Brunswick Still Has flooding Issues Post Fukushima Retrofit

This is what I sent the NRC on Sept 12. Remember hurricane Florence petered out to a below Cat 1 hurricane as it hit landfall. A true cat 4 or 5 would have been devastating. 

Again, was the Fukushima lessen learned comprehensive at Brunswick? Does this prove it wasn't. These are all really smart people, maybe there is fraud and corruption.

Usually this would flip into a special inspection. But now the new NRC has a intermediate step favoring the licensees and the industry...meaning less special inspection. There is no doubt in recent years the NRC has had a lot less special inspection...   

Wednesday, September 12, 2018

NOAA Says The Two Plant Brunswick Nuclear Plant Are Heading For a Meltdown in a Cat 4 Hurricane

Still working on this

Cat 4 Hurricane Hugo had a storm surge of 18 feet in North Carolina. I don't know if it was in the high or low end of a Cat 4 hurricane? Remember Florence is 21 feet about sea level. You know, what is your definition sea level? There is many of them. I got my measurement of Brunswick's above sea-level height of 21 feet from google earth. I kinda thought over topping the Brunswick's site was not probable in a Cat 4 or 5 hurricane. I did not believe these plants could be constructed so closes to sea-level. I figured these plants could easily survive high in the Cat 5 level. I now know it is probable ocean overtopping the site in a cat 4 or 5 is a certainty. I totally believe the NOAA's cat 4 or 5 storm surge calculations. Remember the hurricane ocean over topping is 3 feet at Brunswick per NOAA.

I am shocked at this latitude this plant is so poorly situated. I suspect more plants are in the same situation.

Now I consider it a high probability there will be a guaranteed of meltdown at Brunswick in a cat 4 or 5 hurricane. This is our Fukushima. Are the reactor building, turbine building, diesel generator rooms or the switchyard are not designed for a 6 feet or more ocean over-topping of their site. Can the flex system over come this kind of defect with a 6 feet or more over-topping of their site. In the best of any ones computer models, they is just too much uncertainty.

I think the turbine building and reactor building would quickly fill up with ocean water rendering all ECCS inoperable. I think the ECCS safety busses are on the ground floor. They would become inoperable. As far as the diesel generators, they are probrably on the ground floor. Certainly the diesel generator's local breakers are on the ground floor. There is your blackout where the flex system being useless too. You going to helicopter a flex system big DG or pump into 6 feet of water?

I make the case in climate change, these big hurricanes will be much more probable.

Questions

1) Is it in plant licensing all US are nuclear plant are supposed to survive all cat 4 and 5 Hurricanes without a meltdown?

2) Think about the movement and safety of operators on site in a over-topping conditions. There would be no movement.

3) Would the hardened vent be usable or accessible?

I request a emergency investigation on this Hurricane ocean surge issue on a Cat 4 and 5 levels at Brunswick. Can this plant survive a Cat 4 or 5 hurricane without a meltdown? Is there a extremely high likelihood these plants would not meltdown? Actually, if a plant can't survive a Cat 4 or 5 hurricane without meltdown, these plants should be emediately shutdown in the greater interest of the USA?

I am considering a 2,206?

Sincerely,

Mike Mulligan
Hinsdale, NH

Cell: 1603 209-4206
steamshovel2002@ yahoo.com         

I guess the NRC has flooding issues with Brunswick post Hurricane Michael? 

From: Guill, Paul F <Paul.Guill@duke-energy.com> Sent: Wednesday, September 26, 2018 1:13 PM To: Vega, Frankie Subject: [External_Sender] RE: Brunswick Flooding MSA review
Frankie;

The clarification information requested is provided below in red. Let me know if need any additional information to support your review. Again, thanks for your patience 

From: Vega, Frankie [mailto:Frankie.Vega@nrc.gov]  Sent: Monday, September 24, 2018 1:04 PM To: Guill, Paul F <Paul.Guill@duke-energy.com> Subject: RE: Brunswick Flooding MSA review

*** Exercise caution. This is an EXTERNAL email. DO NOT open attachments or click links from unknown senders or unexpected email. ***  Hello Mr. Guill;

Just a quick follow-up with my request below. I know that you guys are still dealing with the aftermath of the hurricane so I understand if the responses are not yet ready.

Thanks

Frankie 

From: Vega, Frankie  Sent: Wednesday, August 15, 2018 2:25 PM To: 'Guill, Paul F' <Paul.Guill@duke-energy.com> Subject: RE: Brunswick Flooding MSA review

Hello Mr. Guill;

In addition to the documents already provided I would need the following clarification information in order to complete my review:

Flooding MSA Section 3.5.1 states the following: While most safety-related structures have finished floor elevations above 22 feet NGVD29, the Reactor Building has two access openings at 20 feet NGVD29: the equipment access airlock (i.e., railroad airlock) and the personnel airlock. Leakage past these doors is intercepted by floor drains and routed to sump areas on the -17 feet level of the Reactor Building. The minimal water intrusion spread over the large area of the Reactor Building would not challenge any plant equipment relied upon for the FLEX strategy. In order to confirm that no key FLEX equipment is impacted by the LIP, can you please provide additional information regarding in-leakage water quantities and expected flood water depths at the -17 feet level.

