ML093500523

IR 05000315-09-006; 05000316-09-006; on 11/02/2009 - 11/20/2009; Donald C. Cook Nuclear Power Plant, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection

ML093500523
Person / Time
Site:	Cook
Issue date:	12/15/2009
From:	Robert Daley Engineering Branch 3
To:	Jensen J Indiana Michigan Power Co
References
EA-09-313 IR-09-006
Download: ML093500523 (21)

See also: IR 05000315/2009006

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

December 15, 2009

EA-09-313

Mr. Joseph Jensen

Senior Vice President and

Chief Nuclear Officer

Indiana Michigan Power Company

Nuclear Generation Group

One Cook Place

Bridgman, MI 49106

SUBJECT:

DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2

NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REPORT 05000315/2009006(DRS); 05000316/2009006(DRS)

AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Jensen:

On November 20, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a

triennial fire protection inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2.

The enclosed inspection report documents the inspection results, which were discussed on

November 20, 2009, with Mr. Larry Webber and other members of your staff.

As a result of your intent to adopt the National Fire Protection Association Standard

(NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric

Generating Plants, 2001 Edition, as defined by Title 10, Code of Federal Regulations (CFR),

Part 50, Section 48(c), the inspection was conducted in accordance with Inspection

Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 transition Period (Triennial), dated

May 9, 2006. The inspection examined activities conducted under your license as they relate

to safety and compliance with the Commissions rules and regulations and with the conditions

of your license. The inspectors reviewed selected procedures and records, observed

activities, and interviewed personnel.

Based on the results of this inspection, no NRC-identified and no self-revealed findings were

discovered that involved violations of NRC requirements. However, a licensee-identified

violation which was determined to be of very low safety-significance is listed in this report. The

licensee-identified finding was not associated with a finding of high safety-significance (Red)

and met the four criteria established by Section A of the NRC's Interim Enforcement Policy

Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR Part 50.48) for a

licensee in NFPA 805 transition, including being entered into your corrective action program.

The finding also met additional criteria established in Section 12.01.b of Inspection Manual

J. Jensen

-2-

Chapter (IMC) 0305. Therefore, we are exercising enforcement discretion to not cite this

violation in accordance with the NRC's Enforcement Policy. If you disagree with the

characterization of this finding, you should provide a response within 30 days of the date of this

inspection report, with the basis for your disagreement, to the Nuclear Regulatory Commission,

ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional

Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Donald C.

Cook Nuclear Power Station.

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, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-315; 50-316

License Nos. DPR-58; DPR-74

Enclosure:

Inspection Report 05000315/2009006(DRS); 05000316/2009006(DRS)

w/Attachment: Supplemental Information

cc w/encl:

Distribution via ListServ

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos.

50-315; 50-316

License Nos.

DPR-58; DPR-74

Report No:

05000315/2009006(DRS); 05000316/2009006(DRS)

Licensee:

Indiana Michigan Power Company

Facility:

Donald C. Cook Nuclear Power Plant, Units 1 and 2

Location:

Bridgman, MI

Dates:

November 2 through November 20, 2009

Inspectors:

G. Hausman, Senior Reactor Inspector, Lead

M. Munir, Reactor Inspector

B. Winter, Reactor Inspector

Approved by:

R. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Enclosure

1

SUMMARY OF FINDINGS

IR 05000315/2009006(DRS); 05000316/2009006(DRS); 11/02/2009 - 11/20/2009; Donald C.

Cook Nuclear Power Plant, 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. Based on the results of this inspection, no

NRC-identified and no self-revealed findings of safety-significance were identified. 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 NRCs 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.

NRC-Identified and Self-Revealed Findings

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

No findings and/or violations of safety-significance were identified.

B.

Licensee-Identified Violations

A violation of very low safety-significance that was identified by the licensee has been

reviewed by inspectors. Corrective actions taken or planned by the licensee have

been entered into the licensees corrective action program. This violation and

corrective action tracking numbers are listed in Section 4OA7 of this report.

Enclosure

2

REPORT DETAILS

1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection (71111.05TTP)

Indiana Michigan Power Company, the licensee, in a letter (ML060090370) to the U. S.

