ML111330455

IR 05000333/2011008; 04/18/2011 - 04/29/2011; James A. FitzPatrick Nuclear Power Plant; Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event

ML111330455
Person / Time
Site:	FitzPatrick
Issue date:	05/13/2011
From:	Doerflein L T Engineering Region 1 Branch 2
To:	Bronson K Entergy Nuclear Northeast
Shared Package
ML111300168	List: IR 05000219/2011008 IR 05000220/2011010 IR 05000244/2011008 IR 05000271/2011009 IR 05000277/2011009 IR 05000286/2011009 IR 05000289/2011009 IR 05000293/2011009 IR 05000317/2011009 IR 05000333/2011008 IR 05000354/2011009 IR 05000387/2011008 IR 05000443/2011009
References
IR-11-008
Download: ML111330455 (25)

See also: IR 05000333/2011008

Text

UNITED STATES N UCLEAR REGULATORY

COMMISSION

REGION I 475 ALLENDALE

ROAD KlNG OF PRUSSlA. PA 19406-1415

May 13, 20LL Mr. Kevin Bronson Site Vice President Entergy Nuclear Northeast James A. FitzPatrick

Nuclear Power Plant P. O. Box 110 Lycoming, NY 13093 SUBJECT: JAMES A. FITZPATRICK

NUCLEAR POWER PLANT - NRC TEMPOMRY INSTRUCTTON

251 5/1 83 TNSPECTION

REPORT 05000333/201

1008 Dear Mr. Bronson: On April 29,2011, the U.S. Nuclear Regulatory

Comlnission (NRC) completed

an inspection

at your James A. Fitzpatrick

Nuclear Power Plant (FitzPatrick), using T_emporary_lnstruction

2SlSlgg,"Followup

to the Fukushima

Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection

report documents

the inspection

results which were discussed

on April 29, 2011, with Mr. B. Sullivan and other members of your staff'The objective

of this inspection

was to promptly assess the capabilities

of FitzPatrick

to respond to extriordinary

consequences

similar io those that have recently occurred at the Japanese Fukushima

Daiichi Nuclear Station. The results from this inspection, along with the results from this inspection

performed

at other operating

commercial

nuclear plants in the United States will be used to evaluate the United States nuclear industry's

readiness

to safely respond to similar events. These results will also help the NRC to determine

if additional

regulatory

actions are warranted.

All of the potential

issues and observations

identified

by this inspection

are contained

in this report. The NRC's Reactor Oversight

Process will further evaluate any issues to determine

if they are regulatory

findings or violations.

Any resulting

findings or violations

will be documented

ny ine nnj in a sLparate report. You are not required to respond to this letter.

K. Bronson 2 In accordance

with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure

will be made available

electronically

for public inspection

in the NRC Public Document Room or from the Publicly Available

Records (PARS) component

of NRC's document system (ADAMS), accessible

from the NRC Web site at http:l/www.nrc.oovlreadinq-rmladams.html (the Public Electronic

Reading Room).Sincerely,\-0 1C\Slor"r.l---^" l ' t Lawrence T. Doerflein, Chief Engineering

Branch 2 Division of Reactor Safety Docket No.: 50-333 License No.: DPR-59 Enclosure:

lnspection

Report 05000333/2011008

cc w/encl: Distribution

via ListServ

K. Bronson 2 In accordance

with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure

will be made available

electronically

for public inspection

in the NRC Public Document Room or from the Publicly Available

Records (PARS) component

of NRC's document system (ADAMS), accessible

from the NRC Web site at http:llwww.nrc.oov/readino-rm/adams.html (the Public Electronic

Reading Room).Sincerely,/RN Lawrence T. Doerflein, Chief Engineering

Branch 2 Division of Reactor Safety Docket No.: 50-333 License No.: DPR-59 Enclosure:

lnspection

Report 05000333/201

1008 cc w/encl: Distribution

via ListServ ADAMS PACKAGE: M1111300168

ADAMS DOCUMENT ACCESSION:

MLl11330455

SUNSI Review Complete:

LTD (Reviewer's

Initials)DOCUMENT NAME: G:\DRS\Tl-183

Inspection

Reports\FITZ

Tl-183 lR 2011008.docx

After declaring

this document "An Official Agency Record" it will be released to the Public.To racaiva a convof this document.

indicate in the box: "C" = Coov without attachmenVenclosure

'E" = Copy with attachmenVenclosure "N" o receive a coov of this document.

indicate in the box: "C" =Wthoutattachmenvendosure "E" wtn OFFICE RI/DRP RI/DRS RI/DRP RI/DRS NAME EKnutson Via email WSchmidUCGC

