IR 05000254/2012011

IR 05000254-12-011, 05000265-12-011; 07/11/12 ?08/02/12; Quad Cities Nuclear Power Station, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection

ML12250A879
Person / Time
Site:	Quad Cities
Issue date:	09/06/2012
From:	Daley R C Engineering Branch 3
To:	Pacilio M J Exelon Generation Co, Exelon Nuclear
Alan Dahbur
References
IR-12-011
Download: ML12250A879 (24)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532

-4352 September 6, 2012 Mr. Michael J. Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road SUBJECT: QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000254/20 12011; 05000265/20120 11(DRS) Dear Mr. Pacilio

On August 2, 2012, the U.S. Nuclear Regulato ry Commission (NRC) completed a triennial fire protection inspection at your Quad Cities Nuclear Power Station, Units 1 and The enclosed inspection report documents the inspection results, which were discussed on August 2, 2012, with Mr. S. Darin and other members of your staf 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 licens The inspectors reviewed selected procedures and records, observed activities, and interviewed personne Two N RC-identified findings of very low safety significance (Green) were identified during this inspectio These findings were determined to involve violations of NRC requirements. However, because of their very low safety significance and because the issues were entered into your corrective action program, the NRC is treating the issues as Non-Cited Violation s (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy

. If you contest the subject or severity of any N on-Cited Violation you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555

-0001; with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission

- Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532

-4352; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555

-0001; and the NRC Resident Inspector office at the Resident Inspector at Quad Cities Nuclear Power Station

.

M. Pacilio

-2- In accordance with 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 NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Robert C. Daley, Chie f Engineering Branch 3 Division of Reactor Safety Docket Nos. 50

-254 and 50

-265 License Nos. DPR

-29 and DPR

-30 Enclosure:

Inspection Report 05000254/20 12011; 05000265/20 12011(DRS) w/Attachment: Supplemental Information cc w/encl:

Distribution via ListServ

Ž Enclosure U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos:

50-254; 50-265 License Nos:

DPR-29, DPR-30 Report No:

05000254/20 12011; 05000265/20 12011 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: Cordova, IL Dates: July 11 through August 2, 2012 Inspectors:

A. Dahbur , Team Lead, Senior Reactor Inspector N. Valos, Senior Risk Analyst R. Winter, Reactor Inspector Approved by:

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure

SUMMARY

IR 05000254/2012011

, 05000265/2012011

07/11/12 - 08/02/12; Quad Cities Nuclear Power Station, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection.

This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III inspectors.

Two (Green) findings were identified by the inspectors. The findin g s wer e considered Non-Cited Violation s (NCV s) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be (Green) or be assigned a severity level after NRC management review.

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

-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A.

Cornerstone: Mitigating Systems

N RC-Identified and Self-Revealed Findings GreenThe inspectors determined that the finding was more than minor because the procedure deficiency did not ensure the successful energization of Bus 23

-1 from the Unit 2 SBO DG in the event of a fire in fire area TB

-III , which was required to provide Torus cooling for Unit 1. The finding was screened as having very low safety significance in Task 1.3.1 of IMC 0609, Appendix F. This finding did not have a cross-cutting aspect because the finding was not representative of current performance. (Section 1R05.5.b)

. The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix R, Section III.L.3 for the licensee's failure to have an adequate procedure used to implement an alternative shutdown capability in the event of a fire in fire area TB

-III. Specifically, the licensee failed to provide adequate steps to ensure the successful energization of Bus 23-1 from the Unit 2 Station Blackout (SBO) Diesel Generator (DG) in the event of a fire in fire area TB

-III (Turbine Building Southern Zone Group).

The licensee entered the issue into their corrective action program and added a step to close the Bus 23-1 and Bus 71 Tie Breaker

. GreenThe inspectors determined that the finding was more than minor because the procedure deficiency could have resulted in operational complications and could have delayed reaching cold shutdown in the event of a fire in fire area TB-III. The finding was screened as having very low safety significance in Task 1.3.1 of IMC 0609, Appendix F. This finding d id not have a cross-cutting aspect because the finding was not representative of current performance. (Section 1R05.9.b) . The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix R, Section III.L.5 for the licensee's failure to have a procedure in effect that would provide adequate cold shutdown repairs for the 1A Recirculation Pump Discharge Valve MO 1

-202-5A. Specifically, a procedure deficiency in Q uad Cities Annunciator Re sponse Procedure (ARP) 0030-01, Attachment D, provided an incorrect terminal point and cubicle location on MCC 18/19

-5 for the cable wire to be lifted for cold shutdown repair in the event of a fire in fire area TB

-III. The licensee entered the issue into their corrective action program revised the procedure and corrected the deficiency.

B. No violations of significance were identified.Licens ee-Identified Violations

1. REACTOR SAFETY

REPORT DETAILS

Cornerstone s: Initiating Events and Mitigating Systems

1R05 Fire ProtectionThe purpose of the fire protection triennial baseline inspection was to conduct a design based, plant specific, risk

-informed, onsite inspection of the licensee's fire protection program's defense-in-depth elements used to mitigate the consequences of a fi re. The fire protection program shall extend the concept of defense

-in-depth to fire protection in plant areas important to safety by

(71111.05T)preventing fires from starting; rapidly detecting, controlling and extinguishing fires that do occur; providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant; and taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.