Nuclear Regulatory Commission (NRC) dated December 28, 2005, committed to adopt

the National Fire Protection Association Standard (NFPA) 805, Performance-Based

Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001

Edition, as defined by 10 CFR 50.48(c) for the Donald C. Cook Nuclear Power Plant.

The NFPA 805 standard established a comprehensive set of requirements for fire

protection programs at nuclear power plants. The standard incorporated both

deterministic and risk-informed, performance-based concepts. The deterministic

aspects of the standard are comparable to traditional requirements. However, the

transition to a risk-informed, performance-based fire protection program requires an

in-depth nuclear safety circuit analysis for equipment identified for nuclear safety

functions such as safe-shutdown. Because the conversion and licensing process to

NFPA 805 was expected to identify and address a variety of issues that were normally

the subject of the triennial fire protection baseline inspection, the NRC modified the fire

protection inspection program and Enforcement Policy for licensees in transition to

NFPA 805. As a result, this inspection was conducted in accordance with Inspection

Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 transition Period (Triennial),

dated May 9, 2006. Associated with the transition to NFPA 805, when a certain finding

not associated with a finding of high safety-significance meets the four criteria

established by Section A of the NRC's Interim Enforcement Policy Regarding

Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), the violation

would receive enforcement discretion in accordance with the NRC's Enforcement

Policy.

The purpose of the fire protection triennial baseline inspection was to conduct a

design-based, plant specific, risk-informed, onsite inspection of the licensees fire

protection programs defense-in-depth elements used to mitigate the consequences of

a fire. The fire protection program shall extend the concept of defense-in-depth to fire

protection in plant areas important to safety by:

preventing fires from starting;

rapidly detecting, controlling and extinguishing fires that do occur; and

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.

The inspectors evaluation focused on the design, operational status, and material

condition of the reactor plants fire protection program and post-fire safe-shutdown

systems. The objectives of the inspection were to assess whether the licensee had

implemented a fire protection program that: (1) provided adequate controls for

combustibles and ignition sources inside the plant; (2) provided adequate fire detection

and suppression capability; (3) maintained passive fire protection features in good

Enclosure

3

material condition; (4) established adequate compensatory measures for

out-of-service, degraded or inoperable fire protection equipment, systems or features;

(5) ensured 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) identified fire protection issues at an appropriate threshold and ensured these

issues were entered into the licensees problem identification and resolution program.

In addition, the inspectors review and assessment focused on the licensees 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 inspection was performed in

accordance with the NRCs regulatory oversight process using a risk-informed

approach for selecting the fire areas and attributes to be inspected. The inspectors,

with assistance from a Senior Reactor Analyst (SRA), used the licensees Individual

Plant Examination for External Events (IPEEE) to select several risk-significant areas

for detailed inspection and review. Documents reviewed are listed in the Attachment to

this report.

The fire areas and/or fire zones selected for review during this inspection are listed

below and constituted five inspection samples as defined in IP 71111.05TTP.

Fire Area

Fire Zone

Description

M

15

Unit 1, 1CD Diesel Generator Room (EL. 587 0)

EE

29B

Unit 1, Essential Service Water Pump PP-1W (EL. 591-0)

KK

40A

Unit 1, 4-kV AB Switchgear Room (EL. 609-6)

MM

42D

Unit 1, EPS (AB) Battery Room (EL. 609-6)

RR

54

Unit 2, Control Room (EL. 633-0)

.1

Shutdown from Outside Main Control Room

a.

Inspection Scope

The inspectors reviewed the functional requirements identified by the licensee as

necessary for achieving and maintaining hot shutdown conditions to ensure that at

least one post-fire safe-shutdown success path was available in the event of fire in

each of the selected fire areas and for alternative shutdown in the case of control room

evacuation. The inspectors reviewed the plant systems required to achieve and

maintain post-fire safe-shutdown to determine if the licensee had properly identified the

components and systems necessary to achieve and maintain safe-shutdown conditions

for each fire area selected for review. Specifically, the review was performed to

determine the adequacy of the systems selected for reactivity control, reactor coolant

inventory makeup, reactor heat removal, process monitoring, and support system

functions. The review also included the fire safe-shutdown analysis to ensure that all

Enclosure

4

required components in the selected systems were included in the licensees

safe-shutdown analysis.

