NRC 2012-0100, Response to 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding

Response to 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding

ML12326A713
Person / Time
Site:	Point Beach
Issue date:	11/20/2012
From:	Meyer L Point Beach
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC 2012-0100 NEE05-PR-001, Rev 0
Download: ML12326A713 (23)

Text

NEXT; POINT BEACH November 20,2012 NRC 2012-0100 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant, Units 1 and 2 Docket 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 NextEra Energy Point Beach, LLC Response to 10 CFR 50.54(f) Request for lnformation Regardinn Near-Term Task Force Recommendation 2.3, Flooding

References:

(I) NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, Request for lnformation Pursuant to Title 10 of the Code of Federal Regulations 50.540 Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of lnsights from the Fukushima Dai-lchi Accident (MLI 2056A046)

(2) NextEra Energy Point Beach, LLC letter to NRC, dated June 8, 2012, NextEra Energy Point Beach, LLC's Response to NRC Request for lnformation Pursuant to 10 CFR 50.540 Regarding Recommendations 2.1 and 2.3 of the Near-Term Task Force Review of lnsights from the Fukushima Dai-lchi Accident (MLI 2163A250)

(3) NRC letter to Nuclear Energy Institute, dated May 31, 2012, Endorsement of Nuclear Energy lnstitute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features,"

(ML12144A142)

On March 12, 2012, the NRC staff issued Reference (I), requesting information pursuant to 10 CFR 50.54(f). Enclosure 4 of Reference (1) contains specific Requested Actions and Requested lnformation associated with Recommendation 2.3 for Flooding. Requested lnformation Item 2 of Reference (I), Enclosure 4, requested addressees conduct a flooding walkdown and submit a final report which addressed various requirements detailed in the item.

Reference (I), Enclosure 4 required addressees submit a final flooding walkdown report within 180 days of the NRC's endorsement of the flooding walkdown procedure.

Via Reference (2), NextEra Energy Point Beach, LLC (NextEra) confirmed it will use the NRC-endorsedflooding walkdown procedure Nuclear Energy Institute (NEI) 12-07, Guideline for Performing Verification Walkdowns of Plant Flood Protection Features, Revision 0, and submit a report by November 27,2012, which corresponds to 180 days after the NRC endorsed the NEI flooding walkdown guidance (Reference 3).

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, W1 54241

Document Control Desk Page 2 provides Flooding Walkdown Report NEE05-PR-001, Revision 0, which was prepared in accordance with the guidance of NEI 12-01, Revision 0, and provides the requested flooding walkdown information. This submittal completes the NextEra response to the Requested Information of Reference (I), Enclosure 4.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

If you have any questions please contact Mr. Michael Millen, Licensing Manager, at 9201755-7845, I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 20,2012.

Very truly yours, NextEra Energy Point Beach, LLC Site Vice President Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Director, Office of Nuclear Reactor Regulation, USNRC

ENCLOSURE 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 NEXTERA ENERGY POINT BEACH, LLC RESPONSE TO 10 CFR 50.54(F)

REQUEST FOR INFORMATION REGARDING NEAR-TERM TASK FORCE RECOMMENDATION 2.3, FLOODING FLOODING WALKDOWN REPORT NEE05-PR-001 REVISION 0 20 pages follow

FLOODING WALKDOWN REPORT NEE05-PR-001, Rev 0 IN RESPONSE TO THE 50.54(f) INFORMATION REQUEST REGARDING NEAR-TERM TASK FORCE RECOMMENDATION 2.3: FLOODING for the Point Beach Nilclear Plant 6610 Nuclear Rd, 'IWoRivers, WI 54241 Facility Operating License No. DPR-24 and DPR-27 NRC Docket No. 50-266 and 50301 NextErn Energy Resources 700 Universe Boulevard Juno B e ~ c lFL

~ , 33408 Prepared by:

ENERCON Services, Inc.

2056 Wcsti~tgsAvenue, Suite 140 N~perville,IL 60563

NTTF Recommendation2.3 (Walkdowns): Flooding NexlEra Energy Resources PBNP .

Novetr~ber14. 20 12 NEOOS-PR-001. Revision0 Contell tar I . EXECUTIVE

SUMMARY

......................................................................... . . .....................................2 2 . PURPOSE ............................................................................................................................................... 3 a . Background ........................................................................................................................................ 3 b . Site Description ..................................... .................................................................................... . 4

3. ME'l'HODOLOaY ................................................................................................................................. $4

4. REQUESTED INFORMATION.............................................................................................................. 4

n. Requested l~ifontiatio~i ltetn 2(a) - Desig~iBasis Flood Hazards ............................ .,..........................4

b. Roq~lostedItiformatiot~Itetn 2(b) - CLB Protection a~rdMitigatbr Peattr~res.............................. . - 5

c. Requested Infor~i~ation Item 2(c) - Flood Wnrnitig Systerns ........................................................... 7

d. Requested l~lfonnationltern 2(d) - Flood Protectio~iSystemlBarrier Effective~iess............................. 7

e. Requested lnfonnation Item 2(e) - I~nplotne~~tatio~~ o f Walkdown P~uoess......................................,.. I0

f. Requested I~~for~nation ite~ir2(f) - Findings and Corrective Actions TakenIPlanaed ...................... II

g. Requested lnforrnntiorr I t c ~ 2(g) n - Cliff-Edge Effects ntrd Avnilnble Pliysical Margin.......... 14

11. Requested l~iforrnntio~i Item 2(B) - PIaat~edMewly-lnstnlled Flood P~utectiorE~ilratice~ne~rts .. 14 5 . CONCLUSIONS...................................................................................................................................... I4

6. REFERENCES ..................... .............................................................................................................16 7 . ATTACHMENTS ................................................................................................................................1 7 Page 1 of 19

NTTF Reco~nmendrtio~r 2.3 (Walkdowns): Flooding

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NextEm Energy Resources PBNP Nove~nbcr14,2012 NEEOS-PR-001, Revision 0 1, EXECUTIVE

SUMMARY

This report wvas developed to provide inforniatio~~ requested by the United States Nuclear Regulatory Co~nmission(NRC) pul*saant to Title 10 of tlte Code of Federal Regulations, Section 50.54 (0[Ref. 21 011 MRICI 12,2012 for the Point Bemcli Nuclear Plant (PBNP). hr rsesponseto tlie NRC request, NexlEra Energy Resources pefiorrnedwalkdow~lsto verify thnt p h ~features t credited in the n~rrentlice~~sing basis (CLB) for protectio~iand nritigatio~rfir0111external flood events are available, krctioonl, nnd properly maintained. The walkdowns were perfo~~~ned to vorify Illat pennane~Jstructures, systetns, compone~~ts (SSCs), portable flood

~llitigationequipmest, and the procedures needed to install m d or operate tl~eniduring a flood are acceptable and capable of perfor~ni~rg their design fi~nction8s credited in the CLB.

Walkdowtls were perforrricd in accorda~~ce with NEl 12-07 (Rev. 0-A), "Guidelines fbr Perfornling Verification of Plant Plood Protection Features", dated May, 2012 [Ref. I].Tlris documeat was elldomed by the NRC 011May 31, 2012. PBNP Units I & 2 co~lfigr~ration and proccdures were compared to tlre flood protection featt~rescredited in tlre current lice~rsingbasis doci~~nents for exterirrl flooding everts.

Site-specific feahlres creclited for protection r ~ l lnitigntio~i d rtgalnst extemrl flooding events were identifled and evaluated. A sirtnlnrrly of the PBNP CLB, flood protection features and the rest~ltsof tile inspections is provided below.

Current Lice~lsinaBasis There are two design basis floods for PBNP: a probable ~ n n x i ~ nwave t ~ ~ nrilrr-up from Lake Miclrignn and Ico~nbi~led p~vbabletnaxinrt~~n rai~ifallmd snowmelt. The probable nrrxi~nitmwave rua-up rerrches +8,42 R relative to tile plant's refererlce zero elevatiotl of 580,2 A Idet.~utioarlOrert Lakes Datum 1955 (IGLD) and has no dcfirred duratio~r.The second design basis flood conrbines a probable n~axi~nun~ six-hot~rrminfnll wvill~the probable n~aximonrsnow~neltill the seco~ldlralf of Maroll to genernle 1400 acre-ft of rusoff. This flood also llas no defined dartition, Vie floods are not assi~medto occur conourrently.

Flood Protectio~iFeatu~ws Tile PBNP CLB does not state speaific plant co~~figurntlons during a flood cvent or the darn ti or^ of tile flood, The flood nitigntion syste~nsfunction lndepe~rdentlyof plnnt configuratio~i.