MGray/BB LDoerfleiniLTD

DATE 5t13t11 5113111 5113111 5t13t11 OFFICIAL RECORD COPY

K. Bronson Distribution

w/encl: W. Dean, RA D. Lew, DRA D. Roberts, DRP J. Clifford, DRP C. Miller, DRS P. Wilson, DRS S. Bush-Goddard, Rl OEDO T. Kobetz, NRR, DIRS M. Gray, DRP B. Bickett, DRP S. McCarver, DRP M. Jennerich, DRP E. Knutson, DRP, SRI S. Rutenkroger, DRP, Rl K. Kolek, Resident OA D. Bearde, DRS RidsNrrPM

FitzPatrick

Resource RidsNrrDorlLpll

-1 Resource ROPreports

Resource 3

U. S. NUCLEAR REGULATORY

COMMISSION

REGION I Docket No: 50-333 License No: DPR-59 Report No: 05000333/2011008

Licensee:

Entergy Nuclear Northeast (Entergy)Facility:

James A. FitzPatrick

Nuclear Power Plant Location:

Scriba, New York Dates: April 18 through April 29, 2011 lnspectors:

E. Knutson, Senior Resident lnspector S. Rutenkroger, PhD, Resident lnspector Approved by: Lawrence T. Doerflein, Chief Engineering

Branch 2 Division of Reactor Safety Enclosure

lR 0500033312011008;

04/1812011 - 041291201

1; James A. FitzPatrick

Nuclear Power Plant;Temporary

Instruction

25151183 - Followup to the Fukushima

Daiichi Nuclear Station Fuel Damage Event.This report covers an announced

Temporary

lnstruction (Tl) inspection.

The inspection

was conducted

by two resident inspectors.

The NRC's program for overseeing

the safe operation

of commercial

nuclear power reactors is described

in NUREG-1649, "Reactor Oversight

Process," Revision 4, dated December 2006.INSPECTION

SCOPE The intent of the Tl is to provide a broad overview of the industry's

preparedness

for events that may exceed the current design basis for a plant. The focus of the Tl was on (1) assessing

the licensee's

capability

to mitigate consequences

from large fires or explosions

on site, (2) assessing

the licensee's

capability

to mitigate station blackout (SBO) conditions, (3) assessing

the licensee's

capability

to mitigate internal and external flooding events accounted

for by the station's

design, and (4) assessing

the thoroughness

of the licensee's

walkdowns

and inspections

of important

equipment

needed to mitigate fire and flood events to identify the potential

that the equipment's

function could be lost during seismic events possible for the site. lf necessary, a more specific followup inspection

will be performed

at a later date.INSPECTION

RESULTS All of the potential

issues and observations

identified

by this inspection

are contained

in this report. The NRC's Reactor Oversight

Process willfurther

evaluate any issues to determine

if they are regulatory

findings or violations.

Any resulting

findings or violations

will be documented

by the NRC in a separate report.Enclosure

03.01 Assess the licensee's

capability

to mitigate conditions

that result from beyond design basis events, typically

bounded by security threats, committed

to as part of NRC Security Order Section 8.5.b issued February 25, 2002, and severe accident management

guidelines

and as required by Titte 10 of the Code of Federal Regulations

(10 CFR) 50.54(hh).

Use lnspection

Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline.

lf lP 71111.05T

was recently performed

at the facility the inspector

should review the inspection

results and findings to identify any other potential

areas of inspection.

Particular

emphasis should be placed on strategies

related to the spent fuel pool. The inspection

should include, but not be limited to, an assessment

of any licensee actions to: Licensee Action Describe what the licensee did to test or inspect equipment.

a.Verify through test or inspection

that equipment

is available and functional.

Active equipment

shall be tested and passive equipment

shall be walked down and inspected.

lt is not expected that permanently

installed equipment

that is tested under an existing regulatory

testing program be retested.This review should be done for a reasonable

sample of mitigating

strategies/eq

uipment.FitzPatrick

personnel

reviewed the B.5.b equipment

inspection

and testing preventive

maintenance

tasks to ensure that the tasks were up to date and the equipment

was available

and functional.

ln addition, they inventoried

the equipment

and materials

staged to support the B.S.b strategies

per the applicable

procedures.

FitzPatrick

personnel

also inventoried

SAMG (at FitzPatrick, titled Severe Accident Operating

Guidelines, or SAOGs) support equipment

per surveillance

procedure

ST-99C, "Safe Shutdown Equipment

Inventory

and Panel Operability

Verification." Portable equipment

such as the site fire pumper truck and portable radios were tested to verify readiness.

The 8.5.b and SAMG procedures

were verified current and staged in the appropriate

locations.

Describe inspector

actions taken to confirm equipment

readiness (e.9., observed a test, reviewed test results, discussed

actions, reviewed records, etc.).The inspectors

evaluated

the adequacy of installed

and portable equipment

staged explicitly

for implementation

of the mitigation

strategies.

The types of equipment

examined included:

interior fire water pumps, supply piping, and hose stations;

the site fire pumper truck and associated

suction and discharge

hoses, adapters, and tools; portable radios and communications

devices;and equipment

lockers and associated

tools. The inspectors

review included field verification

and inventory

checks of standby and staged equipment, and compatibility

of the portable equipment with installed

systems. ln addition, the inspectors

evaluated

the staqinq/storaqe

locations

of 8,5.b Enclosure

related equipment

to ensure the survivability

and availability

of equipment.

