IR 05000282/2011009

IR 05000282-11-009, 05000306-11-009, on 03/23/2011 - 04/29/2011; Prairie Island Nuclear Generating Plant, Units 1 and 2, Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event

ML111320389
Person / Time
Site:	Prairie Island, Fort Calhoun
Issue date:	05/13/2011
From:	Jack Giessner Reactor Projects Region 3 Branch 4
To:	Schimmel M Northern States Power Co
References
IR-11-009
Download: ML111320389 (31)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 May 13, 2011

Mr. Mark Site Vice President Prairie Island Nuclear Generating Plant Northern States Power Company, Minnesota 1717 Wakonade Drive East Welch, MN 55089 SUBJECT: PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000282/2011009; 05000306/2011009

Dear Mr. Schimmel:

On April 29, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Prairie Island Nuclear Generating Plant, Units 1 and 2, using Temporary Instruction 2515/183, "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 you and other members of your staff.

The objective of this inspection was to promptly assess the capabilities of Prairie Island Nuclear Generating Plant 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 industry's 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 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 by the NRC in a separate report. You are not required to respond to this letter. 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://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ John B. Giessner, Chief Branch 4 Division of Reactor Projects

Docket Nos. 50-285; 50-306;72-010 License Nos. DPR-42: DPR-60; SNM-2506

Enclosure:

Inspection Report 05000282/2011009; 05000306/2011009

REGION III Docket Nos: 50-282; 50-306;72-010 License Nos: DPR-42; DPR-60; SNM-2506 Report No: 05000282/2011009; 05000306/2011009 Licensee: Northern States Power Company, Minnesota Facility: Prairie Island Nuclear Generating Plant, Units 1 and 2 Location: Welch, MN Dates: March 23, 2011, through April 29, 2011 Inspectors: K. Stoedter, Senior Resident Inspector P. Zurawski, Resident Inspector S. Lynch, Nuclear Safety Professional Development Program Participant (observer)

Approved by: John B. Giessner, Chief Branch 4 Division of Reactor Projects 1 Enclosure

SUMMARY OF FINDINGS

05000282/2011009; 05000306/2011009; 03/23/2011 - 04/29/2011; Prairie Island Nuclear Generating Plant, Units 1 and 2; 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 inspectors. The NRC's pr ogram 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 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 TI 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 walk downs 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. 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 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 by the NRC in a separate report.

03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded b y 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 equipment. a. Verify through test or inspection that equipment is available and functional. Active equipment shall be tested and passive

equipment shall be walked down and inspected. It is not expected that permanently installed equipment that is tested under an existing regulatory testing program be retested.

This review should be done for a reasonable sample of mitigating strategies/equipment. The licensee identified equipment (active and passi ve) utilized for implementation of B.5.b actions and Severe Accident Management Guidelines (SAMGs). Permanent plant equipment (i.e., in situ equipment) was not considered within the scope of this inspection since it was normally in service, subjected to maintenance and surveillance activities, and/or checked on operator rounds. The licensee identified surveillances/tests and performance frequencies for the identified equipment and reviewed the most recent results. All active equipment within the scope defined above was retested. Passive equipment within the scope was inspected and inventoried using existing procedures.

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

The licensee's actions discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the adequacy of the licensee's actions and capabilities by reviewing the licensee's activities. This review consisted of reviewing the results of equipment testing activities to ensure B.5.b and SAMG-related equipment could perform as required. The inspectors also independently walked down and inspected major B.5.b and SAMG contingency response equipment staged throughout the site. Discuss general results including corrective actions by licensee. The licensee had only one piece of SAMG-related equipment that was not considered in situ plant equipment. Both the licensee and the inspectors verified that this piece of equipment was in good material condition and in the designated storage location. All designated B.5.b equipment (active and passive) was verified by the licensee and the inspectors to be in the proceduralized storage location. Minimum equipment inventories were also verified to be met. The licensee performed surveillance and/or preventive maintenance activities on specific passive equipment to verify that the equipment was ready for use.

