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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD. KING OF PRUSSIA, PA 19406-2713  
{{#Wiki_filter:UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
  September 14, 2016  
                                          REGION I
Mr. David A. Heacock  
                                  2100 RENAISSANCE BLVD.
President and Chief Nuclear Officer  
                                KING OF PRUSSIA, PA 19406-2713
Dominion Resources 5000 Dominion Boulevard  
                                        September 14, 2016
Mr. David A. Heacock
President and Chief Nuclear Officer
Dominion Resources
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
SUBJECT:        MILLSTONE POWER STATION - NRC TRIENNIAL FIRE PROTECTION
                INSPECTION REPORT 05000336/2016007 AND 05000423/2016007
Dear Mr. Heacock:
On August 11, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire
protection inspection at Millstone Power Station, Units 2 and 3. The enclosed inspection report
documents the inspection results, which were discussed on August 11, 2016, with Mr. John
Daugherty, Site Vice President - Millstone Power Station, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commission's rules and regulations, and with the conditions of your
license. The inspectors reviewed selected procedures and records, observed activities, and
interviewed station personnel. The inspectors also reviewed mitigation strategies for addressing
large fires and explosions.
Based on the results of this inspection, one finding of very low safety significance (Green) was
identified. This finding was determined to be a violation of NRC requirements. However,
because of its very low safety significance, and because it was entered into your corrective
action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with
Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCV in this report, you should
provide a written response within 30 days of the date of this inspection report, with the basis for
your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director,
Office of Enforcement; and the NRC Resident Inspector at Millstone Power Stations.


Glen Allen, VA  23060-6711
D. Heacock                                      2
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records System (PARS) component of the NRC's document system,
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible
from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
                                                  Sincerely,
                                                  /RA/
                                                  Christopher G. Cahill
                                                  Acting Branch Chief
                                                  Engineering Branch 3
                                                  Division of Reactor Safety
Docket Nos. 50-336, 50-423
License Nos. DPR-65, NPF-49
Enclosure:
Inspection Report 05000336/2016007
  and 05000423/2016007
w/Attachment: Supplemental Information
cc w/encl: Distribution via ListServ


SUBJECT: MILLSTONE POWER STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000336/2016007 AND 05000423/2016007
Dear Mr. Heacock:


   
  ML16258A175
On August 11, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire
                                          Non-Sensitive                          Publicly Available
protection inspection at Millstone Power Station, Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on August 11, 2016, with Mr. John Daugherty, Site Vice President - Millstone Power Station, and other members of your staff.
  SUNSI Review
OFFICE          RI/DRS            RI/DRS                RI/DRP              RI/DRS
NAME            JPatel            WCook                GDentel              CCahill
DATE            09/09/16          09/09/16              09/09/16            09/14/16
                                 
                U.S. NUCLEAR REGULATORY COMMISSION
                                    REGION I
Docket Nos.:  50-336, 50-423
License Nos.: DPR-65, NPF-49
Report Nos.:  05000336/2016007 and 05000423/2016007
Licensee:    Dominion Nuclear Connecticut, Inc.
Facility:    Millstone Power Station, Units 2 and 3
Location:    P.O. Box 128
              Waterford, CT 06385
Dates:        July 25, 2016 through August 11, 2016
Inspectors:  J. Patel, Reactor Inspector (Team Leader)
                  Division of Reactor Safety (DRS)
              W. Cook, Senior Reactor Analyst, DRS
              E. DiPaolo, Senior Reactor Inspector, DRS
              D. Orr, Senior Reactor Inspector, DRS
              K. Young, Senior Reactor Inspector, DRS
              L. Dumont, Reactor Inspector, DRS
              S. Galbreath, Reactor Inspector, DRS
              J. Rady, Reactor Inspector, DRS
Observers:    S. Freeman, Senior Reactor Analyst, NRC, Region II, DRS
Approved by:  Chris Cahill, Acting Branch Chief
              Engineering Branch 3
              Division of Reactor Safety
                                    i                              Enclosure


                                      SUMMARY OF FINDINGS
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed station personnel. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.  
IR 05000336/2016007, 05000423/2016007; 07/25/2016 - 08/11/2016; Dominion Nuclear
Connecticut, Inc.; Millstone Power Station, Units 2 and 3; Fire Protection (Triennial).
This report covered a two week on-site triennial fire protection team inspection by specialist
inspectors. One finding of very low safety significance was identified. This finding was
determined to be a non-cited violation. The significance of most findings is indicated by their
color (Green, While, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance
Determination Process. The cross-cutting aspects associated with findings were determined
using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the
significance determination process (SDP) does not apply may be Green or be assigned a
severity level after NRC management review. The NRC's program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 6, dated July 2016.
Cornerstone: Mitigating Systems
  Green. The team identified a finding of very low safety significance (Green) involving a non-
    cited violation of Millstone Power Station, Unit 2, Renewed Facility Operating License
    Condition 2.C.(3) to implement and maintain in effect all provisions of the approved fire
    protection program as described in the Final Safety Analysis Report (FSAR). Specifically,
    Dominion failed to maintain the #2 steam generator (SG) atmospheric dump valve (ADV)
    free from fire damage, which may have affected the availability to maintain hot shutdown
    conditions from the main control room for a fire in Fire Area R-14, Lower 4.16kV Switchgear
    Room and Cable Vault. Dominion promptly entered this safe shutdown issue into their
    corrective action program as condition report (CR) 1043458. Immediate corrective actions
    included implementing compensatory measures in the form of fire watches for fire area R-14
    that are being tracked by Reasonable Assurance of Safety (RAS) determination 3037040.
    Longer term corrective actions included submitting an exemption request to the NRC for use
    of a local operator manual action (OMA) to operate the #2 SG ADV in lieu of meeting fire
    protection requirements for fire area R-14. The team considered Dominions immediate and
    longer term corrective actions appropriate.
    The performance deficiency was more than minor because it affected the Mitigating
    Systems cornerstone objective to ensure the availability, reliability, and capability of systems
    that respond to an external event to prevent undesirable consequences in the event of a fire.
    Specifically, the use of an OMA during post-fire safe shutdown is not as reliable as normal
    systems operation which could be utilized had the requirements of 10 CFR Part 50,
    Appendix R, Section III.G.2 been met and, therefore, prevented fire damage to credited
    components and/or cables, specifically the #2 SG ADV. The inspectors used IMC 0609,
    Appendix F, Fire Protection Significance Determination Process, Phase 1 and determined
    the reactor is able to reach and maintain a hot safe shutdown condition because the SG
    ADVs are used for transition to cold shutdown, therefore this finding was of very low safety
    significance (Green). This finding does not have a cross cutting aspect because the
    performance deficiency occurred greater than three years ago when the June 30, 2011
    exemption request letter to the NRC was supplemented by letter on February 29, 2012, and
    is not indicative of current licensee performance. (Section 1R05.01)
                                              ii


Other Findings
Based on the results of this inspection, one finding of very low safety significance (Green) was
Three violations of very low safety significance that were identified by Dominion were reviewed
identified.  This finding was determined to be a violation of NRC requirements. However, because of its very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with
by the team. Corrective actions taken or planned by Dominion have been entered into
Section 2.3.2 of the NRC Enforcement Policy.  If you contest any NCV in this report, you should
Dominions corrective action program (CAP). The violations and corrective action tracking
provide a written response within 30 days of the date of this inspection report, with the basis for
numbers are listed in Section 4OA7 of this report.
your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Millstone Power Stations.
                                              iii


                                        REPORT DETAILS
 
Background
D. Heacock 2  
This report presents the results of a triennial fire protection inspection conducted in accordance
In accordance with Title 10 of the Code of Federal Regulations  
with the U.S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T,
(10 CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be
Fire Protection (Triennial). The objective of the inspection was to assess whether Dominion
available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's document system, Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible
Nuclear Connecticut, Inc. (Dominion) has implemented an adequate fire protection program
from the NRC Web Site at
(FPP) and that post-fire safe shutdown capabilities have been established and are being
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).  
properly maintained at the Millstone Power Station Unit 2 and Unit 3 (Millstone). The following
fire areas (FA) and/or fire zones (FZ) were selected for detailed review based on risk insights
Sincerely,              /RA/
from the Millstone Individual Plant Examination of External Events (IPEEE).
Christopher G. Cahill
        Unit 2 Fire Areas / Fire Zones
          R-7 / A-15, A Diesel Generator Room A
          R-1 / A-32, Main Ventilation Room (Air Handling Units)
          R-14 / T-7, 6.9 & 4.16 kV Switchgear Room
          R-14 / T-9, East Cable Vault
        Unit 3 Fire Areas
          AB-6, West MCC & Rod Control Area
          CB-11, Instrument Rack Room and Underfloor Area
          EG-3, North Emergency Generator Enclosure
          ESF-3, North Residual Heat Removal - Heat Exchanger Cubicle
Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a
minimum of three samples.
The inspection team evaluated Dominions FPP against applicable requirements which included
Unit 2 Renewed Facility Operating License Condition 2.C.(3), Unit 3 Renewed Facility Operating
License Conditions 2.H, NRC Safety Evaluation Reports (SERs), Title 10 of the Code of Federal
Regulations (10 CFR) 50.48, 10 CFR Part 50, Appendix R and Branch Technical Position (BTP)
Chemical Engineering Branch (CMEB) 9.5-1. The team also reviewed related documents that
included the Updated Final Safety Analysis Report (UFSAR), Fire Protection Program, Fire
Hazards Analyses (FHA), and post-fire Safe Shutdown Analyses Reports.
The team also evaluated two Unit 2 and two Unit 3 licensee mitigating strategies for addressing
large fires and explosions as required by Unit 2 Renewed Facility Operating License Condition
2.C.(13), Unit 3 Renewed Facility Operating License Condition 2.C.(10), and 10 CFR 50.54
(hh)(2). Inspection of these strategies fulfills the inspection procedure requirement to inspect a
minimum of one sample.
Specific documents reviewed by the team are listed in the Attachment to this report.


Acting Branch Chief
                                                2
Engineering Branch 3
1.    REACTOR SAFETY
Division of Reactor Safety
      Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
   
1R05 Fire Protection (IP 71111.05T)
Docket Nos. 50-336, 50-423
.01  Protection of Safe Shutdown Capabilities
License Nos. DPR-65, NPF-49
  a. Inspection Scope
      The team reviewed the FHA, safe shutdown analyses, and supporting drawings and
      documentation to verify that post-fire safe shutdown capabilities were properly protected.
      The team ensured that applicable separation requirements of Section III.G of 10 CFR
      Part 50, Appendix R for Unit 2 and BTP CMEB 9.5-1 for Unit 3 as well as the licensees
      design and licensing bases were maintained for the credited safe shutdown equipment
      and their supporting power, control, and instrumentation cables. This review included an
      assessment of the adequacy of the selected systems for reactivity control, reactor
      coolant makeup, reactor heat removal, process monitoring, and associated support
      system functions.
  b. Findings
      Introduction: The team identified a finding of very low safety significance (Green)
      involving a non-cited violation of Millstone Unit 2 Renewed Facility Operating License
      Condition 2.C.(3) to implement and maintain in effect all provisions of the approved fire
      protection program as described in the FSAR. Specifically, Dominion failed to maintain
      the #2 SG ADV free from fire damage, which may have affected the availability to
      maintain hot shutdown conditions from the main control room for a fire in Fire Area R-14,
      Lower 4.16kV Switchgear Room and Cable Vault.
      Description: The inspectors reviewed the operator manual actions (OMAs) contained in
      operating procedure AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area
      R-14, and compared them against the list of NRC approved OMAs in lieu of meeting
      III.G.2 fire protection requirements and determined that an unapproved OMA was being
      implemented in AOP 2579M. The OMAs in lieu of meeting III.G.2 fire protection
      requirements were approved in an NRC exemption dated December 18, 2012. The
      missing OMA was an action to locally operate air-operated valve, 2-MS-190B, #2 SG
      ADV. The OMA is necessary since a self-induced loss of offsite power (LOOP) will
      occur and station blackout (SBO) condition may occur from fire related cable damage.
      Either condition, LOOP or SBO, will cause a loss of instrument air in response to a
      significant fire in fire area R-14.
      The LOOP will occur when AOP 2579M is implemented because step 3.4 requires the
      operators to trip the reactor (causing a loss of the normal station service transformer)
      and step 3.9 requires the operators to direct CONVEX (transmission operator) to de-
      energize the reserve station service transformer. A SBO may subsequently occur if the
      B emergency diesel generator (EDG) is running and its output breaker does not close,


Enclosure: Inspection Report 05000336/2016007
                                              3
  and 05000423/2016007 
which could occur due to fire-related circuit damage. In either condition, LOOP or SBO,
w/Attachment:  Supplemental Information
the F instrument air compressor, will be de-energized and a loss of instrument air will
occur.
In 2011, Dominion submitted an exemption request to the NRC for several OMAs in lieu
of meeting III.G.2 fire protection requirements in several fire areas and initially postulated
a loss of instrument air for Fire Area R-14. Three OMAs were requested related to the
loss of instrument air for Fire Area R-14 in a June 30, 2011 exemption request letter to
the NRC. Subsequent to the June 30, 2011 exemption request letter, Dominion walked
down several fire areas and from a mechanical perspective concluded that a loss of
instrument air should no longer be postulated for several fire areas. R-14 was included
as a fire area for which a loss of instrument air was no longer considered credible. In a
request for additional information response letter dated February 29, 2012, Dominion
stated that the loss of instrument air was no longer postulated in fire area R-14 and
others, and requested the NRC delete the OMA for locally operating the #2 SG ADV. In
a correction letter dated October 29, 2012, Dominion again reiterated that for Fire Area
R-14, and others, a Loss of Instrument Air was not postulated, but Dominion clarified
that some of the OMAs that were related to a loss of instrument air should be retained
for postulated fire cable damage or loss of power. However, the OMA for locally
operating the #2 SG ADV was not retained since it was not susceptible to cable damage
or loss of power for a fire in area R-14. Dominion stated in its June 30, 2011 exemption
request letter to the NRC that after auxiliary feedwater (AFW) is established from the
control room, operation of the ADV (2-MS-1 90B) is the required method of removing
decay heat to maintain hot standby and transition to cold shutdown.
As described above, the inspectors determined that implementing AOP 2579M as
written will cause a loss of instrument air and the OMA to locally operate the #2 SG ADV
will be necessary after AFW is restored and decay heat removal is transitioned from the
main steam safety valves to the #2 SG ADV for steam generator pressure control. The
inspectors noted that Dominion is currently implementing an unapproved OMA in lieu of
meeting III.G.2 fire protection requirements. Dominion promptly entered this safe
shutdown issue into their corrective action program as CR 1043458. Immediate
corrective actions included implementing compensatory measures in the form of fire
watches for fire area R-14 that are being tracked by RAS determination 3037040.
Longer term corrective actions included submitting an exemption request to the NRC for
use of a local OMA to operate the #2 SG ADV in lieu of meeting fire protection
requirements for fire area R-14. The team considered Dominions immediate and longer
term corrective actions appropriate.
Analysis: Dominions failure to protect the #2 SG ADV, credited for post-fire safe
shutdown from fire damage in Fire Area R-14 caused by single spurious actuation, is
considered a performance deficiency. The performance deficiency was more than minor
because it affected the Mitigating Systems cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to an external event to
prevent undesirable consequences in the event of a fire. Specifically, the use of an
OMA during post-fire safe shutdown may not be as reliable as normal systems operation
which could be utilized had the requirements of 10 CFR Part 50, Appendix R, Section


cc w/encl:  Distribution via ListServ
                                                4
 
    III.G.2 been met and, therefore, prevented fire damage to credited components and/or
    cables, specifically the #2 SG ADV.
    The inspectors used IMC 0609, Appendix F, Fire Protection Significance Determination
    Process, Phase 1 and determined the reactor is able to reach and maintain a hot safe
    shutdown condition because the ADVs are used for transition to cold shutdown,
    therefore this finding was of very low safety significance (Green).
    This finding does not have a cross cutting aspect because the performance deficiency
    occurred greater than three years ago when the June 30, 2011 exemption request letter
    to the NRC was supplemented by letter on February 29, 2012, and is not indicative of
    current licensee performance.
    Enforcement: Millstone Power Station, Unit 2, Renewed Facility Operating License
    Condition 2.C.(3) requires Dominion in part to implement and maintain in effect all
    provisions of the approved fire protection program as described in the FSAR. FSAR
    Section 9.10.6, Safety Shutdown Design Bases, states in part Paragraph 50.48(b) of 10
    CFR 50, which became effective on February 17, 1981, that all nuclear plants licensed
    to operate prior to January 1, 1979, comply with specific portions of Section III of
    Appendix R to 10 CFR 50. Section III.G requires that fire protection features be
    provided for those systems, structures, and components important to safe shutdown.
    These features must be capable of limiting fire damage so that one train of systems
    necessary to achieve and maintain hot shutdown conditions from either the main control
    room or the emergency control stations is free of fire damage.
    Contrary to the above, since February 17, 1981 (the effective date of Appendix R and
    revised 10 CFR 50.48), and ongoing as of the inspection exit date, Dominion failed to
    implement all provisions of the approved fire protection program. Specifically, the safe
    shutdown strategy in Fire Area R-14 for Millstone Unit 2 relied upon an unapproved
    OMA to mitigate post-fire safe shutdown equipment malfunctions caused by a single
    spurious actuation, in lieu of protecting the equipment in accordance with 10 CFR Part
    50 Appendix R, Section III.G.2. The specific OMA associated with Fire Area R-14
    includes local manual control of the #2 SG ADV. Dominions immediate corrective
    actions included implementing compensatory measure in the form of fire watches for fire
    area R-14. Because this violation was of very low safety significance (Green), and was
    entered into Dominions CAP (CR 1043458), this issue is being treated as an NCV
    consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000336/2016007-01,
    Unapproved OMA in Lieu of Meeting III.G.2 Fire Protection Requirements for Fire
    Area R-14, Lower 4kV Switchgear Room and Cable Vault)
.02 Passive Fire Protection
  a. Inspection Scope
    The team walked down accessible portions of the selected fire areas to evaluate
    whether the material conditions of the fire area boundaries were adequate for the fire
    hazards in the area. The team compared the fire area boundaries, including walls,
    ceilings, floors, fire doors, fire dampers, penetration seals, and redundant equipment fire


ML16258A175  SUNSI Review
                                              5
  Non-Sensitive
    barriers to design and licensing basis requirements, industry standards, and the
    Publicly Available
    Millstone Power Station Unit 2 and Unit 3 FPPs, as approved by the NRC, to identify any
  OFFICE RI/DRS RI/DRS RI/DRP RI/DRS  NAME JPatel WCook GDentel CCahill  DATE 09/09/16 09/09/16 09/09/16 09/14/16 
    potential degradation or non-conformances.
    The team reviewed selected engineering evaluations, installation and repair work orders,
   i Enclosure
    and qualification records for a sample of penetration seals to determine whether the fill
  U.S. NUCLEAR REGULATORY COMMISSION
    material was properly installed and whether the as-left configuration satisfied design
REGION I 
    requirements for the intended fire rating.
Docket Nos.:  50-336, 50-423
    The team also reviewed recent inspection and functional test records for fire dampers,
    and the inspection records for penetration seals and fire barriers, to verify whether the
    inspection and testing was adequately conducted, the acceptance criteria were met, and
    any potential performance degradation was identified.
   b. Findings
    No findings were identified.
.03 Active Fire Protection
  a. Inspection Scope
    The team evaluated manual and automatic fire suppression and detection systems in the
    selected fire areas to determine whether they were installed, tested, maintained, and
    operated in accordance with NRC requirements, National Fire Protection Association
    (NFPA) codes of record, and the Millstone FPPs, as approved by the NRC. The team
    also assessed whether the suppression systems capabilities were adequate to control
    and/or extinguish fires associated with the hazards in the selected areas.
    The team reviewed the as-built capability of the fire water supply system to verify the
    design and licensing basis and NFPA code of record requirements were satisfied, and to
    assess whether those capabilities were adequate for the hazards involved. The team
    reviewed the fire water system hydraulic analyses to assess the adequacy of a single
    fire water pump to supply the largest single hydraulic load on the fire water system plus
    concurrent fire hose usage. The team evaluated the fire pump performance tests to
    assess the adequacy of the test acceptance criteria for pump minimum discharge
    pressure at the required flow rate, to verify the criteria was adequate to ensure that the
    design basis and hydraulic analysis requirements were satisfied. The team also
    evaluated the underground fire loop flow tests to verify the tests adequately
    demonstrated that the flow distribution circuits were able to meet design basis
    requirements. In addition, the team reviewed recent pump and loop flow test results to
    verify the testing was adequately conducted, the acceptance criteria were met, and any
    potential performance degradation was identified.
    The team reviewed initial discharge testing, design specifications, vendor requirements,
    modifications and engineering evaluations, and routine functional testing for the CO2 and
    Halon suppression systems for the areas protection. The team walked down accessible
    potions of the CO2 and Halon systems, including storage tanks and supply systems, to


                                                  6
    independently assess the material condition, operational lineup, and availability of the
License Nos.:  DPR-65, NPF-49
    systems. The team also reviewed and walked down the associated firefighting
    
    strategies and CO2 and Halon system operating procedures.
Report Nos.: 05000336/2016007 and 05000423/2016007
    The team walked down accessible portions of the detection and water suppression
    systems in the selected areas and major portions of the fire water supply system,
    including motor and diesel driven fire pumps, interviewed system and program
    engineers, and reviewed selected corrective action program documents (condition
    reports) to independently assess the material condition of the systems and components.
    In addition, the team reviewed recent test results for the fire detection and suppression
    systems for the selected fire areas to verify the testing was adequately conducted, the
    acceptance criteria were met, and any performance degradation was identified.
    The team assessed the fire brigade capabilities by reviewing training, qualification, and
    drill critique records. The team also reviewed Millstone's firefighting strategies (i.e. pre-
    fire plans) and smoke removal plans for the selected fire areas to determine if
    appropriate information was provided to fire brigade members and plant operators to
    identify safe shutdown equipment and instrumentation, and to facilitate suppression of a
    fire that could impact post-fire safe shutdown capability. The team independently
    inspected the fire brigade equipment, including personnel protective gear (e.g. turnout
    gear) and smoke removal equipment, to determine operational readiness for firefighting.
    In addition, the team reviewed Millstone's fire brigade equipment inventory and
    inspection procedure and recent inspection and inventory results to verify adequate
    equipment was available, and any potential material deficiencies were identified.
  b. Findings
    No findings were identified.
.04  Protection from Damage from Fire Suppression Activities
   a. Inspection Scope
    The team walked down the selected fire areas and adjacent areas, and reviewed
    selected documents to determine whether redundant safe shutdown trains could be
    potentially damaged from fire suppression activities or from the rupture or inadvertent
    operation of fire suppression systems. During the walkdowns, the team evaluated the
    adequacy and condition of floor drains, equipment elevations, and spray protection.
    Specifically, to determine whether a potential existed to damage redundant safe
    shutdown trains, the team evaluated whether:
              A fire in one of the selected fire areas would not release smoke, heat, or hot
              gases that could cause unintended activation of suppression systems in adjacent
              fire areas which could potentially damage all redundant safe shutdown trains; or
              A fire suppression system rupture, inadvertent actuation, or actuation due to a
              fire, in one of the selected fire areas, could not directly damage all redundant
              trains (e.g. sprinkler caused flooding of other than the locally affected train); and


   
                                              7
Licensee:  Dominion Nuclear Connecticut, Inc.  
            Adequate drainage was provided in areas protected by water suppression
              systems.
  b. Findings
Facility: Millstone Power Station, Units 2 and 3
    No findings were identified.
.05 Post-Fire Safe Shutdown Capability - Normal and Alternative
  a. Inspection Scope
    The team reviewed the safe shutdown analysis, thermal-hydraulic analysis, operating
    procedures, time critical operator action validation studies, piping and instrumentation
    drawings (P&lDs), electrical drawings, the UFSAR, and other supporting documents for
    the selected fire areas to verify whether Dominion had properly identified the systems
    and components necessary to achieve and maintain post-fire safe shutdown conditions.
    The team evaluated selected systems and components credited by the safe shutdown
    analysis for reactor pressure control, reactivity control, reactor coolant makeup, decay
    heat removal, process monitoring, and support system functions to assess the adequacy
    of Dominion's alternative shutdown methodology. The team also assessed whether
    alternative post-fire shutdown could be performed both with and without the availability
    of off-site power. The team walked down selected plant configurations to verify whether
    they were consistent with the assumptions and descriptions in the safe shutdown and
    fire hazards analyses. In addition, the team evaluated whether the systems and
    components credited for use during post-fire safe shutdown would remain free from fire
    damage.
    The team reviewed the training program for licensed and non-licensed operators to
    verify whether it included alternative shutdown capability. The team also verified
    whether personnel required for post-fire safe shutdown, using either the normal or
    alternative shutdown methods, were trained and available on-site at all times, exclusive
    of those assigned as fire brigade members.
    The team reviewed the adequacy of procedures utilized for post-fire shutdown and
    performed an independent walk through of procedure steps (i.e., a procedure tabletop)
    to assess the adequacy of implementation and human factors within the procedures.
    The team also evaluated the time required to perform specific actions to verify whether
    operators could reasonably be expected to perform those actions within sufficient time to
    maintain plant parameters within specified limits.
    Specific procedures reviewed for normal and alternative post-fire shutdown included the
    following:
          Unit 2
            AOP 2559, Fire;
            AOP 2579A, Fire Procedure for Hot Standby Appendix R Fire Area R-1;


   
                                                  8
  Location:  P.O. Box 128    Waterford, CT  06385
            AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown Appendix R Fire
            Area R-1;
            AOP 2579EE, Fire Procedure for Cooldown and Cold Shutdown Appendix R Fire
            Area R-7, R-9, R-14, and R-17;
            AOP 2579G, Fire Procedure for Hot Standby Appendix R Fire Area R-7; and,
            AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area R-14.
        Unit 3
            EOP 3509, Fire Emergency;
            EOP 3509.1, Control Room, Cable Spreading Area or Instrument Rack Room
            Fire;
            EOP 3509.6, Auxiliary Building West MCC/Rod Control/ACU Area Fire;
            EOP 3509.15, North (A) EDG Enclosure or East (A) F.O. Vault Fire; and,
            EOP 3509.19, ESF Building North RHR Heat Exchanger Cubicle Fire.
    The team reviewed selected operator manual actions to verify whether they had been
    properly reviewed and approved and whether the actions could be implemented in
    accordance with plant procedures in the time necessary to support the safe shutdown
    method for each fire area. The team also reviewed the periodic testing of the alternative
    shutdown transfer and isolation capability, and instrumentation and control functions, to
    evaluate whether the tests were adequate to ensure the functionality of the alternative
    shutdown capability.
  b.  Findings
    No findings were identified.
.06 Circuit Analysis
  a. Inspection Scope
    The team verified that the licensee performed a post-fire safe shutdown analysis for the
    selected fire areas and the analysis appropriately identified the structures, systems, and
    components important to achieving and maintaining safe shutdown. Additionally, the
    team verified that the licensees analysis ensured that necessary electrical circuits were
    properly protected and that circuits that could adversely impact safe shutdown due to hot
    shorts or shorts to ground were identified, evaluated, and dispositioned to ensure
    spurious actuations would not prevent safe shutdown.
    The teams review considered fire and cable attributes, cable routing, potential
    undesirable consequences and common power supply/bus concerns. Specific items
    included the credibility of the fire threat, cable insulation attributes, cable failure modes,
    and actuations resulting in flow diversion or loss of coolant events.
    The team also reviewed cable raceway drawings and/or cable routing databases for a
    sample of components required for post-fire safe shutdown to verify that cables were


                                                  9
    routed as described in the safe shutdown analysis. The team also reviewed equipment
Dates:  July 25, 2016 through August 11, 2016
    important to safe shutdown, but not part of the success path, to verify that the licensee
 
    had taken appropriate actions in accordance with the design and licensing basis and
Inspectors:  J. Patel, Reactor Inspector (Team Leader) 
    NRC Regulatory Guide 1.189, Revision 2.
  Division of Reactor Safety (DRS)
    Cable failure modes were reviewed for the following components:
  W. Cook, Senior Reactor Analyst, DRS
        Unit 2
  E. DiPaolo, Senior Reactor Inspector, DRS    D. Orr, Senior Reactor Inspector, DRS    K. Young, Senior Reactor Inspector, DRS
            P18B, Charging Pump B;
  L. Dumont, Reactor Inspector, DRS
            2-CH-501, VCT Outlet Header to Charging Pumps Isolation Valve;
  S. Galbreath, Reactor Inspector, DRS J. Rady, Reactor Inspector, DRS
            2-CH-519, Loop 1A Charging Isolation Valve; and,
Observers:  S. Freeman, Senior Reactor Analyst, NRC, Region II, DRS
            PI-1023B-1, SG #2 Pressure Indicator.
        Unit 3
Approved by:  Chris Cahill, Acting Branch Chief Engineering Branch 3
            3RCS*LCV459, VCT Letdown Isolation Valve;
Division of Reactor Safety
            3RCS*SV8095A, Head Vent Isolation Valve;
    
            3CHS*MV8438A, Charging Pump A Header Isolation Valve;
   ii  SUMMARY OF FINDINGS
            3FWS*LI501A, SG #1 Level Indicator; and,
IR 05000336/2016007, 05000423/2016007; 07/25/2016 - 08/11/2016; Dominion Nuclear
            3RCS*PI405B, RCS Pressure Indicator.
Connecticut, Inc.; Millstone Power Station, Units 2 and 3; Fire Protection (Triennial).  
    The team reviewed a sample of circuit breaker coordination studies to ensure equipment
    needed to conduct post-fire safe shutdown activities would not be impacted due to a lack
    of coordination that could result in a common power supply or common bus concern.
    The team verified that the transfer of control from the control room to the alternative
    shutdown location(s) would not be affected by fire-induced circuit faults (e.g. by the
    provision of separate fuses and power supplies for alternative shutdown control circuits).
   b. Findings
    No findings were identified.
.07  Communications
   a. Inspection Scope
    The team reviewed safe shutdown procedures, the safe shutdown analysis, and
    associated documents to verify an adequate method of communications would be
    available to plant operators following a fire. During this review the team considered the
    effects of ambient noise levels, clarity of reception, reliability, and coverage patterns.
    The team also inspected the designated emergency storage lockers to verify the
    availability of portable radios for the fire brigade and for plant operators. The team also
    verified that communications equipment such as repeaters and transmitters would not be
    affected by a fire.


