IR 05000247/2012009

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 F Engineering Region 1 Branch 3
To:	Ventosa J Entergy Nuclear Operations
References
IR-12-008, IR-12-009
Preceding documents:	ML13004A336 (4 January 2013)
Download: ML12229A128 (39)

Text

't"ffiUNITED STATESNUCLEAR REGULATORY COMMISSIONREGION I21OO RENAISSANCE BOULEVARD, SUITE 1OOKING OF PRUSSIA, PENNSYLVANIA 1940S'2713August L6, 20L2Mr. John Ventosa, Site Vice PresidentEntergy Nuclear Operations, lnc.Indian Point Energy Center450 Broadway, GSBP.O. Box 249Buchanan, NY 1051 1-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC INSPECTIONREPORT 05000247t2012009 AND 0500028612012008 AND NOTICES OFVIOLATION

Dear Mr. Ventosa:

On April 26,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection atlndian Point Units 2and 3. The enclosed inspection report documents the inspection resultswhich were discussed on April 26, 2012, with Mr. Lawrence Coyle, and other members of yourstaff. Following in-office reviews, an additional meeting was conducted by telephone withMr. Patric Conroy, Director, Nuclear Safety Assurance, on June 8,2012, and an exit meetingwas conducted by telephone with Mr. Patric Conroy and other members of your staff onJuly 20, 2012.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations, and with the conditions of yourlicense. The inspectors reviewed the ongoing implementation of your corrective actions torestore 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 ofmeeting the aforesaid fire protection regulations.Two violations are cited in the enclosed Notices of Violation and the circumstances surroundingthem are described in detail in the subject inspection report. The violations were evaluated inaccordance with the NRC Enforcement Policy. The current Enforcement Policy is included onthe 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 safeshutdown equipment malfunctions caused by a fire-induced single spurious actuation at IndianPoint Units 2 and 3, in lieu of protecting the equipment in accordance with 10 CFR Part 50Appendix 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 inSection 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 areasonable amount of time after the violations were identified to nuclear power plant licenseesin Regulatory lssue Summary 2006-10, Regulatory Expectations with Appendix R Paragraphlll.G.2 Operator ManualActions, on June 30, 2006. You are required to respond to this letterand should follow the instructions specified in the enclosed Notice when preparing yourresponse. The NRC will use your response, in part, to determine whether further enforcementaction is necessary to ensure compliance with regulatory requirements. One other finding of very low safety significance (Green) was also identified. This finding wasdetermined to be a violation of NRC requirements. However, because of its very low safetysignificance, and because it was entered into your corrective action program, the NRC istreating this finding as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRCEnforcement Policy. lf you contest the NCV in this report, you should provide a writtenresponse within 30 days of the date of this inspection report with the basis for your denial, to theU.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C.20555-0001; with copies to the Regional Administrator, Region l; the Director, Office ofEnforcement; and the NRC Senior Resident Inspector at Indian Point Unit 2 or 3. In addition, ifyou disagree with the cross-cutting aspect assigned to any finding in this report, you shouldprovide a response within 30 days of the date of this inspection report, with the basis for yourdisagreement, to the Regional Administrator, Region l, and the Senior Resident Inspector atf ndian Point Unit 2 or 3.ln accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rulesof Practice," a copy of this letter, its enclosure, and your response (if any)will be availableelectronically for public inspection in the NRC Public Document Room or from the PubliclyAvailable Records (PARS) component of the NRC's document system (ADAMS). ADAMS isaccessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the PublicElectronic Reading Room).

Sincerely,4.' i ;,/dfr/--/ John F. Rogge, ChiefEngineering Branch 3Division of Reactor SafetyDocket Nos. 50-247, 50-286License Nos. DPR-26, DPR-64

Enclosures:

1. Notice of Violation2. I nspection Report 05000247 l 20 1 2009 a nd 05000 286 l 20 1 2008

w/Attachment:

Supplemental lnformationcc Mencl: Distribution via ListServ One other finding of very low safety significance (Green) was also identified. This finding wasdetermined to be a violation of NRC requirements. However, because of its very low safetysignificance, and because it was entered into your corrective action program, the NRC istreating this finding as a non-cited violation (NCV)consistent with Section2.3.2 of the NRCEnforcement Policy. lf you contest the NCV in this report, you should provide a writtenresponse within 30 days of the date of this inspection report with the basis for your denial, to theU.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C.20555-0001; with copies to the Regional Administrator, Region l; the Director, Office ofEnforcement; and the NRC Senior Resident Inspector at Indian Point Unit 2 or 3. In addition, ifyou disagree with the cross-cutting aspect assigned to any finding in this report, you shouldprovide a response within 30 days of the date of this inspection report, with the basis for yourdisagreement, to the Regional Administrator, Region l, and the Senior Resident lnspector atlndian Point Unit 2 or 3.ln accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rulesof Practice," a copy of this letter, its enclosure, and your response (if any) will be availableelectronically for public inspection in the NRC Public Document Room or from the PubliclyAvailable Records (PARS) component of the NRC's document system (ADAMS). ADAMS isaccessible from the NRC Web Site at http://www,nrc.gov/reading-rm/adams.html (the PublicElectronic Reading Room).

Sincerely,/RNJohn F. Rogge, ChiefEngineering Branch 3Division of Reactor SafetyDocket Nos. 50-247, 50-286License Nos. DPR-26, DPR-64

Enclosures:

1. Notice of Violation2. I nspection Report 05000247 l 201 2009 and 05000 2861201 2008

w/Attachment:

Supplemental Informationcc w/encl: Distribution via ListServDOCUMENT NAME: GlDRS\Engineering Branch 3\IPEC OMA Inspection\lP OMA Inspection Report.docADAMS ACCESSION NUMBER: ML12229A128g suNstReviewV Non-Sensitiven Sensitiveg Publicly Availablen Non-PubliclyAvailableOFFICERI/DRSRI/DRSRI/ORARI/DRPNAMEDOrrWSchmidtMMcLaughlin via emailMGray via emailDATE8t1t128t2t128t10t128t12t12OFFICERI/DRSRI/DRSNAMEJRoggeCMiller via emailDATE81161128t9t12OFFICIAL J. VentosaDistribution w/encl:W. Dean, RAD. Lew, DRAD. Roberts, DRPJ. Clifford, DRPC. Miller, DRSP. Wilson, DRSS. Kennedy, Rl OEDOM. Gray, DRPB. Bickett, DRPS. McCarver, DRPM. Jennerich, DRPA. Ayegbusi, Acting SRIR. Montgomery, Acting RlP. Cataldo, SRIN. Lafferty, Acting RlD. Hochmuth, AARidsNrrPM lndianPoint ResourceRidsNrrDorlLpll -1 ResourceROPreport ResourceJ. Rogge, DRSD. Orr, DRSW. Schmidt, DRSJ. Lilliendahl, DRS3via E-mail)RIoRAMATL RESOURCE)RIORAMAlL RESOURCE)RIDRPMAlL RESOURCE)RIDRPMAlL RESOURCE)RIDRSMAIL RESOURCE)RIDRSMATL RESOURCE)