Documents

reviewed are listed in the Attachment

to this report.Discuss general results including

corrective

actions by licensee.The licensee did not identify any deficiencies

of significance

as part of their equipment

checks.The licensee identified

several minor issues which they entered into their correction

action program.Based on the selected inspection

samples, reviews, and walkdowns

conducted, the inspector concluded

that the required equipment

was available

and functional.

Licensee Action Describe the licensee's

actions to verify that procedures

are in place and can be executed (e.9., walkdowns, demonstrations, tests, etc.).b. Verify through walkdowns

or demonstration

that procedures

to implement the strategies

associated

with 8.5.b and 10 CFR 50.54(hh)

are in place and are executable.

Licensees

may choose not to connect or operate permanently

To validate the adequacy of procedures

and strategies, FitzPatrick

personnel

performed walkdowns

of B.5.b strategies

contained

in Technical

Support Guideline (TSG)-12, "8.5.b Extreme Damage Scenario Mitigating

Strategies," and in the SAMGs. In addition, operations

department

personnel

performed

validations

of time critical operator actions for several activities, such as operation

of the site fire pumper truck, control room emergency

ventilation, and operation

of the reactor core isolation

cooling system without direct current power available.

Describe inspector

actions and the sample strategies

reviewed.

Assess whether procedures

were in place and could be used as intended.Enclosure

installed

equipment during this verification.

This review should be done for a reasonable

sample of mitigating

strateg ies/eq uipment.The inspectors

examined FitzPatrick's

established

guidelines

and implementing

procedures

for the B.5.b mitigation

strategies

and SAMGS. The inspectors

walked down selected mitigation

strategies

with a plant operator to assess: the adequacy and completeness

of the procedures;

familiarity

of operators

with the procedure

objectives

and specific guidance;

staging and compatibility

of equipment;

and the practicality

of the operator actions prescribed

by the procedures, consistent

with the postulated

scenarios.

Documents

reviewed are listed in the Attachment

to this report.Discuss general results including

corrective

actions by licensee.The licensee did not identify any deficiencies

of significance

as part of their check to verify that procedures

were in-place and executable.

The licensee identified

several minor issues which they entered into their correction

action program.Based on the selected inspection

samples, and the results of the reviews and walkdowns

as described

above, the inspectors

concluded

that procedures

to implement

the strategies

associated

with B.S.b and 10 CFR 50.54(hh)

were in place and were executable.

Licensee Action Describe the licensee's

actions and conclusions

regarding

training and qualifications

of operators and support staff.c. Verify the training and qualifications

of operators

and the support staff needed to implement

the procedures

and work instructions

are current for activities

related to FitzPatrick

conducts initial and continuing

B.5.b training, and verified that training was completed.

Additionally, FitzPatrick

personnel

verified that all required operations

personnel

have received initial and continuing

SAMG training.

Both 8.5.b and SAMG training is included in the continuing

training plan. FitzPatrick

personnel

reviewed training records and documentation

to ensure that the training was up to date and verified that there was a sufficient

number trained on-site personnel

to implement

the severe accident mitigation

guidelines.

Enclosure

Security Order Section B.5.b and severe accident management

guidelines

as required by 10 cFR 50.54 (hh).Describe inspector

actions and the sample strategies

reviewed to assess training and qualifications

of operators

and support staff.The inspectors

examined the periodic refresher

training provided to the Operation

Department

staff most likely to be tasked with the implementation

of the 8.5.b mitigation

strategies.

The inspectors'

review consisted

of examination

of training presentations, training records, and interviews

with station personnel.

The documents

reviewed are listed in the Attachment

to this report.Discuss general results including

corrective

actions by licensee.The licensee did not identify any training deficiencies

of signiflcance.

The licensee identified

several minor issues which they entered into their correction

action program.Based on the selected inspection

samples and reviews conducted, the inspector

concluded

that the training and qualifications

of operators

and the support staff needed to implement

the procedures

and work instructions

were current for activities

related to Security Order Section B.5.b and severe accident management

guidelines

as required by 10 CFR 50.54 (hh).Enclosure

Licensee Action Describe the licensee's

actions and conclusions

regarding

applicable

agreements

and contracts are in place.d.Verify that any applicable

agreements

and contracts

are in place and are capable of meeting the conditions

needed to mitigate the consequences

of these events.This review should be done for a reasonable

sample of mitigating

strateg ies/eq uipment.FitzPatrick

personnel

verified that agreements

with the municipalfire

departments, local law enforcement, emergency

management

offices, and other commitments

for support required to implement

the strategies, were in place and active. Additionally, FitzPatrick

personnel

verified their listing of resources

capable of providing

support equipment

to mitigate the consequences

of large fire or explosion

events, as specified

by TSG-11, "Additional

Resources

for Extreme Damage Events," were correct and current.For a sample of mitigating

strategies

involving

contracts

or agreements

with offsite entities, describe inspector

actions to confirm agreements

and contracts

are in place and current (e.9., confirm that offsite fire assistance

agreement

is in place and curent).The inspectors

verified that the licensee had in place current letters of agreement (LOA) with off-site agencies to provide assistance

in mitigation

strategies.

