IR 05000266/2011010

IR 05000266-11-010; 05000301-11-010, on 03/23/2011 - 04/19/2011, Point Beach Nuclear Plant, Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event

ML111320368
Person / Time
Site:	Point Beach
Issue date:	05/13/2011
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Meyer L Point Beach
References
IR-11-010
Download: ML111320368 (34)

Text

May 13, 2011

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/183, INSPECTION REPORT 05000266/2011-010; 05000301/2011-010

Dear Mr. Meyer:

On April 19, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Point Beach Nuclear Plant, Units 1 and 2, using Temporary Instruction 2515/183, Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event. The enclosed inspection report documents the inspection results which were discussed on April 19, 2011, with Mr. J. Costedio and other members of your staff.

The objective of this inspection was to promptly assess the capabilities of Point Beach Nuclear Plant to respond to extraordinary consequences similar to 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 U.S. nuclear industrys 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 NRCs 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 by the NRC in the next quarterly report. You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRCs 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 NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosure:

Inspection Report 05000266/2011-010; 05000301/2011-010

REGION III==

Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27 Report Nos: 05000266/2011-010; 05000301/2011-010 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: March 23 through April 19, 2011 Inspectors: P. Cardona-Morales, Reactor Engineer S. Burton, Senior Resident Inspector M. Thorpe-Kavanaugh, Resident Inspector Approved by: Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000266/2011-010; 05000301/2011-010, 03/23/2011 - 04/19/2011; Point Beach Nuclear

Plant Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.

This report covers an announced Temporary Instruction (TI) inspection. The inspection was conducted by Resident and Region III inspectors. The NRCs 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 TI is to provide a broad overview of the industrys preparedness for events that may exceed the current design basis for a plant. The focus of the TI was on

(1) assessing the licensees capability to mitigate consequences from large fires or explosions on site,

(2) assessing the licensees capability to mitigate station blackout (SBO) conditions,

(3) assessing the licensees capability to mitigate internal and external flooding events accounted for by the stations design, and

(4) assessing the thoroughness of the licensees walk downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. If necessary, a more specific follow-up 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 NRCs 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 by the NRC in the next quarterly report.

03.01 Assess the licensees 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 B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), Section 02.03 and 03.03 as a guideline. If IP 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 The licensee performed surveillance procedure 0-PT-FP-014, Z-935 Portable Diesel-Driven that equipment is available and Fire Water Pump Quarterly Functional Test, to verify functionality of the Z-935 portable functional. Active equipment diesel-driven fire water pump (B.5.b pump), which the licensee considered active shall be tested and passive equipment. The test verified the B.5.b pump functionality while connected to one of the equipment shall be walked down credited water sources by comparing pump design parameters to acceptance criteria.

and inspected. It is not expected that permanently The licensee also inventoried passive equipment and credited actions using procedure installed equipment that is 0-PT-FP-013, Quarterly Operations B.5.b Fire Equipment Inventory Report. The inventory tested under an existing verified that the tools and equipment for credited actions, including actions for spent fuel regulatory testing program be pool makeup, were adequate.

retested.

Additionally, the licensee reviewed the Extensive Damage Mitigation Guideline (EDMG) and This review should be done for a Severe Accident Mitigation Guideline (SAMG) procedures credited for B.5.b actions to verify reasonable sample of mitigating that permanently installed equipment, such as valves, equipment, and tools, were available strategies/equipment.

and accessible.

Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, reviewed test results, discussed actions, reviewed records, etc.).

The inspectors reviewed completed surveillance, 0-PT-FP-014, and the completed B.5.b fire equipment inventory report, O-PT-FP-013, to ensure that the procedures met the intended objectives. The inspectors review included an assessment of the B.5.b pump acceptance criteria and equipment requirements. The inspectors also observed portions of the performance of the procedures and observed the licensee during selected walkdowns of the procedures. These activities included hose and pump placement with respect to a credited water source.