For tllo wave rilrr-up flood, tlte site provides temporary coircmte Jarsey barriers on the no1Z11and south sides of tlro Citculati~rgWater Y~~tnp House (CWPH) Il~atprovide protectiorr up to i-9 ft. A site procedure pm~nptsthe installationof the barriers based on tlro tusesl~ltsof a tno~rtlrlyclieck of the lake leval. For the possible water thnt could splash over or tl~ro~~glr the barriers, there are storm drains a~oundthe CWPH, n~rdthe lowvesl critical eqaipn~eatin tlre CWPH is ~iror~~rted at 4-9ft. The Ileigl~tof the critical equip~nontdocs not vary with respect to its operating mode; therefore tlla flood ~nitigatiori systetn re~nainsindependeritof plant corfigt~ratio~r.

Tile cornbi~~ccl rail1 rind ssowmell flood is lla~ldledby a co~nbinatiorrof the site's natural draiange, installed storm drain systeln ia the plant yard, rind various drainnp ditcl~esand culverts RI~IIII~ [lie site. The drainnge systeln provides a flow path to Lake Micl~ign~~ for the ru~roff generalad.

Page 2 of 19

NTTI: Recoml~ierrdatloll 2.3 (Walkdowes): Flooding

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NextEra Energy Resources PBNP November 14,2012 NEEOJ-PR-00I,Revision0 Inspection R e s l ~ k Tlre colrcrctejersey barriers inshllcd at the CWPH did not txterrd far enol~glrto the ~ro~tlr atid soullr to provide a barrier up to +9 R. Also due to ulrever ground and featt~res011tlre barriers, sotire gaps existed In tlre ilrslalled cotrfigt~ratios.Work requests were writterr to add dditional barriers nnd pour n co~rcretepad to correct these issi~es.

Tlre site procedure for the installation o f tlre concrelejersey barriers was fot~~rd to be deficient. It did not idelitify that tlre barriers were being i~rstalledin a B.5.b stagir~gRIWR a11d also did not provide perlinel~tisformatio~rfor the support equipmelit tlral wvotlld be reeded, A pracedare clra~lgewill be generated to address these issttos as well as i~rstiti~te n regular check on tlre stagilrg coliditiolr o f the barriers, Tlre corrtrol prnel and bnttery for the diesel fire pt~~mp it1 tlre CWPH webe below t9 It. The control panel, wlriclr also has cimuitry for the battery, contains electrical conrponenls at I-8.375 fl wltich is below tlre flood lreiglrt o f 4-8.42 It, Tlre FSAR [Ref. 81 will be i~pdaledto credit i~rstnlledfloor dantpers for external ns well as internal flooding. Tlris will reduce the flood height witlrilr tlre CWPH to +7.75 R.

~ rtlre platrt yard near the NW corrler o f the Unit 2 Faqade was covered with n nietal A catch b ~ s i in plate. This plato was rclnoved, and p~acedttralco~rtmlsto preve~rtthis conditiotr b l n reocct~rri~rg ale beit~g evaluated.

Tire FSAR states that PBNP has liortll and west ilrtercdptor ditcllas outside of tlre plant yard to divert rtrnoff to the lake. The west side irrterceptorditclr rrllrs bctweea the plant yard and switchynrd, but is obsltr~ctedby trewly i~tstalledequiprne~rtn ~ i dis not c o ~ i t i ~ ~ ~The o u slrortlr

. sido ditclr was not found.

The FSAR will be updated to replace tlre nortber~linterceptor ditch witlr the storm drain systern, and A re-evrluationo f the drailrage near the wveslem interceptor ditch will be perfor~ned.

a There were several i~rstancesof inadequate dl.~bagediblr ~nairrte~rance i~icluditigpmrlially obstrilcted ctllverts atid aolne cases o f draillage ditches l~eedillgto be cleared out or re-gmded, Tlra mmi~ltetrat~ce program rlrd supporting doci~n~eaiatio~r will be i~pdatedto accrlrately reflect the d~ainngeditch configuratioa on site nnd elrstlro its filnctloaality, a~ldn work request wvns geaented to clean out the ditohes and culverts w1re1.ethe inspection criteri~were not met.

PBNP is foilnd to be in co~irplia~ice with its flood pmteclion requirements per the ctrrrent site liceasi~rgbasis rlpoli colnpletiolr of correclive nclio~isfor the above cleficieaciesdiscussed fi~rtlreri ~section r 4f,

2. PURPOSE 111resporrsc to tlre ~~uclenr file1 dn~nagent tllo R~kuslrisin-Dni-icl~i power plant due to the March 11, 201 1 carllrqunke and st~bseqileltttst~trm~tri, the NRC established tlre Near Terrn Task Force (NTTF) to coridt~ctn systanntic view o f NRC processes a ~ l dregulaliorrs, ~ n to d nrake recoe~nrontlatiotlsto tlre Cotnmission to cInriQ ntid stlelrgtlre~r1110 ~vgtllnto~y frmmewvork for protection against nati~ralplrenorne~~a. On Ma~.cIr 12, 2012, the NRC Issued a request for informrtios pttrsl~nntto Title 10 o f the Curlo of Fede~wlRegrrloflorts, Section 50.54 (f) [Ref. 21, 111 Eliclosc~~s 4 o f Itefere~rce2, tlre NRC requested that licensees 'perfonn flood prultecliolr wnlkdowns usitrg AI NRC-etrdorsd wrlkdown ~rietliodologyto identi@ nnd nddress platrt-specific degraded, rrnrco~rfor~ning, or t~nalrnlyzedconditio~rsnlrd cliff-edge eflects tlrrotlglr tho corrective nctiolr prograln (CAP) and ver113) the Page 3 of 19

NTTI: Reco~ti~iieridntion

2.3 (Walkdowns)

Floodilig

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NextSm Energy Resources PBNP Nove~iiber14,2012 NEEObPR-001, Revisio~i0 deqi~mcyo f ~nonitoririgand ~naintenanceprocedures.' Tlre floodi~rgwalkdowns limve been co~npletedand tlie resr~ltsare described in this report.

b, Site Dcsc~*lption Point Beacli Units I and 2 are locmtcd ill east-central Wisco~lsiaon the west sliore o f Lake Miclrigan, apl~roxl~~iatoly 30 ~nilesSE o f Greet) Bay. Tlie site i s located in the NE colatiero f Manito\voc Cou~lty, Wisco~~sin, and coniprises approxinintely 1260 acres, Vie ground surface at the site i s gently ~ullingto flat with elevations varying fro1115 to 60 A above the lneall level o f Lake Micliigmn. Tlie plant reference 0.00 A elevation is 580.2 ft IGLD. In tlie area a w i ~ ~tlie r d platit, tlie land sr~rfaceeither slopes fro111 west to erst town~ulsthe lake or to the nor.tIi and soiltli to divert ri~noflawvayfiwn (lie plant. A Iiigh point just to tlie west o f tlie switcliyard preve~itsany ri~noffinland o f tlie plnnt froa affecti~igplaat opelations. [Ref. 81 In relatio~ito the lake, a mqjority o f the plnnt gvoilnds are located at tlie 26 A elevntion and are riot tlire~tened by [lie wave rt111-upflood o f +8.42 R described in detail ill Sectloll 48, The only exceptio~ito this is the area near tlie CWPH wliere tlie plant draws its circr~lntingwater frola tke lake and llns a g n ~ a floor d elevation o f 7 R,011the east side o f llie plant, the service roads slope down fro111the 26 A elevation to elevations around 7 fi near die CWPH. h i 1 tlie CWPN,tlie stnlctures next closest to tlie lake nlv the Units 1 and 2 Ti~rbine Buildings (TB) with tlie Control Bilildi~ig(CB) located it1 betrveen tlre TBs. The ground floor elevatio~iof the CB a~idTBs is 8 It, and they 81.eabout 100 ft to tlie west o f the CWPH.

3. METHODOLOGY The \valkdow~iswere performed in ncco~drncewitli NEI 12-07 (Rev. 0-A), "Guidelines for Performing Verification o f Plnnt Flood P~+otectioa Features," dated M&y, 2012 [Ref. I].Tlris doculnent was endorsed by the NRC os May 31,2012.

Tlie isfot.nimtio~rrequested in Reference 2, Enclos~~re 4, under yara&raldi 2 o f the 'Requested Infonilation' sectia\, is provided below, Tlie contellts o f eacli item werc devoloped in accordance wit11 Reference I, Appendix D.

a. Rcql~cstcdI~~fonnrtion -

Itclrr 2(n) Design Bnsis Flood Hnarrcls Describe tlie desig bnsis flood liazmrd levelfs) for nll flood-cnusil~~neclunisrs.iliclr~dinnu~ui~~idwateg

iunvess, Tliere are two different design basis external flooding I~amrdsconsidered at PBNP. Tlre first is llie flood level tes~ltingfrom a probable ~uaxi~iiurn wvnve ri11i-upfium Lake Miclilgnn, wid tlie other is a combi~ution o f a p~ubnble~iiaxirnilrns~rownieltwitli a probable tiiaxilnl~lnp~~ocipitmtiotr.