   
                                              10
This report covered a two week on-site triennial fire protection team inspection by specialist inspectors.  One finding of very low safety significance was identified.  This finding was determined to be a non-cited violation. The significance of most findings is indicated by their
  b. Findings
color (Green, While, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process."  The cross-cutting aspects associated with findings were determined
    No findings were identified.
using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the
.08 Emergency Lighting
significance determination process (SDP) does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6, dated July 2016.  
  a. Inspection Scope
    The team observed the placement and coverage area of eight-hour emergency lights
    throughout the selected fire areas to evaluate their adequacy for illuminating access and
    egress pathways and any equipment requiring local operation or instrumentation
    monitoring for post-fire safe shutdown. The team also verified that the battery power
    supplies were rated for at least an eight-hour capacity. Preventive maintenance
    procedures, the vendor manual, completed surveillance tests, and battery replacement
    practices were also reviewed to verify that the emergency lighting was being maintained
    consistent with the manufacturers recommendations and in a manner that would ensure
    reliable operation.
b.  Findings
    No findings were identified.
.09 Cold Shutdown Repairs
  a. Inspection Scope
    The team reviewed Dominion's dedicated repair procedures, for components which
    might be damaged by fire and were required to achieve post-fire cold shutdown (CSD).
    The team evaluated selected CSD repairs to determine whether they could be achieved
    within the time frames assumed in the design and licensing bases. In addition, the team
    verified whether the necessary repair equipment, tools, and materials (e.g., pre-cut
    cables with prepared attachment lugs) were available and accessible on site.
  b. Findings
    No findings were identified.
.10 Compensatory Measures
  a. Inspection Scope
    The team verified compensatory measures were in place for out-of-service, degraded, or
    inoperable fire protection and post-fire safe shutdown equipment, systems, or features
    (e.g., detection and suppression systems and equipment, passive fire barriers, pumps,
    valves, or electrical devices providing safe shutdown functions or capabilities). The
    team evaluated whether the short term compensatory measures adequately
    compensated for the degraded function or feature until appropriate corrective action


  Cornerstone:  Mitigating Systems
                                              11
  Green. The team identified a finding of very low safety significance (Green) involving a non-cited violation of Millstone Power Station, Unit 2, Renewed Facility Operating License Condition 2.C.(3) to implement and maintain in effect all provisions of the approved fire
    could be taken and that the licensee was effective in returning the equipment to service
protection program as described in the Final Safety Analysis Report (FSAR).  Specifically, Dominion failed to maintain the #2 steam generator (SG) atmospheric dump valve (ADV)
    in a reasonable period of time.
free from fire damage, which may have affected the availability to maintain hot shutdown
  b. Findings
conditions from the main control room for a fire in Fire Area R-14, Lower 4.16kV Switchgear Room and Cable Vault.
    No findings were identified.
  Dominion promptly entered this safe shutdown issue into their corrective action program as condition report (CR) 1043458. Immediate corrective actions included implementing compensatory measures in the form of fire watches for fire area R-14
.11 Fire Protection Program Changes
that are being tracked by Reasonable Assurance of Safety (RAS) determination 3037040.
  a. Inspection Scope
    The team reviewed recent changes to the approved fire protection program to verify that
    the changes did not constitute an adverse effect on the ability to safely shutdown.
  b. Findings
    No findings were identified.
.12  Control of Transient Combustibles and Ignition Sources
  a. Inspection Scope
    The team reviewed the licensees procedures and programs for the control of ignition
    sources and transient combustibles to assess their effectiveness in preventing fires and
    in controlling combustible loading within limits established in the FHA. A sample of hot
    work and transient combustible control permits were also reviewed. The team
    performed plant walkdowns to verify that transient combustibles and ignition sources
    were being implemented in accordance with the administrative controls.
  b. Findings
    No findings were identified.
.13 Large Fires and Explosions Mitigation Strategies
  a. Inspection Scope
    The team conducted a review of selected mitigation strategies intended to maintain or
    restore core decay heat removal and spent fuel pool cooling capabilities under the
    circumstances associated with the loss of large areas of the plant due to explosions
    and/or fires. The team assessed whether Dominion continued to meet the requirements
    of the Millstone Power Station Units 2 and 3 Operating Licenses and 10 CFR
    50.54(hh)(2).
    The team reviewed the following mitigation strategies:
            Unit 2 and 3 Manual Operation of Turbine-Driven AFW Pump; and,
            Unit 2 and 3 Manual Operation of SG ADVs.


Longer term corrective actions included submitting an exemption request to the NRC for use of a local operator manual action (OMA) to operate the #2 SG ADV in lieu of meeting fire protection requirements for fire area R-14.  The team considered Dominion's immediate and
                                                12
longer term corrective actions appropriate.
    The team's review included: a detailed assessment of the procedural guidance; a
The performance deficiency was more than minor because it affected the Mitigating
    tabletop discussion with licensed operators; and a walk down of four mitigation
Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to an external event to prevent undesirable consequences in the event of a fire.  Specifically, the use of an OMA during post-fire safe shutdown is not as reliable as normal
    strategies with operators to assess the feasibility of the strategies and operator
systems operation which could be utilized had the requirements of 10 CFR Part 50,
    familiarity; maintenance and surveillance testing of selected strategy equipment; and an
Appendix R, Section III.G.2 been met and, therefore, prevented fire damage to credited
    inventory check of the B.5.b pump and equipment trailers to ensure the appropriateness
components and/or cables, specifically the #2 SG ADV.  The inspectors used IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 and determined the reactor is able to reach and maintain a hot safe shutdown condition because the SG
    of equipment storage and availability.
ADVs are used for transition to cold shutdown, therefore this finding was of very low safety significance (Green).  This finding does not have a cross cutting aspect because the
  b. Findings
performance deficiency occurred greater than three years ago when the June 30, 2011
    No findings were identified.
exemption request letter to the NRC was supplemented by letter on February 29, 2012, and is not indicative of current licensee performance.  (Section 1R05.01) 
4.   OTHER ACTIVITIES [OA]
  iii    Other Findings
4OA2 Identification and Resolution of Problems (IP 71152)
Three violations of very low safety significance that were identified by Dominion were reviewed by the team.  Corrective actions taken or planned by Dominion have been entered into
.01 Corrective Actions for Fire Protection Deficiencies
Dominion's corrective action program (CAP).  The violations and corrective action tracking
   a. Inspection Scope
numbers are listed in Section 4OA7 of this report.
    The team reviewed a sample of condition reports associated with fire protection program
 
    and post-fire safe shutdown issues to determine whether Millstone was appropriately
 
    identifying, characterizing, and correcting problems in these areas, and to assess
  REPORT DETAILS
    whether the planned or completed corrective actions were appropriate.
Background
   b. Findings
    No findings were identified.
This report presents the results of a triennial fire protection inspection conducted in accordance
 
with the U.S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T,
"Fire Protection (Triennial)."  The objective of the inspection was to assess whether Dominion
Nuclear Connecticut, Inc. (Dominion) has implemented an adequate fire protection program
(FPP) and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Millstone Power Station Unit 2 and Unit 3 (Millstone).  The following fire areas (FA) and/or fire zones (FZ) were selected for detailed review based on risk insights
from the Millstone Individual Plant Exam
ination of External Events (IPEEE).
  Unit 2 Fire Areas / Fire Zones
  R-7 / A-15, "A" Diesel Generator Room A  R-1 / A-32, Main Ventilation Room (Air Handling Units)  R-14 / T-7, 6.9 & 4.16 kV Switchgear Room  R-14 / T-9, East Cable Vault
Unit 3 Fire Areas
  AB-6, West MCC & Rod Control Area  CB-11, Instrument Rack Room and Underfloor Area  EG-3, North Emergency Generator Enclosure  ESF-3, North Residual Heat Removal - Heat Exchanger Cubicle
Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a
minimum of three samples.
The inspection team evaluated Dominion's FPP against applicable requirements which included
Unit 2 Renewed Facility Operating License Condition 2.C.(3), Unit 3 Renewed Facility Operating
License Conditions 2.H, NRC Safety Evaluation Reports (SERs), Title 10 of the
Code of Federal
Regulations (10 CFR) 50.48, 10 CFR Part 50, Appendix R and Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1. 
The team also reviewed related documents that included the Updated Final Safety Analysis Repor
t (UFSAR), Fire Protection Program, Fire
Hazards Analyses (FHA), and post-fire Safe Shutdown Analyses Reports.
 
The team also evaluated two Unit 2 and two Unit 3 licensee mitigating strategies for addressing
large fires and explosions as required by Unit 2 Renewed Facility Operating License Condition 2.C.(13), Unit 3 Renewed Facility Operating License Condition 2.C.(10), and 10 CFR 50.54 (hh)(2).  Inspection of these strategies fulfills the inspection procedure requirement to inspect a minimum of one sample.
 
Specific documents reviewed by the team are listed in the Attachment to this report.
 
2  1. REACTOR SAFETY
Cornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity
1R05 Fire Protection (IP 71111.05T) 
.01 Protection of Safe Shutdown Capabilities
  a. Inspection Scope 
The team reviewed the FHA, safe shutdown analyses, and supporting drawings and documentation to verify that post-fire safe shutdown capabilities were properly protected.  The team ensured that applicable separation requirements of Section III.G of 10 CFR
Part 50, Appendix R for Unit 2 and BTP CMEB 9.5-1 for Unit 3 as well as the licensee's
design and licensing bases were maintained for the credited safe shutdown equipment
and their supporting power, control, and instrumentation cables.  This review included an
assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.
    b. Findings
Introduction:  The team identified a finding of very low safety significance (Green) involving a non-cited violation of Millstone Unit 2 Renewed Facility Operating License Condition 2.C.(3) to implement and maintain in effect all provisions of the approved fire
protection program as described in the FSAR.  Specifically, Dominion failed to maintain
the #2 SG ADV free from fire damage, which may have affected the availability to maintain hot shutdown conditions from the main control room for a fire in Fire Area R-14, Lower 4.16kV Switchgear Room and Cable Vault.
Description:  The inspectors reviewed the operator manual actions (OMAs) contained in operating procedure AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area
R-14, and compared them against the list of NRC approved OMAs in lieu of meeting III.G.2 fire protection requirements and determined that an unapproved OMA was being implemented in AOP 2579M.  The OMAs in
lieu of meeting III.G.2 fire protection requirements were approved in an NRC exemption dated December 18, 2012.  The
missing OMA was an action to locally operate air-operated valve, 2-MS-190B, #2 SG
ADV.  The OMA is necessary since a self-induced loss of offsite power (LOOP) will occur and station blackout (SBO) condition may occur from fire related cable damage.  Either condition, LOOP or SBO, will cause a loss of instrument air in response to a
significant fire in fire area R-14.
The LOOP will occur when AOP 2579M is implemented because step 3.4 requires the
operators to trip the reactor (causing a loss of the normal station service transformer) and step 3.9 requires the operators to direct CONVEX (transmission operator) to de-energize the reserve station service transformer.  A SBO may subsequently occur if the
B emergency diesel generator (EDG) is running and its output breaker does not close, 
 
3  which could occur due to fire-related circuit damage.  In either condition, LOOP or SBO, the 'F' instrument air compressor, will be de-energized and a loss of instrument air will
 
occur.  In 2011, Dominion submitted an exemption request to the NRC for several OMAs in lieu of meeting III.G.2 fire protection requirements in several fire areas and initially postulated a loss of instrument air for Fire Area R-14.  Three OMAs were requested related to the
loss of instrument air for Fire Area R-14 in a June 30, 2011 exemption request letter to
the NRC.  Subsequent to the June 30, 2011 exemption request letter, Dominion walked
down several fire areas and from a mechanical perspective concluded that a loss of instrument air should no longer be postulated for several fire areas.  R-14 was included as a fire area for which a loss of instrument air was no longer considered credible.  In a
request for additional information response letter dated February 29, 2012, Dominion
stated that the loss of instrument air was no longer postulated in fire area R-14 and
others, and requested the NRC delete the OMA for
locally operating the #2 SG ADV.  In a correction letter dated October 29, 2012, Dominion again reiterated that for Fire Area R-14, and others, a Loss of Instrument Air was not postulated, but Dominion clarified that some of the OMAs that were related to a loss of instrument air should be retained
for postulated fire cable damage or loss of power.  However, the OMA for locally
operating the #2 SG ADV was not retained since it was not susceptible to cable damage
or loss of power for a fire in area R-14.  Dominion stated in its June 30, 2011 exemption request letter to the NRC that after auxiliary feedwater (AFW) is established from the control room, operation of the ADV (2-MS-1 90B) is the required method of removing
decay heat to maintain hot standby and transition to cold shutdown.
As described above, the inspectors determined that implementing AOP 2579M as
written will cause a loss of instrument air and the OMA to locally operate the #2 SG ADV will be necessary after AFW is restored and decay heat removal is transitioned from the main steam safety valves to the #2 SG ADV for steam generator pressure control.  The
inspectors noted that Dominion is currently implementing an unapproved OMA in lieu of
meeting III.G.2 fire protection requirements.  Dominion promptly entered this safe
shutdown issue into their corrective action program as CR 1043458.  Immediate corrective actions included implementing compensatory measures in the form of fire watches for fire area R-14 that are being tracked by RAS determination 3037040. 
 
Longer term corrective actions included submitting an exemption request to the NRC for use of a local OMA to operate the #2 SG ADV in lieu of meeting fire protection
requirements for fire area R-14.  The team considered Dominion's immediate and longer term corrective actions appropriate.
Analysis:  Dominion's failure to protect the #2 SG ADV, credited for post-fire safe shutdown from fire damage in Fire Area R-14 caused by single spurious actuation, is
considered a performance deficiency.  The performance deficiency was more than minor
because it affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to an external event to prevent undesirable consequences in the event of a fire.  Specifically, the use of an
OMA during post-fire safe shutdown may not be as reliable as normal systems operation
which could be utilized had the requirements of 10 CFR Part 50, Appendix R, Section 
4  III.G.2 been met and, therefore, prevented fire damage to credited components and/or cables, specifically the #2 SG ADV.
The inspectors used IMC 0609, Appendix F, Fire Protection Significance Determination
Process, Phase 1 and determined the reactor is able to reach and maintain a hot safe shutdown condition because the ADVs are used for transition to cold shutdown, therefore this finding was of very low safety significance (Green).
This finding does not have a cross cutting aspect because the performance deficiency
occurred greater than three years ago when the June 30, 2011 exemption request letter to the NRC was supplemented by letter on February 29, 2012, and is not indicative of current licensee performance. 
Enforcement:  Millstone Power Station, Unit 2, Renewed Facility Operating License Condition 2.C.(3) requires Dominion in part to implement and maintain in effect all
provisions of the approved fire protection program as described in the FSAR.  FSAR Section 9.10.6, Safety Shutdown Design Bases, states in part Paragraph 50.48(b) of 10 CFR 50, which became effective on February 17, 1981, that all nuclear plants licensed
to operate prior to January 1, 1979, comply with specific portions of Section III of
Appendix R to 10 CFR 50.  Section III.G requires that fire protection features be
provided for those systems, structures, and components important to safe shutdown. These features must be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions from either the main control
room or the emergency control stations is free of fire damage. 
Contrary to the above, since February 17, 1981 (the effective date of Appendix R and
revised 10 CFR 50.48), and ongoing as of the inspection exit date, Dominion failed to implement all provisions of the approved fire protection program.  Specifically, the safe shutdown strategy in Fire Area R-14 for Millstone Unit 2 relied upon an unapproved
OMA to mitigate post-fire safe shutdown equipment malfunctions caused by a single
spurious actuation, in lieu of protecting the equipment in accordance with 10 CFR Part
50 Appendix R, Section III.G.2.  The specific OMA associated with Fire Area R-14 includes local manual control of the #2 SG ADV.  Dominion's immediate corrective actions included implementing compensatory measure in the form of fire watches for fire area R-14.  Because this violation was of very low safety significance (Green), and was
entered into Dominion's CAP (CR 1043458), this issue is being treated as an NCV
consistent with Section 2.3.2 of the Enforcement Policy.  (NCV 05000336/2016007-01, Unapproved OMA in Lieu of Meeting III.G.2 Fire Protection Requirements for Fire
Area R-14, Lower 4kV Switchgear Room and Cable Vault)
  .02 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to evaluate
whether the material conditions of the fire area boundaries were adequate for the fire
hazards in the area.  The team compared the fire area boundaries, including walls,
ceilings, floors, fire doors, fire dampers, penetration seals, and redundant equipment fire 
5  barriers to design and licensing basis requirements, industry standards, and the Millstone Power Station Unit 2 and Unit 3 FPPs, as approved by the NRC, to identify any
potential degradation or non-conformances.
The team reviewed selected engineering evaluations, installation and repair work orders, and qualification records for a sample of penetration seals to determine whether the fill material was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating. 
The team also reviewed recent inspection and functional test records for fire dampers, and the inspection records for penetration seals and fire barriers, to verify whether the inspection and testing was adequately conducted, the acceptance criteria were met, and
any potential performance degradation was identified.
 
  b. Findings
No findings were identified.
  .03 Active Fire Protection
    a. Inspection Scope
The team evaluated manual and automatic fire suppression and detection systems in the
selected fire areas to determine whether they were installed, tested, maintained, and
operated in accordance with NRC requirements, National Fire Protection Association
(NFPA) codes of record, and the Millstone
FPPs, as approved by the NRC.  The team also assessed whether the suppression systems capabilities were adequate to control and/or extinguish fires associated with the hazards in the selected areas.
The team reviewed the as-built capability of the fire water supply system to verify the design and licensing basis and NFPA code of record requirements were satisfied, and to
assess whether those capabilities were adequate for the hazards involved.  The team
reviewed the fire water system hydraulic analyses to assess the adequacy of a single fire water pump to supply the largest single hydraulic load on the fire water system plus
concurrent fire hose usage.  The team evaluated the fire pump performance tests to
assess the adequacy of the test acceptance criteria for pump minimum discharge
pressure at the required flow rate, to verify the criteria was adequate to ensure that the design basis and hydraulic analysis requirements were satisfied.  The team also evaluated the underground fire loop flow tests to verify the tests adequately
demonstrated that the flow distribution circuits were able to meet design basis
requirements.  In addition, the team reviewed recent pump and loop flow test results to
verify the testing was adequately conducted, the acceptance criteria were met, and any
potential performance degradation was identified.
The team reviewed initial discharge testing, design specifications, vendor requirements, modifications and engineering evaluations, and routine functional testing for the CO
2 and Halon suppression systems for the areas protection.  The team walked down accessible
potions of the CO
2 and Halon systems, including storage tanks and supply systems, to 
6  independently assess the material condition, operational lineup, and availability of the systems.  The team also reviewed and walked down the associated firefighting
strategies and CO
2 and Halon system operating procedures. 
The team walked down accessible portions of the detection and water suppression systems in the selected areas and major portions of the fire water supply system, including motor and diesel driven fire
pumps, interviewed system and program engineers, and reviewed selected correct
ive action program documents (condition reports) to independently assess the material condition of the systems and components.  In addition, the team reviewed recent test results for the fire detection and suppression systems for the selected fire areas to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified. 
 
The team assessed the fire brigade capabilities by reviewing training, qualification, and
drill critique records.  The team also reviewed Millstone's firefighting strategies (i.e. pre-
fire plans) and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a
fire that could impact post-fire safe shutdown capability.  The team independently
inspected the fire brigade equipment, including personnel protective gear (e.g. turnout
gear) and smoke removal equipment, to determine operational readiness for firefighting.  In addition, the team reviewed Millstone's fire brigade equipment inventory and inspection procedure and recent inspection and inventory results to verify adequate
equipment was available, and any potential material deficiencies were identified.
  b.  Findings
No findings were identified.
.04 Protection from Damage from Fire Suppression Activities
  a. Inspection Scope
The team walked down the selected fire areas and adjacent areas, and reviewed
selected documents to determine whether redundant safe shutdown trains could be
potentially damaged from fire suppression activi
ties or from the rupture or inadvertent operation of fire suppression systems.  During the walkdowns, the team evaluated the adequacy and condition of floor drains, equipment elevations, and spray protection. 
Specifically, to determine whether a potential existed to damage redundant safe shutdown trains, the team evaluated whether:
  A fire in one of the selected fire areas would not release smoke, heat, or hot gases that could cause unintended activation of suppression systems in adjacent fire areas which could potentially damage all redundant safe shutdown trains; or
  A fire suppression system rupture, inadvertent actuation, or actuation due to a fire, in one of the selected fire areas, could not directly damage all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and 
7    Adequate drainage was provided in areas protected by water suppression systems. 
  b. Findings
No findings were identified. 
.05 Post-Fire Safe Shutdown Capability - Normal and Alternative
    a.  Inspection Scope
The team reviewed the safe shutdown analysis, thermal-hydraulic analysis, operating procedures, time critical operator action validation studies, piping and instrumentation
drawings (P&lDs), electrical drawings, the UFSAR, and other supporting documents for
the selected fire areas to verify whether Dominion had properly identified the systems
and components necessary to achieve and maintain post-fire safe shutdown conditions. 
The team evaluated selected systems and co
mponents credited by the safe shutdown analysis for reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions to assess the adequacy
of Dominion's alternative shutdown methodology.  The team also assessed whether
alternative post-fire shutdown could be perfo
rmed both with and without the availability of off-site power.  The team walked down selected plant configurations to verify whether they were consistent with the assumptions and descriptions in the safe shutdown and fire hazards analyses.  In addition, the team evaluated whether the systems and
components credited for use during post-fire safe shutdown would remain free from fire
 
damage. 
 
The team reviewed the training program for licensed and non-licensed operators to verify whether it included alternative shutdown capability.  The team also verified
whether personnel required for post-fire safe shutdown, using either the normal or
alternative shutdown methods, were trained and available on-site at all times, exclusive of those assigned as fire brigade members.
 
The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps (i.e., a procedure tabletop)
to assess the adequacy of implementation and human factors within the procedures. 
The team also evaluated the time required to perform specific actions to verify whether
operators could reasonably be expected to perform those actions within sufficient time to maintain plant parameters within specified limits. 
Specific procedures reviewed for normal and alternative post-fire shutdown included the
 
following:
 
Unit 2  AOP 2559, Fire;  AOP 2579A, Fire Procedure for Hot Standby Appendix R Fire Area R-1; 
8    AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown Appendix R Fire
Area R-1;  AOP 2579EE, Fire Procedure for Cooldown and Cold Shutdown Appendix R Fire
Area R-7, R-9, R-14, and R-17;  AOP 2579G, Fire Procedure for Hot Standby Appendix R Fire Area R-7; and,  AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area R-14.
Unit 3  EOP 3509, Fire Emergency;  EOP 3509.1, Control Room, Cable Spreading Area or Instrument Rack Room
Fire;  EOP 3509.6, Auxiliary Building West MCC/Rod Control/ACU Area Fire;  EOP 3509.15, North (A) EDG Enclosure or East (A) F.O. Vault Fire; and,  EOP 3509.19, ESF Building North RHR Heat Exchanger Cubicle Fire.
The team reviewed selected operator manual actions to verify whether they had been properly reviewed and approved and whether the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown
method for each fire area.  The team also reviewed the periodic testing of the alternative
shutdown transfer and isolation capability, and instrumentation and control functions, to
evaluate whether the tests were adequate to ensure the functionality of the alternative
shutdown capability.
b. Findings
No findings were identified.
    .06 Circuit Analysis
  a. Inspection Scope 
The team verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown.  Additionally, the
team verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot
shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The team's review considered fire and cable attributes, cable routing, potential
undesirable consequences and common power supply/bus concerns.  Specific items
included the credibility of the fire threat, cable insulation attributes, cable failure modes,
and actuations resulting in flow diversion or loss of coolant events.
The team also reviewed cable raceway drawings and/or cable routing databases for a
sample of components required for post-fire safe shutdown to verify that cables were 
9  routed as described in the safe shutdown analysis.  The team also reviewed equipment important to safe shutdown, but not part of the success path, to verify that the licensee
had taken appropriate actions in accordance with the design and licensing basis and
NRC Regulatory Guide 1.189, Revision 2.
 
Cable failure modes were reviewed for the following components:
Unit 2  P18B, Charging Pump 'B';  2-CH-501, VCT Outlet Header to Charging Pumps Isolation Valve;  2-CH-519, Loop 1A Charging Isolation Valve; and,  PI-1023B-1, SG #2 Pressure Indicator.
Unit 3  3RCS*LCV459, VCT Letdown Isolation Valve;  3RCS*SV8095A, Head Vent Isolation Valve;  3CHS*MV8438A, Charging Pump 'A' Header Isolation Valve;  3FWS*LI501A, SG #1 Level Indicator; and,  3RCS*PI405B, RCS Pressure Indicator.
The team reviewed a sample of circuit breaker coordination studies to ensure equipment
needed to conduct post-fire safe shutdown activities would not be impacted due to a lack
of coordination that could result in a common power supply or common bus concern. 
The team verified that the transfer of control from the control room to the alternative
shutdown location(s) would not be affected by fire-induced circuit faults (e.g. by the
provision of separate fuses and power supplies for alternative shutdown control circuits).
    b. Findings
No findings were identified.
 
.07 Communications
    a. Inspection Scope 
The team reviewed safe shutdown procedures, the safe shutdown analysis, and
associated documents to verify an adequate method of communications would be
available to plant operators following a fire.  During this review the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns.  The team also inspected the designated emergency storage lockers to verify the
availability of portable radios for the fire brigade and for plant operators.  The team also
verified that communications equipment such as repeaters and transmitters would not be
affected by a fire.
   
10    b. Findings
No findings were identified.
.08 Emergency Lighting
  a. Inspection Scope
The team observed the placement and coverage area of eight-hour emergency lights
throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation or instrumentation monitoring for post-fire safe shutdown.  The team also verified that the battery power
supplies were rated for at least an eight-hour capacity.  Preventive maintenance
procedures, the vendor manual, completed surveillance tests, and battery replacement
practices were also reviewed to verify that the emergency lighting was being maintained
consistent with the manufacturer's recommendations and in a manner that would ensure reliable operation.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
  a. Inspection Scope
The team reviewed Dominion's dedicated repair procedures, for components which might be damaged by fire and were required to achieve post-fire cold shutdown (CSD).  The team evaluated selected CSD repairs to determine whether they could be achieved
within the time frames assumed in the design and licensing bases.  In addition, the team
verified whether the necessary repair equipment, tools, and materials (e.g., pre-cut
cables with prepared attachment lugs) were available and accessible on site. 
  b. Findings
No findings were identified.
 
.10 Compensatory Measures
    a. Inspection Scope
The team verified compensatory measures were in place for out-of-service, degraded, or
inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment, passive fire barriers, pumps, valves, or electrical devices providing safe shutdown functions or capabilities).  The team evaluated whether the short term compensatory measures adequately
compensated for the degraded function or feature until appropriate corrective action 
11  could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.
 
  b. Findings 
No findings were identified.
.11 Fire Protection Program Changes
    a. Inspection Scope
The team reviewed recent changes to the approved fire protection program to verify that
the changes did not constitute an adverse effect on the ability to safely shutdown.
  b. Findings 
No findings were identified.
.12 Control of Transient Combustibles and Ignition Sources
    a. Inspection Scope
The team reviewed the licensee's procedures and programs for the control of ignition
sources and transient combustibles to assess their effectiveness in preventing fires and
in controlling combustible loading within limits established in the FHA.  A sample of hot work and transient combustible control permits were also reviewed.  The team
performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
  b. Findings 
No findings were identified.
.13 Large Fires and Explosions Mitigation Strategies
    a. Inspection Scope
The team conducted a review of selected mitigation strategies intended to maintain or restore core decay heat removal and spent fuel pool cooling capabilities under the
circumstances associated with the loss of large areas of the plant due to explosions
and/or fires.  The team assessed whether Dominion continued to meet the requirements
of the Millstone Power Station Units 2 and 3 Operating Licenses and 10 CFR
 
50.54(hh)(2). 
The team reviewed the following mitigation strategies:
 
  Unit 2 and 3 Manual Operation of Turbine-Driven AFW Pump; and,  Unit 2 and 3 Manual Operation of SG ADVs. 
12    The team's review included: a detailed assessment of the procedural guidance; a  
tabletop discussion with licensed operators; and a walk down of four mitigation  
strategies with operators to assess the feasibility of the strategies and operator  
familiarity; maintenance and surveillance testing of selected strategy equipment; and an inventory check of the B.5.b pump and equipment trailers to ensure the appropriateness of equipment storage and availability.  
 
  b. Findings  
No findings were identified.  
4. OTHER ACTIVITIES [OA]  
4OA2 Identification and Resolution of Problems (IP 71152)
  .01 Corrective Actions for Fire Protection Deficiencies  
   a. Inspection Scope  
The team reviewed a sample of condition reports associated with fire protection program and post-fire safe shutdown issues to determine whether Millstone was appropriately identifying, characterizing, and correcting problems in these areas, and to assess  
whether the planned or completed corrective actions were appropriate.  
   b. Findings
No findings were identified.  
4OA3 Follow-up of Events and Notices of Enforcement Discretion (IP 71153)
4OA3 Follow-up of Events and Notices of Enforcement Discretion (IP 71153)
  .1 (Closed) Licensee Event Report (LER) 05000336/2013-003-00 (Unit 2): Postulated DC Ammeter Circuit Hot Shorts  
.1   (Closed) Licensee Event Report (LER) 05000336/2013-003-00 (Unit 2): Postulated DC
On October 30, 2013, during a review of industry operating experience, Dominion  
    Ammeter Circuit Hot Shorts
identified a postulated fire induced circuit failure involving unfused direct current (DC)  
    On October 30, 2013, during a review of industry operating experience, Dominion
ammeter circuits for Millstone Power Station, Unit 2. The fire induced circuit failures could cause a secondary fire that could adversely affect safe shutdown equipment and cause a loss of alternate shutdown capability which is contrary to Unit 2 Renewed  
    identified a postulated fire induced circuit failure involving unfused direct current (DC)
Facility Operating License Condition 2.C.(3) and Appendix R requirements. The license  
    ammeter circuits for Millstone Power Station, Unit 2. The fire induced circuit failures
condition and regulation requires in part, post-fire safe shutdown cables remain free of  
    could cause a secondary fire that could adversely affect safe shutdown equipment and
the effects of fire-induced cable faults during postulated fires. Specifically, the licensee  
    cause a loss of alternate shutdown capability which is contrary to Unit 2 Renewed
identified DC ammeter circuits for Unit 2, were not provided with overcurrent protection to limit fault current in the 125 volt (V) DC systems. Postulated fires that result in a short to ground concurrent with an opposite polarity short from the same battery could result in  
    Facility Operating License Condition 2.C.(3) and Appendix R requirements. The license
excessive current flow in the ammeter wiring. The excessive current could heat-up the  
    condition and regulation requires in part, post-fire safe shutdown cables remain free of
conductor and could result in a secondary fire in another fire area. The secondary fire  
    the effects of fire-induced cable faults during postulated fires. Specifically, the licensee
could adversely affect safe shutdown equipment and cause a loss of alternate shutdown
    identified DC ammeter circuits for Unit 2, were not provided with overcurrent protection
13  capability.  Dominion determined the cause of the condition was a latent design error that was made during plant construction involving the failure to include protective fuses
    to limit fault current in the 125 volt (V) DC systems. Postulated fires that result in a short
in DC ammeter circuits.
    to ground concurrent with an opposite polarity short from the same battery could result in
 
    excessive current flow in the ammeter wiring. The excessive current could heat-up the
    conductor and could result in a secondary fire in another fire area. The secondary fire
The licensee submitted LER 05000336/2013-003-00 to report this event in accordance with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly degraded plant safety.  The licensee entered this issue into their corrective action program as condition report number CR530987 and implemented compensatory measures in the
    could adversely affect safe shutdown equipment and cause a loss of alternate shutdown
affected fire areas pending final resolution of the issue.
The licensee completed an engineering evaluation (RAS000244) of the issue and developed a design change (MP2-14-01007) to add fuses to the affected ammeter
circuits.  Dominion completed the necessary modifications for all affected ammeter
circuits by May 7, 2014.
The significance and enforcement aspect of this issue are discussed in Section 4OA7.1 of this inspection report.  LER 05000336/2013-003-00 is closed.
.2 (Closed) Licensee Event Report (LER) 05000336/2014-002-00 (Unit 2):  DC Circuit Hot
Shorts  On March 12, 2014, during a review of industry operating experience, Dominion identified postulated fire induced circuit failures involving unfused DC motor control
circuits for Millstone Power Station Unit 2.  The postulated fire induced circuit failures could cause a secondary fire that could adversely affect fire safe shutdown equipment
contrary to Unit 2 Renewed Facility Operating License Condition 2.C.(3) and Appendix R requirements.  The license condition and regulation requires in part, post-fire safe shutdown cables remain free of the effects of fire induced cable faults during postulated fires.  Specifically, the licensee identified 125 V DC control and indication circuits for a
non-safety related main turbine emergency lube oil pump that was not provided with overcurrent protection.  Postulated fires in the turbine battery room, the cable vault, the
plant equipment operator meeting area and the control room could cause failure of the unprotected 125 V DC circuits, which in turn could cause failure of the control circuits for safe shutdown equipment.  Dominion determined the cause of the condition was a
manufacturer's design error that involved the failure to include protective fuses in DC
motor control circuits during plant construction.
The licensee submitted LER 05000336/2014-002-00 (Unit 2) to report this event in accordance with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly degraded plant safety.  The licensee entered this issue into their corrective action
program as condition report number CR541980 and implemented compensatory measures in the affected fire areas pending final resolution of the issue.
The licensee completed an engineering evaluation (RAS000252) of the issue and
developed a design change (MP2-14-01040) to add overcurrent protection (fuses) to
the affected motor control circuit.  Dominion completed the necessary modifications for
the affected motor control circuit by May 5, 2014.
 