Th e inspectors' evaluation focuse d on the design, operational status, and material condition of the reactor plant

's fire protection program, post-fire safe shutdown systems , and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee ha d implemented a fire protection program that:

(1) provided adequate controls for combustibles and ignition sources inside the plant; (2)provide d adequate fire detection and suppression capability; (3)maintain ed passive fire protection features in good material condition; (4)established adequate compensatory measures for out

-of-service, degraded or inoperable fire protection equipment, systems or features; (5)ensure d that procedures, equipment, fire barriers

, and systems exist so that the post

-fire capability to safely shut down the plant was ensured;

(6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and

(7) identifie d fire protection issues at an appropriate threshold and ensure d these issues were entered into the licensee's problem identification and resolution program.

In addition, the inspectors' review and assessment focused on the licensee's post

-fire safe shutdown systems for selected risk

-significant fire areas. Inspector emphasis was placed on determining that the post

-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post

-fire safe shutdown success path was available. The inspectors' review and assessment also focused on the licensee's B.5.b related license conditions and the requirements of Title 10 , Code of Federal Regulations (10 CFR) Part 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the Attachment to this report.

3 Enclosure The fire zones/areas and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire zones/areas selected constitute d four inspection samples and the B.5.b mitigating strategies selected constitute d four inspection samples, respectively, as defined in Inspection Procedure 71111.05T. Fire Area Fire Zone Description CT-1 8.2.4 Unit 1 Cable Tunnel TB-I 8.2.6.E Unit 2 TB Ground Floor TB-III 6.1.B Unit 1 DC Panel Room TB-I 8.2.7.E Unit 2 TB Mezzanine Floor

.1 a. Protection of Safe Shutdown Capabilities

For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected.

Inspection Scope The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the fire protection program and/or post

-fire safe shutdown analysis and procedures.

b. No findings of significance were identified.

Findings

.2 a. Passive Fire Protection

For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association (NFPA) standards to verify that fire protection features met license commitments.

Inspection Scope The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area.

4 Enclosure The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.

b. No findings of significance were identified.

Findings

.3 a. Active Fire Protection

For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and detection systems. The inspectors observed the material condition and configuration of the installed fire detection and suppression systems. The inspectors reviewed design documents and supporting calculations. In addition, the inspectors reviewed license basis documentation, such as, NRC safety evaluation reports, deviations from NRC regulations, and NFPA standards to verify that fire suppression and detection systems met license commitments.

Inspection Scope b. No findings of significance were identified.

Findings

.4 a. Protection from Damage from Fire Suppression Activities

For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.

Inspection Scope b. No findings of significance were identified.

Findings

.5 a. Alternative Shutdown Capability The inspectors reviewed the licensee's systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.

The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.Inspection Scope

5 Enclosure The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked at operator training , as well as consistency between the operations shutdown procedures and any associated administrative controls.

b. Inadequate Procedure to Energize Bus 23

-1 to Provide Torus Cooling for Unit 1 Findings Introduction

The inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation of 10 CFR Part 50, Appendix R, Section III.L.3 for the licensee's failure to have an adequate procedure used to implement an alternative shutdown capability in the event of a fire. Specifically, the licensee failed to implement a procedure which would ensure the successful energization of Bus 23

-1 from the Unit 2 Station Blackout (SBO) Diesel Generator (DG) in the event of a fire in fire area TB

-III (Turbine Building Southern Zone Group).

Bus 23-1 was required to be energized to provide Torus cooling for Unit 1 in the event of a fire in fire area TB

-III. Description

The licensee used the Quad Cities ARP 0030-01, "TB-III Injection with a safety system performance monitor (SSMP) and Bringing the Unit to Cold Shutdown," to safely shutdown the plant in the event of a fire in fire area TB

-III. If power was lost to Bus 23, then Attachment K, "ANSO2 SBO DG 2 Local Emergency Operation," was used to energize Bus 23

-1 from the Unit 2 SBO DG to allow restart of the 2A and 2B Residual Heat Removal Service Water (RHRSW) Pumps to support Unit 1 Torus cooling.

The actions listed in Attachment K were to be performed by an operator from outside the control room.

