ML040090242

E-mail from C. Payne Regarding St. Lucie Tfpi Report

ML040090242
Person / Time
Site:	Saint Lucie
Issue date:	05/07/2003
From:	Payne D NRC/RGN-II
To:	Joel Munday NRC/RGN-II
References
FOIA/PA-2003-0358 IR-03-002
Download: ML040090242 (37)

Text

I Charlie Payne - St. Lucie TFPI Report Page From:

Charlie Payne1 ei To:

Joel Munday Date:

5/7/03 4:22PM

Subject:

St. Lucie TFPI Report Latest version attached.

Thanks...

Charlie Payne Team Leader, Fire Protection EB1, DRS, Region II, USNRC dcp@nrc.gov

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Charlie Payne - STLO302-TFPI-report Revl.wpd Page May xx, 2003 Florida Power and Light Company ATTN:

Mr. J. A. Stall, Senior Vice President Nuclear and Chief Nuclear Officer P. 0. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

ST. LUCIE NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 50-335/03-02 AND 50-389/03-02

Dear Mr. Stall:

On March 28, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed an Inspection at your St. Lucie Nuclear Plant, Units I and 2. The enclosed inspection report documents the inspection findings, which were discussed on March 28, 2003, with Mr. D. Jernigan and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two findings that, combined, have potential safety significance greater than very low significance, however, a safety significance determination has not been completed. These findings did not present an Immediate safety concern.

In addition, the report documents one NRC-identified finding of very low safety significance (Green), which was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because It was entered Into your corrective action program, the NRC is treating this as a non-cited violation (NCV) consistent with Section VLA 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 II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at St. Lucie Nuclear Plant.

( iCharlie Payne - STL0302-TFPI-report Revlw~pd Paac A,

FP&L In accordance with 10 CFR 2.790 of the NRC's Rules of Practice," a copy of this letter and 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 (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

ICharlie Pavne - STL0302-TFPI-report Rev1.wpd Pag I Charlie Payne - STLO3O2-TFPI-report Revi.wpd tag FP&L 3

http://www.nrc.gov/reading-rmIadams.html (the Public Electronic Reading Room).

Sincerely, Charles R. Ogle, Chief Engineering Branch I Division of Reactor Safety Docket Nos.: 50-335, 50-389 License Nos.: DPR-67, NPF-16

Enclosure:

Inspection Report 50-335, 389/03-02 w/

Attachment:

Supplemental Information cc w/encl: (See page 3)

l Charlie Payne - STL0302-TFPI-report Revl.wpd Page I Charlie Payne - STL0302-TFPI-report Revl.wpd Paa FP&L cc:

Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, Florida 34957 Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 M. S. Ross, Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Douglas Anderson County Administrator St. Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. Donald E. Jemigan, Site Vice President St. Lucie Nuclear Plant 6501 South Ocean Drive Jensen Beach, Florida 34957 Mr. R. E. Rose Plant General Manager St. Lucie Nuclear Plant 6501 South Ocean Drive Jensen Beach, Florida 34957 Mr. G. Madden Licensing Manager St. Lucie Nuclear Plant 6501 South Ocean Drive Jensen Beach, Florida 34957

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Mr. Don Mothena Manager, Nuclear Plant Support Services Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. J. Kammel Radiological Emergency Planning Administrator Department of Public Safety 6000 SE. Tower Drive Stuart, Florida 34997 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Mr. Steve Hale St. Lucie Nuclear Plant Florida Power and Light Company 6351 South Ocean Drive Jensen Beach, Florida 34957-2000 Mr. Alan P. Nelson Nuclear Energy Institute 1776 I Street, N.W., Suite 400 Washington, DC 20006-3708 APN@NEI.ORG David Lewis Shaw Pittman, LLP 2300 N Street, N.W.

Washington, D.C. 20037 Mr. Stan Smilan 5866 Bay Hill Cir.

Lake Worth, FL 33463

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-I Charlie Payne - STL0302-TFPI-report Revi.wpd Paq 6

U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket Nos.:

License Nos.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

50-335, 50-389 DPR-67, NPF-16 50-335/03-02 and 50-389/03-02 Florida Power and Light Company (FPL)

St. Lucie Nuclear Plint 6351 South Ocean Drive Jensen Beach, FL 34957 March 10 - 14, 2003 (Week 1)

March 24 - 28, 2003 (Week 2)

R. Deem, Consultant, Brookhaven National Laboratory P. Fillion, Reactor Inspector F. Jape, Senior Project Inspector M. Thomas, Senior Reactor Inspector (Lead Inspector)

S. Walker, Reactor Inspector G. Wiseman, Senior Reactor Inspector Charles R. Ogle, Chief Engineering Branch I Division of Reactor Safety

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SUMMARY

OF FINDINGS IR 05000335/2003-002, 05000389/2003-002; Florida Power and Light Company; 3/10-28/2003; St. Lucie Nuclear Plant, Units 1 and 2; Triennial Fire Protection The report covered a two-week period of inspection by regional inspectors and a consultant.

Three Green non-cited violations (NCVs) and one unresolved item with potential safety significance greater than Green 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, 'Reactor Oversight Process,' Revision 3, dated July 2000.

A.

NRC-Identified and Self-Revealing Findings Cornerstone: Initiating Events and Mitigating Systems TBD. Physical and procedural protection of equipment relied on for safe shutdown (SSD) during a fire in the Unit 2 Train B Switchgear Room (Fire Area C), was inadequate. The fire hazards analysis failed to consider and evaluate the combustibility of 380 gallons of transformer silicone dielectric Insulating fluid in each of six transformers installed in three Unit 2 fire areas (three of the six transformers were in the Train B Switchgear Room) as contributors to fire loading and effects on SSD capability, as required by Fire Protection Program commitments.

A violation of 10 CFR 50.48 and the St. Lucie Nuclear Plant Unit 2 Operating License Condition 2.C.(20), Fire Protection, was identified. This finding is unresolved pending completion of a significance determination. The finding is greater than minor because It affected the objective of the initiating events cornerstone to limit the likelihood of those events that could upset plant stability v

~and challenge critical safety functions relied upon for SSD during a fire. The six previously unidentified silicone oil-filled transformers represented an increase in the ignition frequency of the associated fire areas/zones. Also, when assessed with other findings identified in this report, the significance could be greater than very low significance. (Section 1R05.02.b(1))

TBD. Physical and procedural protection of equipment relied on for safe shutdown (SSD) during a fire in the Unit 2 Train B Switchgear Room (Fire Area C), was inadequate. Train A 480 volt vital load center 2A5 and associated electrical cables were located in the Train B Switchgear Room without adequate spatial separation or fire barriers. This load center powered redundant equipment (via motor control center 2A6 which powered boric acid makeup pumps 2A and 2B) required for SSD in the event of a fire. In lieu of providing adequate physical protection for load center 2A5 and associated electrical cables, manual operator actions outside the main control room (MCR) were used, without prior NRC approval, for achieving and maintaining SSD.

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A violation of 10 CFR 50, Appendix R, Section III.G.2, was identified for failure to ensure that one train of equipment necessary to achieve and maintain safe shutdown would be free of fire damage. This finding is unresolved pending completion of a significance determination. The finding was greater than minor because fire damage to the unprotected cables could prevent operation of SSD equipment from the MCR and challenge the operators' ability to maintain adequate reactor coolant system inventory and reactor coolant pump seal flow during a fire in the B switchgear room. (Section 1 R05.02.b(2))

Cornerstone: Mitigating Systems Green. A non-cited violation of 10 CFR 50, Appendix R, Section III.G.2 was identified concerning a lack of spacial separation or barriers to protect cables against fire damage in containment could result in spurious opening of the pressurizer power operated relief valve (PORV).

This finding is greater than minor because it affected the mitigating systems cornerstone objective of equipment reliability, in that, spurious opening of the PORV during post-fire safe shutdown would adversely affect systems intended to maintain hot shutdown. The finding is of very low safety significance because the initiating event likelihood was low, manual fire suppression capability remained unaffected and all mitigating systems except for the PORV and block valve were unaffected. (Section 40A5)

B.

Licensee-identified Violations Two violations of very low safety significance, which were identified by the licensee, were reviewed by the inspection team. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and corrective action tracking numbers are listed in Section 40A7 of this report.

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REPORT DETAILS

1.

REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems and Barrier Integrity 1 R05 FIRE PROTECTION

01.

Systems Reguired to Achieve and Maintain Post-Fire Safe Shutdown

a.

