IR 05000289/2011009
| ML111310788 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/13/2011 |
| From: | Doerflein L Engineering Region 1 Branch 2 |
| To: | Pacilio M Exelon Nuclear, Exelon Generation Co |
| Shared Package | |
| ML111300168 | List: |
| References | |
| IR-11-009 | |
| Download: ML111310788 (27) | |
Text
UNITED STATES NUCLEAR REGU LATORY COMMISSION
REGION I
475 ALLENDALE ROAD KlNG OF PRUSSTA. PA 19406-1415 May 13, 20LL Mr. Michael Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nucfear Officer (CNO), Exelon Nuclear 4300 Winfield Road Warrenville, lL 60555 SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC TEMPORARY INSTRUCTION 2515t 183 tNSPECTION REPORT 05000289/201 1 009
Dear Mr. Pacilio:
On April 29,2011, the U-S. Nuclear Regulatory Commission (NRC) completed an inspection at your Three Mile lsland Unit 1, using Temporary Instruction 2515t18g, "Followup to th6 Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspeition report documents. the inspection results which were discussed on April 29, 2011, ivitn Ur. R. Libra, and other members of your staff.
The objective of this inspection was to promptly assess the capabilities of Three Mile lsland 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 from this inspection performed at other operating commercial nuclear piants in tne 19s.ult9 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 deteimine 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 re_gulatory findings or violations. Any resulting findings or viol-ations will be documented by the NRC in a separate report. You are not requireJ to resfond to this letter. 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 Agencynride Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.qovireadinq-rm/adams.html (the Public Electronic Reading Room).
Sincerely, l"
c%.^^^r^." T l) *-f/t"--
Lawrence T. Doerflein, Chief /
Engineering Branch 2 Division of Reactor Safety Docket No.: 50-289 License No.: DPR 50
Enclosure:
lnspection Report No. 05000289/2011009
REGION I Docket No.: 50-289 License No.: DPR-50 Report No.: 05000289/201 1009 Licensee: Exelon Generation Company Facility: Three Mile lsland Station, Unit 1 Location: Middletown, PA 17Q57 Dates: April 8-April 29,2011 lnspectors: David Kern, Senior Resident Inspector Justin Heinly, Resident Inspector Approved by: Lawrence T. Doerflein, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
fR 05000289/2011009:0410812011 -0412912011;Three Mile lsland Station, Unit 1;Temporary f nstruction 25151183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.
This report covers an announced Temporary Instruction (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 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 a separate report.
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 Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. lt 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 Licensee actions included the identification of equipment (active and passive) used for inspection that implementation of Extensive Damage Mitigation Guidelines (8.5.b) actions and any additional equipment is available equipment used in Severe Accident Management Guidelines (SAMGS). The scope of the and functional. Active equipment was defined as that equipment specifically designated for 8.5.b or SAMG mitigation equipment shall be (i.e., portable fire pump, special hoses, fittings, electricaljumper cables, specialized tools, radios, tested and passive etc.). Permanent plant equipment (i.e., in situ equipment) was not retested, since it is normally in equipment shall be service, subjected to planned maintenance, periodically tested as required by an existing walked down and regulatory program, and/or checked on operator rounds. The licensee then identified inspected. lt is not surveillances/tests and performance frequencies for the identified equipment, and reviewed the expected that results of recent tests. Active equipment within the scope defined above that did not have recent permanently installed test results was tested. Passive equipment within the scope was walked down and inspected.
equipment that is tested under an existing regulatory testing Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed program be retested.
test results, discussed actions, reviewed records, etc.).
This review should be The inspectors reviewed prior inspection documents associated with NRC Tl25151164, done for a reasonable "lnspection of Nuclear Reactor Safeguards Interim Compensatory Measure - Section 8.5.b Plant sample of mitigating Mitigating Strategies to Address Loss of Large Areas of the Plant Due to Explosions or Fire;" NEI strategies/equipment. 06-12, "8.5.b Phase 2&3 Submittal Guideline," Rev. 2; TMI-1 NRC Triennial Fire Protection fnspection Report 05000289/2011007; and procedures ER-TM-TSC-0010, "TMl-1 SAMGs," Rev.
2; ER-TM-TSC-0020, "Portable Electric Power Sources," Rev. 0; and ER-TM-TSC-0025, "TMl-1 Extensive Damage Mitigation Guidelines," Rev. 2, to verify active and passive equipment credited by licensee procedures to mitigate beyond design basis events were properly included in the scope of licensee review.