The licensee performed flow verification testing on the B.5.b pump to ensure that pump could supply required flows. The inspectors verified that the pump remained able to provide flow commensurate with the B.5.b strategies. Some minor equipment enhancements were identified by the licensee and entered into the corrective action program (CAP).

Specific CAP documents are listed in the List of Documents Reviewed section of this report.

Licensee Action Describe the licensee's actions to verify that procedures are in place and can be executed (e.g. walkdowns, demonstrations, tests, etc.) b. Verify through walkdowns or demonstration that procedures to implement the strategies associated with B.5.b and 10 CFR 50.54(hh) are in place and are executable. Licensees may choose not to connect or

operate permanently installed

equipment during this verification.

This review should be done for a reasonable sample of mitigating strategies/equipment. The licensee formed a response team to evaluate whether B.5.b and SAMG-related procedures were in place and executable. The licensee's response team reviewed industry B.5.b and SAMG guidance, and performed a combination of walkdown and table top reviews, to validate that procedures for implementing the strategies associated with B.5.b and 10 CFR 50.54(hh) were in place and could be executed. The event response team also used a series of simulator scenarios plus a detailed table top review to evaluate the availability and execution of SAMG procedures. Describe inspector actions and the sample strategies reviewed. Assess whether procedures were in place and could be used as intended. A majority of the licensee's actions in this area were completed prior to the issuance of TI 2515/183. The inspectors observed portions of the licensee's SAMG table top review to assess whether the SAMG procedures were executable. The inspectors also assessed the licensee's execution capabilities by conducting a review of the licensee's walkdown activities. Based upon the results of a previous B.5.b inspection, the inspectors chose several B.5.b procedures for review. In each case, the inspectors performed an independent, in-plant walkdown to ensure that appropriate equipment was available, the

procedure could be executed as written, and that previous NRC identified issues with the strategies had been corrected. The inspectors used the results of their independent review to verify the licensee's conclusions.

Discuss general results including corrective actions by licensee. Operations personnel walked down each of the procedures used following a severe accident or B.5.b event to ensure that each action could be performed. No deficiencies were identified. However, enhancements such as the staging of bolt cutters and possible plant modifications to ease procedure execution were identified and documented in the CAP. During the performance of SAMG table top activities, the licensee identified an area for improvement regarding SAMG-related training. Specifically, the licensee identified that SAMG-related continuing training had not been provided to the necessary emergency response organization (ERO) members. The inspectors verified that the initial and continuing training program for all on-shift operations personnel included SAMG and B.5.b-related training. The inspectors also verified that all licensed and non-licensed operators qualified to stand watch had completed B.5.b and SAMG training. The licensee also completed a SAMG-related emergency drill every six years. The lack of SAMG continuing training for other ERO members resulted in extending the amount of time specific ERO members needed to implement the SAMG procedures. However, the SAMG procedures remained executable.

The licensee documented this issue in their CAP. All CAP document numbers initiated as part of this review are provided in the List of Documents Reviewed section of this report.

Licensee Action Describe the licensee's actions and conclusions regarding training and qualifications of operators and support staff. c. Verify the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section B.5.b and severe accident management guidelines as required by 10

CFR 50.54 (hh).

The licensee identified operator training/qualification requirements associated with the implementation of B.5.b or SAMG strategies. The licensee documented that operator training requirements were current and identified those operators with qualification requirements that were not current due to medical restrictions. The licensee also identified the B.5.b and SAMG training/qualification requirements for applicable ERO command and support staff and verified training requirements were current. Describe inspector actions and the sample strategies reviewed to assess training and

qualifications of operators and support staff. The licensee's actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed the licensee's training and qualification activities by conducting a review of training and qualification materials and records related to B.5.b and SAMG event response.