ENCLOSURE 1NOTICE OF VIOLATION - Indian Point Unit 2Entergy Nuclear Operations, lnc.lndian Point Nuclear Generating Unit 2Docket No: 50-247License No: DPR-26During an NRC inspection conducted April 23 through April 26, 2012, a violation of NRCrequirements was identified. ln accordance with the NRC Enforcement Policy, the violation islisted below:License Condition 2.K specifies, in part, that Entergy Nuclear Operations, lnc., (ENO) shallimplement and maintain in effect all provisions of the NRC-approved fire protection programas described in the Updated Final Safety Analysis Report.The Updated Final Safety Analysis Report, Section 9.6 specifies that ENO will meet therequirements of 10 CFR Part 50, Appendix R, Section lll.G.2, which requires, in part, exceptas provided for in paragraph G.3 of this section, where cables or equipment, includingassociated non-safety circuits that could prevent operation or cause maloperation due to hotshorts, open circuits, or shorts to ground, of redundant trains of systems necessary toachieve and maintain hot shutdown conditions are located within the same fire area, one ofthe means of ensuring that one of the redundant trains is free of fire damage shall beprovided, per the requirements in G.2.a - G.2i .Contrary to the above, between June 30, 2006, and April 26,2012, ENO failed to implementall provisions of the approved fire protection program. Specifically, the safe shutdownstrategy for Indian Point Unit 2 relied upon unapproved operator manual actions to mitigatepost-fire safe shutdown equipment malfunctions caused by a single spurious actuation, inlieu of protecting the equipment in accordance with 10 CFR Part 50 Appendix R, Sectionlll.G.2, per the requirements in G.2.a - G.2.f . The specific operator manual actions and fireareas and fire zones that are in violation of Appendix R, Section lll.G.2 are listed in thelndian Point Unit 2 Denied OMA Summary Table of NRC Inspection Report0500024712012009 and 0500028612012008. The use of manual actions in lieu of providingthe 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 writtenstatement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: DocumentControl 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, within30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply shouldbe 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 severitylevel, (2) the corrective steps that have been taken and the results achieved, (3) the correctivesteps that will be taken, and (4) the date when full compliance will be achieved. Your responsemay reference or include previous docketed correspondence, if the correspondence adequatelyaddresses the required response. lf an adequate reply is not received within the time specifiedin this Notice, an order or a Demand for Information may be issued as to why theEnclosure 1 2license should not be modified, suspended, or revoked, or why such other action as may beproper should not be taken. Where good cause is shown, consideration will be given toextending the response time.lf you contest this enforcement action, you should also provide a copy of your response, withthe basis for your denial, to the Director, Office of Enforcement, United States NuclearRegulatory Commission, Washington, DC 20555-0001.Because your response will be made available electronically for public inspection in the NRCPublic Document Room or from the NRC's document system (ADAMS), accessible from theNRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should notinclude any personal privacy, proprietary, or safeguards information so that it can be madeavailable to the public without redaction. lf personal privacy or proprietary information isnecessary to provide an acceptable response, then please provide a bracketed copy of yourresponse that identifies the information that should be protected and a redacted copy of yourresponse that deletes such information. lf you request withholding of such material, you mustspecifically identify the portions of your response that you seek to have withheld and provide indetail the bases for your claim of withholding (e.9., explain why the disclosure of information willcreate an unwarranted invasion of personal privacy or provide the information required by10 CFR 2.390(b) to support a request for withholding confidential commercial or financialinformation). lf safeguards information is necessary to provide an acceptable response, pleaseprovide 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 workingdays of receipt.Dated this 16th day of August, 2012Enclosure 1 NOTICE OF VIOLATION - Indian Point Unit 3Entergy Nuclear Operations, lnc.Indian Point Nuclear Generating Unit 3Docket No: 50-286License No: DPR-64During an NRC inspection conducted April 23 through April 26, 2012, a violation of NRCrequirements was identified. In accordance with the NRC Enforcement Policy, the violation islisted below:License Condition 2.H specifies, in part, that Entergy Nuclear Operations, Inc., (ENO) shallimplement and maintain in effect all provisions of the approved Fire Protection Program asdescribed in the Final Safety Analysis Report.The Final Safety Analysis Report, Section 9.6.2 specifies that ENO will meet therequirements of 10 CFR Part 50, Appendix R, Section lll.G.2, which requires, in part, exceptas provided for in paragraph G.3 of this section, where cables or equipment, includingassociated non-safety circuits that could prevent operation or cause maloperation due to hotshorts, open circuits, or shorts to ground, of redundant trains of systems necessary toachieve and maintain hot shutdown conditions are located within the same fire area, one ofthe means of ensuring that one of the redundant trains is free of fire damage shall beprovided, 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 implementall provisions of the approved fire protection program. Specifically, the safe shutdownstrategy for Indian Point Unit 3 relied upon unapproved manual operator actions to mitigatepost-fire safe shutdown equipment malfunctions caused by a single spurious actuation, inlieu of protecting the equipment in accordance with 10 CFR Part 50 Appendix R, Sectionlll.G.2, per the requirements in G.2.a - G.z.f . The specific operator manual actions and fireareas and fire zones that are in violation of Appendix R, Section lll.G.2 are listed in theIndian Point Unit 3 Denied OMA Summary Table of NRC lnspection Report0500024712012009 AND 0500028612012008. The use of manual actions in lieu of providingthe 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 writtenstatement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: DocumentControl 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, within30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply shouldbe 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 severitylevel, (2) the corrective steps that have been taken and the results achieved, (3) the correctivesteps that will be taken, and (4) the date when full compliance will be achieved. Your responsemay reference or include previous docketed correspondence, if the correspondence adequatelyaddresses the required response. lf an adequate reply is not received within the time specifiedEnclosure 1 2in this Notice, an order or a Demand for lnformation may be issued as to why the license shouldnot be modified, suspended, or revoked, or why such other action as may be proper should notbe taken. Where good cause is shown, consideration will be given to extending the responsetime.lf you contest this enforcement action, you should also provide a copy of your response, withthe basis for your denial, to the Director, Office of Enforcement, United States NuclearRegulatory Commission, Washington, DC 20555-0001.Because your response will be made available electronically for public inspection in the NRCPublic Document Room or from the NRC's document system (ADAMS), accessible from theNRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should notinclude any personal privacy, proprietary, or safeguards information so that it can be madeavailable to the public without redaction. lf personal privacy or proprietary information isnecessary to provide an acceptable response, then please provide a bracketed copy of yourresponse that identifies the information that should be protected and a redacted copy of yourresponse that deletes such information. lf you request withholding of such material, you mustspecifically identify the portions of your response that you seek to have withheld and provide indetail the bases for your claim of withholding (e.9., explain why the disclosure of information willcreate an unwarranted invasion of personal privacy or provide the information required by10 CFR 2.390(b) to support a request for withholding confidential commercial or financialinformation). lf safeguards information is necessary to provide an acceptable response, pleaseprovide 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 workingdays of receipt.Dated this 16th day of August, 2012Enclosure 1 ENCLOSURE 2U.S. NUCLEAR REGULATORY COMMISSIONREGION IDocket Nos.: 50-247,50-286License Nos,: DPR-26, DPR-64ReportNos.: 0500024712012009,05000286/2012008Licensee: Entergy Nuclear Operations, Inc. (ENO)Facility:lndian Point Nuclear Generating Units 2 and 3Location: 450 Broadway, GSBBuchanan, NY 1051 1-0249Dates: April 23 - April 26,2012Inspectors: D. Orr, Senior Reactor InspectorW. Schmidt, Senior Reactor AnalystJ. Lilliendahl, Reactor InspectorApproved by: John F. Rogge, ChiefEngineering Branch 3Division of Reactor SafetyEnclosure 2

SUMMARY OF FINDINGS

lR 0500024712012009, 0500028612012008; 412312012 - 412612012; Indian Point NuclearGenerating 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 specialistinspectors, Three findings of very low significance were identified. Two of these findings weredetermined to be cited violations and one of these findings was determined to be a non-citedviolation. 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 WithinThe 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 isdescribed 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.Ktoimplement and maintain all aspects of the approved fire protection program.Specifically, ENO failed to protect required post-fire safe shutdown components andcabling to ensure one of the redundant trains of equipment remained free from firedamage as required by 10 CFR Part 50, Appendix R, Section lll.G.2. In lieu ofprotecting a redundant safe shutdown train, ENO utilized unapproved operator manualactions to mitigate component malfunctions or spurious operations caused by postulatedsingle 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 numberof fire areas. However, several OMAs within the exemption request were deniedbecause ENO failed to demonstrate that the OMAs were feasible and reliable, or toappropriately evaluate fire protection defense-in-depth. ENO's performance deficiencydelayed achieving full compliance with fire protection regulations and adversely affectedpost-fire safe shutdown. ENO has entered this issue into the corrective program forresolution. The inspectors found the manual actions in addition to roving fire watches inall affected areas to be reasonable interim compensatory measures pending finalresolution by ENO.ENO's failure to protect components credited for post-fire safe shutdown from firedamage caused by single spurious actuation is considered a performance deficiency.The performance deficiency was more than minor because it affected the MitigatingSystems cornerstone objective to ensure the availability, reliability, and capability ofsystems that respond to an external event to prevent undesirable consequences in theevent of a fire. Specifically, the use of operator manual actions during post-fire safeshutdown is not as reliable as normal systems operation which could be utilized had therequirements 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 usedIMC 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 findingwas of very low safety significance (Green). This finding does not have a cross cuttingaspect because the performance deficiency occurred greater than three years ago whenthe exemption request was submitted to the NRC on March 6, 2009, and is not indicativeof 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 toimplement and maintain all aspects of the approved fire protection program.Specifically, ENO failed to protect required post-fire safe shutdown components andcabling to ensure one of the redundant trains of equipment remained free from firedamage as required by 10 CFR Part 50, Appendix R, Section lll.G.2. In lieu ofprotecting a redundant safe shutdown train, ENO utilized unapproved operator manualactions to mitigate component malfunctions or spurious operations caused by postulatedsingle 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 numberof fire areas. However, several OMAs within the exemption request were deniedbecause ENO failed to demonstrate that the OMAs were feasible and reliable, or toappropriately evaluate fire protection defense-in-depth. ENO's performance deficiencydelayed achieving full compliance with fire protection regulations and adversely affectedpost-fire safe shutdown. ENO has entered this issue into the corrective program forresolution. The inspectors found the manual actions in addition to roving fire watches inall affected areas to be reasonable interim compensatory measures pending finalresolution by ENO.ENO's failure to protect components credited for post-fire safe shutdown from firedamage caused by single spurious actuation is considered a performance deficiency,The performance deficiency was more than minor because it affected the MitigatingSystems cornerstone objective to ensure the availability, reliability, and capability ofsystems that respond to an external event to prevent undesirable consequences in theevent of a fire. Specifically, the use of operator manual actions during postfire safeshutdown is not as reliable as normal systems operation which could be utilized had therequirements 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 usedIMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 anda Senior Reactor Analyst conducted a Phase 3 evaluation, to determine that this findingwas of very low safety significance (Green). This finding does not have a cross cuttingaspect because the performance deficiency occurred greater than three years ago whenthe exemption request was submitted to the NRC on March 6, 2009, and is not indicativeof current licensee performance. (Section 4OA2.2)Green. The inspectors identified a Green, Non-Cited Violation of the lndian PointNuclear Generating Unit No. 2 Amended Facility Operating License, Condition 2.K, inthat ENO failed to implement and maintain in effect all provisions of the NRC-approvedfire protection program as described in the Updated Final Safety Analysis Report.Specifically, ENO failed to minimize transient combustible materials within the primaryauxiliary building (PAB) and stored a compressed gas cylinder containing hydrogen gaslll

