IR 05000456/2011011

IR 05000456-11-011, IR 05000457-11-011, on 04/01/2011 - 04/21/2011; Braidwood Station, Units 1 and 2, Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event

ML111320261
Person / Time
Site:	Braidwood
Issue date:	05/13/2011
From:	Eric Duncan Region 3 Branch 3
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
IR-11-011
Download: ML111320261 (25)

Text

May 13, 2011

SUBJECT:

BRAIDWOOD STATION UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000456/2011011; 05000457/2011011

Dear Mr. Pacilio:

On April 21, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Braidwood Station, Units 1 and 2, using Temporary Instruction (TI) 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 21, 2011, with Mr. D. Enright and other members of your staff.

The objective of this inspection was to promptly assess the capabilities of Braidwood 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, 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 a separate 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 the 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/

Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77

Enclosure:

Inspection Report 05000456/2011011; 05000457/2011011 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 50-456; 50-457 License Nos: NPF-72; NPF-77 Report Nos: 05000456/2011011; 05000457/2011011 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Units 1 and 2 Location: Braceville, IL Dates: April 1, 2011, through April 21, 2011 Inspectors: J. Benjamin, Senior Resident Inspector D. Betancourt-Roldan, Acting Resident Inspector M. Perry, IEMA Inspector Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000456/2011011, IR 05000457/2011011; 04/01/2011 - 04/21/2011; Braidwood Station,

Units 1 and 2, Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event This report covers an announced Temporary Instruction inspection. The inspection was conducted by resident 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 a separate 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 Licensee actions included the transport and testing of the portable pump that is utilized that equipment is available and within the applicable licensing basis. The pump was tested in accordance with a predefined functional. Active equipment preventative maintenance work instruction. In addition to the pump, the licensee performed shall be tested and passive hydrostatic testing of the fire hoses that would be utilized with this pump to ensure adequate equipment shall be walked down equipment performance. Permanently installed equipment such as emergency diesel and inspected. It is not generators and emergency core cooling water pumps were not specifically tested as a result expected that permanently of this effort since this equipment was routinely tested and checked on daily operator installed equipment that is rounds.

tested under an existing regulatory testing program be The licensee performed an inventory inspection of equipment staged in the B.5.b pump retested.

warehouse in accordance with station procedures. Additionally, the licensee performed a walkdown within the plant for equipment utilized within the Severe Accident Management This review should be done for a Guidelines (SAMGs). The licensee conducted this review to ensure that equipment used in reasonable sample of mitigating SAMG strategies was available and accessible for use.

strategies/equipment.

The licensee reviewed the materials and equipment storage locations to determine if the specific locations provided adequate shelter from postulated security-related or natural phenomena events.

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

The inspectors reviewed the licensees assessment related to this area to ensure that the licensees review was consistent with the expectations provided in the operating experience.

Additionally, the inspectors reviewed the issues, and observations identified by the licensee and by the inspectors to ensure that they were entered into the corrective action program.

The inspectors conducted independent reviews and walkdowns to ensure that the B.5.b pump and ancillary equipment was available and capable for use consistent with the licensing basis. The inspectors observed the licensees testing of the B.5.b portable pump and reviewed the completed preventative maintenance testing activities to ensure that the pump would function as required. The inspectors performed a walkdown of the B.5.b equipment warehouse to ensure B.5.b equipment was properly staged and available. The inspectors verified that equipment utilized to transport the B.5.b pump was both available and capable. Additionally, the inspectors conducted plant walkdowns for the station auxiliary feedwater, fire protection, and hydrogen recombiner systems to ensure that this equipment was accessible and available for use in implementing the stations SAMGs.

Discuss general results including corrective actions by licensee.

