ML13163A268

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from John Richmond to Larry Doerflein: Fitz Hardened Vent
ML13163A268
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 05/19/2011
From: Richmond J
Division of Reactor Safety I
To: Doerflein L
Division of Reactor Safety I
References
FOIA/PA-2013-0010
Download: ML13163A268 (8)


Text

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From: Richmond, John Sent: Thursday, May 19, 2011 2:16 PM To: Doerflein, Lawrence Cc: Knutson, Ed; Rutenkroger, Scott

Subject:

Fitz Hardened Vent - NRC SER & Other Assorted Documents Attachments: NRC Memo, SER Fitz Hardened Vent, 9-14-1992.pdf; Fitz DBD-27, Hardened Vent Dwg.pdf; Fitz DBD-27, Hardened Vent.pdf; Fitz LTR to NRC, Hardened Vent, 12-06-91.pdf; Fitz LTR to NRC, Hardened Vent, 8-14-92.pdf; Fitz SGTS & R8 Layouts (eLib).pdf; Fitz SGTS P&ID (eLib).pdf; NRC LRT to Fitz, SER Hardened Vent, 9-28-1992.pdf; NRC LTR to Fitz, Hardened Vent, 1-24-1991 .pdf; NRC LTR to Fitz, Hardened Vent, 7-02-1992.pdf a collection of historical documents that explains how the Fitz Hardened Vent got reviewed and approved by the NRC.

A few documents may not be Publicly available.

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Outside of Scope Outside of Scope b.3 following issues:

Fitzpatrick personnel identified the during beeq t

1. TSG-9 does not address hydrogen considerations 1-01 W0 and atPon has S as documented in CR-JAF-201 Outside of Scope Outside of Scope inspectors identified the following issues:

TheThe reference procedure EP-6, "Post Accident Containment Venting and Gas

1. SAMGs containment Control," when venting is required. This procedure assumes that electrical power contains steps to Containment Venting Without AC Power,"

is available. TSG-9, "Primary EP-6 in the SAMGs.

and would be appropriate to list along with manually vent containment, part of their Mark I containment did not install a hardened wet well vent as approval, it may be appropriate

2. FitzPatrick this decision received regulatory program improvements. While and configuration.

the adequacy of the existing wet well vent strategy to reevaluate f

Outside of Scope Potos Tu*

  • v,,y.. Jrp __.:...,~~l i ssewsdocumented in CR-Outside ofVE 01 u1 Scope post accident venting andd gas contro, and backup control rod ga control,
2. Portions training m,aterial. This issue wa included in operations completed.

insertion, are 5not 3 2 , and action has been [[::JAF-2011-01|JAF-2011-01]]

Outside of Scope Outside of Scope cope utsie o ts id a.ýý bdhdreshydrogeflc.fl~iions du Mary I Outside of Scope

Outside of Scope NRC Inspection Report 2011-008 TI 2515/183, "Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event" The objective of this inspection was to assess the adequacy of your actions taken in response to this event. The results from this TI will be used to evaluate the industry's readiness to respond to a similar event, and to help determine if additional regulatory actions are warranted.

The inspection was conducted during the period April 18-29, 2011, and consisted with reviews of records, documents, and procedures, interviews with station personnel, and in-plant inspection.

No findings were identified, and one unresolved item was identified. As always, this is still subject to management review, and I will inform you if there are any significant changes, The areas examined by the TI parallel the recommendations presented in IER 11-1, and I will go through our inspection in that order. We will discuss our observations at the end.

Section 03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded by B.5.b and SAMGs (SAOGs).

a. We reviewed your actions to verify that equipment is available and functional, and that procedures are in place and executable.
  • You walked through the SAOGs and B.5.b implementing procedures

" You verified that equipment that is needed to execute the SAOGs and B.5.b procedures was available by performing the applicable inventory procedures, i.e., ST-99C, "Safe Shutdown Equipment Inventory and Panel Operability Verification"

" You verified that current procedures were staged at appropriate locations

  • You tested portable equipment such as the fire pumper truck and communications
  • We observed selected equipment inventories from ST-99C and the fire protection equipment inventory procedures, and
  • We walked down selected SAOG and B.5.b implementing procedures
b. We reviewed your actions to verify the training and qualification for B.5,b and SAMGs.
  • Which was to verify appropriate qualifications through the course of your procedure reviews
  • We reviewed your training and qualification records
c. We noted that you had verified that applicable agreements and contracts needed to support B.5.b and SAMGs were in place.

