ML093500523
| ML093500523 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/15/2009 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Jensen J Indiana Michigan Power Co |
| References | |
| EA-09-313 IR-09-006 | |
| Download: ML093500523 (21) | |
See also: IR 05000315/2009006
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
December 15, 2009
Mr. Joseph Jensen
Senior Vice President and
Chief Nuclear Officer
Indiana Michigan Power Company
Nuclear Generation Group
One Cook Place
Bridgman, MI 49106
SUBJECT:
DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2
NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REPORT 05000315/2009006(DRS); 05000316/2009006(DRS)
AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Jensen:
On November 20, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a
triennial fire protection inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2.
The enclosed inspection report documents the inspection results, which were discussed on
November 20, 2009, with Mr. Larry Webber and other members of your staff.
As a result of your intent to adopt the National Fire Protection Association Standard
(NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric
Generating Plants, 2001 Edition, as defined by Title 10, Code of Federal Regulations (CFR),
Part 50, Section 48(c), the inspection was conducted in accordance with Inspection
Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 transition Period (Triennial), dated
May 9, 2006. The inspection examined activities conducted under your license as they relate
to safety and compliance with the Commissions rules and regulations and with the conditions
of your license. The inspectors reviewed selected procedures and records, observed
activities, and interviewed personnel.
Based on the results of this inspection, no NRC-identified and no self-revealed findings were
discovered that involved violations of NRC requirements. However, a licensee-identified
violation which was determined to be of very low safety-significance is listed in this report. The
licensee-identified finding was not associated with a finding of high safety-significance (Red)
and met the four criteria established by Section A of the NRC's Interim Enforcement Policy
Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR Part 50.48) for a
licensee in NFPA 805 transition, including being entered into your corrective action program.
The finding also met additional criteria established in Section 12.01.b of Inspection Manual
J. Jensen
-2-
Chapter (IMC) 0305. Therefore, we are exercising enforcement discretion to not cite this
violation in accordance with the NRC's Enforcement Policy. If you disagree with the
characterization of this finding, you should provide a response within 30 days of the date of this
inspection report, with the basis for your disagreement, to the Nuclear Regulatory Commission,
ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional
Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Donald C.
Cook Nuclear Power Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any), will be available electronically for public inspection in
the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-315; 50-316
Enclosure:
Inspection Report 05000315/2009006(DRS); 05000316/2009006(DRS)
w/Attachment: Supplemental Information
cc w/encl:
Distribution via ListServ
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket Nos.
50-315; 50-316
License Nos.
Report No:
05000315/2009006(DRS); 05000316/2009006(DRS)
Licensee:
Indiana Michigan Power Company
Facility:
Donald C. Cook Nuclear Power Plant, Units 1 and 2
Location:
Bridgman, MI
Dates:
November 2 through November 20, 2009
Inspectors:
G. Hausman, Senior Reactor Inspector, Lead
M. Munir, Reactor Inspector
B. Winter, Reactor Inspector
Approved by:
R. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Enclosure
1
SUMMARY OF FINDINGS
IR 05000315/2009006(DRS); 05000316/2009006(DRS); 11/02/2009 - 11/20/2009; Donald C.
Cook Nuclear Power Plant, Units 1 and 2; Routine Triennial Fire Protection Baseline
Inspection.
This report covers an announced triennial fire protection baseline inspection. The inspection
was conducted by Region III inspectors. Based on the results of this inspection, no
NRC-identified and no self-revealed findings of safety-significance were identified. The
significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP).
Findings for which the SDP does not apply may be Green or be assigned a severity level after
NRC management review. The NRCs program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight
Process, Revision 4, dated December 2006.
A.
NRC-Identified and Self-Revealed Findings
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
No findings and/or violations of safety-significance were identified.
B.
Licensee-Identified Violations
A violation of very low safety-significance that was identified by the licensee has been
reviewed by inspectors. Corrective actions taken or planned by the licensee have
been entered into the licensees corrective action program. This violation and
corrective action tracking numbers are listed in Section 4OA7 of this report.
Enclosure
2
REPORT DETAILS
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R05 Fire Protection (71111.05TTP)
Indiana Michigan Power Company, the licensee, in a letter (ML060090370) to the U. S.
