IR 05000245/2011009
| ML111320660 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/13/2011 |
| From: | Doerflein L Engineering Region 1 Branch 2 |
| To: | Heacock D Dominion Resources |
| References | |
| IR-11-009 | |
| Download: ML111320660 (25) | |
Text
UNITED STATES N UGLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
SUBJECT:
MILLSTONE POWER STATION - NRC TEMPORARY INSTRUCTION 25151183 INSPECTION REPORT 05000245/201 1009, 05000336/201 1009, AND 05000423t201 1009
Dear Mr. Heacock:
On April 28,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Millstone Power Station, using Temporary Instruction 2515/183, 'Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection repori documents the inspection results which were discussed on April 28, 2011, with Mr. Richard McManus and other members of your staff.
The objective of this inspection was to promptly assess the capabilities of Millstone Power Station to respond to extraordinary consequences similar to those that have recently occurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, blong with the results from this inspection performed at other operating commercial nuclear plants in tne United States will be used to evaluate the United States nuLlear industry's readiness to safely respond to similar events. These results will also help the NRC to determine if additional regulatory actions are warranted.
All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter. ln 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 Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).
Sincerely, OF(=.'r.1.^--l {)
Lawrence T. Doerflein, Ch Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-245, 50-336, 50-423, License Nos.: DPR-21, DPR'65, NPF-49 Enclosure: Inspection Reports 0500024512011009, 05000336/2011009, and 0500042312011009 cc w/encl: Distribution via ListServ
SUMMARY OF FINDINGS
lR 0500024512011009, 0500033612011009, and 0500042312011009; 0410112011 -0412912011;
Millstone Power Station, Units 1 , 2 and 3; Temporary Instruction 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 three resident inspectors and a region based inspector. 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 externalflooding 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. lf lP 71111.05T was recently performed at the facitity 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) utilized for inspection that implementation of B.5.b actions and any additional equipment used in Severe Accident equipment is available Management Guidelines (SAMG). The scope of the equipment was defined as that equipment and functional. Active specifically designated for 8.5.b or SAMG mitigation (i.e., special hoses, fittings, dieselfire pump, equipment shall be etc.). Permanent plant equipment (i.e., in situ equipment) was not considered in the scope, since tested and passive it is normally in service, subjected to planned maintenance, and/or checked on operator rounds.
equipment shall be The licensee then identified surveillances/tests and performance frequencies for the identified walked down and equipment, and reviewed the results of recent tests. Active equipment within the scope defined inspected. lt is not above that did not have recent test results was tested. Passive equipment within the scope was expected that walked down and inspected.
permanently installed equipment that is tested under an existing regulatory testing program be retested.
Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed test results, discussed actions, reviewed records, etc.).
This review should be done for a reasonable sample of mitigating strateqies/eq u ipment.
The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities. In addition, the inspectors independently walked down and inspected all major B.5.b contingency response equipment staged throughout the site. The results of the inspectors' independent walkdowns confirmed the results obtained by the licensee.
The inspectors determined that the 8.5.b strategy was not required to be applied to the Unit 1 spent fuel pool. However, the inspector reviewed procedures developed by the licensee to respond to a B.5.b type event. Additionally the inspector walked down the spent fuel pool and the paths where mitigating equipment would be employed. Documents reviewed by the inspectors are listed in the Supplemental lnformation Attachment to this report.
Discuss general results including corrective actions by licensee.
All equipment (active and passive) designated for B.5.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. Passive equipment which had surveillance and/or preventative 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. Dominion retested selected active equipment on site. Equipment was verified to be within the required surveillance test interval.
Based on the results of the licensee reviews and their own walkdowns, 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 utilized to mitigate the walkdowns or consequences of a 8.5.b related event and severe accidents. Dominion then compiled verification demonstration that documentation for procedure validations and identified any procedures not issued or validated and procedures to implement any with open change requests. Open change requests were reviewed for potential impacts on the strategies associated procedure functionality. Licensee personnel were then dispatched to walk down all applicable with 8.5.b and 10 CFR procedures to verify the ability of the procedures to be executed.
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. In addition, the inspectors selected several sections of a sample of the This review should be procedures walked down by the licensee and walked those down to independently verify the done for a reasonable licensee's conclusions. Documents reviewed by the inspectors are listed in the Supplemental sample of mitigating Information Attachment.
strategies/eq uipment.
Discuss general results including corrective actions by licensee.
Dominion reviewed SAMG strategies and did not identify any issues. Procedures used for 8.5.b were reviewed by the licensee and walkdowns were performed by operators to ensure actions taken in the field in response to a 8.5.b event could be performed. Open procedure change requests were reviewed by the licensee to verify there were no immediate procedure changes required. Some minor enhancements were identified by the licensee and entered into the Corrective Action Program (CAP).
