IR 05000336/2008008

IR 05000336-08-008; Dominion Nuclear Connecticut, Inc; 11/17/2008 - 12/05/2008; Millstone Power Station, Unit 2; Triennial Fire Protection Team Inspection, Fire Protection

ML090150219
Person / Time
Site:	Millstone
Issue date:	01/14/2009
From:	Rogge J Engineering Region 1 Branch 3
To:	Christian D Dominion Resources
References
IR-08-008
Download: ML090150219 (30)

Text

ary 14, 2009

SUBJECT:

MILLSTONE POWER STATION, UNIT 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000336/2008008

Dear Mr. Christian:

On December 5, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Millstone Power Station, Unit 2. The enclosed inspection report documents the inspection results, which were discussed on December 5, 2008, with Mr. Skip Jordan and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, the NRC identified two findings of very low safety significance (Green) that were violations of NRC requirements. However, because of their very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as a non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at the Millstone Power Station.

In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs document system (ADAMS).

Mr. David ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-336 License No. DPR-65 Enclosure: Inspection Report No. 05000336/2008008 w/Attachment: Supplemental Information

Mr. David

SUMMARY OF FINDINGS

IR 05000336/2008008; 11/17/2008 - 12/05/2008; Dominion Nuclear Connecticut, Inc.; Millstone

Power Station, Unit 2; Triennial Fire Protection Team Inspection, Fire Protection.

This report covered a two-week triennial fire protection team inspection by specialist inspectors.

Two Green NCVs were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Rev. 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The team identified that Dominion failed to administratively control and ensure the availability of all necessary fire safe shutdown equipment to perform manual actions in the 4kV upper switchgear room. This finding was determined to be of very low safety significance (Green) and a NCV of the Millstone Nuclear Power Station, Unit 2 Operating License condition 2.C.(3), Fire Protection.

The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, Dominion did not ensure that an electrical flash jacket necessary to perform local breaker operations was available in the upper 4kV switchgear room. Actions to restore the A diesel generator would have been delayed for a fire in the lower 4kV switchgear room. The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding affected post-fire safe shutdown systems. This finding screened to very low safety significance (Green) in Phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because additional electrical flash jackets were onsite and the local breaker operations would likely have been performed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The safe shutdown analysis most restrictive timeline for a fire in the lower switchgear room required a charging pump restored within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for reactor coolant system makeup. Local breaker operations in the upper 4kV switchgear room would be needed to support ac power to a charging pump. The team determined that this finding had a cross cutting aspect in the area of human performance because personnel did not return an electrical flash jacket to its proper storage location even though it was clearly labeled for the upper 4kV switchgear room. (H.4(b)) (Section 1R05.01)

Green.

The team identified that Dominion failed to ensure that a post-fire manual action to restore auxiliary feedwater (AFW) flow to a steam generator (SG) would be performed within 30 minutes of a plant trip consistent with the Millstone Unit 2 fire safe shutdown analysis. This finding was determined to be of very low safety significance (Green) and a

NCV of the Millstone Nuclear Power Station, Unit 2 Operating License condition 2.C.(3),

Fire Protection.

The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, a timely manual action to restore AFW to SG 1 within 30 minutes of the plant trip for a fire in Fire Area R-2 was not ensured for all circumstances and was validated by Dominion in 1999 to take at least 40 minutes. This finding was similar to more than minor example 3.i in NRC Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix E,

Examples of Minor Issues. The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding affected post-fire safe shutdown systems. This finding screened to very low safety significance (Green) in Phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because Dominion performed a sensitivity analysis of S-02824-S2, Millstone Unit 2, R-2 Fire, Appendix R Analysis, Rev. 2, and determined that restoring AFW flow to steam generator 1 could be delayed for 50 minutes and result in acceptable plant performance during a safe shutdown event. (Section 1R05.01)

Licensee-Identified Violations

None.

REPORT DETAILS

Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether Dominion Nuclear Connecticut, Inc. (Dominion) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Millstone Power Station, Unit 2. The following fire areas and fire zones were selected for detailed review based on risk insights from the Unit 2 Individual Plant Examination of External Events:

• R-1, A-24

• R-2, T-8

• R-10, A-21

• R-11, A-28 The inspection team evaluated Dominions fire protection program (FPP) against applicable requirements which included plant technical specifications, technical requirements manual, Operating License condition 2.C.3, 10 CFR 50.48, and 10 CFR 50 Appendix R. The team also reviewed related documents that included NRC safety evaluation reports, the Final Safety Analysis Report (FSAR), Section 9.10, the fire hazards analysis (FHA), and the post-fire safe shutdown analysis.

