ML070680318
| ML070680318 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/09/2007 |
| From: | Julio Lara Engineering Branch 3 |
| To: | Koehl D Nuclear Management Co |
| References | |
| IR-07-006 IR-07-006 | |
| Download: ML070680318 (11) | |
See also: IR 05000266/2007006
Text
March 9, 2007
Mr. Dennis L. Koehl
Site Vice President
Point Beach Nuclear Plant
Nuclear Management Company, LLC
6590 Nuclear Road
Two Rivers, WI 54241-9516
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - NOTIFICATION TO
CONDUCT A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
WHILE TRANSITION TO 10 CFR PART 50.48(c) IS IN PROGRESS
INSPECTION REPORT 05000266/2007006(DRS); 05000301/2007006(DRS)
Dear Mr. Koehl:
On June 25, 2007, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire
protection baseline inspection at the Point Beach Nuclear Plant, Units 1 and 2. The inspection
will be conducted in accordance with Inspection Procedure 71111.05TTP, the NRCs baseline
fire protection inspection procedure for plants in the process of implementing 10 CFR 50.48(c),
NFPA 805. The inspection guidance is different from the regular triennial inspections in that the
inspectors will concentrate on the fire protection program infrastructure and the adequacy of
compensatory measures implemented for identified departures from code requirements. The
inspectors will not routinely inspect for or evaluate circuit related issues.
The schedule for the inspection is as follows:
Information gathering visit - June 13 - 15, 2007
On-site inspection activity - June 25 - 29, 2007, and July 9 - 13, 2007
The purpose of the information gathering visit is to: (1) obtain information and documentation
needed to support the inspection; (2) become familiar with the Point Beach Nuclear Plants fire
protection program, fire protection features, post-fire safe shutdown capabilities and plant
layout; and (3) 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 May 9, 2007. The second
D. Koehl
-2-
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 June 13, 2007. The
third group of requested documents are those items that the inspection 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 (June 25, 2007). The fourth group lists the 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 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 M. Hausman. We understand that our
initial regulatory contact for this inspection is Ms. Fritzie Flentje 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), 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
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-266; 50-301
Enclosure:
Fire Protection Inspection Document Request
See Attached Distribution List
D. Koehl
-3-
cc w/encl:
F. Kuester, President and Chief
Executive Officer, We Generation
D. Cooper, Senior Vice President, Group Operations
J. McCarthy, Site Director of Operations
D. Weaver, Nuclear Asset Manager
Plant Manager
Regulatory Affairs Manager
Training Manager
Site Assessment Manager
Site Engineering Director
Emergency Planning Manager
J. Rogoff, Vice President, Counsel & Secretary
K. Duveneck, Town Chairman
Town of Two Creeks
Chairperson
Public Service Commission of Wisconsin
J. Kitsembel, Electric Division
Public Service Commission of Wisconsin
State Liaison Officer
D. Koehl
-2-
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 June 13, 2007. The
third group of requested documents are those items that the inspection 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 (June 25, 2007). The fourth group lists the 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 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 M. Hausman. We understand that our
initial regulatory contact for this inspection is Ms. Fritzie Flentje 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), 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
Engineering Branch 3
Division of Reactor Safety
Docket Nos.:
50-266; 50-301
License Nos.:
Enclosure:
Fire Protection Inspection Document Request
See Attached Distribution List
DOCUMENT NAME: C:\\FileNet\\ML070680318.wpd
G Publicly Available
G Non-Publicly Available
G Sensitive
G Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE RIII
RIII
RIII
NAME
GHausman: ls
PLouden
JLara
DATE
03/09/07
03/09/07
03/09/07
OFFICIAL RECORD COPY
D. Koehl
-3-
cc w/encl:
F. Kuester, President and Chief
Executive Officer, We Generation
D. Cooper, Senior Vice President, Group Operations
J. McCarthy, Site Director of Operations
D. Weaver, Nuclear Asset Manager
Plant Manager
Regulatory Affairs Manager
Training Manager
Site Assessment Manager
Site Engineering Director
Emergency Planning Manager
J. Rogoff, Vice President, Counsel & Secretary
K. Duveneck, Town Chairman
Town of Two Creeks
Chairperson
Public Service Commission of Wisconsin
J. Kitsembel, Electric Division
Public Service Commission of Wisconsin
State Liaison Officer
DISTRIBUTION:
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LXR1
RidsNrrDirsIrib
GEG
GLS
KGO
CAA1
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DRPIII
DRSIII
PLB1
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ROPreports@nrc.gov
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
Enclosure
1
Inspection Report: 05000266/2007006(DRS); 05000301/2007006(DRS)
Inspection Dates:
June 13 - 15, 2007
(Information Gathering Visit)
June 25 - 29, 2007
(On-site Inspection Activity)
July 9 - 13, 2007
(On-site Inspection Activity)
Inspection Procedures:
IP 71111.05TTP, Fire Protection-NFPA Transition Period (Triennial)
IP71111.05AQ, Fire Protection (Annual/Quarterly)
IP 71152, "Identification and Resolution of Problems"
Inspectors:
Lead Inspector:
George M. Hausman, (630) 829-9743
Team Members:
Alan K. Dahbur, (630) 829-9810
Dariusz Szwarc, (630) 829-9803
I.
