IR 05000277/2011009

IR 05000277/2011009 and 05000278/2011009; 04/15/2011 - 04/22/2011; Peach Bottom Atomic Power Station Plant; Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event

ML111300540
Person / Time
Site:	Peach Bottom
Issue date:	05/13/2011
From:	Doerflein L Engineering Region 1 Branch 2
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
Shared Package
ML111300168	List: IR 05000219/2011008 IR 05000220/2011010 IR 05000244/2011008 IR 05000271/2011009 IR 05000277/2011009 IR 05000286/2011009 IR 05000289/2011009 IR 05000293/2011009 IR 05000317/2011009 IR 05000354/2011009 IR 05000387/2011008 IR 05000443/2011009 ML111330455
References
IR-11-009
Download: ML111300540 (24)

Text

UNITED STATES NUCLEAR REGU LATORY COMMISSION

REGION I

475 ALLENDALE ROAD KlNG OF PRUSSIA. PA 19406-1415 May 13, 20L1.

Mr. Michael ==SUBJECT:==

PEACH BOTTOM ATOMIC POWER STATION NRC osooo277 t201 1 009 AN D I NSTRUcIoN 2s 1 5/1 s5 iNrsFecr oN REpoRT 05000278/201 1 009

Dear Mr. Pacilio:

(NRC) completgd an inspection at On April 22,2011, the U.S. Nuclear Regulatory CSmmission 2515l183, "Followup to your peach gottom'Atomic power statiSn, Jsing Temporarv lhstruction The enclosed inspection report.

the Fukushima Daiichi Nuclear station'Fueio"il"g" Event-."

documents the inspection results which *"t" Jit.,itsed on Aprll22,2011, with Mr' Navin and other members of Your staff.

capabilities of Peach Bottom Atomic The objective of this inspection was to promptly assess the power station to ,"rpono to eitraoroinary consequenc_es.simi[ar to those that have recently The results from this inspection, occurred at the Japanese Fukushima o"ii.ni Nuciear station.

operating commercial nuclear along with the r"rufii from this inspeciion performed at.other plants in the United states will be used to evaluate the u.s. nuclear industry's readiness to the NRC to determine if additional safely respond to similar events. These results will also help regulatory actions are warranted.

are contained in this All of the potential issues and observations identified by this inspection any issues to determine if report. The NRC,s Reactor Oversight Process willfurtlier evaluate or violations will be documented they are regulatory findings or violations. Any resulting findings respond to this letter'

by the NRG in t!p"t"t"-report. You are not required to

"

M. Pacilio 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 Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely, a%-^,,--,^--PK) *J!t*I Lawrence T. Doerflein, Chief /

Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56

Enclosure:

nspection Report 05000277 1201 1 009 and 0500027 f 81201 lOOg

REGION I Docket Nos: 50-277,50-278 License Nos: DPR.44, DPR-56 Report No: 05000277 t201 1 009, 050002781201 1009 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: April 15 - April 22,2011 Inspectors: C. Cahill, Senior Reactor Analyst, Division of Reactor Safety Approved by: Lawrence T. Doerflein, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

lR 0500027712011009 and 0500027812011009; 0411512011 - 041221201 1; Peach Bottom

Atomic Power Station Units 2 and 3; Temporary Instruction 25151183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.

This report covers an announced Temporary Instruction (Tl) inspection. The inspection was conducted by a region based inspector. 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 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 by security threats, committed to as part of NRC Security Order Section 8.5.b issued February 25, 20Q2, 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 (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.

Verify through test or The licensee reviewed the B.5.b equipment inspection and testing preventative maintenance tasks inspection that to ensure that the tasks were up to date and the equipment was available and functional. In equipment is available addition, the site conducted walkdowns to verify the adequacy of required inventories. Portable and functional. Active equipment such as pumps and generators were operated to verify readiness. B.5.b and severe equipment shall be accident management guidelines (SAMG) procedures were verified current and staged in the tested and passive appropriate locations. To verify that equipment was available and functional, the licensee equipment shall be completed inventories of 8.5.b and SAMG equipment under RT-O-100-505-2, "EOP Tool walked down and f nventory," RT-O-100-580-2, "8.5.b Tool and Material Inventory," and RT-O-037-376-2, "Outside inspected. lt is not Fire Brigade Equipment Inventory and Inspection." Additionally, the adequacy of emergency expected that radios and dosimetry was verified. The licensee tested the portable pump under work order permanently installed R1176714 and portable power supplies under work order R1094814.

equipment that is tested under an existing regulatory testing Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed program be retested.

test results, discussed actions, reviewed records, etc.).

