IR 05000219/2011007

Oyster Creek Nuclear Generating Station - NRC Triennial Fire Protection Inspection Report 05000219/2011007

ML111250021
Person / Time
Site:	Oyster Creek
Issue date:	05/05/2011
From:	Rogge J F Engineering Region 1 Branch 3
To:	Pacilio M J Exelon Generation Co, Exelon Nuclear
References
IR-11-007
Download: ML111250021 (25)

Text

W lt4ay 5,201 1Mr. MichaelJ. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer, Exelon Nuclear4300 Winfield Rd.Warrenville, lL 60555

SUBJECT: OYSTER CREEK NUCLEAR GENERATING STATION - NRC TRIENNIAL FIREPROTECTION INSPECTION REPORT O5OOO21 9/2011007

Dear Mr. Pacilio:

On April 1, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fireprotection inspection at Oyster Creek Nuclear Generating Station. The enclosed inspectionreport documents the inspection results, which were discussed on April 1, 201 1, withMr. Michael Massaro, Site Vice President, and other members of your staff. A follow-updiscussion to provide an update of the inspection findings was held with Mr. J. Chrisley bytelephone on April 28,2011.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations, and with the conditions of yourlicense. The inspectors reviewed selected procedures and records, observed activities, andinterviewed personnel. The inspectors also reviewed mitigation strategies for addressing largefires and explosions.Based on the results of this inspection, one finding of very low safety significance (Green) wasidentified. This finding was also determined to be a violation of NRC requirements. However,because of the very low safety significance, and because the issue was entered into yourcorrective action program, the NRC is treating this finding as a non-cited violation (NCV)consistent with Section 2.3.2 of the NRC Enforcement Policy. lf you contest this NCV in thisreport, you should provide a written response within 30 days of the date of this inspection reportwith the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document ControlDesk, Washington D.C. 20555-0001; with copies to the Regional Administrator, Region l; theDirector, Office of Enforcement; and the NRC Resident Inspector at Oyster Creek NuclearGenerating Station. In addition, if you disagree with the characterization of any finding in thisreport, you should provide a response within 30 days of the date of this inspection report, withthe basis for your disagreement, to the RegionalAdministrator, Region l, and the ResidentInspector at Oyster Creek Nuclear Generating Station. The information you provide will beconsidered in accordance with Inspection Manual Chapter 0305.

M. PacilioIn accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rulesof Practice," a copy of this letter, its enclosure, and your response (if any) will be availableelectronically for public inspection in the NRC Public Document Room or from the PubliclyAvailable Records (PARs) component of the NRC's document system Administrative Documentand Access Management System (ADAMS). ADAMS is accessible from the NRC Web Site athttp://www.nrc.qov/readinq-rm/adams.html (The Public Electronic Reading Room).

Sincerely,John F. Rogge, ChiefEngineering Branch 3Division of Reactor SafetyDocket No.: 50-219License No.: DPR-16

Enclosure:

Inspection Report No. 0500021912011007cc Mencl: Distribution via ListServ

SUMMARY OF FINDINGS

lR 0500021 912011007;0311412011 - 041011201 1; Exelon Generation Company, LLC; OysterCreek Nuclear Generating Station; Triennial Fire Protection Team Inspection.The report covered a two-week triennialfire protection team inspection by specialist inspectors.One finding of very low significance (Green) was identified. This finding was determined to be anon-cited violation (NCV). The significance of most findings is indicated by their color (Green,White, Yellow, Red) using lnspection Manual Chapter 0609, "Significance DeterminationProcess" and the cross-cutting aspect was determined using IMC 0305, "Operating ReactorAssessment Program." Findings for which the significance determination process (SDP) doesnot apply may be Green or be assigned a severity levelafter NRC management review. TheNRC's program for overseeing the safe operation of commercial nuclear power reactors isdescribed in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.Gornerstone: M itigati ng SystemsGreen: The team identified an NCV of 10 CFR 50, Appendix R, lll.G.2, in that Exelon failed tomaintain the credited reactor coolant inventory makeup system free of fire damage in the eventof a fire in the 'B' 480 volt (V) switchgear room. Specifically, Exelon failed to assure that the 'A'control rod drive (CRD) pump would remain available during 'B'480V switchgear room firescenarios. Cables associated with the'A'CRD pump low pressure suction trip are located inthe 'B' 480V switchgear room and are not protected by one of the methods specified in 10 CFR50, Appendix R, Section lll.G.2. Fire damage to these cables could result in the trip of thecredited 'A' pump and render it inoperable from the control room. Exelon entered this issue intoits corrective action program for long term resolution as lssue Report (lR) 01 187591 andpromptly established compensatory measures (an hourly fire watch) in the 'B' 480V switchgearroom. Exelon also promptly performed an extent of condition review to ensure the 'B' CRDpump was not similarly affected for fire areas that credited its remote operation from the maincontrol room.This finding is more than minor because it is associated with the externalfactors attribute (fire)of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective toensure the availability, reliability, and capability of systems that respond to initiating events toprevent undesirable consequences (i.e., core damage). Specifically, the availability of thecredited 'A' CRD pump was not ensured for a 'B'480V switchgear room fire scenario. A SeniorReactor Analyst performed a Phase 3 Fire Protection Significance Determination Processanalysis and determined that this finding was of very low safety significance (Green). ThePhase 3 SDP conservatively assumed the 'A' CRD pump failed for eight separate fire scenariosinitiated by electrical ignition sources or transient combustibles. The results of the SDP werelargely dominated by the availability of the feedwater and condensate system for reactor coolantinventory control because its circuits were not routed through the 'B' 480V switchgear room.This finding did not have a cross-cutting aspect because the performance deficiency occurredduring development of the safe shutdown analysis in the 1980's and is not reflective of currentlicensee performance. (Section 1R05.06)

