ML111330455
| ML111330455 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/13/2011 |
| From: | Doerflein L Engineering Region 1 Branch 2 |
| To: | Bronson K Entergy Nuclear Northeast |
| Shared Package | |
| ML111300168 | List: |
| References | |
| IR-11-008 | |
| Download: ML111330455 (25) | |
See also: IR 05000333/2011008
Text
UNITED STATES
N UCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KlNG OF PRUSSlA. PA 19406-1415
May 13, 20LL
Mr. Kevin Bronson
Site Vice President
Entergy Nuclear Northeast
James A. FitzPatrick Nuclear Power Plant
P. O. Box 110
Lycoming, NY 13093
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC TEMPOMRY
INSTRUCTTON 251 5/1 83 TNSPECTION REPORT 05000333/201 1008
Dear Mr. Bronson:
inspection at
On April 29,2011, the U.S. Nuclear Regulatory Comlnission (NRC) completed an
your James A. Fitzpatrick Nuclear Power Plant (FitzPatrick), using T_emporary_lnstruction
2SlSlgg,"Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The
enclosed inspection report documents the inspection results which were discussed on
April 29,
2011, with Mr. B. Sullivan and other members of your staff'
respond
The objective of this inspection was to promptly assess the capabilities of FitzPatrick to
to extriordinary consequences similar io those that have recently occurred at the Japanese
from
Fukushima Daiichi Nuclear Station. The results from this inspection, along with the results
nuclear plants in the United States will
this inspection performed at other operating commercial
readiness to safely respond to similar
be used to evaluate the United States nuclear industry's
events. These results will also help the NRC to determine if additional regulatory actions are
warranted.
All of the potential issues and observations identified by this inspection are contained in this
report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if
they are regulatory findings or violations. Any resulting findings or violations will be documented
ny ine nnj in a sLparate report. You are not required to respond to this letter.
K. Bronson 2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS), accessible from the NRC Web site at
http:l/www.nrc.oovlreadinq-rmladams.html (the Public Electronic Reading Room).
Sincerely,
\-0 1C\
Slor"r.l---^" l ' t
Lawrence T. Doerflein, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No.: 50-333
License No.: DPR-59
Enclosure: lnspection Report 05000333/2011008
cc w/encl: Distribution via ListServ
K. Bronson 2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS), accessible from the NRC Web site at
http:llwww.nrc.oov/readino-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RN
Lawrence T. Doerflein, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No.: 50-333
License No.: DPR-59
Enclosure: lnspection Report 05000333/201 1008
cc w/encl: Distribution via ListServ
ADAMS PACKAGE: M1111300168 ADAMS DOCUMENT ACCESSION: MLl11330455
SUNSI Review Complete: LTD (Reviewer's Initials)
DOCUMENT NAME: G:\DRS\Tl-183 Inspection Reports\FITZ Tl-183 lR 2011008.docx
After declaring this document "An Official Agency Record" it will be released to the Public.
To convof
racaiva a coov
o receive of this document. indicate in the box: "C" = Coov without attachmenVenclosure "E"
Wthoutattachmenvendosure 'E" = Copy wtn
with attachmenVenclosure "N"
OFFICE RI/DRP RI/DRS RI/DRP RI/DRS
NAME EKnutson WSchmidUCGC MGray/BB LDoerfleiniLTD
Via email
DATE 5t13t11 5113111 5113111 5t13t11
OFFICIAL RECORD COPY
K. Bronson 3
Distribution w/encl:
W. Dean, RA
D. Lew, DRA
D. Roberts, DRP
J. Clifford, DRP
C. Miller, DRS
P. Wilson, DRS
S. Bush-Goddard, Rl OEDO
T. Kobetz, NRR, DIRS
M. Gray, DRP
B. Bickett, DRP
S. McCarver, DRP
M. Jennerich, DRP
S. Rutenkroger, DRP, Rl
K. Kolek, Resident OA
D. Bearde, DRS
RidsNrrPM FitzPatrick Resource
RidsNrrDorlLpll -1 Resource
ROPreports Resource
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No: 50-333
License No: DPR-59
Report No: 05000333/2011008
Licensee: Entergy Nuclear Northeast (Entergy)
Facility: James A. FitzPatrick Nuclear Power Plant
Location: Scriba, New York
Dates: April 18 through April 29, 2011
lnspectors: E. Knutson, Senior Resident lnspector
S. Rutenkroger, PhD, Resident lnspector
Approved by: Lawrence T. Doerflein, Chief
Engineering Branch 2
Division of Reactor Safety
Enclosure
lR 0500033312011008; 04/1812011 - 041291201 1; James A. FitzPatrick Nuclear Power Plant;
Temporary Instruction 25151183 - Followup to the Fukushima Daiichi Nuclear Station Fuel
Damage Event.