14  The significance and enforcement aspect of this issue are discussed in Section 4OA7.2 of this inspection report.  LER 05000336/2014-002-00 (Unit 2) is closed.
.3 (Closed) Licensee Event Report (LER) 05000423/2014-002-00 (Unit 3):  DC Circuit Hot
Shorts  On March 12, 2014, during a review of industry operating experience, Dominion identified postulated fire induced circuit failures involving unfused DC motor control
circuits for Millstone Power Station Unit 3.  The postulated fire induced circuit failures could cause a secondary fire that could adversely affect fire safe shutdown equipment contrary to Unit 3 Renewed Facility Operating License Condition 2.H and the branch technical condition (BTP) 9.5-1 requirements.  The license
condition and the BTP requires in part, post-fire safe shutdown cables remain free
of the effects of fire-induced cable faults during postulated fires.  Specifically, the
licensee identified 125 V DC control circuits for non-safety related main turbine emergency lube oil and a main generator emergency seal oil pumps that were not provided with overcurrent protection.  Postulated fires in the turbine battery
switchgear area, the cable spreading room, the instrument rack room, and the
control room could cause failure of the unprotected 125 V DC control circuits,
which in turn could cause failure of control circuits for safe shutdown equipment.  Dominion determined the cause of the condition was a manufacturer's design error that involved the failure to include protective fuses in DC motor control
circuits during plant construction.
The licensee submitted LER 05000423/2014-002-00 (Unit 3) to report this event in accordance with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly degraded plant safety.  The licensee entered this issue into their corrective action
program as condition report number CR541983 and implemented compensatory measures in the affected fire areas pending final resolution of the issue.
The licensee completed an engineering evaluation (RAS000253) of the issue and developed design change modifications (MP3-14-01071 and MP3-14-01092) to add overcurrent protection (fuses) to the affected motor control circuits.  Dominion completed the necessary modifications for all affected motor control circuits by November 2, 2014.
  The significance and enforcement aspect of this issue are discussed in Section 4OA7.3 of this inspection report.  LER 05000289/2014-001-00 (Unit 3) is closed.
   
15  4OA6 Meetings, Including Exit
  Exit Meeting Summary
The team presented the inspection results to Mr. John Daugherty, Site Vice President, Millstone Power Station, and other members of the site staff at an exit meeting on August 11, 2016.  No proprietary information was included in this inspection report.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by the
 
licensee and are violations of NRC requirements.  These issues satisfy the criteria of the NRC Enforcement Policy of being dispositioned as Non-Cited Violations.
.1 LER 05000336/2013-003-00 (Unit 2) describes an unanalyzed condition in which Dominion identified their DC ammeter circuits were unfused.  Specifically, Dominion did not provide overcurrent protection for wiring associated with DC ammeter indication in
the control room to prevent wires from overheating due to fire induced faults and
excessive currents flowing through the cable.  With enough current flowing through the
cable, the potential existed that the overloaded ammeter wiring could damage system wiring or adjacent safety-related circuits in the cable raceways needed for post-fire safe shutdown.  This condition could result in a loss of the associated safe shutdown
components or a secondary fire in another fire area.  The failure to protect safe
shutdown cables from the effects of postulated fires was a performance deficiency.
This performance deficiency was a violation of Millstone Power Station, Unit 2, Renewed Facility Operating License Condition 2.C.(3), which requires in part, post-fire safe shutdown cables remain free of the effects of fire-induced cable faults during postulated
fires.  Contrary to the above, Dominion identified they failed to meet this requirement and
the condition existed since initial construction of Unit 2.  The issue was more than minor
because it was associated with the protection against external events (fire) attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating
events to prevent undesirable consequences.  The team determined that the finding was
of very low safety significance (Green), based IMC 0609, Appendix F, "Fire Protection
Significance Determination Process (SDP)," Phase 2 screening criteria.
The finding screened to Green based upon, task number 2.3.5, because the
affected cables were routed in alternate shutdown fire areas that are continually
manned or protected by detection and
automatic suppression systems.  Remaining fire areas are protected by detection systems, automatic suppression
systems or rely on manual fire-fighting activities.  Additionally, the cable construction is Institute of Electrical and Electronics Engineers (IEEE) 383 (thermoset) which decreases the likelihood of inter-cable and intra-cable
interactions.  Based on a team walkdown, the team determined that the ammeter
cable routing was not routed near a credible fire ignition source in the affected
fire areas.  Because this finding is of very low safety significance and had been entered into Dominion's corrective action program (CR530987), this violation is 
16  being treated as a Green, licensee-identified NCV consistent with the NRC's Enforcement Policy.
.2 LER 05000336/2014-002-00 (Unit 2) describes an unanalyzed condition in which Dominion identified DC motor control circuits were unfused.  Specifically, Dominion did not provide overcurrent protection for wiring associated with 125 V DC control circuits for a non-safety related main turbine emergency lube oil pump
to prevent wires from overheating due to fire induced faults and excessive
currents flowing through the cable.  With enough current flowing through the
cable, the potential existed that the overloaded motor control wiring could damage adjacent control circuit wiring for components which are needed to achieve and maintain post-fire safe shutdown for a fire in several fire areas (turbine battery
 
room, cable vault, plant equipment operator meeting area, control room).  This condition could result in a loss of the associated safe shutdown components or a
secondary fire in another fire area.  The failure to protect safe shutdown cables from the effect of postulated fires was a performance deficiency.
This performance deficiency was a violation of Millstone Power Station, Unit 2,
Renewed Facility Operating License Condition 2.C.(3), which requires, in part, post-fire safe shutdown cables remain free of the effects of fire induced cable faults during
postulated fires.  Contrary to the above, Dominion identified they failed to meet this
requirement and the condition existed since initial construction.  The issue was more than minor because it was associated with the protection against external events (fire) attribute of the mitigating systems cornerstone and it adversely affected the
cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  The team
determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, "Fire Protection Significance Determination Process," Phase 2
screening criteria.
The finding screened to Green based upon, task number 2.3.5, because the affected cables were routed in alternate shutdown fire areas that are continually manned or
protected by detection and automatic suppression systems.  Remaining fire areas are
protected by detection systems, automatic suppression systems or rely on manual fire-fighting activities.  Additionally, the cable construction is IEEE 383 (thermoset) which decreases the likelihood of inter-cable and intra-cable interactions.  Based on a team walkdown, the team determined that the main turbine emergency lube oil pump cable routing was not routed near a credible fire ignition source in the affected fire areas. 
Because this finding is of very low safety significance and had been entered into
Dominion's corrective action program (CR541980), this violation is being treated as a
Green, licensee-identified NCV consistent with the NRC's Enforcement Policy.
.3 LER 05000423/2014-002-00 (Unit 3) describes an unanalyzed condition in which Dominion identified DC motor control circuits were unfused.  Specifically, Dominion did
not provide overcurrent protection for wiring associated with 125 V DC control circuits for
non-safety related main turbine emergency lube oil and main generator emergency seal oil pumps to prevent wires from overheating due to fire induced faults and excessive currents flowing through the cable.  With enough current flowing through the cable, the 
17  potential existed that the overloaded motor control wiring could damage adjacent control circuit wiring for components which are needed to achieve and maintain post-fire safe
shutdown for a fire in several fire areas (turbine battery switchgear area, cable spreading room, instrument rack room, control room). This condition could result in a loss of the
associated safe shutdown components or a secondary fire in another fire area.  The failure to protect safe shutdown cables from the effect of postulated fires was a performance deficiency.
This performance deficiency was a violation of Millstone Power Station, Unit 3,
Renewed Facility Operating License Condition 2.H, which requires, in part, post-fire safe shutdown cables remain free of the effects of fire induced cable faults during postulated fires.  Contrary to the above, Dominion identified they failed to meet this requirement and the condition existed since initial construction.  The issue was more than minor because it was associated with the protection against external events (fire)
attribute of the mitigating systems cornerstone and it adversely affected the
cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  The team determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, "Fire Protection Significance Determination Process," Phase 2
screening criteria.
The finding screened to Green based upon, task number 2.3.5, because the affected cables were routed in alternate shutdown fire areas that are continually manned or
protected by detection and automatic suppression systems.  Remaining fire areas are
protected by detection systems, automatic suppression systems or rely on manual fire-fighting activities.  Additionally, the cable construction is IEEE 383 (thermoset) which
decreases the likelihood of inter-cable and intra-cable interactions.  Based on a team
walkdown, the team determined that the main turbine emergency lube oil and main generator emergency seal oil pump cable routing was not routed near a credible fire ignition source in the affected fire areas.  Because this finding is of very low safety significance and had been entered into Dominion's corrective action program
(CR541983), this violation is being treated as a Green, licensee-identified NCV
consistent with the NRC's Enforcement Policy.
 
ATTACHMENT:  SUPPLEMENTAL INFORMATION
 
A-1  Attachment SUPPLEMENTAL INFORMATION
  KEY POINTS OF CONTACT
Licensee Personnel J. Daugherty, Site Vice President D. Blakeney, Assistant Plant Manager P. Anastas, Safe Shutdown Engineer
J. Armstrong, Fire Protection Engineer
T. Bryant, Maintenance Supervisor
D. DelBiondo, Site Fire Marshal J. Farley, Electrical System Engineer
B. Ferguson, Unit 2 Senior Reactor Operator
R. Garver, Engineering Director
L. Kelly, Engineering Lead
 
W. McCollum, Unit 2 Supervisor
D. Mello, Senior Fire Instructor K. Perkins, Electrical Engineering Supervisor P. Russell, Unit 3 Senior Reactor Operator
A. Vargas-Mendez, Licensing Engineer
 
NRC Personnel C. Cahill, Acting Branch Chief, Engineering Brach 3, Division of Reactor Safety
C. Highley, Resident Inspector, Millstone Power Station
 
L. Mckown, Resident Inspector, Millstone Power Station 
 
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened None 
Opened and Closed 05000336/2016007-01 NCV Unapproved OMA in Lieu of Meeting III.G.2 Fire
Protection Requirements for Fire Area R-14, Lower 4kV Switchgear Room and Cable Vault 
Closed 05000336/2013-003-00 LER Postulated DC Ammeter Circuit Hot Shorts (Unit 2), (Section 4OA3.1)
05000336/2014-002-00 LER DC Circuit Hot Shorts (Unit 2), (Section 4OA3.2)
 
05000423/2014-002-00 LER DC Circuit Hot Shorts (Unit 3), (Section 4OA3.3)
 
Discussed
None 
A-2  LIST OF DOCUMENTS REVIEWED
Fire Protection Licensing Documents 25203-SP-M2-SU-1046, Unit 2 Appendix R Compliance Report, Revision 1
 
25212-BTP-9.5-1, Unit 3 Branch Technical Position 9.5-1 Compliance Report, Revision 4
25212-MP3-SFR, Millstone Power Station, Unit 3, Safety Function Requirement Manual, Revision 6 LBDCR 07-MP2-010, Millstone U2 Technical Requirements, dated 10/5/09
Letter from Dominion to NRC, Dominion Nuclear Connecticut, Inc. Millstone Power Station Unit 2 Response to Request for Additional Information Request for Exemption from 
10 CFR 50, Appendix R, Section III.G., Fire Protection of Safe Shutdown Capability, with Attachment, dated 2/29/12 Letter from Dominion to NRC, Dominion Nuclear Connecticut, Inc. Millstone Power Station Unit 2 Request for a Revision of an Exemption from 10 CFR 50, Appendix R, Section III.G.,
Fire Protection of Safe Shutdown Capability, with Attachment, dated 10/29/12 Letter from Dominion to NRC, Dominion Nuclear Connecticut. Inc. Millstone Power Station Unit 2 Request for Exemption from 10 CFR 50. Appendix R. Section III.G., Fire Protection of
Safe Shutdown Capability, with Attachments, dated 6/30/11 Letter from NRC to Dominion, Millstone Power Station, Unit 2 -Correction to Previously Issued Exemption from the Requirements of 10 CFR Part 50, Appendix R, Section III.G.2. 
(TAC No. ME6693) with Enclosure, dated 12/18/12 Millstone Unit 2 Technical Requirement Manual, Section 3/4.7.9, Fire Protection System, 2/2/10 Millstone Unit 3 Fire Protection Evaluation Report, Revision 17.4 MP-SPEC-ENG-BTP-9.5-1, Millstone Unit 3 Branch Technical Position (BTP) 9.5-1 Compliance Report, Revision 4 U2-24-FPP-FHA, Unit 2 Fire Hazards Analysis, Revision 12
Updated Final Safety Analysis Report, Section 9.5.1, Fire Protection System, Revision 28.2
Design Basis Documents Fire Code Compliance Review of Safety Related Areas - Fire Protection Systems -Fire Alarm/Detection Systems and the plants Fire Pumps, dated 9/86 TR-151, Fire and Hose Stream Test of #TCO-003 High Density Silicone Elastomer used in Elec.
Opening, Revision 0 TR-189, Fire and Hose Stream Test of 6", 8", and 10" thick specimens of TCO-050, Revision 1
Design Changes DCN DM3-00-1286-97, Revision to the BTP 9.5-1 Compliance Report to Include RHS MOVs, dated 2/5/98 DCR M2-97034, Thermo-Lag Modifications for MP2, Revision 0
M2-98095, TDAFWP Redundant Power Supply, Revision 0
MP2-14-01007, DC Ammeter Hot Short Modification, Revision 1
MP2-14-01040, Appendix R Hot Short Circuit Modification for Emergency Bearing Oil Pump
P63, Revision 1 MP3-13-01183, RHR Cross-Train Suction Motor-Operated Valve Breaker Normal Alignment Change, dated 10/29/13 MP3-14-01071, Appendix R Hot Short Circuit Modification for Emergency Bearing Oil Pump
3TML-P1, Revision 0
 
A-3  MP3-14-01092, Appendix R Hot Short Circuit Modification for Emergency Seal Oil Pump 3GMO-P2, Revision 0 MP3-14-01187, MP3 RPCCW Heat Exchanger 3CCP*E1B Replacement, dated 7/6/15
MPG-13-01131, MDM Flex Strategy Support Modification, dated 9/16/14


                                              13
Calculations/Engineering Evaluation Reports 25203-ER-98-0151, Fire Test Performed for Florida Power & Light Company for Electrical Raceways Protected with Thermo-Lag Fire Barrier Systems, Revision, 0 25203-ER-99-0092, Millstone Unit 2 Appendix R Cooldown Analysis Assumptions and Results, Revision 3 97-ENG-01912E2, 4.16kV Switchgear Relay Settings, Revision 0 98-ENG-02411-C2, MP2 Evaluation Flooding Outside Containment, Revision 1 98-ENG-02621-M2, Determination of the Instrument Air Requirement for Certain Safety Related Valves, Revision 3 99-026, Calculation Change Notice No. 1, Millstone Site Fire Loop Flow Model Bench Markings, Revision 1 99-026, Calculation Change Notice No. 3, Millstone Site Fire Loop Flow Model Bench Markings, Revision 1 99-026, Calculation Change Notice No. 4, Millstone Site Fire Loop Flow Model Bench Markings, Revision 1 99-026, Millstone Site Fire Loop Flow Model Bench Markings, Revision 1  
  capability. Dominion determined the cause of the condition was a latent design error
DNC 2512-ER-04-0030, Validation and Verification of EOP 3509.1 Using Simulator, Field and Table Top Validation, dated 5/28/04 EMP-186, Millstone Nuclear Power Plant U2 Combustible Loading Re-Analysis Calculation, Revision 2 ER-97-0295, Sound Powered Phone and Trunked Radio Systems - Cable Selection, Routing and Figures, dated 1/16/98 ER-97-0302, MP3 BTP 9.5-1 Compliance Report Section 6.2 Revision - Communication Systems, dated 2/10/98 M2-EV-98-0113, Technical Evaluation for 120Vac Vital Bus Appendix R Coordination Study, Revision 1 M3-EV-98-0011, Technical Evaluation for The Use of an 800 MHz Carrier Frequency Trunked Radio System at Millstone Unit 3 for General Purposes and Appendix R Requirements, Revision 1 MP-CALC-ENG-S-0426535, MP3 BTP 9.5-1 RELAP5 Fire Shutdown Analysis 3650 and 3725 MWt, Revision 2 P1164-MP2-COORD, Unit 2 Breaker/Fuse Coordination for the Appendix R Circuits, Revision 0
  that was made during plant construction involving the failure to include protective fuses
RAS000244, Postulated DC Ammeter Circuit Hot Shorts, Revision 0 RAS000252, DC Circuit Hot Shorts, Revision 0 RAS000253, DC Circuit Hot Shorts, Revision 0
  in DC ammeter circuits.
S-02824S2, Millstone Unit 2, R-2 Fire, Appendix R Analysis, Revision 2  
  The licensee submitted LER 05000336/2013-003-00 to report this event in accordance
SP-M3-EE-269, Unit 3 Electrical Design Criteria, Revision 3
  with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly degraded
  plant safety. The licensee entered this issue into their corrective action program as
  condition report number CR530987 and implemented compensatory measures in the
  affected fire areas pending final resolution of the issue.
  The licensee completed an engineering evaluation (RAS000244) of the issue and
  developed a design change (MP2-14-01007) to add fuses to the affected ammeter
  circuits. Dominion completed the necessary modifications for all affected ammeter
  circuits by May 7, 2014.
  The significance and enforcement aspect of this issue are discussed in Section 4OA7.1
  of this inspection report. LER 05000336/2013-003-00 is closed.
.2 (Closed) Licensee Event Report (LER) 05000336/2014-002-00 (Unit 2): DC Circuit Hot
  Shorts
  On March 12, 2014, during a review of industry operating experience, Dominion
  identified postulated fire induced circuit failures involving unfused DC motor control
  circuits for Millstone Power Station Unit 2. The postulated fire induced circuit failures
  could cause a secondary fire that could adversely affect fire safe shutdown equipment
  contrary to Unit 2 Renewed Facility Operating License Condition 2.C.(3) and Appendix
  R requirements. The license condition and regulation requires in part, post-fire safe
  shutdown cables remain free of the effects of fire induced cable faults during postulated
  fires. Specifically, the licensee identified 125 V DC control and indication circuits for a
  non-safety related main turbine emergency lube oil pump that was not provided with
  overcurrent protection. Postulated fires in the turbine battery room, the cable vault, the
  plant equipment operator meeting area and the control room could cause failure of the
  unprotected 125 V DC circuits, which in turn could cause failure of the control circuits for
  safe shutdown equipment. Dominion determined the cause of the condition was a
  manufacturers design error that involved the failure to include protective fuses in DC
  motor control circuits during plant construction.
  The licensee submitted LER 05000336/2014-002-00 (Unit 2) to report this event in
  accordance with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly
  degraded plant safety. The licensee entered this issue into their corrective action
  program as condition report number CR541980 and implemented compensatory
  measures in the affected fire areas pending final resolution of the issue.
  The licensee completed an engineering evaluation (RAS000252) of the issue and
  developed a design change (MP2-14-01040) to add overcurrent protection (fuses) to
  the affected motor control circuit. Dominion completed the necessary modifications for
  the affected motor control circuit by May 5, 2014.


W2-517-744-RE, MP2 Appendix R Cooldown, Revision 3  
                                              14
  The significance and enforcement aspect of this issue are discussed in Section 4OA7.2
  of this inspection report. LER 05000336/2014-002-00 (Unit 2) is closed.
.3 (Closed) Licensee Event Report (LER) 05000423/2014-002-00 (Unit 3): DC Circuit Hot
  Shorts
  On March 12, 2014, during a review of industry operating experience, Dominion
  identified postulated fire induced circuit failures involving unfused DC motor control
  circuits for Millstone Power Station Unit 3. The postulated fire induced circuit
  failures could cause a secondary fire that could adversely affect fire safe shutdown
  equipment contrary to Unit 3 Renewed Facility Operating License Condition 2.H
  and the branch technical condition (BTP) 9.5-1 requirements. The license
  condition and the BTP requires in part, post-fire safe shutdown cables remain free
  of the effects of fire-induced cable faults during postulated fires. Specifically, the
  licensee identified 125 V DC control circuits for non-safety related main turbine
  emergency lube oil and a main generator emergency seal oil pumps that were not
  provided with overcurrent protection. Postulated fires in the turbine battery
  switchgear area, the cable spreading room, the instrument rack room, and the
  control room could cause failure of the unprotected 125 V DC control circuits,
  which in turn could cause failure of control circuits for safe shutdown equipment.
  Dominion determined the cause of the condition was a manufacturers design
  error that involved the failure to include protective fuses in DC motor control
  circuits during plant construction.
  The licensee submitted LER 05000423/2014-002-00 (Unit 3) to report this event in
  accordance with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly
  degraded plant safety. The licensee entered this issue into their corrective action
  program as condition report number CR541983 and implemented compensatory
  measures in the affected fire areas pending final resolution of the issue.
  The licensee completed an engineering evaluation (RAS000253) of the issue and
  developed design change modifications (MP3-14-01071 and MP3-14-01092) to add
  overcurrent protection (fuses) to the affected motor control circuits. Dominion completed
  the necessary modifications for all affected motor control circuits by November 2, 2014.
  The significance and enforcement aspect of this issue are discussed in Section 4OA7.3
  of this inspection report. LER 05000289/2014-001-00 (Unit 3) is closed.


   
                                                  15
A-4  Procedures 3783EA, Component Cooling Pump Motor Replacement for Fire Protection, Revision 005-02 C MP 790, Emergency Light Inspection and Testing, Revision 004-02
4OA6 Meetings, Including Exit
C OP 200.18, Time Critical Action Validation and Verification, Revision 2
    Exit Meeting Summary
C OP 200.18, Time Critical Action Validation and Verification, Revision 3
    The team presented the inspection results to Mr. John Daugherty, Site Vice President,
C SP 600.24, Fire Brigade Equipment Inspection, Revision 000-04 C SP 600.28, Fire Brigade vehicle Equipment Inspection Data Sheet (R3), Revision 000-05 C SP600.24, Unit 2 Fire Brigade Equipment Inspection, Revision 001-00
    Millstone Power Station, and other members of the site staff at an exit meeting on
CM-AA-ETE-101, Engineering Technical Evaluation (ETE), Revision 6
    August 11, 2016. No proprietary information was included in this inspection report.
CM-AA-FPA-10, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 2
4OA7 Licensee-Identified Violations
CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 11 CM-AA-FPA-101, Control of Combustible and Flammable Materials, Revision 8 CM-AA-FPA-102, Fire Protection and Fire Safe Shutdown review and preparation Process and Preparation Process and Design Change Process, Revision 6 COM-04-C, Plant Communication Systems, Revision 0
    The following violations of very low safety significance (Green) were identified by the
ER-AA-102, Preventive Maintenance Program, Revision 9
    licensee and are violations of NRC requirements. These issues satisfy the criteria of the
ER-AA-MRL-100, Implementing Maintenance Rule, Revision 10 FB-00012, Self-Contained Breathing Apparatus SCOTT 4.5, Revision 7 MP 2720U1, Cold Shutdown Fire Damage Repair Procedure for Fire Area R-1 (Appendix R), Revision 004-02 SA-AA-115, Conduct of Fire Drills, Revision 2  
    NRC Enforcement Policy of being dispositioned as Non-Cited Violations.
SFP 10, Fire Protection Inspections, Revision 005-03 SFP 21, Appendix R Fire Cage Inventory, Revision 002-06 SP 2402CR, Steam Generator Pressure Rack Instrument Calibration, Revision 0
.1   LER 05000336/2013-003-00 (Unit 2) describes an unanalyzed condition in which
SP 2601P, CVCS Valve Operability Tests From C-10 and C-02, Revision 0
    Dominion identified their DC ammeter circuits were unfused. Specifically, Dominion did
SP 2610B, Turbine Driven Auxiliary Feed Pump O
    not provide overcurrent protection for wiring associated with DC ammeter indication in
perational Tests from C-10, Revision 1 SP 2610E, Atmospheric Dump Valve Testing from C-10, C-70A and C-70B, Revision 1 SP 2610M, Power Operated Relief Valve Hot Functional Test, Revision 0 SP 3442J01, RCS Wide Range Pressure Rack Calibration, Revision 7
    the control room to prevent wires from overheating due to fire induced faults and
SP 3444A02, Steam Generator Water Level Wide Range Calibration, Revision 7
    excessive currents flowing through the cable. With enough current flowing through the
SP 3641D.3, Fire Detection and Control System Operability Check, Revision 015
    cable, the potential existed that the overloaded ammeter wiring could damage system
SP 3641D.5, Fire Damper Operability Verification, Revision 012
    wiring or adjacent safety-related circuits in the cable raceways needed for post-fire safe
SP 3641F.1, Functional Check of the East and West Switchgear Breathing Air Systems, Revision 2 SP 3673.2, Fire Transfer Switch Panel Operational Testing, Revision 002-06
    shutdown. This condition could result in a loss of the associated safe shutdown
SP 3673.4, Auxiliary Shutdown Panel Operability Test, Revision 010
    components or a secondary fire in another fire area. The failure to protect safe
TR-MP-TPG-2300, Fire Protection Programs Training Program Guide (TPG), Revision 2
    shutdown cables from the effects of postulated fires was a performance deficiency.
WC5, Fuse Control, Revision 2
    This performance deficiency was a violation of Millstone Power Station, Unit 2, Renewed
Operations Procedures AOP 2559, Millstone Unit 2 Fire, Revision 10
    Facility Operating License Condition 2.C.(3), which requires in part, post-fire safe
AOP 2559, Procedure Basis Document, Fire, Revision 009-00
    shutdown cables remain free of the effects of fire-induced cable faults during postulated
AOP 2579A, Fire Procedure for Hot Standby Appendix R Fire Area R-1, Revision 011-00
    fires. Contrary to the above, Dominion identified they failed to meet this requirement and
AOP 2579A, Procedure Basis Document, Fire Procedure for Hot Standby Appendix R Fire Area
    the condition existed since initial construction of Unit 2. The issue was more than minor
R-1, Revision 011-00 AOP 2579A, Unit 2 Fire Procedure for Hot Standby Appendix R Fire Area R-1, Revision 11
    because it was associated with the protection against external events (fire) attribute of
AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-1, Revision 004-08 
    the mitigating systems cornerstone and it adversely affected the cornerstone objective of
A-5  AOP 2579EE, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-7, R-9, R-14, and R-17, Revision 005-09 AOP 2579G, Fire Procedure for Hot Standby Appendix R Fire Area R-7, Revision 006-10
    ensuring the availability, reliability, and capability of systems that respond to initiating
AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area R-14, Revision 006-06
    events to prevent undesirable consequences. The team determined that the finding was
AOP 3577, Loss of Normal and Offsite Power to a 4.16 kV Emergency Bus, Revision 003
    of very low safety significance (Green), based IMC 0609, Appendix F, Fire Protection
AOP 3577, Procedure Basis Document, Loss of Normal and Offsite Power to a 4.16 kV Emergency Bus, Revision 002-00 AOP 3581, Immediate Operator Actions, Revision 003
    Significance Determination Process (SDP), Phase 2 screening criteria.
COP 200.2AIR, "Airborne Threat," Revision 002-03
    The finding screened to Green based upon, task number 2.3.5, because the
EDMG 2.01, MP2 B.5.b Event Control Room Response, Revision 004
    affected cables were routed in alternate shutdown fire areas that are continually
EDMG 2.02, MP2 B.5.b Event TSC Response, Revision 010 EOP 2540, Functional Recovery, Revision 025-00 EOP 2540D, Functional Recovery of Heat Removal, Revision 022-00
    manned or protected by detection and automatic suppression systems.
EOP 2541, Appendix 36, ADV Local Operation, Revision 000-02
    Remaining fire areas are protected by detection systems, automatic suppression
EOP 2541, Appendix 7, TDAFW Pump Abnormal Startup, Revision 000-01
    systems or rely on manual fire-fighting activities. Additionally, the cable
EOP 2541, Standard Appendices, Revision 006
    construction is Institute of Electrical and Electronics Engineers (IEEE) 383
EOP 35 GA-31, Locally Restoring AFW Flow, Revision 004 EOP 3509, Fire Emergency, Revision 027-00 EOP 3509, Procedure Basis Document, Fire Emergency, Revision 026-00
    (thermoset) which decreases the likelihood of inter-cable and intra-cable
EOP 3509.1, Control Room, Cable Spreading Area or Instrument Rack Room Fire, 
    interactions. Based on a team walkdown, the team determined that the ammeter
Revision 019-00 EOP 3509.1, Procedure Basis Document, Control Room, Cable Spreading Area or Instrument Rack Room Fire, Revision 019-00 EOP 3509.15, North (A) EDG Enclosure or East (A) F.O. Vault Fire, Revision 001 
    cable routing was not routed near a credible fire ignition source in the affected
EOP 3509.15, Procedure Basis Document, North (A) EDG Enclosure or East (A) F.O. Vault
    fire areas. Because this finding is of very low safety significance and had been
Fire, Revision 001 EOP 3509.19, ESF Building North RHR Heat Exchanger Cubicle Fire, Revision 000-01 EOP 3509.19, Procedure Basis Document, ESF Building North RHR Heat Exchanger Cubicle
    entered into Dominions corrective action program (CR530987), this violation is
Fire, Revision 000-01 EOP 3509.6, Auxiliary Building West MCC/Rod Control/ACU Area Fire, Revision 002-01
EOP 3509.6, Procedure Basis Document, Auxiliary Building West MCC/Rod Control/ACU Area
Fire, Revision 002-01 MP-PROC-OPS-OP-2322, Auxiliary Feedwater System, Revision 029 OP 2343, 4160 Volt Electrical System, Revision 022 OP 3341B, Fire Protection Halon System, Revision 005-06
OP 3353.MB4A, Main Board 4A Annunciator Response, Revision 003
OP 3353.MB4B, Main Board 4B Annunciator Response, Revision 005
OP-3322, Auxiliary Feedwater System, Revision 025 SACRG-3, Severe Accident CR Guideline for MP3 B.5.b Initial Event Response, Revision 004 SAG-1, Injection into the Steam Generators, Revision 011
SAG-2, Depressurize the RCS, Revision 003
SAG-9, MP3 B.5.b Event TSC Response (EDMG), Revision 016