Other Findings

NoneEnclosure

REPORT DETAILS

BackoroundThis report presents the results of a triennial fire protection inspection conducted in accordancewith NRC Inspection Procedure (lP) 71 11 1.05T, "Fire Protection." The objective of theinspection was to assess whether Exelon has implemented an adequate fire protection programand that post-fire safe shutdown capabilities have been established and are being properlymaintained at the Oyster Creek Nuclear Generating Station (OCNGS). The following fire zones(FZs) were selected for detailed review based on risk insights from the Oyster Creek IndividualPlant Examination (lPE)/lndividual Plant Examination of External Events (IPEEE):. OB-FZ-S Control Room;. OB-FZ-68 'B'480 Volt Switchgear Room;o TB-FZ-11B Turbine Lube Oil Storage, Pumping & Purification Area; and. TB-FZ-11C Switchgear Room - Turbine Building Mezzanine.lnspection of these areaslzones fulfills the inspection procedure requirement to inspect aminimum of three samples.The inspection team evaluated the licensee's fire protection program (FPP) against applicablerequirements which included plant Technical Specifications, Operating License Condition 2.C.3,NRC Safety Evaluations, 10 CFR 50.48, 10 CFR 50, Appendix R, and Branch TechnicalPosition (BTP) Chemical Engineering Branch (CMEB) 9.5-1. The team also reviewed relateddocuments that included the Updated Final Safety Analysis Report (UFSAR), Section 9.5.1, thefire hazards analysis report (FHAR), and the post-fire safe shutdown analyses.The team also evaluated two licensee mitigating strategies for addressing large fires andexplosions as required by Operating License Condition 2.C.8. Inspection of these strategiesfulfills the inspection procedure requirement to inspect a minimum of one sample.Specific documents reviewed by the team are listed in the attachment.1.

REACTOR SAFETY

Cornerstones: lnitiating Events, Mitigating Systems, and Barrier Integrity1R05 Fire Protection (lP 711 11.05T).01 Protection of Safe Shutdown Capabilitiesa. lnspection ScopeThe team reviewed the FHAR, safe shutdown analyses and supporting drawings anddocumentation to verify that safe shutdown capabilities were properly protected.Enclosure b.2The team ensured that applicable separation requirements of Section lll.G of10 CFR 50, Appendix R and the licensee's design and licensing bases were maintainedfor the credited safe shutdown equipment and their supporting power, control, andinstrumentation cables. This review included an assessment of the adequacy of theselected systems for reactivity control, reactor coolant makeup, reactor heat removal,process monitoring, and associated support system functions.FindinosA finding was identified involving a safe shutdown analysis error that resulted in thefailure to protect all cables associated with the credited CRD pump. Refer to Section1R05.06 of this report.Passive Fire Protectionlnspection ScopeThe team walked down accessible portions of the selected fire areas to observe materialconditions and the adequacy of design of fire area boundaries (including walls, ceilings,floors, fire doors, and fire dampers), electrical raceway fire barriers, and equipment firebarriers to ensure they were appropriate for the fire hazards in the area.The team reviewed installation, repair, and qualification records for a sample of openingsand penetration seals to ensure the fill material was of the appropriate fire rating and thatthe installation met the engineering design. The team reviewed similar records for thefire protection wraps to ensure the material was of an appropriate fire rating and that theinstallation met the engineering design. The team also reviewed completed surveillanceand maintenance procedures for selected passive fire protection features to verify thatmaintenance and inspection activities are adequate.FindinqsNo findings were identified.Active Fire Protectionlnspection ScopeThe team reviewed the design, maintenance, testing, and operation of the fire detectionand suppression systems in the selected plant fire areas. This included verification thatthe manual and automatic detection and suppression systems were installed, tested,and maintained in accordance with the National Fire Protection Association (NFPA) codeof record and that each suppression system would control or extinguish fires associatedwith the hazards in the selected areas. A review of the design capabilities of thesuppression agent delivery systems were verified to meet the code requirements for thea..02.03b.a.Enclosure b.a..043hazards involved. The team also performed a walkdown of accessible portions of thedetection and suppression systems in the selected areas as well as a walk down ofmajor system support equipment in other areas (e.9. fire pumps and carbon dioxidestorage tanks and supply system) to assess the material condition and the operationallineup and availability of the systems and components. The team reviewed electric anddiesel fire pump flow and pressure tests to ensure that the pumps were meeting theirdesign requirements. The team also reviewed the fire main loop flow tests to ensurethat the flow distribution circuits were able to meet the design requirements.The team assessed the fire brigade capabilities by reviewing training, qualification, anddrill critique records. The team also compared pre-fire plans for the selected fire areaswith as-built plant conditions and fire response procedures to verify fire-fighting pre-fireplans are consistent with the fire protection features and potentialfire conditionsdescribed in the FPP. In addition, the team inspected the fire brigade equipment(including smoke removal equipment) to determine operational readiness for fire fighting.FindinosNo findings were identified.Protection From Damaqe From Fire Suppression Activitieslnspection ScopeThe team performed document reviews and plant walkdowns to verify that redundanttrains of systems required for hot shutdown, which are located in the same fire area, arenot subject to damage from fire suppression activities or from the rupture or inadvertentoperation of fire suppression systems. Specifically, the team verified that:o A fire in one of the selected fire areas would not indirectly, through production ofsmoke, heat, or hot gases, cause activation of suppression systems that couldpotentially damage all redundant safe shutdown trains;r A fire in one of the selected fire areas (or the inadvertent actuation or rupture of afire suppression system) would not indirectly cause damage to all redundanttrains (e.9. sprinkler caused flooding of other than the locally affected train); and,. Adequate drainage is provided in areas protected by water suppression systems.FindinqsNo findings were identified.Enclosure

.054 Shutdown Caoabilitv - Normal and Alternativelnspection ScopeThe team reviewed the safe shutdown analysis, operating procedures, piping andinstrumentation drawings (P&lDs), electrical drawings, the UFSAR, and other supportingdocuments for the selected fire areas to verify that the licensee had properly identifiedthe systems and components necessary to achieve and maintain safe shutdownconditions.The team assessed the adequacy of the selected systems and components for reactivitycontrol, reactor coolant makeup, reactor heat removal, process monitoring, and supportsystem functions. This review included verification that alternative post-fire shutdowncould be performed both with and without the availability of offsite power. Plantwalkdowns were also performed to verify that the plant configuration was consistent withthat described in the safe shutdown and fire hazards analyses. The team verified thatthe systems and components credited for use during shutdown would remain free fromfire damage.The team verified that the training program for licensed and non-licensed operatorsincluded alternative shutdown capability. The team also verified that personnel requiredfor safe shutdown using the normal or alternative shutdown systems and procedures aretrained and available onsite at all times, exclusive of those assigned as fire brigademembers.The team reviewed the adequacy of procedures utilized for post-fire shutdown andperformed an independent walk through of procedure steps to ensure theimplementation and human factors adequacy of the procedures. The team also verifiedthat the operators could be reasonably expected to perform specific actions within thetime required to maintain plant parameters within specified limits.Specific procedures reviewed for normal and alternative post-fire shutdown included thefollowing:. ABN-1, Reactor Scram, Rev. 10;o ABN-29, Plant Fires, Rev.24;o ABN-30, Control Room Evacuation, Rev. 16; and,. 346, Operation of the Remote and Local Shutdown Panels, Rev. 17.The team reviewed manual actions to ensure that they had been properly reviewed andapproved and that the actions could be implemented in accordance with plantprocedures in the time necessary to support the safe shutdown method for each firearea. The team also reviewed the periodic testing of the alternative shutdown transfercapability and instrumentation and controlfunctions to ensure the tests are adequate toensure the functionality of the alternative shutdown capability.a.Enclosure

