IR 05000369/2006008: Difference between revisions

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{{Adams|number = ML070300007}}
{{Adams
| number = ML070300007
| issue date = 01/29/2007
| title = IR 05000369-06-008 and 05000370-06-008, on 12/14/06, McGuire Nuclear Station, NRC Triennial Fire Protection and Exercise of Enforcement Discretion
| author name = Payne D C
| author affiliation = NRC/RGN-II/DRS/EB2
| addressee name = Peterson G R
| addressee affiliation = Duke Energy Corp
| docket = 05000369, 05000370
| license number = NPF-009, NPF-017
| contact person =
| document report number = IR-06-008
| document type = Inspection Report, Letter
| page count = 39
}}


{{IR-Nav| site = 05000369 | year = 2006 | report number = 008 }}
{{IR-Nav| site = 05000369 | year = 2006 | report number = 008 }}
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Inspection Report 05000369/2006008 and 05000370/2006008w/Attachment; Supplemental Informationcc w/encl: (See page 3)
Inspection Report 05000369/2006008 and 05000370/2006008w/Attachment; Supplemental Informationcc w/encl: (See page 3)
DPC3cc w/encl:C. J. Thomas Regulatory Compliance Manager (MNS)
DPC3cc w/encl:C. J. Thomas Regulatory Compliance Manager (MNS)
Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC Electronic Mail DistributionR. L. Gill, Jr., ManagerNuclear Regulatory Issues and Industry Affairs Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC 526 S. Church Street Charlotte, NC 28201-0006Lisa F. VaughnAssociate General Counsel and Managing Attorney Duke Energy Carolinas, LLC 526 South Church Street-EC07H Charlotte, NC 28202Kathyrn B. NolanSenior Counsel Duke Energy Carolinas, LLC 526 South Church Street-EC 07H Charlotte, NC 28202David A. RepkaWinston & Strawn LLP Electronic Mail DistributionBeverly Hall, Chief, RadiationProctection Section N. C. Department of Environmental Health & Natural Resources Electronic Mail DistributionCounty Manager of Mecklenburg County720 East Fourth Street Charlotte, NC 28202 DPC1ADAMS is accessible from the NRC Web site at: http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).
Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC Electronic Mail DistributionR. L. Gill, Jr., ManagerNuclear Regulatory Issues and Industry Affairs Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC 526 S. Church Street Charlotte, NC 28201-0006Lisa F. VaughnAssociate General Counsel and Managing Attorney Duke Energy Carolinas, LLC 526 South Church Street-EC07H Charlotte, NC 28202Kathyrn B. NolanSenior Counsel Duke Energy Carolinas, LLC 526 South Church Street-EC 07H Charlotte, NC 28202David A. RepkaWinston & Strawn LLP Electronic Mail DistributionBeverly Hall, Chief, RadiationProctection Section N. C. Department of Environmental Health & Natural Resources Electronic Mail DistributionCounty Manager of Mecklenburg County720 East Fourth Street Charlotte, NC 28202  


Sincerely,/RA/D. Charles Payne, Chief, Engineering Branch 2 Division of Reactor SafetyDocket Nos. 50-369, 50-370License Nos. NPF-9, NPF-17
_________________________OFFICERII:DRSRII:DRSRII:DRSRII:DRSRII:DRSRII:DRSRII:DRPSIGNATURE/RA//RA//RA//RA//RA//RA//RA/NAMEG.MacDonaldG.WIsemanR.FannerR.RodriguezC.PayneN.MerriweatherJ.MoormanDATE01/18/0701/19/0701/19/0701/18/0701/29/0701/29/0701/29/07E-MAIL COPY? NO YES YES YES YESNO YES NO REGION IIDocket Nos:50-369, 50-370License Nos:NPF-9, NPF-17 Report Nos:05000369/2006008, 05000370/2006008 Licensee:Duke Energy Corporation Facility:McGuire Nuclear Station, Units 1 and 2 Location:Huntersville, NC 28078 Dates:November 27 - December 1, 2006 (Week 1)December 11- 14, 2006 (Week 2)Inspectors:N. Merriweather, Senior Reactor Inspector (Lead Inspector)R. Fanner, Reactor Inspector G. MacDonald, Senior Reactor Analyst R. Rodriguez, Reactor Inspector G. Wiseman, Senior Reactor InspectorApproved by:D. Charles PayneEngineering Branch 2 Division of Reactor Safety 2Enclosure
 
===Enclosure:===
Inspection Report 05000369/2006008 and 05000370/2006008w/Attachment; Supplemental Informationcc w/encl: (See page 3)
Distribution w/encl:J. Stang, NRR C. Evans (Part 72 Only)
L. Slack, RII EICS OE Mail (email address if applicable)
RIDSNRRDIRS PUBLIC x PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLEG SENSITIVE X NON-SENSITIVEADAMS: x YesACCESSION NUMBER:_________________________OFFICERII:DRSRII:DRSRII:DRSRII:DRSRII:DRSRII:DRSRII:DRPSIGNATURE/RA//RA//RA//RA//RA//RA//RA/NAMEG.MacDonaldG.WIsemanR.FannerR.RodriguezC.PayneN.MerriweatherJ.MoormanDATE01/18/0701/19/0701/19/0701/18/0701/29/0701/29/0701/29/07E-MAIL COPY? NO YES YES YES YESNO YES NO OFFICIAL RECORD COPY DOCUMENT NAME: C:\FileNet\ML070300007.wpdU.S. NUCLEAR REGULATORY COMMISSION REGION IIDocket Nos:50-369, 50-370License Nos:NPF-9, NPF-17 Report Nos:05000369/2006008, 05000370/2006008 Licensee:Duke Energy Corporation Facility:McGuire Nuclear Station, Units 1 and 2 Location:Huntersville, NC 28078 Dates:November 27 - December 1, 2006 (Week 1)December 11- 14, 2006 (Week 2)Inspectors:N. Merriweather, Senior Reactor Inspector (Lead Inspector)R. Fanner, Reactor Inspector G. MacDonald, Senior Reactor Analyst R. Rodriguez, Reactor Inspector G. Wiseman, Senior Reactor InspectorApproved by:D. Charles PayneEngineering Branch 2 Division of Reactor Safety 2Enclosure


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
.................................................. 3
IR 05000369/2006-008, 05000370/2006-008; 11/27-12/1/2006 and 12/11-14/2006; McGuireNuclear Station, Units 1 and 2; Fire Protection


=REPORT DETAILS=
.This report covers an announced two-week triennial fire protection inspection by five specialist inspectors from the U. S. Nuclear Regulatory Commission's (NRC's) Region II office located in Atlanta, Georgia. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.
.........................................................


41R05 FIRE PROTECTION..................................................4.01 Post Fire Shutdown From Main Control (Normal Shutdown)..............5
===NRC-Identified and Self-Revealing Findings===
No findings of significance were identified.


===.02 Protection of Safe Shutdown Capabilities............................10.03 Passive Fire Protection..........................................10===
===B. Licensee-Identified Violations===


===.04 Active Fire Protection ..........................................11===
None.


===.05 Protection From Damage From Fire Suppression Activities..............15.06 Post-Fire Alternative Shutdown Capability (Outside MCR)...............16.07 Circuit Analyses...............................................20===
4Enclosure


===.08 Communications...............................................21===
=REPORT DETAILS=
 
1.
===.09 Emergency Lighting............................................21===
 
===.10 Cold Shutdown Repairs .........................................23.11 Compensatory Measures........................................234.===
 
==OTHER ACTIVITIES==
...................................................244OA2 Identification and Resolution of Problems.........................244OA5 Additional Examples of Unresolved Item 50-369, 370/03-07-04.........244OA6 Meetings, Including Exit.......................................25 3EnclosureSUMMARY OF FINDINGSIR 05000369/2006-008, 05000370/2006-008; 11/27-12/1/2006 and 12/11-14/2006; McGuireNuclear Station, Units 1 and 2; Fire Protection.This report covers an announced two-week triennial fire protection inspection by five specialist inspectors from the U. S. Nuclear Regulatory Commission's (NRC's) Region II office located in Atlanta, Georgia. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A. NRC-Identified and Self-Revealing FindingsNo findings of significance were identified.B. Licensee-Identified ViolationsNone.
 
4EnclosureREPORT DETAILS1.


==REACTOR SAFETY==
==REACTOR SAFETY==
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The team reviewed and walked down applicable sections of fire response procedure AP/0/A/5500/45, "Plant Fire," for FA 5. The team reviewed local operator manual actions to ensure that the actions could beimplemented in accordance with plant procedures in the times necessary to support the SSD method for the applicable FA and to verify that those actions met the criteria in 2 of NRC IP 71111.05TTP. The team reviewed Problem Investigation Process (PIP) corrective action document 05-04859, Appendix R Manual Actions, to verify that the licensee had identified operator manual actions for post-fire SSD in III.G.2areas and had plans in place to keep PIP 05-04859 open to assess and track resolution of the manual action issue as part of the plant-wide risk evaluation for transition to NFPA 805.
The team reviewed and walked down applicable sections of fire response procedure AP/0/A/5500/45, "Plant Fire," for FA 5. The team reviewed local operator manual actions to ensure that the actions could beimplemented in accordance with plant procedures in the times necessary to support the SSD method for the applicable FA and to verify that those actions met the criteria in 2 of NRC IP 71111.05TTP. The team reviewed Problem Investigation Process (PIP) corrective action document 05-04859, Appendix R Manual Actions, to verify that the licensee had identified operator manual actions for post-fire SSD in III.G.2areas and had plans in place to keep PIP 05-04859 open to assess and track resolution of the manual action issue as part of the plant-wide risk evaluation for transition to NFPA 805.


6Enclosureb.Findings1)Failure to Protect Cables Associated With Motor Operated Valve 1CA-42B in FA 5Introduction:  A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for the licensee's failure to protect or separate cabling associated with the
6Enclosureb.Findings1)Failure to Protect Cables Associated With Motor Operated Valve 1CA-42B in FA 5Introduction:  A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for the licensee's failure to protect or separate cabling associated with the "B" train of MDAFW routed through the Unit 1 "A" diesel generator room (FA 5). The "B" train of MDAFW was required to remain operational to achieve and maintain safe shutdown for a postulated fire in FA 5.Description:  During review of procedure AP/0/A/5500/45, "Plant Fire," Enclosure 11, theteam identified that the licensee utilized a local operator manual action (OMA) to de-energize motor operated valve (MOV) 1CA-42B to prevent spurious closure of the MOV due to potential fire damage during a postulated fire in FA 5. MOV 1CA-42B, the 1B MDAFW pump discharge valve to the 1D steam generator (S/G), is normally open and is required to remain open to establish the auxiliary feedwater (AFW) flowpath to the 1D S/G from the 1B MDAFW pump. The McGuire SSA requires the B train of AFW for SSD for a fire in FA 5. The 1D S/G is one of two S/Gs which receive AFW flow from the 1B MDAFW pump. Two S/Gs are required by the SSA for successful SSD. Cables for MOV 1CA-42B were located in FA 5 while the MOV itself was located in the Unit 1 exterior doghouse FA 30. The licensee failed to protect cable 1*CA548 from potential fire damage in FA 5. In lieu of protecting required cables from fire damage which could cause the MOV to spuriously close and defeat the SSD strategy, the licensee instead de-energized the valve using a local OMA. The local OMA was to de-energize MOV 1CA-42B, after verifying correct open position, by locally opening breaker 3E at motor control center (MCC) 1EMXB in FA 14. The team performed a walk through of this local OMA and determined the action to be feasible and reliable per the criteria in Enclosure 2 to NRC Inspection Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 Transition Period (Triennial). The cables and the local OMA to prevent spurious operation were described in the licensee's SSA.Analysis:  Failure to protect required SSD equipment from potential fire damage is aperformance deficiency and is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external events, i.e.
"B" train of MDAFW routed through the Unit 1 "A" diesel generator room (FA 5). The "B" train of MDAFW was required to remain operational to achieve and maintain safe shutdown for a postulated fire in FA 5.Description:  During review of procedure AP/0/A/5500/45, "Plant Fire," Enclosure 11, theteam identified that the licensee utilized a local operator manual action (OMA) to de-energize motor operated valve (MOV) 1CA-42B to prevent spurious closure of the MOV due to potential fire damage during a postulated fire in FA 5. MOV 1CA-42B, the 1B MDAFW pump discharge valve to the 1D steam generator (S/G), is normally open and is required to remain open to establish the auxiliary feedwater (AFW) flowpath to the 1D S/G from the 1B MDAFW pump. The McGuire SSA requires the B train of AFW for SSD for a fire in FA 5. The 1D S/G is one of two S/Gs which receive AFW flow from the 1B MDAFW pump. Two S/Gs are required by the SSA for successful SSD. Cables for MOV 1CA-42B were located in FA 5 while the MOV itself was located in the Unit 1 exterior doghouse FA 30. The licensee failed to protect cable 1*CA548 from potential fire damage in FA 5. In lieu of protecting required cables from fire damage which could cause the MOV to spuriously close and defeat the SSD strategy, the licensee instead de-energized the valve using a local OMA. The local OMA was to de-energize MOV 1CA-42B, after verifying correct open position, by locally opening breaker 3E at motor control center (MCC) 1EMXB in FA 14. The team performed a walk through of this local OMA and determined the action to be feasible and reliable per the criteria in Enclosure 2 to NRC Inspection Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 Transition Period (Triennial). The cables and the local OMA to prevent spurious operation were described in the licensee's SSA.Analysis:  Failure to protect required SSD equipment from potential fire damage is aperformance deficiency and is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external events, i.e.


fire, and it affects the objective of ensuring the reliability and capability of systems that respond to initiating events. The finding was determined to be of very low safety significance (Green) using the significance determination process (SDP) in NRC Inspection Manual Chapter (IMC) 0609 Appendix F. The local OMA was determined to be feasible and reliable because it met the criteria of IP 71111.05TTP Enclosure 2. As such, the local OMA was determined to be a compensatory measure for the lack of cable protection for required SSD component 1CA-42B. PIP 05-04859 tracked the resolution of III.G.2 OMAs.Enforcement:  McGuire Unit 1 License Condition 2.C.4 states that the licensee shallimplement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the Safety Evaluation Report (SER) dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the safety evaluation (SE) dated May 1989. McGuire UFSAR Section 7Enclosure9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection."  This document states in Appendix C, Section C3, "Appendix R," that the McGuire FPP is required to comply with Title 10 of the Code of Federal Regulations (CFR) Part 50 (hereafter referred to as 10 CFR 50), Appendix R, Sections III.G, J, L and O. It also states thatprocedure AP/0/A/5500/045 is derived from the Fire Area Failure Analysis and Compliance Strategy in the Appendix R design basis document, MCS-1465.00-00-0022. The McGuire FPP, which includes the SSA (MCS-1465.00-00-0022) identifies FA 5 as a 10 CFR 50, Appendix R, Section III.G.2 area and further indicates that McGuire iscommitted to 10 CFR 50, Appendix R, Section III.G. Section III.G.1 of 10 CFR 50Appendix R requires that cables for equipment relied upon to achieve and maintain SSD be free of fire damage. Section III.G.2 of Appendix R lists three options for satisfyingthe requirements for separation and protection of equipment needed to ensure safe shutdown remains free of fire damage. The requirements of this section do not allow using manual actions in lieu of protection and separation. Contrary to the above, on December 14, 2006, the licensee utilized a non-approved local OMA as a compensatory measure in lieu of protecting cable 1*CA548 in FA 5 as required by 10 CFR 50, Appendix R, Section III.G.2. This issue has existed for many years.Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and Reactor Oversight Program (ROP) discretion. The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. On February 28, 2005, the licensee submitted a letter to the NRC stating its intent to transition to 10 CFR 50.48(c). In a subsequent letter to the NRC dated April 18, 2006, the licensee provided the NRC with the planned schedule for the McGuire Station to transition to NFPA 805. In a followup letter from the NRC to the licensee dated September 26, 2006, the NRC acknowledged that a three year period of discretion will begin on April 18, 2006, and that the period of discretion will continue beyond the three year expiration date of April 18, 2009, while NRC staff is reviewing the license amendment request.Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)."  Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance.The licensee entered this issue in their corrective action program under PIP 05-4859.
fire, and it affects the objective of ensuring the reliability and capability of systems that respond to initiating events. The finding was determined to be of very low safety significance (Green) using the significance determination process (SDP) in NRC Inspection Manual Chapter (IMC) 0609 Appendix F. The local OMA was determined to be feasible and reliable because it met the criteria of IP 71111.05TTP Enclosure 2. As such, the local OMA was determined to be a compensatory measure for the lack of cable protection for required SSD component 1CA-42B. PIP 05-04859 tracked the resolution of III.G.2 OMAs.Enforcement:  McGuire Unit 1 License Condition 2.C.4 states that the licensee shallimplement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the Safety Evaluation Report (SER) dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the safety evaluation (SE) dated May 1989. McGuire UFSAR Section 7Enclosure9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection."  This document states in Appendix C, Section C3, "Appendix R," that the McGuire FPP is required to comply with Title 10 of the Code of Federal Regulations (CFR) Part 50 (hereafter referred to as 10 CFR 50), Appendix R, Sections III.G, J, L and O. It also states thatprocedure AP/0/A/5500/045 is derived from the Fire Area Failure Analysis and Compliance Strategy in the Appendix R design basis document, MCS-1465.00-00-0022.
 