Nuclear Regulatory Commission (NRC) dated December 28, 2005, committed to adopt
the National Fire Protection Association Standard (NFPA) 805, Performance-Based
Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001
Edition, as defined by 10 CFR 50.48(c) for the Donald C. Cook Nuclear Power Plant.
The NFPA 805 standard established a comprehensive set of requirements for fire
protection programs at nuclear power plants. The standard incorporated both
deterministic and risk-informed, performance-based concepts. The deterministic
aspects of the standard are comparable to traditional requirements. However, the
transition to a risk-informed, performance-based fire protection program requires an
in-depth nuclear safety circuit analysis for equipment identified for nuclear safety
functions such as safe-shutdown. Because the conversion and licensing process to
NFPA 805 was expected to identify and address a variety of issues that were normally
the subject of the triennial fire protection baseline inspection, the NRC modified the fire
protection inspection program and Enforcement Policy for licensees in transition to
NFPA 805. As a result, this inspection was conducted in accordance with Inspection
Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 transition Period (Triennial),
dated May 9, 2006. Associated with the transition to NFPA 805, when a certain finding
not associated with a finding of high safety-significance meets the four criteria
established by Section A of the NRC's Interim Enforcement Policy Regarding
Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), the violation
would receive enforcement discretion in accordance with the NRC's Enforcement
Policy.
The purpose of the fire protection triennial baseline inspection was to conduct a
design-based, plant specific, risk-informed, onsite inspection of the licensees fire
protection programs defense-in-depth elements used to mitigate the consequences of
a fire. The fire protection program shall extend the concept of defense-in-depth to fire
protection in plant areas important to safety by:
preventing fires from starting;
rapidly detecting, controlling and extinguishing fires that do occur; and
providing protection for structures, systems, and components important to
safety so that a fire that is not promptly extinguished by fire suppression
activities will not prevent the safe-shutdown of the reactor plant.
The inspectors evaluation focused on the design, operational status, and material
condition of the reactor plants fire protection program and post-fire safe-shutdown
systems. The objectives of the inspection were to assess whether the licensee had
implemented a fire protection program that: (1) provided adequate controls for
combustibles and ignition sources inside the plant; (2) provided adequate fire detection
and suppression capability; (3) maintained passive fire protection features in good
Enclosure
3
material condition; (4) established adequate compensatory measures for
out-of-service, degraded or inoperable fire protection equipment, systems or features;
(5) ensured that procedures, equipment, fire barriers, and systems exist so that the
post-fire capability to safely shut down the plant was ensured; (6) included feasible and
reliable operator manual actions when appropriate to achieve safe-shutdown; and
(7) identified fire protection issues at an appropriate threshold and ensured these
issues were entered into the licensees problem identification and resolution program.
In addition, the inspectors review and assessment focused on the licensees post-fire
safe-shutdown systems for selected risk-significant fire areas. Inspector emphasis
was placed on determining that the post-fire safe-shutdown capability and the fire
protection features were maintained free of fire damage to ensure that at least one
post-fire safe-shutdown success path was available. The inspection was performed in
accordance with the NRCs regulatory oversight process using a risk-informed
approach for selecting the fire areas and attributes to be inspected. The inspectors,
with assistance from a Senior Reactor Analyst (SRA), used the licensees Individual
Plant Examination for External Events (IPEEE) to select several risk-significant areas
for detailed inspection and review. Documents reviewed are listed in the Attachment to
this report.
The fire areas and/or fire zones selected for review during this inspection are listed
below and constituted five inspection samples as defined in IP 71111.05TTP.
Fire Area
Fire Zone
Description
M
15
Unit 1, 1CD Diesel Generator Room (EL. 587 0)
EE
29B
Unit 1, Essential Service Water Pump PP-1W (EL. 591-0)
KK
40A
Unit 1, 4-kV AB Switchgear Room (EL. 609-6)
MM
42D
Unit 1, EPS (AB) Battery Room (EL. 609-6)
54
Unit 2, Control Room (EL. 633-0)
.1
Shutdown from Outside Main Control Room
a.
