ML040120044
| ML040120044 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/22/2003 |
| From: | Ogle C NRC/RGN-II/DRS/EB |
| To: | Stall J Florida Power & Light Co |
| References | |
| FOIA/PA-2003-0358 IR-03-002 | |
| Download: ML040120044 (31) | |
See also: IR 05000335/2003002
Text
I9
May x, 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 1 and 2. The enclosed inspection report documents the
inspection findings, which were discussed on March 28, 2003, with Mr. D. Jemigan 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. q.
This report documents two findings that,m edhave 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 VL.A of
the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your denial, to
the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-
0001; with copies to the Regional Administrator Region I; the Director, Office of Enforcement,
United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC
Resident Inspector at St. Lucie Nuclear Plant.
FP&L 2
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 inthe
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
httD://www.nrc.aov/readina-rrm/adams.html (the Public Electronic Reading Room).
Sincerely,
Charles R.Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Docket Nos.: 50-335, 50-389
Enclosure: Inspection Report 50-335, 389/03-02
w/Attachment: Supplemental Information
cc w/encl: (See page 3)
3
cc:
Senior Resident Inspector Mr. Don Mothena
St. Lucie Plant-- Manager, Nuclear Plant Support Services
U.S. Nuclear Regulatory Commission Florida Power & Light Company
P.O. Box 6090 P.O. Box 14000
--- Jensen Beach, Florida 34957 Juno Beach, FL 33408-0420
Craig Fugate, Director Mr. Rajiv S. Kundalkar
Division of Emergency Preparedness Vice President - Nuclear Engineering
Department of Community Affairs Florida Power & Light Company
2740 Centerview Drive P.O. Box 14000
Tallahassee, Florida 32399-2100 Juno Beach, FL 33408-0420
M.S. Ross, Attorney Mr. J. Kammel
Florida Power & Light Company Radiological Emergency
P.O. Box 14000 Planning Administrator
Juno Beach, FL 33408-0420 Department of Public Safety
6000 SE. Tower Drive
Mr. Douglas Anderson Stuart, Florida 34997
County Administrator
St. Lucie County Attorney General
2300 Virginia Avenue Department of Legal Affairs
Fort Pierce, Florida 34982 The Capitol
Tallahassee, Florida 32304
Mr. William A. Passetti, Chief
Department of Health Mr. Steve Hale
Bureau of Radiation Control St. Lucie Nuclear Plant
2020 Capital Circle, SE, Bin #C21 Florida Power and Light Company
Tallahassee, Florida 32399-1741 6351 South Ocean Drive
Jensen Beach, Florida 34957-2000
Mr. r'onald . .JerniaSite Vice President
St. Lucie Nuclear Plant Mr. Alan P. Nelson
6501 South Ocean Drive Nuclear Energy Institute
Jensen Beach, Florida 34957 1776 I Street, N.W., Suite 400
Washington, DC 20006-3708
Mr. R. E. Rose APN@NEI.ORG
Plant General Manager
St. Lucie Nuclear Plant David Lewis
6501 South Ocean Drive Shaw Pittman, LLP
Jensen Beach, Florida 34957 2300 N Street, N.W.
Washington, D.C. 20037
M.iG. dd 1
Licensing Manager Mr. Stan Smilan
St. Lucie Nuclear Plant 5866 Bay Hill Cir.
6501 South Ocean Drive Lake Worth, FL 33463
Jensen Beach, Florida 34957
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.: 50-335,50-389
Report No.: 50-335/03-02 and 50-389/03-02
Licensee: Florida Power and Light Company (FPL)
Facility: St. Lucie Nuclear Plant
Location: 6351 South Ocean Drive
Jensen Beach, FL 34957
Dates: March 10- 14, 2003 (Week 1)
March 24 - 28, 2003 (Week 2)
Inspectors: 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
Approved by: Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
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-ldentified and Self-Revealing Findinas
Cornerstone: Initiating Events and Mitigating Systems
TBD. Physical andprocedural rotectio 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
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 2B13equired for SSD in the event of a fir eu of provi
ae ph protection for loa c r 25 and aociated elefcal
cables, m al operator actions o ide the main cqpfol room (C) were
used, wjout prior NRC appro ,for achieving ai maintainiri SSD.