The use of the Unit 2 SBO DG to provide power for Torus cooling was a contingency action in case of loss of offsite power. Safe shutdown circuit analysis has determined that offsite power would not be damaged for a fire in fire area TB

-III. However, the overall reliability and availability of electrical power (i.e., onsite and offsite power) to Bus 23-1 would be decreased in the event of a fire in area TB

-III. Also , since fire area TB-III is an alternative shutdown area, in accordance with the technical requirements of Sections III.L.3 of 10 CFR Part 50, Appendix R, the shutdown capability is required to accommodate post

-fire conditions where offsite power is available and where offsite power is not availabl e for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

. Figure 8.3

-1 "Emergency Power System" of the updated final safety analysis report (UFSAR) showed three breakers required to be closed to provide a power source to Bus 23-1 from the Unit 2 SBO DG. These breakers were the SBO DG 2 feed to Bu s 71 (Breaker 7101), Bus 23-1 Tie Breaker to Bus 71 located at Bus 71 (Breaker 7103) and Bus 23-1 Tie Breaker to B us 71 located at Bus 23

-1 (Breaker 2328). During review of Attachment K by the inspectors, it was determined that the procedure lacked a step to close the Bus 23

-1 Tie Breaker to Bus 71 (Breaker 2328)to provide the final electrical flow path to energize Bus 23

-1 after Bus 71 was energized by the Unit 2 SBO DG. Bus 23-1 was required to be energized to provide Torus cooling for Unit 1 in the event of a fire in fire area TB

-III. In response to the inspectors' concern, the licensee initiated IR 01387237, "FPI

- QCARP Procedure Deficiency, No Step to Energize Bus," and revised K of 6 Enclosure th e Q uad Cities ARP 0030-01 on July 11, 2012

, to provide a step to close the Bus 23-1 Tie Breaker to Bus 71 to provide an electrical flow path to energize Bus 23-1.

Analysis:

The inspectors determined that the failure to implement a procedure which would provide alternative shutdown capability in the event of a fire in fire area TB

-III was contrary to the requirements of 10 CFR Part 50, Appendix R, Section III.L.3

, and was a performance deficiency. Specifically, the licensee failed to implement a procedure to ensure the successful energization of Bus 23

-1 from the Unit 2 SBO DG in the event of a fire in fire area TB

-III. Bus 23-1 was required to be energized to provide Torus cooling for Unit 1 in the event of a fire in fire area TB

-III. The finding was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Events (Fire) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the procedure deficiency did not ensure the successful energization of Bus 23

-1 from the Unit 2 SBO DG in the event of a fire in fire area TB

-III in case of loss of offsite power. In the event of a fire in fire area TB

-III, Bus 23

-1 was required to be energized to provide Torus cooling for Unit 1.

Although the safe shutdown analysis determined that the fire would not damage cables associated with the offsite power sources, the overall reliability and availability of electrical power (i.e., onsite and offsite power

) to Bus 23-1 would be decreased in the event of a fire in area TB

-III. In accordance with IMC 0609 , "Significance Determination Process," Attachment 0609.04, "Phase I - Initial Characterization of Findings," Table 3, the inspectors determined that the finding affected the ability to reach or maintain safe shutdown conditions in case of a fire. Therefore, screening under IMC 0609, Appendix F, "Fire Protection Significance Determination Process," was required.

The inspectors determined that the finding affected the post-fire safe shutdown finding category. The inspectors determined that the finding represented a low degradation because of two factors that limit ed the overall impact on the performance of the Q uad Cities ARP 0030-01. First, the use of the Unit 2 SBO DG to provide power for Torus cooling was a contingency action in case of loss of offsite power in order to meet the requirement of Appendix R,Section III.L

. Second, the affected action was to establish Torus cooling within three hours of a reactor scram. The failure to energize Bus 23

-1 should be readily apparent to the operators. With a time period of three hours to establish Torus cooling, it would be expected that the operators would have diagnose d and correct ed the issue associated with the failure of Bus 23

-1 to be energized. Therefore, the inspectors determined that the finding screened as having very low safety-significance (Green) in Task 1.3.1 of IMC 0609, Appendix F.

The inspectors did not identify a cross

-cutting aspect associated with this finding because the finding was not representative of current performance.

Enforcement

Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G,Section III.J, and Section III.O. Compliance with 10 CFR Part 50, Appendix R, Section III.L is considered necessary in order to satisfy the requirements of 10 CFR Part 50, Appendix R, Section III.G ,Section III.L of 10 CFR Part 50, Appendix R

, specifies implementation of alternative to dedicated shutdown capability required by Section III.G.3 of 10 CFR Part 50, Appendix R.Section III.L.3 of 10 CFR Part 50, 7 Enclosure Appendix R, states, in part, that alternative shutdown capability shall be independent of the specific fire area and that procedures shall be in effect to implement this capability and shall accommodate post

-fire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Section 4.10.1 "Unit 1 Shutdown Analysis," of the Fire Protection Report stated, in part, that an alternative shutdown capability was utilized in the event of a fire in TB

-III. Contrary to the above, from March 4, 2009 until July 11, 2012, for an area where alternative shutdown capability was established

, the licensee's procedure failed to implement this alternative shutdown capability where offsite power was not available. Specifically, Attachment K of procedure Q uad Cities ARP 0030-01 did not ensure the successful energization of Bus 23

-1 from the Unit 2 SBO DG in the event of a fire in fire area TB-III. Bus 23

-1 was required to be energized to provide Torus cooling for Unit 1. Following the identification of the procedure deficiency, the licensee revised the procedure and added a step to ensure the energization of Bus 23-1 in the event of a fire in TB-III. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as IR 01387237, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000254/2012011-01; 05000265/2012011

-01 , Inadequate Procedure to Energize Bus 23-1 to Provide Torus Cooling for Unit 1).

