ML12229A128
| ML12229A128 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/16/2012 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Ventosa J Entergy Nuclear Operations |
| References | |
| IR-12-008, IR-12-009 | |
| Download: ML12229A128 (39) | |
See also: IR 05000247/2012009
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
't"ffi REGION I
21OO RENAISSANCE BOULEVARD, SUITE 1OO
KING OF PRUSSIA, PENNSYLVANIA 1940S'2713
August L6, 20L2
Mr. John Ventosa, Site Vice President
Entergy Nuclear Operations, lnc.
Indian Point Energy Center
450 Broadway, GSB
P.O. Box 249
Buchanan, NY 1051 1-0249
SUBJECT: INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC INSPECTION
REPORT 05000247t2012009 AND 0500028612012008 AND NOTICES OF
VIOLATION
Dear Mr. Ventosa:
On April 26,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
lndian Point Units 2and 3. The enclosed inspection report documents the inspection results
which were discussed on April 26, 2012, with Mr. Lawrence Coyle, and other members of your
staff. Following in-office reviews, an additional meeting was conducted by telephone with
Mr. Patric Conroy, Director, Nuclear Safety Assurance, on June 8,2012, and an exit meeting
was conducted by telephone with Mr. Patric Conroy and other members of your staff on
July 20, 2012.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commission's rules and regulations, and with the conditions of your
license. The inspectors reviewed the ongoing implementation of your corrective actions to
restore full compliance with Title 10 of the Code of Federal Regulations, Part 50, Appendix R,
Section lll.G.2 regarding denied exemptions to implement operator manual actions in lieu of
meeting the aforesaid fire protection regulations.
Two violations are cited in the enclosed Notices of Violation and the circumstances surrounding
them are described in detail in the subject inspection report. The violations were 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/enforcemenVenforce-pol.html.
The violations involved the use of unapproved operator manual actions to mitigate safe
shutdown equipment malfunctions caused by a fire-induced single spurious actuation at Indian
Point Units 2 and 3, in lieu of protecting the equipment in accordance with 10 CFR Part 50
Appendix R, Section lll.G.2. Although determined to be of very low safety significance (Green),
these violations are being cited in the Notices 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, Entergy Nuclear Operations, Inc. (ENO) failed to restore compliance within a
reasonable amount of time after the violations were identified to nuclear power plant licensees
in Regulatory lssue Summary 2006-10, Regulatory Expectations with Appendix R Paragraph
lll.G.2 Operator ManualActions, on June 30, 2006. You are required to 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.
J. Ventosa 2
One other finding of very low safety significance (Green) was also identified. This finding was
determined to be a violation of NRC requirements. However, because of its very low safety
significance, and because it 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 of the NRC
Enforcement Policy. lf 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
U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C.
20555-0001; with copies to the Regional Administrator, Region l; the Director, Office of
Enforcement; and the NRC Senior Resident Inspector at Indian Point Unit 2 or 3. In addition, if
you disagree with the cross-cutting aspect assigned to 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 l, and the Senior Resident Inspector at
f ndian Point Unit 2 or 3.
ln accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules
of Practice," a copy of this letter, its enclosure, and your response (if any)will be available
electronically for public inspection in the NRC Public Document Room or from the Publicly
Available Records (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).
Sincerely,
.'
4
i ;,/
dfr/--
/ John F. Rogge, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-247, 50-286
Enclosures:
1. Notice of Violation
2. nspection Report 05000247 l 20 1 2009 a nd 05000 286 l 20 1 2008
I
w/Attachment: Supplemental lnformation
cc Mencl: Distribution via ListServ
J. Ventosa 2
One other finding of very low safety significance (Green) was also identified. This finding was
determined to be a violation of NRC requirements. However, because of its very low safety
significance, and because it was entered into your corrective action program, the NRC is
treating this finding as a non-cited violation (NCV)consistent with Section2.3.2 of the NRC
Enforcement Policy. lf 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
U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C.
20555-0001; with copies to the Regional Administrator, Region l; the Director, Office of
Enforcement; and the NRC Senior Resident Inspector at Indian Point Unit 2 or 3. In addition, if
you disagree with the cross-cutting aspect assigned to 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 l, and the Senior Resident lnspector at
lndian Point Unit 2 or 3.
ln accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules
of Practice," a copy of this letter, its enclosure, and your response (if any) will be available
electronically for public inspection in the NRC Public Document Room or from the Publicly
Available Records (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).
Sincerely,
/RN
John F. Rogge, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-247, 50-286
Enclosures:
1. Notice of Violation
2. nspection Report 05000247 l 201 2009 and 05000 2861201 2008
I
w/Attachment: Supplemental Information
cc w/encl: Distribution via ListServ
DOCUMENT NAME: GlDRS\Engineering Branch 3\IPEC OMA Inspection\lP OMA Inspection Report.doc
ADAMS ACCESSION NUMBER: ML12229A128
V Non-Sensitive g Publicly Available
g suNstReview
n Sensitive n Non-PubliclyAvailable
OFFICE RI/DRS RI/DRS RI/ORA RI/DRP
NAME DOrr WSchmidt MMcLaughlin via email MGray via email
DATE 8t1t12 8t2t12 8t10t12 8t12t12
OFFICE RI/DRS RI/DRS
NAME JRogge CMiller via email
DATE 8116112 8t9t12
OFFICIAL
J. Ventosa 3
Distribution w/encl: via E-mail)
W. Dean, RA RIoRAMATL RESOURCE)
D. Lew, DRA RIORAMAlL RESOURCE)
D. Roberts, DRP RIDRPMAlL RESOURCE)
J. Clifford, DRP RIDRPMAlL RESOURCE)
C. Miller, DRS RIDRSMAIL RESOURCE)
P. Wilson, DRS RIDRSMATL RESOURCE)
S. Kennedy, Rl OEDO
M. Gray, DRP
B. Bickett, DRP
S. McCarver, DRP
M. Jennerich, DRP
A. Ayegbusi, Acting SRI
R. Montgomery, Acting Rl
P. Cataldo, SRI
N. Lafferty, Acting Rl
D. Hochmuth, AA
RidsNrrPM lndianPoint Resource
RidsNrrDorlLpll -1 Resource
ROPreport Resource
J. Rogge, DRS
D. Orr, DRS
W. Schmidt, DRS
J. Lilliendahl, DRS
ENCLOSURE 1
NOTICE OF VIOLATION - Indian Point Unit 2
Entergy Nuclear Operations, lnc. Docket No: 50-247
lndian Point Nuclear Generating Unit 2 License No: DPR-26
During an NRC inspection conducted April 23 through April 26, 2012, a violation of NRC
requirements was identified. ln accordance with the NRC Enforcement Policy, the violation is
listed below:
License Condition 2.K specifies, in part, that Entergy Nuclear Operations, lnc., (ENO) shall
implement and maintain in effect all provisions of the NRC-approved fire protection program
as described in the Updated Final Safety Analysis Report.
The Updated Final Safety Analysis Report, Section 9.6 specifies that ENO will meet the
requirements of 10 CFR Part 50, Appendix R, Section lll.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, 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.2i .
Contrary to the above, between June 30, 2006, and April 26,2012, ENO failed to implement
all provisions of the approved fire protection program. Specifically, the safe shutdown
strategy for Indian Point Unit 2 relied upon unapproved operator manual 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
lll.G.2, per the requirements in G.2.a - G.2.f . The specific operator manual actions and fire
areas and fire zones that are in violation of Appendix R, Section lll.G.2 are listed in the
lndian Point Unit 2 Denied OMA Summary Table of NRC Inspection Report
0500024712012009 and 0500028612012008. The use of manual actions in lieu of providing
the required protection requires prior NRC approval.
This violation is associated with a Green Significance Determination Finding.
Pursuant to the provisions of 10 CFR 2.201, ENO 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 RegionalAdministrator, Region l,
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" and should include for each violation:
(1) the reason for the violation, or, if 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. lf 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
Enclosure 1
2
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.
lf 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. lf 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. lf 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.9., 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). lf safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
f n accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 16th day of August, 2012
Enclosure 1
NOTICE OF VIOLATION - Indian Point Unit 3
Entergy Nuclear Operations, lnc. Docket No: 50-286
Indian Point Nuclear Generating Unit 3 License No: DPR-64
During an NRC inspection conducted April 23 through April 26, 2012, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
License Condition 2.H specifies, in part, that Entergy Nuclear Operations, Inc., (ENO) shall
implement and maintain in effect all provisions of the approved Fire Protection Program as
described in the Final Safety Analysis Report.
The Final Safety Analysis Report, Section 9.6.2 specifies that ENO will meet the
requirements of 10 CFR Part 50, Appendix R, Section lll.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, 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.z.t.
Contrary to the above, between June 30, 2006 and April 26, 2012, ENO failed to implement
all provisions of the approved fire protection program. Specifically, the safe shutdown
strategy for Indian Point Unit 3 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
lll.G.2, per the requirements in G.2.a - G.z.f . The specific operator manual actions and fire
areas and fire zones that are in violation of Appendix R, Section lll.G.2 are listed in the
Indian Point Unit 3 Denied OMA Summary Table of NRC lnspection Report
0500024712012009 AND 0500028612012008. The use of manual actions in lieu of providing
the required protection requires prior NRC approval.
This violation is associated with a Green Significance Determination Finding.
Pursuant to the provisions of 10 CFR 2.201, ENO 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 l,
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" and should include for each violation:
(1) the reason for the violation, or, if 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. lf an adequate reply is not received within the time specified
Enclosure 1
2
in this Notice, an order or a Demand for lnformation 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.
lf 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. lf 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. lf 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.9., 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). lf safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
ln accordance with 10 CFR 19.11 , you may be required to post this Notice within two working
days of receipt.
Dated this 16th day of August, 2012
Enclosure 1
ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos.: 50-247,50-286
ReportNos.: 0500024712012009,05000286/2012008
Licensee: Entergy Nuclear Operations, Inc. (ENO)
Facility: lndian Point Nuclear Generating Units 2 and 3
Location: 450 Broadway, GSB
Buchanan, NY 1051 1-0249
Dates: April 23 - April 26,2012
Inspectors: D. Orr, Senior Reactor Inspector
W. Schmidt, Senior Reactor Analyst
J. Lilliendahl, Reactor Inspector
Approved by: John F. Rogge, Chief
Engineering Branch 3
Division of Reactor Safety
Enclosure 2
SUMMARY OF FINDINGS
lR 0500024712012009, 0500028612012008; 412312012 - 412612012; Indian Point Nuclear
Generating Units 2 and 3; Annual Follow-up of Selected lssues Inspection.
The report covered a one-week annual follow-up of selected issues inspection by specialist
inspectors, Three findings of very low significance were identified. Two of these findings were
determined to be cited violations and one of these findings was determined to be a non-cited
violation. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using Inspection Manual Chapter (lMC) 0609, Significance Determination Process. Cross-
cutting aspects associated with findings are determined using IMC 0310, Components Within
The Cross-Cutting Areas. Findings for which the significance determination process (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.
Cornerstone: Mitigating Systems
. Green. The inspectors identified a finding of very low safety significance (Green),
involving a cited violation of lndian Point Unit 2 Operating License Condition 2.Kto
implement and maintain all aspects of the approved fire protection program.
Specifically, ENO 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 lll.G.2. In lieu of
protecting a redundant safe shutdown train, ENO utilized unapproved operator manual
actions to mitigate component malfunctions or spurious operations caused by postulated
single fire-induced circuit faults. ENO submitted an exemption request (M1090770151)
on March 6, 2009, in which it sought exemption from requirements of Paragraph lll.G.2,
to permit the use of OMAs upon which it had been relying for safe-shutdown in a number
of fire areas. However, several OMAs within the exemption request were denied
because ENO failed to demonstrate that the OMAs were feasible and reliable, or to
appropriately evaluate fire protection defense-in-depth. ENO's performance deficiency
delayed achieving full compliance with fire protection regulations and adversely affected
post-fire safe shutdown. ENO has entered this issue into the corrective program for
resolution. The inspectors found the manual actions in addition to roving fire watches in
all affected areas to be reasonable interim compensatory measures pending final
resolution by ENO.
ENO'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 safe
shutdown is not as reliable as normal systems operation which could be utilized had the
requirements of 10 CFR Part 50, Appendix R, Section lll.G.2 been met and, therefore,
prevented fire damage to credited components and/or cables. The inspectors used
IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 and
" 2
=nclosure
a Senior Reactor Analyst conducted a Phase 3 evaluation, to determine that this finding
was of very low safety significance (Green). This finding does not have a cross cutting
aspect because the performance deficiency occurred greater than three years ago when
the exemption request was submitted to the NRC on March 6, 2009, and is not indicative
of current licensee performance. (Section 4OA2.1)
Green. The inspectors identified a finding of very low safety significance (Green),
involving a cited violation of Indian Point Unit 3 Operating License Condition 2.H to
implement and maintain all aspects of the approved fire protection program.
Specifically, ENO 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 lll.G.2. In lieu of
protecting a redundant safe shutdown train, ENO utilized unapproved operator manual
actions to mitigate component malfunctions or spurious operations caused by postulated
single fire-induced circuit faults. ENO submitted an exemption request (M1090760993)
on March 6, 2009, in which it sought exemption from requirements of Paragraph lll.G.2,
to permit the use of OMAs upon which it had been relying for safe-shutdown in a number
of fire areas. However, several OMAs within the exemption request were denied
because ENO failed to demonstrate that the OMAs were feasible and reliable, or to
appropriately evaluate fire protection defense-in-depth. ENO's performance deficiency
delayed achieving full compliance with fire protection regulations and adversely affected
post-fire safe shutdown. ENO has entered this issue into the corrective program for
resolution. The inspectors found the manual actions in addition to roving fire watches in
all affected areas to be reasonable interim compensatory measures pending final
resolution by ENO.
ENO'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 postfire safe
shutdown is not as reliable as normal systems operation which could be utilized had the
requirements of 10 CFR 50, Appendix R, Section lll.G.2 been met and, therefore,
prevented fire damage to credited components and/or cables. The inspectors used
IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 and
a Senior Reactor Analyst conducted a Phase 3 evaluation, to determine that this finding
was of very low safety significance (Green). This finding does not have a cross cutting
aspect because the performance deficiency occurred greater than three years ago when
the exemption request was submitted to the NRC on March 6, 2009, and is not indicative
of current licensee performance. (Section 4OA2.2)
Green. The inspectors identified a Green, Non-Cited Violation of the lndian Point
Nuclear Generating Unit No. 2 Amended Facility Operating License, Condition 2.K, in
that ENO failed to implement and maintain in effect all provisions of the NRC-approved
fire protection program as described in the Updated Final Safety Analysis Report.
Specifically, ENO failed to minimize transient combustible materials within the primary
auxiliary building (PAB) and stored a compressed gas cylinder containing hydrogen gas
lll
Enclosure 2
under cable trays. The hydrogen gas cylinder was inappropriately left in its storage
location after a calibration gas cylinder change-out occurred for the waste gas analyzer,
ENO promptly entered this issue into its corrective action program and removed the
hydrogen cylinder from the PAB. ENO initiated a corrective action to evaluate the
identified condition and ensure actions to prevent its recurrence.
ENO's failure to remove the compressed hydrogen gas cylinder from the PAB after its
intended use as a calibration gas for the waste gas analyzer was a performance
deficiency. This finding was more than minor because it was associated with the
External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely
affects the cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences (i.e., core
damage). Specifically, the hydrogen gas cylinder was stored below cable trays in an
area that includes safe shutdown circuits and the associated cables were at increased
risk to fire damage. The inspectors used IMC 0609, Appendix F, Fire Protection
Significance Determination Process, Phase 1 and a Senior Reactor Analyst conducted a
Phase 3 evaluation, to determine that this finding was of very low safety significance
(Green). The inspectors determined that this finding had a cross-cutting aspect in the
area of Human Performance associated with the work practice attribute because ENO
personnel did not follow procedure, Control of Combustibles, EN-DC-161, Rev. 6, as
written and did not remove the hydrogen gas cylinder from the PAB after it was
disconnected from the waste gas analyzer contrary to Control of Combustibles,
EN-DC-161, Rev. 6. (H.4(b) per IMC 0310). (Section 4OA2.3)
B. Licensee-ldentified Violations
None.
iv
Enclosure 2
REPORT DETAILS
Backqround
The NRC requirements related to fire protection are provided in Title 10 of the Code of Federal
Regulations (CFR) Section 50.48. In accordance with 10 CFR 50.48(b), nuclear power plants
licensed to operate before January 1,1979 are required to meet Section lll.G, of 10 CFR Part 50, Appendix R. The underlying purpose of Section lll.G of 10 CFR Part 50, Appendix R, is
to ensure that the ability to achieve and maintain safe-shutdown is preserved following a fire
event.
Paragraph lll.G.2 of Appendix R requires one of the following means to ensure that a redundant
train of safe-shutdown cables and equipment is free of fire damage, where redundant trains are
located in the same fire area outside containment:
a. Separation of cables and equipment by a fire barrier having a three-hour rating;
b. Separation of cables and equipment by a horizontal distance of more than 20 feet with
no intervening combustibles or fire hazards and with fire detectors and an automatic fire
suppression system installed in the fire area; or,
c. Enclosure of cables and equipment of one redundant train in a fire barrier having a one-
hour rating and with fire detectors and an automatic fire suppression system installed in
the fire area.
lnside containments one of the fire protection means specified above or one of the following
fire protection means shall be provided:
d. Separation of cables and equipment and associated non-safety circuits of redundant
trains by a horizontal distance of more than 20 feet with no intervening combustibles or
fire hazards;
e. Installation of fire detectors and an automatic fire suppression system in the fire area; or
f. Separation of cables and equipment and associated non-safety circuits of redundant
trains by a noncombustible radiant energy shield.
However, as a result of safe-shutdown focused inspections conducted in 2000, the NRC
identified that, in lieu of the methods specified in Paragraph lll.G.2, some licensees, including
ENO, were crediting operator manual actions (OMAs) to achieve and maintain safe shutdown in
the event of a fire impacting areas in which both trains of a safe-shutdown system or component
are co-located.
ln 2006, the NRC issued Regulatory lssue Summary 2006-10, Regulatory Expectations with
Appendix R, Paragraph lll.G.2, Operator ManualActions, which clarified Appendix R and that
OMAs are not permitted, unless they have been specifically approved by the NRC as part of a
licensee's request for exemption from the requirements of Paragraph lll.G.2. The NRC also
issued EGM 07-004 (ML071830345), which granted enforcement discretion for licensees relying
on OMAs and provided until March 6, 2009 for licensees to complete corrective actions.
Corrective actions included establishing compliance with fire protection regulations or, as
appropriate, submitting an exemption request to the NRC to implement OMAs in lieu of fire
protection regulations.
Enclosure 2
2
ln response to this issue, on March 6, 2009, ENO submitted exemption requests for Indian Point
Nuclear Generating Units 2 and 3 (M1090770151 and M1090760993) in which it sought
exemption from certain requirements of Paragraph lll.G.2, to permit the use of OMAs upon
which it had been relying for safe-shutdown in a number of fire areas. Because the acceptability
of the OMAs was being considered under this exemption request, enforcement discretion
continued for the duration of the NRC review. The NRC considered ENO's exemption requests,
as supplemented by information provided by ENO in response to NRC requests for additional
information.
The period of enforcement discretion for noncompliance with NRC fire protection requirements
at lndian Point Nuclear Generation Units 2 and 3 ended with the NRC issuance of the
February 1,2012,letters (ML112140509 and ML112200442) documenting completion of the
NRC review. The NRC recognized that ENO implemented additional compensatory measures
(fire watches in all affected fire areas) to enhance the fire protection response in the areas. In a
triennial fire protection inspection in June 2011 (ML111920339), NRC inspectors assessed the
feasibility of these compensatory measures. In addition, NRC fire protection inspections have
verified that Indian Point Nuclear Generating Units 2 and 3 have implemented a defense-in-
depth fire protection program, including a site fire brigade, that is trained and equipped to
respond to and fight fires.
In order to determine how the denied OMAs affected ENO's compliance with Appendix R
requirements, the NRC requested information from ENO about the schedule and plans for
bringing Indian Point Nuclear Generating Units 2 and 3 into full compliance (M112031A176).
ENO responded on March 1,2012 (Mt12074A028) with a proposed schedule that showed full
restoration of compliance for all but two of the OMAs by the fourth quarter of 2012, and for the
finaltwo OMAs by the Unit 2 refueling outage in Spring 2014.
This report presents the results of a problem identification and resolution annual follow-up of
selected issues inspection conducted in accordance with NRC Inspection Procedure (lP) 71152,
Problem ldentification and Resolution to review ENO's implementation of corrective actions to
restore full compliance regarding the use of OMAs.
The objectives of this inspection were to:
a. Assess the adequacy of compensatory measures for unapproved OMAs;
b. Verify commitments to resolve all unapproved OMAs were appropriately entered into the
corrective action program (CAP);
c. Review updates to procedures, OMA feasibility and reliability studies, and safe-
shutdown analyses; and,
d. Review progress to date and the proposed schedule for restoring compliance.
Specific documents reviewed by the inspectors are listed in the attachment.
Enclosure 2
4. OTHER ACTTVTTIES [OAl
4OA2 Problem ldentification and Resolution (71152- 1 sample)
a. Inspection Scope
The inspectors assessed ENO's problem identification threshold, extent of condition
reviews, compensatory actions, and timeliness of corrective actions to determine
whether ENO was appropriately identifying, evaluating, and correcting problems
associated with unapproved OMAs.
The inspectors reviewed the fire hazard analysis, safe shutdown analysis and supporting
licensing and design basis documents to understand the structures, systems, and
components required for fire safe shutdown. The inspectors reviewed the fire safe
shutdown operating procedures to verify that all OMAs were either granted an exemption
or were being addressed by the corrective action program. The inspectors reviewed
condition reports to evaluate the adequacy of evaluations and corrective actions with
respect to the denied OMAs. The fire protection engineer and safe shutdown engineer
were interviewed to evaluate the feasibility of the proposed plan to restore compliance
and to assess corrective actions taken to date.
The inspectors previously walked down all denied OMAs as part of the 2011 triennial fire
protection inspection to assess the feasibility of the OMAs. The inspectors walked down
portions of the OMAs to re-validate the feasibility of the actions. The inspectors walked
down all fire zones that credited denied OMAs to assess the fire risk significance which
can be affected by ignition sources, transient and fixed combustibles, or absence of train
separation, detection, and automatic suppression.
The inspectors reviewed condition reports, fire watch logs, and fire protection program
impairment requirements to verify that compensatory measures in the form of fire
watches were being adequately performed as required by the fire protection program.
b. Findinos
1. Failure to Protect Safe Shutdown Eouipment from the Effects of Fire (Unit 2)
lntroduction. The inspectors identified a finding of very low safety significance (Green),
involving a cited violation of Indian Point Unit2 Operating License Condition 2.Kto
implement and maintain all aspects of the approved fire protection program.
Specifically, ENO 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 lll.G.2. In lieu of
protecting a redundant safe shutdown train, ENO utilized unapproved operator manual
actions to mitigate component malfunctions or spurious operations caused by postulated
single fire-induced circuit faults. ENO submitted an exemption request (M1090770151)
on March 6, 2009, in which it sought exemption from requirements of Paragraph lll.G.2,
to permit the use of OMAs upon which it had been relying for safe-shutdown in a number
of fire areas. However, several OMAs within the exemption request were denied
Enclosure 2
4
because ENO failed to demonstrate that the OMAs were feasible and reliable, or to
appropriately evaluate fire protection defense-in-depth. ENO's performance deficiency
delayed achieving full compliance with fire protection regulations and adversely affected
post-fire safe shutdown.
Description. On June 30, 2006, the NRC issued Regulatory lssue Summary (RlS)
2006-10, Regulatory Expectations with Appendix R, Paragraph lll.G.2, Operator Manual
Actions, which clarified Appendix R and that OMAs are not permitted, unless they have
been specifically approved by the NRC as part of a licensees request for exemption from
the requirements of Paragraph lll.G.2. In addition to information provided to the
licensees in RIS 2006-10, the NRC issued enforcement guidance memorandum (EGM)07-004, which granted enforcement discretion for licensees relying on noncompliant
OMAs to bring themselves back into compliance with the existing regulations, The
enforcement discretion provided licensees until March 6, 2009, to complete their
corrective actions.
ENO submitted exemption requests on March 6, 2009 for OMAs in several non-
compliant fire areas. The NRC considered ENO's exemption requests, as supplemented
by information provided by ENO in response to NRC requests for additional information.
On February 1,2012, the NRC denied many of the requested exemptions based on lack
of fire protection defense-in-depth, such as detection or automatic suppression, or lack
of time margin available to complete the OMA. The NRC's denial of several OMAs
within the exemption requests was based on guidance to the NRC staff and available to
the industry. NUREG 1852, Demonstrating the Feasibility and Reliability of OMAs in
Response to Fire, published October 2007, page 1-2, states that additional
considerations to ensure that adequate defense-in-depth such as fire detection and
suppression is maintained are addressed in Regulatory Guide (RG) 1 .189 and should be
considered when applying for an exemption or license amendment. RG 1 .189, Fire
Protection Program for Nuclear Power Plants, Rev. 1, March 2007, (in effect when
NUREG 1852 was issued) Section 5.3.3 similarly states that allfire-related operator
manual actions must be feasible and reliable. RG 1 .189 further states that the use of
operator manual actions does not obviate the detection and suppression capabilities that
are required by the regulations and in addition, the omission or elimination of these
capabilities in an area containing systems, structures, or components (including circuits)
important to safety would generally be considered an adverse effect on safe shutdown
since it would reduce, at a minimum, fire protection defense-in-depth.
ENO's failure to demonstrate that several OMAs were feasible and reliable, and to
appropriately evaluate fire protection defense-in-depth delayed achieving full compliance
with fire protection regulations and adversely affected post-fire safe shutdown. ENO
entered this issue into its CAP for long term resolution as CR-lP2-2012-00654. Interim
compensatory measures for the fire protection non-compliances included roving fire
watches in all affected fire areas and were initiated in June 2011. The inspectors
considered the interim compensatory measures reasonable pending final resolution.
ENO responded to the NRC in a letter dated March 1,2012 (ML120744028) with a
proposed schedule to resolve all Unit 2 non-compliances for all but two of the OMAs by
the fourth quarter o12012, and for the remaining two OMAs by the Unit 2 refueling
outage in Spring 2014.
Enclosure 2
5
Additionally, the inspectors identified that ENO failed to identify two OMAs that were
being relied upon to achieve and maintain safe shutdown in the event of a fire impacting
FZFlTA. During plant walkdowns, the inspectors noted an emergency control station
within the 480V switchgear room that provided an isolation function and start and stop
controls for the 21 charging pump. Entergy engineers informed the inspectors that the
emergency control station was installed as a plant modification under ER-lP2-03-21959
in 2003 to address a previously identified Appendix R cable separation concern in fire
zone (FZ) F/7A. The emergency control station isolates control circuits that terminate at
a local control panel for the charging pumps. The 21 charging pump can be isolated
from the effects of a fire in FZFITA and started in the 480V switchgear room from the
emergency control station. Entergy failed to include this unapproved operator manual
action in its exemption request submitted on March 6,2009 (M1090770151). During
interviews with Entergy engineers regarding the charging pump local control panel and
its impact on charging pump operation for a fire in FZ F 17 A, the inspectors also identified
that an additional OMA was necessary to operate the 21 charging pump. The additional
OMA required local operation of the 21 charging pump scoop tube positioner to control
the 2l charging pump speed. Entergy promptly entered these missed OMAs into its
corrective action program as CR-lP2-2012-03024 and verified the OMAs were feasible
and reliable and noted that fire watches as compensatory measures for other OMAs
within this fire zone remained in place. The inspectors considered Entergy's
compensatory measures and immediate corrective actions adequate for the missed
OMAs. Similar to the denied OMAs, Entergy planned to resolve the missed OMAs and
establish compliance with 10 CFR Part 50, Appendix R, Section lll.G.2.
Analvsis. The inspectors identified a performance deficiency in that ENO failed to
protect components credited for post-fire safe shutdown from fire-induced damage. The
denied OMAs, as well as the missed OMAs, were considered a single performance
deficiency as the apparent causalfactors were related, an inadequate review and
evaluation of operator manual actions, and also occurred when the exemption request
was submitted to the NRC on March 6, 2009. The performance deficiency was more
than minor because it was associated with the Protection against External Events (Fire)
attribute of the Mitigating Systems Cornerstone and negatively affected the 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 OMAs during post-fire shutdown is not as reliable as normal system operation from
the main control room which would be utilized had the requirements of 10 CFR Part 50,
Appendix R, Section 11,,.G2 been met. The inspectors used IMC 0609, Appendix F, Fire
Protection Significance Determination Process, Phase 1 and a Senior Reactor Analyst
conducted a Phase 3 evaluation, to determine that this finding was of very low safety
significance (Green). This finding does not have a cross cutting aspect because the
performance deficiency occurred greater than three years ago when the exemption
request was submitted to the NRC on March 6, 2009, and is not indicative of current
licensee performance.
The inspectors determined the issue did not screen to Green with a Phase 1 SDP
because the finding category was post-fire safe shutdown and involved operator manual
actions. A Phase 3 SDP was performed by a Senior Reactor Analyst (SRA) because the
Fire Protection Phase 2 SDP is intended to support the assessment of known issues
Enclosure 2
6
only in the context of an individual fire area and this issue involved multiple fire areas
and fire zones. However, the SRA determined the Phase 2 SDP tools could be used on
an area by area basis to inform the Phase 3 SDP and screen fire zones if a sufficient
basis was developed for each fire zone and justified an absence of credible fire
scenarios such that mitigating equipment or its associated cables would not be damaged
or a plant transient would not occur. Guidance in each attachment of IMC 0609,
Appendix F was applied in addition to the following assumptions specific for lndian Point
Nuclear Generating Unit 2 cable construction and detail:
All cables are treated as thermoplastic with damage potential described in Tables
A7.2 and 47.3:
All cables are jacketed with an asbestos braid and do not act as intervening
combustibles or contribute to fire spread; and,
Asbestos cable jacket is not credited as a thermal or radiant heat shield.
The inspectors walked down each of the individual fire zones to identify potential fire
damage scenarios to circuits that were not protected to the requirements of 10 CFR Part 50, Appendix R, Paragraph lll.G.2. For the vapor containment fire area and its
associated operator manual actions, the inspectors reviewed a video that was recorded
by the licensee in the previous Unit 2 refueling outage specifically for this inspection
purpose and at the request of the NRC inspectors.
A summary of the risk evaluation for each OMA and its associated denied or missed
OMAs is in a table at the end of this Analysis section. In general, all of the fire zones
except FZFI6 screened out because:
Detailed circuit and cable analysis demonstrated that cable damage could not
cause spurious operations to credited safe shutdown equipment. The safe
shutdown analysis that was used by ENO to formulate conclusions on the
protection of safe shutdown capability in their exemption request was overly
conservative. Because damage to these cables would not cause a malfunction
of safe shutdown equipment, the associated OMAs were unnecessary and were
not violations of 10 CFR Part 50, Appendix R, lll.G.2.;
An ignition source did not exist that could credibly cause cable damage. The
cables were sufficiently separated from all fixed ignition sources to not be
damaged from thermal or radiant heat and a transient fire with an assumed origin
two feet above the floor would also not generate sufficient thermal or radiant heat
to damage cables at their high elevations; or,
The only credible ignition source was a transient combustible fire and the
associated weighting factor was very low, i.e., the critical floor area was much
smaller than the plausible floor area for the assumed transient combustible fire.
For fire zone FG and its associated denied OMA, OMA 6, the postulated fire resulted
from an oil leak of the 22 charging pump fluid drive causing damage to the pump itself
and the cabling associated with the operation and controls for the charging pump suction
valves. There are two suction paths available to the charging pumps: 1) the volume
control tank (VCT) from a normally open motor operated valve (MOV) 112C which is
physically located in the VCT room, and 2) the refueling water storage tank (RWST) from
Enclosure 2
7
a normally closed air operated valve (AOV) 1128, which is located in the 22 charging
pump cellor FZFl6. Valve 112B is designed to open automatically in the event of a low
VCT level through 1 128 valve position monitoring circuitry. Under these conditions,
1 12C would also close. The fire was conservatively assumed to render 1128 failed
closed and close 1 12C due to cable damage to the 1 128 position monitoring circuit. The
denied OMA 6 included actions within FZ Fl6 to locally open the 1128 bypass valve 288
and in the VCT room to verify closed 112C. These actions were necessary to align the
RWST as a suction source before starting the credited 21 charging pump from the main
control room.
Due to uncertainties involved in fire induced core damage assessment, the SRA
conducted two bounding analyses: 1) a fire model case based on fire modeling which
assumed that only equipment in the subject fire area was potentially damaged and all
other equipment failed probabilistically, and 2) an Appendix R case where only
equipment credited in the safe shutdown analysis was available. For the Phase 3 SDP
results, the SRA chose the fire model case as it represented the more realistic plant and
operator response to a potential fire in FZFl6.
Both analyses were conducted for FZ F/6 using the lP2 SPAR model version 8.20 to
estimate the increase in conditional core damage probability if the denied OMAs were
needed vice not needed and Appendix R requirements were met such that all mitigating
operations were available from the control room. The lP2 SPAR model credits the
charging pumps as an emergency boration source during an anticipated transient
without scram (ATWS) and as a source of reactor coolant pump (RCP) seal injection.
RCP seal injection along with the RCP thermal barrier cooling from the closed cooling
water system (CCW) provides RCP seal cooling and precludes a RCP sealfailure loss
of coolant accident. This core damage analysis differed from the Appendix R guidelines
to maintain or restore RCS pressurizer level. An independent Region I SRA reviewed
and found acceptable the SPAR model changes made to conduct these analyses. Both
analyses assumed that a fire in FZFI6 would:
Occur at a frequency of 5.0E-5 per year consistent with Attachment 4 of the Fire
Protection SDP for a pump oilfire;
a Only occur if the 22 charging pump was running;
a Fail the 22 charging pump;
a Fail1128 closed; and,
a Result in operator responses in accordance with procedures;
o A manually initiated reactor trip, which was reflected as a transient
initiation event; and,
o Removing pressurizer power operated relief valve (PORV) control power
fuses in the control room to prevent spurious PORV operation. This
action was assumed always successful. For ATWS sequences, it was
assumed that all PORVs and RCS safety valves would be open and that
operators would not remove fuses to close the PORVS, but would
continue to recover a charging pump and establish emergency boration.
Enclosure 2
I
The fire model analysis estimated an increase in the core damage frequency less than
1E-9, if the OMAs were not successful, given the estimated22 charging pump lube oil
fire occurred at a frequency of 5E-5 per year and the very limited credit afforded the
charging pumps in core damage mitigation. The dominating core damage sequence
involving the OMAs was an ATWS following the manual reactor trip caused by
mechanical binding of all the control rods, and a failure of operators to manually open
288 to establish emergency boration with the 21 charging pump. The negligible increase
in core damage frequency was also due to the extremely low probability of an ATWS
where emergency boration would be necessary or a common cause failure of the service
water system which would lead to a RCP seal failure. This analysis allowed normal
plant equipment to remain functional provided it was not damaged as a result of the fire
scenario based on fire modeling. The fire model analysis assumed that a fire in FZFI6
would:
. Fail 112C closed with the probability of an intra-conduit hot short of 0.05, based
on NUREG/CR-6850. Fail112C open with a 0.95 probability. lf 112C failed
open, it must be closed to restore the RWST suction to the 21 charging pump.
. Not generate a damaging hot gas layer nor damage any equipment in the
adjacent primary auxiliary building corridor, FZFlTA. This assumption was
based on fire modeling.
. Result in control room operators in accordance with procedure promptly disabling
the 21 charging pump from automatic operation. This action is required by
procedure to preclude damage to the 21 charging pump should it operate without
a water source aligned to its suction as the result of spurious^valve operations. A
failure probability of 1.1E-2 was assumed based on SPAR-H', assuming
diagnosis and allfactors in their nominal state.
. Result in operators implementing the denied OMAs in accordance with
procedures and specifically aligning the RWST to the charging pumps suction
after the fire is extinguished and includes:
o Manually opening valve 288 with a failure probability of 2.3E-l assumed
based on SPAR-H with all factors in their nominal state except for high
stress and conservatively assuming barely sufficient time.
o Verify or close 1 12C with a failure probability o'f 2.3E-1 assumed based
on SPAR-H with all factors in their nominal state except for high stress
and conservatively assuming barely sufficient time.
. Result in control room operators, starting the 21 charging pump, in accordance
with procedure, once suction to the RWST was aligned by the OMAs. A failure
probability of 1.1E-2 was assumed based on SPAR-H assuming diagnosis and
all factors in their nominal state.
The Appendix R analysis estimated an increase in the core damage frequency in the
mid-E-7 range. The Appendix R analysis assumed no credit afforded the charging
pumps in the dominating core damage sequence. In the Appendix R analysis, the
OMAs did not impact the core damage frequency results. The dominating core damage
sequence involved a RCP loss of seal cooling event leading to a small loss of coolant
accident due to RCP sealfailure at a leak rate of 182 gpm per RCP and successful
operation of the 21 AFW train. Although 21 AFW was successful, core damage occurs
because the reactor cannot be depressurized because PORV fuses are removed by
Enclosure 2
9
procedure failing the PORVs closed, and high pressure coolant injection is assumed to
have failed in the Appendix R analysis. lf a loss of RCP seal cooling does not occur, the
dominant core damage sequence included failure of the 21 AFW train (in the range of
1 in 125) and the inability, using high pressure coolant injection and the PORVs (feed
and bleed), to remove decay heat. The Appendix R analysis assumed that a fire in the
FZF16 would:
. Cause a loss of RCP seal cooling and subsequent RCP sealfailure. A loss of
RCP seal cooling occurred due to the fire induced closures of 112C and a CCW
system MOV in the RCP thermal barrier cooling flow path. In this case, with a
fire in the 22 charging pump cell, operators would not be able to open valve 288
to establish a suction path to the 21 charging pump in sufficient time to prevent
the assumed RCP sealfailure.
. Cause a failure of all equipment within fire area F including:
o Both trains of high pressure injection.
o 22train of low pressure injection.
o Motor control centers 264 and 268.
o Cause failure of the 22 motor driven and 23 turbine driven AFW pumps.
The table below summarizes the results for each OMA with its respective fire zone:
Indian Point Unit 2 Denied OMA Summary Table
Fire OMA No.' Violation of lll.G.2 Risk
Area/ lncrease
Zone Comments Results
F/5A No Based on circuit reviews, cables of interest within this No increase
FZ do not result in a spurious operation that
necessitates this OMA.
Ft6 Yes This area required a detailed phase 3 SDP analysis. Negligible
The inspectors assumed a 5200kW fire from 54 increase
gallons of oil leaked from the 22 charging pump fluid based on
drive within a 40 sqft skid 15.5ft directly below cable detailed
YZ1-J85. Details of the phase 3 SDP analysis are Phase 3
described in the analysis section prior to this table. SDP
analysis
No Based on circuit reviews, cables of interest within this No increase
FZ do not result in a spurious operation that
necessitates this OMA.
FITA Yes There were no fixed or assumed transient Screened
combustible ignition sources that could credibly based on
damage cable YZ1-JB1 which is located 14ft above Phase 2
the floor. SDP tasks
Enclosure 2
10
Based on circuit reviews, cables of interest within this No increase
FZ do not result in a spurious operation that
necessitates this OMA.
The only credible ignition source was a transient Screened
combustible fire and the associated transient based on
weighting factor was very low, i.e. an 8sqft critical Phase 2
floor area compared to 6000sqft plausible floor area SDP tasks
equals a 2.3E-7 area weighting factor.
Yes See above, same as FlTA for OMA 20. Screened
based on
Phase 2
SDP tasks
No Based on circuit reviews, cables of interest within this No increase
FZ do not result in a spurious operation that
necessitates this OMA,
Ft27A 5 Yes This OMA involves opening a manual valve, 227, to Screened
align a charging path to the reactor coolant system if based on
the normally open air operated valve, HCY-l42, were Phase 2
to close from a loss of instrument air (lA). Circuits to SDP tasks
HCV-142 do not route through the associated FZs.
Therefore this OMA is only necessary for a fire
induced loss of lA. The inspectors walked down
each FZ and did not identify any lA lines near ignition
sources. Additionally, a loss of lA resulting from the
spurious operation of several lA loads and a
subsequent high demand on the lA system would
require multiple spurious operations.
F/33A 6 Yes The only credible ignition source to cable CK1-YP3, No increase
power supply cable to 112C, is the motor control
center where CK1-YP3 terminates. This is a fire
damage state zero scenario (FDSO). FDSO
scenarios are not analyzed in the SDP as a risk
contributor. See step 2.2 of IMC 0609, Appendix F.
5 Yes See above, same as Fl27A for OMA 5. Screened
based on
Phase 2
SDP tasks
F/594 5 Yes See above, same as Fl27 A for OMA 5. Screened
based on
Phase 2
SDP tasks
Enclosure 2
11
Ht72A I Yes This FZ is in the vapor containment (VC) and was Screened
not accessible to the inspectors for walkdown, NRC based on
inspectors walkdown the VC as part of the baseline Phase 2
inspection program following plant outages and just SDP tasks
prior to plant startup in part to verify the licensee has
thoroughly removed all outage materials and
combustibles. The licensee performs similar
inspections prior to startup. The inspectors observed
the FZ using a video recording taken by the licensee
during the most recent refuel outage. Additionally,
the inspectors reviewed the spatial separation
between ignition sources and cables of concern as
described in ENO's September 29,2010 response to
the NRC's request for additional information on
August 1 1, 2010 (ML1 02930237).
Hl75A 8,9, 10 Yes See above, same as Hl72A for OMA 8. Screened
based on
Phase 2
SDP tasks
Hl77 A 8, 9, 10 Yes See above, same as Hl72A for OMA 8. Screened
based on
Phase 2
SDP tasks
H/84A 8 Yes See above, same as Hl72A for OMA 8. Screened
based on
Phase 2
SDP tasks
H/85A 8 Yes See above, same as Hl72A for OMA 8. Screened
based on
Phase 2
SDP tasks
Hl87 A 8, 9, 10 Yes See above, same as Hl72A for OMA 8. Screened
based on
Phase 2
SDP tasks
Jt19 11 No Based on circuit reviews, cables of interest within this No increase
FZ do not result in a spurious operation that
necessitates this OMA.
Jt25 12 No See above, same as J/19 for OMA 11. No increase
J/39A 11,12
No See above, same as J/19 for OMA 11. No increase
Enclosure 2
12
Jl43A 11, 12, 13 No See above, same as J/19 for OMA 11. No increase
Jt45A 11 No See above, same as J/19 for OMA 11. No increase
Jl46A 11, 12, 13 No See above, same as J/19 for OMA 1 1. No increase
Jl47A 11 No See above, same as J/19 for OMA 11. No increase
J/50A 11,12 No See above, same as J/19 for OMA 11. No increase
J1270 12 No See above, same as J/19 for OMA 11. No increase
K60A 14,15, 19 Yes Based on circuit reviews there are no cables within Screened
these FZs that also result in a loss of main feedwater based on
with the assumed fire-induced loss of auxiliary Phase 2
feedwater from cable damage. Therefore a fire SDP tasks
within this fire zone will not result in a plant transient
from spurious operations.
l(654 14,15,19 Yes Based on circuit reviews there are no cables within Screened
these FZs that also result in a loss of main feedwater based on
with the assumed fire-induced loss of auxiliary Phase 2
feedwater from cable damage. Therefore a fire SDP tasks
within this fire zone will not result in a plant transient
from spurious operations.
1As
identified in table on pages 1 through 4 of Attachment 1 to ENO response letter to the NRC
dated March 1,2012 (M112074A028). OMAs 20 and 21 were NRC identified during plant
walkdowns and are described in the following list.
Description of Indian Point Unit 2 Denied OMAs
5. Open HCV-142 bypass valve 227 to align charging pump makeup path to the reactor
coolant system (RCS).
6. Align charging pump suction source to the refueling water storage tank (RWST).
7. Transfer instrument buses 23 and 23A to alternate power.
8. Fail open valves 2044 (charging flow to the RCS loop 2 hot leg) and 2Q4B (charging flow
to RCS loop 1 cold leg) to align charging pump makeup path to the RCS.
9. Activate or enable alternate safe shutdown system (ASSS) pneumatic instruments
(steam generator level, pressurizer pressure and pressurizer level) at the fan house local
control panel.
10. Enable ASSS source-range channel and RCS loop 21 and 22 hot leg and cold leg
temperature channels.
Enclosure 2
13
11. Trip breakers 52l5A and 52-SAC on Bus 5A and 5216A and 52ffAO at Bus 64 and
remove control power fuses.
12. Transfer instrument buses 23 and 23A to emergency power source.
13. Align charging pump suction to the RWST.
14. Operate transfer switch EDCS and close supply breaker at substation 12FD3 to transfer
the 2l auxiliary feedwater pump (AFW) to the ASSS power source.
15. Open the 21AFW pump recirculation bypass valve BFD-77.
19. Operate the 21AFW pump flow control valves to control AFW flow to steam generators
21 and 22.
20. Locally operate the 21 charging pump scoop tube positioner. OMA 20 was NRC
identified during plant walkdowns and its use in lieu of meeting 10 CFR Part 50,
Appendix R, Section lll.G.2 requirements was not included in the exemption request
submitted to the NRC on March 6, 2009 (M1090770151).
21. Locally start the 21 charging pump using the emergency control station located in the
480V switchgear room. OMA 21 was NRC identified during plant walkdowns and its use
in lieu of meeting 10 CFR 50, Appendix R, Section lll.G.2 requirements was not included
in the exemption request submitted to the NRC on March 6, 2009 (M1090770151 ).
Enforcement. Indian Point Unit 2 Operating License Condition 2.K specifies, in part, that
Entergy Nuclear Operations, lnc., shall implement and maintain in effect all provisions of
the approved Fire Protection Program as described in the Updated Final Safety Analysis
Report. The Updated Final Safety Analysis Report, Section 9.6 specifies that ENO will
meet the requirements of 10 CFR Part 50, Appendix R, Section lll.G.2 which identifies
the means of protecting post-fire safe shutdown equipment from fire damage. Contrary
to the above, between June 30, 2006 and April 26, 2012, ENO failed to implement their
fire protection program by using one of the means described in Appendix R,
Section lll.G.2 to protect circuits required for post-fire safe shutdown from fire-induced
circuit damage. Specifically, ENO used unapproved operator manual actions to mitigate
post-fire safe shutdown equipment malfunctions without having obtained NRC approval.
The specific operator manual actions and fire areas and fire zones that are in violation of
Appendix R, Section lll.G.2 are listed in the Indian Point Unit 2 Denied OMA Summary
Table of this inspection report. 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, ENO failed to restore compliance within a reasonable amount of
time after the violation was identified in RIS 2006-10 on June 30, 2006.
VfO 0500024712012009-01, Failure to Protect Safe Shutdown Equipment from the
Effects of Fire.
Enclosure 2
14
2. Failure to Protect Safe Shutdown Equipment from the Effects of Fire (Unit 3)
Introduction. The inspectors identified a finding of very low safety significance (Green),
involving a cited violation of lndian Point Unit 3 Operating License Condition 2.H to
implement and maintain all aspects of the approved fire protection program.
Specifically, ENO 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 lll.G.2. In lieu of
protecting a redundant safe shutdown train, ENO utilized unapproved operator manual
actions to mitigate component malfunctions or spurious operations caused by postulated
single fire-induced circuit faults. ENO submitted an exemption request (M1090760993)
on March 6, 2009, in which it sought exemption from requirements of Paragraph lll.G.2,
to permit the use of OMAs upon which it had been relying for safe-shutdown in a number
of fire areas. However, several OMAs within the exemption request were denied
because ENO failed to demonstrate that the OMAs were feasible and reliable, or to
appropriately evaluate fire protection defense-in-depth. ENO's performance deficiency
delayed achieving full compliance with fire protection regulations and adversely affected
post-fire safe shutdown.
Descriotion. On June 30, 2006, the NRC issued Regulatory lssue Summary (RlS)
2006-10, Regulatory Expectations with Appendix R, Paragraph lll.G.2, Operator Manual
Actions, which clarified Appendix R and that OMAs are not permitted, unless they have
been specifically approved by the NRC as part of a licensees request for exemption from
the requirements of Paragraph lll.G.2. In addition to information provided to the
licensees in RIS 2006-10, the NRC issued enforcement guidance memorandum (EGM)07-004, which granted enforcement discretion for licensees relying on noncompliant
OMAs to bring the facility back into compliance with the existing regulations. The
enforcement discretion provided licensees until March 6, 2009, to complete corrective
actions,
ENO submitted exemption requests on March 6, 2009 for OMAs in several non-
compliant fire areas. The NRC considered ENO's exemption requests, as supplemented
by information provided by ENO in response to NRC requests for additional information
and on February 1,2012, the NRC denied many of the requested exemptions based on
lack of fire protection defense-in-depth, such as detection or automatic suppression, or
lack of time margin available to complete the OMA. The NRC's denial of several OMAs
within the exemption requests was based on guidance to the NRC staff and available to
the industry. NUREG 1852, Demonstrating the Feasibility and Reliability of OMAs in
Response to Fire, published October 2007 , page 1-2, states that additional
considerations to ensure that adequate defense-in-depth such as fire detection and
suppression is maintained are addressed in Regulatory Guide 1.189 and should be
considered when applying for an exemption or license amendment. RG 1.189, Fire
Protection Program for Nuclear Power Plants, Rev. 1, March 2007, (in effect when
NUREG 1852 was issued) Section 5.3.3 similarly states that allfire-related operator
manual actions must be feasible and reliable. RG 1 .189 further states that the use of
operator manual actions does not obviate the detection and suppression capabilities that
are required by the regulations and in addition, the omission or elimination of these
capabilities in an area containing systems, structures, or components (including circuits)
Enclosure 2
15
important to safety would generally be considered an adverse effect on safe shutdown
since it would reduce, at a minimum, fire protection defense-in-depth.
ENO's failure to demonstrate that several OMAs were feasible and reliable, and to
appropriately evaluate fire protection defense-in-depth delayed achieving full compliance
with fire protection regulations and adversely affected post-fire safe shutdown. ENO
entered this issue into its CAP for long term resolution as CR-lP3-2012-00369. lnterim
compensatory measures for the fire protection non-compliances included roving fire
watches in all affected fire areas and were initiated in June 2011. The inspectors
considered the interim compensatory measures reasonable pending final resolution.
ENO responded to the NRC in a letter dated March 1,2012, (M112074A028) with a
proposed schedule to resolve all Unit 3 non-compliances by the fourth quarter of 2012.
Analvsis. The inspectors identified a performance deficiency in that ENO failed to
protect components credited for post-fire safe shutdown from fire-induced damage. The
performance deficiency was more than minor because it was associated with the
Protection against External Events (Fire) attribute of the Mitigating Systems Cornerstone
and negatively affected the 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 OMAs during post-fire shutdown is not as reliable
as normal system operation from the main control room which would be utilized had the
requirements of 10 CFR Part 50, Appendix R, Section lfl.G.2 been met. The inspectors
used IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase
1 and an SRA conducted a Phase 3 evaluation, to determine that this finding was of very
low safety significance (Green). This finding did not have a cross cutting aspect
because the performance deficiency occurred greater than three years ago when the
exemption request was submitted to the NRC on March 6, 2009, and is not indicative of
current licensee performance.
The inspectors determined the issue did not screen with a Phase 1 SDP because the
finding category was post-fire safe shutdown and involved operator manual actions. A
Phase 3 SDP was performed by a Senior Reactor Analyst (SRA) because the Fire
Protection Phase 2 SDP is intended to support the assessment of known issues only in
the context of an individual fire area and this issue involved multiple fire areas and fire
zones. However, the SRA determined the Phase 2 SDP tools could be used on an area
by area basis to inform the Phase 3 SDP and screen firg zones if a sufficient basis was
developed for each fire zone and justified an absence of credible fire scenarios, such
that mitigating equipment or its associated cables would not be damaged or a plant
transient would not occur. Guidance in each attachment of IMC 0609, Appendix F was
applied in addition to the following assumptions specific for lndian Point Nuclear
Generating Unit 3 cable construction and detail:
. All cables are treated as thermoplastic with damage potential described in Tables
47.2 and 47.3;
. All cables are jacketed with an asbestos braid and do not act as intervening
combustibles or contribute to fire spread; and,
o Asbestos cable jacket is not credited as a thermal or radiant heat shield.
Enclosure 2
16
The inspectors walked down each of the individual fire zone to identify potentialfire
damage scenarios to circuits that were not protected to the requirements of 10 CFR
Part 50, Appendix R, Paragraph lll.G.2.
One of the unapproved OMAs which was associated with several fire zones was local
manual operation of the service water pump strainer backwash. This OMA was
determined to be beyond the scope of an OMA and was documented in a Green non-
cited violation in 201 1 (lnspection Report 05000286/201 1008, ML1 1 1920339), The very
low risk for this OMA was related to the very low likelihood of ever needing the strainer
backwash to operate during a post-fire safe shutdown. With the exception of
FZPAB 2{3}/6, all remaining fire zones and associated OMAs screened because there
were no fixed or assumed transient combustible ignition sources that could credibly
damage the cable of concern within the fire zones.
For FZ PAB-2{3/6, the 32 charging pump cubicle, the SRA assumed a lube oil fire while
the 32 charging pump was in operation damages cables to the volume control tank
(VCT) motor operated outlet valve (112C). The SRA compared differences between
Unit 2 and Unit 3 for the 22 and 32 charging pump cubicle fire scenarios. The only noted
differences between plant configurations or operating procedures was the 1128 valve
design and the fire zone configurations. The 1 128 valve at Unit 2 was a normally closed
air operated valve, and at Unit 3 the 1 128 valve was a normally closed motor operated
valve. At Unit 3, the 31 and 32 charging pumps were in the same fire zone (PAB-2{3yO),
but an exemption was previously granted that found the fire barriers between the
charging pump cubicles acceptable and the 31 charging pump was credited in the event
of a fire in the 32 charging pump cubicle. Both differences between the Unit22 and 32
charging pump fire scenario would not change the fire damage or risk analysis
assumptions. Because there was no applicable difference between the Unit 2 and Unit 3
charging pump fire scenario, the results of the Unit 2 detailed Phase 3 SDP analysis can
be used to determine that the increased risk from this fire scenario is negligible.
The table below summarizes the results for each OMA with its respective fire zone:
Indian Point Unit 3 Denied OMA Summary Table
Risk
Area/ Increase
Zone Comments Results
ETN- 6,8 Yes There were no fixed or assumed transient Screened
4{11/ combustible ignition sources that could credibly based on
7A damage the cable of concern in this area. Phase 2
SDP tasks
ETN- 5,6,8,9,10, Yes There were no fixed or assumed transient Screened
4{1ll 11,12 combustible ignition sources that could credibly based on
60A damage the cable of concern in this area. Phase 2
SDP tasks
Enclosure 2
17
13 Yes This OMA was previously identified as a violation Previously
during the last triennialfire protection inspection and evaluated
was documented in that report as a very low safety as very low
significance (Green) NCV.
ETN- 14,15,16, Yes There were no fixed or assumed transient Screened
4{3It 17 combustible ignition sources that could credibly based on
734 damage the cable of concern in this area. Phase 2
SDP tasks
PAB- 18 Yes This zone was described in detail in the analysis Negligible
2{3}l section above this table. based on
6 detailed
Phase 3
analysis
PAB- 22 Yes There were no fixed or assumed transient Screened
2{5ll combustible ignition sources that could credibly based on
174 damage the cable of concern in this area. Phase 2
SDP tasks
PAB- 19,20 Yes There were no fixed or assumed transient Screened
2{5}l combustible ignition sources that could credibly based on
19A damage the cable of concern in this area. Phase 2
SDP tasks
PAB- 22 Yes There were no fixed or assumed transient Screened
2{5}l combustible ignition sources that could credibly based on
204 damage the cable of concern in this area. Phase 2
SDP tasks
PAB- 22 Yes There were no fixed or assumed transient Screened
2{5ll combustible ignition sources that could credibly based on
274 damage the cable of concern in this area. Phase 2
SDP tasks
PAB- 22 Yes There were no fixed or assumed transient Screened
2{5Il combustible ignition sources that could credibly based on
304 damage the cable of concern in this area. Phase 2
SDP tasks
PAB- 21 Yes There were no fixed or assumed transient Screened
2{5}l combustible ignition sources that could credibly based on
59A damage the cable of concern in this area. Phase 2
SDP tasks
Enclosure 2
18
TBL- 25 Yes This OMA was previously identified as a violation Previously
5137A during the last triennialfire protection inspection and evaluated
was documented in that report as a very low safety as very low
significance (Green) NCV.
TBL- 25 Yes This OMA was previously identified as a violation Previously
5/38A during the last triennialfire protection inspection and evaluated
was documented in that report as a very low safety as very low
significance (Green) NCV.
TBL. 25 Yes This OMA was previously identified as a violation Previously
5t43A during the last triennialfire protection inspection and evaluated
was documented in that report as a very low safety as very low
significance (Green) NCV.
TBL- 25 Yes This OMA was previously identified as a violation Previously
5t44A during the last triennial fire protection inspection and evaluated
was documented in that report as a very low safety as very low
significance (Green) NCV.
TBL- 23,24 Yes There were no fixed or assumed transient Screened
5t52A combustible ignition sources that could credibly based on
damage the cable of concern in this area. Phase 2
SDP tasks
TBL- 24 Yes There were no fixed or assumed transient Screened
5t54A combustible ignition sources that could credibly based on
damage the cable of concern in this area. Phase 2
SDP tasks
YARD 26 Yes There were no fixed or assumed transient Screened
-71 combustible ignition sources that could credibly based on
222 damage the cable of concern in this area. Phase 2
SDP tasks
27 Yes This OMA was previously identified as a violation Previously
during the last triennialfire protection inspection and evaluated
was documented in that report as a very low safety as very low
significance (Green) NCV.
2As
identified in table on pages 1 through 5 of Attachment 2 to ENO response letter to the NRC
dated March 1, 2Q12 (ML1207 4A028).
Description of Indian Point Unit 3 Denied OMAs
5, Operate HCV-1118 manually to control 32 AFW pump.
6. Align Appendix R Diesel Generator (ARDG) to 480 V Buses 2A, 3,A, 5A, and 312.
Enclosure 2
19
8. Locally operate FCV-405B, FCV-405D, or FCV-406B to control AFW flow to Steam
Generators (SGs).
9. Locally open valve 227 to establish charging makeup flowpath to Reactor Coolant
System (RCS).
10. Locally close Level Control Valve (LCV)-1 12C and open valve 288 to align charging
pump suction to the Refueling Water Storage Tank (RWST).
11. Locally operate Pressure Control Valve (PCV)-1 139 to ensure steam supply to 32 AFW
pump.
12. Locally operate PCV-13104 and PCV-13108 to ensure steam supply to 32 AFW pump.
13. Locally manually perform Service Water (SW) pump strainer backwash as required.
14. Operate HCV-1118 manually to control 32 AFW pump.
15. Locally operate PCV-1 139 to ensure steam supply to 32 AFW pump.
16. Locally operate 32 PCV-1310A, PCV-13108 to ensure steam supply to 32 AFW pump.
17. Locally operate FCV-405C and FCV-405D to control AFW flow to SG.
18. Locally close valve LCV-1 12C and open valve 228 to align charging pump suction path
to RWST.
19. Locally close supply breaker 'for 32 Charging Pump.
2Q. Locally control 32 charging pump using scoop tube positioner.
21. Open bypass valve 227 to establish charging flowpath to RCS around potentially failed
closed HCV-142.
22. Locally close LCV-112C and open bypass valve 288 to establish flowpath from RWST to
charging pump suction.
23. Locally operate [bypass valve for] FCV-1121 AFW pump recirculation valve during pump
startup.
24. Locally operate FCV- 406A and FCV-406B to control AFW flow to SGs.
25. Locally/manually backwash SW pump strainer as required if power to strainer associated
with selected SW pump is lost.
26. Locally start ARDG to supply Motor Control Center (MCC) 312A in support of the use of
SW pump 38.
Enclosure 2
20
27. Locally/manually backwash SW Pump strainer as required if power to strainer
associated with selected SW pump is lost.
Enforcement. Indian Point Unit 3 Operating License Condition 2.H specifies, in part, that
Entergy Nuclear Operations, lnc., shall implement and maintain in effect all provisions of
the approved Fire Protection Program as described in the Final Safety Analysis Report.
The Final Safety Analysis Report, Section 9.6.2, specifies that ENO will meet the
requirements of 10 CFR Part 50, Appendix R, Section lll.G.2, which identifies the means
of protecting post-fire safe shutdown equipment from fire damage. Contrary to the
above, between June 30, 2006 and April 26, 2012, ENO failed to implement their fire
protection program by using one of the the means described in Appendix R,
Section lll.G.2, to protect circuits required for post-fire safe shutdown from fire-induced
circuit damage. Specifically, ENO used unapproved operator manual actions to mitigate
post-fire safe shutdown equipment malfunctions without having obtained NRC approval.
The specific operator manual actions and fire areas and fire zones that are in violation of
Appendix R, Section lll.G.2, are listed in the Indian Point Unit 3 Denied OMA Summary
Table of this inspection report. 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, ENO failed to restore compliance within a reasonable amount of
time after the violation was identified in RIS 2006-10 on June 30, 2006.
VIO 0500028612012008-01, Failure to Protect Safe Shutdown Equipment from the
Effects of Fire.
Violation of Combustible Controls Proqram
lntroduction. The inspectors identified a Green, Non-Cited Violation (NCV) of the Indian
Point Nuclear Generating Unit No. 2 Amended Facility Operating License, Condition 2.K,
in that ENO failed to implement and maintain in effect all provisions of the NRC-
approved FPP as described in the Updated Final Safety Analysis Report (UFSAR).
Specifically, ENO failed to minimize transient combustible materials within the primary
auxiliary building (PAB) and stored a compressed gas cylinder containing hydrogen gas
under cable trays.
Description. While walking down electrical cables that were associated with denied
OMA exemptions, the inspectors identified a gas cylinder underneath cable trays in fire
zone (FZ) Fl7 A of the PAB. The gas cylinder was not in use, a valve protection cap was
installed, and the gas cylinder was chained to a corridor wall to prevent accidental
movement or tipping. The gas cylinder's contents were unknown and without label other
than a sticker indicating the contents were flammable.
ENO removed the gas cylinder from the PAB and evaluated its contents. The gas
cylinder was a mixture of 50 percent hydrogen and 50 percent nitrogen gasses and was
previously in service as a calibration gas for the waste gas analyzer in FZ F/8A of the
PAB. lt contained about 150 psig of gas. FZ FlSA is an authorized storage location for
an in service hydrogen calibration gas cylinder, and FZFITA is not an authorized storage
location for any hydrogen gas cylinders.
Enclosure 2
21
The storage of a hydrogen compressed gas cylinder in FZFITA of the PAB was not in
accordance with ENO procedure, Control of Combustibles, EN-DC-161, Rev. 6, and a
flammable compressed gas was not practically minimized. EN-DC-161, among other
requirements, requires plant workers to: 1) limit transient combustibles to those
materials and quantities necessary to support work activities, 2) not place transient
combustibles directly under cable trays, and 3)determine the need for a formal
Transient Combustible Evaluation (TCE).
ENO promptly entered this issue into its CAP as CR-lP2-2012-03036, and removed the
hydrogen cylinder from the PAB. ENO initiated a corrective action to evaluate the
identified condition and ensure actions to prevent its recurrence.
Analvsis. ENO's failure to remove the compressed hydrogen gas cylinder from the PAB
after its intended use as a calibration gas for the waste gas analyzer was a performance
deficiency. This finding was more than minor because it was associated with the
External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely
affected the cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences (i.e., core
damage). Specifically, the hydrogen gas cylinder was stored below cable trays in an
area that includes safe shutdown circuits and the associated cables were at increased
risk to fire damage. The inspectors used IMC 0609, Appendix F, Fire Protection
Significance Determination Process, Phase 1 and a Senior Reactor Analyst conducted a
Phase 3 evaluation, to determine that this finding was of very low safety significance
(Green). The inspectors determined that this finding had a cross-cutting aspect in the
area of Human Performance associated with the work practice attribute because ENO
personnel did not follow procedure, Control of Combustibles, EN-DC-161, Rev. 6, as
written and did not remove the hydrogen gas cylinder from the PAB after it was
disconnected from the waste gas analyzer contrary to Control of Combustibles,
EN-DC-161, Rev.6. (H.4(b) per IMC 0310).
The inspectors used Attachment 2 of IMC 0609, Appendix F, Fire Protection Significance
Determination Process (SDP), and assigned a high degradation rating for this
combustible controls program finding. Accordingly, this finding did not screen to Green
in Phase 1 of IMC 0609, Appendix F, and a Phase 3 analysis was performed by a Senior
Reactor Analyst (SRA) using similar assumptions and methodologies as the denied
OMA findings.
Conduct of the phase 3 SDP included identifying the damage that could result based on
detailed plant walkdowns, review of ENO provided circuit information, fire modeling
evaluation of potential damage to plant equipment, and use of probabilistic fire analysis
methods documented in NRC Inspection Manual Chapter 0609, Appendix F, "Fire
Protection SDP" and NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for
Nuclear Power Facilities." The SRA analyzed the risk of a single hydrogen gas cylinder
fire located directly below the cables in FZFITA that may cause the charging pumps to
lose suction by closing the volume control tank (VCT) outlet valve (112C). Because the
hydrogen compressed gas cylinder was stored along a PAB corridor in FZFITA without
controls or regards to its combustibility or flammability, the SRA assumed for the
purposes of analyzing risk from fire, that the hydrogen gas cylinder was located directly
Enclosure 2
22
beneath cables that if damaged may spuriously close 112C. Closure of 112C causes
the charging pumps to lose suction and OMAs are required to restore the VCT suction or
align the refuel water storage tank (RWST) as an alternate source by opening air
operated valve 1128. The normally open 112C is physically located in the VCT room,
not in FZFlTA, and the normally closed 1128, is located in the 22 charging pump cell
FZFl6. Valve 1128 is designed to open automatically in the event of a low VCT level,
which through 1128 valve position monitoring circuitry would cause the normal VCT
suction valve 1 12C to close. The 1 128 valve position monitoring circuit cable runs from
FZFl6, where 1128 is located, through FZFITA. The fire is assumed to result in 1128
failing to open due to direct power supply cabling damage and 1 12C failing closed due to
damage to the 1128 position monitoring circuit wiring. The denied OMAs tor FZFITA
were used in this analysis. These OMAs included the manual opening of the 1 128
bypass valve (288), the verification or closure of 112C, and starting the 21 charging
pump, after the RWST suction is aligned, using the emergency control station in the
480V switchgear room.
The SRA conducted a detailed probabilistic analysis tor FZ F/7A, using the lP2 SPAR
model version 8.20 to estimate the conditional core damage probability if the fire were to
occur. This analysis represented a fire model estimate that allowed normal plant
equipment to remain functional if it would not be damaged based on fire modeling of the
actual plant configuration. The analysis determined a negligible increase in core
damage frequency (less than 1 in one billion years), given an estimated 6.5E-4 per year
fire frequency (consistent with Attachment 4 of the Fire Protection SDP for a hydrogen
storage tank) and the conditional core damage probability calculated (if the performance
deficiency had not occurred there was no credible ignition source). An independent
Region I SRA reviewed and found acceptable the SPAR model changes made to
conduct the analysis, which were based on following assumptions that a fire in FZFITA
would:
o Cause operators to manually initiate a reactor trip from the control room, which
was reflected as a transient initiation event.
. Failthe running charging pump.
. Fail 1128 closed.
o Fail 112C closed with a probability of an intra-cable hot short of 0.30, based on
NUREG/CR-6850 or fail it open with a 0.70 probability. lf MOV-112C fails open it
must be manually closed as part of restoring the RWST suction flowpath to the
21 charging pump.
. Not generate a hot gas layer in the PAB corridor and not damage any cabling or
equipment outside of FZ F/7A based on fire modeling.
r Result in control room operators in accordance with procedures:
o Removing control power fuses for both PORVs in the control room to
prevent spurious opening which was assumed always successful. For
ATWS sequences, all PORVs and RCS safety valves would be open and
operators would not pull the fuses to close the PORVS, but would
continue to recover charging to establish emergency boration.
o Promptly disabling the 21 charging pump from automatic operation. This
action is required by procedure to preclude damage to the 21 charging
pump should it operate without a water source aligned to its suction as
Enclosure 2
23
the result of spurious valve operations. A failure probability of 1.1E-2 was
assumed based on SPAR-H1, assuming diagnosis and allfactors in their
nominalstate.
o Result in operators implementing the denied OMAs in accordance with
procedures and specifically aligning the RWST to the charging pumps suction
after the fire is extinguished and includes:
o Manually opening valve 288 with a failure probability of 2.3E-1 assumed
based on SPAR-H with all factors in their nominal state except for high
stress and conservatively assuming barely sufficient time.
o Verify or close 112C with a failure probability of 2.3E-1 assumed based
on SPAR-H with all factors in their nominal state except for high stress
and conservatively assuming barely sufficient time.
. Result in operators implementing the missed OMA to start the 21 charging pump
from the emergency control station in the 480 V switchgear room after the RWST
suction was aligned. This action was assigned a failure probability of 2.9E-1
based on SPAR-H assuming diagnosis and allfactors in their nominal state
except for incomplete and poor procedures. Incomplete and poor procedures
was chosen because operators knew of the emergency control station in the
switchgear room, and because it was incorporated in the post-fire safe shutdown
following control room abandonment, however, use of the emergency control
station was not in the procedure used for a PAB fire.
The dominating core damage sequence involving the hydrogen calibration gas cylinder
fire scenario was an ATWS caused by mechanical binding of all control rods and a
failure of the operator to manually open 288 to establish emergency boration with the 21
charging pump. The negligible increase in core damage frequency (less than 1 in one
billion years) is due to the 6.5E-4 per year initiating event frequency and the extremely
low chances of an ATWS situation where emergency boration would be necessary or a
common cause failure of the SW system would lead to a reactor coolant pump seal
failure.
Enforcement. Entergy Nuclear Operations, Inc.(ENO), Operating License,
Condition 2.K, requires, in part, that ENO shall implement and maintain in effect all
provisions of the NRC-approved FPP as described in the UFSAR. UFSAR Section 9.6,2
references the FPP as described in three ENO documents, one of these documents is
the lndian Point Energy Center (IPEC) Fire Protection Program Plan, SEP-FPP-IP-001,
Rev. 0. Control of Combustibles, EN-DC-161, Rev. 6, is referenced in the IPEC FPP
Plan and, in part, requires plant workers to: 1) limit transient combustibles to those
materials and quantities necessary to support work activities (Section 5.2[1]), 2) not
place transient combustibles directly under cable trays, (Section 5.2141),
(Section 5.5[1](d)), and 3) determine the need for a formal Transient Combustible
Evaluation (TCE) (Section 5.6t21). Contrary to the above, a compressed gas cylinder
containing hydrogen gas was left in FZ 7 A of the PAB on an unknown date of the PAB.
The unauthorized storage of a hydrogen gas bottles was identified by the NRC on
April 25, 2012. Because this finding was of very low safety significance (Green) and has
been entered into ENO's corrective action program (CR-lP2-2012-03036), this violation
is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.
(NCV 0500024712012009-001, Violation of Transient Gombustible Gontrol Program)
Enclosure 2
24
40A6 Meetinos. includinq Exit
Exit Meetinq Summarv
The inspectors presented their preliminary inspection results to Mr. Lawrence Coyle,
General Manager, Plant Operations, and other members of the site staff at an exit
meeting on April 26,2012. Following in-office reviews, an additional meeting was
conducted by telephone with Mr. Patric Conroy, Director, Nuclear Safety Assurance, on
June 8, 2012, and an exit meeting was conducted by telephone with Mr. Patric Conroy,
and other members of the site staff on July 20,2012. No proprietary information was
included in this inspection report.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure 2
A-1
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
P. Conroy, Director, Nuclear Safety Assurance
L. Coyle, General Manager, Plant Operations
J. Cottam, Fire Protection Engineer
G. Dahl, Licensing Specialist
K. Elliot, Safe Shutdown Engineer
M. Tesoriero, Manager, Programs and Components
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000247/2012009-01 VIO Failure to Protect Safe Shutdown Equipment from the
Effects of Fire (Section 4042.1)05000286/2012008-01 VIO Failure to Protect Safe Shutdown Equipment from the
Effects of Fire (Section 4042.2)
Opened and Closed
0500024712012009-01 NCV Violation of Transient Combustible Control Program
(Section 4OA2.3)
LIST OF DOCUMENTS REVIEWED
Fire Protection Licensino Documents
Unit 3 Technical Requirements Manual 3.7.8, Appendix R Safe Shutdown Equipment, Rev. 9
Letter from J. Bayne to H. Denton, Appendix R Exemption Request Information, Dated 11122182
Desiqn Basis Documents
lP-RPT-OS, ,P2 10 CFR 50, Appendix R Safe-Shutdown Separation Analysis, Rev. 1
lP2-RPT-03-00015,lP2 Fire Hazards Analysis, Rev. 4
lP3-ANAL-FP-02143, Fire Hazards Analysis Report, Rev. 5
lP3-ANAL-FP-01503, Safe Shutdown Analysis Report, Rev. 2
SEP-FPP-lP-001, IPEC Fire Protection Program Plan, Rev.0
Attachment
A-2
Calcu lations/Enq ineerinq Evaluation Reports
EO-6068, Fire and Heat Resistance Tests on 600V Power and Control Cable and Switchboard
Wires, Dated 8120171
lP-RPT-12-00008, lP3 OMAs 2 through 8 Evaluation, Draft
Evaluation of lP3 OMAs 18 through 22, Draft
Evaluation of lP3 OMA 26, Draft
PGI-00433, Combustible Loading Calculation, Rev. 6
Procedures
SAO-703, Fire Protection lmpairment Criteria and Surveillance, Rev, 28
SEP-FPP-lP-002,IPEC Fire Watch Program, Rev. 0
EN-DC-161, Control of Combustibles, Rev. 6
EN-DC-127, Control of Hot Work and lgnition Sources, Rev. 11
EN-IS-109, Compressed Gas Cylinder Handling and Storage, Rev. 7
Operations Procedures
2-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control, Rev. 18
2-ONOP-FP-001, Plant Fires, Revs. 7 & I
2-SOP-ESP-0O1, Local Equipment Operation and Contingency Actions, Rev. 6
3-ONOP-FP-1, Plant Fires, Rev. 28
3-SOP-EL-Q12, Operation of the Alternative Safe Shutdown Equipment, Rev. 18
3-SOP-ESP-001, Local Equipment Operation and Contingency Actions, Rev. 21
Condition Reports
cR-lP2-2011-02417 CR-1P2-2012-01487 CR-lP3-2011-02325
cR-rP2-2011-03139 CR-IP2-2012-01585 CR-lP3-2011-02853
cR-tP2-201 1-03695 CR-tP2-2012-03024 CR-lP3-2011-02951
cR-tP2-201 1-03889 CR-lP2-2012-03036 CR-IP3-201 1-02966
cR-lP2-201 1-04608 CR-lP2-2012-03410 CR-lP3-2011-03497
cR-rP2-2011-0631 1 CR-IP3-2006-02747 CR-lP3-2011-03563
cR-lP2-2012-00643 CR-lP3-2011-00044 CR-lP3-2012-00369
Attachment
A_3
LIST OF ACRONYMS
ADAMS Agency,vide Documents Access and Management System
ASSS Alternate Safe Shutdown System
ATWS Anticipated Transient Without Scram
CAP Corrective Action Program
ccw Closed Cooling Water
CFR Code of Federal Regulations
DRS Division of Reactor Safety
EGM Enforcement Guidance Memorandum
ENO Entergy Nuclear Operations, Inc.
FDSO Fire Damage State Zero
FSAR Final Safety Analysis Report
FZ Fire Zone
GPM Gallon Per Minute
IA lnstrument Air
IMC Inspection Manual Chapter
IP Inspection Procedure
IPEC Indian Point Energy Center
KW Kilowatt
MOV Motor Operated Valve
NCV Non-Cited Violations
NRC Nuclear Regulatory commission
OMA Operator ManualAction
PAB Primary Auxiliary Building
PAR Publicly Available Records
PORV Power Operated Relief Valve
PSIG Pounds Per Square Inch Gauge
RCP Reactor Coolant Pump
RIS Regulatory lssue Summary
RWST Refuel Water Storage Tank
SDP Significance Determination Process
SQFT Square Feet
SRA Senior Reactor Analyst
TCE Transient Combustible Evaluation
VC Vapor Containment
UFSAR Updated Final Safety Analysis Report
V Volt
VCT Volume ControlTank
Attachment