ML12229A128

IR 05000247-12-009, 05000286-12-008; 4/23/2012 - 4/26/2012; Indian Point Nuclear Generating Units 2 and 3; Annual Follow-up of Selected Issues Inspection

ML12229A128
Person / Time
Site:	Indian Point
Issue date:	08/16/2012
From:	Rogge J Engineering Region 1 Branch 3
To:	Ventosa J Entergy Nuclear Operations
References
IR-12-008, IR-12-009
Download: ML12229A128 (39)

See also: IR 05000247/2012009

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

't"ffi REGION I

21OO RENAISSANCE BOULEVARD, SUITE 1OO

KING OF PRUSSIA, PENNSYLVANIA 1940S'2713

August L6, 20L2

Mr. John Ventosa, Site Vice President

Entergy Nuclear Operations, lnc.

Indian Point Energy Center

450 Broadway, GSB

P.O. Box 249

Buchanan, NY 1051 1-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC INSPECTION

REPORT 05000247t2012009 AND 0500028612012008 AND NOTICES OF

VIOLATION

Dear Mr. Ventosa:

On April 26,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

lndian Point Units 2and 3. The enclosed inspection report documents the inspection results

which were discussed on April 26, 2012, with Mr. Lawrence Coyle, and other members of your

staff. Following in-office reviews, an additional meeting was conducted by telephone with

Mr. Patric Conroy, Director, Nuclear Safety Assurance, on June 8,2012, and an exit meeting

was conducted by telephone with Mr. Patric Conroy and other members of your staff on

July 20, 2012.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commission's rules and regulations, and with the conditions of your

license. The inspectors reviewed the ongoing implementation of your corrective actions to

restore full compliance with Title 10 of the Code of Federal Regulations, Part 50, Appendix R,

Section lll.G.2 regarding denied exemptions to implement operator manual actions in lieu of

meeting the aforesaid fire protection regulations.

Two violations are cited in the enclosed Notices of Violation and the circumstances surrounding

them are described in detail in the subject inspection report. The violations were evaluated in

accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on

the NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcemenVenforce-pol.html.

The violations involved the use of unapproved operator manual actions to mitigate safe

shutdown equipment malfunctions caused by a fire-induced single spurious actuation at Indian

Point Units 2 and 3, in lieu of protecting the equipment in accordance with 10 CFR Part 50

Appendix R, Section lll.G.2. Although determined to be of very low safety significance (Green),

these violations are being cited in the Notices because not all of the criteria specified in

Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation were satisfied.

Specifically, Entergy Nuclear Operations, Inc. (ENO) failed to restore compliance within a

reasonable amount of time after the violations were identified to nuclear power plant licensees

in Regulatory lssue Summary 2006-10, Regulatory Expectations with Appendix R Paragraph

lll.G.2 Operator ManualActions, on June 30, 2006. You are required to respond to this letter

and should follow the instructions specified in the enclosed Notice when preparing your

response. The NRC will use your response, in part, to determine whether further enforcement

action is necessary to ensure compliance with regulatory requirements.

J. Ventosa 2

One other finding of very low safety significance (Green) was also identified. This finding was

determined to be a violation of NRC requirements. However, because of its very low safety

significance, and because it was entered into your corrective action program, the NRC is

treating this finding as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC

Enforcement Policy. lf you contest the NCV in this report, you should provide a written

response within 30 days of the date of this inspection report with the basis for your denial, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C.

20555-0001; with copies to the Regional Administrator, Region l; the Director, Office of

Enforcement; and the NRC Senior Resident Inspector at Indian Point Unit 2 or 3. In addition, if

you disagree with the cross-cutting aspect assigned to any finding in this report, you should

provide a response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region l, and the Senior Resident Inspector at

f ndian Point Unit 2 or 3.

ln accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules

of Practice," a copy of this letter, its enclosure, and your response (if any)will be available

electronically for public inspection in the NRC Public Document Room or from the Publicly

Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is

accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

.'

4

i  ;,/

dfr/--

/ John F. Rogge, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-247, 50-286

License Nos. DPR-26, DPR-64

Enclosures:

1. Notice of Violation

2. nspection Report 05000247 l 20 1 2009 a nd 05000 286 l 20 1 2008

I

w/Attachment: Supplemental lnformation

cc Mencl: Distribution via ListServ

J. Ventosa 2

One other finding of very low safety significance (Green) was also identified. This finding was

determined to be a violation of NRC requirements. However, because of its very low safety

significance, and because it was entered into your corrective action program, the NRC is

treating this finding as a non-cited violation (NCV)consistent with Section2.3.2 of the NRC

Enforcement Policy. lf you contest the NCV in this report, you should provide a written

response within 30 days of the date of this inspection report with the basis for your denial, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C.

20555-0001; with copies to the Regional Administrator, Region l; the Director, Office of

Enforcement; and the NRC Senior Resident Inspector at Indian Point Unit 2 or 3. In addition, if

you disagree with the cross-cutting aspect assigned to any finding in this report, you should

provide a response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region l, and the Senior Resident lnspector at

lndian Point Unit 2 or 3.

ln accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules

of Practice," a copy of this letter, its enclosure, and your response (if any) will be available

electronically for public inspection in the NRC Public Document Room or from the Publicly

Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is

accessible from the NRC Web Site at http://www,nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RN

John F. Rogge, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-247, 50-286

License Nos. DPR-26, DPR-64

Enclosures:

1. Notice of Violation

2. nspection Report 05000247 l 201 2009 and 05000 2861201 2008

I

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

DOCUMENT NAME: GlDRS\Engineering Branch 3\IPEC OMA Inspection\lP OMA Inspection Report.doc

ADAMS ACCESSION NUMBER: ML12229A128

V Non-Sensitive g Publicly Available

g suNstReview

n Sensitive n Non-PubliclyAvailable

OFFICE RI/DRS RI/DRS RI/ORA RI/DRP

NAME DOrr WSchmidt MMcLaughlin via email MGray via email

DATE 8t1t12 8t2t12 8t10t12 8t12t12

OFFICE RI/DRS RI/DRS

NAME JRogge CMiller via email

DATE 8116112 8t9t12

OFFICIAL

J. Ventosa 3

Distribution w/encl: via E-mail)

W. Dean, RA RIoRAMATL RESOURCE)

D. Lew, DRA RIORAMAlL RESOURCE)

D. Roberts, DRP RIDRPMAlL RESOURCE)

J. Clifford, DRP RIDRPMAlL RESOURCE)

C. Miller, DRS RIDRSMAIL RESOURCE)

P. Wilson, DRS RIDRSMATL RESOURCE)

S. Kennedy, Rl OEDO

M. Gray, DRP

B. Bickett, DRP

S. McCarver, DRP

M. Jennerich, DRP

A. Ayegbusi, Acting SRI

R. Montgomery, Acting Rl

P. Cataldo, SRI

N. Lafferty, Acting Rl

D. Hochmuth, AA

RidsNrrPM lndianPoint Resource

RidsNrrDorlLpll -1 Resource

ROPreport Resource

J. Rogge, DRS

D. Orr, DRS

W. Schmidt, DRS

J. Lilliendahl, DRS

ENCLOSURE 1

NOTICE OF VIOLATION - Indian Point Unit 2

Entergy Nuclear Operations, lnc. Docket No: 50-247

lndian Point Nuclear Generating Unit 2 License No: DPR-26

During an NRC inspection conducted April 23 through April 26, 2012, a violation of NRC

requirements was identified. ln accordance with the NRC Enforcement Policy, the violation is

listed below:

License Condition 2.K specifies, in part, that Entergy Nuclear Operations, lnc., (ENO) shall

implement and maintain in effect all provisions of the NRC-approved fire protection program

as described in the Updated Final Safety Analysis Report.

The Updated Final Safety Analysis Report, Section 9.6 specifies that ENO will meet the

requirements of 10 CFR Part 50, Appendix R, Section lll.G.2, which requires, in part, except

as provided for in paragraph G.3 of this section, where cables or equipment, including

associated non-safety circuits that could prevent operation or cause maloperation due to hot

shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to

achieve and maintain hot shutdown conditions are located within the same fire area, one of

the means of ensuring that one of the redundant trains is free of fire damage shall be

provided, per the requirements in G.2.a - G.2i .

Contrary to the above, between June 30, 2006, and April 26,2012, ENO failed to implement

all provisions of the approved fire protection program. Specifically, the safe shutdown

strategy for Indian Point Unit 2 relied upon unapproved operator manual actions to mitigate

post-fire safe shutdown equipment malfunctions caused by a single spurious actuation, in

lieu of protecting the equipment in accordance with 10 CFR Part 50 Appendix R, Section

lll.G.2, per the requirements in G.2.a - G.2.f . The specific operator manual actions and fire

areas and fire zones that are in violation of Appendix R, Section lll.G.2 are listed in the

lndian Point Unit 2 Denied OMA Summary Table of NRC Inspection Report

0500024712012009 and 0500028612012008. The use of manual actions in lieu of providing

the required protection requires prior NRC approval.

This violation is associated with a Green Significance Determination Finding.

Pursuant to the provisions of 10 CFR 2.201, ENO is hereby required to submit a written

statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document

Control Desk, Washington, DC 20555-0001 with a copy to the RegionalAdministrator, Region l,

and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within

30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should

be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation or severity

level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective

steps that will be taken, and (4) the date when full compliance will be achieved. Your response

may reference or include previous docketed correspondence, if the correspondence adequately

addresses the required response. lf an adequate reply is not received within the time specified

in this Notice, an order or a Demand for Information may be issued as to why the

Enclosure 1

2

license should not be modified, suspended, or revoked, or why such other action as may be

proper should not be taken. Where good cause is shown, consideration will be given to

extending the response time.

lf you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRC's document system (ADAMS), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. lf personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. lf you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.9., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). lf safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

f n accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days of receipt.

Dated this 16th day of August, 2012

Enclosure 1

NOTICE OF VIOLATION - Indian Point Unit 3

Entergy Nuclear Operations, lnc. Docket No: 50-286

Indian Point Nuclear Generating Unit 3 License No: DPR-64

During an NRC inspection conducted April 23 through April 26, 2012, a violation of NRC

requirements was identified. In accordance with the NRC Enforcement Policy, the violation is

listed below:

License Condition 2.H specifies, in part, that Entergy Nuclear Operations, Inc., (ENO) shall

implement and maintain in effect all provisions of the approved Fire Protection Program as

described in the Final Safety Analysis Report.

