ML042170111
| ML042170111 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/03/2004 |
| From: | Ogle C Division of Reactor Safety II |
| To: | Gannon C Carolina Power & Light Co |
| References | |
| IR-04-010 | |
| Download: ML042170111 (7) | |
See also: IR 05000324/2004010
Text
August 3, 2004
Carolina Power and Light Company
ATTN: Mr. C. J. Gannon
Vice President
Brunswick Steam Electric Plant
P. O. Box 10429
Southport, NC 28461
SUBJECT: NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
(NRC INSPECTION REPORT NOS. 05000325/2004010 AND
Dear Mr. Gannon:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
Region II staff will conduct a triennial fire protection baseline inspection of your Brunswick
Steam Electric Plant in November, 2004. The inspection team will be led by Mr. Charles Payne,
Senior Reactor Inspector, of the Region II Office. The team will be composed of personnel
from the NRC Region II Office. The inspection will be conducted in accordance with the NRCs
baseline fire protection inspection procedure 71111.05.
The inspection objective will be to evaluate your fire protection program implementation with
emphasis on post-fire safe shutdown capability and the fire protection features provided to
ensure at least one post-fire safe shutdown success path is maintained free of fire damage.
The inspection team will focus their review on the separation of the systems and equipment
necessary to achieve and maintain safe shutdown and fire protection features of selected fire
areas.
On August 3, 2004, during a telephone conversation with Mr. Steve Tabor, Senior Licensing
Analyst, our respective staffs confirmed arrangements for a three-day information gathering
onsite visit and a two-week onsite inspection. The schedule for the inspection is as follows:
- Information gathering onsite visit - Week of October 11-15, 2004
- Week 1 of onsite inspection - November 1-5, 2004
- Week 2 of onsite inspection - November 15-19, 2004
The purposes of the information gathering visit are to obtain information and documentation
needed to support the inspection, and to become familiar with the Brunswick fire protection
program, fire protection features, post-fire safe shutdown capabilities and plant layout. The
types of documents the team will be interested in reviewing, and possibly obtaining, are listed in
the Enclosure. Please contact Mr. Payne prior to preparing copies of the materials listed in the
Enclosure. The inspection team will try to minimize your administrative burden by specifically
identifying those documents required for inspection preparation.
CP&L 2
During the information gathering visit, the team will also discuss the following inspection support
administrative details - office space, specific documents to be made available to the team in its
office space, arrangements for reactor site access (including radiation protection training,
security, safety and fitness for duty requirements), and the availability of knowledgeable plant
engineering and licensing organization personnel to serve as points of contact during the
inspection.
We request that during the inspection weeks you ensure that copies of analyses, evaluations or
documentation regarding the implementation and maintenance of the Brunswick fire protection
program, including post-fire safe shutdown capability, be readily accessible to the team for its
review. Of specific interest are those documents which establish that your fire protection
program satisfies NRC regulatory requirements and conforms to applicable NRC and industry
fire protection guidance. Also, personnel should be available at the site during the inspection
who are knowledgeable regarding those plant systems required to achieve and maintain safe
shutdown conditions from inside and outside the control room (including the electrical aspects
of the relevant post-fire safe shutdown analyses), reactor plant fire protection systems and
features, and the Brunswick fire protection program and its implementation.
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRCs
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).
Your cooperation and support during this inspection will be appreciated. If you have questions
concerning this inspection, or the inspection teams information or logistical needs, please
contact Mr. Payne at (404) 562-4669, or me at (404) 562-4605.
Sincerely,
/RA: K. ODonohue for:/
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Docket Nos.: 50-325, 50-324
Enclosure: Triennial Fire Protection Inspection Support Documentation
cc w/encl:
W. C. Noll, Director
Site Operations
Brunswick Steam Electric Plant
Carolina Power & Light
Electronic Mail Distribution
(cc w/encl contd - See page 3)
CP&L 3
(cc w/encl contd)
David H. Hinds
Plant Manager
Brunswick Steam Electric Plant
Carolina Power & Light Company
Electronic Mail Distribution
James W. Holt, Manager
Performance Evaluation and
Regulatory Affairs PEB 7
Carolina Power & Light Company
Electronic Mail Distribution
Edward T. O'Neil, Manager
Support Services
Carolina Power & Light Company
Brunswick Steam Electric Plant
Electronic Mail Distribution
Lenny Beller, Supervisor
Licensing/Regulatory Programs
Carolina Power and Light Company
Electronic Mail Distribution
Steven R. Carr
Associate General Counsel - Legal Dept.
Progress Energy Service Company, LLC
Electronic Mail Distribution
John H. O'Neill, Jr.
