C:\filenet\ml072400443.wpd

Mr. Christopher M. CranePresident and CNOExelon NuclearExelon Generation Company, LLC200 Exelon WayKennett Square, PA 19348 LIMERICK GENERATING STATION - NRC TRIENNIAL FIRE PROTECTIONINSPECTION REPORT 05000352/2007006 AND 05000353/2007006 On August 3, 2007, the NRC completed a triennial fire protection team inspection at yourLimerick Generating Station. The enclosed report documents the inspection results which werediscussed at an exit meeting on August 9, 2007, with Mr. C. Mudrick and other members ofyour staff.
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 your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewedpersonnel.
This report documents one NRC-identified finding of very low safety significance (Green). Thefinding was determined to involve a violation of NRC requirements. However, because of thevery low safety significance and because it was entered into your corrective action program, theNRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of theNRC Enforcement Policy. If you contest the NCV in this report, you should provide a responsewithin 30 days of the date of this inspection report, with the basis for your denial, to the NuclearRegulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; withcopies to the Regional Administrator, Region I; the Director, Office of Enforcement, UnitedStates Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC ResidentInspector at Limerick Generating Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) component ofNRC’s document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).
John F. Rogge, ChiefEngineering Branch 3Division of Reactor Safety Docket Nos. 50-352, 50-353License Nos. NPF-39, NPF-85 Enclosure: NRC Inspection Report 05000352/2007006 and 05000353/2007006 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC’s document system(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).
John F. Rogge, ChiefEngineering Branch 3Division of Reactor Safety Enclosure: NRC Inspection Report 05000352/2007006 and 05000353/2007006 SUNSI Review Complete: JFR (Reviewer’s Initials)
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cc w/encl:Chief Operating Officer, Exelon Generation Company, LLCSite Vice President - Limerick Generating StationPlant Manager, Limerick Generating StationRegulatory Assurance Manager - LimerickSenior Vice President - Mid-Atlantic OperationsSenior Vice President - Operations SupportVice President - Licensing and Regulatory AffairsDirector - Licensing and Regulatory Affairs, Exelon Generation Company, LLC Manager, Licensing - Limerick Generating StationVice President, General Counsel and SecretaryCorrespondence Control DeskDirector, Bureau of Radiation Protection, PA Department of Environmental ProtectionJ. Johnsrud, National Energy Committee, Sierra ClubChairman, Board of Supervisors of Limerick Township (via E-mail)
S. Collins, RAM. Dapas, DRAR. Laufer, RI OEDO H. Chernoff, NRRP. Bamford, PM, NRR J. Hughey, NRRJ. Lubinski, NRRM. Gamberoni, DRSJ. Rogge, DRSK. Young, DRSP. Krohn, DRPR. Fuhrmeister, DRPS. Hansell, DRP - Senior Resident InspectorC. Bickett, DRP - Resident Inspector L. Pinkham - Resident OARegion I Docket Room (with concurrences)ROPreports@nrc.gov DRS file Limerick Generating Station, Units 1 & 2 K. Young, Senior Reactor Inspector, DRS P. Finney, Reactor Inspector, DRSJ. Lilliendahl, Reactor Inspector, DRSO. Yee, Nuclear Safety Professional Development Program, DRS John F. Rogge, ChiefEngineering Branch 3 Division of Reactor Safety IR 05000352/2007006, 05000353/2007006; 07/16/2007 - 08/03/2007; Exelon Nuclear;Limerick Generating Station, Units 1 and 2; Triennial Fire Protection Team Inspection.
The report covered a two-week triennial fire protection team inspection by three Region Ispecialist inspectors. One Green finding was identified. The significance of most findings isindicated by their color (Green, White, Yellow) using Inspection Manual Chapter (IMC) 0609,“Significance Determination Process” (SDP). Findings for which the SDP does not apply maybe Green or be assigned a severity level after NRC management review. The NRC’s programfor overseeing the safe operation of commercial nuclear power reactors is described inNUREG-1649, “Reactor Oversight Process,” Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
Green. The team identified a finding of very low safety significance (Green) involving anon-cited violation of the Limerick Generating Station operating license, in that theprocedure for shutting down the plant in response to a fire in the cable spreading roomwas not consistent with the safe shutdown analysis. Specifically, impediments related tothe safe shutdown procedure would have prevented the operators from securing thehigh pressure coolant injection (HPCI) system within the design time limit. Fire inducedcable failures in the cable spreading room could allow HPCI to overfill the reactor vesselwhich would adversely affect the operation of the reactor core isolation cooling (RCIC)system and the main steam relief valves (MSRVs).