b.a,.065FindinqsNo findings were identified.Circuit AnalvsisInspection ScopeThe team verified that the licensee performed a post-fire safe shutdown analysis for theselected fire areas and the analysis appropriately identified the structures, systems, andcomponents important to achieving and maintaining safe shutdown. Additionally, theteam verified that the licensee's analysis ensured that necessary electrical circuits wereproperly protected and that circuits that could adversely impact safe shutdown due to hotshorts, shorts to ground, or other failures were identified, evaluated, and dispositioned toensure spurious actuations would not prevent safe shutdown.The team's review considered fire and cable attributes, potential undesirableconsequences, and common power supply/bus concerns. Specific items included thecredibility of the fire threat, cable insulation attributes, cable failure modes, andactuations resulting in flow diversion or loss of coolant events.The team also reviewed cable raceway drawings for a sample of components requiredfor post-fire safe shutdown to verify that cables were routed as described in the cablerouting matrices.Cable failure modes were reviewed for the following components:r Emergency Diesel Generator 2;. Electromatic Relief Valves;. 'A'Control Rod Drive Pump;. 'B' Core Spray Pump; and,. Reactor Vessel Wide Range Level Instrument Ll-1413.The team reviewed circuit breaker coordination studies to ensure equipment needed toconduct post-fire safe shutdown activities would not be impacted due to a lack ofcoordination. Additionally, the team reviewed a sample of circuit breaker maintenancerecords to verify that circuit breakers for components required for post-fire safeshutdown were properly maintained in accordance with procedural requirements.FindinqsControl Cables for the Reactor Coolant Inventorv Makeup Source Not Protected FromFire DamaqeIntroduction: The team identified a Green, non-cited violation (NCV)of 10 CFR 50,Appendix R, lll.G.2, in that Exelon failed to maintain the safe shutdown credited reactorcoolant inventory makeup system free of fire damage in the event of a fire in theb.Enclosure 6'8'480 volt (V) switchgear room. Specifically, Exelon failed to assure that the controlcables associated with the'A' CRD pump low suction pressure trip circuitry wereprotected from the effects of a fire in this area. Without the required protection, firedamage to the cables could cause the pump to trip and could also prevent operatorsfrom starting the pump.Descriotion: The team requested several electrical schematics and wiring diagrams ofinstrumentation, control, and power circuits associated with components the licensee'sanalysis credited to be operable and free of fire damage for the selected inspection fireareas. While collecting the documents, Exelon engineers identified that a low pressuresuction trip control circuit for the 'A' CRD pump was not included in the safe shutdownanalysis. Exelon evaluated the affected circuitry and determined that two cables, thatcontained conductors used in the low suction pressure trip circuit, passed through the'B'480V switchgear room and were not protected from fire damage. Fire inducedfailures of either of these cables in the 'B' 480V switchgear room could spuriously trip the'A'CRD pump and render it inoperable from the main control room. The NRC is treatingthis issue as a NRO-identified finding because, although Exelon engineers identified thesafe shutdown analysis discrepancy, the discrepancy would not have been identified ifthe NRC inspectors did not select the'A' CRD pump as an inspection sample.10 CFR 50.48(bX1) requires that all nuclear power plants licensed to operate prior toJanuary 1, 1979, must satisfy the applicable requirements of 10 CFR Part 50,Appendix R, Section lll.G. Appendix R, lll.G.2, requires, in part, that where cables orequipment, including associated non-safety circuits that could prevent operation orcause maloperation due to hot shorts, open circuits, or shorts to ground, of redundanttrains of systems necessary to achieve and maintain hot shutdown conditions arelocated within the same fire area outside of primary containment, one of three means ofprotecting cables to ensure that one of the redundant trains is free of fire damage shallbe provided. The three acceptable methods described in Appendix R, Section lllG.2 formaintaining one of the redundant trains in the same fire area free of fire damage arebased on the use of physical barriers, spatial separation, and fire detection and anautomatic fire suppression system. OCNGS FHAR Section 7.0, Rev. 15, stated that fora fire in the'B' 480V switchgear room, hot shutdown will be achieved using isolationcondenser'A'for decay heat removal in conjunction with CRD pump 'A'for reactorcoolant makeup. The failure to ensure the'A' CRD pump low pressure suction tripcircuitry was protected by one of the three acceptable methods described in Appendix R,Section lll.G.2 was a performance deficiency.Exelon entered this issue into its corrective action program for resolution as lssue Report(f R) 01 187591and established compensatory measures (an hourly fire watch in the'B' 480V switchgear room). Exelon also promptly performed an extent of conditionreview and confirmed the 'B' CRD pump was not similarly affected for fire areas thatcredited its remote operation from the main control room. The team concluded thatExelon's interim compensatory measures were implemented in a timely manner andcommensurate with the risk significance of the issue.Analvsis: Exelon's failure to ensure the'A' CRD pump was available and not subject toa spurious trip on low suction pressure for a postulated 'B' 480V switchgear room fireEnclosure 7was a performance deficiency. This finding was more than minor because it isassociated with the externalfactors attribute (fire) of the Mitigating Systems Cornerstoneand adversely affects the cornerstone objective to ensure the availability, reliability, andcapability of systems that respond to initiating events to prevent undesirableconsequences (i.e. core damage). Specifically, the availability of 'A' CRD pump was notensured for a 'B' 480V switchgear room fire scenario.The team evaluated this issue using Phase 1 of IMC 0609, Appendix F, Fire ProtectionSignificance Determination Process (SDP), and determined that a Phase 2 or Phase 3SDP evaluation would be required because a high degradation rating was assigned (dueto the lack of any physical protection for the affected cables) and the fire area total firefrequency was relatively high (greater than 1E-6). A Senior Reactor Analyst (SRA)performed a Phase 3 SDP evaluation in which it was conservatively assumed the 'A'CRD pump failed for eight separate fire scenarios involving electrical equipment failuresor transient combustibles. The results of the SDP were dominated by the availability ofthe condensate and feedwater systems for reactor coolant makeup when it wasdetermined that circuits for these components were not routed through the 'B' 480Vswitchgear room. The team reviewed electrical circuits and cable routes with Exelonengineers to confirm that the condensate and feedwater systems could be appropriatelycredited during the Phase 3 evaluation. Based on the results of the Phase 3 SDPevaluation the team determined the issue was of very low safety significance (Green).The team also determined that no cross-cutting aspects were associated with thisfinding. The performance deficiency occurred during initial development of the fire safeshutdown analysis in the 1980's and was not identified during a licensee project toupdate the fire safe shutdown analysis in the 1990's. Because the error occurred morethan three years ago, the performance deficiency is not considered to be indicative ofcurrent licensee performance.Enforcement. 10 CFR 50.48(bX1) requires that all nuclear power plants licensed tooperate prior to January 1, 1979, must satisfy the applicable requirements of10 CFR Part 50, Appendix R, Section lll.G. Appendix R, lll.G.2, requires, in part, thatwhere cables or equipment, including associated non-safety circuits that could preventoperation or cause maloperation due to hot shorts, open circuits, or shorts to ground, ofredundant trains of systems necessary to achieve and maintain hot shutdown conditionsare located within the same fire area outside of primary containment, one of three meansof protecting cables to ensure that one of the redundant trains is free of fire damage shallbe provided. OCNGS FHAR Section 7.0, Rev. 15, stated that for a fire in the 'B'480Vswitchgear room, hot shutdown will be achieved using isolation condenser'A'for decayheat removal in conjunction with CRD pump'A'for reactor coolant makeup. Contrary tothe above, on March 15,2011, the NRC identified that Exelon did not meet thisrequirement and had not historically met this requirement for the 'B' 480 V switchgearroom fire area. Exelon failed to protect the'A' CRD pump motor control circuits from apostulated fire-induced circuit failure resulting in the potential for pump trip due to a fireinduced low pressure suction trip. Because this finding was of very low safetysignificance and was entered into Exelon's corrective action program (lR 01 187591), thisviolation is being treated as an NCV, consistent with Section 2.3.2, of the NRCEnclosure