The inspectors reviewed the licensees post-fire safe-shutdown analysis, normal and

abnormal operating procedures, piping and instrumentation drawings, electrical

drawings, their updated final safety analysis report, and other supporting documents to

verify that hot and cold shutdown could be achieved and maintained from outside the

control room for fires that rely on shutdown from outside the control room. This review

included verification that shutdown from outside the control room could be performed

both with and without the availability of offsite power.

The inspectors also examined the operators ability to perform the necessary manual

actions for achieving safe-shutdown by reviewing post-fire shutdown procedures, the

accessibility of safe-shutdown equipment, and the available time for performing the

actions.

The inspectors reviewed the updated final safety analysis report and the licensees

engineering and/or licensing justifications (e.g., NRC guidance documents, license

amendments, Technical Specifications, safety evaluation reports, exemptions, and

deviations) to determine the licensing basis.

b.

Findings

No findings of safety-significance were identified.

.2

Protection of Safe-shutdown Capabilities

a.

Inspection Scope

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.

The inspectors reviewed the licensee 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. The inspectors performed plant walkdowns to verify that protective features

were being properly maintained and administrative controls were being implemented.

The inspectors also reviewed the licensees 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.

Findings

No findings of safety-significance were identified.

Enclosure

5

.3

Passive Fire Protection

a.

Inspection Scope

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 NFPA standards to verify that fire protection features met license

commitments.

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.

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.

Findings

No findings of safety-significance were identified.

.4

Active Fire Protection

a.

Inspection Scope

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.

b.

Findings

No findings of safety-significance were identified.

.5

Protection from Damage from Fire Suppression Activities

a.

Inspection Scope

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

Enclosure

6

selected fire areas to assess conditions such as the adequacy and condition of floor

drains, equipment elevations, and spray protection.

b.

Findings

No findings of safety-significance were identified.

.6

Alternative Shutdown Capability

a.

Inspection Scope

The inspectors reviewed the licensees 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.

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.

Findings

No findings of safety-significance were identified.

.7

Circuit Analyses

a.

Inspection Scope

In accordance with IP 71111.05TTP, Fire Protection - NFPA 805 Transition Period

(Triennial), dated May 9, 2006, this section of the IP was suspended for facilities in

NFPA 805 transition.

b.

Findings

No findings of safety-significance were identified.

.8

Communications

a.

Inspection Scope

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. 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.

Enclosure

7

b.

Findings

No findings of safety-significance were identified.

.9

Emergency Lighting

a.

Inspection Scope

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.

b.

Findings

No findings of safety-significance were identified.

.10

Cold Shutdown Repairs

a.

Inspection Scope

The inspectors reviewed the licensees 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.

b.

Findings

No findings of safety-significance were identified.

.11

Compensatory Measures

a.

Inspection Scope

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 on

the adequacy of short term compensatory measures to compensate for a degraded

function or feature until appropriate corrective actions were taken.

b.

Findings

No findings of safety-significance were identified.

Enclosure

8

4.

OTHER ACTIVITIES

4OA2 Problem Identification and Resolution (71152)

a.

Inspection Scope

The inspector reviewed the licensees 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 in

the corrective action program. The inspectors reviewed selected samples of condition

reports, design packages, and fire protection system non-conformance documents.

b.

Findings

No findings of safety-significance were identified.

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

(Closed)Licensee Event Report (LER) 05000315/2008-002-00: 250Vdc Cable

Separation Criteria for 10 CFR Part 50, Appendix R Not Met

This event, which occurred on February 6, 2008, during the licensees transition to

NFPA 805, a finding of nonconformance and a violation of NRC requirements (see

Section 4OA7), was discovered by the licensee in their Appendix R fire protection

analyses for both units. The finding involved the failure to identify a short section of

Train A 250Vdc conduit enclosed cable passing through the Train B 4kV switchgear

room. The routing of the unprotected conduit enclosed cable presented a potential fire

hazard which, if left unprotected, could disable both the Train B switchgear as-well-as

the remote control to the Train A 4kV switchgear due to fire damaged should a fire occur

in the Train B 4kV switchgear room. As a result, the licensee issued AR00825805,

Appendix R Compliance for Train B 4kV Room Fire. In addition, compensatory fire

watch tours of the affected fire zones were established and remained in effect until

permanent corrective actions were implemented. Permanent corrective action included

wrapping the conduit with a fire retardant material and converting the CO2 suppression

system from manual to automatic in accordance with the requirements of Appendix R,

Section III.G.2.(c). In addition, the applicable design documents were updated to reflect

the installed fire protective material.