Specific documents reviewed by the team are listed in the attachment.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection (IP 71111.05T)

.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and

Normal Shutdown

a. Inspection Scope

Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentations drawings, electrical drawings, the FSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room. This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the FHA. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown locations would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).

Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.

Operational Implementation The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for safe shutdown using the normal or alternative shutdown systems and procedures are trained and available onsite at all times, exclusive of those assigned as fire brigade members.

The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also verified that the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time critical actions, which were verified included restoration of alternating current (AC) electrical power, establishing the remote shutdown panel, establishing reactor coolant makeup, and establishing decay heat removal.

Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:

• AOP 2579A, Fire Procedure for Hot Standby Appendix R Fire Area R-1, Rev. 009-07;

• AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-1, Rev. 004-02;

• AOP 2579B, Fire Procedure for Hot Standby Appendix R Fire Area R-2, Rev. 006-04;

• AOP 2579BB, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-2, Rev. 005-04;

• AOP 2579D, Fire Procedure for Hot Standby Appendix R Fire Area R-11, Rev. 006-06;

• AOP 2579DD, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-11, Rev. 005-04;

• AOP 2579F, Fire Procedure for Hot Standby Appendix R Fire Area R-10, Rev. 006-03;

• AOP 2579FF, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-8 and R-10, Rev. 005-03; and,

• AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area R-14, Rev. 006-03.

The team reviewed manual actions to ensure that they had been properly reviewed and approved and that the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each fire area. The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to ensure the tests were adequate to ensure the functionality of the alternative shutdown capability.

b. Findings

===.1

Introduction.

The team identified that Dominion failed to administratively control and===

ensure the availability of all necessary fire safe shutdown equipment to perform manual actions in the upper 4kV switchgear room. This finding was determined to be of very low safety significance (Green) and a NCV of the Millstone Nuclear Power Station, Unit 2 Operating License condition 2.C.(3), Fire Protection.

Description.

On November 20, 2008, the team observed operators walkthrough portions of AOP 2579A, Fire Procedure for Hot Standby Appendix R Fire Area R-1, Rev. 009-07.

6 of AOP 2579A required operators to perform manual 4kV and 6.9kV breaker operations in the upper 4kV switchgear room and necessitated that an electrical flash jacket, as well as other protective gear be worn while conducting local breaker operations.

The team noted that an electrical flash jacket was missing from its assigned locker.

Dominion investigated the missing electrical flash jacket and discovered that it was left in the lower 4kV switchgear room. Dominion believed that the electrical flash jacket was likely left in the lower 4kV switchgear room during the week of November 10, 2008, when local breaker operations were performed to support on-line maintenance activities. The electrical flash jacket was clearly marked as belonging to the upper 4kV switchgear room.

Dominion maintained two electrical flash jackets for operator use at Unit 2, and both were stored in the lower 4kV switchgear room from about November 10, 2008 to November 20, 2008. Other electrical flash jackets were maintained on site, such as at Unit 3, but their locations would have delayed local breaker operations in the upper 4kV switchgear room.

An electrical fire in the lower 4kV switchgear room would have required operators to locate an electrical flash jacket from outside the Unit 2 designated safe shutdown areas to complete manual breaker operations in the upper 4kV switchgear room.

Dominion promptly relocated the electrical flash jacket to the upper 4kV switchgear room.

Dominion also documented this issue in corrective action program condition report CR 119667 and initiated a review of administrative controls to ensure an electrical flash jacket was always maintained in each 4kV switchgear room. The team determined that failing to administratively control and ensure all necessary fire safe shutdown equipment available to perform manual actions in the upper 4kV switchgear room is a performance deficiency.

Analysis.

The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, Dominion did not ensure that an electrical flash jacket necessary to perform local breaker operations was available in the upper 4kV switchgear room. Actions to restore the A diesel generator would have been delayed for a fire in the lower 4kV switchgear room.