This issue was more than minor because it affected the procedure quality attributeassociated with the mitigating systems cornerstone as related to the objective ofensuring the reliability and availability of the RCIC system and MSRVs under postulatedfire scenarios. The finding was of very low safety significance based on a Phase 2Significance Determination Process (SDP) evaluation performed in accordance with IMC0609, Appendix F, “Fire Protection Significance Determination Process.” (Section1R05.01) This report presents the results of a triennial fire protection inspection conducted in accordancewith NRC Inspection Procedure (IP) 71111.05T, “Fire Protection.” The objective of theinspection was to assess whether Exelon Nuclear, has implemented an adequate fire protectionprogram and that post-fire safe shutdown capabilities have been established and are beingproperly maintained at the Limerick Generating Station (LGS). The following fire areas (FAs)were selected for detailed review based on risk insights from the LGS Individual PlantExamination of External Events (IPEEE): 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 evaluation reports (SERs), 10 CFR 50.48, and Branch Technical Position (BTP)Chemical Engineering Branch (CMEB) 9.5-1. The team also reviewed related documents thatincluded the Updated Final Safety Analysis Report (UFSAR), the fire hazards analysis (FHA),and the safe shutdown analysis.
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems Post-Fire Safe Shutdown From Outside the Main Control Room (Alternative Shutdown)and Normal Shutdown The team reviewed the safe shutdown analysis, operating procedures, piping andinstrumentation drawings (P&IDs), electrical drawings, the UFSAR and other supportingdocuments to verify that hot and cold shutdown could be achieved and maintained fromoutside 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 beperformed both with and without the availability of offsite power. Plant walkdowns werealso performed to verify that the plant configuration was consistent with that described inthe safe shutdown and fire hazards analyses. These inspection activities focused onensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation and supportsystems functions. The team verified that the systems and components credited for useduring post-fire safe shutdown would remain free from fire damage. The team verifiedthat the transfer of control from the control room to the alternative shutdown location(s)would not be affected by fire-induced circuit faults (e.g., by the provision of separatefuses and power supplies for alternative shutdown control circuits).
Similarly, for fire areas that utilize shutdown from the control room, the team alsoverified that the shutdown methodology properly identified the components and systemsnecessary to achieve and maintain safe shutdown conditions. 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 procedureswere trained, available onsite at all times, and exclusive of those assigned as firebrigade members.
The team reviewed the adequacy of procedures utilized for post-fire safe shutdown andperformed an independent walk through of procedure steps to ensure theimplementation and human factors adequacy of the procedures. The team also verifiedthat operators could reasonably be expected to perform specific actions within the timerequired to maintain plant parameters within specified limits. Time critical actions whichwere verified included restoring alternating current (AC) electrical power, establishingremote shutdown panel operation, establishing reactor coolant makeup, andestablishing decay heat removal.
Specific procedures reviewed for alternative shutdown, including shutdown from outsidethe control room included the following: 2FSSG-3023, Fire Area 23 Fire Guide, Revision 2; and 2FSSG-3068W, Fire Area 68W Fire Guide, Revision 2.
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 periodic testing records of the alternative shutdowntransfer capability and instrumentation and control functions to ensure the testsdemonstrated the functionality of the alternative shutdown capability.
Introduction: The team identified a finding of very low safety significance (Green)involving a violation of the LGS operating license, in that the procedure for shutting down the plant in response to a fire in the cable spreading room was not consistent withthe safe shutdown analysis. Specifically, human performance impediments related tothe safe shutdown procedure would have prevented the operators from securing highpressure coolant injection (HPCI) within the design time limit. Fire induced cable failuresin the cable spreading room could cause the spurious operation of the HPCI system andresult in overfill of the reactor vessel. This would affect the operation of reactor coreisolation cooling (RCIC) system and the main steam relief valves (MSRVs).