.07.0 8.09b.a.8Enforcement Policy. (NCV 500021912011007-001, Gontrol Cables for the ReactorCoolant Inventory Makeup Source Not Protected From Fire Damage)CommunicationsInspection ScopeThe team reviewed safe shutdown procedures, the safe shutdown analysis, andassociated documents to verify an adequate method of communications would beavailable to plant operators following a fire.During this review the team considered the effects of ambient noise levels, clarity ofreception, reliability, and coverage patterns. The team also inspected the designatedemergency storage lockers to verify the availability of portable radios for the fire brigadeand for plant operators. The team also verified that communications equipment such asrepeaters and transmitters would not be affected by a fire.FindinqsNo findings were identified.Emerqencv LiohtinqInspection ScopeThe team observed the placement and coverage area of eight-hour emergency lightsthroughout the selected fire areas to evaluate their adequacy for illuminating access andegress pathways and any equipment requiring local operation or instrumentationmonitoring for post-fire safe shutdown. The team also verified that the battery powersupplies were rated for at least an eight-hour capacity. Preventive maintenanceprocedures, the vendor manual, completed surveillance tests, and battery replacementpractices were also reviewed to verify that the emergency lighting was being maintainedconsistent with the manufacturer's recommendations and in a manner that would ensurereliable operation.FindinqsNo findings were identified.Cold Shutdown Repairslnspection ScopeThe team verified that the licensee had dedicated repair procedures, equipment, andmaterials to accomplish repairs of components required for cold shutdown which mightbe damaged by the fire to ensure cold shutdown could be achieved within the timeframes specified in their design and licensing bases. The team verified that the repairEnclosure

b..10b..12b..119equipment, components, tools, and materials (e.9. pre-cut cables with preparedattachment lugs) were available and accessible on site.FindinqsNo findings were identified.Compensatorv Measureslnspection ScopeThe team verified 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.9. detection and suppression systems and equipment, passive firebarriers, or pumps, valves or electrical devices providing safe shutdown functions orcapabilities). The team also verified that the short term compensatory measurescompensated for the degraded function or feature until appropriate corrective actioncould be taken and that the licensee was effective in returning the equipment to servicein a reasonable period of time.The team reviewed compensatory measures in the form of manual actions for10 CFR Part 50 Appendix R, Section lll.G.2 areas to verify that there is reasonableassurance that manual actions can be accomplished. Specific attributes reviewedinclude diagnostic instrumentation, environmental consideration, staffing,communications, equipment availability, training, procedures, and verification andvalidation.FindinqsNo findings were identified.Fire Protection Prooram Chanoeslnspection ScopeThe team reviewed recent changes to the approved fire protection program to verify thatthe changes did not constitute an adverse effect on the ability to safely shutdown.FindinqsNo findings were identified.Control of Transient Combustibles and lqnition Sourceslnspection ScopeThe team reviewed the licensee's procedures and programs for the control of ignitionsources and transient combustibles to assess their effectiveness in preventing fires andEnclosure