Tlie deterraiaatio~ro f tile flood level for tlie probable ~liaxinit~rl~ wvnve run-11pco~iservalivelycotnbines the liisto~*icnlliigll lake level of +I.7 A, a ~liaxi~nr~rii deep water wave nln-up on n verticnl surface o f I-6.55ft, and H wind tide settlp o f SO. 17 n for 8 total wave run-up of I-8.42f l nbove llle plfitrt's referwrce 0.00 ft elevatlorr o f 580.2 A IOLD. Tlie origi~lrlanalysis o f tlie deep water wave run-~IOwvns perfornied by Sargent & Lr~ndyin Referonce 5. This ntulysis starts by ~alct~lrnti~ig tlie deep wvater wclve heights based t~pondata taken fiwn Reference 4, Howvover, the very sl~allowslope o f tlie bcacli out into llie lake at PBNP (Ion 100 for the first 1000 fl into the lake and I on 200 for tlie next 4000 fl) causes tliose lnrger deep water waves to break offsllo~e.'rile ~naxiniu~n wave run-up resr~ltsfium esti~nmtiagthe prubable maximum secondary wave that wvould reform nAer tlie deep wvater wave llas broken and tlie ~.esultingrial-up on the bench. Tlie lin~ititigcase Page 4 of 19

N'ITF Recon~~nendntion 2,3 (Walkdowns): Flooding NextEra Energy Resources - PBNP Noventber 14,2012 NBE05-PR-001, Revision 0 for PBNP is +6,55 ft of run-up on a vertical structi~rewith a period of 8 seconds. In addition lo this wave ru~t-up, wind tide setup is considered for rlre conservative co~lditiorisof a concun.ent sustaiued easterly wind of 40 rnpl~over a fetch lengtlr of 70 r~iilesand average water depth of 465 ft, which produces at1 additional 4-0.17 A, Tlierefore, tlre combination of the run-up, wind tide setup, anti previously recorded 11igh lake level of 4-1 .7 ft produces a design basis flood level of +8.42 ft or approxi~nately8' 5". [Ref. 51 The other design basis external flood threat nt PBNP is a large snowlnelt in tile spring conlbined wit11 sl~stainedlreavy winfalls to produce a total of 1400 aci-e-ft of ru~loffon Llie site. This analysis was performed in Referetrce 7. The report states that the atice in 50 years snowrnelt potential (defined as tlre water content of slrow in late March) at the site is 360 acre-fl in each of tlie two drainage areas on site. For the once in 50 years six-hour rainfall expected 011 site, the report gives a value of 31 7 acre-ft in each drainage area.

Therefore, the design basis flood threat fro111a cornbi~iedsnow~rleltand six-I10ur rainfall is con~crvatively given as 1400 acre-A of runoff, Tliere is 110n~el~tion of an associated flood l~eiglltfor this desigtl basis flood, Other flood causing meclrunisms were considered wlrer~cleterrni~litigthe maximulu flood llrreat ftom tile lake, but were uot foiurd to be tlie botlrldirig cases. Tlie maximum storm surge level was calculated based upon Reference 6.Tlre aualysis arrived at a water rise of 1-4.14 R asst~~ning the passage of a squall line with a pressure jump of 8 ~nillibarsand a speed of ~rrove~ne~lt of 65 knots with n shoali~igfnctor of 3.5. The analysis also states that an additional I ft could be added if w i ~ ~velocities tl arc grentcr tllan or equal to 70 knots.

Rogardless, the stonn surge's maxilnu~nwater rise of +5.14 A is bounded by the watcr rise of +6,72 ft res~tltingfrom the wave actioa.

Seiclies were also considered in tlie vici~lityof PBNP. Most of the data reviewed collcerned seicl~es011 the southern elid of Lake Micliigan near Chicago. These data itldicated that a record seiclre occurred in 1954 that produced n rise of 2-4 ft ia Clricago harbors. However; this event is not representative of tlle conditions at PBNP because Cllicago is subject to the seiolie's reflection off of the south end of tlie lake, whereas PBNP is located on an open shoreline and is not susceptible to this reflection, Therefore, it was coocluded thnt n seiche 1-2 ft in atnplitude would bound any seiclie ueae PBNP,a~rdtlle deep watel. wave nin-up is still the bounding flood threat from Lake Michigan at PBNP. It slioi~ldbe noted that a search of records did not discover ally evidence of a coincident occuwetice of a major seiclie wit11 a major high wave occurrence

[Ref. 81.

Groundwater ingress is not considered as a desig~lbasis flooding event due to the high clay conter~tof the soil at PBNP, which inhibits percolation and drainage to L ~ k Miehignn e [Ref, 8).

b. Requested Information Item 2(b) - CLB Protection at~rlMitigation Fcatures Describe !~rotectionand niitigatio~ifeatures that are consiclered in the licensing basis evaluation to protect against external ingress of water i~itoSSCs impotta~ltto safetyl T l ~ eexternal flood licensing basis at PBNP provides for the rlritigntion of design bnsis floods tlrat keeps external ingress of water f'rorn occt~rri~~g in rooms with strtlclures, systems, aud cotnpollents (SSCs) important to safety with the exception of possible water intrt~sionto the service and fire water pump roolns in the CWPH during wave run-up event. The CLB does not specify wllicll plant configt.ations arc considered. T l ~ eflood protectioa systems considered in the walkdown also irrdepe~rde~itof the plant configt~ratio~r.

'Tire first situation to consider is tlie design basis rnaxi~nr~nlprobable wave run-LIPof 4-8-42 ft from Lake Michigan. Tlrc CLB calls for tile installatioa of temporary concrete jersey barriers to provide a flooding barrier at the CWPH tlrat woi~ldprotect equipment i n tlie CWPH,TBs, and CB fronl the flood waters up to

+9 ft. These ba~.rie~~s are installed under a site procedure, which planipts tlie irrstallatioli if a ntontlily clieck of tlie L ~ k eMiclriga~~ water level indicates a vali~eof 580.7 fi lGLD or Irigtler. The it~stallationof tlrese barriers is a~iticipatolyand dependent on the u~idisturbedlake level. Since lake level clialige is a slow process, there Page 5 of 19

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NTTF Reconrn~eridatiorr2.3 (Wnlkdowns): Flooding

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NextE~aEnergy Resoiirces PBNP November 14'20 12 NBEOS-PR-00 I, RcvbioI~0 a1.e miany days before tlie barriers must be in place. TJle actual itistallation titne is rni~chless tliall the required tirne, tlremfore it is not credible tlrat tllere will be itrclernent weather that will prevent tlre installation of tlis barriers wilhin tlie required titne, Tlie barriers are illstalled on both the nortl~and south sides of the CWPH forebay strilcture as indicated willlin the procedure ia two rows of three barriers each. This moans that 12 barriers are installed aad extend approxinlately 37.5 ft to the north a11d soutli of the CWPH. Tlie CWPH is also protected from direct impact of tlie wave rcm-up by the three foot thick reinforced concrete walls of the forebay strt~cturewliicl~rise to lleights of +15,4 ft parallel to the shore (fiont) and +I2 ft perpe~~dict~lar to the shore. ,

Since some water is likely to spill over or th~uuglithe jersey barrielms,the storm drains around the CWPH are also credited to provide a relief flow ~ R U Ifor ally water that rntty begin to collect behind tlie barriers by dninirig it to the lake. Sirlce tlre water that collects belrind the barriers could cl~alleagethe doors iuto the CWPH, the CLB further clarifies that the lowest pieces of essential equipment in the CWPH are the service water and fire water purnp motors that are tnot~ntedat t9 ft. The fire pumps in the CWPH are designated as augmented quality equipment acid are not safety-related. For this inspection, support equipment necessnry for the operation of tltcse pump rnoton wns also considered, i~loluditigtlie co~~trol panels for both fire punips as well as the battery for the diesel fire pump. It can also be rroted tlrat while not yet explicitly credited for external flooding situations, there are internal flood relief dampers in the floor of the CWPH that prevent water fium building up to ce~tainl~eiglitsinsitle tire pump lioi~seas a part of the internal floodirtg program.

The CLB does not define a duration for tl~isdeslgr~basis flood, only 1\18probable maximum height of the wave run-itp.

The otl~erdesign basis situation that is considered in tlre CLB is the tnitigatioti of tlie combined rain and saowmelt flood that generates 1400 acreft of runoff. The CLB for this floodi~~g situation in Reference 8 states that the nrtrlrml site dniaage is "adequate to relnove this a~nortlltof water," and a storm drain system as well as drainage interceptor ditclrcs are provided in addition to the natural drainage.

