ML111330455
| 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: |
| References | |
| IR-11-008 | |
| Download: ML111330455 (25) | |
See also: IR 05000333/2011008
Text
UNITED STATESN UCLEAR REGULATORY COMMISSIONREGION I475 ALLENDALE ROADKlNG OF PRUSSlA. PA 19406-1415May 13, 20LLMr. Kevin BronsonSite Vice PresidentEntergy Nuclear NortheastJames A. FitzPatrick Nuclear Power PlantP. O. Box 110Lycoming, NY 13093SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC TEMPOMRYINSTRUCTTON 251 5/1 83 TNSPECTION REPORT 05000333/201 1008Dear Mr. Bronson:On April 29,2011, the U.S. Nuclear Regulatory Comlnission (NRC) completed an inspection atyour James A. Fitzpatrick Nuclear Power Plant (FitzPatrick), using T_emporary_lnstruction2SlSlgg,"Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." Theenclosed 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 respondto extriordinary consequences similar io those that have recently occurred at the JapaneseFukushima Daiichi Nuclear Station. The results from this inspection, along with the results fromthis inspection performed at other operating commercial nuclear plants in the United States willbe used to evaluate the United States nuclear industry's readiness to safely respond to similarevents. These results will also help the NRC to determine if additional regulatory actions arewarranted.All of the potential issues and observations identified by this inspection are contained in thisreport. The NRC's Reactor Oversight Process will further evaluate any issues to determine ifthey are regulatory findings or violations. Any resulting findings or violations will be documentedny ine nnj in a sLparate report. You are not required to respond to this letter.
K. Bronson 2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be made available electronically for public inspection in the NRCPublic Document Room or from the Publicly Available Records (PARS) component ofNRC's document system (ADAMS), accessible from the NRC Web site athttp:l/www.nrc.oovlreadinq-rmladams.html (the Public Electronic Reading Room).Sincerely,\-0 1C\Slor"r.l---^" l ' tLawrence T. Doerflein, ChiefEngineering Branch 2Division of Reactor SafetyDocket No.: 50-333License No.: DPR-59Enclosure: lnspection Report 05000333/2011008cc w/encl: Distribution via ListServ
K. Bronson 2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be made available electronically for public inspection in the NRCPublic Document Room or from the Publicly Available Records (PARS) component ofNRC's document system (ADAMS), accessible from the NRC Web site athttp:llwww.nrc.oov/readino-rm/adams.html (the Public Electronic Reading Room).Sincerely,/RNLawrence T. Doerflein, ChiefEngineering Branch 2Division of Reactor SafetyDocket No.: 50-333License No.: DPR-59Enclosure: lnspection Report 05000333/201 1008cc w/encl: Distribution via ListServADAMS PACKAGE: M1111300168ADAMS DOCUMENT ACCESSION: MLl11330455SUNSI Review Complete: LTD (Reviewer's Initials)DOCUMENT NAME: G:\DRS\Tl-183 Inspection Reports\FITZ Tl-183 lR 2011008.docxAfter 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"wtnOFFICE RI/DRPRI/DRSRI/DRPRI/DRSNAME EKnutsonVia emailWSchmidUCGCMGray/BBLDoerfleiniLTDDATE 5t13t11511311151131115t13t11OFFICIAL RECORD COPY
K. BronsonDistribution w/encl:W. Dean, RAD. Lew, DRAD. Roberts, DRPJ. Clifford, DRPC. Miller, DRSP. Wilson, DRSS. Bush-Goddard, Rl OEDOT. Kobetz, NRR, DIRSM. Gray, DRPB. Bickett, DRPS. McCarver, DRPM. Jennerich, DRPE. Knutson, DRP, SRIS. Rutenkroger, DRP, RlK. Kolek, Resident OAD. Bearde, DRSRidsNrrPM FitzPatrick ResourceRidsNrrDorlLpll -1 ResourceROPreports Resource3
U. S. NUCLEAR REGULATORY COMMISSIONREGION IDocket No: 50-333License No: DPR-59Report No: 05000333/2011008Licensee: Entergy Nuclear Northeast (Entergy)Facility: James A. FitzPatrick Nuclear Power PlantLocation: Scriba, New YorkDates: April 18 through April 29, 2011lnspectors: E. Knutson, Senior Resident lnspectorS. Rutenkroger, PhD, Resident lnspectorApproved by: Lawrence T. Doerflein, ChiefEngineering Branch 2Division of Reactor SafetyEnclosure
