IR 05000461/2011011

IR 05000461-11-011, on 03/23/2011 - 04/29/2011, Clinton Power Station, Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event

ML111320336
Person / Time
Site:	Clinton
Issue date:	05/13/2011
From:	Ring M NRC/RGN-III/DRP/B1
To:	Pacilio M Exelon Nuclear
References
IR-11-011
Download: ML111320336 (29)

Text

May 13, 2011

SUBJECT:

CLINTON POWER STATION - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000461/2011-011

Dear Mr. Pacilio:

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Clinton Power Station, 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 May 4, 2011, with Mr. F. Kearney and other members of your staff.

The objective of this inspection was to promptly assess the capabilities of Clinton 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, along with the results from this inspection performed at other operating commercial nuclear plants in the United States, will be used to evaluate the U.S. nuclear industrys readiness to safely respond to similar events. These results will also help the NRC to determine if additional regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in the next quarterly report. You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark A. Ring, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62

Enclosure:

Inspection Report 05000461/2011-011

REGION III==

Docket No: 50-461 License No: NPF-62 Report No: 05000461/2011-011 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station, Unit 1 Location: Clinton, IL Dates: March 23 through April 29, 2011 Inspectors: B. Kemker, Senior Resident Inspector D. Lords, Resident Inspector S. Mischke, Resident Inspector, Illinois Emergency Management Agency Approved by: M. Ring, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 0500005000461/2011-011, 03/23/2011 - 04/29/2011; Clinton Power Station 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 and Region III inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,

Reactor Oversight Process, Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the TI (Temporary Instruction) is to provide a broad overview of the industrys preparedness for events that may exceed the current design basis for a plant. The focus of the TI was on

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

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

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

(4) assessing the thoroughness of the licensees walk downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. If necessary, a more specific follow-up inspection will be performed at a later date.

INSPECTION RESULTS

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in the next quarterly report.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines, and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), Section 02.03 and 03.03 as a guideline. If IP 71111.05T was recently performed at the facility, the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect the equipment.

a. Verify through test or inspection The licensees actions included identification of equipment (active and passive) utilized for that equipment is available and implementation of Section B.5.b actions and any additional equipment used in Severe functional. Active equipment Accident Management Guidelines (SAMGs). The scope of the equipment was defined as shall be tested and passive that equipment specifically designated for B.5.b or SAMG mitigation (e.g., special hoses, equipment shall be walked down fittings, pumps, cables, tools, etc.). Permanent plant equipment (i.e., in situ equipment) was and inspected. It is not generally not considered in the scope, since it is normally in service, subjected to planned expected that permanently maintenance, and/or checked on operator rounds. However, the horizontal fire pump installed equipment that is (0FP03P), which is permanently installed equipment available for use by the licensees tested under an existing response procedures, was specifically tested. The licensee walked down the mitigation regulatory testing program be procedures referenced below in Section 03.01.b to verify that any equipment needed to retested.

perform required actions was available and functional, was identified in the referenced procedures, and the location was tracked and periodically checked. The current condition This review should be done for a of the contingency and portable equipment was verified. The licensee then identified reasonable sample of mitigating surveillances/tests and performance frequencies for the identified equipment, and reviewed strategies/equipment.

the results of recent tests. Active equipment within the scope defined above that did not have recent test results was tested. Passive equipment within the scope was walked down and inspected.

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

Most of the licensees actions discussed above were completed prior to the issuance of NRC Temporary Instruction (TI) 2515/183. The inspectors assessed the licensees capabilities by conducting a review of the results from the licensees walk down activities.

The inspectors independently walked down and inspected all major B.5.b contingency response equipment staged throughout the site with the licensee. The inspectors observed the licensee test the horizontal fire pump, portable (i.e., trailer mounted) B.5.b fire pump, and portable floating fire pump. In addition, the inspectors performed independent walk downs of seven of the B.5.b extensive damage mitigation procedures and four of the SAMG implementation procedures with licensed and non-licensed operators. In general, the results of the inspectors independent equipment and procedure walk downs confirmed the results obtained by the licensee. The inspectors reviewed and discussed the results of the recently performed IP 71111.05T inspection (NRC Inspection Report 05000461/2011009)with the inspection team leader. There were no significant issues related to B.5.b extensive damage mitigation actions during the IP 71111.05T inspection.