The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding affected post-fire safe shutdown systems. This finding screened to very low safety significance (Green) in phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because additional electrical flash jackets were onsite and the local breaker operations would likely have been performed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The safe shutdown analysis most restrictive timeline for a fire in the lower switchgear room required a charging pump restored within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for reactor coolant system makeup. Local breaker operations in the upper 4kV switchgear room would be needed to provide AC power to a charging pump.

The team determined that this finding had a cross cutting aspect in the area of human performance because personnel did not return an electrical flash jacket to its proper storage location even though it was clearly labeled for the upper 4kV switchgear room.

(H.4(b))

Enforcement.

Millstone Nuclear Power Station Operating License condition 2.C.(3)requires that Dominion Nuclear Connecticut, Inc. shall implement and maintain in effect all provisions of the Fire Protection Program as described in the approved fire protection program as described in the Final Safety Analysis Report (FSAR). FSAR section 9.10 states in part that the Millstone Nuclear Power Station Fire Protection Program Manual (MP-24-FPP-PRG, Fire Protection Program, Rev. 003-004) has been developed to ensure that any single fire will not prevent the performance of necessary safe shutdown functions.

Section 1.3.2 of MP-24-FPP-PRG, Fire Protection Program, Rev. 003-004 defines fire safe shutdown equipment as Included within this group are the dedicated equipment, tools and consumables required to perform manual action and cold shutdown repair activities for safe shutdown. Section 4.3.3 of MP-24-FPP-PRG requires administrative control of equipment credited for safe shutdown. Contrary to the above, from about November 10, 2008, until November 20, 2008, Dominion failed to administratively control an electrical flash jacket, equipment credited for safe shutdown for a fire in the lower switchgear room. Because this finding was of very low safety significance (Green) and has been entered into Dominions corrective action program (CR 119667), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy.

NCV 05000336/2008008-01, Failure to Ensure Equipment Necessary For Fire Safe Shutdown Available.

===.2

Introduction.

The team identified that Dominion failed to ensure that a post-fire manual===

action to restore auxiliary feedwater (AFW) flow to a steam generator (SG) could be performed within 30 minutes of a plant trip consistent with the Millstone Unit 2 fire safe shutdown analysis. This finding was determined to be of very low safety significance (Green) and a NCV of the Millstone Nuclear Power Station, Unit 2 Operating License condition 2.C.(3), Fire Protection.

Description.

Millstone Power Station Unit 2 post-fire safe shutdown analysis, 25203-SP-M2-SU-1046, MP2 Appendix R Compliance Report, Rev. 00, required that AFW flow be restored to a single SG within 30 minutes of the plant trip for a fire in Fire Area R-2. The requirement was derived from analysis S-02824-S2, Millstone Unit 2, R-2 Fire, Appendix R Analysis, Rev. 2. Restoring AFW flow within 30 minutes of the plant trip ensured that SG 1 would not dryout, thereby maintaining decay heat removal and ensuring that pressurizer level indication remained on scale.

M2-SU-1046 also determined that only the Facility Z1 motor driven AFW (MDAFW) pump could be credited for decay heat removal because both the turbine driven AFW (TDAFW)pump and Facility Z2 MDAFWP pump were disabled because of the potential of spurious operations. Additionally, procedure AOP 2579B, Fire Procedure for Hot Standby Appendix R Fire Area R-2, Rev. 006-04, included procedure steps to disable the TDAFW pump and the Facility Z2 MDAFW pump. For a Fire Area R-2 fire, operation of diesel generator A (DG A) may be required to support the Facility Z1 MDAFW pump.

On March 17, 1999, operators at Millstone Unit 2 performed a time validation of AOP 2579B, Rev. 4., Attachment 5, Restoring AC Power to Bus 24C and Align Power to Bus 24C from DG A, with a 40 minute completion time. The team noted that the current AOP 2579B revision, Rev. 006-004, maintained the same sequence and manual actions as AOP 2579B, Rev. 4. Considering the 30 minute requirement derived from calculation M2-SU-1046 to restore AFW, the team questioned Dominions ability to restore AC power in sufficient time to prevent SG 1 dryout.