The McGuire FPP, which includes the SSA (MCS-1465.00-00-0022) identifies FA 5 as a 10 CFR 50, Appendix R, Section III.G.2 area and further indicates that McGuire iscommitted to 10 CFR 50, Appendix R, Section III.G. Section III.G.1 of 10 CFR 50Appendix R requires that cables for equipment relied upon to achieve and maintain SSD be free of fire damage. Section III.G.2 of Appendix R lists three options for satisfyingthe requirements for separation and protection of equipment needed to ensure safe shutdown remains free of fire damage. The requirements of this section do not allow using manual actions in lieu of protection and separation. Contrary to the above, on December 14, 2006, the licensee utilized a non-approved local OMA as a compensatory measure in lieu of protecting cable 1*CA548 in FA 5 as required by 10 CFR 50, Appendix R, Section III.G.2. This issue has existed for many years.Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and Reactor Oversight Program (ROP) discretion. The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. On February 28, 2005, the licensee submitted a letter to the NRC stating its intent to transition to 10 CFR 50.48(c). In a subsequent letter to the NRC dated April 18, 2006, the licensee provided the NRC with the planned schedule for the McGuire Station to transition to NFPA 805. In a followup letter from the NRC to the licensee dated September 26, 2006, the NRC acknowledged that a three year period of discretion will begin on April 18, 2006, and that the period of discretion will continue beyond the three year expiration date of April 18, 2009, while NRC staff is reviewing the license amendment request.Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)."  Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance.The licensee entered this issue in their corrective action program under PIP 05-4859.


8Enclosure2)Failure to Protect 1SV1AB Cabling in FA 5Introduction:  A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for the licensee's failure to protect "D" Steam Generator (S/G) pilot operated relief valve (PORV) cabling located in the Unit 1 Train "A" emergency diesel generator room (FA 5). Cables for the "D" S/G PORV, 1SV1AB, were required to achieve and maintain safe shutdown for a postulated fire in FA 5 but were not protected from fire damage in FA 5. The SSD strategy required that S/G PORV 1SV1AB remain closed and not spuriously operate for a fire in FA 5.Description:  During review of the McGuire SSA and procedure AP/0/A/5500/045,Enclosure 11, the team determined that the licensee did not identify cables 1*SV588 and 1*SV591 for the "D" S/G PORV (1SV1AB) as passing through FA 5. The McGuire SSA did not list 1SV1AB cables as being in FA 5 and the cables were not protected from postulated fire damage in FA 5 even though they were associated with equipment required for achieving and maintaining SSD for postulated fires in FA 5. Procedure AP/0/A/5500/045 did not have an action to prevent spurious actuation of 1SV1AB.
8Enclosure2)Failure to Protect 1SV1AB Cabling in FA 5Introduction:  A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for the licensee's failure to protect "D" Steam Generator (S/G) pilot operated relief valve (PORV) cabling located in the Unit 1 Train "A" emergency diesel generator room (FA 5). Cables for the "D" S/G PORV, 1SV1AB, were required to achieve and maintain safe shutdown for a postulated fire in FA 5 but were not protected from fire damage in FA 5. The SSD strategy required that S/G PORV 1SV1AB remain closed and not spuriously operate for a fire in FA 5.Description:  During review of the McGuire SSA and procedure AP/0/A/5500/045,Enclosure 11, the team determined that the licensee did not identify cables 1*SV588 and 1*SV591 for the "D" S/G PORV (1SV1AB) as passing through FA 5. The McGuire SSA did not list 1SV1AB cables as being in FA 5 and the cables were not protected from postulated fire damage in FA 5 even though they were associated with equipment required for achieving and maintaining SSD for postulated fires in FA 5. Procedure AP/0/A/5500/045 did not have an action to prevent spurious actuation of 1SV1AB.
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fire, and it affects the objective of ensuring the reliability and capability of systems that respond to initiating events. The failure to protect cables for S/G PORV 1SV1AB from potential fire damage in FA 5 could allow spurious opening of the valve, but this condition could easily be recognized and the valve could be closed from the MCR using existing procedures. The performance deficiency was judged to represent a SSD finding of low degradation because the noncompliance would not disable the SSD strategy. The noncompliance was therefore determined to be of very low safety significance (Green) using IMC 0609 Appendix F.
fire, and it affects the objective of ensuring the reliability and capability of systems that respond to initiating events. The failure to protect cables for S/G PORV 1SV1AB from potential fire damage in FA 5 could allow spurious opening of the valve, but this condition could easily be recognized and the valve could be closed from the MCR using existing procedures. The performance deficiency was judged to represent a SSD finding of low degradation because the noncompliance would not disable the SSD strategy. The noncompliance was therefore determined to be of very low safety significance (Green) using IMC 0609 Appendix F.


9EnclosureThe finding was judged to represent a low degradation to SSD because the OMA wasfeasible and would not disable the SSD strategy. PIP M-06-05803 was initiated to address corrective actions to procedure AP/0/A/5500/045.Enforcement:  McGuire Unit 1 License Condition 2.C.4 states that the licensee shallimplement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection."  This document states in Appendix C, Section C3,
9EnclosureThe finding was judged to represent a low degradation to SSD because the OMA wasfeasible and would not disable the SSD strategy. PIP M-06-05803 was initiated to address corrective actions to procedure AP/0/A/5500/045.Enforcement:  McGuire Unit 1 License Condition 2.C.4 states that the licensee shallimplement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection."  This document states in Appendix C, Section C3, "Appendix R," that the McGuire FPP is required to comply with Sections III.G, J, L and Oof 10 CFR 50, Appendix R. The McGuire FPP, which includes the SSA (MCS-1465.00-00-0022), identifies FA 5 as a10 CFR 50, Appendix R, Section III.G.2 fire area and indicates that McGuire is requiredto comply with 10 CFR 50, Appendix R, Section III.G. Section III.G.1 of 10 CFR 50Appendix R requires that cables for equipment relied upon to achieve and maintain SSD be free of fire damage. Section III.G.2 of Appendix R lists three options for satisfying therequirements for separation and protection of equipment needed to ensure safe shutdown remains free of fire damage. Contrary to the above, on December 14, 2006, the licensee had failed to ensure that cables 1*SV588 and 1*SV591 associated with S/G PORV 1SV1AB were adequately separated or protected from potential fire damage in FA 5 in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G.2 . Thisissue has existed for several years.Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.
"Appendix R," that the McGuire FPP is required to comply with Sections III.G, J, L and Oof 10 CFR 50, Appendix R. The McGuire FPP, which includes the SSA (MCS-1465.00-00-0022), identifies FA 5 as a10 CFR 50, Appendix R, Section III.G.2 fire area and indicates that McGuire is requiredto comply with 10 CFR 50, Appendix R, Section III.G. Section III.G.1 of 10 CFR 50Appendix R requires that cables for equipment relied upon to achieve and maintain SSD be free of fire damage. Section III.G.2 of Appendix R lists three options for satisfying therequirements for separation and protection of equipment needed to ensure safe shutdown remains free of fire damage. Contrary to the above, on December 14, 2006, the licensee had failed to ensure that cables 1*SV588 and 1*SV591 associated with S/G PORV 1SV1AB were adequately separated or protected from potential fire damage in FA 5 in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G.2 . Thisissue has existed for several years.Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.


The Enforcement Policy and ROP also state that the finding must not be evaluated as Red.
The Enforcement Policy and ROP also state that the finding must not be evaluated as Red.
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====a. Inspection Scope====
====a. Inspection Scope====
For the selected fire areas, the team evaluated the potential for fires, the combustible fireload characteristics, and the potential exposure fire severity. The team reviewed selected licensee maintenance procedures, plant smoking policy, and programs for the control of ignition sources and transient combustibles. These reviews were conducted to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the Fire Protection Program (FPP). The team performed plant walkdowns to verify (1) the material condition of fire protectionsystems and equipment, (2) the storage of permanent and transient combustible materials, (3) the administrative controls for limiting fire hazards, and (4) combustible waste collection, housekeeping practices, and cleanliness conditions were being implemented consistent with the UFSAR, administrative procedures, and other FPP procedures. The specific documents reviewed are listed in the Attachment.
For the selected fire areas, the team evaluated the potential for fires, the combustible fireload characteristics, and the potential exposure fire severity. The team reviewed selected licensee maintenance procedures, plant smoking policy, and programs for the control of ignition sources and transient combustibles. These reviews were conducted to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the Fire Protection Program (FPP). The team performed plant walkdowns to verify
: (1) the material condition of fire protectionsystems and equipment,
: (2) the storage of permanent and transient combustible materials,
: (3) the administrative controls for limiting fire hazards, and
: (4) combustible waste collection, housekeeping practices, and cleanliness conditions were being implemented consistent with the UFSAR, administrative procedures, and other FPP procedures. The specific documents reviewed are listed in the Attachment.


====b. Findings====
====b. Findings====
Line 158: Line 162:
The principal fire ignition sources in these areas were space heaters. The space heaters were de-energized and placed under administrative control.
The principal fire ignition sources in these areas were space heaters. The space heaters were de-energized and placed under administrative control.


The licensee indicated that the space heaters would be re-energized only if the doghouse temperature was less than 50 0 F. Also plant modification, MD200834, had been issuedto add detection in the areas.Enforcement:  McGuire License Condition 2.C.4, for Units 1 and 2, respectively, statesthat the licensee shall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, 15Enclosurerespectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part,that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008,
The licensee indicated that the space heaters would be re-energized only if the doghouse temperature was less than 50 0 F. Also plant modification, MD200834, had been issuedto add detection in the areas.Enforcement:  McGuire License Condition 2.C.4, for Units 1 and 2, respectively, statesthat the licensee shall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, 15Enclosurerespectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part,that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection."  This document states in Appendix C, Section C3, "Appendix R," that the McGuire FPP is required to comply with Sections III.G, J, L and O of 10 CFR 50, Appendix R. Section III.G.2 of Appendix R lists threeoptions for satisfying the requirements for separation and protection of redundant trains within the same FA to ensure that one of the redundant trains remains free of fire damage. Two of the options require that fire detectors and an automatic fire suppression system be installed in the area. The third option requires that a 3-hour rated fire barrier be utilized to protect one safe shutdown train from fire damage. Contrary to the above, on December 14, 2006, fire areas 28 thru 31 (Units 1 and 2 interior and exterior main steam dog houses), did not have fire detection and automatic fire suppression or a 3-hour rated fire barrier installed for these areas containing redundant trains of systems.No enforcement action is required for the above noncompliance because pursuant to theCommission's Enforcement Policy and NRC Manual Chapter 0305, under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion. The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)."  Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance.
"Plant Design Basis Specification for Fire Protection."  This document states in Appendix C, Section C3, "Appendix R," that the McGuire FPP is required to comply with Sections III.G, J, L and O of 10 CFR 50, Appendix R. Section III.G.2 of Appendix R lists threeoptions for satisfying the requirements for separation and protection of redundant trains within the same FA to ensure that one of the redundant trains remains free of fire damage. Two of the options require that fire detectors and an automatic fire suppression system be installed in the area. The third option requires that a 3-hour rated fire barrier be utilized to protect one safe shutdown train from fire damage. Contrary to the above, on December 14, 2006, fire areas 28 thru 31 (Units 1 and 2 interior and exterior main steam dog houses), did not have fire detection and automatic fire suppression or a 3-hour rated fire barrier installed for these areas containing redundant trains of systems.No enforcement action is required for the above noncompliance because pursuant to theCommission's Enforcement Policy and NRC Manual Chapter 0305, under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion. The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)."  Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance.


===.05 Protection From Damage From Fire Suppression Activities===
===.05 Protection From Damage From Fire Suppression Activities===
Line 186: Line 189:


However, the licensee's shutdown strategy requires them to make repairs prior to taking the plant to cold shutdown, so the long term assured source must be available. The TDAFW pump long term assured suction source is from the service water systemthrough a flowpath that includes valves 2CA161C, 2CA162C, and 0RN4AC which are physically located in FA 3. Their associated cables are unprotected from potential fire damage in the area. The inspectors determined that the licensee would not transfer to the SSS until fire damage had occurred, and they have lost control and indication of vital plant equipment from the MCR. Thus multiple failures would have had to occur prior to transferring to the SSS. The procedure for transferring to the SSS (AP/2/A/5500/24)specifies an operator manual action to open normally closed valves, 2CA161C and 2CA162C, from the SSF control panel. In addition, upon transfer to the SSS, service water valve 0RN4AC will get an automatic signal to go open. If any of the valves (i.e.,
However, the licensee's shutdown strategy requires them to make repairs prior to taking the plant to cold shutdown, so the long term assured source must be available. The TDAFW pump long term assured suction source is from the service water systemthrough a flowpath that includes valves 2CA161C, 2CA162C, and 0RN4AC which are physically located in FA 3. Their associated cables are unprotected from potential fire damage in the area. The inspectors determined that the licensee would not transfer to the SSS until fire damage had occurred, and they have lost control and indication of vital plant equipment from the MCR. Thus multiple failures would have had to occur prior to transferring to the SSS. The procedure for transferring to the SSS (AP/2/A/5500/24)specifies an operator manual action to open normally closed valves, 2CA161C and 2CA162C, from the SSF control panel. In addition, upon transfer to the SSS, service water valve 0RN4AC will get an automatic signal to go open. If any of the valves (i.e.,
2CA161C, 2CA162C, or 0RN4AC) fail to open due to fire damage, an operator would be required to enter the fire affected area to manually open the valves locally. The two auxiliary feedwater valves (2CA161C and 2CA162C) are normally closed valves that must be opened to support hot shutdown functions. Failure of either of these valves to open would result in a loss of the assured suction source. The other suction valve (0RN4AC) is normally open and must remain open to support hot shutdown. By design this valve goes closed upon a safety injection signal or loss of offsite power. If fire damage to the control circuit occurred prior to a loss of offsite power, the torque switch could possibly be bypassed and the valve could be mechanically damaged, preventing it from being manually reopened. Based on the above, the team concluded that MOVs 2CA161C, 2CA162C, and 0RN4ACcould be subject to failure or spurious operation due to postulated fire damage to their power and control cables in FA 3. The team noted that fire response procedure AP/0/A/5500/45 did not include steps to protect against mal-operation or failure of these valves prior to transferring operation to the SSS. Thus, the assured suction supply to the TDAFW pump may be made unavailable due to fire damage. The SSA only addressed spurious closure of the normal suction supply through auxiliary feedwater valve 2CA0007A.
2CA161C, 2CA162C, or 0RN4AC) fail to open due to fire damage, an operator would be required to enter the fire affected area to manually open the valves locally.
 