Discuss general results including corrective actions by the licensee.

In general, all equipment (active and passive) designated for B.5.b was verified to be located in appropriate storage locations and contained in applicable procedures.

All passive equipment was walked down and verified to be in place and ready for use.

Passive equipment that 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 and tested by the licensee. Several equipment staging and labeling enhancements were identified by the licensee and entered into its corrective action program.

The licensee identified the following deficiencies:

(1) Action Request (AR) 01191284 was written to identify that functional testing of two Rosemount direct current (DC) voltage sources and a handheld tachometer identified dead batteries. The tachometer was replaced with a functioning tachometer and the associated procedures were revised to allow use of alternate DC sources and a standard multi-meter for monitoring transmitter output. Additional actions to revise the quarterly inventory procedure to include functional testing of these devices are being tracked by the licensee.

(2) AR 01196176 was written to identify that the fuel in the portable B.5.b fire pump has not been replaced within the past year, as required by recently issued procedure OP-AA-201-010-1001, B.5.b Mitigating Strategies Equipment Expectations.

The licensee is evaluating the most appropriate approach to ensuring high quality fuel is maintained for this pump.

(3) AR 01191290 was written to identify that CPS 4303.01F001, Extensive Mitigation Guide Flowchart, directs arranging for fuel deliveries, consideration for obtaining a trailer mounted 4160 volt alternating current (VAC) diesel generator, obtaining an offsite air supply, arranging for supplies of food, drinking water, personal necessities, and portable toilets. Although no Memorandums of Understanding (MOUs) were located specifically addressing these items, these are items that would be obtained as part of the normal Emergency Response Organization (ERO) functions. These are not equipment that would be required in order to implement any mitigating strategy prior to staffing the ERO. The licensee is evaluating whether MOUs would be appropriate for this activity.

The inspectors noted the following issue:

(1) Material condition of the diesel-driven horizontal fire pump was generally poor and the licensee has not focused appropriate attention to maintaining the pump. During a test run observed by the inspectors on April 6, 2011, the pumps inboard and outboard shaft packing glands overheated and failed. The operator had to shut down the pump early during the test run. ARs 01198618 and 01203214 were written to address the pump shaft packing problem. During the past year, there have been several material condition issues identified by the licensee affecting the horizontal fire pump including problems with the pump shaft packing glands, bearings, battery, and battery charger. No specific commitments were found during this review for the licensee to maintain this pump to implement the strategies associated with B.5.b and 10 CFR 50.54(hh).

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

b. Verify through walk downs or The licensees verification actions included identification of those procedures utilized to demonstration that procedures implement the strategies associated with B.5.b and SAMGs. The licensee then compiled to implement the strategies verification documentation for procedure validations and identified any procedures not associated with B.5.b and issued or validated and any with open change requests. Open change requests were 10 CFR 50.54(hh) are in place reviewed for potential impacts on procedure functionality. The licensee walked down all and are executable. Licensees applicable procedures containing B.5.b and SAMG implementation strategies to validate may choose not to connect or that the strategies were in place and executable. In addition, associated support/referenced operate permanently installed procedures were reviewed to identify any use of any temporary or specially fabricated equipment during this equipment. Current revisions of approved procedures were validated to be located in the verification.

designated emergency use locations (i.e., Main Control Room, Technical Support Center, Operations Support Center, Remote Shutdown Panel, and Radwaste Operations Center).

This review should be done for a reasonable sample of mitigating Describe the inspectors actions and the sample strategies reviewed. Assess strategies/equipment.

whether procedures were in place and could be used as intended.

As discussed above, most of the licensees actions were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capabilities by conducting an independent review of the licensees procedures and walk down activities. In addition, the inspectors performed independent walk downs of seven of the B.5.b extensive damage mitigation procedures and four of the SAMG implementation procedures, as discussed above, with licensed and non-licensed operators. In general, the results of the inspectors independent procedure walk downs confirmed the results obtained by the licensee. As discussed below, the inspectors identified some procedure issues during their walk downs.