The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities, interviewing station personnel, and verifying associated licensee-identified deficiencies were properly addressed in the corrective action program (CAP). The inspectors independently walked down and inspected major B.5.b contingency response equipment staged throughout the site. Emphasis was placed on strategies related to the spent fuel pool and to inject water to flood the reactor building containment.
Discuss general results including corrective actions by licensee.
The licensee has no equipment designated for use in the SAMGs that is not considered in situ plant equipment. All equipment (active and passive) designated for B.S.b was verified by the licensee to be in applicable procedures. All passive equipment was walked down and verified to be in place and ready for use. The licensee identified that a small portion (inflatable plugs) of the passive materials credited in the SFP leakage control strategy was not maintained at the onsite warehouse as described in the procedure (lR 1 189429). The inspectors determined that there was sufficient additional mitigation equipment available and appropriate corrective action was initiated to address this issue.
Passive equipment which had surveillance and/or preventive maintenance tasks had those activities performed to verify readiness for use. All active equipment located at the site was verified in place by the licensee. The licensee successfully tested the designated 8.5.b fire pump (FS-P-15). which is a dieselfire pump mounted on a trailer.
Based on these reviews, the inspectors concluded that the required equipment is available and functional.
Describe the licensee's actions to verify that procedures are in place and can be executed (e.g.
Licensee Action walkdowns, demonstrations, tests, etc.)
b. Verify through Licensee actions included the identification of those procedures used to mitigate the walkdowns or consequences of 8.5.b related events and severe accidents. The licensee then compiled demonstration that verification documentation for procedure validations. Licensee personnelwalked down all procedures to implement applicable procedures to verify current revisions of each procedure were in their required the strategies associated locations, implementing control locations were accessible, each procedure could be executed, and with B.S.b and 10 CFR associated labeling was correct.
50.54(hh) are in place and are executable.
Licensees may choose Describe inspector actions and the sample strategies reviewed. Assess whether procedures were not to connect or in place and could be used as intended.
operate permanently installed equipment during this verification. The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities. The inspectors verified implementation procedures for each B.5.b mitigation This reviefu should be strategy were established and issued for use. The inspectors reviewed ER-TM-TSC-O010, "TMl done for a reasonable Severe Accident Management Guidelines," Rev. 2 and found their level of detail to be consistent sample of mitigating with the current regulatory requirements. The inspectors discussed the reactor building vent strategies/eq uipment.
SAMG with licensee emergency response organization (ERO) staff, who identified a viable vent pathway for which a procedure could be written and executed. ln addition, the inspectors independently walked down six mitigation strategy procedures onsite. Emphasis was placed on procedures used to implement mitigation strategies for the spent fuel pool (SFP) and injecting water to flood the reactor building containment.
Discuss general results including corrective actions by licensee.
The licensee reviewed the SAMG and 8.5.b strategies and did not identify any issues that would prevent implementation of these strategies. Several minor deficiencies or enhancements were identified and documented in the CAP. The inspectors verified each issue was promptly corrected (e.9., current revision of 8.5.b strategy procedures now available at the 8.5.b fire pump trailer) or assigned an appropriate date for resolution in the corrective action program, commensurate with its safety significance. Specific issue reports (lRs) reviewed are listed in the Supplemental Information Attachment to this report.
Based on the reviews conducted, the inspectors concluded that the procedures used to implement the strategies associated with 8.5.b and 10 CFR 50.54(hh) were in place and were executable.
Describe the licensee's actions and conclusions regarding training and qualifications of operators Licensee Action and support staff.
Verify the training and Licensee actions included the identification of training/qualification requirements for operators and qualifications of maintenance first line supervisors (FLS) for the implementation of actions needed to mitigate a operators and the 8.5.b related event, and for the implementation of actions needed for the SAMGS. The licensee support staff needed to documented that operator and maintenance FLS personnel training requirements were current. In implement the addition, the licensee identified the training/qualification requirements for applicable ERO procedures and work command and support staff for the implementation of actions needed to mitigate a 8.5.b related instructions are current event, and for the implementation of actions needed for the SAMGS, and documented that ERO for activities related to command and support staff training requirements were current.
Security Order Section 8.5.b and severe accident management Describe inspector actions and the sample strategies reviewed to assess training and guidelines as required by qualifications of operators and support staff.
10 cFR 50.54 (hh).
The inspectors assessed the licensee's training and qualification activities by conducting a review of training and qualification materials and records related to 8.5.b and SAMG event response.
Additionally, the inspectors reviewed a selection of operator classroom and control room simulator training lesson plans for BS.b and SAMG event response.
Discuss general results including corrective actions by licensee.
