IR 05000413/2011008

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NRC Temporary Instruction 2515/183 Inspection Report 05000413/2011008, 05000414/2011008
ML111330185
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 05/13/2011
From: Bartley J
NRC/RGN-II/DRP/RPB1
To: Morris J
Duke Energy Carolinas
References
IR-11-008
Download: ML111330185 (21)


Text

UNITED STATES May 13, 2011

SUBJECT:

CATAWBA NUCLEAR STATION - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000413/2011008, 05000414/2011008

Dear Mr. Morris:

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Catawba Nuclear Station using Temporary Instruction 2515/183, Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event. The enclosed inspection report documents the inspection results which were discussed on May 10, 2011, with you and other members of your staff.

The objective of this inspection was to promptly assess the capabilities of Catawba 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 industrys 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 NRCs 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.

DEC 2 In accordance with 10 CFR 2.390 of the NRCs 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 NRCs 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/

Jonathan H. Bartley, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52

Enclosure:

05000413/2011008, 05000414/2011008 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-413, 50-414, 72-45 License Nos.: NPF-35, NPF-52 Report Nos.: 05000413/2011008, 05000414/2011008 Licensee: Duke Energy Carolinas, LLC Facility: Catawba Nuclear Station, Units 1 and 2 Location: York, SC 29745 Dates: March 23, 2011, through April 29, 2011 Inspectors: A. Hutto, Senior Resident Inspector R. Cureton, Resident Inspector Approved by: Jonathan H. Bartley, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

INSPECTION RESULTS IR 05000413/2011-008, 05000414/2011-008, 03/23/2011 - 04/29/2011; Catawba Nuclear Station, Units 1 and 2; Temporary Instruction 2515/183 - Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event This report covers an announced Temporary Instruction (TI) inspection conducted by the resident inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

INSPECTION SCOPE The intent of the TI is to provide a broad overview of the industrys preparedness for events that may exceed the current design basis for a plant. The focus of the TI was on (1) assessing the licensees capability to mitigate consequences from large fires or explosions on site, (2)

assessing the licensees capability to mitigate station blackout (SBO) conditions, (3) assessing the licensees capability to mitigate internal and external flooding events accounted for by the stations design, and (4) assessing the thoroughness of the licensees walk downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments 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 NRCs 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.

Enclosure

03.01 Assess the licensees 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 (SAMGs) 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.

The licensee tested the Hale pump and turbine driven auxiliary feed water (TDAFW) pump a. Verify through test or inspection room portable sump pump for proper operation using the applicable operating procedure.

that equipment is available and All staged passive equipment, supplies and response gear in warehouses, and the functional. Active equipment extensive damage mitigation (EDM) trailer were inventoried and inspected.

shall be tested and passive Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, equipment shall be walked down reviewed test results, discussed actions, reviewed records, etc.).

and inspected. It is not expected that permanently The inspectors reviewed completed operating procedures used to test the Hale pump and installed equipment that is TDAFW room portable sump pump to verify operational readiness of the system. The tested under an existing inspectors also walked down passive response equipment listed above and inventoried regulatory testing program be equipment to verify that the equipment was present, accurately labeled, and secured to retested. prevent inadvertent use for non B.5.b. activities.

Discuss general results including corrective actions by licensee.

This review should be done for a reasonable sample of mitigating All equipment was operational and accounted for with no issues noted.

strategies/equipment.

Describe the licensees actions to verify that procedures are in place and can be executed Licensee Action (e.g. walkdowns, demonstrations, tests, etc.)

The licensee performed walkdowns of the applicable abnormal, response, and operating b. Verify through walkdowns or procedures, EDM guidelines and Severe Accident Mitigation Guidelines (SAMGs) to demonstration that procedures validate that they could be successfully implemented. Portions of the operating procedures to implement the strategies for operation of the Hale pump and the TDAFW room portable sump pump were performed associated with B.5.b and 10 to verify equipment functionality.

CFR 50.54(hh) are in place and Enclosure

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.

Describe inspector actions and the sample strategies reviewed. Assess whether procedures were in place and could be used as intended.