Inspection Scope
The inspectors reviewed the functional requirements identified by the licensee as
necessary for achieving and maintaining hot shutdown conditions to ensure that at
least one post-fire safe-shutdown success path was available in the event of fire in
each of the selected fire areas and for alternative shutdown in the case of control room
evacuation. The inspectors reviewed the plant systems required to achieve and
maintain post-fire safe-shutdown to determine if the licensee had properly identified the
components and systems necessary to achieve and maintain safe-shutdown conditions
for each fire area selected for review. Specifically, the review was performed to
determine the adequacy of the systems selected for reactivity control, reactor coolant
inventory makeup, reactor heat removal, process monitoring, and support system
functions. The review also included the fire safe-shutdown analysis to ensure that all
Enclosure
4
required components in the selected systems were included in the licensees
safe-shutdown analysis.
The inspectors reviewed the licensees post-fire safe-shutdown analysis, normal and
abnormal operating procedures, piping and instrumentation drawings, electrical
drawings, their updated final safety analysis report, and other supporting documents to
verify that hot and cold shutdown could be achieved and maintained from outside the
control room for fires that rely on shutdown from outside the control room. This review
included verification that shutdown from outside the control room could be performed
both with and without the availability of offsite power.
The inspectors also examined the operators ability to perform the necessary manual
actions for achieving safe-shutdown by reviewing post-fire shutdown procedures, the
accessibility of safe-shutdown equipment, and the available time for performing the
actions.
The inspectors reviewed the updated final safety analysis report and the licensees
engineering and/or licensing justifications (e.g., NRC guidance documents, license
amendments, Technical Specifications, safety evaluation reports, exemptions, and
deviations) to determine the licensing basis.
b.
Findings
No findings of safety-significance were identified.
.2
Protection of Safe-shutdown Capabilities
a.
Inspection Scope
For each of the selected fire areas, the inspectors reviewed the fire hazards analysis,
safe-shutdown analysis, and supporting drawings and documentation to verify that
safe-shutdown capabilities were properly protected.
The inspectors reviewed the licensee procedures and programs for the control of
ignition sources and transient combustibles to assess their effectiveness in preventing
fires and in controlling combustible loading within limits established in the fire hazards
analysis. The inspectors performed plant walkdowns to verify that protective features
were being properly maintained and administrative controls were being implemented.
The inspectors also reviewed the licensees design control procedures to ensure that
the process included appropriate reviews and controls to assess plant changes for any
potential adverse impact on the fire protection program and/or post-fire safe-shutdown
analysis and procedures.
b.
Findings
No findings of safety-significance were identified.
Enclosure
5
.3
Passive Fire Protection
a.
Inspection Scope
For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers,
penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical
cables. The inspectors observed the material condition and configuration of the
installed barriers, seals, doors, and cables. The inspectors reviewed approved
construction details and supporting fire tests. In addition, the inspectors reviewed
license documentation, such as NRC safety evaluation reports, and deviations from
NRC regulations and NFPA standards to verify that fire protection features met license
commitments.
The inspectors walked down accessible portions of the selected fire areas to observe
material condition and the adequacy of design of fire area boundaries (including walls,
fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the
area.
The inspectors reviewed the installation, repair, and qualification records for a sample
of penetration seals to ensure the fill material was of the appropriate fire rating and that
the installation met the engineering design.
b.
Findings
No findings of safety-significance were identified.
.4
Active Fire Protection
a.
Inspection Scope
For the selected fire areas, the inspectors evaluated the adequacy of fire suppression
and detection systems. The inspectors observed the material condition and
configuration of the installed fire detection and suppression systems. The inspectors
reviewed design documents and supporting calculations. In addition, the inspectors
reviewed license basis documentation, such as, NRC safety evaluation reports,
deviations from NRC regulations, and NFPA standards to verify that fire suppression
and detection systems met license commitments.
b.
Findings
No findings of safety-significance were identified.
.5
Protection from Damage from Fire Suppression Activities
a.
Inspection Scope
For the selected fire areas, the inspectors verified that redundant trains of systems
required for hot shutdown would not be subject to damage from fire suppression
activities or from the rupture or inadvertent operation of fire suppression systems
including the effects of flooding. The inspectors conducted walkdowns of each of the
Enclosure
6
selected fire areas to assess conditions such as the adequacy and condition of floor
drains, equipment elevations, and spray protection.
b.
Findings
No findings of safety-significance were identified.
.6
Alternative Shutdown Capability
a.