The training requirements, qualifications, and associated records needed for operators for the implementation of SAMGs and 8.5.b event response were reviewed by the licensee. Appropriate training requirements were embedded within the position qualifications for the shift managers, shift engineers, unit supervisors, and reactor operators. The licensee confirmed that all shift operators verify their qualifications prior to assuming a shift position. The training requirements, qualifications, and associated records needed for ERO command and support staff for the implementation of actions needed to mitigate a 8.5.b event or implement the SAMGs were also reviewed. All ERO command and support staff training requirements were verified as current by the licensee.
Based on the reviews conducted, the inspectors concluded that the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section B.S.b and SAMGs as required by 10 CFR 50.54 (hh).
Describe the licensee's actions and conclusions regarding applicable agreements and contracts Licensee Action are in place.
d. Verify that any The licensee reviewed TMI 8.5.b event mitigation strategies (ER-TM-TSC-0025, OP-TM-AOP-applicable agreements 009, and OP-TM-AOP-035) and the SAMG strategies (ER-TM-TSC-0010) to identify any and contracts are in necessary agreements and contracts to support implementation of the strategies. The licensee place and are capable of determined only one contract was necessary and verified purchase order 442035 was in place meeting the conditions through 2011 for annual preventive maintenance on FS-P-15. Additionally, the licensee verified needed to mitigate the the reference list of available suppliers of portable electric generators was current.
consequences of these events.
For a sample of mitigating strategies involving contracts or agreements with offsite entities, This review should be describe inspector actions to confirm agreements and contracts are in place and current (e.9.,
done for a reasonable confirm that offsite fire assistance agreement is in place and current).
sample of mitigating strategies/eq uipment.
The inspectors assessed the licensee's capabilities by conducting an independent review of the licensee's FS-P-15 maintenance contract. Additionally, the inspectors noted that several additional contracts, letters of agreement, or memoranda of understanding (MOU) had been established with offsite support providers. These MOUs were primarily for firefighting, ambulance, and medical services. The licensee did not consider these MOUs to be required to successfully implement their procedures for B.5.b and SAMG mitigation strategies. The inspectors determined the MOUs with offsite firefighting companies were necessary to support implementation of OP-TM-251-904, "SFP Building (External) Spray," Rev. 1. The inspectors verified this additional group of MOUs was documented in the TMI Radiological Emergency Plan Annex and that the MOUs were current, and assessed whether or not it was adequate for meeting the licensee's mitigation strategy.
Discuss general results including corrective actions by licensee.
The licensee reviews partially identified contracts, letters of agreement, and MOUs needed to implement B.5.b and SAMG mitigation strategies.
The inspectors identified additional MOUs necessary to implement required strategies for the spent fuel pool. Since these MOUs were current, the failure of the licensee to assess them had no impact on their effectiveness.
As a result of these reviews, the inspectors concluded that applicable agreements and contracts were in place and were capable of meeting the conditions needed to mitigate the consequences of these events.
Document the corrective action report number and briefly summarize problems noted by the Licensee Action licensee that have significant potential to prevent the success of any existing mitigating strategy.
e. Review any open The following entries into the licensee's CAP were made in response to issues identified in section corrective action 03.01:
documents to assess problems with mitigating lR 1189429, lnflatable plugs not available IAW ER-TM-TSC-002 Step 4.3.2; strategy implementation lR 1190193, ER-TM-TSC-0020 could not be found in the TMI-1 Control Room; identified by the lR 1 192401, AOP-023 not located in simulator file cabinet; licensee. Assess the lR 1193762, lmprove labeling of fuses for OP-TM-734-9211922 in CRS desk; impact of the problem on lR 1196007, NOS lD: lnventory of B.5.b Equipment not performed; the mitigating capability lR 1199363, Bldg 71 storage area for B.5.B pump, FS-P-15; and and the remaining lR 1199718, Procedure review required for 8.5.B pump FS-P-15 capability that is not impacted.
The inspectors reviewed each lR for potential impact to the licensee's mitigation strategies. No significant impacts were identified.
03.02 Assess the licensee's 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 Tl 25151120, "lnspection of lmplementation of Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that Tl 25151120 be completely reinspected.
The inspection should include, but not be limited to, an assessment of any licensee actions to:
Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO Licensee Action event.
a. Verify through The licensee verified that equipment required to perform SBO mitigation actions has been walkdowns and identified in procedures, the location is tracked and periodically checked, and the shelf life inspection that all limitations are understood. The licensee conducted walkdowns of the required equipment to required materials are ensure it was adequate and properly staged. Additionally, the licensee also conducted a review of adequate and properly open CAP items for potential SBO equipment impact.
staged, tested, and maintained.
Describe inspector actions to verify equipment is available and useable.
