ML111330455
| ML111330455 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/13/2011 |
| From: | Doerflein L Engineering Region 1 Branch 2 |
| To: | Bronson K Entergy Nuclear Northeast |
| Shared Package | |
| ML111300168 | List: |
| 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
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