Inspection Scope
The inspectors reviewed the licensees systems required to achieve alternative safe-
shutdown to determine if the licensee had properly identified the components and
systems necessary to achieve and maintain safe-shutdown conditions. The inspectors
also focused on the adequacy of the systems to perform reactor pressure control,
reactivity control, reactor coolant makeup, decay heat removal, process monitoring,
and support system functions.
The inspectors conducted selected area walkdowns to determine if operators could
reasonably be expected to perform the alternate safe-shutdown procedure actions and
that equipment labeling was consistent with the alternate safe-shutdown procedure.
The review also looked at operator training as well as consistency between the
operations shutdown procedures and any associated administrative controls.
b.
Findings
No findings of safety-significance were identified.
.7
Circuit Analyses
a.
Inspection Scope
In accordance with IP 71111.05TTP, Fire Protection - NFPA 805 Transition Period
(Triennial), dated May 9, 2006, this section of the IP was suspended for facilities in
NFPA 805 transition.
b.
Findings
No findings of safety-significance were identified.
.8
Communications
a.
Inspection Scope
The inspectors reviewed, on a sample basis, the adequacy of the communication
system to support plant personnel in the performance of alternative safe-shutdown
functions and fire brigade duties. The inspectors verified that plant telephones, page
systems, sound powered phones, and radios were available for use and maintained in
working order. The inspectors reviewed the electrical power supplies and cable routing
for these systems to verify that either the telephones or the radios would remain
functional following a fire.
Enclosure
7
b.
Findings
No findings of safety-significance were identified.
.9
a.
Inspection Scope
The inspectors performed a plant walkdown of selected areas in which a sample of
operator actions would be performed in the performance of alternative safe-shutdown
functions. As part of the walkdowns, the inspectors focused on the existence of
sufficient emergency lighting for access and egress to areas and for performing
necessary equipment operations. The locations and positioning of the emergency
lights were observed during the walkdown and during review of manual actions
implemented for the selected fire areas.
b.
Findings
No findings of safety-significance were identified.
.10
Cold Shutdown Repairs
a.
Inspection Scope
The inspectors reviewed the licensees procedures to determine whether repairs were
required to achieve cold shutdown and to verify that dedicated repair procedures,
equipment, and material to accomplish those repairs were available onsite. The
inspectors also evaluated whether cold shutdown could be achieved within the
required time using the licensee's procedures and repair methods. The inspectors also
verified that equipment necessary to perform cold shutdown repairs was available
onsite and properly staged.
b.
Findings
No findings of safety-significance were identified.
.11
Compensatory Measures
a.
Inspection Scope
The inspectors conducted a review to verify that compensatory measures were in
place for out-of-service, degraded or inoperable fire protection and post-fire safe-
shutdown equipment, systems, or features (e.g., detection and suppression systems,
and equipment, passive fire barriers, pumps, valves or electrical devices providing
safe-shutdown functions or capabilities). The inspectors also conducted a review on
the adequacy of short term compensatory measures to compensate for a degraded
function or feature until appropriate corrective actions were taken.
b.
Findings
No findings of safety-significance were identified.
Enclosure
8
4.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution (71152)
a.
Inspection Scope
The inspector reviewed the licensees corrective action program procedures and
samples of corrective action documents to verify that the licensee was identifying issues
related to the fire protection program at an appropriate threshold and entering them in
the corrective action program. The inspectors reviewed selected samples of condition
reports, design packages, and fire protection system non-conformance documents.
b.
Findings
No findings of safety-significance were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)
(Closed)Licensee Event Report (LER) 05000315/2008-002-00: 250Vdc Cable
Separation Criteria for 10 CFR Part 50, Appendix R Not Met
This event, which occurred on February 6, 2008, during the licensees transition to
NFPA 805, a finding of nonconformance and a violation of NRC requirements (see
Section 4OA7), was discovered by the licensee in their Appendix R fire protection
analyses for both units. The finding involved the failure to identify a short section of
Train A 250Vdc conduit enclosed cable passing through the Train B 4kV switchgear
room. The routing of the unprotected conduit enclosed cable presented a potential fire
hazard which, if left unprotected, could disable both the Train B switchgear as-well-as
the remote control to the Train A 4kV switchgear due to fire damaged should a fire occur
in the Train B 4kV switchgear room. As a result, the licensee issued AR00825805,
Appendix R Compliance for Train B 4kV Room Fire. In addition, compensatory fire
watch tours of the affected fire zones were established and remained in effect until
permanent corrective actions were implemented. Permanent corrective action included
wrapping the conduit with a fire retardant material and converting the CO2 suppression
system from manual to automatic in accordance with the requirements of Appendix R,
Section III.G.2.(c). In addition, the applicable design documents were updated to reflect
the installed fire protective material.
