ML043360326
| ML043360326 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/01/2004 |
| From: | Julio Lara NRC/RGN-III/DRS/EEB |
| To: | Domonique Malone Nuclear Management Co |
| References | |
| IR-05-003 | |
| Download: ML043360326 (8) | |
See also: IR 05000255/2005003
Text
December 1, 2004
Mr. Daniel J. Malone
Site Vice President
Palisades Nuclear Plant
Nuclear Management Company, LLC
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT:
PALISADES NUCLEAR PLANT
NOTIFICATION OF AN NRC TRIENNIAL FIRE PROTECTION BASELINE
INSPECTION 05000255/2005003(DRS)
Dear Mr. Malone:
On January 10, 2005, the NRC will begin a triennial fire protection baseline inspection at the
Palisades Nuclear Plant. This inspection will be performed in accordance with the NRC
baseline Inspection Procedure 71111.05.
The schedule for the inspection is as follows:
Information gathering visit: December 20 - 22, 2004
On-site inspection activity: January 10 - 14, 2005 and January 24 - 28, 2005
The purpose of the information gathering visit is: (1) to obtain information and documentation
needed to support the inspection; (2) to become familiar with the Palisades Nuclear Plant fire
protection programs, fire protection features, post-fire safe shutdown capabilities and plant
layout; and (3) to arrange administrative details such as office space, availability of
knowledgeable office personnel and to ensure unescorted site access privileges.
Experience has shown that the baseline fire protection inspections are extremely resource
intensive both for the NRC inspectors and the licensee staff. In order to minimize the
inspection impact on the site and to ensure a productive inspection for both organizations, we
have enclosed a request for documents needed for the inspection. These documents have
been divided into four groups. The first group lists information necessary to aid the inspection
team in choosing specific focus areas for the inspection. It is requested that this information be
provided to the lead inspector via mail or electronically no later than December 6, 2004. The
second group lists information necessary to ensure that the inspection team is adequately
prepared for the inspection. This information should be available on-site no later than
December 20, 2004. The third group of requested documents are those items that the team will
review, or need access to, during the inspection. Please have this information available by the
first day of the on-site portion of the inspection (January 10, 2005). The fourth group lists
information necessary to aid the inspection team in tracking issues identified as a result of the
inspection. It is requested that this information be provided to the lead inspector as the
D. Malone
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information is generated during the inspection. It is important that all of these documents are
up to date and complete in order to minimize the number of additional documents requested
during the preparation and/or the on-site portions of the inspection.
The lead inspector for this inspection is Mr. George Hausman. We understand that our
regulatory contact for this inspection is Ms. Barb Dotson of your organization. If there are any
questions about the inspection or the material requested, please contact the lead inspector at
(630) 829-9743 or via e-mail at gmh1@nrc.gov.
In accordance with 10 CFR 2.390 of the NRC's "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 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).
Sincerely,
/RA/
Julio F. Lara, Chief
Electrical Engineering Branch
Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure:
Fire Protection Inspection Document Request
cc w/encl:
J. Cowan, Executive Vice President
and Chief Nuclear Officer
R. Fenech, Senior Vice President, Nuclear
Fossil and Hydro Operations
D. Cooper, Senior Vice President - Group Operations
Manager, Regulatory Affairs
J. Rogoff, Vice President, Counsel and Secretary
A. Udrys, Esquire, Consumers Energy Company
Director of Nuclear Assets, Consumers Energy Company
Supervisor, Covert Township
Office of the Governor
Michigan Department of Environmental Quality -
Waste and Hazardous Materials Division
Michigan Department of Attorney General
D. Malone
-2-
information is generated during the inspection. It is important that all of these documents are
up to date and complete in order to minimize the number of additional documents requested
during the preparation and/or the on-site portions of the inspection.
The lead inspector for this inspection is Mr. George Hausman. We understand that our
regulatory contact for this inspection is Ms. Barb Dotson of your organization. If there are any
questions about the inspection or the material requested, please contact the lead inspector at
(630) 829-9743 or via e-mail at gmh1@nrc.gov.
In accordance with 10 CFR 2.390 of the NRC's "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 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).
Sincerely,
/RA/
Julio F. Lara, Chief
Electrical Engineering Branch
Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure:
Fire Protection Inspection Document Request
cc w/encl:
J. Cowan, Executive Vice President
and Chief Nuclear Officer
R. Fenech, Senior Vice President, Nuclear
Fossil and Hydro Operations
D. Cooper, Senior Vice President - Group Operations
Manager, Regulatory Affairs
J. Rogoff, Vice President, Counsel and Secretary
A. Udrys, Esquire, Consumers Energy Company
Director of Nuclear Assets, Consumers Energy Company
Supervisor, Covert Township
Office of the Governor
Michigan Department of Environmental Quality -
Waste and Hazardous Materials Division
Michigan Department of Attorney General
DOCUMENT NAME: E:\\Filenet\\ML043360326.wpd
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy
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DATE
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11/30/04
12/01/04
OFFICIAL RECORD COPY
D. Malone
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INITIAL DOCUMENT REQUEST
Enclosure
1
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Inspection Report: 05000255/2005003(DRS)
Inspection Dates:
December 20 - 22, 2004
(Information Gathering)
January 10 - 14, 2005
(On-site Inspection Activity)
January 24 - 28, 2005
(On-site Inspection Activity)
Inspection Procedures:
IP 71111.05, Fire Protection
IP 71152, "Identification and Resolution of Problems"
Inspectors:
Lead Inspector:
George M. Hausman
Team Members:
Audrey L. Klett
Darrell L. Schrum
Information Requested Prior to the Information Gathering Visit
The following information is requested by December 6, 2004. If you have any questions
regarding this information, please call the lead inspector as soon as possible. All information
may be sent electronically (to Mr. George M. Hausman, e-mail address gmh1@nrc.gov) or
provided on compact disc (preferred method).