InsDection Scope The team evaluated the licensee's fire protection program against applicable requirements, including Operating License Condition (OLC) 2.C.20, Fire Protection; Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix R; 10 CFR 50.48; Appendix A to Branch Technical Position (BTP) Auxiliary Systems Branch (ASB) 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants; related NRC Safety Evaluation Reports (SERs); the Plant St. Lucie (PSL) Updated Final Safety Analysis Report (UFSAR); and plant Technical Specifications (TS). The team evaluated all areas of this inspection, as documented below, against these requirements. The team reviewed the licensee's Individual Plant Examination for External Events (IPEEE) and performed in-plant walk downs to choose three risk-significant fire areas for detailed inspection and review. The three fire areas selected were:

Unit 2 Fire Area B, Cable Spreading Room (Fire Zone 52)

Unit 2 Fire Area C, Train B Switchgear Room (Fire Zone 34) and Electrical Equipment Supply Fan Room (Fire Zone 48)

Unit 2 Fire Area I, Cable Loft (Fire Zone 51 West), Personnel Rooms (Fire Zone 21),

PASS and Radiation Monitoring Room (Fire Zone 32), Instrument Repair Shop (Fire Zone 331), and Train B Electrical Penetration Room (Fire Zone 23)

The team reviewed the licensee's fire protection program (FPP) documented in the PSL UFSAR (Appendix 9.5A, Fire Protection Program Report); safe shutdown analysis (SSA); fire hazards analysis (FHA); safe shutdown (SSD) essential equipment list; and system flow diagrams to identify the components and systems necessary to achieve and maintain safe shutdown conditions. The objective of this evaluation was to assure the SSD equipment and post-fire SSD analytical approach were consistent with and satisfied the Appendix R reactor performance criteria for SSD. For each of the selected fire areas, the team focused on the fire protection features, and on the systems and equipment necessary for the licensee to achieve and maintain SSD in the event of a fire in those fire areas. Systems and/or components selected for review included:

pressurizer power operated relief valves (PORVs); boric acid makeup pumps 2A and 2B; boric acid gravity feed valves V2508 and V2509; auxiliary feedwater (AFW);

charging pumps and volume control tank (VCT) outlet valve V2501; shutdown cooling; heating, ventilation, and air conditioning (HVAC); atmospheric dump valves (ADVs); and component cooling water (CCW). The team also reviewed the licensee's maintenance

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Charlie Payne - STL0302-TFPI-report Revi.wpd Pane 10 program to determine if a sample of manual valves used to achieve SSD were included.

b.

Findings No findings of significance were identified.

.02 Fire Protection of Safe Shutdown CaDability

a.

Inspection Scone For the selected fire areas, the team evaluated the frequency of fires or the potential for fires, the combustible fire load characteristics and potential fire severity, the separation of systems necessary to achieve SSD, and the separation of electrical components and circuits located within the same fire area to ensure that at least one train of redundant SSD systems was free of fire damage. The team also inspected the fire protection features to confirm they were Installed In accordance with the codes of record to satisfy the applicable separation and design requirements of 10 CFR 50, Appendix R, Section III.G, and Appendix A of BTP ASB 9.5-1. The team reviewed the following documents, which established the controls and practices to prevent fires and to control combustible fire loads and ignition sources, to verify that the objectives established by the NRC-approved FPP were satisfied:

UFSAR, Appendix 9.5A, Fire Protection Program Report PSL Individual Plant Examination of External Events (IPEEE)

Administrative Procedure 1800022, Fire Protection Plan Administrative Procedure 0010434, Plant Fire Protection Guidelines Electrical Maintenance Procedure 52.01, Periodic Maintenance of 4160 Volt Switchgear The team toured the selected plant fire areas to observe whether the licensee had properly evaluated in-situ compartment fire loads and limited transient fire hazards In a manner consistent with the fire prevention and combustible hazards control procedures.

In addition, the team reviewed fire protection inspection reports, corrective action program condition reports (CRs) resulting from fire, smoke, sparks, arcing, and overheating incidents for the years 2001-2002 to assess the effectiveness of the fire prevention program, and to identify any maintenance or material condition problems related to fire incidents.

The team reviewed the fire brigade response, training, and drill program procedures.

The team reviewed fire brigade initial and continuing training course materials to verify that appropriate training was being conducted. In addition, the team evaluated fire brigade drill training records for the operating shifts from August 2001 - February 2003.

The reviews were performed to determine whether fire brigade drills had been conducted In high fire risk plant areas and whether fire brigade personnel qualifications, drill response, and performance met the requirements of the licensee's FPP.

Cnarlie Pyne - STL0302-TFPI-report Revl.wpd Page I Charlie Payne - STLO3O2-TFPI-report Revl.wpd Page 11 The team walked down the fire brigade staging and dress-out areas in the turbine building and fire brigade house to assess the condition of fire fighting and smoke control equipment. The team examined the fire brigade's personal protective equipment, self-contained breathing apparatuses (SCBAs), portable communications equipment, and various other fire brigade equipment to determine accessibility, material condition and operational readiness of equipment. Also, the availability of supplemental fire brigade SCBA breathing air tanks, and the capability for refill, was evaluated. In addition, the team examined personnel evacuation pathways to verify that emergency exit lighting was provided to the outside in accordance with the National Fire Protection Association (NFPA) 101, Life Safety Code, and the Occupational Safety and Health Administration (OSHA) Part 1910, Occupational Safety and Health Standards. This review included an examination of backup emergency lighting units along pathways to, and within, the dress-out and staging areas in support of fire brigade operations during a fire-induced power failure.

Team members walked down the selected fire areas to compare the associated fire fighting pre-fire strategies and drawings with as-built plant conditions. This was done to verify that fire fighting pre-fire strategies and drawings were consistent with the fire protection features and potential fire conditions described in the UFSAR Fire Protection Program Report. Also, the team performed a review of drawings and engineering calculations for fire suppression-caused flooding associated with the floor and equipment drain systems for the train B switchgear room, the electrical equipment supply fan room, and the train B electrical penetration room. The review focused on ensuring that those actions required for SSD would not be inhibited by fire suppression activities or leakage from fire suppression systems.

The team reviewed design control procedures to verify that plant changes were adequately reviewed for the potential impact on the fire protection program, SSD equipment, and procedures as required by PSL Unit 2 Operating License Condition 2.C(20). Additionally, the team performed an independent technical review of the licensee's plant change documentation completed in support of 2002 temporary system alteration (TSA) 2-02-006-3, which placed two exhaust fans in a fire damper opening between the cable spreading room and the train B switchgear room. This TSA was evaluated in order to verify that modifications to the plant were performed consistent with plant design control procedures.

b.

Findings Fire Area C - Unit 2 Train B Switchaear Room

==

Introduction:==

A finding was identified concerning failure to meet the FPP requirements.

The technical analysis for and physical protection of equipment relied upon for SSD during a fire in the Train B Switchgear Room were inadequate. The team Identified silicone oil-filled transformers installed In the fire area were not evaluated in the FHA as contributors to fire loading, and their effects on SSD capability. Additionally, in lieu of providing adequate physical protection for SSD equipment and associated electrical

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-TOO-FIrpr RelwdPg 12 cables, the licensee used local manual operator actions, without prior NRC approval, for achieving and maintaining SSD.

-(1)--lInadeuate'Fire Hazards Analvsis

==

Description:==

During a pre-inspection plant walk down on February 26, 2003, the team found six oil-filled transformers installed in three Unit 2 fire areas/fire zones (one in Fire Area A/Fire Zone 37, Train A Switchgear Room; three in Fire Area C/Fire Zone 34, Train B Switchgear Room; and two in Fire Area QQ/Fire Zone 47, Turbine Building Switchgear Room) which were not evaluated in the FHA as contributors to fire loading, and their effects on SSD capability, as required by the FPP. The six Unit 2 indoor medium-voltage power transformers were cooled and insulated by a silicone-type fluid.

The licensee provided the team with information from the transformer vendor which indicated that the transformer insulating fluid was Dow Coming (DC) 561, a dimethyl silicone insulating fluid. The team performed an independent technical review of the licensee's engineering calculations and maintenance documentation, transformer vendor technical Information manual, insulating fluid manufacturer information, Underwriters Laboratory (UL) and Factory Mutual (FM) listing agencies' documentation, and Institute of Electrical and Electronics Engineers (IEEE) Standards.

The DC 561 technical manual described the DC 561 fluid as a silicone liquid that would burn, but was less flammable than paraffin-type insulating oils. The technical manual also stated that the DC 561 fluid had a flash point of 324 C, a total heat release rate (HRR) of 140 kw/m2 (per ASTM E 1354-90), and a fire point of 357 C. In their FHA, the licensee evaluated the adequacy of their fire areas/zones and electrical raceway fire barrier system (ERFBS) enclosures based on the combustible hazard content and overall fire loading (analyzed fire duration) present within the associated areas/zones.

Based on the FHA information, the team determined that the transformer Insulating fluid was an in-situ combustible liquid that had not been accounted for nor evaluated in the PSL FHA. Additionally, the team noted that the licensee had conducted an UFSAR Combustible Loading Update evaluation In 1997. This evaluation, documented In PSL-ENG-SEMS-97-070, failed to identify that the transformers in Fire Zone 37 contained combustible silicone Insulating fluid. Also, a PSL triennial fire protection audit conducted in 2001 (documented in QA Audit Report QSL-FP-01-07), reviewed the FHA but did not identify any fire loading discrepancies.

The team determined that the six, previously unidentified, silicone oil-filled transformers represented an increase in the ignition frequency of the associated fire areas/zones.

Also, the additional in-situ combustible fire load and fire severity represented by the combustible transformer insulating fluid increased the likelihood of a sustained fire event from a catastrophic failure of an affected transformer that may upset plant stability and challenge critical safety functions during SSD operations.