The two auxiliary feedwater valves (2CA161C and 2CA162C) are normally closed valves that must be opened to support hot shutdown functions. Failure of either of these valves to open would result in a loss of the assured suction source. The other suction valve (0RN4AC) is normally open and must remain open to support hot shutdown. By design this valve goes closed upon a safety injection signal or loss of offsite power. If fire damage to the control circuit occurred prior to a loss of offsite power, the torque switch could possibly be bypassed and the valve could be mechanically damaged, preventing it from being manually reopened. Based on the above, the team concluded that MOVs 2CA161C, 2CA162C, and 0RN4ACcould be subject to failure or spurious operation due to postulated fire damage to their power and control cables in FA 3. The team noted that fire response procedure AP/0/A/5500/45 did not include steps to protect against mal-operation or failure of these valves prior to transferring operation to the SSS. Thus, the assured suction supply to the TDAFW pump may be made unavailable due to fire damage. The SSA only addressed spurious closure of the normal suction supply through auxiliary feedwater valve 2CA0007A.


19EnclosureTherefore, AP/0/A/5500/45 did not have actions to prevent loss of the assured suctionflow path due to failure of valves 2CA161C, 2CA162C, and 0RN4AC. This issue was entered into the corrective action program as PIP M-06-5656 and a 1-hour roving fire watch was established in fire areas 3 (Unit 2) and 4 (Unit 1). FA 4 is a common fire area where the equivalent Unit 1 valves 1CA161C and 1CA162C are located. The inspectors identified that the licensee missed a prior opportunity to correct thisproblem in 1994 as part of their review for GL 92-08, "Thermo-Lag 330-1 Fire Barriers."
19EnclosureTherefore, AP/0/A/5500/45 did not have actions to prevent loss of the assured suctionflow path due to failure of valves 2CA161C, 2CA162C, and 0RN4AC. This issue was entered into the corrective action program as PIP M-06-5656 and a 1-hour roving fire watch was established in fire areas 3 (Unit 2) and 4 (Unit 1). FA 4 is a common fire area where the equivalent Unit 1 valves 1CA161C and 1CA162C are located. The inspectors identified that the licensee missed a prior opportunity to correct thisproblem in 1994 as part of their review for GL 92-08, "Thermo-Lag 330-1 Fire Barriers."
Line 193: Line 198:


=====Enforcement:=====
=====Enforcement:=====
McGuire Unit 2 Operating License Condition 2.C.4 states that the licenseeshall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection."  This document states in Appendix C, Section C3,
McGuire Unit 2 Operating License Condition 2.C.4 states that the licenseeshall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection."  This document states in Appendix C, Section C3, "Appendix R," that McGuire Nuclear Station FPP is required to comply with Sections III.G, J, L and O of 10 CFR 50, Appendix R. 10 CFR 50, Appendix R, Sections III.G andIII.L require that the alternative or dedicated shutdown capability be independent ofcables in the area under consideration. The dedicated shutdown capability that was relied on for large fires in FA 3 was the SSS.
"Appendix R," that McGuire Nuclear Station FPP is required to comply with Sections III.G, J, L and O of 10 CFR 50, Appendix R. 10 CFR 50, Appendix R, Sections III.G andIII.L require that the alternative or dedicated shutdown capability be independent ofcables in the area under consideration. The dedicated shutdown capability that was relied on for large fires in FA 3 was the SSS.


20EnclosureContrary to the above requirements, on December 14, 2006, the alternative anddedicated shutdown capability (the SSS) utilized the TDAFW pump for a severe fire in FA 3 and was not independent of cables for valves 2CA161C, 2CA162C, and 0RN4AC which were located in FA 3. This condition has existed for several years. The safety consequence was a reduction in the availability and reliability of the SSS to mitigate a large fire in FA 3. This noncompliance is also applicable to FA 4 where SSS valves 1CA161C and 1CA162C are not independent of cables in FA 4 which is a SSS shutdownarea.
20EnclosureContrary to the above requirements, on December 14, 2006, the alternative anddedicated shutdown capability (the SSS) utilized the TDAFW pump for a severe fire in FA 3 and was not independent of cables for valves 2CA161C, 2CA162C, and 0RN4AC which were located in FA 3. This condition has existed for several years. The safety consequence was a reduction in the availability and reliability of the SSS to mitigate a large fire in FA 3. This noncompliance is also applicable to FA 4 where SSS valves 1CA161C and 1CA162C are not independent of cables in FA 4 which is a SSS shutdownarea.
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Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305, under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.
Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305, under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.


The Enforcement Policy and ROP also state that the finding must not be evaluated as Red.Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)."  Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance. The licensee entered this issue in their corrective action program under PIP M-06-5656 and implemented 1-hour roving fire watches as compensatory measures in the FA..07Circuit Analyses
The Enforcement Policy and ROP also state that the finding must not be evaluated as
 
Red.Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)."  Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance. The licensee entered this issue in their corrective action program under PIP M-06-5656 and implemented 1-hour roving fire watches as compensatory measures in the FA..07Circuit Analyses


====a. Inspection Scope====
====a. Inspection Scope====
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====b. Findings====
====b. Findings====
Fixed Emergency Lighting Units not Installed to Support Operator Manual ActionsIntroduction. A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for failure to install fixed emergency lighting in three areas where OMAs are required to support post-fire SSD procedures.Description:  During a walkdown of post-fire safe shutdown procedures, the inspectorsidentified three areas where fixed emergency lighting had not been installed to support OMAs. The inspectors determined that fixed emergency lighting had not been installed at panel 1EMXB, or along the access route to panel 1EMXB, or on the 733 ft. elevation of the AB near column DD-53 in FA 4, where operators may be required to manually open Unit 1 auxiliary feedwater valves 1CA161C and 1CA162C. The licensee had previously identified all three areas in PIP M-04-4928 and had developed a modification package to install the lights.Analysis: This issue is a performance deficiency because the licensee had not installedfixed emergency lighting units for the support of OMAs while performing post-fire safe shutdown procedures as required by the FPP. This finding is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire) and it affects the objective of ensuring reliability and capability of systems that respond to initiating events. The team determined that this finding was of very low safety significance (Green) because the operators had a high likelihood of completing the task using flashlights.Enforcement:  McGuire Unit 1 Operating License Condition 2.C.4 states that the licenseeshall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, Plant Design Basis Specification for Fire Protection. This document states in Appendix C, Section C3,
Fixed Emergency Lighting Units not Installed to Support Operator Manual ActionsIntroduction. A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for failure to install fixed emergency lighting in three areas where OMAs are required to support post-fire SSD procedures.Description:  During a walkdown of post-fire safe shutdown procedures, the inspectorsidentified three areas where fixed emergency lighting had not been installed to support OMAs. The inspectors determined that fixed emergency lighting had not been installed at panel 1EMXB, or along the access route to panel 1EMXB, or on the 733 ft. elevation of the AB near column DD-53 in FA 4, where operators may be required to manually open Unit 1 auxiliary feedwater valves 1CA161C and 1CA162C. The licensee had previously identified all three areas in PIP M-04-4928 and had developed a modification package to install the lights.Analysis: This issue is a performance deficiency because the licensee had not installedfixed emergency lighting units for the support of OMAs while performing post-fire safe shutdown procedures as required by the FPP. This finding is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire) and it affects the objective of ensuring reliability and capability of systems that respond to initiating events. The team determined that this finding was of very low safety significance (Green) because the operators had a high likelihood of completing the task using flashlights.Enforcement:  McGuire Unit 1 Operating License Condition 2.C.4 states that the licenseeshall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, Plant Design Basis Specification for Fire Protection. This document states in Appendix C, Section C3, "Appendix R," that McGuire FPP is required to comply with Sections III.G, J, L and O of10 CFR 50, Appendix R. 10 CFR 50, Appendix R, Section III.J, "Emergency Lighting,"
"Appendix R," that McGuire FPP is required to comply with Sections III.G, J, L and O of10 CFR 50, Appendix R. 10 CFR 50, Appendix R, Section III.J, "Emergency Lighting,"
states in part, that ELUs with at least an 8-hour battery supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto. Contrary to the above, on December 14, 2006, during a walkdown of post-fire SSDprocedures, the inspectors identified three areas where fixed emergency lighting had not been installed to support OMAs. The licensee had previously identified all 3 areas in PIP M-04-4928 and had developed a modification package to address this issue. This issue has existed for several years. Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.
states in part, that ELUs with at least an 8-hour battery supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto. Contrary to the above, on December 14, 2006, during a walkdown of post-fire SSDprocedures, the inspectors identified three areas where fixed emergency lighting had not been installed to support OMAs. The licensee had previously identified all 3 areas in PIP M-04-4928 and had developed a modification package to address this issue. This issue has existed for several years. Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.


Line 283: Line 288:
: [[contact::S. Walker]], Resident Inspector
: [[contact::S. Walker]], Resident Inspector
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
Opened/ClosedNone.Discussed0500369, 370/2003007-04URI Requirements Relative to the Number of SpuriousOperations That Must Be Postulated (Section 40A5)
Opened/Closed
None.Discussed0500369, 370/2003007-04URI Requirements Relative to the Number of SpuriousOperations That Must Be Postulated (Section 40A5)
2Attachment
2Attachment
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
Line 375: Line 381:
: MCS-1223.SS-00-0001, Design Basis Specification for the SSS, Rev. 18
: MCS-1223.SS-00-0001, Design Basis Specification for the SSS, Rev. 18
: MCS-1465.00-00-0022, Appendix R SSA, Rev. 6
: MCS-1465.00-00-0022, Appendix R SSA, Rev. 6
: MCSF-1560.SS-01, Summary Flow Diagram SSS, Rev. 2ProceduresAP/1/A/5500/07, Enclosure 12, RF Pump A & B Emergency Power Alignment, Rev. 26AP/0/A/5500/45, Plant Fire, Rev. 4
: MCSF-1560.SS-01, Summary Flow Diagram SSS, Rev. 2
: ProceduresAP/1/A/5500/07, Enclosure 12, RF Pump A & B Emergency Power Alignment, Rev. 26AP/0/A/5500/45, Plant Fire, Rev. 4
: AP/0/A/5500/45, Plant Fire, Rev. 5
: AP/0/A/5500/45, Plant Fire, Rev. 5
: AP/1/A/5500/01, Steam Leak, Rev.15
: AP/1/A/5500/01, Steam Leak, Rev.15
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: Minor Design Change No. MD100745, Add 8 Hour Emergency Lights
: Minor Design Change No. MD100745, Add 8 Hour Emergency Lights
: Fire StrategiesStrategy Number 2, Aux-U1-AFWP-Room, Elevation 716, Rev. 1Strategy Number 5, Aux-Diesel Generator 1A Room, Elevation 736, Rev. 0
: Fire StrategiesStrategy Number 2, Aux-U1-AFWP-Room, Elevation 716, Rev. 1Strategy Number 5, Aux-Diesel Generator 1A Room, Elevation 736, Rev. 0
: Strategy Number 19, Aux-U1-Cable Room, Elevation 750, Rev. 0Applicable Codes and Standards NFPA 10 - 1978, Standard for Portable Fire ExtinguishersNFPA 12A - 1977, Standard on Halon 1301 Fire Extinguishing Systems
: Strategy Number 19, Aux-U1-Cable Room, Elevation 750, Rev. 0Applicable Codes and Standards
: NFPA 10 - 1978, Standard for Portable Fire ExtinguishersNFPA 12A - 1977, Standard on Halon 1301 Fire Extinguishing Systems
: NFPA 13 - 1978,
: NFPA 13 - 1978,
: Standard for the Installation of Sprinkler Systems  
: Standard for the Installation of Sprinkler Systems  
Line 538: Line 546:
==LIST OF ACRONYMS==
==LIST OF ACRONYMS==
ABAuxiliary BuildingAFWAuxiliary Feedwater
ABAuxiliary BuildingAFWAuxiliary Feedwater
: [[APA]] [[bnormal Procedure]]
APAbnormal Procedure
: [[CA]] [[]]
CAPCorrective Action Program
: [[PC]] [[orrective Action Program]]
CFRCode of Federal Regulation
: [[CF]] [[]]
CORCode of Record
: [[RC]] [[ode of Federal Regulation]]
ELUEmergency Lighting Unit
: [[CO]] [[]]
FAFire Area
: [[RC]] [[ode of Record]]
FHAFire Hazards Analysis
: [[EL]] [[]]
FPPFire Protection Program
UEmergency Lighting Unit
: [[FAF]] [[ire Area]]
: [[FH]] [[]]
: [[AF]] [[ire Hazards Analysis]]
: [[FP]] [[]]
PFire Protection Program
ft.foot
ft.foot
: [[HVA]] [[]]
HVACHeating, Ventilation, and Air Conditioning
: [[CH]] [[eating, Ventilation, and Air Conditioning]]
IMCInspection Manual Chapter
: [[IM]] [[]]
IPInspection Procedure
CInspection Manual Chapter
IPEEEIndividual Plant Examination for External Events
: [[IPI]] [[nspection Procedure]]
MCCMotor Control Center
: [[IPEE]] [[]]
MCEMechanical and Civil Engineering
: [[EI]] [[ndividual Plant Examination for External Events]]
MCRMain Control Room
: [[MC]] [[]]
MDAFWMotor Driven Auxiliary Feedwater Pump
: [[CM]] [[otor Control Center]]
MOVMotor Operated Valve
: [[MC]] [[]]
: [[NFPAN]] [[ational Fire Protection Association]]
: [[EM]] [[echanical and Civil Engineering]]
: [[NRCU.]] [[S. Nuclear Regulatory Commission]]
: [[MC]] [[]]
OEPOperating Experience Program
: [[RM]] [[ain Control Room]]
OMAOperator Manual Action
: [[MDAF]] [[]]
P&IDsPiping and Instrumentation Drawings
: [[WM]] [[otor Driven Auxiliary Feedwater Pump]]
PIPProblem Investigation Report
: [[MO]] [[]]
PORVPilot Operated Relief Valve
: [[VM]] [[otor Operated Valve]]
ROPReactor Oversight Process
: [[NFP]] [[]]
SCBASelf-Contained Breathing Apparatus
: [[AN]] [[ational Fire Protection Association]]
SDPSignificance Determination Process
: [[NR]] [[]]
SESafety Evaluation
: [[CU.]] [[S. Nuclear Regulatory Commission]]
SERSafety Evaluation Report
: [[OE]] [[]]
: [[PO]] [[perating Experience Program]]
: [[OM]] [[]]
: [[AO]] [[perator Manual Action]]
: [[P&]] [[]]
: [[ID]] [[sPiping and Instrumentation Drawings]]
: [[PI]] [[]]
: [[PP]] [[roblem Investigation Report]]
: [[POR]] [[]]
: [[VP]] [[ilot Operated Relief Valve]]
: [[RO]] [[]]
: [[PR]] [[eactor Oversight Process]]
: [[SCB]] [[]]
: [[AS]] [[elf-Contained Breathing Apparatus]]
: [[SD]] [[]]
PSignificance Determination Process
: [[SES]] [[afety Evaluation]]
: [[SE]] [[]]
RSafety Evaluation Report
S/GSteam Generator
S/GSteam Generator
: [[SS]] [[]]
SSASafe Shutdown Analysis
: [[AS]] [[afe Shutdown Analysis]]
SSDSafe Shutdown
: [[SS]] [[]]
SSFStandby Shutdown Facility
: [[DS]] [[afe Shutdown]]
SSSStandby Shutdown System
: [[SS]] [[]]
UFSARUpdated Final Safety Analysis Report
: [[FS]] [[tandby Shutdown Facility]]
: [[URIU]] [[nresolved Item]]
: [[SS]] [[]]
: [[SS]] [[tandby Shutdown System]]
: [[UFSA]] [[]]
: [[RU]] [[pdated Final Safety Analysis Report]]
: [[UR]] [[]]
: [[IU]] [[nresolved Item]]
}}
}}

