ML070320675

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Notification of an NRC Triennial Fire Protection Baseline Inspection 05000361-07-008; 05000362-07-008
ML070320675
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/31/2007
From: Laura Smith
Division of Reactor Safety IV
To: Rosenblum R
Southern California Edison Co
References
IR-07-008
Download: ML070320675 (8)


See also: IR 05000361/2007008

Text

January 31, 2007

Richard M. Rosenblum

Senior Vice President and

Chief Nuclear Officer

San Onofre, Units 2 and 3

Southern California Edison Co.

P.O. Box 128

San Clemente, California 92674-0128

SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION - NOTIFICATION OF AN

NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

050000361/2007008; 050000362/2007008

Dear Mr. Rosenblum:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC),

Region IV staff will conduct a triennial fire protection baseline inspection at the San Onofre

Nuclear Generating Station in March and April of 2007. The inspection team will be comprised

of reactor inspectors from the NRC Region IV office and two contractors. The inspection will be

conducted in accordance with Inspection Procedure 71111.05, "Fire Protection," the NRCs

baseline fire protection inspection procedure.

The schedule for the inspection is as follows:

  • Information gathering visit: March 13 - 15, 2007
  • Onsite inspection: March 26 - 30, and April 9 - 13, 2007

Members of the inspection team will visit the San Onofre Nuclear Generating Station on

March 13 -15, 2007, to gather information and documents needed to support the inspection,

obtain unescorted access, to become familiar with your fire protection program, and to select

fire areas on which to focus the inspection. The enclosure to this letter provides a list of the

documents the team will want to review for use in preparing for the inspection. We would

appreciate it if you could send this information so that it will arrive in our office in Arlington,

Texas, no later than noon on March 19, 2007. Please note that several documents are

requested by March 5, 2007 to support the information gathering trip.

We request that during the onsite inspection weeks, you ensure that copies of analyses,

evaluations, or documentation regarding the implementation and maintenance of the fire

protection program, including post-fire safe shutdown capability, be readily accessible to the

team for their review. Of specific interest are those documents that establish that your fire

protection program satisfies NRC regulatory requirements and conforms to applicable NRC

and industry fire protection guidance. Also, appropriate personnel knowledgeable of: (1) those

Southern California Edison Co. -2-

plant systems required to achieve and maintain safe shutdown conditions from inside and

outside the control room, (2) the electrical aspects of the post-fire safe shutdown analyses,

(3) reactor plant fire protection systems, and (4) the fire protection program and its

implementation should be available to support the team at the site during the inspection.

Your cooperation and support during this inspection will be appreciated. If you have questions

concerning this inspection or the inspection team's information or logistical needs, please

contact Neil OKeefe at 817-860-8269.

Sincerely,

/RA

Linda J. Smith, Chief

Engineering Branch 2

Division of Reactor Safety

Enclosure: Triennial Fire Protection

Inspection Supporting Documentation

Dockets: 50-361; 50-362

Licenses: NPF-10; NPF-15

cc w/enclosure:

Chairman, Board of Supervisors

County of San Diego

1600 Pacific Highway, Room 335

San Diego, CA 92101

Gary L. Nolff

Assistant Director-Resources

City of Riverside

3900 Main Street

Riverside, CA 92522

Mark L. Parsons

Deputy City Attorney

City of Riverside

3900 Main Street

Riverside, CA 92522

Ray W. Waldo

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

Southern California Edison Co. -3-

David Spath, Chief

Division of Drinking Water and

Environmental Management

California Department of Health Services

P.O. Box 942732

Sacramento, CA 94234-7320

Michael R. Olson

San Onofre Liaison

San Diego Gas & Electric Company

8315 Century Park Ct. CP21G

San Diego, CA 92123-1548

Director, Radiological Health Branch

State Department of Health Services

P.O. Box 997414 (MS 7610)

Sacramento, CA 95899-7414

Mayor

City of San Clemente

100 Avenida Presidio

San Clemente, CA 92672

James D. Boyd, Commissioner

California Energy Commission

1516 Ninth Street (MS 34)

Sacramento, CA 95814

Douglas K. Porter, Esq.

Southern California Edison Company

2244 Walnut Grove Avenue

Rosemead, CA 91770

James T. Reilly

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

Daniel P. Breig

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

Southern California Edison Co. -4-

A. Edward Scherer

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

Brian Katz

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

Southern California Edison Co. -5-

Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (RJC1)

Senior Resident Inspector (CCO1)

Branch Chief, DRP/D (TWP)

Senior Project Engineer, DRP/D (GEW)

Team Leader, DRP/TSS (RLN)

RITS Coordinator (MSH3)

DRS STA (DAP)

ROPreports

SO Site Secretary ()

SUNSI Review Completed: ljs ADAMS: Yes G No Initials: ljs

Publicly Available G Non-Publicly Available G Sensitive Non-Sensitive

R:\_SO\2007\SO2007008-ltr-nfo.wpd

RIV: DRS/E2B/SRI C: EB2

NFOkeefe LJSmith

/RA/ /RA/

1/30/07 1/30/07

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE

Triennial Fire Protection Inspection Documentation Requested

Please provide the following documentation prior to the onsite information gathering trip,

preferably no later than March 5, 2007. Where practical, please provide copies electronically

on compact discs.