The inspectors reviewed a sample of the above procedures to independently verify procedures were in place and current to allow execution of the B.5.b. and SAMG strategies.

The inspectors conducted walkdowns to verify that equipment specified was appropriate and that interconnecting plant equipment was accessible and accurately labeled. The inspectors also walked down placement positions for spent fuel cooling equipment to ensure that the areas were unobstructed and accurately marked.

Discuss general results including corrective actions by licensee.

The procedures reviewed were determined to be executable and the equipment specified was appropriate. The inspectors identified an inconsistency related to placement of spray nozzles during implementation of spent fuel pool strategies. The EDM Strategy Diagrams specified placement of the nozzles which differed from AP/1/A/5500/041, Loss of Spent Fuel Cooling or Level. The licensee entered this issue into their corrective action program (CAP).

Enclosure

Describe the licensees actions and conclusions regarding training and qualifications of Licensee Action operators and support staff.

The licensee identified all training specified for B.5.b. response and SAMG implementation c. Verify the training and for operations, fire brigade, security, maintenance, and emergency response organization qualifications of operators and personnel. The licensee verified that qualifications were current, and sufficient numbers of the support staff needed to personnel in the above disciplines were qualified to effectively respond and implement the implement the procedures and mitigation strategies.

work instructions are current for activities related to Security Describe inspector actions and the sample strategies reviewed to assess training and Order Section B.5.b and severe qualifications of operators and support staff accident management The inspectors reviewed selected training documents and lesson plans to verify that the guidelines as required by 10 training was appropriate and to the sufficient level of detail to ensure effective CFR 50.54 (hh). implementation of the B.5.b. and SAMG strategies. The inspectors also reviewed qualification records to independently verify the number of qualified individuals identified in each organization.

Discuss general results including corrective actions by licensee.

No issues were identified or corrective actions taken with respect to B.5.b. and SAMG training.

Describe the licensees actions and conclusions regarding applicable agreements and Licensee Action contracts are in place.

Memorandums of Understanding (MOUs) had been established with various off-site d. Verify that any applicable agencies and organizations to provide fire fighting, emergency response and radiological agreements and contracts are in response support. The licensee verified that written agreement letters were current and place and are capable of verified through telephone discussions each organizations ability to provide the support meeting the conditions needed specified in the MOUs.

to mitigate the consequences of For a sample of mitigating strategies involving contracts or agreements with offsite entities, these events. 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).

Enclosure

This review should be done for a The inspectors independently reviewed MOUs established for Bethel Volunteer Fire reasonable sample of mitigating Department, York County Emergency Management, the Department of Energy (DOE), and strategies/equipment. the National Nuclear Security Administration to verify that the agreements were in place and current and were adequate for meeting the licensees mitigation strategy.

Discuss general results including corrective actions by licensee.

The MOUs for Bethel Volunteer Fire Department and the York Emergency Management were renewed and effective in January 2011 and February 2011 respectively with no changes necessary. The MOU with the National Nuclear Security Administration was renewed March 2011 and the MOU with DOE was last issued September 2009. The licensee contacted the DOE Radiation Emergency Assistance Center/Training Site to verify that the agreement was still in place and that personnel were available to provide support.

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.

There were no issues identified by the licensee that had the significant potential to prevent e. Review any open corrective the success of the existing mitigation strategies.

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.

Enclosure

03.02 Assess the licensees 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 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 re-inspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Describe the licensees actions to verify the adequacy of equipment needed to mitigate an Licensee Action SBO event.

The licensee verified that all equipment required to handle a SBO event was permanently a. Verify through walkdowns and installed plant equipment, which was regularly inspected and tested. The inspected inspection that all required equipment included all components in the standby shutdown facility (SSF), plant motor materials are adequate and control centers which can be powered by the SSF diesel and the transfer bunkers in the properly staged, tested, and plant switchgear rooms. The licensee also reviewed the Work Management System to maintained. verify there were no outstanding functional deficiencies.

Describe inspector actions to verify equipment is available and useable.