The inspectors independently verified the material condition of the B.5.b pump and its components, including the engine and the air intake. The inspectors reviewed the licensees passive equipment list and verified the material condition of six hoses, related hose clamps, distribution fittings, and nozzles used to transfer water to the credited plant areas. The inspectors verified the material condition of the two trailers and vehicle used to transport the B.5.b pump and hoses. Additionally, the inspectors reviewed EDMG-2, Loss Of Large Areas Of The Plant Due To Fire Or Explosion, and SAMG SAG-4, Inject Into Containment, and verified that the designated permanently installed equipment, valves, and tools used or manipulated in the implementation of the procedures were available and in good material condition.

Discuss general results including corrective actions by licensee.

During the licensees testing and review, the licensee was able to demonstrate that the current licensing basis (CLB) of the equipment credited for B.5.b actions was met.

However, the licensee identified procedural and equipment enhancements. Items identified, corrective actions (CAs) taken by the licensee, and the licensee's corrective action program tracking number included:

• A lack of spare parts for the B.5.b pump. (AR01630372)

• A need for controls when the credited B.5.b vehicle or equipment was offsite for maintenance, drills, or other activities. Immediate CAs included the placement of a sign on the vehicle requiring the Shift Manager be notified when the designated vehicle is taken offsite so that another vehicle can be designated to support related activities. The licensee also noted that there were typically several vehicles onsite that could perform this function. (AR01632686)

• A need for spare parts and tools to perform field repairs of passive equipment, including valves and fittings. ( AR01632672, AR01631501)

• A need for spare hoses in the event a designated hose was unavailable or failed.

(AR01632678)

• A possible need of a second B.5.b pump as an enhancement to the licensees program. ( AR01631487)

• The consideration of an emergency preparedness (EP) drill with a loss of power to the technical support center (TSC) and the emergency operations facility (EOF).

(AR01632667)

The inspectors performed an independent review of the licensees related procedures and equipment and concluded that they met the CLB. Observations identified by the inspectors included:

• A seismic vulnerability of the B.5.b pump and equipment associated with B.5.b actions because these items are stored in a non-seismic building. This configuration meets the CLB; however, the licensee has initiated a condition report to consider the observation for further review. (AR01632672)

• A vulnerability of the B.5.b pump surveillance test acceptance criteria.

The inspectors identified that the licensees test did not consider the impact of using a pressurized source vs. a non-pressurized source and did not consider the impact on the acceptance criteria. The licensee credits both pressurized and non-pressurized sources for the B.5.b actions. This item was inspected using inspection procedure (IP) 71111.22 and will be documented in Inspection Report (IR) 2011003, Section 1R22. (AR01641496)

• A need for testing, charging, and inspecting the two sets of start-up batteries on the B.5.b pump diesel engine. Although the batteries were ultimately tested using the related surveillance test, the licensee had no procedures to test or charge both sets of batteries. Additionally, the licensee had no procedures to inspect the batteries and ensure the functionality of the non-aligned batteries. (AR01638483)

Describe the licensees actions to verify that procedures are in place and can be Licensee Action executed (e.g.. walkdowns, demonstrations, tests, etc.).

b. Verify through walkdowns or The licensee performed walkdowns and demonstrations using their abnormal operating demonstration that procedures procedures (AOPs), severe accident control room guideline (SACRG), EDMG, and SAMG to implement the strategies procedures credited for B.5.b strategy actions. The licensees walkdowns included using associated with B.5.b and auxiliary operators (AOs) to route and connect hoses used to provide water credited in their 10 CFR 50.54

(hh) are in place B.5.b analysis, and verifying valve lineups for credited flow paths. The licensee evaluated and are executable. Licensees their ability to perform the procedures, as well as a review of equipment and plant may choose not to connect or accessibility needed to perform proceduralized actions. Additionally, the licensee operate permanently installed completed table-top exercises with qualified individuals to verify the procedures could be equipment during this implemented as written.

verification.

This review should be done for a Describe inspector actions and the sample strategies reviewed. Assess whether reasonable sample of mitigating procedures were in place and could be used as intended.

strategies/equipment.

The inspectors independently reviewed EDMG-2, "Loss of Large Areas Of The Plant Due To Fire Or Explosion." to verify the procedure could be executed to implement the B.5.b strategies. The inspectors reviewed completed procedures SAMG SAG-1, Inject Into The Steam Generators, and SAMG SAG-4, Inject Into Containment, to verify the procedures were executable and that deficiencies noted were documented in the corrective action program (CAP).