0 We observed the agreements and noted that they were current

d. And we reviewed corrective actions initiated to address problems with mitigating strategy implementation.
  • CRs were generated during your reviews as issues were identified s We reviewed the CRs and status of corrective actions For section 03.01, no findings were identified.

V Section 03.02 Assess the licensee's capability to mitigate station blackout conditions.

a. We reviewed your actions to verify that required materials are staged, tested, and maintained.

" You performed walkdowns and inspected equipment used to perform procedures o AOP-49, "Station Blackout" o AOP-49a, "Station Blackout in Cold Condition" and o TSG-8, "Extending Site Black-out Coping Time, Starting an EDG/Injecting to Vessel with No DC Power Available"

" We walked down selected equipment to verify it was staged and in working order

" We reviewed associated CRs and the status of corrective actions

b. We reviewed your actions to walkdown SBO procedures.
  • You performed a SBO scenario in the simulator to validate the procedure and timelines
  • We reviewed your documentation of the scenario
  • We walked through AOP-49 with an operator For section 03.02, no findings were identified.

Section 03.03 Assess the licensee's capability to mitigate design basis internal and external flooding events.

a. We reviewed your actions to verify that required materials are staged, tested, and maintained.
  • You walked down equipment and features required to mitigate internal flooding to verify their conditions were consistent with design functions

" We walked down selected plant areas to ensure identified features appeared adequate

" We verified that the IPEEE excluded external flooding as a concern I We reviewed associated CRs and the status of corrective actions For section 03.03, no findings were identified.

Section 03.04 Assess the thoroughness of the licensee's walkdowns and inspections of equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events; and Assess the licensee's development of new mitigating strategies for identified vulnerabilities.

a. We reviewed your actions to verify that required materials are staged, tested, and maintained.
  • You walked down seismic and non-seismic structures, equipment, and features used in, or relevant to, fire and flooding events

" You evaluated the survivability of non-seismic equipment based on engineering judgment

" No new mitigating measures were identified for a flooding event

" We walked down selected non-seismic features identified as likely to survive a seismic event

" We did not identify any features relevant to external flooding

  • We reviewed associated CRs and the status of corrective actions For section 03.04, no findings were identified.

.4.. F Observations

1. The portable diesel generator and auto-transformer credited for your Appendix R analysis are located in warehouse 2, which is non-seismic. This equipment should be considered lost in a seismic event, and therefore, unavailable to mitigate conditions during a fire.
2. Contingency action described for dealing with damage to EDG ductwork does not include staged tools or pre-planned actions to create the needed opening. A tornado damper or blowout panel would eliminate this issue.
3. AOP-49 issues:

" Section E 9.1 could include considerations for notifying security with the action to open the switchgear room doors;

" Attachment 6 could include a provisional step for manual breaker operation;

" Equipment is staged at various locations throughout the plant, could include a map or clearly specify locations

4. The fire engine pumper truck may not have sufficient hard hose to reach the lake if the planned site for placing the truck is inaccessible after a seismic event.
5. The west diesel fire pump battery rack is not seismically qualified, so it may not be correct to classify that fire pump as seismic; the battery rack was evaluated as being likely to survive a seismic event, but you could evaluate enhancements, such as cell hold-downs
6. Bases for flooding analysis calculations for the EDG and EDG switchgear rooms are not consistent with actual conditions.

- CR initiated for new calculations, this item will be unresolved.

7. B-EDG room southeast floor drain contains standing water, indicating possible blockage

- CRIWO initiated to correct.

8. The EDG room floor drains are cross-connected; this makes them single-point vulnerable to blockage which, in turn, would affect assumptions for your flooding analysis.

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