The inspectors identified an enhancement associated with the positioning of the Unit 1 spent fuel pool crane. The licensee entered the issue into the corrective action program (CR 422447).
Based on the results of their reviews the inspectors concluded that that procedures to implement the strategies associated with 8.5.b and 10 CFR 50.54(hh) are in place and are 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 for qualifications of the implementation of actions needed to mitigate a 8.5.b related event, and for the implementation operators and the of actions needed for the SAMG. The licensee documented that operator training requirements support staff needed to were current, and identified those operators with qualification requirements that were not current.
implement the The number of individual with non-current qualifications was small and mainly associated with procedures and work individuals still in the initial training phase of their qualifications. In addition, the licensee identified instructions are current the training/qualification requirements for applicable emergency response organization (ERO)for activities related to command and support staff for the implementation of actions needed to mitigate a 8.5.b related Security Order Section event, and for the implementation of actions needed for the SAMGs, and documented that ERO B.5.b and severe command and support staff training requirements were current. Where applicable, those ERO accident management command and support staff with qualification requirements that were not current were identified.
guidelines as required by 10 cFR 50.54 (hh).
Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.
The inspectors 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.
Based on the reviews completed, the inspectors concluded that the training and qualiflcations of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section 8.5.b and severe accident management guidelines as required by 10 CFR 50.54 (hh).
Documents reviewed by the inspectors are listed in the Supplemental Information Attachment.
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. Training was identified for shift managers, shift engineers, and unit supervisors, and verified that the training requirements were embedded within the position qualifications for the operators. Dominion 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 B.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 8.5.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 Licensee actions included the identification of all 16 applicable agreements committed to be in applicable agreements place for offsite support for the emergency plan, including equipment and services to mitigate a and contracts are in B.5.b related event. The licensee verified that the agreements were current, and documented place and are capable of whether or not the required offsite equipment and services were available.
meeting the conditions needed to mitigate the consequences of these For a sample of mitigating strategies involving contracts or agreements with offsite entities, events.
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 current).
This review should be done for a reasonable sample of mitigating The inspectors assessed the licensee's capabilities by conducting an independent review of the strategies/equipment.
licensee's emergency response agreements with the Town of Waterford Town Fire Commission, and Electric Boat Corporation. The inspectors' review of the agreements verified that they were current, and assessed whether or not they were adequate for meeting the licensee's mitigation strategy.
Documents reviewed by the inspectors are listed in the Supplemental Information Attachment.
Discuss general results including corrective actions by licensee.
Dominion reviewed their letter of agreement with the Town of Waterford Fire Commission. The letter of agreement was last revised in November 2008. The Fire Chief was contacted by the licensee as part of their review efforts to ensure that the letter of agreement was still in effect and that no changes were necessary. The Fire Chief confirmed the status of the letter of agreement.
In addition, the licensee also verified the list of available vendors for portable pumps and generators had changed. During the course of their review, the licensee updated their offsite vendor list.
Based on their review, the inspectors concluded that applicable agreements and contracts are in place and are 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.
Review any open The inspectors reviewed each condition report (CR) listed in the Supplemental Information for corrective action potential impact to the licensee's mitigation strategies. No significant impacts were identified.
documents to assess problems with mitigating strategy implementation identified by the licensee. Assess the impact of the problem on the mitigating capability and the remaining capability that is nol impacted.
03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Afternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that 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 Dominion actions included the identification of equipment utilized/required for mitigation of a SBO.
walkdowns and Dominion conducted walkdowns of this equipment to ensure they were adequate and properly inspection that all staged. Additionally, the licensee conducted a review of open CRs for potential SBO impact.
required materials are adequate and properly staged, tested, and Describe inspector actions to verify equipment is available and useable.
maintained.
The inspectors assessed the licensee's capability to mitigate SBO conditions by conducting a review of Dominion's walkdown activities. In addition, the inspectors selected a sample of equipment utilized/required for mitigation of a SBO and conducted independent walkdowns of that equipment to ensure that it was properly aligned and staged. The sample of equipment selected by the inspectors included, but was not limited to, the SBO diesel generator and its auxiliaries.
Documents reviewed by the inspectors are listed in the Supplemental lnformation Attachment.
Discuss general results including corrective actions by licensee.
ln general, Dominion's reviews verified that SBO equipment was ready to respond to a SBO condition. The licensee identified a number of enhancements during their review and these were entered in to their corrective action program. The CRs are listed in the Supplemental Information
.
Based on the their reviews, the inspectors concluded that the required equipiment was properly staged, tested and maintained.
Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.
b. Demonstrate through Dominion actions included the identification of procedures required for response to a SBO, along walkdowns that with verification that the identified procedures were current and that no critical revision requests procedures for response were in progress. Dominion verified that the mitigating procedures had been properly validated.
to an SBO are Additionalty, Dominion conducted a review of their corrective action program for any condition executable.
reports which had the potential to impact the SBO 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 Dominion's validation activities. In addition, the inspectors selected several sections of a sample of SBO procedures and walked those down with a Dominon senior reactor operator to independently verify the licensee's conclusions.