SP 2669A, Unit 2 Auxiliary Building Rounds, Revision 063
                                              16
  being treated as a Green, licensee-identified NCV consistent with the NRCs
  Enforcement Policy.
.2 LER 05000336/2014-002-00 (Unit 2) describes an unanalyzed condition in which
  Dominion identified DC motor control circuits were unfused. Specifically,
  Dominion did not provide overcurrent protection for wiring associated with 125 V
  DC control circuits for a non-safety related main turbine emergency lube oil pump
  to prevent wires from overheating due to fire induced faults and excessive
  currents flowing through the cable. With enough current flowing through the
  cable, the potential existed that the overloaded motor control wiring could damage
  adjacent control circuit wiring for components which are needed to achieve and
  maintain post-fire safe shutdown for a fire in several fire areas (turbine battery
  room, cable vault, plant equipment operator meeting area, control room). This
  condition could result in a loss of the associated safe shutdown components or a
  secondary fire in another fire area. The failure to protect safe shutdown cables
  from the effect of postulated fires was a performance deficiency.
  This performance deficiency was a violation of Millstone Power Station, Unit 2,
  Renewed Facility Operating License Condition 2.C.(3), which requires, in part, post-fire
  safe shutdown cables remain free of the effects of fire induced cable faults during
  postulated fires. Contrary to the above, Dominion identified they failed to meet this
  requirement and the condition existed since initial construction. The issue was more
  than minor because it was associated with the protection against external events (fire)
  attribute of the mitigating systems cornerstone and it adversely affected the
  cornerstone objective of ensuring the availability, reliability, and capability of systems
  that respond to initiating events to prevent undesirable consequences. The team
  determined that the finding was of very low safety significance (Green), based on IMC
  0609, Appendix F, Fire Protection Significance Determination Process, Phase 2
  screening criteria.
  The finding screened to Green based upon, task number 2.3.5, because the affected
  cables were routed in alternate shutdown fire areas that are continually manned or
  protected by detection and automatic suppression systems. Remaining fire areas are
  protected by detection systems, automatic suppression systems or rely on manual fire-
  fighting activities. Additionally, the cable construction is IEEE 383 (thermoset) which
  decreases the likelihood of inter-cable and intra-cable interactions. Based on a team
  walkdown, the team determined that the main turbine emergency lube oil pump cable
  routing was not routed near a credible fire ignition source in the affected fire areas.
  Because this finding is of very low safety significance and had been entered into
  Dominions corrective action program (CR541980), this violation is being treated as a
  Green, licensee-identified NCV consistent with the NRCs Enforcement Policy.
.3 LER 05000423/2014-002-00 (Unit 3) describes an unanalyzed condition in which
  Dominion identified DC motor control circuits were unfused. Specifically, Dominion did
  not provide overcurrent protection for wiring associated with 125 V DC control circuits for
  non-safety related main turbine emergency lube oil and main generator emergency seal
  oil pumps to prevent wires from overheating due to fire induced faults and excessive
  currents flowing through the cable. With enough current flowing through the cable, the


   
                                                17
A-6  Completed Tests/Surveillances 722481, B.5.b pump annual preventive maintenance, Completed 7/26/16 C OP 200.18, Time Critical Action Validation and Verification, Completed 8/4/16
    potential existed that the overloaded motor control wiring could damage adjacent control
C SP 600.13, P-82 Electric Fire Pump Annual Operability Demonstration, Completed 5/19/16 &
    circuit wiring for components which are needed to achieve and maintain post-fire safe
9/17/16 C SP 600.14, P-82 Electric Fire Pump Annual Operability Demonstration, Completed 12/4/14 &
    shutdown for a fire in several fire areas (turbine battery switchgear area, cable spreading
12/4/15 C SP 600.16 Fire Protection System Underground Main Flush & Flow Test, Completed 10/13/10
    room, instrument rack room, control room). This condition could result in a loss of the
& 10/9/13 C SP 600.18, Unit 2 Fire Hose Station Inspection, Completed 6/22/16
    associated safe shutdown components or a secondary fire in another fire area. The
C SP 600.22, Unit 2 Fire Hose Station Flow Test, Completed 2/13/15 C SP 600.24, Unit 2 Fire Brigade Equipment Inspection, Completed 4/24/16 C SP 600.24, Unit 2 Fire Brigade Equipment Inspection, Completed 5/25/16
    failure to protect safe shutdown cables from the effect of postulated fires was a
C SP 600.25, Unit 2 Fire Door Inspection, Completed 6/20/16
    performance deficiency.
C SP 600.25, Unit 3 Fire Door Inspection, Completed 9/3/15
    This performance deficiency was a violation of Millstone Power Station, Unit 3,
C SP 600.28, Fire Brigade Vehicle Equipment Inspection Data Sheet (R1), Completed 5/21/16
    Renewed Facility Operating License Condition 2.H, which requires, in part, post-fire
C SP 600.6, Electric Fire Pump M7-8 Monthly Operability Demonstration, Completed 5/10/16 &
    safe shutdown cables remain free of the effects of fire induced cable faults during
6/3/16 C SP 600.7, Electric Fire Pump M7-8 Annual Operability Demonstration, Completed 12/22/14 &
    postulated fires. Contrary to the above, Dominion identified they failed to meet this
12/19/15 C SP 600.8, Diesel Fire Pump M7-7 Monthly Operability Demonstration, Completed 5/13/16 &
    requirement and the condition existed since initial construction. The issue was more
6/8/16 C SP 600.9, Diesel Fire Pump M7-7 Annual Operability Demonstration, Completed 8/6/15 &
    than minor because it was associated with the protection against external events (fire)
6/8/16 C SP 788A, Fire Pump Diesel Engine Battery Quarterly Surveillance, Completed 6/16/16
    attribute of the mitigating systems cornerstone and it adversely affected the
C SP 788B, Fire Pump Diesel Engine Battery 18-Month Surveillance, Completed 6/10/16
    cornerstone objective of ensuring the availability, reliability, and capability of systems
C SP 788C, Fire Pump Diesel Engine Battery Weekly Surveillance, Completed 6/16/16 CSP 600.24, Fire Brigade Equipment Inspection, Completed 6/3/16 SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 1, Completed 2/10/06
    that respond to initiating events to prevent undesirable consequences. The team
SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 4, Completed 2/9/11
    determined that the finding was of very low safety significance (Green), based on IMC
SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 4, Completed 10/9/14
    0609, Appendix F, Fire Protection Significance Determination Process, Phase 2
SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 9, Completed 12/27/13
    screening criteria.
SFP 21, Unit 2 Appendix R Fire Cage Inventory, Completed 11/25/15 SFP 9, Unit 3 - Fire Extinguisher Inspection Data Sheet - Train B, Completed 6/29/16 SFP 9, Unit 3 - Fire Extinguisher Inspection Data Sheet - Train A, Completed 7/11/16
    The finding screened to Green based upon, task number 2.3.5, because the affected
SFP Procedure 21, Unit 3 Safe Shutdown Fire Cage Inventory, Completed on 11/26/2015
    cables were routed in alternate shutdown fire areas that are continually manned or
SP 2402CR, Steam Generator Pressure Rack Instrument Calibration, Revision 0, Completed 8/12/14 and 3/16/16 SP 2601P, Unit 2 CVCS Valve Operability Tests from C-10 and C-02, Revision 0, Completed
    protected by detection and automatic suppression systems. Remaining fire areas are
10/30/15 SP 2610B, Turbine Driven Auxiliary Feed Pump Operational Tests from C-10, Completed 3/2/16
    protected by detection systems, automatic suppression systems or rely on manual fire-
SP 2610E, Atmospheric Dump Valve Testing From C-10, C-70A and C-70B, Completed
    fighting activities. Additionally, the cable construction is IEEE 383 (thermoset) which
10/21/15 SP 2610M, Power Operated Relief Valve Hot Functional Test, Completed 11/1/15 SP 2657, EOP Equipment Inventory, Completed 9/7/15 SP 3442J01, RCS Wide Range Pressure Rack Calibration, Completed 9/16/14 and 2/11/16
    decreases the likelihood of inter-cable and intra-cable interactions. Based on a team
SP 3444A02, Steam Generator Water Level Wide Range Calibration, Completed 7/10/13 and
    walkdown, the team determined that the main turbine emergency lube oil and main
3/11/15 
    generator emergency seal oil pump cable routing was not routed near a credible fire
A-7  SP 3451Q01, Unit 3 Instrument Rack Room and Fire Pump House - Halon Fire System Test, Completed 2/26/16 SP 3641B.2, IRR Halon System Flow Test, Completed 5/17/15
    ignition source in the affected fire areas. Because this finding is of very low safety
SP 3641B.2, IRR Halon System Flow Test, Completed 5/8/14
    significance and had been entered into Dominions corrective action program
SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 1/8/15
    (CR541983), this violation is being treated as a Green, licensee-identified NCV
SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 1/19/13 SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 12/21/14
    consistent with the NRCs Enforcement Policy.
SP 3641D.3, Fire Protection Zone Panel 5C EDG A Area Detector Operability Checks, Completed 2/25/16 SP 3641D.5, Fire Damper Operability Verification, Completed 1/25/06
ATTACHMENT: SUPPLEMENTAL INFORMATION
SP 3641D.5, Fire Damper Operability Verification, Completed 5/8/11 SP 3641D.5, Fire Damper Operability Verification, Completed 9/5/99 SP 3641D.6, Fire Rated Assemblies Inspection, Completed 8/2/15
SP 3641F.1, Functional Check of the East and West Switchgear Breathing Air System, Completed 6/21/15 SP 3672.2-10, Fire Transfer Switch Panel Operational Testing-3RCS*PCV455A, Completed
11/9/14 SP 3672.2-2, Fire Transfer Switch Panel Operational Testing-3HVP*FN1A and FN1C, Completed 3/20/12 SP 3672.2-7, Fire Transfer Switch Panel Operational Testing-3SWP*MOV54A and MOV54C, Completed 8/1/13 SP 3672.2-8, Fire Transfer Switch Panel Operational Testing-3SWP*MOV71A Completed
11/23/15 SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVP*FN1A and 3HVP*FN1C, Completed 3/20/12 SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*FN14A, Completed
10/25/14 SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*MOD50A, Completed 12/20/12 SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*ACU1A, Completed
12/22/15 SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVY*FN2A, Completed
12/18/12 SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3SWP*MOV71A, Completed 11/23/15 SP 3673.4, Auxiliary Shutdown Panel Operability Test for Charging Injection Path, Completed
5/1/16 SP 3673.4, Auxiliary Shutdown Panel Operability Test for Charging Isolation Path, Completed
5/1/16 SP 3673.4, Auxiliary Shutdown Panel Operability Test for Train A CVCS Components, Completed 1/14/15 SP 3673.4-001, Auxiliary Shutdown Panel Operability Test, Completed 5/8/16
SP 3673.4-004, Auxiliary Shutdown Panel Operability Test Train A Auxiliary Feedwater Components, Completed 2/8/15 SP 3673.4-007, Auxiliary Shutdown Panel Operability Test Train B Auxiliary Feedwater Components, Completed 2/1/15 SP 3673.4-009, Auxiliary Shutdown Panel Operability Test Train B CVCS Components, Completed 5/22/16 
A-8  SP 3673.4-011, Auxiliary Shutdown Panel Operability Test Train A PORV and Block Valves, Completed 1/9/14 SP 3673.4-014, Auxiliary Shutdown Panel Operability Test Non-Train Related Components, Completed 5/1/16 SP2618C, Smoke and Heat Detector Testing, Auxiliary Building, Completed 3/24/16
SP2618C, Smoke Detector Testing, Switchgear Detector Testing, Facility 1, Completed 5/30/16 SP2618C, Smoke Detector Testing, Turbine Building, Completed 1/19/16  SP2618C, Turbine Bldg. 25'6'' Cable Vault and Vertical Shaft Smoke Detector Test, Completed
3/4/16 SP2618D, "A" DG Deluge Systems Design Function Test, Completed 1/12/16 
SP2618D, Fire Protection System sprinkler and Deluge Design Function test, Completed
5/20/15 SP2618H, Fire Protection System Deluge Nozzle Flow Test, Completed 7/16/14
SP2618L, Fire Protection Coating Inspection, Completed 8/4/15 
SP2618L, TSI Fire Wrap Inspection, Completed 8/7/15
SP2657, Inventory Remote Shutdown Station Storage, Completed 5/13/16


Operating Experience Evaluations Information Notice 2014-10, Potential Circuit Failure-Induced Secondary Fires or Equipment Damage, dated 9/16/14
                                              A-1
                                SUPPLEMENTAL INFORMATION
Quality Assurance Audits and Self Assessments Audit 15-04, Fire Protection Program, dated 7/15/15
                                  KEY POINTS OF CONTACT
Licensee Personnel
J. Daugherty, Site Vice President
D. Blakeney, Assistant Plant Manager
P. Anastas, Safe Shutdown Engineer
J. Armstrong, Fire Protection Engineer
T. Bryant, Maintenance Supervisor
D. DelBiondo, Site Fire Marshal
J. Farley, Electrical System Engineer
B. Ferguson, Unit 2 Senior Reactor Operator
R. Garver, Engineering Director
L. Kelly, Engineering Lead
W. McCollum, Unit 2 Supervisor
D. Mello, Senior Fire Instructor
K. Perkins, Electrical Engineering Supervisor
P. Russell, Unit 3 Senior Reactor Operator
A. Vargas-Mendez, Licensing Engineer
NRC Personnel
C. Cahill, Acting Branch Chief, Engineering Brach 3, Division of Reactor Safety
C. Highley, Resident Inspector, Millstone Power Station
L. Mckown, Resident Inspector, Millstone Power Station
                      LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Opened and Closed
05000336/2016007-01            NCV          Unapproved OMA in Lieu of Meeting III.G.2 Fire
                                            Protection Requirements for Fire Area R-14, Lower
                                            4kV Switchgear Room and Cable Vault
Closed
05000336/2013-003-00          LER          Postulated DC Ammeter Circuit Hot Shorts (Unit 2),
                                            (Section 4OA3.1)
05000336/2014-002-00          LER          DC Circuit Hot Shorts (Unit 2), (Section 4OA3.2)
05000423/2014-002-00          LER          DC Circuit Hot Shorts (Unit 3), (Section 4OA3.3)
Discussed
None
                                                                                      Attachment


                                              A-2
System Health Reports 3341 A, B, C, F - Fire Protections Water, Halon, CO2, Emerg. Breathing Air, dated 10/1/14- 12/31/14 3341 A, B, C, F - Fire Protections Water, Halon, CO2, Emerg. Breathing Air, dated 10/1/15- 12/31/15 3341D - Fire Detection, dated 10/1/14- 12/31/14
                              LIST OF DOCUMENTS REVIEWED
3341D - Fire Detection, dated 10/1/15- 12/31/15 
Fire Protection Licensing Documents
25203-SP-M2-SU-1046, Unit 2 Appendix R Compliance Report, Revision 1
25212-BTP-9.5-1, Unit 3 Branch Technical Position 9.5-1 Compliance Report, Revision 4
25212-MP3-SFR, Millstone Power Station, Unit 3, Safety Function Requirement Manual,
        Revision 6
LBDCR 07-MP2-010, Millstone U2 Technical Requirements, dated 10/5/09
Letter from Dominion to NRC, Dominion Nuclear Connecticut, Inc. Millstone Power Station Unit
        2 Response to Request for Additional Information Request for Exemption from
        10 CFR 50, Appendix R, Section III.G., Fire Protection of Safe Shutdown Capability, with
        Attachment, dated 2/29/12
Letter from Dominion to NRC, Dominion Nuclear Connecticut, Inc. Millstone Power Station Unit
        2 Request for a Revision of an Exemption from 10 CFR 50, Appendix R, Section III.G.,
        Fire Protection of Safe Shutdown Capability, with Attachment, dated 10/29/12
Letter from Dominion to NRC, Dominion Nuclear Connecticut. Inc. Millstone Power Station Unit
        2 Request for Exemption from 10 CFR 50. Appendix R. Section III.G., Fire Protection of
        Safe Shutdown Capability, with Attachments, dated 6/30/11
Letter from NRC to Dominion, Millstone Power Station, Unit 2 -Correction to Previously Issued
        Exemption from the Requirements of 10 CFR Part 50, Appendix R, Section III.G.2.
        (TAC No. ME6693) with Enclosure, dated 12/18/12
Millstone Unit 2 Technical Requirement Manual, Section 3/4.7.9, Fire Protection System, 2/2/10
Millstone Unit 3 Fire Protection Evaluation Report, Revision 17.4
MP-SPEC-ENG-BTP-9.5-1, Millstone Unit 3 Branch Technical Position (BTP) 9.5-1 Compliance
        Report, Revision 4
U2-24-FPP-FHA, Unit 2 Fire Hazards Analysis, Revision 12
Updated Final Safety Analysis Report, Section 9.5.1, Fire Protection System, Revision 28.2
Design Basis Documents
Fire Code Compliance Review of Safety Related Areas - Fire Protection Systems -Fire
        Alarm/Detection Systems and the plants Fire Pumps, dated 9/86
TR-151, Fire and Hose Stream Test of #TCO-003 High Density Silicone Elastomer used in Elec.
        Opening, Revision 0
TR-189, Fire and Hose Stream Test of 6, 8, and 10 thick specimens of TCO-050, Revision 1
Design Changes
DCN DM3-00-1286-97, Revision to the BTP 9.5-1 Compliance Report to Include RHS MOVs,
        dated 2/5/98
DCR M2-97034, Thermo-Lag Modifications for MP2, Revision 0
M2-98095, TDAFWP Redundant Power Supply, Revision 0
MP2-14-01007, DC Ammeter Hot Short Modification, Revision 1
MP2-14-01040, Appendix R Hot Short Circuit Modification for Emergency Bearing Oil Pump
        P63, Revision 1
MP3-13-01183, RHR Cross-Train Suction Motor-Operated Valve Breaker Normal Alignment
        Change, dated 10/29/13
MP3-14-01071, Appendix R Hot Short Circuit Modification for Emergency Bearing Oil Pump
        3TML-P1, Revision 0


ELU System Health Report, 1
                                              A-3
St Quarter 2016
MP3-14-01092, Appendix R Hot Short Circuit Modification for Emergency Seal Oil Pump
ELU System Health Report, 4
      3GMO-P2, Revision 0
th Quarter 2015 Program/Comp Health Report FP- Fire Protection - Including Appendix R, 4
MP3-14-01187, MP3 RPCCW Heat Exchanger 3CCP*E1B Replacement, dated 7/6/15
th Quarter 2015 Program/Comp Health Report FP- Fire Protection - Including Appendix R, 1
MPG-13-01131, MDM Flex Strategy Support Modification, dated 9/16/14
st Quarter 2016 System Health Report 2352, 3720B - Safe Shutdown Lighting, 1
Calculations/Engineering Evaluation Reports
st Quarter 2016 System Health Report 2352, 3720B - Safe Shutdown Lighting, 4
25203-ER-98-0151, Fire Test Performed for Florida Power & Light Company for Electrical
th Quarter 2015 U 2 Fire Protection & Deluge, CO2 Alterex, Halon Supression, 4
      Raceways Protected with Thermo-Lag Fire Barrier Systems, Revision, 0
th Quarter 2014 U 2 Fire Protection & Deluge, CO2 Alterex, Halon Supression, 4
25203-ER-99-0092, Millstone Unit 2 Appendix R Cooldown Analysis Assumptions and Results,
th Quarter 2015
      Revision 3
Unit 2 AC and DC Systems, 4
97-ENG-01912E2, 4.16kV Switchgear Relay Settings, Revision 0
th qtr. 2015 and 1
98-ENG-02411-C2, MP2 Evaluation Flooding Outside Containment, Revision 1
st Quarter 2016
98-ENG-02621-M2, Determination of the Instrument Air Requirement for Certain Safety Related
Unit 3 AC and DC Systems, 4
      Valves, Revision 3
th qtr. 2015 and 1
99-026, Calculation Change Notice No. 1, Millstone Site Fire Loop Flow Model Bench Markings,
st Quarter 2016
      Revision 1
99-026, Calculation Change Notice No. 3, Millstone Site Fire Loop Flow Model Bench Markings,
 
      Revision 1
A-9  Drawings and Wiring Diagrams
99-026, Calculation Change Notice No. 4, Millstone Site Fire Loop Flow Model Bench Markings,
12179-30276, U3 Generator Seal Oil System Em
      Revision 1
ergency Seal Oil pump 3GMO-P2 Control, Revision 5 12179-FIG-77B, Fire Hazard Analysis Plan Elevation 24 Feet 6 inch, Revision 6  
99-026, Millstone Site Fire Loop Flow Model Bench Markings, Revision 1
12179-FIG-77C, Fire Hazard Analysis Plant Elevation 38 Feet 6 inch, Revision 11
DNC 2512-ER-04-0030, Validation and Verification of EOP 3509.1 Using Simulator, Field and
25203-24070, Sheet 10, RCP Oil Collection System Details for RCP Motor in Cubicle "A", Revision 2 25203-24070, Sheet 11, RCP Oil Collection System Details for RCP Motor in Cubicle "A",  dated 5/16/95 25203-24070, Sheet 12, RCP Oil Collection System Details for RCP Motor in Cubicle "A",  dated 4/19/95 25203-24070, Sheet 13, RCP Oil Collection System Details for RCP Motor in Cubicle "A",  dated 4/20/95 25203-28500, Sht.356, Unit 2 PT-1023B Steam Generator Pressure Loop Diagram, Revision 10
      Table Top Validation, dated 5/28/04
25203-30001, Unit 2 Main Single Line Diagram, Revision 40
EMP-186, Millstone Nuclear Power Plant U2 Combustible Loading Re-Analysis Calculation,
25203-30005, Unit 2 Single Line Meter and Relay Diagram 4.16kV Emergency Buses 24C and  
      Revision 2
24D, Revision 21 25203-30009, Unit 2 Single Line Meter and Relay Diagram 4.16kV Emergency Buses 25E and 24G, Revision 13 25203-30022, Sht. 3, Unit 2 DV20 125Vdc and 120Vac Distribution Panel Schedule, Revision  
ER-97-0295, Sound Powered Phone and Trunked Radio Systems - Cable Selection, Routing
21 25203-30023, U2 Single Line Diagram 125VDC System-Turbine Battery, Revision 9 25203-30024, U2 Single Line Diagram 125VDC Emergency & 120VAC Vital Systems, Revision  
      and Figures, dated 1/16/98
39 25203-30053, Sheet 1, U2 Schematic Diagram 125VDC Switchgear Bus D01, Revision 7
ER-97-0302, MP3 BTP 9.5-1 Compliance Report Section 6.2 Revision - Communication
25203-30053, Sheet 3, U2 Schematic Diagram 125VDC Switchgear Bus D02, Revision 9
      Systems, dated 2/10/98
25203-30053, Sheet 5, U2 Switchgear Diagram 125VDC Switchgear Bus D03, Revision 10
M2-EV-98-0113, Technical Evaluation for 120Vac Vital Bus Appendix R Coordination Study,
25203-30102, Unit 2 Instrument Rack Loading Diagram Fire Shutdown Panel C09, Revision 3 25203-32002, Sh. 16, 4.16kV Switchgear Kirk Key Interlocks, Revision 5  
      Revision 1
25203-32006, Sheet 13, U2 Magnetic Starter Elementary Diagram, Revision 8
M3-EV-98-0011, Technical Evaluation for The Use of an 800 MHz Carrier Frequency Trunked
25203-32009, Sht. 37, Unit 2 Charging Line Distribution Solenoid Valve CH519, Revision 9
      Radio System at Millstone Unit 3 for General Purposes and Appendix R Requirements,
25203-32009, Sht. 41, Unit 2 Charging Pump Control MP18B, Revision 23
      Revision 1
25203-32009, Sht. 42A, Unit 2 Charging Pump Control MP18B, Revision 3 25203-32009, Sht. 6, Unit 2 Volume Control Tank Discharge MOV CH501, Revision 13 25203-34051, Unit 2 Auxiliary Building Miscellaneous Plan Section and Details, Revision 40
MP-CALC-ENG-S-0426535, MP3 BTP 9.5-1 RELAP5 Fire Shutdown Analysis 3650 and 3725
25203-39076, Sheet 9A, U2 Magnetic Starter Elementary Diagram, Revision 1  
      MWt, Revision 2
25203-39076, Sheet 9B, U2 Magnetic Starter Elementary Diagram, Revision 1  
P1164-MP2-COORD, Unit 2 Breaker/Fuse Coordination for the Appendix R Circuits, Revision 0
25203-39220, Sht. 1B, Unit 2 Instrument Rack Loading Diagram Spec 200 Cabinet RC30B, Revision 19 25203-39352, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP1 & Static Sw. VS1, 
RAS000244, Postulated DC Ammeter Circuit Hot Shorts, Revision 0
Revision 5 25203-39353, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP2 & Static Sw. VS2, 
RAS000252, DC Circuit Hot Shorts, Revision 0
Revision 5 25203-39354, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP3 & Static Sw. VS3, 
RAS000253, DC Circuit Hot Shorts, Revision 0
Revision 5 25203-39355, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP4 & Static Sw. VS4, Revision 3 25203-39356, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP5, Revision 5 
S-02824S2, Millstone Unit 2, R-2 Fire, Appendix R Analysis, Revision 2
A-10  25203-39357, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP6, Revision 6 25203-39367, Sheet 6, U2 Schematic Totalizing Box Turbine Battery Charger 201D/DC4, Revision 2 25205-25003, Station Fire Loop Operating & Hydraulic Analysis Schematic, Revision 14
SP-M3-EE-269, Unit 3 Electrical Design Criteria, Revision 3
25212-24036, Fire Stop & Seals Map Locations, Revision 0  
W2-517-744-RE, MP2 Appendix R Cooldown, Revision 3
25212-24037, Fire Stop & Seals Map Locations, Revision 0 25212-24273, Wall Pene. Map Aux. BLDG. EL. 45'-6", Revision 2 25212-29367 SH 20, Fire Protection & Detection Systems, dated 6/2/75
25212-29680 SH.0010, TCO-003 High Density Silicone Elastomer Fire, Air, and/or Radiation Seal for Electrical Blockout Openings, dated 8/20/84 25212-29680 SH.0023, TCO-050 Silicone Foam Fire or Air Seals for Sleeve, Conduit, Cast or Core Bored Openings up to 5" Dial, dated 1/26/85
25212-30001, Unit 3 Main One Line Diagram, Revision 26
25212-30004, Unit 3 Main One Line Diagram 4160V Normal and Emergency Buses, Revision  
20 25212-30010, Unit 3 6900V One Line Diagram Bus 35A and 35B, Revision 20