The -T-E Unit Substation Transformers Instruction Manual recommended that the dielectric insulating fluid be sampled annually and the dielectric strength of the fluid be tested to ensure that It was at 26 KV or better. The licensee determined that, except for four tests conducted during the period 1990-1992, there were no records of the

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[Charlie Payne - STLO3O2-TFPI-report Revi.wpd Paae 13 transformers' fluid being sampled and tested. This issue regarding failure to sample the transformer fluid in accordance with the vendor manual was entered into the corrective action program as CR 03-0978.

Analysis: The team determined that this finding was associated with the "protection against external factors" attribute and affected the objective of the initiating events cornerstone to limit the likelihood of those events that could upset plant stability and challenge critical safety functions relied upon for SSD from a fire, and was, therefore, greater than minor. The six, previously unidentified, silicone oil-filled transformers In Unit 2 represented an increase in the ignition frequency of the associated fire areas/zones. This finding was unresolved pending completion of a significance determination. However, when assessed in combination with other findings Identified in this report, the significance could be greater than very low significance.

Enforcement: 10 CFR 50.48 states, in part, that each operating nuclear power plant must have a fire protection program that satisfies Criterion 3 of ID CFR 50, Appendix A.

PSL Unit 2 Operating License NPF-16, Condition 2.C.(20) states, in part, that the licensee shall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR, and supplemented by licensee submittals dated July 14, 1982, February 25, 1983, July 22, 1983, December 27, 1983, November 28, 1984, December 31, 1984, and February 21, 1985 for the facility; and as approved In the NRC Safety Evaluation Report Supplement 3 dated April 1983, and supplemented by NRC letter dated December 5, 1986. The approved FPP is maintained and documented in the PSL UFSAR, Appendix 9.5A, Fire Protection Program Report.

The Fire Protection Program Report stated, in part, that the PSL fire protection program implemented the philosophy of defense-in-depth protection against fire hazards and effects of fire on SSD equipment. The PSL fire protection program is guided by the plant FHA and by credible fire postulations. It further stated that the FHA performed for PSL Unit 2 considered potential fire hazards and their possible effect on SSD capability.

PSL administrative fire protection procedure 1800022, Section 8.3 states that the FHA is an individual study of each plant's design, potential fire hazards In the plant, potential of those threats occurring, and the effect of postulated fires on SSD capability. Further, Section 8.7.1.A of this procedure stated that in-situ combustible features were evaluated in the FHA as contributors to fire loading in the respective fire zones.

Contrary to the above, the licensee failed to meet 10 CFR 50.48 and their FPP commitments, in that, they did not adequately evaluate the combustible fire loading in the FHA for Fire Area A/Fire Zone 37, Fire Area C/Fire Zone 34, and Fire Area QQ/Fire Zone 47. Specifically, 380 gallons of in-situ combustible transformer silicone dielectric insulating fluid in each of six transformers located In Unit 2 was not considered nor evaluated in the FHA as contributors to fire loading and possible effects on SSD capability.

This finding was entered into the licensee's corrective action program as condition

I I Fharije Pavne - STLO302-TFPI-report Revl.wpd Paae I h1) an - STOO-FIrprtRv wdPn 14 report (CR) 03-0637. However, when assessed in combination with other findings identified in this report, the significance could be greater than very low significance.

This finding is unresolved item (URI) 50-389/03-02-01, Failure to Provide Adequate Protection for Redundant Safe Shutdown Equipment and Cables in the Event of a Fire in the Unit 2 Train B Switchgear Room (Fire Area C).

(2) Inadequate Protection of Equipment and Cables Required for SSD/Use of Manual Operator Actions Outside the MCR to Achieve Safe Shutdown for 10 CFR 50.

Appendix R.Section III.G.2 Areas

==

Description:==

On January 22, 2003, the licensee identified that PSL relied on manual operator actions outside the MCR for SSD in non-alternative shutdown fire areas (i.e.,

areas designated as 10 CFR 50, Appendix R, Section III.G.2) and the manual actions did not have prior NRC approval. The licensee documented this issue in CR 03-0153.

During this inspection, the team noted that the licensee used manual operator actions outside the MCR for a number of areas designated as 10 CFR 50, Appendix R, Section III.G.2 areas. The team reviewed the manual operator actions for the III.G.2 areas selected for this inspection (Fire Area C and Fire Area I). Manual operator actions relative to Fire Area C are discussed in this section of the inspection report. Manual operator actions relative to fire Area I are discussed in Section 40A7 of this inspection report.

As an example, the team found that Train A 480 volt vital load center 2A5 and associated electrical cables were located in the Train B Switchgear Room without adequate spatial separation or fire barriers. Train A load center 2A5 powered fire SSD equipment [via 480 volt motor control center (MCC) 2A6 which powered boric acid makeup (BAM) pumps 2A and 2B]. Train B MCC 2B5, which was located in the Train B Switchgear Room in Fire Area C, powered the boric acid gravity feed motor operated valves V2508 and V2509. The licensee's SSA stated that the BAM pumps and the boric acid gravity feed valves were redundant to each for SSD. The SSA further stated that manual operator actions were required for a fire in Fire Area C because the fire could affect the BAM pumps and the boric acid gravity feed valves. Therefore, in lieu of providing adequate physical protection for load center 2A5 and associated electrical cables, the licensee used manual operator actions outside the MCR, without prior NRC approval, for achieving and maintaining SSD.

Analysis: This finding was greater than minor because fire damage to the unprotected cables could prevent operation of SSD equipment from the MCR and challenge the operators' ability to maintain adequate reactor coolant system inventory and reactor coolant pump seal flow during a fire In the B Switchgear Room. This finding was unresolved pending completion of a significance determination to assess the risk associated with using manual operator actions in lieu of providing physical protection equipment and cables. However, when assessed In combination with other findings identified in this report, the significance could be greater than very low significance.

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-- 1 Charlie Payne - STLO3O2-TFPI-reDort Revi.wDd Pa,e 15 Enforcement: 10 CFR 50, Appendix R, Section Il.G.2, requires in part, that, where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:

(a) Separation of cables and equipment of redundant trains by a fire barrier having a 3-hour rating.

(b) Separation of cables and equipment of redundant trains by a horizontal distance of more than 20 feet with no Intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

(c) Enclosure of cable and equipment of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed In the fire area.

Manual operator actions to respond to maloperations are not listed as an acceptable method for satisfying this requirement.

Contrary to the above, on March 28, 2003, the team found that the licensee failed to protect equipment and related cables with an adequate fire barrier or to provide 20 feet of separation between Train A load center 2A5 and the Train B electrical equipment and cables located in the Train B Switchgear Room. As a result, redundant equipment necessary for SSD in the event of a fire in the Train B Switchgear Room would not be available (e.g., BAM pumps 2A and 2B, and boric acid gravity feed valves V2508 and V2509). Instead, the licensee used manual operator actions outside the MCR in lieu of providing adequate physical protection, without obtaining prior NRC approval.

This finding was entered into the licensee's corrective action program as CR 03-0153.

The licensee performed a SSD manual operator action time line for Fire Areas C to determine the time requirements when the SSD functions were needed, and, If personnel and procedural guidance were adequate to perform the actions. The licensee determined that the assistance of one operator from the Unit 1 operating shift staff was needed perform the actions required for Unit 2 SSD In the event of a fire in Fire Area C. The team reviewed the time line, personnel needed versus TS shift staffing requirements, and the SSD procedures. Based on this review, the team determined that potential maloperations were properly accounted for In the SSD procedures and the personnel needed to perform the manual actions (including the use of an operator from Unit 1) for Fire Area C and Fire Area I were reasonable. The team assessed the manual operator actions used for this fire area against the guidance provided In Enclosure 2 of NRC Revised Oversight Program (ROP) Procedure 71111.05, Fire Protection, dated March 6, 2003. The team determined that the manual actions were reasonable and met the criteria in Enclosure 2 of Procedure 71111.05.

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Page 16 However, when assessed In combination with other findings identified In this report, the significance could be greater than very low significance. This finding is identified as URI 50-389/03-02-01, Failure to Provide Adequate Protection for Redundant Safe Shutdown Equipment and Cables in the Event of a Fire in the Unit 2 Train B Switchgear Room (Fire Area C).

.03 Post-Fire Safe Shutdown Circuit Analysis

a.

InsDection ScoDe The team reviewed how systems would be used to achieve inventory control, reactor coolant pump seal protection, core heat removal and reactor coolant system (RCS) pressure control during and following a postulated fire in the fire areas selected for review. Portions of the licensee's Appendix R Safe Shutdown Analysis Report which outlined equipment and components in the chosen fire areas, power sources, and their respective cable functions and system flow diagrams were reviewed. Control circuit schematics were analyzed to Identify and evaluate cables important to safe shutdown.

The team traced the routing of cables through fire areas selected for review by using cable schedule, and conduit and tray drawings. The team walked down these fire areas to compare the actual plant configuration to the layout indicated on the drawings. The team evaluated the above Information to determine if the requirements for protection of control and power cables were met. The licensee's circuit breaker and fuse coordination study was reviewed for adequate electrical scheme protection of equipment necessary for safe shutdown. The following equipment and components were reviewed during the inspection:

V 1474 and V1475, Pressurizer PORVs V1476 and V1477, Pressurizer Isolation Block Valves MV-09-03 and MV-09-04, Feedwater Bypass Valves 2HVE-13B, Control Room Booster Fan V2501, Volume Control Tank Discharge Outlet Valve MV-07 -04, Containment Spray Isolation Valve LP-208, Lighting Panel 208 LP-209, Lighting Panel 209 HCV-3625, Safety Injection Block Valve V3444, Shutdown Cooling Block Valve PI-1107/1108, Pressurizer Pressure for Hot Shutdown Panel LI-1104/1105, Pressurizer Level for Hot Shutdown Panel L-9113/9123, Steam Generator Level for Hot Shutdown Panel Safety Injection Actuation System Logic 2A5/2A6 and related feeds, 480 Volt Motor Control Center 2B5/2B6 and related feeds, 480 Volt Motor Control Center Load Center 2A5 480 Volt Switchgear

b.