The inspectors observed the licensee perform sections of EDMG-2 and verified it could be completed as written. Specifically, the inspectors observed the licensee routing the hoses from a B.5.b pump credited source to the spent fuel pool.

The inspectors independently reviewed the path used to position the B.5.b pump and hoses to and from its suction sources to verify the paths were accessible and usable for design basis and beyond design basis (BDB) events. Specifically, the inspectors walked down the routes outside of the turbine building, intake structure, technical support center building, and the extension building and verified there were no obstructions that may impede completing the procedure as written. Additionally, the inspectors walked down the path to the spent fuel pool to verify it was accessible.

Discuss general results including corrective actions by licensee.

During the licensees walkdowns and table-top exercises, the licensee demonstrated that the current design and credited B.5.b actions met the CLB. However, the licensee identified procedural and equipment enhancements. Items identified and CAs taken by the licensee included:

• A need to provide controls to prevent the placement or staging of equipment in areas that may challenge the completion of B.5.b actions. Specifically, the licensee identified that scaffolding, cables, and other equipment were placed in the location where the B.5.b pump would be staged to obtain water from one of the credited suction sources. Although the licensee was still able to place the pump at the credited source, it was difficult to place the pump as proceduralized. The licensee initiated condition reports AR01630519 and AR01638039 to assess this and similar issues that could result from outages or other activities on performing procedural actions.

• A need for multiple procedural and equipment enhancements was identified.

These condition reports are listed in the reference section of this report.

The inspectors performed an independent review of the listed procedures and concluded that procedures used to implement the strategies associated with B.5.b and 10 CFR 50.54(hh) are in place, are executable, and meet the CLB. Observations identified by the inspectors included:

• A vulnerability related to the transportation paths used to transfer the B.5.b pump and the trailer containing the hoses, valves, and other equipment credited for B.5.b actions due to the paths being adjacent to non-seismic structures, systems, and component (SSCs). (AR01635479)

• A vulnerability related to the paths used to route the hoses from the B.5.b pump to the areas credited by the B.5.b actions, such as the spent fuel pool, due to the paths containing non-seismic SSCs. (AR01635484)

Describe the licensees actions and conclusions regarding training and qualifications Licensee Action of operators and support staff.

c. Verify the training and The licensee reviewed the required training and qualifications of needed staff to verify they qualifications of operators and were current for activities related to B.5.b and SAMG procedures. The licensee reviewed the support staff needed to qualification requirements for the fire brigade, operations personnel, and the emergency implement the procedures and response organization related to EDMG and SAMG actions. Additionally, the licensee work instructions are current for reviewed the number of individuals qualified for each of the positions and the number of activities related to Security individuals required for each shift to ensure credited actions could be performed.

Order Section B.5.b and severe accident management guidelines as required by Describe inspector actions and the sample strategies reviewed to assess training and 10 CFR 50.54 (hh).

qualifications of operators and support staff.

The inspectors verified the adequacy of the training and qualifications of operators and support staff needed to implement procedures and work instructions related to B.5.b and SAMG actions. Additionally, the inspectors verified the training was documented and current.

The inspectors sampled the licensees training program documents, including the qualification matrix, qualification journals, and training slides. The inspectors reviewed procedure PBN LOC 10B 004L, Auxiliary Operator Training Program, PBN LOC 09C 007L, Licensed Operator Continuing, and PBN BEP 081 001L, Emergency Management Guideline for Decision Makers/Evaluators, to verify the adequacy of the training. The inspectors also reviewed the licensees training program document, PBN EP TP, Training Program Description, Emergency Preparedness, to verify the adequacy of the EP training.

Additionally, the inspectors reviewed related training records to verify they were current and adequate.

Discuss general results including corrective actions by licensee.

During the licensees review, the licensee identified several observations. Items identified and CAs taken by the licensee included:

• Missing training records for some positions required to implement procedures related to B.5.b and SAMG. The licensee interviewed the team members whose records were missing and those members did recall attending the required training.

Team members with missing training records were provided with remedial training.

The licensee initiated multiple condition reports to assess this issue.

These condition reports are listed in the reference section of this report.

