ML13015A640
| ML13015A640 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/06/2011 |
| From: | Scott Rutenkroger NRC/RGN-I/DRP/PB5 |
| To: | Cook W, Knutson E Reactor Projects Branch 2, Division of Reactor Safety I |
| References | |
| FOIA/PA-2013-0010 | |
| Download: ML13015A640 (4) | |
Text
Rao, Ami From: Rutenkroger, Scott Sent: Friday, May 06, 2011 11:40 AM To: Cook, William; Knutson, Ed
Subject:
RE: Please review and edit as needed.
Attachments: Fitz til 83 section 0304 cook revised SPR.docx I reviewed and agreed with most all the changes. I've attached a version with a few additional changes. The only real difference concerns their consideration of internal flooding since they don't have any overall procedure for internal flooding or any training as such. I believe AOP-51 dealing with an unexpected fire pump start is the most applicable procedure to be able to reference something.
-Scott From: Cook, William Sent: Friday, May 06, 2011 10:16 AM To: Knutson, Ed; Rutenkroger, Scott
Subject:
Please review and edit as needed.
- Thanks, Bill 1
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.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 licensee's walkdowns and inspections.
Describe the licensee's actions to assess the potential impact of seismic events on the Licensee Action availability of equipment used in fire and floodinq mitiqation strategies.
The licensee tabulated a list of equipment available to mitigate fire and flood events and
- a. Verify through identified if this equipment was seismically -classified. For equipment not classified as walkdowns that all seismic, but appearing more rugged in design, the licensee used engineering judgment to required materials are determine whether or not the equipment was likely to survive a seismic event. The licensee adequate and properly described an overall mitigating strategy for fires of relying upon either the fire engine pumper staged, tested, and truck or a seismically designed portion of the fire protection system, consisting of the west maintained. 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-51, "Unexpected Fire Pump Start, Revision 5 provides guidance for dealing with internal flooding due to a fire main leak or rupture, such as from seismically induced fire main pipe breaks.
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The inspectors walked down all fire protection features and equipment designated for
,-sei ""mically desi, Re,- 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 internal flood event vulnerabilities and design features that would mitigate the consequences of internal flooding and reviewed AOP-51 .te
- ....'p ,* *R runl fl.., onR , dama..ge Gent.. l Quu',4-uR e. . The inspectors reviewed data available from the National Geophysical Data Center and verified that historical information
indicates athe maximum recorded tsunami event, or runup, on Lake Ontario of five feet (and on all the Great Lakes a maximum of nine feet on Lake Erie). Since the maximum design basis flood water level is greater than ten feet below the ground level elevation of the facility, the inspectors did not identify any plant vulnerabilities relevant to external flooding. The inspectors concluded that the licensee meets the current licensing basis for fire and flood protection.
Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.
The licensee did not identify any new 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, internal flooding 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 operations personnel on shift and is capable of dealing with a single fire only while maintaining minimum control room staffing.
The inspectors identified the following vulnerabilities:
The portable diesel generator and associated equipment which are credited for meeting Appendix R requirements are located in a structure which is not constructed to withstand a design basis seismic event.
The licensee initially determined that the fire engine pumper truck would likely be capable of.
drafting from Lake Ontario based on existing suction hose available. The inspectors determined that the assumeddesi ated drafting location may not be available following a seismic event and additional hose may be required for a different drafting location.
The EDG room floor drains are cross-connected between the two divisions. Flooding analysis supporting specified operator actions assumes individual floor drains will either be free-flowing or entirely plugged. The inspectors determined that a seismic event may also
compromise this floor drain system such that flooding in one division would cross flood into the other, potentially compromising both divisions of emergency AC.
FitzPatrick did not install a hardened wet well vent as part of their Mark I containment program improvements. While the decision not to do so received regulatory approval, it may be appropriate to reevaluate the adequacy of the existing wet well vent strategy and configuration.
CR-JAF-2011-02336: the portable fire fighting foam tanks, 76TRL-1 and 76CART-1, the foam trailer and foam cart, respectively, have not been sampled or tested since being procured (a period of time on the order of twenty years). The associated vendor manual recommends a periodic foam concentrate sample be taken and tested and the foam tank refilled, as needed, following the sample. The licensee initiated a preventive maintenance task request to implement an annual foam sample test and ensure the tanks remain filled.
The following licensee-identified vulnerabilities were reviewed by the inspectors-.
CR-JAF-2011-01443 (CA 18): an agreement does not exist with a local fire department for contingency use of a fire engine pumper truck when the FitzPatrick fire engine pumper truck is unavailable. The licensee initiated a corrective action to establish -su4ih-an agreement.
LO-WTJAF-2011-00112 (CA 1): the fire engine pumper truck is not located within a structure likely to survive a design basis seismic event. The licensee initiated a CA to evaluate relocating the truck to a seismically rugged enclosure.
LO-WTJAF-2011-0112 (CA 2): a strategy for drafting from Lake Ontario and providing water to the fire engine pumper truck does not exist. The licensee initiated a CA to evaluate and develop such a strategy.
LO-WTJAF-2011-0112 (CA 3): the isolation valves between the seismically qualified portion of the inner fire water loop and the rest of the fire water system are not procedurally referenced or identified in pre-fire plans. The licensee initiated a CA to determine the appropriate procedure or reference to provide this information to Operations during an event.