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

't"ffi UNITED STATES NUCLEAR REGULATORY

COMMISSION

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. I nspection

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

Report 05000247 l 201 2009 and 05000 2861201 2008 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

g suNstReview

V Non-Sensitive

n Sensitive g Publicly Available 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 Distribution

w/encl: W. Dean, RA D. Lew, DRA D. Roberts, DRP J. Clifford, DRP C. Miller, DRS P. Wilson, DRS 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 3 via E-mail)RIoRAMATL

RESOURCE)RIORAMAlL

RESOURCE)RIDRPMAlL

RESOURCE)RIDRPMAlL

RESOURCE)RIDRSMAIL

RESOURCE)RIDRSMATL

RESOURCE)

ENCLOSURE

1 NOTICE OF VIOLATION - Indian Point Unit 2 Entergy Nuclear Operations, lnc.lndian Point Nuclear Generating

Unit 2 Docket No: 50-247 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.Indian Point Nuclear Generating

Unit 3 Docket No: 50-286 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" =nclosure

2

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

B.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)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 b.1.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.Findinos 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: a a a a Occur at a frequency

of 5.0E-5 per year consistent

with Attachment

4 of the Fire Protection

SDP for a pump oilfire;Only occur if the 22 charging pump was running;Fail the 22 charging pump;Fail1128 closed; and, 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.'Area/Zone Violation

of lll.G.2 Comments Risk lncrease Results F/5A FITA No Based on circuit reviews, cables of interest within this No increase FZ do not result in a spurious operation

that necessitates

this OMA.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.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage cable YZ1-JB1 which is located 14ft above the floor.Ft6 Screened based on Phase 2 SDP tasks Enclosure

2

10 Ft27A 5 F/33A 6 5 Yes Based on circuit reviews, cables of interest within this FZ do not result in a spurious operation

that necessitates

this OMA.The only credible ignition source was a transient combustible

fire and the associated

transient weighting

factor was very low, i.e. an 8sqft critical floor area compared to 6000sqft plausible

floor area equals a 2.3E-7 area weighting

factor.See above, same as FlTA for OMA 20.No Based on circuit reviews, cables of interest within this FZ do not result in a spurious operation

that necessitates

this OMA, Yes This OMA involves opening a manual valve, 227, to align a charging path to the reactor coolant system if the normally open air operated valve, HCY-l42, were to close from a loss of instrument

air (lA). Circuits to 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.

Yes The only credible ignition source to cable CK1-YP3, 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.Yes See above, same as Fl27A for OMA 5.No increase Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks No increase Screened based on Phase 2 SDP tasks No increase Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks F/594 5 Yes See above, same as Fl27 A for OMA 5.Enclosure

2

11 Ht72A I Hl75A 8,9, 10 Hl77 A 8, 9, 10 Yes See above, same as Hl72A for OMA 8.H/84A 8 Yes See above, same as Hl72A for OMA 8.H/85A 8 Yes See above, same as Hl72A for OMA 8.Hl87 A 8, 9, 10 Yes See above, same as Hl72A for OMA 8.Yes This FZ is in the vapor containment (VC) and was not accessible

to the inspectors

for walkdown, NRC inspectors

walkdown the VC as part of the baseline inspection

program following

plant outages and just 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).

Yes See above, same as Hl72A for OMA 8.Screened based on Phase 2 SDP tasks Jt19 11 Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks No increase Jt25 12 J/39A 11,12 No Based on circuit reviews, cables of interest within this FZ do not result in a spurious operation

that necessitates

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

2

12 Jl43A 11, 12, Jt45A 11 Jl46A 11, 12, Jl47A 11 J/50A 11,12 J1270 12 K60A 14,15, 13 13 No See above, same as J/19 for OMA 11.No See above, same as J/19 for OMA 11.No See above, same as J/19 for OMA 1 1.No See above, same as J/19 for OMA 11.No See above, same as J/19 for OMA 11.No See above, same as J/19 for OMA 11.Yes Based on circuit reviews there are no cables within these FZs that also result in a loss of main feedwater with the assumed fire-induced

loss of auxiliary feedwater

from cable damage. Therefore

a fire within this fire zone will not result in a plant transient from spurious operations.

Yes Based on circuit reviews there are no cables within these FZs that also result in a loss of main feedwater with the assumed fire-induced

loss of auxiliary feedwater

from cable damage. Therefore

a fire within this fire zone will not result in a plant transient from spurious operations.

