ML103090613
| ML103090613 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/05/2010 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Heacock D Dominion Resources |
| References | |
| EA-10-175, FOIA/PA-2011-0115 IR-10-008, IR-10-009 | |
| Download: ML103090613 (43) | |
See also: IR 05000336/2010008
Text
Mr. David Heacock
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415
November 5, 2010
President and Chief Nuclear Officer
Dominion Resources
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
SUBJECT:
MILLSTONE POWER STATION - NRC TRIENNIAL FIRE PROTECTION
INSPECTION REPORT 05000336/2010008 AND 05000423/2010008 AND
NOTICE OF VIOLATION AND TEMPORARY INSTRUCTION 2515/181
INSPECTION REPORT 05000336/2010009
Dear Mr. Heacock:
On September 22,2010, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Millstone Power Station Unit 2 and Unit 3. In addition to the triennial fire
protection inspection results, these inspection reports also document the results of an inspection
performed on Unit 2 in accordance with Temporary Instruction (TI) 2515/181, "Validate the
Effectiveness of the Regulatory Infrastructure Related to Fire Induced Circuit Failures and
Operator Manual Actions. The preliminary results of these inspections were discussed on
August 5,2010, with Mr. A. J. Jordan and other members of your staff. Following additional in-
office and on-site reviews an exit meeting was conducted by telephone with Mr. A. J. Jordan
and other members of your staff on September 22, 2010.
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.
In conducting the inspection, the team reviewed selected procedures, calculations and records,
observed activities, and interviewed station personnel.
One violation is cited in the enclosed Notice of Violation and the circumstances surrounding it
are described in detail in the subject inspection report. The violation was evaluated in
accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on
the NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
The violation involved the use of unapproved manual operator actions to mitigate post-fire safe
shutdown equipment malfunctions caused by a single spurious actuation on Millstone Unit 2, in
lieu of protecting the equipment in accordance with 10 CFR Part 50 Appendix R, Section III.G.2
(EA-10-175). Although determined to be of very low safety significance (Green), this violation is
being cited in the Notice because not all of the criteria specified in section 2.3.2.a of the NRC
Enforcement Policy for a noncited violation were satisfied. Specifically, Dominion Nuclear
Connecticut, Inc. failed to restore compliance within a reasonable amount of time after the
violation was identified in condition report 119114 in November 2008. You are required to
D. Heacock
2
respond to this letter and should follow the instructions specified in the enclosed Notice when
preparing your response. The NRC will use your response, in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
One additional finding of very low safety significance (Green) was also identified. This finding
was also determined to be a violation of NRC requirements. However, because of the very low
safety significance, and because the issue was entered into your corrective action program, the
NRC is treating this finding as a non-cited violation (NCV) consistent with section 2.3.2.a of the
NRC Enforcement Policy. If you contest the NCV in this report, you should provide a written
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 D.C.
20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of
Enforcement; and the NRC Senior Resident Inspector at Millstone. In addition, if you disagree
with the characterization of any finding in this report, you should provide a response within
30 days of the date of this inspection report, with the basis for your disagreement, to the
Regional Administrator, .Region I, and the Senior Resident Inspector at Millstone. The
information you provide will be considered in accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response will be available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of the
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room). To the extent
possible, your response should not include any personal privacy, proprietary, or safeguards
information so that it can be made available to the Public without redaction.
Docket Nos:
50-336,50-423
Enclosures:
Sincerely,
John F. Rogge, Chief
Engineering Branch 3
Division of Reactor Safety
2. Inspection Report 05000336/2010008; 05000423/2010008; and,
w/Attachment: Supplemental Information
cc w/encl:
Distribution via ListServ
D. Heacock
2
respond to this letter and should follow the instructions specified in the enclosed Notice when
preparing your response. The NRC will use your response, in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
One additional finding of very low safety significance (Green) wasoalso identified. This finding
was also determined to be a violation of NRC requirements. However, because of the very low
safety significance, and because the issue was entered into your corrective action program, the
NRC is treating this finding as a non-cited violation (NCV) consistent with section 2.3.2.a of the
NRC Enforcement Policy. If you contest the NCV in this report, you should provide a written
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 D.C.
20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of
Enforcement; and the NRC Senior Resident Inspector at Millstone. In addition, if you disagree
with the characterization of any finding in this report, you should provide a response within
30 days of the date of this inspection report, with the basis for your disagreement, to the
Regional Administrator, Region I, and the Senior Resident Inspector at Millstone. The
information you provide will be considered in accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response will be available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of the
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room). To the extent
possible, your response should not include any personal privacy, proprietary, or safeguards
information so that it can be made available to the Public without redaction.
Docket Nos:
50-336,50-423
Enclosures:
Sincerely,
IRA!
John F. Rogge, Chief
Engineering Branch 3
Division of Reactor Safety
2. Inspection Report 05000336/2010008; 05000423/2010008; and,
w/Attachment: Supplemental Information
cc w/encl:
Distribution via ListServ
ADAMS ACCESSION: ML 103090613
SUNSI Review Complete:
JFR
(Reviewer's Initials)
DOCUMENT NAME: Y:\\Division\\DRS\\Engineering Branch 3\\Scholl\\MS 2010-08 Fire Report Finaldb.docx
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DATE
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DATE
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OFFICIAL RECORD COPY
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RidsNRRPM Millstone Resource
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ROPreportsResource@nrc.gov
Dominion Nuclear Connecticut, Inc.
Millstone Nuclear Station, Unit 2
Docket No: 50-336
License No: DPR-65
During an NRC inspection conducted July 19 through September 22, 2010, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
License Condition 2.C.(3) specifies, in part, Dominion shall implement and maintain in effect
all provisions of the approved fire protection program as described in the Final Safety
Analysis Report and as approved in the Safety Evaluation Report (SER) dated
September 19, 1978, and a supplement dated July 17, 1990.
The Final Safety Analysis Report, Section 9.10.6 specifies that Dominion will meet the
requirements of 10 CFR Part 50, Appendix R, Section III.G.2, which requires, in part, except
as provided for in paragraph G.3 of this section, 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 means of ensuring that one of the redundant trains is free
of fire damage shall be provided, per the requirements in G.2.a-G.2.f.
Contrary to the above, through September 22, 2010, Dominion failed to implement all
provisions of the approved fire protection program as described in the Final Safety Analysis
Report and as approved in the SER dated September 19, 1978, and a supplement dated
July 17, 1990. Specifically, the safe shutdown strategy for Millstone Unit 2 relied upon
unapproved manual operator actions to mitigate post-fire safe shutdown equipment
malfunctions caused by a single spurious actuation, in lieu of protecting the equipment in
accordance with 10 CFR Part 50 Appendix R, Section III.G.2, per the requirements in G.2.a-
G.2.f. The use of manual actions in lieu of providing the required protection requires prior
NRC approval. Dominion had not requested or received NRC approval for the use of
manual actions affecting components that included the following: charging header
containment isolation valve 2-CH-249, steam generator main steam isolation valves
2-MS-64A1B, steam generator blowdown control valves 2-MS-220AlB, charging system
isolation valve 2-CH-192, auxiliary feedwater flow control valves 2-FW-43 AlB and turbine
driven auxiliary feedwater pump 2-FW-P4.
This violation is associated with a Green Significance Determination Finding.
Pursuant to the provisions of 10 CFR 2.201, Dominion Nuclear Connecticut, Inc. is hereby
required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is
the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of
Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation;
EA 10-175" and should include for each violation: (1) the reason for the violation, or, if
Enclosure 1
2
contested, the basis for disputing the violation or severity level, (2) the corrective steps that
have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the
date when full compliance will be achieved. Your response may reference or include previous
docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a
Demand for Information may be issued as to why the license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken. Where
good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRC's document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html. to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 5th day of November, 2010
Enclosure 1
Docket Nos:
License Nos:
Report Nos:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
50-336,50-423
05000336/2010008; 05000423/2010008; and
Dominion Nuclear Connecticut, Inc.
Millstone Power Station, Units 2 and 3
P.O. Box 128
Waterford, CT 06385
July 19 through September 22, 2010
L. Scholl, Senior Reactor Inspector (Team Leader)
W. Schmidt, Senior Reactor Analyst
G. Replogle, Region IV, Senior Reactor Analyst
J. Richmond, Senior Reactor Inspector
R. Fuhrmeister, Senior Reactor inspector
M. Patel, Reactor Inspector
E. Huang, Reactor Inspector
J. Rady, Reactor Inspector
G. Pick, Region IV, Senior Reactor Inspector
D. Frumkin, NRR (Observer)
G. Cooper, NRR (Observer)
John F. Rogge, Chief
Engineering Branch 3
Division of Reactor Safety
Enclosure 2
SUMMARY OF FINDINGS
IR 05000336/2010008,05000423/2010008, and 05000336/2010009; 07/19/2010 - 09/22/2010;
Millstone Power Station, Units 2 and 3; Triennial Fire Protection and Millstone Power Station,
Unit 2; Temporary Instruction 2515/181 Inspection.
These reports covered an initial two week on-site triennial fire protection team inspection and a
one week on-site inspection of regulatory infrastructure related to fire-induced circuit failures
and operator manual actions by NRC Regions I and IV specialist inspectors. Additional in-office
and site inspections were performed following the initial inspection. One cited and one non-
cited finding of very low significance (Green) was 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)." The cross-cutting aspects were
determined using IMC 0305, "Operating Reactor Assessment Program." 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 4, dated
December 2006.
A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. The team identified a non-cited violation of Millstone Unit 2 Operating License
Condition 2.C.(3), and Unit 3 Operating License Condition 2.H, for the failure to
implement all provisions of the approved Fire Protection Programs. Specifically,
Dominion did not implement adequate review, approval and distribution of fire fighting
strategies to provide for the adequate development and maintenance of effective
strategies. As a result, the team found that Dominion did not provide adequate guidance
in the fire fighting strategies for several areas that included the Unit 2 "8" emergency
diesel generator (EDG) room, and the Unit 3 west switchgear room. This issue was
entered into Dominion's corrective action program as condition report (CR) 388786.
The team determined that the failure to administratively control fire fighting strategies as
required by the fire protection program was a performance deficiency. This finding was
more than minor because it adversely affected the availability and capability objectives
of the protection against external events (i.e., fire) attribute under the Mitigating Systems
Cornerstone. Specifically, the above examples would likely cause delays in manual fire
fighting activities and, therefore, adversely affected the defense-in-depth aspect of the
fire protection program to limit fire damage by quick suppression of those fires that
occur. The team performed a Phase 1 SDP screening, in accordance with NRC
IMC 0609, Appendix F, "Fire Protection Significance Determination Process." This
finding affected fire prevention and administrative controls, and was screened to very
low safety significance (Green) because this failure to control fire fighting strategies was
determined to represent a low degradation rating. This finding had a cross-cutting
aspect in the area of human performance because Dominion failed to ensure complete
and accurate fire fighting strategies were available to the fire brigade to support timely
extinguishment of fires. H.2(c) (Section 1 R05.03)
ii
Enclosure 2
Green. The team identified a cited violation of 10 CFR Part 50, Appendix R,
Section III.G.2 for the failure to protect required post-fire safe shutdown components and
cabling to ensure one of the redundant trains of equipment remains free from fire
damage. In lieu of providing the required separation, Dominion utilized unapproved
operator manual actions to mitigate component malfunctions or spurious operations
caused by a single fire induced circuit fault (hot short, open circuit or short to ground).
Dominion has entered this issue into the corrective program for resolution. The team
found the manual actions to be reasonable interim compensatory measures pending
final resolution by Dominion.
Dominion's failure to protect components credited for post-fire safe shutdown from fire
damage caused by single spurious actuation is considered a performance deficiency.
The performance deficiency was more than minor because it affected the Mitigating
Systems cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to an external event to prevent undesirable consequences in the
event of a fire. Specifically, the use of operator manual actions during post-fire
shutdown is not as reliable as normal systems operation which could be utilized had the
separation requirements of 10 CFR 50, Appendix R, Section III.G.2 been met and
therefore prevented fire damage to credited components and/or cables. The team used
IMC 0609, Appendix F, "Rre Protection Significance Determination Process (SDP),"
Phase 1 and an SRA conducted Phase 3 evaluation, to determine that this finding was
of very low safety significance (Green). The team determined the finding had a low
degradation rating because the manual actions were reviewed by the team and were
found to be acceptable interim compensatory measures (pending licensee actions to
resolve the non-compliances or obtain exemptions) because they did not require
complicated actions, adequate time was available to accomplish the actions and the
actions were properly included in the appropriate abnormal operating procedures. This
finding had a cross cutting aspect in the area of problem identification and resolution
associated with the corrective action program because Dominion did not completely and
accurately identify deficiencies related to single spurious actuations of credited post-fire
safe shutdown components. [P.1.(a)] (Section 1 R05.06)
B.