Revision as of 02:34, 25 October 2018

IR 05000369-06-008 and 05000370-06-008, on 12/14/06, McGuire Nuclear Station, NRC Triennial Fire Protection and Exercise of Enforcement Discretion
ML070300007
Person / Time
Site: Mcguire, McGuire  Duke Energy icon.png
Issue date: 01/29/2007
From: Payne D C
NRC/RGN-II/DRS/EB2
To: Peterson G R
Duke Energy Corp
References
IR-06-008
Download: ML070300007 (39)


Text

January 29, 2007

Duke Energy CorporationATTN:Mr. G. R. PetersonVice President McGuire Nuclear Station12700 Hagers Ferry Road Huntersville, NC 28078-8985

SUBJECT: MCGUIRE NUCLEAR STATION - NRC TRIENNIAL FIRE PROTECTIONINSPECTION REPORT 05000369/2006008 AND 05000370/2006008 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Peterson:

On December 14, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a triennialfire protection inspection at your McGuire Nuclear Station, Units 1 and 2. The enclosed report documents the inspection findings which were discussed at an exit meeting on that date, with you and members of your staff. The inspection examined activities conducted under your licenses as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The enclosed report documents six noncompliances that were identified during the inspectionfor which the NRC is exercising enforcement discretion. The NRC is not taking any enforcement action for these noncompliances because they meet the criteria of the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, 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 NRC's document system(ADAMS).

DPC2ADAMS is accessible from the NRC Web site at: http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely,/RA/D. Charles Payne, Chief, Engineering Branch 2 Division of Reactor SafetyDocket Nos. 50-369, 50-370License Nos. NPF-9, NPF-17

Enclosure:

Inspection Report 05000369/2006008 and 05000370/2006008w/Attachment; Supplemental Informationcc w/encl: (See page 3)

DPC3cc w/encl:C. J. Thomas Regulatory Compliance Manager (MNS)

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC Electronic Mail DistributionR. L. Gill, Jr., ManagerNuclear Regulatory Issues and Industry Affairs Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC 526 S. Church Street Charlotte, NC 28201-0006Lisa F. VaughnAssociate General Counsel and Managing Attorney Duke Energy Carolinas, LLC 526 South Church Street-EC07H Charlotte, NC 28202Kathyrn B. NolanSenior Counsel Duke Energy Carolinas, LLC 526 South Church Street-EC 07H Charlotte, NC 28202David A. RepkaWinston & Strawn LLP Electronic Mail DistributionBeverly Hall, Chief, RadiationProctection Section N. C. Department of Environmental Health & Natural Resources Electronic Mail DistributionCounty Manager of Mecklenburg County720 East Fourth Street Charlotte, NC 28202

_________________________OFFICERII:DRSRII:DRSRII:DRSRII:DRSRII:DRSRII:DRSRII:DRPSIGNATURE/RA//RA//RA//RA//RA//RA//RA/NAMEG.MacDonaldG.WIsemanR.FannerR.RodriguezC.PayneN.MerriweatherJ.MoormanDATE01/18/0701/19/0701/19/0701/18/0701/29/0701/29/0701/29/07E-MAIL COPY? NO YES YES YES YESNO YES NO REGION IIDocket Nos:50-369, 50-370License Nos:NPF-9, NPF-17 Report Nos:05000369/2006008, 05000370/2006008 Licensee:Duke Energy Corporation Facility:McGuire Nuclear Station, Units 1 and 2 Location:Huntersville, NC 28078 Dates:November 27 - December 1, 2006 (Week 1)December 11- 14, 2006 (Week 2)Inspectors:N. Merriweather, Senior Reactor Inspector (Lead Inspector)R. Fanner, Reactor Inspector G. MacDonald, Senior Reactor Analyst R. Rodriguez, Reactor Inspector G. Wiseman, Senior Reactor InspectorApproved by:D. Charles PayneEngineering Branch 2 Division of Reactor Safety 2Enclosure

SUMMARY OF FINDINGS

IR 05000369/2006-008, 05000370/2006-008; 11/27-12/1/2006 and 12/11-14/2006; McGuireNuclear Station, Units 1 and 2; Fire Protection

.This report covers an announced two-week triennial fire protection inspection by five specialist inspectors from the U. S. Nuclear Regulatory Commission's (NRC's) Region II office located in Atlanta, Georgia. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Violations

None.

4Enclosure

REPORT DETAILS

1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity1R05Fire ProtectionThis report presents the results of a triennial fire protection inspection for a plant intransition to National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition." This inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05TTP, "Fire Protection-NFPA 805 Transition Period (Triennial)."

The objective of the inspection was to review the McGuire Nuclear Station (McGuire) fire protection program (FPP) for selected risk-significant fire areas. The team selected three fire areas for detailed review to examine the licensee's implementation of the FPP.

The team also reviewed issues associated with six other fire areas that are discussed in this report. The original three fire areas chosen for review were selected based on risk insights from the licensee's Individual Plant Examination for External Events (IPEEE),

information contained in FPP documents, results of prior NRC triennial fire protection inspections, and in-plant tours by the inspectors. Section 71111.05-05 of the IP specifies a minimum sample size of three fire areas. Detailed inspection of these three fire areas fulfills the procedure completion criteria. The three areas chosen were:*Fire Area (FA) 2 - Unit 1 Motor Driven Auxiliary Feedwater (MDAFW) Pump Room,Auxiliary Building (AB), Elevation 716 foot (ft.)*FA 5 - Unit 1 Train "A" Diesel Generator Room, AB, Elevation 736 ft.

  • FA 19 - Unit 1 Cable Spreading Room, AB, Elevation 750 ft.

Other fire areas examined for specific issues were:

  • FA 3 - Unit 2 MDAFW Pump Room, AB, Elevation 716 ft.
  • FA 4 - AB Common, Elevation 716 ft.
  • FA 28 - Unit 1 Interior Doghouse, Elevation 750 ft.
  • FA 29 - Unit 2 Interior Doghouse, Elevation 750 ft.
  • FA 30 - Unit 1 Exterior Doghouse, Elevation 750 ft.
  • FA 31 - Unit 2 Exterior Doghouse, Elevation 750 ft.

5EnclosureFor each of the selected fire areas, the inspection team evaluated the licensee's FPPagainst the applicable NRC requirements. The specific documents reviewed by the team are listed in the attachment.

.01 Post-Fire Safe Shutdown From Main Control Room (Normal Shutdown)a.Inspection ScopeMethodologyThe team reviewed the Design Basis Specification for the Appendix R Safe ShutdownAnalysis (SSA) MCS-1465.00-00-0022, revision 6, abnormal operating procedures

(APs), piping and instrumentation drawings (P&IDs), electrical drawings, the Updated Final Safety Analysis Report (UFSAR), and other supporting documents for postulated fires in FA 5. The review was performed to verify that hot and cold shutdown could be achieved and maintained from the main control room (MCR) for postulated fires in FA 5.

This review also included verification that shutdown from the MCR could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the fire hazards analysis (FHA) and SSA. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring instrumentation and support systems functions. The team reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. Operational ImplementationThe team reviewed the adequacy of procedures utilized for post-fire safe shutdown(SSD) and performed a walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits. The team reviewed time critical actions including those for selected components toprevent fire-induced spurious operation for decay heat removal required components.

The team reviewed and walked down applicable sections of fire response procedure AP/0/A/5500/45, "Plant Fire," for FA 5. The team reviewed local operator manual actions to ensure that the actions could beimplemented in accordance with plant procedures in the times necessary to support the SSD method for the applicable FA and to verify that those actions met the criteria in 2 of NRC IP 71111.05TTP. The team reviewed Problem Investigation Process (PIP) corrective action document 05-04859, Appendix R Manual Actions, to verify that the licensee had identified operator manual actions for post-fire SSD in III.G.2areas and had plans in place to keep PIP 05-04859 open to assess and track resolution of the manual action issue as part of the plant-wide risk evaluation for transition to NFPA 805.

6Enclosureb.Findings1)Failure to Protect Cables Associated With Motor Operated Valve 1CA-42B in FA 5Introduction: A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for the licensee's failure to protect or separate cabling associated with the "B" train of MDAFW routed through the Unit 1 "A" diesel generator room (FA 5). The "B" train of MDAFW was required to remain operational to achieve and maintain safe shutdown for a postulated fire in FA 5.Description: During review of procedure AP/0/A/5500/45, "Plant Fire," Enclosure 11, theteam identified that the licensee utilized a local operator manual action (OMA) to de-energize motor operated valve (MOV) 1CA-42B to prevent spurious closure of the MOV due to potential fire damage during a postulated fire in FA 5. MOV 1CA-42B, the 1B MDAFW pump discharge valve to the 1D steam generator (S/G), is normally open and is required to remain open to establish the auxiliary feedwater (AFW) flowpath to the 1D S/G from the 1B MDAFW pump. The McGuire SSA requires the B train of AFW for SSD for a fire in FA 5. The 1D S/G is one of two S/Gs which receive AFW flow from the 1B MDAFW pump. Two S/Gs are required by the SSA for successful SSD. Cables for MOV 1CA-42B were located in FA 5 while the MOV itself was located in the Unit 1 exterior doghouse FA 30. The licensee failed to protect cable 1*CA548 from potential fire damage in FA 5. In lieu of protecting required cables from fire damage which could cause the MOV to spuriously close and defeat the SSD strategy, the licensee instead de-energized the valve using a local OMA. The local OMA was to de-energize MOV 1CA-42B, after verifying correct open position, by locally opening breaker 3E at motor control center (MCC) 1EMXB in FA 14. The team performed a walk through of this local OMA and determined the action to be feasible and reliable per the criteria in Enclosure 2 to NRC Inspection Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 Transition Period (Triennial). The cables and the local OMA to prevent spurious operation were described in the licensee's SSA.Analysis: Failure to protect required SSD equipment from potential fire damage is aperformance deficiency and is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external events, i.e.

fire, and it affects the objective of ensuring the reliability and capability of systems that respond to initiating events. The finding was determined to be of very low safety significance (Green) using the significance determination process (SDP) in NRC Inspection Manual Chapter (IMC) 0609 Appendix F. The local OMA was determined to be feasible and reliable because it met the criteria of IP 71111.05TTP Enclosure 2. As such, the local OMA was determined to be a compensatory measure for the lack of cable protection for required SSD component 1CA-42B. PIP 05-04859 tracked the resolution of III.G.2 OMAs.Enforcement: McGuire Unit 1 License Condition 2.C.4 states that the licensee shallimplement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the Safety Evaluation Report (SER) dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the safety evaluation (SE) dated May 1989. McGuire UFSAR Section 7Enclosure9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection." This document states in Appendix C, Section C3, "Appendix R," that the McGuire FPP is required to comply with Title 10 of the Code of Federal Regulations (CFR) Part 50 (hereafter referred to as 10 CFR 50), Appendix R, Sections III.G, J, L and O. It also states thatprocedure AP/0/A/5500/045 is derived from the Fire Area Failure Analysis and Compliance Strategy in the Appendix R design basis document, MCS-1465.00-00-0022.

The McGuire FPP, which includes the SSA (MCS-1465.00-00-0022) identifies FA 5 as a 10 CFR 50, Appendix R, Section III.G.2 area and further indicates that McGuire iscommitted to 10 CFR 50, Appendix R, Section III.G.Section III.G.1 of 10 CFR 50Appendix R requires that cables for equipment relied upon to achieve and maintain SSD be free of fire damage.Section III.G.2 of Appendix R lists three options for satisfyingthe requirements for separation and protection of equipment needed to ensure safe shutdown remains free of fire damage. The requirements of this section do not allow using manual actions in lieu of protection and separation. Contrary to the above, on December 14, 2006, the licensee utilized a non-approved local OMA as a compensatory measure in lieu of protecting cable 1*CA548 in FA 5 as required by 10 CFR 50, Appendix R, Section III.G.2. This issue has existed for many years.Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and Reactor Oversight Program (ROP) discretion. The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. On February 28, 2005, the licensee submitted a letter to the NRC stating its intent to transition to 10 CFR 50.48(c). In a subsequent letter to the NRC dated April 18, 2006, the licensee provided the NRC with the planned schedule for the McGuire Station to transition to NFPA 805. In a followup letter from the NRC to the licensee dated September 26, 2006, the NRC acknowledged that a three year period of discretion will begin on April 18, 2006, and that the period of discretion will continue beyond the three year expiration date of April 18, 2009, while NRC staff is reviewing the license amendment request.Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance.The licensee entered this issue in their corrective action program under PIP 05-4859.

8Enclosure2)Failure to Protect 1SV1AB Cabling in FA 5Introduction: A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for the licensee's failure to protect "D" Steam Generator (S/G) pilot operated relief valve (PORV) cabling located in the Unit 1 Train "A" emergency diesel generator room (FA 5). Cables for the "D" S/G PORV, 1SV1AB, were required to achieve and maintain safe shutdown for a postulated fire in FA 5 but were not protected from fire damage in FA 5. The SSD strategy required that S/G PORV 1SV1AB remain closed and not spuriously operate for a fire in FA 5.Description: During review of the McGuire SSA and procedure AP/0/A/5500/045,Enclosure 11, the team determined that the licensee did not identify cables 1*SV588 and 1*SV591 for the "D" S/G PORV (1SV1AB) as passing through FA 5. The McGuire SSA did not list 1SV1AB cables as being in FA 5 and the cables were not protected from postulated fire damage in FA 5 even though they were associated with equipment required for achieving and maintaining SSD for postulated fires in FA 5. Procedure AP/0/A/5500/045 did not have an action to prevent spurious actuation of 1SV1AB.

Opening of 1SV1AB due to potential fire damage to cables 1*SV588 and 1*SV591 located in FA 5 could affect the "D" S/G which was one of two S/Gs which receive AFW flow from the "B" MDAFW train. Two S/Gs are required by the SSA for successful SSD.

The SSD strategy required that 1SV1AB remain closed and not spuriously operate.