The inspectors assessed the licensee's capability to mitigate a SBO event by conducting a review of the licensee's walkdown activities. ln addition, the inspectors selected a sample of equipment utilized/required for mitigation of a SBO event and conducted independent walkdowns to verify that the equipment was properly aligned, staged, tested and maintained. The sample of equipment selected by the inspectors included, but was not limited to, the SBO diesel generator (EG-Y-4), control building portable ventilation, and DC electricalfuses.
Discuss general results including corrective actions by licensee.
The licensee's reviews verified that SBO equipment was ready to respond to a SBO event. The inspector's review of the recent SBO diesel quarterly runs, daily operator rounds data, and quarterly equipment inventories has identified no major issues. The inspector's independent walkdowns of SBO equipment identified no issues of concern. In addition, during their CAP review, the licensee did not identify any issues that would impact the SBO event mitigation strategy.
Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.
b. Demonstrate through Licensee actions included the identification of procedures required to mitigate a SBO event, along walkdowns that with verification that the identified procedures were current. The licensee performed walkdowns to procedures for response confirm that SBO mitigating procedures are executable and controlled copies of the procedures to an SBO are are located in their designated locations. Also, the licensee reviewed and validated that adequate executable.
operator training on SBO mitigation procedures is being performed. Additionally, the licensee conducted a review of open CAP items for potential impact to SBO event procedures.
Describe inspector actions to assess whether procedures were in place and could be used as intended.
The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activity results. In addition, the inspectors selected a sample of SBO mitigation procedures to walkdown and independently verify the licensee's conclusions. Specifically, the inspectors verified the capability of operators to start the SBO diesel generator and supply power to a vital 4kV bus within the SBO event design basis response time. Also, the inspectors conducted field walkdowns to validate the feasibility of operators to perform manual manipulations of plant equipment directed by abnormal operating procedures for a SBO event.
Discuss general results including corrective actions by licensee.
The inspectors verified that the licensee's procedures used to respond to a SBO event were executable. Procedures adequately direct operators to start the SBO diesel generator and supply power to a site vital bus from the control room with permanently installed plant equipment.
Additionally, the inspectors verified the licensee conducts adequate training for licensed and non-licensed operators on the performance of SBO procedures. Inspector walkdowns of the SBO event mitigating procedures identified no issues of concern.
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.
Describe the licensee's actions to verify the capability to mitigate existing design basis flooding Licensee Action events.
a. Verify through Licensee actions included review of the TMI-1 Flood Protection Systems Design Basis Document walkdowns and and identification of equipment and penetration seals used/required for mitigation of internal and inspection that all externalflooding. This review addressed both the TMI-1 and TMI-2 flood barrier system and the required materials are Unit 1 severe flood mitigation system. The licensee then conducted walkdowns of this equipment adequate and properly to ensure it was adequate and properly staged. Doors, barriers, tools, and penetration seals that staged, tested, and were used for mitigation of flooding were identified, and checked to see if they were routinely maintained.
inspected to ensure functionality. Where routine inspections were not performed or could not be relied upon to ensure functionality, the licensee performed walkdowns and inspections to ensure that the components were functional. Additionally, detailed plant walkdown/inspections of all externalflood barriers, seals, and penetrations were performed in late 2010, as corrective action to an external flood deficiency previously documented in NRC Inspection Report 05000289/201 0005.
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.
The inspectors assessed the licensee's capabilities to mitigate flooding by conducting a review of the licensee's walkdown activities. In several instances, these reviews involved the inspectors accompanying licensee engineering personnel during their in-field walkdowns. In addition, the inspectors conducted independent walkdowns of selected flood mitigation equipment to contribute to the overall assessment of the licensee's flood mitigating capabilities. Licensee flood mitigation procedures were reviewed and discussed with licensee staff to verify they could be used as intended. Selected periodic maintenance and inspection records were reviewed to verify flood protection barriers and equipment were properly maintained. The inspectors verified each flood-related issue was entered into the CAP and reviewed the initial assessment and assigned schedule for resolution.
Discuss general results including corrective actions by licensee.
The inspectors determined that, in general, all required materials are adequate and properly staged, tested, and maintained to respond to an internal flood or external flood within the plant's design bases. While this effort did not identify any operability or significant concerns, the licensee identified several minor deficiencies and enhancements associated with preventive maintenance or periodic testing for the severe flood mitigation pumps, a sewage line check valve, and turbine building flood detection. The licensee also identified that the assumed operator response time for a circulating water rupture in the turbine building was unrealistic. The licensee initiated appropriate lRs for further assessment and resolution of licensee and inspector identified issues, as listed in the Supplemental lnformation Attachment to this report. The inspectors reviewed the associated issue reports and determined the licensee's initial responses, including their assessment and prioritization, were appropriate. The inspectors noted the licensee was in the process of reanalyzing the Probable Maximum Flood (PMF) associated with plant's external flood design basis. Accordingly, the licensee established contingency actions to reassess station flood mitigation measures following completion of the PMF reanalysis.