B.under cable trays. The hydrogen gas cylinder was inappropriately left in its storagelocation 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 thehydrogen cylinder from the PAB. ENO initiated a corrective action to evaluate theidentified condition and ensure actions to prevent its recurrence.ENO's failure to remove the compressed hydrogen gas cylinder from the PAB after itsintended use as a calibration gas for the waste gas analyzer was a performancedeficiency. This finding was more than minor because it was associated with theExternal Factors attribute (fire) of the Mitigating Systems Cornerstone and adverselyaffects the cornerstone objective to ensure the availability, reliability, and capability ofsystems that respond to initiating events to prevent undesirable consequences (i.e., coredamage). Specifically, the hydrogen gas cylinder was stored below cable trays in anarea that includes safe shutdown circuits and the associated cables were at increasedrisk to fire damage. The inspectors used IMC 0609, Appendix F, Fire ProtectionSignificance Determination Process, Phase 1 and a Senior Reactor Analyst conducted aPhase 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 thearea of Human Performance associated with the work practice attribute because ENOpersonnel did not follow procedure, Control of Combustibles, EN-DC-161, Rev. 6, aswritten and did not remove the hydrogen gas cylinder from the PAB after it wasdisconnected 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 ViolationsNone.ivEnclosure 2

REPORT DETAILS

BackqroundThe NRC requirements related to fire protection are provided in Title 10 of the Code of FederalRegulations (CFR) Section 50.48. In accordance with 10 CFR 50.48(b), nuclear power plantslicensed to operate before January 1,1979 are required to meet Section lll.G, of 10 CFRPart 50, Appendix R. The underlying purpose of Section lll.G of 10 CFR Part 50, Appendix R, isto ensure that the ability to achieve and maintain safe-shutdown is preserved following a fireevent.Paragraph lll.G.2 of Appendix R requires one of the following means to ensure that a redundanttrain of safe-shutdown cables and equipment is free of fire damage, where redundant trains arelocated 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 withno intervening combustibles or fire hazards and with fire detectors and an automatic firesuppression 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 inthe fire area.lnside containments one of the fire protection means specified above or one of the followingfire protection means shall be provided:d. Separation of cables and equipment and associated non-safety circuits of redundanttrains by a horizontal distance of more than 20 feet with no intervening combustibles orfire hazards;e. Installation of fire detectors and an automatic fire suppression system in the fire area; orf. Separation of cables and equipment and associated non-safety circuits of redundanttrains by a noncombustible radiant energy shield.However, as a result of safe-shutdown focused inspections conducted in 2000, the NRCidentified that, in lieu of the methods specified in Paragraph lll.G.2, some licensees, includingENO, were crediting operator manual actions (OMAs) to achieve and maintain safe shutdown inthe event of a fire impacting areas in which both trains of a safe-shutdown system or componentare co-located.ln 2006, the NRC issued Regulatory lssue Summary 2006-10, Regulatory Expectations withAppendix R, Paragraph lll.G.2, Operator ManualActions, which clarified Appendix R and thatOMAs are not permitted, unless they have been specifically approved by the NRC as part of alicensee's request for exemption from the requirements of Paragraph lll.G.2. The NRC alsoissued EGM 07-004 (ML071830345), which granted enforcement discretion for licensees relyingon OMAs and provided until March 6, 2009 for licensees to complete corrective actions.Corrective actions included establishing compliance with fire protection regulations or, asappropriate, submitting an exemption request to the NRC to implement OMAs in lieu of fireprotection regulations.Enclosure 2 2ln response to this issue, on March 6, 2009, ENO submitted exemption requests for Indian PointNuclear Generating Units 2 and 3 (M1090770151 and M1090760993) in which it soughtexemption from certain requirements of Paragraph lll.G.2, to permit the use of OMAs uponwhich it had been relying for safe-shutdown in a number of fire areas. Because the acceptabilityof the OMAs was being considered under this exemption request, enforcement discretioncontinued 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 additionalinformation.The period of enforcement discretion for noncompliance with NRC fire protection requirementsat lndian Point Nuclear Generation Units 2 and 3 ended with the NRC issuance of theFebruary 1,2012,letters (ML112140509 and ML112200442) documenting completion of theNRC 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 atriennial fire protection inspection in June 2011 (ML111920339), NRC inspectors assessed thefeasibility of these compensatory measures. In addition, NRC fire protection inspections haveverified 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 torespond to and fight fires.In order to determine how the denied OMAs affected ENO's compliance with Appendix Rrequirements, the NRC requested information from ENO about the schedule and plans forbringing 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 fullrestoration of compliance for all but two of the OMAs by the fourth quarter of 2012, and for thefinaltwo OMAs by the Unit 2 refueling outage in Spring 2014.This report presents the results of a problem identification and resolution annual follow-up ofselected issues inspection conducted in accordance with NRC Inspection Procedure (lP) 71152,Problem ldentification and Resolution to review ENO's implementation of corrective actions torestore 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 thecorrective 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 [OAl4OA2 Problem ldentification and Resolution (71152- 1 sample)a. Inspection Scopeb.1.The inspectors assessed ENO's problem identification threshold, extent of conditionreviews, compensatory actions, and timeliness of corrective actions to determinewhether ENO was appropriately identifying, evaluating, and correcting problemsassociated with unapproved OMAs.The inspectors reviewed the fire hazard analysis, safe shutdown analysis and supportinglicensing and design basis documents to understand the structures, systems, andcomponents required for fire safe shutdown. The inspectors reviewed the fire safeshutdown operating procedures to verify that all OMAs were either granted an exemptionor were being addressed by the corrective action program. The inspectors reviewedcondition reports to evaluate the adequacy of evaluations and corrective actions withrespect to the denied OMAs. The fire protection engineer and safe shutdown engineerwere interviewed to evaluate the feasibility of the proposed plan to restore complianceand to assess corrective actions taken to date.The inspectors previously walked down all denied OMAs as part of the 2011 triennial fireprotection inspection to assess the feasibility of the OMAs. The inspectors walked downportions of the OMAs to re-validate the feasibility of the actions. The inspectors walkeddown all fire zones that credited denied OMAs to assess the fire risk significance whichcan be affected by ignition sources, transient and fixed combustibles, or absence of trainseparation, detection, and automatic suppression.The inspectors reviewed condition reports, fire watch logs, and fire protection programimpairment requirements to verify that compensatory measures in the form of firewatches were being adequately performed as required by the fire protection program.FindinosFailure 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.Ktoimplement and maintain all aspects of the approved fire protection program.Specifically, ENO failed to protect required post-fire safe shutdown components andcabling to ensure one of the redundant trains of equipment remained free from firedamage as required by 10 CFR Part 50, Appendix R, Section lll.G.2. In lieu ofprotecting a redundant safe shutdown train, ENO utilized unapproved operator manualactions to mitigate component malfunctions or spurious operations caused by postulatedsingle 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 numberof fire areas. However, several OMAs within the exemption request were deniedEnclosure 2