This report covers an announced Temporary lnstruction (Tl) inspection. The inspection was
conducted by two resident inspectors. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"
Revision 4, dated December 2006.
INSPECTION SCOPE
The intent of the Tl is to provide a broad overview of the industry's preparedness for events that
may exceed the current design basis for a plant. The focus of the Tl was on (1) assessing the
licensee's capability to mitigate consequences from large fires or explosions on site,
(2) assessing the licensee's capability to mitigate station blackout (SBO) conditions,
(3) assessing the licensee's capability to mitigate internal and external flooding events
accounted for by the station's design, and (4) assessing the thoroughness of the licensee's
walkdowns and inspections of important equipment needed to mitigate fire and flood events to
identify the potential that the equipment's function could be lost during seismic events possible
for the site. lf necessary, a more specific followup inspection will be performed at a later date.
INSPECTION RESULTS
All of the potential issues and observations identified by this inspection are contained in this
report. The NRC's Reactor Oversight Process willfurther 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.
Enclosure
03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded by
security threats, committed to as part of NRC Security Order Section 8.5.b issued February 25, 2002, and severe accident
management guidelines and as required by Titte 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use lnspection
Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. lf lP 71111.05T was recently
performed at the 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 FitzPatrick personnel reviewed the B.5.b equipment inspection and testing preventive
inspection that maintenance tasks to ensure that the tasks were up to date and the equipment was available and
equipment is available functional. ln addition, they inventoried the equipment and materials staged to support the B.S.b
and functional. Active strategies per the applicable procedures. FitzPatrick personnel also inventoried SAMG (at
equipment shall be FitzPatrick, titled Severe Accident Operating Guidelines, or SAOGs) support equipment per
tested and passive surveillance procedure ST-99C, "Safe Shutdown Equipment Inventory and Panel Operability
equipment shall be Verification." Portable equipment such as the site fire pumper truck and portable radios were
walked down and tested to verify readiness. The 8.5.b and SAMG procedures were verified current and staged in
inspected. lt is not the appropriate locations.
expected that
permanently installed
equipment that is tested Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed
under an existing test results, discussed actions, reviewed records, etc.).
regulatory testing
program be retested.
The inspectors evaluated the adequacy of installed and portable equipment staged explicitly for
This review should be implementation of the mitigation strategies. The types of equipment examined included: interior
done for a reasonable fire water pumps, supply piping, and hose stations; the site fire pumper truck and associated
sample of mitigating suction and discharge hoses, adapters, and tools; portable radios and communications devices;
strategies/eq uipment. and equipment lockers and associated tools. The inspectors review included field verification and
inventory checks of standby and staged equipment, and compatibility of the portable equipment
with installed systems. ln addition, the inspectors evaluated the staqinq/storaqe locations of 8,5.b
Enclosure
related equipment to ensure the survivability and availability of equipment. Documents reviewed
are listed in the Attachment to this report.
Discuss general results including corrective actions by licensee.
The licensee did not identify any deficiencies of significance as part of their equipment checks.
The licensee identified several minor issues which they entered into their correction action
program.
Based on the selected inspection samples, reviews, and walkdowns conducted, the inspector
concluded that the required equipment was available and functional.
Describe the licensee's actions to verify that procedures are in place and can be executed (e.9.,
Licensee Action
walkdowns, demonstrations, tests, etc.).
b. Verify through To validate the adequacy of procedures and strategies, FitzPatrick personnel performed
walkdowns or walkdowns of B.5.b strategies contained in Technical Support Guideline (TSG)-12, "8.5.b Extreme
demonstration that Damage Scenario Mitigating Strategies," and in the SAMGs. In addition, operations department
procedures to implement personnel performed validations of time critical operator actions for several activities, such as
the strategies associated operation of the site fire pumper truck, control room emergency ventilation, and operation of the
with 8.5.b and 10 CFR reactor core isolation cooling system without direct current power available.