Findings

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.Chri

,an

,,T00 17 No findings of significance were identified.

04.

Alternative Post-Fire Safe-Shutdown Carabilit

a.

Inspection Scove The cable spreading room, which was one of two ASD fire areas listed in the PSL Unit 2 SSA, was selected for detailed inspection of post-fire SSD capability. Emphasis was placed on verification that hot and cold shutdown from outside the control room could be implemented, and that transfer of control from the MCR to the hot shutdown control panel (HSCP) and other equipment isolation locations, could be accomplished within the performance goals stated in 10 CFR 50, Appendix R, Section III.L.3. This review also included a comparison of actions in procedures with the licensee's thermal hydraulic time line analysis.

Electrical diagrams of power, control, and instrumentation cables required for ASD were analyzed for fire-induced faults that could defeat operation from the MCR or the HSCP.

The team reviewed the electrical isolation and protective fusing in the transfer circuits of components (e.g., motor operated valves) required for post-fire SSD at the HSCP to verify that the SSD components were physically and electrically separated from the fire area. The team also examined the electrical circuits for a sampling of components operable at the HSCP to ensure that a fire in the B Switchgear Room would not adversely affect SSD capability from the MCR. The team's review was performed to verify that adequate isolation capability of equipment used for SSD implementation was in place, accessible, and that the HSCP was capable of controlling all the required equipment necessary to bring the unit to a SSD.

b.

Findings No findings of significance were Identified.

05.-

Operational Implementation of Post-Fire Safe Shutdown Capability

a.

Inspection Scope The team reviewed off normal operating procedure 2-ONP-100.02, Control Room Inaccessibility, Rev. 13B, the licensee's procedure for ASD, and procedure 2-ONP-100.01, Response to Fire, Rev. 9, the licensee's off normal operating procedure for post-fire SSD from the MCR. The review focused on ensuring that all required functions for post-fire SSD and the corresponding equipment necessary to perform those functions were included in the procedures. The review also examined the consistency between the operations shutdown procedures and other procedure driven activities associated with post-fire SSD (i.e., fire fighting activities).

b.

Findings

Charlie Pavne - STL0302-TFPI-rerport Revl.wDd Paae I Chrli Payn - SL32TP-eotRv wdPc 18 No findings of significance were identified. The licensee identified that manual operator actions outside the MCR were used in lieu of physical protection of equipment and cables relied on for SSD during a fire, without obtaining prior NRC approval. Findings related to this Issue are discussed in Section 1 R05.02.b(2) of this Inspection report for Fire Area C, and Section 40A7 of this inspection report for Fire Area I.

06.

Communications

a.

InsDection Scone The team reviewed plant communication capabilities to verify that they were adequate to support unit shutdown and fire brigade duties. This included verifying that site paging (PA), portable radios, and sound-powered phone systems would be available during fire response activities and were consistent with the licensing basis. The team reviewed the licensee's communications features to assess whether they were properly evaluated In the licensee's SSA (protected from exposure fire damage) and properly integrated Into the post-fire SSD procedures. The team also walked down sections of the post-fire SSD procedures to verify that adequate communications equipment would be available to support the SSD process. The team also reviewed the periodic testing of the site fire alarm and PA systems; maintenance checklists for the sound-powered phone circuits and amplifiers; and inventory surveillance of post-fire SSD operator equipment to assess whether the maintenance/surveillance test program for the communications systems was sufficient to verify proper operation of the systems.

b.

Findings No findings of significance were Identified.

07.

Emergency Lighting

a.

lnsgection ScoDe The team reviewed the licensee's emergency lighting Installation against the requirements of 10 CFR 50, Appendix R, Section II.J, to verify that eight hour emergency lighting coverage was provided in areas where manual operator actions were required during post-fire SSD operations, including the ingress and egress routes.

The team's review also included verifying that emergency lighting requirements were evaluated in the licensee's SSA and properly integrated nto the post-fire SSD procedures as described in the UFSAR, Appendix 9.5A, Section 3.7. During plant walk downs of selected areas where local manual actions directed by post-fire SSD procedures would be performed, the team inspected area emergency lighting units (ELUs) for operability and checked the aiming of lamp heads to determine If adequate illumination was available to correctly and safely perform the actions required by the procedures. The team also inspected emergency lighting features along access and egress pathways used during SSD activities for adequacy and personnel safety. The team checked the ELUs' battery power supplies to verify that they were rated with at

, ICharlie Payne - STL0302-TFPl report Rev1.wpd _,~~~~~~~~~~~~~~~~~~~~~~~~~~Pa Cr e 19 least an 8-hour capacity. In addition, the team reviewed the manufacturer's information and the licensee's periodic maintenance tests to verify that the ELUs were being maintained and tested in accordance with the manufacturer's recommendations.

b.

Findings No findings of significance were Identified.

08.

Cold Shutdown ReDairs

a.

InsDection ScoDe The team reviewed the licensee's SSA and existing plant procedures to determine if any repairs were necessary to achieve cold shutdown, and If needed, the equipment and procedures required to implement those repairs was available onsite.

b.

Findings No findings of significance were identified.

.09 Fire Barriers and Fire Area/Zone/Room Penetration Seals

a.

Inspection Scone The team walked down the selected fire zones/areas to evaluate the adequacy of the fire resistance of barrier enclosure walls, ceilings, floors, and cable protection. The team selected several fire barrier features for detailed evaluation and inspection to verify proper installation and qualification. This evaluation included fire barrier penetration fire stop seals, fire doors, fire dampers, fire barrier partitions, and Thermo-Lag ERFBS enclosures to ensure that at least one train of SSD equipment would be maintained free of fire damage from a single fire.

The team observed the material condition and configuration of the selected fire barrier features and also reviewed construction details and supporting fire endurance tests for the installed fire barrier features. This review was performed to verify that the observed fire barrier penetration seal and ERFBS configurations conformed with the design drawings and tested configurations. The team also compared the penetration seal and ERFBS ratings with the ratings of the barriers In which they were installed.

The team reviewed licensing documentation, engineering evaluations of Generic Letter 86-10 fire barrier features, and NFPA code deviations to verify that the fire barrier installations met design requirements and license commitments. In addition, the tean reviewed surveillance and maintenance procedures for selected fire barrier features to verify the fire barriers were being adequately maintained.

b.

Findings

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rcharlie Payne - STLO3O2-TFPI-report Revl.wpd Paae:

20 No findings of significance were Identified.

.10 Fire Pr6tecti6ri-Svsteris. Features and Ecuipment

a.

InsDection Scone The team reviewed flow diagrams, electrical schematic diagrams, periodic test procedures, engineering technical evaluations for NFPA code deviations, operational valve lineup procedures, and cable routing data for the power and control circuits of the electric motor-driven fire pumps and the fire protection water supply system yard mains.

The review was performed to assess whether the common fire protection water delivery and supply components could be damaged or inhibited by fire-induced failures of electrical power supplies or control circuits and subsequent possible loss of fire water supply to the plant. Additionally, team members walked down the fire protection water supply system piping and actuation valves for the selected fire areas to assess the adequacy of the system material condition, consistency of the as-built configuration with engineering drawings, and operability of the system in accordance with applicable administrative procedures and NFPA standards.

The team walked down accessible portions of the fire detection and alarm systems in the selected fire areas to evaluate the engineering design and operation of the Installed configurations. The team also reviewed engineering drawings for fire detector spacing and locations in the four selected fire areas for consistency with the licensee's fire protection plan, engineering evaluations for NFPA code deviations, and the requirements in NFPA 72A and 72D.

The team also walked down the selected fire zones/areas with automatic sprinkler suppression systems to verify the proper type, placement and spacing of the heads/nozzles and the lack of obstructions. The team examined vendor information, engineering evaluations for NFPA code deviations, and design calculations to verify that the required suppression system density for each protected area was available.

The team reviewed the manual suppression standpipe and fire hose system to verify the adequacy of their design, installation, and operation for the selected fire areas. The team examined design flow calculations and evaluations to verify that the required fire hose water flow and sprinkler system density for each protected area were available.

The team checked a sample of manual fire hose lengths to determine whether they would reach the SSD equipment. Additionally, the team observed placement of the fire hoses and extinguishers to assess consistency with the fire fighting pre-plan drawings.

b.

Findings No findings of significance were Identified.

4.

Other Activities

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I Charlie Payne - STL0302-TFPI-report Revi.wpd Page:

21 40A2 Problem Identification and Resolution

a.