Discuss general results including corrective actions by licensee. The licensee reviewed the training program descriptions for all licensed and non-licensed operations personnel and determined that B.5.b and SAMG-related training was provided as part of the operations initial and continuing training programs. The licensee reviewed training qualification dates contained in their learning management system and verified that all operators qualified to stand watch had received the training required by the operator continuing training program within the specified frequency. The licensee confirmed that all operations personnel verify their qualifications prior to assuming an on-shift position. The training requirements, qualifications, and associated records needed for ERO command and support staff were also reviewed. While all ERO personnel had completed required training, the licensee identified that no training requirement existed to ensure that ERO personnel received continuing training on SAMG procedures on a specified frequency (see Section 03.01b above). This issue was documented in the licensee's CAP. The licensee was implementing activities to develop continuing training for SAMG decision makers and evaluators at the conclusion of this inspection.

Licensee Action Describe the licensee's actions and conclusions regarding applicable agreements and contracts are in place. d. Verify that any applicable agreements and contracts are in place and are capable of meeting the conditions needed to mitigate the consequences of

these events.

This review should be done for a reasonable sample of mitigating strategies/equipment. The licensee identified all applicable contracts and agreements committed to be in place for the mitigation of a B.5.b related event. The licensee verified that the contracts and agreements were current and documented whether or not the contracts/agreements were capable of meeting the mitigation strategy. For a sample of mitigating strategies involving contracts or agreements with offsite

entities, 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). The licensee's actions as discussed above were completed prior to the issuance of NRC TI 2515/183. The inspectors assessed th e licensee's capabilities by conducting an independent review of the agreements and contracts. The inspectors' determined that the agreements and contracts were current and adequat e for meeting the licensee's mitigation strategy.

Discuss general results including corrective actions by licensee. The licensee reviewed all contracts and agreements to ensure that the documents were current and that all required equipment covered by these documents remained available. An additional agreement was in place with the National Guard should an event extend beyond the capabilities of the agreed upon resources and/or local and state government.

Licensee Action Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy. e. Review any open corrective 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.

CAP 1276003 - Re-Evaluate Continuing Training Requirements for SAMG Training CAP 1276437 - EDMG Portable Pump and Tow Vehicle Stuck in Mud CAP 1276441 - EDMG Portable Fire Pump Priming Issues during TP-1423 CAP 1276445 - EDMG Portable Fire Pump Suction Gauge not Functioning CAP 1276645 - Desired Equipment and Possible Modifications to Enhance SAMG Implementation CAP 1277505 - Enhancements to SAMG Procedures CAP 1276723 - Type on Equipment Availability Check Figure CAP 1277744 - Enhancement to SAMG Diagnostic Flow Chart CAP 1278970 - No Plywood Mats Available for use if Equipment Placed on Soft Ground

The inspectors reviewed each CAP for potential impact to the licensee's mitigation strategies. No significant impacts were identified. While the inspectors were concerned regarding the licensee's lack of SAMG continuing training for ERO personnel, the inspectors observed portions of the licensee's SAMG table top activities and verified that currently qualified ERO staff members (SAMG decision makers and evaluators) were able to execute the SAMG procedures.

03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of Al l 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:

Licensee Action Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO event. a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained. Following an SBO event, Prairie Island procedures direct operations personnel to provide alternate AC to the SBO unit via the opposite unit's emergency diesel generators (EDG).

As a result, there was no temporary or staged equipment needed to respond to an SBO event. The licensee reviewed recent EDG test results to verify that each EDG had been adequately tested. The licensee also performed a review of test results and calculations to determine that each EDG had the capacity to provide alternate AC during an SBO event.

The licensee reviewed the electrical distribution system to ensure that alternate AC could be aligned to the SBO unit within required timeframe. Condensate and EDG fuel oil inventories were reviewed to verify that adequate inventories were maintained. Various plant support systems were also reviewed to ensure that power would be available to this equipment following the alignment of alternate AC. Operations personnel performed walkdowns of procedures used to respond to an SBO event to ensure that the procedures were adequate

and executable.

The licensee also conducted a review of open CAP items for potential SBO equipment impact. 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 activities. The inspectors selected a sample of equipment utilized for mitigation of a SBO and conducted independent walkdowns of that equipment to verify that the equipment was properly aligned. The sample of equipment selected by the inspectors included, but was not limited to, EDGs and auxiliaries. The inspectors also observed recent surveillance testing (including a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load test) on two EDGs to ensure that this equipment was able to perform its safety function.