lR 0500033312011008; 04/1812011 - 041291201 1; James A. FitzPatrick Nuclear Power Plant;Temporary Instruction 25151183 - Followup to the Fukushima Daiichi Nuclear Station FuelDamage Event.This report covers an announced Temporary lnstruction (Tl) inspection. The inspection wasconducted by two resident inspectors. The NRC's program for overseeing the safe operation ofcommercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"Revision 4, dated December 2006.INSPECTION SCOPEThe intent of the Tl is to provide a broad overview of the industry's preparedness for events thatmay exceed the current design basis for a plant. The focus of the Tl was on (1) assessing thelicensee'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 eventsaccounted for by the station's design, and (4) assessing the thoroughness of the licensee'swalkdowns and inspections of important equipment needed to mitigate fire and flood events toidentify the potential that the equipment's function could be lost during seismic events possiblefor the site. lf necessary, a more specific followup inspection will be performed at a later date.INSPECTION RESULTSAll of the potential issues and observations identified by this inspection are contained in thisreport. The NRC's Reactor Oversight Process willfurther evaluate any issues to determine ifthey are regulatory findings or violations. Any resulting findings or violations will be documentedby 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 bysecurity threats, committed to as part of NRC Security Order Section 8.5.b issued February 25, 2002, and severe accidentmanagement guidelines and as required by Titte 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use lnspectionProcedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. lf lP 71111.05T was recentlyperformed at the facility the inspector should review the inspection results and findings to identify any other potential areas ofinspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but notbe limited to, an assessment of any licensee actions to:Licensee ActionDescribe what the licensee did to test or inspect equipment.a.Verify through test orinspection thatequipment is availableand functional. Activeequipment shall betested and passiveequipment shall bewalked down andinspected. lt is notexpected thatpermanently installedequipment that is testedunder an existingregulatory testingprogram be retested.This review should bedone for a reasonablesample of mitigatingstrategies/eq uipment.FitzPatrick personnel reviewed the B.5.b equipment inspection and testing preventivemaintenance tasks to ensure that the tasks were up to date and the equipment was available andfunctional. ln addition, they inventoried the equipment and materials staged to support the B.S.bstrategies per the applicable procedures. FitzPatrick personnel also inventoried SAMG (atFitzPatrick, titled Severe Accident Operating Guidelines, or SAOGs) support equipment persurveillance procedure ST-99C, "Safe Shutdown Equipment Inventory and Panel OperabilityVerification." Portable equipment such as the site fire pumper truck and portable radios weretested to verify readiness. The 8.5.b and SAMG procedures were verified current and staged inthe appropriate locations.Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewedtest results, discussed actions, reviewed records, etc.).The inspectors evaluated the adequacy of installed and portable equipment staged explicitly forimplementation of the mitigation strategies. The types of equipment examined included: interiorfire water pumps, supply piping, and hose stations; the site fire pumper truck and associatedsuction and discharge hoses, adapters, and tools; portable radios and communications devices;and equipment lockers and associated tools. The inspectors review included field verification andinventory checks of standby and staged equipment, and compatibility of the portable equipmentwith installed systems. ln addition, the inspectors evaluated the staqinq/storaqe locations of 8,5.bEnclosure
related equipment to ensure the survivability and availability of equipment. Documents reviewedare 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 actionprogram.Based on the selected inspection samples, reviews, and walkdowns conducted, the inspectorconcluded that the required equipment was available and functional.Licensee ActionDescribe the licensee's actions to verify that procedures are in place and can be executed (e.9.,walkdowns, demonstrations, tests, etc.).b. Verify throughwalkdowns ordemonstration thatprocedures to implementthe strategies associatedwith 8.5.b and 10 CFR50.54(hh) are in placeand are executable.Licensees may choosenot to connect oroperate permanentlyTo validate the adequacy of procedures and strategies, FitzPatrick personnel performedwalkdowns of B.5.b strategies contained in Technical Support Guideline (TSG)-12, "8.5.b ExtremeDamage Scenario Mitigating Strategies," and in the SAMGs. In addition, operations departmentpersonnel performed validations of time critical operator actions for several activities, such asoperation of the site fire pumper truck, control room emergency ventilation, and operation of thereactor core isolation cooling system without direct current power available.Describe inspector actions and the sample strategies reviewed. Assess whether procedures werein place and could be used as intended.Enclosure