Procedure AP/0/A/5500/045, Enclosure 11, contained an action to fail 1SV19AB to the closed position but did not address 1SV1AB. The team reviewed procedure AP/1/A/5500/01, "Steam Leak," revision 15, and determined that the procedure contained guidance for the operators to recognize a spuriously opened S/G PORV and actions to close the valve. The guidance in AP/1/A/5500/01 was similar to the guidance in AP/0/A/5500/045 Enclosure 11 and directed the closure of the S/G PORVs by failing the air to the pneumatic controls. Additionally, further guidance in AP/1/A/5500/01 directed operator action to close the S/G PORV block valve and to close the S/G PORV locally manually, if necessary. The team concluded that while the SSA analysis failed to include fire affected cables to 1SV1AB located in FA 5, the existing procedural guidance would enable the operators to deal with the potential fire-induced spurious valve opening.Analysis: Failure to protect required SSD equipment from potential fire damage is aperformance deficiency and is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external events, i.e.

fire, and it affects the objective of ensuring the reliability and capability of systems that respond to initiating events. The failure to protect cables for S/G PORV 1SV1AB from potential fire damage in FA 5 could allow spurious opening of the valve, but this condition could easily be recognized and the valve could be closed from the MCR using existing procedures. The performance deficiency was judged to represent a SSD finding of low degradation because the noncompliance would not disable the SSD strategy. The noncompliance was therefore determined to be of very low safety significance (Green) using IMC 0609 Appendix F.

9EnclosureThe finding was judged to represent a low degradation to SSD because the OMA wasfeasible and would not disable the SSD strategy. PIP M-06-05803 was initiated to address corrective actions to procedure AP/0/A/5500/045.Enforcement: McGuire Unit 1 License Condition 2.C.4 states that the licensee shallimplement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection." This document states in Appendix C, Section C3, "Appendix R," that the McGuire FPP is required to comply with Sections III.G, J, L and Oof 10 CFR 50, Appendix R. The McGuire FPP, which includes the SSA (MCS-1465.00-00-0022), identifies FA 5 as a10 CFR 50, Appendix R,Section III.G.2 fire area and indicates that McGuire is requiredto comply with 10 CFR 50, Appendix R, Section III.G.Section III.G.1 of 10 CFR 50Appendix R requires that cables for equipment relied upon to achieve and maintain SSD be free of fire damage.Section III.G.2 of Appendix R lists three options for satisfying therequirements for separation and protection of equipment needed to ensure safe shutdown remains free of fire damage. Contrary to the above, on December 14, 2006, the licensee had failed to ensure that cables 1*SV588 and 1*SV591 associated with S/G PORV 1SV1AB were adequately separated or protected from potential fire damage in FA 5 in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G.2 . Thisissue has existed for several years.Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.

The Enforcement Policy and ROP also state that the finding must not be evaluated as Red.

Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance. The licensee entered this issue in their corrective action program under PIP M-06-05803.

10Enclosure.02Protection of Safe Shutdown Capabilities

a. Inspection Scope

For the selected fire areas, the team evaluated the potential for fires, the combustible fireload characteristics, and the potential exposure fire severity. The team reviewed selected licensee maintenance procedures, plant smoking policy, and programs for the control of ignition sources and transient combustibles. These reviews were conducted to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the Fire Protection Program (FPP). The team performed plant walkdowns to verify

(1) the material condition of fire protectionsystems and equipment,
(2) the storage of permanent and transient combustible materials,
(3) the administrative controls for limiting fire hazards, and
(4) combustible waste collection, housekeeping practices, and cleanliness conditions were being implemented consistent with the UFSAR, administrative procedures, and other FPP procedures. The specific documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified..03 Passive Fire Protection

a. Inspection Scope

The team inspected the material condition of accessible passive fire barriers surroundingand within fire areas 2, 5, and 19. Barriers in use included walls, ceilings, floors, structural steel fireproofing, mechanical and electrical penetration seals, fire doors, and fire dampers. Construction details and fire endurance test data which established the ratings of fire barriers were reviewed by the team. Engineering evaluations and relevant exemptions described in NRC SERs related to firebarriers were reviewed. Where applicable, the team examined installed barriers to compare the configuration of the barrier to the rated configuration to verify that the as-built configurations met design requirements, license commitments, standard industry practices and were either properly evaluated or qualified by appropriate fire endurance tests. In addition, a sample of completed surveillance and maintenance procedures for selected fire doors, fire dampers, and penetration seals in the selected fire areas were reviewed to ensure that these passive fire barrier features were properly inspected and maintained. The fire protection features included in the review are listed in the

.

b. Findings

No findings of significance were identified.

11Enclosure.04Active Fire Protection

a. Inspection Scope

The team reviewed flow diagrams, cable routing information, system operatinginstructions, operational valve lineup procedures, and vendor documentation associated with the fire pumps and auxiliary building fire protection isolation deluge valves.

Using operating and valve alignment procedures, team members toured selected fire pumps and portions of the fire main piping system to evaluate material condition, consistency of as-built configurations with engineering drawings, and to verify correct system valve lineups. The common fire protection water delivery and supply components were reviewed to assess if they could be damaged or inhibited by fire-induced failures of electrical power supplies or control circuits. In addition, the team reviewed periodic surveillance and operability flow test data for the electric fire pumps, fire main loop and auxiliary building fire protection isolation deluge valves to assess whether the test program was sufficient to validate proper operation of the fire protection water supply system in accordance with its design requirements. The team reviewed the fire detection system protecting the fire areas selected for reviewto assess the adequacy of the design and installation. This was accomplished by reviewing design drawings, ceiling beam location drawings, and code of record (COR) for detector location requirements (i.e., NFPA 72E, 1974 Edition). The team reviewed the McGuire Fire Protection Code Deviation Calculation to determine if there were any outstanding code detector deviations for the selected areas. The team walked down the fire detection and alarm systems in Fire Areas 2, 5, and 19 to evaluate the appropriateness of detection methods for the category of fire hazards in the selected fire areas. The team also evaluated the installed detector locations relative to the NFPA 72E COR location requirements. Additionally, the team reviewed the surveillance test procedures and alarm annunciator response procedures for the detection and alarm systems to determine compliance with UFSAR Section 16.9. Through in-plant observation of systems, design document review and reference to theapplicable NFPA codes and standards, the team evaluated the material condition and operational lineup of fire suppression systems protecting the selected fire areas. The Halon 1301 suppression system in the train A diesel generator room (FA 5) was also reviewed. Fire hose and standpipe systems were evaluated from source to discharge device including hydraulic calculations performed by the licensee to demonstrate adequate flow, pressure and water distribution. During plant tours, the team observed placement of the fire hoses and extinguishers to verify they were not blocked and were consistent with the pre-fire plans and FPP documents. The team reviewed the fire brigade staging and dress-out areas to assess theoperational readiness of fire fighting and smoke control equipment. The fire brigade personal protective equipment, self-contained breathing apparatuses (SCBAs) and SCBA cylinder refill capability were reviewed for adequacy and functionality.

12EnclosureThe team also reviewed operator and fire brigade staffing, fire brigade response reports,offsite fire department communications and staging procedures, fire fighting pre-plan strategies, fire brigade qualification training, and the fire brigade drill program procedures. Five fire brigade response-to-drill scenarios and associated brigade drill evaluations/critiques that transpired over the last 12 months were reviewed. The team reviewed the fire pre-plan strategies for fire areas 2, 5, and 19, as well as the fire response procedures to verify that pertinent information was provided to fire brigade members to identify potential effects to plant safety and personnel safety and to facilitate suppression of an exposure fire that could impact SSD capability. The team walked down the selected fire areas to compare the associated fire pre-planstrategy drawings with as-built plant conditions and fire response procedures. This was done to verify that fire fighting pre-plan strategies and drawings were consistent with the fire protection features and potential fire conditions described in the FHA. The team also evaluated whether the fire response procedures and fire pre-plan strategies for the selected fire areas could be implemented as intended. Additionally, the team assessed the adequacy of the off-site fire fighting assistance including entry into the plant area, communications, emergency dosimetry, and fire equipment usage. The documents included in the review are listed in the Attachment.

b. Findings

1)Pertinent Fire Brigade Information and Guidance to Facilitate Suppression of a Fire Not Identified in Fire Fighting StrategiesIntroduction: A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for the licensee's failure to include pertinent fire brigade information and guidance in fire fighting pre-plan strategies for postulated fires in fire areas 2, 5, and 19 as required by the licensing basis.

Description:

The team identified on November 28, 2006, that the McGuire fire pre-planstrategies for fire areas 2, 5, and 19 did not provide pertinent information and guidance on plant areas to assist the fire brigade to be better prepared for fire fighting within those areas. The fire strategies were judged to be deficient because they did not identify the most favorable direction from which to fight a fire in the area, as well as providing appropriate information and guidance for accessing the nearest safe location of fire extinguishants best suited for controlling a fire. Information on the most favorable direction from which to fight a fire and on accessing fire fighting equipment are subjects required to be covered in the pre-fire strategy plans as described in the licensee's fire protection program (MCS-1465.00-0008, Design Basis Specification for Fire Protection),

Appendix B, Section 5.d. These licensing basis' requirements are not currently being met by the licensee.

Analysis:

The fire fighting strategy plans are the fire brigade equivalent ofabnormal/emergency procedures used by licensed operators, and similarly the strategy actions taken based on these strategy plans are time sensitive. The pre-fire strategies identify to the fire brigade the most favorable direction from which to fight a fire in the area and information on safely accessing fire fighting equipment so that the brigade leader can plan (in a timely manner) a strategy for how to approach and extinguish a fire.

13EnclosureIncomplete fire fighting strategies could increase the time response of the brigade inputting out the fire, resulting in an increase in fire damage. Consequently, the lack of pertinent information covered in the pre-fire strategy plans was considered a degradation for manual fire fighting effectiveness. This performance deficiency affects the Mitigating Systems cornerstone objectives of protection from external factors including fire and procedure quality. Consequently, the finding is greater than minor. Under the SDP analysis the performance deficiency was determined to be of very low safety significance.

This was because the performance deficiency only minimally diminished manual suppression effectiveness without affecting the fire ignition frequency within the areas or the previously established safe shutdown strategy for a fully developed active fire within the applicable areas. The licensee initiated PIP M-06-05645 to address this issue. Also, the licensee provided a copy of PIP M-06-0576, in which the they had documented other deficiencies in the pre-fire plan layout drawings and strategies discovered following corrective actions to address several examples of NRC identified fire strategy problems documented in NRC inspection reports (IRs) 2004-03, -04,and -05. The team noted that the licensee was currently implementing an ongoing Fire Strategy Revision, Fire Protection Program Design Basis Specification, Appendix B.5 Section Review, project to revise their pre-fire plan strategies by March 2007 to cover these subjects.

Enforcement:

McGuire Unit 1 License Condition 2.C.4 states that the licensee shallimplement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection." The FPP states, in Appendix B.5, "Fire Fighting Procedures," that fire fighting procedures would identify the strategies established for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment. The strategies should cover specific subjects including the most favorable direction from which to fight a fire in the area, as well as the location of the nearest safe location of fire extinguishants best suited for controlling a fire.Contrary to the above, prior to November 28, 2006, fire fighting pre-plan strategynumbers 2, 5, and 19 neither identified the most favorable direction from which to fight a fire in the area nor provided appropriate information and guidance for accessing the nearest safe location of fire extinguishants best suited for controlling a fire.Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.

The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire 14EnclosureProtection Issues (10 CFR 50.48)." Specifically, this issue would have been expected tobe identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance. 2)Failure to have Fire Detectors and Automatic Suppression Systems Installed in Fire Areas 28, 29, 30 and 31Introduction: A noncompliance with McGuire Operating License Condition 2.C.4, for Units1 and 2, was identified for the licensee's failure to have fire detectors and an automatic suppression system installed in fire areas 28 through 31 (Units 1 and 2 interior and exterior main steam dog houses). The violation meets the criteria of NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)" for enforcement discretion.Description: On October 8, 2004, the licensee identified during an internal fire protectionaudit that fire detection devices and fire suppression are not installed in any of the interior or exterior main steam dog houses. A fire in these areas may not directly be detected and smoke from the areas may not be easily seen. Additionally, the lack of detection may increase the notification and response of the fire brigade in putting out the fire, resulting in an increase in fire damage. Consequently, the lack of fire detection devices and fire suppression was considered a degradation of fire fighting effectiveness.

The licensee issued PIP M-04-04930 to track the resolution of this 10 CFR 50, Appendix R, III.G.2 noncompliance and 1-hour roving compensatory fire watch patrols had beeninitiated for the plant areas.Analysis: The failure to install detection and suppression in an Appendix R, III.G.2 firearea is a performance deficiency and is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external events, i.e. fire, and it affects the objective of ensuring the reliability and capability of systems that respond to initiating events. The inspectors determined the finding was of very low safety significance (Green) because the issue screened out in phase 2 of the IMC 0609, Appendix F, SDP evaluation due to low ignition frequency in the areas and minimal impact to SSD mitigation equipment. Also, the absence of detection and suppression in the affected areas would not result in a control room evacuation and thus would not require the use of the more difficult alternative procedure for shutdown from outside the control room.

The principal fire ignition sources in these areas were space heaters. The space heaters were de-energized and placed under administrative control.

The licensee indicated that the space heaters would be re-energized only if the doghouse temperature was less than 50 0 F. Also plant modification, MD200834, had been issuedto add detection in the areas.Enforcement: McGuire License Condition 2.C.4, for Units 1 and 2, respectively, statesthat the licensee shall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, 15Enclosurerespectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part,that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection." This document states in Appendix C, Section C3, "Appendix R," that the McGuire FPP is required to comply with Sections III.G, J, L and O of 10 CFR 50, Appendix R.Section III.G.2 of Appendix R lists threeoptions for satisfying the requirements for separation and protection of redundant trains within the same FA to ensure that one of the redundant trains remains free of fire damage. Two of the options require that fire detectors and an automatic fire suppression system be installed in the area. The third option requires that a 3-hour rated fire barrier be utilized to protect one safe shutdown train from fire damage. Contrary to the above, on December 14, 2006, fire areas 28 thru 31 (Units 1 and 2 interior and exterior main steam dog houses), did not have fire detection and automatic fire suppression or a 3-hour rated fire barrier installed for these areas containing redundant trains of systems.No enforcement action is required for the above noncompliance because pursuant to theCommission's Enforcement Policy and NRC Manual Chapter 0305, under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion. The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance.

.05 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team performed document reviews and in-plant walkdowns to verify that redundanttrains of systems required for hot shutdown were not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team:*Reviewed fire damper location and vendor detail drawings, and heating, ventilation, andair conditioning (HVAC) system drawings to verify that a fire in one of the selected fire areas would not directly, through production of smoke, heat or hot gases, inhibit access to alternate shutdown equipment or performance of alternate safe shutdown operator actions by smoke migration through duct work from the area of a fire to adjacent plant areas.