The Final Safety Analysis Report, Section 9.6.2 specifies that ENO will meet the

requirements of 10 CFR Part 50, Appendix R, Section lll.G.2, which requires, in part, except

as provided for in paragraph G.3 of this section, where cables or equipment, including

associated non-safety circuits that could prevent operation or cause maloperation due to hot

shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to

achieve and maintain hot shutdown conditions are located within the same fire area, one of

the means of ensuring that one of the redundant trains is free of fire damage shall be

provided, per the requirements in G.2.a - G.z.t.

Contrary to the above, between June 30, 2006 and April 26, 2012, ENO failed to implement

all provisions of the approved fire protection program. Specifically, the safe shutdown

strategy for Indian Point Unit 3 relied upon unapproved manual operator actions to mitigate

post-fire safe shutdown equipment malfunctions caused by a single spurious actuation, in

lieu of protecting the equipment in accordance with 10 CFR Part 50 Appendix R, Section

lll.G.2, per the requirements in G.2.a - G.z.f . The specific operator manual actions and fire

areas and fire zones that are in violation of Appendix R, Section lll.G.2 are listed in the

Indian Point Unit 3 Denied OMA Summary Table of NRC lnspection Report

0500024712012009 AND 0500028612012008. The use of manual actions in lieu of providing

the required protection requires prior NRC approval.

This violation is associated with a Green Significance Determination Finding.

Pursuant to the provisions of 10 CFR 2.201, ENO is hereby required to submit a written

statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document

Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region l,

and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within

30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should

be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation or severity

level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective

steps that will be taken, and (4) the date when full compliance will be achieved. Your response

may reference or include previous docketed correspondence, if the correspondence adequately

addresses the required response. lf an adequate reply is not received within the time specified

Enclosure 1

2

in this Notice, an order or a Demand for lnformation may be issued as to why the license should

not be modified, suspended, or revoked, or why such other action as may be proper should not

be taken. Where good cause is shown, consideration will be given to extending the response

time.

lf you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRC's document system (ADAMS), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. lf personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. lf you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.9., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). lf safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

ln accordance with 10 CFR 19.11 , you may be required to post this Notice within two working

days of receipt.

Dated this 16th day of August, 2012

Enclosure 1

ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos.: 50-247,50-286

License Nos,: DPR-26, DPR-64

ReportNos.: 0500024712012009,05000286/2012008

Licensee: Entergy Nuclear Operations, Inc. (ENO)

Facility: lndian Point Nuclear Generating Units 2 and 3

Location: 450 Broadway, GSB

Buchanan, NY 1051 1-0249

Dates: April 23 - April 26,2012

Inspectors: D. Orr, Senior Reactor Inspector

W. Schmidt, Senior Reactor Analyst

J. Lilliendahl, Reactor Inspector

Approved by: John F. Rogge, Chief

Engineering Branch 3

Division of Reactor Safety

Enclosure 2

SUMMARY OF FINDINGS

lR 0500024712012009, 0500028612012008; 412312012 - 412612012; Indian Point Nuclear

Generating Units 2 and 3; Annual Follow-up of Selected lssues Inspection.

The report covered a one-week annual follow-up of selected issues inspection by specialist

inspectors, Three findings of very low significance were identified. Two of these findings were

determined to be cited violations and one of these findings was determined to be a non-cited

violation. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter (lMC) 0609, Significance Determination Process. Cross-

cutting aspects associated with findings are determined using IMC 0310, Components Within

The Cross-Cutting Areas. Findings for which the significance determination process (SDP)

does not apply may be Green or be assigned a severity level after NRC management review.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

. Green. The inspectors identified a finding of very low safety significance (Green),

involving a cited violation of lndian Point Unit 2 Operating License Condition 2.Kto

implement and maintain all aspects of the approved fire protection program.

Specifically, ENO failed to protect required post-fire safe shutdown components and

cabling to ensure one of the redundant trains of equipment remained free from fire

damage as required by 10 CFR Part 50, Appendix R, Section lll.G.2. In lieu of

protecting a redundant safe shutdown train, ENO utilized unapproved operator manual

actions to mitigate component malfunctions or spurious operations caused by postulated

single fire-induced circuit faults. ENO submitted an exemption request (M1090770151)

on March 6, 2009, in which it sought exemption from requirements of Paragraph lll.G.2,

to permit the use of OMAs upon which it had been relying for safe-shutdown in a number

of fire areas. However, several OMAs within the exemption request were denied

because ENO failed to demonstrate that the OMAs were feasible and reliable, or to

appropriately evaluate fire protection defense-in-depth. ENO's performance deficiency

delayed achieving full compliance with fire protection regulations and adversely affected

post-fire safe shutdown. ENO has entered this issue into the corrective program for

resolution. The inspectors found the manual actions in addition to roving fire watches in

all affected areas to be reasonable interim compensatory measures pending final

resolution by ENO.

ENO's failure to protect components credited for post-fire safe shutdown from fire

damage caused by single spurious actuation is considered a performance deficiency.

The performance deficiency was more than minor because it affected the Mitigating

Systems cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to an external event to prevent undesirable consequences in the

event of a fire. Specifically, the use of operator manual actions during post-fire safe

shutdown is not as reliable as normal systems operation which could be utilized had the

requirements of 10 CFR Part 50, Appendix R, Section lll.G.2 been met and, therefore,

prevented fire damage to credited components and/or cables. The inspectors used

IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 and

" 2

=nclosure

a Senior Reactor Analyst conducted a Phase 3 evaluation, to determine that this finding

was of very low safety significance (Green). This finding does not have a cross cutting

aspect because the performance deficiency occurred greater than three years ago when

the exemption request was submitted to the NRC on March 6, 2009, and is not indicative

of current licensee performance. (Section 4OA2.1)

Green. The inspectors identified a finding of very low safety significance (Green),

involving a cited violation of Indian Point Unit 3 Operating License Condition 2.H to

implement and maintain all aspects of the approved fire protection program.

Specifically, ENO failed to protect required post-fire safe shutdown components and

cabling to ensure one of the redundant trains of equipment remained free from fire

damage as required by 10 CFR Part 50, Appendix R, Section lll.G.2. In lieu of

protecting a redundant safe shutdown train, ENO utilized unapproved operator manual

actions to mitigate component malfunctions or spurious operations caused by postulated

single fire-induced circuit faults. ENO submitted an exemption request (M1090760993)

on March 6, 2009, in which it sought exemption from requirements of Paragraph lll.G.2,

to permit the use of OMAs upon which it had been relying for safe-shutdown in a number

of fire areas. However, several OMAs within the exemption request were denied

because ENO failed to demonstrate that the OMAs were feasible and reliable, or to

appropriately evaluate fire protection defense-in-depth. ENO's performance deficiency

delayed achieving full compliance with fire protection regulations and adversely affected

post-fire safe shutdown. ENO has entered this issue into the corrective program for

resolution. The inspectors found the manual actions in addition to roving fire watches in

all affected areas to be reasonable interim compensatory measures pending final

resolution by ENO.

ENO's failure to protect components credited for post-fire safe shutdown from fire

damage caused by single spurious actuation is considered a performance deficiency,

The performance deficiency was more than minor because it affected the Mitigating

Systems cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to an external event to prevent undesirable consequences in the

event of a fire. Specifically, the use of operator manual actions during postfire safe

shutdown is not as reliable as normal systems operation which could be utilized had the

requirements of 10 CFR 50, Appendix R, Section lll.G.2 been met and, therefore,

prevented fire damage to credited components and/or cables. The inspectors used

IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 and

a Senior Reactor Analyst conducted a Phase 3 evaluation, to determine that this finding

was of very low safety significance (Green). This finding does not have a cross cutting

aspect because the performance deficiency occurred greater than three years ago when

the exemption request was submitted to the NRC on March 6, 2009, and is not indicative

of current licensee performance. (Section 4OA2.2)

Green. The inspectors identified a Green, Non-Cited Violation of the lndian Point

Nuclear Generating Unit No. 2 Amended Facility Operating License, Condition 2.K, in

that ENO failed to implement and maintain in effect all provisions of the NRC-approved

fire protection program as described in the Updated Final Safety Analysis Report.

Specifically, ENO failed to minimize transient combustible materials within the primary

auxiliary building (PAB) and stored a compressed gas cylinder containing hydrogen gas

lll

Enclosure 2

under cable trays. The hydrogen gas cylinder was inappropriately left in its storage

location after a calibration gas cylinder change-out occurred for the waste gas analyzer,

ENO promptly entered this issue into its corrective action program and removed the

hydrogen cylinder from the PAB. ENO initiated a corrective action to evaluate the

identified condition and ensure actions to prevent its recurrence.

ENO's failure to remove the compressed hydrogen gas cylinder from the PAB after its

intended use as a calibration gas for the waste gas analyzer was a performance

deficiency. This finding was more than minor because it was associated with the

External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely

affects the cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences (i.e., core

damage). Specifically, the hydrogen gas cylinder was stored below cable trays in an

area that includes safe shutdown circuits and the associated cables were at increased

risk to fire damage. The inspectors used IMC 0609, Appendix F, Fire Protection

Significance Determination Process, Phase 1 and a Senior Reactor Analyst conducted a

Phase 3 evaluation, to determine that this finding was of very low safety significance

(Green). The inspectors determined that this finding had a cross-cutting aspect in the

area of Human Performance associated with the work practice attribute because ENO

personnel did not follow procedure, Control of Combustibles, EN-DC-161, Rev. 6, as

written and did not remove the hydrogen gas cylinder from the PAB after it was

disconnected from the waste gas analyzer contrary to Control of Combustibles,

EN-DC-161, Rev. 6. (H.4(b) per IMC 0310). (Section 4OA2.3)

B. Licensee-ldentified Violations

None.

iv

Enclosure 2

REPORT DETAILS

Backqround

The NRC requirements related to fire protection are provided in Title 10 of the Code of Federal

Regulations (CFR) Section 50.48. In accordance with 10 CFR 50.48(b), nuclear power plants

licensed to operate before January 1,1979 are required to meet Section lll.G, of 10 CFR Part 50, Appendix R. The underlying purpose of Section lll.G of 10 CFR Part 50, Appendix R, is

to ensure that the ability to achieve and maintain safe-shutdown is preserved following a fire

event.