This review should be The inspector assessed the licensee's capabilities by conducting a review of the licensee's done for a reasonable walkdown activities. ln addition, the inspector independently walked down and inspected all major sample of mitigating B.5.b contingency response equipment staged throughout the site. The inspector reviewed strateg ies/eq uipment. completed inventories and compared them with the results of field observations. Additionally, the resident inspector observed the testing of the portable pump under R1176714 on March 22, 2011.

Discuss general results including corrective actions by licensee.

The inspector concluded that equipment was available and functional. No significant deficiencies were identified. The licensee did identify several enhancements to improve the long term reliability of equipment, such as repairing the equipment trailer tarps and removing fuel out of standby generators. These were documented in AR 01192350 and AR 01189595 respectively.

Additionally, the licensee identified sevbral enhancements to increase the survivability of portable equipment in beyond-design basis type events. All equipment (active and passive) designated for B.S.b was verified by the licensee to be in applicable procedures. All passive equipment for both units was walked down and verified to be in place and ready for use. The licensee issued Action Request (AR) 01189595 to track the actions associated with this activity.

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 The licensee performed audits of all applicable procedures identified in AR 01 189595 for walkdowns or procedures located in the Main Control Room, Shift Manager's office, Technical Support Center, demonstration that and Offsite Support Center. In addition, Records Management also audited all special event (SE)procedures to implement procedures and allT-200-3 series procedures. These audits verified that all documents were the strategies associated current and in good condition. Licensee personnel walked down all applicable procedures to with 8.5.b and 10 CFR verify the ability of the procedures to be executed.

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 installed equipment during this verification. The inspector examined the station's established guidelines and implementing procedures for the 8.5.b mitigation strategies. The inspector assessed how the licensee coordinated and This review should be documented the interface/transition between existing off-normal and Emergency Operating done for a reasonable Procedures (EOPs) with the mitigation strategies. The inspector selected a number of mitigation sample of mitigating strategies and conducted plant walk downs with responsible plant staff to assess: the adequacy strateg ies/eq uipment.

and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

Discuss general results including corrective actions by licensee.

The inspector concluded that procedures to implement the strategies associated with 8.5.b and 10CFR50.54(hh) were in place and were executable. The licensee reviewed SAMG strategies and did not identify any deficiencies. Procedures used for 8.5.b were reviewed by the licensee and walkdowns were performed by operators to ensure actions taken in the field in response to a B.S.b event could be performed. Some minor procedural enhancements were identified by the licensee and entered into the corrective action program (CAP).

Describe the licensee's actions and conclusions regarding training and qualifications of operators Licensee Action and support staff.

Verify the training and The licensee conducted initial and continuing B.5.b training and verified that training was qualifications of completed. Additionally, the licensee verified that all required operations personnel have received operators and the initialand continuing SAMG training. Both 8.5.b and SAMG training is an annualtraining support staff needed to requirement in accordance with the Long Range Training Plan. The licensee reviewed training implement the records and documentation to ensure that the training was up to date and verified that there was a procedures and work sufficient number of personnel trained on-site and throughout Exelon to implement the severe instructions are current accident mitigation guidelines.

for activities related to Security Order Section B.S.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 inspector examined the introductory and periodic/refresher training provided to the Operations and Security Department staffs most likely to be tasked with the implementation of the B.5.b mitigation strategies. The inspector's review consisted of examination of training records, actions completed as documented in AR 01189595, and interviews with station personnel.

Discuss general results including corrective actions by licensee.

Based upon the inspector's review of training associated with AR 01189363, interviews, and observations of plant staff during the walk down of mitigating strategies in the field, the inspector concluded that overall 8.5.b and severe accident management guideline training provided by the licensee was appropriate and consistent with regulatory and industry guidelines.