.6 a. Circuit Analyses

The inspectors 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 inspectors 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, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.

Inspection Scope The inspectors' review considered fire and cable attributes, 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 inspectors also reviewed cable raceway drawings for a sample of components required for post

-fire safe shutdown to verify that cables were routed as described in the cable routing matrices.

The inspectors reviewed 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.

Additionally, the inspectors reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post

-fire safe shutdown were properly maintained in accordance with procedural requirements.

The inspectors verified for cables that are important to safe shutdown (SSD) but not part of the success path, and that do not meet the separation/protection requirements of Section III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the cable failure modes. In addition, the inspectors have verified that the licensee has either:

(1) determined that there is not a credible fire scenario (through fire 8 Enclosure modeling);

(2) implemented feasible and reliable manual actions to assure SSD capability

or

(3) performed a circuit fault analysis demonstrating no potential impact on SSD capability exists.

b. No findings of significance were identified.

Findings

.7 a. Communications

The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties.

The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.

Inspection Scope The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.

b. No findings of significance were identified.

Findings

.8 a. Emergency Lighting

The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative safe shutdown functions. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations.

The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.

Inspection Scope b. No findings of significance were identified.

Findings

.9 a. Cold Shutdown Repairs

The inspectors reviewed the licensee's procedures to determine whether repairs were required to achieve cold shutdown and to verify that dedicated repair procedures, equipment, and material to accomplish those repairs were available onsite. The inspectors also evaluated whether cold shutdown could be achieved within the required time using the licensee's procedures and repair methods. The inspectors also verified that equipment necessary to perform cold shutdown repairs was available onsite and properly staged.

Inspection Scope

9 Enclosure b. Inadequate Procedure for Cold Shutdown Repair of 1A Recirculation Pump Discharge Valve MO 1 5A Findings Introduction

The inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation of 10 CFR Part 50, Appendix R, Section III.L.5 for the licensee's failure to have a procedure in effect that would provide adequate cold shutdown repair for the 1A Recirculation Pump Discharge Valve MO 1 5A. Specifically, Attachment D

, "Repair of MO 202-5A Valve," of the Quad Cities ARP 0030-01, provided an incorrect Terminal Point

(19) and cubicle location (Cubicle A4) on motor control center (MCC) 18/19-5 for the cable wire to be lifted for Cable 12654. These inadequate repair instructions could have resulted in operational complications and could have caused a delay in reaching cold shutdown in the event of a fire in fire area TB-III (Turbine Building Southern Zone Group).

Description

The licensee used the Quad Cities ARP 0030-01 to safely shutdown the plant in the event of a fire in fire area TB

-III. To ensure that there is no backflow through the 1A Recirculation Pump and injection bypassing the reactor, motor operated valve MO 1-202-5A , "1A Recirculation Pump Discharge Valve,"

must be closed when reconfiguring the Unit 1 Division 1 RHR system for shutdown cooling

. The MCC, 480V MCC 18/19-5 , which supplied power to motor operated valve MO 1-202-5A was located inside primary containment and was not readily accessible.

The safe shutdown analysis indicated that a fire in fire area TB

-III may damage the control cables associated with the 480V MCC 18/19

-5. Because of the location of the valve and the potential cable damage, a repair was required to remotely close valve MO 1 5A from Unit 1 480V MCC 18/19-5. Attachment D, "Repair of 1 5A Valve," was used to provide the repair to allow remote closure of the 1A Recirculation Pump Discharge Valve MO 1-202-5A. Attachment D provided repair instructions to lift cable wires at certain terminal points to isolate the control circuit to allow the cold shutdown repair of valve MO 1 5A. During the inspectors' review of Attachment D and schematic/wiring drawings associated with the motor operated valve, it was determined that the procedure listed an incorrect Terminal Point

(19) and cubicle location (Cubicle A4) on MCC 18/19

-5 for the cable wire to be lifted for Cable 12654. The correct terminal point was for a GRN

-BLK conductor for Cable 12654 to be lifted at MCC 18/19

-5, Cubicle B2, Terminal Point 17. During 2009, the licensee implemented a modification per Engineering Change (EC) 344616 (that electrically disconnected the Reactor Recirculation Loop Crosstie and Crosstie Bypass Valves MO 1-202-6A, 6B and MO 1-202-9A, 9B) that changed the wiring configuration associated with MO 1 5A. The EC 344616 did not identify the Quad Cities ARP 0030-01 as a procedure that was required to be changed as a result of the modification. The Q uad Cities ARP 0030-01, Attachment D, was required to be revised to reflect the new correct terminal point and cubicle location for the cable wire to be lifted for Cable 12654.