The inspectors reviewed the licensees corrective actions for the above described
Appendix R nonconformance finding. The inspectors review of applicable licensee
documents showed that the licensee had established compensatory fire watch tours for
the affected fire zones and that the fire watch tours remained in effect until permanent
corrective actions were implemented. Based on the inspectors review of applicable
modification documents (e.g., EC-48720 and EC-48721) and by independent walkdown
observations, the inspectors concluded that the previously unprotected conduit enclosed
cable was now wrapped with an appropriate fire retardant material (i.e., 3M' Interam)
and that the CO2 suppression system was converted from a manual suppression system
to an automatic suppression system to restore conformance with the requirements of
10 CFR Part 50, Appendix R, Paragraph III.G.2(c) requirements and the licensees
original Appendix R Program assumptions. The inspectors concluded that the licensees
corrective actions, both taken and planned, were appropriate and reasonable.
Enclosure
9
The enforcement aspects of this finding are discussed in Section 4OA7. Documents
reviewed as part of this inspection are listed in the Attachment. This LER is closed.
This event follow-up review constituted one sample as defined in IP 71153-05.
4OA6 Management Meetings
.1
Exit Meeting Summary
On November 20, 2009, the inspectors presented the inspection results to Mr. Larry
Webber and other members of the licensee staff. The licensee acknowledged the issues
presented. The inspectors confirmed that none of the potential report input discussed
was considered proprietary.
4OA7 Licensee-Identified Violations
The following violation of very low safety-significance (Green) was identified by the
licensee and is a violation of NRC requirements which meet the criteria of the NRC
Enforcement Policy, for being dispositioned as a NCV.
Title 10 CFR Part 50, Appendix R, requires, in part, that one train of systems necessary to
achieve and maintain hot shutdown conditions from either the control room or emergency
control station is free of fire damage. On February 6, 2008, the licensee identified an
Appendix R non-compliance (see Section 4OA3), where the Train A 4kV switchgear would
not be free of fire damage to support safe-shutdown in the unlikely event of a postulated
fire in the Train B 4kV switchgear room. The licensee performed a safety-significance
evaluation (i.e., PRA Study 054) and determined that the issue was not of high safety-
significance (i.e., the event had a CDF of 1.93E-7). The inspectors concurred with the
overall results of the licensees evaluation for safety-significance. This finding met the
criteria for enforcement discretion under Interim Enforcement Policy Regarding
Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) published in
Federal Register Notices dated June 16, 2004; January 14, 2005; and April 18, 2006.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Attachment
1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
D. Baker, Mechanical Production Supervisor
L. Bush, Performance Assurance Manager
D. Cobb, Operations Fire Protection Manager
J. Gebbie, Plant Manager
R. Gray, Design Engineering Mechanical (DEM) Fire Protection Program Manager
K. Housh, Fire Protection System Manager
R. Hruby, Site Support Vice President
D. MacDougall, DEM- Fire Protection
B. Mammoser, Design Engineering- Mechanical Supervisor
R. Niedzielski, Regulatory Affairs- Sr. Licensing Coordinator
K. OConnor, Design Engineering Manager
S. Partin, Maintenance Manager
T. Robinson, Learning Organization Department Corrective Action Program Supervisor
M. Scarpello, Regulatory Affairs Manager
L. Webber, Site Vice President
R. Werdann, Design Engineering Director
Nuclear Regulatory Commission
R. Daley, Chief, Engineering Branch 3, Division of Reactor Safety
P. LaFlamme, Resident Inspector
J. Lennartz, Senior Reactor Inspector
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
None
Closed
05000315/2008-002-00
LER
250Vdc Cable Separation Criteria for 10 CFR Part 50
Appendix R Not Met
Discussed
None
Attachment
2
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall
inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the
document or any part of it, unless this is stated in the body of the inspection report.