The inspectors performed independent walkdowns of the SSF and the switchgear rooms to verify that the material condition was adequate to ensure function of the equipment. The inspectors also observed a performance test of the SSF diesel following preventative maintenance and performance testing of the Unit 2 SSF turbine building sump pump.

Discuss general results including corrective actions by licensee.

No issues were identified or corrective actions taken with respect to the adequacy of equipment needed to mitigate an SBO event.

Licensee Action Describe the licensees actions to verify the capability to mitigate an SBO event.

The licensee reviewed procedures for SBO response by completing walkdowns and b. Demonstrate through tabletop reviews and document reviews to ensure the procedures were effective. The walkdowns that procedures for procedures reviewed included abnormal and emergency procedures for loss of AC power, response to an SBO are the abnormal procedure for main generator and grid disturbances, and procedures for SSF executable. operation.

Enclosure

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

The inspectors independently reviewed a sample of the above SBO procedures to verify they were in place, current, and executable. The inspectors also reviewed the training job performance measure for placing the SSF diesel in operation due to the time critical aspects of the action.

Discuss general results including corrective actions by licensee.

There were no issues identified by the licensee that had the potential to have a significant impact on the mitigation of an SBO event.

03.03 Assess the licensees 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. 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 licensees actions to verify the capability to mitigate existing design basis Licensee Action flooding events.

The licensee identified all design features credited for mitigation of internal and external a. Verify through walkdowns and flood events which included active plant equipment, portable equipment not credited but inspection that all required available for flood mitigation, and passive features which included doors, barriers, berms, materials are adequate and penetration seals, yard drains, and sealed trench covers. All accessible passive features properly staged, tested, and subject to aging management failure modes were walked down and portable equipment maintained. was tested. Active equipment that was routinely tested and inspected under existing Preventive Maintenances (PMs) was not included in the walkdowns.

Enclosure

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 a review of the licensees walkdown activities and the flood licensing and design basis documents to verify that flood design features were adequate to protect the plant from external and internal flooding. The inspectors independently walked down selected passive design features to verify licensee observations, reviewed selected flood mitigation procedures to verify they were executable, and observed testing of the Unit 2 SSF turbine building sump pump performance test.

Discuss general results including corrective actions by licensee.

The licensees flood mitigation design features were verified to be present, periodically inspected and tested, and in acceptable condition. All design features such as berms, seals, barriers and yard drains were generally in good condition; however some exceptions were noted and entered into the licensees CAP.

  • Foam penetration seals in the auxiliary feedwater pump rooms and the diesel room roofs were not coated with sealant per the licensees design specification. The licensee wrote Work Orders to apply sealant to the foam.
  • The auxiliary feedwater room penetration seals were not included in the licensees internal flooding design basis document and were inspected as part of the existing seal inspection PM. Additional inspection PMs were created for inspection of conduit manhole flood seals and the diesel generator roof hatch covers.
  • The licensee noted that two limited areas of the cooling tower yard berms designed to direct precipitation runoff away from the power block were degraded and required repair.

Additionally, two jersey barriers were identified near the low pressure service water intake structure that could potentially affect runoff and were removed. The inspectors noted several cooling tower yard catch basins were partially blocked by rocks, silt and vegetation growth. Additional minor issues were identified relating to degraded trench cover sealant and flood barrier/door labeling.

Enclosure

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees 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 licensees walkdowns and inspections.

Describe the licensees actions to assess the potential impact of seismic events on the Licensee Action availability of equipment used in fire and flooding mitigation strategies.

The licensee performed walkdowns of both permanent (installed) and portable fire and flood a. Verify through walkdowns that mitigation features. As part of the assessment, the licensee identified where additional all required materials are mitigation strategies may be developed to address seismic vulnerabilities.

adequate and properly 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 inspectors reviewed the list of fire and flood mitigation equipment and features included in the licensees assessment to verify the scope of the assessment was comprehensive and the reviews sufficiently thorough. The inspectors selected a sample of the licensees equipment and performed independent walkdowns to verify the licensees conclusions. The inspectors determined that the procedures were in place and could be used as intended.