Discuss general results including corrective actions by licensee. In general, the licensee's reviews verified that SBO equipment was ready to respond to a SBO condition. During their CAP review, however, the licensee noted multiple previously identified equipment issues on SBO support equipment which were not yet corrected. The inspectors were aware of each equipment issue identified by the licensee. The licensee had previously evaluated each condition using their prompt and immediate operability program. Functionality/Operability of the equipment was maintained in all cases. However, some cases required the implementation of compensatory measures. The inspectors reviewed each of the previously identified issues and determined that they would not prevent the licensee from responding to an SBO event. Corrective action program document numbers for each of the previously identified equipment issues are provided in the List of Documents Reviewed section of this report.

Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event. b. Demonstrate through walkdowns that procedures for response to an SBO are executable. The licensee conducted walkthroughs of SBO-related procedures with operations personnel to ensure the procedures were able to be executed without difficulty. In addition, the licensee performed several simulator scenarios using SBO-related procedures during the development of a risk assessment for one of the previously identified equipment issues.

Describe inspector actions to assess whether procedures were in place and could be

used as intended. The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walk through activities. The inspectors selected several sections of procedures walked through by the licensee and performed an independent review to verify the licensee's conclusions. The inspectors also observed several of the licensee's simulator scenarios. Through these simulator observations, the inspectors concluded that the SBO-related procedures utilized had been in place for some time and were fully executable.

Discuss general results including corrective actions by licensee. The licensee concluded that all procedures used to respond to an SBO event were executable. One CAP document was written regarding the need to evaluate whether some equipment should be labeled as emergency use only. However, this did not impact the licensee's ability to execute the SBO procedures. The CAP document number for this issue is provided in the List of Documents Reviewed section of this report.

03.03 Assess the licensee's 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. T he 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.

Licensee Action Describe the licensee's actions to verify the capability to mitigate existing design basis flooding events. a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and

maintained. The licensee reviewed the design and licensing bases for both internal and external flooding. Licensee actions included reviewing flooding related procedures and identifying equipment and penetration seals utilized/required for flood mitigation. The licensee walked down flooding related equipment to ensure it was adequate and properly staged. Flood related doors, bulk heads, barriers, penetration seals and equipment were identified. The licensee verified that this equipment was routinely inspected for functionality. Where routine inspections were not performed or could not be relied upon to ensure functionality, the licensee performed walkdowns and inspections to ensure that the components were functional. The licensee had also installed several in-plant modifications to address internal flooding vulnerabilities within the turbine building. The licensee verified that these modifications remained in good condition and provided appropriate protection during a

flooding event. Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended. The inspectors assessed the licensee's capabilities to mitigate flooding by conducting a review of the licensee's walkdown activities. In several instances, these reviews involved the inspectors accompanying licensee personnel during their walkdowns. The inspectors also conducted independent walkdowns of selected flood mitigation equipment as part of the overall assessment of the licensee's flood mitigating capabilities. Licensee flood mitigation procedures were reviewed to verify usability. The inspector's conclusions aligned with the results obtained by the licensee.

Discuss general results including corrective actions by licensee.

The licensee's verification of flood mitigation capability consisted of procedure reviews and walk downs to verify that the systems, structures, and components (SSCs) were present, periodically tested, and in acceptable condition. All design features, such as flood barriers, were present and in good condition with exceptions documented in the licensee's corrective action system. The licensee initiated several CAPs to document degraded seals. For these instances, the licensee's assessment of operability, which was reviewed by the inspectors, determined that the missing seal did not have any significant adverse impact on flood mitigation capability.

