IR 05000369/2011008

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NRC Temporary Instruction 2515/183 Inspection Report 05000369/2011008, 05000370/2011008
ML111330180
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 05/13/2011
From: Bartley J
NRC/RGN-II/DRP/RPB1
To: Repko R
Duke Energy Carolinas
References
IR-11-008
Download: ML111330180 (20)


Text

UNITED STATES May 13, 2011

SUBJECT:

MCGUIRE NUCLEAR STATION - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000369/2011008, 05000370/2011008

Dear Mr. Repko:

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your McGuire Nuclear Station using Temporary Instruction 2515/183, Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event. The enclosed inspection report documents the inspection results which were discussed on May 11, 2011, with you and other members of your staff.

The objective of this inspection was to promptly assess the capabilities of McGuire 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.

DEC 2 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/

Jonathan H. Bartley, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-369, 50-370 License Nos.: NPF-9, NPF-17

Enclosure:

05000369/2011008, 05000370/2011008 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-369, 50-370 License Nos: NPF-9, NPF-17 Report No: 05000369/2011008, 05000370/2011008 Licensee: Duke Energy Carolinas, LLC Facility: McGuire Nuclear Station, Units 1 and 2 Location: Huntersville, NC 28078 Dates: March 23, 2011, through April 29, 2011 Inspectors: J. Heath, Resident Inspector Approved by: Jonathan H. Bartley, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

INSPECTION RESULTS IR 05000369/2011-008, 05000370/2011-008; 03/23/2011 - 04/29/2011; McGuire Nuclear Station, Units 1 and 2; Temporary Instruction 2515/183, Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event This report covers an announced Temporary Instruction (TI) inspection conducted by the resident inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

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 in a separate report.

Enclosure

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 (SAMGs) 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.

The licensee inspected installed and portable support equipment used for implementation of a. Verify through test or inspection B.5.b mitigation strategies to ensure proper inventories and readiness of fire brigade that equipment is available and equipment in selected storage areas. The equipment inspected included fire equipment functional. Active equipment located in both the turbine building and auxiliary building storage areas, existing outside fire shall be tested and passive water supply hydrants and hose stations, interior fire water supply piping, the diesel-driven equipment shall be walked down portable pumps, hose equipment, and pre-fabricated B.5.b adapters and tools. The and inspected. It is not inspection included partial performance of the annual Hale pump test.

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

tested under an existing regulatory testing program be The inspectors evaluated through walkdowns, the adequacy of permanently installed and retested. portable equipment staged explicitly for implementation of B.5.b mitigation strategies. The inspectors walkdowns included interior and exterior firefighting equipment staged for B.5.b This review should be done for a commitments located onsite.

reasonable sample of mitigating Discuss general results including corrective actions by licensee.

strategies/equipment.

All active and passive B.5.b mitigation equipment was verified to be in place and ready for use.

The portions of the Hale pump test that were performed revealed no issues. Selected vendor-supported functions were not performed (pump flow verification, battery checks, gauge verification). The annual full performance test which included vendor-supported sections was last performed in October 2010.

Enclosure

Attempts to run the Godwin portable sump pump were unsuccessful on initial attempts due to a failed battery. The vendor was notified, the battery was replaced, and the pump was successfully started. The Godwin portable sump pump was inspected but flow tests were not performed because the pump was staged for use to support Unit 2 outage activities.

The pump vendor performs preventative pump maintenance on a three month interval. The maintenance was modified to include a battery check and diesel start. In addition, the licensee was evaluating adding a quarterly performance test.

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

The licensee verified procedures that could be used for B.5.b or severe accident mitigations.

b. Verify through walkdowns or The scope of those procedures included applicable abnormal (AP), response (RP), and demonstration that procedures operating (OP) procedures, extensive damage mitigation (EDM) guidelines and SAMGs.

to implement the strategies The licensee performed tabletops and walkdowns to validate that these procedures could associated with B.5.b and 10 be successfully implemented.

CFR 50.54(hh) are in place and Describe inspector actions and the sample strategies reviewed. Assess whether are executable. Licensees may procedures were in place and could be used as intended.

choose not to connect or operate permanently installed The inspectors reviewed a sample of the licensees B.5.b mitigation procedures to equipment during this independently verify procedures were in place, current, and executable.

verification. In addition, the inspectors independently performed field walkdowns of several of the licensees tabletop walkthroughs for B.5.b mitigation actions. The scope of the independent This review should be done for a walkdowns included several of the licensees EDM strategies. The EDM guidelines reasonable sample of mitigating provided initial operator actions to respond to onsite events involving large fires, explosions, strategies/equipment. and loss of ability to maintain spent fuel pool cooling under specific conditions. The EDM review included walkdowns of the spent fuel pool and outside yard area to verify equipment was in place and that implementation strategies were reasonable.