0
2
A violation of 10 CFR 50, Appendix R,Section ill.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 1R05.02.b(2))
Cornerstone: Mitigating Systems
Green. A non-citediolation of 10 CFR 50, Appendix R, Section III.G.2 was
identified copeefP g a lack of spacial separation or barriers to protect cables
against fire damage in containmenlcould result in spurious opening of the
pressurizer power operated relief vklve (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.
k
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems and Barrier-integrity
1R05 FIRE PROTECTION
01. Systems Required to Achieve and Maintain Post-Fire Safe Shutdown
a. Inspection 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
program to determine if a sample of manual valves used to achieve SSD were included.
b. Findings
2
No findings of significance were identified.
.02 Fire Protection of Safe Shutdown CaDabilitv
a. Inspection Scope
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
Ill.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 hazard ocedures.
In addition, the team reviewed fire protection inspection reports action
program condition reports (CRs) resulting from fire, smoke, sp ks, 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.
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
3
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-lccupational.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 Switchgear 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
cables, the licensee used local manual operator actions, without prior NRC approval, for
achieving and maintaining SSD.
(1) Inadequate Fire Hazards Analysis
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 Rbom; 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
- X
4
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
l--icensee provided the team-with information from the transformer vendor which indicated
that the transformer insulating fluid was Dow Corning (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 techni6al 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
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
challenge critical safety functions relied upon for SSD from a fire, and wa efore,
greater than minor. The six, previously unident , cone oil-filled t sformers in
Unit 2 represented an increase in the ignition equency f the associated fire
areas/zones. This finding was unresolved pe completion of a significance
5
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 10 CFR 50, Appendix A.
-PSLUnit2-Operatinglicense NP-F1 6, 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 lo6ated 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
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 Eauipment and Cables Required for SSD/Use of Manual
Operator Actions Outside the MCR to Achieve Safe Shutdown for 10 CFR 50.
Appendix R. Section Ill.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 Ill.G.2) and the manual actions
did not have prior NRC approval. The licensee documented this issue in CR 03-0153.
6
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
I--iG -2 areasThe .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.
Enforcement: 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:
(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.
7
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-betweenTrainAJoad center 2A5-and theJrainB1electrical 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 I opeiating 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.
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. Inspection Scone
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
8
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:
- VI 474 and Vi 475, Pressurizer PORVs
- VI 476 and VI 477, Pressurizer Isolation Block Valves
- MV-09-03 and MV-09-04, Feedwater Bypass Valves
- 2HVE-1 3B, 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
- P-1107/1108, Pressurizer Pressure for Hot Shutdown Parpel
- LI-1 104/1105, Pressurizer Level for Hot Shutdown Panel
- LI-9113/9123, Steam Generator Level for Hot Shutdown Panel
- Safety Injection Actuation System Logic
- 2A5/2A6 and related feeds, 480 Volt Motor Control Center
- 2B512B6 and related feeds, 480 Volt Motor Control Center
- Load Center 2A5 480 Volt Switchgear
b. Findings
No findings of significance were identified.
04. Alternative Post-Fire Safe Shutdown Capability
a. Inspection Scope
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
I
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9
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
-NoJindings-of-significance-wereJdenified._
05. Operational Implementation of Post-Fire Safe Shutdown Capability
a. Inspection ScoDe
The team reviewed off normal operating procedure 2-ONP-1 00.02, 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
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 1R05.02.b(2) of this inspection report for
Fire Area C, and Section 40A7 of this inspection report for Fire Area I.
06. Communications
a. Inspection 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.
- a
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07. - Emergency Lighting
a. Inspection Scope
The team reviewed the licensee's emergency lighting installation against the
-- requirements of 10 CFR-50,-Appendix-RSection. ll.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 into 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
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. Inspection Scope
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. InsDection Scope
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.
S -
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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
EREBS-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 team
reviewed surveillance and maintenance procedures for selected fire barrier features to
verify the fire barriers were, being adequately maintained.
b. Findings
No findings of significance were identified.
.10 Fire Protection Systems. Features, and Equipment
a. Inspection Scope
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
12
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
40A2 Problem Identification and Resolution
a. Inspection ScoDe
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 FollowuD
.1 (Closed) LER 50-335. 389/00-01, Outside Design Bases Appendix R Hi-L6 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 lI.G.2.d and Il.G.2. f. The first
case, involving the pressurizer PORVs, applied to Units I 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
13
--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
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-1 105, PT-1 106 and PT-1 107 are in cable tray L2224; and PT-1 103, PT-1104
and PT-1 108 are in conduits 2501 8Y and 23091 A. PT-1 107 and PT-1 108 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 2501 8Y and 23091 A 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
ll, G, 2. Refer to Section 40A7 of this report for enforcement aspects.