The inspectors identified that the licensee would have encountered several unplanned challenges in implementing various B.5.b mitigating strategies. These issues were identified by both the inspectors and by the licensee. These challenges include several examples in which prior opportunities for identification by the licensee existed. For example, the starting of the B.5.b pump was delayed after an issue with a support system required to start the pump was identified (IR 118926). Other delays identified by the licensee and/or the inspectors included:

• Flanges required to support B.5.b strategies were made of steel and were very heavy, making transport and installation of the equipment difficult with the resources that may be available (IR 1190517);

• Difficulty in obtaining access to a fire protection valve needed to implement B.5.b strategies due to the specific location (IR 1190203);

• Miscellaneous B.5.b equipment was not labeled (IR 1195986, IR 1190292);

• A weld must be removed to open a hatch to gain access to a refueling water storage tank (RWST) area used to implement B.5.b strategies (IR 1190588); and

• The B.5.b procedure lacked required steps to install fire pump hoses at multiple locations (IR 1194736).

Both the inspectors and the licensee identified that the B.5.b pump annual preventative maintenance test did not contain clear acceptance criteria that ensured the pump would be capable of supplying rated flow. Additionally, the testing of this pump was currently treated as a preventative maintenance activity rather than a testing activity. As such, the structure of the acceptance criteria was embedded in the work instruction as compared to clearly identifiable acceptance criteria more commonly found in a surveillance activity. The inspectors did not identify a violation associated with these observations since the B.5.b pump was not safety-related or of augmented quality. Additionally, the licensee informed the inspectors that it was typical for the vendor to observe the annual pump performance test and that flow was monitored. The licensee captured the inspectors observations in the corrective action program (IR 1204857).

The licensee identified that the make-up demineralizer project abandoned the non-essential service water (WM) supply to the fire protection cross-tie, which was identified as a potential water source for B.5.b equipment. The licensee entered this issue into their corrective action program (IR 1190186).

Additional issues identified by the inspectors included:

• The licensee did not understand how long the B.5.b pump would run under rated load (i.e., did not understand the size of the fuel oil tank and pump rated fuel oil usage). Additionally, the inspectors identified that the B.5.b pump and pump skid did not have a fuel oil gage that would provide operators an indication of how much fuel oil remained in the fuel oil tank;

• The station did not utilize a fuel oil additive to ensure that the fuel oil remained useable during extremely cold weather conditions (IR 1204477).

The licensee identified that the B.5.b pump warehouse was not seismically qualified, and was not required to be seismically qualified. The licensee entered this observation in the stations corrective action program (IR 1190212). The inspectors observed that the B.5.b warehouse had no fire protection detection or suppression.

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 reviewed the B.5.b strategies and applicable Severe Accident Management demonstration that procedures Strategies to ensure that the implementing procedures were available at their required to implement the strategies locations. The licensee performed system walkdowns of selected procedures to verify that associated with B.5.b and the equipment was accessible, adequately labeled, and that the procedure could be 10 CFR 50.54(hh) are in place executed as written.

and are executable. Licensees Describe inspector actions and the sample strategies reviewed. Assess whether may choose not to connect or procedures were in place and could be used as intended.

operate permanently installed The inspectors reviewed the licensees assessment related to this area to ensure that the equipment during this licensees review was consistent with the expectations provided in the operating experience.

verification.

Additionally, the inspectors reviewed the issues and observations identified by the licensee and by the inspectors to ensure that they were entered into the corrective action program.

This review should be done for a reasonable sample of mitigating The inspectors independently verified that the procedures were available at a sample of the strategies/equipment.

assumed locations and were the correction revision. The inspectors conducted independent walkdowns at the B.5.b building and within the station to verify that equipment utilized in the Extensive Damage Mitigation Guidelines (EDMGs) and SAMGs was available for use.

Discuss general results including corrective actions by licensee.

Procedures were properly staged and of the correct revision. The station identified numerous issues with delays with implementing the B.5.b mitigation strategies, issues with equipment labeling, and one issue which may have resulted in the removal of a credited B.5.b water source. Additionally, the stations Nuclear Oversight Department (NOS)identified that previously scheduled actions to label B.5.b equipment in response to a December 2009 NOS evaluation had not yet been completed (IR 1195986).

As a result of the operating experience review, the licensee placed an administrative hold on removing the stations hydrogen recombiners from the SAMGs. This system had previously been removed from the stations licensing basis and considered abandoned in place. Although the system was abandoned in place, the system was physically installed and may be available for use in beyond design basis accident conditions. As a part of this review, the station was re-evaluating the status of this system (IR 1190228).