The inspectors identified that several APs incorrectly referenced the staging location of the Godwin sump pump. There was reasonable assurance that the Godwin sump pump could be located and was available for use. This issue was previously identified by the licensee and was entered into their corrective action program (CAP).

Enclosure

Discuss general results including corrective actions by licensee.

The procedures reviewed were determined to be executable and the support equipment specified was appropriate. The licensees review of SAMG strategies related to B.5.b did not identify any significant issues, however, several procedural enhancements specific to implementation of SAMG strategies were identified.

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

The licensee verified qualifications of the Emergency Response Organization (ERO), Fire c. Verify the training and Brigade, and training records of individuals qualified to the five Technical Support Center qualifications of operators and (TSC) positions that require biennial SAMG and B.5.b training. The licensee also verified the support staff needed to that Security personnel training qualifications were up to date.

implement the procedures and work instructions are current for Operations (Ops) verified personnel qualifications to Hale pump, Godwin Pump, SAMGs, activities related to Security and EP/APs. Ops also verified operations personnel were qualified to fire protection Order Section B.5.b and severe procedures and procedures related to fire and sabotage events.

accident management Describe inspector actions and the sample strategies reviewed to assess training and guidelines as required by 10 qualifications of operators and support staff CFR 50.54 (hh).

The inspectors performed a review of licensee-provided qualifications records for operations personnel to operate systems and equipment related to B.5.b and SAMG event response.

Specific required systems and equipment qualifications reviewed included the standby shutdown facility (SSF), Hale pump, halon fire protection, and qualifications required by Operations personnel to perform selected activities specific to the Auxiliary Building and Turbine Building following fire or sabotage events. The review also included verification of all Fire Brigade qualifications along with Security personnel qualified to B.5.b functions.

Discuss general results including corrective actions by licensee.

Licensee reviews determined that all training and qualification requirements for personnel in ERO, Ops, Fire Brigade, and Security were satisfactory and up-to-date. No issues were identified or corrective actions taken with respect to B.5.b and SAMG training.

Enclosure

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

The licensee identified applicable contracts and agreements committed to be in place for d. Verify that any applicable the mitigation of a B.5.b related event. The licensee has a contract for diesel fuel oil agreements and contracts are in delivery. In addition to the contracts, the licensee has Memorandums of Understanding place and are capable of (MOUs) in place with several offsite agencies for support during an emergency.

meeting the conditions needed to mitigate the consequences of For a sample of mitigating strategies involving contracts or agreements with offsite entities, these events. describe inspector actions to confirm agreements and contracts are in place and current (e.g., confirm that offsite fire assistance agreement is in place and current).

This review should be done for a The inspectors verified by review of the contract agreement for diesel fuel oil supply to the reasonable sample of mitigating Lincoln Combustion Turbine facility that it was current, and appeared to meet the licensees strategies/equipment. mitigation strategy. The inspectors also discussed several MOUs with surrounding county emergency management divisions and determined that those agreements were in place and current.

Discuss general results including corrective actions by licensee.

All vendor contracts identified were determined to be in place and current. The licensee verified the following MOUs were current:

  • Fire Departments (Mecklenburg, Cornelius Volunteer, Huntersville)
  • County Emergency Management (Iredell, Lincoln, Gaston, Catawba, Cabarrus)
  • Institute of Nuclear Power Operations
  • Department of Energy
  • Oak Ridge Radiation Emergency Assistance Center 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.

Enclosure

There were no issues identified by the licensee that have the significant potential to prevent e. Review any open corrective the success of the existing mitigation strategies.

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

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

All equipment that is relied upon to mitigate a SBO is permanently installed plant equipment.

a. Verify through walkdowns and There is no staged equipment. The licensee verified through walkdowns that all equipment inspection that all required required to handle an SBO event was adequate and functional. The walkdowns were materials are adequate and performed using SBO response procedures. The walkdowns included all components in the properly staged, tested, and SSF, associated switchgear, and transfer bunkers located in the safety-related switchgear maintained. rooms. The licensee reviewed safety bus crosstie alignments and reviewed their Work Management System for any functional deficiencies that could affect SBO equipment.

Enclosure

Describe inspector actions to verify equipment is available and useable.