Information Requested Prior to the Information Gathering Visit
The following information is requested by May 9, 2007. If you have any questions regarding
this information, please call the lead inspector as soon as possible. Please ensure that the
information to be provided in lists contain enough information to be easily understood by
someone who has a knowledge of the technology. All information should be sent to
Mr. George M. Hausman (e-mail address gmh1@nrc.gov). Electronic media is preferred, if
readily available. The preferred file format is a searchable .pdf file on a CDROM. The
CDROM should be indexed and hyper-linked to facilitate ease of use, if possible. Please
provide 4 copies of each CDROM submitted (one for each inspector and for a senior reactor
analysis).
(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 and/or 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, or where both safe shutdown trains can be affected.
(3)
A copy of the current version of the Fire Protection Program (FPP), Fire Hazards
Analysis (FHA), Safe Shutdown Analysis (SSA), Updated Safety Analysis Report
(USAR), Technical Specifications and License.
(4)
A copy of the current fire protection system Health Report, if available.
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
Enclosure
2
(5)
A copy of the current plant drawings referred to as Horse Notes, if available.
(6)
Status of 10 CFR 50.48(c), NFPA 805 implementation.
II.
Information Requested During the Information Gathering Visit
(June 13 - 15, 2007)
The following information is requested to be provided to the inspection team during the on-site
information gathering visit as one set of hard-copy documents. In addition, the requested
information is to be provided as a file searchable compact disc (CD), if possible. If a CD(s) can
be provided, three sets (one for each inspector) are requested.
(1)
Licensing Information
(a)
The Facilitys license, including the fire protection license condition;
(b)
All Nuclear Regulatory Commission (NRC) Safety Evaluation Reports (SERs)
applicable to fire protection (specifically including those SERs referenced by the
plant fire protection license condition) and all other associated licensing
correspondence applicable to fire protection;
(c)
The FPP and applicable portions of the USAR, as referenced by the fire
protection license condition;
(d)
Exemptions from 10 CFR 50.48 and 10 CFR Part 50, Appendix R, and
associated licensing correspondence;
(e)
For pre-1979 plants (i.e., Appendix R plants), a listing of all 10 CFR Part 50,
Appendix R sections and paragraphs that are applicable to the plant under
(f)
For pre-1979 plants, all licensing correspondence associated with those sections
of 10 CFR Part 50, Appendix R, that are not applicable to the plant under
10 CFR 50.48(b)(1). Specifically, the licensing correspondence associated with
those fire protection features proposed or implemented by the licensee that have
been accepted by the NRC staff as satisfying the provisions of Appendix A to
Branch Technical Position (BTP) APCSB 9.5-1 reflected in the NRC fire
protection SERs issued before February 19, 1981 (10 CFR 50.48(b)(1)(i)); or
those fire protection features which were accepted by the NRC staff in
comprehensive fire protection SERs issued before Appendix A to BTP
APCSB 9.5-1 was published in August 1976 (10 CFR 50.48(b)(1)(ii));
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
Enclosure
3
(g)
For post-1979 plants, all licensing correspondence associated with the
comparison to Standard Review Plan (NUREG-0800), Section 9.5.1 or
equivalent for licensing purposes; and
(h)
For plants intending to transition to NFPA 805, provide: (1) all correspondence
to and responses from the NRC, (2) a list of all areas showing assessment
review status, (3) assessments for all areas that have been completed, (4) a list
of all identified non-conformances, and their respective compensatory
measure(s).