The inspectors reviewed the licensees corrective actions for the above described

Appendix R nonconformance finding. The inspectors review of applicable licensee

documents showed that the licensee had established compensatory fire watch tours for

the affected fire zones and that the fire watch tours remained in effect until permanent

corrective actions were implemented. Based on the inspectors review of applicable

modification documents (e.g., EC-48720 and EC-48721) and by independent walkdown

observations, the inspectors concluded that the previously unprotected conduit enclosed

cable was now wrapped with an appropriate fire retardant material (i.e., 3M' Interam)

and that the CO2 suppression system was converted from a manual suppression system

to an automatic suppression system to restore conformance with the requirements of

10 CFR Part 50, Appendix R, Paragraph III.G.2(c) requirements and the licensees

original Appendix R Program assumptions. The inspectors concluded that the licensees

corrective actions, both taken and planned, were appropriate and reasonable.

Enclosure

9

The enforcement aspects of this finding are discussed in Section 4OA7. Documents

reviewed as part of this inspection are listed in the Attachment. This LER is closed.

This event follow-up review constituted one sample as defined in IP 71153-05.

4OA6 Management Meetings

.1

Exit Meeting Summary

On November 20, 2009, the inspectors presented the inspection results to Mr. Larry

Webber 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.

4OA7 Licensee-Identified Violations

The following violation of very low safety-significance (Green) was identified by the

licensee and is a violation of NRC requirements which meet the criteria of the NRC

Enforcement Policy, for being dispositioned as a NCV.

Title 10 CFR Part 50, Appendix R, requires, in part, that one train of systems necessary to

achieve and maintain hot shutdown conditions from either the control room or emergency

control station is free of fire damage. On February 6, 2008, the licensee identified an

Appendix R non-compliance (see Section 4OA3), where the Train A 4kV switchgear would

not be free of fire damage to support safe-shutdown in the unlikely event of a postulated

fire in the Train B 4kV switchgear room. The licensee performed a safety-significance

evaluation (i.e., PRA Study 054) and determined that the issue was not of high safety-

significance (i.e., the event had a CDF of 1.93E-7). The inspectors concurred with the

overall results of the licensees evaluation for safety-significance. This finding met the

criteria for enforcement discretion under Interim Enforcement Policy Regarding

Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) published in

Federal Register Notices dated June 16, 2004; January 14, 2005; and April 18, 2006.

(EA-09-313)

ATTACHMENT: SUPPLEMENTAL INFORMATION

Attachment

1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Baker, Mechanical Production Supervisor