Describe the licensee's actions and conclusions regarding applicable agreements and contracts Licensee Action are in place.

d. Verify that any The licensee verified that agreements from the municipal fire departments and other commitments applicable agreements for various pieces of support equipment required to implement the strategies were in place and and contracts are in active. The primary memorandum of understanding associated with this strategy is with the Delta, place and are capable of Pennsylvania Fire Department. The licensee renewed this agreement with the Delta Fire meeting the conditions Company on February 1,2011. As a result of this effort the licensee reaffirmed the conditions of needed to mitigate the this agreement with the Delta Fire Chief. The licensee documented this review in AR01189595.

consequences of these Additionally, the licensee reviewed current interface agreements for support, and contracts with events.

suppliers and vendors to ensure that they were capable of meeting the conditions needed to mitigate the consequences of large fire or explosion type event.

This review should be done for a reasonable sample of mitigating For a sample of mitigating strategies involving contracts or agreements with offsite entities, strateg ies/eq uipment.

describe inspector actions to confirm agreements and contracts are in place and current (e.9.,

confirm that offsite fire assistance agreement is in place and current).

The inspector verified that the licensee had in place a current memorandum of understanding (MOU) or a letter of agreement (LOA) with off-site agencies to provide assistance in mitigation strategies.

Discuss general results including corrective actions by licensee.

No deficiencies were identified. The inspector concluded that the agreement and contracts in place were appropriate for the strategies evaluated.

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

Review any open The licensee identified minor equipment and procedural issues and entered them into the CAP. A corrective action list of corrective actions is included in the documents reviewed listed in the Attachment to this documents to assess report. The inspector sampled the identified conective actions and determined that none of the problems with mitigating issues identified were significant or would preclude the successful implementation of any existing strategy implementation mitigating strategy.

identified by the licensee. Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.

03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that Tl 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..

a. Verify through The licensee conducted walkdowns of all onsite required SBO related equipment to ensure that it walkdowns and was adequate, properly staged, tested, and maintained. In addition, the licensee ensured that the inspection that all off-site alternate AC power source was capable of being aligned to support the site in the required required materials are time. The licensee also conducted a review of open CAP items for potential SBO equipment adequate and properly impact.

staged, tested, and maintained.

Describe inspector actions to verify equipment is available and useable.

The inspector assessed the licensee's capability to mitigate SBO conditions by conducting a review of the licensee's walkdown activities, interviewing operators, and independently walking down on-site SBO equipment. Specifically, the inspector walked down all emergency diesel generators, station batteries, SBO switching batteries, and alternate AC power source switchgear.

The inspector also reviewed a sample of SBO related maintenance and test activities to ensure that the equipment was properly, designed, tested, and maintained.

Discuss general results including corrective actions by licensee.

03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that Tl 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.

a. Verify through The licensee conducted walkdowns of all onsite required SBO related equipment to ensure that it walkdowns and was adequate, properly staged, tested, and maintained. In addition, the licensee ensured that the inspection that all off-site alternate AC power source was capable of being aligned to support the site in the required required materials are time. The licensee also conducted a review of open CAP items for potential SBO equipment adequate and properly impact.

staged, tested, and maintained.

Describe inspector actions to verify equipment is available and useable.

The inspector assessed the licensee's capability to mitigate SBO conditions by conducting a review of the licensee's walkdown activities, interviewing operators, and independently walking down on-site SBO equipment. Specifically, the inspector walked down all emergency diesel generators, station batteries, SBO switching batteries, and alternate AC power source switchgear.

The inspector also reviewed a sample of SBO related maintenance and test activities to ensure that the equipment was properly, designed, tested, and maintained.

Discuss general results including corrective actions by licensee.

No deficiencies were identified. The inspector concluded that the licensee's reviews verified the adequacy of the SBO equipment to respond to an event. During their reviews, the licensee identified potential enhancements in emergency lighting and documented these results in AR 01 189595.

Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.

b. Demonstrate through The licensee conducted walkdowns to verify that the procedures for response to an SBO were walkdowns that executable. Additionally, the licensee performed audits of all applicable procedures located in the procedures for response Main Control Room, Shift Manager's office, Technical Support Center, and Offsite Support Center.

to an SBO are These audits verified that all documents were current and in good condition.

executable.

