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{{Adams
#REDIRECT [[ET 14-0006, Response to Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns at Wolf Creek Generating Station]]
| number = ML14035A225
| issue date = 01/28/2014
| title = Response to Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns at Wolf Creek Generating Station
| author name = Broschak J P
| author affiliation = Wolf Creek Nuclear Operating Corp
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000482
| license number =
| contact person =
| case reference number = ET 14-0006
| document type = Letter
| page count = 6
}}
 
=Text=
{{#Wiki_filter:W LF CREEKVNUCLEAR OPERATING CORPORATION John P. BroschakVice President Engineering January 28, 2014ET 14-0006U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555
 
==References:==
: 1) Letter dated March 12, 2012 from E. J. Leeds and M. R. Johnson,USNRC, to M. W. Sunseri, WCNOC, "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-ichiAccident"
: 2) Letter dated May 31, 2012 from D. L. Skeen, USNRC, to A. P.Heymer, NEI, "Endorsement of Nuclear Energy Institute (NEI)12-07, Guidelines for Performing Verification Walkdowns of PlantFlood Protection Features"
: 3) Letter ET 12-0013, dated June 5, 2012, from J. P. Broschak, WCNOC, to USNRC4) Letter ET 12-0031, dated November 27, 2012, from J. P.Broschak, WCNOC, to USNRC5) Letter dated December 23, 2013, from R. J. Pascarelli, USNRC,to M. W. Sunseri, WCNOC, "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3,Flooding Walkdowns"
 
==Subject:==
 
Docket No. 50-482: Response to Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3,Flooding Walkdowns Gentlemen:
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 to allpower reactor licensees and holders of construction permits in active or deferred status andspecifically issued a 10 CFR 50.54(f) letter to Wolf Creek Nuclear Operating Corporation (WCNOC).
In Reference 3, WCNOC confirmed that it will use the flooding walkdown procedure endorsed by Reference 2 as the basis for performing flooding walkdowns at Wolf CreekAp.P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831An Equal Opportunity Employer M/F/HCNET ET 14-0006Page 2 of 3Generating Station.
Reference 4 provided WCNOC's final response to Reference 1, Enclosure 4, "Recommendation 2.3: Flooding."
Reference 5 transmitted a Request for Additional Information (RAI) associated with Recommendation 2.3. The attachment to this letter providesWCNOC's response to the RAI.This letter contains no commitments.
If you have any questions concerning this matter, pleasecontact me at (620) 364-4085, or Mr. Michael J. Westman at (620) 364-4009.
Sincerely, John P. BroschakJPB/rltAttachment cc: M. L. Dapas (NRC), w/aE. J. Leeds (NRC), w/aC. F. Lyon (NRC), w/aN. F. O'Keefe (NRC), w/aSenior Resident Inspector (NRC), w/a ET 14-0006Page 3 of 3STATE OF KANSAS )COUNTY OF COFFEYSS)John P. Broschak, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf ofsaid Corporation with full power and authority to do so; and that the facts therein stated are trueand correct to the best of his knowledge, information and belief.Joh .BroschakVieresident Engineering SUBSCRIBED and sworn to before me this 2A day of .l.. k(.- Lc' ,2014.CAYLE SHEPHEARD Not ublicackry putjIiý -Stateofan StA ,_rt. _ pi S l KExpiration Date m12-L I 6 Attachment to ET 14-0006Page 1 of 3Response to Request for Additional Information The Nuclear Regulatory Commission (NRC) issued Reference 1 to all power reactor licensees and holders of construction permits in active or deferred status and specifically issued a 10CFR 50.54(0 letter to Wolf Creek Nuclear Operating Corporation (WCNOC).
In Reference 3,WCNOC confirmed that it will use the flooding walkdown procedure endorsed by Reference 2as the basis for performing flooding walkdowns at Wolf Creek Generating Station.
Reference 4provided WCNOC's final response to Reference 1, Enclosure 4, "Recommendation 2.3:Flooding."
Reference 5 transmitted a Request for Additional Information (RAI) associated withRecommendation 2.3. This attachment provides WCNOC's response to the RAI. The specificNRC questions are shown in italic type.1. Confirmation that the process for evaluating the APM was reviewed.
Response:
Wolf Creek Nuclear Operating Corporation has completed a review of the processused at Wolf Creek Generating Station to evaluate available physical margin (APM).2. Confirmation that the APM process is now or was always consistent with the guidance inNEI 12-07 and discussed in this RAI.Response:
The original walkdown effort followed the guidance provided in NEI 12-07,"Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features."
: However, a small margin evaluation had not been performed for any of the flood protection features.
Although a small margin value was not pre-established, the original walkdown effortconfirmed that the seals can perform their intended safety function against floods up to thecurrent licensing basis flood height. Condition Report (CR) 78295 has been entered into thecorrective action program to perform a small margin evaluation for specific flood protection features in accordance with NEI 12-07, Section 5.8.3. If changes are necessary, a general description of any process changes to establish thisconsistency.
Response:
A small margin value will be defined.
APMs calculated during the walkdown willthen be compared to the small margin value. Any flood protection feature found to have smallmargin will be identified and entered into the corrective action program.
Attachment to ET 14-0006Page 2 of 34. As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, floodgates, etc.) was challenging for some licensees.
Generally, licensees were expected to useeither Approach A or Approach B (described below) to determine the APM for seals:a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value forAPM was documented.
No further action was performed if the APM value wasgreater than the pre-established small-margin threshold value. If the APM valuewas small, an assessment of "significant consequences" was performed and theguidance in NEI 12-07 Section 5.8 was followed.
b) If the seal pressure rating was not known, the APM for seals in a flood barrier isassumed to be greater than the pre-established small-margin threshold value ifthe following conditions were met: (1) the APM for the barrier in which the sealis located is greater than the small-margin threshold value and there is evidencethat the seals were designed/procured, installed, and controlled as flooding sealsin accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary todetermine that the seal configuration has been governed by the plant's designcontrol process since installation.
In this case, the APM for the seal could havebeen documented as "not small".As part of the RAI response, state if either Approach A or Approach B was used as part ofthe initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used.If neither Approach A or B was used to determine the APM values for seals (either as partof the walkdowns or as part of actions taken in response to this RAI), then perform thefollowing two actions:Enter the condition into the CAP (note: it is acceptable to utilize a single CAPentry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07,Section 5.8. The CAP disposition should confirm all seals can perform theirintended safety function against floods up to the current licensing basis floodheight. Disposition may occur as part of the Integrated Assessment.
If anIntegrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and takeinterim action(s),
if necessary, via the CAP processes.
These actions do notneed to be complete prior to the RAI response.
Report the APM as "undetermined" and provide the CAP reference in the RAIresponseResponse:
Approach A was used to determine the APM values for seals. Seal ratings wereused to determine APM and a numerical value for APM was documented.
Although a smallmargin value was not pre-established, the original walkdown effort confirmed that the seals canperform their intended safety function against floods up to the current licensing basis floodheight. CR 78295 has been entered into the corrective action program to perform a smallmargin evaluation for specific flood protection features in accordance with NEI 12-07, Section5.8.
Attachment to ET 14-0006Page 3 of 3
 