.13 a.10in controlling combustible loading within limits established in the FHAR. A sample of hotwork and transient combustible control permits were also reviewed. The teamperformed plant walkdowns to verify that transient combustibles and ignition sourceswere being implemented in accordance with the administrative controls.FindinqsNo findings were identified.Laroe Fires and Explosions Mitiqation StrateqiesInspection ScopeThe team reviewed the licensee's preparedness to handle large fire or explosions byreviewing two mitigating strategies to verify they continue to meet operating licensecondition 2.C.17 by determining that:r Procedures are being maintained and adequate;o Equipment is properly staged and is being maintained and tested; and,o Station personnel are knowledgeable and can implement the procedures.FindinosOne finding was identified and is documented in NRC Inspection Report0500021 9/201 1 009.orHER ACTTVTTlES [OAIldentification and Resolution of ProblemsCorrective Actions for Fire Protection DeficienciesInspection ScopeThe team verified that the licensee was identifying fire protection and post-fire safeshutdown issues at an appropriate threshold and entering them into the corrective actionprogram. The team also reviewed a sample of selected issues to verify that the licenseehad taken or planned appropriate corrective actions.FindinqsNo findings were identified.b.4.4c.42.01a.b.Enclosure

11Meetinqs. lncludino ExitExit Meetinq SummarvThe team presented their preliminary inspection results to Mr. Michael Massaro, SiteVice President, and other members of the site staff at an exit meeting on April 1, 2011.An updated status of the findings was provided to Mr. J. Chrisley by telephone on April28, 2011. No proprietary information was included in this inspection report.Enclosure A-1ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Carlson Fire Protection Safe Shutdown EngineerJ. Chrisley Regulatory Assurance SpecialistN. Onuorah Fire Protection Safe Shutdown EngineerC. Pragman Exelon Corporate Fire Protection ManagerT. Prosser Fire MarshallM. Taylor Exelon Corporate Fire ProtectionT. Trettel Fire Protection System ManagerNRCJ. Rogge ChiefProperty "Contact" (as page type) with input value "M. Carlson Fire Protection Safe Shutdown EngineerJ. Chrisley Regulatory Assurance SpecialistN. Onuorah Fire Protection Safe Shutdown EngineerC. Pragman Exelon Corporate Fire Protection ManagerT. Prosser Fire MarshallM. Taylor Exelon Corporate Fire ProtectionT. Trettel Fire Protection System ManagerNRCJ. Rogge Chief" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Engineering Branch 3, Division of Reactor Safety

J. Kulp Senior Resident Inspector, Oyster Creek Nuclear Generating Station

J. Ambrosini Resident Inspector, Oyster Creek Nuclear Generating Station

B. Keighley Resident Inspector, Acting, Oyster Creek Nuclear Generating Station

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

OPEN/GLOSED050002191201107-01NCVControl Cables for the Reactor Coolant Inventory MakeupSource Not Protected From Fire Damage(Section 1R05.06)Attachment

A-2

LIST OF DOCUMENTS REVIEWED

Fire Protection Licensinq Documents990-1746, OCNGS Fire Hazards Analysis Report, Rev. 15License No.

DPR-16, Exelon Generation Company, Docket No. 50-219, OCNGS Amendment toRenewal Facility Operating License, Amendment No. 277SP-1302-06-013, Augmented Quality Fire Protection Specification for Post-Fire Safe ShutdownProgram Requirements at OCNGS, Rev. 4UFSAR, Chapter 9, OCNGS Updated Final Safety Analysis Report, Rev. 14Desiqn ChanqesSDD

OC-642 A, Appendix R Modifications to Electromatic Relief Valves, Rev. 5Calculations/Enqineerinq Evaluation Reports08-00553, Fire Sprinklers System Expansion, A/B 4160V and C Battery Rooms, Rev. 198-E04, Upgrade of Raceways62-158 and 62-161,12-602 and 12-603,12-600 and 12-601,dated 315198A2014648, Evaluate Penetrations on Sheetrock Wall Between

OB-FZ-6A and 68, Rev. 0A2014648-6, Attachment A, Technical Evaluation of a One-Hour Rated Penetration Seallnstalled in a Gypsum Stud Partition, Rev. 0BM-TE-14, Mecatiss Systems

MTS-1 and

MPF-60 Interfacing with Partially Covered SiliconeFoam Penetration Seal, dated 11129100C-1302-700-5350-003,

OC-4160V Class 1E Protective Device Relay Setpoints, Rev. 5C-1302-811-E310-036, 4160V Room Fire Protection Preaction Sprinkler System HydraulicCalculation, Rev. 1C-1302-813-E120-001, Halon 1301 Fire Protection Systems for Main Control Room Systems A,B, C, and A/B Battery Room System, Rev. 0C-1302-911-E120-001 , Fire ArealZones

OB-FA-S - Fire Safe Shutdown Analysis, Rev. 0G2C-1302-911-E120-OO7 , Fire ArealZones

OB-FZ-OB - Fire Safe Shutdown Analysis, Rev. 0G3C-1302-911-E120-008, Fire ArealZones

TB-FZ-11C &

TB-FA-26 - Fire Safe ShutdownAnalysis, Rev.0G3C-1302-91 1-E120-018, Fire ArealZones

TB-FZ-11B - Fire Safe Shutdown Analysis, Rev. 0G3ETR-P1787-001, Appendix R Evaluation of Protective Device Coordination, Rev. 0OC

PSA-012, Internal Flood Evaluation Summary and Notebook, Rev. 1OC-SDP-2011-01, Oyster Creek SDP Evaluation for CRD Pump 'A' Unavailable during 480VSwitchgear Room'B'Fire, Rev. 0Report 3731-021, Study for Appendix R - Spurious Actuation of Electromatic Relief Valves,Rev. 1Report 3731-042, Study for Appendix R - Evaluation of Tripping Feedwater Pumps From TheControl Room in the Event of a Fire Outside of the Control Room Complex, Rev. 1SP-'!302-06-13, Post-Fire Safe Shutdown Requirements at OCNGS, Rev. 4Attachment

A-3Procedures101.2, Oyster Creek Site Fire Protection Program, Rev. 672400-APR-3228.01, Appendix R - Temporary Torus Water Level lnstrument, Rev.82400-APR-3900.01, Appendix R Repair Kit Annual Inspection, Rev. 18305, Shutdown Cooling System Operation, Rev.

105307, lsolation Condenser System, Rev. 112320.1, Demineralized Water Transfer System, Rev. 58333, Plant Fire Protection System, Rev.