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

The inspector reviewed the licensee actions to demonstrate that procedures for response to an SBO are executable, as documented in their internal review report associated with the Fukushima Daiichi Nuclear Station Fuel Damage Event. The inspector also conducted a table-top exercise of the site SBO, including reviewing procedures used by the offsite organization for the operation of the alternate AC power supply (i.e., Conowingo Hydroelectric Station). The inspector independently walked down the station blackout procedure SE-11.1, in the field and on the simulator to verify its adequacy.

Discuss general results including corrective actions by licensee.

No deficiencies were identified. The inspector concluded that the licensee's reviews verified that SBO procedures were adequate and executable to respond to an SBO condition.

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.

Verify through The licensee conducted walkdowns and inspections of all required materials and equipment walkdowns and necessary to mitigate an internal or external flood to ensure they were adequate and properly inspection that all staged. As part of these walkdowns, the licensee considered the potential that the equipment's required materials are function could be lost during seismic events appropriate for the site. The licensee documented the adequate and properly area or structures, systems and components (SSC) inspected, procedures and staged, tested, and surveillances/preventative maintenance activities reviewed, permanent or portable SSC inspected, maintained.

and vulnerabilities identified.

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

The inspector independently walked down risk significant flood protection features and structures associated with the emergency diesel generators, emergency cooling tower, and emergency/high pressure service water. The inspector also walked down portions of the flooding procedure, SE-4, and reviewed the design qualification and installation of a selected sample of flood seals. The inspector also reviewed a sample of flood related corrective actions resulting from the licensee's review.

Discuss general results including corrective actions by licensee.

The inspector concluded that that all required materials were adequate and properly staged, tested, and maintained to mitigate a flooding event within the plant's design basis. While no operability or significant concerns were identified, the licensee identified several minor flood barrier and door discrepancies and procedural enhancements which were appropriately entered into the corrective action program. Beyond design basis vulnerabilities were identified and entered into the corective action program for further evaluation. The inspector reviewed the associated action requests listed in the Attachment to this report, and determined the licensee's initial responses, including their assessment and prioritization, were appropriate.

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 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 availability Licensee Action of equipment used in fire and flooding mitigation strategies.

a. Verify through The licensee utilized industry guidance to assess the potential impact of seismic events on the walkdowns that all availability of equipment used in fire and flooding mitigation strategies. These industry guidelines required materials are were used to govern the conduct of walkdowns and inspections of both permanent and temporary adequate and properly plant equipment.

staged, tested, and maintained.

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

The inspector reviewed the scope of the licensee assessments and the results of their walkdowns.

The inspector also independently walked down a sample of risk significant areas of the plant to assess beyond design basis seismic and flooding vulnerabilities. Systems of particular interest included the emergency diesel generators, service water, emergency cooling tower, vital switchgear, and batteries. Additionally, the inspector reviewed the licensee's design basis documents for Internal Hazards (P-T-09) and External Hazards (P-T-07). The inspector concluded that the licensee meets the current licensing and design bases for fire protection and flooding.

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 inspector concluded that the licensee's reviews were comprehensive. In reviewing beyond design basis flooding and seismic interactions, the licensee identified several potential enhancements that could improve the survivability of equipment or mitigation strategies. These enhancements mainly focused on improvements to the seismic quality of the fire suppression systems and the flood detection and sump pump systems. Additionally, the licensee identified enhancements in the placement and storage of portable equipment used to mitigate beyond design basis events. The licensee documented their observations in the Corrective Action Program under issue reports (lR's) 1 199602, 1 199620, 1 199643, 1 199739, 1 199761 , 1199773, and 1 201 621 lor further evaluation.

Meetinos 4OAO Exit Meetinq The inspectors presented the inspection results to Mr. P. Navin and other members of licensee management at the conclusion of the inspection on April 22,2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

P. Navin, Operations Director

J. Armstrong, Regulatory Assurance Manager

P. Kester, Design Engineering

J. Lyter, Operations Support

J. McClintock, Operator Training

C. Sinopoli, Fire Protection Engineer

R. Smith, Regulatory Assurance

Nuclear Requlgtorv Commission

A. Ziedonis, Peach Bottom Resident Inspector

Other

B. Fuller, Nuclear Safety Specialist, Pennsylvania Department of Environmental Protection