50.54(hh) are in place
and are executable.
Licensees may choose Describe inspector actions and the sample strategies reviewed. Assess whether procedures were
not to connect or in place and could be used as intended.
operate permanently
Enclosure
installed equipment
during this verification. The inspectors examined FitzPatrick's established guidelines and implementing procedures for the
B.5.b mitigation strategies and SAMGS. The inspectors walked down selected mitigation
This review should be strategies with a plant operator to assess: the adequacy and completeness of the procedures;
done for a reasonable familiarity of operators with the procedure objectives and specific guidance; staging and
sample of mitigating compatibility of equipment; and the practicality of the operator actions prescribed by the
strateg ies/eq uipment. procedures, consistent with the postulated scenarios. Documents reviewed are listed in the
Attachment to this report.
Discuss general results including corrective actions by licensee.
The licensee did not identify any deficiencies of significance as part of their check to verify that
procedures were in-place and executable. The licensee identified several minor issues which they
entered into their correction action program.
Based on the selected inspection samples, and the results of the reviews and walkdowns as
described above, the inspectors concluded that procedures to implement the strategies associated
with B.S.b and 10 CFR 50.54(hh) were in place and were executable.
Describe the licensee's actions and conclusions regarding training and qualifications of operators
Licensee Action
and support staff.
c. Verify the training and FitzPatrick conducts initial and continuing B.5.b training, and verified that training was completed.
qualifications of Additionally, FitzPatrick personnel verified that all required operations personnel have received
operators and the initial and continuing SAMG training. Both 8.5.b and SAMG training is included in the continuing
support staff needed to training plan. FitzPatrick personnel reviewed training records and documentation to ensure that
implement the the training was up to date and verified that there was a sufficient number trained on-site
procedures and work personnel to implement the severe accident mitigation guidelines.
instructions are current
for activities related to
Enclosure
Security Order Section
B.5.b and severe Describe inspector actions and the sample strategies reviewed to assess training and
accident management qualifications of operators and support staff.
guidelines as required by
10 cFR 50.54 (hh).
The inspectors examined the periodic refresher training provided to the Operation Department
staff most likely to be tasked with the implementation of the 8.5.b mitigation strategies. The
inspectors' review consisted of examination of training presentations, training records, and
interviews with station personnel.
The documents reviewed are listed in the Attachment to this report.
Discuss general results including corrective actions by licensee.
The licensee did not identify any training deficiencies of signiflcance. The licensee identified
several minor issues which they entered into their correction action program.
Based on the selected inspection samples and reviews conducted, the inspector concluded that
the training and qualifications of operators and the support staff needed to implement the
procedures and work instructions were current for activities related to Security Order Section B.5.b
and severe accident management guidelines as required by 10 CFR 50.54 (hh).
Enclosure
Describe the licensee's actions and conclusions regarding applicable agreements and contracts
Licensee Action
are in place.
d. Verify that any FitzPatrick personnel verified that agreements with the municipalfire departments, local law
applicable agreements enforcement, emergency management offices, and other commitments for support required to
and contracts are in implement the strategies, were in place and active. Additionally, FitzPatrick personnel verified
place and are capable of their listing of resources capable of providing support equipment to mitigate the consequences of
meeting the conditions large fire or explosion events, as specified by TSG-11, "Additional Resources for Extreme
needed to mitigate the Damage Events," were correct and current.
consequences of these
events.
For a sample of mitigating strategies involving contracts or agreements with offsite entities,
This review should be describe inspector actions to confirm agreements and contracts are in place and current (e.9.,
done for a reasonable confirm that offsite fire assistance agreement is in place and curent).
sample of mitigating
strateg ies/eq uipment.
The inspectors verified that the licensee had in place current letters of agreement (LOA) with off-
site agencies to provide assistance in mitigation strategies. The inspectors verified that several
organizations had equipment with adequate lifting capability to elevate a monitor or spray nozzle
to allow spraying into the spent fuel pool. The documents reviewed are listed in the Attachment to
this report.
Discuss general results including corrective actions by licensee.
The licensee did not identify any deficiencies of significance. The licensee identified several minor
issues which they entered into their correction action program.