104346, Operation of the Remote and Local Shutdown Panels, Rev. 17ABN-29, Plant Fires, Rev. 24ABN-3, Loss of Shutdown Cooling, Rev. 3ABN-30, Control Room Evacuation, Revs. 15 and 16ABN-40, Stuck Open EMRV, Rev. 7CC-AA-21 1, Fire Protection Program, Rev. 4EMG-3200.01A, EOP Flowchart RPV Control- No ATWS, Rev. 6MA-AA-716-040, Control of Portable Measurement and Test Equipment Program, Rev. 7Com pleted Tests/Surveillances645.4.012, Fire Pump Functional Test, Rev. 6, Completed 216109645.4.012, Fire Pump FunctionalTest, Rev. 9, Completed 1117109645.6.010, Fire Suppression Deluge Valve Functional Test, Rev. 32, Completed 117109645.6.010, Fire Suppression Deluge Valve Functional Test, Rev. 34, Completed

2119110,4113110, and 6121110645.6.013, Fire Suppression System Halon Functional Test, Rev. 29, Completed 212109645.6.013, Fire Suppression System Halon FunctionalTest, Rev. 30, Completed7l2ll09 and4t27110645.6.014, Fire Suppression System Halon Cylinder Check, Rev.20, Completed

6123109,12111109, and7l30l1o645.6.017, Fire Barrier Penetration Surveillance, Rev. 10, Completed

6126107,

6124109, and7t23t07645.6.017,Fire Barrier Penetration Surveillance, Rev. 12, CompletedTl23lOT645.6.01 7 , Fire Barrier Penetration Surveillance, Rev. 14, Completed 6/29109645.6.017,Fire Barrier Penetration Surveillance, Rev. 15, Completed 8/3/10 and 1Ol11l1O645.6.023, Fire Suppression Water System Underground Flow Test, Rev. 1 1, Completed12t12t06645.6.023, Fire Suppression Water System Underground Flow Test, Rev. 14, Completed4t15t10645.6.026, Fire Damper lnspection, Rev. 11, CompletedGl2TlOG and 6/13/08645.6.028, Thermo-Lag and Mecatiss Envelope System Fire Barriers, Rev. 8, Completed2t16t07645.6.028, Thermo-Lag and Mecatiss Envelope System Fire Barriers, Rev. 10, Completed121161O9645.6.032, Fire Detection System Alarm Circuitry Test for Turbine Building and 4160VSwitchgear Room, Rev. 17, Completed 1 1/30/07,

12112108, and 5l29log645.6.032, Fire Detection System Alarm Circuitry Test for Turbine Building and 4160VSwitchgear Room, Rev. 19, Completed 4l7l1OAttachment

A-4645.6.033, Fire Detection System Alarm Circuitry Test for Control Room and Upper and LowerCable Spreading Room, Rev. 14, Completed 6/10/09 and6114110645.6.034, Fire Detection System Alarm Circuitry Test for 480V Switchgear Rooms, A/B BatteryRooms, and MG Set Room, Rev. 12, Completed 6/19/09 and7l30l10TP 400i0.1, Control Room Emergency Lighting Test, Rev. 0, Completed 10126184TP 44715,480V Switchgear Room Halon System Functional Test, Rev. 0, Completed 1214186TP 46112, Appendix R Emergency Lighting Test, Rev. 0, Completed 2128189Qualitv Assurance Audits and Self AssessmentsFire Protection Self-Assessment Report, Dated 112112011Svstem Health ReportsFire Barriers, 3'd and 4tn Qtr. 2010Fire Detection Systems, 3'd and 4th Qtr. 2010Fire Protection Halon System, 3d and 4th Qtr. 2010Fire Protection Water System, 3'd and 4tn Qtr. 2010Drawinqs and Wirinq Diaorams0370-031-005, Relay Panel

ER 188 Connection Diagram, Rev. 5103D4623, Sheet 1,

AKD-5 Powermaster Switchgear Connection Diagram, Rev. 21103D4625, Connection Diagram

AKD-5 Powermaster Switchgear, Rev.

213102, Turbine Building Tray Plan Basement, Rev. 63118, Turbine Building Lighting Plan Operating Floor, Rev. 53159, Office Building Conduit & Tray Plan - 1't Floor, Rev.

253179, Miscellaneous Outdoor Facilities, Rev. 93180, Sheet 1, Miscellaneous Outdoor Facilities, Rev. 123E-611-17-004, Sheet 1, Elec. Elem. Diagram Control Panel 1Fl2F-Annun. B, Rev. 137023-56752-43, Sheet 1, Connection Diagram Local Shutdown Panel

LSP-1A2, Rev.77023-56754-43, Sheets 1 & 2, Wiring Diagram Local Shutdown Panel

LSP-DG2, Revs. 8 and 6BR 3000, Electrical Power System Key One Line Diagram, Rev. 13BR 3001, Plant Electrical Generation Main One Line Diagram, Sheet 1, Rev. 15BR 3001, Emergency Power System One Line Diagram - Emergency Diesel Generators,Sheet 2, Rev. 4BR 30014, 4160V System One Line Diagram, 4160V SWGR Bus 1,A, Rev. 11BR 3001C, 4160V System One Line Diagram, 4160V Emergency SWGR Bus 1C & 1D, Rev. 1BR 3002, 480V System One Line Diagram, 460V Unit Substation 1A1 & 181, Sheet 4, Rev. 13BR 3002, 480V System One Line Diagram, 460V Unit Substation 1A2 & 1B.2, Sheet 2, Rev. 1 1BR 3002, 480V System One Line Diagram, 460V Unit Substation 1A3 & 183, Sheet 3, Rev. 9BR 3004, Reactor Building 460V MCC One Line Diagram,1A21 & 1421A., Sheet 1, Rev. 17BR 3004, Reactor Building 460V MCC One Line Diagram,1A21B & 1A23, Sheet 2, Rev. 14BR 3004, Reactor Building 460V MCC One Line Diagram,lB21 & 1821A, Sheet 3, Rev. '16BR 3004, Reactor Building 460V MCC One Line Diagram, 18.218 & 1823, Sheet 4, Rev. 18BR 3005, Misc. Building 460V MCC One Line Diagram, Sheet 2, Rev. 9BR 3005, Misc. Building 460V MCC One Line Diagram, Sheet 3, Rev. 14BR 3005, Misc. Building 460V MCC One Line Diagram, Sheet 4, Rev. 5Attachment