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

In general, the licensee identified a generic fire mitigation equipment issue as the majority of equipment was not seismically qualified for the design basis earthquake (DBE). Examples included interior and exterior fire protection systems. Portions of these systems were housed in non-seismic structures including the three motor driven fire pumps. The diesel generator CO2 systems were non-seismic which were also housed in a non-seismic structure. The Hale pump, pump structure, and permanently staged suction and discharge piping were not seismically qualified. B.5.b. and fire brigade turnout gear in various locations were located in non-seismic storage locations and containers. Additional specific Enclosure

issues were identified and corrected. Additional mitigation strategies to address the generic fire mitigation issue were to be determined by the licensee in accordance with industry guidance.

Similarly, the licensee identified a generic flood mitigation equipment/feature issue as the majority of equipment and passive features were not seismically qualified for the DBE.

External flood mitigation features including the yard drainage system catch basins, sheet outfall areas, external flood doors and seals were non seismic; however, the bounding flood scenario was the probable maximum precipitation event and was independent of a seismic event. Water height from external flooding does not reach yard elevation. Internal flooding issues identified included various instrumentation relied on to detect internal flood were non-seismically qualified, the service building and turbine building flood walls were located in non-seismic structures, and the auxiliary feedwater pump room floor drain sump pumps and the SSF submersible pumps were non-seismic.

Enclosure

Meetings (including Exit Meeting)

Exit Meeting On May 10, 2011, the inspectors presented the inspection results to Mr. Jim Morris, Catawba Vice President, and other members of licensee management. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

Enclosure

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel T. Arlow, Emergency Planning Manager W. Byers, Security Manager J. Caldwell, Work Control Manager D. Cantrell, Chemistry Manager J. Ferguson, Mechanical, Civil Engineering Manager T. Hamilton, Engineering Manager G. Hamrick, Station Manager R. Hart, Regulatory Compliance Manager T. Jenkins, Superintendent of Maintenance J. Morris, Catawba Site Vice President K. Phillips, Training Manager S. Putnam, Safety Assurance Manager M. Sawicki, Regulatory Compliance Engineer R. Simril, Operations Superintendent J. Smith, Radiation Protection Manager W. Suslick, Modifications Engineering Manager LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events Number Description or Title Date or Revision CNS Extensive Damage Mitigation Guidelines Rev. 04 PT/0/A/4400/002F EDM Equipment Inspection Rev. 02 OP/0/B/6400/002D Hale Portable Pump Operation Rev. 02 OP/0/B/6400/002E Portable CAPT Sump Pump Operation Rev. 02 PT/0/B/4600/032 Fire Brigade Equipment Inspection/Inventory Rev. 07 AP/1(2)/A/5500/025 Damaged Spent Fuel Rev. 16 AP/1/(2)/A/5500-041 Loss of Spent Fuel Cooling or Level Rev. 04 Attachment

AP/0/A/5500/046 Hostile Aircraft Activity Rev. 03 AP/0/A/5500/048 Extensive Damage Mitigation Rev. 06 EM/0/A/5200/001 Troubleshooting Cause for Improper Operation of Rev. 04 VC/YC System IP/1(2)/A/5200/003 Troubleshooting Cause for a Diesel Generator Failing Rev. 03 to Start EM/1/A/5200/003 Fire Damage Control Procedure Rev. 19,20 OP/0/B/6100/013 Standby Shutdown Facility Rev. 50 RP/0/A/5000/007 Natural Disaster and Earthquake Rev. 031 CN-OPS-N0171 Location of B.5.b Equipment (NLO ETQS qualification) Rev. 01 OP-CN-CP-EDM PRAC Extensive Damage Mitigation Guidelines Practical Rev. 00 Exercise (lesson plan)