• Missing training records for required SAMG tabletop drills. The licensee identified that a number of records for required table-top drills performed since 2005 were missing. Qualified individuals were interviewed; these individuals stated that they recalled performing the drills. Subsequently, the licensee completed makeup exercises for the required table-top training where records were missing.

(AR01631034)

• A desire to revisit the current training policy on SAMG and EDMG procedures to consider having more individuals complete the training, have more detailed training, and/or changing the frequency of the training. (AR01632682)

The inspectors reviewed the licensees CAs for the deficiencies noted, and the CAs taken appeared to address the issues identified and meet the CLB. Observations identified by the inspectors included:

• A lack of procedural controls for the training program that would allow individuals to be on watch for emergency response positions without completing initial SAMG training. As a result of the observation, the licensee updated the training program to have SAMG training as a part of the initial emergency response qualification. The licensee initiated multiple condition reports, which are listed in the reference section of this report.

• A possible vulnerability related to the number of qualified AOs required to be at the site due to the amount of actions they would have to perform during a BDB event.

(AR01632643)

Describe the licensees actions and conclusions regarding applicable agreements and Licensee Action contracts are in place.

d. Verify that any applicable The licensee verified that applicable agreements and contracts were in place, current, and agreements and contracts are in capable of meeting the conditions needed to mitigate the consequences of events related to place and are capable of B.5.b and SAMG actions. Specifically, the licensee reviewed the B.5.b and SAMG procedures meeting the conditions needed and commitments to ensure the applicable agreements were adequate.

to mitigate the consequences of these events.

For a sample of mitigating strategies involving contracts or agreements with offsite This review should be done for a entities, describe inspector actions to confirm agreements and contracts are in place and reasonable sample of mitigating current (e.g., confirm that offsite fire assistance agreement is in place and current).

strategies/equipment.

The inspectors reviewed the licensees B.5.b commitments to verify the licensee had the appropriate letters of agreement and contracts in place. The inspectors sampled the letters of agreement and contracts to verify they were current and appeared capable of meeting the conditions needed to mitigate the consequences of these events. Specifically, the inspectors reviewed the agreements with the Two Rivers Fire Department/Ambulance and the Two Creeks Volunteer Fire Department. Additionally, the inspectors reviewed the agreements to see if they reflected the capability and equipment of the party in agreement.

Discuss general results including corrective actions by licensee.

The licensee had an observation concerning the agreements. Items identified and CAs taken by the licensee included:

• A lack of formal agreements with two facilities credited to support the licensee in fire fighting events as stated in the B.5.b commitments. However, the licensee identified memos containing mutual aid agreements with these facilities, including the facilities fire fighting capabilities. Additionally, the licensee identified that formal agreements were not necessary due to the facilities not being the primary fire protection support and that they would provide support as necessary as part of Mutual Aid Box Alarm System network.

(AR01633805)

The inspectors reviewed the licensees CAs for the observation noted. From the samples reviewed, the inspectors concluded that actions taken by the licensee appear to have addressed the issues identified and meet the CLB. Observations identified by the inspectors included:

• A lack of formal documentation reflecting the capabilities of the external fire fighting resources for which agreements were in place. The inspectors were concerned that the licensee could not ensure that credited resources would remain available upon renewal of the agreements. (AR01641520)

Document the corrective action report number and briefly summarize problems noted Licensee Action 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 No conditions were identified by the licensee that would impact the ability of the equipment problems with mitigating or procedures to meet the mitigation strategies or events identified in the CLB.

strategy implementation identified by the licensee.

The licensees open CAs for enhancements or reviews included:

Assess the impact of the problem on the mitigating

• AR01630818, IER 11-1 - Storage of B.5.b Truck and Trailer capability and the remaining This condition report will assess the adequacy of the current storage location of the capability that is not impacted.

B.5.b pump and related equipment. The licensee is considering if the B.5.b pump and related equipment should be stored in an offsite storage facility or a seismic location, or if they should consider acquiring another unit for seismic and diversity considerations.

• AR01632641, IER1 11-1 Consider Split Storage of Boric Acid This condition report will assess a need to have boric acid stored in separate locations. This would to reduce the risk of losing all of the boric acid during a natural event.