4because ENO failed to demonstrate that the OMAs were feasible and reliable, or toappropriately evaluate fire protection defense-in-depth. ENO's performance deficiencydelayed achieving full compliance with fire protection regulations and adversely affectedpost-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 ManualActions, which clarified Appendix R and that OMAs are not permitted, unless they havebeen specifically approved by the NRC as part of a licensees request for exemption fromthe requirements of Paragraph lll.G.2. In addition to information provided to thelicensees in RIS 2006-10, the NRC issued enforcement guidance memorandum (EGM)07-004, which granted enforcement discretion for licensees relying on noncompliantOMAs to bring themselves back into compliance with the existing regulations, Theenforcement discretion provided licensees until March 6, 2009, to complete theircorrective 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 supplementedby 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 lackof fire protection defense-in-depth, such as detection or automatic suppression, or lackof time margin available to complete the OMA. The NRC's denial of several OMAswithin the exemption requests was based on guidance to the NRC staff and available tothe industry. NUREG 1852, Demonstrating the Feasibility and Reliability of OMAs inResponse to Fire, published October 2007, page 1-2, states that additionalconsiderations to ensure that adequate defense-in-depth such as fire detection andsuppression is maintained are addressed in Regulatory Guide (RG) 1

.189 and should beconsidered when applying for an exemption or license amendment. RG 1 .189, FireProtection Program for Nuclear Power Plants, Rev. 1, March 2007, (in effect whenNUREG 1852 was issued) Section 5.3.3 similarly states that allfire-related operatormanual actions must be feasible and reliable. RG 1 .189 further states that the use ofoperator manual actions does not obviate the detection and suppression capabilities thatare required by the regulations and in addition, the omission or elimination of thesecapabilities in an area containing systems, structures, or components (including circuits)important to safety would generally be considered an adverse effect on safe shutdownsince it would reduce, at a minimum, fire protection defense-in-depth.ENO's failure to demonstrate that several OMAs were feasible and reliable, and toappropriately evaluate fire protection defense-in-depth delayed achieving full compliancewith fire protection regulations and adversely affected post-fire safe shutdown. ENOentered this issue into its CAP for long term resolution as CR-lP2-2012-00654. Interimcompensatory measures for the fire protection non-compliances included roving firewatches in all affected fire areas and were initiated in June 2011. The inspectorsconsidered the interim compensatory measures reasonable pending final resolution.ENO responded to the NRC in a letter dated March 1,2012 (ML120744028) with aproposed schedule to resolve all Unit 2 non-compliances for all but two of the OMAs bythe fourth quarter o12012, and for the remaining two OMAs by the Unit 2 refuelingoutage in Spring 2014.Enclosure 2