In response to the inspectors concern, the licensee conducted a preliminary review of the electrical diagrams associated with the motor operated valve MO 1 5A and determined that the GRN-BLK conductor for Cable 12654 at MCC 18/19

-5, Cubicle B2, Terminal Point 17, was not required to be lifted to allow remote closure of valve MO 1-202-5A. Because of the lifting of other wires as specified in the repair procedure, safe shutdown could be accomplished without lifting this wire, fire induced failures of cables associated with the valve would not result in spurious opening of the valve in the event 10 Enclosure of a fire in TB

-III. However, the inspectors determined that the procedure deficiency could have caused a delay in reaching cold shutdown in the event of a fire in fire area TB-III, while the cause of the procedure deficiency was investigated.

Specifically, the inspectors were concerned that the procedure deficiency could have resulted in operational complications and could have delayed reaching cold shutdown in the event of a fire in fire area TB

-III. The licensee entered this issue into their corrective action program as IR 01393856, "FPI - QCARP 0030

-01 and 0030

-02 Identified Discrepancies," and revised the procedure and corrected the deficiency.

Analysis The finding was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Events (Fire) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the procedure deficiency could have resulted in operationa l complications and could have delayed reaching cold shutdown in the event of a fire in fire area TB

-III. The procedure deficiency delayed the capability of systems to achieve cold shutdown and would have added burden as well as uncertainty for operation s person nel during an already challenging fire event.  : The inspectors determined that the failure to provide an adequate procedure for the cold shutdown repair of 1A Recirculation Pump Discharge Valve MO 1 5A in the event of a fire in fire area TB

-III was contrary to the requirements of 10 CFR Part 50, Appendix R, Section III.L.

5 and was a performance deficiency.

Specifically, procedure Quad Cities ARP 0030-01, Attachment D, provided an incorrect Terminal Point

(19) and cubicle location (Cubicle A4) on MCC 18/19

-5 for the cable wire to be lifted for Cable 12654 associated with MO 1 5A. In accordance with IMC 0609 , "Significance Determination Process," Attachment 0609.04, "Phase I - Initial Characterization of Findings," Table 3, the inspectors determined that the finding affected the ability to reach or maintain safe shutdown conditions in case of a fire. Therefore, screening under IMC0609, Appendix F, "Fire Protection Significance Determination Process," was required.

The inspectors determined that the finding affected the post-fire safe shutdown finding category and only affected the ability to reach and maintain cold shutdown conditions. Therefore, the inspectors determined that the finding screened as having very low safety significance (Green) in Task 1.3.1 of IMC 0609, Appendix F.

The inspectors did not identify a cross

-cutting aspect associated with this finding because the finding was not representative of current performance.

Enforcement

Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, III.J, and III.O. Compliance with 10 CFR Part 50, Appendix R, Section III.L is considered necessary in order to satisfy the requirements of 10 C FR Part 50, Appendix R,Section III.G.Section III.L of 10 CFR Part 50, Appendix R, specifies implementation of alternative of dedicated shutdown capability required by Section III.G.3 of 10 CFR Part 50, Appendix R.Section III.L.5 of 10 CFR Part 50, Appendix R, states, in part, that the fire damage to equipment and systems shall be limited so that the systems can be made operable and cold shutdown achieved 11 Enclosure within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and that procedures shall be in effect to implement such repairs. Section 4.10.1 "Unit 1 Shutdown Analysis," of the Fire Protection Report stated, in part, that an alternative shutdown capability was utilized in the event of a fire in TB

-III. Contrary to the above, from April 28, 2009

, until July 31, 2012, the licensee did not have a procedure in effect that would provide adequate cold shutdown repairs for the 1A Recirculation Pump Discharge Valve MO 1 5A. Specifically, a procedure deficiency in the Quad Cities ARP 0030-01, Attachment D, provided an incorrect Terminal Point

(19) and cubicle location (Cubicle A4) on MCC 18/19

-5 for the cable wire to be lifted for Cable 12654, which could have resulted in operational complications and could have delayed reaching cold shutdown in the event of a fire in fire area TB

-III. Following the identification of the procedure deficiency, the licensee revised the procedure and corrected the deficiency. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as IR 01393856, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000254/2012011

-02; 05000265/2012011

-02 , Inadequate Procedure for Cold Shutdown Repair of 1A Recirculation Pump Discharge Valve MO 1 5A).

.10 a. Compensatory Measures

The inspectors conducted a review to verify that 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 inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.

Inspection Scope b. No findings of significance were identified.

Findings

.11 a. Review and Documentation of Fire Protection

Program Changes The inspectors reviewed changes to the approved fire protection program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the fire protection program and/or post

-fire safe shutdown analysis and procedures.

Inspection Scope b. No findings of significance were identified.Findings 12 Enclosure

.12 a. Control of Transient Combustibles and Ignition Sources

The inspectors 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 fire hazards analysis. A sample of hot work and transient combustible control permits were also reviewed.

The inspectors performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.

Inspection Scope b. No findings of significance were identified.