Description: LGS’s thermal hydraulic analysis for fire safe shutdown, G-080-VC-00028,analyzes a scenario where a fire in the cable spreading room causes a spurious start ofHPCI that also bypasses the HPCI level 8 automatic trip. For this scenario, there is aprotected switch at the remote shutdown panel which will secure HPCI. The analysisdetermined that for the worst case conditions, HPCI must be secured within fourminutes. If not secured promptly, HPCI would overfill the reactor vessel and waterwould enter the main steam lines which would adversely impact RCIC and the MSRVs. Operator action to secure the HPCI system is credited in the fire safe shutdown analysisfor the Unit 2 cable spreading room, LF-0016-023. During the inspection, several walkdowns conducted in the plant and in the simulatorwere performed to assess the ability to secure HPCI within the specified four minutes. During these walkdowns several complications were identified, two of which weresignificant. First, the single key required to secure the HPCI system was located insidea box containing sixty similar keys, but was not labeled for quick identification. Second,the procedure directing the operator to secure HPCI, procedure 2FSSG-3023, “FireArea 023 Fire Guide,” referred to a section in procedure SE-1, “Remote Shutdown,”which was ambiguous since the exact step was not referenced and the necessaryprerequisites were not identified. Based upon these human performance impedimentsand a demonstration conducted by the licensee which took nearly seven minutes tocomplete, the team had no confidence that the HPCI system could be secured within thefour minute time limit.
Corrective action program issue report (IR) 656185 was written to address this issue. LGS promptly added clear labeling for the HPCI key, revised all affected fire responseprocedures, and conducted operator training on securing HPCI following a postulatedfire in the cable spreading room. The team concluded that these corrective actions wereappropriate and provided reasonable assurance that a reactor vessel overfill event couldbe averted in the event of a spurious fire induced HPCI system initiation. A preliminaryevaluation by LGS concluded that the thermal hydraulic analysis, of record, was overlyconservative and that the time available to secure HPCI prior to vessel overfill may bebetween 6.5 to 7 minutes. The team learned that LGS was considering a revision to thedesign basis to extend the available time to the operators to secure HPCI.
The performance deficiency associated with this finding was that LGS failed to assurethat an important time requirement in the safe shutdown analysis was translated andproperly validated in the remote shutdown procedure. This deficiency resulted inoperators not being able to secure HPCI within the fire safe shutdown credited four minute time limit. The licensee entered this performance deficiency into their correctiveaction program for resolution. Analysis: The team referred to MC 0612 and determined this issue was more than minorbecause it affected the procedure quality attribute associated with the mitigatingsystems cornerstone as related to the objective of ensuring the reliability and availabilityof the RCIC system and MSRVs under postulated fire safe shutdown conditions. The team assessed this finding in accordance with NRC Manual Chapter 0609,Appendix F, “Fire Protection Significance Determination Process.” This finding affectedoperator response to postulated fires in the Unit 1 cable spreading room, the Unit 2cable spreading room, and the combined control room. Based upon the screeningcriteria of Appendix F and using conservative fire scenario characterizations (mediumdegradation) and propagation (frequency and confinement), this finding screened tovery low risk significance (Green) per Task No. 2.3.5. In support of this risk significanceconclusion, the team noted that the Unit 1 and 2 cable spreading rooms are designatedtransient combustible free zones, fire/smoke detection systems alarm in the controlroom, automatic sprinkler systems and manual CO suppression systems are installed, and the electrical cables installed are flame retardant in accordance with Institute ofElectrical and Electronic Engineers (IEEE) 383, “IEEE Standard for Qualifying Class 1EElectric Cables and Field Splices for Nuclear Power Generating Stations.” Similar firescenario assumptions and design attributes were credited with respect to postulatedfires in the control room and the team noted that the control room is continuouslymanned. Accordingly, the risk contribution to this finding associated with postulatedcontrol room fires is negligible. This significance determination was independentlyreviewed and verified by a Region I Senior Reactor Analyst.