Discuss general results including corrective actions by the licensee.

The licensee reviewed and walked down procedures utilized to implement the strategies associated with B.5.b and SAMGs and did not identify any significant issues. Refer to Section 03.01.a for the discussion of deficiencies identified with the availability and functionality of temporary equipment required to implement these strategies.

Open procedure change requests were reviewed by the licensee to verify that no immediate procedure changes were required. Numerous procedure enhancements were identified by the licensee and entered into its corrective action program; however, no significant deficiencies were identified in this area.

The licensee identified the following issue:

(1) AR 01192277 was written to identify multiple issues and enhancements to the B.5.b procedures and equipment. One noteworthy example was that the licensees review of CPS 4303.01P019, Hydrogen Igniter Operation With External AC Power, identified that with the current dedicated B.5.b portable generator rated at 5500 Watts, sufficient power would not be available to energize all of the hydrogen igniters.

The Division 1 hydrogen igniters would require 6720 Watts and the Division 2 hydrogen igniters would require 7080 Watts. Depending upon the number of igniter circuits (each division contains five separate circuits) powered by the portable generator, there would be very limited capacity to perform any additional external electrical supply support functions (e.g., powering the safety relief valves).

The inspectors noted the following issues:

(1) CPS 4303.01P026, Emergency Containment Spray Makeup From Fire Protection, Section 1.1, Containment Spray Using RHR [Residual Heat Removal] Flush Lines, Step 1.1.1.7 to align a 480 VAC source to valve 1E12-F028A(B) lacks sufficiently detailed instructions to connect temporary power from Turbine Building outage power panels 0OP64E and 0OP65E. (AR 01211906)

(2) CPS 4303.01P002, Spent Fuel Pool Makeup From Containment Pool, Section 1.1, Spent Fuel Pool Makeup Using IFTS [Inclined Fuel Transfer System], Step 1.1.3 to open valve 1F42-F004 from the Fuel Building hydraulic power unit lacks sufficiently detailed instructions for all but a few plant staff with additional specific knowledge of the system to open the valve. (AR 01210365)

(3) The licensee had not initially reviewed open change requests for potential impacts on procedure functionality, but completed the review in response to the inspectors questions. No significant impacts were identified during the review.

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

c. Verify the training and The licensees actions included the identification of training/qualification requirements for qualifications of operators and licensed and non-licensed operators for implementing actions needed to mitigate a B.5.b the support staff needed to related event and for implementing the SAMGs. In addition, the licensee identified the implement the procedures and training/qualification requirements for applicable ERO command and support staff for work instructions are current for implementing actions needed to mitigate a B.5.b related event and for implementing the activities related to Security SAMGs. The licensee documented that all training requirements were current.

Order Section B.5.b and severe accident management Describe the inspectors actions and the sample strategies reviewed to assess guidelines as required by training and qualifications of operators and support staff.

10 CFR 50.54 (hh).

The licensees actions discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees training and qualification activities by conducting a review of the training and qualification materials and records related to B.5.b and SAMG event response. In general, the results of the inspectors review confirmed the results obtained by the licensee.

Discuss general results including corrective actions by the licensee.

The training/qualification requirements for licensed and non-licensed operators, as well as ERO command and support staff for the implementation of B.5.b event response and SAMGs, were verified current by the licensee. The inspectors identified no discrepancies with the licensees training materials or records.

The inspectors noted the following issue:

(1) Adequate training is lacking for implementation of CPS 4303.01, Extensive Damage Mitigation Guide, and CPS 4303.01P018, ERO Activation During Extreme Damage Event, to enable non-licensed plant staff (e.g., non-licensed operators and security staff) on shift to initiate communications and activate the ERO in accordance with the procedures. In particular, non-licensed operators and security staff were unfamiliar with these procedures and have had no specific training on them. (AR 01211906)

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

d. Verify that any applicable The licensees actions included the identification of all applicable contracts and agreements agreements and contracts are in committed to be in place for the mitigation of a B.5.b related event. The licensee verified place and are capable of that the contracts and agreements were current, and documented whether or not the meeting the conditions needed contracts/agreements were capable of meeting the mitigation strategy. MOUs to support to mitigate the consequences of fire response, security response, medical response, and ERO support were reviewed and these events.

organizations contacted to validate that they are capable of meeting the conditions needed to support the associated MOU. Local law enforcement involvement related to B.5.b and This review should be done for SAMG events is limited to controlling access and directing traffic. These functions are a reasonable sample of addressed in the associated MOUs.

mitigating strategies/equipment.