Findings

.13 a. B.5.b Inspection Activities

The inspectors reviewed the licensee's preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b related license conditions and 1 0 CFR 50.54(hh)(2) by determining that:

Inspection Scope Procedures were being maintained and adequate

Equipment was properly staged

, maintained, and tested

Station personnel were knowledgeable and could implement the procedures; and Additionally, inspectors review ed the storage, maintenance, and testing of B.5.b related equipment.

The inspectors reviewed the licensee's B.5.b related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction (TI) 2515/171 or subsequent performances of these inspections.

The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3 1 of Nuclear Energy Institute (NEI) 06

-12, "B.5.b Phase II and III Submittal Guidance," Revision 2 are evaluated each time due to the mitigation strategies' scenario selected.

13 Enclosure NEI 06-12, Revision 2 , Section Licensee Strategy (Table)2.2 SFP Internal Makeup (Table A.2

-1) 2.3.1 SFP External Makeup (Table A.2-2) 2.3.2 SFP External Spray (Table A.2

-3) 3.4.6 Maximize Control Rod Drive Flow (Table A.5

-6) b. No findings of significance were identified.

Findings

4OA2 Identification and Resolution

of Problems a. (71152) The inspectors reviewed the licensee's corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the fire protection program at an appropriate threshold and entering them i n the corrective action program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non

-conformance documents.

Inspection Scope b. No findings of significance were identified.

Findings

4OA6

.1 Management Meetings

On August 2, 2012, the inspectors presented the inspection results to Mr. Darin, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

Exit Meeting Summary

ATTACHMENT:

SUPPLEMENTAL INFORMATION

Attachment

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC

T

S. Darin, Plant Manager

Licensee

C. Alguire, System Engineering Manager

W. Beck, Regulatory Assurance Manager

K. Ohr, Engineering Director

J. Garrity, Maintenance

Director

A. Misak, Nuclear Oversight Manager

K. O'Shea, Operations Director

B. Steadman, Design Engineering Director

M. Wagner, Regulatory Assurance

C. Pragman, Fire Protection Program Manager, Corporate Office

M. Dunlay, Design Engineering

M. Humphrey, Engineering Program

L. Geerts, Fire Marshal

V. Ezugha, Fire Protection System Manager

S. Fisher, CMO Manager/ SRO

M. Bridges, Operations/SRO

J. Rathman, Design Engineering (Electrical)

M. Taylor, Fire Protection Engineer, Corporate Office

T. Wojcik, Work Control

M. Rice, Program Engineering Manager

G. Harris, Human Performance Manager

T. Peterson, Regulatory Assurance Lead

T. Scott, Work Management Director

J. McGee, Senior Resident Inspector Nuclear Regulatory Commission

B. Cushman, Resident Inspector

LIST OF ITEMS OPENED, CLOSED AND DISCUSS

ED 05000 254/2012011

-01; 05000265/2012011

-01 Opened and Closed

NCV Inadequate Procedure to Energize Bus 23

-1 to Provide Torus Cooling for Unit 1

(Section 1RO5.5.b) 05000 254/2012011

-02; 05000265/2012011

-02 NCV Inadequate Procedure for Cold Shutdown Repair of 1A Recirculation Pump Discharge Valve MO 1

-202-5A (Section 1RO5.9.b)

Attachment

LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

CALCULATIONS

Number Description or Title

EC 368850 Date or Revision

Documentation of Various Equipment

Capabilities to Support a Security Event

QDC-4100-M-0691 Combustible Loading Calculation (TB

-1) 4 ASSESSMENTS

Number Description or Title

1309880-03 Date or Revision

Pre NRC Triennial Inspection Self

-Assessment (FASA)

April 30, 2012

CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION

Number Description or Title

01386913 Date or Revision

FPI - QCOS 4100-37 Needs Batt. Trickle Charger Info Added

July 10. 2012

01386917 FPI - QCARP Procedure Discrepancy

- Procedure Vs Hard Card

July 10, 2012

01387040 FPI - QCARP Procedure Discrepancy

- Wrong Cubicle Number

July 10, 2012

01387112 FPI - ELP 16M Aimed Incorrectly

July 10, 2012

01387131 FPI - QCOA 0010-20 Location of Non

-PBX Phones (B.5.b)