A-5BR 3005, Misc. Building 460V MCC One Line Diagram, Sheet 5, Rev. 13BR 3013, AC Vital Power System One Line Diagram, Vital MCC 1M & 182, Sheet 1, Rev. 13BR 3013, AC Vital Power System One Line Diagram, Vital MCC 1A82, 1A2 & 182, Sheet 2,BR 3028, 125V Station DC System One Line Diagram,125V DC Distribution Center A & B,MCC

DC-1, Sheet 1, Rev. 17BR 3038, Sheet 1N, Control Rod Drive System Electrical Elementary Diagram CRD FeedPumps P-15-001A and P-15-0018 Control lnterlock, Rev. 25BR 3138, Reactor Building Conduit Plan El. 51-3", Rev. 20DJP 3E-81 1-22-2001, Sheets 1 and 2, Fire Sprinkler System Expansion 4160V SwitchgearRoom and Fire Protection Hose Stations, Rev. 0DJP FBS

OB-FZ-68-01, Sheet 1, lsometric Fire Barrier (Mecatiss) B 480V Switchgear Room,Rev.0DJP FBS

OB-FZ-6B-02, Sheet 1, lsometric Fire Barrier (Mecatiss) B 480V Switchgear Room,Rev.0DJP FBS

OB-FZ-6B-03, Sheet 1, lsometric Fire Barrier (Mecatiss) B 480V Switchgear Room,Rev.0DJP FBS

OB-FZ-68-04, Sheet 1, lsometric Fire Barrier (Mecatiss) B 480V Switchgear Room,Rev.0DJP FBS

OB-FZ-6B-05, Sheet 1, lsometric Fire Barrier (Mecatiss) B 480V Switchgear Room,Rev.0E1132, Elementary Diagram 1A2-U033C CRD Feed Pump NC08A, Rev. 15EB D-3033,125V Station DC System One Line Diagram, 125V DC Distribution Center Cand MCC DC-z, Rev. 31EM

839790, Sheets 1 - 8, and 11 Emergency Diesel Generator #2Electrical Elementary WiringDiagram, Revs. 24,29, 12, 8,2, 4, 5, 4, and 2GE 103D5287, Sheets 2 and 3, Metalclad Switchgear Interconnection Diagram, Revs. 25 and29GE 112C2247, Sheetg, Main Control Room Panels Electrical Connection Diagram Panel 4F,Rev.32GE 112C2650, Sheet 4, Main Control Room Panel Electrical Connection Diagram Panel 5F/6F,Rev.24GE 112C2808, Sheet 3, Reactor Plant Instrumentation Electrical Connection DiagramInstrumentation Rack RK01, Reactor Prot 1A, 2A & NSSS, Rev. 13GE 112C3701, Sheets 2, 3 & 4, Electrical Connection Diagram Panel 10R, Revs. 19,22 and 14GE 148F712, Sheet 1, Reactor Vessel Level/Pressure/Temperature Instruments, Rev. 47GE 148F912, Sheets 1 and 3, Reactor Plant Instm Electrical Elementary Diagram, Rev. 7and 17GE 223R0173, Sheets 21 and 24, Core Spray System Electrical Elementary Diagram,Rev. 26 and 24GE719E211, Sheets 6,9 and 10, Main Control Room Panel Electrical Connection DiagramPanel 1Fl2F, Rev. 10,4 and 6GE719E251, Sheet 1, Panel ER18A, Rev.29GE719E252, Sheet 1, Panel ER188, Rev.27GE729E182, Sheets 1 - 5, Auto Depressurization Sys Electrical Elementary Diagram, Revs. 33,19, 19, 2, and2GU 3C-733-11-006, 120 AC Vital Power System Panel Schedule Instrument Panel 4, Rev. 5JC 19479, Sheet 1, Fire Protection Water System Flow Diagram, Rev. 38JC 19479, Sheet 3, Fire Protection Water System Flow Diagram, Rev. 68Attachment

A-6JC 19629, Sheet 1, Fire Protection Carbon Dioxide Flow Diagram, Rev.8JC 19629, Sheet 2, Fire Protection Halon Flow Diagram, Rev. 8NU 5060E6003, Sheets 2 and 4, Core Spray/RBCCW Drywell lsolation, Revs. 25 and 15SK 13432-42-APPR, Sheet 13, Location of Shutdown Ckis Appendix R Report 1't and 2"d FlrOffice Building, Rev.2SK 13432-42-APPR, Sheet 15, Tray ldentification Appendix R Report 1st g 2no Floor OfficeBuilding, Rev.0SK 13432-42-APPR, Sheet 16, Tray ldentification Appendix R Report 3'o Floor Office Building,Rev.0SK 13432-42-APPR, Sheet 19., Tray ldentification Appendix R Report Reactor Building E. 51'-3", Rev.0SK 13432-42-APPR, Sheet 22,Tray ldentification Appendix R Report Turbine BuildingBasement, Rev.0SK 13432-42-APPR, Sheet 23,Tray ldentification Appendix R Report Turbine BuildingMezzanine, Rev.0SK 13432-42-APPR, Sheet 7, Location of Shutdown Ckts Appendix R Report Turbine BuildingBasement, Rev. 1SK 13432-42-APPR, Sheet 8, Location of Shutdown Ckts Appendix R Report Turbine BuildingMezzanine, Rev. 1SN 13432-44-EE-03, Sheet 3, Connection and Wiring Diagram Analog, Rev. 10SN 15050-611-EE-238, Emergency Diesel Generators Connection Diagram Panel 8F/9F,Rev.8T3113, Turbine Building Conduit & Tray - Sections & Details, Rev. 4Piping and lnstrumentation Diaqrams3E-243-21-1000, Drywell and Torus Vacuum Relief System, Rev. 28BR 2002, Main Steam System, Sheet 1, Rev. 61BR 2002, Main Steam System, Sheet 2, Rev. 67BR 2003, Condensate/Feed System, Rev. 92BR 2004, Condensate Transfer System, Sheet 2, Rev. 94BR 2005, Emergency Service Water System, Sheet 4, Rev. 82BR 2006, Reactor Building Closed Cooling Water System, Sheet 1, Rev. 73BR 2006, Reactor Building Closed Cooling Water System, Sheet 2, Rev. 44BR 2006, Reactor Building Closed Cooling Water System, Sheet 3, Rev. 56BR 2010, Office Building HVAC - 480V Switchgear Room, Sheet 3, Rev. 23GE 148F262, Emergency Condenser System, Rev. 53GE 148F444, Clean-Up Demineralizer System, Rev.97GE 148F711, Shutdown Cooling System, Rev. 43GE 148F740, Containment Spray System, Rev. 43GE237E487, Control Rod Drive System, Rev.68GE 237E798, Recirculation System, Rev. 33GE 885D781, Core Spray System, Rev. 71GU 3E-243-21-1000, Drywell and Torus Vacuum Relief System, Rev. 28M0320, Flow Diagram Office Building 480V Switchgear Room Ventilation, Rev. 4Attachment