5Additionally, the inspectors identified that ENO failed to identify two OMAs that werebeing relied upon to achieve and maintain safe shutdown in the event of a fire impactingFZFlTA. During plant walkdowns, the inspectors noted an emergency control stationwithin the 480V switchgear room that provided an isolation function and start and stopcontrols for the 21 charging pump. Entergy engineers informed the inspectors that theemergency control station was installed as a plant modification under ER-lP2-03-21959in 2003 to address a previously identified Appendix R cable separation concern in firezone (FZ) F/7A. The emergency control station isolates control circuits that terminate ata local control panel for the charging pumps. The 21 charging pump can be isolatedfrom the effects of a fire in FZFITA and started in the 480V switchgear room from theemergency control station. Entergy failed to include this unapproved operator manualaction in its exemption request submitted on March 6,2009 (M1090770151). Duringinterviews with Entergy engineers regarding the charging pump local control panel andits impact on charging pump operation for a fire in FZ F 17 A, the inspectors also identifiedthat an additional OMA was necessary to operate the 21 charging pump. The additionalOMA required local operation of the 21 charging pump scoop tube positioner to controlthe 2l charging pump speed. Entergy promptly entered these missed OMAs into itscorrective action program as CR-lP2-2012-03024 and verified the OMAs were feasibleand reliable and noted that fire watches as compensatory measures for other OMAswithin this fire zone remained in place. The inspectors considered Entergy'scompensatory measures and immediate corrective actions adequate for the missedOMAs. Similar to the denied OMAs, Entergy planned to resolve the missed OMAs andestablish compliance with 10 CFR Part 50, Appendix R, Section lll.G.2.Analvsis. The inspectors identified a performance deficiency in that ENO failed toprotect components credited for post-fire safe shutdown from fire-induced damage. Thedenied OMAs, as well as the missed OMAs, were considered a single performancedeficiency as the apparent causalfactors were related, an inadequate review andevaluation of operator manual actions, and also occurred when the exemption requestwas submitted to the NRC on March 6, 2009. The performance deficiency was morethan minor because it was associated with the Protection against External Events (Fire)attribute of the Mitigating Systems Cornerstone and negatively affected the objective toensure the availability, reliability, and capability of systems that respond to initiatingevents to prevent undesirable consequences in the event of a fire. Specifically, the useof OMAs during post-fire shutdown is not as reliable as normal system operation fromthe 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, FireProtection Significance Determination Process, Phase 1 and a Senior Reactor Analystconducted a Phase 3 evaluation, to determine that this finding was of very low safetysignificance (Green). This finding does not have a cross cutting aspect because theperformance deficiency occurred greater than three years ago when the exemptionrequest was submitted to the NRC on March 6, 2009, and is not indicative of currentlicensee performance.The inspectors determined the issue did not screen to Green with a Phase 1 SDPbecause the finding category was post-fire safe shutdown and involved operator manualactions. A Phase 3 SDP was performed by a Senior Reactor Analyst (SRA) because theFire Protection Phase 2 SDP is intended to support the assessment of known issuesEnclosure 2 6only in the context of an individual fire area and this issue involved multiple fire areasand fire zones. However, the SRA determined the Phase 2 SDP tools could be used onan area by area basis to inform the Phase 3 SDP and screen fire zones if a sufficientbasis was developed for each fire zone and justified an absence of credible firescenarios such that mitigating equipment or its associated cables would not be damagedor 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 PointNuclear Generating Unit 2 cable construction and detail:All cables are treated as thermoplastic with damage potential described in TablesA7.2 and 47.3:All cables are jacketed with an asbestos braid and do not act as interveningcombustibles 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 firedamage scenarios to circuits that were not protected to the requirements of 10 CFRPart 50, Appendix R, Paragraph lll.G.2. For the vapor containment fire area and itsassociated operator manual actions, the inspectors reviewed a video that was recordedby the licensee in the previous Unit 2 refueling outage specifically for this inspectionpurpose and at the request of the NRC inspectors.A summary of the risk evaluation for each OMA and its associated denied or missedOMAs is in a table at the end of this Analysis section. In general, all of the fire zonesexcept FZFI6 screened out because:Detailed circuit and cable analysis demonstrated that cable damage could notcause spurious operations to credited safe shutdown equipment. The safeshutdown analysis that was used by ENO to formulate conclusions on theprotection of safe shutdown capability in their exemption request was overlyconservative. Because damage to these cables would not cause a malfunctionof safe shutdown equipment, the associated OMAs were unnecessary and werenot violations of 10 CFR Part 50, Appendix R, lll.G.2.;An ignition source did not exist that could credibly cause cable damage. Thecables were sufficiently separated from all fixed ignition sources to not bedamaged from thermal or radiant heat and a transient fire with an assumed origintwo feet above the floor would also not generate sufficient thermal or radiant heatto damage cables at their high elevations; or,The only credible ignition source was a transient combustible fire and theassociated weighting factor was very low, i.e., the critical floor area was muchsmaller 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 resultedfrom an oil leak of the 22 charging pump fluid drive causing damage to the pump itselfand the cabling associated with the operation and controls for the charging pump suctionvalves. There are two suction paths available to the charging pumps: 1) the volumecontrol tank (VCT) from a normally open motor operated valve (MOV) 112C which isphysically located in the VCT room, and 2) the refueling water storage tank (RWST) fromEnclosure 2 7a normally closed air operated valve (AOV) 1128, which is located in the 22 chargingpump cellor FZFl6. Valve 112B is designed to open automatically in the event of a lowVCT level through 1 128 valve position monitoring circuitry. Under these conditions,1 12C would also close. The fire was conservatively assumed to render 1128 failedclosed and close 1 12C due to cable damage to the 1 128 position monitoring circuit. Thedenied OMA 6 included actions within FZ Fl6 to locally open the 1128 bypass valve 288and in the VCT room to verify closed 112C. These actions were necessary to align theRWST as a suction source before starting the credited 21 charging pump from the maincontrol room.Due to uncertainties involved in fire induced core damage assessment, the SRAconducted two bounding analyses: 1) a fire model case based on fire modeling whichassumed that only equipment in the subject fire area was potentially damaged and allother equipment failed probabilistically, and 2) an Appendix R case where onlyequipment credited in the safe shutdown analysis was available. For the Phase 3 SDPresults, the SRA chose the fire model case as it represented the more realistic plant andoperator response to a potential fire in FZFl6.Both analyses were conducted for FZ F/6 using the lP2 SPAR model version 8.20 toestimate the increase in conditional core damage probability if the denied OMAs wereneeded vice not needed and Appendix R requirements were met such that all mitigatingoperations were available from the control room. The lP2 SPAR model credits thecharging pumps as an emergency boration source during an anticipated transientwithout 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 coolingwater system (CCW) provides RCP seal cooling and precludes a RCP sealfailure lossof coolant accident. This core damage analysis differed from the Appendix R guidelinesto maintain or restore RCS pressurizer level. An independent Region I SRA reviewedand found acceptable the SPAR model changes made to conduct these analyses. Bothanalyses assumed that a fire in FZFI6 would:aaaaOccur at a frequency of 5.0E-5 per year consistent with Attachment 4 of the FireProtection 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 transientinitiation event; and,o Removing pressurizer power operated relief valve (PORV) control powerfuses in the control room to prevent spurious PORV operation. Thisaction was assumed always successful. For ATWS sequences, it wasassumed that all PORVs and RCS safety valves would be open and thatoperators would not remove fuses to close the PORVS, but wouldcontinue to recover a charging pump and establish emergency boration.Enclosure 2 IThe fire model analysis estimated an increase in the core damage frequency less than1E-9, if the OMAs were not successful, given the estimated22 charging pump lube oilfire occurred at a frequency of 5E-5 per year and the very limited credit afforded thecharging pumps in core damage mitigation. The dominating core damage sequenceinvolving the OMAs was an ATWS following the manual reactor trip caused bymechanical binding of all the control rods, and a failure of operators to manually open288 to establish emergency boration with the 21 charging pump. The negligible increasein core damage frequency was also due to the extremely low probability of an ATWSwhere emergency boration would be necessary or a common cause failure of the servicewater system which would lead to a RCP seal failure. This analysis allowed normalplant equipment to remain functional provided it was not damaged as a result of the firescenario based on fire modeling. The fire model analysis assumed that a fire in FZFI6would:. Fail 112C closed with the probability of an intra-conduit hot short of 0.05, basedon NUREG/CR-6850. Fail112C open with a 0.95 probability. lf 112C failedopen, 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 theadjacent primary auxiliary building corridor, FZFlTA. This assumption wasbased on fire modeling.. Result in control room operators in accordance with procedure promptly disablingthe 21 charging pump from automatic operation. This action is required byprocedure to preclude damage to the 21 charging pump should it operate withouta water source aligned to its suction as the result of spurious^valve operations. Afailure probability of 1.1E-2 was assumed based on SPAR-H', assumingdiagnosis and allfactors in their nominal state.. Result in operators implementing the denied OMAs in accordance withprocedures and specifically aligning the RWST to the charging pumps suctionafter the fire is extinguished and includes:o Manually opening valve 288 with a failure probability of 2.3E-l assumedbased on SPAR-H with all factors in their nominal state except for highstress and conservatively assuming barely sufficient time.o Verify or close 1 12C with a failure probability o'f 2.3E-1 assumed basedon SPAR-H with all factors in their nominal state except for high stressand conservatively assuming barely sufficient time.. Result in control room operators, starting the 21 charging pump, in accordancewith procedure, once suction to the RWST was aligned by the OMAs. A failureprobability of 1.1E-2 was assumed based on SPAR-H assuming diagnosis andall factors in their nominal state.The Appendix R analysis estimated an increase in the core damage frequency in themid-E-7 range. The Appendix R analysis assumed no credit afforded the chargingpumps in the dominating core damage sequence. In the Appendix R analysis, theOMAs did not impact the core damage frequency results. The dominating core damagesequence involved a RCP loss of seal cooling event leading to a small loss of coolantaccident due to RCP sealfailure at a leak rate of 182 gpm per RCP and successfuloperation of the 21 AFW train. Although 21 AFW was successful, core damage occursbecause the reactor cannot be depressurized because PORV fuses are removed byEnclosure 2 9procedure failing the PORVs closed, and high pressure coolant injection is assumed tohave failed in the Appendix R analysis. lf a loss of RCP seal cooling does not occur, thedominant core damage sequence included failure of the 21 AFW train (in the range of1 in 125) and the inability, using high pressure coolant injection and the PORVs (feedand bleed), to remove decay heat. The Appendix R analysis assumed that a fire in theFZF16 would:. Cause a loss of RCP seal cooling and subsequent RCP sealfailure. A loss ofRCP seal cooling occurred due to the fire induced closures of 112C and a CCWsystem MOV in the RCP thermal barrier cooling flow path. In this case, with afire in the 22 charging pump cell, operators would not be able to open valve 288to establish a suction path to the 21 charging pump in sufficient time to preventthe 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 TableFire OMA No.'Area/ZoneViolation of lll.G.2CommentsRisklncreaseResultsF/5AFITANoBased on circuit reviews, cables of interest within this No increaseFZ do not result in a spurious operation thatnecessitates this OMA.Yes This area required a detailed phase 3 SDP analysis. NegligibleThe inspectors assumed a 5200kW fire from 54 increasegallons of oil leaked from the 22 charging pump fluid based ondrive within a 40 sqft skid 15.5ft directly below cable detailedYZ1-J85. Details of the phase 3 SDP analysis are Phase 3described in the analysis section prior to this table. SDPanalysisNo Based on circuit reviews, cables of interest within this No increaseFZ do not result in a spurious operation thatnecessitates this OMA.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage cable YZ1-JB1 which is located 14ft abovethe floor.Ft6Screenedbased onPhase 2SDP tasksEnclosure 2 10Ft27A 5F/33A 65YesBased on circuit reviews, cables of interest within thisFZ do not result in a spurious operation thatnecessitates this OMA.The only credible ignition source was a transientcombustible fire and the associated transientweighting factor was very low, i.e. an 8sqft criticalfloor area compared to 6000sqft plausible floor areaequals a 2.3E-7 area weighting factor.See above, same as FlTA for OMA 20.No Based on circuit reviews, cables of interest within thisFZ do not result in a spurious operation thatnecessitates this OMA,Yes This OMA involves opening a manual valve, 227, toalign a charging path to the reactor coolant system ifthe normally open air operated valve, HCY-l42, wereto close from a loss of instrument air (lA). Circuits toHCV-142 do not route through the associated FZs.Therefore this OMA is only necessary for a fireinduced loss of lA. The inspectors walked downeach FZ and did not identify any lA lines near ignitionsources. Additionally, a loss of lA resulting from thespurious operation of several lA loads and asubsequent high demand on the lA system wouldrequire multiple spurious operations.Yes The only credible ignition source to cable CK1-YP3,power supply cable to 112C, is the motor controlcenter where CK1-YP3 terminates. This is a firedamage state zero scenario (FDSO). FDSOscenarios are not analyzed in the SDP as a riskcontributor. See step 2.2 of IMC 0609, Appendix F.Yes See above, same as Fl27A for OMA 5.No increaseScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksNo increaseScreenedbased onPhase 2SDP tasksNo increaseScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksF/594 5Yes See above, same as Fl27 A for OMA 5.Enclosure 2 11Ht72A IHl75A 8,9, 10Hl77 A 8, 9, 10 Yes See above, same as Hl72A for OMA 8.H/84A 8Yes See above, same as Hl72A for OMA 8.H/85A 8Yes 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 wasnot accessible to the inspectors for walkdown, NRCinspectors walkdown the VC as part of the baselineinspection program following plant outages and justprior to plant startup in part to verify the licensee hasthoroughly removed all outage materials andcombustibles. The licensee performs similarinspections prior to startup. The inspectors observedthe FZ using a video recording taken by the licenseeduring the most recent refuel outage. Additionally,the inspectors reviewed the spatial separationbetween ignition sources and cables of concern asdescribed in ENO's September 29,2010 response tothe NRC's request for additional information onAugust 1 1, 2010 (ML1 02930237).Yes See above, same as Hl72A for OMA 8.Screenedbased onPhase 2SDP tasksJt19 11Screenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksNo increaseJt25 12J/39A 11,12No Based on circuit reviews, cables of interest within thisFZ do not result in a spurious operation thatnecessitates this OMA.No See above, same as J/19 for OMA 11.No See above, same as J/19 for OMA 11.No increaseNo increaseEnclosure 2 12Jl43A 11, 12,Jt45A 11Jl46A 11, 12,Jl47A 11J/50A 11,12J1270 12K60A 14,15,1313No 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 withinthese FZs that also result in a loss of main feedwaterwith the assumed fire-induced loss of auxiliaryfeedwater from cable damage. Therefore a firewithin this fire zone will not result in a plant transientfrom spurious operations.Yes Based on circuit reviews there are no cables withinthese FZs that also result in a loss of main feedwaterwith the assumed fire-induced loss of auxiliaryfeedwater from cable damage. Therefore a firewithin this fire zone will not result in a plant transientfrom spurious operations.No increaseNo increaseNo increaseNo increaseNo increaseNo increaseScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasks195.l(654 14,15,191As identified in table on pages 1 through 4 of Attachment 1 to ENO response letter to the NRCdated March 1,2012 (M112074A028). OMAs 20 and 21 were NRC identified during plantwalkdowns and are described in the following list.Description of Indian Point Unit 2 Denied OMAsOpen HCV-142 bypass valve 227 to align charging pump makeup path to the reactorcoolant 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 flowto 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 localcontrol panel.Enable ASSS source-range channel and RCS loop 21 and 22 hot leg and cold legtemperature channels.Enclosure 26.7.8.9.10.