Paragraph lll.G.2 of Appendix R requires one of the following means to ensure that a redundant

train of safe-shutdown cables and equipment is free of fire damage, where redundant trains are

located in the same fire area outside containment:

a. Separation of cables and equipment by a fire barrier having a three-hour rating;

b. Separation of cables and equipment by a horizontal distance of more than 20 feet with

no intervening combustibles or fire hazards and with fire detectors and an automatic fire

suppression system installed in the fire area; or,

c. Enclosure of cables and equipment of one redundant train in a fire barrier having a one-

hour rating and with fire detectors and an automatic fire suppression system installed in

the fire area.

lnside containments one of the fire protection means specified above or one of the following

fire protection means shall be provided:

d. Separation of cables and equipment and associated non-safety circuits of redundant

trains by a horizontal distance of more than 20 feet with no intervening combustibles or

fire hazards;

e. Installation of fire detectors and an automatic fire suppression system in the fire area; or

f. Separation of cables and equipment and associated non-safety circuits of redundant

trains by a noncombustible radiant energy shield.

However, as a result of safe-shutdown focused inspections conducted in 2000, the NRC

identified that, in lieu of the methods specified in Paragraph lll.G.2, some licensees, including

ENO, were crediting operator manual actions (OMAs) to achieve and maintain safe shutdown in

the event of a fire impacting areas in which both trains of a safe-shutdown system or component

are co-located.

ln 2006, the NRC issued Regulatory lssue Summary 2006-10, Regulatory Expectations with

Appendix R, Paragraph lll.G.2, Operator ManualActions, which clarified Appendix R and that

OMAs are not permitted, unless they have been specifically approved by the NRC as part of a

licensee's request for exemption from the requirements of Paragraph lll.G.2. The NRC also

issued EGM 07-004 (ML071830345), which granted enforcement discretion for licensees relying

on OMAs and provided until March 6, 2009 for licensees to complete corrective actions.

Corrective actions included establishing compliance with fire protection regulations or, as

appropriate, submitting an exemption request to the NRC to implement OMAs in lieu of fire

protection regulations.

Enclosure 2

2

ln response to this issue, on March 6, 2009, ENO submitted exemption requests for Indian Point

Nuclear Generating Units 2 and 3 (M1090770151 and M1090760993) in which it sought

exemption from certain requirements of Paragraph lll.G.2, to permit the use of OMAs upon

which it had been relying for safe-shutdown in a number of fire areas. Because the acceptability

of the OMAs was being considered under this exemption request, enforcement discretion

continued for the duration of the NRC review. The NRC considered ENO's exemption requests,

as supplemented by information provided by ENO in response to NRC requests for additional

information.

The period of enforcement discretion for noncompliance with NRC fire protection requirements

at lndian Point Nuclear Generation Units 2 and 3 ended with the NRC issuance of the

February 1,2012,letters (ML112140509 and ML112200442) documenting completion of the

NRC review. The NRC recognized that ENO implemented additional compensatory measures

(fire watches in all affected fire areas) to enhance the fire protection response in the areas. In a

triennial fire protection inspection in June 2011 (ML111920339), NRC inspectors assessed the

feasibility of these compensatory measures. In addition, NRC fire protection inspections have

verified that Indian Point Nuclear Generating Units 2 and 3 have implemented a defense-in-

depth fire protection program, including a site fire brigade, that is trained and equipped to

respond to and fight fires.

In order to determine how the denied OMAs affected ENO's compliance with Appendix R

requirements, the NRC requested information from ENO about the schedule and plans for

bringing Indian Point Nuclear Generating Units 2 and 3 into full compliance (M112031A176).

ENO responded on March 1,2012 (Mt12074A028) with a proposed schedule that showed full

restoration of compliance for all but two of the OMAs by the fourth quarter of 2012, and for the

finaltwo OMAs by the Unit 2 refueling outage in Spring 2014.

This report presents the results of a problem identification and resolution annual follow-up of

selected issues inspection conducted in accordance with NRC Inspection Procedure (lP) 71152,

Problem ldentification and Resolution to review ENO's implementation of corrective actions to

restore full compliance regarding the use of OMAs.

The objectives of this inspection were to:

a. Assess the adequacy of compensatory measures for unapproved OMAs;

b. Verify commitments to resolve all unapproved OMAs were appropriately entered into the

corrective action program (CAP);

c. Review updates to procedures, OMA feasibility and reliability studies, and safe-

shutdown analyses; and,

d. Review progress to date and the proposed schedule for restoring compliance.

Specific documents reviewed by the inspectors are listed in the attachment.

Enclosure 2

4. OTHER ACTTVTTIES [OAl

4OA2 Problem ldentification and Resolution (71152- 1 sample)

a. Inspection Scope

The inspectors assessed ENO's problem identification threshold, extent of condition

reviews, compensatory actions, and timeliness of corrective actions to determine

whether ENO was appropriately identifying, evaluating, and correcting problems

associated with unapproved OMAs.

The inspectors reviewed the fire hazard analysis, safe shutdown analysis and supporting

licensing and design basis documents to understand the structures, systems, and

components required for fire safe shutdown. The inspectors reviewed the fire safe

shutdown operating procedures to verify that all OMAs were either granted an exemption

or were being addressed by the corrective action program. The inspectors reviewed

condition reports to evaluate the adequacy of evaluations and corrective actions with

respect to the denied OMAs. The fire protection engineer and safe shutdown engineer

were interviewed to evaluate the feasibility of the proposed plan to restore compliance

and to assess corrective actions taken to date.

The inspectors previously walked down all denied OMAs as part of the 2011 triennial fire

protection inspection to assess the feasibility of the OMAs. The inspectors walked down

portions of the OMAs to re-validate the feasibility of the actions. The inspectors walked

down all fire zones that credited denied OMAs to assess the fire risk significance which

can be affected by ignition sources, transient and fixed combustibles, or absence of train

separation, detection, and automatic suppression.

The inspectors reviewed condition reports, fire watch logs, and fire protection program

impairment requirements to verify that compensatory measures in the form of fire

watches were being adequately performed as required by the fire protection program.

b. Findinos

1. Failure to Protect Safe Shutdown Eouipment from the Effects of Fire (Unit 2)

lntroduction. The inspectors identified a finding of very low safety significance (Green),

involving a cited violation of Indian Point Unit2 Operating License Condition 2.Kto

implement and maintain all aspects of the approved fire protection program.

Specifically, ENO failed to protect required post-fire safe shutdown components and

cabling to ensure one of the redundant trains of equipment remained free from fire

damage as required by 10 CFR Part 50, Appendix R, Section lll.G.2. In lieu of

protecting a redundant safe shutdown train, ENO utilized unapproved operator manual

actions to mitigate component malfunctions or spurious operations caused by postulated

single fire-induced circuit faults. ENO submitted an exemption request (M1090770151)

on March 6, 2009, in which it sought exemption from requirements of Paragraph lll.G.2,

to permit the use of OMAs upon which it had been relying for safe-shutdown in a number

of fire areas. However, several OMAs within the exemption request were denied

Enclosure 2

4

because ENO failed to demonstrate that the OMAs were feasible and reliable, or to

appropriately evaluate fire protection defense-in-depth. ENO's performance deficiency

delayed achieving full compliance with fire protection regulations and adversely affected

post-fire safe shutdown.

Description. On June 30, 2006, the NRC issued Regulatory lssue Summary (RlS)

2006-10, Regulatory Expectations with Appendix R, Paragraph lll.G.2, Operator Manual

Actions, which clarified Appendix R and that OMAs are not permitted, unless they have

been specifically approved by the NRC as part of a licensees request for exemption from

the requirements of Paragraph lll.G.2. In addition to information provided to the

licensees in RIS 2006-10, the NRC issued enforcement guidance memorandum (EGM)07-004, which granted enforcement discretion for licensees relying on noncompliant

OMAs to bring themselves back into compliance with the existing regulations, The

enforcement discretion provided licensees until March 6, 2009, to complete their

corrective actions.

ENO submitted exemption requests on March 6, 2009 for OMAs in several non-

compliant fire areas. The NRC considered ENO's exemption requests, as supplemented

by information provided by ENO in response to NRC requests for additional information.

On February 1,2012, the NRC denied many of the requested exemptions based on lack

of fire protection defense-in-depth, such as detection or automatic suppression, or lack

of time margin available to complete the OMA. The NRC's denial of several OMAs

within the exemption requests was based on guidance to the NRC staff and available to

the industry. NUREG 1852, Demonstrating the Feasibility and Reliability of OMAs in

Response to Fire, published October 2007, page 1-2, states that additional

considerations to ensure that adequate defense-in-depth such as fire detection and

suppression is maintained are addressed in Regulatory Guide (RG) 1 .189 and should be

considered when applying for an exemption or license amendment. RG 1 .189, Fire

Protection Program for Nuclear Power Plants, Rev. 1, March 2007, (in effect when

NUREG 1852 was issued) Section 5.3.3 similarly states that allfire-related operator

manual actions must be feasible and reliable. RG 1 .189 further states that the use of

operator manual actions does not obviate the detection and suppression capabilities that

are required by the regulations and in addition, the omission or elimination of these

capabilities in an area containing systems, structures, or components (including circuits)

important to safety would generally be considered an adverse effect on safe shutdown

since it would reduce, at a minimum, fire protection defense-in-depth.

ENO's failure to demonstrate that several OMAs were feasible and reliable, and to

appropriately evaluate fire protection defense-in-depth delayed achieving full compliance

with fire protection regulations and adversely affected post-fire safe shutdown. ENO

entered this issue into its CAP for long term resolution as CR-lP2-2012-00654. Interim

compensatory measures for the fire protection non-compliances included roving fire

watches in all affected fire areas and were initiated in June 2011. The inspectors

considered the interim compensatory measures reasonable pending final resolution.

ENO responded to the NRC in a letter dated March 1,2012 (ML120744028) with a

proposed schedule to resolve all Unit 2 non-compliances for all but two of the OMAs by

the fourth quarter o12012, and for the remaining two OMAs by the Unit 2 refueling

outage in Spring 2014.