The inspectors performed independent walkdowns of the SSF and safety-related 4160V switchgear rooms to verify that the material condition of the equipment was adequate to ensure functionality.

Discuss general results including corrective actions by licensee.

No issues were identified or corrective actions taken with respect to the adequacy of equipment needed to mitigate an SBO event. In general, all installed plant systems required to respond to an SBO were found to be capable of performing their respective SBO design functions.

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

See 03.02.a. The licensee reviewed procedures for SBO response by completing b. Demonstrate through walkdowns, tabletop reviews, and document reviews to ensure the procedures were walkdowns that procedures for effective for the procedure scope and executable. The procedures reviewed included APs response to an SBO are and EPs for loss of AC power, generator and grid disturbances, and SSF operation. The executable. licensee also reviewed and walked down alternative strategy procedures that could be used to mitigate SBO events. These alternative strategies were beyond SBO and not required.

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

The inspectors independently reviewed a sample of the above procedures for SBO to verify they were in place, current and executable. In addition to the required procedures, the inspectors reviewed the licensees alternative strategies for restoring power to a safety-related bus and walked down the relative equipment to verify the procedures were executable.

Discuss general results including corrective actions by licensee.

There were no issues identified by the licensee that had the potential to have a significant impact on the mitigation of an SBO event.

Enclosure

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 basis Licensee Action flooding events.

The licensee performed a tabletop of APs and alternative strategies for mitigating flood a. Verify through walkdowns and events. Walk downs were performed for sections of the procedures/guidelines that required inspection that all required local actions. For external flooding mitigation, the licensee walked the yard drain system, materials are adequate and even though the system is not credited to mitigate an external flood event. The licensees properly staged, tested, and review also included the evaluation of flood barriers and mitigation equipment that could be maintained. affected by a seismic event. Active equipment (including instrumentation) routinely tested and inspected under existing PMs was not included in the walkdowns. The licensee verified that those PMs were current.

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

The design basis for internal flooding relies on the isolation of the leak source to limit the flood levels within the Auxiliary and Turbine buildings. The inspectors sampled portions of the internal flooding AP to determine that they were able to be implemented. This sampling included walkdowns of the Turbine and Auxiliary buildings to ensure that required flood barriers were intact. The inspectors also walked down the site yard area for deficiencies that could compromise the mitigation strategy for an external flooding event. The inspectors also reviewed engineering calculations against Design Basis Documents to validate calculations for both internal and external flooding events. The inspectors determined that the procedures were in place and useable.

Discuss general results including corrective actions by licensee.

All equipment necessary for internal and external flood mitigation was verified to be in its designated storage location and in good working condition. There were no issues identified associated with active equipment required for flood detection.

Enclosure

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use IP 71111.21, Component Design Basis Inspection, Appendix 3, Component Walkdown Considerations, as a guideline to assess the thoroughness of the licensees walkdowns and inspections.

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

The licensee performed walkdowns of permanently installed and portable firefighting and a. Verify through walkdowns that suppression equipment for possible interactions that could be affected following a seismic all required materials are event. As part of the assessment, the licensee identified mitigation strategies would be adequate and properly staged, appropriate to address seismic vulnerabilities associated with fire and flood protection tested, and maintained. equipment.

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 list of fire and flood mitigation equipment and features included in the licensees assessment to verify the scope of the assessment was adequate. As part of the review, the inspectors walked down the outside yard area relating to fire and flood protection to verify the licensees assessment. The inspectors determined that the procedures were in place and useable.

Enclosure

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 following issues were identified:

  • Interior/Exterior fire protection systems (RF/RY) and equipment were not seismically designed. There were no contingencies in place to provide firefighting water in the event of a loss of all RF/RY due to a seismic event.
  • Appendix R fire equipment, which includes the SSF, and supporting firefighting and suppression equipment were not seismically qualified and therefore not credited to function following a design basis earthquake.
  • The Hale pump may be in use performing its B.5.b. function and may not be available for firefighting.
  • Hale pump and Godwin pump were located across a non-seismic bridge in non-seismic structures.
  • Several hose carts were stored between two non-seismic buildings
  • There were no debris removal procedures in place and therefore onsite motor vehicles relied upon to transport portable plant equipment following a seismic event may be immobilized.
  • Procedures were not written to remove beyond design basis flood water from the Auxiliary and Turbine Buildings.

In addition to purchasing additional support equipment, plans for developing mitigating strategies to address these issues are under evaluation and completion dates have not been identified.