No increase No increase No increase No increase No increase No increase Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks 19 5.l(654 14,15,19 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 Open HCV-142 bypass valve 227 to align charging pump makeup path to the reactor coolant system (RCS).Align charging pump suction source to the refueling

water storage tank (RWST).Transfer instrument

buses 23 and 23A to alternate

power.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.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.Enable ASSS source-range

channel and RCS loop 21 and 22 hot leg and cold leg temperature

channels.Enclosure

2 6.7.8.9.10.

11.13 Trip breakers 52l5A and 52-SAC on Bus 5A and 5216A and 52ffAO at Bus 64 and remove control power fuses.Transfer instrument

buses 23 and 23A to emergency

power source.Align charging pump suction to the RWST.Operate transfer switch EDCS and close supply breaker at substation

12FD3 to transfer the 2l auxiliary

feedwater

pump (AFW) to the ASSS power source.Open the 21AFW pump recirculation

bypass valve BFD-77.Operate the 21AFW pump flow control valves to control AFW flow to steam generators

21 and 22.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).

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.12.13.14.15.19.20.21.Enclosure

2

2.14 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 Area/Zone Comments Risk Increase Results ETN- 6,8 4{11/7A Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks ETN- 5,6,8,9,10, Yes There were no fixed or assumed transient 4{1ll 11,12 combustible

ignition sources that could credibly 60A damage the cable of concern in this area.Enclosure

2

17 ETN- 14,15,16, 4{3It 17 734 PAB- 18 2{3}l 6 Previously

evaluated as very low Screened based on Phase 2 SDP tasks Negligible

based on detailed Phase 3 SDP analysis Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks 13 Yes This OMA was previously

identified

as a violation during the last triennialfire

protection

inspection

and was documented

in that report as a very low safety significance (Green) NCV.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes This zone was described

in detail in the analysis section above this table.PAB- 22 2{5ll 174 PAB- 19,20 2{5}l 19A PAB- 22 2{5}l 204 PAB- 22 2{5ll 274 PAB- 22 2{5Il 304 PAB- 21 2{5}l 59A Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Enclosure

2

18 TBL- 25 5137A TBL- 25 5/38A TBL. 25 5t43A TBL- 25 5t44A TBL- 23,24 5t52A TBL- 24 5t54A YARD 26-71 222 Yes This OMA was previously

identified

as a violation during the last triennialfire

protection

inspection

and was documented

in that report as a very low safety significance (Green) NCV.Yes This OMA was previously

identified

as a violation during the last triennialfire

protection

inspection

and was documented

in that report as a very low safety significance (Green) NCV.Yes This OMA was previously

identified

as a violation during the last triennialfire

protection

inspection

and was documented

in that report as a very low safety significance (Green) NCV.Yes This OMA was previously

identified

as a violation during the last triennial

fire protection

inspection

and was documented

in that report as a very low safety significance (Green) NCV.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes There were no fixed or assumed transient combustible

ignition sources that could credibly damage the cable of concern in this area.Yes This OMA was previously

identified

as a violation during the last triennialfire

protection

inspection

and was documented

in that report as a very low safety significance (Green) NCV.Previously

evaluated as very low Previously

evaluated as very low Previously

evaluated as very low Previously

evaluated as very low Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Screened based on Phase 2 SDP tasks Previously

evaluated as very low 27 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

27.20 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 DocumentslP-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 8120171lP-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

ADAMS AFW ASSS ATWS CAP ccw CFR DRS EGM ENO FDSO FSAR FZ GPM IA IMC IP IPEC KW MOV NCV NRC OMA PAB PAR PORV PSIG RCP RCS RIS RWST SDP SQFT SRA TCE VC UFSAR V VCT A_3 LIST OF ACRONYMS Agency,vide

Documents

Access and Management

System Auxiliary

Feedwater Alternate

Safe Shutdown System Anticipated

Transient

Without Scram Corrective

Action Program Closed Cooling Water Code of Federal Regulations

Division of Reactor Safety Enforcement

Guidance Memorandum

Entergy Nuclear Operations, Inc.Fire Damage State Zero Final Safety Analysis Report Fire Zone Gallon Per Minute lnstrument

Air Inspection

Manual Chapter Inspection

Procedure Indian Point Energy Center Kilowatt Motor Operated Valve Non-Cited

Violations

Nuclear Regulatory

commission

Operator ManualAction

Primary Auxiliary

Building Publicly Available

Records Power Operated Relief Valve Pounds Per Square Inch Gauge Reactor Coolant Pump Reactor Coolant System Regulatory

lssue Summary Refuel Water Storage Tank Significance

Determination

Process Square Feet Senior Reactor Analyst Transient

Combustible

Evaluation

Vapor Containment

Updated Final Safety Analysis Report Volt Volume ControlTank

Attachment