Enclosure 2

5

Additionally, the inspectors identified that ENO failed to identify two OMAs that were

being relied upon to achieve and maintain safe shutdown in the event of a fire impacting

FZFlTA. During plant walkdowns, the inspectors noted an emergency control station

within the 480V switchgear room that provided an isolation function and start and stop

controls for the 21 charging pump. Entergy engineers informed the inspectors that the

emergency control station was installed as a plant modification under ER-lP2-03-21959

in 2003 to address a previously identified Appendix R cable separation concern in fire

zone (FZ) F/7A. The emergency control station isolates control circuits that terminate at

a local control panel for the charging pumps. The 21 charging pump can be isolated

from the effects of a fire in FZFITA and started in the 480V switchgear room from the

emergency control station. Entergy failed to include this unapproved operator manual

action in its exemption request submitted on March 6,2009 (M1090770151). During

interviews with Entergy engineers regarding the charging pump local control panel and

its impact on charging pump operation for a fire in FZ F 17 A, the inspectors also identified

that an additional OMA was necessary to operate the 21 charging pump. The additional

OMA required local operation of the 21 charging pump scoop tube positioner to control

the 2l charging pump speed. Entergy promptly entered these missed OMAs into its

corrective action program as CR-lP2-2012-03024 and verified the OMAs were feasible

and reliable and noted that fire watches as compensatory measures for other OMAs

within this fire zone remained in place. The inspectors considered Entergy's

compensatory measures and immediate corrective actions adequate for the missed

OMAs. Similar to the denied OMAs, Entergy planned to resolve the missed OMAs and

establish compliance with 10 CFR Part 50, Appendix R, Section lll.G.2.

Analvsis. The inspectors identified a performance deficiency in that ENO failed to

protect components credited for post-fire safe shutdown from fire-induced damage. The

denied OMAs, as well as the missed OMAs, were considered a single performance

deficiency as the apparent causalfactors were related, an inadequate review and

evaluation of operator manual actions, and also occurred when the exemption request

was submitted to the NRC on March 6, 2009. The performance deficiency was more

than minor because it was associated with the Protection against External Events (Fire)

attribute of the Mitigating Systems Cornerstone and negatively affected the objective to

ensure the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences in the event of a fire. Specifically, the use

of OMAs during post-fire shutdown is not as reliable as normal system operation from

the main control room which would be utilized had the requirements of 10 CFR Part 50,

Appendix R, Section 11,,.G2 been met. The inspectors used IMC 0609, Appendix F, Fire

Protection Significance Determination Process, Phase 1 and a Senior Reactor Analyst

conducted a Phase 3 evaluation, to determine that this finding was of very low safety

significance (Green). This finding does not have a cross cutting aspect because the

performance deficiency occurred greater than three years ago when the exemption

request was submitted to the NRC on March 6, 2009, and is not indicative of current

licensee performance.

The inspectors determined the issue did not screen to Green with a Phase 1 SDP

because the finding category was post-fire safe shutdown and involved operator manual

actions. A Phase 3 SDP was performed by a Senior Reactor Analyst (SRA) because the

Fire Protection Phase 2 SDP is intended to support the assessment of known issues

Enclosure 2

6

only in the context of an individual fire area and this issue involved multiple fire areas

and fire zones. However, the SRA determined the Phase 2 SDP tools could be used on

an area by area basis to inform the Phase 3 SDP and screen fire zones if a sufficient

basis was developed for each fire zone and justified an absence of credible fire

scenarios such that mitigating equipment or its associated cables would not be damaged

or a plant transient would not occur. Guidance in each attachment of IMC 0609,

Appendix F was applied in addition to the following assumptions specific for lndian Point

Nuclear Generating Unit 2 cable construction and detail:

All cables are treated as thermoplastic with damage potential described in Tables

A7.2 and 47.3:

All cables are jacketed with an asbestos braid and do not act as intervening

combustibles or contribute to fire spread; and,

Asbestos cable jacket is not credited as a thermal or radiant heat shield.

The inspectors walked down each of the individual fire zones to identify potential fire

damage scenarios to circuits that were not protected to the requirements of 10 CFR Part 50, Appendix R, Paragraph lll.G.2. For the vapor containment fire area and its

associated operator manual actions, the inspectors reviewed a video that was recorded

by the licensee in the previous Unit 2 refueling outage specifically for this inspection

purpose and at the request of the NRC inspectors.

A summary of the risk evaluation for each OMA and its associated denied or missed

OMAs is in a table at the end of this Analysis section. In general, all of the fire zones

except FZFI6 screened out because:

Detailed circuit and cable analysis demonstrated that cable damage could not

cause spurious operations to credited safe shutdown equipment. The safe

shutdown analysis that was used by ENO to formulate conclusions on the

protection of safe shutdown capability in their exemption request was overly

conservative. Because damage to these cables would not cause a malfunction

of safe shutdown equipment, the associated OMAs were unnecessary and were

not violations of 10 CFR Part 50, Appendix R, lll.G.2.;

An ignition source did not exist that could credibly cause cable damage. The

cables were sufficiently separated from all fixed ignition sources to not be

damaged from thermal or radiant heat and a transient fire with an assumed origin

two feet above the floor would also not generate sufficient thermal or radiant heat

to damage cables at their high elevations; or,

The only credible ignition source was a transient combustible fire and the

associated weighting factor was very low, i.e., the critical floor area was much

smaller than the plausible floor area for the assumed transient combustible fire.

For fire zone FG and its associated denied OMA, OMA 6, the postulated fire resulted

from an oil leak of the 22 charging pump fluid drive causing damage to the pump itself

and the cabling associated with the operation and controls for the charging pump suction

valves. There are two suction paths available to the charging pumps: 1) the volume

control tank (VCT) from a normally open motor operated valve (MOV) 112C which is

physically located in the VCT room, and 2) the refueling water storage tank (RWST) from

Enclosure 2

7

a normally closed air operated valve (AOV) 1128, which is located in the 22 charging

pump cellor FZFl6. Valve 112B is designed to open automatically in the event of a low

VCT level through 1 128 valve position monitoring circuitry. Under these conditions,

1 12C would also close. The fire was conservatively assumed to render 1128 failed

closed and close 1 12C due to cable damage to the 1 128 position monitoring circuit. The

denied OMA 6 included actions within FZ Fl6 to locally open the 1128 bypass valve 288

and in the VCT room to verify closed 112C. These actions were necessary to align the

RWST as a suction source before starting the credited 21 charging pump from the main

control room.

Due to uncertainties involved in fire induced core damage assessment, the SRA

conducted two bounding analyses: 1) a fire model case based on fire modeling which

assumed that only equipment in the subject fire area was potentially damaged and all

other equipment failed probabilistically, and 2) an Appendix R case where only

equipment credited in the safe shutdown analysis was available. For the Phase 3 SDP

results, the SRA chose the fire model case as it represented the more realistic plant and

operator response to a potential fire in FZFl6.

Both analyses were conducted for FZ F/6 using the lP2 SPAR model version 8.20 to

estimate the increase in conditional core damage probability if the denied OMAs were

needed vice not needed and Appendix R requirements were met such that all mitigating

operations were available from the control room. The lP2 SPAR model credits the

charging pumps as an emergency boration source during an anticipated transient

without scram (ATWS) and as a source of reactor coolant pump (RCP) seal injection.

RCP seal injection along with the RCP thermal barrier cooling from the closed cooling

water system (CCW) provides RCP seal cooling and precludes a RCP sealfailure loss

of coolant accident. This core damage analysis differed from the Appendix R guidelines

to maintain or restore RCS pressurizer level. An independent Region I SRA reviewed

and found acceptable the SPAR model changes made to conduct these analyses. Both

analyses assumed that a fire in FZFI6 would:

Occur at a frequency of 5.0E-5 per year consistent with Attachment 4 of the Fire

Protection SDP for a pump oilfire;

a Only occur if the 22 charging pump was running;

a Fail the 22 charging pump;

a Fail1128 closed; and,

a Result in operator responses in accordance with procedures;

o A manually initiated reactor trip, which was reflected as a transient

initiation event; and,

o Removing pressurizer power operated relief valve (PORV) control power

fuses in the control room to prevent spurious PORV operation. This

action was assumed always successful. For ATWS sequences, it was

assumed that all PORVs and RCS safety valves would be open and that

operators would not remove fuses to close the PORVS, but would

continue to recover a charging pump and establish emergency boration.

Enclosure 2

I

The fire model analysis estimated an increase in the core damage frequency less than

1E-9, if the OMAs were not successful, given the estimated22 charging pump lube oil

fire occurred at a frequency of 5E-5 per year and the very limited credit afforded the

charging pumps in core damage mitigation. The dominating core damage sequence

involving the OMAs was an ATWS following the manual reactor trip caused by

mechanical binding of all the control rods, and a failure of operators to manually open

288 to establish emergency boration with the 21 charging pump. The negligible increase

in core damage frequency was also due to the extremely low probability of an ATWS

where emergency boration would be necessary or a common cause failure of the service

water system which would lead to a RCP seal failure. This analysis allowed normal

plant equipment to remain functional provided it was not damaged as a result of the fire

scenario based on fire modeling. The fire model analysis assumed that a fire in FZFI6

would:

. Fail 112C closed with the probability of an intra-conduit hot short of 0.05, based

on NUREG/CR-6850. Fail112C open with a 0.95 probability. lf 112C failed

open, it must be closed to restore the RWST suction to the 21 charging pump.

. Not generate a damaging hot gas layer nor damage any equipment in the

adjacent primary auxiliary building corridor, FZFlTA. This assumption was

based on fire modeling.

. Result in control room operators in accordance with procedure promptly disabling

the 21 charging pump from automatic operation. This action is required by

procedure to preclude damage to the 21 charging pump should it operate without

a water source aligned to its suction as the result of spurious^valve operations. A

failure probability of 1.1E-2 was assumed based on SPAR-H', assuming

diagnosis and allfactors in their nominal state.

. Result in operators implementing the denied OMAs in accordance with

procedures and specifically aligning the RWST to the charging pumps suction

after the fire is extinguished and includes:

o Manually opening valve 288 with a failure probability of 2.3E-l assumed

based on SPAR-H with all factors in their nominal state except for high

stress and conservatively assuming barely sufficient time.

o Verify or close 1 12C with a failure probability o'f 2.3E-1 assumed based

on SPAR-H with all factors in their nominal state except for high stress

and conservatively assuming barely sufficient time.

. Result in control room operators, starting the 21 charging pump, in accordance

with procedure, once suction to the RWST was aligned by the OMAs. A failure

probability of 1.1E-2 was assumed based on SPAR-H assuming diagnosis and

all factors in their nominal state.