• AR01632643, IER1 11-1 Review Current Staffing Levels This condition report will assess the current staffing levels for fire fighting and shift staffing to ensure the station can respond to natural events that may challenge the station. The inspectors noted that station AOs could be expected to perform a large number of actions during a design or BDB event. The licensees minimum staffing requirements for the total number of AOs onsite ranged for 2 to 4 depending on the operating mode of the units.

Other related condition reports are listed in the reference section of this report.

03.02 Assess the licensees capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, Loss of All Alternating Current Power, and station design is functional and valid. Refer to TI 2515/120, Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22, as a guideline. It is not intended that TI 2515/120 be completely reinspected.

The inspection should include, but not be limited to, an assessment of any licensee actions to:

Describe the licensees actions to verify the adequacy of equipment needed to Licensee Action mitigate an SBO event.

a. Verify through walkdowns and The licensee used ECA 0.0, Loss Of All AC Power, AOP-23, Establishing Alternate AFW inspection that all required Suction Supply, and AOP-30, Temporary Ventilation for Vital Areas, procedures which are materials are adequate and credited for SBO actions, to verify and walkdown the equipment necessary to perform the properly staged, tested, and actions. Specifically, the licensee verified that appropriate lighting, tools, power cables, and maintained.

other equipment were properly staged, tested, and maintained.

Describe inspector actions to verify equipment is available and useable.

The inspectors observed the licensee perform walkdowns of portions of ECA 0.0 and AOP 30 to verify materials were adequate and properly staged, tested, and maintained.

Specifically, the inspectors observed the licensee walk down areas used in the procedures to verify stationed and permanent equipment, including portable lighting, permanent lighting, and tools, were properly staged, had valid calibrations and testing, and were in acceptable material condition. The inspectors also walked down areas related to the procedures, including the area around the condenser steam dumps, the feedwater regulating valves, the main steam isolation valves, the auxiliary feedwater pump rooms, and the facade.

The inspectors performed an independent review of selected items, including wrenches, portable lighting, and staged tools used during the procedures, to verify the material condition of the equipment.

Discuss general results including corrective actions by licensee.

During the licensees walkdowns and equipment verification, the licensee demonstrated that the CLB for the equipment credited for SBO. However, the licensee identified procedural and equipment enhancements which included:

• A vulnerability for some equipment credited for actions required by SBO procedures because it was not being inventoried. Additionally, the NRC inspectors inquired about inventories for tools and equipment for all off-normal and emergency procedures which the licensee had not considered. The licensees subsequent review identified multiple occurrences of equipment not being inventoried. The licensee initiated multiple condition reports, which are listed in the reference section of this report.

• A vulnerability due to a lack of procedural guidance to ensure that power cables (extension cords) were routed in a manner which ensured the cables were long enough to perform the intended functions. The licensee identified an insufficient number of power cables to support concurrent activities. Immediate CAs included the manufacture/purchase of new cables to ensure sufficient cables of the appropriate length and quantity were available. Additionally, the licensee is considering a modification to allow easier cable connections through wall penetrations. (AR01633591, AR01633951)

The inspectors performed an independent review of credited equipment and found it to be capable of performing as required by the CLB. Observations identified by the inspectors included:

• A possible vulnerability related to the seismic qualification of credited support equipment. Specifically, the licensee is crediting installed lighting that is not seismically qualified and may not be available to perform actions through the plant in case of a SBO during a seismic event. The licensee initiated condition report AR01635992 to consider alternate lighting options such as head lamps for operators.

Licensee Action Describe the licensees actions to verify the capability to mitigate an SBO event.

b. Demonstrate through The licensee performed walkdowns, a table-top exercise, and simulator runs for ECA 0.0 walkdowns that procedures for to verify SBO procedures were executable. The licensee also reviewed and performed response to an SBO are walkdowns of procedures AOP-23 and AOP-30 to ensure the procedures could be executable.

executed as written.

Describe inspector actions to assess whether procedures were in place and could be used as intended.

The inspectors independently reviewed procedure ECA 0.0 and AOP-30 to verify the procedures could be performed as written. The inspectors accompanied the licensee on selected walkdowns to verify the licensees actions and assess procedural adequacy.