Per Section 2.2 "Topograpliy" of Reference 8, the general site topograplly is credited with diverting surface runoff away from the plant. The wording in Section 2.2 is used as tla ~nairibasis for the CLB that the ground slrould slope either generally from west to east towards the lake or to the north and soutlr to drain 8way from the plant.

Tlie credited stolm drain systen~handles runoff within the plant protected a m . The systetn consists of a inairi drain line on both tlre north and south side of the plant and two s11111Ier drain lines that (Iraia to the north and soutll of tlle CWPH.The drain lines consist of open catcll basins and mdergroa~dpiping that enlpty out onto outfalls at the beaclr, Finally, there are also several drainage ditches around the site that provide relief paths for the flood wrters to flow away from the plant. Section 2.5 of Reference 8 states, "An interceptor ditch drainiug to the lake is provided outside the yard on the north and west sides and on the south slde wliere the orlginal ground elevation is above the plant yard!' In addition to tl~esamain ditches, a small drainage ditch to the aortll of tlie switcliyard and B drainage ditch running along the north plant access road exist and drain dow~iinto the northern storm drain line. Tbere are also several ditches along the service roads on the west side of the plant protected alea that drain either to tlie storm drain system or to one of the rnain drninage ditches.

The CLB does not define ti duratioa for this flood and only provides that the amoulrt of r~lnofffronlrain was calc~~lrted based on the once in 50 years six-Lotrr rainfall. It is also tlnclear what lreigl~tthe flood waters wot~ldreach because only a give11volume of runoff was quoted for this design basis flood.

In ~ccor(1ancewith PAQ-007 [Ref. 101, exterior walls tllat were subject to groundwater intrt~sio~l were it~clildedas a part of the walkdown scope even dougl~they are not credited external flood features within the PBNP CLB. Data on the groundwater table deptli taken as a pnrt of the sib's Oroundwater Monitoring Page 6 of 19

NTTF Recolnn~endntion2.3 (Walkdowns): Floodi~~g NextEra Energy Resources - PBNP Novenlbcr 14,2012 NEEOS-PR-001, Revision 0 Program was used to detelrliine the scope of the walls to be inspected. The water deptlis were taken on the west side of the p l a ~ ~illt !lie Unit 1 aiid 2 Facades on the 6.5 A elevntion. Tlie data intlicated tliat tlie g~uuadwaterdeptlis fell below the 6.5 fi level by several feet except near the westeni walls. Conlbi~ii~ig this with the information hiat the groi~~idwater lias a gradient towards the enst niearis tl~atthe groundwater table is below tlie platit's 8 ft grouncl floor elevation. Therefore, only the walls on the west side of the facades at the 6,s ft level aud tlie Primary Aoxilinry Building (PAB) at the 8 A level, tlie tendon galleries under both uuits' co~ltaiu~nents, and the external walls of tile Residual I-feat Re~noval(RHR) areas on the -5 R and -19 fi elevntions need to be iaspected.

c. Requested Information Item 2(c) - Flood Warning Systems Describe RIIV war~rinesvsteliis to detect tlie presence of water i ~rooms i i~~iporta~~l to safety.

The primaiy flood warning system employed at the site for exterlial flood protection is the periodic check, wliicl~protnpts a tno~itlllycheck 011 tlie level of Lake Michigall. If tlie lake level is greater that1 or equal to 580.7 f (2.5 A above nornitlal lake level), t l ~ a !lie ~ i tempora~ybarriers that pl.otect the CWPH, TBs, and CB are installed witbin tlic next tllrcc weeks and are to stay installed until the next ~ ~ i o ~ ~check t l i l yfalls below the 580.7 I? threshold.

No water level ~nonitoringsystems internnl to tlie plant arc credited for ~nitigntionof an external flood. It sl~ol~ld be noted tliat there are high water level switclles in all four RHR puslp cubicles 011 tlie -I9 ft elevation of !lie PAB that iniliste an alarm response procedure for draining the pump cubicles.

(I. Requested Information Item 2(d) - Flood Protection Systcm/Barrier Effectivaness Disci~ssthe effective~iessof flood protection svstelns wid exterior. ircorpornted. and temporal?l flood barriers. Discuss how tliese s~stemsa~idbarriers were evaluated usins. the acceptallce criteria developed as part of Requested l~rfor~natio~~ Item l .I1 [in Etlclosure 4 of the March 12.2012,50.54(f'l letter1 Vis~~al inspectio~lsof !lie exter~lnlflood protection features identified it1 !lie PBNP CLB were perforaied with tlie objective of comparing the observed conditio~~ of the feature to tlie accepta~wecriteria as defined in Secliorl 6 of NEl 12-07. This approach provided the b ~ s i sfor assessing !lie feature's ability to perfor111its intended exter~lal flood protection f ~ ~ ~ ~ cand t i o nidentifyiag co~lditior~s warrantitig eritry illlo the CAP.

Observations entered into the CAP and dispositioncd as deficicrit arc discussed in Sectio114fof this report.

With the exceptio~iof features entered into the CAP and deerned deticielit as disci~ssedin section 4f, the walkdowrls fouad lliat the flood protectio~tfeatures meel their applicable acceptnnce criteria.

Tlie following sectiotis detail wlietlier or not tlre acccptaricc critcria wvorc net for the features inspected, and a disc~~ssio~l of the alitigatioti system's effcctivencss:

Teauorarv Coricrete Jersey Barriels l~lstallalior~

Tlie tempornly concrete jersey barriers were itistnlled on the 11ortl1and soutli sides of tlic CWPH to ensure that they were available, functionnl, and iniplementoblc to provide protectioa up to 4-9 ft as stated it) the PBNP CLB. Tlie reasonable si~nulationfor installillg the barriers met the acceptance criteria for s~~ccessfi~lly i~lstalli~ig tlie jersey barriers witlii~itliree weeks of tlre lake level determination per the site procedure for iristallatio~land witti llecessnly support equipnient readily nvailable, plavi~igthe feasibility of !Ire operator actions required. I-lowever, the procedure did not identify that the barriers were installed in B.5.b staging areas on either side of the CWPH, so it was deterrninecl that it was not able to be conlpleted ns writter. The associated corrective actions for the i~~stallation procedure are described in sectlo114f.

The co~~figumtion of the jcrscy barriers was visl~allyinspected after inslallntion, Tlie barriers did not rnect tlie acceptance criteria for provitling a barrier to +9 ft against the wave action because the

NTTI: Reco~iime~~dntion 2.3 (Walkdowns): Flooding NextEn Energy Resources - PBNP November 14,2012 NEE05-PR-00 1, Revision 0 jersey barriers did not extend far enoi~ghto tlie nortl~and soi~tliwhere tlie site grade reaches +9 ft.

Tlie barriers also sat on uneves groitrid in solne areas cai~siriguliacceptable gaps uudernenth the barriers to forni. Tlie configoration of the actt~albarrier systcln inspccted upon installation was considered to be ineffective, pending the corrective actions to bc taken detailed ill section 4f.

CWPH Structure and Critical Eai~ipnient Tlie forebny structure of tlie CWPH is credited for protecting tlic CWPH fi.0111 tlie probnble

~naximun~ wave n~s-np.T l ~ cexternal forebay wall parallel to tlie lake was inspected to ensure tliat the barrier liatl adequate Iieigbt, surface cracking was minor, aud no obvious signs of structural degradation were present. Tlie structute niet these acceptance criterin nnd was deemed an effective barrier to the expected wave action.

Tlie CLB also credits the l~eiglltof tlie lowcst critical equipment in tlic CWPH, thc fire and service water pump motors, as -i-9 ft. The lieigllts of tliese no tors and tllcir associated si~ppo~t equipnient were visi~allyinspected to verify the credited heiglit, All of the pump motors were mounted at least

+9 fl, b d tlie control panel and battery for tlie diesel fire pump did 11ot~neettlie acceptance criteria. It slioi~ldbe noted tllnt tlie fire puolps ie tlie CWPH are considered ailg~nentedqi~alitypicccs of eqt~ip~ilcnt and are not safety-relnted. Tlie corrective action for ibis situation is detailed in section 4E Storm Dl-ain S ~ s t e ~ n Tlie storrn drain system on the site is credited for mitigating boll1 the probable ninxitiium wave run-up (otily tlie drains around tlic CWPH) and tlie probable tnaxi~numco~iibinedrainfall and snow~nelt(all storrn drains). The acceptance criteria used for tlre inspection was that all tlrains were illstalled per design, cleaned, and ~~nobstri~cted. Tlie storrn drain systeni is n~ai~itainedby a preventative maintenauce (PM) program perfor~iiedonce every six ~nontlis.A PM is perfor~nedfor the CWPH drains that cleans nnd tests tlic storm drains, and another PM inspects a~ldcleans the re~nainderof thc stornl drain systeni. Tlie PM program was decnied to meet the frtnctional requirements of tllese acceptance criteria, a ~ flle ~ dstor111drains are considered to be achieving their flood protection fi~nction.In addition to the credited PM program established for tlie storrn drains, an extensive irispectioti of the stonn drniii system was condi~ctedit1 June of 2010 by AECOM [Ref. 1 I],

which also concluded that "nonc of the structures in the storm drain systeril appeared to shown any significant deterioration," Pipe seg~nentswere generally in good condition with snlall atnounts of gravel or dirt on tlie botlo~nof the pipes, wllicll was determined to riot sigriifica~~tly restrict the capnoity of tile pipe. During A visual inspectio~ito ensirre no unexpected conditions existed, one storni (Irain was found to be covered with a ~netnlplate, and tlie corrective action associated with that is detailed in section 4f.