Based on the selected inspection samples and reviews conducted, the inspector concluded that
applicable agreements and contracts were in place and were capable of meeting the conditions
needed to mitigate the consequences of these events.
Enclosure
Document the conective action report number and briefly summarize problems noted by the
Licensee Action
licensee that have significant potential to prevent the success of any existing mitigating strategy.
e. Review any open The inspector reviewed numerous corrective action documents during this inspection, which are
corrective action listed in the Attachment to this report. In addition, NRC Resident Inspectors conduct daily reviews
documents to assess of newly issued condition reports. The inspector reviewed all condition reports identified by the
problems with mitigating licensee during their recent self assessments of 8.5.b mitigating strategies. The inspector
strategy implementation evaluated the licensee's immediate corrective actions for the associated condition reports, and
identified by the concluded that the actions appeared to be reasonable.
licensee. Assess the
impact of the problem on The inspectors determined that the identified issues would not impact successful implementation
the mitigating capability of a mitigating strategy.
and the remaining
capability that is not
impacted.
03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All
Afternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of
Station Blackout Rule Multi-Plant Action ltem A-22 as a guideline. lt is not intended that Tt 25151120 be completely reinspected.
The inspection should include, but not be limited to, an assessment of any licensee actions to:
Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO
Licensee Action
event.
Enclosure
a. Verify through The licensee performed walkdowns and visually inspected the equipment required to complete
walkdowns and steps in AOP-49, "Station Blackout," AOP-49A, "Station Blackout in Cold Condition," and TSG-8,
inspection that all "Extending Site Black-out Coping Time, Starting an EDG/lnjecting to Vesselwith No DC Power
required materials are Available." The licensee verified the referenced equipment was staged, available, and appeared
adequate and properly to be in good working order.
staged, tested, and
maintained.
Describe inspector actions to verify equipment is available and useable.
The inspectors assessed the licensee's capability to mitigate SBO conditions by conducting a
review of the licensee's walkdown activities. In addition, the inspectors selected a sample of
equipment utilized for mitigation of an SBO and conducted independent walkdowns of that
equipment to verify the equipment was properly aligned and staged. The sample of equipment
selected by the inspectors included, but was not limited to, portable radios, tools used for lifting
leads, portable lighting, vital area keys, tools for manual breaker operation, the portable diesel
generator and autotransformer, and an emergency field flash jumper cable.
The documents reviewed are listed in the Attachment to this report.
Discuss general results including corrective actions by licensee.
The licensee verified that SBO equipment was ready to respond to an SBO event. The licensee
identified several minor issues which they entered into their correction action program.
Based on the selected inspection samples, and the results of the reviews and walkdowns as
described above, the inspector concluded that the required equipment was available and
functional.
Enclosure
Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.
b. Demonstrate through The licensee performed a simulated SBO scenario using the simulator, supported by a
walkdowns that walkthrough of activities in the plant, using the appropriate SBO procedures. The licensee
procedures for response validated that the required timelines were met, procedure steps were executable, and operators
to an SBO are executed steps as expected.
executable.
Describe inspector actions to assess whether procedures were in place and could be used as
intended.
The inspectors reviewed the licensee's documentation from the simulated SBO scenario and
verified that the required timelines were met, procedure steps were executable, and operators
executed steps as expected. The inspectors walked through implementation of AOP-49 with an
operator, discussed the performance of each step, and verified that AOP-49 procedure steps were
executable. The documents reviewed are listed in the Attachment to this report.
Discuss general results including corrective actions by licensee.
The required equipment for coping and restoring from an SBO consisted of permanently installed
safety related equipment. The licensee and the inspectors did not identify any significant
deficiencies with the equipment, and determined the SBO procedures were in place and
executable.
The licensee identified an apparent beyond design and licensing basis vulnerability, in that current
procedures do not address hydrogen considerations during primary containment venting. This
issue was documented in CR-JAF-2011-01529. As an immediate corrective action, the licensee
revised TSG-9 to provide a caution for operators to consider the presence of hydrogen.
The inspectors identified a beyond design and licensing bases vulnerability, in that FitzPatrick's
current licensing basis did not require the plant to have a primary containment torus air space
hardened vent svstem as part of their Mark I containment improvement oroqram. The current
Enclosure
licensed configuration is a hard pipe from primary containment to the suction of the standby gas
treatment system, which is located outside the reactor building in an adjacent building. The NRC
has established an agency task force to conduct a near term evaluation of the need for agency
actions, which includes containment venting, following the events in Japan.