Inspection Scope The team reviewed a sample of licensee audits, self-assessments, and PSL CRs to verify that items related to fire protection and safe shutdown were appropriately entered into the licensee's corrective action program in accordance with the PSL quality assurance program and procedural requirements. The items selected were also reviewed for classification and appropriateness of the corrective actions taken or initiated to resolve the items. In addition, the team reviewed the licensee's applicability evaluations and corrective actions for selected industry experience issues related to fire protection. The operating experience reports were reviewed to verify that the licensee's review and actions were appropriate. The reports are listed in the List of Documents Reviewed Section.

b.

Findings No findings of significance were identified 40A3 Event Followup

.1 (Closed) LER 50-335. 389/00-01, Outside Design Bases Appendix R Hi-Lo Pressure Interface and Separation Issues.

On March 9, 2000, the licensee Identified seven cases where the plant was not in compliance with 10 CFR 50, Appendix R, Sections Ill.G.2.d and III.G.2. f. The first case, involving the pressurizer PORVs, applied to Units 1 and 2, and is discussed In Section 4AO5 of this report. The other six cases apply to Unit 2 only, and are discussed as follows.

(1)

Shutdown Cooling Valves Shutdown cooling valves V3652 and V3481 could spuriously open due to fire induced cable-to-cable short circuits. The location of vulnerability was a pull box (JB-2031) in the annulus region of containment. The valves are motor operated type valves which are de-energized by procedure during normal plant operation. The problem however Is that the power cables for both these valves were routed through a pull box together with other three-phase power cables. Therefore, the potential existed for fire induced cable to cable short circuiting which could inadvertently energize the motors to open these valves. Both valves would have to open to have a problem. Opening of these valves directly connects the RCS to piping that is not rated for RCS normal operating pressure.

Should the valves open when the RCS is at operating pressure, a pressure relief valve would open and RCS coolant would flow from the RCS to the containment sump. This situation Is essentially a large break LOCA. Valve V3545 is a normally open motor operated valve in series with V3652 and V3481. Theoretically, V3545 could be closed by the operator to stop the outflow, but the cables for V3545 could have been damaged

I Charlie Pavne - STLO302-TFPI-report Revl.wpd Page

. -hri Pan CT wdPq 22 by the same fire. The licensee resolved the problem by installing new power cables using armored cable. This precluded the possibility of cable to cable short circuits.

Inspectors confirmed implementation of the modification through review of plant modification PCM01028.

The reported condition was a violation of Appendix R requirements of more than minor significance because it could adversely affect the equipment reliability objective of the cornerstones of mitigating systems and barrier integrity as described above. Using techniques described in NRC Procedure 0609, Appendix F, the inspectors determined that the finding was of very low safety significance (Green). Specifically the SDP worksheet for large break LOCA was evaluated. The conclusion was supported primarily by the negligible probability of the initiating event occurring and the fact that cables for mitigating systems for LOCA are located outside containment. The enforcement considerations for this violation are given in Section 40A7.

(2)

Pressurizer Pressure Instrumentation Affected by Tray-Conduit Interaction Lack of 20-foot separation or a radiant heat shield between a cable tray and two conduits in containment meant that a fire which could start in the cable tray due to cable self ignition could result in damage to a number of pressurizer pressure instrumentation loops. PT-1105, PT-1106 and PT-1107 are in cable tray L2224; and PT-1103, PT-1104 and PT-1108 are in conduits 25018Y and 23091A. PT-1107 and PT-1108 were the instruments specified in the post-fire shutdown procedure. These instruments also provide input to alarms, automatically initiate automatic actions, provide permissives, computer inputs, input to calculations and indications of pressure at various locations.

The inspector reviewed the consequences and ramifications of instruments failing either high or low. Also reviewed, was which pressurizer pressure instrumentations remain unaffected by the fire. This information was analyzed by the inspector, and It was concluded that the affected instrumentation would not lead to any transient nor to change in core damage frequency. The finding is therefore of very low safety significance. As corrective action, conduits 25018Y and 23091A were protected by a radiant heat shield for twenty feet either side of the tray L2224 by plant modification PCM99104, Supplement 1. The licensee reports the fact that both channels of pressurizer pressure instruments specified in the post-fire shutdown procedure could have been affected by one fire represents a violation of 10 CFR 50, Appendix R, Section 1II, G, 2. Refer to Section 40A7 of this report for enforcement aspects.

(3) Pressurizer Level Instrumentation Affected by Tray-Conduit Interaction Lack of 20-foot separation or a radiant heat shield between a cable tray and two conduits in containment meant that a fire which could start in the cable tray due to cable self ignition could result In damage to all pressurizer level Instrumentation loops.

LT-111OX and LT-1105 are In tray L2213; and LT-1I1OY and LT-1104 are in conduits 23320D and 23090A. LT-1 11 OX & Y were specified In the post-fire shutdown procedure. It was determined that the failure mode for a short-circuit between the twisted pair or open circuit caused by fire exposure of the signal wires was level fails

. ICharlie Payne - STL0302-TFPI-report Rev1.wpd age.

I Charlie Payne - STL0302-TFPl-report Revl.wpd Page.

23 low. Level failing low initiates several automatic actions some of which tend to cause level to rise and some of which cause level to fall. The de-energization of pressurizer heaters dominates the situation and results in falling level. This leads to a reactor trip with safety injection on low pressurizer pressure. When the safety injection pumps start, the level will rise. Since the operator cannot see level, he may not turn off the safety injection pumps. So It follows that the pressurizer will go solid. The post-fire safe shutdown procedure directs the operator to place the PORVs In override due to concerns about spurious opening. Therefore, rising level and concomitant pressure rise would be relieved by the safety relief valves. To obtain the risk significance of the fire induced failure of pressurizer level instrumentation, the SDP worksheet for stuck open relief valve was evaluated. The results indicated the finding was of very low safety significance (Green) for the same reasons mentioned in Section 4A05.1 which deals with spurious opening of PORVs. The licensee reports the fact that both channels of pressurizer level instruments specified In the post-fire shutdown procedure could have been affected by one fire represents a violation of 10 CFR 50, Appendix R, Section III.G.2. Refer to Section 40A7 of this report for enforcement aspects.

(4) Pressurizer Level Instrumentation Affected by Conduit to Conduit Interaction Lack of 20-foot separation or a radiant heat shield between two conduits in containment containing cables for redundant channels of pressurizer level instrumentation meant that the separation requirements of Appendix R were not met. The location of the interaction is in the annulus area at an elevation where there are no ignition sources other than the cables themselves. It is not considered credible that low voltage, low energy, instrumentation circuits could self-induce cable ignition, and even if such occurred within a conduit, the fire would not affect another conduit. The reported problem was a violation of Appendix R requirements with regard to separation of cables. The inspectors determined that, given the particular configuration at issue, it could not credibly adversely affect any cornerstone. The licensee corrected the separation problem by installing a radiant heat shield on one of the conduits per plant modification PCM99104, Supplement 1. This licensee identified issue constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section IV of the NRC's Enforcement Policy.

(5) Circuits Related to Automatic Pressurizer Pressure Control Affected by Conduit to Conduit Interaction Lack of separation or a radiant heat shield between certain conduits in containment related to automatic pressurizer pressure control meant that the separation requirements of Appendix R were not met. The circuits Involved were for the PORV and the auxiliary spray isolation valves. The concern was that, If one fire could affect both these circuits, two diverse subsystems designed to reduce pressure when necessary may not function. There are other ways to reduce pressure, but the above mentioned ones were the systems designated in the post-fire shutdown procedure for this function. The location of the nteraction is in the annulus area at an elevation where there are no ignition sources other than the cables themselves. It is not considered

I Charlie Pavne - STLO302-TFPI-rer)ort Rev1.WDd Page I'~

Cha'i Payne - *TLQ3O2-TFPI -rer-o Rv.wo Paae 24 credible that a fire starting within one conduit would expand to affect other nearby conduits. The reported problem was a violation of Appendix R requirements with regard to separation'bf cables. 7Thb irispectors-determined that, given the particular configuration at issue, it could not credibly adversely affect any cornerstone. The licensee corrected the separation problem by installing a radiant heat shield on a sufficient number of the conduits per plant modification PCM99104, Supplement 2. This licensee identified issue constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section IV of the NRC's Enforcement Policy.

(6) Radiant Heat Shields Not Installed Der Appendix R Accepted Deviation Inside containment In the area between the containment wall and the bioshield four' groups of cable trays are Installed. There are five trays in each group. These trays run horizontally along the circumference of the containment to carry cables from the penetration area to their various ultimate destinations in the containment. Train B cables are in trays near the containment wall, and Train A cables are in trays near the bioshield. There is at least seven foot horizontal separation between these two sets of trays in the area of interest. Both the Train A set and the Train B set consists of a group running above the 45-foot elevation grating and a group running above the 23-foot elevation grating. Examples of cable trays involved are instrumentation trays L2223 (Train A) and L2224 (Train B); or control trays C2223 (Train A) and C2224 (Train B).

According to the safety evaluation report each of the four groups should have had a radiant heat shield installed directly below the group. This is actually an accepted deviation, or exemption, from the requirement to have a heat shield between the redundant cables. The licensee reported In the LER that the radiant heat shields below the groups at the 45-foot elevation were not installed. The missing radiant heat shields have now been installed per PCM01028.

The inspector evaluated the risk significance of the lack of radiant heat shield below the 45-foot elevation groups of trays. The conclusion of this evaluation was that the problem was of very low safety significance (Green). Some of the dominant factors considered were:

Fire brigade capability for a fire in containment was not impaired.