16Enclosure*Reviewed the physical configuration of electrical raceways and safe shutdowncomponents in the selected fire areas to verify water from a pipe rupture, actuation of the automatic suppression system, or manual fire suppression activities would not directly cause damage to all redundant trains within the FA or an adjacent plant area that could inhibit SSD (e.g., fire suppression caused flooding of other than the locally affected train).*Reviewed floor drain locations and building drain system drawings to verify thatadequate drainage is provided in areas protected by water suppression systems.The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified..06Post-Fire Safe Shutdown From Outside the Main Control Room (Alternative Shutdown)

a. Inspection Scope

MethodologyThe team reviewed the licensee's FPP described in UFSAR Section 9.5.1, the SSA, APs,P&IDs, electrical drawings, and other supporting documents for postulated fires in fire areas 2 and 19. The reviews focused on ensuring that the required functions for post-fire SSD and the corresponding equipment necessary to perform those functions were included in the procedures. The review included assessing whether hot and cold shutdown from outside the MCR could be implemented, and that transfer of control from the MCR to the standby shutdown facility (SSF) could be accomplished. This review also included verification that shutdown from outside the MCR could be performed both with and without the availability of offsite power. Plant walkdowns were performed to verify that the plant configuration was consistent withthat described in the SSA. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring instrumentation and support systems functions. The team reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. The team also reviewed a Unit 2 concern involving the licensee's fire responseprocedures for postulated fires in FA 3 where valves associated with the assured suction source to the turbine driven auxiliary feedwater (TDAFW) pump could spurious operate or be damaged by a fire in the area.

17EnclosureOperational ImplementationThe team reviewed the training lesson plans for licensed and non-licensed operators toverify that the training reinforced the shutdown methodology in the SSA and APs for the selected FAs. The team also reviewed shift turnover logs and shift manning to verify that personnel required for SSD using the alternative shutdown systems and procedures were available onsite, exclusive of those assigned as fire brigade members. The team reviewed the adequacy of procedures utilized for post-fire SSD and performeda walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits. Time critical actions reviewed included electrical power distribution alignment,establishing control at the SSF, establishing reactor coolant makeup, and establishingdecay heat removal. The team reviewed and walked down applicable sections of the following fire response abnormal operating procedures:*AP/0/A/5500/45, Plant Fire, Rev.5*AP/1/A/5500/24, Loss of Plant Control Due to Fire or Sabotage, Rev.24

  • OP/0/A/6100/21, Shutdown Outside the Control Room Following a Fire, Rev. 18The team also reviewed the periodic test procedures and test records of the alternativeshutdown transfer capability and instrumentation and control functions to ensure the tests were adequate to verify the functionality of the alternative shutdown capability. Electrical schematics were reviewed to verify that circuits for SSD equipment, which could be damaged due to fire, were isolated by disconnect switches and by swapping power supplies for selected MCC. In addition, the team reviewed wiring diagrams for instrumentation located on the SSF to verify that necessary process monitoring was available as required by 10 CFR 50, Appendix R, Section III.L.

b. Findings

Potential for Loss of the TDAFW Pump Assured Suction Supply Flow Path (FA3)Introduction: A noncompliance with McGuire Unit 2 Operating License Condition 2.C.4was identified for the licensee's failure to ensure that the cables and equipment needed for the alternative and dedicated standby shutdown system (SSS) were independent of cables in FA 3. Specifically, the assured suction supply for the Unit 2 TDAFW pump could be lost as a result of fire damage in FA 3 because it was not independent of cables, systems, and components in FA 3.

Description:

The MDAFW pump room (FA 3) is an alternative shutdown area utilizing theSSS with secondary heat removal via the TDAFW pump. The normal suction flow path for the turbine driven auxiliary feedwater pump is from the 300,000 gallon AFW system condensate storage tank through MOV 2CA0007A.

18EnclosureThe valve is open during normal plant operation. However, this valve is subject tospurious operation from potential fire damage to the control cables in certain fire areas, including FA 3. Spurious closure of this valve from fire damage could cause damage to the pump if automatic transfer to the alternate suction sources does not initiate within sufficient time. The team noted that the SSA does not take credit for operation of the automatic transfer function to the standby assured suction source on low pump suction pressure due to the fact that the circuits associated with the pressure switches and valves 2CA161C and 2CA162C have not been analyzed for fire damage. Instead, the licensee has implemented compensatory OMAs in fire response procedureAP/0/A/5500/45 to verify or open valve 2CA0007A and trip open the power supply breaker within the first 10 minutes of a fire. This action is necessary to assure that the normal water supply will remain available for the TDAFW pump. This water source could supply the TDAFW pump and maintain hot standby conditions for several hours.

However, the licensee's shutdown strategy requires them to make repairs prior to taking the plant to cold shutdown, so the long term assured source must be available. The TDAFW pump long term assured suction source is from the service water systemthrough a flowpath that includes valves 2CA161C, 2CA162C, and 0RN4AC which are physically located in FA 3. Their associated cables are unprotected from potential fire damage in the area. The inspectors determined that the licensee would not transfer to the SSS until fire damage had occurred, and they have lost control and indication of vital plant equipment from the MCR. Thus multiple failures would have had to occur prior to transferring to the SSS. The procedure for transferring to the SSS (AP/2/A/5500/24)specifies an operator manual action to open normally closed valves, 2CA161C and 2CA162C, from the SSF control panel. In addition, upon transfer to the SSS, service water valve 0RN4AC will get an automatic signal to go open. If any of the valves (i.e.,

2CA161C, 2CA162C, or 0RN4AC) fail to open due to fire damage, an operator would be required to enter the fire affected area to manually open the valves locally.

The two auxiliary feedwater valves (2CA161C and 2CA162C) are normally closed valves that must be opened to support hot shutdown functions. Failure of either of these valves to open would result in a loss of the assured suction source. The other suction valve (0RN4AC) is normally open and must remain open to support hot shutdown. By design this valve goes closed upon a safety injection signal or loss of offsite power. If fire damage to the control circuit occurred prior to a loss of offsite power, the torque switch could possibly be bypassed and the valve could be mechanically damaged, preventing it from being manually reopened. Based on the above, the team concluded that MOVs 2CA161C, 2CA162C, and 0RN4ACcould be subject to failure or spurious operation due to postulated fire damage to their power and control cables in FA 3. The team noted that fire response procedure AP/0/A/5500/45 did not include steps to protect against mal-operation or failure of these valves prior to transferring operation to the SSS. Thus, the assured suction supply to the TDAFW pump may be made unavailable due to fire damage. The SSA only addressed spurious closure of the normal suction supply through auxiliary feedwater valve 2CA0007A.

19EnclosureTherefore, AP/0/A/5500/45 did not have actions to prevent loss of the assured suctionflow path due to failure of valves 2CA161C, 2CA162C, and 0RN4AC. This issue was entered into the corrective action program as PIP M-06-5656 and a 1-hour roving fire watch was established in fire areas 3 (Unit 2) and 4 (Unit 1). FA 4 is a common fire area where the equivalent Unit 1 valves 1CA161C and 1CA162C are located. The inspectors identified that the licensee missed a prior opportunity to correct thisproblem in 1994 as part of their review for GL 92-08, "Thermo-Lag 330-1 Fire Barriers."

In a 1994 letter to the NRC, the licensee committed to open and de-energize valves CA161C and CA162C within the first 10 minutes of a fire in FA 3 as part of the corrective actions to alleviate the reliance on Thermo-lag. However, the licensee failed to implement this commitment in Procedure AP/0/A/5500/45. The failure to implement this NRC commitment has been entered into the licensee's corrective action program as PIP M-06-05730.Pressure switches 1/2CAPS5044 and 1/2CAPS5380 will initiate swapover to the assuredsuction source on low TDAFW pump suction pressure by automatically opening valves 1/2CA161C and 1/2CA162C. The team had a concern that the control cables associatedwith these pressure switches 1/2CAPS5044 and 1/2CAPS5380 were not adequately analyzed for potential fire damage in FA 3. The inspectors postulated that a severe fire in FA 3 could cause multiple shorts to ground, result in a loss of control power, and make the valves inoperable from the SSF control panel. This issue was entered into the corrective action program under PIP M-06-5900.Analysis: The lack of independence of the SSS from cables in FA 3 is a performancedeficiency because it is contrary to the requirements of McGuire Unit 2 Operating License Condition 2.C.4. This performance deficiency is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external events, i.e. fire, and it affects the objective of ensuring the reliability and capability of systems that respond to initiating events. The team determined that this issue was of very low safety significance (Green) after reviewing the results of the licensee's risk analysis which had assumed no credit for flow through suction valves 2CA161C ,2CA162C and 0RN4AC for a postulated fire in FA 3. The inspectors reviewed the licensee's analysis and found it to be acceptable.

Enforcement:

McGuire Unit 2 Operating License Condition 2.C.4 states that the licenseeshall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, "Plant Design Basis Specification for Fire Protection." This document states in Appendix C, Section C3, "Appendix R," that McGuire Nuclear Station FPP is required to comply with Sections III.G, J, L and O of 10 CFR 50, Appendix R. 10 CFR 50, Appendix R, Sections III.G andIII.L require that the alternative or dedicated shutdown capability be independent ofcables in the area under consideration. The dedicated shutdown capability that was relied on for large fires in FA 3 was the SSS.

20EnclosureContrary to the above requirements, on December 14, 2006, the alternative anddedicated shutdown capability (the SSS) utilized the TDAFW pump for a severe fire in FA 3 and was not independent of cables for valves 2CA161C, 2CA162C, and 0RN4AC which were located in FA 3. This condition has existed for several years. The safety consequence was a reduction in the availability and reliability of the SSS to mitigate a large fire in FA 3. This noncompliance is also applicable to FA 4 where SSS valves 1CA161C and 1CA162C are not independent of cables in FA 4 which is a SSS shutdownarea.

Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305, under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.

The Enforcement Policy and ROP also state that the finding must not be evaluated as

Red.Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 andchange their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." Specifically, this issue would have been expected to be identified and addressed during the licensee's transition to NFPA 805, was entered into the licensee's corrective action program and will be corrected, was not likely to have been previously identified by routine licensee efforts, was not willful, and was not associated with a finding of high safety significance. The licensee entered this issue in their corrective action program under PIP M-06-5656 and implemented 1-hour roving fire watches as compensatory measures in the FA..07Circuit Analyses

a. Inspection Scope

This segment is suspended for plants in transition because a more detail review of cablerouting and circuit analysis will be conducted as part of the fire protection program transition to NFPA 805. However, a review of the licensee's preliminary cable routing information was used by the team to assess the adequacy of the licensee's fire response procedures in the selected fire areas. The routing information was based upon a list of safe shutdown components submitted by the inspectors. Results of these reviews are documented in IR05.01 and IR05.06 sections of this report.

b. Findings

No findings of significance were identified.

21Enclosure.08Communications

a. Inspection Scope

The team reviewed plant communication capabilities to evaluate the availability of thecommunication systems to support plant personnel in the performance of local operator manual actions to achieve and maintain SSD conditions. During this review, the team considered the effects of ambient noise levels, clarity of reception, and reliability. The team also reviewed the communication systems available at different locations in the plant. Both fixed and portable communication systems were reviewed for the impact of fire damage in the selected fire areas. A review was performed to verify the availability of the portable radios for use during the SSD procedures. In addition, the team reviewed the radio battery usage ratings for the radios stored and maintained on charging stations for operator use while performing the SSD procedure. The team reviewed preventative maintenance and surveillance test records to verify that the communication equipment was being properly maintained. The team also requested that the licensee exercise the primary method of communication credited to perform the various actions identified in the procedure review.The team reviewed the plant communication systems that would be relied upon tosupport fire event notification and fire brigade fire fighting activities to verify their availability. The team reviewed selected fire brigade drill evaluation/critique reports to assess proper operation and effectiveness of the fire brigade command post portable radio communications during fire drills and to identify any history of operational or performance problems with radio communications during fire drills. In addition, the team reviewed the radio battery usage ratings for the fire brigade radios stored and maintained on charging stations to verify their availability.

b. Findings

No findings of significance were identified..09Emergency Lighting

a. Inspection Scope

The team observed the placement and coverage area of fixed eight-hour battery packemergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. The team observed whether emergency exit lighting was provided for personnel evacuation pathways to the outside exits as identified in the NFPA 101, "Life Safety Code," and the Occupational Safety and Health Administration Part 1910, "Occupational Safety and Health Standards." This review also included examination of whether backup emergency lighting units (ELUs)were provided for the primary and secondary fire emergency equipment storage locker locations and dress-out areas in support of fire brigade operations should power fail during a fire emergency.

b. Findings

Fixed Emergency Lighting Units not Installed to Support Operator Manual ActionsIntroduction. A noncompliance with McGuire Unit 1 Operating License Condition 2.C.4was identified for failure to install fixed emergency lighting in three areas where OMAs are required to support post-fire SSD procedures.Description: During a walkdown of post-fire safe shutdown procedures, the inspectorsidentified three areas where fixed emergency lighting had not been installed to support OMAs. The inspectors determined that fixed emergency lighting had not been installed at panel 1EMXB, or along the access route to panel 1EMXB, or on the 733 ft. elevation of the AB near column DD-53 in FA 4, where operators may be required to manually open Unit 1 auxiliary feedwater valves 1CA161C and 1CA162C. The licensee had previously identified all three areas in PIP M-04-4928 and had developed a modification package to install the lights.Analysis: This issue is a performance deficiency because the licensee had not installedfixed emergency lighting units for the support of OMAs while performing post-fire safe shutdown procedures as required by the FPP. This finding is more than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire) and it affects the objective of ensuring reliability and capability of systems that respond to initiating events. The team determined that this finding was of very low safety significance (Green) because the operators had a high likelihood of completing the task using flashlights.Enforcement: McGuire Unit 1 Operating License Condition 2.C.4 states that the licenseeshall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, February 1983, respectively, and the SE dated May 1989. McGuire UFSAR Section 9.5.1 states in part, that the McGuire FPP is contained in design basis document MCS-1465.00-00-0008, Plant Design Basis Specification for Fire Protection. This document states in Appendix C, Section C3, "Appendix R," that McGuire FPP is required to comply with Sections III.G, J, L and O of10 CFR 50, Appendix R. 10 CFR 50, Appendix R, Section III.J, "Emergency Lighting,"

states in part, that ELUs with at least an 8-hour battery supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto. Contrary to the above, on December 14, 2006, during a walkdown of post-fire SSDprocedures, the inspectors identified three areas where fixed emergency lighting had not been installed to support OMAs. The licensee had previously identified all 3 areas in PIP M-04-4928 and had developed a modification package to address this issue. This issue has existed for several years. Pursuant to the Commission's Enforcement Policy and NRC Manual Chapter 0305,under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48(c) are eligible for enforcement and ROP discretion.

23EnclosureThe Enforcement Policy and ROP also state that the finding must not be evaluated asRed. Because the licensee committed, prior to December 31, 2005, to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." Specifically, this issue had previouslybeen identified, entered into the licensee's corrective action program and will be corrected, and was not associated with a finding of high safety significance..10Cold Shutdown Repairs

a. Inspection Scope

The team reviewed the licensee's SSA to determine if any repairs were necessary toachieve cold shutdown. Station procedures IP/0/A/3090/23, and IP/0/A/3004/05 describe methods for repairing equipment, following a fire, needed to bring the units to cold shutdown. The team verified that repair kits necessary to restore valves 1ND1B, 1ND2AC, 1NV457A, and 1NV458B for remote operation as well as bulk cable reels weretagged and stored on-site for the sole purpose of damage control measures.

b. Findings

No findings of significance were identified.

.11 Compensatory Measures

a. Inspection Scope

The team reviewed the administrative controls for out-of-service, degraded, and/orinoperable fire protection features (e.g., detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing SSD functions or capabilities). The team reviewed the fire protection impairment log for fire areas 2, 5, and 19. The compensatory measures that had been established in these areas were compared to those specified for the applicable fire protection feature to verify that the risk associated with removing the fire protection feature from service was properly assessed and adequate compensatory measures were implemented in accordance with the approved FPP. Additionally, the team reviewed the licensee's short term compensatory measures(compensatory fire watches) to verify that they were adequate to compensate for a 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.

b. Findings

No findings of significance were identified.