installed equipmentduring this verification.This review should bedone for a reasonablesample of mitigatingstrateg ies/eq uipment.The inspectors examined FitzPatrick's established guidelines and implementing procedures for theB.5.b mitigation strategies and SAMGS. The inspectors walked down selected mitigationstrategies with a plant operator to assess: the adequacy and completeness of the procedures;familiarity of operators with the procedure objectives and specific guidance; staging andcompatibility of equipment; and the practicality of the operator actions prescribed by theprocedures, consistent with the postulated scenarios. Documents reviewed are listed in theAttachment 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 thatprocedures were in-place and executable. The licensee identified several minor issues which theyentered into their correction action program.Based on the selected inspection samples, and the results of the reviews and walkdowns asdescribed above, the inspectors concluded that procedures to implement the strategies associatedwith B.S.b and 10 CFR 50.54(hh) were in place and were executable.Licensee ActionDescribe the licensee's actions and conclusions regarding training and qualifications of operatorsand support staff.c. Verify the training andqualifications ofoperators and thesupport staff needed toimplement theprocedures and workinstructions are currentfor activities related toFitzPatrick conducts initial and continuing B.5.b training, and verified that training was completed.Additionally, FitzPatrick personnel verified that all required operations personnel have receivedinitial and continuing SAMG training. Both 8.5.b and SAMG training is included in the continuingtraining plan. FitzPatrick personnel reviewed training records and documentation to ensure thatthe training was up to date and verified that there was a sufficient number trained on-sitepersonnel to implement the severe accident mitigation guidelines.Enclosure
Security Order SectionB.5.b and severeaccident managementguidelines as required by10 cFR 50.54 (hh).Describe inspector actions and the sample strategies reviewed to assess training andqualifications of operators and support staff.The inspectors examined the periodic refresher training provided to the Operation Departmentstaff most likely to be tasked with the implementation of the 8.5.b mitigation strategies. Theinspectors' review consisted of examination of training presentations, training records, andinterviews 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 identifiedseveral minor issues which they entered into their correction action program.Based on the selected inspection samples and reviews conducted, the inspector concluded thatthe training and qualifications of operators and the support staff needed to implement theprocedures and work instructions were current for activities related to Security Order Section B.5.band severe accident management guidelines as required by 10 CFR 50.54 (hh).Enclosure
Licensee ActionDescribe the licensee's actions and conclusions regarding applicable agreements and contractsare in place.d.Verify that anyapplicable agreementsand contracts are inplace and are capable ofmeeting the conditionsneeded to mitigate theconsequences of theseevents.This review should bedone for a reasonablesample of mitigatingstrateg ies/eq uipment.FitzPatrick personnel verified that agreements with the municipalfire departments, local lawenforcement, emergency management offices, and other commitments for support required toimplement the strategies, were in place and active. Additionally, FitzPatrick personnel verifiedtheir listing of resources capable of providing support equipment to mitigate the consequences oflarge fire or explosion events, as specified by TSG-11, "Additional Resources for ExtremeDamage 