Site Touogrnpli~

Tile nnturnl drainage of tlie site is credited for providing a flow path for tlie generated runoff during tlie probable niaxinit~~ii rain and s~iown~elt. Tlie acceptance criteria developed were based upon Section 2.2 of the FSAR [Ref. 81, wliicll st~tetlthat tlie topography of tlie site either provided n gladient fro111west to east towards tlie lake or towards tlio north and south nwny fi-o~ntlie phit. The addition of paveillent to tlie site wns not considered to inc~aasetlie i~npeniicabilityof tlie ground becnusc tlic site all-eady has a higli clay contenl preventing percolntion as stated in Iteference 8. A visual inspection was conducted a~.ot~nd tlie site area to verify this, and ao cliangcs in land use or topograpliy were uoted tliat caused ndvelse ilnpact to drainage. On tlie nortli side, the nddition of tlie Diesel Generntor Building (DGB)nntl Nortll Service Building llave built up sonle areas closcr to tlie lake eli~ninatingthe west to east flow path, but Illis cllange is supplemented by the storrn drain system, wliicll drains out tlie potential areas of pontling created by tliese cl~nrigesand deemed to be Page 8 of 19

N7TF Recornlaendation 2.3 (Walkdowns): Flooding

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NextEra Energy Resources PBNP November 14,20 12 NEBO5-PR-001, Revision 0 acceptable. A similar siti~ationexists near the CWPH whe~esecerity llreasures installed created a possible Irindraace for the flow path towards the lake, but tlie possible area of pouding is adequately drai~ledby the CWPH storm drains. Otherwise, tlie additional buildings and clianged land use were not found to cause adverse impacts to the site's drainage.

Drrrinaae Ditches The CLB credits interceptor ditches 011the north, south, and west sides of tlte plant that drain to the lake for providing a flow path for the gerlerated runoff. The acceptance criteria developed for these ditches included confirming their configuration as described in the FSAR [Rec 81 as well as tlre lack of obstructio~isin the ditcli patlrways and culve~ts.The ~011thdrainage ditch was foulid config\~redas described in Reference 8. Tlre westerr] irrterceptor ditch was fotr~idto run between the plant yard and switchyard, but tlie additiotl of new plant equipment created unaccept~bleobstructio~rsin the drainage pathways, and it was not a continuous ditcli. Tlie aortl~erninterceplor ditch was not found doring walkdowns, and tlre ritnoff generated oti the nortll side of the plant area is handled by the storm drain system illstead. Tlre corrective actions associated wit11 the deficiencies for the interceptor ditches on tlre t~orlliand west sides ale detailed in section 4f.

In additloti to the issues with tlie tiortlt and west interceptor ditches, there were several at-ersaround the site wltere drainage ditches were not found to be maintained adequately. This includes three drainage culverts on tlie south side of the site that were either partially obstructed or sitb~nergedin pollding. Another dr~illagec111ve1Tnear the north security gate was also found to be obstriwted. Some drainage ditcl~eslrad buildups of dirt and silt that indicated poor drttitiage flow arrd required upkeep or possible regrading. This pri~narilyapplied to the draillnge paths along tlre north and south sides of the switchyard. The corrective actions associated wit11 these observations are detailed in section 4f.

Tlie subgrade walls at PBNP are not credited feati~res,but wem inspected in accorda~~ce wit11 PAQ-007 [Ref. 101. The groi~ndwatertable atid subgrade walls are inspected in the PBNP Facilities Monitoring Program (FMP),which contains acceptance criteria for i~upectionas stringent as those used in Reference 1 and I0 CFR 50.65. This includes co~lfirrni~lg that there are no unacceptable signs of water seepage tllrotlgli the walls, and surface cracking is less than 0.04 in, Therefore, walls already being tracked adequately by the FMP were vist~allyscanned only for ut~expectedconditions not previously documented witllin the PMP.

Units 1 nnd 2 Facades Tlie subgrade walls and floors in the Units I R I I ~2 Facades were confirmed to be stn~cturally sound with no t~nexpectedcracking or water seepage. However, three arens we^: identified where diict banks penetr~titigthe walls have partially or fitlly degraded senls by design with open drai~lpans 10 prevent cable submersion. These sliowed signs of water scepage and are poi~rtsof prior water intrusion into the facades. However, this is not considered to be a violatio~lof the CLB because tlre fapade walls do not protect safety-related equipment.

U~rits1 arld 2 Tendon Galleries The walls of the Units I and 2 Tendon Galleries li~venot been ttncked by the PMP, and during Lspection of tliese walls, several areas of water seepage were found. Tlris observation was noted in the PBNP CAP, wliicl~determined that tlie leakage rate t1)rougll tlre walls is not errougk to cl~allengeany safety related eqt~ipment.1Yle tendon gallery walls lyill be tracked in the FMP begin~ringwith tlie Fall 2012 Unit 2 r~fi~eling outage.

Page 9 of 19

NTTF Recom~ncudation2.3 (Walkdowus): Flooding NextErn Energy Resources PBNP-Noveniber 14,2012 NEE05-PR-001, Revision 0 Units 1 and 2 RHR Pipeways The U~iitsI and 2 RHR Pipeways on tlre -5 ft atid -19 A elevations are liigh 1.adiati011a~ld liigh contamiuatiotr areas causing thear to be infieqiiently inspected by tlre FMP. During inspections of these areas, signs of groundwater seepage tlirougll tlie walls were found in both Pipeways. On the Unit 1 side, tlre NW corner of the area sllowed signs of water ingress behind the ductwork in tlie cortiel; and previous instances of grou~idwaterint~vsionat this point of ent~yhave been doci~~nented in the CAP. For tlie U~iit2 RHR Pipeway, a builditp of eflorescetrce was found underneatll peldrations to tire Uliit 2 Tendoti Oallery. It could not immediately be determined if the water causing this efflorescence originated fiom within tlie tendon gallery or an exter~talgroundwater intrusion. These observations were not considered to be deficiencies by the CAP, citing a prior evalaation of tlie groundwater leakage rates and drainage capacity of the RHR pump cubicles.

Is general, tlre sub~mdewalls are considered to be effective in prevetiting groundwater intrusion into the plant based upon tlie adequate sife monitoring program they are included on with the exception of tlie rioted observations above, Tlrese observations will be Iiandled by the PBNP CAP and tracked within the PMP 111tlie fi~ture.

Overall, PBNP e~nploysa nutnber of different flooding protection fertttres that are available, filnctiontll, and ilnplenietitable respective to their credited flood protectiol~filnctions upon co~npletionof tlie corrective actions detailed i ~section i 4L

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e. Requested Information Item 2(e) Implementntion of Wnlkdo~vnProcess Present ir~forrnationrelated to tlie imple~nentationof the walkdown process (e.~..details of select-walkdown tea111and procedures) using the documentation template disc~lssedin Requested Infor~nntiorlItem 1,i fill Enclosu~~e 4 of the Marc11 12. 2012. 50.54(fl letterl. i~lclrtdia~

actions taken in resuonse to the peer review.

Consistent with Section 5.3 of NEl 12-07, wrtlkdown teams consisted of at le~sthvo trained individlrals with a complementary set of skills, The walkdown tealti consisted of tlaee rnechanical engineers from ENERCON and three rnecl~~nical engineers from tlre site. h c h walkdowa was perforriled by at least twa members of the walkdown team. The membe~~s of the walkdowns tea111 had varying levels of experic~rce wit11 plant iiiodifications, engineering walkdowns, and prior flooding work boll1 at PBNP and other sites. In addition, a civil liydra~~lic engineer provided expertise during the develap~nelltof tlie walkdow~ipackage for surfice drainage features.