The Appendix R analysis estimated an increase in the core damage frequency in the

mid-E-7 range. The Appendix R analysis assumed no credit afforded the charging

pumps in the dominating core damage sequence. In the Appendix R analysis, the

OMAs did not impact the core damage frequency results. The dominating core damage

sequence involved a RCP loss of seal cooling event leading to a small loss of coolant

accident due to RCP sealfailure at a leak rate of 182 gpm per RCP and successful

operation of the 21 AFW train. Although 21 AFW was successful, core damage occurs

because the reactor cannot be depressurized because PORV fuses are removed by

Enclosure 2

9

procedure failing the PORVs closed, and high pressure coolant injection is assumed to

have failed in the Appendix R analysis. lf a loss of RCP seal cooling does not occur, the

dominant core damage sequence included failure of the 21 AFW train (in the range of

1 in 125) and the inability, using high pressure coolant injection and the PORVs (feed

and bleed), to remove decay heat. The Appendix R analysis assumed that a fire in the

FZF16 would:

. Cause a loss of RCP seal cooling and subsequent RCP sealfailure. A loss of

RCP seal cooling occurred due to the fire induced closures of 112C and a CCW

system MOV in the RCP thermal barrier cooling flow path. In this case, with a

fire in the 22 charging pump cell, operators would not be able to open valve 288

to establish a suction path to the 21 charging pump in sufficient time to prevent

the assumed RCP sealfailure.

. Cause a failure of all equipment within fire area F including:

o Both trains of high pressure injection.

o 22train of low pressure injection.

o Motor control centers 264 and 268.

o Cause failure of the 22 motor driven and 23 turbine driven AFW pumps.

The table below summarizes the results for each OMA with its respective fire zone:

Indian Point Unit 2 Denied OMA Summary Table

Fire OMA No.' Violation of lll.G.2 Risk

Area/ lncrease

Zone Comments Results

F/5A No Based on circuit reviews, cables of interest within this No increase

FZ do not result in a spurious operation that

necessitates this OMA.

Ft6 Yes This area required a detailed phase 3 SDP analysis. Negligible

The inspectors assumed a 5200kW fire from 54 increase

gallons of oil leaked from the 22 charging pump fluid based on

drive within a 40 sqft skid 15.5ft directly below cable detailed

YZ1-J85. Details of the phase 3 SDP analysis are Phase 3

described in the analysis section prior to this table. SDP

analysis

No Based on circuit reviews, cables of interest within this No increase

FZ do not result in a spurious operation that

necessitates this OMA.

FITA Yes There were no fixed or assumed transient Screened

combustible ignition sources that could credibly based on

damage cable YZ1-JB1 which is located 14ft above Phase 2

the floor. SDP tasks

Enclosure 2

10

Based on circuit reviews, cables of interest within this No increase

FZ do not result in a spurious operation that

necessitates this OMA.

The only credible ignition source was a transient Screened

combustible fire and the associated transient based on

weighting factor was very low, i.e. an 8sqft critical Phase 2

floor area compared to 6000sqft plausible floor area SDP tasks

equals a 2.3E-7 area weighting factor.

Yes See above, same as FlTA for OMA 20. Screened

based on

Phase 2

SDP tasks

No Based on circuit reviews, cables of interest within this No increase

FZ do not result in a spurious operation that

necessitates this OMA,

Ft27A 5 Yes This OMA involves opening a manual valve, 227, to Screened

align a charging path to the reactor coolant system if based on

the normally open air operated valve, HCY-l42, were Phase 2

to close from a loss of instrument air (lA). Circuits to SDP tasks

HCV-142 do not route through the associated FZs.

Therefore this OMA is only necessary for a fire

induced loss of lA. The inspectors walked down

each FZ and did not identify any lA lines near ignition

sources. Additionally, a loss of lA resulting from the

spurious operation of several lA loads and a

subsequent high demand on the lA system would

require multiple spurious operations.

F/33A 6 Yes The only credible ignition source to cable CK1-YP3, No increase

power supply cable to 112C, is the motor control

center where CK1-YP3 terminates. This is a fire

damage state zero scenario (FDSO). FDSO

scenarios are not analyzed in the SDP as a risk

contributor. See step 2.2 of IMC 0609, Appendix F.

5 Yes See above, same as Fl27A for OMA 5. Screened

based on

Phase 2

SDP tasks

F/594 5 Yes See above, same as Fl27 A for OMA 5. Screened

based on

Phase 2

SDP tasks

Enclosure 2

11

Ht72A I Yes This FZ is in the vapor containment (VC) and was Screened

not accessible to the inspectors for walkdown, NRC based on

inspectors walkdown the VC as part of the baseline Phase 2

inspection program following plant outages and just SDP tasks

prior to plant startup in part to verify the licensee has

thoroughly removed all outage materials and

combustibles. The licensee performs similar

inspections prior to startup. The inspectors observed

the FZ using a video recording taken by the licensee

during the most recent refuel outage. Additionally,

the inspectors reviewed the spatial separation

between ignition sources and cables of concern as

described in ENO's September 29,2010 response to

the NRC's request for additional information on

August 1 1, 2010 (ML1 02930237).

Hl75A 8,9, 10 Yes See above, same as Hl72A for OMA 8. Screened

based on

Phase 2

SDP tasks

Hl77 A 8, 9, 10 Yes See above, same as Hl72A for OMA 8. Screened

based on

Phase 2

SDP tasks

H/84A 8 Yes See above, same as Hl72A for OMA 8. Screened

based on

Phase 2

SDP tasks

H/85A 8 Yes See above, same as Hl72A for OMA 8. Screened

based on

Phase 2

SDP tasks

Hl87 A 8, 9, 10 Yes See above, same as Hl72A for OMA 8. Screened

based on

Phase 2

SDP tasks

Jt19 11 No Based on circuit reviews, cables of interest within this No increase

FZ do not result in a spurious operation that

necessitates this OMA.

Jt25 12 No See above, same as J/19 for OMA 11. No increase

J/39A 11,12

No See above, same as J/19 for OMA 11. No increase

Enclosure 2

12

Jl43A 11, 12, 13 No See above, same as J/19 for OMA 11. No increase

Jt45A 11 No See above, same as J/19 for OMA 11. No increase

Jl46A 11, 12, 13 No See above, same as J/19 for OMA 1 1. No increase

Jl47A 11 No See above, same as J/19 for OMA 11. No increase

J/50A 11,12 No See above, same as J/19 for OMA 11. No increase

J1270 12 No See above, same as J/19 for OMA 11. No increase

K60A 14,15, 19 Yes Based on circuit reviews there are no cables within Screened

these FZs that also result in a loss of main feedwater based on

with the assumed fire-induced loss of auxiliary Phase 2

feedwater from cable damage. Therefore a fire SDP tasks

within this fire zone will not result in a plant transient

from spurious operations.

l(654 14,15,19 Yes Based on circuit reviews there are no cables within Screened

these FZs that also result in a loss of main feedwater based on

with the assumed fire-induced loss of auxiliary Phase 2

feedwater from cable damage. Therefore a fire SDP tasks

within this fire zone will not result in a plant transient

from spurious operations.

1As

identified in table on pages 1 through 4 of Attachment 1 to ENO response letter to the NRC

dated March 1,2012 (M112074A028). OMAs 20 and 21 were NRC identified during plant

walkdowns and are described in the following list.

Description of Indian Point Unit 2 Denied OMAs

5. Open HCV-142 bypass valve 227 to align charging pump makeup path to the reactor

coolant system (RCS).

6. Align charging pump suction source to the refueling water storage tank (RWST).

7. Transfer instrument buses 23 and 23A to alternate power.

8. Fail open valves 2044 (charging flow to the RCS loop 2 hot leg) and 2Q4B (charging flow

to RCS loop 1 cold leg) to align charging pump makeup path to the RCS.

9. Activate or enable alternate safe shutdown system (ASSS) pneumatic instruments

(steam generator level, pressurizer pressure and pressurizer level) at the fan house local

control panel.

10. Enable ASSS source-range channel and RCS loop 21 and 22 hot leg and cold leg

temperature channels.

Enclosure 2

13

11. Trip breakers 52l5A and 52-SAC on Bus 5A and 5216A and 52ffAO at Bus 64 and

remove control power fuses.

12. Transfer instrument buses 23 and 23A to emergency power source.

13. Align charging pump suction to the RWST.

14. Operate transfer switch EDCS and close supply breaker at substation 12FD3 to transfer

the 2l auxiliary feedwater pump (AFW) to the ASSS power source.

15. Open the 21AFW pump recirculation bypass valve BFD-77.

19. Operate the 21AFW pump flow control valves to control AFW flow to steam generators

21 and 22.

20. Locally operate the 21 charging pump scoop tube positioner. OMA 20 was NRC

identified during plant walkdowns and its use in lieu of meeting 10 CFR Part 50,

Appendix R, Section lll.G.2 requirements was not included in the exemption request

submitted to the NRC on March 6, 2009 (M1090770151).

21. Locally start the 21 charging pump using the emergency control station located in the

480V switchgear room. OMA 21 was NRC identified during plant walkdowns and its use

in lieu of meeting 10 CFR 50, Appendix R, Section lll.G.2 requirements was not included

in the exemption request submitted to the NRC on March 6, 2009 (M1090770151 ).

Enforcement. Indian Point Unit 2 Operating License Condition 2.K specifies, in part, that

Entergy Nuclear Operations, lnc., shall implement and maintain in effect all provisions of

the approved Fire Protection Program as described in the Updated Final Safety Analysis

Report. The Updated Final Safety Analysis Report, Section 9.6 specifies that ENO will

meet the requirements of 10 CFR Part 50, Appendix R, Section lll.G.2 which identifies

the means of protecting post-fire safe shutdown equipment from fire damage. Contrary

to the above, between June 30, 2006 and April 26, 2012, ENO failed to implement their

fire protection program by using one of the means described in Appendix R,

Section lll.G.2 to protect circuits required for post-fire safe shutdown from fire-induced

circuit damage. Specifically, ENO used unapproved operator manual actions to mitigate

post-fire safe shutdown equipment malfunctions without having obtained NRC approval.

The specific operator manual actions and fire areas and fire zones that are in violation of

Appendix R, Section lll.G.2 are listed in the Indian Point Unit 2 Denied OMA Summary

Table of this inspection report. This finding is being cited because not all of the criteria

specified in Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation were

satisfied. Specifically, ENO failed to restore compliance within a reasonable amount of

time after the violation was identified in RIS 2006-10 on June 30, 2006.