Enforcement: License Condition 2.C.3 for LGS Unit 1 and Unit 2 states that, “Exelon
Nuclear shall implement and maintain in effect all provisions of the approved Fire
Protection Program as described in the UFSAR.” Appendix 9A of the UFSAR requires
the licensee to comply with BTP CMEB 9.5-1, position C.5.c, Alternative or Dedicated
Shutdown Capability. The BTP CMEB 9.5-1, position C.5.c.3 requires procedures to
implement the capability to perform alternative (remote) shutdown. Contrary to these
requirements, from approximately October 14, 2004, to August 3, 2007, the licensee’s
procedure for remote shutdown was not adequate to prevent overfilling of the reactor
vessel following a spurious, fire-induced start of HPCI. Because the finding was of very
low safety significance and has been entered into LGS’s corrective action program (IR
656185), this violation is being treated as a non-cited violation (NCV), consistent with
Section VI.A.1 of the NRC Enforcement Policy. NCV 05000352, 353/2007006-01,
Inadequate Fire Safe Shutdown Procedure for Securing HPCI.

The team reviewed the fire hazards analysis, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properlyprotected. The team ensured that separation requirements of the UFSAR, weremaintained for the credited safe shutdown equipment including supporting power,control and instrumentation cables. This review included an assessment of theadequacy of the selected systems for reactivity control, reactor coolant makeup, reactorheat removal, process monitoring, and associated support system functions.
The team reviewed the licensee’s procedures and programs for the control of ignitionsources and transient combustibles to assess their effectiveness in preventing fires andcontrolling combustible loading within limits established in the FHA. A sample of hotwork and transient combustible control permits were also reviewed. The teamperformed plant walkdowns to verify that protective features were being properlymaintained and administrative controls were being implemented.
The team also reviewed the licensee’s design control procedures to ensure that theprocess included appropriate reviews and controls to assess plant changes for anypotential adverse impact on the fire protection program and/or post-fire safe shutdownanalysis and procedures.
No findings of significance were identified.
The team walked down accessible portions of the selected fire areas to observe thematerial condition and design adequacy of fire area boundaries (including walls, firedoors and dampers), and electrical raceway fire barriers to ensure they were appropriatefor the fire hazards within the area.
The team reviewed installation/repair and qualification records for a sample ofpenetration seals to ensure the fill material was of the appropriate fire rating and that theinstallation met the engineering design. The team also reviewed similar records for fireprotection wraps to ensure the material was of an appropriate fire rating and that theinstallation met the engineering design.
No findings of significance were identified.
The team reviewed the design, maintenance, testing, and operation of the fire detectionand suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested,and maintained in accordance with the National Fire Protection Association (NFPA)code of record, or as NRC approved deviations, and that each suppression systemwould control or extinguish fires associated for the hazards in the selected areas. Areview of the design capability of suppression agent delivery systems was verified tomeet the code requirements for the fire hazards involved. The team also performed awalkdown of accessible portions of the detection and suppression systems in theselected areas as well as a walkdown of major support equipment in other areas (e.g.,fire pumps, carbon dioxide (CO ) storage tanks and supply system) and assessed the material condition of the systems and components.
The team reviewed electric and diesel fire pump flow and pressure tests to ensure thatthe pumps were meeting their design requirements. The team also reviewed the firemain loop flow tests to ensure that the flow distribution circuits were able to meet thedesign requirements.
The team assessed the fire brigade capabilities by reviewing training, qualification, anddrill critique records. The team reviewed pre-fire plans and smoke removal plans for theselected fire areas to determine if appropriate information was provided to fire brigademembers and plant operators to identify safe shutdown equipment and instrumentation,and to facilitate suppression of a fire that could impact post-fire safe shutdown. Inaddition, the team inspected the fire brigade’s protective ensembles, self-containedbreathing apparatus (SCBA), and various fire brigade equipment (including smokeremoval equipment) to verify fire fighting readiness.
No findings of significance were identified. Protection From Damage From Fire Suppression Activities The team reviewed documents and walked down the selected fire areas to verify thatredundant trains of systems required for hot shutdown were not subject to damage fromfire suppression activities or from the rupture or inadvertent operation of fire suppressionsystems. Specifically, the team verified that: A fire in one of the selected fire areas would not directly, through production ofsmoke, heat or hot gases, cause activation of suppression systems that couldpotentially damage all redundant safe shutdown trains.