24Enclosure4.

OTHER ACTIVITIES

4OA2Identification and Resolution of Problems

a. Inspection Scope

Corrective action program (CAP) PIPs related to the McGuire FPP, and the capability tosuccessfully achieve and maintain the plant in a SSD condition following a plant fire, as well as selected fire brigade response, emergency / incidents, and fire safety inspection reports were reviewed. This review was conducted to assess the frequency of fire incidents and effectiveness of the fire prevention program and any maintenance-related or material condition problems related to fire incidents. The team also reviewed other CAP documents, including completed corrective actionsdocumented in selected PIPs, and operating experience program (OEP) documents to verify that industry-identified fire protection problems potentially or actually affecting McGuire were appropriately entered into, and resolved by, the corrective action program process. Items included in the OEP effectiveness review were NRC Regulatory Issue Summaries, Information Notices, industry or vendor-generated reports of defects and noncompliance under 10 CFR Part 21, and vendor information letters. In addition, the inspectors reviewed a sample of the fire protection program audits and self-assessments which the licensee performed in the previous one-year period to assess the types of findings that were generated and that the findings were appropriately entered into the licensee's CAP.

The inspectors evaluated the effectiveness of the corrective actions for a sample of identified issues. The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.4OA5Additional Examples of Unresolved Item (URI) 50-369,370/03-07-04During the 2003 triennial fire protection inspection, URI 50-369,370/03-07-04,"Requirements Relative to the Number of Spurious Operations That Must be Postulated"was opened. The URI was opened pending NRC guidance related to the number of concurrent fire-induced spurious operations associated with a component or set of components that must be postulated during SSD analysis of a fire area. The licensee's SSA included the assumption that only one spurious operation due to fire damage need be postulated . The team determined two additional components where multiple fire-induced cable shortcircuits could cause equipment to change position and affect plant SSD. The exampleswere AFW air-operated control valves 1CA36AB and 1CA64AB. Two simultaneous, proper polarity direct current short circuits could cause either valve to close isolatingAFW flow from the TDAFW pump to either the D or A S/G respectively. The valves are normally open, air-operated control valves which fail open on loss of air or power. The valves and their cables were located in FA 2 and no actions existed in the fire response procedure to prevent spurious operation.

25EnclosureThe licensee relied on the assumption of only one spurious operation to justify thevalves remaining open during postulated fire scenarios in FA 2. Therefore, this represents an additional example of URI 50-369,370/03-07-04. The URI remains open pending NRC resolution of the generic industry issue regarding the licensing basis for concurrent multiple spurious hot shorts.

4OA6 Meetings, Including ExitOn December 14, 2006, the lead inspector presented the inspection results to Mr. G.Peterson and other members of his staff.

Proprietary information is not included in this report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

Arlow, T., OperationsAshe, K., Licensing Specialist

Bradshaw, S., Superintendent, Plant Operations

Brown, S., Manager, Engineering

Burns, Renard, Safety Assurance

Crane, K., Licensing Specialist

Hunt, M., Mechanical and Civil Engineering (MCE)

Jennings, D., Nuclear Generatoring Office Nuclear Performance Assessments

Johansen, B., MCE Balance of Plant

Kammer, J., Manager, Safety Assurance

Mebane, D., MCE

Nolan, J., Manager, MCE

Oldham, J., Fire Protection Lead Engineer

Peterson, G., Site Vice President, McGuire Nuclear Station

Snyder, S., Manager, RES Engineering

Thomas, J., Manager, Regulatory Compliance

NRC personnel

J. Brady, Senior Resident Inspector
S. Walker, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened/Closed

None.Discussed0500369, 370/2003007-04URI Requirements Relative to the Number of SpuriousOperations That Must Be Postulated (Section 40A5)

2Attachment

LIST OF DOCUMENTS REVIEWED

Section 1R05.03.a: List of Fire Barrier Features Inspected in Relation to Safe ShutdownSeparation RequirementsFloors/Walls/CeilingsDescriptionConcrete Masonry Block Wall

Fire Area 2 to Fire Area 2AGypsum Wallboard WallFire Area 19 to Fire Area 20
Fire DampersDescription716-16.1-7 Fire Area 2 to Fire Area 2A
750-29.1-1Fire Area 19 to Fire Area 20
750-29.1-3Fire Area 19 to Fire Area 20Fire DoorsDescription600AFire Area 2 to Stairway600DFire Area 2 to Fire Area 2A
703Fire Area 5 to Fire Area 15
704Fire Area 5 to Fire Area 6
RA1Fire Area 5 to Fire Area 6
801JFire Area 19 to Fire Area 20Fire Barrier Penetration SealsDescription716-14.1-1Fire Area 2 to Fire Area 2A716-14.1-13Fire Area 2 to Fire Area 2A
716-16.1-11Fire Area 2 to Fire Area 2A
736-5.1-1Fire Area 5 to Fire Area 15
736-5.1-9Fire Area 5 to Fire Area 15
736-5.1-15Fire Area 5 to Fire Area 15
736-6.1-1Fire Area 5 to Fire Area 6
750-29.2-3Fire Area 19 to Fire Area 17ADrawingsMC-1108-1, Architectural Rolling Door Schedule & Details, Rev. 32MC-1200-06.03, Architectural Steel Studs & Concrete Block Walls, Rev. 31
MC-1208-01.01, Architectural Door Schedule, Rev. 50
MC-1208-01.03-02, Architectural Special Purpose Door Details, Rev. 11
MC-1220-13, Auxiliary Building Units 1&2 Floor Drain Layout, Rev 13
MC-1224-3, Unit 1 Auxiliary Building Concrete and Curbs, Rev 21
MC-1231-13, Diesel Generator Building Units 1&2 Floor Drain Layout, Rev 2
MC-1315-01.02-004, Fire, Flood, & HVAC Boundaries AFW Pump Room, Arrangement, Elevation 716.0, Rev 0
MC-1315-01.02-120, Fire, Flood, & HVAC Boundaries Arrangement, Elevation 716.0, Rev 1
MC-1315-01.03-005, Fire, Flood, & HVAC Boundaries Arrangement, Elevation 733.0, Rev 2
MC-1315-01.04-100, Fire, Flood, & HVAC Boundaries Arrangement, Elevation 736.0, Rev 7
MC-1315-01.05-105, Fire, Flood, & HVAC Boundaries Arrangement, Elevation 750.0, Rev 1
MC-1315-05.01-005, Penetration Seal Fire Stop Design, Rev. 0
MC-1384-07.13-01, Fire Plan Layout, Elevation 716.0, Rev 9
MC-1384-07.14-02, Fire Plan Layout, Elevation 733.0 & 736.5, Rev 11
3AttachmentMC-1384-07.15-01, Fire Plan Layout, Elevation 750.0, Rev 12MC-1577-01, Flow Diagram of Auxiliary Building Ventilation System (VA), Rev 36
MC-1578-01.01, Flow Diagram of Control Area Ventilation System (VC), Rev 28
MC-1579-01, Flow Diagram of Diesel Generator Building Ventilation System (VD), Rev 15
MCEE-216-00.21-01, Elementary Diagram, Main Fire Protection System Pump A, Rev 2
MCEE-216-00.47-01, Elementary Diagram, Main Fire Protection System Pump B, Rev 4
MCEE-133-00.19-01, Elementary Diagram, Main Fire Protection System Pump C, Rev 3
MCFD-1599.0-Series, Flow Diagram of Fire Protection (RF,RY) System, Rev. 15
MCM-1206.07-0014-001, Flow Control Valve 1RY113 and 1RY114 Schematic Drawing, Rev D2
MC-1705-01.01, One Line Diagram 125 VDC /120 VAC Vital Instr and Control PWR SYS, Rev. 29
MC-1705-03.01, One and Three Line Diagram 250/125 VDC Auxiliary Power System Standby Shutdown Facility, Rev. 26
MC-1845-13.00, Lighting Hot Standby Emergency Lights Schedule, Rev. 3
MC-1857-04.00, Lighting Standby Shutdown Facility Plans and Details, Rev. 12
MC-2901-02.01, Computer Cable Routing Auxiliary Building Plan Below Elev. 733' +0", Rev. 37
MCCD-1700-00.00, Unit 1 Configuration One Line Diagram Unit Essential Power System,
Rev. 4MCCD-1700-00.01, Unit 1 Configuration One Line Diagram Unit Auxiliary Power System, Rev. 6MCCD-1702-02.00, One Line Diagram 4160 V Essential Auxiliary Power System, Rev. 2
MCCD-1703-06.10, One Line Diagram 600 VAC Essential MCC 1EMXH1, Rev. 2
MCCD-1703-06.11, One Line Diagram 600 VAC Essential MCC 1EMXA4, Rev. 3
MCCD-1703-06.12, One Line Diagram 600 VAC Essential MCC 1EMXA5, Rev. 3
MCCD-1703-10.02, One Line Diagram 600 VAC Load Center 1SLXG, Rev. 1
MCCD-1703-10.03, One Line Diagram 600 VAC MCC SMXG1, Rev. 1
MCCD-1703-10.06, One Line Diagram 600 VAC MCC SMXE, Rev. 6
MCCD-1703-10.09, One Line Diagram 600 VAC MCC, Rev. 0
MCCD-1703-10.10, One Line Diagram 600 VAC MCC SMXG, Rev. 5
MCCEE-0138-00.08, Elementary Diagram Low Level Supply B Shutoff Valve 0RN0010AC,
Rev. 0MCCEE-0138-00.08-01, Elementary Diagram Low Level Supply B Shutoff Valve 0RN0010AC,
Rev. 0MCCEE-0138-00.08-02, Elementary Diagram Low Level Supply B Shutoff Valve 0RN0010AC,
Rev. 7MCCEE-0138-00.10, Elementary Diagram Low Level Supply A Shutoff Valve 0RN0012AC,
Rev. 12MCCEE-0138-00.10-01, Elementary Diagram Low Level Supply A Shutoff Valve 0RN0010AC,
Rev. 8MCCEE-0138-00.10-02, Elementary Diagram Low Level Supply A Shutoff Valve 0RN0010AC,
Rev. 7MCCEE-0138-00.39, Elementary Diagram CCW Discharge A Isolation Valve 0RN147AC, Rev. 9MCCEE-0138-00.39-01, Elementary Diagram CCW Discharge A Isolation Valve 0RN147AC, Rev. 7MCCEE-0138-00.39-02, Elementary Diagram CCW Discharge A Isolation Valve 0RN147AC, Rev. 9
4AttachmentMCCEE-0138-00.63, Elementary Diagram CCW Discharge B Isolation Valve 0RN283AC,Rev. 8MCCEE-0138-00.63-01, Elementary Diagram CCW Discharge A Isolation Valve 0RN147AC,Rev. 10MCCEE-0138-00.63-02, Elementary Diagram CCW Discharge A Isolation Valve 0RN147AC,Rev. 9MCCEE-0138-00.68, Elementary Diagram Containment Vent. System Supply Isolation Valve0RN301AC, Rev. 9MCCEE-0138-00.68-01, Elementary Diagram Containment Vent. System Supply Isolation Valve0RN301AC, Rev. 8MCCEE-0138-00.68-02, Elementary Diagram Containment Vent. System Supply Isolation Valve0RN301AC, Rev. 7MCCEE-0171-00.05, Elementary Diagram Steam Generator 1A Blowdown Containment Isolation Valve 1BB5A, Rev. 16MCCEE-112-00.30, Elementary Diagram SSF Transfer Scheme, Rev. 5
MCCEE-112-00.30-01, Elementary Diagram SSF Transfer Scheme, Rev. 5
MCEE-0141-00.02, Elementary Diagram NC Loop 3 Discharge to ND System ContainmentIsolation Valve Inside 1ND02AC, Rev. 0MCEE-0147-02.00, Elementary Diagram AFW System Selector Station Control Circuit, Rev.0
MCEE-0147-02.01, Elementary Diagram AFW System Selector Station Control Circuit, Rev. 1
MCEE-0147-08.00, Elementary Diagram AFW System Selector Station Control Circuit, Rev. 2
MCEE-0147-13.00, Elementary Diagram AFW System Turbine Start Circuit (Auto), Rev. 3
MCEE-0147-17.00, Elementary Diagram AFW System Hotwell Supply Valve 1CA0002, Rev. 2
MCEE-0147-31.00, Elementary Diagram AFW System Solenoid Valve 1SASV0482 &1SASV0484, Rev. 5MCEE-0147-32.00, Elementary Diagram AFW System (CA) D.C. MOV 1CA0161C, Rev. 2
MCEE-0147-33.00, Elementary Diagram AFW System (CA) D.C. MOV 1CA0162C, Rev. 2
MCEE-0161-00.01, Elementary Diagram PZR. Liquid Sample Line Inside Containment Isolation1NM3AC, Rev. 9MCFD-1554-01.00, Flow Diagram of Chemical and Volume Control System, Rev. 4
MCFD-1554-01.01, Flow Diagram of Chemical and Volume Control System, Rev. 7
MCFD-1554-01.02, Flow Diagram of Chemical and Volume Control System, Rev. 8
MCFD-1554-01.03, Flow Diagram of Chemical and Volume Control System, Rev. 3
MCFD-1574-01.00, Flow Diagram of Nuclear Service Water System, Rev. 7
MCFD-1574-03.00, Flow Diagram of Nuclear Service Water System, Rev. 23
MCFD-1580-01.00, Flow Diagram of S/G Blowdown Recycle System, Rev. 23
MCFD-1592-01.00, Flow Diagram of AFW System, Rev. 7
MCFD-1592-01.01, Flow Diagram of AFW System, Rev. 14
MCFD-1592-01.02, Flow Diagram of AFW System, Rev. 8
MCFD-1592-02.00, Flow Diagram of AFW System, Rev. 3
MCFD-1593-01.00, Flow Diagram of Main Steam (MS) System MS Vent to Atmosphere, Rev. 17MCFD-1593-01.01, Flow Diagram of MS System MS Atmosphere, Rev. 12
MCFD-1593-01.03, Flow Diagram of MS System MS Atmosphere, Rev. 15
MCFD-1593-01.03, Flow Diagram of MS System MS Vent to Atmosphere,
Rev. 15
MCFD-2592-01.01, Flow Diagram of AFW System, Rev. 16
MCID-1499-CA.08, Instrument Detail TDAFW Pump Discharge To S/G Valve Control, Rev. 1
5AttachmentMCID-1499-CA.12, Instrument Detail TDAFWP Suction Flow and Pressure, Rev. 5MCID-1499-CA.12-01, Instrument Detail TDAFW Pump Suction Flow and Pressure, Rev. 2
MCID-1499-SA.02, Instrument Detail Steam to AFW Pump Turbine, Rev. 3
MCID-1499-SM.09, Instrument Detail MS PORV Control, Rev. 6
MCS-1223.SS-00-0001, Design Basis Specification for the SSS, Rev. 18
MCS-1465.00-00-0022, Appendix R SSA, Rev. 6
MCSF-1560.SS-01, Summary Flow Diagram SSS, Rev. 2
ProceduresAP/1/A/5500/07, Enclosure 12, RF Pump A & B Emergency Power Alignment, Rev. 26AP/0/A/5500/45, Plant Fire, Rev. 4
AP/0/A/5500/45, Plant Fire, Rev. 5
AP/1/A/5500/01, Steam Leak, Rev.15
AP/1/A/5500/24, Loss of Plant Control Due to Fire or Sabotage, Rev. 24
IP/0/A/3004/005, Installation of ND1B and ND2A Emergency Power Feeders, Rev. 11
IP/0/A/3090/023, Fire Damage Control Procedure, Rev. 4
IP/0/A/3190/003 A, Panelboard and Miscellaneous Power Equipment Preventative Maintenance, Rev. 7
IP/0/A/3190/030, Molded Case Circuit Breaker Inspection and Functional Test, Rev. 28
IP/1/B/3260/031, SSS Emergency Lighting Quarterly Test, Rev. 7
MP/0/A/7650/064, Installation and Repair of Penetration Seals, Rev. 30
OP/0/A/6100/017, Operation of SSF During Significant Sabotage Event That May Cause Plant Flooding, Rev. 29
OP/0/A/6100/20, Operational Guidelines Following a Fire In AB or Vital Area, Rev.19
OP/0/A/6100/21, Shutdown Outside the Control Room Following a Fire, Rev. 18
OP/1/A/6100/10 N, Annunciator Response for Panel 1AD-13, Window D3
OP/1/A/6100/10 N, Annunciator Response for Panel 1AD-13, Window E3
OP/1/A/6200/005, Spent Fuel Pool Level Control
OP/1/A/6250/002, AFW System, Rev. 96
OP/1/A/6100/010, Annunciator Response for Panel
AD-5, Rev. 0
OP/0/A/6400/002B, Halon Fire Protection System, Rev. 15
OP/1/A/6400/002C, Fire Detection System, Rev. 38
PT/1/A/4400/001N, Halon 1301 System Periodic Test, Rev. 33
PT/0/A/4250/004, Fire Barrier Inspection,
Rev. 24
PT/0/A/4600/016B, Halon fire Detector Monthly Test, Rev. 13
RP/0/A/5700/000, Classification of Emergency, Rev. 13
RP/0/A/5700/025, Fire Brigade Response, Rev. 11
NSD 112, Fire Brigade Organization, Training, and Responsibilities, Rev. 7
NSD 313, Control of Combustible and Flammable Material, Rev. 5
NSD 314, Hot Work Authorization, Rev. 6
NSD 316, Fire Protection Impairment and Surveillance, Rev. 6
6AttachmentCompleted Surveillance Test Procedures and Test RecordsIP/0/B/3260/028, SSS Emergency Lighting Battery Discharge Test, Rev. 10IP/0/B/3260/031, SSS Emergency Lighting Quarterly Test, Rev. 007
PT/0/A/4200/002, SSF Operability Test, Rev. 35, completed 09/30/06
PT/0/A/4200/002, SSF Operability Test, Rev. 35, completed 10/26/06
PT/0/A/4200/002, SSF Operability Test, Rev. 35, completed 11/06/06
PT/0/A/4600/113, Operator Time Critical Task Verification, Rev. 11
MG-PM-17, Quantar Radio Operations
WO#
01699644-02, PT/0/A/4250/020, Roll-Up Fire Door Semi-Annual Inspection/Test, completed 11/2/2006
WO#
98686086-01, PT/0/A/4250/004, Fire Barrier/Fire Door Inspection, completed 5/5/2005
WO#
585727-01, PT/0/A/4250/004, Fire Barrier/Penetration Seals Inspection, completed
5/5/2006
WO#
98754231, PT/0/A/4400/001A, Fire Protection Annual Valve Test, completed 4/9/2006
WO#
1715387-01, PT/0/A/4400/001C, Fire Protection System Monthly Test, completed
11/9/2006
WO#
98694072-01, PT/0/A/4400/001T, Fire Protection System AB Flush and Flow Test, completed 8/2/2005
WO#
01716101-01, PT/0/A/4600/016B, Test Fire Detectors Zones 37Hand 50H, completed
11/14/2006 CalculationsMCS-1465.00-00-0008, Unit 1&2 Fire Area SSD Train Designation, Rev. 7MCS-1465.00-00-0022, Appendix E. Unit 1 & Unit 2 SSD Equipment List, Rev. 6
MC-1174.00-2, Specification for McGuire 1-2 Fire-Rated Concrete Masonry Units, Mill Power Supply, dated October 5, 1972
MCC-1435.00-00-0006, McGuire Penetration Seals Design, Rev. 2
MCC-1435.03-00-0012, McGuire Penetration Seals Database and 86-10 Evaluations, Rev. 0
MCC-1435.03-00-0013, McGuire Fire Protection Code Deviations, Rev. 3
MCM-1206.07-0029-001, McGuire Units 1&2 Diesel Generator Area Halon Fire Protection System Calculation, Rev. D01Design ChangesMinor Design Change No. MD200834,
EC 92169, Install a Fire Detection System for the Unit 2
Interior and Exterior Doghouses, dated 8/7/2006
Minor Design Change No. MD100745, Add 8 Hour Emergency Lights
Fire StrategiesStrategy Number 2, Aux-U1-AFWP-Room, Elevation 716, Rev. 1Strategy Number 5, Aux-Diesel Generator 1A Room, Elevation 736, Rev. 0
Strategy Number 19, Aux-U1-Cable Room, Elevation 750, Rev. 0Applicable Codes and Standards
NFPA 10 - 1978, Standard for Portable Fire ExtinguishersNFPA 12A - 1977, Standard on Halon 1301 Fire Extinguishing Systems
NFPA 13 - 1978,
Standard for the Installation of Sprinkler Systems
7AttachmentNFPA 14 - 1976, Standard for the Installation of Standpipes and Hose SystemsNFPA 15 - 1977, Standard for Water Spray Fixed Systems for Fire Protection
NFPA 20 - 1978, Standard for the Installation of Centrifugal Fire Pumps
NFPA 24 - 1977, Standard for the Installation of Private Service Mains and Their Appurtenances
NFPA 27 - 1975, Private Fire Brigades
NFPA 30 - 1977, Flammable and Combustible Liquids Code
NFPA 72E-1974, Standard on Automatic Fire Detection
NFPA 101-1996, Life Safety Code
NUREG-1552, Supplement 1, Fire Barrier Penetration Seals in Nuclear Power Plants, dated January 1999Technical Manuals and Vendor InformationData Sheet Angus Redskin 500 Fire Hose, dated 2005Data Sheet Akron Turbojet Fire Hose Nozzles, 1715E,1720E, and1727, dated 2006
Data Sheet ICI Aerospace Electrically Actuated Frangible Link Assembly, Model 630, dated
10/19/1993
Data Sheet O-Z/Gedney Fire Seals, CFS Series, dated 3/28/1981
Data Sheet Protectoseal In-Line Flame Arrester, Model 4950, dated 1979
Data Sheet and Installation Instructions Air Balance Inc., 119A,
UL-Classified Static Rated Fire Damper, dated 3/20/1978
Data Sheet Ruskin Manufacturing, IBD23, Fire Damper and Leakage 3Hr Rated Interlocking Blade Dampers, dated 1/6/1986
Data Sheet P16164 SuperVac Smoke Ventilator Data Sheet P200S SuperVac Smoke Ventilator Ventilator Users Guide for SuperVac Smoke Ventilators, dated 8/28/98
SuperVac Smoke Ventilation Training Manual for Smoke Ventilators, dated 8/28/1998
The Overly Manufacturing Company, Order
C-45485, Fire Rated Metal Doors and Hardware, dated 7/13/2000
The Philipp Manufacturing Company, Order 73-5629H12, Fire Rated Hollow Metal Doors and Hardware, dated 5/17/1994Licensing Basis DocumentsUFSAR Chapter 9, Section 9.5.1, Fire Protection SystemUFSAR Chapter 16, Fire Protection Selected Licensee Commitments Letter from W.O. Parker, Duke Power Co., to H.R. Denton, NRC, McGuire Nuclear Station Fire
Protection, dated January 9, 1979
McGuire Operating License Conditions 2.C.4, Fire Protection Program, for Units 1 and 2, respectively Title 10 of the Code of Federal Regulations, Part 50 (10
CFR 50), Appendix R, Sections
III.G, J,
L, and O
CFR 50.48, Fire Protection Appendix A to Branch Technical Position Auxiliary and Power Conversion Systems Branch
9.5-1, Guideline for Fire Protection for Nuclear Power Plants
8AttachmentDesign Basis DocumentsMCS-1465.00-00-0008, Design Basis Specification for Fire Protection, Rev. 7MCS-1465.00-00-0022, Design Basis Specification for the Appendix R Safe Shutdown Analysis, Rev. 6
MCS-1579.VD-00-0001, Design Basis Specification for VD System, Rev. 9
MCS-1599.RF.-00-0001, Design Basis Specification for RF/RY System, Rev. 16Other DocumentsTT/1/A/9100/08, Halon Discharge Test for Unit 1 Diesel Generator Rooms, dated 5/9/1978Report of a Standard ASTM Fire Endurance Test and Fire and Hose Stream Test on a Non-