The licensee also identified several issues that appeared to be beyond the plant's design and licensing bases concerning potential seismically induced internalflooding associated with non-seismically qualified piping (fire service water, portions of feed water, and secondary river water)installed in rooms containing safety related mitigating equipment used for safe shutdown. The licensee intends to review the capability of the listed non-seismic systems to maintain their integrity during a safe shutdown earthquake. Based on an initial inspector review, these piping failures were not within the scope of the seismic safe shutdown path assumed in the licensee's response to NRC Generic Letter 87-02. The licensee initiated appropriate issue reports for further assessment and resolution of licensee and inspector identified issues, as listed in the Supplemental lnformation Attachment of this report.
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.
Describe the licensee's actions to assess the potential impact of seismic events on the availability Licensee Action of equipment used in fire and flooding mitigation strategies.
a. Verify through Licensee actions included the identification of equipment used for mitigation of fire and flood walkdowns that all events. Station personnel walked down and inspected both permanent and temporary equipment, required materials are including storage of transient materials throughout the station. Engineering personnel determined adequate and properly if the equipment was seismically qualified, and where not seismically qualified performed staged, tested, and preliminary assessments of adequacy based on piping construction. Station personnel also maintained.
reviewed the most recent (2010) periodic maintenance rule program structural inspection records.
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.
The inspectors conducted multiple walkdowns, both independently and in conjunction with licensee personnel, of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost or degraded during a seismic event. This equipment included, but was not limited to:
o all major B.5.b contingency response equipment staged throughout the site;
.
fire protection and suppression equipment in portions of the turbine building, control building, auxiliary building, intermediate building, and emergency diesel generator buildings;
.
the installed diesel and electric fire pumps; and
.
numerous flood barriers and penetration seals.
Licensee earthquake, flood, and fire mitigation procedures were reviewed to verify they could be used as written. The results of the inspectors' reviews aligned with the licensee's conclusions that there were a number of seismic vulnerabilities that potentially need to be addressed, as described below. The inspectors determined that the licensee meets the current licensing and design bases for 8.5.b, fire protection, and flooding.
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 inspectors noted the licensee meets the current licensing and design bases for 8.5.b, fire protection, and flooding. The licensee identified a number of issues pertaining to potential fire system and flood protection vulnerabilities, and documented these issues in the CAP. See the Supplemental lnformation Attachment to this report for a listing of lRs initiated by the licensee.
Seismically qualified is defined as those structures, systems, and components (SSCs) that have been formally qualified to function during and after a design basis earthquake. The licensee's reviews determined that non-safety related SSCs, in general, were not considered to be either seismically qualified or rugged. Further evaluation was initiated via the CAP (lR 1201621) to determine whether portions of the fire protection or flood mitigation systems could be classified as seismically rugged. Various building sump pumps and flood detectors were not designed as seismically qualified and have not been evaluated, to date, as being seismically rugged.
The inspectors observed that fire protection piping is generally well supported for vertical loads with rod hangers and support spacing consistent with ANSI 831.1 recommendations. Rod hangers provide for stable support for horizontal loading. Lateral support is often provided at valve headers, hose stations, and areas of concentrated weight. Firefighting equipment staged to respond to 8.5.b events was not stowed in seismically qualified buildings and locations, as a seismic event and 8.5.b event were not assumed to occur coincidentally.
The existing earthquake procedure, OP-TM-AOP-003, "Earthquake," was considered sufficient by the licensee. The licensee determined that fire or flood mitigation strategy enhancements would be considered following industry recommendations from other plants that have identified similar beyond-desig n-bases vulnerabilities.
Meetinqs 40A6 EXit Meetinq The inspectors presented the inspection results to Mr. R. Libra, Plant Manager, and other members of licensee management at the conclusion of the inspection on April 29, 2011. Proprietary information reviewed by the inspectors during the inspection was returned to the licensee. The inspectors verified the inspection report does not contain proprietary information.
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- W. Carsky, Director, Engineering
- M. Fitzwater, Senior Regulatory Affairs Engineer
- P. Bennet, Manager, Mechanical Design Engineering
- H. CraMord, Manager, Reactor Engineering
Other
- D. Dyckman, Nuclear Safety Specialist, Pennsylvania Department of Environmental Protection