability to perform the actions concurrent with the site design basis flood of 578 above sea level. Discussions with the licensee indicated that this action was assigned preemptively prior to the industry request for information, but was erroneously credited as a licensee response. The licensee initiated PER 361999 for this omission. Subsequently, the licensee completed the walkdown of the SBO procedure by a licensed operator. An independent walkdown by the inspectors of more significant portions of the SBO response procedure (control room actions) verified that the procedure was executable except for the issues identified in 3.02.a above.

Additional corporate licensing recommendations to be evaluated by the licensee:

• Alternate power source for key primary containment instruments necessary to make EOI decisions

• Transfer of non-safety related DC loads, main turbine and reactor feed pumps emergency oil pumps 03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design. Refer to IP 71111.01, Adverse Weather Protection, Section 02.04, Evaluate Readiness to Cope with External Flooding as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.

Describe the licensees actions to verify the capability to mitigate existing design basis Licensee Action flooding events.

a. Verify through walkdowns and The licensee verified that all existing equipment necessary to mitigate flooding events were inspection that all required capable of performing their function in accordance with existing procedures, including materials are adequate and internal and external doors. Additionally, the licensee assigned a licensed operator to properly staged, tested, and walkdown the abnormal operating instructions associated with flooding to verify the maintained.

capability of the procedures and equipment necessary to mitigate flooding. The licensee also reviewed the PM procedures and work orders for the affected systems and verified the periodicity and last date of completion.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors reviewed the licensees walkdown activities and verified the completion of PM work orders. The inspectors also independently walked down and inspected selected risk significant doors and mitigating equipment throughout the site. Furthermore, the inspectors verified the licensees flood mitigation procedures were executable. .

Discuss general results including corrective actions by licensee.

In general, the station appears to be ready to respond to an external flood consistent with the plant design. However, some items of note were discovered by the licensee and are being addressed through the CAP. PMs and abnormal operating instructions (AOI) were determined to be executable with some items requiring enhancement.

Three external watertight doors for the safety related service water pump rooms were determined to be degraded, but functional, as previously identified by the licensee before the issuance of NRC TI 2515/183. The licensee determined the watertight door leakage would be within the capacity of the individual room sump pumps, therefore allowing the equipment to perform its function during an external flood. Repair of two of the degraded doors were completed on April 2, 2011 per WO# 112108564. The third door was scheduled to be replaced on May 31, 2011, via WO# 08-721887-000.

Diesel generator building flood sluice gates (emergency drain valves) did not have a PM program. The licensee initiated PER 345987 to develop PMs for the flood sluice gates.

Upon request by the inspectors, the licensee successfully cycled these DG building drain valves. However, service request (SR) 360256 was initiated for these drain valves because of the excessive difficulty cycling these valves manually. This SR was attached to PER 345987.

The licensee determined the Probable Maximum Precipitation (PMP) ditch surrounding the plant needed to be dredged, but was functional The licensee initiated PER 294004to dredge the ditch.

The licensee initiated PER 344531 to enhance emergency plan implementation procedure (EPIP) classification for internal flooding events. The internal flood strategy was adequately prescribed in the sites emergency operating instructions and annunciator response procedures.

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use IP 71111.21, Component Design Basis Inspection, Appendix 3, Component Walkdown Considerations, as a guideline to assess the thoroughness of the licensees walkdowns and inspections.

Describe the licensees actions to assess the potential impact of seismic events on the Licensee Action availability of equipment used in fire and flooding mitigation strategies.

a. Verify through walkdowns that Licensee actions included the identification of important equipment required for mitigation of all required materials are fire and flood events, and to identify the potential for loss of equipment function during adequate and properly staged, seismic events. The licensee convened a multi-disciplined team and created a team charter tested, and maintained.

to conduct table-top type of reviews, including walkdowns and inspections of the equipment, both permanent and temporary. Licensee personnel inspected the material condition of the equipment and surrounding seismic equipment and structures to determine if the equipment was seismically qualified, or assessed whether it would be possible to evaluate the equipment as being seismically rugged. The licensee also assessed the transportability and ruggedness of credited portable equipment. Seismic vulnerabilities, including storage locations, were identified, along with mitigating strategies for equipment that was not seismically qualified.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors conducted independent walkdowns of important equipment needed to mitigate fire and flood events to assess the potential that the equipments function could be lost during a seismic event. This equipment included, but was not limited to:

• Major B.5.b contingency response equipment staged throughout the site

• Installed electric fire pumps and their controls

• Watertight doors at the RHRSW/ EECW pumps at the intake structure, EDG buildings and reactor building

• External emergency drain isolation valves for EDG buildings The licensees external flood and earthquake abnormal operating instructions (AOI) were reviewed to verify usability. The results of the inspectors reviews were consistent with the licensees conclusions that there were a number of seismic vulnerabilities that potentially needed to be addressed, as described below.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

The licensee determined that non-safety related SSCs, in general, were not considered to be either seismically qualified or seismically rugged. Some flood mitigation equipment (DG building external drain valves, portable water tight doors and reactor building flooding detectors) were not designed to be seismically qualified. Similarly, the vast majority of the fire protection system, including the installed electric fire pumps and the diesel driven channel fire pump, were not seismically qualified. Firefighting equipment staged to respond to B.5.b events were not stowed in seismically qualified buildings and locations, since a seismic event and B.5.b event was not assumed to occur coincidentally. Furthermore, even flood mitigation equipment that was seismically qualified equipment (e.g., RHRSW/EECW water tight doors) were not analyzed for a simultaneous stacked event.

The licensee entered the following issues into their CAP:

• PER 348491, Evaluate upgrading high pressure fire pumps (HPFP) and piping to seismic class I

• PER 348485, Evaluate construction of seismic class I structure to house fire personnel and equipment

• PER 348496, Evaluate design to cross-connect emergency equipment cooling water (EECW) piping to HPFP system piping as a possible new strategy

• PER 349896, Potential new strategy for EDG buildings if external water tight doors cannot be evaluated for stacked events

• PER 349897 Potential new strategy for EDG buildings if external drain valves and piping cannot be seismically qualified

• PER 349898 Potential new strategy for EDG buildings if flooding mitigation equipment cannot be seismically qualified

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. K. Polson and other members of BFN management at the conclusion of the inspection on May 6, 2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Baker, Operations Support Superintendent

M. Bryant, Fire Operations

J. Davenport, Site Licensing

T. Feltman, EP Manager

L. Hughes, Operations Manager

T. Marlow, Licensing Manager

M. Rasmussen, Operations Shift Superintendent