In-situ ignition sources were negligible, and transient ignition sources and combustibles are not present during normal plant operation.

Only the top tray in each group contains power cables (480 volt) carrying sufficient energy capable of self ignition of IEEE 383 flame tested cable. Most of the power cables in containment are not energized during normal plant operation. These trays are solid metallic bottom and cover type trays. This construction inherently limits the spread of internal tray fire, and effectively provides a shield limiting the radiant heat energy.

The "target" cable trays have a minimum spatial separation of 15 feet vertical

charlie Payne - STLO302-TFPI-report Revl.wpd Page 25 and 7 feet horizontal from the potentially burning cable tray. The target trays have solid metallic bottoms. Radiant energy flowing between source and target is blocked to a great extent by intervening HVAC ducts, large pipes, tanks and building steel. Hot gas layer is not a factor in the part of containment under consideration.

The target cables would be instrumentation cables, and various scenarios involving damage to these same instrumentation cables discussed in relation to other findings within this report Section were shown to be of very low safety significance.

A very similar configuration in the Unit 1 containment was analyzed by the licensee and reviewed by the NRC in great detail, and found to be an acceptable configuration from the fire protection viewpoint. The Unit 1 study had a safety factor of at least two, which provides margin to account for geometry and other unknown differences between the two units.

Failure to adhere to the configuration of cable trays and radiant heat shields described in an exception to 10 CFR 50, Appendix R, Section Ill.G.2 represents a licensee identified violation. Refer to Section 4AO7 of this report for enforcement aspects.

.2 (Closed) LER 50-335/00-04, Pressurizer Level Instrumentation Conduit Separation Outside Appendix R Design Bases Lack of 20-foot separation or a radiant heat shield between a cable tray and a conduit in Unit 1 containment meant that a fire which could start in the cable tray due to cable self ignition could result in damage to all pressurizer level instrumentation. The discussion of risk significance and requirements for this issue would be identical to the discussion of essentially the same issue on Unit 2 in Section.1 above under the heading:

Pressurizer level instrumentation affected by tray-conduit interaction. Refer to Section 4AO7 of this report for enforcement aspects.

40A5 Other Activities

.1 (Closed) URI 335.389/99-08-03. PORV Cabling May Not be Protected from Hot-Shorts Inside Containment

==

Introduction:==

A Green non-cited violation (NCV) was identified for failure to comply with 10 CFR 50, Appendix R, Sections IlI.G.2.d and IlI.G.2.f, related to spurious opening of the pressurizer PORV.

DescriDtion: During conduct of an Inspection in the area of fire protection (NRC Inspection Report 50-335, 389/99-08, dated January 31, 2000) the inspectors identified the possibility that the PORV cables inside containment were not protected from fire induced cable to cable short circuits. The issue was identified through review of the licensee's analysis. However, the analysis referred to a study which showed that the cable to cable short circuit leading to spurious opening of the PORV was not credible.

Since the study could not be located at the time of the inspection, an unresolved item

ICharlie Payne - STL0302-TFPI-rerport Revl.wpd Paae

. Chri Payn -ST 32-PIrotRelwdae 26 was initiated to track this issue. Subsequently, LER 50-335, 389/00-01 reported that the pressurizer PORVs could open due to fire induced short circuits that could occur in a cable tray in containment. In addition, cables for the associated block valve were routed in the same cable tray. This meant the block valve may not be available to counter the spurious opening of the PORV. Cables for one PORV and its block valve were in a tray near the containment wall and cables for the other set were in a tray near the bioshield.

The condition applied to both units.

The licensee resolved the problem by installing new PORV cables using armored cable.

This precluded the possibility of cable to cable short circuits. The potential for spurious opening due to spurious pressure signal had already been offset by having the operator place the control switch in override in response to a fire In containment. Inspectors confirmed the modification was implemented through review of plant modification package PCM00059 (Unit 1) and PCM99104, Rev. 4 (Unit 2).

LER 00-01 mentioned above also reported licensee identified findings in the area of Appendix R. In addition, Unit 1 LER 00-04 reported similar problems. Refer to Section 40A3 for discussion of these findings.

Analysis: The finding was a performance deficiency because it represented a violation of Appendix R requirements. It was considered greater than minor because it could adversely affect the cornerstones of mitigating systems and barrier Integrity. It affects mitigating systems in the sense that systems designated for post-fire shutdown would be adversely affected by an open PORV during the early stages of post-fire shutdown.

It affects the cornerstone of barrier integrity in the sense that a spuriously open PORV represents a breach of the RCS pressure boundary which is one of the barriers. Using techniques described in NRC Procedure 0609, Appendix F, the inspectors determined that the finding was of very low safety significance (Green). Specifically, the SDP worksheet for stuck open relief valve was evaluated. A key factor leading to this conclusion was that the initiating event likelihood was relatively low. It was less likely than the likelihood for stuck open PORV due to non-fire induced causes. Manual suppression of fires in the containment was in the normal state because the plant had fire detectors, a fire plan and there were no automatic valves in the water source that could be affected by the fire. Even though no credit could be given for the block valve, other mitigating systems were unaffected because their associated cables were outside of containment.

Enforcement: Because this violation of 10 CFR 50, Appendix R, Section IlI.G.2.d. and f, is of very low safety significance, has been entered into the CAP (CROO-0386) and the problem has been corrected through a plant modification It is being treated as an NCV, consistent with Section VL.A of the NRC Enforcement Policy. The number and title of this NCV is: NCV 50-335,389/03-02-02, Failure to Meet 10 CFR 50, Appendix R, Section III.G.2, for Protection of the PORV Cables in Containment.

40A6 Meetings On March 28, 2003, the team presented the inspection rsults to Mr. D. Jernigan and

I Charlie Pavne - STLO302-TFPI-reDort Revl.wDd Paae L Chri Payne - ST00-FIreo OrvlwdPe 27 other members of your staff, who acknowledged the findings. The team confirmed that proprietary information is not included in this report.

40A7 Licensee-Identified Violations The following findings of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as NCVs.

(1) On January 22, 2003, the licensee documented in CR 03-0153 that PSL relied on manual operator actions outside the MCR for SSD in non-alternative shutdown fire areas (i.e., areas designated as 10 CFR 50, Appendix R, Section II.G.2) and the manual actions did not have prior NRC approval.

During this inspection, the team found that the licensee used manual operator actions outside the MCR for a number of fire areas which the licensee had designated as 10 CFR 50, Appendix R, Section III.G.2 areas. The team reviewed the manual operator actions for the III.G.2 areas selected for this inspection (Fire Area C and Fire Area I). Enforcement related to using manual operator actions for Fire Area I are discussed in this report section. Findings related to using manual operator actions for Fire Area C are discussed in Section 1 R05.02.b(2) of this inspection report.

10 CFR 50, Appendix R, Section III.G.2, requires in part, that, where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:

Separation of cables and equipment of redundant trains by a fire barrier having a 3-hour rating.

Separation of cables and equipment of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.

Enclosure of cable and equipment of one redundant train in a fire barrier having a 1-hour rating.

Manual operator actions to respond to maloperations are not listed as an acceptable method for satisfying this requirement.

Contrary to the above, the licensee did not provide adequate protection to ensure that redundant trains of systems and equipment necessary to achieve and maintain SSD were maintained free of fire damage in the event of a fire in Fire Area I. In lieu

harlie Payne - STL0302-TFPI-report Revi.wpd Page I hariie Payne - STL0302-TFPI-report Revl.wpd Page 28 of providing adequate physical protection, the licensee used manual operator actions outside the MCR without obtaining prior NRC approval.

This finding was entered into the licensee's corrective action program as CR 03-0153. The licensee performed a SSD manual operator action time line for Fire Area I to determine the time requirements when the SSD functions were needed, and, if personnel and procedural guidance were adequate to perform the actions.

The licensee determined that the assistance of one operator from the Unit 1 operating shift staff was needed perform the actions required for Unit 2 SSD in the event of a fire in Fire Area I. The team reviewed the time line, personnel needed versus Unit 1 TS shift staffing requirements, and the SSD procedures. Based on this review, the team determined that manual actions to mitigate potential maloperations were properly addressed in the SSD procedures and the personnel needed to perform the manual actions (including the use of an operator from Unit 1) for Fire Area I was reasonable. The team assessed the manual operator actions used for this fire area against the guidance provided in Enclosure 2 of NRC ROP Procedure 71111.05, Fire Protection, dated March 6, 2003. The team determined that the manual actions were reasonable and met the criteria in Enclosure 2 of Procedure 71111.05.

(2) 10 CFR 50, Appendix R, Section III.G.2, Fire protection of safe shutdown capability, requires that, for cables that could prevent operation or cause maloperation due to hot shorts, open circuits or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions and located inside noninerted containments, one of the following fire protection means shall be provided:

Separation of cables of redundant trains by a horizontal distance of more than 20-feet with no intervening combustibles or fire hazards; or Separation of cables of redundant trains by a non-combustible radiant energy shield.

Contrary to the above, since the requirement became effective, the required fire protection was not provided for the following redundant cables:

Shutdown cooling valves V3652 and V3481 on Unit 2.