CALCULATIONS
Number
Description or Title
Date or Revision
MD-12-HV-013-N Hydrogen Generation Calculation
1
P1900-500-001
Unit 1 - 4kV East (AB Switchgear) Room T11A
Switchgear Fire Scenario Analysis
October 15, 2008
TH-04-05
Appendix R RCS Cooldown Analysis Using
RETRAN
1
CORRECTIVE ACTION PROGRAM DOCUMENTS GENERATED DURING INSPECTION
Number
Description or Title
Date or Revision
FPTI - Unauthorized Tape On FP Wall
November 3, 2009
FPTI - Battery Charger Float/Equalize Setting
Discrepancies
November 5, 2009
Pressurizer Heater Procedure Error - FPTI
November 6, 2009
Hot Shutdown Control Described In UFSAR
Out-of-Date
November 13, 2009
Component Numbers Not Recorded On EBL Test
Datasheet
November 17, 2009
Emergency Lighting Aiming Instructions
November 18, 2009
Discovered Data Sheet with Blank Spot for Initial
November 18, 2009
FPTI - TRS 8.7.7.5 Test Pressure Acceptance
Criteria Not Clear
November 19, 2009
Degrade Fire Seal W9097
November 19, 2009
Fire Door 230 Fusible Link - FPTI
November 20, 2009
Open Junction Box, Unit 1 Screen House
November 18, 2009
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
Date or Revision
Minor Corrections to Emergency Remote
Shutdown Procedures
November 11, 2008
Appendix R Compliance for Train B 4kV Room
Fire
February 6, 2008
Repeat Trend in Active Fire Suppression Systems
April 15, 2008
Abandon CO2 Hose Reels No Longer Required by
May 20, 2009
Attachment
3
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
Date or Revision
FP Program
Appendix R Safe-shutdown - Analysis Area 43
September 17, 2009
Noncompliance of NFPA 805 and Lack of
Integrated Project Schedule
August 14, 2009
Appendix R Safe-Shutdown-Analysis Area 43
September 17, 2009
Breaker/Fuse Coordination Engineering
Evaluation
October 17, 2009
CR003092067
Condition Report to Document DC Cook Epoxy
Coating Program Controls
April 2, 2003
CR00816263
Tech Eval 12.7 is Inconsistent w/OPS App R
Procedures
July 18, 2007
DRAWINGS
Number
Description or Title
Date or Revision
12-5973-9
Fire Hazard Analysis Basement Plan EL 591-0
and 5870 Units 1 and 2
9
12-5973-9 REF
Appendix R Hot Standby Equipment and
Emergency Lighting Plan El 591-0 and 587-0
December 29, 2005
12-5974-8 REF
Appendix R Hot Standby Equipment and
Emergency Lighting Plan El 609-0
December 29, 2005
12-5976-8 REF
Appendix R Hot Standby Equipment and
Emergency Lighting Plan El 633-0
December 29, 2005
OP-1-5153-8
Flow Diagram Fire Protection CO2 17 Ton
System Key Plan
8
OP-1-5153E-4
Flow Diagram Fire Protection CO2 Emergency
Diesel and Fuel Oil Transfer Pump Rm Unit 1
and 2
4
OP-1-5153E-5
Flow Diagram Fire Protection CO2 Lower 4kV
Areas Unit 1
5
OP-1-5153K-4
Flow Diagram Fire Protection CO2 Emergency
Diesel and Fuel Oil Transfer Pump Rm Unit 1
and 2
4
OP-1-12001-78
Main Auxiliary One Line Diagram Bus A and B
78
OP-1-12002-62
Main Auxiliary One Line Diagram Bus C and D
62
OP-1-12003-32
250Vdc Main One Line Diagram
32
OP-2-12002-36
Main Auxiliary One Line Diagram Bus C and D
36
Attachment
4
EVALUATION
Number
Description or Title
Date or Revision
PRA Study 054
Cook Unit 1 LER 2008-002-00 Risk Assessment
October 16, 2008
MISCELLANEOUS
Number
Description or Title
Date or Revision
2007-002
Facility Fire Report
November 14, 2007
2009-003
Facility Fire Report
February 27, 2009
AEP:NRC:6054-03
Response to GL 2006-03: Potentially
Nonconforming Hemyc and MT Fire
Barrier Configurations
June 1, 2006
ERS-BKD-4025-001-001 Emergency Remote Shutdown
1
Typical Fire and Pressure and Fire,
Pressure and Radiological Seal Details,