Documents reviewed by the inspectors are listed in the Supplemental Information Attachment.
Discuss general results including corrective actions by licensee.
The Dominion procedures utilized to respond to a SBO are within the site's emergency operating procedures (EOP). Actions to start the SBO diesel generator and supply power to site essential loads are performed from permanently installed equipment in the plant. For purposes of this requirement, the licensee credited their original validation of the specific EOPs by a crew of licensed operators prior to the implementation of the current revision. No current issues were identified by the licensee. Based on the activities discussed above, the inspectors concluded that the procedures for responding to an SBO were executable.
03.03 Assess the licensee's capability to mitigate internal and external ftooding events required by station design. Refer to lP 71111.01, "Adverse Weather Protection," Section O2.O4, "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.
Verify through Dominion walked through their abnormal operating procedures dealing with internal and external walkdowns and flooding to verify that the procedures could be completed as written. Watertight doors and flood inspection that all gates were checked to ensure they were functional. Dominion performed walkdowns of flood required materials are protection equipment to ensure that it was properly staged.
adequate and properly staged, tested, and maintained.
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 Dominion's capabilities to mitigate flooding by conducting a review of their walkdown activities. The reviews involved accompanying Dominion personnel during their walkdown and conducting independent walkdowns of the abnormal operating procedures and flood mitigation equipment. The inspectors' conclusions aligned with the results obtained by Dominion.
Documents reviewed by the inspectors are listed in the Supplemental Information Attachment.
Discuss general results including corrective actions by licensee.
The inspectors concluded that all required materials are adequate and properly staged, tested, and maintained to respond to an internal or external flood within the Millstone design basis. While no operability or significant concerns were identified, Dominion identified a few minor deficiencies during their walkdowns and initiated CRs to address them. The CRs are listed in the Supplemental lnformation Attachment of this report. The inspector reviewed the associated CRs and determined that the licensee's initial responses, including their assessment and prioritization, were appropriate.
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 vulnerabitities (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 Inspection," 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 Dominion engineers walked down fire and flooding equipment to determine the impact of seismic walkdowns that all events on station fire and flooding mitigation strategies. Dominion engineers examined equipment required materials are that is seismically qualified, seismically rugged, or vulnerable to seismic events. For the adequate and properly equipment that was vulnerable to seismic events, the engineers determined if there were staged, tested, and mitigating strategies in place or that further evaluation was needed.
maintained.
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 during a seismic event. This equipment included, but was not limited to:
.
all major 8.5.b contingency response equipment staged throughout the site; o the installed diesel and electric fire pumps and their controls; and e watertight doors, flood doors, and flood protection equipment Licensee flood and fire mitigation procedures were reviewed to verify usability. 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 current licensing and design basis for B.5.b, fire protection, and flooding.
Documents reviewed by the inspectors are listed in the Supplemental Information Attachment.
Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.
As noted above, the inspectors determined that the licensee meets current licensing and design basis for 8.5.b, fire protection, and flooding "Seismically qualified" is defined as the structures, systems, and components (SSC) 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 seismically rugged. The majority of room flood mitigation sump pumps and flooding detectors were not designed as seismically qualified and have not been evaluated as being seismically rugged. Similarly, the vast majority of the fire protection system, including both installed fire pumps, was not designed as seismically qualified and cannot be considered seismically rugged. Firefighting equipment staged to respond to B.5.b events was not stowed in seismically qualified buildings and locations, as a seismic event and B.S.b event were not assumed to occur coincidentally. Finally, the inspectors determined that the access pathways to the spent fuel pool island, although robustly designed, could not be verified to withstand seismic loading. The licensee entered these issues into a beyond design basis database for further evaluation.
Dominion's preliminary reviews identified instances where seismic event response capability could be enhanced. These included improving procedural guidance and reviewing the locations of portable equipment. Final resolution and/or mitigating strategies were still under evaluation at the close of this inspection.
The inspector determined that the Unit 1 fire main isolation valve would need to be operated to pressurize the fire main to mitigate a fire in Unit 1, but the valve would be under water (inaccessible) following a design basis flood event. This item required further evaluation and was documented in Dominion's CAP.
Meetinos 4OAO Exit Meetinq The inspector presented the inspections results for the Unit 1 spent fuel pool to Mr. R MacManus and other members of the licensee management on April 15,2011. The inspectors presented the remaining inspection results to Mr. MacManus and other members of licensee management at the conclusion of the inspection on April 28,2011.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
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SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. MacManus, Director of Safety and Licensing
- T. Cleary, Supervisor, Licensing
- B. Bartron, Supervisor Licensing
- T. Berger, Shift Manager Unit 3
- S. Baker, Former Shift Manager, Unit 2