IN TOUCH Extensive Damage Mitigation Support Team 3/30/2010 Expectations - site refresher OP/CN-CP-EDM Extensive Damage Mitigation Lesson Plan Rev. 4 CN-EP-EA49-N Revised Design Basis Threat Response (B.5.b.) Rev. 01 1465.00-00-0019 DBD for Extensive Damage Mitigation Rev. 00 EG/0/A/CSAM/SAG3 Inject into the NC System Rev. 02 EG/0/A/CSAM/SAG4 Inject into Containment Rev. 02 EG/0/A/CSAM/SAG6 Control Containment Conditions Rev. 02 EG/0/A/CSAM/SAG7 Reduce Containment Hydrogen Rev. 02 EG/1/A/CSAM/SACRG1 Severe Accident Control Room Guideline - Initial Rev. 05 Response EG/1/A/CSAM/SACRG2 Severe Accident Control Room Guideline for Rev. 02 Transients after TSC on Functional Emergency Plan Support agreements in-place with local fire 2009-2011 Appendix 5 departments, local law enforcement and offsite support agencies: Bethel Volunteer Fire Department, York County Emergency Management, Department of Energy, National Nuclear Security Administration PIP C-11-2223 Missing connection point in drawing, CNEE-0131-06.05 PIP C-11-2230 Label discrepancy in drawing, CNEE-0131-06.06 PIP C-11-2232 Drawing nomenclature discrepancy in CNLT-1752-01.07 PIP C-11-2240 Procedure enhancements to fire damage control procedures PIP C-11-2251 Enhancements to Severe Action Mitigation Strategy and Resource Manual PIP C-11-2352 Evaluate the need to procure a second Hale pump and portable sump pump PIP C-11-3346 Inconsistent guidance on spent fuel pool emergency cooling nozzle placement Attachment

03.02 Assess the licensees capability to mitigate station blackout (SBO) conditions Number Description or Title Date or Revision EP/1(2)/A/5000/ECA Loss of All AC Power Rev. 39 0.0 AP/1(2)/A/5500/007 Loss of Normal Power Rev. 61 AP/1(2)/A/5500/037 Main Generator and Grid Disturbances Rev. 0 OP/0/B/6100/013 Standby Shutdown Facility Operations Rev. 50 OP/1/A//6100/020 Operational Guidelines for Achieving Cold Shutdown Rev. 30 Following a Fire in the Plant OP/1/A/6100/004 Shutdown Outside the Control Room from Hot Standby to Rev. 53 Cold Shutdown EM/1/A/5200/004 Install Jumper to Auto Start Diesel Generator 1A or 1B Rev. 04 1465.00-00-0018 DBD for the Station Blackout Rule Rev. 04 OP-CN-CP-AD-003 Job Performance Measure/Place SSF Diesel in Operation Rev. 23 CNEE-0120-01.01 Elementary Diagram Diesel Engine Control Panel 1A & Rev. 11 1B (Typical Part 1) Engine Panel Electrical Schematic 03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design Number Description or Title Date or Revision AP/0/A/5500/030 Plant Flooding Rev. 10 PT/0/A/4450/018 RC Submersible Pump Test Rev. 08 1465.00-00-0011 DBD for the Flooding from External Sources Rev. 03 1465.00-00-0020 DBD for the Flooding from Internal Sources Rev. 00 CN-1022-9 Grading Sections and Details, Sheet 3 Rev. 05 CN-1220-51 Diesel Generator Area Units 1 & 2 Rev. 09 CN-1493-ZD.00- Diesel Generator Engine Crankcase Vacuum System Rev. 01 007 03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events Number Description or Title Date or Revision 1465.00-00-0011 DBD for the Flooding from External Sources Rev. 03 1465.00-00-0020 DBD for the Flooding from Internal Sources Rev. 00 1465.00-00-0019 DBD for Extensive Damage Mitigation Rev. 00 1465.00-00-0006 DBD for Plant Fire Protection Rev. 19 Attachment

LIST OF ACRONYMS USED ADAMS Agencywide Documents Access and Management System CAP Corrective Action Program CFR Code of Federal Regulations DBE Design Basis Earthquake DOE Department of Energy EDM Extensive Damage Mitigation MOU Memorandum of Understanding NRC United States Nuclear Regulatory Commission PIP Problem Investigation Program PM Preventive Maintenance SAMG Severe Accident Mitigation Guidelines SBO Station Blackout SSF Standby Shutdown Facility TDAFW turbine driven auxiliary feed water TI Temporary Instruction Attachment