Pressurizer pressure instrumentation PT-1107 and PT-1108 on Unit 2 Pressurizer level Instrumentation LT-1 11 OX and LT-1 11 OY on Units I & 2 Cables contained in cable trays L2223 (Train A) and L2224 (Train B)

These findings have been entered Into the licensee's corrective action program (CR 99-1963, Rev. 2, and CR 00-0386), corrected by plant modifications, and are of very

I Charlie Payne - STLO302-TFPI-report Revl.wpd Page.

b 29 low safety significance for reasons given in Sections 4AO3.1 and 4AO3.2.

Charlie Payne - STL0302-TFPI-report Revl.Wpd Paqe '

I tharlie Payne

- 5TL0302-TFPI-re~~~~~~~~~~~~~~~ort Revi.w~~~~~~d Paoe-.1 30 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel D. Albritton, Senior Reactor Operator P. Barnes, Fire Protection Engineering Supervisor R. De La Esprella, Site Quality Manager B. Dunn, Site Engineering Manager K. Frehafer, Licensing Engineer J. Hoffman, Design Engineering Manager D. Jemigan, Site Vice President R. Lamb, Senior Reactor Operator G. Madden, Licensing Manager R. Maier, Protection Services Manager R. McDaniel, Fire Protection Supervisor T. Patterson, Operations Manager R. Rose, Plant General Manager V. Rubano, Engineering Special Projects Manager S. Short, Electrical Engineering Supervisor NRC Personnel C. Ogle, Branch Chief R. Rodriguez, Nuclear Safety Intem (Trainee)

T. Ross, Senior Resident Inspector S. Sanchez, Resident Inspector LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-389103-02-01 URI Failure to Provide Adequate Protection for Redundant Safe Shutdown Equipment and Cables in the Event of a Fire the Unit 2 Train B Switchgear Room (Fire Area C) (Section 1 R05.02.b) 50-335,389/03-02-02 NCV Failure to Meet 10 CFR 50, Appendix R, Section III.G.2, for Protection of the PORV Cables in Containment (Section 40A5)

Closed 50-335,389/99-08-03 URI PORV Cabling May Not be Protected from Hot-Shorts Inside Containment (Section 40A5.1) 50-335,389/00-001 LER Outside Design Bases Appendix R Hi-Lo Pressure

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31 Interface and Separation Issues (Section 40A3.1) 50-335/00-004 LER Pressurizer Level Instrumentation Conduit Separation Outside Appendix R Design Bases (Section 4OA3.2)

Discussed None LIST OF DOCUMENTS REVIEWED Section 1R05: Fire Protection Procedures:

2-ADM-03.01, Unit 2 Power Distribution Breaker List, Rev. 6C 2-ONP-1 00.01, Response to Fire, Rev.9 2-ONP-100.02, Control Room Inaccessibility, Rev.13B 2-M-0018D, Mechanical Maintenance Safety-Related PM Program (Dampers), Rev. 11 Administrative Procedure 0005729, Fire Protection Training, Qualification, and Requalification, Rev. 17 Administrative Procedure 0010239, Fire Protection System Impairment, Rev. 13B Administrative Procedure 0010434, Plant Fire Protection Guidelines, Rev. 37C Administrative Procedure 1800022, Fire Protection Plan, Rev. 35 EMP 50.10, Self-Contained Emergency Lighting Unit Maintenance and Inspection, Rev. 9 EMP 52.01, Periodic Maintenance of 4160 Volt Switchgear, Rev. 14 General Maintenance Procedure 2-M-0018F, Safety-Related PM Program (Fire PMs), Rev. 25B Protection Services Guidelines, PSG-15.01, Monitoring Fire Protection System Failures, Rev. 0 QI-3-PSL-1, Design Control, Rev. 11 0-OSP-1 5.11, Fire Protection System Quarterly Alignment Verification, Rev. 6 0-OSP-1 5.17, Fire Protection System Triennial Flow Test, Rev. 1 2-OSP-1 00.1 6, Remote Shutdown Components 18 Month Functional Test, Rev. 2 2-IMP-69.02, ESFAS Monthly Channel Functional Test, Rev. 4A Drawings:

2998-G-078, Sheets 107, 108, 109, 110, Unit 2 Reactor Coolant System, Rev. 1 2998-G-078, Sheets 121A, 121B & 122, Unit 2 Chemical and Volume Control System, Rev. 16 2998-G-078, Sheets 130A, 130B, 131, 132, Unit 2 Safety Injection System, Rev. 12 2998-G-079, Sheets 1, 2 & 7, Unit 2 Main Steam System, Rev. 20 2998-G-080, Sheets 2A & 2B, Unit 2 Feedwater and Condensate System, Rev. 25 2998-G-082, Sheets I & 2, Unit 2 Circulating and Intake Cooling Water System, Rev. 37 2998-G-083, Sheets I & 2, Unit 2 Component Cooling Water System, Rev. 28 2998-G-084, Unit 2 Flow Diagram Domestic & Make-up Water Systems, Rev. 33

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,hri Pan TOO-FIrpr elwdPg 32 2998-G-088, Sheet 1, Unit 2 Containment Spray and Refueling Water System, Rev. 35 2988-G-275 series, 480 V. Switchgear One Line Wiring Diagrams, Rev. 4 2988-G-424, Reactor Auxiliary Building Fire Detectors and Emergency Lights, Rev 9.

2988-G-890, Reactor Auxiliary Building Plumbing and Drainage Plan, Rev. 8 2988-G-891, Reactor Auxiliary Building Plumbing and Drainage Plan El. 43', Rev. 10 2998-B-733, Unit 2 Fire Protection Penetration Schedule, Rev. 6 2998-G-785, Reactor Auxiliary Building Room and Door Schedule, Rev. 8 2998-G-882, HVAC Equipment Schedule and Details, Rev. 1 2998-16082, Air Balance Inc. SL-2121 List of Materials, 319 ALV & 319 ALH Fire Dampers, Rev. 0 8770-B-327, Control Wiring Diagrams for Fire Water Pumps, Rev. 14 2998-G-424, Sheet 7, Unit 2 Reactor Containment Fire Detectors and Emergency Lights, Rev I 2998-G-879, Sheets 1 & 2, Unit 2 HVAC Flow and Control Diagrams, dated 10/20189 2998-G-41 1, Reactor Auxiliary Building El' 1 9'50 Conduit Layout, Sheet 14, Rev. 8 2998-G-41 1, Reactor Auxiliary Building El' 1 9'50 Conduit Layout, Sheet 15, Rev. 6 2998-G-411, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 19, Rev. 5 2998-G-411, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 10, Rev. 6 2998-G-41 1, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 4, Rev. 5 2998-G-41 1, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 3, Rev. 6 2998-G-411, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 13, Rev. 5 2998-G-41 1, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 7, Rev. 9 2998-G-41 1, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 8, Rev. 8 2998-G-41 1, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 9, Rev. 8 2998-G-41 1, Reactor Auxiliary Building Electrical Pen Area Conduit Layout, Sheet 20, Rev. 9 2998-G-410, Cable Vault Trays - Key Plan, Sheet 6, Rev. 6 2998-G-394, Reactor Auxiliary Building El' 43'0 Conduit, Trays & Grounding, Sheet 1, Rev. 27 2998-G-392, Reactor Auxiliary Building El' 19'6 Conduit, Trays & Grounding, Sheet 1, Rev. 17 2998-G-374, Reactor Auxiliary Building Pen Area Conduit, Trays & Grounding, Sheet 1, Rev.

11 2998-G-076, Reactor Auxiliary Building Misc. Plans & Sections, Rev. 19 2998-G-071, General Arrangement Reactor Auxiliary Building Plan Sheet 3, Rev. 24 2998-G-272A, Combined Main and Auxiliary One Line Diagrams, Rev. 7 2998-B-327, Pressurizer Relief Isolation Valve V-1477, Sheet 118, Rev. 14 2998-B-327, Pressurizer Relief Isolation Valve V-1476, Sheet 120, Rev. 14 2998-B-327, LPSI Pump 2A Suction Valve V-3444, Sheet 1531, Rev. 6 2998-B-327, LPSI Flow Control Valve HCV-3625, Sheet 260, Rev. 16 2998-B-327, Pressurizer Relief Valve V-1475, Sheet 1630, Rev. 10 2998-B-327, Pressurizer Relief Valve V-1474, Sheet 1624, Rev. 10 2998-B-327, Pressurizer Level Channel L-1110, Sheet 139, Rev. 13 2998-B-400, Lighting Panel Details, Sheet 209, Rev. 8 2998-B-325, Bill of Material, Sheet 026-01, Rev. 5 2998-B-327, Steam Generator 2A12B Pressure & Level, Sheet 369, Rev. 12 2998-B-327, Pressurizer Pressure & Level, Sheet 370, Rev. 12 2998-B-327, Measurement Channels F2212, P2212, P2215, T2229, T2221, Sheet 150, Rev. 15 C-13172-412-522, Process Instruments Remote Nest Interconnection Diagram, Sheet 1, Rev. 3 C-13172-412-523, Process Instruments Remote Nest Interconnection Diagram, Sheet 1, Rev. 2