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

c. Verify the training and The licensees review included the identification of operator training and qualification qualifications of operators and requirements for the implementation of actions needed to mitigate B.5.b related events, and the support staff needed to for the implementation of the SAMGs. The licensee reviewed the stations learning implement the procedures and management training system records to verify that the required Maintenance first line work instructions are current for supervisors and Operations personnel met the B.5.b and SAMG training qualification activities related to Security requirements. In addition, the licensee identified the training qualification requirements for Order Section B.5.b and severe applicable emergency response organization (ERO) command and support staff for the accident management implementation of actions needed to mitigate a B.5.b related event, and for the guidelines as required by implementation of actions for the SAMGs. The licensee ensured that a sample of the ERO 10 CFR 50.54 (hh).

command and support staff training requirements were current.

Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.

The inspectors reviewed the licensees assessment related to this area to ensure that the licensee review was consistent with the expectations provided in the operating experience.

The inspectors independently reviewed records from the stations learning management system and independently sampled a population of ERO command and support staff SAMG training records to ensure that the staffs training was up to date. Additionally, the inspectors reviewed a sample of the training material for SAMGs and B.5.b to understand the type of training that was provided.

Discuss general results including corrective actions by licensee.

The licensee did not identify any issues. The inspectors did not identify any issues.

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

d. Verify that any applicable The licensee conducted a review of the Braidwood B.5.b and severe accident management agreements and contracts are in strategies to identify any applicable off-site agreements and contracts necessary to support place and are capable of implementation. These contracts and agreements involved the local fire department, meeting the conditions needed hospitals, law enforcement, and diesel fuel oil vendor, as well as contracts with engineering to mitigate the consequences of vendors. Additionally, the licensee verified that these contracts were adequate to meet the these events.

intent for which they were comprised.

This review should be done for a For a sample of mitigating strategies involving contracts or agreements with offsite reasonable sample of mitigating entities, describe inspector actions to confirm agreements and contracts are in place strategies/equipment.

and current (e.g., confirm that offsite fire assistance agreement is in place and current).

The inspectors reviewed the licensees assessment related to this area to ensure that the licensees review was consistent with the expectations provided in the operating experience.

Additionally, the inspectors verified that issues, observations, and enhancements were entered into the stations corrective action program as appropriate.

The licensee did not identify any issues with the final review. The inspectors did not identify any issues with the off-site agreements from a current licensing basis perspective, however one observation was identified that was outside the scope of the current licensing basis.

The inspectors reviewed the licensees state National Pollutant Discharge Elimination System (NPDES) permit as it pertained to the ability to replenish the stations cooling water lake from a nearby water source, (i.e. Monster Lake and adjacent flooded coal strip mine bodies of water). This permit allowed the licensee to transfer water from these bodies of water if the normal Kankakee River make-up water sources was experiencing low flow.

This allowance could be used by the licensee to maintain power generation capability. The inspectors identified that this permit would not apply to a beyond licensing basis situation in which the ultimate heat sink became depleted. As stated, these sources of water were physically available for use. The inspectors reviewed the licensing basis and did not identify any regulatory issues since the licensing basis assumed that the ultimate heat sink was available following a design basis earthquake and assumed that the ultimate heat sink supply was capable of removing decay heat loads for 30 days following a design basis reactor event.

Discuss general results including corrective actions by licensee.

The licensee determined that the off-site contractual agreements would be adequate for events pertaining to B.5.b and applicable SAMGs. The licensee entered the NRC inspectors observation into their corrective action program for review (IR 1202017).

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 Corrective Action Program issue report numbers are listed in the attachment to this report.

action documents to assess problems with mitigating The inspectors reviewed each of the IRs for potential impact to the licensees B.5.b strategy implementation mitigating strategies. Any findings and/or violations identified as a result of this inspection identified by the licensee.

will be documented in a separate inspection report.

Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.

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 whether 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 re-inspected.