A fire in one of the selected fire areas (or the inadvertent actuation or rupture ofa fire suppression system) would not directly cause damage to all redundant safeshutdown trains (e.g., sprinkler caused flooding of other than the locally affectedtrain).
Adequate drainage was provided in areas protected by water suppressionsystems.
No findings of significance were identified.
Alternative shutdown capability for the selected fire areas inspection utilizes shutdownfrom outside the control room and is discussed in Section 1R05.01 of this report.
The team verified that the licensee performed a post-fire safe shutdown analysis for theselected fire areas and that the analysis appropriately identified the structures, systems,and components important to achieving and maintaining post-fire safe shutdown. Additionally, the team verified that licensee’s analysis ensured that necessary electricalcircuits were properly protected and that circuits that could adversely impact safeshutdown due to hot shorts, shorts to ground, or other failures were identified,evaluated, and dispositioned to ensure spurious actuations would not prevent safeshutdown.
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, spuriousactuations, and actuations that could result in a loss of coolant event.
The team also reviewed cable routing data sheets and wiring diagrams for a sample ofcomponents to verify that all necessary cables had been included in the safe shutdownanalysis and that the routing ensures safe shutdown equipment cables remained freefrom fire damage.
Cable failure modes were reviewed for the following components: HV49-2F029, HV49-2F031, RCIC Suppression Suction Valves; HV49-2F012, HV49-2F013, RCIC Pump Discharge Valves; HV51-2F004A, HV51-2F006A, RHR Loop A Pump Suction Valves; HV51-2F017A, LPCI Outboard Containment Isolation Valve.
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. The team confirmed that the coordination studies addressed multiplefaults due to fire. Additionally, the team reviewed a sample of circuit breakermaintenance records to verify that circuit breakers for components required for post-firesafe shutdown were properly maintained in accordance with procedural requirements.
No findings of significance were identified.
The 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 theeffects of ambient noise levels, clarity of reception, reliability, and coverage patterns. The team also inspected the designated emergency storage lockers to verify theavailability of portable radios for the fire brigade and plant operators. The team alsoverified that communications equipment such as repeaters and transmitters would notbe affected by a fire.
No findings of significance were identified.
The team observed the placement and coverage area of eight-hour emergency lightsthroughout the selected fire areas and evaluated their adequacy for illuminating accessand egress pathways and any equipment requiring local operation and/orinstrumentation monitoring for post-fire safe shutdown. The team also verified that thebattery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests, and batteryreplacement practices were reviewed to verify that the emergency lighting was beingmaintained in a manner that would ensure reliable operation.
No findings of significance were identified.
The 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 specific in their design and licensing bases. The inspectors verified that therepair equipment, components, tools, and materials (e.g. pre-cut cables with preparedattachment lugs) were available and accessible on site.
No findings of significance were identified.
The 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.g., detection and suppression systems and equipment, passive firebarriers, 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 licensee was effective in returning the equipment to service in areasonable period of time.
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems Corrective Actions for Fire Protection Deficiencies The 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 completed or planned appropriate corrective actions.
No findings of significance were identified.
On August 9, 2007, the team presented the inspection results to Mr. C. Mudrick, SiteVice President, and other members of the site staff. No proprietary information wasincluded in this inspection report.