For a sample of mitigating strategies involving contracts or agreements with offsite entities, describe the inspectors actions to confirm agreements and contracts are in place and current (e.g., confirm that offsite fire assistance agreement is in place and current).

The licensees actions discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capabilities by reviewing the existing agreements to verify that they were current and that appropriate support needs were addressed by the agreements. The results of the inspectors review confirmed the results obtained by the licensee.

Discuss general results including corrective actions by the licensee.

Existing agreements were current and were capable of meeting the mitigation strategies.

The licensee identified the following issue during its review:

(1) AR 01191290 was written to identify that CPS 4303.01F001, Extensive Mitigation Guide Flowchart, directs arranging for fuel deliveries, obtaining a trailer mounted 4160 VAC diesel generator, obtaining an offsite air supply, arranging for supplies of food, drinking water, personal necessities and portable toilets. Although no MOUs exist specifically addressing these items, they would not be required to implement any mitigating strategy prior to staffing the ERO.

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 The inspectors reviewed action requests initiated by the licensee for potential impact to action documents to assess the licensees mitigation strategies. Noteworthy issues identified by the licensee and the problems with mitigating inspectors were discussed above in Sections 03.01.a through 03.01.d.

strategy implementation Numerous procedure enhancements were identified by the licensee and entered into its identified by the licensee.

corrective action program; however, no significant deficiencies were identified in this area.

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 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 walk downs and The licensees actions included the identification of equipment (both active and passive)inspection that all required utilized/required for mitigation of a SBO. The licensee tested active equipment to verify that materials are adequate and it was functional and conducted walk downs of staged equipment to ensure it was adequate properly staged, tested, and and available.

maintained.

Describe the inspectors actions to verify equipment is available and useable.

Many of the licensees actions discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capability to mitigate SBO conditions by reviewing the licensees testing and walk down activities. In addition, the inspectors selected a sample of equipment utilized/required for mitigation of a SBO and conducted independent walk downs of that equipment to verify that the equipment was properly aligned and staged. In addition, the inspectors performed a walk down of one of the SBO mitigation procedures with a licensed operator. The results of the inspectors independent equipment and procedure walk downs confirmed the results obtained by the licensee.

Discuss general results including corrective actions by the licensee.

In general, all equipment designated for SBO mitigation was verified to be located in appropriate storage locations and was contained in applicable procedures. All passive equipment was walked down and verified to be in place and ready for use. All active equipment located at the site was verified in place and tested by the licensee.

The licensee identified the following deficiencies:

(1) AR 116032 was written on January 24, 2011, to track repairs to gasoline-powered Main Control Room (MCR) cooling fan 0VC28CA that failed to start during functional testing. Troubleshooting determined that the engine had no spark. Since the backup MCR Cooling fan (0VC28CB) operated properly when tested on March 28, 2011, the SBO MCR cooling strategy was maintained. The 0VC28CA fan was restored to service on April 1, 2011. The licensee has a regularly scheduled preventive maintenance program, including testing of the gasoline-powered MCR fans.

(2) During SBO procedure walk downs, the resistance temperature detector (RTD)precision resistor bridge specified by CPS 4200.01C003, Monitoring CNMT

[Containment] Temperatures During a SBO, for monitoring containment, drywell, and suppression pool temperatures was found in the licensees on-site calibration lab with a dead battery. Alternate instrumentation (digital multi-meter) was functional and available in several maintenance and testing equipment issue areas, including the MCR.

However, a correlation to utilize an alternate instrument had not been validated.