25212-30011, Unit 3 6900V One Line Diagram Bus 35C and 35D, Revision 21 25212-30027, Sht. 3, Unit 3 480V Motor Control Center One Line Diagram Auxiliary Building, Revision 44 25212-30272, Sht. 29A, Unit 3 Feedwater System Steam Generator 3RCS*SG1A Wide Range Level Indication, Revision 8 25212-30272, Sht. 30, Feedwater System Steam Generator 3RCS*SG1A, Revision 5 25212-30343, Sht. 10A, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop
                                              A-4
Diagram, Revision 6 25212-30343, Sht. 10B, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop
Procedures
Diagram, Revision 5 25212-30343, Sht. 10C, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop
3783EA, Component Cooling Pump Motor Replacement for Fire Protection, Revision 005-02
Diagram, Revision 5 25212-30343, Sht. 11, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop
C MP 790, Emergency Light Inspection and Testing, Revision 004-02
Diagram, Revision 5
C OP 200.18, Time Critical Action Validation and Verification, Revision 2
25212-30379, Sheet 8, U3 Turbine Generator Lube Oil System Emergency Bearing Oil Pump Control, Revision 3 25212-3200, Sht. 7, Elementary Diagram Reactor Head Vent Isolation Valves 3RCS*SV8095A(B), Revision 6 25212-32001, Elementary Diagram 480V MCC Charging Header Isolation Valve 2CHS*MV8438A, Revision 15 25212-32001, Sheet 6CI, U3 Elementary Diagram 125VDC Emergency Bearing Oil Pump [3TML-P1], Revision 10 25212-32001, Sheet 6CS, U3 Elementary Diagram 125VDC Generator Emergency Seal Oil Pump [3GMO-P2], Revision 14 25212-32001, Sht. 7DX, Elementary Diagram Letdown Line Isolation Valves 3RCS*LCV459 and 3RCS*LCV460, Revision 9 25212-32068, U3 Elementary Diagram Diesel Driven Fire Pump M7-7 Control Circuit, Revision  
C OP 200.18, Time Critical Action Validation and Verification, Revision 3
2 25212-39002, Sheet 1020, U3 DC Starter Emergency Seal Oil Elementary, Revision D 25212-39002, Sheet 1021, U3 DC Starter Emergency Seal Oil Schematic, Revision C
C SP 600.24, Fire Brigade Equipment Inspection, Revision 000-04
25212-39002, Sheet 1062, U3 Emergency Bearing Oil Pump Starter-Outline Schematic & Conn.
C SP 600.28, Fire Brigade vehicle Equipment Inspection Data Sheet (R3), Revision 000-05
Diagram, Revision E 
C SP600.24, Unit 2 Fire Brigade Equipment Inspection, Revision 001-00
A-11  SKE-3.1-ELEC DIST, Emergency System One Line Diagram for Appendix R, Revision 2
CM-AA-ETE-101, Engineering Technical Evaluation (ETE), Revision 6
CM-AA-FPA-10, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 2
Piping and Instrumentation Diagrams 25203-26005, Sht. 2, Unit 2 P&ID Feed System, Revision 73
CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 11
25203-26008, Sh. 2, Piping and Instrumentation Diagram Service Water, Revision 114
CM-AA-FPA-101, Control of Combustible and Flammable Materials, Revision 8
CM-AA-FPA-102, Fire Protection and Fire Safe Shutdown review and preparation Process and
      Preparation Process and Design Change Process, Revision 6
COM-04-C, Plant Communication Systems, Revision 0
ER-AA-102, Preventive Maintenance Program, Revision 9
ER-AA-MRL-100, Implementing Maintenance Rule, Revision 10
FB-00012, Self-Contained Breathing Apparatus SCOTT 4.5, Revision 7
MP 2720U1, Cold Shutdown Fire Damage Repair Procedure for Fire Area R-1 (Appendix R),
      Revision 004-02
SA-AA-115, Conduct of Fire Drills, Revision 2
SFP 10, Fire Protection Inspections, Revision 005-03
SFP 21, Appendix R Fire Cage Inventory, Revision 002-06
SP 2402CR, Steam Generator Pressure Rack Instrument Calibration, Revision 0
SP 2601P, CVCS Valve Operability Tests From C-10 and C-02, Revision 0
SP 2610B, Turbine Driven Auxiliary Feed Pump Operational Tests from C-10, Revision 1
SP 2610E, Atmospheric Dump Valve Testing from C-10, C-70A and C-70B, Revision 1
SP 2610M, Power Operated Relief Valve Hot Functional Test, Revision 0
SP 3442J01, RCS Wide Range Pressure Rack Calibration, Revision 7
SP 3444A02, Steam Generator Water Level Wide Range Calibration, Revision 7
SP 3641D.3, Fire Detection and Control System Operability Check, Revision 015
SP 3641D.5, Fire Damper Operability Verification, Revision 012
SP 3641F.1, Functional Check of the East and West Switchgear Breathing Air Systems,
      Revision 2
SP 3673.2, Fire Transfer Switch Panel Operational Testing, Revision 002-06
SP 3673.4, Auxiliary Shutdown Panel Operability Test, Revision 010
TR-MP-TPG-2300, Fire Protection Programs Training Program Guide (TPG), Revision 2
WC5, Fuse Control, Revision 2
Operations Procedures
AOP 2559, Millstone Unit 2 Fire, Revision 10
AOP 2559, Procedure Basis Document, Fire, Revision 009-00
AOP 2579A, Fire Procedure for Hot Standby Appendix R Fire Area R-1, Revision 011-00
AOP 2579A, Procedure Basis Document, Fire Procedure for Hot Standby Appendix R Fire Area
      R-1, Revision 011-00
AOP 2579A, Unit 2 Fire Procedure for Hot Standby Appendix R Fire Area R-1, Revision 11
AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-1,
      Revision 004-08


25203-26011, Fire Protection, Revision 57 25203-26014, Sht. 1, Unit 2 P&ID Reactor Coolant System, Revision 41 25203-26014, Sht. 2, Unit 2 P&ID Reactor Coolant System, Revision 46
                                            A-5
25203-26017, Sht. 1, Unit 2 P&ID Charging System, Revision 63
AOP 2579EE, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-7, R-
      9, R-14, and R-17, Revision 005-09
AOP 2579G, Fire Procedure for Hot Standby Appendix R Fire Area R-7, Revision 006-10
AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area R-14, Revision 006-06
AOP 3577, Loss of Normal and Offsite Power to a 4.16 kV Emergency Bus, Revision 003
AOP 3577, Procedure Basis Document, Loss of Normal and Offsite Power to a 4.16 kV
      Emergency Bus, Revision 002-00
AOP 3581, Immediate Operator Actions, Revision 003
COP 200.2AIR, Airborne Threat, Revision 002-03
EDMG 2.01, MP2 B.5.b Event Control Room Response, Revision 004
EDMG 2.02, MP2 B.5.b Event TSC Response, Revision 010
EOP 2540, Functional Recovery, Revision 025-00
EOP 2540D, Functional Recovery of Heat Removal, Revision 022-00
EOP 2541, Appendix 36, ADV Local Operation, Revision 000-02
EOP 2541, Appendix 7, TDAFW Pump Abnormal Startup, Revision 000-01
EOP 2541, Standard Appendices, Revision 006
EOP 35 GA-31, Locally Restoring AFW Flow, Revision 004
EOP 3509, Fire Emergency, Revision 027-00
EOP 3509, Procedure Basis Document, Fire Emergency, Revision 026-00
EOP 3509.1, Control Room, Cable Spreading Area or Instrument Rack Room Fire,
      Revision 019-00
EOP 3509.1, Procedure Basis Document, Control Room, Cable Spreading Area or Instrument
      Rack Room Fire, Revision 019-00
EOP 3509.15, North (A) EDG Enclosure or East (A) F.O. Vault Fire, Revision 001
EOP 3509.15, Procedure Basis Document, North (A) EDG Enclosure or East (A) F.O. Vault
      Fire, Revision 001
EOP 3509.19, ESF Building North RHR Heat Exchanger Cubicle Fire, Revision 000-01
EOP 3509.19, Procedure Basis Document, ESF Building North RHR Heat Exchanger Cubicle
      Fire, Revision 000-01
EOP 3509.6, Auxiliary Building West MCC/Rod Control/ACU Area Fire, Revision 002-01
EOP 3509.6, Procedure Basis Document, Auxiliary Building West MCC/Rod Control/ACU Area
      Fire, Revision 002-01
MP-PROC-OPS-OP-2322, Auxiliary Feedwater System, Revision 029
OP 2343, 4160 Volt Electrical System, Revision 022
OP 3341B, Fire Protection Halon System, Revision 005-06
OP 3353.MB4A, Main Board 4A Annunciator Response, Revision 003
OP 3353.MB4B, Main Board 4B Annunciator Response, Revision 005
OP-3322, Auxiliary Feedwater System, Revision 025
SACRG-3, Severe Accident CR Guideline for MP3 B.5.b Initial Event Response, Revision 004
SAG-1, Injection into the Steam Generators, Revision 011
SAG-2, Depressurize the RCS, Revision 003
SAG-9, MP3 B.5.b Event TSC Response (EDMG), Revision 016
SP 2669A, Unit 2 Auxiliary Building Rounds, Revision 063


25212-25008, Yard Water & Fire Protection Piping, Revision 29
                                              A-6
Completed Tests/Surveillances
722481, B.5.b pump annual preventive maintenance, Completed 7/26/16
C OP 200.18, Time Critical Action Validation and Verification, Completed 8/4/16
C SP 600.13, P-82 Electric Fire Pump Annual Operability Demonstration, Completed 5/19/16 &
      9/17/16
C SP 600.14, P-82 Electric Fire Pump Annual Operability Demonstration, Completed 12/4/14 &
      12/4/15
C SP 600.16 Fire Protection System Underground Main Flush & Flow Test, Completed 10/13/10
      & 10/9/13
C SP 600.18, Unit 2 Fire Hose Station Inspection, Completed 6/22/16
C SP 600.22, Unit 2 Fire Hose Station Flow Test, Completed 2/13/15
C SP 600.24, Unit 2 Fire Brigade Equipment Inspection, Completed 4/24/16
C SP 600.24, Unit 2 Fire Brigade Equipment Inspection, Completed 5/25/16
C SP 600.25, Unit 2 Fire Door Inspection, Completed 6/20/16
C SP 600.25, Unit 3 Fire Door Inspection, Completed 9/3/15
C SP 600.28, Fire Brigade Vehicle Equipment Inspection Data Sheet (R1), Completed 5/21/16
C SP 600.6, Electric Fire Pump M7-8 Monthly Operability Demonstration, Completed 5/10/16 &
      6/3/16
C SP 600.7, Electric Fire Pump M7-8 Annual Operability Demonstration, Completed 12/22/14 &
      12/19/15
C SP 600.8, Diesel Fire Pump M7-7 Monthly Operability Demonstration, Completed 5/13/16 &
      6/8/16
C SP 600.9, Diesel Fire Pump M7-7 Annual Operability Demonstration, Completed 8/6/15 &
      6/8/16
C SP 788A, Fire Pump Diesel Engine Battery Quarterly Surveillance, Completed 6/16/16
C SP 788B, Fire Pump Diesel Engine Battery 18-Month Surveillance, Completed 6/10/16
C SP 788C, Fire Pump Diesel Engine Battery Weekly Surveillance, Completed 6/16/16
CSP 600.24, Fire Brigade Equipment Inspection, Completed 6/3/16
SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 1, Completed 2/10/06
SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 4, Completed 2/9/11
SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 4, Completed 10/9/14
SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 9, Completed 12/27/13
SFP 21, Unit 2 Appendix R Fire Cage Inventory, Completed 11/25/15
SFP 9, Unit 3 - Fire Extinguisher Inspection Data Sheet - Train B, Completed 6/29/16
SFP 9, Unit 3 - Fire Extinguisher Inspection Data Sheet - Train A, Completed 7/11/16
SFP Procedure 21, Unit 3 Safe Shutdown Fire Cage Inventory, Completed on 11/26/2015
SP 2402CR, Steam Generator Pressure Rack Instrument Calibration, Revision 0, Completed
      8/12/14 and 3/16/16
SP 2601P, Unit 2 CVCS Valve Operability Tests from C-10 and C-02, Revision 0, Completed
      10/30/15
SP 2610B, Turbine Driven Auxiliary Feed Pump Operational Tests from C-10, Completed 3/2/16
SP 2610E, Atmospheric Dump Valve Testing From C-10, C-70A and C-70B, Completed
      10/21/15
SP 2610M, Power Operated Relief Valve Hot Functional Test, Completed 11/1/15
SP 2657, EOP Equipment Inventory, Completed 9/7/15
SP 3442J01, RCS Wide Range Pressure Rack Calibration, Completed 9/16/14 and 2/11/16
SP 3444A02, Steam Generator Water Level Wide Range Calibration, Completed 7/10/13 and
      3/11/15


25212-25009, Yard Water & Fire Protection Piping, Revision 24 25212-26902, Sht. 1, Unit 3 P&ID Reactor Coolant System, Revision 33 25212-26902, Sht. 3, Unit 3 P&ID Reactor Coolant System, Revision 25
                                            A-7
25212-26904, Sht. 1, Unit 3 P&ID Chemical and Volume Control, Revision 54
SP 3451Q01, Unit 3 Instrument Rack Room and Fire Pump House - Halon Fire System Test,
25212-26904, Sht. 2, Unit 3 P&ID Chemical and Volume Control, Revision 17
      Completed 2/26/16
25212-26905, Sht. 1, Unit 3 P&ID Charging Pump Seal and Lubrication, Revision 33
SP 3641B.2, IRR Halon System Flow Test, Completed 5/17/15
25212-26921, Sht. 1, Unit 3 P&ID Component Cooling Water, Revision 33 25212-26970, Fire Protection System, Revision 12
SP 3641B.2, IRR Halon System Flow Test, Completed 5/8/14
SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 1/8/15
Pre-Fire Plans Fire Area AB-6, Auxiliary Building West MCC and Rod Control Area, Revision 0
SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 1/19/13
Fire Area CB-11, Control Building Instrument Rack Room Underfloor Area, Revision 0 Fire Area EG-3, Emergency Generator North Emergency generator Enclosure, Revision 0 Fire Area ESF-3, Engineered Safety Features Building North Residual Heat Removal Heat
SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 12/21/14
Exchanger Cubicle, Revision 0 MP2 Fire Fighting Strategies, Unit 2, Fire Area A-15, Diesel Generator A Cubicle, Revision 0
SP 3641D.3, Fire Protection Zone Panel 5C EDG A Area Detector Operability Checks,
MP2 Fire Fighting Strategies, Unit 2, Fire Area A-32, Air Handling Units 38'6'', Revision 0 MP2 Fire Fighting Strategies, Unit 2, Fire Area T-7, 69. And 4.16 KV Switchgear Room, Revision 0 MP2 Fire Fighting Strategies, Unit 2, Fire Area T-9, East 45' Cable Vault (Z1 train), Revision 0
      Completed 2/25/16
SP 3641D.5, Fire Damper Operability Verification, Completed 1/25/06
SP 3641D.5, Fire Damper Operability Verification, Completed 5/8/11
SP 3641D.5, Fire Damper Operability Verification, Completed 9/5/99
SP 3641D.6, Fire Rated Assemblies Inspection, Completed 8/2/15
SP 3641F.1, Functional Check of the East and West Switchgear Breathing Air System,
      Completed 6/21/15
SP 3672.2-10, Fire Transfer Switch Panel Operational Testing-3RCS*PCV455A, Completed
      11/9/14
SP 3672.2-2, Fire Transfer Switch Panel Operational Testing-3HVP*FN1A and FN1C,
      Completed 3/20/12
SP 3672.2-7, Fire Transfer Switch Panel Operational Testing-3SWP*MOV54A and MOV54C,
      Completed 8/1/13
SP 3672.2-8, Fire Transfer Switch Panel Operational Testing-3SWP*MOV71A Completed
      11/23/15
SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVP*FN1A and
      3HVP*FN1C, Completed 3/20/12
SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*FN14A, Completed
      10/25/14
SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*MOD50A,
      Completed 12/20/12
SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*ACU1A, Completed
      12/22/15
SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVY*FN2A, Completed
      12/18/12
SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3SWP*MOV71A,
      Completed 11/23/15
SP 3673.4, Auxiliary Shutdown Panel Operability Test for Charging Injection Path, Completed
      5/1/16
SP 3673.4, Auxiliary Shutdown Panel Operability Test for Charging Isolation Path, Completed
      5/1/16
SP 3673.4, Auxiliary Shutdown Panel Operability Test for Train A CVCS Components,
      Completed 1/14/15
SP 3673.4-001, Auxiliary Shutdown Panel Operability Test, Completed 5/8/16
SP 3673.4-004, Auxiliary Shutdown Panel Operability Test Train A Auxiliary Feedwater
      Components, Completed 2/8/15
SP 3673.4-007, Auxiliary Shutdown Panel Operability Test Train B Auxiliary Feedwater
      Components, Completed 2/1/15
SP 3673.4-009, Auxiliary Shutdown Panel Operability Test Train B CVCS Components,
      Completed 5/22/16


                                              A-8
Fire Drills and Critiques
SP 3673.4-011, Auxiliary Shutdown Panel Operability Test Train A PORV and Block Valves,
Fire in Building 454, Completed 6/7/16 Fire in U1 Maintenance Shop, Completed 12/14/15 Fire in U2 H2 Seal Oil Skid Pass, Completed 6/18/15
        Completed 1/9/14
Fire in U2 Intake, Completed 12/4/15  
SP 3673.4-014, Auxiliary Shutdown Panel Operability Test Non-Train Related Components,
Fire in U2 Lube Oil Room, Completed 6/9/15  
        Completed 5/1/16
SP2618C, Smoke and Heat Detector Testing, Auxiliary Building, Completed 3/24/16
SP2618C, Smoke Detector Testing, Switchgear Detector Testing, Facility 1, Completed 5/30/16
SP2618C, Smoke Detector Testing, Turbine Building, Completed 1/19/16
SP2618C, Turbine Bldg. 256 Cable Vault and Vertical Shaft Smoke Detector Test, Completed
        3/4/16
SP2618D, A DG Deluge Systems Design Function Test, Completed 1/12/16
SP2618D, Fire Protection System sprinkler and Deluge Design Function test, Completed
        5/20/15
SP2618H, Fire Protection System Deluge Nozzle Flow Test, Completed 7/16/14
SP2618L, Fire Protection Coating Inspection, Completed 8/4/15
SP2618L, TSI Fire Wrap Inspection, Completed 8/7/15
SP2657, Inventory Remote Shutdown Station Storage, Completed 5/13/16
Operating Experience Evaluations
Information Notice 2014-10, Potential Circuit Failure-Induced Secondary Fires or Equipment
        Damage, dated 9/16/14
Quality Assurance Audits and Self Assessments
Audit 15-04, Fire Protection Program, dated 7/15/15
System Health Reports
3341 A, B, C, F - Fire Protections Water, Halon, CO2, Emerg. Breathing Air, dated
        10/1/14- 12/31/14
3341 A, B, C, F - Fire Protections Water, Halon, CO2, Emerg. Breathing Air, dated
        10/1/15- 12/31/15
3341D - Fire Detection, dated 10/1/14- 12/31/14
3341D - Fire Detection, dated 10/1/15- 12/31/15
ELU System Health Report, 1St Quarter 2016
ELU System Health Report, 4th Quarter 2015
Program/Comp Health Report FP- Fire Protection - Including Appendix R, 4th Quarter 2015
Program/Comp Health Report FP- Fire Protection - Including Appendix R, 1st Quarter 2016
System Health Report 2352, 3720B - Safe Shutdown Lighting, 1st Quarter 2016
System Health Report 2352, 3720B - Safe Shutdown Lighting, 4th Quarter 2015
U 2 Fire Protection & Deluge, CO2 Alterex, Halon Supression, 4th Quarter 2014
U 2 Fire Protection & Deluge, CO2 Alterex, Halon Supression, 4th Quarter 2015
Unit 2 AC and DC Systems, 4th qtr. 2015 and 1st Quarter 2016
Unit 3 AC and DC Systems, 4th qtr. 2015 and 1st Quarter 2016


Fire in U2 Upper 4160 Switch Gear, Completed 4/28/15 Fire in U3 Maintenance Shop, Completed 12/12/15
                                              A-9
Drawings and Wiring Diagrams
Fire Brigade Training B5b Familiarization PowerPoint Presentation
12179-30276, U3 Generator Seal Oil System Emergency Seal Oil pump 3GMO-P2 Control,
B5b Hands-On Training attendance records, dated 5/12/15 and 11/17/15
      Revision 5
Beyond Design Basis, Non-Licensed Operator Training Presentation
12179-FIG-77B, Fire Hazard Analysis Plan Elevation 24 Feet 6 inch, Revision 6
   
12179-FIG-77C, Fire Hazard Analysis Plant Elevation 38 Feet 6 inch, Revision 11
A-12  Operator Safe Shutdown Training 15605L, EOP 3509.1 Self-Guided in Plant Walkdown, Revision 0 AOP 2559 - Fire AOP 2579A/AA - Appendix R Fire in R-1, Aux Bldg including Control Room/Computer Rooms/25' Cable Vault, Millstone Unit 2 Licensed Operator Training
25203-24070, Sheet 10, RCP Oil Collection System Details for RCP Motor in Cubicle A,
Program Slides ASP115C, Auxiliary Shutdown Equipment/Auxiliar
      Revision 2
y Shutdown Panel Lesson Plan, Revision 3 C15506N, MP3*NLCT*EOP 3509.1, Revision 0 Common Operating Procedure 200.18 Time Critical Action Validation and Verification Slides, dated 7/12/16 JPM P003, Isolate Emergency Bus 34C in Accordance with EOP 3509.1, Revision 7
25203-24070, Sheet 11, RCP Oil Collection System Details for RCP Motor in Cubicle A,
JPM P011 (MC-00094), Primary Side Plant Equipment Operator (PEO) Actions on a Control Room Evacuation (Parts 1 and 2), Revision 9/0 JPM P012, Secondary Side PEO Actions on a Control Room Evacuation, Revision 6
      dated 5/16/95
JPM P015, Secondary Side PEO Actions on a Control Room Evacuation due to Fire, Revision 8
25203-24070, Sheet 12, RCP Oil Collection System Details for RCP Motor in Cubicle A,
JPM P173, Aligning the Fire Transfer Switch
      dated 4/19/95
Panel and Auxiliary Shutdown Panel in Response
25203-24070, Sheet 13, RCP Oil Collection System Details for RCP Motor in Cubicle A,
to a Fire, Revision 2 JPM P188, Installation of 3CHS-PI102T, Revision 0 JPM P209, Cross-Connect Service Water to East Switchgear Ventilation, Revision 1 SEG S13406L, Respond to a Control Room, Cabl
      dated 4/20/95
e Spreading Area or Instrument Rack Room
25203-28500, Sht.356, Unit 2 PT-1023B Steam Generator Pressure Loop Diagram, Revision 10
Fire, Revision 0 SEG S15304L, Fire in Instrument Rack Room, Revision 0
25203-30001, Unit 2 Main Single Line Diagram, Revision 40
Unit 2 Licensed Operator Requalification Program Attendance Sheet for Cycle 16-3, 5/10 - 6/17
25203-30005, Unit 2 Single Line Meter and Relay Diagram 4.16kV Emergency Buses 24C and
Hot Work and Ignition Source Permits, and Tr
      24D, Revision 21
ansient Combustible Permits and Evaluations
25203-30009, Unit 2 Single Line Meter and Relay Diagram 4.16kV Emergency Buses 25E and
29633-12-FP 30391-13-IS 31960-15-IS 41224-12-FP
      24G, Revision 13
41316-12-FP 41399-12-IS 43879-15-FP 43965-15-IS 44356-16-FP 44385-16-IS 44389-16-IS 44390-16-IS 44499-16-FP   
25203-30022, Sht. 3, Unit 2 DV20 125Vdc and 120Vac Distribution Panel Schedule, Revision
      21
Corrective Action Program Documents (Condition Reports)
25203-30023, U2 Single Line Diagram 125VDC System-Turbine Battery, Revision 9
463259 515160 520964 522469 522722 522740 522848 522850 523785 527755 530987 541980
25203-30024, U2 Single Line Diagram 125VDC Emergency & 120VAC Vital Systems, Revision
541983 553343 557088 576367
      39
578178 578333 581890 582625
25203-30053, Sheet 1, U2 Schematic Diagram 125VDC Switchgear Bus D01, Revision 7
582652 582665 1004974 1009069 1037462 1041883 1042283* 1043063* 1043417* 1043422* 1043425* 1043455*
25203-30053, Sheet 3, U2 Schematic Diagram 125VDC Switchgear Bus D02, Revision 9
1043458* 1043959* 1044278* 1044301*
25203-30053, Sheet 5, U2 Switchgear Diagram 125VDC Switchgear Bus D03, Revision 10
1044326* 1044332* 1044334* 1044348*
25203-30102, Unit 2 Instrument Rack Loading Diagram Fire Shutdown Panel C09, Revision 3
1044422* 1044536* 1044760* 
25203-32002, Sh. 16, 4.16kV Switchgear Kirk Key Interlocks, Revision 5
  * NRC identified during this inspection.
25203-32006, Sheet 13, U2 Magnetic Starter Elementary Diagram, Revision 8
25203-32009, Sht. 37, Unit 2 Charging Line Distribution Solenoid Valve CH519, Revision 9
25203-32009, Sht. 41, Unit 2 Charging Pump Control MP18B, Revision 23
25203-32009, Sht. 42A, Unit 2 Charging Pump Control MP18B, Revision 3
25203-32009, Sht. 6, Unit 2 Volume Control Tank Discharge MOV CH501, Revision 13
25203-34051, Unit 2 Auxiliary Building Miscellaneous Plan Section and Details, Revision 40
25203-39076, Sheet 9A, U2 Magnetic Starter Elementary Diagram, Revision 1
25203-39076, Sheet 9B, U2 Magnetic Starter Elementary Diagram, Revision 1
25203-39220, Sht. 1B, Unit 2 Instrument Rack Loading Diagram Spec 200 Cabinet RC30B,
      Revision 19
25203-39352, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP1 & Static Sw. VS1,
      Revision 5
25203-39353, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP2 & Static Sw. VS2,
      Revision 5
25203-39354, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP3 & Static Sw. VS3,
      Revision 5
25203-39355, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP4 & Static Sw. VS4,
      Revision 3
25203-39356, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP5, Revision 5


                                            A-10
 
25203-39357, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP6, Revision 6
A-13  Work Orders
25203-39367, Sheet 6, U2 Schematic Totalizing Box Turbine Battery Charger 201D/DC4,
53M20807693 53012768647 53102490410 53102502011
      Revision 2
53102582983 53102605405 53102649190 53102656386
25205-25003, Station Fire Loop Operating & Hydraulic Analysis Schematic, Revision 14
53102659739 53102669361 53102693811 53102695870
25212-24036, Fire Stop & Seals Map Locations, Revision 0
53102698825 53102698915 53102698922 53102698928 53102698931 53102716240 53102716256 53102732991 53102735138 53102759052 53102760642 53102764120
25212-24037, Fire Stop & Seals Map Locations, Revision 0
53102786767 53102814722 53102846681 53102853315
25212-24273, Wall Pene. Map Aux. BLDG. EL. 45-6, Revision 2
53102854686 53102861679 53102871440 53102873143
25212-29367 SH 20, Fire Protection & Detection Systems, dated 6/2/75
53102887195 53102892290 53102900241 53102905692 53102914238 53102952946 53102958935 
25212-29680 SH.0010, TCO-003 High Density Silicone Elastomer Fire, Air, and/or Radiation
      Seal for Electrical Blockout Openings, dated 8/20/84
Vendor Manuals 25212-902-001, Vendor Technical Manual for Emergency Lighting from Exide, Holophane, Dualite, Birns, Revision 6 TI 2AI-130, Spec 200 Current-To-Voltage Converters, dated 10/77
25212-29680 SH.0023, TCO-050 Silicone Foam Fire or Air Seals for Sleeve, Conduit, Cast or
Industry Standards NFPA 10-1968, Installation for Portable Fire Extinguishers
      Core Bored Openings up to 5 Dial, dated 1/26/85
NFPA 13-1971, Installation of Sprinkler Systems
25212-30001, Unit 3 Main One Line Diagram, Revision 26
NFPA 14-1978, Installation of Standpipe and Hose Systems NFPA 15-1985, Water Spray for Fixed Systems for Fire Protection NFPA 27-1975, Private Fire Brigade
25212-30004, Unit 3 Main One Line Diagram 4160V Normal and Emergency Buses, Revision
NFPA 72D-1986, Maintenance and Use of Proprietary protective Signaling Systems
      20
25212-30010, Unit 3 6900V One Line Diagram Bus 35A and 35B, Revision 20
25212-30011, Unit 3 6900V One Line Diagram Bus 35C and 35D, Revision 21
25212-30027, Sht. 3, Unit 3 480V Motor Control Center One Line Diagram Auxiliary Building,
      Revision 44
25212-30272, Sht. 29A, Unit 3 Feedwater System Steam Generator 3RCS*SG1A Wide Range
      Level Indication, Revision 8
25212-30272, Sht. 30, Feedwater System Steam Generator 3RCS*SG1A, Revision 5
25212-30343, Sht. 10A, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop
      Diagram, Revision 6
25212-30343, Sht. 10B, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop
      Diagram, Revision 5
25212-30343, Sht. 10C, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop
      Diagram, Revision 5
25212-30343, Sht. 11, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop
      Diagram, Revision 5
25212-30379, Sheet 8, U3 Turbine Generator Lube Oil System Emergency Bearing Oil Pump
      Control, Revision 3
25212-3200, Sht. 7, Elementary Diagram Reactor Head Vent Isolation Valves
      3RCS*SV8095A(B), Revision 6
25212-32001, Elementary Diagram 480V MCC Charging Header Isolation Valve
      2CHS*MV8438A, Revision 15
25212-32001, Sheet 6CI, U3 Elementary Diagram 125VDC Emergency Bearing Oil Pump
      [3TML-P1], Revision 10
25212-32001, Sheet 6CS, U3 Elementary Diagram 125VDC Generator Emergency Seal Oil
      Pump [3GMO-P2], Revision 14
25212-32001, Sht. 7DX, Elementary Diagram Letdown Line Isolation Valves 3RCS*LCV459 and
      3RCS*LCV460, Revision 9
25212-32068, U3 Elementary Diagram Diesel Driven Fire Pump M7-7 Control Circuit, Revision
      2
25212-39002, Sheet 1020, U3 DC Starter Emergency Seal Oil Elementary, Revision D
25212-39002, Sheet 1021, U3 DC Starter Emergency Seal Oil Schematic, Revision C
25212-39002, Sheet 1062, U3 Emergency Bearing Oil Pump Starter-Outline Schematic & Conn.
      Diagram, Revision E