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 performed walkdowns and inspections of contingency and portable equipment inspection that all required relative to mitigating a station blackout event in accordance with the stations quarterly materials are adequate and surveillance procedure (0BwOS OALS-Q1). Additionally, the licensee utilized the operator properly staged, tested, and daily shift round checks performed on the emergency power sources credited during a maintained.

station blackout event.

Describe inspector actions to verify equipment is available and useable.

The inspectors reviewed the licensees assessment related to this area to ensure that the licensees review was consistent with the expectations provided in the operating experience.

Additionally, the inspectors verified that issues, observations, and enhancements were entered into the stations corrective action program as appropriate.

The inspectors verified that a sample of equipment maintained in the stations quarterly surveillance checklist was available and properly staged. Additionally, the inspectors performed a walkdown of all the stations emergency diesel generators to identify any apparent issues that could affect operability. The inspectors reviewed the licensees corrective action program for any known issues that could challenge the functionality of the equipment to ensure that the licensee had performed an adequate assessment and corrective actions were in place.

Discuss general results including corrective actions by licensee.

The licensee identified a number of minor issues and enhancement opportunities.

The inspectors did not identify any issues and determined that the issues identified by the licensee were minor in nature. However, the inspectors identified one observation.

The inspectors observed that there is no direct indication of the stations spent fuel pool level or temperature available in the control room. The inspectors did not identify a regulatory issue with this observation. Additionally, the inspectors observed that the station does not calculate a spent fuel pool time to boil when the units are operating at power. In the case that spent fuel pool cooling is lost, the station has a bounding analysis for the onset of spent fuel pool boiling.

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

b. Demonstrate through The licensee verified that implementing procedures for the station blackout strategies were walkdowns that procedures for up to date and available at their required locations. The licensee performed walkdowns of response to an SBO are these strategies to verify that areas were accessible, procedures could be executed, and executable.

equipment labeling was correct.

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

The inspectors reviewed the licensees assessment related to this area to ensure that the licensees review was consistent with the expectations provided in the operating experience.

Additionally, the inspectors verified that issues, observations, and enhancements were entered into the stations corrective action program as appropriate.

The inspectors reviewed a sample of the station procedures that would be utilized during a station blackout event. The inspectors discussed these procedures with a Braidwood senior reactor operator to understand how these procedures would be utilized from a command and control perspective. The inspectors conducted equipment walkdowns of the emergency diesel generators and auxiliary feedwater systems to identify any apparent issues or challenges in implementing the procedures. Additionally, the inspectors specifically reviewed the capability for the Units to share aspects of their auxiliary feedwater system through a common cross-tie piping connection.

Discuss general results including corrective actions by licensee.

The license identified a number of issues which were entered into the stations corrective action program. The inspectors reviewed these issues and did not identify any findings of significance.

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 identified the flooding procedures that would be utilized for both internally and inspection that all required externally generated flooding events. These procedures were verified to be approved and materials are adequate and in place. The licensee performed walkdowns to verify that all equipment identified in plant properly staged, tested, and procedures conformed to the licensing requirements and was staged appropriately. Doors, maintained.

barriers, penetration seals, and curbs that were utilized for flooding mitigation were inspected to identify deficiencies and to ensure that they would provide a sufficient barrier.

Additionally, the licensee reviewed outstanding work orders and corrective action assignments to evaluate if any vulnerability existed. Identified issues were re-evaluated to ensure compliance with the current licensing basis or evaluated if the issue posed a beyond design basis risk to the plant.

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

The inspectors reviewed the licensees assessment related to this area to ensure that the licensees review was consistent with the expectations provided in the operating experience.

Additionally, the inspectors verified that issues, observations, and enhancements were entered into the stations corrective action program as appropriate.

With regard to external flooding, the inspectors review included checking for deviations from the descriptions provided in the Updated Final Safety Analysis Report (UFSAR) for features intended to mitigate the potential for flooding from external factors. The inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined whether barriers required to mitigate a flooding event were in place and operable.

Additionally, the inspectors performed a walkdown of the protected area to identify any modification to the site which would inhibit site drainage during a probable maximum precipitation event or allow water ingress past a barrier. The inspectors also reviewed the abnormal operating procedure for mitigating the design basis flood to ensure it could be implemented as written.