11.13Trip breakers 52l5A and 52-SAC on Bus 5A and 5216A and 52ffAO at Bus 64 andremove 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 transferthe 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 generators21 and 22.Locally operate the 21 charging pump scoop tube positioner. OMA 20 was NRCidentified 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 requestsubmitted to the NRC on March 6, 2009 (M1090770151).Locally start the 21 charging pump using the emergency control station located in the480V switchgear room. OMA 21 was NRC identified during plant walkdowns and its usein lieu of meeting 10 CFR 50, Appendix R, Section lll.G.2 requirements was not includedin 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, thatEntergy Nuclear Operations, lnc., shall implement and maintain in effect all provisions ofthe approved Fire Protection Program as described in the Updated Final Safety AnalysisReport. The Updated Final Safety Analysis Report, Section 9.6 specifies that ENO willmeet the requirements of 10 CFR Part 50, Appendix R, Section lll.G.2 which identifiesthe means of protecting post-fire safe shutdown equipment from fire damage. Contraryto the above, between June 30, 2006 and April 26, 2012, ENO failed to implement theirfire 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-inducedcircuit damage. Specifically, ENO used unapproved operator manual actions to mitigatepost-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 ofAppendix R, Section lll.G.2 are listed in the Indian Point Unit 2 Denied OMA SummaryTable of this inspection report. This finding is being cited because not all of the criteriaspecified in Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation weresatisfied. Specifically, ENO failed to restore compliance within a reasonable amount oftime after the violation was identified in RIS 2006-10 on June 30, 2006.VfO 0500024712012009-01, Failure to Protect Safe Shutdown Equipment from theEffects of Fire.12.13.14.15.19.20.21.Enclosure 2 2.14Failure 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 toimplement and maintain all aspects of the approved fire protection program.Specifically, ENO failed to protect required post-fire safe shutdown components andcabling to ensure one of the redundant trains of equipment remained free from firedamage as required by 10 CFR Part 50, Appendix R, Section lll.G.2. In lieu ofprotecting a redundant safe shutdown train, ENO utilized unapproved operator manualactions to mitigate component malfunctions or spurious operations caused by postulatedsingle 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 numberof fire areas. However, several OMAs within the exemption request were deniedbecause ENO failed to demonstrate that the OMAs were feasible and reliable, or toappropriately evaluate fire protection defense-in-depth. ENO's performance deficiencydelayed achieving full compliance with fire protection regulations and adversely affectedpost-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 ManualActions, which clarified Appendix R and that OMAs are not permitted, unless they havebeen specifically approved by the NRC as part of a licensees request for exemption fromthe requirements of Paragraph lll.G.2. In addition to information provided to thelicensees in RIS 2006-10, the NRC issued enforcement guidance memorandum (EGM)07-004, which granted enforcement discretion for licensees relying on noncompliantOMAs to bring the facility back into compliance with the existing regulations. Theenforcement discretion provided licensees until March 6, 2009, to complete correctiveactions,ENO submitted exemption requests on March 6, 2009 for OMAs in several non-compliant fire areas. The NRC considered ENO's exemption requests, as supplementedby information provided by ENO in response to NRC requests for additional informationand on February 1,2012, the NRC denied many of the requested exemptions based onlack of fire protection defense-in-depth, such as detection or automatic suppression, orlack of time margin available to complete the OMA. The NRC's denial of several OMAswithin the exemption requests was based on guidance to the NRC staff and available tothe industry. NUREG 1852, Demonstrating the Feasibility and Reliability of OMAs inResponse to Fire, published October 2007 , page 1-2, states that additionalconsiderations to ensure that adequate defense-in-depth such as fire detection andsuppression is maintained are addressed in Regulatory Guide 1.189 and should beconsidered when applying for an exemption or license amendment. RG 1.189, FireProtection Program for Nuclear Power Plants, Rev. 1, March 2007, (in effect whenNUREG 1852 was issued) Section 5.3.3 similarly states that allfire-related operatormanual actions must be feasible and reliable. RG 1

.189 further states that the use ofoperator manual actions does not obviate the detection and suppression capabilities thatare required by the regulations and in addition, the omission or elimination of thesecapabilities in an area containing systems, structures, or components (including circuits)Enclosure 2