The inspectors

verified that several organizations

had equipment

with adequate lifting capability

to elevate a monitor or spray nozzle to allow spraying into the spent fuel pool. The documents

reviewed are listed in the Attachment

to this report.Discuss general results including

corrective

actions by licensee.The licensee did not identify any deficiencies

of significance.

The licensee identified

several minor issues which they entered into their correction

action program.Based on the selected inspection

samples and reviews conducted, the inspector

concluded

that applicable

agreements

and contracts

were in place and were capable of meeting the conditions

needed to mitigate the consequences

of these events.Enclosure

Licensee Action Document the conective

action report number and briefly summarize

problems noted by the licensee that have significant

potential

to prevent the success of any existing mitigating

strategy.e.Review any open corrective

action documents

to assess problems with mitigating

strategy implementation

identified

by the licensee.

Assess the impact of the problem on the mitigating

capability

and the remaining capability

that is not impacted.The inspector

reviewed numerous corrective

action documents

during this inspection, which are listed in the Attachment

to this report. In addition, NRC Resident Inspectors

conduct daily reviews of newly issued condition

reports. The inspector

reviewed all condition

reports identified

by the licensee during their recent self assessments

of 8.5.b mitigating

strategies.

The inspector evaluated

the licensee's

immediate

corrective

actions for the associated

condition

reports, and concluded

that the actions appeared to be reasonable.

The inspectors

determined

that the identified

issues would not impact successful

implementation

of a mitigating

strategy.03.02 Assess the licensee's

capability

to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Afternating

Current Power," and station design, is functional

and valid. Refer to Tl 25151120, "lnspection

of lmplementation

of Station Blackout Rule Multi-Plant

Action ltem A-22 as a guideline.

lt is not intended that Tt 25151120 be completely

reinspected.

The inspection

should include, but not be limited to, an assessment

of any licensee actions to: Licensee Action Describe the licensee's

actions to verify the adequacy of equipment

needed to mitigate an SBO event.Enclosure

a.Verify through walkdowns

and inspection

that all required materials

are adequate and properly staged, tested, and maintained.

The licensee performed

walkdowns

and visually inspected

the equipment

required to complete steps in AOP-49, "Station Blackout," AOP-49A, "Station Blackout in Cold Condition," and TSG-8,"Extending

Site Black-out

Coping Time, Starting an EDG/lnjecting

to Vesselwith

No DC Power Available." The licensee verified the referenced

equipment

was staged, available, and appeared to be in good working order.Describe inspector

actions to verify equipment

is available

and useable.The inspectors

assessed the licensee's

capability

to mitigate SBO conditions

by conducting

a review of the licensee's

walkdown activities.

In addition, the inspectors

selected a sample of equipment

utilized for mitigation

of an SBO and conducted

independent

walkdowns

of that equipment

to verify the equipment

was properly aligned and staged. The sample of equipment selected by the inspectors

included, but was not limited to, portable radios, tools used for lifting leads, portable lighting, vital area keys, tools for manual breaker operation, the portable diesel generator

and autotransformer, and an emergency

field flash jumper cable.The documents

reviewed are listed in the Attachment

to this report.Discuss general results including

corrective

actions by licensee.The licensee verified that SBO equipment

was ready to respond to an SBO event. The licensee identified

several minor issues which they entered into their correction

action program.Based on the selected inspection

samples, and the results of the reviews and walkdowns

as described

above, the inspector

concluded

that the required equipment

was available

and functional.

Enclosure

Licensee Action Describe the licensee's

actions to verify the capability

to mitigate an SBO event.b.Demonstrate

through walkdowns

that procedures

for response to an SBO are executable.

The licensee performed

a simulated

SBO scenario using the simulator, supported

by a walkthrough

of activities

in the plant, using the appropriate

SBO procedures.

The licensee validated

that the required timelines

were met, procedure

steps were executable, and operators executed steps as expected.Describe inspector

actions to assess whether procedures

were in place and could be used as intended.The inspectors

reviewed the licensee's

documentation

from the simulated

SBO scenario and verified that the required timelines

were met, procedure

steps were executable, and operators executed steps as expected.

The inspectors

walked through implementation

of AOP-49 with an operator, discussed

the performance

of each step, and verified that AOP-49 procedure

steps were executable.

The documents

reviewed are listed in the Attachment

to this report.Discuss general results including

corrective

actions by licensee.The required equipment

for coping and restoring

from an SBO consisted

of permanently

installed safety related equipment.

The licensee and the inspectors

did not identify any significant

deficiencies

with the equipment, and determined

the SBO procedures

were in place and executable.