The licensee identified a vulnerability, in that AOP-49A contained contingency actions using the
decay heat removal system in an attachment that directed operators to use normal operating
procedures. The normal operating procedure for starting decay heat removal included
unnecessary steps for a SBO situation and did not include workable provisions for starting decay
heat removal with the system drained. The licensee initiated immediate corrective actions to
revise the procedure and fabricate an adaptor to connect a 1.5 inch fire hose to a 1 inch pipe
thread fitting in order to fill the decay heat removal system using fire water, if necessary. The
licensee entered this issue into their corrective action program as CR-JAF-2011-01674. The
inspector reviewed the licensee's immediate and proposed corrective actions, including their
assessment and prioritization, and concluded they were reasonable.
The inspectors identified several potential procedure enhancements which could improve operator
response, and communicated these enhancements to the licensee.
03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design. Refer to lP
71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. The
inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections
that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include
verification that accessible doors, barriers, and penetration seals are functional.
Describe the licensee's actions to verify the capability to mitigate existing design basis flooding
Licensee Action
events.
Enclosure
a. Verify through The licensee identified equipment and features required to mitigate internalflooding. The licensee
walkdowns and then conducted walkdowns of this equipment to ensure it appeared adequate and verified design
inspection that all features matched conditions described in supporting calculations, including such features as
required materials are bulkheads, water-tight bellows, fire doors, sump pump covers and gaskets, pump timers,
adequate and properly penetration seals, floor drains, and relative elevations of equipment potentially affected by
staged, tested, and flooding.
maintained.
Describe inspector actions to verify equipment is available and useable. Assess whether
procedures were in place and could be used as intended.
The inspectors reviewed the Individual Plant Examination for External Events (IPEEE) and
determined that FitzPatrick had been evaluated as not susceptible to an externalflooding event.
The inspectors reviewed data available from the National Geophysical Data Center and verified
that historical information indicated a maximum recorded tsunami event, or run-up, on Lake
Ontario of five feet (and on all the Great Lakes a maximum of nine feet on Lake Erie). The
inspector also determined that the maximum probable water level of Lake Ontario was calculated
to be 252.5 feet, and the ground level elevation at FitzPatrick was 279 feet.
The inspectors reviewed the licensee's self assessment actions and performed independent
walkdowns of various plant areas to ensure the licensee's identified list was comprehensive. The
inspectors examined accessible features to ensure the physical conditions and measurements
appeared adequate. The equipment inspected included bulkheads, floor drains, fire doors, door
sills, dampers, penetration seals, room volumes, and equipment elevations. The inspectors
verified that no material, tools, or equipment of a portable or staged manner appeared to be
required in order to cope with internal flooding.
Discuss general results including corrective actions by licensee.
The inspectors determined that, in general, all required materials were adequate and properly
staged, tested, and maintained to respond to an internalflood within the plant's design basis.
While this effort did not identify any operability or significant concerns, the licensee found issues
with desiqn information for internalfloodinq in the control room chiller room and the insoector
Enclosure
questioned design assumptions for internal flooding in the EDG switchgear rooms. The licensee
initiated condition reports to assess and resolve licensee and inspector identified issues, as listed
in the Attachment to this report. The inspectors reviewed the associated condition reports, and
determined the licensee's initial responses, including their assessment and prioritization, were
appropriate.
Since the maximum design basis externalflood water level was at least ten feet below the ground
level elevation of the facility, the inspectors concluded that the plant did not appear to have any
external flood vulnerabilities.
The inspectors concluded that the licensee meets the current design and licensing basis for flood
protection.
03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and
flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess
the licensee's development of any new mitigating strategies for identified vulnerabilities (e.9., entered it in to the corrective action
program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of
important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response
equipment; and developed mitigating strategies to cope with the loss of that important function. Use lP 71111.21, "Component
Design Basis lnspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the
licensee's walkdowns and inspections.
Describe the licensee's actions to assess the potential impact of seismic events on the availability
Licensee Action
of equipment used in fire and floodinq mitiqation strateqies.