Enclosure

Meetings Exit Meeting On May 11, 2011, the inspectors presented the inspection results to Mr. Regis Repko, McGuire Vice President, and other members of licensee management. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

Enclosure

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee K. Ashe, Manager, Regulatory Compliance D. Black, Security Manager D. Brenton, Superintendent, Plant Operations D. Brewer, Manager, Safety Assurance S. Capps, Station Manager K. Crane, Regulatory Compliance C. Curry, Engineering Manager R. Repko, Site Vice President, McGuire Nuclear Station LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events Number Description or Title Date or Revision PT/0/A/4400/019 Hale Portable Pump Quarterly 002 PT/0/A/4400/020 Hale Portable Pump Annual 004 PT/0/A/4600/112 Exterior/Interior Fire Equipment Inspection 007 OP/0/B/6400/019 Godwin Portable Sump Pump Operation 003 TSC Site Threat Alternate Alignments and Strategies Vol. 2 OP/0/A/6100/020 Operational Guidelines Following a Fire in the Aux. Bldg 023 OP/0/A/6100/021 Shutdown Outside the control room following a Fire 019 AP/1/A/5500/041 Loss of Spent Fuel Cooling or Level 009 AP/0/A/5500/044 Plant Flooding 009 AP/0/A/5500/047 Security Events 007 AP/0/A/5500/048 Extensive Damage Mitigation 003 RP/0/A/5700/006 Natural Disaster 022 RP/0/A/5700/007 Earthquake 019 RP/0/A/5700/008 Release of Toxic or Flammable Gases 006 AP/0/A/5500/045 Plant Fire 012 PT/0/B/4600/118 Fire Brigade 003 Emergency Plan Support agreements in place with local fire departments, 2010 county emergency management, NC state, INPO, DOE and Oak Ridge Attachment

PIP M-11-2188 Fukushima Daiichi nuclear station fuel damage caused by 3/16/11 earthquake PIP M-11-2382 Godwin portable sump pump did not start due to dead 3/21/11 battery PIP M-11-2502 MNS did not complete recommended INPO IER tasks 3/24/11 related to Fukushima event on schedule PIP M-11-2517 Discrepancies noted during performance of 3/24/11 Exterior/Interior Fire Equipment Inspection PIP M-11-2562 INPO event report requested licensee evaluate equipment 3/25/11 for beyond design basis events, MNS needs to evaluate equipment and storage PIP M-11-2725 Yard drain blocked by sandbags and steel plate 3/30/11 PIP M-11-2901 B.5.b fire hoses manufactured in 2007 have not been 4/5/11 hydrostatically tested PIP M-11-3154 PIP should have been written to capture a gap found 4/14/11 during the development of the response to IER 11-1 vs.

including the item in an existing PIP CA 03.02 Assess the licensees capability to mitigate station blackout (SBO) conditions Number Description or Title Date or Revision Eng. Review safety bus cross unit alignment impairments NA TSC Vol.2 Alternate Means to Restore Essential Power to 4160V 028 Bus, Encl. 11 EP/1/A/5000/ECA 0.0 Loss of all AC power 028 AP/1/A/5500/05 Generator Voltage and Electric Grid Disturbances 008 AP/1/A/5500/007 Loss of Electrical Power 029 3/17 Fire Impairment Logs - Active Entries 03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design Number Description or Title Date or Revision AP/0/A/5500/044 Plant Flooding 008 MCS-1465.00-00-0012 DBD for Flooding from External Sources 001 MCC-1206.47-69-1001 Auxiliary Building Flooding Analysis 015 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 Number Description or Title Date or Revision MCS-1569.RF-00-0001 Design Basis Specification (DBD) for the RF/RY System 019 MCS-1465.00-00-0012 DBD for Flooding from External Sources 001 MCS-1465.00-00-0009 DBD for Seismic Design 000 MCC-1206.47-69-1001 Auxiliary Building Flooding Analysis 015 Attachment

LIST OF ACRONYMS USED ADAMS Agencywide Documents Access and Management System AP Abnormal Procedure CAP Corrective Action Program CFR Code of Federal Regulations EDM Extensive Damage Mitigation EP Emergency Procedure ERO Emergency Response Organization MOU Memorandum of Understanding NRC United States Nuclear Regulatory Commission OP Operating Procedure Ops Operations PIP Problem Investigation Program RF/RY Interior/Exterior fire protection systems RP Response Procedure SAMG Severe Accident Mitigation Guidelines SBO Station Blackout SSF standby shutdown facility TSC Technical Support Center Attachment