VfO 0500024712012009-01, Failure to Protect Safe Shutdown Equipment from the

Effects of Fire.

Enclosure 2

14

2. Failure to Protect Safe Shutdown Equipment from the Effects of Fire (Unit 3)

Introduction. The inspectors identified a finding of very low safety significance (Green),

involving a cited violation of lndian Point Unit 3 Operating License Condition 2.H to

implement and maintain all aspects of the approved fire protection program.

Specifically, ENO failed to protect required post-fire safe shutdown components and

cabling to ensure one of the redundant trains of equipment remained free from fire

damage as required by 10 CFR Part 50, Appendix R, Section lll.G.2. In lieu of

protecting a redundant safe shutdown train, ENO utilized unapproved operator manual

actions to mitigate component malfunctions or spurious operations caused by postulated

single fire-induced circuit faults. ENO submitted an exemption request (M1090760993)

on March 6, 2009, in which it sought exemption from requirements of Paragraph lll.G.2,

to permit the use of OMAs upon which it had been relying for safe-shutdown in a number

of fire areas. However, several OMAs within the exemption request were denied

because ENO failed to demonstrate that the OMAs were feasible and reliable, or to

appropriately evaluate fire protection defense-in-depth. ENO's performance deficiency

delayed achieving full compliance with fire protection regulations and adversely affected

post-fire safe shutdown.

Descriotion. On June 30, 2006, the NRC issued Regulatory lssue Summary (RlS)

2006-10, Regulatory Expectations with Appendix R, Paragraph lll.G.2, Operator Manual

Actions, which clarified Appendix R and that OMAs are not permitted, unless they have

been specifically approved by the NRC as part of a licensees request for exemption from

the requirements of Paragraph lll.G.2. In addition to information provided to the

licensees in RIS 2006-10, the NRC issued enforcement guidance memorandum (EGM)07-004, which granted enforcement discretion for licensees relying on noncompliant

OMAs to bring the facility back into compliance with the existing regulations. The

enforcement discretion provided licensees until March 6, 2009, to complete corrective

actions,

ENO submitted exemption requests on March 6, 2009 for OMAs in several non-

compliant fire areas. The NRC considered ENO's exemption requests, as supplemented

by information provided by ENO in response to NRC requests for additional information

and on February 1,2012, the NRC denied many of the requested exemptions based on

lack of fire protection defense-in-depth, such as detection or automatic suppression, or

lack of time margin available to complete the OMA. The NRC's denial of several OMAs

within the exemption requests was based on guidance to the NRC staff and available to

the industry. NUREG 1852, Demonstrating the Feasibility and Reliability of OMAs in

Response to Fire, published October 2007 , page 1-2, states that additional

considerations to ensure that adequate defense-in-depth such as fire detection and

suppression is maintained are addressed in Regulatory Guide 1.189 and should be

considered when applying for an exemption or license amendment. RG 1.189, Fire

Protection Program for Nuclear Power Plants, Rev. 1, March 2007, (in effect when

NUREG 1852 was issued) Section 5.3.3 similarly states that allfire-related operator

manual actions must be feasible and reliable. RG 1 .189 further states that the use of

operator manual actions does not obviate the detection and suppression capabilities that

are required by the regulations and in addition, the omission or elimination of these

capabilities in an area containing systems, structures, or components (including circuits)

Enclosure 2

15

important to safety would generally be considered an adverse effect on safe shutdown

since it would reduce, at a minimum, fire protection defense-in-depth.

ENO's failure to demonstrate that several OMAs were feasible and reliable, and to

appropriately evaluate fire protection defense-in-depth delayed achieving full compliance

with fire protection regulations and adversely affected post-fire safe shutdown. ENO

entered this issue into its CAP for long term resolution as CR-lP3-2012-00369. lnterim

compensatory measures for the fire protection non-compliances included roving fire

watches in all affected fire areas and were initiated in June 2011. The inspectors

considered the interim compensatory measures reasonable pending final resolution.

ENO responded to the NRC in a letter dated March 1,2012, (M112074A028) with a

proposed schedule to resolve all Unit 3 non-compliances by the fourth quarter of 2012.

Analvsis. The inspectors identified a performance deficiency in that ENO failed to

protect components credited for post-fire safe shutdown from fire-induced damage. The

performance deficiency was more than minor because it was associated with the

Protection against External Events (Fire) attribute of the Mitigating Systems Cornerstone

and negatively affected the objective to ensure the availability, reliability, and capability

of systems that respond to initiating events to prevent undesirable consequences in the

event of a fire. Specifically, the use of OMAs during post-fire shutdown is not as reliable

as normal system operation from the main control room which would be utilized had the

requirements of 10 CFR Part 50, Appendix R, Section lfl.G.2 been met. The inspectors

used IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase

1 and an SRA conducted a Phase 3 evaluation, to determine that this finding was of very

low safety significance (Green). This finding did not have a cross cutting aspect

because the performance deficiency occurred greater than three years ago when the

exemption request was submitted to the NRC on March 6, 2009, and is not indicative of

current licensee performance.

The inspectors determined the issue did not screen with a Phase 1 SDP because the

finding category was post-fire safe shutdown and involved operator manual actions. A

Phase 3 SDP was performed by a Senior Reactor Analyst (SRA) because the Fire

Protection Phase 2 SDP is intended to support the assessment of known issues only in

the context of an individual fire area and this issue involved multiple fire areas and fire

zones. However, the SRA determined the Phase 2 SDP tools could be used on an area

by area basis to inform the Phase 3 SDP and screen firg zones if a sufficient basis was

developed for each fire zone and justified an absence of credible fire scenarios, such

that mitigating equipment or its associated cables would not be damaged or a plant

transient would not occur. Guidance in each attachment of IMC 0609, Appendix F was

applied in addition to the following assumptions specific for lndian Point Nuclear

Generating Unit 3 cable construction and detail:

. All cables are treated as thermoplastic with damage potential described in Tables

47.2 and 47.3;

. All cables are jacketed with an asbestos braid and do not act as intervening

combustibles or contribute to fire spread; and,

o Asbestos cable jacket is not credited as a thermal or radiant heat shield.

Enclosure 2

16

The inspectors walked down each of the individual fire zone to identify potentialfire

damage scenarios to circuits that were not protected to the requirements of 10 CFR

Part 50, Appendix R, Paragraph lll.G.2.

One of the unapproved OMAs which was associated with several fire zones was local

manual operation of the service water pump strainer backwash. This OMA was

determined to be beyond the scope of an OMA and was documented in a Green non-

cited violation in 201 1 (lnspection Report 05000286/201 1008, ML1 1 1920339), The very

low risk for this OMA was related to the very low likelihood of ever needing the strainer

backwash to operate during a post-fire safe shutdown. With the exception of

FZPAB 2{3}/6, all remaining fire zones and associated OMAs screened because there

were no fixed or assumed transient combustible ignition sources that could credibly

damage the cable of concern within the fire zones.

For FZ PAB-2{3/6, the 32 charging pump cubicle, the SRA assumed a lube oil fire while

the 32 charging pump was in operation damages cables to the volume control tank

(VCT) motor operated outlet valve (112C). The SRA compared differences between

Unit 2 and Unit 3 for the 22 and 32 charging pump cubicle fire scenarios. The only noted

differences between plant configurations or operating procedures was the 1128 valve

design and the fire zone configurations. The 1 128 valve at Unit 2 was a normally closed

air operated valve, and at Unit 3 the 1 128 valve was a normally closed motor operated

valve. At Unit 3, the 31 and 32 charging pumps were in the same fire zone (PAB-2{3yO),

but an exemption was previously granted that found the fire barriers between the

charging pump cubicles acceptable and the 31 charging pump was credited in the event

of a fire in the 32 charging pump cubicle. Both differences between the Unit22 and 32

charging pump fire scenario would not change the fire damage or risk analysis

assumptions. Because there was no applicable difference between the Unit 2 and Unit 3

charging pump fire scenario, the results of the Unit 2 detailed Phase 3 SDP analysis can

be used to determine that the increased risk from this fire scenario is negligible.

The table below summarizes the results for each OMA with its respective fire zone:

Indian Point Unit 3 Denied OMA Summary Table

Risk

Area/ Increase

Zone Comments Results

ETN- 6,8 Yes There were no fixed or assumed transient Screened

4{11/ combustible ignition sources that could credibly based on

7A damage the cable of concern in this area. Phase 2

SDP tasks

ETN- 5,6,8,9,10, Yes There were no fixed or assumed transient Screened

4{1ll 11,12 combustible ignition sources that could credibly based on

60A damage the cable of concern in this area. Phase 2

SDP tasks

Enclosure 2

17

13 Yes This OMA was previously identified as a violation Previously

during the last triennialfire protection inspection and evaluated

was documented in that report as a very low safety as very low

significance (Green) NCV.

ETN- 14,15,16, Yes There were no fixed or assumed transient Screened

4{3It 17 combustible ignition sources that could credibly based on

734 damage the cable of concern in this area. Phase 2

SDP tasks

PAB- 18 Yes This zone was described in detail in the analysis Negligible

2{3}l section above this table. based on

6 detailed

Phase 3

SDP

analysis

PAB- 22 Yes There were no fixed or assumed transient Screened

2{5ll combustible ignition sources that could credibly based on

174 damage the cable of concern in this area. Phase 2

SDP tasks

PAB- 19,20 Yes There were no fixed or assumed transient Screened

2{5}l combustible ignition sources that could credibly based on

19A damage the cable of concern in this area. Phase 2

SDP tasks

PAB- 22 Yes There were no fixed or assumed transient Screened

2{5}l combustible ignition sources that could credibly based on

204 damage the cable of concern in this area. Phase 2

SDP tasks

PAB- 22 Yes There were no fixed or assumed transient Screened

2{5ll combustible ignition sources that could credibly based on

274 damage the cable of concern in this area. Phase 2

SDP tasks

PAB- 22 Yes There were no fixed or assumed transient Screened

2{5Il combustible ignition sources that could credibly based on

304 damage the cable of concern in this area. Phase 2

SDP tasks

PAB- 21 Yes There were no fixed or assumed transient Screened

2{5}l combustible ignition sources that could credibly based on

59A damage the cable of concern in this area. Phase 2

SDP tasks

Enclosure 2

18

TBL- 25 Yes This OMA was previously identified as a violation Previously

5137A during the last triennialfire protection inspection and evaluated

was documented in that report as a very low safety as very low

significance (Green) NCV.