Enclosure
a. Verify through The licensee tabulated a list of equipment available to mitigate fire and flood events and identified
walkdowns that all whether the equipment was seismically classified. For equipment not classified as seismic, but
required materials are appearing more rugged in design, the licensee used engineering judgment to determine whether
adequate and properly or not the equipment was likely to survive a seismic event. The licensee described an overall
staged, tested, and mitigating strategy for fires as relying upon either the fire engine pumper truck or a seismically
maintained. designed portion of the fire protection system, consisting of the west diesel fire pump and a portion
of the fire water header inner loop.
No mitigating measures were identified or needed to address a postulated external flood event.
AOP-S1, "Unexpected Fire Pump Start," Revision 5 provided guidance for dealing with internal
flooding due to a fire main leak or rupture, such as from seismically induced fire main pipe breaks.
Describe inspector actions to verify equipment is available and useable. Assess whether
procedures were in place and could be used as intended.
The inspectors walked down all fire protection features and equipment designated for mitigating
strategies in the event installed fire protection systems do not survive a seismic event. This
designated equipment included the west diesel fire pump, a portion of the fire water header inner
loop, fire hose stations supplied from the portion of inner loop, the fire engine pumper truck and
accessories, wheeled carbon dioxide extinguishers, fire fighting foam trailer, and other portable
extinguishing equipment. The inspectors also walked down and examined internalflood event
vulnerabilities and design features that would mitigate the consequences of internal flooding and
reviewed AOP-51.
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 deficiencies of significance. The licensee identified several minor
issues or beyond licensinq basis vulnerabilities which they entered into their corrective action
Enclosure
program. The inspectors reviewed the associated condition reports, and determined the
licensee's initial responses, including their assessment and prioritization, were appropriate.
The licensee did not identify any new or additional mitigating strategies beyond those identified
above. The inspectors observed that significant areas of the plant would have reduced fire
fighting capability following a design basis seismic event since the majority of the fire water system
is not seismically qualified, nor likely to survive such an event. In addition, internalflooding
caused by ruptures following a design basis seismic event would require operators to walkdown
areas, identify the source(s), and take prompt actions to secure the source(s) of flooding.
Postulating a design basis seismic event followed by significant fire(s) and/or internal flooding, the
limited number of on-shift personnel would be challenged to complete the needed mitigation
actions. In particular, the fire brigade consists of on-shift operations personnel and is capable of
dealing with a single fire only while maintaining minimum control room staffing.
The inspectors identified a minor deficiency in the fire protection program. The licensee had not
implemented vendor recommended periodic fire fighting foam concentrate testing for on-site
portable fire fighting foam tanks. The licensee entered this issue into their corrective action
program as CR-JAF-2011-02336, and initiated a preventive maintenance task request to
implement an annual foam sample test and ensure the tanks remain filled.
The inspectors identified severaladditional beyond design and licensing basis vulnerabilities and
communicated those issues to the licensee.
Enclosure
Meetinqs
4OAO Exit Meetinq
The inspectors presented the inspection results to Mr. B. Sullivan and other members of
licensee management at the conclusion of the inspection on April 29,2011. Propriety
information reviewed by the inspectors during the inspection was returned to the
licensee. The inspectors verified the inspection report does not contain proprietary
information.
14 Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
B. Sullivan, General Manager, Plant Operations
B. Finn, Director Nuclear Safety Assurance
C. Adner, Manager Operations
J. Barnes, Manager, Training and Development
M. Reno, Manager Maintenance
P. Cullinan, Manager, Emergency Preparedness
J. Pechacek, Licensing Manager
E. Dorman, Senior Licensing Engineer
R. Sullivan, Assistant Manager, Plant Operations
D. Poulin, Manager, System Engineering
F. Lukaczyk, Assistant Manager, Plant Operations
D. Ruddy, Supervisor, Engineering
A. Barton, Senior Engineer
D. Stokes, Senior Engineer
D. Koelbel, Senior Engineer
D. Burch, Senior Staff Engineer
Nuclear Requlatorv Commission
C. Cahill, Senior Reactor Analyst
W. Cook, Senior Reactor Analyst
W. Schmidt, Senior Reactor Analyst
Other
G. Tarbell, Fire Protection Specialist, Bureau of Fire Protection
P. Eddy, Utility Supervisor, New York State Department of Public Service
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. lnclusion 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.