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 severalorganizations had equipment with adequate lifting capability to elevate a monitor or spray nozzleto allow spraying into the spent fuel pool. The documents reviewed are listed in the Attachment tothis report.Discuss general results including corrective actions by licensee.The licensee did not identify any deficiencies of significance. The licensee identified several minorissues which they entered into their correction action program.Based on the selected inspection samples and reviews conducted, the inspector concluded thatapplicable agreements and contracts were in place and were capable of meeting the conditionsneeded to mitigate the consequences of these events.Enclosure
Licensee ActionDocument the conective action report number and briefly summarize problems noted by thelicensee that have significant potential to prevent the success of any existing mitigating strategy.e.Review any opencorrective actiondocuments to assessproblems with mitigatingstrategy implementationidentified by thelicensee. Assess theimpact of the problem onthe mitigating capabilityand the remainingcapability that is notimpacted.The inspector reviewed numerous corrective action documents during this inspection, which arelisted in the Attachment to this report. In addition, NRC Resident Inspectors conduct daily reviewsof newly issued condition reports. The inspector reviewed all condition reports identified by thelicensee during their recent self assessments of 8.5.b mitigating strategies. The inspectorevaluated the licensee's immediate corrective actions for the associated condition reports, andconcluded that the actions appeared to be reasonable.The inspectors determined that the identified issues would not impact successful implementationof 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 AllAfternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation ofStation 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 ActionDescribe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBOevent.Enclosure
a.Verify throughwalkdowns andinspection that allrequired materials areadequate and properlystaged, tested, andmaintained.The licensee performed walkdowns and visually inspected the equipment required to completesteps 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 PowerAvailable." The licensee verified the referenced equipment was staged, available, and appearedto 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 areview of the licensee's walkdown activities. In addition, the inspectors selected a sample ofequipment utilized for mitigation of an SBO and conducted independent walkdowns of thatequipment to verify the equipment was properly aligned and staged. The sample of equipmentselected by the inspectors included, but was not limited to, portable radios, tools used for liftingleads, portable lighting, vital area keys, tools for manual breaker operation, the portable dieselgenerator 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 licenseeidentified 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 asdescribed above, the inspector concluded that the required equipment was available andfunctional.Enclosure
Licensee ActionDescribe the licensee's actions to verify the capability to mitigate an SBO event.b.Demonstrate throughwalkdowns thatprocedures for responseto an SBO areexecutable.The licensee performed a simulated SBO scenario using the simulator, supported by awalkthrough of activities in the plant, using the appropriate SBO procedures. The licenseevalidated that the required timelines were met, procedure steps were executable, and operatorsexecuted steps as expected.Describe inspector actions to assess whether procedures were in place and could be used asintended.The inspectors reviewed the licensee's documentation from the simulated SBO scenario andverified that the required timelines were met, procedure steps were executable, and operatorsexecuted steps as expected. The inspectors walked through implementation of AOP-49 with anoperator, discussed the performance of each step, and verified that AOP-49 procedure steps wereexecutable. 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 installedsafety related equipment. The licensee and the inspectors did not identify any significantdeficiencies with the equipment, and determined the SBO procedures were in place andexecutable.The licensee identified an apparent beyond design and licensing basis vulnerability, in that currentprocedures do not address hydrogen considerations during primary containment venting. Thisissue was documented in CR-JAF-2011-01529. As an immediate corrective action, the licenseerevised 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'scurrent licensing basis did not require the plant to have a primary containment torus air spacehardened vent svstem as part of their Mark I containment improvement oroqram. The currentEnclosure