(1)
The reactor plant's Individual Plant Examination for External Events (IPEEE) for fire,
results of any post-IPEEE reviews for fire, and listings of actions taken/plant
modifications conducted in response to IPEEE information for fire. Alternatively,
probabilistic risk analyses for fire and associated information, if it exists and is more
recent than the IPEEE.
(2)
A list of fire areas requiring alternative shutdown capability, i.e., those areas for which
10 CFR Part 50, Appendix R, Section III.G requirements are satisfied under
Section III.G.3.
Information Requested During the Information Gathering Visit (December 20 - 22, 2004)
This information is requested to be available on-site during the information gathering visit.
(1)
The current version of the Fire Protection Program and Fire Hazards Analysis.
(2)
Listing of plant fire protection licensing basis documents.
(3)
Copies of the NRC Safety Evaluation Reports (SERs) and of the 50.59 reviews which
form the licensing basis for the reactor plant's post-fire safe shutdown configuration.
(4)
A list of Generic Letter 86-10 evaluations.
INITIAL DOCUMENT REQUEST
Enclosure
2
(5)
A list of applicable codes and standards related to the design of plant fire protection
features. The list should include National Fire Protection Association (NFPA) code
versions committed to (i.e., the NFPA codes of record).
(6)
A list of plant deviations from code commitments.
(7)
Post-fire safe shutdown analyses, including post-fire safe shutdown systems and
separation analysis.
(8)
Piping and instrumentation (flow) diagrams showing the components used to achieve
and maintain hot standby and cold shutdown for fires outside the control room and those
components used for those areas requiring alternative shutdown capability.
(9)
Plant layout and equipment drawings which identify the physical plant locations of hot
standby and cold shutdown equipment for selected fire zones/areas (to be determined
during information gathering visit).
(10)
Plant layout drawings which identify plant fire area delineation, areas protected by
automatic fire suppression and detection, and the locations of fire protection equipment
for selected fire zones/areas (to be determined during information gathering visit).
(11)
Listing of open and closed fire protection condition reports (problem identification forms
and their resolution reports) for the past three years.
(12)
Listing of fire impairments for the previous year.
(13)
Pre-fire plans for selected fire zones/areas (to be determined during information
gathering visit).
(14)
Plant operating procedures which would be used and describe shutdown for a
postulated fire in selected fire zones/areas (to be determined during information
gathering visit).
(15)
A listing of the protection methodologies identified under 10 CFR Part 50, Appendix R,
Section III.G used to achieve compliance for selected fire zones/areas (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 each
selected fire zone/area.
(16)
One-line schematic drawings of the electrical distribution system for 4160 Volts -
alternating current (Vac) down to 480 Vac.
(17)
One-line schematic drawings of the electrical distribution system for 250 Volts - direct
current (Vdc) and 125 Vdc systems as applicable.
INITIAL DOCUMENT REQUEST
Enclosure
3
(18)
A listing of abbreviations/designators for plant systems.
(19)
Organization charts of site personnel down to the level of fire protection staff personnel.
(20)
A phone list for on-site licensee personnel.
In addition, during the information gathering visit, it is requested that licensee staff be available
for the following:
(1)
Informal discussion on plant procedures operators would use in the event of fire and
under what conditions would the plant be shutdown using alternative shutdown
methodology.
(2)
Informal discussion on the plants safe shutdown cable routing database and the plant-
wide cable routing database, as applicable.
(3)
A tour of alternative shutdown and risk significant fire areas.
Information Requested to be Available on First Day of Inspection (January 10, 2005)
(1)
List of the fire protection program implementing procedures (e.g., administrative
controls, surveillance testing, fire brigade).
(2)
List of maintenance and surveillance testing procedures for alternative shutdown
capability and fire barriers, detectors, pumps and suppression systems.
(3)
List of maintenance procedures which routinely verify fuse breaker coordination in
accordance with the post-fire safe shutdown coordination analysis.
(4)
List of procedures/instructions that control the configuration of the reactor plant's fire
protection program, features, and post-fire safe shutdown methodology and system
design.
(5)
List of procedures/instructions that govern the implementation of plant modifications,
maintenance, and special operations, and their impact on fire protection.
(6)
Coordination calculations and/or justifications that verify fuse/breaker coordination for
selected fire zones/areas (to be determined during information gathering visit) that are
fed off of the same electrical buses as components in the protected safe shutdown train.
(7)
Copies of significant fire protection and post-fire safe shutdown related design change
package descriptions (including their associated 10 CFR 50.59 evaluations) and Generic Letter (GL) 86-10 evaluations.
(8)
Gaseous suppression system pre-operational testing, if applicable, for selected fire
zones/areas (to be determined during information gathering visit).
Enclosure
4
(9)
Hydraulic calculations and supporting test data which demonstrate operability for water
suppression systems, if applicable, for selected fire zones/areas (to be determined
during information gathering visit).
(10)
Alternating current (AC) coordination calculations for 4160 Vac down to 480 Vac
electrical systems.
(11)
The three most recent fire protection Quality Assurance (QA) audits and/or fire
protection self-assessments.
(12)
Corrective action documents (e.g., condition reports, including status of corrective
actions) generated as a result of the three most recent fire protection Quality Assurance
(QA) audits and/or fire protection self-assessments.
Information Requested to Be Provided Throughout the Inspection
(1)
Copies of any corrective action documents generated as a result of the teams questions
or queries during this inspection.
(2)
Copies of the list of questions submitted by the team members and the status/resolution
of the information requested (provide daily during the inspection to each team member).