15important to safety would generally be considered an adverse effect on safe shutdownsince it would reduce, at a minimum, fire protection defense-in-depth.ENO's failure to demonstrate that several OMAs were feasible and reliable, and toappropriately evaluate fire protection defense-in-depth delayed achieving full compliancewith fire protection regulations and adversely affected post-fire safe shutdown. ENOentered this issue into its CAP for long term resolution as CR-lP3-2012-00369. lnterimcompensatory measures for the fire protection non-compliances included roving firewatches in all affected fire areas and were initiated in June 2011. The inspectorsconsidered the interim compensatory measures reasonable pending final resolution.ENO responded to the NRC in a letter dated March 1,2012, (M112074A028) with aproposed 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 toprotect components credited for post-fire safe shutdown from fire-induced damage. Theperformance deficiency was more than minor because it was associated with theProtection against External Events (Fire) attribute of the Mitigating Systems Cornerstoneand negatively affected the objective to ensure the availability, reliability, and capabilityof systems that respond to initiating events to prevent undesirable consequences in theevent of a fire. Specifically, the use of OMAs during post-fire shutdown is not as reliableas normal system operation from the main control room which would be utilized had therequirements of 10 CFR Part 50, Appendix R, Section lfl.G.2 been met. The inspectorsused IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase1 and an SRA conducted a Phase 3 evaluation, to determine that this finding was of verylow safety significance (Green). This finding did not have a cross cutting aspectbecause the performance deficiency occurred greater than three years ago when theexemption request was submitted to the NRC on March 6, 2009, and is not indicative ofcurrent licensee performance.The inspectors determined the issue did not screen with a Phase 1 SDP because thefinding category was post-fire safe shutdown and involved operator manual actions. APhase 3 SDP was performed by a Senior Reactor Analyst (SRA) because the FireProtection Phase 2 SDP is intended to support the assessment of known issues only inthe context of an individual fire area and this issue involved multiple fire areas and firezones. However, the SRA determined the Phase 2 SDP tools could be used on an areaby area basis to inform the Phase 3 SDP and screen firg zones if a sufficient basis wasdeveloped for each fire zone and justified an absence of credible fire scenarios, suchthat mitigating equipment or its associated cables would not be damaged or a planttransient would not occur. Guidance in each attachment of IMC 0609, Appendix F wasapplied in addition to the following assumptions specific for lndian Point NuclearGenerating Unit 3 cable construction and detail:. All cables are treated as thermoplastic with damage potential described in Tables47.2 and 47.3;. All cables are jacketed with an asbestos braid and do not act as interveningcombustibles or contribute to fire spread; and,o Asbestos cable jacket is not credited as a thermal or radiant heat shield.Enclosure 2 16The inspectors walked down each of the individual fire zone to identify potentialfiredamage scenarios to circuits that were not protected to the requirements of 10 CFRPart 50, Appendix R, Paragraph lll.G.2.One of the unapproved OMAs which was associated with several fire zones was localmanual operation of the service water pump strainer backwash. This OMA wasdetermined 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 verylow risk for this OMA was related to the very low likelihood of ever needing the strainerbackwash to operate during a post-fire safe shutdown. With the exception ofFZPAB 2{3}/6, all remaining fire zones and associated OMAs screened because therewere no fixed or assumed transient combustible ignition sources that could crediblydamage 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 whilethe 32 charging pump was in operation damages cables to the volume control tank(VCT) motor operated outlet valve (112C). The SRA compared differences betweenUnit 2 and Unit 3 for the 22 and 32 charging pump cubicle fire scenarios. The only noteddifferences between plant configurations or operating procedures was the 1128 valvedesign and the fire zone configurations. The 1 128 valve at Unit 2 was a normally closedair operated valve, and at Unit 3 the 1 128 valve was a normally closed motor operatedvalve. 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 thecharging pump cubicles acceptable and the 31 charging pump was credited in the eventof a fire in the 32 charging pump cubicle. Both differences between the Unit22 and 32charging pump fire scenario would not change the fire damage or risk analysisassumptions. Because there was no applicable difference between the Unit 2 and Unit 3charging pump fire scenario, the results of the Unit 2 detailed Phase 3 SDP analysis canbe 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 TableArea/ZoneCommentsRiskIncreaseResultsETN- 6,84{11/7AYes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Screenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksETN- 5,6,8,9,10, Yes There were no fixed or assumed transient4{1ll 11,12 combustible ignition sources that could credibly60A damage the cable of concern in this area.Enclosure 2 17ETN- 14,15,16,4{3It 17734PAB- 182{3}l6Previouslyevaluatedas very lowScreenedbased onPhase 2SDP tasksNegligiblebased ondetailedPhase 3SDPanalysisScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasks13Yes This OMA was previously identified as a violationduring the last triennialfire protection inspection andwas documented in that report as a very low safetysignificance (Green) NCV.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes This zone was described in detail in the analysissection above this table.PAB- 222{5ll174PAB- 19,202{5}l19APAB- 222{5}l204PAB- 222{5ll274PAB- 222{5Il304PAB- 212{5}l59AYes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Enclosure 2 18TBL- 255137ATBL- 255/38ATBL. 255t43ATBL- 255t44ATBL- 23,245t52ATBL- 245t54AYARD 26-71222Yes This OMA was previously identified as a violationduring the last triennialfire protection inspection andwas documented in that report as a very low safetysignificance (Green) NCV.Yes This OMA was previously identified as a violationduring the last triennialfire protection inspection andwas documented in that report as a very low safetysignificance (Green) NCV.Yes This OMA was previously identified as a violationduring the last triennialfire protection inspection andwas documented in that report as a very low safetysignificance (Green) NCV.Yes This OMA was previously identified as a violationduring the last triennial fire protection inspection andwas documented in that report as a very low safetysignificance (Green) NCV.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes There were no fixed or assumed transientcombustible ignition sources that could crediblydamage the cable of concern in this area.Yes This OMA was previously identified as a violationduring the last triennialfire protection inspection andwas documented in that report as a very low safetysignificance (Green) NCV.Previouslyevaluatedas very lowPreviouslyevaluatedas very lowPreviouslyevaluatedas very lowPreviouslyevaluatedas very lowScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksScreenedbased onPhase 2SDP tasksPreviouslyevaluatedas very low272As identified in table on pages 1 through 5 of Attachment 2 to ENO response letter to the NRCdated March 1, 2Q12 (ML1207 4A028).Description of Indian Point Unit 3 Denied OMAs5, 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 2 198. Locally operate FCV-405B, FCV-405D, or FCV-406B to control AFW flow to SteamGenerators (SGs).9. Locally open valve 227 to establish charging makeup flowpath to Reactor CoolantSystem (RCS).10. Locally close Level Control Valve (LCV)-1 12C and open valve 288 to align chargingpump suction to the Refueling Water Storage Tank (RWST).11. Locally operate Pressure Control Valve (PCV)-1 139 to ensure steam supply to 32 AFWpump.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 pathto 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 failedclosed HCV-142.22. Locally close LCV-112C and open bypass valve 288 to establish flowpath from RWST tocharging pump suction.23. Locally operate [bypass valve for] FCV-1121 AFW pump recirculation valve during pumpstartup.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 associatedwith selected SW pump is lost.26. Locally start ARDG to supply Motor Control Center (MCC) 312A in support of the use ofSW pump 38.Enclosure 2 27.20Locally/manually backwash SW Pump strainer as required if power to strainerassociated with selected SW pump is lost.Enforcement. Indian Point Unit 3 Operating License Condition 2.H specifies, in part, thatEntergy Nuclear Operations, lnc., shall implement and maintain in effect all provisions ofthe 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 therequirements of 10 CFR Part 50, Appendix R, Section lll.G.2, which identifies the meansof protecting post-fire safe shutdown equipment from fire damage. Contrary to theabove, between June 30, 2006 and April 26, 2012, ENO failed to implement their fireprotection 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-inducedcircuit damage. Specifically, ENO used unapproved operator manual actions to mitigatepost-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 ofAppendix R, Section lll.G.2, are listed in the Indian Point Unit 3 Denied OMA SummaryTable of this inspection report. This finding is being cited because not all of the criteriaspecified in Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation weresatisfied. Specifically, ENO failed to restore compliance within a reasonable amount oftime after the violation was identified in RIS 2006-10 on June 30, 2006.VIO 0500028612012008-01, Failure to Protect Safe Shutdown Equipment from theEffects of Fire.Violation of Combustible Controls Proqramlntroduction. The inspectors identified a Green, Non-Cited Violation (NCV) of the IndianPoint 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 primaryauxiliary building (PAB) and stored a compressed gas cylinder containing hydrogen gasunder cable trays.Description. While walking down electrical cables that were associated with deniedOMA exemptions, the inspectors identified a gas cylinder underneath cable trays in firezone (FZ) Fl7 A of the PAB. The gas cylinder was not in use, a valve protection cap wasinstalled, and the gas cylinder was chained to a corridor wall to prevent accidentalmovement or tipping. The gas cylinder's contents were unknown and without label otherthan a sticker indicating the contents were flammable.ENO removed the gas cylinder from the PAB and evaluated its contents. The gascylinder was a mixture of 50 percent hydrogen and 50 percent nitrogen gasses and waspreviously in service as a calibration gas for the waste gas analyzer in FZ F/8A of thePAB. lt contained about 150 psig of gas. FZ FlSA is an authorized storage location foran in service hydrogen calibration gas cylinder, and FZFITA is not an authorized storagelocation for any hydrogen gas cylinders.Enclosure 2 21The storage of a hydrogen compressed gas cylinder in FZFITA of the PAB was not inaccordance with ENO procedure, Control of Combustibles, EN-DC-161, Rev. 6, and aflammable compressed gas was not practically minimized. EN-DC-161, among otherrequirements, requires plant workers to: 1) limit transient combustibles to thosematerials and quantities necessary to support work activities, 2) not place transientcombustibles directly under cable trays, and 3)determine the need for a formalTransient Combustible Evaluation (TCE).ENO promptly entered this issue into its CAP as CR-lP2-2012-03036, and removed thehydrogen cylinder from the PAB. ENO initiated a corrective action to evaluate theidentified condition and ensure actions to prevent its recurrence.Analvsis. ENO's failure to remove the compressed hydrogen gas cylinder from the PABafter its intended use as a calibration gas for the waste gas analyzer was a performancedeficiency. This finding was more than minor because it was associated with theExternal Factors attribute (fire) of the Mitigating Systems Cornerstone and adverselyaffected the cornerstone objective to ensure the availability, reliability, and capability ofsystems that respond to initiating events to prevent undesirable consequences (i.e., coredamage). Specifically, the hydrogen gas cylinder was stored below cable trays in anarea that includes safe shutdown circuits and the associated cables were at increasedrisk to fire damage. The inspectors used IMC 0609, Appendix F, Fire ProtectionSignificance Determination Process, Phase 1 and a Senior Reactor Analyst conducted aPhase 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 thearea of Human Performance associated with the work practice attribute because ENOpersonnel did not follow procedure, Control of Combustibles, EN-DC-161, Rev. 6, aswritten and did not remove the hydrogen gas cylinder from the PAB after it wasdisconnected 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 SignificanceDetermination Process (SDP), and assigned a high degradation rating for thiscombustible controls program finding. Accordingly, this finding did not screen to Greenin Phase 1 of IMC 0609, Appendix F, and a Phase 3 analysis was performed by a SeniorReactor Analyst (SRA) using similar assumptions and methodologies as the deniedOMA findings.Conduct of the phase 3 SDP included identifying the damage that could result based ondetailed plant walkdowns, review of ENO provided circuit information, fire modelingevaluation of potential damage to plant equipment, and use of probabilistic fire analysismethods documented in NRC Inspection Manual Chapter 0609, Appendix F, "FireProtection SDP" and NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology forNuclear Power Facilities." The SRA analyzed the risk of a single hydrogen gas cylinderfire located directly below the cables in FZFITA that may cause the charging pumps tolose suction by closing the volume control tank (VCT) outlet valve (112C). Because thehydrogen compressed gas cylinder was stored along a PAB corridor in FZFITA withoutcontrols or regards to its combustibility or flammability, the SRA assumed for thepurposes of analyzing risk from fire, that the hydrogen gas cylinder was located directlyEnclosure 2 22beneath cables that if damaged may spuriously close 112C. Closure of 112C causesthe charging pumps to lose suction and OMAs are required to restore the VCT suction oralign the refuel water storage tank (RWST) as an alternate source by opening airoperated 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 cellFZFl6. 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 VCTsuction valve 1 12C to close. The 1 128 valve position monitoring circuit cable runs fromFZFl6, where 1128 is located, through FZFITA. The fire is assumed to result in 1128failing to open due to direct power supply cabling damage and 1 12C failing closed due todamage to the 1128 position monitoring circuit wiring. The denied OMAs tor FZFITAwere used in this analysis. These OMAs included the manual opening of the 1 128bypass valve (288), the verification or closure of 112C, and starting the 21 chargingpump, after the RWST suction is aligned, using the emergency control station in the480V switchgear room.The SRA conducted a detailed probabilistic analysis tor FZ F/7A, using the lP2 SPARmodel version 8.20 to estimate the conditional core damage probability if the fire were tooccur. This analysis represented a fire model estimate that allowed normal plantequipment to remain functional if it would not be damaged based on fire modeling of theactual plant configuration. The analysis determined a negligible increase in coredamage frequency (less than 1 in one billion years), given an estimated 6.5E-4 per yearfire frequency (consistent with Attachment 4 of the Fire Protection SDP for a hydrogenstorage tank) and the conditional core damage probability calculated (if the performancedeficiency had not occurred there was no credible ignition source). An independentRegion I SRA reviewed and found acceptable the SPAR model changes made toconduct the analysis, which were based on following assumptions that a fire in FZFITAwould:o Cause operators to manually initiate a reactor trip from the control room, whichwas 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 onNUREG/CR-6850 or fail it open with a 0.70 probability. lf MOV-112C fails open itmust be manually closed as part of restoring the RWST suction flowpath to the21 charging pump.. Not generate a hot gas layer in the PAB corridor and not damage any cabling orequipment 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 toprevent spurious opening which was assumed always successful. ForATWS sequences, all PORVs and RCS safety valves would be open andoperators would not pull the fuses to close the PORVS, but wouldcontinue to recover charging to establish emergency boration.o Promptly disabling the 21 charging pump from automatic operation. Thisaction is required by procedure to preclude damage to the 21 chargingpump should it operate without a water source aligned to its suction asEnclosure 2 23the result of spurious valve operations. A failure probability of 1.1E-2 wasassumed based on SPAR-H1, assuming diagnosis and allfactors in theirnominalstate.o Result in operators implementing the denied OMAs in accordance withprocedures and specifically aligning the RWST to the charging pumps suctionafter the fire is extinguished and includes:o Manually opening valve 288 with a failure probability of 2.3E-1 assumedbased on SPAR-H with all factors in their nominal state except for highstress and conservatively assuming barely sufficient time.o Verify or close 112C with a failure probability of 2.3E-1 assumed basedon SPAR-H with all factors in their nominal state except for high stressand conservatively assuming barely sufficient time.. Result in operators implementing the missed OMA to start the 21 charging pumpfrom the emergency control station in the 480 V switchgear room after the RWSTsuction was aligned. This action was assigned a failure probability of 2.9E-1based on SPAR-H assuming diagnosis and allfactors in their nominal stateexcept for incomplete and poor procedures. Incomplete and poor procedureswas chosen because operators knew of the emergency control station in theswitchgear room, and because it was incorporated in the post-fire safe shutdownfollowing control room abandonment, however, use of the emergency controlstation was not in the procedure used for a PAB fire.The dominating core damage sequence involving the hydrogen calibration gas cylinderfire scenario was an ATWS caused by mechanical binding of all control rods and afailure of the operator to manually open 288 to establish emergency boration with the 21charging pump. The negligible increase in core damage frequency (less than 1 in onebillion years) is due to the 6.5E-4 per year initiating event frequency and the extremelylow chances of an ATWS situation where emergency boration would be necessary or acommon cause failure of the SW system would lead to a reactor coolant pump sealfailure.Enforcement. Entergy Nuclear Operations, Inc.(ENO), Operating License,Condition 2.K, requires, in part, that ENO shall implement and maintain in effect allprovisions of the NRC-approved FPP as described in the UFSAR. UFSAR Section 9.6,2references the FPP as described in three ENO documents, one of these documents isthe 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 FPPPlan and, in part, requires plant workers to: 1) limit transient combustibles to thosematerials and quantities necessary to support work activities (Section 5.2[1]), 2) notplace transient combustibles directly under cable trays, (Section 5.2141),(Section 5.5[1](d)), and 3) determine the need for a formal Transient CombustibleEvaluation (TCE) (Section 5.6t21). Contrary to the above, a compressed gas cylindercontaining 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 onApril 25, 2012. Because this finding was of very low safety significance (Green) and hasbeen entered into ENO's corrective action program (CR-lP2-2012-03036), this violationis 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 2440A6 Meetinos. includinq ExitExit Meetinq SummarvThe inspectors presented their preliminary inspection results to Mr. Lawrence Coyle,General Manager, Plant Operations, and other members of the site staff at an exitmeeting on April 26,2012. Following in-office reviews, an additional meeting wasconducted by telephone with Mr. Patric Conroy, Director, Nuclear Safety Assurance, onJune 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 wasincluded in this inspection report.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