licensed configuration is a hard pipe from primary containment to the suction of the standby gastreatment system, which is located outside the reactor building in an adjacent building. The NRChas established an agency task force to conduct a near term evaluation of the need for agencyactions, which includes containment venting, following the events in Japan.The licensee identified a vulnerability, in that AOP-49A contained contingency actions using thedecay heat removal system in an attachment that directed operators to use normal operatingprocedures. The normal operating procedure for starting decay heat removal includedunnecessary steps for a SBO situation and did not include workable provisions for starting decayheat removal with the system drained. The licensee initiated immediate corrective actions torevise the procedure and fabricate an adaptor to connect a 1.5 inch fire hose to a 1 inch pipethread fitting in order to fill the decay heat removal system using fire water, if necessary. Thelicensee entered this issue into their corrective action program as CR-JAF-2011-01674. Theinspector reviewed the licensee's immediate and proposed corrective actions, including theirassessment and prioritization, and concluded they were reasonable.The inspectors identified several potential procedure enhancements which could improve operatorresponse, 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 lP71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. Theinspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspectionsthat all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall includeverification that accessible doors, barriers, and penetration seals are functional.Licensee ActionDescribe the licensee's actions to verify the capability to mitigate existing design basis floodingevents.Enclosure
a. Verify throughwalkdowns andinspection that allrequired materials areadequate and properlystaged, tested, andmaintained.The licensee identified equipment and features required to mitigate internalflooding. The licenseethen conducted walkdowns of this equipment to ensure it appeared adequate and verified designfeatures matched conditions described in supporting calculations, including such features asbulkheads, water-tight bellows, fire doors, sump pump covers and gaskets, pump timers,penetration seals, floor drains, and relative elevations of equipment potentially affected byflooding.Describe inspector actions to verify equipment is available and useable. Assess whetherprocedures were in place and could be used as intended.The inspectors reviewed the Individual Plant Examination for External Events (IPEEE) anddetermined that FitzPatrick had been evaluated as not susceptible to an externalflooding event.The inspectors reviewed data available from the National Geophysical Data Center and verifiedthat historical information indicated a maximum recorded tsunami event, or run-up, on LakeOntario of five feet (and on all the Great Lakes a maximum of nine feet on Lake Erie). Theinspector also determined that the maximum probable water level of Lake Ontario was calculatedto 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 independentwalkdowns of various plant areas to ensure the licensee's identified list was comprehensive. Theinspectors examined accessible features to ensure the physical conditions and measurementsappeared adequate. The equipment inspected included bulkheads, floor drains, fire doors, doorsills, dampers, penetration seals, room volumes, and equipment elevations. The inspectorsverified that no material, tools, or equipment of a portable or staged manner appeared to berequired 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 properlystaged, 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 issueswith desiqn information for internalfloodinq in the control room chiller room and the insoectorEnclosure