L. Bush, Performance Assurance Manager

D. Cobb, Operations Fire Protection Manager

J. Gebbie, Plant Manager

R. Gray, Design Engineering Mechanical (DEM) Fire Protection Program Manager

K. Housh, Fire Protection System Manager

R. Hruby, Site Support Vice President

D. MacDougall, DEM- Fire Protection

B. Mammoser, Design Engineering- Mechanical Supervisor

R. Niedzielski, Regulatory Affairs- Sr. Licensing Coordinator

K. OConnor, Design Engineering Manager

S. Partin, Maintenance Manager

T. Robinson, Learning Organization Department Corrective Action Program Supervisor

M. Scarpello, Regulatory Affairs Manager

L. Webber, Site Vice President

R. Werdann, Design Engineering Director

Nuclear Regulatory Commission

R. Daley, Chief, Engineering Branch 3, Division of Reactor Safety

P. LaFlamme, Resident Inspector

J. Lennartz, Senior Reactor Inspector

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

None

Closed

05000315/2008-002-00

LER

250Vdc Cable Separation Criteria for 10 CFR Part 50

Appendix R Not Met

Discussed

None

Attachment

2

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

Date or Revision

MD-12-HV-013-N Hydrogen Generation Calculation

1

P1900-500-001

Unit 1 - 4kV East (AB Switchgear) Room T11A

Switchgear Fire Scenario Analysis

October 15, 2008

TH-04-05

Appendix R RCS Cooldown Analysis Using

RETRAN

1

CORRECTIVE ACTION PROGRAM DOCUMENTS GENERATED DURING INSPECTION

Number

Description or Title

Date or Revision

AR00860069

FPTI - Unauthorized Tape On FP Wall

November 3, 2009

AR00860231

FPTI - Battery Charger Float/Equalize Setting

Discrepancies

November 5, 2009

AR00860260

Pressurizer Heater Procedure Error - FPTI

November 6, 2009

AR00860618

Hot Shutdown Control Described In UFSAR

Out-of-Date

November 13, 2009

AR00860766

Component Numbers Not Recorded On EBL Test

Datasheet

November 17, 2009

AR00860840

Emergency Lighting Aiming Instructions

November 18, 2009

AR00860896

Discovered Data Sheet with Blank Spot for Initial

November 18, 2009

AR00860915

FPTI - TRS 8.7.7.5 Test Pressure Acceptance

Criteria Not Clear

November 19, 2009

AR00860974

Degrade Fire Seal W9097

November 19, 2009

AR00861033

Fire Door 230 Fusible Link - FPTI

November 20, 2009

WR06372057

Open Junction Box, Unit 1 Screen House

November 18, 2009

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number

Description or Title

Date or Revision

AR00821922

Minor Corrections to Emergency Remote

Shutdown Procedures

November 11, 2008

AR00825805

Appendix R Compliance for Train B 4kV Room

Fire

February 6, 2008

AR00829915

Repeat Trend in Active Fire Suppression Systems

April 15, 2008

AR00851791

Abandon CO2 Hose Reels No Longer Required by

May 20, 2009

Attachment

3

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number

Description or Title

Date or Revision

FP Program

AR00857611

Appendix R Safe-shutdown - Analysis Area 43

September 17, 2009

AR09226013

Noncompliance of NFPA 805 and Lack of

Integrated Project Schedule

August 14, 2009

AR09260005

Appendix R Safe-Shutdown-Analysis Area 43

September 17, 2009

AR09280012

Breaker/Fuse Coordination Engineering

Evaluation

October 17, 2009

CR003092067

Condition Report to Document DC Cook Epoxy

Coating Program Controls

April 2, 2003

CR00816263

Tech Eval 12.7 is Inconsistent w/OPS App R

Procedures

July 18, 2007

DRAWINGS

Number

Description or Title

Date or Revision

12-5973-9

Fire Hazard Analysis Basement Plan EL 591-0

and 5870 Units 1 and 2

9

12-5973-9 REF

Appendix R Hot Standby Equipment and

Emergency Lighting Plan El 591-0 and 587-0

December 29, 2005

12-5974-8 REF

Appendix R Hot Standby Equipment and

Emergency Lighting Plan El 609-0

December 29, 2005

12-5976-8 REF

Appendix R Hot Standby Equipment and

Emergency Lighting Plan El 633-0

December 29, 2005

OP-1-5153-8

Flow Diagram Fire Protection CO2 17 Ton

System Key Plan

8

OP-1-5153E-4

Flow Diagram Fire Protection CO2 Emergency

Diesel and Fuel Oil Transfer Pump Rm Unit 1

and 2

4

OP-1-5153E-5

Flow Diagram Fire Protection CO2 Lower 4kV

Areas Unit 1

5

OP-1-5153K-4

Flow Diagram Fire Protection CO2 Emergency

Diesel and Fuel Oil Transfer Pump Rm Unit 1

and 2

4

OP-1-12001-78

Main Auxiliary One Line Diagram Bus A and B

78

OP-1-12002-62

Main Auxiliary One Line Diagram Bus C and D

62

OP-1-12003-32

250Vdc Main One Line Diagram

32

OP-2-12002-36

Main Auxiliary One Line Diagram Bus C and D

36

Attachment

4

EVALUATION

Number

Description or Title

Date or Revision

PRA Study 054

Cook Unit 1 LER 2008-002-00 Risk Assessment

October 16, 2008

MISCELLANEOUS

Number

Description or Title

Date or Revision

2007-002

Facility Fire Report

November 14, 2007

2009-003

Facility Fire Report

February 27, 2009

AEP:NRC:6054-03

Response to GL 2006-03: Potentially

Nonconforming Hemyc and MT Fire

Barrier Configurations

June 1, 2006

ERS-BKD-4025-001-001 Emergency Remote Shutdown

1

ES-FIRE-0601-QCF

Typical Fire and Pressure and Fire,

Pressure and Radiological Seal Details,

Attachment 1

1

FPCE 2003-0017

Safe-shutdown Capability Assessment

8

LER 2008-002-00

250Vdc Cable Separation Criteria for

10 CFR Part 50 Appendix R Not Met

April 1, 2008

SSCA

Safe-shutdown Capability Assessment

14

Test Plan CTP-1199

One Hour Fire Endurance Test 3M'