With regard to internal flooding, the inspectors reviewed selected risk-important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flooding analyses and design documents, including the UFSAR; engineering calculations; and abnormal operating procedures, to identify licensee commitments. In addition, the inspectors conducted plant system walkdowns to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or circulating water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood-related items to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the essential service water system area to assess the adequacy of watertight doors and to verify that drains and sumps were clear of debris and were operable, and that the licensee complied with all commitments.

Discuss general results including corrective actions by licensee.

The licensee did not identify any regulatory issues, but did identify a number of enhancements. Issues identified by the licensee included:

• IR 1192624. The licensee identified the need to have a predefined contingent work order in place to prevent unnecessary delays in opening flood seal vaults to access auxiliary feedwater system isolation valves.

• IR 1200980. The licensee identified that there were no actions to manually isolate the essential service water pump suction valve by hand or to isolate the essential service water discharge to the lake. Additionally, associated valve labels were difficult to read from the ground.

• IR 1197767. The licensee identified there were differences in the Braidwood and Byron flooding procedure isolation points. Due to the similarities in the plant design and licensing basis between these stations, the licensee documented this observation to better understand the basis for these differences.

• IR 1197770. The licensee identified that the stations flood seal inspection criteria was general and subjective in nature.

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 into 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 identified the applicable procedures that would be utilized to mitigate a fire and all required materials are or flood event to identify any potential that the equipments function could be lost during a adequate and properly staged, design basis seismic event at the station. The licensee performed walkdowns associated tested, and maintained.

with the storage of fire protection equipment, such as the stations fire brigade truck, carbon dioxide storage tanks, halon bottles, and the emergency diesel generators fuel oil storage tanks foam suppression system. The licensee evaluated if the equipment and particular storage location was seismically qualified to ascertain if it would be reasonable to conclude if the equipment would be available for use during and following a design basis earthquake.

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

The inspectors reviewed the licensees assessment related to this area to ensure that the licensees review was consistent with the expectations provided in the operating experience.

Additionally, the inspectors verified that issues, observations, and enhancements were entered into the stations corrective action program as appropriate.

The inspectors independently reviewed the procedures that would be utilized during an earthquake, fire, and/or flooding event. The inspectors conducted multiple independent walkdowns and reviewed the documented assessment for the walkdowns conducted by the licensee. These walkdowns included, but were not limited to:

• B.5.b pump warehouse and ancillary equipment;

• All installed fire protection and suppression equipment in the turbine building;

• The emergency diesel generator fuel oil storage tank rooms;

• The main steam line tunnel area.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

The licensee did not identify any new mitigating strategies as a result of their review.

The licensee did identify that a number of fire protection suppression and support systems were not designed or stored within seismic structures. Additionally, on-site radio and pager communications were also located in non-seismic structures. Therefore, these systems may not be available during a design basis earthquake. For example, the carbon dioxide and halon tanks used as the source of fire suppression for the upper and lower cable spreading rooms were located in the turbine building (IR1199209). Additionally, the station fire brigade vehicle was, at times, stored in the turbine building. The turbine building was not a safety-related seismic structure. The licensee entered these observations into the corrective action program for further internal assessment.

4OA6 Management Meetings

.1 Exit Meeting Summary

On April 21, 2011, the inspectors presented the inspection results to Mr. D. Enright, and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Enright, Site Vice President

M. Kanavas, Plant Manager

P. Daly, Radiation Protection Manager

B. Finlay, Security Manager

R. Gadbois, Maintenance Manager

G. Galloway, Work Control Manager

M. Marchionda, Operations Manager

S. McKinney, Emergency Preparedness Coordinator

J. Moser, Radiation Protection Manager

R. Radulovich, Nuclear Oversight Manager

J. Rappeport, Chemistry/Environmental Manager

A. Ferko, Engineering Manager

C. VanDenburgh, Regulatory Assurance Manager

W. Waznis, Nuclear Oversight

Nuclear Regulatory Commission

E. Duncan, Chief, Branch 3, Division of Reactor Projects

LIST OF ITEMS

OPENED

Opened

None.

Enclosure