July 10, 2012

01387237 FPI - QCARP Procedure Discrepancy, No Step to Energize Bus

July 10, 2012

01387464 FPI - Procedure Enhancement to Increase Flow to SFP

July 11, 2012

01388193 FPI - Fuel Oil XFER

Valves not Removed from Documentation

July 12, 2012

01388444 FPI - Evaluate Outside Storage of B.5.b Equipment Trailer

July 13, 2012

01388474 FPI - B.5.b and EDMG Procedure Enhancements

July 13, 2012

01389344 FPI - Procedure Enhancement to QCOP

4100-16 July 16, 2012

01390280 FPI - Missing FME Covers on Hydrogen Cylinder Manifold

July 18, 2012

Attachment

CALCULATIONS

Number Description or Title

01390530 Date or Revision

FPI - Incorrect EPN in SSR Equipment List

July 19, 2012

01390853 FPI - Degraded Fire Department Connection Sign

July 19, 2012

01390857 FPI - ELP 42Q has a Misaligned Head Lamp July 19, 2012

01390860 FPI - Unwanted Material in Cable Tray

July 19, 2012

01391023 FPI - Uncontrolled Plant Change

July 20, 2012

01391061 FPI - SSEL Flow Instrument

July 19, 2012

01393856 FPI - QCARP 0030-01 and 0030

-02 Identified Discrepancies

July 27, 2012

01394613 FPI - NRC Identified QCARB Procedure Enhancements

July 30, 2012

0139 5960 FPI - Drip Pan Below U2 Main Gen not Seismically Anchored

August 1, 2012

139 5983 FPI Minor Housekeeping Issue, Grease Board Near Cooling Line

August 1, 2012

0139 6185 FPI - NRC Identified QCARP Procedure Enhancements

August 2, 2012

0139 6372 SSMP MOV Breaker and Fuse Coordination

August 2, 2012

0139 6480 FPI - OP-MW-201-007 Attach. 1 Section II Enhancement

August 2, 2012

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

0847883 Date or Revision

0847885 01018262 Enhancement Items from B.5.B Inspection

Use of Internal Piping for External B.5.B Strategy MSOPS 2Y - RCIC Test Line to CCST Flow Diversion

November 20, 2008

November 20, 2008

January 19, 2010

00879256 Fire Watch Expectations Were not Met

February 11, 2009

00915978 Outdated Fire Watch Inspection Log (Rev 6) Used May 5, 2009

00948119 Confusion Over Firewatch Turnover

July 31, 2009

01098995 Adverse Trand: U2 EDG Cooling Water Total Flow Indication

August 6, 2010

01340283 OPEX Review for Flammable Gas Cylinder Issue March 13, 2012

01389065 Fast Charge Light Will not Extinguish

July 16, 2012 01052407 MSOPS 2AA

- Spurious Operation of April 05, 2010

Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

RCIC Minimum Flow Valve

Date or Revision

01018262 MSOPS 2Y - RCIC Test Line to CCST Flow Diversion

January 19, 2010

DRAWINGS Number Description or Title

M-29, Sheet 1 Date or Revision

Diagram of Fire Pump Diesel Engine Fuel Piping L M-46, Sheet 1

Diagram of High Pressure Coolant Injection

- HPCI Piping

CB M-46, Sheet 2

Diagram of High Pressure Coolant Injection

- HPCI Piping

R M-70 Diagram of Safe Shutdown Make

-Up Pump System Z M-87, Sheet 1

M-89, Sheet 1

Diagram of High Pressure Coolant Injection

- HPCI Piping

Diagram of Reactor Core Isolation Cooling RCIC Piping

BL BB F-11-1 Detection and Suppression Cable Tunnel

G F-13-1 Detection and Suppression Turbine Building

Ground Floor

O F-14-1 Detection and Suppression Turbine Building Mezzanine Floor

K F-15-1 Detection and Suppression Turbine Building Mezzanine Floor

L F-27 Turbine Building Corridor Ground Floor Suppression System

F F-251 Underground Loops Fire Protection Piping

H F-261 Fire Protection Piping Plan Cable Tunnel Area G F-276 Fire Suppression System Three Reactor Feed Pumps Speed Increaser Gears Area H

K F-297 Fire Suppression System Hydrogen Seal Oil Unit Cir. Water Va. Hydraulic Op Unit

B F-313 Fire Suppression System Trackway Area M

L F-320 Trackway Unit 2 Turbine Building

F-330 Cable Tunnel

- Unit 1 Turbine Building

F-370 sht. 12

Fire Protection Piping for Hydraulic Operations System

A

Attachment

DRAWINGS Number Description or Title

M-27 Date or Revision

Diagram of Fire Protection Piping QE 4E-1346A Schematic Diagram

- Safe Shutdown System; 4KV ACB 152

-3101 and 152

-1425 G 4E-6613A Schematic Diagram

- Motor Operated Valves 2901

-6 and 2901

-7 G PROCEDURES

Number Description or Title

QCARP 0010

-01 Date or Revision

QCARP 0010

-01 QCARP 0020-01 QCARP 0020

-02 QCARP 0030

-01

QCARP 0030

-02 QCARP 0030

-03 QCARP 0030

-04 QCARP 0040

-01

QCARP 0040

-02 QCARP 0050

-01 QCARP 0050

-02

QCARP 0060

-01 QCARP 0060

-02 QCOA 0010-12 QCOA 0010-20 QCOA 1900-01 QCOP 1000-30 QCOP 2900-02 RB-IS Injection with SSMP and Bringing the Unit to Cold Shutdown

RB-2S Injection with SSMP and Bringing the Unit to Cold Shutdown

RB-IN Injection with SSMP and Bringing the Unit to Cold Shutdown RB-2N Injection with SSMP and Bringing the Unit to Cold Shutdown