TBL- 25 Yes This OMA was previously identified as a violation Previously

5/38A during the last triennialfire protection inspection and evaluated

was documented in that report as a very low safety as very low

significance (Green) NCV.

TBL. 25 Yes This OMA was previously identified as a violation Previously

5t43A during the last triennialfire protection inspection and evaluated

was documented in that report as a very low safety as very low

significance (Green) NCV.

TBL- 25 Yes This OMA was previously identified as a violation Previously

5t44A during the last triennial fire protection inspection and evaluated

was documented in that report as a very low safety as very low

significance (Green) NCV.

TBL- 23,24 Yes There were no fixed or assumed transient Screened

5t52A combustible ignition sources that could credibly based on

damage the cable of concern in this area. Phase 2

SDP tasks

TBL- 24 Yes There were no fixed or assumed transient Screened

5t54A combustible ignition sources that could credibly based on

damage the cable of concern in this area. Phase 2

SDP tasks

YARD 26 Yes There were no fixed or assumed transient Screened

-71 combustible ignition sources that could credibly based on

222 damage the cable of concern in this area. Phase 2

SDP tasks

27 Yes This OMA was previously identified as a violation Previously

during the last triennialfire protection inspection and evaluated

was documented in that report as a very low safety as very low

significance (Green) NCV.

2As

identified in table on pages 1 through 5 of Attachment 2 to ENO response letter to the NRC

dated March 1, 2Q12 (ML1207 4A028).

Description of Indian Point Unit 3 Denied OMAs

5, Operate HCV-1118 manually to control 32 AFW pump.

6. Align Appendix R Diesel Generator (ARDG) to 480 V Buses 2A, 3,A, 5A, and 312.

Enclosure 2

19

8. Locally operate FCV-405B, FCV-405D, or FCV-406B to control AFW flow to Steam

Generators (SGs).

9. Locally open valve 227 to establish charging makeup flowpath to Reactor Coolant

System (RCS).

10. Locally close Level Control Valve (LCV)-1 12C and open valve 288 to align charging

pump suction to the Refueling Water Storage Tank (RWST).

11. Locally operate Pressure Control Valve (PCV)-1 139 to ensure steam supply to 32 AFW

pump.

12. Locally operate PCV-13104 and PCV-13108 to ensure steam supply to 32 AFW pump.

13. Locally manually perform Service Water (SW) pump strainer backwash as required.

14. Operate HCV-1118 manually to control 32 AFW pump.

15. Locally operate PCV-1 139 to ensure steam supply to 32 AFW pump.

16. Locally operate 32 PCV-1310A, PCV-13108 to ensure steam supply to 32 AFW pump.

17. Locally operate FCV-405C and FCV-405D to control AFW flow to SG.

18. Locally close valve LCV-1 12C and open valve 228 to align charging pump suction path

to RWST.

19. Locally close supply breaker 'for 32 Charging Pump.

2Q. Locally control 32 charging pump using scoop tube positioner.

21. Open bypass valve 227 to establish charging flowpath to RCS around potentially failed

closed HCV-142.

22. Locally close LCV-112C and open bypass valve 288 to establish flowpath from RWST to

charging pump suction.

23. Locally operate [bypass valve for] FCV-1121 AFW pump recirculation valve during pump

startup.

24. Locally operate FCV- 406A and FCV-406B to control AFW flow to SGs.

25. Locally/manually backwash SW pump strainer as required if power to strainer associated

with selected SW pump is lost.

26. Locally start ARDG to supply Motor Control Center (MCC) 312A in support of the use of

SW pump 38.

Enclosure 2

20

27. Locally/manually backwash SW Pump strainer as required if power to strainer

associated with selected SW pump is lost.

Enforcement. Indian Point Unit 3 Operating License Condition 2.H specifies, in part, that

Entergy Nuclear Operations, lnc., shall implement and maintain in effect all provisions of

the approved Fire Protection Program as described in the Final Safety Analysis Report.

The Final Safety Analysis Report, Section 9.6.2, specifies that ENO will meet the

requirements of 10 CFR Part 50, Appendix R, Section lll.G.2, which identifies the means

of protecting post-fire safe shutdown equipment from fire damage. Contrary to the

above, between June 30, 2006 and April 26, 2012, ENO failed to implement their fire

protection program by using one of the the means described in Appendix R,

Section lll.G.2, to protect circuits required for post-fire safe shutdown from fire-induced

circuit damage. Specifically, ENO used unapproved operator manual actions to mitigate

post-fire safe shutdown equipment malfunctions without having obtained NRC approval.

The specific operator manual actions and fire areas and fire zones that are in violation of

Appendix R, Section lll.G.2, are listed in the Indian Point Unit 3 Denied OMA Summary

Table of this inspection report. This finding is being cited because not all of the criteria

specified in Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation were

satisfied. Specifically, ENO failed to restore compliance within a reasonable amount of

time after the violation was identified in RIS 2006-10 on June 30, 2006.

VIO 0500028612012008-01, Failure to Protect Safe Shutdown Equipment from the

Effects of Fire.

Violation of Combustible Controls Proqram

lntroduction. The inspectors identified a Green, Non-Cited Violation (NCV) of the Indian

Point Nuclear Generating Unit No. 2 Amended Facility Operating License, Condition 2.K,

in that ENO failed to implement and maintain in effect all provisions of the NRC-

approved FPP as described in the Updated Final Safety Analysis Report (UFSAR).

Specifically, ENO failed to minimize transient combustible materials within the primary

auxiliary building (PAB) and stored a compressed gas cylinder containing hydrogen gas

under cable trays.

Description. While walking down electrical cables that were associated with denied

OMA exemptions, the inspectors identified a gas cylinder underneath cable trays in fire

zone (FZ) Fl7 A of the PAB. The gas cylinder was not in use, a valve protection cap was

installed, and the gas cylinder was chained to a corridor wall to prevent accidental

movement or tipping. The gas cylinder's contents were unknown and without label other

than a sticker indicating the contents were flammable.

ENO removed the gas cylinder from the PAB and evaluated its contents. The gas

cylinder was a mixture of 50 percent hydrogen and 50 percent nitrogen gasses and was

previously in service as a calibration gas for the waste gas analyzer in FZ F/8A of the

PAB. lt contained about 150 psig of gas. FZ FlSA is an authorized storage location for

an in service hydrogen calibration gas cylinder, and FZFITA is not an authorized storage

location for any hydrogen gas cylinders.

Enclosure 2

21

The storage of a hydrogen compressed gas cylinder in FZFITA of the PAB was not in

accordance with ENO procedure, Control of Combustibles, EN-DC-161, Rev. 6, and a

flammable compressed gas was not practically minimized. EN-DC-161, among other

requirements, requires plant workers to: 1) limit transient combustibles to those

materials and quantities necessary to support work activities, 2) not place transient

combustibles directly under cable trays, and 3)determine the need for a formal

Transient Combustible Evaluation (TCE).

ENO promptly entered this issue into its CAP as CR-lP2-2012-03036, and removed the

hydrogen cylinder from the PAB. ENO initiated a corrective action to evaluate the

identified condition and ensure actions to prevent its recurrence.

Analvsis. ENO's failure to remove the compressed hydrogen gas cylinder from the PAB

after its intended use as a calibration gas for the waste gas analyzer was a performance

deficiency. This finding was more than minor because it was associated with the

External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely

affected the cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences (i.e., core

damage). Specifically, the hydrogen gas cylinder was stored below cable trays in an

area that includes safe shutdown circuits and the associated cables were at increased

risk to fire damage. The inspectors used IMC 0609, Appendix F, Fire Protection

Significance Determination Process, Phase 1 and a Senior Reactor Analyst conducted a

Phase 3 evaluation, to determine that this finding was of very low safety significance

(Green). The inspectors determined that this finding had a cross-cutting aspect in the

area of Human Performance associated with the work practice attribute because ENO

personnel did not follow procedure, Control of Combustibles, EN-DC-161, Rev. 6, as

written and did not remove the hydrogen gas cylinder from the PAB after it was

disconnected from the waste gas analyzer contrary to Control of Combustibles,

EN-DC-161, Rev.6. (H.4(b) per IMC 0310).

The inspectors used Attachment 2 of IMC 0609, Appendix F, Fire Protection Significance

Determination Process (SDP), and assigned a high degradation rating for this

combustible controls program finding. Accordingly, this finding did not screen to Green

in Phase 1 of IMC 0609, Appendix F, and a Phase 3 analysis was performed by a Senior

Reactor Analyst (SRA) using similar assumptions and methodologies as the denied

OMA findings.

Conduct of the phase 3 SDP included identifying the damage that could result based on

detailed plant walkdowns, review of ENO provided circuit information, fire modeling

evaluation of potential damage to plant equipment, and use of probabilistic fire analysis

methods documented in NRC Inspection Manual Chapter 0609, Appendix F, "Fire

Protection SDP" and NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for

Nuclear Power Facilities." The SRA analyzed the risk of a single hydrogen gas cylinder

fire located directly below the cables in FZFITA that may cause the charging pumps to

lose suction by closing the volume control tank (VCT) outlet valve (112C). Because the

hydrogen compressed gas cylinder was stored along a PAB corridor in FZFITA without

controls or regards to its combustibility or flammability, the SRA assumed for the

purposes of analyzing risk from fire, that the hydrogen gas cylinder was located directly

Enclosure 2

22

beneath cables that if damaged may spuriously close 112C. Closure of 112C causes

the charging pumps to lose suction and OMAs are required to restore the VCT suction or

align the refuel water storage tank (RWST) as an alternate source by opening air

operated valve 1128. The normally open 112C is physically located in the VCT room,

not in FZFlTA, and the normally closed 1128, is located in the 22 charging pump cell

FZFl6. Valve 1128 is designed to open automatically in the event of a low VCT level,

which through 1128 valve position monitoring circuitry would cause the normal VCT

suction valve 1 12C to close. The 1 128 valve position monitoring circuit cable runs from

FZFl6, where 1128 is located, through FZFITA. The fire is assumed to result in 1128

failing to open due to direct power supply cabling damage and 1 12C failing closed due to

damage to the 1128 position monitoring circuit wiring. The denied OMAs tor FZFITA

were used in this analysis. These OMAs included the manual opening of the 1 128

bypass valve (288), the verification or closure of 112C, and starting the 21 charging

pump, after the RWST suction is aligned, using the emergency control station in the

480V switchgear room.