Attachment 1
1
FPCE 2003-0017
Safe-shutdown Capability Assessment
8
LER 2008-002-00
250Vdc Cable Separation Criteria for
10 CFR Part 50 Appendix R Not Met
April 1, 2008
SSCA
Safe-shutdown Capability Assessment
14
Test Plan CTP-1199
One Hour Fire Endurance Test 3M'
Interam Fire Wrap
0
UFSAR, Chapter 1
Section 1.4.1, Criterion 11, Control Room
22.1
UFSAR, Chapter 7
Section 7.7.8, Hot Shutdown Control
22
UFSAR, Chapter 7
Section 7.7.10, Local Shutdown and
Cooldown Station
22
MODIFICATIONS
Number
Description or Title
Date or Revision
DIT-B-03318-00
Appendix R Operator Action Times
None
Install Fire Wrap on Conduit U1
FCN-003
Install Fire Wrap on Conduit U2
FCN-004
PROCEDURES
Number
Description or Title
Date or Revision
1-OHP-4021-082-006
Operation of 1AB and 1CD Battery
Chargers
11
1-OHP-4024-101
Composite
Annunciator No. 101 Response: Plant Fire
System
21
1-OHP-4025-R-Index
System Restoration Procedures Index
2
Attachment
5
PROCEDURES
Number
Description or Title
Date or Revision
1-OHP-4025-R-1
Restore Pressurizer Heaters
2
1-OHP-4030-101-044
Unit One LSI Panel Surveillance
4
1-OHP-5030-APR-001
Appendix R Toolbox and Ladder Inventory
3
2-OHP-4025-001-001
Emergency Remote Shutdown
6 and 7
2-OHP-4025-LS-1
Process Monitoring from LSI Panels
3
2-OHP-4025-LS-2
Start-Up AFW
2
2-OHP-4025-LTI-2
Local Main Steam Isolation
3
2-OHP-4025-LTI-4
Local RCP Trip and Isolation
2
2-OHP-4025-LTI-7
Local Pressurizer Heater Trip and Isolation
2
2-OHP-4025-R-1
Restore Pressurizer Heaters
2
2-OHP-4030-201-044
Unit Two LSI Panel Surveillance
4
2-OHP-4030-214-031,
Attachment 1
Operations Weekly Surveillance Checks
Unit Two Hot Shutdown Panel Switch
Position Checklist
17
2-OHP-4030-214-049,
Attachment 14
Hot Shutdown Panel Operability Test
Steam Generator PORV Operability Test
6
2-OHP-5030-APR-001
Appendix R Toolbox and Ladder Inventory
4
12-EHP-5070-BPI-001
Buried Pipe Inspection and Mitigation
Program
1
12-FFP-2270-066-001
Portable Fire Extinguisher Inspections
9
12-FFP-2270-066-002
Establishment of Backup Fire Protection
Water Supplies
2
12-FFP-4030-066-016
Inspection of Thermo-lag, Darmatt and
Mecatiss Wrapped Enclosures And 3M'
Interam Material
1
12-FFP-4030-066-023
Test and Inspections of Plant Fire Hose
Standpipe Stations
2
12-FFP-4030-066-024
Hydrostatic Testing and Re-Rack of Fire
Hose
2
12-FFP-4030-066-205
Fire Detection Instrumentation Channel
Operational Test
0
12-IHP-4030-082-001
AB, CD and N-Train Battery Weekly
Surveillance and Maintenance
15
12-IHP-5021-EMP-009
Battery Cell Charging
6
12-IHP-5030-EMP-010
Emergency Battery Light Units
16
12-IHP-5040-EMP-011
Pressurizer Backup Heaters Temporary
Power
1
12-OHP-4025-001-002
Fire Response Guidelines
3
PMP-5055-001-001
Winterization/Summerization
10
Attachment
6
TRAINING DOCUMENTS
Number
Description or Title
Date or Revision
AE-C-03202 LP
Emergency Diesel Generators - Refresher
0
AE-C-03202
Course Attendance History
November 5, 2009
Image Title 1-LSI-1 Visual Component Database
April 16, 2002
Image Title 1-LSI-2 Visual Component Database
August 12, 2002
Image Title 1-LSI-3 Visual Component Database
January 16, 1990
Image Title 1-LSI-4 Visual Component Database
January 16, 1990
Image Title 1-LSI-5 Visual Component Database
April 16, 2002
Image Title 1-LSI-6 Visual Component Database
August 12, 2002
RELLP-RQ-C-3244 RQ-C-3244 Appendix R Equipment and
Procedures
0
RQ-C-3244
Course Attendance History
November 5, 2009
RO-C-EC01 LP
Appendix R Equipment
7
RO-C-EC01
Objective Slides
None
RO-C-EC01
Course Attendance History