load-Bearing Wall Assembly, for Duke Power Company, Project 6579, dated December 12,

1978
Duke
Memorandum to File, Circuit Protection for Fire Pump C Controls, File
MC-1435.00, dated
11/9/1984
Fire Emergency Reports, RP/0/A/5700/025 Enclosure 4.3 for Period January 2003 through November 2006
Fire Drill Summary Reports for Fire Brigade Drills Conducted in 2006
NGD-FB-05, Initial Fire Brigade Training, Fire Hose, Nozzles, Appliances, and Streams, Rev. 4
McGuire Fire Strategy Revision Workflow Process, Fire Protection Program DBD, Appendix B.5
Section Review, projected due date 3/2007
Information Notice 2005-01: Halon Fire-Extinguishing System Piping Incorrectly Connected, dated 2/4/2005
Duke Letter of Intent to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition, dated 2/28/2006
JPM for AP/0/A/5500/45, Plant Fire, Enc. 23,
AB 750' Unit 1 Cable Spreading Room Fire Unit 1Actions, 07/25/06JPM for AP/0/A/5500/45, Plant Fire, Enc. 8,
AB 716' Unit 2 T/D CA Pump Room Fire Unit 2Actions, 07/25/06JPM-CP-AD-126T, 1ETA Room Actions
JPM-CP-AD-127T, SSF Actions
JPM-CP-AD-129T, Unit 2 SSF Actions
JPM-CP-AD-61T, SSF Actions
JPM-CP-AD-87T, 1ETA Room Actions Control Room Shift Turnover Records for Day and Night Shifts for the following dates: 12/20/05,07/03/06, 08/01/06, 08/02/06, 11/24/06, and 11/27/06Memorandum To Bruce Hamilton, Nov. 3, 1992, AP/24 Loss of Plant Control Due to Fire TimeLine for Local Steps.Duke Letter to NRC, dated 11/18/1983, McGuire Units 1 and 2, Docket Nos. 50-369 and 50-
370, Issuance of Amendment No. 31 to Facility Operating License
NPF-9 and Amendment No.

to

Facility Operating License
NPF-17 - McGuire Nuclear Station, Units 1 and 2
Background Document for AP/0/A/5500/45
Background Document for AP/1&2/A/5500/24
Work Request No. WR 911971
Federal Register/Vol. 70, No. 10/Friday, January 14, 2005/Notices, Pages 2662 thru 2664, NRC
Enforcement Policy; Extension of Enforcement Discretion of Interim Policy
9AttachmentInterim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection
Issues (10 CFR 50.48)
Duke Letter to NRC dated November 28,1994, Subject: McGuire Nuclear Station, Units 1 and 2
Docket Nos. 50-369 and 50-370 NRC Generic Letter 92-08, Thermo-Lag 330-1 Fire BarriersProblem Investigation Process (PIP) Reports Generated as a Result of This InspectionM-06-05645, Evaluate Potential Enhancements Needed to Revise Fire Plan/Strategies in the
DG and Cable Spreading Rooms
M-06-05647, Emergency Lighting and Exit Signs to Support Fire Fighting Emergency Operations and Personnel Evacuation
M-06-05656, NRC inspector questioned response of
AP-45 Plant Fire Procedure in dealing with
CA assured source to the turbine driven auxiliary feedwater pump
M-06-05671, Loss of Power Supply for Fire Suppression Supply Deluge Valves 1RY113 and
1RY114
M-06-05730, As part of responding to PIP M-06-5656, a potential concern has been identified in how committed actions are tracked by McGuire
M-06-05867, Availability of Assured Power Source for Portable Smoke Ejectors During Plant Fires
M-06-05803, Items noted during NRC triennial fire protection inspection
M-06-05900, NRC question raised during triennial inspection on potential for problem with failure of two specific pressure switches
M-06-05901, Potential Spurious Operation of 1CA64AB and 1CA36ABOther Corrective Action Documents (PIPs) Reviewed During This Inspection00-04491,Evaluate Cabling for NC PORV and Block Valve02-06055,Designated App R lighted pathway from Control Room to ETA Room can't be used for fire in cable spreading room
M-03-02118, Appendix R logics for auxiliary feedwater do not show valve 2CA0007A
M-03-03827, DC Emergency Lighting and Ctmt Hoist Motor
M-04-02837, Engineering review of ELD system Maintenance rule functions
M-04-02981, The ELD system has not been adequately monitored per 10
CFR 50.65, The Maintenance Rule.
04-03317, App R SSF SBMUP NC influent for boration
M-04-04928, Fire Audit observation on Appendix R 8-hour Emergency Lighting
M-04-20983, The Unit 2 ELD system requires classification as A(1) status due to exceeding
ELD.02 Performance Criteria.
05-04859, Appendix R Manual Action
M-06-00979, 06 CDBI Self Assessment
M-00-04469, Hot shorts on all three control circuits for fire pumps could prevent automatic start on demand
M-04-04930, No Detection System in Any Doghouse
M-04-05510,Documents 2004 Annual Offsite Fire Drill and Training for Volunteer Departments
M-05-00215, Evaluation of Halon Suppression Systems Incorrectly Piped
M-05-05495, Documents 2005 Annual Offsite Fire Drill and Training for Volunteer Departments
M-06-00576, Track Additional Corrective Actions Needed to Revise Fire Plan/Strategies
M-06-04539, PIP initiated to ensure appropriate actions have been taken in order to receive enforcement discretion during the transition to the NFPA Standard 805
10Attachment

LIST OF ACRONYMS

ABAuxiliary BuildingAFWAuxiliary Feedwater

APAbnormal Procedure

CAPCorrective Action Program

CFRCode of Federal Regulation

CORCode of Record

ELUEmergency Lighting Unit

FAFire Area

FHAFire Hazards Analysis

FPPFire Protection Program

ft.foot

HVACHeating, Ventilation, and Air Conditioning

IMCInspection Manual Chapter

IPInspection Procedure

IPEEEIndividual Plant Examination for External Events

MCCMotor Control Center

MCEMechanical and Civil Engineering

MCRMain Control Room

MDAFWMotor Driven Auxiliary Feedwater Pump

MOVMotor Operated Valve

NFPAN ational Fire Protection Association
NRCU. S. Nuclear Regulatory Commission

OEPOperating Experience Program

OMAOperator Manual Action

P&IDsPiping and Instrumentation Drawings

PIPProblem Investigation Report

PORVPilot Operated Relief Valve

ROPReactor Oversight Process

SCBASelf-Contained Breathing Apparatus

SDPSignificance Determination Process

SESafety Evaluation

SERSafety Evaluation Report

S/GSteam Generator

SSASafe Shutdown Analysis

SSDSafe Shutdown

SSFStandby Shutdown Facility

SSSStandby Shutdown System

UFSARUpdated Final Safety Analysis Report

URIU nresolved Item