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, NW
Washington, DC 20037-1128
Beverly Hall, Acting Director
Division of Radiation Protection
N. C. Department of Environment
and Natural Resources
Electronic Mail Distribution
Peggy Force
Assistant Attorney General
State of North Carolina
Electronic Mail Distribution
(cc w/encl contd - See page 4)
CP&L 4
(cc w/encl contd)
Chairman of the North Carolina
Utilities Commission
c/o Sam Watson, Staff Attorney
Electronic Mail Distribution
Robert P. Gruber
Executive Director
Public Staff NCUC
4326 Mail Service Center
Raleigh, NC 27699-4326
Public Service Commission
State of South Carolina
P. O. Box 11649
Columbia, SC 29211
David R. Sandifer
Brunswick County Board of
Commissioners
P. O. Box 249
Bolivia, NC 28422
Warren Lee
Emergency Management Director
New Hanover County Department of
Emergency Management
P. O. Box 1525
Wilmington, NC 28402-1525
Distribution w/encl.:
B. Mozafari, NRR
L. Slack, RII
OEMAIL
RIDSNRRDIPMIIPB
PUBLIC
OFFICE RII:DRS RII:DRP RII:DRS RII:DRS
NAME PAYNE FREDERICKSON ODONOHUE
DATE 08/ 3 /2004 08/ 3 /2004 08/ /2004 08/ 3 /2004
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
PUBLIC DOCUMENT YES NO
OFFICIAL RECORD COPY DOCUMENT NAME: C:\ORPCheckout\FileNET\ML042170111.wpd
Triennial Fire Protection Inspection Support Documentation
Note: This is a broad list of the documents the NRC inspection team may be interested
in reviewing, and possibly obtaining, during the information gathering site visit. The
current version of these documents is expected unless specified otherwise. Electronic
media is preferred, if readily available. (The preferred file format is searchable .pdf
files on CDROM. The CDROM should be indexed and hyperlinked to facilitate ease of
use. Please provide 5 copies of each CDROM submitted.) Information in lists should
contain enough information to be easily understood by someone who has a knowledge
of the technology. The lead inspector will discuss specific information needs with the
licensee staff and may request additional documents.
1. The Fire Protection Program document and the Fire Hazards Analysis.
2. The fire protection program implementing procedures (e.g., administrative controls,
surveillance testing, fire brigade).
3. The fire brigade training program document and the pre-fire plans for the selected fire
areas/zones (to be determined during information gathering visit).
4. The post-fire safe shutdown analysis, including system and separation analyses.
5. The alternative shutdown analysis.
6. Piping and instrumentation (flow) diagrams for the fire suppression systems.
7. Piping and instrumentation (flow) diagrams for the systems and components used to
achieve and maintain hot standby, and cold shutdown, for fires outside the control room.
8. Piping and instrumentation (flow) diagrams for the systems and components used to
achieve and maintain hot standby, and cold shutdown, in areas requiring alternative
shutdown capability.
9. Plant layout and equipment drawings which identify the physical plant locations of hot
standby and cold shutdown equipment.
10. Plant layout drawings which identify plant fire area and/or fire zone delineation, areas
protected by automatic fire suppression and detection, and the locations of fire
protection equipment for the selected fire areas/zones (to be determined during
information gathering visit).
11. Plant layout drawings which identify the general location of the post-fire emergency
lighting units.
12. Plant operating procedures used to, and describing, shutdown from inside the control
room with a postulated fire occurring in any plant area outside the control room
including, but not limited to, emergency, abnormal, normal and annunciator procedures.
Enclosure
2
13. Plant operating procedures used to implement the alternative shutdown capability from
outside the control room with a fire in either the control or cable spreading room (or any
other alternative shutdown area).
14. Maintenance and surveillance testing procedures for alternative shutdown capability
(including Appendix R emergency lights and communication systems) and fire barriers,
detectors, fire pumps and fire suppression systems.
15. Calculations and/or justifications that verify fuse/breaker coordination for the selected
fire areas/zones (to be determined during information gathering visit) that are fed off the
same electrical buses as components in the protected train. Also, a list of the
maintenance procedures used to routinely verify fuse/breaker coordination in
accordance with the post-fire safe shutdown coordination analysis.
16. A list of the significant fire protection and post-fire safe shutdown design change
descriptions (including their associated 10 CFR 50.59 evaluations) and Generic Letter
(GL) 86-10 evaluations.
17. A list of the protection methodologies (as identified in 10 CFR Part 50, Appendix R,
Section III.G) used to achieve regulatory compliance for the selected fire areas/zones
(to be determined during information gathering visit). That is, please specify whether 3-
hour rated fire barriers (Section III.G.2.a), 20-foot separation along with detection and
suppression (Section III.G.2.b), 1-hour rated fire barriers with detection and suppression
(Section III.G.2.c), or alternative shutdown capability (Section III.G.3) is used for the
selected fire areas/zones.
18. Procedures or instructions that govern the implementation of plant modifications,
temporary modifications, maintenance, and special operations, and their impact on fire
protection.
19. Organization chart(s) of site personnel down to the level of the fire protection staff.
20. Procedures or instructions that control the configuration of the fire protection program,
features, and post-fire safe shutdown methodology and system design.
21. A list of applicable codes and standards related to the design of plant fire protection
features and evaluations of code deviations (i.e., a listing of the NFPA code editions
committed to (Code of Record)).
22. The three most recent fire protection QA audits and/or fire protection self-assessments.
23. A list of open and closed fire protection problem identification and resolution reports
[also known as action reports/condition reports/problem reports/problem investigation
reports/NCRs/EARs] associated with fire protection or Appendix R safe shutdown for the
past three years.
Enclosure
3
24. A list of plant fire protection licensing basis documents (i.e., a list of the SERs and
change evaluations which form the licensing basis for the facilitys post-fire safe
shutdown configuration).
25. A list of fire protection or Appendix R calculations.
26. A list of fire impairments identified during the previous year.
27. A list of abbreviations/designators for plant systems.
Enclosure