Per Sectiorr 5.3 of NEI 12-07, personnel selected to perform walkdown insyeotfori activities were experienced and kno\vledgeable of tlie site current lice~rsingbasis. Personnel were experienced or trained to perform visilal inspections of SSCs and met tlre knowledge reqrtireme~itsof Appendix C of NEI 12-07, All team membets that perfonlied the vist~alinspectio~rswere trailred to and knowledgenble of tlre below informntiorr:

NANTEL lesson on Oet~ericFlood Protection Walkdowns Specific PBNP licorrsing basis ~natcrial NTTF recommendation 2.3-Flooding and tlie NRC lelter dated Mawll 12,20 12 [Ref, 21 NEI 12-07, Revision 0-A [Ref. I]

ENERCON pe~ronnelweis supported by site and craft perso~~nel cluriog tlie walkdow~rwlro were 1101 scqui~.edto meet the above requi~rnents.These pessonnel were used because of their familiarity with plant Page 10 of 19

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NTTF Recom~nendation2.3 (Walkdowns): Flooding NextEra Energy Resources PBNP -

Noveniber 14,2012 NEE05-Pk001, Revision 0 SSC's and protective measures. Generally, these personnel inet the knowledge require~nentsbut did not undergo the ~~quircd training. A pre-job brief was perfoiuned prior to conducting the waikdowns usi~rgp l a ~ ~ t lit~~nan performa~~ce procedures and was tailored to the walkdow~~ task, Eacli walkdown performed a specified inspecti011to assess the capability of the item to perfonn its requised fnnction. All walkdow~l results were docu~nentedin accordance wit11 tlie recornmendations of Section 7 of NEI 12-07 and usi~igtlie walkdown record form template in Appendix B of NEl 12-07.

f. Requated Information Item 2(f) - Findings and Corrective Actions TakenIPlanned Results of tlie wvalkdown inclirdiap kev fi~iditi~s ar~didentified deuraded. non-conforming, or unnnalvzed conditions. lticl~~de a detailed descri~tiotlof the actions taken or nlant~edto address tllese conditio~~s usin8 hpuidance In Reatdatorv bsues sum mar^ 2005-20. Rev I.Revision to NRC lnspectioti Manual Part 9900 Technical Ciuidance, "Ooerabilitv Conditio~isAdverse to Oaality or Safetv." i~~clttdinn enter in^ the co~~dition fn the corrcctlve action pronrm All observatio~lsmade during the walkdowns that were riot im~nedintelyjudged as acceptable were entered into the CAP to be dispositioned by the site. The following details {lieobservations that were determined to be deficie~iciesand their respective corrective aotious planned in accordance witli Reference 3:

..

Fentare Dispositio~~

Description oTDeficiency Category Slatus Due to the insufflcie~~t length The configuration of thejersey of the jersey barrier barriers was found to be inadequate. configuration and the possibly Field merrs~~retnents indicated that on unacceptable gaps in between both sides of the CWPH, the barriers barriers, this situation was did riot extend far enotrgll north and altered into the CAP and south to provide flood pmtectiot~up determined to be a deficiency.

to the design flood height of 4-8.42 R The corrective actions (CAs)

In the currelit configuration, the y la~lnediuclude:

lerlgtli of the tliree-barrier-long 1) Adding four tnorejersey artallgemeat011 either side Is barriers to (lie ct~rrent approxinlately 37.5 ft. On the nortll Being con figtwlio~lto achieve tracked side, it was foti~~d that tlie barriers the needed flood need to extend anotlier I IS inches to Ts~npornry usder pmlsolioll protect ngai~~st the flood level, and Passive corrective on tlie soutli side, the barriers need to 2) Pouri~~g a new concrete action extend another 122 i11cl1es.In pad to provide tliejersey program addition, the rigid coricrete bmrriers barriers with an even do not sit flush on the tineven groia~ci surface to be installed in the vicinity of the foreb~y,and upon and eli~nirlategaps some gttps exist between tlie ground t~nder~~eatllthe barriers and the barriers. Fisally, on the sides There is no operability issue of tlie barriers, there are nietal loop$ because the current lake level that are used for anchoring the is low e~iougllthat the barriers together, and these loops probable maximum run-up cause gaps of approximately 3 inches woi~ldnot affect pla~it to exist in betweeen tlie barriers. equip~nent, Page 11 of 19

NTTF Reconlmendation2.3 (Walkdowns): Flooding NextEra Energy Resot~rces- PBNP November 14,2012 NEE05-PR-001, Revisio~lO Ii%atirro Descrpfion of Deficiency Disposition Sfattls Catego~y The reasonable simnuiation for the iastallation of the barriers slio\ved Tliese observations were the procedure cannot be execlited as deter.rniaedto be a deficialcy, written. The jersey barriers are and a CA was ge~ieratedto installed in a location on either side write a procednre change to of the CWPH that is marked as a eli~ninatethe procedure's inadequacies and incorporate Being B.5.b staging areti, and no provisions tlre suggested enhaacements. tracked are made to ensure B.5,b TetnporflrJ' Thro is no operability issue uuder requiremetits are rnet wlt i lo tile passive because the current fake level corrective barriers are installed. Also, the entry is low enough that tlre actiotr into the CAP suggests that the 1)1agram riecessaly support equipment probable ~naxinlurnrial-lip (forklifts, etc,), site support (security would not affect platlt coverage), and a periodic clreok of equipment, and thejersey the staging conditiorl of the barriers barriers would not be needed.

be added to further ellha~lccthe procedure.

Wlle~lthe heights of the fire and This observation was service water pump ll~otorswere deteimined to be a deficiency, obtained within the CWPH, a and !lie plarlned CA is t~ credit deficiency was fot~ndrelating to the the CWPH floor dainpers for diesel fire pump. The diesel fire extenlal as welt as internal pump's colltrol pallel C-6 1 and flooding. This will reduce the battery D-600 did not meet the flood lieiglit to 4-7.75 A fro111 Being credited height of +9 ft. The +8,42 ft based up011tile tracked termiaatioim of the batte~ywere lllcorp~rated existing capacity for flood under mensured to be +8,5 ft off of the relief in the CWPH, Tllere is floor, just above the flood height of no ftttlctio~lrlityissue because action

+8,42 ft, and the electrical panel that the current lake level is low program contained C-G1 atid oil-ortitryfor enongh that the probable D-600 had electrical co~npolletltsat niaximum run-up would rlot

+8.375 R off of the floor, which is affect plant equipmalt. These below the flood height. It should be are not Tecl~uionlSpecificatio~i noted the fire pump is augcnerited equiptnent.

quality equipment, not safety-related.

Page 12 of 19

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NTTF Recon~mendmtion2.3 (Walkdowns): Floodi~~g NextEm Energy Resources - PBNP Noveniber 14,2012 NEEO5-PK-001, Revisinn 0 Fcature Disposition Status Description of Dof'iclcncy Cntegory Tliis observation was detemlined to be a deficic~lcy, and the plate has bee11 re~noved.A CA was created to update tlie model work orders Beillg It was observed that the catch basin (MWOs) for tlry firel storage it1 the plant yard near the NW corner tricked to i~icludea step to reemove t~nder of tlie Unit 2 fapade was covered hicorporated ground supporl plates after with a metal plate, prevetiti~lgit from Passive corrective co~npletio~i of tlie campaign.. actiotl accotnplislii~lgits flood protection No safety significant plant filnction. program equipment is clialle~iged because there are no ide~rtified intrusio~rpaths into tlic fapade, Diesel Gelieralor Building, and L e PAB above grade level.

Tliis situation was deterinitled to be a deficierlcy by tlie CAP and the planned CAs inclide:

During tlie walkdow~~ of tlie drainage ditches, it was discovered tllat the 1) Updating PSAR to replace i~iterceptorditches on the ~iorlliand the north interceptor ditcli west side of the plant [Ref. 8) were with the storrl~drain eitlier not folttld or inadequate. Tlre system on tlie north side.

west side interceptor ditch that runs Tliis is at1 equivalent between the plant yard and change that was never switcllyard on either side of tlie incorporated after tlie Being 13.8 kV Buildi~igwas dearled co~istrt~ctio~~ of the DOB. tracked illadequate' On the south side of lticorporated 2) Perfor~iiinga re-evaluation under 13.8 kV Building, the ditcli is Passive of tlie drainage 011ttie west corrective obstructed by u new (~a~isformer acid side of tlie pln~ityard action propalie lank. On tlie nortli side, tlic around tlie ditch, taking Iwogram ditcli is riot well defined ntrd nlso has illto consideratioa tlie a liew transformer and capacitor added cquip~nentthat Itas bank blockilig its path, For the north obstructed the ditcli.

interceptor ditch, 110apparent ditch was found tliat drained to tlie lake. No snfety significasl platit All of the drainage fotl~~d in or tlear equipmalt is cl~alle~~ged tile plant yard OII the riortli side feeds because them fire no identified dow~ito the iio~tlistorm drwin line. intrusion paths into the fapade, Diesel Generator Building, slid the PAB above grade level.