1. The current version of your fire protection program and fire hazards analysis.

2. Post-fire safe shutdown analysis and the supporting calculations which demonstrate

acceptable plant response.

3. Copies of the licensing basis documents for fire protection (Safety Evaluation Reports,

pertinent sections of the Final Safety Analysis Report, exemptions, deviations, letters

to/from the NRC regarding fire protection/fire safe shutdown, etc.).

4. The Fire PRA or portions of the plants IPEEE addressing fire events.

Please provide the following documentation, either during the onsite information gathering trip

March 13 - 15, 2007, or by noon on March 19, 2007, in order to support inspection preparation.

Where practical, please provide copies electronically on compact discs. However, drawings

should be provided as paper copies of sufficient size that all details are legible.

5. Fire protection program implementing procedures (e.g., administrative controls, operator

response procedures for fires, fire fighting procedures, etc.).

6. Operating procedures used for achieving and maintaining hot and cold shutdown

conditions from the control room in the event of a fire outside the control room (III.G.2

areas).

7. Operating procedure(s) used to implement an alternative shutdown (III.G.3 areas)

capability with or without control room evacuation.

8. Pre-fire plans for the selected fire areas (areas to be selected by the team during the

information-gathering trip).

9. A list of equipment used to achieve and maintain hot standby and cold shutdowns in the

event of a fire (safe shutdown equipment lists).

10. Piping and instrumentation (flow) diagrams showing the components used to achieve

and maintain hot standby and cold shutdowns for fires outside the control room and

those components used for those areas requiring alternative shutdown capability. Two

copies of the piping and instrumentation (flow) diagrams for these systems of a size

sufficient to read all details. These should include the systems used for RCS makeup,

RCS pressure control, decay heat removal, and reactivity control, including the essential

support systems.

Enclosure

11. Plant layout and equipment drawings for the selected fire areas that identify (a) the

physical plant locations of major hot standby and cold shutdown equipment; (b) plant fire

area and/or fire zone delineation; and (c) the locations of fire protection equipment, such

as detection, suppression, and post-fire emergency lighting units, and (d) fire area

boundaries.

12. Procedures/instructions that govern the implementation of plant modifications,

temporary modifications, maintenance, and special operations, and their impact on fire

protection.

13. A listing of design change packages, which were determined to impact fire protection

and post-fire safe shutdowns, performed in the last 3 years.

14. Copies of Generic Letter 86-10 evaluations performed in the last 3 years.

15. A listing of open and closed action requests initiated in the last 3 years which relate to

the fire protection program or equipment.

16. A listing of the applicable codes and standards (e.g. NFPA) related to the design of

plant fire protection features and evaluations of any code deviations.

17. Drawings of the portions of the emergency lighting system which support fire response.

18. Procedures used to remove smoke from safety-related areas and the engineering

studies or calculations which support the design basis.

19. Drawings of communication systems credited in the license basis for firefighting and

plant operations during fires where control room is occupied and/or evacuated.

20. Piping and instrumentation (flow) diagrams for the fire water and sprinkler systems.

21. A listing of maintenance and surveillance testing procedures for alternative shutdown

capability and fire barriers, detectors, pumps and suppression systems.

22. Maintenance Rule performance criteria and a summary of the last 3 years performance

history for fire protection program systems or functions monitored within the

Maintenance Rule program.

23. A copy of fire protection program requirements (e.g. limiting conditions for operation,

surveillance test requirements) covered by Technical Specifications, Technical

Requirements Manual, UFSAR, or similar documents.

24. Copies of internal and external self-assessments, audits, peer-assessments or similar

reviews related to post-fire safe shutdown capability or the fire protection program

completed since May 1, 2004.

25. A list of manual actions taken outside the control room which are credited to mitigate the

consequences of fires in III.G.2 areas (non-alternative shutdown areas). The list should

group actions by the initiating fire area or zone and indicate where the action must take

place.

-2- Enclosure

26. Electronic copies of operator study guides (i.e. lesson plan text and graphics) or design

basis documents that describe the purpose/function/operating characteristics of the safe

shutdown systems (RCS makeup, RCS pressure control, decay heat removal, and

reactivity control, including the essential support systems).

27. Two copies of one-line diagrams of the electrical distribution system. These should

depict how power gets from the switchyard to ESF loads (480V and 4160V). Also,

include the vital DC distribution system one-line diagrams.

28. A list of automatic and manually initiated gaseous fire suppression systems in the plant,

giving location and the key equipment being protected.

29. A list of repairs (and the procedure that controls the actions) needed to: a) reach and/or

maintain hot shutdown; b) reach and/or maintain cold shutdowns.

30. A list of high to low pressure interface valves.

31. A copy of procedures governing the training and operation of the fire brigade.

32. Organization charts of site personnel down to the level of fire protection staff personnel.

33. A contact list of key site personnel who will be supporting this inspection, giving location

of their office and phone number onsite.

34. The team would like to observe a fire brigade drill in the plant, if possible, during the

week of March 26, 2007. Please put us in contact with the appropriate personnel for

planning drills during the onsite information gathering trip.

35. The team would like to perform a walkthrough of the procedure for control room due to

fire with qualified operators in the plant during the week of March 26, 2007. Please put

us in contact with the appropriate personnel for planning the walkthrough during the

onsite information gathering trip.

-3- Enclosure