Interam Fire Wrap

0

UFSAR, Chapter 1

Section 1.4.1, Criterion 11, Control Room

22.1

UFSAR, Chapter 7

Section 7.7.8, Hot Shutdown Control

22

UFSAR, Chapter 7

Section 7.7.10, Local Shutdown and

Cooldown Station

22

MODIFICATIONS

Number

Description or Title

Date or Revision

DIT-B-03318-00

Appendix R Operator Action Times

None

EC-48720

Install Fire Wrap on Conduit U1

FCN-003

EC-48721

Install Fire Wrap on Conduit U2

FCN-004

PROCEDURES

Number

Description or Title

Date or Revision

1-OHP-4021-082-006

Operation of 1AB and 1CD Battery

Chargers

11

1-OHP-4024-101

Composite

Annunciator No. 101 Response: Plant Fire

System

21

1-OHP-4025-R-Index

System Restoration Procedures Index

2

Attachment

5

PROCEDURES

Number

Description or Title

Date or Revision

1-OHP-4025-R-1

Restore Pressurizer Heaters

2

1-OHP-4030-101-044

Unit One LSI Panel Surveillance

4

1-OHP-5030-APR-001

Appendix R Toolbox and Ladder Inventory

3

2-OHP-4025-001-001

Emergency Remote Shutdown

6 and 7

2-OHP-4025-LS-1

Process Monitoring from LSI Panels

3

2-OHP-4025-LS-2

Start-Up AFW

2

2-OHP-4025-LTI-2

Local Main Steam Isolation

3

2-OHP-4025-LTI-4

Local RCP Trip and Isolation

2

2-OHP-4025-LTI-7

Local Pressurizer Heater Trip and Isolation

2

2-OHP-4025-R-1

Restore Pressurizer Heaters

2

2-OHP-4030-201-044

Unit Two LSI Panel Surveillance

4

2-OHP-4030-214-031,

Attachment 1

Operations Weekly Surveillance Checks

Unit Two Hot Shutdown Panel Switch

Position Checklist

17

2-OHP-4030-214-049,

Attachment 14

Hot Shutdown Panel Operability Test

Steam Generator PORV Operability Test

6

2-OHP-5030-APR-001

Appendix R Toolbox and Ladder Inventory

4

12-EHP-5070-BPI-001

Buried Pipe Inspection and Mitigation

Program

1

12-FFP-2270-066-001

Portable Fire Extinguisher Inspections

9

12-FFP-2270-066-002

Establishment of Backup Fire Protection

Water Supplies

2

12-FFP-4030-066-016

Inspection of Thermo-lag, Darmatt and

Mecatiss Wrapped Enclosures And 3M'