(3) Pressurizer Level Instrumentation Affected by Tray-Conduit Interaction
14
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-
111 OX and LT-1 105 are in tray L2213; and LT-1 11 0Y and LT-1 104 are in conduits
23320D and 23090A. LT-111 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
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 4AO5.1 which deals
with spurious opening of PORVs. The licensee reports the fact that both channels of
pressurizer level instruments specified i the post-fire shutdown procedure could have
been affected by one fire represents a violation of 10 CFR 50, Appendix R, Section
Ill.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
I
15
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 f unction. The location of the interaction is inthe annulus area at an elevation where
there are no ignition sources other than the cables themselves. It is not considered
credible that a fire starting within one conduit would expand to affect other nearby
conduits.-The-reported problem-was a-iolation-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 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 per ApDendix 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.
16
- The "target" cable trays have a minimum spatial separation of 15 feet vertical 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 I 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 Il.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 Ill.G.2.f, related to spurious opening of
the pressurizer PORV.
Description: 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
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
17
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 Ill.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 Il.G.2, for Protection of the PORV Cables in Containment.
40A6 Meetings
On March 28, 2003, the team presented the inspection results to Mr. D. Jernigan and
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
4 .
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'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 Il.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 1R05.02.b(2) of this
inspection report.
10 CFR 50, Appendix R, Section Ill.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
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
4 *
19
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-1 107 and PT-1 108 on Unit 2
- Pressurizer level instrumentation LT-1 11 OX and LT-1 11 OY on Units 1 & 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
low safety significance for reasons given in Sections 4AO3.1 and 4AO3.2.
I
. V
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. Jernigan, 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 Intern (Trainee)
T. Ross, Senior Resident Inspector
S. Sanchez, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-389/03-02-01 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 1R05.02.b)
50-335,389/03-02-02 NCV Failure to Meet 10 CFR 50, Appendix R, Section IllI.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
Interface and Separation Issues (Section 40A3.1)
- C
50-335/00-004 LER Pressurizer Level Instrumentation Conduit Separation
Outside Appendix R Design Bases (Section 40A3.2)
Discussed
None
LIST OF DOCUMENTS REVIEWED
Section 1RO5: 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
QJ-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.
2-OSP-1 00.16, 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 1 & 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
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
2
2998-G-882, HVAC Equipment Schedule and Details, Rev.
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 1
-2998-G-879,-Sheets-1-& 2,-Unit2-HVAC-Flow and Control Diagrams, dated 10/20/89
2998-G-411, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 14, Rev. 8
2998-G-41 1, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 15, Rev. 6
2998-G-41 1, Reactor Auxiliary Building El' 19'50 Conduit Layout, Sheet 19, Rev. 5
2998-G-41 1, 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-41 0, 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-1 476, 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-1 110, 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 2A/2B 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-1 3172-412-523, Process Instruments Remote Nest Interconnection Diagram, Sheet 1, Rev. 2
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-1 FJM-91 -001, PSL-1 RAB Electrical Equipment Rooms HVAC Computer Model Data
Inputs and Outputs, Rev. 1
PSL-FPER-00-004, Disposition of Unit 2 Fire Detection System Nonconformance, Rev. I
3
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. 1
PSL-FPER-99-01 1, Disposition of Unit 2 NFPA Code Nonconformance, Rev. 1
PSL-FPER-00-01 26, 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, 2B5 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-1 100X&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.
DBD-CVCS-2, Chemical and Volume Control System, Rev. 1
Applicable 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,
Audit Reports:
QSL-FP-00-07, Annual Fire Protection Functional Area Audit
QSL-FP-01-07, Triennial Fire Protection Functional Audit
QSL-FP-02-05, Fire Protection Functional Audit
Condition Reoorts:
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 00-1 514, 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
4
CR 01-2459,4-kV 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 Reports Generated During this Inspection
CR 03-0153, Use of manual actions in Appendix R, lIl.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 U1 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 11/03/01
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 (L1 103/4/5/1116) Calibration, dated
1/10/03
WO 3100682601, T.S. Pressurizer & Quench Tank Level (L1 103/4/5/11) Calibration, dated
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
5
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 10/28177
-- IPEEE-Submittal-for-StLucie-Units -- and-2,-Rev-0dated-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.
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-f ire 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