A-7Pre-Fire PlansOP-OC-201-008, OCGS Pre-Fire Plans, Rev. 12OP-OC-201-008-1018, OCGS Pre-Fire Plan for

OB-FZ-5, Rev. 1OP-OC-201-008-1023, OCGS Pre-Fire Plan for

OB-FZ-6B, Rev. 1OP-OC-201-008-1024, OCGS Pre-Fire Plan for

TB-FZ-11C,

TB-FA-26, Rev. 1OP-OC-201-008-1031, OCGS Pre-Fire Plan forTB-FZ-11B, Rev. 2Fire Brigade DocumentsFire System lmpairment Log, Dated 3114111OP-AA-201-001, Fire Marshall Tours, Rev. 5OP-AA-201-002, Fire Reports, Rev. 4OP-AA-201-003, Fire Drill Performance, Rev. 12OP-AA-201-004, Fire Prevention for Hot Work, Rev. 8OP-AA-201-005, Fire Brigade Qualification, Rev. 7OP-AA-201-006, Controlof Temporary Heat Sources, Rev.5OP-AA-201-007, Fire Protection System lmpairment Control, Rev. 6OP-AA-201-008, Pre-Fire Plan Manual, Rev. 3OP-AA-2O1-009, Control of Transient Combustible Material, Rev. 11Fire Brioade Drills. Critiques and TraininqFire Drif l Records and Critiques, Completed

9129110,

1120111,

2120111,

1115111,

1121111 ,2116111, and 3112111Learning Management System, Electronic Training RecordsOperator Safe Shutdown Trainino2621.882.0.0029, Initial License Training Simulator Exercise Guide - Plant Fire, Rev. 32621.882.0.00304, lnitial License Training Simulator Exercise Guide - Control RoomEvacuation, Rev. 32621.885.0.0023A, Licensed Operator Requalification Training Simulator Exercise Guide -Appendix R Secario 1, Fire in 480V Switchgear Room, Rev. 32621.885.0.0023E, Licensed Operator Requalification Training Simulator Exercise Guide -Station Fire in 4160V SWGR RM, Rev. 1Hot Work and lqnition Source Permitsc2019912c2025283M2212606R2111054R2173801Attachment

A-8Transient Com bustible Evaluations11-02, Transient Combustible Permit,

31711111-03, Transient Combustible Permit,

311111111-05, Transient Combustible Permit,

313111111-06, Transient Combustible Permit,

311811111-07, Transient Combustible Permit, 4110111Miscellaneous Documents990-6054, Underuvriters Laboratories Report, Test Deck 1, Dated 215196990-6056, Undenryriters Laboratories Report Test Deck 3, Dated 217196990-6058, Undenruriters Laboratories Report Test Deck 5, Dated 219196990-1704, Chemetron Fire Systems Halon 1301 Discharge Test, Dated 11117186EPRITR-106826, Battery Performance Monitoring By lnternal Ohmic Measurement, EmergencyLighting Unit Batteries, Dated 1219620030117-01, OCNGS Safe Shutdown Component and Cable Data Sheets, Rev.020021203-06, OCNGS Safe Shutdown Cable Location Sheets, Rev. 0Pull/Termination Sheet Cable 24-68Pull/Termination Sheet Cable 62-17 0Pull/Termination Sheet Cable 7 1 -109Pull/Termination Sheet Cable 82-197Pull/Termination Sheet Cable 1 1-332Pull/Termination Sheet Cable 1 1 -535lssue Reports059136606445390783645078582008070910815222081 98360822104083821608439320847756085743608775811058913105892610589771

0590501

0593611

0593951

0593951

0594501

0596361 06075410626121 08826910902231 09439310949891 1

386951 1

589301 1 590261159444116109311716721182345.1182450*1182462*1182707*1185944"1187591*1 1 87591 *1187849.1 1 87856.1 187909.11881171 1 8831 8*1 1 8881 6*1189197-1 1 93360.1194171.1 1 94591.1 194613.1 195389"84210284213188846991068793531 7977549978274* NRC identified during this inspection.Attachment Work OrdersR0804233R0804234R2033837R2069963R2073167R2073169R2073286R2088573R2093925R2095793R2096505R2096959R2097766R2097766ADAMSBTPCFRCMEBCRDDRPDRSFAFHARFPPFZIPIPEIPEEEIRNCVNFPANRCOCNGSP&IDPARsSDPSESERSRASRISUNSIUFSARVR2099815R2105776R2106913R21 10802R2112744R2114375R21 16503R2120040R2120833R2125725R2125839R2126149R2127854R2130173A-9R2130450R2131656R2132324R2132811R2133519R2134391R2135731R2137980R2139017R2139133R2142611R2145689R2147110R2147838

LIST OF ACRONYMS

R2150592R2150594R2150602R2156009R2156010R2156012R2159857R2160534R2161593R2165178R2165310R2166763R2168295R2169424Agencywide Documents Access and Management SystemBranch Technical PositionCode of Federal RegulationsChemical Engineering BranchControl Rod DriveDivision of Reactor ProjectsDivision of Reactor SafetyFire AreaFire Hazards Analysis ReportFire Protection ProgramFire ZoneInspection ProcedureIndividual Plant ExaminationIndividual Plant Examination of External Eventslssue ReportNon-Cited ViolationNational Fire Protection AssociationNuclear Regulatory CommissionOyster Creek Nuclear Generating StationPiping and Instrumentation DrawingPublicly Available RecordsSignificance Determination ProcessSafety EvaluationSafety Evaluation ReportSenior Risk AnalystSenior Resident lnspectorSensitive Unclassified Non-Safeguards lnformationUpdated Final Safety Analysis ReportVoltR2170362R2170758R2171458R2172589R2172590Attachment