NFPA 72E-1984, Automatic Fire Detectors
                                              A-11
SKE-3.1-ELEC DIST, Emergency System One Line Diagram for Appendix R, Revision 2
Piping and Instrumentation Diagrams
25203-26005, Sht. 2, Unit 2 P&ID Feed System, Revision 73
25203-26008, Sh. 2, Piping and Instrumentation Diagram Service Water, Revision 114
25203-26011, Fire Protection, Revision 57
25203-26014, Sht. 1, Unit 2 P&ID Reactor Coolant System, Revision 41
25203-26014, Sht. 2, Unit 2 P&ID Reactor Coolant System, Revision 46
25203-26017, Sht. 1, Unit 2 P&ID Charging System, Revision 63
25212-25008, Yard Water & Fire Protection Piping, Revision 29
25212-25009, Yard Water & Fire Protection Piping, Revision 24
25212-26902, Sht. 1, Unit 3 P&ID Reactor Coolant System, Revision 33
25212-26902, Sht. 3, Unit 3 P&ID Reactor Coolant System, Revision 25
25212-26904, Sht. 1, Unit 3 P&ID Chemical and Volume Control, Revision 54
25212-26904, Sht. 2, Unit 3 P&ID Chemical and Volume Control, Revision 17
25212-26905, Sht. 1, Unit 3 P&ID Charging Pump Seal and Lubrication, Revision 33
25212-26921, Sht. 1, Unit 3 P&ID Component Cooling Water, Revision 33
25212-26970, Fire Protection System, Revision 12
Pre-Fire Plans
Fire Area AB-6, Auxiliary Building West MCC and Rod Control Area, Revision 0
Fire Area CB-11, Control Building Instrument Rack Room Underfloor Area, Revision 0
Fire Area EG-3, Emergency Generator North Emergency generator Enclosure, Revision 0
Fire Area ESF-3, Engineered Safety Features Building North Residual Heat Removal Heat
        Exchanger Cubicle, Revision 0
MP2 Fire Fighting Strategies, Unit 2, Fire Area A-15, Diesel Generator A Cubicle, Revision 0
MP2 Fire Fighting Strategies, Unit 2, Fire Area A-32, Air Handling Units 386, Revision 0
MP2 Fire Fighting Strategies, Unit 2, Fire Area T-7, 69. And 4.16 KV Switchgear Room,
        Revision 0
MP2 Fire Fighting Strategies, Unit 2, Fire Area T-9, East 45 Cable Vault (Z1 train), Revision 0
Fire Drills and Critiques
Fire in Building 454, Completed 6/7/16
Fire in U1 Maintenance Shop, Completed 12/14/15
Fire in U2 H2 Seal Oil Skid Pass, Completed 6/18/15
Fire in U2 Intake, Completed 12/4/15
Fire in U2 Lube Oil Room, Completed 6/9/15
Fire in U2 Upper 4160 Switch Gear, Completed 4/28/15
Fire in U3 Maintenance Shop, Completed 12/12/15
Fire Brigade Training
B5b Familiarization PowerPoint Presentation
B5b Hands-On Training attendance records, dated 5/12/15 and 11/17/15
Beyond Design Basis, Non-Licensed Operator Training Presentation


Miscellaneous Documents
                                            A-12
Aid Agreement letter Between Millstone and the Waterford Fire Service, dated 8/6/15 Electrical Cable and Conduit Routing Information - SAFE
Operator Safe Shutdown Training
Fire and Hose-Stream tests for Penetration Seal Systems, dated 4/82
15605L, EOP 3509.1 Self-Guided in Plant Walkdown, Revision 0
Fire Qualification Test on Floor Penetration Seals, dated 11/30/79
AOP 2559 - Fire AOP 2579A/AA - Appendix R Fire in R-1, Aux Bldg including Control
Hazard Evaluation Sheet Building - CB, dated 12/11/85 Millstone Site Fire Protection Active Impairment List, dated 7/11/16 Millstone Site Fire Protection Active Impairment List, dated 7/26/16
        Room/Computer Rooms/25 Cable Vault, Millstone Unit 2 Licensed Operator Training
Millstone Site Fire Protection Active Impairment List, dated 7/27/16  
        Program Slides
Waterford Ambulance Service Memorandum of Understanding (MOU), dated 8/5/15
ASP115C, Auxiliary Shutdown Equipment/Auxiliary Shutdown Panel Lesson Plan, Revision 3
C15506N, MP3*NLCT*EOP 3509.1, Revision 0
Common Operating Procedure 200.18 Time Critical Action Validation and Verification Slides,
        dated 7/12/16
JPM P003, Isolate Emergency Bus 34C in Accordance with EOP 3509.1, Revision 7
JPM P011 (MC-00094), Primary Side Plant Equipment Operator (PEO) Actions on a Control
        Room Evacuation (Parts 1 and 2), Revision 9/0
JPM P012, Secondary Side PEO Actions on a Control Room Evacuation, Revision 6
JPM P015, Secondary Side PEO Actions on a Control Room Evacuation due to Fire, Revision 8
JPM P173, Aligning the Fire Transfer Switch Panel and Auxiliary Shutdown Panel in Response
        to a Fire, Revision 2
JPM P188, Installation of 3CHS-PI102T, Revision 0
JPM P209, Cross-Connect Service Water to East Switchgear Ventilation, Revision 1
SEG S13406L, Respond to a Control Room, Cable Spreading Area or Instrument Rack Room
        Fire, Revision 0
SEG S15304L, Fire in Instrument Rack Room, Revision 0
Unit 2 Licensed Operator Requalification Program Attendance Sheet for Cycle 16-3, 5/10 - 6/17
Hot Work and Ignition Source Permits, and Transient Combustible Permits and Evaluations
  29633-12-FP            30391-13-IS        31960-15-IS          41224-12-FP
  41316-12-FP            41399-12-IS        43879-15-FP          43965-15-IS
  44356-16-FP            44385-16-IS        44389-16-IS          44390-16-IS
  44499-16-FP
Corrective Action Program Documents (Condition Reports)
  463259                  515160            520964                522469
  522722                  522740            522848                522850
  523785                  527755            530987                541980
  541983                  553343            557088                576367
  578178                  578333            581890                582625
  582652                  582665            1004974              1009069
  1037462                1041883            1042283*              1043063*
  1043417*                1043422*          1043425*              1043455*
  1043458*                1043959*          1044278*              1044301*
  1044326*                1044332*          1044334*              1044348*
  1044422*                1044536*          1044760*
* NRC identified during this inspection.


Waterford Fire Service MOU, dated 8/6/15 Waterford Police Department MOU, dated 9/14/15  
                                              A-13
Work Orders
 
53M20807693              53012768647            53102490410          53102502011
A-14  LIST OF ACRONYMS
53102582983              53102605405            53102649190          53102656386
ADAMS Agencywide Documents Access and Management System ADV  Atmospheric Dump Valve
53102659739              53102669361            53102693811          53102695870
AFW  Auxiliary Feedwater
53102698825              53102698915            53102698922          53102698928
AOP  Abnormal Operating Procedure BTP  Branch Technical Position CAP  Corrective Action Program
53102698931              53102716240            53102716256          53102732991
CFR  Code of Federal Regulations
53102735138              53102759052            53102760642          53102764120
CMEB  Chemical Engineering Branch
53102786767              53102814722            53102846681          53102853315
53102854686              53102861679            53102871440          53102873143
53102887195              53102892290            53102900241          53102905692
53102914238              53102952946            53102958935
Vendor Manuals
25212-902-001, Vendor Technical Manual for Emergency Lighting from Exide, Holophane,
        Dualite, Birns, Revision 6
TI 2AI-130, Spec 200 Current-To-Voltage Converters, dated 10/77
Industry Standards
NFPA 10-1968, Installation for Portable Fire Extinguishers
NFPA 13-1971, Installation of Sprinkler Systems
NFPA 14-1978, Installation of Standpipe and Hose Systems
NFPA 15-1985, Water Spray for Fixed Systems for Fire Protection
NFPA 27-1975, Private Fire Brigade
NFPA 72D-1986, Maintenance and Use of Proprietary protective Signaling Systems
NFPA 72E-1984, Automatic Fire Detectors
Miscellaneous Documents
Aid Agreement letter Between Millstone and the Waterford Fire Service, dated 8/6/15
Electrical Cable and Conduit Routing Information - SAFE
Fire and Hose-Stream tests for Penetration Seal Systems, dated 4/82
Fire Qualification Test on Floor Penetration Seals, dated 11/30/79
Hazard Evaluation Sheet Building - CB, dated 12/11/85
Millstone Site Fire Protection Active Impairment List, dated 7/11/16
Millstone Site Fire Protection Active Impairment List, dated 7/26/16
Millstone Site Fire Protection Active Impairment List, dated 7/27/16
Waterford Ambulance Service Memorandum of Understanding (MOU), dated 8/5/15
Waterford Fire Service MOU, dated 8/6/15
Waterford Police Department MOU, dated 9/14/15


CO 2  Carbon Dioxide CONVEX Connecticut Valley Electric Exchange CR Condition Report  
                                            A-14
CSD Cold Shutdown  
                                  LIST OF ACRONYMS
DC Direct Current  
ADAMS    Agencywide Documents Access and Management System
Dominion Dominion Nuclear Connecticut, Inc.  
ADV      Atmospheric Dump Valve
DRS Division of Reactor Safety EDG Emergency Diesel Generator EOP Emergency Operating Procedure  
AFW      Auxiliary Feedwater
FA Fire Area  
AOP      Abnormal Operating Procedure
FHA Fire Hazards Analysis  
BTP      Branch Technical Position
FPP Fire Protection Program FSAR Final Safety Analysis Report FZ Fire Zone  
CAP      Corrective Action Program
IEEE Institute of Electrical and Electronics Engineering  
CFR      Code of Federal Regulations
IMC Inspection Manual Chapter  
CMEB      Chemical Engineering Branch
IP Inspection Procedure IPEEE Individual Plant Examination of External Events IR Inspection Report  
CO2      Carbon Dioxide
LER Licensee Event Report  
CONVEX   Connecticut Valley Electric Exchange
LOOP Loss of Offsite Power  
CR       Condition Report
Millstone Millstone Power Station Unit 2 and Unit 3  
CSD       Cold Shutdown
NCV Non-Cited Violation NFPA National Fire Protection Association NRC Nuclear Regulatory Commission  
DC       Direct Current
OMA Operator Manual Action  
Dominion Dominion Nuclear Connecticut, Inc.
P&ID Piping and Instrumentation Drawing  
DRS       Division of Reactor Safety
PARS Publicly Available Records System RAS Reasonable Assurance of Safety SBO Station Blackout  
EDG       Emergency Diesel Generator
SDP Significance Determination Process  
EOP       Emergency Operating Procedure
SER Safety Evaluation Report  
FA       Fire Area
SFP Site Fire Protection  
FHA       Fire Hazards Analysis
SG Steam Generator UFSAR Updated Final Safety Analysis Report V Volts  
FPP       Fire Protection Program
V dc Voltage Direct Current
FSAR     Final Safety Analysis Report
FZ       Fire Zone
IEEE     Institute of Electrical and Electronics Engineering
IMC       Inspection Manual Chapter
IP       Inspection Procedure
IPEEE     Individual Plant Examination of External Events
IR       Inspection Report
LER       Licensee Event Report
LOOP     Loss of Offsite Power
Millstone Millstone Power Station Unit 2 and Unit 3
NCV       Non-Cited Violation
NFPA     National Fire Protection Association
NRC       Nuclear Regulatory Commission
OMA       Operator Manual Action
P&ID     Piping and Instrumentation Drawing
PARS     Publicly Available Records System
RAS       Reasonable Assurance of Safety
SBO       Station Blackout
SDP       Significance Determination Process
SER       Safety Evaluation Report
SFP       Site Fire Protection
SG       Steam Generator
UFSAR     Updated Final Safety Analysis Report
V         Volts
V dc     Voltage Direct Current
}}
}}

Revision as of 14:08, 30 October 2019

NRC Triennial Fire Protection Inspection Report 05000336/2016007 and 05000423/2016007
ML16258A175
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 09/14/2016
From: Christopher Cahill
Engineering Region 1 Branch 3
To: Heacock D
Dominion Resources
References
IR 2016007
Download: ML16258A175 (37)
v • d • e


See also: IR 05000336/2016007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD.

KING OF PRUSSIA, PA 19406-2713

September 14, 2016

Mr. David A. Heacock

President and Chief Nuclear Officer

Dominion Resources

5000 Dominion Boulevard

Glen Allen, VA 23060-6711

SUBJECT: MILLSTONE POWER STATION - NRC TRIENNIAL FIRE PROTECTION

INSPECTION REPORT 05000336/2016007 AND 05000423/2016007

Dear Mr. Heacock:

On August 11, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire

protection inspection at Millstone Power Station, Units 2 and 3. The enclosed inspection report

documents the inspection results, which were discussed on August 11, 2016, with Mr. John

Daugherty, Site Vice President - Millstone Power Station, and other members of your staff.

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

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

license. The inspectors reviewed selected procedures and records, observed activities, and

interviewed station personnel. The inspectors also reviewed mitigation strategies for addressing

large fires and explosions.

Based on the results of this inspection, one finding of very low safety significance (Green) was

identified. This finding was determined to be a violation of NRC requirements. However,

because of its very low safety significance, and because it was entered into your corrective

action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with

Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCV in this report, you should

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

your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director,

Office of Enforcement; and the NRC Resident Inspector at Millstone Power Stations.

D. Heacock 2

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's

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

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

Publicly Available Records System (PARS) component of the NRC's document system,

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

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

Reading Room).

Sincerely,

/RA/

Christopher G. Cahill

Acting Branch Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-336, 50-423

License Nos. DPR-65, NPF-49

Enclosure:

Inspection Report 05000336/2016007

and 05000423/2016007

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

ML16258A175

Non-Sensitive Publicly Available

SUNSI Review

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

NAME JPatel WCook GDentel CCahill

DATE 09/09/16 09/09/16 09/09/16 09/14/16

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos.: 50-336, 50-423

License Nos.: DPR-65, NPF-49

Report Nos.: 05000336/2016007 and 05000423/2016007

Licensee: Dominion Nuclear Connecticut, Inc.

Facility: Millstone Power Station, Units 2 and 3

Location: P.O. Box 128

Waterford, CT 06385

Dates: July 25, 2016 through August 11, 2016

Inspectors: J. Patel, Reactor Inspector (Team Leader)

Division of Reactor Safety (DRS)

W. Cook, Senior Reactor Analyst, DRS

E. DiPaolo, Senior Reactor Inspector, DRS

D. Orr, Senior Reactor Inspector, DRS

K. Young, Senior Reactor Inspector, DRS

L. Dumont, Reactor Inspector, DRS

S. Galbreath, Reactor Inspector, DRS

J. Rady, Reactor Inspector, DRS

Observers: S. Freeman, Senior Reactor Analyst, NRC, Region II, DRS

Approved by: Chris Cahill, Acting Branch Chief

Engineering Branch 3

Division of Reactor Safety

i Enclosure

SUMMARY OF FINDINGS

IR 05000336/2016007, 05000423/2016007; 07/25/2016 - 08/11/2016; Dominion Nuclear

Connecticut, Inc.; Millstone Power Station, Units 2 and 3; Fire Protection (Triennial).

This report covered a two week on-site triennial fire protection team inspection by specialist

inspectors. One finding of very low safety significance was identified. This finding was

determined to be a non-cited violation. The significance of most findings is indicated by their

color (Green, While, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance

Determination Process. The cross-cutting aspects associated with findings were determined

using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the

significance determination process (SDP) does not apply may be Green or be assigned a

severity level after NRC management review. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 6, dated July 2016.

Cornerstone: Mitigating Systems

Green. The team identified a finding of very low safety significance (Green) involving a non-

cited violation of Millstone Power Station, Unit 2, Renewed Facility Operating License

Condition 2.C.(3) to implement and maintain in effect all provisions of the approved fire

protection program as described in the Final Safety Analysis Report (FSAR). Specifically,

Dominion failed to maintain the #2 steam generator (SG) atmospheric dump valve (ADV)

free from fire damage, which may have affected the availability to maintain hot shutdown

conditions from the main control room for a fire in Fire Area R-14, Lower 4.16kV Switchgear

Room and Cable Vault. Dominion promptly entered this safe shutdown issue into their

corrective action program as condition report (CR) 1043458. Immediate corrective actions

included implementing compensatory measures in the form of fire watches for fire area R-14

that are being tracked by Reasonable Assurance of Safety (RAS) determination 3037040.

Longer term corrective actions included submitting an exemption request to the NRC for use

of a local operator manual action (OMA) to operate the #2 SG ADV in lieu of meeting fire

protection requirements for fire area R-14. The team considered Dominions immediate and

longer term corrective actions appropriate.

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

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

that respond to an external event to prevent undesirable consequences in the event of a fire.

Specifically, the use of an OMA during post-fire safe shutdown is not as reliable as normal

systems operation which could be utilized had the requirements of 10 CFR Part 50,

Appendix R,Section III.G.2 been met and, therefore, prevented fire damage to credited

components and/or cables, specifically the #2 SG ADV. The inspectors used IMC 0609,

Appendix F, Fire Protection Significance Determination Process, Phase 1 and determined

the reactor is able to reach and maintain a hot safe shutdown condition because the SG

ADVs are used for transition to cold shutdown, therefore this finding was of very low safety

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

performance deficiency occurred greater than three years ago when the June 30, 2011

exemption request letter to the NRC was supplemented by letter on February 29, 2012, and

is not indicative of current licensee performance. (Section 1R05.01)

ii

Other Findings

Three violations of very low safety significance that were identified by Dominion were reviewed

by the team. Corrective actions taken or planned by Dominion have been entered into

Dominions corrective action program (CAP). The violations and corrective action tracking

numbers are listed in Section 4OA7 of this report.

iii

REPORT DETAILS

Background

This report presents the results of a triennial fire protection inspection conducted in accordance

with the U.S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T,

Fire Protection (Triennial). The objective of the inspection was to assess whether Dominion

Nuclear Connecticut, Inc. (Dominion) has implemented an adequate fire protection program

(FPP) and that post-fire safe shutdown capabilities have been established and are being

properly maintained at the Millstone Power Station Unit 2 and Unit 3 (Millstone). The following

fire areas (FA) and/or fire zones (FZ) were selected for detailed review based on risk insights

from the Millstone Individual Plant Examination of External Events (IPEEE).

Unit 2 Fire Areas / Fire Zones

R-7 / A-15, A Diesel Generator Room A

R-1 / A-32, Main Ventilation Room (Air Handling Units)

R-14 / T-7, 6.9 & 4.16 kV Switchgear Room

R-14 / T-9, East Cable Vault

Unit 3 Fire Areas

AB-6, West MCC & Rod Control Area

CB-11, Instrument Rack Room and Underfloor Area

EG-3, North Emergency Generator Enclosure

ESF-3, North Residual Heat Removal - Heat Exchanger Cubicle

Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a

minimum of three samples.

The inspection team evaluated Dominions FPP against applicable requirements which included

Unit 2 Renewed Facility Operating License Condition 2.C.(3), Unit 3 Renewed Facility Operating

License Conditions 2.H, NRC Safety Evaluation Reports (SERs), Title 10 of the Code of Federal

Regulations (10 CFR) 50.48, 10 CFR Part 50, Appendix R and Branch Technical Position (BTP)

Chemical Engineering Branch (CMEB) 9.5-1. The team also reviewed related documents that

included the Updated Final Safety Analysis Report (UFSAR), Fire Protection Program, Fire

Hazards Analyses (FHA), and post-fire Safe Shutdown Analyses Reports.

The team also evaluated two Unit 2 and two Unit 3 licensee mitigating strategies for addressing

large fires and explosions as required by Unit 2 Renewed Facility Operating License Condition

2.C.(13), Unit 3 Renewed Facility Operating License Condition 2.C.(10), and 10 CFR 50.54

(hh)(2). Inspection of these strategies fulfills the inspection procedure requirement to inspect a

minimum of one sample.

Specific documents reviewed by the team are listed in the Attachment to this report.

2

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection (IP 71111.05T)

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the FHA, safe shutdown analyses, and supporting drawings and

documentation to verify that post-fire safe shutdown capabilities were properly protected.

The team ensured that applicable separation requirements of Section III.G of 10 CFR

Part 50, Appendix R for Unit 2 and BTP CMEB 9.5-1 for Unit 3 as well as the licensees

design and licensing bases were maintained for the credited safe shutdown equipment

and their supporting power, control, and instrumentation cables. This review included an

assessment of the adequacy of the selected systems for reactivity control, reactor

coolant makeup, reactor heat removal, process monitoring, and associated support

system functions.

b. Findings

Introduction: The team identified a finding of very low safety significance (Green)

involving a non-cited violation of Millstone Unit 2 Renewed Facility Operating License

Condition 2.C.(3) to implement and maintain in effect all provisions of the approved fire

protection program as described in the FSAR. Specifically, Dominion failed to maintain

the #2 SG ADV free from fire damage, which may have affected the availability to

maintain hot shutdown conditions from the main control room for a fire in Fire Area R-14,

Lower 4.16kV Switchgear Room and Cable Vault.

Description: The inspectors reviewed the operator manual actions (OMAs) contained in

operating procedure AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area

R-14, and compared them against the list of NRC approved OMAs in lieu of meeting

III.G.2 fire protection requirements and determined that an unapproved OMA was being

implemented in AOP 2579M. The OMAs in lieu of meeting III.G.2 fire protection

requirements were approved in an NRC exemption dated December 18, 2012. The

missing OMA was an action to locally operate air-operated valve, 2-MS-190B, #2 SG

ADV. The OMA is necessary since a self-induced loss of offsite power (LOOP) will

occur and station blackout (SBO) condition may occur from fire related cable damage.

Either condition, LOOP or SBO, will cause a loss of instrument air in response to a

significant fire in fire area R-14.

The LOOP will occur when AOP 2579M is implemented because step 3.4 requires the

operators to trip the reactor (causing a loss of the normal station service transformer)

and step 3.9 requires the operators to direct CONVEX (transmission operator) to de-

energize the reserve station service transformer. A SBO may subsequently occur if the

B emergency diesel generator (EDG) is running and its output breaker does not close,

3

which could occur due to fire-related circuit damage. In either condition, LOOP or SBO,

the F instrument air compressor, will be de-energized and a loss of instrument air will

occur.

In 2011, Dominion submitted an exemption request to the NRC for several OMAs in lieu

of meeting III.G.2 fire protection requirements in several fire areas and initially postulated

a loss of instrument air for Fire Area R-14. Three OMAs were requested related to the

loss of instrument air for Fire Area R-14 in a June 30, 2011 exemption request letter to

the NRC. Subsequent to the June 30, 2011 exemption request letter, Dominion walked

down several fire areas and from a mechanical perspective concluded that a loss of

instrument air should no longer be postulated for several fire areas. R-14 was included

as a fire area for which a loss of instrument air was no longer considered credible. In a

request for additional information response letter dated February 29, 2012, Dominion

stated that the loss of instrument air was no longer postulated in fire area R-14 and

others, and requested the NRC delete the OMA for locally operating the #2 SG ADV. In

a correction letter dated October 29, 2012, Dominion again reiterated that for Fire Area

R-14, and others, a Loss of Instrument Air was not postulated, but Dominion clarified

that some of the OMAs that were related to a loss of instrument air should be retained

for postulated fire cable damage or loss of power. However, the OMA for locally

operating the #2 SG ADV was not retained since it was not susceptible to cable damage

or loss of power for a fire in area R-14. Dominion stated in its June 30, 2011 exemption

request letter to the NRC that after auxiliary feedwater (AFW) is established from the

control room, operation of the ADV (2-MS-1 90B) is the required method of removing

decay heat to maintain hot standby and transition to cold shutdown.

As described above, the inspectors determined that implementing AOP 2579M as

written will cause a loss of instrument air and the OMA to locally operate the #2 SG ADV

will be necessary after AFW is restored and decay heat removal is transitioned from the

main steam safety valves to the #2 SG ADV for steam generator pressure control. The

inspectors noted that Dominion is currently implementing an unapproved OMA in lieu of

meeting III.G.2 fire protection requirements. Dominion promptly entered this safe

shutdown issue into their corrective action program as CR 1043458. Immediate

corrective actions included implementing compensatory measures in the form of fire

watches for fire area R-14 that are being tracked by RAS determination 3037040.

Longer term corrective actions included submitting an exemption request to the NRC for

use of a local OMA to operate the #2 SG ADV in lieu of meeting fire protection

requirements for fire area R-14. The team considered Dominions immediate and longer

term corrective actions appropriate.

Analysis: Dominions failure to protect the #2 SG ADV, credited for post-fire safe

shutdown from fire damage in Fire Area R-14 caused by single spurious actuation, is

considered a performance deficiency. The performance deficiency was more than minor

because it affected the Mitigating Systems cornerstone objective to ensure the

availability, reliability, and capability of systems that respond to an external event to

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

OMA during post-fire safe shutdown may not be as reliable as normal systems operation

which could be utilized had the requirements of 10 CFR Part 50, Appendix R, Section

4

III.G.2 been met and, therefore, prevented fire damage to credited components and/or

cables, specifically the #2 SG ADV.

The inspectors used IMC 0609, Appendix F, Fire Protection Significance Determination

Process, Phase 1 and determined the reactor is able to reach and maintain a hot safe

shutdown condition because the ADVs are used for transition to cold shutdown,

therefore this finding was of very low safety significance (Green).

This finding does not have a cross cutting aspect because the performance deficiency

occurred greater than three years ago when the June 30, 2011 exemption request letter

to the NRC was supplemented by letter on February 29, 2012, and is not indicative of

current licensee performance.

Enforcement: Millstone Power Station, Unit 2, Renewed Facility Operating License

Condition 2.C.(3) requires Dominion in part to implement and maintain in effect all

provisions of the approved fire protection program as described in the FSAR. FSAR

Section 9.10.6, Safety Shutdown Design Bases, states in part Paragraph 50.48(b) of 10

CFR 50, which became effective on February 17, 1981, that all nuclear plants licensed

to operate prior to January 1, 1979, comply with specific portions of Section III of

Appendix R to 10 CFR 50.Section III.G requires that fire protection features be

provided for those systems, structures, and components important to safe shutdown.

These features must be capable of limiting fire damage so that one train of systems

necessary to achieve and maintain hot shutdown conditions from either the main control

room or the emergency control stations is free of fire damage.

Contrary to the above, since February 17, 1981 (the effective date of Appendix R and

revised 10 CFR 50.48), and ongoing as of the inspection exit date, Dominion failed to

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

shutdown strategy in Fire Area R-14 for Millstone Unit 2 relied upon an unapproved

OMA to mitigate post-fire safe shutdown equipment malfunctions caused by a single

spurious actuation, in lieu of protecting the equipment in accordance with 10 CFR Part

50 Appendix R,Section III.G.2. The specific OMA associated with Fire Area R-14

includes local manual control of the #2 SG ADV. Dominions immediate corrective

actions included implementing compensatory measure in the form of fire watches for fire

area R-14. Because this violation was of very low safety significance (Green), and was

entered into Dominions CAP (CR 1043458), this issue is being treated as an NCV

consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000336/2016007-01,

Unapproved OMA in Lieu of Meeting III.G.2 Fire Protection Requirements for Fire

Area R-14, Lower 4kV Switchgear Room and Cable Vault)

.02 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to evaluate

whether the material conditions of the fire area boundaries were adequate for the fire

hazards in the area. The team compared the fire area boundaries, including walls,

ceilings, floors, fire doors, fire dampers, penetration seals, and redundant equipment fire

5

barriers to design and licensing basis requirements, industry standards, and the

Millstone Power Station Unit 2 and Unit 3 FPPs, as approved by the NRC, to identify any

potential degradation or non-conformances.

The team reviewed selected engineering evaluations, installation and repair work orders,

and qualification records for a sample of penetration seals to determine whether the fill

material was properly installed and whether the as-left configuration satisfied design

requirements for the intended fire rating.

The team also reviewed recent inspection and functional test records for fire dampers,

and the inspection records for penetration seals and fire barriers, to verify whether the

inspection and testing was adequately conducted, the acceptance criteria were met, and

any potential performance degradation was identified.

b. Findings

No findings were identified.

.03 Active Fire Protection

a. Inspection Scope

The team evaluated manual and automatic fire suppression and detection systems in the

selected fire areas to determine whether they were installed, tested, maintained, and

operated in accordance with NRC requirements, National Fire Protection Association

(NFPA) codes of record, and the Millstone FPPs, as approved by the NRC. The team

also assessed whether the suppression systems capabilities were adequate to control

and/or extinguish fires associated with the hazards in the selected areas.

The team reviewed the as-built capability of the fire water supply system to verify the

design and licensing basis and NFPA code of record requirements were satisfied, and to

assess whether those capabilities were adequate for the hazards involved. The team

reviewed the fire water system hydraulic analyses to assess the adequacy of a single

fire water pump to supply the largest single hydraulic load on the fire water system plus

concurrent fire hose usage. The team evaluated the fire pump performance tests to

assess the adequacy of the test acceptance criteria for pump minimum discharge

pressure at the required flow rate, to verify the criteria was adequate to ensure that the

design basis and hydraulic analysis requirements were satisfied. The team also

evaluated the underground fire loop flow tests to verify the tests adequately

demonstrated that the flow distribution circuits were able to meet design basis

requirements. In addition, the team reviewed recent pump and loop flow test results to

verify the testing was adequately conducted, the acceptance criteria were met, and any

potential performance degradation was identified.

The team reviewed initial discharge testing, design specifications, vendor requirements,

modifications and engineering evaluations, and routine functional testing for the CO2 and

Halon suppression systems for the areas protection. The team walked down accessible

potions of the CO2 and Halon systems, including storage tanks and supply systems, to

6

independently assess the material condition, operational lineup, and availability of the

systems. The team also reviewed and walked down the associated firefighting

strategies and CO2 and Halon system operating procedures.

The team walked down accessible portions of the detection and water suppression

systems in the selected areas and major portions of the fire water supply system,

including motor and diesel driven fire pumps, interviewed system and program

engineers, and reviewed selected corrective action program documents (condition

reports) to independently assess the material condition of the systems and components.

In addition, the team reviewed recent test results for the fire detection and suppression

systems for the selected fire areas to verify the testing was adequately conducted, the

acceptance criteria were met, and any performance degradation was identified.

The team assessed the fire brigade capabilities by reviewing training, qualification, and

drill critique records. The team also reviewed Millstone's firefighting strategies (i.e. pre-

fire plans) and smoke removal plans for the selected fire areas to determine if

appropriate information was provided to fire brigade members and plant operators to

identify safe shutdown equipment and instrumentation, and to facilitate suppression of a

fire that could impact post-fire safe shutdown capability. The team independently

inspected the fire brigade equipment, including personnel protective gear (e.g. turnout

gear) and smoke removal equipment, to determine operational readiness for firefighting.

In addition, the team reviewed Millstone's fire brigade equipment inventory and

inspection procedure and recent inspection and inventory results to verify adequate

equipment was available, and any potential material deficiencies were identified.

b. Findings

No findings were identified.

.04 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The team walked down the selected fire areas and adjacent areas, and reviewed

selected documents to determine whether redundant safe shutdown trains could be

potentially damaged from fire suppression activities or from the rupture or inadvertent

operation of fire suppression systems. During the walkdowns, the team evaluated the

adequacy and condition of floor drains, equipment elevations, and spray protection.