Page 13 of 19

NITF Reco~ri~~~endatioti 2.3 (Walkdowns): Flooding NextEra Energy Resources PDNP Nove~trber14,2012

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NEE05-PR-001, Revision0 Feature Dcsc~*iptloao f Doficlercy Disposltlotr Stnttts Cat@gory Tlie niai~tte~iarice of drainage ditches Tltese observntio~iswere and culverts wvas not found to be entered illto tlre CAP acid determined to be a deflcicncy.

adequate after several drainage patlis Tlie drainage ditcli were fou~tdto be pa~liallyobstri~ctcd.

Tliis iticluded tliree drainage culverts ~naititetiancewill be updated to address tlre shortconri~igsin o r tlie soetli side o f tlre site tliat were citlier parlially obstructed or tlie current PM program. I n Beitig additio~i,tlre plant drmwing tracked sub'nergd in pO'lding' drai~iageculvert near tlre ~iortlr lncorpornted used to guide the PMs will be wider Passive updated to more accc~wtely corrective security gate was nlso foit~rdto be reflect the co~iflgt~ration o f the action obstri~cted.Sonie d~.aiiiageclitclies surface drminage features at the proyrnlii lrad buildups of did mod sill tliat site. N o safety sig~l;ificatilplant indicated poor dsmiaage flow a ~ i d eqt~ipnreatis challe~iged required clenri~igor possible becoi~setlrere nre no idetrtified re-grading. Tliis primarily applied to intntsion patlts into tire faqnde, the drmi~iappatlis a101ig t l i ~iortlr

~

Diesel Generator Buildi~ig,and and sot~tlrsides o f tlie switcliyard.

the PAB above grade level.

PBNP has tio flood protection fertttrws designated as restricted access or inaccessible.

g. Rcquestod I n f o r m n t i o ~I t~e m 2(g) - Cliff -Edge Effects nnd A v ~ f l n b l ePltysicnl M n r g %

pocu~netltaliv cliff-ed~eeffects idetrtified arid the associated basis. lrldicate tliose tlrat were entered into the corrective mctio~lproitrnln. Also inclt~dea detailed descriptiort o f die actio~istaken or plttn~redto address tlrese effects, hi accordance with NEI 12-07, Available Pltysicml Margins linve been collected and doct~~~re~ited ill tlre Walkdow~lRecord fornr (Appendix B). The g~~idnt~ce provided illFAQ-006 [Ref. 9) was also followed. Tlris ittforri~atiotlwill be used illtlie flood liaznd reevalt~ationsperformed in response to ltoni 2.1: Flooding in tlre 50.54(f) letter [Ref. 21.

Ir, Requested Infolm~mtionI t c n 2(11) ~ - PI~nnedlNowly-lnstrlleclFlood P~~otection Enl~mcetnents Describe w oil- or acwlv ltrstnlled flood umtcction svste~iisor flood mitiaatiotr incasttres j~rcludhnflood barriers (hat A~rtlrere~ilim~rce tlie flood protectios, ldetrtifv ~esultsm~rdally sttbseque~rtactiotg jnke~lin resuorise to the Deer ~*evie\v, Curt~~ttly, tliere NI~! no plrn~redor aewly installed flood protectioa eriha~lce~r~ents or flood lrlitigatioti trieRsltres nt PBNP, Tllere were no cltaitges to tlte wvalkdown process r s descsibecl ill Section 7 or l l ~ ewalkdowi~record for111 111 Apperidix S o f Refet.etice I.

5, CONCLUSIONS Walkdowtis were performed i s rccosd~~rce witll NEI 12-07 (Rev. 0-A), "Guidelines for PerFor~ni~ig Verificalio~ro f Plant Flood Protection Features," dated May, 2012 [Ref. I].miis doct~rne~rt was eiidossed by

[lie NRC on Mny 31, 2012. PBNP Units I & 2 co~iflgtrr~tio~r and procedures were co~npmredto the flood Page 14 of 19

Nm'F Recomaietldntion 2.3 (Walkdowns): Flooding NexlBra Energy Resources - PBNP Novenibcr 14,20 12 NEE05-PR-00I , Revision 0 protection features credited in the curreut licetlsi~tg basis docu~neots for external floodirlg events.

Site-specific features credited far protection and mitigatiolr agni~tstcxtelaal flooding events were idenlified and evaluated. The results of the inspections are si~lntnarizedbelow.

Reasonable Simulations Tlie reasonable silnulation of tllc instnllatio~iof the jersey bawiers did not raise mly concerns over completion of time setlsilive nctiorls but did identify sonle sl~ortcomingsin the procedure concerniog tlle collflict with B'5.b staging requiremeats and otller stiggestetl e~ihancemenisthat are beirig ndded, Tliese have been entered into the PBNP CAP.

Insvection Deficiencies Tlie flooding walkdowus verjfied that pctmanent structures, systcms, co~nponcr\ts(SSCs), tempora~yflood mitigation barriers, and the procedures needed lo install atid or opel~tetlieni during a flood are acceptable and capable of perfonling their design fitnctiot~as credited in the current liceasiug basis (CLB) with these cxcey)tions.

The jersey barrier co~lfigi~ratio~~ was fouttd to be ir~sl~fficierlt in letigtll to the ilorllt and sot~tllof tile CWPT-Ito provide protection to 3- 9 fi.

The procedure for the iastallation of tlle jersey barriers did not provide provisio~isfor the fact that the jersey barriers are itistalled in B.5,b staging areas on either side of die CWPH, r Tlie control panel and battery for tlic diesel fire pump in tlie CWPH was below tlie flood height.

A catcll basil1 jn the plant yard iiear tlie NW corller of the Unit 2 Fagado was found to be covered with a metal plate.

Tlie ool-th and west ii~terceptorditches called out in Refere~lce8 were either not found (north interceptor) or i~iaclequate(west interceptor).

Several drainage culverts and ditcllcs wore found to be pastially obstructed, Cossective Actiolts Tile following CAs were taken in response to the above identified deficiencies:

Additional jersey barriers will be acquired to extend the lel~gtliof the barrier configuration, and n coucrete pad will bc po~~red to address potetllially unacceptable gaps in tile coafigumtiotl, A procedure clla~~ge will be cornpieled to address the inadequacies in tile site procedure for jersey bari~ier.installation, lustalled floor dampers in the CWPI-I will be credited for external ns well ns inlerual floodilig to reduce the flood height in the CWPH Lo 7.75 fi.

Tlte metal plate was removetl from tlie catch basill, a~idthe addition of procednral controls to preverit fi~tl~reobstri~ctionsis being reviewed.

Tile PSAR will be updated to replace the nortl~erninterceptor tlitcli wit11 tile stow1 drain system, and a re-evaluation of the drainage laear the westeln interceptor ditch will be perfosmed.

Both the mainta~anceprogrn~llfor tile drainago dilclles acid the plant drawing used to guide the PMs will be t~pdated.

Newlv installed and ~lallliedflood !>rotectionci~bancements

?'here are no tiewly iitstalled or planned flood protectio~lenha~~cenlents at PBNP, Page 15 of 19

NTTF Recommendation 2.3 (Walkdowns): Flooding NextEra Energy Resources - PBNP November 14,2012 NEE05-PR-001, Revision 0

6. REFERENCES

1. Nuclear Energy Institute (NEI), Report 12-07 [Rev 0-A]. Guidelines for Performing VeriJication Walkdowns of Plant Protection Feattrres. May 2012 [NRC endorsed May 31,2012; updated and re-issued June 18,20121.

2. U.S. Nuclear Regulatory Commission. Letter to Licensees. Requestfor Information Pursuant to Title 10 of the Code of Federal Regulations 50.54flRegarding Recommendations 2.1, 2.3, and 9.3 of the Near Term Task Force Review of Insightsfiom the Ftrktrshima Dai-ichi Accident. March 12,2012.

3. U.S. Nuclear Regulatory Commission. Operability Determinations & Fzrnctionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety. NRC Inspection Manual. Part 9900: Technical Guidance. Regulatory Issues Summary 2005-20, Revisions 1.

September 26,2005.

4. Technical Memorandum No. 36, Beach Erosion Board, Office of the Chief of Engineers, Department of the Army.

5. "Maximum Deep Water Waves & Beach Run-up at Point Beach," Sargent & Lundy, 1967

6. "The Prediction of Surges in the Southern Basin of Lake Michigan, Part I, The Dynamical Basis for Prediction", G.W. Platzman, 1965

7. "Preliminary Hydrologic and Hydraulic Studies for Nuclear Power Plant Site Selection," Harza Engineering Company, 1966.

8. Point Beach Units 1 & 2 Updated Final Safety Analysis Report, Chapter 2 "Site and Environment."

9. FAQ-006, Inquiry Form-NRC Submittal, Revision 4, Applicable Features for Quantifying APM, September 13,2012.

10. FAQ-007, Inqui~yForm-NRC Submittal, Revision 0, Inspection of Exterior Walls, August 1,2012.

11. AECOM Technical Services, Inc. "Final Report: Drainage System Inspection; Point Beach Nuclear Plant; Two Rivers, Wisconsin." June 2010.