AR 01194055 was written to identify the unavailability of the RTD precision resistor bridge, evaluate the use of more readily available test equipment to perform this verification, and to identify the lack of periodic inventory verification for this instrumentation. Functionality of the RTD precision resistor bridge was restored on March 29, 2011.

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

b. Demonstrate through walk The licensees actions included the identification of procedures required for response to a downs that procedures for SBO, along with verification that the identified procedures were current and that no critical response to an SBO are revision requests were in place. The licensee then verified that the mitigating procedures executable.

had been properly validated. The procedures provide coping strategies in the event of a SBO to maintain reactor water level. The procedures dictate load shedding actions to be completed within one hour, remote monitoring of critical plant parameters, manual containment isolation actions, and actions to attempt to restore electrical power.

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

Most of the licensees actions discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensees capabilities by conducting a review of the results from the licensees walk down activities. In addition, the inspectors performed a walk down of one of the SBO mitigation procedures with a licensed operator.

Discuss general results including corrective actions by the licensee.

The licensee walked down the SBO response procedures and verified them to be executable. The results of the inspectors review and independent equipment and procedure walk downs confirmed the results obtained by the licensee. The licensee had not initially reviewed open change requests for potential impacts on procedure functionality, but completed the review in response to the inspectors questions. No significant impacts were identified during the review.

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 walk downs and inspections that all required materials and equipment are adequate and properly staged. These walk downs 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 walk downs and The licensees actions included the identification of equipment, barriers, and penetration inspection that all required seals utilized/required for mitigation of internal and external flooding. The licensee then materials are adequate and conducted walk downs of equipment to ensure it was adequate and properly staged.

properly staged, tested, and Doors, barriers, and penetration seals that were utilized for mitigation of flooding were maintained.

identified, and checked to see if they were routinely inspected to ensure functionality.

Where routine inspections were not performed or could not be relied upon to ensure functionality, the licensee performed walk downs and inspections to ensure that the components and flood barriers were functional. The internal and external flooding mitigation procedures (CPS 4303.02, Abnormal Lake Level, and CPS 4304.01, Flooding)were walked down to validate that flood mitigation strategies were in place and executable and required materials and equipment were adequate and properly staged. In addition, associated support/referenced procedures were reviewed by the licensee to identify any use of any temporary equipment.

Describe the inspectors actions to verify equipment is available and useable.

Assess whether procedures were in place and could be used as intended.

The inspectors assessed the licensees capabilities to mitigate flooding by conducting a review of the licensees walk down activities. In several instances, these reviews involved the inspectors accompanying licensee operations and engineering personnel during their in-field walk downs. In addition, the inspectors conducted independent walk downs of selected flood mitigation equipment to contribute to the overall assessment of the licensees flood mitigating capabilities. Licensee flood mitigation procedures were reviewed to verify usability. In general, the inspectors conclusions aligned with the results obtained by the licensee.

Discuss general results including corrective actions by the licensee.

The licensee reviewed and walked down procedures and equipment/materials utilized to implement the strategies associated with internal and external flooding and did not identify any significant issues. Doors, barriers, and seal penetrations credited with flood propagation control were determined from the sites flooding analyses. The licensees reviews confirmed that all flood doors were inspected as part of a routine maintenance program. Flood barriers and penetrations that also serve as fire barriers were determined by the licensee to have been inspected on a routine basis as part of the sites fire protection program. However, the barriers and penetrations that were not part of the fire protection program were identified as not being routinely inspected. The licensee entered this issue into its corrective action program as noted below. Where accessible, the licensee walked down these flood barriers and penetrations. However, the licensee noted that many plant locations were not readily accessible due to high dose rates. Numerous procedure enhancements were identified by the licensee and entered into its corrective action program; however, no significant deficiencies were identified in this area.

The licensee identified the following issues:

(1) AR 01197979 was written to identify that most flood penetration seals were not routinely inspected. No preventive maintenance program or procedural acceptance criteria existed. The licensee completed walk downs of plant areas with flood penetration seals and observed accessible seals. The licensees long term resolution will be to develop a preventive maintenance program to inspect seals on a periodic basis.

(2) AR 01197981 was written to identify that temporary/portable pumps referenced in the licensees flooding response procedures were not staged or identified for specific use.