Attachment
A-2
03.01 Assess the licensee's capability to mitigate conditions that result from beyond
design basis events
Procedures:
AOP-13, High Winds, Hurricanes, and Tornadoes, Rev. 19
EAP-13, Damage Control, Rev. 19
EP-10, Fire Water Crosstie to RHRSW Loop'A'When Directed by EOP-4 or SAOGS, Rev. 1
EP-11, Alternate Depressurization Using SRVs from 02ADS-71, Rev. 1
EP-12,lsolating RBCLC Supply to the Drywell, Rev. 0
EP-14, Alternate Containment Sprays, Rev. 3
EP-z, lsolation/lnterlock Overrides, Rev. 7
EP-3, Backup Control Rod Insertion, Rev. I
EP-4, Boron Injection Using CRD System, 2
EP-6, Post Accident Containment Venting and Gas Control, Rev. 9
EP-7, Primary Containment Flooding, Rev. 5
EP-g, Opening MSlVs, Rev.3
SAOG-1a, RPV and PC Flooding, RPV Breach, Rev. 3
SAOG-1b, RPV and PC Flooding, RPV Level above TAF, Rev. 2
SAOG-1c, RPV and PC Flooding, RPV Level above BAF, Rev. 2
SAOG-1d, RPV and PC Flooding, RPV Injection above MRDIR, Rev. 2
SAOG-1e, RPV and PC Flooding, Parameters within PSP, Rev. 2
SAOG-1f, RPV and PC Flooding, Parameters outside PSP, Rev. 2
SAOG-2, RPV, Containment, and Radioactivity Release Control, Rev. 3
SAP-3, Emergency Communications Testing, Rev. 80
ST-76E, Quarterly Fire Hose Station Inspections, Rev. 16
ST-99C, Safe Shutdown Equipment lnventory and Panel Operability Verification, Rev. 31
TSG-11, Additional Resources for Extreme Damage Events, Rev. 2
TSG-12, 8.5.b Extreme Damage Scenario Mitigating Strategies, Rev. 3
TSG-6, Extending Site Blackout Coping Time, Starting an EDG/ Injecting to Vesselwith no DC
Power Available, Rev. 3
TSG-9, Primary Containment Venting without AC Power, Rev. 3
Condition Reports:
CR-JAF-2Q11-01443, Fukushima Daiichi Nuclear Station Fuel Damage Event, Rev. 0
CR-JAF-2011-01528,lmprove Staging for lnterlock Override Keys, Rev. 0
CR-JAF-2g11-01529, TSG-9 does not Address Hydrogen Considerations during Primary
Containment Venting, Rev. 0
CR-JAF-201 1-01531 , TSGs are not Listed in the Operations Task List or Operations
Qualification Documents, Rev. 0
CR-JAF-2011-01532, No Operations Training for Portions of EP-6 and EP-3, Rev. 0
CR-JAF-2Q11-01955, Minor Discrepancies with Labeling and Equipment Access Noted during
EOP and SAOG Walkdowns, Rev. 0
Attachment
A-3
03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions
Procedures:
AOP-49, Station Blackout, Rev. 17
AOP-49A, Station Blackout in Cold Condition, Rev. 7
FE-14A, Wiring Diagram Emergency Diesel Generator 93EDG-A System 93, Rev. 18
OP-30, Fuel Pool Cooling and Clean-Up System, Rev. 38
OP-30A, Refueling Water Level Control, Rev. 14
OP-4, Circulating Water System, Rev. 68
ST-28, Portable Diesel Generator Operability Test, Rev. 7
ST-99C, Safe Shutdown Equipment lnventory and Panel Operability Verification, Rev. 31
TSG-8, Extending Site Blackout Coping Time, Starting and EDG/lnjecting to Vesselwith no DC
Power Available, Rev. 3
Calculations/Evaluations:
JAF-CALC-ELEC-02609, 125V DC Station Battery'A'Sizing and Voltage Drop, 2
Condition Reports:
CR-JAF-2011-01528, Emergency Keys for EP and AOP Actions should be More Accessible and
Should be Inventoried as Part of Surveillances , Rev. 0
CR-JAF-2011-01660, Handheld Lanterns Listed as Located in a Fire Brigade LockerWhich
does not Exist at that Location, Rev. 0
CR-JAF-2g11-01674, AOP-49A and AOP-498 Refer to Using Decay Heat Removal Utilizing