The SRA conducted a detailed probabilistic analysis tor FZ F/7A, using the lP2 SPAR

model version 8.20 to estimate the conditional core damage probability if the fire were to

occur. This analysis represented a fire model estimate that allowed normal plant

equipment to remain functional if it would not be damaged based on fire modeling of the

actual plant configuration. The analysis determined a negligible increase in core

damage frequency (less than 1 in one billion years), given an estimated 6.5E-4 per year

fire frequency (consistent with Attachment 4 of the Fire Protection SDP for a hydrogen

storage tank) and the conditional core damage probability calculated (if the performance

deficiency had not occurred there was no credible ignition source). An independent

Region I SRA reviewed and found acceptable the SPAR model changes made to

conduct the analysis, which were based on following assumptions that a fire in FZFITA

would:

o Cause operators to manually initiate a reactor trip from the control room, which

was reflected as a transient initiation event.

. Failthe running charging pump.

. Fail 1128 closed.

o Fail 112C closed with a probability of an intra-cable hot short of 0.30, based on

NUREG/CR-6850 or fail it open with a 0.70 probability. lf MOV-112C fails open it

must be manually closed as part of restoring the RWST suction flowpath to the

21 charging pump.

. Not generate a hot gas layer in the PAB corridor and not damage any cabling or

equipment outside of FZ F/7A based on fire modeling.

r Result in control room operators in accordance with procedures:

o Removing control power fuses for both PORVs in the control room to

prevent spurious opening which was assumed always successful. For

ATWS sequences, all PORVs and RCS safety valves would be open and

operators would not pull the fuses to close the PORVS, but would

continue to recover charging to establish emergency boration.

o Promptly disabling the 21 charging pump from automatic operation. This

action is required by procedure to preclude damage to the 21 charging

pump should it operate without a water source aligned to its suction as

Enclosure 2

23

the result of spurious valve operations. A failure probability of 1.1E-2 was

assumed based on SPAR-H1, assuming diagnosis and allfactors in their

nominalstate.

o Result in operators implementing the denied OMAs in accordance with

procedures and specifically aligning the RWST to the charging pumps suction

after the fire is extinguished and includes:

o Manually opening valve 288 with a failure probability of 2.3E-1 assumed

based on SPAR-H with all factors in their nominal state except for high

stress and conservatively assuming barely sufficient time.

o Verify or close 112C with a failure probability of 2.3E-1 assumed based

on SPAR-H with all factors in their nominal state except for high stress

and conservatively assuming barely sufficient time.

. Result in operators implementing the missed OMA to start the 21 charging pump

from the emergency control station in the 480 V switchgear room after the RWST

suction was aligned. This action was assigned a failure probability of 2.9E-1

based on SPAR-H assuming diagnosis and allfactors in their nominal state

except for incomplete and poor procedures. Incomplete and poor procedures

was chosen because operators knew of the emergency control station in the

switchgear room, and because it was incorporated in the post-fire safe shutdown

following control room abandonment, however, use of the emergency control

station was not in the procedure used for a PAB fire.

The dominating core damage sequence involving the hydrogen calibration gas cylinder

fire scenario was an ATWS caused by mechanical binding of all control rods and a

failure of the operator to manually open 288 to establish emergency boration with the 21

charging pump. The negligible increase in core damage frequency (less than 1 in one

billion years) is due to the 6.5E-4 per year initiating event frequency and the extremely

low chances of an ATWS situation where emergency boration would be necessary or a

common cause failure of the SW system would lead to a reactor coolant pump seal

failure.

Enforcement. Entergy Nuclear Operations, Inc.(ENO), Operating License,

Condition 2.K, requires, in part, that ENO shall implement and maintain in effect all

provisions of the NRC-approved FPP as described in the UFSAR. UFSAR Section 9.6,2

references the FPP as described in three ENO documents, one of these documents is

the lndian Point Energy Center (IPEC) Fire Protection Program Plan, SEP-FPP-IP-001,

Rev. 0. Control of Combustibles, EN-DC-161, Rev. 6, is referenced in the IPEC FPP

Plan and, in part, requires plant workers to: 1) limit transient combustibles to those

materials and quantities necessary to support work activities (Section 5.2[1]), 2) not

place transient combustibles directly under cable trays, (Section 5.2141),

(Section 5.5[1](d)), and 3) determine the need for a formal Transient Combustible

Evaluation (TCE) (Section 5.6t21). Contrary to the above, a compressed gas cylinder

containing hydrogen gas was left in FZ 7 A of the PAB on an unknown date of the PAB.

The unauthorized storage of a hydrogen gas bottles was identified by the NRC on

April 25, 2012. Because this finding was of very low safety significance (Green) and has

been entered into ENO's corrective action program (CR-lP2-2012-03036), this violation

is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 0500024712012009-001, Violation of Transient Gombustible Gontrol Program)

Enclosure 2

24

40A6 Meetinos. includinq Exit

Exit Meetinq Summarv

The inspectors presented their preliminary inspection results to Mr. Lawrence Coyle,

General Manager, Plant Operations, and other members of the site staff at an exit

meeting on April 26,2012. Following in-office reviews, an additional meeting was

conducted by telephone with Mr. Patric Conroy, Director, Nuclear Safety Assurance, on

June 8, 2012, and an exit meeting was conducted by telephone with Mr. Patric Conroy,

and other members of the site staff on July 20,2012. No proprietary information was

included in this inspection report.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure 2

A-1

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

P. Conroy, Director, Nuclear Safety Assurance

L. Coyle, General Manager, Plant Operations

J. Cottam, Fire Protection Engineer

G. Dahl, Licensing Specialist

K. Elliot, Safe Shutdown Engineer

M. Tesoriero, Manager, Programs and Components

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000247/2012009-01 VIO Failure to Protect Safe Shutdown Equipment from the

Effects of Fire (Section 4042.1)05000286/2012008-01 VIO Failure to Protect Safe Shutdown Equipment from the

Effects of Fire (Section 4042.2)

Opened and Closed

0500024712012009-01 NCV Violation of Transient Combustible Control Program

(Section 4OA2.3)

LIST OF DOCUMENTS REVIEWED

Fire Protection Licensino Documents

Unit 3 Technical Requirements Manual 3.7.8, Appendix R Safe Shutdown Equipment, Rev. 9

Letter from J. Bayne to H. Denton, Appendix R Exemption Request Information, Dated 11122182

Desiqn Basis Documents

lP-RPT-OS, ,P2 10 CFR 50, Appendix R Safe-Shutdown Separation Analysis, Rev. 1

lP2-RPT-03-00015,lP2 Fire Hazards Analysis, Rev. 4

lP3-ANAL-FP-02143, Fire Hazards Analysis Report, Rev. 5

lP3-ANAL-FP-01503, Safe Shutdown Analysis Report, Rev. 2

SEP-FPP-lP-001, IPEC Fire Protection Program Plan, Rev.0

Attachment

A-2

Calcu lations/Enq ineerinq Evaluation Reports

EO-6068, Fire and Heat Resistance Tests on 600V Power and Control Cable and Switchboard

Wires, Dated 8120171

lP-RPT-12-00008, lP3 OMAs 2 through 8 Evaluation, Draft

Evaluation of lP3 OMAs 18 through 22, Draft

Evaluation of lP3 OMA 26, Draft

PGI-00433, Combustible Loading Calculation, Rev. 6

Procedures

SAO-703, Fire Protection lmpairment Criteria and Surveillance, Rev, 28

SEP-FPP-lP-002,IPEC Fire Watch Program, Rev. 0

EN-DC-161, Control of Combustibles, Rev. 6

EN-DC-127, Control of Hot Work and lgnition Sources, Rev. 11

EN-IS-109, Compressed Gas Cylinder Handling and Storage, Rev. 7

Operations Procedures

2-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control, Rev. 18

2-ONOP-FP-001, Plant Fires, Revs. 7 & I

2-SOP-ESP-0O1, Local Equipment Operation and Contingency Actions, Rev. 6

3-ONOP-FP-1, Plant Fires, Rev. 28

3-SOP-EL-Q12, Operation of the Alternative Safe Shutdown Equipment, Rev. 18

3-SOP-ESP-001, Local Equipment Operation and Contingency Actions, Rev. 21

Condition Reports

cR-lP2-2011-02417 CR-1P2-2012-01487 CR-lP3-2011-02325

cR-rP2-2011-03139 CR-IP2-2012-01585 CR-lP3-2011-02853

cR-tP2-201 1-03695 CR-tP2-2012-03024 CR-lP3-2011-02951

cR-tP2-201 1-03889 CR-lP2-2012-03036 CR-IP3-201 1-02966

cR-lP2-201 1-04608 CR-lP2-2012-03410 CR-lP3-2011-03497

cR-rP2-2011-0631 1 CR-IP3-2006-02747 CR-lP3-2011-03563

cR-lP2-2012-00643 CR-lP3-2011-00044 CR-lP3-2012-00369

Attachment

A_3

LIST OF ACRONYMS

ADAMS Agency,vide Documents Access and Management System

AFW Auxiliary Feedwater

ASSS Alternate Safe Shutdown System

ATWS Anticipated Transient Without Scram

CAP Corrective Action Program

ccw Closed Cooling Water

CFR Code of Federal Regulations

DRS Division of Reactor Safety

EGM Enforcement Guidance Memorandum

ENO Entergy Nuclear Operations, Inc.

FDSO Fire Damage State Zero

FSAR Final Safety Analysis Report

FZ Fire Zone

GPM Gallon Per Minute

IA lnstrument Air

IMC Inspection Manual Chapter

IP Inspection Procedure

IPEC Indian Point Energy Center

KW Kilowatt

MOV Motor Operated Valve

NCV Non-Cited Violations

NRC Nuclear Regulatory commission

OMA Operator ManualAction

PAB Primary Auxiliary Building

PAR Publicly Available Records

PORV Power Operated Relief Valve

PSIG Pounds Per Square Inch Gauge

RCP Reactor Coolant Pump

RCS Reactor Coolant System

RIS Regulatory lssue Summary

RWST Refuel Water Storage Tank

SDP Significance Determination Process

SQFT Square Feet

SRA Senior Reactor Analyst

TCE Transient Combustible Evaluation

VC Vapor Containment

UFSAR Updated Final Safety Analysis Report

V Volt

VCT Volume ControlTank

Attachment