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
B. Dickinson, Director of EngineeringP. Gardner, D. Hamilton, Sr. Manager Engineering DesignR. Harding, C. Pragman, Corporate Fire ProtectionM. Taylor, J. Rogge, Chief, Engineering Branch 3, Division of Reactor SafetyW. Cook, Senior Reactor Analyst, Division of Reactor SafetyS. Hansell, Senior Resident Inspector, LGSC. Bickett, Resident Inspector, LGS LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Inadequate Fire Safe Shutdown Procedurefor Securing HPCI (Section 1R05.01) LIST OF DOCUMENTS REVIEWED
LGS, SER (NUREG 0991, 8/1983)LGS, SSER 2LGS, SSER 4LGS UFSAR, Section 9.5, Other Auxiliary Systems, Fire Protection ProgramLGS UFSAR, Section 9A, Fire Protection Evaluation Report Calculations/Engineering Evaluation Reports/Specifications LGS, Safe Shutdown Analysis for Fire Events, 5/1989 Thermal Hydraulic Analysis for Fire Events, Rev. 0 LGS, Assessment of Post Fire Safe ShutdownMethodology Changes, 12/1997 Walkdown Paths for FSSD Man. Actions/Repairs, Rev. 0 HPCI and RCIC Lds. During Fire Safe Shutdown, Rev. 0A Fire Area 12 Fire Safe Shutdown Analysis, Rev. 0 Fire Area 23 Fire Safe Shutdown Analysis, Rev. 1 Fire Area 68E Fire Safe Shutdown Analysis, Rev. 0 Fire Area 68W Fire Safe Shutdown Analysis, Rev. 1 Fire Area 79 Fire Safe Shutdown Analysis, Rev. 1 Specification for Post-Fire Safe Shutdown ProgramRequirements at LGS, Rev. 3 Moderate Energy Line Break Analysis for ReactorEnclosures, Rev. 6 MFPB Analysis - Fire Protection System Operation, Rev. 1 Load Circuit-Overcurrent Trip Devices, Rev. 8 Safeguard 208/120V AC Panel Circuit BreakerCoordination, Rev.1 Man. Water Spray Hydraulic Calc. Sys. WP-75, Rev.0 Man. Water Spray Hydraulic Calc. Sys. WP-75, Rev.0 Eval. of Ultra-Low Sulfur Diesel (ULSD) Fuel for DieselDriven Fire Pumps Control of Hazard Doors/Hatches/Panels at Limerick GeneratingStation (LGS), Rev.15 Fire Protection Program Configuration Change, Rev.1 Fire Protection Program Configuration Change Review, Rev.1 Performance Based Evaluations for Fire Protection, Rev.3 Fire Protection Program Performance Indicators, Rev.1 Fire Protection System Impairment Control, Rev.4 Control of Transient Combustible Material, Rev.5 Local and Remote Manual Startup of a Diesel Generator, Rev. 46 Protected Depressurization Control, Rev. 12 Functional Test of Alternate Shutdown Communication System,Rev. 11, Completed 4/24/2007 FSSD ELU 8 Hour Capacity Verification Test, Rev.9, Completed09/26/06 FSSD ELU 8 Hour Capacity Verification Test, Rev.9, Completed10/18/06 Inspection of Safe Shutdown Equipment, Completed 1/31/06,8/7/06, & 2/1/07 Verification of Operator Qualifications, Rev.11, Completed05/30/07 Fire Detection - Fire Detection Instrumentation ChannelFunctional Test and Supervisory Circuit Operability Test, Zones7,8,9,12,13,14 and 15, Rev.21, Completed 05/19/06, Rev.20,Completed 11/03/06 Fire Detection - Smoke Detection Instrumentation ChannelFunctional Test and Supervisory Circuit Operability Test, Zones21, 23, Rev.11, Completed 02/08/05, Rev.13, Completed 02/07/06 Fire Detection - Smoke Detection Instrumentation ChannelFunctional Test and Supervisory Circuit Operability Test, Zones68A, 68B, 68C, Rev.14, Completed 05/12/06, Rev.15, Completed02/21/07 Fire Detection - Fire Detection Instrumentation ChannelFunctional Test and Supervisory Circuit Operability Test, Zone 79,Rev.18, Completed 11/14/06 & 05/29/07 Fire Detection - Heat Detection Instrumentation ChannelFunctional Test and Supervisory Circuit Operability Test, Zone68A, Rev.9, Completed 12/15/06 & 07/21/06 Remote Shutdown System RCIC Operability Test, Completed6/2/2005 Remote Shutdown System RCIC Operability Test, Completed8/12/2005 Fire Rated Assembly Inspection, Rev.3, Completed 05/26/06,Rev.4, Completed 05/24/07 Spray and Sprinkler Visual Inspection, Rev.3, Completed 02/12/07 Underground Fire Main Flow Test, Rev.4, Completed 09/29/05 &09/29/06 Diesel Driven Fire Pump Flow Test, Rev.27, Completed 06/04/07,Rev.26, Completed 05/11/07 Diesel Driven Fire Pump Characteristic Curve Test, Rev.5,Completed 05/11/07, Rev.6, Completed 05/18/07 Motor Driven Fire Pump Characteristic Curve Test, Rev.3,Completed 12/26/05, Rev.5, Completed 06/26/07 Unit 1 and Common FSWS Operability Verification, Rev.0,Completed 12/16/06 Quality Assurance (QA) Audits and Self Assessments LGS, Focused Self-Assessment, Fire Protection Program, Rev. 4 LG 96-02491, UFSAR Change to Provide Explanatory Notes for Fire Drills, Rev.0LG-97-03146, Installation Package, ESW Pump A, 11/12/97LG-97-03148, Mod P000701-1:Installation Package, EDG 1AG501, 11/12/97LG 01-00897, Barriers and Defensive Positions - Control Structure, Rev.0 Reactor Building Units 1 & 2 Structural Steel Column Schedule,Rev.24 Reactor Building Units 1 & 2 Structural Steel Fire ProofingColumn Schedule, Rev.0 Control Room Area Interior Walls El.180'-0" to El.332'-0" Area 8,Rev.21 Single Line Meter & Relay Diagram 4 KV Safeguard PowerSystem 1 Unit, Rev. 27 Single Line Meter & Relay Diagram 4 KV Safeguard PowerSystem 2 Unit, Rev. 22 Single Line Meter & Relay Diagram Load Center Load TabulationSafeguard Load Center - 1 & 2 Units, Rev. 19 Single Line Diagram, 120V AC Power Supply HVAC SafeguardMOVs & Dampers Single Line Meter & Relay Diagram D114, D124, D134, D144,Safeguard Load Centers, 440 V - 1 Unit, Rev. 18 Single Line Meter & Relay Diagram D214, D224, D234, D244,Safeguard Load Centers, 440 V - 2 Unit, Rev. 17 Single Line Diagram Instrumentation AC System 1 Unit Single Line Diagram Instrumentation AC System 2 Unit Single Line Meter & Relay Diagram 125/250 VDC System 2 Unit Single Line Meter & Relay Diagram 125/250 VDC System 2 Unit Schematic Meter & Relay Diagram D11 & D12 Safeguard Buses,4KV 1 Unit, Rev. 18 Schematic Meter & Relay Diagram D13 & D14 Safeguard Buses,4KV 1 Unit, Rev. 20 Schematic Meter & Relay Diagram D21 & D22 Safeguard Buses,4KV 2 Unit, Rev. 19 Schematic Meter & Relay Diagram D23 & D24 Safeguard Buses,4KV 2 Unit, Rev. 21 Schematic Meter & Relay Diagram Diesel Generators, 4KV 1&2,Rev. 18 Schematic Block Diagram RHR System 1 & 2 Units, Rev. 33 Schematic Diagram RCIC System 1 & 2 Units, Rev. 28 Schematic Block Diagram Auto Depressurization & StandbyLiquid Control Systems - 1 & 2 Units Emergency Service Water Pumps - Common, Rev. 19 Schematic Diagram RHR Pumps 1 & 2 Units D11 Diesel Generator Control & Auxiliaries Communication & Fire Alarm Layout Turbine Enclosure Unit 1Above El.239'-0" & 254'-0", Rev.18 Communication & Fire Alarm Diesel Generator Enclosure Unit 1Above El.217'-0", Rev.7 Communication & Fire Alarm Layout Turbine Enclosure Unit 2Plan Above El.239'-0" & 254'-0", Rev.3 Communication & Fire Alarm Layout Reactor Enclosure - Unit 2Plan Above El.253'-0", Rev.10 Elementary Dia. Auto Depressurization System, Rev. 19 Elementary Dia. Auto Depressurization System, Rev. 7 Elementary Dia. Remote