Page 16 of 19

NTTP Reco~nlrre~idatio~r 2.3 (Wnlkdowns): Flooding

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NextEru Energy Resoilrccs PBNP November 14.20 12 NEE05-PR-001, Revision 0 Attael~nre~tt 1: FAQ-006 [Ref. 91

4. TOPIC; AppUcnblc Fentures for Qannti$Iag APM Soilme docttment: NEI 12-07 Section: 3.13 & 5.8

p. DESCRIPTIOlyi Sections 3.13 nlrd 5.8 provide a dofinition, description, and exa~nplesfor Available Plrysical Margin (APM). 111Section 3.13, APM is defl~iedas "the differe~rcebetween licensing basis flood lleigllt and tlre flood height at wlriclr water co111d affect nn SSC ilnportarrt to safety". This ieqrli~yis inte~rdedto clarify

!Ire latter part o f tl~isdefl~rition, co~rsideringtlrat tl~atsome featrlres will not hnve a clearly defined exceedance heigllt.

p, RESOLUTIONI(Include ndditional pages if necessary. Total pages: 2 )

Inquiry number:OOb Priority: H Sections 3.13 m d 5,8 provide a definition, description, and oxa~nplesfor Availnblo Plrysicsl Margin (APM). 111Section 3.13, APM is defined as 'Yhe differcnco between licensiag basis flood lreight and tlre flood Ire ant to safety". The latter (gnderli~~ed) pert o f the definition can be interpreted as the height nt which the flood protectiorr capnbllity of n feature is exceeded.

For some features, the exceeda~lceheigllt cnn be olenrly defi~~ed (0.g. flood wvnlls, lovoes, dikes, cofferdams, flood gntes, tlre elevntio~lo f unsealed pendrntions or o t b r openilrgs, etc.), For other features (e,g. sad, plug, or water-tight door pressrrre rntil~gs,pilnlllp flow mtes, etc,), 111%sxceedatlce I~eiglacannot be clearly defined witlroirt porforrlri~igna ellgineeri~rgnnalysis tllnt is beyo~ldtlre scope o f the flooding rvalkdow~v.As a restllt, it is nppropriate to record APM as a si~nplemeast~remc~it o f trelglrt difference, Irowvever additional co~isiderationsapply.

Tlreie is a concern tllat recording largo APM on tile Walkdowv~rRecord Forin could be ~liislendingif tlle APM is i~rterpretedas ~nargiatlrnt is avnilnble for ndditio~inlflood protection witho~~t fi~rtllerevnl~tation.

For exa~nple,for a flood protection wall tl~at1s 10-R lriglr and tlro CLB water Ileiglrt is 9.5-R,, it is reasonable to stnte tlrat tlre APM is 6-inclles for the wall. However, if tlre previolls wall is now 20-0 lrigll and CLB rvnter lroigllt is still 9.5-lt, it CRIIIO~ be stated tl~nttlrc wall's APM is 10.5-ft based 011 engineeringjudgment lon no, I n order to verify n Inrge APM that is not already defined f r tlie existing dosig~rdoctnnents, nn nnalysis woulcl have to be perforn~edto evalunte tlie effect o f the ~dditionalflood lrefglrt 011 wall lords and prwsstllweretention capbility for any associated pene!ration SB~IS, ASa regi~lt,tlre rnalrner in wbioh na APM sfrould be ~ecoldedoa tlie Wnlkdownl Record for111depends r~ponwhetber the APM is cotrside~~cd lnrgo (nrr i~rtorprctntiotro f rvl~ntconstibtos n "lnrgo" APM is nt tlro discmtion o f tlro utility).

V i e followi~rggi~idatrceapplies, For wnllrclow~istlini hnve rot yet been pcrfornrccl anrllor t l o c ~ ~ ~ r c r ~ t e d r Recording APMs on tlre Wnlkdown Record Slreet as a difference in lreigllt is n reasonable statenlent of the nvnilnble ~lrargitrbaarl olr e~lgineeringjudg~neata111esstlie APM is large. For APMs ,llrlae options are avaitable: (I)recold a s~ualler,but defensible, APM value based Page 17 of 19

N'lTF Reconrmendation 2.3 (Walkdowns): Flooding NextEra Eneigy Resources - PBNP November 14,20 12 NEE05-PI<--001,Revision 0 otl engineering judgment with a co~~respoudi~ig note in the "com~~teats"section; (2) record no value for the APM wit11 a corresponding tlotc in the "comme~lts" scctioti that an engineering allalysis is necessary to determine tlie maxirnum APM tlle wall can withstaod before a firl~ctio~~al failurc; or (3) referei~cetile existing PSAR section or desigcl documcnt that suppo~tstlie APM.

Nole that tliis 11otatioi1should be made in the response to QI 1, 423, or 427 of tlie Walkdowli Record Forin, ns applicable, For wnlltdolvns that liave been completed:

Recog~lizi~ig that it is not resource effective to revise completed paperwork, it is not necessaly to cl~atigetlte way the APM was recordcd in co~npleledportions of tlrc Welkdowvn Record Fornl. 111 tliese cases, APMs that have been recorded as siiliple measurements of height differences are acceptable as long as tlle APM determination process did ~iotresull in overlooking some pote~~tial margins, as defined by the site per Sectio~i5.8 of NEl 12-07.

For Wnllcdowa Reports:

lt~dicnteit1 the walkdow~~ report if ally APM information was recorded before the large APM approach described in this PAQ was developed.

Notes:

1. Typically, the CLB for the site will indicate what the probable maximum flood level is & tho level to whicll the SSC i~nportalltlo safety is protected, If the recorded APM exceeds tlle diffetencc between these two values at~dtlie rnargin is to be credited for additio~ialflood proleclioil, the margin must be justified by one of the followilig inethods:

R. Doci~liie~~ted application of ~.easonableatld i~lclepe~~de~~tly verified engineeringjudgme~lt

b. Perfolmauce of ricw cngi~leeritlgallalysis

c. Reference to at) existing docurnent or atlalysis that soppoi-tstile higher protection level Revision: 4 Date: 9/13/12 E.NRC Ravielv:

Not Necessary Necessary X Explanation: --

P. Industry An13roval:

Doct~a~etitation Method: Sent 13.2012 lneetitw Date:_ - -

G. NRC Accentnnce:

Interpretatiott X Agenoy Position Documcnt~tionMethod: Sept 13,20 I2 ineetitip Datel Page 18 of 19

NTTF Recornnlendation 2.3 (Walkdowns): FIooditrg

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NextEra Energy Resources PBNP November 14,20 12 NEEOS-PR-00 I, Revision 0 Attachment 2: FAQ-007 [Ref. 101 A. TOPIC: l~~spectioti of exterior walls Source doctrnent: NEI 12-07 Sectioe: 5.5.2 B. DWCRIPTIONr We liave a wet site where the SSCs are licensed to flood and the core is protected t~sinymitigating actions. Some of tlie bdldings have safety-related equipment below grade and below groundwater levels.

The building's concrete walls keep groundwater from altering ll~estr~rnturebut tlierc is no rnention of the walls being credited flood or grou~ldwaterprotmtion featl~resin the CLB. If the walls A I I any

~ associated penetrntioll seals are not credited in the CLB as providing protection (against surface water or groaedwater flooding), do they need to be i~~cluded in the walkdown scope?

On tlre otller krul, if the walls auld associated seals are performing r flood protection fi~nction, specif'icnlly for grol~lldwateringrcss, even tlloitgli the CLB for floodi~lgis silent on it, sl~olulda visl~al observatioil of the walls be peufor~ned?

C. Initiator; ne: J Bellini Pllorre: (6 10) 877-6022 pate: 713 1112 E-Mail:joe, bellini@nmec.com J).RESOLUTION; (lncltde additional pnges if necessary. Total pages: I )

Inquiuy number:D07 Priority: H Ally exterior wall (above or below grade) protectillg spncc credited as dry in tllc CLB froln groutldwater or surface water flooding shortld be incli~dedin the walkdown scope, even if the exterior walls are 11ot explicitly mentioned in the CLB. Tlre inspection of the walls slio~rld also note degtading or l~oncollfownjngcoriditions for associated penet~wtio~is,seals, eto., altlloi~glrthe penetrations/seals tlletnselves do not need to be listed as separate fentures, wit11 separate walkdow~lrecord forms, ur~less individually credited In the CLB.Tlia inspection applies to portio~lsof the walls below design basis flood and/or grotindwater levels.

Note that Available Physical Margin sl~ouldbe obtained to the lowost u~sealed,unqualified and or inspected sealed penetration above tlre design basis water level.

Revision: 0 Date: 8/1/2012 E. NRC Review; Not Necessary X Necessary Explanation:

F.lndustw Annroval:

Docuii~entationMethod: Dnte: