ML14086A754
| ML14086A754 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/27/2014 |
| From: | John Dixon NRC/RGN-IV/DRS/EB-2 |
| To: | Flores R Luminant Generation Co |
| References | |
| IR-14-008 | |
| Download: ML14086A754 (31) | |
See also: IR 05000445/2014008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
March 27, 2014
Rafael Flores, Senior Vice President
and Chief Nuclear Officer
Attention: Regulatory Affairs
Luminant Generation Company LLC
Comanche Peak Nuclear Power Plant
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC
TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000445/2014008 AND
Dear Mr. Flores:
On March 19, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Comanche Peak Nuclear Power Plant, Units 1 and 2. The enclosed inspection report
documents the inspection results, which were discussed in an initial exit meeting on
February 13, 2014, with Mr. B. Mays, Assistant to the Chief Nuclear Officer, and other members
of your staff. The team conducted a re-exit meeting on March 19, 2014, with Mr. T. Hope,
Nuclear Licensing Manager, and other members of your staff.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. Further, inspectors documented a
licensee-identified violation which was determined to be of very low safety significance. The
NRC is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the
If you contest the violations or significance of the violations in this report, you should provide a
written response within 30 days of the date of this inspection report, with the basis for your
denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington,
D.C. 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of
Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001;
and the NRC Resident Inspectors at the Comanche Peak Nuclear Power Plant. The information
you provide will be considered in accordance with Inspection Manual Chapter 0305.
If you disagree with the characterization of 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 IV, and the NRC
Resident Inspectors at Comanche Peak Nuclear Power Plant.
R. Flores -2-
In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding,
of the NRCs 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 NRCs document system (ADAMS).
ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Sincerely,
/RA/
John L. Dixon Jr., Acting Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos.: 50-445, 50-446
Enclosure: Inspection Report No. 05000445/2014008 and 05000446/2014008
w/Attachment: Supplemental Information
cc w/Enclosure:
R. Flores -3-
Electronic distribution by RIV:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Steven.Reynolds@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
DRP Deputy Director (Troy.Pruett@nrc.gov)
Acting DRS Director (Jeff.Clark@nrc.gov)
Acting DRS Deputy Director (Geoffrey.Miller@nrc.gov)
Senior Resident Inspector (John.Kramer@nrc.gov)
Resident Inspector (Rayomand.Kumana@nrc.gov)
Administrative Assistant - Vacant
Branch Chief, DRP/A (Wayne.Walker@nrc.gov)
Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)
Project Engineer, DRP/A (Fabian.Thomas@nrc.gov)
Project Engineer, DRP/A (Brian.Cummings@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Balwant.Singal@nrc.gov)
Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
Branch Chief, RES/DRA/FRB (MarkHenry.Salley@nrc.gov)
RIV/ETA: OEDO (Joseph.Nick@nrc.gov)
File located:R:\_REACTORS\_CPSES\2014\CP2014008-RPT-EDU ADAMS: ML14086A754
SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials EDU
Publicly Avail Yes No Sensitive Yes No Sens. Type Initials
RI:DRS RI:DRS RI:DRS RI:DRS BC:DRP/A
EDUribe SMAlferink BKCorrell JLWatkins WWalker
/RA/ /RA/ /RA/ /RA/ /RA/
3/21/14 3/24/14 3/24/14 3/24/14 3/25/14
BC:DRS/EB2
JLDixon
/RA/
3/27/14
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-445, 50-446
Report Nos.: 05000445/2014008 and 05000446/2014008
Licensee: Luminant Generation Company LLC
Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2
Location: FM-56, Glen Rose, Texas
Dates: January 27 through March 19, 2014
Team Leader: E. Uribe, Reactor Inspector, Engineering Branch 2
Inspectors: S. M. Alferink, Reactor Inspector, Engineering Branch 2
B. K. Correll, Reactor Inspector, Engineering Branch 2
J. L. Watkins, Reactor Inspector, Engineering Branch 2
Approved By: John L. Dixon Jr., Acting Branch Chief
Engineering Branch 2
Division of Reactor Safety
-1- Enclosure
SUMMARY OF FINDINGS
IR 05000445/2014008 and 05000446/2014008; 01/27/2014 - 03/19/2014; Comanche Peak
Nuclear Power Plant, Units 1 and 2; Triennial Fire Protection Team Inspection.
The report covered a two-week triennial fire protection team inspection by specialist inspectors
from Region IV. One Green finding, which was a non-cited violation, was documented. The
significance of inspection findings are indicated by their color (i.e., Green, White, Yellow, or
Red) and determined using Inspection Manual Chapter 0609, Significance Determination
Process, dated June 2, 2011. Cross-cutting aspects are determined using Inspection Manual
Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 19, 2013. All
violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement
Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4,
dated December 2006.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. The team reviewed a Green self-revealing non-cited violation of
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, for the failure to ensure that quality related procedures provide
adequate guidance for labeling and terminating cables during implementation of
circuit modifications. Specifically, procedure CMP-EL-1006, Cable
Terminations, Revision 3, did not prescribe the appropriate human performance
standards and cable label controls when installing new cable. As a result, a
wiring error caused one of the two turbine-driven auxiliary feedwater pump steam
supply valves to fail open when the hot shutdown panel transfer/isolation switch
was taken to the remote position. The licensee entered this into the corrective
action program as condition report CR-2013-000140. The corrective actions
included: confirming that the same error did not exist for the other steam supply
valve or for the Unit 1 transfer switch, retiring procedure CMP-EL-1006 and
revising other maintenance section generic procedures that will be used to
implement future circuit modifications.
The licensees failure to ensure that procedures provide adequate guidance for
labeling and terminating cables during circuit modifications was a performance
deficiency. The finding was more than minor because if left uncorrected this
could have the potential to lead to a more significant safety concern. Specifically,
operation of the hot shutdown panel auxiliary feedwater transfer/isolation switch
cannot be reliably performed. Using NRC Inspection Manual Chapter 0609,
Appendix F, Attachment 1, Part 1: Fire Protection SDP Phase 1 Worksheet,
dated September 30, 2013, the finding was determined to be of very low safety
significance (Green), by answering Step 1.3.1, Question 2, because the finding
did not affect the reactor to be able to reach and maintain a safe shutdown
condition. The finding had a human performance cross-cutting aspect in
resources because leaders failed to ensure that personnel and procedures were
available and adequate to support nuclear safety. [H.1] (Section 4OA3)
-2-
B. Licensee-Identified Violations
A violation of very low safety significance that was identified by the licensee has been
reviewed by the NRC. Corrective actions taken or planned by the licensee have been
entered into the licensees corrective action program. This violation and the corrective
action tracking number are listed in Section 4OA7 of this report.
-3-
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R05 Fire Protection (71111.05T)
This report presents the results of a triennial fire protection inspection conducted in
accordance with NRC Inspection Procedure 71111.05T, Fire Protection (Triennial), at
the Comanche Peak Nuclear Power Plant, Units 1 and 2. The inspection team
evaluated the implementation of the approved fire protection program in selected risk-
significant areas with an emphasis on the procedures, equipment, fire barriers, and
systems that ensure the post-fire capability to safely shutdown the plant.
Inspection Procedure 71111.05T requires the selection of three to five fire areas and one
or more mitigating strategies for review. The inspection team used the fire hazards
analysis section of the Comanche Peak Steam Electric Station Individual Plant
Examination of External Events to select the following five risk-significant fire areas
(inspection samples) for review:
- Fire Area EO, Unit 1 - Control Room
- Fire Area ER, Unit 1 - Uninterruptible Power Supply AC Unit
- Fire Area SC, Unit 1 - Turbine Driven AFW Pump
- Fire Area SD, Unit 1 - Electrical Equipment Room/Train A Switchgear Room
The inspection team evaluated the licensees fire protection program using the
applicable requirements, which included plant Technical Specifications; Operating
License Condition 2.G for Unit 1 and Unit 2; NRC safety evaluations and supplements;
10 CFR 50.48; and Branch Technical Position 9.5-1, Appendix A. The team also
reviewed related documents that included the Final Safety Analysis Report, Sections 9.5
and 13.3B; the fire protection report; and the post-fire safe shutdown analysis. Specific
documents reviewed by the team are listed in the attachment. Five fire area inspection
samples and one mitigating strategy sample were completed.
.1 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the piping and instrumentation diagrams, safe shutdown equipment
list, safe shutdown design basis documents, and the post-fire safe shutdown analysis to
verify that the licensee properly identified the components and systems necessary to
achieve and maintain safe shutdown conditions for fires in the selected fire areas. The
team observed walkdowns of the procedures used for achieving and maintaining safe
shutdown in the event of a fire to verify that the procedures properly implemented the
safe shutdown analysis provisions.
For each of the selected fire areas, the team reviewed the separation of redundant safe
shutdown cables, equipment, and components located within the same fire area. The
-4-
team also reviewed the licensees method for meeting the requirements of
10 CFR 50.48; Branch Technical Position 9.5-1, Appendix A; and 10 CFR Part 50,
Appendix R,Section III.G. Specifically, the team evaluated whether at least one
post-fire safe shutdown success path remained free of fire damage in the event of a fire.
In addition, the team verified that the licensee met applicable license commitments.
b. Findings
No findings were identified.
.2 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to observe the
material condition and configuration of the installed fire area boundaries (including walls,
doors, and dampers) and verify that the electrical raceway fire barriers were appropriate
for the fire hazards in the area. The team compared the installed configurations to the
approved construction details, supporting fire tests, and applicable license commitments.
The team reviewed installation, inspection procedures, repair, and qualification records
for a sample of penetration seals to ensure the fill material possessed an appropriate fire
rating and that the installation met the engineering design. The team also reviewed
similar records for the rated fire wraps to ensure the material possessed an appropriate
fire rating and that the installation met the engineering design.
b. Findings
No findings were identified.
.3 Active Fire Protection
a. Inspection Scope
The team reviewed the design, maintenance, testing, and operation of the fire detection
and suppression systems in the selected fire areas. The team verified the automatic
detection systems and the manual and automatic suppression systems were installed,
tested, and maintained in accordance with the National Fire Protection Association code
of record or approved deviations and that each suppression system was appropriate for
the hazards in the selected fire areas.
The team performed a walkdown of accessible portions of the detection and suppression
systems in the selected fire areas. The team also performed a walkdown of major
system support equipment in other areas (e.g., fire pumps and halon supply systems) to
assess the material condition of these systems and components.
The team reviewed the electric and diesel fire pumps flow and pressure tests to verify
that the pumps met their design requirements. The team reviewed the yard loop flow
and pressure drop tests. The team also reviewed the halon suppression functional tests
to verify that the system capability met the design requirements.
-5-
The team assessed the fire brigade capabilities by reviewing training, qualification, and
drill critique records. The team also reviewed pre-fire plans and smoke removal plans
for the selected fire areas to determine if appropriate information was provided to fire
brigade members and plant operators to identify safe shutdown equipment and
instrumentation and to facilitate suppression of a fire that could impact post-fire safe
shutdown capability. In addition, the team inspected fire brigade equipment to determine
operational readiness for fire fighting.
The team observed an unannounced fire drill and subsequent drill critique on
February 11, 2014, using the guidance contained in Inspection Procedure 71111.05AQ,
Fire Protection (Annual/Quarterly). The team observed fire brigade members fight a
simulated fire in the turbine-driven auxiliary feedwater pump room of Unit 1 Auxiliary
Building (Fire Area SC). The team verified that the licensee identified problems, openly
discussed them in a self-critical manner at the drill debrief, and identified appropriate
corrective actions. Specific attributes evaluated were: (1) proper wearing of turnout gear
and self-contained breathing apparatus; (2) proper use and layout of fire hoses;
(3) employment of appropriate fire fighting techniques; (4) sufficient fire fighting
equipment was brought to the scene; (5) effectiveness of fire brigade leader
communications, command, and control; (6) search for victims and propagation of the
fire into other areas; (7) smoke removal operations; (8) utilization of pre-planned
strategies; (9) adherence to the pre-planned drill scenario; and (10) drill objectives.
b. Findings
No findings were identified.
.4 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed plant walkdowns and document reviews to verify that redundant
trains of systems required for hot shutdown, which are located in the same fire area,
would not be subject to damage from fire suppression activities or from the rupture or
inadvertent operation of fire suppression systems. Specifically, the team verified:
- a fire in one of the selected fire areas would not directly, through production of
smoke, heat, or hot gases, cause activation of suppression systems that could
potentially damage all redundant safe shutdown trains
- a fire in one of the selected fire areas or the inadvertent actuation or rupture of a
fire suppression system would not directly cause damage to all redundant trains
(e.g., sprinkler-caused flooding of other than the locally affected train)
- adequate drainage is provided in areas protected by water suppression systems
b. Findings
No findings were identified.
-6-
.5 Alternative Shutdown Capability
a. Inspection Scope
Review of Methodology
The team reviewed the safe shutdown analysis, operating procedures, piping and
instrumentation drawings, electrical drawings, the Final Safety Analysis Report, and
other supporting documents to verify that hot and cold shutdown could be achieved and
maintained from outside the control room for fires that require evacuation of the control
room, with or without offsite power available.
The team conducted plant walkdowns to verify that the plant configuration was
consistent with the description contained in the safe shutdown and fire hazards
analyses. The team focused on ensuring the adequacy of systems selected for
reactivity control, reactor coolant makeup, reactor decay heat removal, process
monitoring instrumentation, and support systems functions.
The team also verified that the systems and components credited for shutdown would
remain free from fire damage. Finally, the team verified that the transfer of control from
the control room to the alternative shutdown location would not be affected by
fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for
alternative shutdown control circuits).
Review of Operational Implementation
The team verified that licensed and non-licensed operators received training on
alternative shutdown procedures. The team also verified that sufficient personnel to
perform a safe shutdown were trained and available onsite at all times, exclusive of
those assigned as fire brigade members.
The team performed a walkdown of the post-fire safe shutdown procedure with licensed
and non-licensed operators to determine the adequacy of the procedure. The team
verified that the operators could be reasonably expected to perform specific actions
within the time required to maintain plant parameters within specified limits. Time critical
actions that were verified included restoring electrical power, establishing control at the
remote shutdown and local shutdown panels, establishing reactor coolant makeup, and
establishing decay heat removal.
The team also reviewed the periodic testing of the alternative shutdown transfer
capability and instrumentation and control functions to verify that the tests were
adequate to demonstrate the functionality of the alternative shutdown capability.
b. Findings
No findings were identified.
-7-
.6 Circuit Analysis
a. Inspection Scope
The team reviewed the post-fire safe shutdown analysis to verify that the licensee
identified the circuits that may impact the ability to achieve and maintain safe shutdown.
The team verified, on a sample basis, that the licensee properly identified the cables for
equipment required to achieve and maintain safe shutdown conditions in the event of a
fire in the selected fire areas. The team verified that these cables were either
adequately protected from the potentially adverse effects of fire damage or were
analyzed to show that fire-induced circuit faults (e.g., hot shorts, open circuits, and
shorts to ground) would not prevent safe shutdown. For cables that were important to
safe shutdown, the team verified that the licensees analysis considered potential
spurious operations due to fire-induced cable faults.
The teams evaluation focused on the schematics and cables of selected components
from the reactor coolant system, specifically the pressurizer power-operated relief and
block valves, chemical volume and control system, auxiliary feedwater, residual heat
removal system, and electrical distribution breaker controls and circuit coordination. For
the sample of components selected, the team reviewed electrical elementary and block
diagrams and identified power, control, and instrument cables necessary to support their
operation. In addition, the team reviewed cable routing information to verify that fire
protection features were in place as needed to satisfy the separation requirements
specified in the fire protection license basis. Specific components reviewed by the team
are listed in the attachment.
b. Findings
No findings were identified.
.7 Communications
a. Inspection Scope
The team inspected the contents of designated emergency storage lockers and
reviewed the alternative shutdown procedure to verify that portable radio
communications and fixed emergency communications systems were available,
operable, and adequate for the performance of designated activities. The team verified
the capability of the communication systems to support the operators in the conduct and
coordination of their required actions. The team also verified that the design and
location of communications equipment such as repeaters and transmitters would not
cause a loss of communications during a fire. The team discussed system design,
testing, and maintenance with the system engineer.
b. Findings
No findings were identified.
-8-
a. Inspection Scope
The team reviewed the portion of the emergency lighting system required for alternative
shutdown to verify that it was adequate to support the performance of manual actions
required to achieve and maintain hot shutdown conditions and to illuminate access and
egress routes to the areas where manual actions would be required. The team
evaluated the locations and positioning of the emergency lights during a walkdown of the
alternative shutdown procedure.
The team verified that the licensee installed emergency lights with an 8-hour capacity,
maintained the emergency light batteries in accordance with manufacturer
recommendations, and tested and performed maintenance in accordance with plant
procedures and industry practices.
b. Findings
No findings were identified.
.9 Cold Shutdown Repairs
a. Inspection Scope
The team verified that the licensee identified repairs needed to reach and maintain cold
shutdown and had dedicated repair procedures, equipment, and materials to accomplish
these repairs. Using these procedures, the team evaluated whether these components
could be repaired in time to bring the plant to cold shutdown within the time frames
specified in their design and licensing bases. The team verified that the repair
equipment, components, tools, and materials needed for the repairs were available and
accessible on site.
b. Findings
No findings were identified.
.10 Compensatory Measures
a. Inspection Scope
The team verified that compensatory measures were implemented for out-of-service,
degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems,
or features (e.g., detection and suppression systems and equipment; passive fire
barriers; or pumps, valves, or electrical devices providing safe shutdown functions). The
team also verified that the short-term compensatory measures compensated for the
degraded function or feature until appropriate corrective action could be taken and that
the licensee was effective in returning the equipment to service in a reasonable period of
time.
The team reviewed operator manual actions credited for achieving hot shutdown for fires
that do not require an alternative shutdown. The team verified that operators could
-9-
reasonably be expected to perform the actions within the applicable shutdown time
requirements. The team reviewed these operator manual actions using the guidance
contained in NUREG-1852, Demonstrating the Feasibility and Reliability of Operator
Manual Actions in Response to Fire, dated October 2007.
b. Findings
No findings were identified.
.11 Review and Documentation of Fire Protection Program Changes
a. Inspection Scope
The team reviewed changes to the approved fire protection program. The team verified
that the changes did not constitute an adverse effect on the ability to safely shutdown.
b. Findings
No findings were identified.
.12 Control of Transient Combustibles and Ignition Sources
a. Inspection Scope
The team reviewed the licensees approved fire protection program, implementing
procedures, and programs for the control of ignition sources and transient combustibles.
The team assessed the licensees effectiveness in preventing fires and in controlling
combustible loading within limits established in the fire hazards analysis. The team
performed plant walkdowns to independently verify that transient combustibles and
ignition sources were being properly controlled in accordance with the administrative
controls.
b. Findings
No findings were identified.
.13 Alternative Mitigation Strategy Inspection Activities
a. Inspection Scope
The team reviewed the licensees implementation of guidance and strategies intended to
maintain or restore core, containment, and spent fuel pool cooling capabilities under the
circumstances associated with the potential loss of large areas of the plant due to
explosions or fire as required by 10 CFR 50.54(hh)(2).
The team verified that the licensee maintained and implemented adequate procedures,
maintained and tested equipment necessary to properly implement the strategies, and
ensured station personnel were knowledgeable and capable of implementing the
procedures. The team performed a visual inspection of portable equipment used to
implement the strategy to ensure the availability and material readiness of the
equipment, including the adequacy of portable pump trailer hitch attachments, and verify
- 10 -
the availability of on-site vehicles capable of towing the portable pump. The team
assessed the ability to obtain fuel for the portable pump and sampled various equipment
storage lockers to verify required equipment was available for use. The strategy and
procedure selected for this inspection sample included:
- Extreme Damage Mitigation Guideline A.4-4, Manually Depressurize S/Gs and
Use Portable AME Pump for Makeup, Revision 6
One sample was completed.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES [OA]
4OA2 Identification and Resolution of Problems
Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team selected a sample of condition reports and operating experience reviews
associated with the licensees fire protection program to verify that the licensee had an
appropriate threshold for identifying deficiencies. The team reviewed the corrective
actions proposed and implemented to verify that they were effective in correcting
identified deficiencies. The team evaluated the quality of recent engineering evaluations
through a review of condition reports, calculations, and other documents during the
inspection. The team evaluated two items in this section:
1. The team performed a review of the licensees response to Information
Notice 1992-18, Potential Loss of Remote Shutdown Capability Following
Control Room Fire, and determined a licensee identified violation occurred. This
violation is documented in Section 4OA7.
2. During the 2008 triennial fire protection inspection, the team identified a concern
with the potential loss of the charging pump relied upon for an alternative
shutdown due to a loss of suction. Specifically, the team was concerned that the
spurious closure of one of the volume control tank outlet valves (LCV-112B or
LCV-112C) prior to the opening of one of the refueling water storage tank outlet
valves (LCV-112D or LCV-112E) would result in a loss of suction and loss of the
charging pump. The team documented this issue as Unresolved
Item 05000445/2008006-01 for Unit 1 and 05000446/2008006-02 for Unit 2 on
July 3, 2008. This unresolved item was subsequently closed as non-cited
violation NCV 05000445/2009004-04; 05000446/2009004-04, Inadequate
Postfire Safe Shutdown Procedure.
As a corrective action for this violation, the licensee designed plant modifications
(FDA-2010-000172-63 for Unit 1 and FDA-2010-000172-64 for Unit 2) to:
- install hot short prevention cable in the control room and cable spreading
- 11 -
room for all four valves
- install new control switches at the hot shutdown panel and shutdown transfer
panel for valves LCV-112B and LCV-112D to allow control of these valves
from the hot shutdown panel
- reconfigure the control circuits for the valves to comply with the requirements
- remove the 3-hour cable in the power and control circuits for LCV-112B
This modification was originally scheduled to be completed in 2014 during the
spring outage for Unit 2 and the fall outage for Unit 1. On February 7, 2014, the
licensee made a decision to delay the modification for Unit 2 from Refueling
Outage 14 to Refueling Outage 15. The licensee documented this decision in
condition report CR-2014-001506. This condition report provided the following
information for delaying the modification:
The complexity and breadth of this modification coupled with
corrective actions from recent plant events led to late development
of work orders and test procedures resulting in a significant impact
on producing quality, complete, and impacted work orders for field
implementation required to support station outage milestones.
Deferral of this modification provides the station time to properly
assess and address risk factors to assure final implementation
meets all station requirements.
The team noted that the recent plant events referred to in this condition report
occurred on December 4, 2013, and were described in Licensee Event
Notification 49606, condition report CR-2013-012287, and Licensee Event
Report 05000445/2013-003-00.
The team reviewed the licensees rationale for delaying the Unit 2 modification.
The team concluded that it was reasonable to delay the modification in order to
give the licensee time to implement corrective actions associated with the
modification process.
The team determined that a performance deficiency existed because the
corrective actions for the original fire protection violation (NCV 05000445/2009004-04; 05000446/2009004-04) were untimely. Specifically, the
team determined that the corrective actions were untimely since the violation has
existed for more than six years and the licensee has yet to correct and restore
compliance for Unit 2. The enforcement aspect of this performance deficiency
will be documented in a future NRC Inspection Report with the closure of
Licensee Event Report 05000445/2013-003-00 since the underlying cause of the
delay was associated with problems with the modification process that
manifested themselves during the December 4, 2013, event.
b. Findings
No findings were identified.
- 12 -
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
(Closed) Licensee Event Report 05000446/2013-001-00, Unit 2 Hot Shutdown Panel
Transfer Switch Inoperable Due to Wiring Error
a. Inspection Scope
The licensee event report documented wiring errors during implementation of hot
shutdown panel control transfer switch modifications. The inspectors performed a review
of the event. The inspectors examined written procedures, electrical drawings, condition
reports, and the licensees root cause evaluation.
b. Findings
Introduction. The team reviewed a Green, self-revealing non-cited violation of
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for
the licensees failure to ensure that procedures provide adequate guidance for labeling
and terminating cables during circuit modifications. Specifically, procedure
CMP-EL-1006, Cable Terminations, Revision 3, did not prescribe the appropriate
human performance standards and cable label controls when installing new cable.
Description. On January 6, 2013, the licensee performed a surveillance test of the
Unit 2 hot shutdown panel. During this test, transfer/isolation switch 2-HS-2452D,
Auxiliary Feedwater Pump Turbine Main Steam Line 1 Supply Valve Control Transfer,
was placed in the HSP position. This caused the turbine-driven auxiliary feedwater
pump steam supply valve, 2-HV-2452, to unexpectedly open when it should have
remained closed. After declaring the hot shutdown panel inoperable, the licensee
performed troubleshooting efforts which revealed that incorrect wiring, due to incorrect
cable labeling, was the cause of the event. The incorrect wiring occurred during the
previous outage in October 2012 and the post-modification testing failed to identify the
error. The licensee performed a root cause evaluation, documented in condition report
CR-2013-000140 and corrected the cable labeling and wiring to restore the hot
shutdown panel to operable.
The team reviewed the licensees root cause evaluation which determined the root
cause to be an inadequate modification procedure, CMP-EL-1006, which has existed
since 1995. The evaluation concluded that this procedure failed to provide controls for
removal, replacement, and verification of cable labels. The evaluation also identified
several contributing causes associated with engineering and operations post-work
testing training, management ownership of the construction procedure, and inaccurate
methods for quality control inspections. The wiring error caused one of the two turbine-
driven auxiliary feedwater pump steam supply valves to fail open when the hot shutdown
panel transfer/isolation switch was taken to the remote position. The valve failed to its
safety position and would not have prevented the turbine-driven pump from performing
its safe shutdown function. The redundant steam supply valve was unaffected by the
wiring error.
The team determined that this issue had a cross-cutting aspect that was indicative of
current plant performance. An open action to address a procedure change was
- 13 -
captured in condition report CR 2010-007615, which was extended three times from
December 2011 through December 2012, consequently the licensee had multiple
opportunities to foresee and correct the procedure deficiencies.
The licensee entered this into the corrective action program as condition report
CR-2013-000140. The corrective actions included: confirming that the same error did not
exist for the other steam supply valve or for the Unit 1 transfer switch, retiring procedure
CMP-EL-1006 and revising other maintenance section generic procedures that will be
used to implement future circuit modifications.
Analysis. The licensees failure to ensure that procedures provide adequate guidance
for labeling and terminating cables during circuit modifications was a performance
deficiency. The finding was more than minor because if left uncorrected this could have
the potential to lead to a more significant safety concern. Specifically, because
operation of the hot shutdown panel auxiliary feedwater transfer/isolation switch cannot
be reliably performed. Using NRC Inspection Manual Chapter 0609, Appendix F,
Attachment 1, Part 1: Fire Protection SDP Phase 1 Worksheet, dated
September 30, 2013, the finding was determined to be of very low safety significance
(Green), by answering Step 1.3.1, Question 2, because the finding did not affect the
reactor to be able to reach and maintain a safe shutdown condition. The finding had a
human performance cross-cutting aspect in resources because leaders failed to ensure
that personnel and procedures were available and adequate to support nuclear
safety.[H.1]
Enforcement. Title 10 of the Codes of Federal Regulation Part 50, Appendix B, Criterion
V, Instructions, Procedures, and Drawings, requires, in part, activities affecting quality
shall be prescribed by documented instructions, procedures, or drawings, of a type
appropriate to the circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings. Contrary to the above, from 1995 to 2013, the
licensee failed to ensure that activities affecting quality were prescribed by documented
instructions, procedures, or drawings and were accomplished in accordance with the
instructions, procedures, or drawings. Specifically, procedure CMP-EL-1006, Cable
Terminations, Revision 3, did not prescribe the appropriate cable label controls when
installing new cable. Since the violation was of very low safety significance and was
documented in the licensees corrective action program as condition report
CR-2013-000140, it is being treated as a non-cited violation, consistent with Section
2.3.2.a of the NRC enforcement Policy: NCV 05000446/2014008-01, Failure to Update
Procedures for Cable Label Controls.
4OA5 Other Activities
(Closed) Unresolved Item 05000445/2013004-06; 05000446/2013004-06, Potential
Motor-Operated Valve Single Spurious Operation Vulnerability
On November 6, 2013, inspectors identified a concern and documented an unresolved
item associated with the potential vulnerability of motor-operated valves to fire-induced
single spurious operations. Specifically, the inspectors were concerned that a single hot
short could cause the spurious operation of motor-operated valves and bypass their
torque/limit switch, resulting in potential damage to the pressure boundary.
The licensee had previously entered this issue into their corrective action program as
- 14 -
condition report CR-2010-007806 and implemented compensatory measures. As a
corrective action for this issue, the licensee chose to perform modifications on 60 motor-
operated valves. Since the licensee implemented compensatory measures and
developed corrective actions that would resolve the concern, the licensee decided not to
perform an evaluation at the time in order to determine if the spurious operation of the
motor-operated valves could result in damage to the pressure boundary.
In response to the unresolved item, the licensee evaluated the possibility that the
spurious operation of the motor-operated valves could result in damage to the pressure
boundary. The licensee evaluated 252 motor-operated valves and determined that six
valves were susceptible to damage (e.g., the valves could be damaged due to the failure
of the main flange bolting or the bonnet flange), but the damage was not sufficient to
damage the pressure boundary.
During this inspection, the inspectors reviewed the licensees evaluation. The inspectors
determined that the licensee appropriately evaluated the possibility that the single
spurious operation could damage the pressure boundary. Because the six valves in
question were not relied upon for post-fire safe shutdown in the fire areas of concern, the
team concluded that there was no impact on the ability to achieve and maintain safe
shutdown. Therefore, no performance deficiency exists.
This unresolved item is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented the inspection results to Mr. Ben Mays, Assistant to the Chief
Nuclear Officer, and other members of the licensees staff at an initial exit meeting on
February 13, 2014. All members present acknowledged the findings presented.
On March 19, 2014, the inspection team lead discussed an update to the inspection
results with Mr. Tim Hope, Nuclear Licensing Manager. All proprietary information has
been discarded.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the
licensee and is a violation of NRC requirements which meets the criteria of
Section 2.3.2.a of the NRC Enforcement Policy, to disposition it as a non-cited violation.
License Condition 2.G requires the licensee to implement and maintain in effect all
provisions of the approved fire protection program as described in the Final Safety
Analysis Report through Amendment 78 and as approved in the Safety Evaluation
Report (NUREG-0797) and its supplements through SSER 24 for Unit 1, and through
Amendment 87 and as approved in the Safety Evaluation Report (NUREG-0797) and its
supplements through SSER 27 for Unit 2. Section 13.3B.5 of the Final Safety Analysis
Report describes the fire protection quality assurance program, which requires, in part,
that measures be established to ensure that design and procurement document changes
are subject to the same controls that were applicable to the original design. Contrary to
the above, from 1999 through 2005, the licensee failed to update Attachment Y of
- 15 -
Calculation ME-CA-0000-1093, Design data for CPSES Unit 1, 2, Common Safety-
related Motor-Operated Valves (MOV) within the scope of NRC Generic Letter 89-10,
Revision 25, when making changes to the motor-operated valve gear ratios for motor-
operated valves credited in the fire safe shutdown analysis. The licensee initially
identified and documented this violation in condition report CR-2011-002717. The
violation was of very low safety significance because it does not affect the ability to
reach and maintain a stable plant condition within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, per Inspection
Manual Chapter 0609, Appendix F, Attachment 1, Part 1: Fire Protection SDP Phase 1
Worksheet, dated September 30, 2013, Task 1.4.5 Question B.
ATTACHMENT: SUPPLEMENTAL INFORMATION
- 16 -
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Acosta Electrical/I&C Engineering Modification Manager
F. Ames Maintenance Supervisor
H. Beck Fire Safe Shutdown Analysis Engineer
G. Bryan Unit Supervisor-Accident Mitigation SME
C. Gibson CB&I Consultant
J. Hammons MT22 Electrician
J. Hicks Regulatory Affairs
T. Hope Nuclear Licensing Manager
B. Mays Assistant to the CNO
J. McGaha MT22 Electrician
M. Montellano Nuclear Equipment Operator
R. Plunkett Fire Protection Engineer
L. Slaughter Cause Analyst
J. Squires MT27 Electrician
M. Wisdom Fire Protection System Engineer
L. Zimmerman Procurement Engineering & Engineering Programs Manager
NRC Personnel
J. Dixon, Acting Branch Chief, Engineering Branch 2
J. Kramer, Senior Resident Inspector
R. Kumana, Resident Inspector
G. Miller, Acting Deputy Director, Division of Reactor Safety
F. Sanchez, Senior Resident Inspector, South Texas Project
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
Failure to Update Procedures for Cable Label Controls05000446/2014008-01 NCV
(Section 4OA3)
Closed
05000445/2013004-06; Potential Motor-Operated Valve Single Spurious Operation
05000446/2013004-06 Vulnerability (Section 4OA5)
Unit 2 Hot Shutdown Panel Transfer Switch Inoperable Due
05000446/2013-001-00 LER
to Wiring Error (Section 4OA3)
A-1 Attachment
LIST OF DOCUMENTS REVIEWED
CALCULATIONS
Number Title Revision
0210-063-0002 As-Built Combustible Loading Calculation Unit 1 014
Safeguards Building
0210-063-0012 Hose Station Coverage Calculation 002
0210-063-0035 Emergency Communication Systems Availability 001
0210-063-0051 Smoke Removal Calculation 001
225-10 Fire Protection Yard Piping Pressure Drop (Gibbs & 001
Hill)
2-EE-0051 Emergency Communication Systems Availability - 000
CPSES Unit 2
CN-TA-07-88 Fire Safe Shutdown Analysis for 3612 MWt Power 002
Uprate
CS-CA-0000-3262 Seismic Qualification of Electrical and Mechanical 000
Equipment
EE-CA-0008-157 Coordination Study of 6.9 kV Power Distribution 003
System
ER-ME-125 Thermal / Hydraulic Analysis of the Fire Safe Shutdown 001
Scenario
ME-CA-0000-1086 Fire Safe Shutdown Analysis for CPSES Unit 1, Unit 2, 002
and Common
CONDITION REPORTS
2008-000311 2011-001836 2013-005889 2014-001084*
2008-000324 2011-002581 2013-007927 2014-001091*
2008-000488 2011-002717 2013-007964 2014-001093*
2009-003415 2011-012603 2013-008873 2014-001109*
2010-005052 2012-000050 2013-008875 2014-001127*
2010-006501 2013-000140 2013-008908 2014-001135*
2010-007615 2013-001238 2013-008910 2014-001204*
2010-007806 2013-002903 2013-012701 2014-001248*
2011-001318 2013-003039 2014-000844* 2014-001310*
2011-001647 2013-003180 2014-000998* 2014-001312*
2011-001742 2013-004082 2014-001061* 2014-001492*
2011-001821 2013-005314 2014-001062* 2014-001495*
A-2
2014-001506* 2014-001564* 2014-001568* 2014-001629*
2014-001541* 2014-001566* 2014-001614*
- Issued as a result of inspection activities.
DESIGN BASIS DOCUMENTS
Number Title Revision
DBD-EE-048 Communication System 016
DBD-EE-057 Separation Criteria 029
DBD-ME-001 CPSES Fire Protection Program 008
DBD-ME-002 Penetration Seals 010
DBD-ME-020 Fire Safe Shutdown Analysis 013
DBD-ME-063 Fire Barriers 006
DBD-ME-104 Fire Detection System 015
DBD-ME-225 Fire Suppression System 020
DRAWINGS
Number Title Revision
E1-0004 6.9 kV Auxiliaries One Line Diagram Safeguards Buses CP-38
E1-0018, Sh. 1 208/120V AC, One Line Diagram CP-47
E1-0018, Sh. 1A 208/120V AC, One Line Diagram CP-16
E1-0018, Sh. 1B 208/120V AC, One Line Diagram CP-31
E1-0018, Sh. D 118V AC, Instrument Bus Distribution, One Line CP-26
Diagram
E1-0018, Sh. F 118V AC, Instrument Bus Distribution, One Line CP-19
Diagram
E1-0020, Sh. B 125V DC, One Line Diagram CP-18
E1-0020, Sh. H 125V DC, One Line Diagram CP-16
E1-0031, Sh. 01 6.9 kV Switchgear Bus 1EA1 Start-up Breaker 1EA1-1 CP-9
Schematic Diagram
A-3
Number Title Revision
E1-0031, Sh. 03 6.9 kV Switchgear Bus 1EA1 Breaker 1EA1-2 CP-16
Schematic Diagram
E1-0038, Sh. 52A Steam Generator FW, Miscellaneous Switches CP-6
E1-0061, Sh. 01 Motor Operated Valve 1-8100 Reactor Coolant Pump CP-5
Seal Water Isolation
E1-0061, Sh. 02 Motor Operated Valve 1-8105 Charging Pump to CP-4
Reactor Coolant System Isolation
E1-0061, Sh. 04 Motor Operated Valve 1-8110 Charging Pump Miniflow CP-9
Isolation
E1-0061, Sh. 05 Motor Operated Valve 1-8111 Charging Pump Miniflow CP-8
Isolation
E1-0061, Sh. 06 Motor Operated Valve 1-8112 Reactor Coolant Pump CP6
Seal Water Isolation
E1-0061, Sh. 19 Air Operated Valve 1-LCV-0459 Letdown Isolation Line CP-7
Valve
E1-0061, Sh. 20 Air Operated Valve 1-LCV-0460 Letdown Isolation Line CP-6
Valve
E1-0061, Sh. 30 Air Operated Valve 1-8153 Excess Letdown Line CP-8
Isolation
E1-0061, Sh. 31 Air Operated Valve 1-8154 Excess Letdown Line CP-8
Isolation
E1-0061, Sh. 36 Air Operated Valve 1-8149A Letdown Orifice Isolation CP-7
E1-0061, Sh. 37 Air Operated Valve 1-8149B Letdown Orifice Isolation CP-9
E1-0061, Sh. 38 Air Operated Valve 1-8149C Letdown Orifice Isolation CP-6
E1-0061, Sh. 40 Air Operated Valve 1-8152 Letdown Line Isolation CP-2
E1-0061, Sh. 86 Air Operated Valve 1-8160 Letdown Line Isolation CP-7
E1-0062, Sh. 05 Motor Operated Valve 1-8801A Charging Pumps Safety CP-5
Injection Header Isolation
A-4
Number Title Revision
E1-0062, Sh. 22 Motor Operated Valve 1-8811A Sump to Number 1 CP-8
Residual Heat Removal Pump Schematic/Ext Conn
Diagram
E1-0062, Sh. 24 Motor Operated Valve 1-8812A Refueling Water CP-6
Storage Tank to RHR Pump 1 Isolation Schematic/Ext
Conn Diagram
E1-0063, Sh. 7 Motor Operated Valve 1-8716A Residual Heat Removal CP-4
Cross Connect
E1-0064, Sh. 1 Motor Operated Valve 1-8000A Pressurizer Relief CP-8
Isolation Valve
E1-0064, Sh. 02 Motor Operated Valve 1-8000B Pressurizer Relief CP-8
Isolation Valve
E1-0064, Sh. 11 Nitrogen Operated Valve 1-PCV-0455A Pressurizer CP-8
Power Relief Valve
E1-0064, Sh. 12 Nitrogen Operated Valve 1-PCV-0456 Pressurizer CP-8
Power Relief Valve
E1-0197, Sh. 2D Feedwater Pump 1A and 1B, Digital Control Panel CP-6
CP1-FWECLP-01, Interconnection Diagram
E1-0901 Lighting System, Lighting One Line Diagram, CP-24
Safeguards Building
E1-0911, Sh. L Safeguards Building Lighting Maintenance Plan El. CP-1
810-6
E1-0911, Sh. T Safeguards and Diesel Generator Buildings Emergency CP-4
Lighting Plan El. 810-6
E1-0916, Sh. 1T Control Building, Emergency Lighting Plan, EL 778-0 CP-2
E1-0916, Sh. 2T Control Building Battery Rooms, Emergency Lighting CP-5
Plan, EL 792-0
E1-0940, Sh. T Safeguards and Diesel Generator Buildings, CP-4
Emergency Lighting Plan, EL 831-6 and 844-0
E1-2001, Sh. D Miscellaneous Systems, One Line Diagram, PNL CP-2
XEC2-7
A-5
Number Title Revision
E2-0031, Sh. 53 6.9 kV Switchgear Bus 2EA1 Centrifugal Charging PP CP-5
22 Tag TCX-CSAPCH-02 Bkr 2APCH2 Schematic
Diagram
E2-0031, Sh. 55 6.9 kV Switchgear Bus 2EA2 Centrifugal Charging CP-5
Pump 21 Tag TCX-CSAPCH-01 Bkr 2APCH1
Schematic Diagram
E2-0061, Sh. 66 Motor Operated Valve 1-8351A Seal Water Injection CP-5
Isolation
M1-0202 Flow Diagram Main Steam Reheat and Steam Dump CP-33
M1-0203 Flow Diagram, Steam Generator, Feedwater System CP-29
M1-0204, Sh. 3 Flow Diagram, Condensate System CP-20
M1-0225 Flow Diagram Fire Protection System CP-22
M1-0225, Sh. 1 Flow Diagram Turbine Building Unit 1 Fire Protection CP-12
M1-0225, Sh. 2 Flow Diagram Auxiliary Building Fire Protection CP-22
M1-0225, Sh. 3 Flow Diagram Safeguard Building Unit 1 Fire Protection CP-9
M1-0225, Sh. 3 Flow Diagram Safeguard Building Unit 1 Fire Protection CP-15
M1-0225, Sh. 3A Flow Diagram Safeguard and Diesel Generator CP-8
Buildings Unit 1 Fire Protection
M1-0225, Sh. 4 Flow Diagram Fuel Building Fire Protection CP-12
M1-0225, Sh. 4A Flow Diagram Electric Control Building Fire Protection CP-14
M1-0225, Sh. 5 Flow Diagram Containment Building Unit 1 Fire CP-12
Protection
M1-0250 Flow Diagram, Reactor Coolant System CP-34
M1-0253 Flow Diagram Chemical and Volume Control System CP-21
M1-0253, Sh. A Flow Diagram Chemical and Volume Control System CP-10
M1-0255 Flow Diagram Chemical and Volume Control System CP-28
Volume Control Tank Loop
A-6
Number Title Revision
M1-0261 Flow Diagram Safety Injection System Sheet 1 of 5 CP-22
M1-0263, Sh. B Flow Diagram Safety Injection System Sheet 5 of 5 CP-14
M1-1700 Thermolag and Res Schedule CP-5
M1-1920, Sh. 1 Fire Hazard Analysis Unit Containment and Safeguards CP-3
Buildings Plan at El. 790-6
M1-1927, Sh. 1 Fire Hazard Analysis Unit 1 Auxiliary/Electrical Control CP-5
Building El. 778-0 and El. 790-6
M1-1927, Sh. 1A Fire Hazard Analysis Unit 1 Auxiliary and Electrical CP-3
Control Building Partial plan El. 792-0
M1-1928, Sh. 1 Fire Hazard Analysis Auxiliary and Electrical Control CP-3
Building El. 807-0 and El. 810-6
M2-0225, Sh. 1 Flow Diagram Turbine Building Fire Protection CP-13
M2-0225, Sh. 2A Flow Diagram Auxiliary Building Fire Protection CP-13
M2-0225, Sh. 3 Flow Diagram Safeguard Building Unit 2 Fire Protection CP-10
M2-0225, Sh. 3A Flow Diagram Diesel Generator Building Unit 2 Fire CP-5
Protection
M2-0225, Sh. 5 Flow Diagram Containment Building Unit 2 Fire CP-6
Protection
M2-1920, Sh. 1 Fire Hazard Analysis Unit Containment and Safeguard CP-4
Buildings Plan at El. 790-6
MX-0225, Sh. 10 Flow Diagram With Valve Arrangements CP-9
MX-0225, Sh. 7 Flow Diagram Fire Protection Treated Water Supply CP-16
System
MX-0225, Sh. 8 Flow Diagram Fire Protection Treated Water Supply CP-11
System
SK-0001-10-000172- Motor Operated Valve 1-8716A Residual Heat Removal 001
48-01 Cross Connect
A-7
EVALUATIONS
Number Title Date
EV-CR-2011- SER Equivalency Evaluation November
008909-5 21, 2013
EV-CR-2013- HEMYC Fabrication August 14,
003882-1 2013
EV-CR-2014- CPNPP Fire Pump Testing February
000844-2 12, 2014
EV-CR-2014-1084 Fire Piping Yard Loop Flow February
11, 2014
MISCELLANEOUS DOCUMENTS
Number Title Revision
/Date
2323-ES-100 Electrical Installation 104
2323-MI-0750 Ventilation Auxiliary Building Plan EL. 778-0 008
CDF 17923 Commitment Data Form Report PLCT004 October 5,
2001
CDF 17930 Commitment Data Form Report PLCT004 October 27,
1998
CP-201301082 MOU between Luminant Generation Company LLC Augusts 28,
and Air Evac EMS, Inc. dated June 24, 2010 2013
DR C-89-1903 Deficiency Report Regarding Fire Pump Testing 000
Interval Frequency
GENESIS Database Cable and Raceway Database for the Sampled Fire
Areas
PCI-FD-CPX- Installation Details For Fire Dampers 002
VADPFD-103
PCI-FD-CPX- Installation Details For Fire Dampers 002
VADPFD-113
SG-001 Emergency Planning Writers Guide 019
A-8
WPT-15195 Westinghouse Letter: Motor Operated Valves June 16,
1993
CPF-07772-001 Emergency Lighting 006
Operating Limits of a Enterprise DSRV-16-4 Engine October 25,
Loaded to 800 kW With No Service Water Flow, 2007
Comanche Peak, Unit S/Ns 76001, 76002, 76003,
76004
MODIFICATIONS92-071 2008-000324-03 2010-000172-28 2010-000172-51
2008-000324-01 2010-000172-07 2010-000172-38 2010-000172-51
2008-000324-02 2010-000172-21 2010-000172-64
PROCEDURES
Number Title Revision
ABN-104 Residual Heat Removal System Malfunction 009
ABN-301 Instrument Air System Malfunction 012
ABN-601 Abnormal Conditions Procedures Manual 012
ABN-803A Response To A Fire In The Control Room Or Cable 011
Spreading Room
ABN-804A Response to Fire in the Safeguards Building 005
ABN-804B Response to Fire in the Safeguards Building 003
ABN-805A Response to Fire in the Auxiliary Building or the Fuel 007
Building
ABN-806A Response to Fire in the Electrical and Control Building 007
ABN-808A Response to Fire in Service Water Intake Structure 005
ABN-901 Fire Protection System Alarms or Malfunctions 009
ECE 5.01-08 Electronic Design Change Process 001
ECE 5.01-08 Electronic Design Change Process 019
ECE-5.01 Design Control Program 024
A-9
Number Title Revision
EDMG-A.4-4 Manually Depressurize S/Gs and Use Portable AME 006
Pump for Makeup
EOP-0.0A Reactor Trip or Safety Injection 008
EPG-3.01 Electronic Data Management System (EDMS) 005
FIR-201 Preparation, Control, Review and Use of Fire Preplan 009
Instructions
FIR-202 Fire Protection Inspections 005
FIR-301 Portable Fire Extinguisher Inspection, Maintenance, 005
Recharging, and Hydrostatic Testing
FIR-302 Fire Door Tests and Inspections 007
FIR-303 Halon Fire Suppression System Inspection 005
FIR-307 Inspection of Sprinkler Systems 003
FIR-308 Fire Brigade Equipment 004
FIR-309 Hose Station and Hydrant/Hose House Inspections 004
FIR-310 Penetration Seal Inspection 003
FIR-311 Fire Rated Assembly Visual Inspection 002
FIR-312 Hydrostatic Testing of Fire Hose 001
FIR-P1-3115 Deluge Valves 1-HV-4113M, R, Q Unit 1 Safeguards 001
Building Train A/B Switchgear Rooms and Electrical
Equipment Room
FIR-PX-3200 Fire Suppression Loop Flow Test 003
FIR-PX-3203 Fire Protection Pump CPX-FPAPFP-01 Emergency Fill 003
Flow Test
FIR-PX-3601 Fire Hydrant Yearly Flow Test 001
FIR-PX-3801 Electric Driven Fire Protection Pump CPX-FPAPFP-04 004
Operability Test
FIR-PX-3802 Diesel Driven Fire Protection Pump CPX-FPAPFP-05 004
Operability Test
A-10
Number Title Revision
FPI-102A Unit 1 Safeguards Building Elevation 790-0 003
FPI-103A Unit 1 Safeguards Building Elevation 810-6 Rad, 003
Penetration Area and Electrical Equipment Room
FPI-501 Electrical & Control Building Control Room Elevation 004
778-0
FPI-506 Electrical & Control Building Control Room Elevation 004
830-0
FPI-701 Service Water Intake Structure Elev. 796-0 & 810-6 003
FPI-702 Fire Water Pumphouse 001
FPI-901 Protected Area Yard, Main FP Underground Loop and 002
Supplies
MSE-P0-5306 Emergency Lighting Unit Inspection 008
MSE-CO-7334 Testing Fenwal Fire Detection Unit 002
MSE-CO-7335 Ionization Detector Sensitivity Test and Visual Check 003
MSE-CX-6003 Fire Water Pump House 480 V Motor Control Center 000
XB38-1 (CPX-EPMCNB-53) Temporary Power
MSE-GO-7700 Fire Protection System Troubleshooting 001
MSE-P1-7702 Fire Protection Control Panel test CP1-EIPRLV-33 003
MSE-P1-7703 Fire Protection Control Panel test CP1-EIPRLV-33A 003
MSE-P1-7704 Halon Fire System Test CPX-EIPRLV-42 003
MSE-PX-4011 Fire Pump Motor Inspection 001
MSE-PX-5004 Pump House Battery Inspection 002
MSE-PX-7715 Halon Fire System Test CPX-EIPRLV-44A 002
MSM-C0-7316 Diesel Engine Driven Fire Pump Maintenance 002
MSM-CO-1856 Grinnell Strainer Maintenance (Models A and B-1) 002
MSM-CO-7318 Electric Motor Driven Fire Pump X-04 Maintenance 000
A-11
Number Title Revision
MSM-PO-0705 Fire Damper Inspection and Cleaning 003
MSM-PX-4702 Fire Pump Diesel Engine Preventive Maintenance 002
(CPX-FPAPFP-05D and CPX-FPAPFP-06D)
OPT-216A Remote Shutdown Operability Test 013
OWI-201-35 Accident Mitigation Equipment Periodic Review R-4
OWI-203 Operations Department Management Periodic Reviews 013
OWI-203-19 Emergency Use Job Aids/Tools Periodic Review R-18
(Unit 1)
SOP-904 Fire Protection Main Water Supply and Fire Pumps 016
System
STA-214 Timed Operator Action Program 002
STI-214.01 Control of Timed Operator Actions 000
STA-421 Initiation of Condition Reports 019
STA-422 Processing Condition Reports 031
STA-426 Industry Operating Experience Program 007
STA-426.03 Processing Noteworthy OE (NOE) 000
STA-606 Control of Maintenance and Work Activities 032
STA-606 Control of Maintenance and Work Activities 032
STA-722 Fire Protection Program 007
STA-723 Fire Protection Systems/Equipment Requirements 005
STA-724 Fire Reporting and Response 003
STA-727 Fire Brigade 005
STA-728 Storage and Handling of Flammable/Combustible 004
Material and Compressed/Cryogenic Gases
STA-729 Control of Transient Combustibles, Ignition Sources 011
and Fire Watches
A-12
STA-738 Fire Protection Systems/Equipment Impairments 007
STI-606.01 Work Control Process 000
TRA-104 Fire Protection Training 015
WORK ORDERS
3889306 4230390 4398528 4576864
3944733 4300544 4400089 4782303
4097224 4333534 4452277
4195438 4350894 4463866
A-13