Shutdown System, Rev. 1 Elementary Diagram Reactor Core Isolation, Rev. 10 Elementary Diagram Reactor Core Isolation, Rev. 1 Heating, Venting & Air Conditioning Control Area Cable SpreadingRoom, Rev.32 Control Room Area Room 8 Interior Wall, Rev.13 Control Room Area 8 Interior Wall Elevations Wall Nos.59 thru 67& 107, Rev.11 Reactor Building Unit 2 Exterior Wall Penetrations Col. Line JAbove El.217'-0", Rev.9 Reactor Building Unit 2 Exterior Wall Penetrations Col. Line JAbove El.217'-0", Rev.3 Pipe or Conduit thru 3 Hour Rated Fire Barrier, Rev.0 Typical 3-Hour Fire Barrier Penetrations, Rev.1 Typical 3 Hr Fire Barrier Penetrations, Rev.1 9140052262, Lightguard F100 Vendor Manual, Rev.09140052272, Lightguard F85 Vendor Manual, Rev.0 Unit 1 D13 Emerg 4KV Switchgear Room 434 (El. 239) Fire Area 12,Rev.8, Rev.9 Unit 2 Cable Spreading Room (El.254') Fire Area 23, Rev.7, Rev.8 D11 Diesel Generator Room and Fuel Oil and Lube Oil Tank Room Rms311A and 312A (El.217) Fire Area 79, Rev.5, Rev.6 Unit 2 CRD Equipment and Neutron Monitoring Areas Rooms 475, 476,477, 479 (El.253) Fire Area 68, Rev.11 R1035635 09/29/06 R1048774 12/14/06R1048000 12/22/06 R1049330 12/16/06R0132865 07/21/06 R1047776 09/28/06R1047494 09/28/06 R0979387 02/09/05R0976593 09/23/04 R0971077 09/23/04R0960703 04/18/04 R0952167 03/26/04R1020651 06/01/06 R1013883 01/26/06R1035635 09/29/06 R1044553 09/28/06R1048774 12/14/06 R0966687 07/08/04R0964102 07/16/04 R0964993 07/22/04R0965532 07/29/04 R0962767 08/05/04 LGS Fire Brigade Training Records 01/25/06, 05/31/06. JPM: Emergency Power to 0B ESW Pump, Rev. 9 JPM: Emergency Power to RCIC Inboard Isolation Valve, Rev. 7 JPM: Alignment of Equip. for Manual Operation of LPCI, Rev. 2 JPM: Align. of Long Term Pneumatics for MSRV Op., Rev. 1 Licensed Oper. Requal, SE-1 and SE-6 In-Plant Training, Rev. 0 Licensed Operator Requal, Simulator Training Outline, Rev. 0 Lic. Oper. Requal, Fire Safe Shutdown Guides - SE-1-3, Rev. 0 Simulator Training Scenario, Fire in Cable Spread Room, Rev. 8 Shift Train. Doc., Prompt Action for HPCI Trip at RSP, 8/3/07 A1618979A1437776A1437799A1511486A1621745A1507935 Miscellaneous DocumentsArchival Operations Narrative Logs from 05/11/07 to 07/18/07Bisco Reports, 748-63-A 03/11/82, 748-64 01/15/82, 748-220 04/15/87INDMS - Cable Location ReportINDMS - Safe & Alternative Shutdown LogicsNRC Sup. Guid.
“Nuclear Plant Fire Protection Functional Responsibilities,”08/29/77 Battery Performance Monitoring by Internal OhmicMeasurements, 12/96 Pre-Operational Test Procedure 2P-13.2, Rev.0Startup Field Report 233D-007 Cable Spreading Room Unit 2IISCP for PSL-022-026 A1354849-E5, E8, E10-12A1605498A1615942273644 LIST OF ACRONYMS USED
Agency Documents Access and Management System Institute of Electrical & Electronic Engineers Individual Plant Examination of External Events Sensitive Unclassified Non-Safeguards Information

Source: http://www.appendixr.com/Inspections/2007_IRs/2007_Limerick_ML072400443.pdf

F:\coa opinions\14th\081601\991102f.wpd

Affirmed and Opinion filed August 9, 2001. Fourteenth Court of Appeals ____________ NO. 14-99-01102-CV ____________ DR. ARTHUR B. CONDE, Appellant VINCENT R. GARDNER, Appellee On Appeal from the 240th District Court Fort Bend County, Texas Trial Court Cause No. 99,829 A jury found that Dr. Arthur Conde (“Conde”), appellant, made defamatorystatements about Vince

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