The inspectors also performed independent walkdowns and inspections of areas that required local operation of equipment. Specifically, the inspectors walked down areas around the condenser steam dumps, the feedwater regulating valves, the main steam isolation valves, the AFW pump rooms, and the facade to verify the areas were accessible and had appropriate lighting and tools to be able to complete actions required by the SBO procedures.

Discuss general results including corrective actions by licensee.

During the licensees review, the licensee was able to demonstrate that they meet the CLB for the equipment credited during an SBO. However, the licensee identified several procedural vulnerabilities which included:

• A vulnerability in procedure ECA 0.0 that directed the reactor operator to reset and close a breaker that was closed previously in the procedure. This step if performed would cause the breaker to open and de-energize a safety-related bus.

The licensee made procedure changes to ensure the bus was not inadvertently de-energized. Additionally, the licensee stated that based on operator training and proper procedure use, the operator would be expected to progress through the steps without de-energizing needed buses. (AR01632722)

• A vulnerability in AOP-30 that allowed multiple fans to be connected to a portable power panel. If these fans were connected to the same circuit it could create a circuit overload condition. This could result in the operator having to reestablish the loads and reset the fans. The licensee made a procedure change to provide guidance on how to connect the fans. (AR01636370)

• A vulnerability in ECA 0.0 because the procedure would allow the G-05 gas turbine, the station SBO alternate-current power source, to be aligned to a 13.8 kiloVolt bus during an SBO while the unaffected side of the bus remained connected to the de-energized grid. This could cause G-05 to trip on under-voltage or under-frequency if it attempted to pick up load from the grid. The licensee has since changed the procedure to ensure G-05 is isolated from the grid during the response to an SBO. (AR01634081, AR01633783)

The inspectors did not identify any deficiencies that appeared to impact the performance of activities needed to meet the CLB. Observations identified by the inspectors included:

• An equipment and procedural vulnerability due to the AFW pump rooms having a shared thermometer for determining if equipment was affected by temperature.

Specifically, the Unit 1 AFW pump room has a wall-mounted thermometer and the unit specific procedure, ECA 0.0, requires the licensee enter AOP-30 if temperature exceeds 120 degrees F in either the Unit 1 or Unit 2 AFW pump rooms.

The licensee indicated that sufficient communication existed between the AFW rooms, which are separated by a normally closed fire door, due to damper and ventilation configuration and that one thermometer was sufficient. Based on operational observations, the inspectors were not confident that the one thermometer was capable of performing adequately. The licensee indicated that operators were capable of detecting differences in room temperatures, and if differences were noted, they would use an infrared thermometer to obtain the required temperatures. After further questions by the inspectors, the licensee initiated condition report AR01641992 to assess the qualification of the operators and the procedural guidance relative to taking general area temperature readings using an infrared device.

03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design. Refer to IP 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.

Describe the licensees actions to verify the capability to mitigate existing design Licensee Action basis flooding events.

a. Verify through walkdowns and The licensee performed walkdowns of areas and SSCs credited to mitigate internal and inspection that all required external flooding events. Specifically, the licensee verified the adequacy of credited flood materials are adequate and barriers using procedure RMP 9011-1, Safe Shutdown Fire Door Inspections. The properly staged, tested, and licensee verified the material condition of the doors, dampers, residual heat removal (RHR)maintained.

cubicle equipment, and flood barriers. Additionally, the licensee verified and tested doors credited as flood barriers as well as performed surveillances of the RHR cubicle drain valves, level switches, and alarm.

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 RMP 9011-1, NP 8.4.17, PBNP Flooding Barrier Control, and PC 80, Part 7, External Floods, to ensure they could be executed as written.

The inspectors accompanied the licensee on selected walkdowns to verify the licensees actions, such as the testing and maintenance of flood doors, and to assess their adequacy.

The inspectors independently walked down areas susceptible to flooding. Specifically, the inspectors walked down the G-01 and G-02 emergency diesel generator (EDG) rooms, the RHR pump pits, multiple flood doors throughout the plant, flood barriers, and the intake structure to verify the material condition of flood mitigating barriers, dampers, and drains to ensure they could perform their intended function.

Discuss general results including corrective actions by licensee.