Dominion reviewed the teams issue and concluded that the local manual actions necessary to restore ac power to bus 24C from DG A could exceed 30 minutes dependent on the initial service water header alignment. Specifically, if Facility Z2 service water pump was initially aligned to the Facility Z1 service water header, DG A would be manually tripped or not started until manual actions to isolate unnecessary service water loads were performed. These actions would be necessary to prevent a runout condition on the Facility Z1 service water pump and to align sufficient service water flow to DG A.

Dominion further concluded that DG A would be started in sufficient time to restore AFW flow within 30 minutes from the Facility Z1 MDAFW pump if valve 2-SW-97A, B Service Water Pump Discharge to A Service Water Header, was maintained in its normally closed position.

Dominion promptly issued an operations shift night order to implement technical requirements manual compensatory actions for Fire Area R-2 if 2-SW-97A was maintained open. Dominion also documented this issue in corrective action program condition report CR 121147 and intended to re-perform a time validation of AOP 2579B.

The team concluded that failing to ensure that AFW flow would be restored to a SG within 30 minutes consistent with the Millstone Unit 2 post-fire safe shutdown analysis is a performance deficiency.

Analysis.

The team determined that this finding was similar to more than minor example 3.i in NRC Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, in that an analysis of S-02824-S2, Millstone Unit 2, R-2 Fire, Appendix R Analysis, had to be re-evaluated to determine the allowable time delay for restoring AFW flow to SG 1. Specifically, the mitigating system cornerstone affected a timely manual action to restore AFW to SG 1 within 30 minutes of the plant trip for a fire in Fire Area R-2. This manual action was not ensured for all circumstances and was validated by Dominion in 1999 to take at least 40 minutes.

The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding affected post-fire safe shutdown systems. This finding screened to very low safety significance (Green) in Phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because Dominion performed a sensitivity analysis of S-02824-S2, Millstone Unit 2, R-2 Fire, Appendix R Analysis, Rev. 2, and determined that restoring AFW flow to steam generator 1 could be delayed for 50 minutes and result in acceptable plant performance during a safe shutdown event.

The team determined that this finding did not have a cross cutting aspect because the performance deficiency occurred in 1999 and was not indicative of current licensee performance.

Enforcement.

Millstone Nuclear Power Station Operating License condition 2.C.(3)requires that Dominion Nuclear Connecticut, Inc. shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report (FSAR). FSAR section 9.10 states in part that the Millstone Nuclear Power Station Fire Protection Program Manual (MP-24-FPP-PRG, Fire Protection Program, Rev. 003-004) has been developed to ensure that any single fire will not prevent the performance of necessary safe shutdown functions. Section 4.1.2.e. of MP-24-FPP-PRG, Fire Protection Program, Rev. 003-004 ensures the manual actions identified in the Fire Safe Shutdown Compliance Report can be performed under prevailing conditions, and that adequate time, manpower, emergency lighting, and communications are available. Contrary to the above, from about March 17, 1999 until November 20, 2008, Dominion failed to ensure that a manual action, restoring AFW flow, for Fire Area R-2 could be performed under all circumstances within 30 minutes consistent with the Fire Safe Shutdown Compliance Report. Because this finding was of very low safety significance (Green) and has been entered into Dominions corrective action program (CR 121147), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000336/2008008-02, Failure to Ensure Timely Manual Action Consistent with the Post-Fire Safe Shutdown

.02 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the FHA, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separation requirements of Section III.G of 10 CFR 50, Appendix R were maintained for the credited safe shutdown equipment and their supporting power, control and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.

The team reviewed Dominions procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.

b. Findings

No findings of significance were identified.

.03 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors and fire dampers), and electrical raceway fire barriers to ensure they were appropriate for the fire hazards in the area.

The team reviewed installation/repair and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design. The team also reviewed similar records for the fire protection wraps to ensure the material was of an appropriate fire rating and that the installation met the engineering design.

b. Findings

No findings of significance were identified.

.04 Active Fire Protection

a. Inspection Scope

The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association (NFPA) code of record or as NRC approved exemptions, and that each suppression system would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of the suppression agent delivery systems was verified to meet the code requirements for the hazards involved. The team also performed a walkdown of accessible portions of the detection and suppression systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire pumps, storage tanks and supply system) to assess the material condition of the systems and components.

The team reviewed electric and diesel fire pump flow and pressure tests to ensure that the pumps were meeting their design requirements. The team also reviewed the fire main loop flow tests to ensure that the flow distribution circuits were able to meet the design requirements.