questioned design assumptions for internal flooding in the EDG switchgear rooms. The licenseeinitiated condition reports to assess and resolve licensee and inspector identified issues, as listedin the Attachment to this report. The inspectors reviewed the associated condition reports, anddetermined the licensee's initial responses, including their assessment and prioritization, wereappropriate.Since the maximum design basis externalflood water level was at least ten feet below the groundlevel elevation of the facility, the inspectors concluded that the plant did not appear to have anyexternal flood vulnerabilities.The inspectors concluded that the licensee meets the current design and licensing basis for floodprotection.03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire andflood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assessthe licensee's development of any new mitigating strategies for identified vulnerabilities (e.9., entered it in to the corrective actionprogram and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections ofimportant equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood responseequipment; and developed mitigating strategies to cope with the loss of that important function. Use lP 71111.21, "ComponentDesign Basis lnspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of thelicensee's walkdowns and inspections.Licensee ActionDescribe the licensee's actions to assess the potential impact of seismic events on the availabilityof equipment used in fire and floodinq mitiqation strateqies.Enclosure
a.Verify throughwalkdowns that allrequired materials areadequate and properlystaged, tested, andmaintained.The licensee tabulated a list of equipment available to mitigate fire and flood events and identifiedwhether the equipment was seismically classified. For equipment not classified as seismic, butappearing more rugged in design, the licensee used engineering judgment to determine whetheror not the equipment was likely to survive a seismic event. The licensee described an overallmitigating strategy for fires as relying upon either the fire engine pumper truck or a seismicallydesigned portion of the fire protection system, consisting of the west diesel fire pump and a portionof 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 internalflooding 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 whetherprocedures were in place and could be used as intended.The inspectors walked down all fire protection features and equipment designated for mitigatingstrategies in the event installed fire protection systems do not survive a seismic event. Thisdesignated equipment included the west diesel fire pump, a portion of the fire water header innerloop, fire hose stations supplied from the portion of inner loop, the fire engine pumper truck andaccessories, wheeled carbon dioxide extinguishers, fire fighting foam trailer, and other portableextinguishing equipment. The inspectors also walked down and examined internalflood eventvulnerabilities and design features that would mitigate the consequences of internal flooding andreviewed AOP-51.Discuss general results including corrective actions by licensee. Briefly summarize any newmitigating strategies identified by the licensee as a result of their reviews.The licensee did not identify any deficiencies of significance. The licensee identified several minorissues or beyond licensinq basis vulnerabilities which they entered into their corrective actionEnclosure
program. The inspectors reviewed the associated condition reports, and determined thelicensee's initial responses, including their assessment and prioritization, were appropriate.The licensee did not identify any new or additional mitigating strategies beyond those identifiedabove. The inspectors observed that significant areas of the plant would have reduced firefighting capability following a design basis seismic event since the majority of the fire water systemis not seismically qualified, nor likely to survive such an event. In addition, internalfloodingcaused by ruptures following a design basis seismic event would require operators to walkdownareas, 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, thelimited number of on-shift personnel would be challenged to complete the needed mitigationactions. In particular, the fire brigade consists of on-shift operations personnel and is capable ofdealing 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 notimplemented vendor recommended periodic fire fighting foam concentrate testing for on-siteportable fire fighting foam tanks. The licensee entered this issue into their corrective actionprogram as CR-JAF-2011-02336, and initiated a preventive maintenance task request toimplement an annual foam sample test and ensure the tanks remain filled.The inspectors identified severaladditional beyond design and licensing basis vulnerabilities andcommunicated those issues to the licensee.Enclosure