The licensee identified

an apparent beyond design and licensing

basis vulnerability, in that current procedures

do not address hydrogen considerations

during primary containment

venting. This issue was documented

in CR-JAF-2011-01529.

As an immediate

corrective

action, the licensee revised TSG-9 to provide a caution for operators

to consider the presence of hydrogen.The inspectors

identified

a beyond design and licensing

bases vulnerability, in that FitzPatrick's

current licensing

basis did not require the plant to have a primary containment

torus air space hardened vent svstem as part of their Mark I containment

improvement

oroqram. The current Enclosure

licensed configuration

is a hard pipe from primary containment

to the suction of the standby gas treatment

system, which is located outside the reactor building in an adjacent building.

The NRC has established

an agency task force to conduct a near term evaluation

of the need for agency actions, which includes containment

venting, following

the events in Japan.The licensee identified

a vulnerability, in that AOP-49A contained

contingency

actions using the decay heat removal system in an attachment

that directed operators

to use normal operating procedures.

The normal operating

procedure

for starting decay heat removal included unnecessary

steps for a SBO situation

and did not include workable provisions

for starting decay heat removal with the system drained. The licensee initiated

immediate

corrective

actions to revise the procedure

and fabricate

an adaptor to connect a 1.5 inch fire hose to a 1 inch pipe thread fitting in order to fill the decay heat removal system using fire water, if necessary.

The licensee entered this issue into their corrective

action program as CR-JAF-2011-01674.

The inspector

reviewed the licensee's

immediate

and proposed corrective

actions, including

their assessment

and prioritization, and concluded

they were reasonable.

The inspectors

identified

several potential

procedure

enhancements

which could improve operator response, and communicated

these enhancements

to the licensee.03.03 Assess the licensee's

capability

to mitigate internal and external flooding events required by station design. Refer to lP 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate

Readiness

to Cope with External Flooding" as a guideline.

The inspection

should include, but not be limited to, an assessment

of any licensee actions to verify through walkdowns

and inspections

that all required materials

and equipment

are adequate and properly staged. These walkdowns

and inspections

shall include verification

that accessible

doors, barriers, and penetration

seals are functional.

Licensee Action Describe the licensee's

actions to verify the capability

to mitigate existing design basis flooding events.Enclosure

a. Verify through walkdowns

and inspection

that all required materials

are adequate and properly staged, tested, and maintained.

The licensee identified

equipment

and features required to mitigate internalflooding.

The licensee then conducted

walkdowns

of this equipment

to ensure it appeared adequate and verified design features matched conditions

described

in supporting

calculations, including

such features as bulkheads, water-tight

bellows, fire doors, sump pump covers and gaskets, pump timers, penetration

seals, floor drains, and relative elevations

of equipment

potentially

affected by flooding.Describe inspector

actions to verify equipment

is available

and useable. Assess whether procedures

were in place and could be used as intended.The inspectors

reviewed the Individual

Plant Examination

for External Events (IPEEE) and determined

that FitzPatrick

had been evaluated

as not susceptible

to an externalflooding

event.The inspectors

reviewed data available

from the National Geophysical

Data Center and verified that historical

information

indicated

a maximum recorded tsunami event, or run-up, on Lake Ontario of five feet (and on all the Great Lakes a maximum of nine feet on Lake Erie). The inspector

also determined

that the maximum probable water level of Lake Ontario was calculated

to be 252.5 feet, and the ground level elevation

at FitzPatrick

was 279 feet.The inspectors

reviewed the licensee's

self assessment

actions and performed

independent

walkdowns

of various plant areas to ensure the licensee's

identified

list was comprehensive.

The inspectors

examined accessible

features to ensure the physical conditions

and measurements

appeared adequate.

The equipment

inspected

included bulkheads, floor drains, fire doors, door sills, dampers, penetration

seals, room volumes, and equipment

elevations.

The inspectors

verified that no material, tools, or equipment

of a portable or staged manner appeared to be required in order to cope with internal flooding.Discuss general results including

corrective

actions by licensee.The inspectors

determined

that, in general, all required materials

were adequate and properly staged, tested, and maintained

to respond to an internalflood

within the plant's design basis.While this effort did not identify any operability

or significant

concerns, the licensee found issues with desiqn information

for internalfloodinq

in the control room chiller room and the insoector Enclosure

questioned

design assumptions

for internal flooding in the EDG switchgear

rooms. The licensee initiated

condition

reports to assess and resolve licensee and inspector

identified

issues, as listed in the Attachment

to this report. The inspectors

reviewed the associated

condition

reports, and determined

the licensee's

initial responses, including

their assessment

and prioritization, were appropriate.

Since the maximum design basis externalflood

water level was at least ten feet below the ground level elevation

of the facility, the inspectors

concluded

that the plant did not appear to have any external flood vulnerabilities.

The inspectors

concluded

that the licensee meets the current design and licensing

basis for flood protection.