TB-III Injection with SSMP and Bringing the Unit to Cold Shutdown

TB-I Injection with SSMP and Bringing the Unit to Cold Shutdown

TB-II Unit 1 Injection with HPCI and Bringing the Unit to Cold Shutdown

TB-II Unit 2 Injection with RCIC and Bringing the Unit to Cold Shutdown

13-1 Injection with SSMP and Bringing the Unit to Cold Shutdown

24-1 Injection with SSMP and Bringing the Unit to Cold Shutdown

SB-1-1 Injection with SSMP and Bringing

the Unit to Cold Shutdown

SB-1-2 Injection with RCIC and Bringing the Unit to Cold Shutdown

CT-I Injection with SSMP and Bringing the Unit to Cold Shutdown

CT-2 Injection with SSMP and Bringing the Unit to Cold Shutdown

Fire/Explosion

Security Event

Loss of Water Level in the Fuel Storage Pool or Reactor Cavity (G.7.c)

Post-Accident RHR Operation

Safe Shutdown Makeup Pump System Start Up

11 15 14 20,22,24 16 16 20 16 18 23 25 14 19 38

23 28 24

Attachment

PROCEDURES

Number Description or Title

QCOP 4100-16 Date or Revision

QCOP 4100-19 QCOP 6620-11 QCOS 0010-03 QCOS 0010-15 QCOS 4100-36 Manually Filling the Diesel Fire Pump Day Tank

Emergency Portable Pump Operation (H.7.a.)

SBO DG 1(2) Local Emergency Operation

Safe Shutdown Equipment Inspection

Security Event Support Equipment Surveillance (J.7.a, J.7.b)

Emergency Portable Pump Surveillance (I.7.a.)

13 8 27 10,11 10 QCAP 1500-01 Administrative Requirements for Fire Protection

REFERENCES

Number Description or Title

FPR-R17-008 Date or Revision

LN-ARP LN-B.5.b.1 LN-B.5.b.2

PM-11-010 Transfer Pumps Eliminated as Normal Fill Supply to Diesel Driven Fire Pumps Lesson Plan

- QCARPS Lesson Plan

- Extreme Damage Mitigation B.5.b Strategies

Lesson Plan

- Extreme Damage Mitigation B.5.b Portable Diesel Driven Pump Operation

Update to Existing Letter of Agreement with the Cordova Fire Department Dist

July 15, 2005 March 5, 2009

May 4, 2012

May 22, 2012

October 10, 2011

WORK ORDERS

(WO) Number Description or Title

01378921 01

Date or Revision

01470925 01

Emergency Portable Pump Oil/Filter Change

Unit 2 Safe Shutdown Cabinet Inspection

October 13, 2011 March 13, 2012

01484244 01

Emergency Portable Pump Surveillance

April 25, 2012

01484245 01

01484597 01

Semi Annual Portable DG DC Supply Functional Test

Unit 1 Safe Shutdown Cabinet Inspection

April 25, 2012

April 27, 2012

01311627 01 EM Walkdown Group 2 Penet Fire Stops for SCAFF. Requirements

June 17, 2011

01311627 01 EM Group 2 Penetration Fire Stop Inspection Turb/Rx Bldg September 2, 2011

01475164 01 Outage Only Accessible Fire Pen Seal Inspection

March 21, 2012

01512312 01 EM Perform Group 5 Eight Hour ELP Inspection

May 11, 2012

Attachment

ADAMS Agencywide Document Access Management System

List of Acronyms Used

ARP Annunciator

Response Procedure

CFR Code of Federal Regulations

DG Diesel Generator

DRS Division of Reactor Safety EC Engineering Change

ECCS Emergency Core Cooling System

EDG Emergency Diesel Generator

EPRI Electric Power Research Institute

FSAR Final Safety Analysis Report

IMC Inspection Manual Chapter

IP Inspection Procedure

IPEEE Individual Plant Examination

of External Events

IR Inspection Report

IR Issue Report

LC Load Center

LCB Load Center Breaker

LCO Limiting Condition for Operation

LOOP Loss of Off

-site Power

MCC Motor Control Center

MOV Motor-Operated Valve

NCV Non-Cited Violation

NEI Nuclear Energy Institute NFPA National Fire Protection Association

NRC U.S. Nuclear Regulatory Commission

PARS Publicly Available Records

PI Performance Indicator

PI&R Problem Identification and Resolution

RCIC Reactor Core Isolation Cooling

SBO Station Blackout

SDP Significance Determination Process

SFP Spent Fuel Pool

SSC Systems, Structures, and Components

SSD Safe Shutdown

SSMP Safe Shutdown Makeup Pump

TB Turbine Building

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

WO Work Order

M. Pacilio

-2- In accordance with 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 NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html (the Public Electronic Reading Room).

Sincerely, Robert

C. Daley, Chie f Engineering Branch 3

Division of Reactor Safety Docket Nos.

50-254; 50-265 License Nos. DPR-29; DPR-30 Enclosure:

Inspection Report 05000

254/2012011(DRS); and 05000 266/2012011(DRS) w/Attachment: Supplemental Information

cc w/encl:

Distribution via ListServŽ

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-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/enc

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