Interam Material

1

12-FFP-4030-066-023

Test and Inspections of Plant Fire Hose

Standpipe Stations

2

12-FFP-4030-066-024

Hydrostatic Testing and Re-Rack of Fire

Hose

2

12-FFP-4030-066-205

Fire Detection Instrumentation Channel

Operational Test

0

12-IHP-4030-082-001

AB, CD and N-Train Battery Weekly

Surveillance and Maintenance

15

12-IHP-5021-EMP-009

Battery Cell Charging

6

12-IHP-5030-EMP-010

Emergency Battery Light Units

16

12-IHP-5040-EMP-011

Pressurizer Backup Heaters Temporary

Power

1

12-OHP-4025-001-002

Fire Response Guidelines

3

PMP-5055-001-001

Winterization/Summerization

10

Attachment

6

TRAINING DOCUMENTS

Number

Description or Title

Date or Revision

AE-C-03202 LP

Emergency Diesel Generators - Refresher

0

AE-C-03202

Course Attendance History

November 5, 2009

Image Title 1-LSI-1 Visual Component Database

April 16, 2002

Image Title 1-LSI-2 Visual Component Database

August 12, 2002

Image Title 1-LSI-3 Visual Component Database

January 16, 1990

Image Title 1-LSI-4 Visual Component Database

January 16, 1990

Image Title 1-LSI-5 Visual Component Database

April 16, 2002

Image Title 1-LSI-6 Visual Component Database

August 12, 2002

RELLP-RQ-C-3244 RQ-C-3244 Appendix R Equipment and

Procedures

0

RQ-C-3244

Course Attendance History

November 5, 2009

RO-C-EC01 LP

Appendix R Equipment

7

RO-C-EC01

Objective Slides

None

RO-C-EC01

Course Attendance History

November 5, 2009

RO-C-EC02 LP

Appendix R Procedures

6

RO-C-EC02

Course Attendance History

November 5, 2009

UO-C-ER01 LP

Emergency Response

4

UO-C-ER01

Course Attendance History

November 5, 2009

WORK DOCUMENTS

Number

Description or Title

Date or Revision

55239216

Perform Appendix R Batlit Discharge

July 23, 2008

55273991

Perform Appendix R Batlit Discharge

February 28, 2008

55288640 01

U1 CD Diesel Generator CO2 Fire Suppression

September 3, 2008

55289542 01

U1 East (CD) and West (AB) 4kV Switchgear

CO2 Suppression

October 23, 2008

55315940 01

Inspection of Fire Doors, Frames and Their

Hardware

September 17, 2008

55327998 01

Inspection of Fire Doors, Frames and Their

Hardware

March 27, 2009

55336682

Perform PM Inspection on Appendix R

August 17, 2009

55337578

Perform PM Inspection on Appendix R Lights

September 2, 2009

Attachment

7

LIST OF ACRONYMS USED

ADAMS

Agencywide Documents Access and Management System

AFW

Auxiliary Feedwater

AR

Action Request

CDF

Core Damage Frequency

CFR

Code of Federal Regulations

CO2

Carbon Dioxide

dc or DC

Direct Current

DEM

Design Engineering Mechanical

DIT

Design Information Transmittal

DRP

Division of Reactor Projects

DRS

Division of Reactor Safety

EBL

Emergency Battery Light

EPS

Emergency Power System

FP

Fire Protection

FPTI

Fire Protection Triennial Inspection

GL

Generic Letter

IMC

Inspection Manual Chapter

IP

Inspection Procedure

IPEEE

Individual Plant Examination of External Events

IR

Inspection Report

LER

Licensee Event Report

LSI

Local Shutdown Instrumentation

MT

Mecatiss

NCV

Non Cited Violation

NFPA

National Fire Protection Association

NRC

U.S. Nuclear Regulatory Commission

PARS

Publicly Available Records

PM

Preventative Maintenance

PORV

Power-Operated Relief Valve

PRA

Probabilistic Risk Assessment

RCP

Reactor Coolant Pump

RCS

Reactor Coolant System

RETRAN

Thermalhydraulic Computer Code

ROP

Reactor Oversight Process

SDP

Significance Determination Process

SRA

Senior Reactor Analyst

UFSAR

Updated Final Safety Analysis Report

V

Volt

J. Jensen

-2-

Chapter (IMC) 0305. Therefore, we are exercising enforcement discretion to not cite this violation in

accordance with the NRC's Enforcement Policy. If you disagree with the characterization of this finding,

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

disagreement, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC

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

United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector at the Donald C. Cook Nuclear Power Station.

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, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-315; 50-316

License Nos. DPR-58; DPR-74

Enclosure:

Inspection Report 05000315/2009006(DRS); 05000316/2009006(DRS)

w/Attachment: Supplemental Information

cc w/encl:

Distribution via ListServ

Distribution

See next page

DOCUMENT NAME: G:\\DRS\\Work in Progress\\DCC 2009 006 DRS GMH.doc

Publicly Available

Non-Publicly Available

Sensitive

Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE

RIII

E RIII

DRS

NAME

GHausman:ls RDaley

DATE

12/15/09

12/15/09

OFFICIAL RECORD COPY

Letter to Mr. Joseph Jensen from Mr. Robert C. Daley dated December 15, 2009.

SUBJECT:

DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2

NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REPORT 05000315/2009006(DRS); 05000316/2009006(DRS)

AND EXERCISE OF ENFORCEMENT DISCRETION

DISTRIBUTION:

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