Specifically, to determine whether a potential existed to damage redundant safe

shutdown trains, the team evaluated whether:

A fire in one of the selected fire areas would not release smoke, heat, or hot

gases that could cause unintended activation of suppression systems in adjacent

fire areas which could potentially damage all redundant safe shutdown trains; or

A fire suppression system rupture, inadvertent actuation, or actuation due to a

fire, in one of the selected fire areas, could not directly damage all redundant

trains (e.g. sprinkler caused flooding of other than the locally affected train); and

7

Adequate drainage was provided in areas protected by water suppression

systems.

b. Findings

No findings were identified.

.05 Post-Fire Safe Shutdown Capability - Normal and Alternative

a. Inspection Scope

The team reviewed the safe shutdown analysis, thermal-hydraulic analysis, operating

procedures, time critical operator action validation studies, piping and instrumentation

drawings (P&lDs), electrical drawings, the UFSAR, and other supporting documents for

the selected fire areas to verify whether Dominion had properly identified the systems

and components necessary to achieve and maintain post-fire safe shutdown conditions.

The team evaluated selected systems and components credited by the safe shutdown

analysis for reactor pressure control, reactivity control, reactor coolant makeup, decay

heat removal, process monitoring, and support system functions to assess the adequacy

of Dominion's alternative shutdown methodology. The team also assessed whether

alternative post-fire shutdown could be performed both with and without the availability

of off-site power. The team walked down selected plant configurations to verify whether

they were consistent with the assumptions and descriptions in the safe shutdown and

fire hazards analyses. In addition, the team evaluated whether the systems and

components credited for use during post-fire safe shutdown would remain free from fire

damage.

The team reviewed the training program for licensed and non-licensed operators to

verify whether it included alternative shutdown capability. The team also verified

whether personnel required for post-fire safe shutdown, using either the normal or

alternative shutdown methods, were trained and available on-site at all times, exclusive

of those assigned as fire brigade members.

The team reviewed the adequacy of procedures utilized for post-fire shutdown and

performed an independent walk through of procedure steps (i.e., a procedure tabletop)

to assess the adequacy of implementation and human factors within the procedures.

The team also evaluated the time required to perform specific actions to verify whether

operators could reasonably be expected to perform those actions within sufficient time to

maintain plant parameters within specified limits.

Specific procedures reviewed for normal and alternative post-fire shutdown included the

following:

Unit 2

AOP 2559, Fire;

AOP 2579A, Fire Procedure for Hot Standby Appendix R Fire Area R-1;

8

AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown Appendix R Fire

Area R-1;

AOP 2579EE, Fire Procedure for Cooldown and Cold Shutdown Appendix R Fire

Area R-7, R-9, R-14, and R-17;

AOP 2579G, Fire Procedure for Hot Standby Appendix R Fire Area R-7; and,

AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area R-14.

Unit 3

EOP 3509, Fire Emergency;

EOP 3509.1, Control Room, Cable Spreading Area or Instrument Rack Room

Fire;

EOP 3509.6, Auxiliary Building West MCC/Rod Control/ACU Area Fire;

EOP 3509.15, North (A) EDG Enclosure or East (A) F.O. Vault Fire; and,

EOP 3509.19, ESF Building North RHR Heat Exchanger Cubicle Fire.

The team reviewed selected operator manual actions to verify whether they had been

properly reviewed and approved and whether the actions could be implemented in

accordance with plant procedures in the time necessary to support the safe shutdown

method for each fire area. The team also reviewed the periodic testing of the alternative

shutdown transfer and isolation capability, and instrumentation and control functions, to

evaluate whether the tests were adequate to ensure the functionality of the alternative

shutdown capability.

b. Findings

No findings were identified.

.06 Circuit Analysis

a. Inspection Scope

The team verified that the licensee performed a post-fire safe shutdown analysis for the

selected fire areas and the analysis appropriately identified the structures, systems, and

components important to achieving and maintaining safe shutdown. Additionally, the

team verified that the licensees analysis ensured that necessary electrical circuits were

properly protected and that circuits that could adversely impact safe shutdown due to hot

shorts or shorts to ground were identified, evaluated, and dispositioned to ensure

spurious actuations would not prevent safe shutdown.

The teams review considered fire and cable attributes, cable routing, potential

undesirable consequences and common power supply/bus concerns. Specific items

included the credibility of the fire threat, cable insulation attributes, cable failure modes,

and actuations resulting in flow diversion or loss of coolant events.

The team also reviewed cable raceway drawings and/or cable routing databases for a

sample of components required for post-fire safe shutdown to verify that cables were

9

routed as described in the safe shutdown analysis. The team also reviewed equipment

important to safe shutdown, but not part of the success path, to verify that the licensee

had taken appropriate actions in accordance with the design and licensing basis and

NRC Regulatory Guide 1.189, Revision 2.

Cable failure modes were reviewed for the following components:

Unit 2

P18B, Charging Pump B;

2-CH-501, VCT Outlet Header to Charging Pumps Isolation Valve;

2-CH-519, Loop 1A Charging Isolation Valve; and,

PI-1023B-1, SG #2 Pressure Indicator.

Unit 3

3RCS*LCV459, VCT Letdown Isolation Valve;

3RCS*SV8095A, Head Vent Isolation Valve;

3CHS*MV8438A, Charging Pump A Header Isolation Valve;

3FWS*LI501A, SG #1 Level Indicator; and,

3RCS*PI405B, RCS Pressure Indicator.

The team reviewed a sample of circuit breaker coordination studies to ensure equipment

needed to conduct post-fire safe shutdown activities would not be impacted due to a lack

of coordination that could result in a common power supply or common bus concern.

The team verified that the transfer of control from the control room to the alternative

shutdown location(s) would not be affected by fire-induced circuit faults (e.g. by the

provision of separate fuses and power supplies for alternative shutdown control circuits).

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team reviewed safe shutdown procedures, the safe shutdown analysis, and

associated documents to verify an adequate method of communications would be

available to plant operators following a fire. During this review the team considered the

effects of ambient noise levels, clarity of reception, reliability, and coverage patterns.

The team also inspected the designated emergency storage lockers to verify the

availability of portable radios for the fire brigade and for plant operators. The team also

verified that communications equipment such as repeaters and transmitters would not be

affected by a fire.

10

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team observed the placement and coverage area of eight-hour emergency lights

throughout the selected fire areas to evaluate their adequacy for illuminating access and

egress pathways and any equipment requiring local operation or instrumentation

monitoring for post-fire safe shutdown. The team also verified that the battery power

supplies were rated for at least an eight-hour capacity. Preventive maintenance

procedures, the vendor manual, completed surveillance tests, and battery replacement

practices were also reviewed to verify that the emergency lighting was being maintained

consistent with the manufacturers recommendations and in a manner that would ensure

reliable operation.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The team reviewed Dominion's dedicated repair procedures, for components which

might be damaged by fire and were required to achieve post-fire cold shutdown (CSD).

The team evaluated selected CSD repairs to determine whether they could be achieved

within the time frames assumed in the design and licensing bases. In addition, the team

verified whether the necessary repair equipment, tools, and materials (e.g., pre-cut

cables with prepared attachment lugs) were available and accessible on site.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

The team verified compensatory measures were in place for out-of-service, degraded, or

inoperable fire protection and post-fire safe shutdown equipment, systems, or features

(e.g., detection and suppression systems and equipment, passive fire barriers, pumps,

valves, or electrical devices providing safe shutdown functions or capabilities). The

team evaluated whether the short term compensatory measures adequately

compensated for the degraded function or feature until appropriate corrective action

11

could be taken and that the licensee was effective in returning the equipment to service

in a reasonable period of time.

b. Findings

No findings were identified.

.11 Fire Protection Program Changes

a. Inspection Scope

The team reviewed recent changes to the approved fire protection program to verify that

the changes did not constitute an adverse effect on the ability to safely shutdown.

b. Findings

No findings were identified.

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the licensees procedures and programs for the control of ignition

sources and transient combustibles to assess their effectiveness in preventing fires and

in controlling combustible loading within limits established in the FHA. A sample of hot

work and transient combustible control permits were also reviewed. The team

performed plant walkdowns to verify that transient combustibles and ignition sources

were being implemented in accordance with the administrative controls.

b. Findings

No findings were identified.

.13 Large Fires and Explosions Mitigation Strategies

a. Inspection Scope

The team conducted a review of selected mitigation strategies intended to maintain or

restore core decay heat removal and spent fuel pool cooling capabilities under the

circumstances associated with the loss of large areas of the plant due to explosions

and/or fires. The team assessed whether Dominion continued to meet the requirements

of the Millstone Power Station Units 2 and 3 Operating Licenses and 10 CFR

50.54(hh)(2).

The team reviewed the following mitigation strategies:

Unit 2 and 3 Manual Operation of Turbine-Driven AFW Pump; and,

Unit 2 and 3 Manual Operation of SG ADVs.

12

The team's review included: a detailed assessment of the procedural guidance; a

tabletop discussion with licensed operators; and a walk down of four mitigation

strategies with operators to assess the feasibility of the strategies and operator

familiarity; maintenance and surveillance testing of selected strategy equipment; and an

inventory check of the B.5.b pump and equipment trailers to ensure the appropriateness

of equipment storage and availability.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES [OA]

4OA2 Identification and Resolution of Problems (IP 71152)

.01 Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team reviewed a sample of condition reports associated with fire protection program

and post-fire safe shutdown issues to determine whether Millstone was appropriately

identifying, characterizing, and correcting problems in these areas, and to assess

whether the planned or completed corrective actions were appropriate.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (IP 71153)

.1 (Closed) Licensee Event Report (LER) 05000336/2013-003-00 (Unit 2): Postulated DC

Ammeter Circuit Hot Shorts

On October 30, 2013, during a review of industry operating experience, Dominion

identified a postulated fire induced circuit failure involving unfused direct current (DC)

ammeter circuits for Millstone Power Station, Unit 2. The fire induced circuit failures

could cause a secondary fire that could adversely affect safe shutdown equipment and

cause a loss of alternate shutdown capability which is contrary to Unit 2 Renewed

Facility Operating License Condition 2.C.(3) and Appendix R requirements. The license

condition and regulation requires in part, post-fire safe shutdown cables remain free of

the effects of fire-induced cable faults during postulated fires. Specifically, the licensee

identified DC ammeter circuits for Unit 2, were not provided with overcurrent protection

to limit fault current in the 125 volt (V) DC systems. Postulated fires that result in a short

to ground concurrent with an opposite polarity short from the same battery could result in

excessive current flow in the ammeter wiring. The excessive current could heat-up the

conductor and could result in a secondary fire in another fire area. The secondary fire

could adversely affect safe shutdown equipment and cause a loss of alternate shutdown

13

capability. Dominion determined the cause of the condition was a latent design error

that was made during plant construction involving the failure to include protective fuses

in DC ammeter circuits.

The licensee submitted LER 05000336/2013-003-00 to report this event in accordance

with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly degraded

plant safety. The licensee entered this issue into their corrective action program as

condition report number CR530987 and implemented compensatory measures in the

affected fire areas pending final resolution of the issue.

The licensee completed an engineering evaluation (RAS000244) of the issue and

developed a design change (MP2-14-01007) to add fuses to the affected ammeter

circuits. Dominion completed the necessary modifications for all affected ammeter

circuits by May 7, 2014.

The significance and enforcement aspect of this issue are discussed in Section 4OA7.1

of this inspection report. LER 05000336/2013-003-00 is closed.

.2 (Closed) Licensee Event Report (LER) 05000336/2014-002-00 (Unit 2): DC Circuit Hot

Shorts

On March 12, 2014, during a review of industry operating experience, Dominion

identified postulated fire induced circuit failures involving unfused DC motor control

circuits for Millstone Power Station Unit 2. The postulated fire induced circuit failures

could cause a secondary fire that could adversely affect fire safe shutdown equipment

contrary to Unit 2 Renewed Facility Operating License Condition 2.C.(3) and Appendix

R requirements. The license condition and regulation requires in part, post-fire safe

shutdown cables remain free of the effects of fire induced cable faults during postulated

fires. Specifically, the licensee identified 125 V DC control and indication circuits for a

non-safety related main turbine emergency lube oil pump that was not provided with

overcurrent protection. Postulated fires in the turbine battery room, the cable vault, the

plant equipment operator meeting area and the control room could cause failure of the

unprotected 125 V DC circuits, which in turn could cause failure of the control circuits for

safe shutdown equipment. Dominion determined the cause of the condition was a

manufacturers design error that involved the failure to include protective fuses in DC

motor control circuits during plant construction.

The licensee submitted LER 05000336/2014-002-00 (Unit 2) to report this event in

accordance with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly

degraded plant safety. The licensee entered this issue into their corrective action

program as condition report number CR541980 and implemented compensatory

measures in the affected fire areas pending final resolution of the issue.

The licensee completed an engineering evaluation (RAS000252) of the issue and

developed a design change (MP2-14-01040) to add overcurrent protection (fuses) to

the affected motor control circuit. Dominion completed the necessary modifications for

the affected motor control circuit by May 5, 2014.

14

The significance and enforcement aspect of this issue are discussed in Section 4OA7.2

of this inspection report. LER 05000336/2014-002-00 (Unit 2) is closed.

.3 (Closed) Licensee Event Report (LER) 05000423/2014-002-00 (Unit 3): DC Circuit Hot

Shorts

On March 12, 2014, during a review of industry operating experience, Dominion

identified postulated fire induced circuit failures involving unfused DC motor control

circuits for Millstone Power Station Unit 3. The postulated fire induced circuit

failures could cause a secondary fire that could adversely affect fire safe shutdown

equipment contrary to Unit 3 Renewed Facility Operating License Condition 2.H

and the branch technical condition (BTP) 9.5-1 requirements. The license

condition and the BTP requires in part, post-fire safe shutdown cables remain free

of the effects of fire-induced cable faults during postulated fires. Specifically, the

licensee identified 125 V DC control circuits for non-safety related main turbine

emergency lube oil and a main generator emergency seal oil pumps that were not

provided with overcurrent protection. Postulated fires in the turbine battery

switchgear area, the cable spreading room, the instrument rack room, and the

control room could cause failure of the unprotected 125 V DC control circuits,

which in turn could cause failure of control circuits for safe shutdown equipment.

Dominion determined the cause of the condition was a manufacturers design

error that involved the failure to include protective fuses in DC motor control

circuits during plant construction.

The licensee submitted LER 05000423/2014-002-00 (Unit 3) to report this event in

accordance with 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition that significantly

degraded plant safety. The licensee entered this issue into their corrective action

program as condition report number CR541983 and implemented compensatory

measures in the affected fire areas pending final resolution of the issue.

The licensee completed an engineering evaluation (RAS000253) of the issue and

developed design change modifications (MP3-14-01071 and MP3-14-01092) to add

overcurrent protection (fuses) to the affected motor control circuits. Dominion completed

the necessary modifications for all affected motor control circuits by November 2, 2014.

The significance and enforcement aspect of this issue are discussed in Section 4OA7.3

of this inspection report. LER 05000289/2014-001-00 (Unit 3) is closed.

15

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented the inspection results to Mr. John Daugherty, Site Vice President,

Millstone Power Station, and other members of the site staff at an exit meeting on

August 11, 2016. No proprietary information was included in this inspection report.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the

licensee and are violations of NRC requirements. These issues satisfy the criteria of the

NRC Enforcement Policy of being dispositioned as Non-Cited Violations.

.1 LER 05000336/2013-003-00 (Unit 2) describes an unanalyzed condition in which

Dominion identified their DC ammeter circuits were unfused. Specifically, Dominion did

not provide overcurrent protection for wiring associated with DC ammeter indication in

the control room to prevent wires from overheating due to fire induced faults and

excessive currents flowing through the cable. With enough current flowing through the

cable, the potential existed that the overloaded ammeter wiring could damage system

wiring or adjacent safety-related circuits in the cable raceways needed for post-fire safe

shutdown. This condition could result in a loss of the associated safe shutdown

components or a secondary fire in another fire area. The failure to protect safe

shutdown cables from the effects of postulated fires was a performance deficiency.

This performance deficiency was a violation of Millstone Power Station, Unit 2, Renewed

Facility Operating License Condition 2.C.(3), which requires in part, post-fire safe

shutdown cables remain free of the effects of fire-induced cable faults during postulated

fires. Contrary to the above, Dominion identified they failed to meet this requirement and

the condition existed since initial construction of Unit 2. The issue was more than minor

because it was associated with the protection against external events (fire) attribute of

the mitigating systems cornerstone and it adversely affected the cornerstone objective of

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

events to prevent undesirable consequences. The team determined that the finding was

of very low safety significance (Green), based IMC 0609, Appendix F, Fire Protection

Significance Determination Process (SDP), Phase 2 screening criteria.

The finding screened to Green based upon, task number 2.3.5, because the

affected cables were routed in alternate shutdown fire areas that are continually

manned or protected by detection and automatic suppression systems.

Remaining fire areas are protected by detection systems, automatic suppression

systems or rely on manual fire-fighting activities. Additionally, the cable

construction is Institute of Electrical and Electronics Engineers (IEEE) 383

(thermoset) which decreases the likelihood of inter-cable and intra-cable

interactions. Based on a team walkdown, the team determined that the ammeter

cable routing was not routed near a credible fire ignition source in the affected

fire areas. Because this finding is of very low safety significance and had been

entered into Dominions corrective action program (CR530987), this violation is

16

being treated as a Green, licensee-identified NCV consistent with the NRCs

Enforcement Policy.

.2 LER 05000336/2014-002-00 (Unit 2) describes an unanalyzed condition in which

Dominion identified DC motor control circuits were unfused. Specifically,

Dominion did not provide overcurrent protection for wiring associated with 125 V

DC control circuits for a non-safety related main turbine emergency lube oil pump

to prevent wires from overheating due to fire induced faults and excessive

currents flowing through the cable. With enough current flowing through the

cable, the potential existed that the overloaded motor control wiring could damage

adjacent control circuit wiring for components which are needed to achieve and

maintain post-fire safe shutdown for a fire in several fire areas (turbine battery

room, cable vault, plant equipment operator meeting area, control room). This

condition could result in a loss of the associated safe shutdown components or a

secondary fire in another fire area. The failure to protect safe shutdown cables

from the effect of postulated fires was a performance deficiency.

This performance deficiency was a violation of Millstone Power Station, Unit 2,

Renewed Facility Operating License Condition 2.C.(3), which requires, in part, post-fire

safe shutdown cables remain free of the effects of fire induced cable faults during

postulated fires. Contrary to the above, Dominion identified they failed to meet this

requirement and the condition existed since initial construction. The issue was more

than minor because it was associated with the protection against external events (fire)

attribute of the mitigating systems cornerstone and it adversely affected the

cornerstone objective of ensuring the availability, reliability, and capability of systems

that respond to initiating events to prevent undesirable consequences. The team

determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 2

screening criteria.

The finding screened to Green based upon, task number 2.3.5, because the affected

cables were routed in alternate shutdown fire areas that are continually manned or

protected by detection and automatic suppression systems. Remaining fire areas are

protected by detection systems, automatic suppression systems or rely on manual fire-

fighting activities. Additionally, the cable construction is IEEE 383 (thermoset) which

decreases the likelihood of inter-cable and intra-cable interactions. Based on a team

walkdown, the team determined that the main turbine emergency lube oil pump cable

routing was not routed near a credible fire ignition source in the affected fire areas.

Because this finding is of very low safety significance and had been entered into

Dominions corrective action program (CR541980), this violation is being treated as a

Green, licensee-identified NCV consistent with the NRCs Enforcement Policy.

.3 LER 05000423/2014-002-00 (Unit 3) describes an unanalyzed condition in which

Dominion identified DC motor control circuits were unfused. Specifically, Dominion did

not provide overcurrent protection for wiring associated with 125 V DC control circuits for

non-safety related main turbine emergency lube oil and main generator emergency seal

oil pumps to prevent wires from overheating due to fire induced faults and excessive

currents flowing through the cable. With enough current flowing through the cable, the

17

potential existed that the overloaded motor control wiring could damage adjacent control

circuit wiring for components which are needed to achieve and maintain post-fire safe

shutdown for a fire in several fire areas (turbine battery switchgear area, cable spreading

room, instrument rack room, control room). This condition could result in a loss of the

associated safe shutdown components or a secondary fire in another fire area. The

failure to protect safe shutdown cables from the effect of postulated fires was a

performance deficiency.

This performance deficiency was a violation of Millstone Power Station, Unit 3,

Renewed Facility Operating License Condition 2.H, which requires, in part, post-fire

safe shutdown cables remain free of the effects of fire induced cable faults during

postulated fires. Contrary to the above, Dominion identified they failed to meet this

requirement and the condition existed since initial construction. The issue was more

than minor because it was associated with the protection against external events (fire)

attribute of the mitigating systems cornerstone and it adversely affected the

cornerstone objective of ensuring the availability, reliability, and capability of systems

that respond to initiating events to prevent undesirable consequences. The team

determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 2

screening criteria.

The finding screened to Green based upon, task number 2.3.5, because the affected

cables were routed in alternate shutdown fire areas that are continually manned or

protected by detection and automatic suppression systems. Remaining fire areas are

protected by detection systems, automatic suppression systems or rely on manual fire-

fighting activities. Additionally, the cable construction is IEEE 383 (thermoset) which

decreases the likelihood of inter-cable and intra-cable interactions. Based on a team

walkdown, the team determined that the main turbine emergency lube oil and main

generator emergency seal oil pump cable routing was not routed near a credible fire

ignition source in the affected fire areas. Because this finding is of very low safety

significance and had been entered into Dominions corrective action program

(CR541983), this violation is being treated as a Green, licensee-identified NCV

consistent with the NRCs Enforcement Policy.

ATTACHMENT: SUPPLEMENTAL INFORMATION

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Daugherty, Site Vice President

D. Blakeney, Assistant Plant Manager

P. Anastas, Safe Shutdown Engineer

J. Armstrong, Fire Protection Engineer

T. Bryant, Maintenance Supervisor

D. DelBiondo, Site Fire Marshal

J. Farley, Electrical System Engineer

B. Ferguson, Unit 2 Senior Reactor Operator

R. Garver, Engineering Director

L. Kelly, Engineering Lead

W. McCollum, Unit 2 Supervisor

D. Mello, Senior Fire Instructor

K. Perkins, Electrical Engineering Supervisor

P. Russell, Unit 3 Senior Reactor Operator

A. Vargas-Mendez, Licensing Engineer

NRC Personnel

C. Cahill, Acting Branch Chief, Engineering Brach 3, Division of Reactor Safety

C. Highley, Resident Inspector, Millstone Power Station

L. Mckown, Resident Inspector, Millstone Power Station

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000336/2016007-01 NCV Unapproved OMA in Lieu of Meeting III.G.2 Fire

Protection Requirements for Fire Area R-14, Lower

4kV Switchgear Room and Cable Vault

Closed

05000336/2013-003-00 LER Postulated DC Ammeter Circuit Hot Shorts (Unit 2),

(Section 4OA3.1)

05000336/2014-002-00 LER DC Circuit Hot Shorts (Unit 2), (Section 4OA3.2)

05000423/2014-002-00 LER DC Circuit Hot Shorts (Unit 3), (Section 4OA3.3)

Discussed

None

Attachment

A-2

LIST OF DOCUMENTS REVIEWED

Fire Protection Licensing Documents

25203-SP-M2-SU-1046, Unit 2 Appendix R Compliance Report, Revision 1

25212-BTP-9.5-1, Unit 3 Branch Technical Position 9.5-1 Compliance Report, Revision 4

25212-MP3-SFR, Millstone Power Station, Unit 3, Safety Function Requirement Manual,

Revision 6

LBDCR 07-MP2-010, Millstone U2 Technical Requirements, dated 10/5/09

Letter from Dominion to NRC, Dominion Nuclear Connecticut, Inc. Millstone Power Station Unit

2 Response to Request for Additional Information Request for Exemption from

10 CFR 50, Appendix R, Section III.G., Fire Protection of Safe Shutdown Capability, with

Attachment, dated 2/29/12

Letter from Dominion to NRC, Dominion Nuclear Connecticut, Inc. Millstone Power Station Unit

2 Request for a Revision of an Exemption from 10 CFR 50, Appendix R, Section III.G.,

Fire Protection of Safe Shutdown Capability, with Attachment, dated 10/29/12

Letter from Dominion to NRC, Dominion Nuclear Connecticut. Inc. Millstone Power Station Unit

2 Request for Exemption from 10 CFR 50. Appendix R.Section III.G., Fire Protection of

Safe Shutdown Capability, with Attachments, dated 6/30/11

Letter from NRC to Dominion, Millstone Power Station, Unit 2 -Correction to Previously Issued

Exemption from the Requirements of 10 CFR Part 50, Appendix R, Section III.G.2.

(TAC No. ME6693) with Enclosure, dated 12/18/12

Millstone Unit 2 Technical Requirement Manual, Section 3/4.7.9, Fire Protection System, 2/2/10

Millstone Unit 3 Fire Protection Evaluation Report, Revision 17.4

MP-SPEC-ENG-BTP-9.5-1, Millstone Unit 3 Branch Technical Position (BTP) 9.5-1 Compliance

Report, Revision 4

U2-24-FPP-FHA, Unit 2 Fire Hazards Analysis, Revision 12

Updated Final Safety Analysis Report, Section 9.5.1, Fire Protection System, Revision 28.2

Design Basis Documents

Fire Code Compliance Review of Safety Related Areas - Fire Protection Systems -Fire

Alarm/Detection Systems and the plants Fire Pumps, dated 9/86

TR-151, Fire and Hose Stream Test of #TCO-003 High Density Silicone Elastomer used in Elec.

Opening, Revision 0

TR-189, Fire and Hose Stream Test of 6, 8, and 10 thick specimens of TCO-050, Revision 1

Design Changes

DCN DM3-00-1286-97, Revision to the BTP 9.5-1 Compliance Report to Include RHS MOVs,

dated 2/5/98

DCR M2-97034, Thermo-Lag Modifications for MP2, Revision 0

M2-98095, TDAFWP Redundant Power Supply, Revision 0

MP2-14-01007, DC Ammeter Hot Short Modification, Revision 1

MP2-14-01040, Appendix R Hot Short Circuit Modification for Emergency Bearing Oil Pump

P63, Revision 1

MP3-13-01183, RHR Cross-Train Suction Motor-Operated Valve Breaker Normal Alignment

Change, dated 10/29/13

MP3-14-01071, Appendix R Hot Short Circuit Modification for Emergency Bearing Oil Pump

3TML-P1, Revision 0

A-3

MP3-14-01092, Appendix R Hot Short Circuit Modification for Emergency Seal Oil Pump

3GMO-P2, Revision 0

MP3-14-01187, MP3 RPCCW Heat Exchanger 3CCP*E1B Replacement, dated 7/6/15

MPG-13-01131, MDM Flex Strategy Support Modification, dated 9/16/14

Calculations/Engineering Evaluation Reports

25203-ER-98-0151, Fire Test Performed for Florida Power & Light Company for Electrical

Raceways Protected with Thermo-Lag Fire Barrier Systems, Revision, 0

25203-ER-99-0092, Millstone Unit 2 Appendix R Cooldown Analysis Assumptions and Results,

Revision 3

97-ENG-01912E2, 4.16kV Switchgear Relay Settings, Revision 0

98-ENG-02411-C2, MP2 Evaluation Flooding Outside Containment, Revision 1

98-ENG-02621-M2, Determination of the Instrument Air Requirement for Certain Safety Related

Valves, Revision 3

99-026, Calculation Change Notice No. 1, Millstone Site Fire Loop Flow Model Bench Markings,

Revision 1

99-026, Calculation Change Notice No. 3, Millstone Site Fire Loop Flow Model Bench Markings,

Revision 1

99-026, Calculation Change Notice No. 4, Millstone Site Fire Loop Flow Model Bench Markings,

Revision 1

99-026, Millstone Site Fire Loop Flow Model Bench Markings, Revision 1

DNC 2512-ER-04-0030, Validation and Verification of EOP 3509.1 Using Simulator, Field and

Table Top Validation, dated 5/28/04

EMP-186, Millstone Nuclear Power Plant U2 Combustible Loading Re-Analysis Calculation,

Revision 2

ER-97-0295, Sound Powered Phone and Trunked Radio Systems - Cable Selection, Routing

and Figures, dated 1/16/98

ER-97-0302, MP3 BTP 9.5-1 Compliance Report Section 6.2 Revision - Communication

Systems, dated 2/10/98

M2-EV-98-0113, Technical Evaluation for 120Vac Vital Bus Appendix R Coordination Study,

Revision 1

M3-EV-98-0011, Technical Evaluation for The Use of an 800 MHz Carrier Frequency Trunked

Radio System at Millstone Unit 3 for General Purposes and Appendix R Requirements,

Revision 1

MP-CALC-ENG-S-0426535, MP3 BTP 9.5-1 RELAP5 Fire Shutdown Analysis 3650 and 3725

MWt, Revision 2

P1164-MP2-COORD, Unit 2 Breaker/Fuse Coordination for the Appendix R Circuits, Revision 0

RAS000244, Postulated DC Ammeter Circuit Hot Shorts, Revision 0

RAS000252, DC Circuit Hot Shorts, Revision 0

RAS000253, DC Circuit Hot Shorts, Revision 0

S-02824S2, Millstone Unit 2, R-2 Fire, Appendix R Analysis, Revision 2

SP-M3-EE-269, Unit 3 Electrical Design Criteria, Revision 3

W2-517-744-RE, MP2 Appendix R Cooldown, Revision 3

A-4

Procedures

3783EA, Component Cooling Pump Motor Replacement for Fire Protection, Revision 005-02

C MP 790, Emergency Light Inspection and Testing, Revision 004-02

C OP 200.18, Time Critical Action Validation and Verification, Revision 2

C OP 200.18, Time Critical Action Validation and Verification, Revision 3

C SP 600.24, Fire Brigade Equipment Inspection, Revision 000-04

C SP 600.28, Fire Brigade vehicle Equipment Inspection Data Sheet (R3), Revision 000-05

C SP600.24, Unit 2 Fire Brigade Equipment Inspection, Revision 001-00

CM-AA-ETE-101, Engineering Technical Evaluation (ETE), Revision 6

CM-AA-FPA-10, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 2

CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, Revision 11

CM-AA-FPA-101, Control of Combustible and Flammable Materials, Revision 8

CM-AA-FPA-102, Fire Protection and Fire Safe Shutdown review and preparation Process and