During the licensees testing and review, the licensee identified issues that may adversely impact the CLB of the equipment credited for flooding. Items identified and CAs taken by the licensee included:

• A possible adverse impact to the RHR pumps. The licensee identified having six non-seismic tanks in the primary auxiliary building (PAB) that if damaged during a seismic event could potentially flood the elevation where the RHR pumps are located. The licensee identified that the RHR room sump pumps were non-safety related. Additionally, the storage capacity of the tanks exceeded the volume of water necessary to overflow the walls and flood the RHR pump rooms. As part of the licensees immediate CAs, the licensee is administratively controlling the combined water volume of the tanks to ensure that the volume was less than the amount that could potentially impact the RHR pumps. The licensee initiated condition report AR01633384. This item was inspected and will be documented in IR 2011003, Section 1R15.

• A possible adverse impact to the vital switchgear room. Specifically, the condensate storage tanks (CSTs) and a block wall in the vicinity of the CST, which was serving as a flood barrier, may not be seismically qualified. The water in the CST could impact the vital switchgear room during a seismic event. The licensee initiated condition report AR01634515. This item was inspected using IP 71111.15 and will be documented in IR 2011003, Section 1R15.

• A lack of adequate procedural guidance for flood door inspections. Specifically, the procedure did not provide adequate direction to ensure consistent measurement of the sweep gap on flood doors. No doors were found to have gaps in excess of the acceptance criteria. As part of the CAs, the licensee revised procedure RMP 9011-1 and incorporated the use of a tapered gauge to measure the door sweep gap accurately and consistently. (AR01633548)

The inspectors performed an independent review of selected equipment and materials to ensure that they were adequately staged, tested, and maintained. The inspectors identified no issues that would have prevented the SSCs and procedures from meeting the CLB. In addition to observations identified by the licensee, the inspectors had the following observations:

• A possible adverse impact to the RHR pumps, as discussed above. The inspectors questioned the current and past operability of the RHR pumps due to the possible adverse impact caused by non-seismic tanks. This item was inspected using IP 71111.15 and will be documented in IR 2011003, Section 1R15.

• A possible adverse impact to the vital switchgear room, as discussed above.

The inspectors questioned the current and past operability. This item was inspected using IP 71111.15 and will be documented in IR 2011003, Section 1R15.

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site.

Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., 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 IP 71111.21, Component Design Basis Inspection, Appendix 3, Component Walkdown Considerations, as a guideline to assess the thoroughness of the licensees walkdowns and inspections.

Describe the licensees actions to assess the potential impact of seismic events on Licensee Action the availability of equipment used in fire and flooding mitigation strategies.

a. Verify through walkdowns that The licensee performed walkdowns and inspections of all permanently installed fire all required materials are protection equipment, the B.5.b pump, and the B.5.b equipment storage facility.

adequate and properly staged, Specifically, the licensee walked down the electric-driven fire pump and related tested, and maintained.

components, the diesel-driven fire pump (DFP) and related components, the DFP fuel day tank, intake structure piping, portable pump suction sources, B.5.b pump, the B.5.b storage building, related B.5.b components, fire mains, and fire system piping on site. Additionally, the licensee walked down flood barriers used to prevent or limit intrusion of water into vital areas.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors accompanied the licensee on selected walkdowns to verify the licensees actions and assess their adequacy. Additionally, the inspectors independently walked down fire piping, fire mitigating components, the B.5.b pump, B.5.b related equipment, flood barriers, and areas susceptible to flooding. The walkdown included the RHR pits, G-01 and G-02 EDG rooms, the CST area, the intake structure, fire protection piping, the DFP, DFP day tank, flood barriers, and flood dampers.

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 demonstrated that the SSCs reviewed met the CLB. However, the licensee identified equipment that may be adversely impacted during a seismic event. Additionally, the licensee identified the potential need for mitigation strategies for affected SSCs.

Items identified by the licensee included:

• A review of a need to seismically qualify the DFP day tank. (AR01637972)

• A consideration for, and alternate means of, transferring additional fuel to the DFP day tank. ( AR01637978)

• A consideration for replacement of the DFP engine, and potentially the DFP, due to it being obsolete and unreliable. (AR01637979)

• A consideration for installing wall hydrants to permit connection of portable pumps and the installation of hose jumpers to allow the bypassing of buried fire protection piping sections which are susceptible to damage during a seismic event.