(2)
(a)
If not already provided under request II.(1)(c) above, FPP documents including
(b)
A listing of changes made to the FPP (including associated adverse to SSA);
(c)
For pre-1979 plants, 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 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barriers;
(Section III.G.2.a), 20 foot separation along with detection and suppression;
(Section III.G.2.b), 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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;
(d)
A list of Generic Letter 86-10 evaluations (i.e., a list of adverse to safe shutdown
evaluations);
(e)
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);
(f)
A list of plant deviations from code commitments and associated evaluations;
(g)
Plant layout drawings which identify plant fire area delineation, areas protected
by automatic fire suppression and detection, and the locations of fire protection
equipment.
(3)
Facility Information
(a)
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;
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
Enclosure
4
(b)
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);
(c)
Plant layout drawings which identify the general location of the post-fire
emergency lighting units;
(d)
One-line schematic drawings of the electrical distribution system for
4160 Volts alternating current (Vac) down to 480 Vac;
(e)
One-line schematic drawings of the electrical distribution system for
250 Volts direct current (Vdc) and 125 Vdc systems as applicable; and
(f)
Safe shutdown cable routing database (requested electronically such as on
compact disc, if available).
(4)
Operations Response for Fire Protection
(a)
Pre-fire plans for selected fire zones/areas (to be determined during
information gathering visit);and.
(b)
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).
(5)
Corrective Actions
(a)
Listing of open and closed fire protection condition reports (i.e., problem
identification forms and their resolution reports) since the date of the last triennial
fire protection inspection; and
(b)
Listing of fire impairments since the date of the last triennial fire protection
inspection.
(6)
General Information
(a)
A listing of abbreviations and/or designators for plant systems;
(b)
Organization charts of site personnel down to the level of fire protection staff
personnel; and
(c)
A phone list for on-site licensee personnel.
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
Enclosure
5
(7)
On-Site Discussions
In addition, during the information gathering visit, it is requested that licensee staff be
available for the following:
(a)
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;
(b)
Informal discussion on the plants safe shutdown cable routing database and the
plant-wide cable routing database, as applicable; and
(c)
A tour of alternative shutdown and risk significant fire areas.
III.
Information Requested to be Available on First Day of Inspection
(June 25, 2007)
(1)
Procedures
(a)
List of the FPP implementing procedures (e.g., administrative controls,
surveillance testing, fire brigade);
(b)
List of maintenance and surveillance testing procedures for alternative shutdown
capability and fire barriers, detectors, pumps, and suppression systems;
(c)
List of maintenance procedures which routinely verify fuse breaker coordination
in accordance with the post-fire safe shutdown coordination analysis;
(d)
List of procedures and/or instructions that control the configuration of the reactor
plant's FPP, features, and post-fire safe shutdown methodology and system
design; and
(e)
List of procedures and/or instructions that govern the implementation of plant
modifications, maintenance, and special operations, and their impact on fire
protection.
(2)
Design and Equipment Information
(a)
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;
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
Enclosure
6
(b)
Copies of significant fire protection and post-fire safe shutdown related design
change package descriptions (including their associated 10 CFR Part 50.59
evaluations) and Generic Letter (GL) 86-10 (or adverse to safe shutdown)
evaluations;
(c)
Gaseous suppression system pre-operational testing, if applicable, for selected
fire zones/areas (to be determined during information gathering visit);
(d)
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);
(e)
Alternating current (ac) coordination calculations for 4160 Vac down to 480 Vac
electrical systems;
(f)
Vendor manuals and information for fire protection equipment (such as
detection, suppression systems, fire pumps), applicable to selected fire
zones/areas (to be determined during information gathering visit); and
(g)
List of all fire protection or Appendix R calculations.
(3)
Assessment and Corrective Actions
(a)
The three most recent fire protection Quality Assurance (QA) audits and/or fire
protection self-assessments; and
(b)
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.
IV.
Information Requested to Be Provided Throughout the Inspection
(1)
Copies of any corrective action documents generated as a result of the inspection
teams questions or queries during this inspection.
(2)
Copies of the list of questions submitted by the inspection team members and the
status/resolution of the information requested (provided daily during the inspection to
each inspection team member).