03.04 Assess the thoroughness

of the licensee's

walkdowns

and inspections

of important

equipment

needed to mitigate fire and flood events to identify the potential

that the equipment's

function could be lost during seismic events possible for the site. Assess the licensee's

development

of any new mitigating

strategies

for identified

vulnerabilities (e.9., entered it in to the corrective

action program and any immediate

actions taken). As a minimum, the licensee should have performed

walkdowns

and inspections

of important

equipment (permanent

and temporary)

such as storage tanks, plant water intake structures, and fire and flood response equipment;

and developed

mitigating

strategies

to cope with the loss of that important

function.

Use lP 71111.21, "Component

Design Basis lnspection," Appendix 3, "Component

Walkdown Considerations," as a guideline

to assess the thoroughness

of the licensee's

walkdowns

and inspections.

Licensee Action Describe the licensee's

actions to assess the potential

impact of seismic events on the availability

of equipment

used in fire and floodinq mitiqation

strateqies.

Enclosure

a.Verify through walkdowns

that all required materials

are adequate and properly staged, tested, and maintained.

The licensee tabulated

a list of equipment

available

to mitigate fire and flood events and identified

whether the equipment

was seismically

classified.

For equipment

not classified

as seismic, but appearing

more rugged in design, the licensee used engineering

judgment to determine

whether or not the equipment

was likely to survive a seismic event. The licensee described

an overall mitigating

strategy for fires as relying upon either the fire engine pumper truck or a seismically

designed portion of the fire protection

system, consisting

of the west diesel fire pump and a portion of the fire water header inner loop.No mitigating

measures were identified

or needed to address a postulated

external flood event.AOP-S1, "Unexpected

Fire Pump Start," Revision 5 provided guidance for dealing with internal flooding due to a fire main leak or rupture, such as from seismically

induced fire main pipe breaks.Describe inspector

actions to verify equipment

is available

and useable. Assess whether procedures

were in place and could be used as intended.The inspectors

walked down all fire protection

features and equipment

designated

for mitigating

strategies

in the event installed

fire protection

systems do not survive a seismic event. This designated

equipment

included the west diesel fire pump, a portion of the fire water header inner loop, fire hose stations supplied from the portion of inner loop, the fire engine pumper truck and accessories, wheeled carbon dioxide extinguishers, fire fighting foam trailer, and other portable extinguishing

equipment.

The inspectors

also walked down and examined internalflood

event vulnerabilities

and design features that would mitigate the consequences

of internal flooding and reviewed AOP-51.Discuss general results including

corrective

actions by licensee.

Briefly summarize

any new mitigating

strategies

identified

by the licensee as a result of their reviews.The licensee did not identify any deficiencies

of significance.

The licensee identified

several minor issues or beyond licensinq

basis vulnerabilities

which they entered into their corrective

action Enclosure

program. The inspectors

reviewed the associated

condition

reports, and determined

the licensee's

initial responses, including

their assessment

and prioritization, were appropriate.

The licensee did not identify any new or additional

mitigating

strategies

beyond those identified

above. The inspectors

observed that significant

areas of the plant would have reduced fire fighting capability

following

a design basis seismic event since the majority of the fire water system is not seismically

qualified, nor likely to survive such an event. In addition, internalflooding

caused by ruptures following

a design basis seismic event would require operators

to walkdown areas, identify the source(s), and take prompt actions to secure the source(s)

of flooding.Postulating

a design basis seismic event followed by significant

fire(s) and/or internal flooding, the limited number of on-shift personnel

would be challenged

to complete the needed mitigation

actions. In particular, the fire brigade consists of on-shift operations

personnel

and is capable of dealing with a single fire only while maintaining

minimum control room staffing.The inspectors

identified

a minor deficiency

in the fire protection

program. The licensee had not implemented

vendor recommended

periodic fire fighting foam concentrate

testing for on-site portable fire fighting foam tanks. The licensee entered this issue into their corrective

action program as CR-JAF-2011-02336, and initiated

a preventive

maintenance

task request to implement

an annual foam sample test and ensure the tanks remain filled.The inspectors

identified

severaladditional

beyond design and licensing

basis vulnerabilities

and communicated

those issues to the licensee.Enclosure

Meetinqs 4OAO Exit Meetinq The inspectors

presented

the inspection

results to Mr. B. Sullivan and other members of licensee management

at the conclusion

of the inspection

on April 29,2011. Propriety information

reviewed by the inspectors

during the inspection

was returned to the licensee.

The inspectors

verified the inspection

report does not contain proprietary

information.