The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown capability.

In addition, the team inspected the fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.

b. Findings

No findings of significance were identified.

.05 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture of inadvertent operation of fire suppression systems. Specifically, the team verified that:

• A fire in one of the selected fire areas would not directly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains;

• A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not directly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and,

• Adequate drainage is provided in areas protected by water suppression systems.

b. Findings

No findings of significance were identified.

.06 Alternative Shutdown Capability

a. Inspection Scope

Alternative shutdown capability for the areas selected for inspection utilizes shutdown from outside the control room and is discussed in section 1R05.01 of this report.

b. Findings

No findings of significance were identified.

.07 Circuit Analysis

a. Inspection Scope

The team verified that Dominion performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the team verified that the Dominions analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.

The teams review considered fire and cable attributes, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.

The team also reviewed cable routing for a sample of components required for post-fire safe shutdown to verify that cable routing was consistent with the assumptions and conclusions of the safe shutdown analyses.

Cable failure modes were reviewed for the following components:

• P18B, B Charging Pump;

• P18C, C Charging Pump;

• P9B, B Auxiliary Feedwater Pump;

• 2-CH-089, Regenerative Heat Exchanger Discharge Isolation Valve; and,

• FI-5277A-1, Auxiliary Feedwater Flow Indicator to Steam Generator 1.

The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.

b. Findings

No findings of significance were identified.

.08 Communications

a. Inspection Scope

The team reviewed safe shutdown procedures, the FHA, and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review, the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns. The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and for plant operators. The team also verified that communications equipment such as sound powered phone system cables, repeaters, and transmitters would not be affected by a fire.

b. Findings

No findings of significance were identified.

.09 Emergency Lighting

a. Inspection Scope

The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained in a manner that would ensure reliable operation.

b. Findings

No findings of significance were identified.

.10 Cold Shutdown Repairs

a. Inspection Scope

The team verified that Dominion had dedicated repair procedures, equipment, and materials to accomplish repairs of components required for cold shutdown which might be damaged by the fire to ensure cold shutdown could be achieved within the time frames specified in their design and licensing bases. The team verified that the repair equipment, components, tools, and materials (e.g. pre-cut cables with prepared attachment lugs)were available and accessible on site.

b. Findings

No findings of significance were identified.

.11 Compensatory Measures

a. Inspection Scope

The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g. detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that Dominion was effective in returning the equipment to service in a reasonable period of time.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

[OA]

4OA2 Identification and Resolution of Problems

.01 Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team verified that Dominion was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program. The team also reviewed a sample of selected issues to verify that Dominion had taken or planned appropriate corrective actions.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented their preliminary inspection results to Mr. Skip Jordan, Site Vice President, and other members of the site staff at an exit meeting on December 5, 2008.

On January 6, 2009, the team leader updated the inspection results to S. Waino and other members of the site staff. No proprietary information was included in this inspection report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

P. Anastas, Nuclear Engineer

J. Armstrong, Nuclear Engineer

D. Aube, Supervisor Nuclear Engineering

C. Chapin, Supervisor Nuclear Shift Operations

G. Closius, Licensing Lead

K. Deveau, Inspection Liaison

A. Elms, Manager Nuclear Engineering

B. Griffin, Director Nuclear Safety and Licensing

M. Jalbert, Inspection Liaison

A. Jordan, Site Vice President

R. MacManus, Director Engineering

J. Mangeno, Nuclear Engineer

P. Raimondi, Nuclear Engineer

J. Semancek, Operations Manager

R. Tooker, Inspection Liaison

S. Waino, Supervisor Nuclear Engineering

B. Wilkins, Fire Marshall

NRC

J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety

W. Schmidt, Senior Reactor Analyst, Division of Reactor Safety

S. Shaffer, Senior Resident Inspector, Millstone Power Station

B. Haagensen, Resident Inspector, Millstone Power Station

J. Krafty, Resident Inspector, Millstone Power Station

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000336/2008008-01 NCV Failure to Ensure Equipment Necessary For Fire Safe Shutdown Available

05000336/2008008-02 NCV Failure to Ensure Timely Manual Action Consistent with the Post-Fire Safe Shutdown Analysis

Closed

None

Discussed

None