The licensees planned resolution is to determine the necessary materials and ways to control inventory or stage the pumps. The pumps are normally stocked in general plant tooling inventory. In addition, the licensee plans to evaluate and develop a testing periodicity for the temporary/portable pumps.

(3) AR 01197984 was written to identify that a sufficient number of sandbags were not staged to support both the main dam and the Lake Screen House. Sand is staged near the maintenance shed for the Screen House and also at the dam. The licensees planned actions include validating the staged volumes of sand and increasing the number of sand bags in stores.

(4) AR 01197992 was written to identify that the flooding response procedures reviewed contained several temporary equipment requirements. However, this equipment was not inspected or inventoried on a routine basis. The licensees planned actions are to establish inventory, preventive maintenance, and testing for the temporary equipment.

(5) AR 01197991 was written to identify that during review of each valve used to mitigate internal floods in CPS 4304.01, operators determined that valve 1FP132 was not accessible to use for isolation. The licensees planned action is to identify a different valve further back on the ring header for isolation.

(6) AR 01197988 was written to identify that the necessary inventory fuses for reinstallations called out in CPS 4304.01 for restoration activities was unknown.

These fuses may be available in general populations such as remote-shutdown supplies, but were not set aside or staged to support timely restoration activities.

The licensees planned actions are to segregate and ensure the necessary inventory of fuses.

(7) Transport equipment (i.e., loader or back-hoe, pick-up truck, and shovels) needed to fill/transport sandbags for the main dam and Lake Screen House and to place rip-rap at the dam may not be sufficient. However, this would only be for a beyond design basis flooding event. This was documented in AR 01201621.

In addition, the inspectors identified the following issue:

(1) In July 2010, the inspectors identified that one of three redundant level switches (1LS-TF001B) in the main condenser pit had failed to actuate while testing during the last refueling outage. This is one of three level switches that provides for closure of motor-operated valve 1TF013 to isolate the condenser pit from the Turbine Building floor drain sump in the event of flooding in the main condenser pit. AR 01023891 was written on January 31, 2010, to document the level switch failure; however, the nonconforming condition was not corrected prior to startup from the refueling outage and no evaluation (functionality assessment or nonconformance evaluation) was performed.

Operators signed off the functional test as satisfactory even though one of the level switches had failed. AR 01092206 was written on July 19, 2010, to evaluate the condition and AR 01093181 was written to repair the level switch. The inspectors concluded at that time that the issue was of minor safety significance.

03.04 Assess 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.

Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walk downs 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 walk downs 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 walk downs that The licensees actions included the identification of equipment utilized/required for all required materials are mitigation of fire and flooding events. Engineering guidelines were developed by the adequate and properly staged, licensee for assessing fire suppression and flooding mitigation capabilities. The guidelines tested, and maintained.

included criteria for conducting walk downs and inspections of the equipment, both permanent and temporary. Licensee engineering personnel determined if the equipment was seismically qualified, or assessed whether it would be possible to evaluate the equipment as being seismically rugged. Seismic vulnerabilities, including storage locations, were identified, along with mitigating strategies for equipment that was not seismically qualified.

Describe the inspectors actions to verify equipment is available and useable.

Assess whether procedures were in place and could be used as intended.

The inspectors conducted multiple walk downs, both independently and in conjunction with licensee personnel, of important equipment needed to mitigate fire and flooding events to identify the potential that the equipments function could be lost during a seismic event.

This equipment included, but was not limited to:

• all major B.5.b and SAMG contingency response equipment staged throughout the site;

• installed fire suppression equipment in several areas of the power plant;

• the installed diesel fire pumps and their controls; and

• watertight doors, roof hatches, and floor plugs at the Lake Screen House.

The licensees flooding and fire mitigation procedures were reviewed to verify usability.

The results of the inspectors reviews aligned with the licensees conclusions.

Discuss general results including corrective actions by the licensee.

Briefly summarize any new mitigating strategies identified by the licensee as a result of its reviews.

The licensee reviewed and walked down procedures and structures/equipment/materials utilized to mitigate fire and flooding events to identify where the potential existed for the function of important equipment could be lost during seismic events possible for the site.