The licensee used plant specific design information to determine doors, barriers, and penetration seals that were required to remain functional to mitigate a flooding event. The licensee's reviews confirmed that all flood doors were inspected as part of a routine maintenance program. The licensee walked down other flood barriers and identified some internal flooding discharge paths that were not consistent with calculations/evaluations of record. The licensee evaluated these inconsistencies and determined that no operability issue existed. Independent assessment by the inspectors concluded similar results. Previous to this inspection, the licensee identified two additional flood barrier doors which had bottom seals that functioned intermittently. The licensee had previously established compensatory measures for each of these doors. Inspector review confirmed compensatory measures remained in place as of the date of this inspection. Additionally, the licensee identified a flood barrier penetration seal with a loose boot clamp. The licensee implemented actions to correct the problem by tightening the clamp. Other minor issues were noted by the licensee as part of the walkdown activities.

A list of items placed in the corrective action system is provided in the List of Documents Reviewed section of this inspection report.

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.

Licensee Action Describe the licensee's actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies. a. Verify through walkdowns that all required materials are adequate and properly staged, tested, and maintained. The licensee identified equipment utilized/required for mitigation of fire and flood events. Industry seismic experts conducted walkdowns of fire and flood mitigating SSCs to determine whether this equipment would remain available following a safe shutdown earthquake. Seismic vulnerabilities, including storage locations, were identified, along with mitigating strategies for equipment that was not seismically qualified.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended. The inspectors conducted walkdowns, both independently and in conjunction with licensee personnel, of important SSCs needed to mitigate fire and flood events to identify the potential that the SSC's function could be lost during a seismic event. This equipment included, but was not limited to:

• all major B.5.b contingency response equipment;

• all installed fire protection and suppression equipment in the turbine building;

• the installed diesel and electric fire pumps and their controls; and

• water tight doors, roof hatches and floor plugs at the plant screenhouse.

The results of the inspectors' reviews aligned with the licensee's conclusions that there were a number of seismic vulnerabilities that potentially need to be addressed, as described

below. Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

Seismically qualified SSCs normally consist of safety-related equipment that has been formally qualified to function during and after a design basis earthquake. The licensee's reviews for this issue determined that nonsafety-related SSCs, in general, were not considered to be either seismically qualified or seismically rugged due to a wide variety of issues. A majority of installed sump pumps and flooding detectors were not designed as seismically qualified and have not been evaluated as being seismically rugged. However, a majority of the sump pumps and flooding detectors were not relied upon following a seismic/flooding event. Similarly, the vast majority of the fire protection system was not designed to be seismically qualified and could not be considered seismically rugged.

Firefighting equipment staged to respond to B.5.b events was not stowed in seismically qualified buildings and locations, as a seismic event and B.5.b event have never been assumed to occur concurrently.

The licensee's reviews identified instances where response capability could be enhanced.

These included reviewing the locations of portable equipment and reviewing the need for supplemental portable equipment to compensate for the possible loss of much of the fire protection system.

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. The existing mitigation strategy was considered presently sufficient by the licensee. Further mitigation strategies may be developed and implemented following a review of industry lessons learned from the Fukushima Daiichi event. The licensee entered the issues identified into their CAP as CAPs 1280101 and 1280380; INPO ER L1 11-1: Recommendation 4 Vulnerabilities and Enhancements.

Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. S. Northard and other members of licensee management at the conclusion of the inspection on April 29, 2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

14 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Schimmel, Site Vice President

K. Davison, Plant Manager

T. Roddey, Site Engineering Director

J. Anderson, Regulatory Affairs Manager

C. Bough, Chemistry and Environmental Manager

B. Boyer, Radiation Protection Manager

K. DeFusco, Emergency Preparedness Manager

D. Goble, Safety and Human Performance Manager

J. Hamilton, Security Manager

J. Lash, Nuclear Oversight Manager

M. Milly, Maintenance Manager

J. Muth, Operations Manager

S. Northard, Performance Improvement Manager

K. Peterson, Business Support Manager

A. Pullam, Training Manager

R. Womack, Production Planning Manager (Acting)

Nuclear Regulatory Commission

J. Giessner, Chief, Reactor Projects Branch 4

T. Wengert, Project Manager, NRR

Enclosure

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list does