November 5, 2009
RO-C-EC02 LP
Appendix R Procedures
6
RO-C-EC02
Course Attendance History
November 5, 2009
UO-C-ER01 LP
Emergency Response
4
UO-C-ER01
Course Attendance History
November 5, 2009
WORK DOCUMENTS
Number
Description or Title
Date or Revision
55239216
Perform Appendix R Batlit Discharge
July 23, 2008
55273991
Perform Appendix R Batlit Discharge
February 28, 2008
55288640 01
U1 CD Diesel Generator CO2 Fire Suppression
September 3, 2008
55289542 01
U1 East (CD) and West (AB) 4kV Switchgear
CO2 Suppression
October 23, 2008
55315940 01
Inspection of Fire Doors, Frames and Their
Hardware
September 17, 2008
55327998 01
Inspection of Fire Doors, Frames and Their
Hardware
March 27, 2009
55336682
Perform PM Inspection on Appendix R
August 17, 2009
55337578
Perform PM Inspection on Appendix R Lights
September 2, 2009
Attachment
7
LIST OF ACRONYMS USED
Agencywide Documents Access and Management System
Action Request
Core Damage Frequency
CFR
Code of Federal Regulations
Carbon Dioxide
dc or DC
Direct Current
Design Engineering Mechanical
DIT
Design Information Transmittal
Division of Reactor Projects
Division of Reactor Safety
Emergency Battery Light
Emergency Power System
Fire Protection
Fire Protection Triennial Inspection
GL
Generic Letter
IMC
Inspection Manual Chapter
IP
Inspection Procedure
Individual Plant Examination of External Events
IR
Inspection Report
LER
Licensee Event Report
LSI
Local Shutdown Instrumentation
Mecatiss
Non Cited Violation
National Fire Protection Association
NRC
U.S. Nuclear Regulatory Commission
Publicly Available Records
Preventative Maintenance
Power-Operated Relief Valve
Reactor Coolant Pump
RETRAN
Thermalhydraulic Computer Code
Reactor Oversight Process
Significance Determination Process
Senior Reactor Analyst
Updated Final Safety Analysis Report
V
Volt
J. Jensen
-2-
Chapter (IMC) 0305. Therefore, we are exercising enforcement discretion to not cite this violation in
accordance with the NRC's Enforcement Policy. If you disagree with the characterization of this finding,
you should provide a response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC
20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement,
United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident
Inspector at the Donald C. Cook Nuclear Power Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and
your response (if any), will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide
Documents Access and Management System (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-315; 50-316
Enclosure:
Inspection Report 05000315/2009006(DRS); 05000316/2009006(DRS)
w/Attachment: Supplemental Information
cc w/encl:
Distribution via ListServ
Distribution
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DOCUMENT NAME: G:\\DRS\\Work in Progress\\DCC 2009 006 DRS GMH.doc
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Non-Publicly Available
Sensitive
Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE
RIII
E RIII
NAME
GHausman:ls RDaley
DATE
12/15/09
12/15/09
OFFICIAL RECORD COPY
Letter to Mr. Joseph Jensen from Mr. Robert C. Daley dated December 15, 2009.
SUBJECT:
DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2
NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REPORT 05000315/2009006(DRS); 05000316/2009006(DRS)
AND EXERCISE OF ENFORCEMENT DISCRETION
DISTRIBUTION:
Susan Bagley
RidsNrrDorlLpl3-1 Resource
RidsNrrPMDCCook Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
DRPIII
DRSIII
Patricia Buckley
ROPreports Resource