Meetinqs4OAO Exit MeetinqThe inspectors presented the inspection results to Mr. B. Sullivan and other members oflicensee management at the conclusion of the inspection on April 29,2011. Proprietyinformation reviewed by the inspectors during the inspection was returned to thelicensee. The inspectors verified the inspection report does not contain proprietaryinformation.14Enclosure
A-1SUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicenseeB. Sullivan, General Manager, Plant OperationsB. Finn, Director Nuclear Safety AssuranceC. Adner, Manager OperationsJ. Barnes, Manager, Training and DevelopmentM. Reno, Manager MaintenanceP. Cullinan, Manager, Emergency PreparednessJ. Pechacek, Licensing ManagerE. Dorman, Senior Licensing EngineerR. Sullivan, Assistant Manager, Plant OperationsD. Poulin, Manager, System EngineeringF. Lukaczyk, Assistant Manager, Plant OperationsD. Ruddy, Supervisor, EngineeringA. Barton, Senior EngineerD. Stokes, Senior EngineerD. Koelbel, Senior EngineerD. Burch, Senior Staff EngineerNuclear Requlatorv CommissionC. Cahill, Senior Reactor AnalystW. Cook, Senior Reactor AnalystW. Schmidt, Senior Reactor AnalystOtherG. Tarbell, Fire Protection Specialist, Bureau of Fire ProtectionP. Eddy, Utility Supervisor, New York State Department of Public ServiceLIST OF DOCUMENTS REVIEWEDThe following is a list of documents reviewed during the inspection. Inclusion on this list doesnot imply that the NRC inspectors reviewed the documents in their entirety but rather thatselected sections of portions of the documents were evaluated as part of the overall inspectioneffort. lnclusion of a document on this list does not imply NRC acceptance of the document orany part of it, unless this is stated in the body of the inspection report.Attachment
A-203.01 Assess the licensee's capability to mitigate conditions that result from beyonddesign basis eventsProcedures:AOP-13, High Winds, Hurricanes, and Tornadoes, Rev. 19EAP-13, Damage Control, Rev. 19EP-10, Fire Water Crosstie to RHRSW Loop'A'When Directed by EOP-4 or SAOGS, Rev. 1EP-11, Alternate Depressurization Using SRVs from 02ADS-71, Rev. 1EP-12,lsolating RBCLC Supply to the Drywell, Rev. 0EP-13, RPV Venting, Rev. 2EP-14, Alternate Containment Sprays, Rev. 3EP-z, lsolation/lnterlock Overrides, Rev. 7EP-3, Backup Control Rod Insertion, Rev. IEP-4, Boron Injection Using CRD System, 2EP-6, Post Accident Containment Venting and Gas Control, Rev. 9EP-7, Primary Containment Flooding, Rev. 5EP-g, Opening MSlVs, Rev.3SAOG-1a, RPV and PC Flooding, RPV Breach, Rev. 3SAOG-1b, RPV and PC Flooding, RPV Level above TAF, Rev. 2SAOG-1c, RPV and PC Flooding, RPV Level above BAF, Rev. 2SAOG-1d, RPV and PC Flooding, RPV Injection above MRDIR, Rev. 2SAOG-1e, RPV and PC Flooding, Parameters within PSP, Rev. 2SAOG-1f, RPV and PC Flooding, Parameters outside PSP, Rev. 2SAOG-2, RPV, Containment, and Radioactivity Release Control, Rev. 3SAP-3, Emergency Communications Testing, Rev. 80ST-76E, Quarterly Fire Hose Station Inspections, Rev. 16ST-99C, Safe Shutdown Equipment lnventory and Panel Operability Verification, Rev. 31TSG-11, Additional Resources for Extreme Damage Events, Rev. 2TSG-12, 8.5.b Extreme Damage Scenario Mitigating Strategies, Rev. 3TSG-6, Extending Site Blackout Coping Time, Starting an EDG/ Injecting to Vesselwith no DCPower Available, Rev. 3TSG-9, Primary Containment Venting without AC Power, Rev. 3Condition Reports:CR-JAF-2Q11-01443, Fukushima Daiichi Nuclear Station Fuel Damage Event, Rev. 0CR-JAF-2011-01528,lmprove Staging for lnterlock Override Keys, Rev. 0CR-JAF-2g11-01529, TSG-9 does not Address Hydrogen Considerations during PrimaryContainment Venting, Rev. 0CR-JAF-201 1-01531 , TSGs are not Listed in the Operations Task List or OperationsQualification Documents, Rev. 0CR-JAF-2011-01532, No Operations Training for Portions of EP-6 and EP-3, Rev. 0CR-JAF-2Q11-01955, Minor Discrepancies with Labeling and Equipment Access Noted duringEOP and SAOG Walkdowns, Rev. 0Attachment