Normal Operating Procedures which are not Optimum, Rev. 0
CR-JAF-2O11-01680, No Preventive Maintenance Program could be Found for the Auto-
transformer, Rev. 0
Other:
File No. 11825-1.12-23A, Data Sheet - Emergency Generator, 12110170
File No. 1.12-41, Schematic Diagram Static Exciter and Voltage Regulator Emergency Diesel
Generator, Rev.7
Simulator Scenario 70275-1-LOl, AOP-49, Station Blackout, 3118111
WO 52282143, Portable Diesel Generator Operability Test, 3/15/11
WO 52301195, Perform Freshening Charge and Voltage Checks, 3118111
03.03 Assess the licensee's capability to mitigate internal and external flooding events
required by station design
Procedures:
ESP-50.001, Floor Drain Flow Test, Rev. 1
Attachment
A-4
Calculations/Evaluations:
SWEC Calculation 14620.9015-US(N)-001-0, Evaluation of lmpact of Flooding Inside
Emergency Diesel Generator Rooms on Safety-Related Equipment, Rev. 0
SWEC Calculation 14620-8-9017-1, Potential Flooding lmpactfor EDG Room Sprinkler
Actuation with Floor Drains Plugged and Two Equipment Drains Opened and all Floor
Drains Opened, Rev. 2
Condition Reports:
CR-JAF-2O11-01762, Flooding Calculation for the Control Room Chiller Room Contains
Discrepancies with Respect to Actual Room Conditions, Rev. 0
Other:
DBD-076 Tab 1, Design Basis Document for Fire Protection 076, System Water Supply and
Distribution System, Rev. 4
03.04 Assess the thoroughness of the licensee's walkdowns and inspections of
important equipment needed to mitigate fire and flood events to identify the
potential that the equipment's function could be lost during seismic events
Procedures:
AOP-14, Earthquake, Rev. 13
AOP-28, Operation During Plant Fires, Rev. 18
AOP-49, Station Blackout, Rev. 17
AOP-49A, Station Blackout in Cold Condition, Rev. 7
ESP-50.001, Floor Drain Flow Test, Rev. 1
FPP-1.13, Fire Brigade Equipment Inventory, Rev.0
FPP-3.49, Fire Protection Equipment Inspection, Rev. 0
FPP-3.50, Fire Engine Inspection, Rev. 0
OP-30, Fuel Pool Cooling and Clean-Up System, Rev. 38
OP-30A, Refueling Water Level Control, Rev. 14
OP-4, Circulating Water System, Rev. 68
ST-28, Portable Diesel Generator Operability Test, Rev. 7
ST-99C, Safe Shutdown Equipment Inventory and Panel Operability Verification, Rev. 31
TSG-8, Extending Site Blackout Coping Time, Starting and EDG/lnjecting to Vesselwith no DC
Power Available, Rev. 3
Condition Reoorts:
CR-JAF-2O11-01443, Fukushima Daiichi Nuclear Station Fuel Damage Event, Rev. 0
CR-JAF-2O11-02336, Portable Foam Tanks Lack Vendor Recommended PM, Rev. 0
LO-WTJAF-2011-0112, Tracking of Potential Enhancements ldentified during the Response to
Recommendation 4, Rev. 0
Attachment
A-5
Other:
DBD-076 Tab 1, Design Basis Document for Fire Protection 076 System Water Supply and
Distribution System,4
LIST OF ACRONYMS USED
AC Alternating Current
ADAMS Agencywide Documents Access and Management System
CA Corrective Action
CFR Code of Federal Regulations
CR Condition Report
EDG Emergency Diesel Generator
EOP Emergency Operating Proced ure
1P Inspection Procedure
IPEEE lndividual Plant Examination of External Events
LOA Letter of Agreement
NRC Nuclear Regulatory Commission
PAR Publically Available Record
SAMG Severe Accident Mitigation Guideline
SAOG Severe Accident Operating Guideline
SBO Station Blackout
SFP Spent Fuel Pool
SRV Safety/Relief Valve
TI Temporary Instruction
TSG Technical Support Guideline
Attachment