DUKE RESPONSE: In-leakage is conservatively determined to be 30 gpm for 6.3 hours from Reactor Building Doors D-2 and D-3 (closed). This leakage would migrate to the -17 ft elevation and be distributed over an area of about 140 ft by 40 ft and would result in approximately 3.25 in. (0.3 ft) of water on the -17 ft elevation floor. The RCIC pump, located in the S. RHR Room, is relied upon for the FLEX strategy and is located on raised pedestal 2 ft-8 in above the floor. Instruments on the bottom row of instrument racks are located at least 12.9 in above the floor resulting an APM of 0.8 ft. 

Also, water levels are expected to reach 26 feet NGVD29 or above at the reactor building due to the combined effects storm surge. These levels are well above the access openings for the reactor building airlock doors referenced above. It appears that the MSA doesn’t address the potential water leakage through these doors due to storm surge water levels. In order to confirm that no key FLEX equipment is impacted by the storm surge, please provide additional information regarding expected in-leakage water quantities and expected flood water depths at the -17 feet level.

DUKE RESPONSE: In the Combined Effects Storm Surge event, temporary passive barriers are to be installed interior to the reactor airlock doors D-2 and D-3 with triggers for actions as per BSEP Administrative Instruction 0AI-68. There is no in-leakage past these barriers and therefore in-leakage calculations are not performed for these locations. Modifications to these barriers are required to raise the top elevation from 26 ft to 27.5 ft NGVD29, which presents a minimum of 0.8 ft of margin at these barriers.

No formal responses are needed at this moment so replying to this email or placing the information in the electronic reading room (ERR) would work for me. If you have questions or need clarification on the questions above, please let me know. 

I will be out of the office starting tomorrow until August 28 so no rush on this response. My replacement during my time-off would be Joe Sebrosky (Joseph.Sebrosky@nrc.gov). Joe is not familiar with Brunswick’s flooding MSA so no need to forward him the response to the questions.

Thanks

Frankie

From: Vega, Frankie  Sent: Wednesday, August 08, 2018 3:44 PM To: Guill, Paul F <Paul.Guill@duke-energy.com> Subject: Brunswick Flooding MSA review

Mr. Guill;

Hope you’re doing well. I’m currently reviewing the Brunswick MSA submittal and in order to complete the review I would need to have the following references from the MSA submittal available in the electronic reading room (ERR):

11. BSEP Procedure, Abnormal Operating Procedure 0AOP-13.0, Operation during Hurricane, Flood Conditions, Tornado, or Earthquake, Revision 67. 14. BSEP Calculation BNP-14-009, Combined Effects Flood Evaluation, Revision 1. 22. BSEP Engineering Change, EC 287907, Fukushima 2.3 Flooding Inspection Documentation – BNP, Attachment Z01, Flood Protection Walkdown Final Report for BNP Nuclear Plant Site, Revision 3. 30. BSEP Drawing F-02277, Diesel Generator Building Floor & Wall Sleeves, Revision 32.
3
33. BSEP Calculation BNP-17-001, Evaluation of Brunswick Plant Local Intense Precipitation along FLEX Deployment Path, Revision 0. 34. BSEP Drawing F-11018, Reactor Building – Unit 1 Equipment Foundations at El. (-)17’-4, Revision 3. 35. BSEP Drawing F-01118, Reactor Building – Unit 2 Equipment Foundations at El. (-)17’-4, Revision 5.

I have access to the CERTREC IMS ERR so if you are using that ERR we should be good. At this moment I’m the only NRC staff member that needs access to the documents referenced above.

Thanks 

Frankie G. Vega, P.E. Project Manager NRR/DLP/PBMB 301-415-1617 Location: O-12F0

This e-mail guy is the first one about hurricane flooding post Hurricane Florence. It is dated Oct 27, 2018. Hurricane Florence hit landfall on Sept 14 2018

September 27, 2018 Serial: RA-18-0144
 U.S. Nuclear Regulatory Commission Attention:  Document Control Desk Washington, DC 20555-0001
 Subject: Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 NRC Docket Nos. 50-325 and 50-324 Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 3, Flooding Focused Evaluation Summary Report References: 1. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340
 2. NRC Letter, Supplemental Information Related to Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Flooding Hazard Reevaluations for Recommendation 2.1 of the Near Term Task Force Review of Insights from the Fukushima.Dai-ichi Accident, dated March 1, 2013, ADAMS Accession Number ML13044A561 3. BSEP Letter, Flood Hazard Reevaluation Report, Response to NRC 10 CFR 50.54(f) Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3 and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 11, 2015, ADAMS Accession Number ML15079A385
 4. NRC Staff Requirements Memoranda to COMSECY-14-0037, Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluation of Flooding Hazards, dated March 30, 2015, ADAMS Accession Number ML15089A236
 5. NRC Letter, Coordination of Requests for Information Regarding Flooding Hazard Reevaluations and Mitigating Strategies for Beyond-Design-Basis External Events, dated September 1, 2015, ADAMS Accession Number ML15174A257
 6. Nuclear Energy Institute (NEI) Report, NEI 16-05, Revision 1, External Flooding Assessment Guidelines, dated June 2016, ADAMS Accession Number ML16165A178
U.S. Nuclear Regulatory Commission Page 2 of 4