(AR01637985)

• A consideration of a contingency plan to provide procedural guidance to supply the B.5.b pump with fuel from other sources. (AR01637992)

• A consideration of upgrading fire water system components within the intake structure to withstand a safe shutdown earthquake. (AR01637972)

The inspectors sampled the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events and identified no deficiencies relative to the CLB.

The inspectors communicated the below observations to the licensee:

• The inspectors found no alternate means of supplying, or moving, fuel from onsite sources to related mitigation equipment, including methods to use fuel that may be floating on water that may have intruded into tanks.

• The inspectors found no requirement to ensure that all fuel tanks are filled prior to high risk conditions such as adverse weather.

• The inspectors found no repetitive task to periodically test and replace batteries for portable equipment.

• The inspectors found no consideration for the need for additional hoses and equipment if alternate routes are needed due to unanticipated problems.

• The inspectors found no method for dealing with interference from energized equipment or wires resulting from events.

• The inspectors found no contingencies for a loss of power that could affect SSC accessibility due to de-energized electrically controlled doors or components.

• The inspectors found no consideration to reassess the duties and cross-qualification of onshift personnel, such as the shift technical advisor, and radiation protection technicians, for collateral or contingency duties during events.

• The inspectors found no periodic reviews or surveillances to reaffirm the capabilities of organizations credited through letters of agreement.

• The inspectors found that the licensee had not considered what offsite equipment could be used during events; nor had the licensee identified the need to ensure that fittings or adaptors were available to allow offsite equipment to be used onsite during events. Similarly, the inspectors noted that the licensee had not considered equipment that could be shared between Point Beach and the Kewaunee Power Station.

• The inspectors noted that the licensee had not considered resource conflicts that may arise if shared resources between Point Beach and the Kewaunee Power Station were demanded simultaneously.

• The inspectors noted that the licensee had not reviewed any common mode impacts that may simultaneously affect Point Beach and Kewaunee Power Station, such as downed power lines or blocked site evacuation or site access routes.

• The inspectors noted that there may be a need to review inclement weather contingencies, e.g., snow emergency route maintenance with local government.

• The inspectors noted that there were no letters of agreement to supply alternate sources of electricity, or other equipment and resources, such as pumps, ventilation, food, water, or compressed air, during some events (e.g., SBO, tornado).

• The inspectors noted that there were no agreements to ensure that the licensee obtained priority standing in case of emergency.

• The inspectors noted that the impact of events on outside resources had not been assessed. For example, the licensee had not assessed the impact of a loss of engineering support groups in the corporate offices in Florida, or alternate capabilities to interface with the engineering support groups in Florida.

• The inspectors noted that the licensee had not considered assessing offsite storage of alternate emergency equipment.

• The inspectors found no specific requirements for the frequency or quantity of repetitive training, such as simulator training or drills, related specifically to SBO, B.5.b, and other events.

• The inspectors found no recent review of post-TMI [Three Mile Island] actions or commitments.

• The inspectors questioned the method and incorporation of operating experience from natural phenomena such a tornado at the Fermi nuclear plant in 2010, hurricane Andrew in 1992, and hurricane Katrina in 2005.

• The inspectors found that the licensee had not performed a review of natural phenomena related to the independent spent fuel storage installation subsequent to the current events.

The licensee initiated condition report AR01641960 to assess these observations.

Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. J. Costedio and other members of licensee management at the conclusion of the inspection on April 19, 2011.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. Proprietary information was returned to the licensee.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Costedio, Licensing Manager

B. Castiglia, Performance Improvement Manager

P. Wild, Engineering Site Manager-Design

C. Hill, Operations Assistant Manager-Training

T. Kendall, Principal Design Engineer

J. Loor, Environmental Qualification Engineer

D. Minerath, Electrical Engineer

B. Scherwinski, Licensing Analyst

Nuclear Regulatory Commission

P. Cardona-Morales, Reactor Engineer

S. Burton, Senior Resident Inspector

M. Thorpe-Kavanaugh, Resident Inspector

Enclosure