-j Charlie Payne - STLO3O2-TFPI-report Revl.wpd Page I Charlie Payne - STLO302-TFPI-report Revl.wpd Page 33 Calculations and Evaluations 2998-B-048, St. Lucie Unit 2, Appendix R Safe Shutdown Analysis Fire Area Report 2998-B-049, St. Lucie Unit 2 Essential Equipment List, Rev. 6 2998-2-FJE-98-002, Review of Circuit Breaker and Fuse Coordination for St. Lucie Unit 2 Appendix R Essential Equipment List Circuits, Rev. 0 PSL-2-FJE-90-0020, St. Lucie Unit 2 2A & 2B EDG Electrical Loads, Rev. 7 PSL-1FJM-91-001, PSL-1 RAB Electrical Equipment Rooms HVAC Computer Model Data Inputs and Outputs, Rev. I PSL-FPER-00-004, Disposition of Unit 2 Fire Detection System Nonconformance, Rev. I PSL-BFSM-98-004, Hose Station Supply Piping (Standpipe) Hydraulic Analysis, Rev. 0 PSL-ENG-97-070, UFSAR Combustible Loading Update for Unit 2, Rev. 0 PSL-FPER-99-008, Two-sided Cable Tray Fire Stop Redesign, Rev. I PSL-FPER-99-01, Disposition of Unit 2 NFPA Code Nonconformance, Rev. 1 PSL-FPER-00-0126, Evaluation of Fire Barrier Rating for Barriers Containing Two-sided Fire Stops, Rev.0 Calculation to determine the capacity of diked areas surrounding Unit 2 transformers 2A5, 2B5 and 2B2, dated March 12, 2003 Evaluation to determine compliance with DC 561 Technical Manual Use Restrictions" for Unit 2 transformers 2A5, 285 and 2B2, dated March 10, 2003 Design Basis Documents:

Component Functions for Pressurizer Wide Range Pressure Instrument Loop, Section 7.22 Component Functions for Pressurizer Instrument Loop P-11 00X&Y, Section 7.23 Component Functions for Pressurizer Pressure/Safety Injection Instrument Loop, Section 7.28 DBD-ESF-2, Engineering Safety Features Actuation System, Rev. 1 DBD-CVCS-2, Chemical and Volume Control System, Rev. I ADDlicable Codes and Standards:

IEEE Standard 100, Standard Dictionary of Electrical and Electronics Terms, Fourth Edition NFPA 13, Standard for the Installation of Sprinkler Systems, 1973 Edition NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 1973 Edition NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, 1972 Edition NFPA 72A, Standard on Local Protective Signaling Systems, 1972 Edition NFPA 72D, Standard for the Installation, Maintenance, and Use of Proprietary Protection Signaling Systems, 1973 Edition NFPA 80, Standard on Fire Doors and Windows, 1973 Edition NFPA 90A, Standard on Air Conditioning and Ventilating Systems, 1981 Edition NUREG-1552, Supplement 1, Fire Barrier Penetration Seals In Nuclear Power Plants, dated January 1999 Underwriters Laboratories, Fire Resistance Directory, January 1998 OSHA Standard 29 CFR 1910, Occupational Safety and Health Standards,

I I Charlie Payne - STLO302-TFPI-reoort Revl.wDd Paqne:

34 Audit ReDorts:

QSL-FP-00-07, Annual Fire Protection Functional Area Audit QSL-FP-01-079-Triennial Fire-Protection Functional Audit-QSL-FP-02-05, Fire Protection Functional Audit Condition Revorts:

CR 98-0260, Evaluate Deviations from NFPA 72 Code CR 98-0405, Evaluate Deviations from NFPA 13-1975 Code CR 98-0563, Assess Currently Installed Fire Hose Nozzles In Both Units CR 00-1514, Failure of 500KV Main Transformer, SEN 215 CR 01-0577, Circuit Breaker Failure and Fire, SEN 218 CR 01-2296, Assess Deviations from NFPA 72 Code addressed In QA Audit QSL-FP-01-07 CR 01-2459, 4-kW Breaker Failure, SER 5-01 CR 02-0396, Assess Qualifications of Thermo-Lag Walls at PSL CR 02-1619, Potential Problems with Heat Collectors, NRC Information Notice 2002-24 CR 02-2081, Design Change Checklist CR 02-2098, PSL CARS CR 02-3145, Failure to Obtain FRG Review of Several Procedure Changes Condition ReDorts Generated During this nsDection CR 03-0153, Use of manual actions In Appendix R, ll.G.2 areas without prior NRC approval CR 03-0637, Silicone oil-filled transformers installed in Unit 2 Interior rooms CR 03-0847, Hot shutdown repairs using tools to achieve safe shutdown In the event of a fire CR 03-0888, Update UFSAR to show previously approved Deviation C6 no longer required CR 03-0942, Discrepancies between the SSA, EEL, and the breaker/fuse coordination study CR 03-0964, Rubatex insulation installed in U2 Intake (fire area R-R) not considered in the FHA CR 03-0965, Combustible fire load for Ul and U2 intake fire areas different for each unit's FHA CR 03-0966, Temp Mod did not sufficiently evaluate potential impact on fire protection CR 03-0978, Transformers' oil not being sampled and tested in accordance with vendor manual CR 03-0986, Discrepancies between SSA and EEL, determined that EEL was in error CR 03-1010, Discrepancy between UFSAR and procedure regarding cold shutdown repairs Work Orders/Job Tasks WO 3201713801, T.S. 044A S/G 2A Level Loop Calibration, dated 1/7/03 WO 3100661301, T.S. 044A S/G 2A Level Loop Calibration, dated 8/8/01 WO 3101259101, T.S. 044B S/G 2B Level Loop Calibration, dated 11103/01 WO 3181734101, T.S. F-2212 Charging Pump Flow Calibration, dated 4/24/02 WO 3101222101, T.S. Charging Pump Discharge P-2212 Calibration, dated 9/7/01 WO 3201736501, T.S. Pressurizer Level (P1107/1108/1116) Calibration, dated 11/10/03 WO 3100693301, T.S. Pressurizer Level (P1107/1108/1116) Calibration, dated 7/12/01 WO 3261652901, T.S. Pressurizer & Quench Tank Level (L1103/4/511116) Calibration, dated 1/10/03 WO 3100682601, T.S. Pressurizer & Quench Tank Level (L1103/4/5111) Calibration, dated

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35 7/11/01 Technical Manuals/vendor Information Dow Corning 561 Silicone Transformer Liquid, Material Safety Data Sheet 01496247,1/27/97 Dow Corning 561 Silicone Transformer Fluid Technical Manual,10-453-97, 1997 Data Sheet Issue C Duraspeed, Automatic Sprinklers, Grinnell Sprinkler Corporation Data Sheet Model F950, Upright and Pendent Sprinklers, Grinnell Sprinkler Corporation Data Sheet Model L-205-EB, Industrial Electrical Non-Shock Fog Nozzles, Elkhart Brass Manufacturing Co. Inc.

IB-PD-1001, Gould Inc. -T-E Unit Substation Transformers Instruction Manual S2000, Protecto-wire Fire Systems Fire System 2000 Fire Alarm Control Panel, Rev. 1998 Sheet 5-4/14-8, Factory Mutual Research Approval Guide-Transformer Fluids Miscellaneous 0711206, Reactor Operator Lesson Pressurizer Pressure and Level Control, Rev.12 1/M-CE 917 Foxboro Specification 200 Control System Manual # 79N-36291, dated 8/20/98 Consumer Product Safety Commission (CPSC) Recall Alert, Invensys Building Systems Recall of Siebe Actuators in Building Fire/Smoke Dampers, dated October 2, 2002 Ebasco Specification - Electric Cables, Project 10 # FLO 298.292, dated 10/28/77 IPEEE Submittal for St. Lucie Units I and 2, Rev. 0, dated December 15, 1994 Fire Brigade Drill Training Reports for operating shifts, August 2001-February 2003 Letter from Ebasco to Florida Power and Light, on the subject of UL Qualification Test for Pullman Industries Internal Expansion Damper Assembly, dated April 16, 1986 NRC Supplemental Safety Evaluation Report SSER 3, for St. Unit 2 PC/M 174-295M, Reroute of Cable 21702C, Rev. I Pre-fire Strategy No. 4, A Switchgear Room, Fire Area A, Rev. 23 Pre-fire Strategy No. 6, Cable Spread Room, Fire Area B, Rev. 23 Pre-fire Strategy No. 7, B Switchgear Room, Fire Area C, Rev. 23 Pre-fire Strategy No. 8, Electrical Equipment Supply Fan Room, Fire Area C, Rev. 23 Pre-fire Strategy No. 25, Personnel Monitoring Area & Health Physics Area, Fire Area I, Rev. 23 Pre-fire Strategy No. 26, Electrical Penetration Room B, Fire Area I, Rev. 23 Pre-fire Strategy No. 57, Turbine Building, Fire Area QQ, Rev. 23 Technical Specifications, St. Lucie Unit 2, LCO 3.3.3.5 Technical Specifications, St. Lucie Unit 2, SR 4.3.3.5.1 / 4.3.3.5.2 UFSAR Section 8, Electrical Power UFSAR Appendix 9.5A, Fire Protection Program Report Underwriters Laboratories, Report File R4708, Fire Test of 3HR Curtain Type Fire Damper Utilizing an Alternate Method of Installation, Air Balance, Inc., dated December 5, 1984

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