1. Flooding Walkdown Guidance
George Attarian, Progress Energy
April 6, 2012

2. Guidance based on approach to IER 11-1 walkdowns
Current Status
Guidance based on approach to IER 11-1 walkdowns
Draft prepared and sent to the NRC and industry on March 9
Currently being reviewed by NRC
Comments discussed during March 15 and 27 webinars
NRC comments on key concepts will need to be resolved

3. Guideline Content Introduction Purpose Definitions Scope Methodology
Acceptance Criteria
Monitoring and Maintenance
Reporting Results

4. Purpose
Verify that permanent and temporary SSCs, related procedures, and associated manual actions credited in the external flooding licensing basis are in acceptable condition and capable of performing their intended function

5. Definitions
Deficiency: A condition that prevents a plant flood protection feature from performing its intended function during a licensing basis flood event. This condition shall be determined by the Corrective Action Program.

6. Definitions
Inaccessible areas are areas that cannot reasonably be inspected due to significant personnel safety hazard, Very High Radiation Areas, major equipment disassembly, or no reasonable means of access (e.g., buried).

7. Definitions
Reasonable simulation is a walk-through of a procedure or activity to verify the procedure or activity can be executed as specified/written. Reasonable simulation may require the actual performance of these activities if there has never been a demonstration that the activity can be completed in the credited time.

8. Walkdown Team Selection and Training
Experienced personnel trained for visual inspections of plant structures, systems, and components within the walkdown scope
Trained to
Walkdown guidance
Walkdown packages being performed
Flooding related items in enclosures 2 and 4 of 50.54(f) letters
Recommend 2 staff on each visual inspection team
Training content described in Appendix C of guidance

9. Scope
Compare current plant configuration and procedures to features in existing design and licensing basis that are credited for protection and mitigation of external floods
Comparison to UFSAR, current drawings, and procedures
Inspection does not include the initiators that cause the floods
Inspection of upstream dams WILL NOT be required, but inspection of the flood protection features that are credited to protect against or mitigate the effects of a dam failure WILL BE required

10. Methodology General Examples are in Appendix B
Permanently installed passive SSCs
Permanently installed active SSCs
Temporarily installed passive SSCs
Temporarily installed active SSCs
Examples are in Appendix B

11. Methodology Protection features All Temporary
Assess the capability to perform the required function (visual inspection of SSC, review of operating procedures and PMs)
Any observation that cannot be immediately judged as acceptable must be entered into the Corrective Action Program for disposition
Temporary
Verify accessibility, transportability, staging and function of necessary supplies, and feasibility of installation

12. Methodology Functional tests/PM’s All equipment
Assess appropriateness of the test
Tests completed with acceptable results within their required frequency (if applicable) and at least once

13. Methodology Procedures and associated manual actions
Reasonable simulation
Actions must be feasible considering conditions that may exist at the time of the flood
Must consider station staffing limitations and site access concerns
Staff must be trained
Ensure that site warning procedures are in place

14. Acceptance Criteria
Flood protection features are considered acceptable if no conditions adverse to quality were identified during walkdowns, verification activities, or program reviews as determined by the licensee’s Corrective Action Program. Conditions adverse to quality that prevent the flood protection feature from performing its credited function during a design basis external flooding event are “deficiencies” and must be reported to the NRC in the response to the 50.54(f) letter.

15. Walkdown Documentation
Walkdown record form in Appendix B
Description of feature
Results of
Visual inspection
Functional test
Procedure walk through
Maintenance and monitoring
Conclusion
Photographs should be considered for visual inspection documentation

16. Reporting Requested information in 50.54(f) letter
Additional considerations
Deficiencies
Schedule for inspecting features that were not inspected
Reasonable assurance that flood protection function of inaccessible features will be met

17. Estimated Schedule for Guidance
Draft provided to NRC
March 9
NRC meetings to discuss comments
Apr 11, Apr 25
Submit final draft to NRC and industry
Early May
NRC endorsement
Late May
Utility commitment to use (90 day response)
June 10

18. Other Considerations
Utilities should use walkdowns to prepare for flooding hazard evaluations and Integrated Assessment
Look for potential vulnerabilities and available margin
Assess implications of
All plant configurations
Full flood duration
Separate guidance will be provided