ML070720214

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Notification of an NRC Triennial Fire Protection Baseline Inspection While Transition to 10 CFR Part 50.48(c) Is in Progress (05000298-07-006)
ML070720214
Person / Time
Site: Cooper Entergy icon.png
Issue date: 03/12/2007
From: Laura Smith
Division of Reactor Safety IV
To: Minahan S
Nebraska Public Power District (NPPD)
References
IR-07-006
Download: ML070720214 (8)


See also: IR 05000298/2007006

Text

March 12, 2007

Stewart B. Minahan, Vice

President-Nuclear and CNO

Nebraska Public Power District

72676 648A Avenue

Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - NOTIFICATION OF AN NRC TRIENNIAL FIRE

PROTECTION BASELINE INSPECTION WHILE TRANSITION TO

10 CFR PART 50.48 (c) IS IN PROGRESS. (05000298/2007006)

Dear Mr. Minahan:

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 Cooper Nuclear

Station in May and June of 2007. The inspection team will be comprised of reactor inspectors

from the NRC Region IV office and a contractor. 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 for 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:

May 9 - 10, 2007

Onsite inspection:

May 21 - 25, 2007

June 11 - 15, 2007

Members of the inspection team will visit the Cooper Nuclear Station on May 9 - 10, 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 the fire areas of interest for

the inspection. The enclosure to this letter provides a list of documents the team will need to

review. You are requested to transmit copies of some of the documents to the NRC Region IV

office for team use in preparation for the inspection by the dates listed.

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

Nebraska Public Power District

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protection program satisfies NRC regulatory requirements and conforms to applicable NRC

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

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, (4) the current fire protection program and its

implementation, and (5) the NFPA 805 implementation program 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 John M. Mateychick at 817-276-6560.

Sincerely,

/RA/

Linda J. Smith, Chief

Engineering Branch 2

Division of Reactor Safety

Docket: 50-298

License: DPR-46

Enclosure: Triennial Fire Protection

Inspection Documentation Requested

cc w/enclosure:

Gene Mace

Nuclear Asset Manager

Nebraska Public Power District

P.O. Box 98

Brownville, NE 68321

John C. McClure, Vice President

and General Counsel

Nebraska Public Power District

P.O. Box 499

Columbus, NE 68602-0499

P. V. Fleming, Licensing Manager

Nebraska Public Power District

P.O. Box 98

Brownville, NE 68321

Nebraska Public Power District

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Michael J. Linder, Director

Nebraska Department of

Environmental Quality

P.O. Box 98922

Lincoln, NE 68509-8922

Chairman

Nemaha County Board of Commissioners

Nemaha County Courthouse

1824 N Street

Auburn, NE 68305

Julia Schmitt, Manager

Radiation Control Program

Nebraska Health & Human Services

Dept. of Regulation & Licensing

Division of Public Health Assurance

301 Centennial Mall, South

P.O. Box 95007

Lincoln, NE 68509-5007

H. Floyd Gilzow

Deputy Director for Policy

Missouri Department of Natural Resources

P. O. Box 176

Jefferson City, MO 65102-0176

Director, Missouri State Emergency

Management Agency

P.O. Box 116

Jefferson City, MO 65102-0116

Chief, Radiation and Asbestos

Control Section

Kansas Department of Health

and Environment

Bureau of Air and Radiation

1000 SW Jackson, Suite 310

Topeka, KS 66612-1366

Daniel K. McGhee, State Liaison Officer

Bureau of Radiological Health

Iowa Department of Public Health

Lucas State Office Building, 5th Floor

321 East 12th Street

Des Moines, IA 50319

Nebraska Public Power District

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Don Flater, Radiation Control

Program Director

Bureau of Radiological Health

Iowa Department of Public Health

Lucas State Office Building, 5th Floor

321 East 12th Street

Des Moines, IA 50319

Ronald D. Asche, President

and Chief Executive Officer

Nebraska Public Power District

1414 15th Street

Columbus, NE 68601

Kevin V. Chambliss, Director of

Nuclear Safety Assurance

Nebraska Public Power District

P.O. Box 98

Brownville, NE 68321

John F. McCann, Director, Licensing

Entergy Nuclear Northeast

Entergy Nuclear Operations, Inc.

440 Hamilton Avenue

White Plains, NY 10601-1813

Keith G. Henke, Planner

Division of Community and Public Health

Office of Emergency Coordination

930 Wildwood, P.O. Box 570

Jefferson City, MO 65102

Nebraska Public Power District

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Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (RJC1)

Senior Resident Inspector (SCS)

Branch Chief, DRP/C (MCH2)

Senior Project Engineer, DRP/C (WCW)

Team Leader, DRP/TSS (MAS3)

RITS Coordinator (MSH3)

DRS STA (DAP)

D. Cullison, OEDO RIV Coordinator (DGC)

ROPreports

CNS Site Secretary (SEF1)

W. A. Maier, RSLO (WAM)

R. E. Kahler, NSIR (REK)

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

Publicly Available G Non-Publicly Available

G Sensitive

Non-Sensitive

R:\\_REACTORS\\_CNS\\2007\\CNS FPT Notification Letter.wpd

DRS/EB2/SRI

C: EB2

JMMateychick(lar)

LJSmith

/RA/

/RA/

3/9/2007

3/9/2007

OFFICIAL RECORD COPY

T=Telephone E=E-mail F=Fax

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Enclosure

ENCLOSURE

Triennial Fire Protection Inspection Documentation Requested

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

preferably no later than April 30, 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 any 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 during the onsite information gathering trip May 9 -

10, 2007. 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,

surveillance testing).

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.

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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.

A listing of Generic Letter 86-10 evaluations performed in the last 3 years.

15.

A listing of open and closed fire protection condition reports 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 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.

Maintenance and surveillance testing procedures for alternative shutdown capability and

fire barriers, detectors, pumps and suppression systems.

22.

Maintenance Rule performance criteria and 3 years worth of 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 within the last 3 years.

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.

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Enclosure

26.

Electronic copies of operator study guides (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.

Please provide a list of automatic and manually initiated gaseous fire suppression

systems in the plant, giving location and the key equipment being protected.

29.

Please provide 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.

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

week of June 11, 2007. Please put us in contact with the appropriate personnel for

planning drills during the onsite information gathering trip May 9 - 10, 2007.

33.

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

34.

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

of their office and phone number onsite.