Where accessible, the licensee walked down areas of the plant to evaluate survivability of important equipment/materials following a credible seismic event. However, the licensee noted that many plant locations were not readily accessible due to high dose rates.

The licensees reviews for this issue determined that non-safety related equipment and structures, in general, were not considered to be either seismically qualified or seismically rugged due to a wide variety of issues. Many of the room flooding mitigation sump pumps and flooding detectors were not designed as seismically qualified. Similarly, the vast majority of the fire protection (FP) system, including the installed fire pumps and the structures that house them, were not designed as seismically qualified and cannot be considered seismically rugged. Firefighting equipment staged to respond to B.5.b events (e.g., portable trailer mounted fire pump, special hoses, fittings, temporary pumps, cables, tools, etc.) was not stowed in seismically qualified buildings, as a seismic event and B.5.b event have never been assumed to occur coincidentally. However, this could affect the licensees ability to access this equipment if it were needed for firefighting actions following a seismic event.

The licensees reviews identified instances where response capability could be enhanced.

These included improving procedural guidance, reviewing the locations of portable equipment, and reviewing the need for supplemental portable equipment to compensate for the possible loss of the fire pumps and much of the FP system piping.

Further, reviews by the licensee identified that in the event of a postulated earthquake equipment may not function properly due to loss of essential power or being subjected to physical displacement. Numerous survivability enhancements were identified by the licensee as well as some minor material condition issues. No significant deficiencies were identified in this area.

The licensee identified the following issues:

(1) The FP system, in general, is not seismically qualified. The system, including both water and carbon dioxide suppression, was not designed to be seismically qualified.

The FP system services non-seismically qualified buildings, including administrative buildings. Damage to these buildings during a seismic event could impact the FP system ring header. Several plant locations were found to have FP system piping in contact with or in close proximity to other support steel. Although permitted by current design requirements, the FP system piping could be damaged in a seismic event.

Two installed hose stations in the plant were found to have abnormally long unsupported runs. These were identified as unique compared to all other hose station installations in the plant. The licensee also identified that a large scale break in a FP header could also impact some fire barriers such as 2-hour masonry walls.

In addition, the licensee identified that penetration seals are non-seismically qualified.

These seals could fail and leak after a seismic event (particularly those with pipes or conduits in them). They are installed per design, but this is in general a long-term vulnerability with respect to flooding following a seismic event. That said, most plant piping is anchored near the penetration, thus the likelihood for survivability is higher.

AR 01201621 was written to track the licensees evaluation of these and other FP system vulnerabilities that are beyond the plants design basis.

(2) AR 01200782 was written to identify that general staging and storage practices around FP system equipment primarily in non-safety related areas of the plant does not have appropriate sensitivity toward the FP equipment. While storage of some materials near FP equipment may restrict access to it, some storage of larger items could result in displacement and contact with FP equipment causing damage during a seismic event.

(3) AR 01200783 was written to identify abandoned penetration sleeves are laying on FP piping in the vicinity of unfinished walls. These sleeves were previously evaluated as acceptable through analysis, however marginally acceptable. Although tied to general survivability of FP piping during a seismic event, these are unique and easily corrected.

Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. F. Kearney, and other members of licensee management, at the conclusion of the inspection on May 4, 2011.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Bensen, Operations

T. Chalmers, Operations Director

J. Cunningham, Security Manager

A. Darelius, Emergency Preparedness Manager

B. Davis, Regulatory Assurance Manager

R. Frantz, Regulatory Assurance

M. Heger, Mechanical/Structural Design Engineering Manager

F. Kearney, Site Vice President

N. Keen, Mechanical/Structural Design Engineering

A. Khanifar, Engineering Director

S. Kuntz, Operations

S. Lakebrink, Mechanical/Structural Design Engineering

J. Lizewski, Operations

E. Rodriguez-Ramos, Plant Systems Engineering

J. Ruth, Operations Training Manager

D. Shelton, Operations Services Manager

J. Ufert, Fire Marshall

S. Wilson, Design Engineering Response

J. Wrage, Operations

Enclosure