14 Enclosure

A-1 SUPPLEMENTAL

INFORMATION

KEY POINTS OF CONTACT Licensee B. Sullivan, General Manager, Plant Operations

B. Finn, Director Nuclear Safety Assurance C. Adner, Manager Operations

J. Barnes, Manager, Training and Development

M. Reno, Manager Maintenance

P. Cullinan, Manager, Emergency

Preparedness

J. Pechacek, Licensing

Manager E. Dorman, Senior Licensing

Engineer R. Sullivan, Assistant

Manager, Plant Operations

D. Poulin, Manager, System Engineering

F. Lukaczyk, Assistant

Manager, Plant Operations

D. Ruddy, Supervisor, Engineering

A. Barton, Senior Engineer D. Stokes, Senior Engineer D. Koelbel, Senior Engineer D. Burch, Senior Staff Engineer Nuclear Requlatorv

Commission

C. Cahill, Senior Reactor Analyst W. Cook, Senior Reactor Analyst W. Schmidt, Senior Reactor Analyst Other G. Tarbell, Fire Protection

Specialist, Bureau of Fire Protection

P. Eddy, Utility Supervisor, New York State Department

of Public Service LIST OF DOCUMENTS

REVIEWED The following

is a list of documents

reviewed during the inspection.

Inclusion

on this list does not imply that the NRC inspectors

reviewed the documents

in their entirety but rather that selected sections of portions of the documents

were evaluated

as part of the overall inspection

effort. lnclusion

of a document on this list does not imply NRC acceptance

of the document or any part of it, unless this is stated in the body of the inspection

report.Attachment

A-2 03.01 Assess the licensee's

capability

to mitigate conditions

that result from beyond design basis events Procedures:

AOP-13, High Winds, Hurricanes, and Tornadoes, Rev. 19 EAP-13, Damage Control, Rev. 19 EP-10, Fire Water Crosstie to RHRSW Loop'A'When

Directed by EOP-4 or SAOGS, Rev. 1 EP-11, Alternate

Depressurization

Using SRVs from 02ADS-71, Rev. 1 EP-12,lsolating

RBCLC Supply to the Drywell, Rev. 0 EP-13, RPV Venting, Rev. 2 EP-14, Alternate

Containment

Sprays, Rev. 3 EP-z, lsolation/lnterlock

Overrides, Rev. 7 EP-3, Backup Control Rod Insertion, Rev. I EP-4, Boron Injection

Using CRD System, 2 EP-6, Post Accident Containment

Venting and Gas Control, Rev. 9 EP-7, Primary Containment

Flooding, Rev. 5 EP-g, Opening MSlVs, Rev.3 SAOG-1a, RPV and PC Flooding, RPV Breach, Rev. 3 SAOG-1b, RPV and PC Flooding, RPV Level above TAF, Rev. 2 SAOG-1c, RPV and PC Flooding, RPV Level above BAF, Rev. 2 SAOG-1d, RPV and PC Flooding, RPV Injection

above MRDIR, Rev. 2 SAOG-1e, RPV and PC Flooding, Parameters

within PSP, Rev. 2 SAOG-1f, RPV and PC Flooding, Parameters

outside PSP, Rev. 2 SAOG-2, RPV, Containment, and Radioactivity

Release Control, Rev. 3 SAP-3, Emergency

Communications

Testing, Rev. 80 ST-76E, Quarterly

Fire Hose Station Inspections, Rev. 16 ST-99C, Safe Shutdown Equipment

lnventory

and Panel Operability

Verification, Rev. 31 TSG-11, Additional

Resources

for Extreme Damage Events, Rev. 2 TSG-12, 8.5.b Extreme Damage Scenario Mitigating

Strategies, Rev. 3 TSG-6, Extending

Site Blackout Coping Time, Starting an EDG/ Injecting

to Vesselwith

no DC Power Available, Rev. 3 TSG-9, Primary Containment

Venting without AC Power, Rev. 3 Condition

Reports: CR-JAF-2Q11-01443, Fukushima

Daiichi Nuclear Station Fuel Damage Event, Rev. 0 CR-JAF-2011-01528,lmprove

Staging for lnterlock

Override Keys, Rev. 0 CR-JAF-2g11-01529, TSG-9 does not Address Hydrogen Considerations

during Primary Containment

Venting, Rev. 0 CR-JAF-201

1-01531 , TSGs are not Listed in the Operations

Task List or Operations

Qualification

Documents, Rev. 0 CR-JAF-2011-01532, No Operations

Training for Portions of EP-6 and EP-3, Rev. 0 CR-JAF-2Q11-01955, Minor Discrepancies

with Labeling and Equipment

Access Noted during EOP and SAOG Walkdowns, Rev. 0 Attachment

A-3 03.02 Assess the licensee's

capability

to mitigate station blackout (SBO) conditions

Procedures:

AOP-49, Station Blackout, Rev. 17 AOP-49A, Station Blackout in Cold Condition, Rev. 7 FE-14A, Wiring Diagram Emergency

Diesel Generator

93EDG-A System 93, Rev. 18 OP-30, Fuel Pool Cooling and Clean-Up System, Rev. 38 OP-30A, Refueling

Water Level Control, Rev. 14 OP-4, Circulating

Water System, Rev. 68 ST-28, Portable Diesel Generator

Operability

Test, Rev. 7 ST-99C, Safe Shutdown Equipment

lnventory

and Panel Operability

Verification, Rev. 31 TSG-8, Extending

Site Blackout Coping Time, Starting and EDG/lnjecting

to Vesselwith

no DC Power Available, Rev. 3 Calculations/Evaluations:

JAF-CALC-ELEC-02609, 125V DC Station Battery'A'Sizing

and Voltage Drop, 2 Condition

Reports: CR-JAF-2011-01528, Emergency

Keys for EP and AOP Actions should be More Accessible

and Should be Inventoried

as Part of Surveillances , Rev. 0 CR-JAF-2011-01660, Handheld Lanterns Listed as Located in a Fire Brigade LockerWhich

does not Exist at that Location, Rev. 0 CR-JAF-2g11-01674, AOP-49A and AOP-498 Refer to Using Decay Heat Removal Utilizing Normal Operating

Procedures

which are not Optimum, Rev. 0 CR-JAF-2O11-01680, No Preventive

Maintenance

Program could be Found for the Auto-transformer, Rev. 0 Other: File No. 11825-1.12-23A, Data Sheet - Emergency

Generator, 12110170 File No. 1.12-41, Schematic

Diagram Static Exciter and Voltage Regulator

Emergency

Diesel Generator, Rev.7 Simulator

Scenario 70275-1-LOl, AOP-49, Station Blackout, 3118111 WO 52282143, Portable Diesel Generator

Operability

Test, 3/15/11 WO 52301195, Perform Freshening

Charge and Voltage Checks, 3118111 03.03 Assess the licensee's

capability

to mitigate internal and external flooding events required by station design Procedures:

ESP-50.001, Floor Drain Flow Test, Rev. 1 Attachment

A-4 Calculations/Evaluations:

SWEC Calculation

14620.9015-US(N)-001-0, Evaluation

of lmpact of Flooding Inside Emergency

Diesel Generator

Rooms on Safety-Related

Equipment, Rev. 0 SWEC Calculation

14620-8-9017-1, Potential

Flooding lmpactfor

EDG Room Sprinkler Actuation

with Floor Drains Plugged and Two Equipment

Drains Opened and all Floor Drains Opened, Rev. 2 Condition

Reports: CR-JAF-2O11-01762, Flooding Calculation

for the Control Room Chiller Room Contains Discrepancies

with Respect to Actual Room Conditions, Rev. 0 Other: DBD-076 Tab 1, Design Basis Document for Fire Protection

076, System Water Supply and Distribution

System, Rev. 4 03.04 Assess the thoroughness

of the licensee's

walkdowns

and inspections

of important

equipment

needed to mitigate fire and flood events to identify the potential

that the equipment's

function could be lost during seismic events Procedures:

AOP-14, Earthquake, Rev. 13 AOP-28, Operation

During Plant Fires, Rev. 18 AOP-49, Station Blackout, Rev. 17 AOP-49A, Station Blackout in Cold Condition, Rev. 7 ESP-50.001, Floor Drain Flow Test, Rev. 1 FPP-1.13, Fire Brigade Equipment

Inventory, Rev.0 FPP-3.49, Fire Protection

Equipment

Inspection, Rev. 0 FPP-3.50, Fire Engine Inspection, Rev. 0 OP-30, Fuel Pool Cooling and Clean-Up System, Rev. 38 OP-30A, Refueling

Water Level Control, Rev. 14 OP-4, Circulating

Water System, Rev. 68 ST-28, Portable Diesel Generator

Operability

Test, Rev. 7 ST-99C, Safe Shutdown Equipment

Inventory

and Panel Operability

Verification, Rev. 31 TSG-8, Extending

Site Blackout Coping Time, Starting and EDG/lnjecting

to Vesselwith

no DC Power Available, Rev. 3 Condition

Reoorts: CR-JAF-2O11-01443, Fukushima

Daiichi Nuclear Station Fuel Damage Event, Rev. 0 CR-JAF-2O11-02336, Portable Foam Tanks Lack Vendor Recommended

PM, Rev. 0 LO-WTJAF-2011-0112, Tracking of Potential

Enhancements

ldentified

during the Response to Recommendation

4, Rev. 0 Attachment

A-5 Other: DBD-076 Tab 1, Design Basis Document for Fire Protection

076 System Water Supply and Distribution

System,4 AC ADAMS CA CFR CR EDG EOP 1P IPEEE LOA NRC PAR SAMG SAOG SBO SFP SRV TI TSG LIST OF ACRONYMS USED Alternating

Current Agencywide

Documents

Access and Management

System Corrective

Action Code of Federal Regulations

Condition

Report Emergency

Diesel Generator Emergency

Operating

Proced ure Inspection

Procedure lndividual

Plant Examination

of External Events Letter of Agreement Nuclear Regulatory

Commission

Publically

Available

Record Severe Accident Mitigation

Guideline Severe Accident Operating

Guideline Station Blackout Spent Fuel Pool Safety/Relief

Valve Temporary

Instruction

Technical

Support Guideline Attachment