Opened05000247/2012009-01 VIO Failure to Protect Safe Shutdown Equipment from theEffects of Fire (Section 4042.1)05000286/2012008-01 VIO Failure to Protect Safe Shutdown Equipment from theEffects 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 DocumentsUnit 3 Technical Requirements Manual 3.7.8, Appendix R Safe Shutdown Equipment, Rev. 9Letter from J. Bayne to H. Denton, Appendix R Exemption Request Information, Dated 11122182Desiqn Basis DocumentslP-RPT-OS, ,P2 10

CFR 50, Appendix R Safe-Shutdown Separation Analysis, Rev. 1lP2-RPT-03-00015,lP2 Fire Hazards Analysis, Rev. 4lP3-ANAL-FP-02143, Fire Hazards Analysis Report, Rev. 5lP3-ANAL-FP-01503, Safe Shutdown Analysis Report, Rev. 2SEP-FPP-lP-001, IPEC Fire Protection Program Plan, Rev.0Attachment

A-2Calcu lations/Enq ineerinq Evaluation ReportsEO-6068, Fire and Heat Resistance Tests on 600V Power and Control Cable and SwitchboardWires, Dated 8120171lP-RPT-12-00008, lP3 OMAs 2 through 8 Evaluation, DraftEvaluation of lP3 OMAs 18 through 22, DraftEvaluation of lP3

OMA 26, DraftPGI-00433, Combustible Loading Calculation, Rev. 6ProceduresSAO-703, Fire Protection lmpairment Criteria and Surveillance, Rev, 28SEP-FPP-lP-002,IPEC Fire Watch Program, Rev. 0EN-DC-161, Control of Combustibles, Rev. 6EN-DC-127, Control of Hot Work and lgnition Sources, Rev. 11EN-IS-109, Compressed Gas Cylinder Handling and Storage, Rev. 7Operations Procedures2-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control, Rev. 182-ONOP-FP-001, Plant Fires, Revs. 7 & I2-SOP-ESP-0O1, Local Equipment Operation and Contingency Actions, Rev. 63-ONOP-FP-1, Plant Fires, Rev. 283-SOP-EL-Q12, Operation of the Alternative Safe Shutdown Equipment, Rev. 183-SOP-ESP-001, Local Equipment Operation and Contingency Actions, Rev. 21Condition ReportscR-lP2-2011-02417

CR-1P2-2012-01487 CR-lP3-2011-02325cR-rP2-2011-03139

CR-IP2-2012-01585 CR-lP3-2011-02853cR-tP2-201

1-03695 CR-tP2-2012-03024 CR-lP3-2011-02951cR-tP2-201

1-03889 CR-lP2-2012-03036

CR-IP3-201

1-02966cR-lP2-201

1-04608 CR-lP2-2012-03410 CR-lP3-2011-03497cR-rP2-2011-0631 1

CR-IP3-2006-02747 CR-lP3-2011-03563cR-lP2-2012-00643 CR-lP3-2011-00044 CR-lP3-2012-00369Attachment

ADAMSAFWASSSATWSCAPccwCFRDRSEGMENOFDSOFSARFZGPMIAIMCIPIPECKWMOVNCVNRCOMAPABPARPORVPSIGRCPRCSRISRWSTSDPSQFTSRATCEVCUFSARVVCTA_3

LIST OF ACRONYMS

Agency,vide Documents Access and Management SystemAuxiliary FeedwaterAlternate Safe Shutdown SystemAnticipated Transient Without ScramCorrective Action ProgramClosed Cooling WaterCode of Federal RegulationsDivision of Reactor SafetyEnforcement Guidance MemorandumEntergy Nuclear Operations, Inc.Fire Damage State ZeroFinal Safety Analysis ReportFire ZoneGallon Per Minutelnstrument AirInspection Manual ChapterInspection ProcedureIndian Point Energy CenterKilowattMotor Operated ValveNon-Cited ViolationsNuclear Regulatory commissionOperator ManualActionPrimary Auxiliary BuildingPublicly Available RecordsPower Operated Relief ValvePounds Per Square Inch GaugeReactor Coolant PumpReactor Coolant SystemRegulatory lssue SummaryRefuel Water Storage TankSignificance Determination ProcessSquare FeetSenior Reactor AnalystTransient Combustible EvaluationVapor ContainmentUpdated Final Safety Analysis ReportVoltVolume ControlTankAttachment