Preparation Process and Design Change Process, Revision 6

COM-04-C, Plant Communication Systems, Revision 0

ER-AA-102, Preventive Maintenance Program, Revision 9

ER-AA-MRL-100, Implementing Maintenance Rule, Revision 10

FB-00012, Self-Contained Breathing Apparatus SCOTT 4.5, Revision 7

MP 2720U1, Cold Shutdown Fire Damage Repair Procedure for Fire Area R-1 (Appendix R),

Revision 004-02

SA-AA-115, Conduct of Fire Drills, Revision 2

SFP 10, Fire Protection Inspections, Revision 005-03

SFP 21, Appendix R Fire Cage Inventory, Revision 002-06

SP 2402CR, Steam Generator Pressure Rack Instrument Calibration, Revision 0

SP 2601P, CVCS Valve Operability Tests From C-10 and C-02, Revision 0

SP 2610B, Turbine Driven Auxiliary Feed Pump Operational Tests from C-10, Revision 1

SP 2610E, Atmospheric Dump Valve Testing from C-10, C-70A and C-70B, Revision 1

SP 2610M, Power Operated Relief Valve Hot Functional Test, Revision 0

SP 3442J01, RCS Wide Range Pressure Rack Calibration, Revision 7

SP 3444A02, Steam Generator Water Level Wide Range Calibration, Revision 7

SP 3641D.3, Fire Detection and Control System Operability Check, Revision 015

SP 3641D.5, Fire Damper Operability Verification, Revision 012

SP 3641F.1, Functional Check of the East and West Switchgear Breathing Air Systems,

Revision 2

SP 3673.2, Fire Transfer Switch Panel Operational Testing, Revision 002-06

SP 3673.4, Auxiliary Shutdown Panel Operability Test, Revision 010

TR-MP-TPG-2300, Fire Protection Programs Training Program Guide (TPG), Revision 2

WC5, Fuse Control, Revision 2

Operations Procedures

AOP 2559, Millstone Unit 2 Fire, Revision 10

AOP 2559, Procedure Basis Document, Fire, Revision 009-00

AOP 2579A, Fire Procedure for Hot Standby Appendix R Fire Area R-1, Revision 011-00

AOP 2579A, Procedure Basis Document, Fire Procedure for Hot Standby Appendix R Fire Area

R-1, Revision 011-00

AOP 2579A, Unit 2 Fire Procedure for Hot Standby Appendix R Fire Area R-1, Revision 11

AOP 2579AA, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-1,

Revision 004-08

A-5

AOP 2579EE, Fire Procedure for Cooldown and Cold Shutdown, Appendix R Fire Area R-7, R-

9, R-14, and R-17, Revision 005-09

AOP 2579G, Fire Procedure for Hot Standby Appendix R Fire Area R-7, Revision 006-10

AOP 2579M, Fire Procedure for Hot Standby Appendix R Fire Area R-14, Revision 006-06

AOP 3577, Loss of Normal and Offsite Power to a 4.16 kV Emergency Bus, Revision 003

AOP 3577, Procedure Basis Document, Loss of Normal and Offsite Power to a 4.16 kV

Emergency Bus, Revision 002-00

AOP 3581, Immediate Operator Actions, Revision 003

COP 200.2AIR, Airborne Threat, Revision 002-03

EDMG 2.01, MP2 B.5.b Event Control Room Response, Revision 004

EDMG 2.02, MP2 B.5.b Event TSC Response, Revision 010

EOP 2540, Functional Recovery, Revision 025-00

EOP 2540D, Functional Recovery of Heat Removal, Revision 022-00

EOP 2541, Appendix 36, ADV Local Operation, Revision 000-02

EOP 2541, Appendix 7, TDAFW Pump Abnormal Startup, Revision 000-01

EOP 2541, Standard Appendices, Revision 006

EOP 35 GA-31, Locally Restoring AFW Flow, Revision 004

EOP 3509, Fire Emergency, Revision 027-00

EOP 3509, Procedure Basis Document, Fire Emergency, Revision 026-00

EOP 3509.1, Control Room, Cable Spreading Area or Instrument Rack Room Fire,

Revision 019-00

EOP 3509.1, Procedure Basis Document, Control Room, Cable Spreading Area or Instrument

Rack Room Fire, Revision 019-00

EOP 3509.15, North (A) EDG Enclosure or East (A) F.O. Vault Fire, Revision 001

EOP 3509.15, Procedure Basis Document, North (A) EDG Enclosure or East (A) F.O. Vault

Fire, Revision 001

EOP 3509.19, ESF Building North RHR Heat Exchanger Cubicle Fire, Revision 000-01

EOP 3509.19, Procedure Basis Document, ESF Building North RHR Heat Exchanger Cubicle

Fire, Revision 000-01

EOP 3509.6, Auxiliary Building West MCC/Rod Control/ACU Area Fire, Revision 002-01

EOP 3509.6, Procedure Basis Document, Auxiliary Building West MCC/Rod Control/ACU Area

Fire, Revision 002-01

MP-PROC-OPS-OP-2322, Auxiliary Feedwater System, Revision 029

OP 2343, 4160 Volt Electrical System, Revision 022

OP 3341B, Fire Protection Halon System, Revision 005-06

OP 3353.MB4A, Main Board 4A Annunciator Response, Revision 003

OP 3353.MB4B, Main Board 4B Annunciator Response, Revision 005

OP-3322, Auxiliary Feedwater System, Revision 025

SACRG-3, Severe Accident CR Guideline for MP3 B.5.b Initial Event Response, Revision 004

SAG-1, Injection into the Steam Generators, Revision 011

SAG-2, Depressurize the RCS, Revision 003

SAG-9, MP3 B.5.b Event TSC Response (EDMG), Revision 016

SP 2669A, Unit 2 Auxiliary Building Rounds, Revision 063

A-6

Completed Tests/Surveillances

722481, B.5.b pump annual preventive maintenance, Completed 7/26/16

C OP 200.18, Time Critical Action Validation and Verification, Completed 8/4/16

C SP 600.13, P-82 Electric Fire Pump Annual Operability Demonstration, Completed 5/19/16 &

9/17/16

C SP 600.14, P-82 Electric Fire Pump Annual Operability Demonstration, Completed 12/4/14 &

12/4/15

C SP 600.16 Fire Protection System Underground Main Flush & Flow Test, Completed 10/13/10

& 10/9/13

C SP 600.18, Unit 2 Fire Hose Station Inspection, Completed 6/22/16

C SP 600.22, Unit 2 Fire Hose Station Flow Test, Completed 2/13/15

C SP 600.24, Unit 2 Fire Brigade Equipment Inspection, Completed 4/24/16

C SP 600.24, Unit 2 Fire Brigade Equipment Inspection, Completed 5/25/16

C SP 600.25, Unit 2 Fire Door Inspection, Completed 6/20/16

C SP 600.25, Unit 3 Fire Door Inspection, Completed 9/3/15

C SP 600.28, Fire Brigade Vehicle Equipment Inspection Data Sheet (R1), Completed 5/21/16

C SP 600.6, Electric Fire Pump M7-8 Monthly Operability Demonstration, Completed 5/10/16 &

6/3/16

C SP 600.7, Electric Fire Pump M7-8 Annual Operability Demonstration, Completed 12/22/14 &

12/19/15

C SP 600.8, Diesel Fire Pump M7-7 Monthly Operability Demonstration, Completed 5/13/16 &

6/8/16

C SP 600.9, Diesel Fire Pump M7-7 Annual Operability Demonstration, Completed 8/6/15 &

6/8/16

C SP 788A, Fire Pump Diesel Engine Battery Quarterly Surveillance, Completed 6/16/16

C SP 788B, Fire Pump Diesel Engine Battery 18-Month Surveillance, Completed 6/10/16

C SP 788C, Fire Pump Diesel Engine Battery Weekly Surveillance, Completed 6/16/16

CSP 600.24, Fire Brigade Equipment Inspection, Completed 6/3/16

SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 1, Completed 2/10/06

SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 4, Completed 2/9/11

SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 4, Completed 10/9/14

SFP 17, Unit 3 Fire Penetration Seal and Barrier Inspection- Group 9, Completed 12/27/13

SFP 21, Unit 2 Appendix R Fire Cage Inventory, Completed 11/25/15

SFP 9, Unit 3 - Fire Extinguisher Inspection Data Sheet - Train B, Completed 6/29/16

SFP 9, Unit 3 - Fire Extinguisher Inspection Data Sheet - Train A, Completed 7/11/16

SFP Procedure 21, Unit 3 Safe Shutdown Fire Cage Inventory, Completed on 11/26/2015

SP 2402CR, Steam Generator Pressure Rack Instrument Calibration, Revision 0, Completed

8/12/14 and 3/16/16

SP 2601P, Unit 2 CVCS Valve Operability Tests from C-10 and C-02, Revision 0, Completed

10/30/15

SP 2610B, Turbine Driven Auxiliary Feed Pump Operational Tests from C-10, Completed 3/2/16

SP 2610E, Atmospheric Dump Valve Testing From C-10, C-70A and C-70B, Completed

10/21/15

SP 2610M, Power Operated Relief Valve Hot Functional Test, Completed 11/1/15

SP 2657, EOP Equipment Inventory, Completed 9/7/15

SP 3442J01, RCS Wide Range Pressure Rack Calibration, Completed 9/16/14 and 2/11/16

SP 3444A02, Steam Generator Water Level Wide Range Calibration, Completed 7/10/13 and

3/11/15

A-7

SP 3451Q01, Unit 3 Instrument Rack Room and Fire Pump House - Halon Fire System Test,

Completed 2/26/16

SP 3641B.2, IRR Halon System Flow Test, Completed 5/17/15

SP 3641B.2, IRR Halon System Flow Test, Completed 5/8/14

SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 1/8/15

SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 1/19/13

SP 3641D.3, Fire Protection Zone Panel 3B Detector Operability Checks, Completed 12/21/14

SP 3641D.3, Fire Protection Zone Panel 5C EDG A Area Detector Operability Checks,

Completed 2/25/16

SP 3641D.5, Fire Damper Operability Verification, Completed 1/25/06

SP 3641D.5, Fire Damper Operability Verification, Completed 5/8/11

SP 3641D.5, Fire Damper Operability Verification, Completed 9/5/99

SP 3641D.6, Fire Rated Assemblies Inspection, Completed 8/2/15

SP 3641F.1, Functional Check of the East and West Switchgear Breathing Air System,

Completed 6/21/15

SP 3672.2-10, Fire Transfer Switch Panel Operational Testing-3RCS*PCV455A, Completed

11/9/14

SP 3672.2-2, Fire Transfer Switch Panel Operational Testing-3HVP*FN1A and FN1C,

Completed 3/20/12

SP 3672.2-7, Fire Transfer Switch Panel Operational Testing-3SWP*MOV54A and MOV54C,

Completed 8/1/13

SP 3672.2-8, Fire Transfer Switch Panel Operational Testing-3SWP*MOV71A Completed

11/23/15

SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVP*FN1A and

3HVP*FN1C, Completed 3/20/12

SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*FN14A, Completed

10/25/14

SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*MOD50A,

Completed 12/20/12

SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVR*ACU1A, Completed

12/22/15

SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3HVY*FN2A, Completed

12/18/12

SP 3673.2, Unit 3 Fire Transfer Switch Panel Operational Testing for 3SWP*MOV71A,

Completed 11/23/15

SP 3673.4, Auxiliary Shutdown Panel Operability Test for Charging Injection Path, Completed

5/1/16

SP 3673.4, Auxiliary Shutdown Panel Operability Test for Charging Isolation Path, Completed

5/1/16

SP 3673.4, Auxiliary Shutdown Panel Operability Test for Train A CVCS Components,

Completed 1/14/15

SP 3673.4-001, Auxiliary Shutdown Panel Operability Test, Completed 5/8/16

SP 3673.4-004, Auxiliary Shutdown Panel Operability Test Train A Auxiliary Feedwater

Components, Completed 2/8/15

SP 3673.4-007, Auxiliary Shutdown Panel Operability Test Train B Auxiliary Feedwater

Components, Completed 2/1/15

SP 3673.4-009, Auxiliary Shutdown Panel Operability Test Train B CVCS Components,

Completed 5/22/16

A-8

SP 3673.4-011, Auxiliary Shutdown Panel Operability Test Train A PORV and Block Valves,

Completed 1/9/14

SP 3673.4-014, Auxiliary Shutdown Panel Operability Test Non-Train Related Components,

Completed 5/1/16

SP2618C, Smoke and Heat Detector Testing, Auxiliary Building, Completed 3/24/16

SP2618C, Smoke Detector Testing, Switchgear Detector Testing, Facility 1, Completed 5/30/16

SP2618C, Smoke Detector Testing, Turbine Building, Completed 1/19/16

SP2618C, Turbine Bldg. 256 Cable Vault and Vertical Shaft Smoke Detector Test, Completed

3/4/16

SP2618D, A DG Deluge Systems Design Function Test, Completed 1/12/16

SP2618D, Fire Protection System sprinkler and Deluge Design Function test, Completed

5/20/15

SP2618H, Fire Protection System Deluge Nozzle Flow Test, Completed 7/16/14

SP2618L, Fire Protection Coating Inspection, Completed 8/4/15

SP2618L, TSI Fire Wrap Inspection, Completed 8/7/15

SP2657, Inventory Remote Shutdown Station Storage, Completed 5/13/16

Operating Experience Evaluations

Information Notice 2014-10, Potential Circuit Failure-Induced Secondary Fires or Equipment

Damage, dated 9/16/14

Quality Assurance Audits and Self Assessments

Audit 15-04, Fire Protection Program, dated 7/15/15

System Health Reports

3341 A, B, C, F - Fire Protections Water, Halon, CO2, Emerg. Breathing Air, dated

10/1/14- 12/31/14

3341 A, B, C, F - Fire Protections Water, Halon, CO2, Emerg. Breathing Air, dated

10/1/15- 12/31/15

3341D - Fire Detection, dated 10/1/14- 12/31/14

3341D - Fire Detection, dated 10/1/15- 12/31/15

ELU System Health Report, 1St Quarter 2016

ELU System Health Report, 4th Quarter 2015

Program/Comp Health Report FP- Fire Protection - Including Appendix R, 4th Quarter 2015

Program/Comp Health Report FP- Fire Protection - Including Appendix R, 1st Quarter 2016

System Health Report 2352, 3720B - Safe Shutdown Lighting, 1st Quarter 2016

System Health Report 2352, 3720B - Safe Shutdown Lighting, 4th Quarter 2015

U 2 Fire Protection & Deluge, CO2 Alterex, Halon Supression, 4th Quarter 2014

U 2 Fire Protection & Deluge, CO2 Alterex, Halon Supression, 4th Quarter 2015

Unit 2 AC and DC Systems, 4th qtr. 2015 and 1st Quarter 2016

Unit 3 AC and DC Systems, 4th qtr. 2015 and 1st Quarter 2016

A-9

Drawings and Wiring Diagrams

12179-30276, U3 Generator Seal Oil System Emergency Seal Oil pump 3GMO-P2 Control,

Revision 5

12179-FIG-77B, Fire Hazard Analysis Plan Elevation 24 Feet 6 inch, Revision 6

12179-FIG-77C, Fire Hazard Analysis Plant Elevation 38 Feet 6 inch, Revision 11

25203-24070, Sheet 10, RCP Oil Collection System Details for RCP Motor in Cubicle A,

Revision 2

25203-24070, Sheet 11, RCP Oil Collection System Details for RCP Motor in Cubicle A,

dated 5/16/95

25203-24070, Sheet 12, RCP Oil Collection System Details for RCP Motor in Cubicle A,

dated 4/19/95

25203-24070, Sheet 13, RCP Oil Collection System Details for RCP Motor in Cubicle A,

dated 4/20/95

25203-28500, Sht.356, Unit 2 PT-1023B Steam Generator Pressure Loop Diagram, Revision 10

25203-30001, Unit 2 Main Single Line Diagram, Revision 40

25203-30005, Unit 2 Single Line Meter and Relay Diagram 4.16kV Emergency Buses 24C and

24D, Revision 21

25203-30009, Unit 2 Single Line Meter and Relay Diagram 4.16kV Emergency Buses 25E and

24G, Revision 13

25203-30022, Sht. 3, Unit 2 DV20 125Vdc and 120Vac Distribution Panel Schedule, Revision

21

25203-30023, U2 Single Line Diagram 125VDC System-Turbine Battery, Revision 9

25203-30024, U2 Single Line Diagram 125VDC Emergency & 120VAC Vital Systems, Revision

39

25203-30053, Sheet 1, U2 Schematic Diagram 125VDC Switchgear Bus D01, Revision 7

25203-30053, Sheet 3, U2 Schematic Diagram 125VDC Switchgear Bus D02, Revision 9

25203-30053, Sheet 5, U2 Switchgear Diagram 125VDC Switchgear Bus D03, Revision 10

25203-30102, Unit 2 Instrument Rack Loading Diagram Fire Shutdown Panel C09, Revision 3

25203-32002, Sh. 16, 4.16kV Switchgear Kirk Key Interlocks, Revision 5

25203-32006, Sheet 13, U2 Magnetic Starter Elementary Diagram, Revision 8

25203-32009, Sht. 37, Unit 2 Charging Line Distribution Solenoid Valve CH519, Revision 9

25203-32009, Sht. 41, Unit 2 Charging Pump Control MP18B, Revision 23

25203-32009, Sht. 42A, Unit 2 Charging Pump Control MP18B, Revision 3

25203-32009, Sht. 6, Unit 2 Volume Control Tank Discharge MOV CH501, Revision 13

25203-34051, Unit 2 Auxiliary Building Miscellaneous Plan Section and Details, Revision 40

25203-39076, Sheet 9A, U2 Magnetic Starter Elementary Diagram, Revision 1

25203-39076, Sheet 9B, U2 Magnetic Starter Elementary Diagram, Revision 1

25203-39220, Sht. 1B, Unit 2 Instrument Rack Loading Diagram Spec 200 Cabinet RC30B,

Revision 19

25203-39352, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP1 & Static Sw. VS1,

Revision 5

25203-39353, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP2 & Static Sw. VS2,

Revision 5

25203-39354, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP3 & Static Sw. VS3,

Revision 5

25203-39355, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP4 & Static Sw. VS4,

Revision 3

25203-39356, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP5, Revision 5

A-10

25203-39357, Sheet 1, U2 One Line Diagram, 15KVA Inverter VIP6, Revision 6

25203-39367, Sheet 6, U2 Schematic Totalizing Box Turbine Battery Charger 201D/DC4,

Revision 2

25205-25003, Station Fire Loop Operating & Hydraulic Analysis Schematic, Revision 14

25212-24036, Fire Stop & Seals Map Locations, Revision 0

25212-24037, Fire Stop & Seals Map Locations, Revision 0

25212-24273, Wall Pene. Map Aux. BLDG. EL. 45-6, Revision 2

25212-29367 SH 20, Fire Protection & Detection Systems, dated 6/2/75

25212-29680 SH.0010, TCO-003 High Density Silicone Elastomer Fire, Air, and/or Radiation

Seal for Electrical Blockout Openings, dated 8/20/84

25212-29680 SH.0023, TCO-050 Silicone Foam Fire or Air Seals for Sleeve, Conduit, Cast or

Core Bored Openings up to 5 Dial, dated 1/26/85

25212-30001, Unit 3 Main One Line Diagram, Revision 26

25212-30004, Unit 3 Main One Line Diagram 4160V Normal and Emergency Buses, Revision

20

25212-30010, Unit 3 6900V One Line Diagram Bus 35A and 35B, Revision 20

25212-30011, Unit 3 6900V One Line Diagram Bus 35C and 35D, Revision 21

25212-30027, Sht. 3, Unit 3 480V Motor Control Center One Line Diagram Auxiliary Building,

Revision 44

25212-30272, Sht. 29A, Unit 3 Feedwater System Steam Generator 3RCS*SG1A Wide Range

Level Indication, Revision 8

25212-30272, Sht. 30, Feedwater System Steam Generator 3RCS*SG1A, Revision 5

25212-30343, Sht. 10A, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop

Diagram, Revision 6

25212-30343, Sht. 10B, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop

Diagram, Revision 5

25212-30343, Sht. 10C, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop

Diagram, Revision 5

25212-30343, Sht. 11, Unit 3 Reactor Coolant System Channel 1 Wide Range Pressure Loop

Diagram, Revision 5

25212-30379, Sheet 8, U3 Turbine Generator Lube Oil System Emergency Bearing Oil Pump

Control, Revision 3

25212-3200, Sht. 7, Elementary Diagram Reactor Head Vent Isolation Valves

3RCS*SV8095A(B), Revision 6

25212-32001, Elementary Diagram 480V MCC Charging Header Isolation Valve

2CHS*MV8438A, Revision 15

25212-32001, Sheet 6CI, U3 Elementary Diagram 125VDC Emergency Bearing Oil Pump

[3TML-P1], Revision 10

25212-32001, Sheet 6CS, U3 Elementary Diagram 125VDC Generator Emergency Seal Oil

Pump [3GMO-P2], Revision 14

25212-32001, Sht. 7DX, Elementary Diagram Letdown Line Isolation Valves 3RCS*LCV459 and

3RCS*LCV460, Revision 9

25212-32068, U3 Elementary Diagram Diesel Driven Fire Pump M7-7 Control Circuit, Revision

2

25212-39002, Sheet 1020, U3 DC Starter Emergency Seal Oil Elementary, Revision D

25212-39002, Sheet 1021, U3 DC Starter Emergency Seal Oil Schematic, Revision C

25212-39002, Sheet 1062, U3 Emergency Bearing Oil Pump Starter-Outline Schematic & Conn.

Diagram, Revision E

A-11

SKE-3.1-ELEC DIST, Emergency System One Line Diagram for Appendix R, Revision 2

Piping and Instrumentation Diagrams

25203-26005, Sht. 2, Unit 2 P&ID Feed System, Revision 73

25203-26008, Sh. 2, Piping and Instrumentation Diagram Service Water, Revision 114

25203-26011, Fire Protection, Revision 57

25203-26014, Sht. 1, Unit 2 P&ID Reactor Coolant System, Revision 41

25203-26014, Sht. 2, Unit 2 P&ID Reactor Coolant System, Revision 46

25203-26017, Sht. 1, Unit 2 P&ID Charging System, Revision 63

25212-25008, Yard Water & Fire Protection Piping, Revision 29

25212-25009, Yard Water & Fire Protection Piping, Revision 24

25212-26902, Sht. 1, Unit 3 P&ID Reactor Coolant System, Revision 33

25212-26902, Sht. 3, Unit 3 P&ID Reactor Coolant System, Revision 25

25212-26904, Sht. 1, Unit 3 P&ID Chemical and Volume Control, Revision 54

25212-26904, Sht. 2, Unit 3 P&ID Chemical and Volume Control, Revision 17

25212-26905, Sht. 1, Unit 3 P&ID Charging Pump Seal and Lubrication, Revision 33

25212-26921, Sht. 1, Unit 3 P&ID Component Cooling Water, Revision 33

25212-26970, Fire Protection System, Revision 12

Pre-Fire Plans

Fire Area AB-6, Auxiliary Building West MCC and Rod Control Area, Revision 0

Fire Area CB-11, Control Building Instrument Rack Room Underfloor Area, Revision 0

Fire Area EG-3, Emergency Generator North Emergency generator Enclosure, Revision 0

Fire Area ESF-3, Engineered Safety Features Building North Residual Heat Removal Heat

Exchanger Cubicle, Revision 0

MP2 Fire Fighting Strategies, Unit 2, Fire Area A-15, Diesel Generator A Cubicle, Revision 0

MP2 Fire Fighting Strategies, Unit 2, Fire Area A-32, Air Handling Units 386, Revision 0

MP2 Fire Fighting Strategies, Unit 2, Fire Area T-7, 69. And 4.16 KV Switchgear Room,

Revision 0

MP2 Fire Fighting Strategies, Unit 2, Fire Area T-9, East 45 Cable Vault (Z1 train), Revision 0

Fire Drills and Critiques

Fire in Building 454, Completed 6/7/16

Fire in U1 Maintenance Shop, Completed 12/14/15

Fire in U2 H2 Seal Oil Skid Pass, Completed 6/18/15

Fire in U2 Intake, Completed 12/4/15

Fire in U2 Lube Oil Room, Completed 6/9/15

Fire in U2 Upper 4160 Switch Gear, Completed 4/28/15

Fire in U3 Maintenance Shop, Completed 12/12/15

Fire Brigade Training

B5b Familiarization PowerPoint Presentation

B5b Hands-On Training attendance records, dated 5/12/15 and 11/17/15

Beyond Design Basis, Non-Licensed Operator Training Presentation

A-12

Operator Safe Shutdown Training

15605L, EOP 3509.1 Self-Guided in Plant Walkdown, Revision 0

AOP 2559 - Fire AOP 2579A/AA - Appendix R Fire in R-1, Aux Bldg including Control

Room/Computer Rooms/25 Cable Vault, Millstone Unit 2 Licensed Operator Training

Program Slides

ASP115C, Auxiliary Shutdown Equipment/Auxiliary Shutdown Panel Lesson Plan, Revision 3

C15506N, MP3*NLCT*EOP 3509.1, Revision 0

Common Operating Procedure 200.18 Time Critical Action Validation and Verification Slides,

dated 7/12/16

JPM P003, Isolate Emergency Bus 34C in Accordance with EOP 3509.1, Revision 7

JPM P011 (MC-00094), Primary Side Plant Equipment Operator (PEO) Actions on a Control

Room Evacuation (Parts 1 and 2), Revision 9/0

JPM P012, Secondary Side PEO Actions on a Control Room Evacuation, Revision 6

JPM P015, Secondary Side PEO Actions on a Control Room Evacuation due to Fire, Revision 8

JPM P173, Aligning the Fire Transfer Switch Panel and Auxiliary Shutdown Panel in Response

to a Fire, Revision 2

JPM P188, Installation of 3CHS-PI102T, Revision 0

JPM P209, Cross-Connect Service Water to East Switchgear Ventilation, Revision 1

SEG S13406L, Respond to a Control Room, Cable Spreading Area or Instrument Rack Room

Fire, Revision 0

SEG S15304L, Fire in Instrument Rack Room, Revision 0

Unit 2 Licensed Operator Requalification Program Attendance Sheet for Cycle 16-3, 5/10 - 6/17

Hot Work and Ignition Source Permits, and Transient Combustible Permits and Evaluations

29633-12-FP 30391-13-IS 31960-15-IS 41224-12-FP

41316-12-FP 41399-12-IS 43879-15-FP 43965-15-IS

44356-16-FP 44385-16-IS 44389-16-IS 44390-16-IS

44499-16-FP

Corrective Action Program Documents (Condition Reports)

463259 515160 520964 522469

522722 522740 522848 522850

523785 527755 530987 541980

541983 553343 557088 576367

578178 578333 581890 582625

582652 582665 1004974 1009069

1037462 1041883 1042283* 1043063*

1043417* 1043422* 1043425* 1043455*

1043458* 1043959* 1044278* 1044301*

1044326* 1044332* 1044334* 1044348*

1044422* 1044536* 1044760*

  • NRC identified during this inspection.

A-13

Work Orders

53M20807693 53012768647 53102490410 53102502011

53102582983 53102605405 53102649190 53102656386

53102659739 53102669361 53102693811 53102695870

53102698825 53102698915 53102698922 53102698928

53102698931 53102716240 53102716256 53102732991

53102735138 53102759052 53102760642 53102764120

53102786767 53102814722 53102846681 53102853315

53102854686 53102861679 53102871440 53102873143

53102887195 53102892290 53102900241 53102905692

53102914238 53102952946 53102958935

Vendor Manuals

25212-902-001, Vendor Technical Manual for Emergency Lighting from Exide, Holophane,

Dualite, Birns, Revision 6

TI 2AI-130, Spec 200 Current-To-Voltage Converters, dated 10/77

Industry Standards

NFPA 10-1968, Installation for Portable Fire Extinguishers

NFPA 13-1971, Installation of Sprinkler Systems

NFPA 14-1978, Installation of Standpipe and Hose Systems

NFPA 15-1985, Water Spray for Fixed Systems for Fire Protection

NFPA 27-1975, Private Fire Brigade

NFPA 72D-1986, Maintenance and Use of Proprietary protective Signaling Systems

NFPA 72E-1984, Automatic Fire Detectors

Miscellaneous Documents

Aid Agreement letter Between Millstone and the Waterford Fire Service, dated 8/6/15

Electrical Cable and Conduit Routing Information - SAFE

Fire and Hose-Stream tests for Penetration Seal Systems, dated 4/82

Fire Qualification Test on Floor Penetration Seals, dated 11/30/79

Hazard Evaluation Sheet Building - CB, dated 12/11/85

Millstone Site Fire Protection Active Impairment List, dated 7/11/16

Millstone Site Fire Protection Active Impairment List, dated 7/26/16

Millstone Site Fire Protection Active Impairment List, dated 7/27/16

Waterford Ambulance Service Memorandum of Understanding (MOU), dated 8/5/15

Waterford Fire Service MOU, dated 8/6/15

Waterford Police Department MOU, dated 9/14/15

A-14

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

ADV Atmospheric Dump Valve

AFW Auxiliary Feedwater

AOP Abnormal Operating Procedure

BTP Branch Technical Position

CAP Corrective Action Program

CFR Code of Federal Regulations

CMEB Chemical Engineering Branch

CO2 Carbon Dioxide

CONVEX Connecticut Valley Electric Exchange

CR Condition Report

CSD Cold Shutdown

DC Direct Current

Dominion Dominion Nuclear Connecticut, Inc.

DRS Division of Reactor Safety

EDG Emergency Diesel Generator

EOP Emergency Operating Procedure

FA Fire Area

FHA Fire Hazards Analysis

FPP Fire Protection Program

FSAR Final Safety Analysis Report

FZ Fire Zone

IEEE Institute of Electrical and Electronics Engineering

IMC Inspection Manual Chapter

IP Inspection Procedure

IPEEE Individual Plant Examination of External Events

IR Inspection Report

LER Licensee Event Report

LOOP Loss of Offsite Power

Millstone Millstone Power Station Unit 2 and Unit 3

NCV Non-Cited Violation

NFPA National Fire Protection Association

NRC Nuclear Regulatory Commission

OMA Operator Manual Action

P&ID Piping and Instrumentation Drawing

PARS Publicly Available Records System

RAS Reasonable Assurance of Safety

SBO Station Blackout

SDP Significance Determination Process

SER Safety Evaluation Report

SFP Site Fire Protection

SG Steam Generator

UFSAR Updated Final Safety Analysis Report

V Volts

V dc Voltage Direct Current

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