Licensee-Identified Violations
None.
iii
Enclosure 2
REPORT DETAILS
Background
This report presents the results of a triennial fire protection inspection conducted in accordance
with NRC Inspection Procedure (IP) 71111.05T, "Fire Protection." The objective of the
inspection was to assess whether Dominion Nuclear Connecticut, Inc. (Dominion) had
implemented an adequate fire protection program and whether post-fire safe shutdown
capabilities had been established and were properly maintained at Millstone Power Station
Unit 2 and Unit 3 (Millstone). The following fire areas and fire zones were selected for detailed
review based on risk insights from the Millstone Individual Plant Examination of External Events,
past inspection results, recent operational experience, and resident inspector input:
Unit 2 Fire Areas / Fire Zones
R-1 / A-1B, Reactor Building Closed Cooling Water (RBCCW) Pump & Heat Exchanger
Area
R-2 / T-10, Upper 4 kV Switchgear (SWGR)
R-8 / A-16, "B" EDG Room
R-13 / T-6, West 480 Volt Load Center Room
Unit 3 Fire Areas / Fire Zones
AB-5, East Motor Control Center and Rod Control Area
CB-1, West SWGR Area
CB-7, Battery Room 5
CB-8, Cable Spreading Area
Inspection of these fire areas/zones fulfilled the inspection procedure requirement to inspect a
minimum of three samples on each unit.
The team evaluated Dominion's fire protection program (FPP) against applicable requirements
which included Unit 2 Operating License Conditions 2.C.(3) and 2.C.(13), Unit 3 Operating
License Conditions 2.C.(10) and 2.H, NRC Safety Evaluation Reports (SERs), 10 CFR 50.48,
10 CFR 50 Appendix R, and the NRC Branch Technical Position (BTP) Chemical Engineering
Branch (CMEB) 9.5-1. The team also reviewed related documents that included the Updated
Final Safety Analysis Report (UFSAR), Fire Protection Program, Fire Hazards Analyses (FHA),
and post-fire Safe Shutdown Analyses Reports.
Section 4.0.A.5.2 presents the results of an inspection of Unit 2 conducted in accordance with
Temporary Instruction (TI) 2515/181, 'Validate the Effectiveness of the Regulatory Infrastructure
Related to Fire Induced Circuit Failures and Operator Manual Actions:'
Specific documents reviewed by the team are listed in the attachment to this report.
Enclosure 2
2
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1 R05 Fire Protection (IP 71111.05T)
.01
Protection of Safe Shutdown Capabilities
a.
Inspection Scope
The team reviewed the FHA, safe shutdown analyses, and supporting drawings and
documentation, to evaluate the fire protection of safe shutdown equipment and
capabilities. The team compared the separation requirements described in the UFSAR
and in 10 CFR 50, Appendix R, Section III.G to the designed and installed fire protection
features for credited safe shutdown equipment, including their supporting power, control,
and instrumentation cables to assess the protection adequacy of safe shutdown
capabilities. The team's review included an assessment of the adequacy of the selected
systems for reactivity control, reactor coolant makeup, reactor heat removal, process
monitoring, and associated support system functions.
The team reviewed procedures and programs for the control of ignition sources and
transient combustibles to assess their effectiveness in preventing fires and in controlling
combustible loading less than the analyzed limits established in the FHA. The team
reviewed selected hot work permits, transient combustible control, and fire protection
program evaluations to assess the adequacy of the fire protection program
administrative controls. During plant walkdowns, the team observed permanent and
transient combustible loading and potential ignition sources to independently verify
whether the installed protective features were being properly maintained and
administrative controls were being adequately implemented.
b.
Findings
No findings were identified .
. 02
Passive Fire Protection
a.
Inspection Scope
The team walked down accessible portions of the selected fire areas to evaluate
whether the observed material conditions of the fire area boundaries were adequate for
the fire hazards in the area. The team compared the fire area boundaries, including
walls, fire doors, fire dampers, penetration fire barrier seals, electrical raceway fire
barriers, and redundant equipment fire barriers to design basis requirements, industry
standards, and the Millstone FPP, as approved by the NRC, to identify any potential
degradation or non-conformances.
The team reviewed selected engineering evaluations, installation work orders, and
qualification records for a sample of penetration fire barrier seals to determine whether
Enclosure 2
3
the fill material was properly installed and whether the as-left configuration satisfied
design requirements for the intended fire rating. For Unit 2, there were no credited fire
protection wraps in the selected fire areas.
In addition, the team reviewed the most recent test results for fire damper functionality
tests and inspection records of penetration fire barrier seals and fire separation barriers
for the selected fire areas, to verify whether the inspection and testing was adequately
conducted, the acceptance criteria were met, and any potential performance degradation
was identified.
b.
Findings
No findings were identified .
. 03
Active Fire Protection
a.
Inspection Scope
The team evaluated the fire detection and suppression systems in the selected fire areas
to determine whether they were installed, tested, maintained, and operated in
accordance with NRC requirements and approved exemptions, National Fire Protection
Association (NFPA) codes of record, and the fire protection program, as approved by the
NRC. The team also assessed whether the suppression systems capabilities were
adequate to control and/or extinguish fires associated with the hazards in the selected
areas. The team reviewed initial discharge testing, design specifications, modifications,
and engineering evaluations for Unit 3 carbon dioxide (C02) suppression systems for the
west switchgear room, east motor control center and rod control area, and cable
spreading room. The team also reviewed and walked down the associated fire fighting
strategies and CO2 system operating procedures.
The team reviewed the design capability of the fire water supply system to verify whether
the design basis and NFPA code requirements for the hazards involved were adequately
satisfied. The team reviewed the fire water system hydraulic analyses and assessed the
adequacy of the underground fire loop flow tests to verify whether the tests adequately
demonstrated that the flow distribution circuits were able to meet design basis
requirements. The team evaluated the motor-driven and diesel-driven fire pump
capacity tests to assess the adequacy of the test acceptance criteria. In addition, the
team reviewed the most recent pump and loop flow test results to verify whether the
testing was adequately conducted, the acceptance criteria were met, and any potential
performance degradation was identified.
The team walked down accessible portions of the detection and suppression systems in
the selected areas and major portions of the fire water supply system, including motor
and diesel driven fire pumps, fire water storage tank, interviewed system and program
engineers, and reviewed selected open condition reports (CRs) to assess the material
condition of the systems and components. In addition, the team reviewed the most
recent test results
Enclosure 2
4
for the Unit 2 "B" emergency diesel generator (EDG) room deluge system, and for the
smoke and heat detectors for the selected fire areas, to verify whether the testing was
adequately conducted, the acceptance criteria were met, and any potential performance
degradation was identified.
The team assessed the fire brigade capabilities by reviewing training, qualification, and
drill critique records. In addition, the team interviewed fire brigade members, fire brigade
leaders, a fire brigade advisor, and the site Fire Marshall, to better assess the site fire
fighting capabilities. The team reviewed Dominion's fire fighting strategies (Le., pre-fire
plans) and smoke removal plans for the selected fire areas to determine if appropriate
information was provided to fire brigade members and plant operators to identify safe
shutdown equipment and instrumentation, and to facilitate suppression of a fire that
could impact post-fire safe shutdown capability. The team independently inspected the
fire brigade equipment, including personnel protective gear (e.g., turnout gear) and
smoke removal equipment, to determine operational readiness for fire fighting.
b.
Findings
Introduction. The team identified a finding of very low safety significance (Green),
involving a non-cited violation of Millstone Unit 2 Operating License Condition 2.C.(3),
and Unit 3 Operating License Condition 2.H, to implement and maintain all aspects of
the approved fire protection programs (FPPs), in that Dominion had not adequately
controlled fire fighting strategies as required by the FPPs. Specifically, Dominion did not
implement adequate review, approval and controlled distribution of fire fighting strategies
to provide for the adequate development and maintenance of effective strategies. As a
result, the team determined that the guidance in the fire fighting strategies for several
Unit 2 and 3 fire areas would likely result in a delay in manual fire suppression activities.
Description. The team reviewed eight fire fighting strategies, and identified multiple
issues with the strategies. The team determined that the fire fighting strategies were not
controlled as required by CM-AA-FPA-1 00, "Fire Protection/Appendix R (Fire Safe
Shutdown) Program," and CM-AA-FPA-102, "Fire Protection and Fire Safe Shutdown
Review and Preparation Process and Design Change Process." Specifically,
CM-AA-FPA-102, Attachment 12A, required Dominion to maintain effective fire fighting
strategies, including review, approval, and controlled distribution of fire fighting
strategies. The team identified that fire fighting strategies were being updated and
informally distributed by the site Fire Marshall in lieu of the implementation of appropriate
independent reviews, approvals, and controlled distribution.
Unit 2 Issues
The team reviewed the fire fighting strategy and the relevant fire zone design features
for Unit 2 fire zone A-16, the "B" EDG room. The team noted that the",t{'and "B" EDG
rooms shared a common ventilation system that included fan F-27 to circulate air
between the two rooms. The team also noted that the fire detection systems in the two
rooms utilize heat detectors and that normal personnel access to the "B" room is via the
'~room. Based on the ventilation, fire detection (Le., heat vs. smoke detection) and
personnel access design features, the team concluded that the first indication of a fire, in
Enclosure 2
5
particular a small or slowly developing fire, in the "B" EDG room would likely be the
observation of smoke in the "A" EDG room. The team identified that the fire fighting
strategy did not alert the fire brigade to the possibility that smoke in the "A" EDG room
could be due to a fire in the "B" EDG room, did not provide any guidance regarding
operations of recirculation fan F-27, and did not provide any guidance for additional fire
location diagnostics, such as early verification of conditions in adjacent areas. The team
also noted that the fire fighting strategy for EDG rooms did not provide guidance for
operators to consider securing of a running EDG prior to initiation of manual suppression
activities.
The team also identified an inconsistency in the fire fighting strategy for the Unit 2 west
480V load center room, in that the strategy did not appropriately identify the fire
suppression equipment. Specifically, the strategy's "Fire Suppression Capabilities"
section specified one specific fire hose station that included a hose that was not long
enough to reach the areas covered by the specific strategy, while the "Initial Actions"
section listed a different hose station that did include a hose of sufficient length.
As a result, the team determined that manual suppression in these Unit 2 areas could
reasonably be delayed as a result of the fire fighting strategy deficiencies.
Unit 3 Issues
The team reviewed the fire fighting strategy for Unit 3 fire zone CB-1, west switchgear
room, and determined that the strategy provided inadequate guidance for manual
discharge of CO2. The strategy for the west switchgear room provided instructions for
aligning fire dampers prior to initiating the CO2 suppression system. However, the
section of the strategy erroneously referred to the damper alignment as if the strategy
was dealing with a fire in the east switchgear room. In addition, the team discussed this
issue with a fire brigade leader and interviewed a fire brigade advisor. The team
determined that the information provided in the strategy, which referenced both west and
east switchgear rooms, was sufficiently inconsistent and misleading to result in the
brigade members delaying the initiation of the CO2 suppression system until they could
verify the damper operation instructions were correct.
The team also identified an error in the fire fighting strategy for the Unit 3 main
transformer area, in that the specified fire hydrant for manual fire fighting had been
removed by a modification, and a new hydrant, installed in an adjacent area, was not
listed.
As a result, the team determined that manual suppression in these Unit 3 areas could
reasonably be delayed as a result of the fire fighting strategy deficiencies.
Analysis. The team determined that the failure to control fire fighting strategies as
required by the fire protection program was a performance deficiency. Specifically,
CM-AA-FPA-100 and CM-AA-FPA-102 required Dominion to maintain effective fire
fighting strategies, and required review, approval, and controlled distribution of fire
fighting strategies. As a result, Dominion had not provided fully effective guidance in the
Enclosure 2
6
fire fighting strategies for the Unit 2 "B" EDG room, and the Unit 3 west switchgear room,
such that delays in manual fire fighting activities would likely occur.
This finding was more than minor because it adversely affected the availability and
capability objectives of the protection against external events (Le., fire) attribute under
the Mitigating Systems Cornerstone. Specifically, the above examples would likely
cause delays in manual fire fighting activities and, therefore, adversely affected the
defense-in-depth aspect of the fire protection program to limit fire damage by quick
suppression of those fires that occur. The team performed a Phase 1 SDP screening, in
accordance with NRC IMC 0609, Appendix F, "Fire Protection Significance
Determination Process." This finding affected fire prevention and administrative
controls, and was screened to very low safety significance (Green) because this failure
to control fire fighting strategies was determined to represent a low degradation rating.
A low degradation rating was assigned because there was only a minimum impact to the
performance of manual fire fighting activities, such that those activities were expected to
display nearly the same level of effectiveness and reliability as they would have the
degradation not been present. In addition, this issue did not affect the likelihood that a
fire might occur. The team concluded that this performance deficiency was reasonably
within Dominion's ability to foresee and prevent.
This finding had a cross-cutting aspect in the area of Human Performance, Resources
component, because Dominion failed to ensure complete and accurate fire fighting
strategies were available to the fire brigade to support timely extinguishment of fires.
[H.2.(c)]
Enforcement. Unit 2 License Condition 2.C.(3), and Unit 3 License Condition 2.H, in
part, require that Dominion implement and maintain in effect all provisions of the
approved FPP as described in the Final Safety Analysis Report. Dominion's FPP as
implemented by CM-AA-FPA-100 and CM-AA-FPA-102 require the maintenance of
effective fire fighting strategies, through a program that includes appropriate review,
approval, and controlled distribution of fire fighting strategies. Contrary to above, fire
fighting strategies for Unit 2 and 3 were not controlled as required by Dominion's Fire
Protection Program. Because this finding was of very low safety significance (Green)
and was entered into Dominion's corrective action program (CR 388786), this violation is
being treated as a non-cited violation (NCV), consistent with section 2.3.2.a. of the NRC
Enforcement Policy. NCV 05000336/2010008*01; 05000423/2010008*01, Failure to
Properly Control Fire Fighting Strategies.
Enclosure 2
7
.04
Protection from Damage from Fire Suppression Activities
a.
Inspection Scope
The team walked down the selected fire areas and adjacent areas, and reviewed
selected documents to determine whether redundant safe shutdown trains could be
potentially damaged from fire suppression activities or from the rupture or inadvertent
operation of fire suppression systems. Specifically, to determine whether a potential
existed to damage redundant safe shutdown trains, the team evaluated whether:
A fire in one of the selected fire areas would not release smoke, heat, or hot
gases that could cause unintended activation of suppression systems in adjacent
fire areas which could potentially damage all redundant safe shutdown trains;
A fire suppression system rupture, inadvertent actuation, or actuation due to a
fire, in one of the selected fire areas, could not directly damage all redundant
trains (e.g., sprinkler caused flooding of other than the locally affected train); and,
Adequate drainage was provided in areas protected by water suppression
systems.
b.
Findings
No findings were identified .
. 05
Alternative Shutdown Capability
a.
Inspection Scope
Methodology
The team reviewed the safe shutdown analysis, operating procedures, piping and
instrumentations drawings (P&IDs), electrical drawings, the UFSAR, and other
supporting documents to evaluate whether Dominion could achieve and maintain hot
and cold shutdown from outside the control room, for fire scenarios that rely on a
shutdown methodology from outside the control room. The team assessed Dominion's
ability to shutdown the plant from outside the control room both with and without the
availability of offsite power. Plant walkdowns were also performed to independently
verify whether the plant configuration was consistent with that described in the FHA and
safe shutdown analysis. The team's review focused on systems selected for reactivity
control, reactor coolant make-up, reactor decay heat removal, process monitoring
instrumentation, and support system functions to assess the adequacy of the selected
systems. In addition, the team assessed the systems and components credited for use
during the shutdown to determine whether they would remain free from fire damage.
The team reviewed the transfer of control from the control room to the alternative
shutdown locations to verify whether it would be affected by fire-induced circuit faults
(e.g., by the provision of separate fuses and power supplies for alternative shutdown
control ci rcu its).
Enclosure 2
8
Similarly, for fire scenarios that relied on a shutdown from the control room, the team
also evaluated the shutdown methodology to verify the adequacy of the selected
components and systems to achieve and maintain safe shutdown conditions.
Operational Implementation
The team reviewed the training program for licensed and non-licensed operators to
assess training adequacy for alternative shutdown systems and procedures. In addition,
the team evaluated operator minimum shift staffing requirements to verify whether an
adequate number of operators were available on-site at all times, exclusive of those
assigned as fire brigade members, to perform fire related safe shutdown activities using
either the normal or alternative shutdown systems.
The team reviewed the procedures utilized for post-fire safe shutdown, walked down key
equipment and control stations, and performed a tabletop walk through of selected
procedure steps to independently assess human factor elements and procedure
adequacy. The team also evaluated the available time to assess whether operators
could reasonably perform the specific actions needed to maintain plant parameters
within specified limits. Specifically, the team evaluated the time critical operator actions
to restore alternating current (AC) electrical power, transfer operational command and
control from the main control room to the remote shutdown panel, establish reactor
coolant make-up, and establish decay heat removal.
The team reviewed selected operator manual actions to determine whether Dominion
had adequately validated and verified that the actions could be implemented in
accordance with approved procedures, and in the time necessary to support the safe
shutdown method for each fire area. In addition, the team reviewed the most recent test
results for alternative shutd'own transfer capability, and instrumentation and control
functions, to verify whether the testing was adequately conducted, the acceptance
criteria were met, and any potential performance issues were identified, to ensure the
alternative shutdown capability remained functional.
b.
Findings
No findings were identified .
. 06
Circuit Analysis
a.
Inspection Scope
The team reviewed Dominion's post-fire safe shutdown analysis for the selected fire
areas to determine whether the analysis appropriately identified the structures, systems,
and components important to achieving and maintaining safe shutdown. In addition, the
team evaluated the analysis to assess whether the necessary electrical circuits were
properly protected and whether circuits that could adversely impact safe shutdown due
to hot shorts, shorts to ground, or other failures were identified, evaluated, and properly
dispositioned to ensure spurious actuations would not prevent safe shutdown.
Enclosure 2
9
The team's review considered fire and cable attributes, potential undesirable
consequences, and common power supply or bus issues. Specific review aspects
included fire threat credibility, cable insulation properties, cable failure modes, and
potential spurious actuations which could result in flow diversion or loss of coolant
events.
The team also reviewed cable routing data bases for a sample of components required
for post-fire safe shutdown to determine whether the cables were routed as described in
the safe shutdown analyses.
Cable failure modes were reviewed for the following components:
3RCS*Ll459C, Pressurizer Level Indicator
3RCS*PI455B, Pressurizer Pressure Indicator
3RCS*MV8000A, Pressurizer Relief Isolation Valve
3RHS*MV8701A, Residual Heat Removal Inlet Isolation Valve
3CHS*MV8438C, Charging Header Isolation Valve
A-EDG, Emergency Diesel Generator
LI-1123B, Steam Generator Level Indicator
LI-110X, Pressurizer Level Indicator
In addition, the team reviewed circuit breaker coordination studies to assess whether
equipment needed to support post-fire safe shutdown activities could be impacted due to
inadequate over-current coordination. Additionally, the team reviewed a sample of
circuit breaker maintenance records to verify whether the circuit breakers for
components required for post-fire safe shutdown were properly maintained in
accordance with approved procedures.
b.
Findings
Introduction. The team identified a finding of very low safety significance (Green),
involving a cited violation of Millstone Unit 2 Operating License Condition 2.C.(3) to
implement and maintain all aspects of the approved fire protection program.
Specifically, Dominion failed to protect required post-fire safe shutdown components and
cabling to ensure one of the redundant trains of equipment remained free from fire
damage as required by 10 CFR Part 50, Appendix R, Section III.G.2. In lieu of providing
the required separation, Dominion utilized unapproved operator manual actions to
mitigate component malfunctions or spurious operations caused by potential single fire
induced circuit faults (hot short, open circuit or short to ground).
Description. As a result of a self-assessment (Self-Assessment Report 000506),
Dominion initiated condition report (CR) 119114 in November 2008 to identify the lack of
Enclosure 2
10
documentation concerning a review of their use of operator manual actions against the
guidance contained in Regulatory Issue Summary (RIS) 2006-10, "Regulatory
Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions,"
dated June 30, 2006. The CR also identified that exemption requests may be needed to
obtain NRC approval for the use of operator manual actions.
In addition to information provided to the licensees in RIS 2006-010, the NRC issued
several enforcement guidance memoranda (EGM) to promulgate interim enforcement
guidance to the staff while the issues of non-compliant manual actions and fire induced
circuit faults were being resolved. Specifically, EGM 07-004 defined March 6,2009, as
the date by which corrective actions were to have been completed for non-compliances
involving the use of unapproved post-fire manual actions. If corrective actions were
completed by this date the licensees would be eligible to receive enforcement discretion
for the associated violations of NRC requirements. The scope of this EGM included use
of manual actions to mitigate component malfunctions that resulted from fire-induced
single spurious actuations but did not include malfunctions due to multiple spurious
actuations. The NRC subsequently issued EGM 09-002 to describe the conditions
limiting enforcement during the resolution of fire protection concerns involving multiple
spurious actuations. EGM 09-002 made enforcement discretion available provided
licensees entered these non-compliances into their corrective action program and
implemented interim compensatory measures within six months of the issuance of NRC
Regulatory Guide (RG) 1.189, Rev. 2, and then implemented corrective actions within
three years of the issuance of RG 1.189, Rev. 2. Accordingly, based on the issuance
date of the RG, May 2, 2010, was established as the date by which non-compliances
associated with multiple spurious actuations were to be entered into the corrective action
program and November 2,2012, is the date by which corrective actions must be
completed for licensees to be eligible to receive enforcement discretion for the
associated non-compliances. At the time of this inspection, a fleet wide Dominion
project for identification and resolution of multiple spurious operation issues was in
progress.
In June 2010, during the performance of a fire protection self-assessment (SAR001 036),
Dominion initiated CR 383734 which documented that CR 119114 had been improperly
closed to the multiple spurious operations evaluation process. Further review by the
team confirmed that issues opened in CR 119114 associated with the use of
unapproved manual actions to address single spurious actuation had not yet been
resolved. Additional licensee reviews during this inspection subsequently identified
numerous components that did not meet the separation requirements of 10 CFR Part 50,
Appendix R,Section III,G.2. This issue was entered into Dominion's corrective action
program as CR 388775.
Specifically, the team reviewed information provided by Dominion concerning potential
unapproved manual operator actions in seven fire areas (R-2, R-4, R-9, R-10, R-13,
R-14, and R-17). The team focused on actions that needed to be completed in a
relatively short period of time to ensure core cooling, specifically feeding of the steam
generators (SG) using the available auxiliary feedwater system (AFW). The team
reviewed the Fire Safe Shutdown Analysis and procedures to reach hot shutdown for
each of these areas, identifying the credited path that would need to be free of fire
Enclosure 2
11
damage to be in compliance with Appendix R,Section III.G.2. This included
identification of the required pump or pumps and flow path including the SG flow control
valve (FCV) to one of the two SGs, referred to as the required path. The team then
identified any
flow path to the other SG using the other FCV, referred to as the redundant path.
The team identified the post-fire safe shutdown required paths and the associated
components that were operated by procedures from outside the control room using
manual actions to restore/maintain the required safe shutdown function because of
potential fire damage. This review identified five general types of actions needed to
maintain decay heat removal with the SGs that could be subject to exemption. These
included: 1) operating the required flow path FCV locally or from the fire safe shutdown
panel; 2) closure of the required SG blowdown valve; 3) restoration of instrument air, if
offsite power is lost, to allow continued operation of the FCVs from the control room or
fire safe shutdown panel; 4) operation of the turbine driven (TO) AFW pump from the fire
safe shutdown panel including not over filling the SGs; and 5) actions to protect the
required 4160 volt AC bus and DC power supplies. This resulted in 11 actual individual
unapproved manual actions for which the licensee had not requested exemption.
Analysis. The team identified a performance deficiency in that Dominion failed to protect
components credited for post-fire safe shutdown from fire induced damage that could
result in a single spurious actuation. The performance deficiency was more than minor
because it affected the Mitigating Systems Cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences in the event of a fire. Specifically, the use of
operator manual actions during post-fire shutdown is not as reliable as normal systems
operation which could be utilized had the separation requirements of 10 CFR 50,
Appendix R,Section III.G.2 been met and therefore prevented fire damage to credited
components and/or cables. The team used IMC 0609, Appendix F, "Fire Protection
Significance Determination Process (SOP):' Phase 1 and an SRA conducted Phase 3
analyses, to determine that this finding was of very low safety significance (Green).
In six of the identified fire areas actions were needed to maintain AFW flow to the
required SG within 30 to 45 minutes. The actions to restore charging flow were not
needed until over three hours and were not reviewed. Actions needed to operate SG
atmospheric dump valves to control the plant cooldown were not reviewed, because
steam generator safety valves were the assumed path for decay heat removal. Simple
actions to isolate components such as repositioning switches at the bottle-up panel to
force isolations and prevent spurious actuations to isolate the SGs were not reviewed,
because th~y were essentially equivalent to actions from the control room. Actions
needed to restore instrument air to support control room operation of the AFW FCVs
were not reviewed because of installed two-hour air bottles on each FCV. As such, fire
areas R-4, R-9, R-10, and R-17 were screened as having low degradation in the Phase
1 of the Fire SOP, Inspection Manual Chapter 0609, Appendix F.
The SRA conducted Phase 3 risk evaluations for the unapproved manual action in fire
areas R-2, R-13, and R-14. The individual analyses reviewed the increase in risk due to
the unapproved manual actions. These evaluations allowed for use of the available flow
Enclosure 2
12
path to the redundant steam generator. The bases case assumed conformance with
III,G.2 (Le., operation from the required flow path components from the control room)
and the condition case assumed non-conforming manual actions taking place outside
the control room. SPAR H was used to model both the conforming and non-conforming
manual actions. Specifically:
R-2 - the required path to the #1 steam generator with operation of the "IX'MD AFW
pump from the control room with local manual operation of the "IX' FCV vice operation
from the control room.
R-13 - the required path to the #2 steam generator with operation of the TDAFW
pump and the "B" FCV from the fire safe shutdown panel vice the control room.
R-14 - the required path to the #2 steam generator with either the TDAFW pump or
the "B" MDAFW pump operating from the control room, with:
local manual action to isolate the 24D safety bus, and align the "B" EDG, vice
no action needed
local manual operation of the "B" FCV vice operation from the control room.
Based on the fire frequencies specified in the Individual Plant Evaluation of External
Events (IPEEE) for these areas, the total conditional core damage probability increase
given the local manual actions vice control room was estimated to be in the range of 1
core damage accident in 1.1 million years (high E-7 range).
The team found the unapproved manual actions in fire areas R-2, R-4, R-9, R-10, R-13,
R-14, and R-17 to be reasonable interim compensatory measures (pending licensee
actions to resolve the non-compliances or obtain exemptions) because they did not
require complicated actions, adequate time was available to accomplish the actions and
the actions were properly included in the appropriate abnormal operating procedures.
This finding has a cross cutting aspect in the area of problem identification and
resolution associated with the corrective action program because Dominion did not
completely and accurately identify deficiencies related to single spurious actuations of
credited post- fire safe shutdown components. As a result, appropriate actions were not
taken to address the use of unapproved manual actions as described above. (P.1.a)
Enforcement. License Condition 2.C.(3) specifies, "The licensee shall implement and
maintain in effect all provisions of the approved fire protection program as described in
the Updated Final Safety Analysis Report and as approved in the SER dated
September 19,1978, and supplements dated October 21,1980, November 11,1981,
October 31,1985, April 15, 1986, January 15, 1987, April 29, 1988, July 17, 1990,
and November 3, 1995:' Final Safety Analysis Report, Section 9.10.6 specifies that the
licensee will meet the requirements of 10 CFR Part 50, Appendix R, Section III,G.2 that
identifies three methods of protecting post-fire safe shutdown equipment from fire
damage. Additionally, by letter B17399, dated March 17, 1999, Dominion informed the
NRC staff of variances between the SER supplement (dated July 17, 1990) related to
post-fire alternative shutdown capability, and their current (1999) safe shutdown strategy
for Millstone Unit 2. Letter B17399, in part, clarified that only four fire areas (R-1, R-3,
R-11, and R-16) relied on alternative shutdown capability. As a result, use of manual
Enclosure 2
13
operator actions in lieu of protecting the equipment in accordance with 10 CFR 50,
Appendix R, III.G.2 would only be allowed if approved by the NRC.
Contrary to the above, through September 22,2010, Dominion failed to implement their
fire protection program by using one of the three methods described in Appendix R,
Section III.G.2 to protect circuits required for post-fire safe shutdown from fire induced
circuit damage. Specifically, Dominion continued to use unapproved manual actions to
mitigate post-fire safe shutdown equipment malfunctions caused by a single spurious
actuation without having obtained NRC approval. This finding is being cited because not
all of the criteria specified in section 2.3.2.a of the NRC Enforcement Policy for a non-
cited violation were satisfied. Specifically, Dominion failed to restore compliance within a
reasonable amount of time after the violation was identified in CR 119114 in November
2008. Additionally, because the violations were not corrected by March 6, 2009,
Dominion is not eligible to receive enforcement discretion previously available by EGM 07-004. VIO 05000336/2010008-02, Failure to Protect Safe Shutdown Equipment
From the Effects of Fire .
. 07
Communications
a.
Inspection Scope
The team reviewed selected fire related safe shutdown procedures, the FHA, the safe
shutdown analysis, and associated documents to assess whether the expected method
of communications would be available during and following a fire. During this review, the
team considered the effects of ambient noise levels, clarity of reception, reliability, and
coverage patterns. The team inspected the designated emergency storage lockers to
verify whether sufficient portable radios would be available for the fire brigade and
operators. In addition, the team assessed whether communications equipment, such as
sound powered phone system cables, repeaters, transmitters, and uninterruptable and
back-up power supplies would be adversely affected by a fire.
b.
Findings
No findings were identified.
08
a.
Inspection Scope
The team walked down the emergency lights in the selected fire areas to independently
evaluate the placement and coverage areas of the lights. The team assessed whether
the lights provided adequate illumination on local equipment and instrumentation,
required for post-fire safe shutdown, to ensure local operations could be reliably
performed under expected post-fire conditions. Emergency light placement was also
evaluated to determine adequate illumination of local area access and egress pathways.
Enclosure 2
14
The team verified whether the emergency light batteries were rated for at least an eight-
hour capacity. Preventive maintenance procedures, the vendor manual, completed
surveillance tests, and battery replacement practices were also reviewed to evaluate
whether the emergency lighting was being maintained in a manner that would ensure
reliable operation.
b.
Findings
No findings we~e identified .
. 09
Cold Shutdown Repairs
a.
Inspection Scope
The team reviewed dedicated repair procedures for selected components which might
be damaged by the fire, to determine whether the a cold shutdown could be achieved
within the time specified in the design and licensing bases. The team also reviewed the
associated equipment, materials, and tools needed to perform the repairs (e.g., pre-cut
cables with lugs attached), to determine whether they were available and accessible on-
site.
b.
Findings
No findings were identified .
. 10
Compensatory Measures
a.
Inspection Scope
The team reviewed selected fire protection and post-fire safe shutdown equipment,
systems, or features that were out-of-service, degraded, or inoperable (e.g., detection
and suppression systems, passive fire barriers, pumps or valves, or electrical devices
providing safe shutdown functions or capabilities) to determine whether Dominion had
implemented appropriate compensatory measures. The team also evaluated selected
short term compensatory measures to assess whether the degraded function or feature
was adequately compensated until appropriate corrective action could be taken to return
the equipment to service. In addition, the team assessed Dominion's effectiveness to
return equipment to service in a reasonable period of time.
b.
Findings
No findings were identified.
Enclosure 2
15
.11
Large Fires and Explosions Mitigation Strategies
a.
Inspection Scope
The team reviewed Dominion's preparedness to handle large fires or explosions by
reviewing two mitigating strategies on each unit to verify they continue to meet the
requirements of the Unit 2 and Unit 3 license conditions 2.C.(13) and 2.C.(10),
respectively by determining that:
-Procedures are being maintained and adequate;
-Equipment is properly staged and is being maintained and tested; and,
-Station personnel are knowledgeable and can implement the procedures.
b.
Findings
The results of this inspection are document in NRC Inspection Report 05000336/2010011 and 05000423/2010011.
4.
OTHER ACTIVITIES
40A2 Identification and Resolution of Problems (IP 71152)
a.
Inspection Scope
The team reviewed a sample of CRs associated with the FPP and post-fire safe
shutdown issues to determine whether Dominion was appropriately identifying,
characterizing, and correcting problems associated with these areas and whether the
planned or completed corrective actions were appropriate. The CRs reviewed are listed
in the attachment.
The team determined that the licensee had identified several multiple spurious operation
(MSO) scenarios for further review. Dominion placed the identified scenarios into their
corrective action program and implemented alternate compensatory measures prior to
May 2,2010.
b.
Findings
No findings were identified.
40A5 Other Activities
.1
(Closed) URI 50-423/2003-02-03, Generic Industry and NRC Resolution of Fire Safe
Shutdown Issues
NRC Inspection Report 50-423/2003-002 closed Licensee Event Report 50-423/2002-00
Supplement 01, which was associated with inadequate validation of fire safe shutdown
assumptions (fire-induced circuit fault). In addition, that inspection report also closed a
previous NRC unresolved item (URI) 50-423/2002-05-07 which tracked the resolution of
Enclosure 2
16
an NRC and industry initiative to develop generic guidance to evaluate fire-induced
circuit failures. That URI was closed because it was considered too narrow in scope, in
that it only addressed the resolution of an issue related to power operated relief valves.
That inspection report opened a new URI (50-423/2003-02-01) to track the broader
resolution of the issue. (Note: The NRC tracking number was subsequently
administratively changed to URI 50-423/2003-02-03.)
There were two specific aspects of fire-induced circuit faults that the NRC subsequently
addressed. The first issue involved fire-induced single circuit cable faults and
associated operator manual actions, not specifically approved by the NRC, which
licensees relied upon as compensatory measures to mitigate potential adverse effects
on equipment required for post-fire safe shutdown. NRC EGM 2007-004 authorized
enforcement discretion for such issues, provided that licensees entered those issues into
their corrective action programs, instituted appropriate compensatory measures until the
issues were corrected, and either (a) corrected the conditions or (b) submitted an
exemption request to the NRC, by March 6, 2009. The EGM also stated that non-
compliances involving single fire-induced circuit faults identified after March 6, 2009
would be subject to enforcement actions.
The second issue involved fire-induced multiple circuit cable faults and associated
operator manual actions. EGM 2009-002, dated May 14,2009, authorized enforcement
discretion for such issues, provided that licensees identified those issues, entered them
into their corrective action programs, and instituted appropriate compensatory measures
until the issues were corrected, within the six month period following a planned revision
to RG 1.189, "Fire Protection for Nuclear Power Plants." RG 1.189, Rev. 2, issued in
October 2009, provided a method acceptable to the NRC to evaluate and resolve
multiple fire-induced circuit faults. After the 6 month period for identification of issues,
the EGM further authorized enforcement discretion an additional 30 month period, for
licensees to resolve the identified multiple fire-induced circuit fault issues.
The two EGMs and RG 1.189, discussed above, provide adequate technical guidance
and an acceptable time table to evaluate and resolve the issues tracked by
URI 50-423/2003-02-03, regarding fire-induced cable faults. The adequacy of licensee
actions to address these issues will continue to be reviewed within the framework of the
NRC's reactor oversight process which includes the triennial fire protection team
inspections and problem identification and resolution inspections. Therefore,
URI 50-423/2003-02-03 is no longer necessary to track these issues and is closed .
. 2
Temporary Instruction (Tn 2515/181! 'Validate the Effectiveness of the Regulatory
Infrastructure Related to Fire-Induced Circuit Failures and Operator Manual Actions'
Background
This TI is intended to verify that the regulatory infrastructure is sufficient for licensees to
achieve compliance in the areas of fire induced circuit failures and post-fire operator
manual actions for spurious actuations due to fire-induced failures. 10 CFR Part 50,
Appendix R,Section III.G.2, identifies three acceptable methods to meet the requirement
for maintaining one of the redundant trains in the same fire area, outside of primary
Enclosure 2
17
containment, free of fire damage. The three methods include a combination of physical
barriers, spatial separation, and fire detection and automatic suppression systems.
In October 2009, the NRC issued guidance in Regulatory Guide 1.189, "Fire Protection
for Nuclear Power Plants;' Revision 2, to identify acceptable methods for resolving issues
related to circuits required for post-fire safe shutdown and circuits important to
post-fire safe shutdown. Equipment required post-fire safe shutdown (credited train)
must use one of the three methods identified in Section III.G.2 to protect the circuits
located within the same fire area from fire damage, including single and multiple
spurious operations. For important to post-fire safe shutdown circuits, the licensee may
use operator manual actions if the licensee demonstrates they can be shown to be
feasible and reliable or resolve issues using other analysis methods including fire
modeling.
a. Inspection Scope
During this inspection, the team reviewed a representative sampling of single and
multiple spurious issues for Unit 2 to:
1) Determine if the licensee used the guidance in Regulatory Guide 1.189, Revision 2
and Nuclear Energy Institute (NEI) 00-01, "Guidance for Post Fire Safe Shutdown
Analysis;' Revision 2, to successfully address single and multiple spurious issues in
a manner that met the regulations. This included equipment required for safe
shutdown and equipment important for safe shutdown.
2) Evaluate the adequacy of the licensee's method for determining that the required
trains of safe shutdown equipment do not rely on operator manual actions.
3) Evaluate the adequacy of the licensee's method for determining if redundant trains
of post fire safe shutdown equipment (required and important to post fire safe
shutdown equipment) are made inoperable or nonfunctional due to Single or
multiple spurious actuations.
4) Evaluate the adequacy of the licensee's multiple spurious actuation evaluation in
accordance with RG 1.189 and NEI 00-01 for alternative or dedicated shutdown
areas.
5) Evaluate the licensee's understanding of the requirements related to allowed
operator manual actions. (Note: The team added this question to assure sufficient
information was available related to Task 4 of the fire protection stabilization plan.)
The team reviewed the Unit 2 post-fire safe shutdown analysis, Unit 2 licensing basis,
project instructions, drawings, and corrective action documents. The team interviewed
the multiple spurious operation project expert panel chairman, the fire protection safe
shutdown engineer, the fire protection system engineer, and a reviewer who participated
in the screening circuit analysis and disposition of the expert panel questions. Two NRC
staff with expertise in circuit analysis and the requirements related to multiple spurious
Enclosure 2
18
operations from the Fire Protection Branch in the Office of Nuclear Reactor Regulation
provided assistance to the team during this inspection.
b.
Findings
No findings were identified.
Licensee Process
Dominion established a process that followed the guidelines established in NEI 00-01.
This process included the following components:
Establishment of an expert panel that reviewed the generic list of multiple
spurious operations established in NEI 00-01, Appendix G, "Generic List of
MSOs;'for pressurized water reactors. The expert panel identified the multiple
spurious operations that could be applicable based on the Unit 2 plant-specific
design;
Evaluation of the identified applicable multiple spurious operation scenarios to
determine whether the existing post-fire safe shutdown analysis and safe
shutdown strategy already included measures that adequately addressed any
potential adverse impacts of the particular scenario;
Identification of cables for the components within the scope of the multiple
spurious operations scenario evaluation and identification of their physical
routing by fire areas;
Performance of an initial circuit analysis to determine which of the cables
selected in the previous step could cause a component to actuate from their
initial state to an undesired state due to fire induced circuit damage;
Performance of fire area analyses to identify fire areas that contained the
cables for each of the components whose combinations are necessary to result
in a multiple spurious operation of concern;
Documentation and evaluation of multiple spurious operation scenarios that
require resolution in the corrective action program and implement compensatory
measures;
Performance of additional circuit and fire area analyses for those multiple
spurious operation scenarios that have been entered into the corrective action
program to confirm which scenarios could realistically occur and implement
corrective for final resolution; and,
Documentation of the multiple spurious operation project process, evaluations
and results.
Enclosure 2
19
At the time of this inspection, the team determined that Dominion had not implemented
this process for their alternative or dedicated shutdown areas. Dominion indicated that
they had plans to evaluate their alternative or dedicated shutdown areas following the
same process described above.
1) Determine if the licensee used the guidance contained in Regulatory Guide 1.189.
Rev. 2. and NEI 00-01. Rev. 2. to successfully address single and multiple spurious
operations in a manner that met regulations. This includes equipment required for safe
shutdown and equipment important for safe shutdown.
The team found that Dominion established appropriate project instructions for
conducting their expert panel and for conducting their circuit analysis. The project
instructions utilized the guidance contained in NEI 00-01, Section 3 for evaluating the
different circuit failure combinations and utilized the guidance contained in NEI 00-01,
Appendix F for conducting the expert panel evaluations of potential MSO scenarios
including the generic multiple spurious operations listed for pressurized water reactors in
NEI 00-01, Appendix G. The team also found that Dominion programs were adequate to
identify single spurious operations. However, the team found that unapproved operator
manual actions were being used to mitigate previously identified equipment spurious
actuations that could be caused by single fire induced circuit failures. Refer to section
1 R05.06 above for details.
The team concluded Dominion used the guidance in RG 1.189 and NEI 00-01 to conduct
their review for single and multiple spurious operations. The team concluded that these
documents provided sufficient guidance for Dominion to establish an appropriate review
process that evaluated spurious operations of both required and important post fire safe
shutdown equipment.
2) Evaluate the adequacy of the licensee's method for determining that the redundant
trains of safe shutdown equipment do not rely on operator manual actions.
The team found that Dominion's eXisting safe shutdown analysis program adequately
determined where required trains of post-fire safe shutdown equipment relied upon
operator manual actions. The use of manual operator actions to address single spurious
actuation issues are identified and documented in 25203-SP-M2-SU-1046, MP 2,
Appendix R Compliance Report, Rev. 01. However, the team also found that the
licensee had not corrected conditions that resulted in reliance on operator manual
actions, nor had Dominion obtained NRC approval for the use of operator manual
actions that involved equipment required for safe shutdown. Refer to section 1 R05.06
for details.
The team also noted that Dominion has not yet identified MSO scenarios whose
resolution may require reliance on operator manual actions. At the time of this
inspection Dominion's MSO program had progressed to the point where CRs have been
initiated for multiple spurious operation scenarios for which their initial reviews
determined to be potential viable concerns. As a result, additional licensee reviews and
evaluations will be necessary to determine which MSO scenarios may require corrective
Enclosure 2
20
actions and whether operator manual actions would be considered as a viable corrective
action.
Based on these reviews, the team concluded that Dominion's methods are adequate to
identify where the redundant trains of safe shutdown equipment do not meet the
separation requirements of 10 CFR 50, Appendix R and the safe shutdown methodology
for single or multiple spurious operations may rely on operator manual actions.
3) Evaluate the adequacy of the licensee's method for determining if redundant trains of
safe shutdown equipment are made inoperable or nonfunctional due to single or multiple
spurious actuations.
Dominion does not consider safe shutdown equipment to be inoperable or nonfunctional
due to a potential single spurious actuation if they have determined that an acceptable
operator manual action has been established. However, Dominion did acknowledge the
need to take actions to establish compliance with the requirements of 10 CFR 50,
Appendix R,Section III.G.2. Refer to section 1 R05.06 for details of the violation.
Dominion performed a functionality assessment for potential component failures as a
result of multiple spurious operations on a fire area basis. Dominion considered these
components as "operable but degraded and nonconforming:' Consequently, Dominion
evaluated the components using the guidance described in Regulatory Information
Summary 2005-20, "Revision to NRC Inspection Manual Part 9900 Technical Guidance,
Operability Determinations & Functionality Assessments for Resolution of Degraded or
Nonconforming Conditions Adverse to Quality or Safety;' Rev. 1. Dominion determined
that the types ofissues identified by the multiple spurious operation review would not
significantly affect the plant margin of safety and that these multiple spurious operations
did not constitute a degraded fire protection feature within the scope of the Millstone
Unit 2 Technical Requirements Manual (TRM).
Dominion has determined the impact of multiple spurious operations had low risk and
safety consequences. Dominion based this conclusion, in part, on the following
technical factors: (1) a large fire lasting longer than 20 minutes would likely be
necessary to result in a multiple spurious operation; (2) the fire will likely have been
detected prior to reaching a damaging level; (3) the suppression systems will actuate
long before the temperatures reach the levels required to damage thermoset cables
(500-700 OF); (4) the fire must continue in the area of the cables for long periods to
result in maloperation; and, (5) multiple hot shorts would need to occur.
Based on the above assessment, Dominion implemented interim compensatory
measures in the form of enhanced operator rounds as described in their functional
assessment prior to May 2, 2010 to provide an additional level of awareness. Dominion
enhanced the operator rounds by: (1) training operators on the fire hazards to increase
their awareness, (2) adding statements to the rounds for the types of items to monitor
(e.g., degraded fire features and increased combustibles), and (3) requiring the
operators to routinely document that these items were reviewed. In addition to the
changes to the operator rounds, additional monitoring of fire detection system operability
Enclosure 2
21
has been implemented. Upon final confirmation that specific multiple spurious operation
scenarios are valid concerns that require corrective actions.
Dominion specified that they would initiate individual corrective action documents and
implement compensatory measures specified in their TRM for the identified
nonconformance.
The team concluded Dominion had an adequate method for evaluating the operability
and functionality of components subject to multiple spurious operations. However,
actions to ensure compliance with Appendix R for single spurious actuation issues were
not timely (refer to section 1 R05.06 above).
4) Evaluate the adequacy of the licensee's multiple spurious actuation evaluation in
accordance with Regulatory Guide 1.189 and NEI 00-01 for alternative or dedicated
shutdown areas.
The team determined that Dominion had established a process to evaluate their
alternative or dedicated shutdown areas. Dominion planned to implement this review
following the steps used for evaluating the 10 CFR Part 50, Appendix R, Section IILG.2
multiple spurious operation evaluations.
5) Evaluate the licensee's implementation of the requirements related to allowed
The team reviewed Dominion's implementation of guidance and requirements involving
the use of operator manual actions for post-fire safe shutdown. Aspects reviewed
included the differences regarding the use of operator manual actions contained in
10 CFR Part 50, Appendix R, Sections IILG.2 and IILG.3, including the circumstances
under which an NRC exemption would be required. The team confirmed that Dominion
understood that when reviewing the acceptability of specific manual actions associated
with a licensing action, the NRC would utilize the guidelines contained in NUREG-1852,
'Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to
Fire:'
The team also reviewed Dominion's program for addressing the use of operator manual
actions to resolve MSO issues. Specifically, the team confirmed that Dominion's
program was consistent with the guidance specified in RG 1.189 and NEI 00-01,
including differentiation between required' and '~mportant' to safe shutdown equipment.
40A6 Meetings. including Exit
The team presented the preliminary inspection results to Mr. A. J. Jordan, Site Vice
President, and other members of Dominion's staff on August 5, 2010. Following
additional in-office and on-site reviews, an exit meeting was conducted by telephone
with Mr. A. J. Jordan and other members of your staff on September 22, 2010. The
team verified that this report does not contain proprietary information.
Enclosure 2
A-1
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
P. Anastas, Safe Shutdown Program Engineer
J. Armstrong, Fire Protection Engineer
R. Beal, Senior Reactor Operator
R. Bonner, Supervisor, Electrical and I&C System Engineering
C. Chatman, Senior Reactor Operator
K. Cyr, Electrical Design Engineer
P. Dillon, Diesel System Engineer
P. Freeman, Electrical Design Engineer
W. Harrelson, Senior Reactor Operator
C. Karpinski, Fire Brigade Training
L. LeBaron, System Engineer
J. Lupa, Reactor Operator
J. Mangeno, Fire Protection Engineer
J. Martin, MSO Project Manger
T. McNatt, System Engineer
R. Patel, Electrical Design Engineer
B. Pinkowitz, Simulator Instructor
J. Powers, System Engineer
J. Rigatti, Manager, Nuclear Engineering
T. Ryan, System Engineer
S. Wainio, Engineering Supervisor
B. Wilkens, Site Fire Marshal
NRC Personnel
S. Shaffer, Senior Resident Inspector- Millstone
B. Haagensen, Resident Inspector- Millstone
J. Krafty, Resident Inspector- Millstone
Attachment
A-2
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
05000336/201 0008-02
Failure to Protect Safe Shutdown Equipment From the
Effects of Fire. (Section 1 R05.06)
Opened and Closed
05000336/201 0008-01
05000423/201 0008-01
Closed
Failure to Control Fire Fighting Strategies
(Section 1 R05.03)05000423/2003002-03
Generic Industry and NRC Resolution of Fire Safe
Shutdown Issues (Section 40A5.1)
LIST OF DOCUMENTS REVIEWED
Fire Protection Licensing Documents
25203-SP-M2-SU-1046, Unit 2 Appendix R Compliance Report, Rev. 1
25212-BTP-9.5-1, Unit 3 Branch Technical Position 9.5-1 Compliance Report, Rev. 3
Unit 3 FSAR Fire Protection Evaluation Report, Rev. 23
Unit 2 Fire Hazards Analysis Report, Rev. 11
Unit 2 FHA Boundary Dwg., Sh. 1, Auxiliary & Containment Bldg, Elev. minus 45 ft., Rev. 3
Unit 2 FHA Boundary Dwg., Sh. 2, Auxiliary & Containment Bldg, Elev. minus 25 ft., Rev. 2
Unit 2 FHA Boundary Dwg., Sh. 3, Auxiliary & Containment Bldg, Elev. minus 5 ft., Rev. 3
Unit 2 FHA Boundary Dwg., Sh. 4, Auxiliary & Containment Bldg, Elev. 14 ft., Rev. 5
Unit 2 FHA Boundary Dwg., Sh. 5, Auxiliary & Containment, Elev. 25 ft., Rev. 3
Unit 2 FHA Boundary Dwg., Sh. 6, Auxiliary & Containment, Elev. 38 ft., Rev. 6
Unit 2 FHA Boundary Dwg., Sh. 7, Turbine Bldg, Elev. 14 ft., Rev. 4
Unit 2 FHA Boundary Dwg., Sh. 8, Turbine Bldg, Elev. 31 ft., Rev. 3
Unit 2 FHA Boundary Dwg., Sh. 9, Turbine Bldg, Elev. 54 ft., Rev. 2
Unit 2 FHA Boundary Dwg., Sh. 10, Outside Buildings, Rev. 4
Unit 2 FHA Boundary Dwg., Sh. 11, Yard Areas, Rev. 4
Fire Protection Program Procedures
CM-AA-FPA-100, Fire Protection 1 Appendix R (Fire Safe Shutdown) Program, Rev. 1
CM-AA-FPA-101, Control of Combustible and Flammable Materials, Rev. 2
CM-AA-FPA-102, Fire Protection, Fire Safe Shutdown Review, and Preparation Process and
Design Change Process, Rev. 0
Unit 2 Technical Requirements Manual, Section 7.1, Appendix R Safe Shutdown Requirements,
2/02/10
Attachment
A-3
Calculations and Engineering Evaluation Reports
25203-ER-08-0042, Unit 2 Delayed AFW Following a Fire in Area R-2, Rev. 0
25205-ER-09-0002, Unit 2 & 3 Fire Protection Time Critical Operator Actions, Rev. 0
25203-ER-99-0092, Unit 2 App- R Cooldown Analysis Assumptions and Results, Rev. 3
25212-ER-97-0302, Section 6.4, Communications, Rev. 3
98-ENG-02411-C2, Flooding Outside of Containment Evaluation, Rev. 1
98-ENG-02621-M2, Instrument Air Requirement for Certain Safety Related Valves, Rev. 3 99-026, Millstone Site Fire Loop Hydraulic Model, Rev. 1
ACE 1392-CR1 07561, Potential for Water Relief through Pressurizer Safety Valves from a
Control Room Fire, Rev. 0
C OP 200.18, Time Critical Action Validation and Verification, Rev. 0
M2-EV-970061, Unit 2 Compensatory Actions, Loss of Ventilation in Electric Switchgear Areas,
Rev. 3
M2-EV-97-0061, Compensatory Actions for Loss of Ventilation to SWitchgear Areas, Rev. 3
M2-EV-98-0013, 120 VAC Vital Bus Coordination Study, Rev. 0
M2-EV-99-0093, Compensatory Measures for Loss of Ventilation, Rev. 4
MP2-CD-1457, MEPL Determination, Rev. 0
P1164-MP2-COORD, Breaker & Fuse Coordination for Panels D11, D12, D21, and D22, Rev. 0
P1117-025, Unit 2 NFPA Code Compliance Deviation Closeout Review, 1/98
PA84-065-0753GE, Unit 2 480V Breaker Over-current Trip Devices, Rev. 2
PA85-082-0812GE, Unit 2 125VDC Coordination Study, Rev. 2
RAS 121147, Reasonable Assurance of Safety for CR 121147,12/18/08
RAS 000159, Emergency Lighting Units with Melted & Discolored Lens, 7/21/10
RAS 000066, Potential for Fire Damage to LCV112B/C, VCT Outlet Valves, Could Result in
Damage to "A" CHS PP Credited for Post Fire Shutdown, Rev. 1
S2-EV-99-0103, Safety Evaluation forTRM Change-99-2-16, Minimum Shift Staffing Required
to Implement App-R Manual Actions, Rev. 0
SP-GEE-6, Specification for 600 Volt Switchboard Wire, Rev. 2
SP-GEE-19, Specification for 600 Volt Control Cable, Rev. 4
SP-GEE-20, Specification for 600 Volt Instrument Cable, Rev. 3
SP-GEE-22, Specification for 600 Volt Power Cable, Rev. 4
SP-M3-EE-269, Appendix R Breaker Coordination Study, Rev. 2
W2-517-744-RE, Unit 2 App-R Cooldown, Rev. 3
Drawings and Wiring Diagrams
25203-24071, Sh. 5, Unit 2 Fire Damper Schedule, Rev. 2
25203-24091, Sh. C0102, Unit 2 Conduit Fire Seal Foam for Floor & Wall Detail, Rev. 2
25203-24091, Sh. G0002, Unit 2 Fire Grout Seal Detail, Rev. 2
25203-24092, Sh. T1 OF12, Unit 2 Penetration Seal Survey Map & Inspection Record, Rev. 1
25203-28200, Sh. 69, Unit 2 LT-110X, LT-110Y Pressurizer Level Functional Diagram, Rev. 3
25203-28500, Sh. 69A, Unit 2 L T -11 OX & 11 OY Pressurizer Level Loop Diagram, Rev. 11
25203-28500, Sh. 69B, Unit 2 L T -11 OX & 11 OY Pressurizer Level Loop Diagram, Rev. 7
25203-28500, Sh. 69C, Unit 2 L T-11 OX, 11 OY Pressurizer Level Loop Diagram, Rev. 9
25203-28500, Sh. 69D, Unit 2 L T-11 OX, 11 OY Pressurizer Level Loop Diagram, Rev. 7
25203-28500, Sh. 381, Unit 2 L T1123B Steam Generator Level Loop Diagram, Rev. 10
25203-29550, Sh. 1, Unit 2 EDG Rooms Pre-action Systems, Rev. 1
Attachment
A-4
25203-30001, Unit 2 Main Single Line Diagram, Rev. 30
25203-30101, Unit 2 Fire Shutdown Panel C10, Rev. 3
25203-31148, Sh. 3, Unit 2 Process Instruments Level Transmitters Connection Diag., Rev. 7
25203-32020, Sh. 27, Unit 2 ADV PV4224 Schematic, Rev. 1
25203-32020, Sh. 61, Unit 2 ADV Quick Open Control Schematic, Rev. 6
25203-32021, Sh. 5, Unit 2 Cable Vault Recirculating Fan MF19 Schematic, Rev. 4
25203-32023, Sh. 33, Unit 2 Cable Vault Fan MF123 Schmidt, Rev. 8
25203-32041, Sh. 3, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 12
25203-32041, Sh. 4, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 10
25203-32041, Sh. 5, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 6
25203-32041, Sh. 6, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 8
25203-32041, Sh. 7, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 8
25203-32041, Sh. 8, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 2
25203-32041, Sh. 9, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 6
25203-32041, Sh. 10, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 7
25203-32041, Sh. 11, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 10
25203-32041, Sh. 12, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 6
25203-32041, Sh. 13, Unit 2 Diesel Generator 15G-12U Engine Control, Rev. 10
25203-34060, Unit 2 Conduit Plan Fire Detail, Aux Bldg Elev. minus 14 ft., Rev. 7
25203-37076, Sh. 1, Unit 2 Instrumentation System Cable Routing, Rev. 1
25203-37076, Sh. 4, Unit 2 Instrumentation System Cable Routing, Rev. 1
25203-39212, Sh. 1, Unit 2 "A" EDG Panel C26H Connection Diagram, Rev. 2
25203-39212, Sh. 2, Unit 2 "B" EDG Panel C26G Connection Diagram, Rev. 2
25212-30343, Sh. 70, Unit 3 PZR 3RCS*TK1 Pressure Indication Test Loop Diag., Rev. 6
25212-30343, Sh. 75A, Unit 3 PZR Level Alarm, Indication, and Control Test Loop Diag., Rev. 4
25212-30343, Sh. 75B, Unit 3 PZR Level Alarm, Indication, and Control Test Loop Diag., Rev. 4
25212-30343, Sh. 75C, Unit 3 PZR Level Alarm, Indication, and Control Test Loop Diag., Rev. 3
25212-30343, Sh. 75D, Unit 3 PZR Level Alarm, Indication, and Control Test Loop Diag., Rev. 3
25212-30343, Sh. 75E, Unit 3 PZR Level Alarm, Indication, and Control Test Loop Diag., Rev. 1
25212-30343, Sh. 75F, Unit 3 PZR Level Alarm, Indication, and Control Test Loop Diag., Rev. 1
25212-30343, Sh. 75G, Unit 3 PZR Level Alarm, Indication, and Control Test Loop Diag., Rev. 3
25212-30343, Sh. 75H, Unit 3 PZR Level Alarm, Indication, and Control Test Loop Diag., Rev. 1
25212-30343, Sh. 76, Unit 3 PZR Level Indication Test Loop Diag., Rev. 6
25212-32001, Sh. 6AJS, Unit 3 Charging Header Isolation Valve Elementary Diag., Rev. 12
25212-32001, Sh. 60T, Unit 3 RHR Inlet Isolation Valve 3RHS*MV8701A Elementary, Rev. 17
25212-32001, Sh. 6TD, Unit 3 PZR Relief Isolation Valve 3RCS*MV8000A Elementary, Rev. 20
25212-32001, Sh. 8KC, Unit 3 EDG A Start Circuit 3EGSA01 3EGS*EG-A, Rev. 12
25212-32001, Sh. 8KD, Unit 3 EDG A Stop Circuit 3EGSA03 3EGS*EG-A, Rev. 15
25212-32001, Sh. 8KE, Unit 3 EDG A Governor Control Circuit 3EGSA05 3EGS*EG-A, Rev. 14
25212-32001, Sh. 8KJ, Unit 3 EDG A Shutdown Circuit 3EGSA06 3EGS*EG-A, Rev. 12
25212-32404, Unit 3 PZR Relief Isolation Valve 3RCS*MV8000A Cable Block Diag., Rev. 9
25212-32414, Unit 3 Charging Header Isolation Valve 3CHS*MV8438C Cable Diag., Rev. 3
25212-32449, Unit 3 RHS Inlet Isolation Valve 3RHS*MV8701A Cable Block Diagram, Rev. 6
25212-32722, Unit 3 EDG Excitation 3EGS*~G-A Cable Block Diag., Rev. 4
25212-32722, Unit 3 EDG 3EGS*EG-A Start Circuit Cable Block Diag., Rev. 3
25212-32722, Unit 3 EDG 3EGS*EG-A Engine Control Cable Block Diag., Rev. 6
25212-32722, Unit 3 EDG Governor ControI3EGS*EG-A Cable Block Diag., Rev. 5
25212-32722, Unit 3 EDG 3EGS*EG-A Engine Shutdown Cable Block Diag., Rev. 2
Attachment
A-5
25212-34032, Sh. 2, Unit 3 Conduit Plan Containment Structure Elev. 51 ft., Rev. 12
25212-34035, Unit 3 Conduit Plan Containment Structure Elev. 3 ft, Rev. 14
25212-34042, Unit 3 Containment Outer Annulus Elevation Safe Shutdown Review, Rev. 1
25212-34085, Unit 3 Conduit Plan, Auxiliary Building Elev. 24 ft., Rev. 17
K-13942, Actuator Fail in Last Position for 2-SW-3.1 AlB, 2-SW-3.2A1B, 2-SW-97 AlB, Rev. 3
Piping and Instrumentation Diagrams
25203-26027, Sh. 1, EDG HVAC, Rev. 47
25205-25003, Fire Loop operating & Hydraulic Schematic, Rev. 9
25203-26002, Sh. 1, Unit 2 Main Steam System, Rev. 73
25203-26005, Sh. 3, Unit 2 Condensate Storage & Auxiliary Feedwater System, Rev. 57
25203-26008, Sh. 2, Unit 2 Service Water, Rev. 94
25203-26011, Sh. 1, Unit 2 Fire Protection System, Rev. 52
25203-26011, Sh. 4, Unit 2 Halon & Exciter C02 Fire Protection, Rev. 6
25203-26011, Sh. 5, Unit 2 Fire Protection Auto Sprinkler Valve Details, Rev. 8
25203-26011, Sh. 7, Unit 2 Fire Protection Auto Sprinkler Valve Details, Rev. 1
25203-26017, Sh. 1, Unit 2, Charging System, Rev. 60
25203-26027, Sh. 1, Unit 2 HVAC for EDG Rooms, Rev. 47
25212-24036, Unit 3 Fire Stop & Seals Map Locations, Rev. 0
25212-26902, Sh. 3, Unit 3 Reactor Coolant System, Rev. 23
25212-26904, Sh. 1, Unit 3 Chemical and Volume Control, Rev. 50
25212-26912, Sh. 1, Unit 3 Low Pressure Safety Injection, Rev. 48
'25212-26946, Sh. 1, Unit 3 Fire Protection, Rev. 29
25212-26946, Sh. 2, Unit 3 Fire Protection, Rev. 49
25212-26946, Sh. 3, Unit 3 Fire Protection, Rev. 21
25212-26946, Sh. 4, Unit 3 Fire Protection, Rev. 25
25212-26946, Sh. 5, Unit 3 Fire Protection System Details, Rev. 2
25212-26951, Sh. 2, Unit 3 Control Building Heating, Ventilation and Air Conditioning, Rev. 20
25212-26951, Sh. 3, Unit 3 Control Building Heating, Ventilation and Air Conditioning, Rev. 0
Modifications and Fire Protection Engineering Evaluations
DCR-M3-08024, Unit 3 Main Transformer Fire Detection and Deluge Building, Rev. 0
DM2-00-0073, Roof Hatch Se~1 Installation in Fire Area T-6, Rev. 10
DM2-00-0343, Replace 24-inch Service Water Cross Connect Valve 2-SW-97 A, Rev. 8
DM3-00-0045-09, Charging Valve Control Circuit Appendix R Modification, Rev. 1
DMG-00-0280, Fire Penetration Seal Installation in Fire Areas T-6 and T-10, Rev. 9
DMG-00-0015-09, Power Supply Changes and Lighting Control, Rev. 0
Transient Combustible Evaluations
24991-04-FP
26660-07 -FP
26675-07 -FP
26676-07 -FP
26756-07 -FP
27077 -08-FP
28018-09-FP
37167 -07 -FP
37175-07-FP
37178-07-FP
37191-07-FP
37195-07 -FP
37981-08-FP
Attachment
A-6
Hot Work Permits
26656-07 -IS
26657 -07 -IS
26870-07 -IS
27655-09-IS
37262-07 -IS
37262-07 -IS
37402-07 -IS
37626-07 -IS
37672-07 -IS
38350-08-IS
38351-08-IS
38461-08-IS
39454-10-IS
System Health Reports
Unit 3, 4.16KV, 1 st Quarter 2010
Unit 3, Load Centers, 1st Quarter 2010
Unit 3, Motor Control Centers, 1 st Quarter 2010
Unit Common, Safe Shutdown Lighting - Category B, 1 st Quarter 2010
Procedures
C MP 790, Emergency Lighting Inspection and Testing, Rev. 3
C OP 200.17, Fire Watch and Impairment Tracking, Rev. 0
C SP 600.8, Diesel Fire Pump M7-7 Monthly Operability Demonstration, Rev. 3
C SP 600.9, Diesel Fire Pump M7-7 Annual Operability Demonstration, Rev. 4
C SP 600.6, Electric Fire Pump M7-8 Monthly Operability Demonstration, Rev. 3
C SP 600.7, Electric Fire Pump M7-8 Annual Operability Demonstration, Rev. 4
C SP 600.13, Electric Fire Pump P-82 Monthly Operability Demonstration, Rev. 2
C SP 600.14, Electric Fire Pump P-82 Annual Operability Demonstration, Rev. 2
C SP 600.16, Fire Protection System Underground Main Flush & Flow Test, Rev. 0
CY-AA-AUX-310, Diesel Fuel Oil Sampling and Testing, Rev. 3
SAIC 2.4, Fire PRA Cable Selection, Routing, Circuit Analysis, Rev. 0
SAIC 4.1, Identification and Evaluation of Multiple Spurious Operations of Equipment Using
Expert Panel, Rev. 0
SAIC 4.2, Draft SECY 08-0093 Analysis Process, Rev. 0
SFP 31, Fire Water System Back-up Supply Plan, Rev. 4
SP 2618C, Fire Protection System Smoke and Heat Detector Test, Rev. 13
SP 2618D, "B" EDG Deluge System Function Test, Rev. 0
SP 3442A02, RCS Wide Range Temperature Calibration, Rev. 6
SP 3446C20, Appendix R Instrumentation Calibration, Rev. 0
SP 3641 D.5, Fire Damper Operability Verification, Rev. 10
SP 3646A.1, EDG A Operability Test, Rev. 18
Operations Procedures
AOP 2559, Fire, Rev. 7
AOP 2571, Inadvertent ESFAS Actuation, Rev. 5
AOP 2579A, Hot Standby for Fire Area R-1, Rev. 9
AOP 2579B, Hot Standby for Fire Area R-2, Rev. 6
AOP 2579H, Hot Standby for Fire Area R-8, Rev. 6
AOP 2579L, Hot Standby for Fire Area R-13, Rev. 6
AOP 2579AA, Cooldown and Cold Shutdown for Fire Area R-1, Rev. 4
Attachment
A-7
AOP 2579BB, Cooldown and Cold Shutdown for Fire Area R-2, Rev. 5
AOP 2579FF, Cooldown and Cold Shutdown for Fire Areas R-8 and R-10, Rev. 5
AOP 2579LL, Cooldown and Cold Shutdown for Fire Area R-13, Rev. 5
EOP 2525, Standard Post Trip Actions, Rev. 23
EOP 2541, App-41, Aligning Compensatory Cooling for Switchgear Rooms, Rev. 1
EOP 3509, Fire Emergency, Rev. 24
EOP 3509.1, Control Room, Cable Spreading Area, or Instrument Rack Room Fire, Rev. 13
EOP 3509.2, Aux Bldg. Elev. 24 ft. South Floor, Elev. 43 ft. & 66 ft. Fire, Rev. 4
EOP 3509.5, Aux Bldg, East MCC & Rod Control Area Fire, Rev. 2
EOP 3509.5, EOP 3509.5 Basis Information, Rev. 2
EOP 3509.8, Control Bldg. Elev. 4 ft., West SWGR Area Fire, Rev. 3
EOP 35 GA-14, Establish Head Vent Letdown, Rev. 0
MP-14-0PS-GDL400, Operations Administrative Procedures, Rev. 9
MP-26-EPI-FAP06-002, Unit 2 Emergency Action Levels (EALs), Rev. 6
MP-26-EPA-REF02, Unit 2 EAL Technical Basis Document, Rev. 15
OP-AA-100, Conduct of Operations, Rev. 9
OP-AA-102, Operability Determination, Rev. 5
OP 2315K, Vital 480V Electrical Switchgear Room Cooling Systems, Rev. 1
OP 2315L, Vital 125V DC Electrical Switchgear Room Cooling Systems, Rev. 1
SP3670.1-009, Primary Plant Equipment Rounds, Rev. 6
SP3670.1-014, Radwaste Plant Equipment Rounds, Rev. 8
Cold Shutdown Repair Procedures
MP 2720U1, Cold Shutdown Fire Damage Repair for Fire Area R-1, Rev. 4
MP 2720U2, Cold Shutdown Fire Damage Repair for Fire Area R-3, Rev. 4
MP 2720U3, Cold Shutdown Fire Damage Repair for Fire Area R-11, Rev. 4
MP 2720U4, Cold Shutdown Fire Damage Repair for Fire Area R-16, Rev. 4
MP 2720U5, Splicing Fire-Damaged Power Cables and Connecting Pump Motors Needed for
Cold Shutdown, Rev. 3
MP 3783EA, Component Cooling Pump Motor Replacement for Fire Protection, Rev. 5
EOP 3509.1 Attachment-I, BAT "A" Level Instrument installation, Rev. 13
Operator Safe Shutdown Training
C01216N, Auxiliary Shutdown Panel Operations, Rev. 0
C01217C, PEO Briefing S01306C, Fire Emergency! Control Room Evacuation, Rev. 0
C04602L, Operating Experience PowerPoint Presentation, Rev. 0
C98205L, Fire Safe Shutdown Overview, Rev. 0
C98027L, EOP 3509.1 In-Plant Walkdown, Rev. 1
C9888206L, EOP 3509.1 Procedure Overview, Rev. 0
E09809C, Chapter 0, Fire Emergency, Rev. 2
FPS086C, Chapter 2, Fire Protection, Detection and Control, Rev. 4
JIT-302-002, Just In Time Training for DCR M3-01008, Rev. 0
JIT-304-001, Chapter 2, Just In Time Training for DCRs M3-02006 & 01008, Rev. 0
JPM-052, Manual Operation of a 4160 Volt Breaker, Rev. 3
JPM-088, Commence Shutdown from Outside the Control Room, Rev. 3
JPM-092, Transfer Controls from the Control Room to C-10, Rev. 5
Attachment
A-8
JPM-093, Local Manual Operation of the "A" Atmospheric Dump Valve, Rev. 9
JPM-141, Removellnstall opening and Closing Coils for 480V MCC Breaker, Rev. 1
JPM-206, Shutdown from Outside the Control Room (Alt. Path), Rev. 2
JPM-207, Local Manual Operation of the "A" Atmospheric Dump Valve, Rev. 1
JPM-217, Manual Operation of RBCCW SDC HX Outlet Valves, Rev. 2
P07602N, PEO In-Plant Walkdown, Cycle 07-6, Rev. 0
P08101JPM, Cycle 08-1 LORT/NLCT In-Plant JPMs, Rev. 0
P09101JPM, In-Plant JPMs, Rev. 0
PEO-04-J, Plant Equipment Operator On-the-Job Training, Rev. 6
S01306C, Simulator Scenario 6, Fire Emergency, Control Room Evacuation, Rev. 1
S03702L, Simulator Scenario 2, Fire Emergency, Control Room Evacuation, Rev. 0
S04405L, Cycle 04-4 Simulator Session 5, Rev. 0
S05105, Cycle 05-1 Simulator Session 5, Rev. 0
S05206L, Cycle 05-2 Simulator Session 6, Rev. 0
S05405L, CTMT Fire and Loss of Shutdown Cooling andlor RCS Inventory, Rev. 0
S05501 L, Cycle 05-5 Simulator Session 1, Rev. 0
S07405L, Cycle 07-4 Simulator Session 5, Rev. 0
S98202L, Cycle 98-2 Simulator Session 2, Rev. 0
S99306L, Simulator Scenario 6, Fire Emergency, Control Room Evacuation, Rev. 0
Fire Fighting Strategies (Le., Pre-Fire Plans)
Unit 2 Zone A-16, "B" EDG Room, 4/30105
Unit 2 Zone T-6, West 480 Volt Load Center Room, 4/01/01
Unit 2 Zone A-1B, Auxiliary Bldg RBCCW & Heat Exchanger Area, 4/01/01
Unit 2 Zone T-10, Turbine Bldg 6.9 and 4.16 kV Switchgear Room, 4/01/01
Unit 3 Zone AB-5, East MCC and Rod Control Area, March 1998
Unit 3 Zone CB-1, West Switchgear Room, January 2002
Unit 3 Zone CB-7, East Switchgear Room, March 1998
Unit 3 Zone CB-8, Cable Spreading Area, April 2004
Fire Brigade Training, Drills, and Drill Critiques
TPD-7.209, Fire Protection Programs, Rev. 1
Unannounced Drills:
Site Bldg 428, 12/23/08
Unit 3 Turb. Bldg Enclosure, 3/16/09
Unit 2 Turbine Bearing, 5/14/09
Unit 1 14H Bus, 9/13/09
Unit 3 Cable Spreading Area, 12/03/09
Unit 2 4160 Switchgear, 12/27109
Unit 3 East Elect. Rm Batt. Charger, 9111/08
Unit 2 Turb. Deck Wooded Bldg, 12/12/08
Unit 3 Cable Spreading Room, 12/16/08
Unit 2 Control Room AlC Area, 6128108
Unit 2 DC SWGR "A" MG set, 9/14/07 .
