ML13163A265

from Larry Doerflein to Diane Screnci: Summary of Inspection Issues

ML13163A265
Person / Time
Site:	FitzPatrick
Issue date:	05/13/2011
From:	Doerflein L Division of Reactor Safety I
To:	Frank Arner, Mcnamara N, Chris Miller, Darrell Roberts, Diane Screnci, Neil Sheehan, Williams C Office of Public Affairs, NRC Region 1
References
FOIA/PA-2013-0010
Download: ML13163A265 (18)

Text

Doerflein, Lawrence From: Doerflein, Lawrence Sent: Friday, May 13, 2011 2:05 PM To: Screnci, Diane; Sheehan, Neil; McNamara, Nancy; Miller, Chris; Roberts, Darrell Cc: Williams, Christopher; Arner, Frank

Subject:

summary of inspection issues Attachments: Summary of Issues with Context added .docx Follow Up Flag: Follow up Flag Status: Flagged FYI, attached is a summary of the issues identified in the TI 183 inspections.

They are broken down by section (03.01, 03.02), then by plant.

I C/3

TI 2515/183 REGION I

SUMMARY

OF OBSERVATIONS TI Section 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 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).

Site I Issue Summary i

Outside of Scope

/ FitzPatrick The licensee identified that a PM requirement for periodic hydrostatic testing of staged B.5.b hoses and periodic testing of staged nozzles did not exist.

The licensee identified that the annual PM contract on the fire engine pumper 3

I truck did not specify the required maintenance actions.

The licensee identified that the primary containment venting procedure did not address hydrogen concentrations.

The licensee identified that some agreements were required to be established with local volunteer fire departments.

The inspectors identified that the current licensing basis does not require the licensee to have a hardened wet well vent installed as part of their Mark I containment program improvements. While the decision to not install the hardened vent received regulatory approval, it may be appropriate to reevaluate the adequacy of the existing wet well vent strategy and configuration.

The inspectors identified that the SAMGs reference procedure EP-6, 'Post Accident Containment Venting and Gas Control," when containment venting is required, however, this procedure assumes that electrical power is available.

CONTEXT HYDROGEN VENTING FROM CONTAINMENT 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 basis vulnerability, in that FitzPatrick's current licensing basis did not require the plant to have a primary containment torus air space hardened vent as part of their Mark I containment improvement program. 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.

Outside of Scope

Outside of Scope Outside of Scope Outside of Scope TI Section 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 whether station design is functional and valid.

Site I Issue Summary Outside of Scope FitzPatrick The licensee identified that an auto-transformer did not have any associated PM tasks assigned, 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 identified an apparent beyond design and licensing basis vulnerability, in that current procedures do not address hydrogen considerations during primary containment venting.

The inspectors identified a beyond design and licensing basis vulnerability, in that FitzPatrick's current licensing basis did not require the plant to have a hardened torus vent as part of their Mark I containment improvement program.

CONTEXT: The inspectors found that Fitzpatrick meets their existing licensing and design bases. However, The NRC has established an agency task force to conduct a near term evaluation of the need for

Outside of Scope Outside of Scope Outside of Scope TI Section 03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design.

Site Issue Summary Outside of Scope Pit7P~qtrir~k I Ninnp Outside of Scope

Outside of Scope I

TI Section 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.

Site I Issue Summary Outside of Scope

Outside of Scope FitzPatrick FitzPatrick The inspectors identified 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. Given a design basis seismic event followed by significant fire(s) and internal flooding, there would likely be insufficient personnel to effectively deal with these events simultaneously. 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.

CONTEXT: These issues are beyond design bases type considerations which the NRC Task Force will continue to review and evaluate if future actions are required.

The inspectors identified a beyond design and licensing basis vulnerability, in that the licensee had not implemented vendor recommended periodic fire fiahtina foam concentrate testinq for on-site portable fire fighting foam tanks.

~1 Outside of Scope

Outside of Scope Outside of Scope Outside of Scope Outside of Scope Outside of Scope