A-303.02 Assess the licensee's capability to mitigate station blackout (SBO) conditionsProcedures:AOP-49, Station Blackout, Rev. 17AOP-49A, Station Blackout in Cold Condition, Rev. 7FE-14A, Wiring Diagram Emergency Diesel Generator 93EDG-A System 93, Rev. 18OP-30, Fuel Pool Cooling and Clean-Up System, Rev. 38OP-30A, Refueling Water Level Control, Rev. 14OP-4, Circulating Water System, Rev. 68ST-28, Portable Diesel Generator Operability Test, Rev. 7ST-99C, Safe Shutdown Equipment lnventory and Panel Operability Verification, Rev. 31TSG-8, Extending Site Blackout Coping Time, Starting and EDG/lnjecting to Vesselwith no DCPower Available, Rev. 3Calculations/Evaluations:JAF-CALC-ELEC-02609, 125V DC Station Battery'A'Sizing and Voltage Drop, 2Condition Reports:CR-JAF-2011-01528, Emergency Keys for EP and AOP Actions should be More Accessible andShould be Inventoried as Part of Surveillances , Rev. 0CR-JAF-2011-01660, Handheld Lanterns Listed as Located in a Fire Brigade LockerWhichdoes not Exist at that Location, Rev. 0CR-JAF-2g11-01674, AOP-49A and AOP-498 Refer to Using Decay Heat Removal UtilizingNormal Operating Procedures which are not Optimum, Rev. 0CR-JAF-2O11-01680, No Preventive Maintenance Program could be Found for the Auto-transformer, Rev. 0Other:File No. 11825-1.12-23A, Data Sheet - Emergency Generator, 12110170File No. 1.12-41, Schematic Diagram Static Exciter and Voltage Regulator Emergency DieselGenerator, Rev.7Simulator Scenario 70275-1-LOl, AOP-49, Station Blackout, 3118111WO 52282143, Portable Diesel Generator Operability Test, 3/15/11WO 52301195, Perform Freshening Charge and Voltage Checks, 311811103.03 Assess the licensee's capability to mitigate internal and external flooding eventsrequired by station designProcedures:ESP-50.001, Floor Drain Flow Test, Rev. 1Attachment
A-4Calculations/Evaluations:SWEC Calculation 14620.9015-US(N)-001-0, Evaluation of lmpact of Flooding InsideEmergency Diesel Generator Rooms on Safety-Related Equipment, Rev. 0SWEC Calculation 14620-8-9017-1, Potential Flooding lmpactfor EDG Room SprinklerActuation with Floor Drains Plugged and Two Equipment Drains Opened and all FloorDrains Opened, Rev. 2Condition Reports:CR-JAF-2O11-01762, Flooding Calculation for the Control Room Chiller Room ContainsDiscrepancies with Respect to Actual Room Conditions, Rev. 0Other:DBD-076 Tab 1, Design Basis Document for Fire Protection 076, System Water Supply andDistribution System, Rev. 403.04 Assess the thoroughness of the licensee's walkdowns and inspections ofimportant equipment needed to mitigate fire and flood events to identify thepotential that the equipment's function could be lost during seismic eventsProcedures:AOP-14, Earthquake, Rev. 13AOP-28, Operation During Plant Fires, Rev. 18AOP-49, Station Blackout, Rev. 17AOP-49A, Station Blackout in Cold Condition, Rev. 7ESP-50.001, Floor Drain Flow Test, Rev. 1FPP-1.13, Fire Brigade Equipment Inventory, Rev.0FPP-3.49, Fire Protection Equipment Inspection, Rev. 0FPP-3.50, Fire Engine Inspection, Rev. 0OP-30, Fuel Pool Cooling and Clean-Up System, Rev. 38OP-30A, Refueling Water Level Control, Rev. 14OP-4, Circulating Water System, Rev. 68ST-28, Portable Diesel Generator Operability Test, Rev. 7ST-99C, Safe Shutdown Equipment Inventory and Panel Operability Verification, Rev. 31TSG-8, Extending Site Blackout Coping Time, Starting and EDG/lnjecting to Vesselwith no DCPower Available, Rev. 3Condition Reoorts:CR-JAF-2O11-01443, Fukushima Daiichi Nuclear Station Fuel Damage Event, Rev. 0CR-JAF-2O11-02336, Portable Foam Tanks Lack Vendor Recommended PM, Rev. 0LO-WTJAF-2011-0112, Tracking of Potential Enhancements ldentified during the Response toRecommendation 4, Rev. 0Attachment
A-5Other:DBD-076 Tab 1, Design Basis Document for Fire Protection 076 System Water Supply andDistribution System,4ACADAMSCACFRCREDGEOP1PIPEEELOANRCPARSAMGSAOGSBOSFPSRVTITSGLIST OF ACRONYMS USEDAlternating CurrentAgencywide Documents Access and Management SystemCorrective ActionCode of Federal RegulationsCondition ReportEmergency Diesel GeneratorEmergency Operating Proced ureInspection Procedurelndividual Plant Examination of External EventsLetter of AgreementNuclear Regulatory CommissionPublically Available RecordSevere Accident Mitigation GuidelineSevere Accident Operating GuidelineStation BlackoutSpent Fuel PoolSafety/Relief ValveTemporary InstructionTechnical Support GuidelineAttachment