7. U.S. Nuclear Regulatory Commission, JLD-ISG-2016-01, Revision 0, Guidance for Activities Related to Near-Term Task Force Recommendation 2.1, Flood Hazard Reevaluation; Focused Evaluation and Integrated Assessment, dated July 11, 2016, ADAMS Accession Number ML16162A301
 8. NRC Letter, Brunswick Steam Electric Plant, Units 1 and 2 - Interim Staff Response to Reevaluated Flood Hazards Submitted In Response to 10 CFR 50.54(f) Information Request - Flood-Causing Mechanism Reevaluation (CAC Nos. MF6104 and MF6105), dated March 16, 2017, ADAMS Accession Number ML17072A364
 9. NRC Letter, Nuclear Regulatory Commission Report for the Audit of Duke Energy Progress Flood Hazard Reevaluation Report Submittal Related to the Near-Term Task Force Recommendation 2.1-Flooding for Brunswick Steam Electric Plant, Units 1 and 2, (CAC Nos. MF6104 and MF6105; EPID L-2015-JLD-007 and EPID L-2015-JLD-008), dated November 15, 2017, ADAMS Accession Number ML17271A248
 10. NRC Letter, Brunswick Steam Electric Plant Units 1 and 2 - Staff Assessment of Response to 10 CFR 50.54(f) Information Request Flood-Causing Mechanism Reevaluation (EPID Nos. 000495/05000325/L-2015-JLD-0007 and 000495/05000324/L2015-JLD-0008), dated April 16, 2018, ADAMS Accession No. ML18089A055

Ladies and Gentlemen:
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 to request information associated with Near-Term Task Force (NTTF) Recommendation 2.1 for Flooding. One of the required responses in Reference 1 directed licensees to submit a Flood Hazard Reevaluation Report (FHRR). On March 1, 2013, the NRC issued Reference 2 to provide supplemental information to the request. The FHRR for Brunswick Steam Electric Plant (BSEP), Units 1 and 2, was submitted on March 11, 2015 (i.e., Reference 3).
 Following the Commission's directive to NRC Staff (i.e., Reference 4), the NRC issued a letter to industry (i.e., Reference 5) indicating that guidance is being prepared to replace existing instructions and provide for a "graded approach to flooding reevaluations and provide for more focused evaluations of local intense precipitation and available physical margin in lieu of proceeding to an integrated assessment."
 Guidance for performing flooding reevaluations is contained in Reference 6, which has been endorsed by the NRC in Reference 7. Reference 6 indicates that each flood-causing mechanism that is not bounded by the design basis flood (i.e., using only stillwater and/or wind-wave run-up levels) shall follow one of the following five assessment paths:
 Path 1: Demonstrate Flood Mechanism is Bounded Path 2: Demonstrate Effective Flood Protection Path 3: Demonstrate a Feasible Response to Local Intense Precipitation (LIP) Path 4: Demonstrate Effective Mitigation Path 5: Scenario Based Approach

U.S. Nuclear Regulatory Commission Page 3 of 4
Non-bounded flood-causing mechanisms in Paths 1, 2, or 3 require a Focused Evaluation to complete the actions related to external flooding required by Reference 1. Mechanisms in Paths 4 or 5 require an Integrated Assessment. The enclosure to this letter provides the Flooding Focused Evaluation Summary for BSEP.
The flooding analysis described in References 8, 9 and 10 was utilized as an input to this Flooding Focused Evaluation. The Flooding Focused Evaluation reaffirms that BSEP has reliable, passive protection of key structures, systems, and components (SSCs) to maintain key safety functions (KSFs).
The Flooding Focused Evaluation follows Path 2 of Reference 6 and utilized Appendices B and C of Reference 6 for guidance on evaluating the site protection features. This submittal completes the actions related to external flooding required by Reference 1.
The purpose of this letter is to provide the BSEP, Unit Nos. 1 and 2, Flooding Focused Evaluation Summary Report. Enclosure 1 provides the report.
This letter contains new regulatory commitments. Enclosure 2 provides a list of these commitments.
If you have any questions regarding this submittal, please contact Mr. Lee Grzeck, Manager- Regulatory Affairs, at (910) 832-2487.
I declare under penalty of perjury that the foregoing is true and correct. Executed on September 27, 2018.
s~
William R. Gideon
Enclosure 1: Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Flooding Focused Evaluation Summary Report
Enclosure 2: Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Flooding Focused Evaluation Summary Report, Regulatory Commitments