==References:==
: 1. Letter from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC,"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 ForceReview of Insights from the Fukushima Dai-ichi Accident,"
March 12, 2012; ADAMSAccession No. ML12053A340.
: 2. Letter from D. L. Skeen, USNRC, to A. P. Heymer, NEI, "Endorsement of NuclearEnergy Institute (NEI) 12-07, Guidelines for Performing Verification Walkdowns of PlantFlood Protection Features,"
May 31, 2012.3. WCNOC letter ET 12-0013, "Wolf Creek Nuclear Operating Corporation's 90-dayResponse to NRC Request for Information Pursuant to 10 CFR 50.54(f)
Regarding Recommendation 2.3, Flooding, of the Near-Term Task Force Review of Insights fromthe Fukushima Dai-ichi Accident,"
June 5, 2012; ADAMS Accession No. ML12165A244.
: 4. WCNOC letter ET 12-0031, "Wolf Creek Nuclear Operating Corporation 180-dayResponse to NRC Request for Information Pursuant to 10 CFR 50.54(f)Recommendation 2.3 (Flooding) of the Near- Term Task Force Review of Insights fromthe Fukushima Dai-ichi Accident,"
November 27, 2012; ADAMS Accession No.ML12340A397.
: 5. Letter from R. J. Pascarelli, USNRC, to M. W. Sunseri, WCNOC, "Request forAdditional Information Associated with Near-Term Task Force Recommendation 2.3,Flooding Walkdowns,"
December 23, 2013; ADAMS Accession No. ML1 3325A891.}}

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