Unit 3 Fuel Pool Cooling Pumps, 10/10107
Unit 2 Turbine Aux Battery Room, 11/07107
Bldg 434 - Site Warehouse, 11/09/07
Unit 3 EDG, 12/12/07
Attachment
Announced Drills:
Unit 2 "B" Main Transformers, 6/10/08
Unit 2 "A" EDG, 7/15/08
Unit 2 "B" EDG, 7/24/08
Completed Tests and Surveillances
A-9
Unit 2 "B" EDG, 7/29/08
Unit 2 "A" EDG, 8/05/08
Unit 2 "A" EDG, 8/12/08
C SP 600.6, Electric Fire Pump M7-8 Monthly Operability Demo, Performed 5/16/10 & 6/15/10
C SP 600.7, Electric Fire Pump M7-8 Annual Operability Demo, Performed 5/14/09 & 6/15/10
C SP 600.8, Diesel Fire Pump M7-7 Monthly Operability Demo, Performed 5/19/10 & 6/17/10
C SP 600.9, Diesel Fire Pump M7-7 Annual Operability Demo, Performed 9/12/08 & 5/26/09
C SP 600.10, Diesel Fire Pump Fuel Oil Storage Tank Sample Results, Performed 2/16/10 &
4/27/10
C SP 600.13, Electric Fire Pump P-82 Monthly Operability Demo, Performed 5/26/10 & 6/24/10
C SP 600.14, Electric Fire Pump P-82 Annual Operability Demo, Performed 4/28/09 & 4/01/10
C SP 600.26-002, Appendix R Ventilation Fan Operational Check, Performed 3/6/10
C SP 600.26-001, Auxiliary Building Safe Shutdown Portable Emergency Ventilation Fan
MTE 1122, MTE-00613 Calibration, Performed 5/2/08
MTE 1122, MTE-00666 Calibration, Performed 10/2/08
SP 2601 M-01, Operability Test of Facility 2 Charging Pumps from C-10, Performed 3/4/10
SP 2601 P, CVS Valve Operability Tests from C-10 and C-02, Performed 10/16/09
SP 2610BO-05, TDAFW Operational Tests from C-10, Performed 3/28/09
SP 261 OE, Atmospheric Dump Valve Testing from C-10, C-70AlB, Performed 10/11/09
SP 2610E-03, Atmospheric Dump Valve Testing, Performed 11/18/04
SP 2618C-01, Unit 2 Fire Protection System Smoke & Heat Detector Test, Performed 9/27/09
SP 2618D-03, Unit 2 "B" EDG Deluge System Function Test, Performed 6/03/10 & 12/07/09
SP 2618G, Fire Damper Operability Verification, Performed 7/25/09,12/09/08,11/28/08, &
10/27/08
SP 2618L-01, Fire Protection Coating Inspection, Performed 1/27/09 & 9/09/08
SP 2618L-02, TSI (Thermo-Lag) Fire Wrap Inspection, Performed 1/29/10
SP 2619C-01, Control Room Weekly Checks, Performed 8/1/10
SP 2619E-01, Control Room Monthly Checks, Performed 7/10/10
SP 3641 D.5, Fire Damper Operability Verification, Performed 8/25/08, 9/4/09, & 9/26/06
SP 3641 D.6, Fire Rated Assemblies Inspection, Performed 11/29/08
SP 3646A.1, Local Operation Test of "A" EDG, Performed 8/16/05 & 5/20/08
SP 3673.2-02, Transfer Switch 3HVP*FN1A & FN1C Function Test, Performed 12/30/08
SP 3673.2-03, Transfer Switch 3HVR*FN14A Function Test, Performed 10/13/08
SP 3673.2-04, Transfer Switch 3HVR*MOD50A Function Test, Performed 10/8/08
SP 3673.2-05, Transfer Switch 3HVR*ACU1A Function Test, Performed 8/14/08
SP 3673.2-06, Transfer Switch 3HVY*FN2A & AOD23A Function Test, Performed 10/1/08
SP 3673.2-07, Transfer Switch 3SWP*MOV54A1C Function Test, Performed 11/24/09
SP 3673.2-08, Transfer Switch 3SWP*MOV71A Function Test, Performed 12/29/08
SP 3673.2-09, Transfer Switch 3SWP*MOV102A1C Function Test, Performed 12/28/08
SP 3673.2-10, Transfer Switch 3RCS*PCV455A Function Test, Performed 5/8/10
SP 3673.2-11, Transfer Switch 3RCS*HCV442A Function Test, Performed 12/4/07
SP 3673.2-12, Transfer Switch 3SIL*HCV943A Function Test, Performed 6/14/08
SP 3673.2-13, Transfer Switch 3CHS*HCV190A Function Test, Performed 5/13/08
Attachment
A-10
SP 3673.4-02, Aux. Shutdown Panel Operability Test RHR Isolation, Performed 4/22/10
SP 3673.4-10, Aux. Shutdown Panel Operability Test, Charging Header MOVS, Performed
1/21/09
SP 3673.4-11, Aux. Shutdown Panel Operability Test, PORV Block Valve, Performed 6/14/08
SP 3673.4-12, Aux. Shutdown Panel Operability Test, SIL Accumulator Vent Valves, Performed
8/9/08
SP 3673.4-13, Aux. Shutdown Panel Operability Test, Charging Pump Cooling Pump A,
Performed 1/20109
SP 3673.4-21, Aux. Shutdown Panel Operability Test, Charging Isolation Path, Performed
4/30/10
.
SP 3673.5-01, Remote Shutdown Monitoring Instrumentation, Performed 5/28/10
SFP 17-01, Unit 2 Group-1 Fire Penetration Seal Inspection, Performed 3/11/04 & 6/24/98
SFP 17-02, Unit 2 Group-2 Fire Penetration Seal Inspection, Performed 7/12/05, 7/11/05, &
9/24/98
SFP 17-04, Unit 2 Group-4 Fire Penetration Seal Inspection, Performed 12/05/06
SFP 17-09, Unit 2 Group-9 Fire Penetration Seal Inspection, Performed 4/18/01 & 1/17/00
SFP 6, Fire Protection System Underground Main Flow and Flush Test, Performed 9/26/03
SFP 6, Fire Protection System Underground Main Flow and Flush Test, Performed 2/22/07
SFP 21-01, Unit 2 Appendix R Fire Cage Inventory, Performed 9/4/09
SPROC 97-3-15, Unit 3 Emergency Lighting Test, Performed 12/5/97
T3341CP, Unit 3 Initial C02 Discharge Test, West Switchgear Room, Performed 11/06/85
T3341CP, Unit 3 Initial C02 Discharge Test, Cable Spreading Room, Performed 11/08/85
T3341CP, Unit 3 Initial C02 Discharge Test, East MCC/Rod Control Area, Performed 11116/85
Condition Reports (* denotes NRC identified during this inspection)
CR-03-00383
CR-03-00448
CR-05-08134
CR-05-08437
CR-06-01133
CR-06-02202
CR-06-03953
CR-07 -08455
CR-07-11917
CR-07-12142
CR-08-01677
CR-08-02674
CR-08-05317
CR-08-05851
CR-08-06786
CR-08-08323.
CR-08-08741
CR108620
CR109594
CR119114
CR119611
CR119667
CR119726
CR121019
CR121147
CR137203
CR316336
CR317567
CR320599
CR323868
CR327233
CR327631
CR331 009
CR332133
CR332754
CR334825
CR336063
CR337602
CR340225
CR343586
CR344375
CR348684
CR358414
CR377915
CR378579
CR378689
CR378691
CR378695
CR378699
CR378936
CR378939
CR378940
CR378941
CR378944
CR378945
CR378950
CR378951
CR378954
CR380609
CR382675
CR382835
CR382866
CR382968
CR382979
CR383130
CR383152
CR383154
CR383205
CR383276
CR383304
CR383357
CR383363
CR383687
CR383841
CR384105
CR384243
CR384258
CR384311
CR384372
CR384384
CR384443
CR384805
CR385501*
CR385687*
CR387120*
CR387186*
CR387227*
CR387870
Attachment
CR388484*
CR388508*
CR388646*
CR388756*
CR388775
Work Orders
53130710605
53102310955
53102200513
53102269887
53102269887
Vendor Manuals
CR388786*
CR388788*
CR388807
CR388969
CR389332
53102270437
53102274953
53102276397
53102291903
53102292975
A-11
CR389495
CR389590
CR389660
CR389736
CR389876*
53102304691
M2-04-12928
M3-02-11954
M3-04-17886
M3-05-11850
8M-1-70, Instructions for Fisher Actuators Types 4960, 496U, and 486L
MS2 Vendor Inspection Report for UPS System, dated 1/4/10 and 4/14/10
Industry Standards
CR389972
CR390069*
CR390295*
M2-98-01891
M3-05-14068
M3-06-08987
M3-06-00018
M2-07-02847
M3-07-03861
Electric Power Research Institute (EPRI) TR-100249, Emergency Battery Lighting Unit
Maintenance and Application Guide, Rev. 1
NEI 2000-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Rev. 2
NFPA 13-1987, Installation of Sprinkler Systems
NFPA 27-1975, Private Fire Brigades
NRC RG 1.189, Fire Protection for Nuclear Power Plants, Rev. 2
NRC EGM 2007-004, Enforcement Discretion for Post-Fire Manual Actions Used as
Compensatory Measures for Fire induced Circuit Failures, 6/30107
NRC EGM 2009-002, Enforcement Discretion for Fire Induced Circuit Faults, 5/14/09
Miscellaneous Documents
Cable database printouts of cable routing for Valve 2-CH-429 in Fire Areas R1, R2 and R3
Cable database printouts of cable routing for Valve 2-MS-190B in Fire Areas R 1, R2 R 10
and R11
Calculation S-02824-S2, Millstone Unit 2, R-2 Fire, Appendix R Analysis, Rev. 2
Example of auxiliary building plant equipment operator rounds
Industry Position Paper on Use of Compensatory Measures for Multiple Spurious Operations,
4/16/2010
Letter B17399, 10CFR50, Appendix R Exemptions and Fire Protection Safety Evaluation Report
Comments, 3/17/1999
List of Millstone Power Station, Unit 2, expert panel members
Maintenance Rule Functional Failures Database Report on ELU Failures, 12/23/01 to 7122110
Millstone Power Station, Unit 2, Draft MSO Evaluation List
Millstone Power Station, Unit 2, Final Safety Analysis Report, Section 9.10
Millstone Power Station, Unit 2, Technical Requirements Manual, Sections 3.7.10 and 7.1
MP-2009-246, App-R ELU Recurring PM Tasks, 8/04/10
Attachment
A-12
N-2005-2208-E1, Review of NRC IN 05-14, Loss of Seal Cooling to Reactor Coolant Pumps
NEI 00-01, Guidance for Post Fire Safe Shutdown Analysis, Rev. 2
OE31606, Burn Mark on Plastic Lens Degrades Halogen Emergency Light, 7/19/10
Part 9900 Technical Guidance - Operability Determinations & Functionality Assessments for
Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety
Reasonable Assurance of Safety RAS000117, Rev. 0
Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, Rev. 2
Results of component cable routing on a fire area basis for Generic Multiple Spurious
Operation 9 (MSO 9), Reactor Coolant System Makeup Isolation; MSO 18, Multiple
PORVs; MSO 19, Multiple PORV Block Valves; and MSO 28, AUXiliary Feedwater Flow
Isolation"
Safety Evaluation Report, Revocation of Exemption from 10 CFR Part 50, Appendix R,
Sections III.G and III.L for Certain Fire Areas - Millstone Nuclear Power Station, Unit 2,
7/17/1990
Self Assessment SAR000506, Triennial Fire Protection Preparation Assessment, 6/9/2010
Site Fire Protection Impairment Tracking Report (Active), 7/01/10 to 7/10/10
SO-08-024, Unit 2 Operations Standing Order, 12/3/08
Status update slides related to fire induced circuit failureslmultiple spurious operations,
6/16/2010
Unit 2 Fire Protection Active Impairment List, 7/20/10
Unit 3 Fire Protection Active Impairment List, 7/19/10
ASSS
BAT
CFR
CMEB
CR
FCU
HRR
IMC
IP
LIST OF ACRONYMS
Alternating Current
[NRC] Agency-wide Documents Access and Management System
Auxiliary Feedwater System
American Society of Mechanical Engineers
Alternate Safe Shutdown System
Boric Acid Tank
[NRC] Branch Technical Position
Component Cooling Water
Core Damage Frequency
Code of Federal Regulations
[NRC] Chemical Engineering Branch
Carbon Dioxide
Condition Report
[NRC] Enforcement Guidance Memorandum
Emergency Lighting Units
Flow Control Valve
Fire Hazards Analysis
Heat Release Rate
[NRC] Inspection Manual Chapter
[NRC] Inspection Procedure
Attachment
IR
kV
NEI
NRC
PZR
TD
TI
A-13
Individual Plant Evaluation of External Events
[NRC] Inspection Report
kilo-volts
Loss of Coolant Accident
Motor Operated Valve
Nuclear Energy Institute
National Fire Protection Association
Non-Cited Violation
Nuclear Regulatory Commission
Piping and Instrumentation Drawing
Publicly Available Records
[NRC] Publicly Available Records
Pressurizer
Reasonable Assurance of Safety
Reactor Building Closed Cooling Water
Reactor Coolant Pump
[NRC] Regulatory Guide
Regulatory Issue Summary
Refuel Water Storage Tank
[NRC] Significance Determination Process
[NRC] Safety Evaluation Report
Safe Shutdown Analysis Report
Structures, Systems and Components
Switchgear
Turbine Driven
Temporary Instruction
Technical Requirements Manual
Updated Final Safety Analysis Report
[NRC] Unresolved Item
Volume Control Tank
Attachment