ML070860659
| ML070860659 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/27/2007 |
| From: | Julio Lara Engineering Branch 3 |
| To: | Harden P Nuclear Management Co |
| References | |
| IR-07-005 | |
| Download: ML070860659 (13) | |
Text
March 27, 2007 Mr. Paul A. Harden Site Vice President Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES NUCLEAR PLANT, UNIT 1 - NOTIFICATION TO CONDUCT A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION WHILE TRANSITION TO 10 CFR PART 50.48(c) IS IN PROGRESS INSPECTION REPORT 05000255/2007005(DRS)
Dear Mr. Harden:
On May 7, 2007, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire protection baseline inspection at the Palisades Nuclear Plant, Unit 1. 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 April 17-19, 2007.
On-site inspection activity May 7-11, 2007, and May 21-25, 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 Palisades 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 April 9, 2007. The second group lists
P. Harden information necessary to ensure that the inspection team is adequately prepared for the inspection. This information should be available on-site no later than April 17, 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 (May 7, 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 following fire areas were selected for this inspection: Emergency Diesel Generator 1-1 Room; (Fire Area 5); Intake Structure/Screen House (Fire Area 9); Battery Room No. 1 (Fire Area 11); and the Component Cooling Water Room (Fire Area 16).
The lead inspector for this inspection is Mr. Zelig Falevits. We understand that our initial regulatory contact for this inspection is Ms. Barbara Dotson of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at (630) 829-9717 or via e-mail at zxf@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 by AM Stone Acting For/
Julio F. Lara, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-255 License Nos. DPR-20
Enclosure:
Fire Protection Inspection Document Request See Attached Distribution List
P. Harden cc w/encl:
M. Sellman, President and Chief Executive Officer R. Fenech, Senior Vice President, Nuclear Fossil and Hydro Operations D. Cooper, Senior Vice President - Group Operations L. Lahti, Manager, Regulatory Affairs J. Rogoff, Vice President, Counsel and Secretary A. Udrys, Esquire, Consumers Energy Company S. Wawro, Director of Nuclear Assets, Consumers Energy Company Supervisor, Covert Township Office of the Governor State Liaison Office, State of Michigan L. Brandon, Michigan Department of Environmental Quality -
Waste and Hazardous Materials Division
P. Harden information necessary to ensure that the inspection team is adequately prepared for the inspection. This information should be available on-site no later than April 17, 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 (May 7, 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 following fire areas were selected for this inspection: Emergency Diesel Generator 1-1 Room; (Fire Area 5); Intake Structure/Screen House (Fire Area 9); Battery Room No. 1 (Fire Area 11); and the Component Cooling Water Room (Fire Area 16).
The lead inspector for this inspection is Mr. Zelig Falevits. We understand that our initial regulatory contact for this inspection is Ms. Barbara Dotson of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at (630) 829-9717 or via e-mail at zxf@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 by AM Stone Acting For/
Julio F. Lara, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos.:
50-255 License Nos.:
Enclosure:
Fire Protection Inspection Document Request See Attached Distribution List DOCUMENT NAME: C:\\FileNet\\ML070860659.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 ZFalevits for DSchrum: ls CLipa AMStone for JLara DATE 03/27/07 03/ /07 03/26/07 OFFICIAL RECORD COPY
P. Harden cc w/encl:
M. Sellman, President and Chief Executive Officer R. Fenech, Senior Vice President, Nuclear Fossil and Hydro Operations D. Cooper, Senior Vice President - Group Operations L. Lahti, Manager, Regulatory Affairs J. Rogoff, Vice President, Counsel and Secretary A. Udrys, Esquire, Consumers Energy Company S. Wawro, Director of Nuclear Assets, Consumers Energy Company Supervisor, Covert Township Office of the Governor State Liaison Office, State of Michigan L. Brandon, Michigan Department of Environmental Quality -
Waste and Hazardous Materials Division DISTRIBUTION:
MLC TEB RidsNrrDirsIrib GEG KGO GLS JBG JAE CAA1 DRPIII DRSIII PLB1 TXN
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION Request for Information Enclosure 1
Inspection Report: 05000255/2007005(DRS)
Inspection Dates:
April 17-19, 2007 (Information Gathering Visit)
May 7-11, 2007 (On-site Inspection Activity)
May 21-25, 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 Problem Inspectors:
Lead Inspector:
Zelig Falevits, (630) 829-9717 Team Members:
Darrell Schrum, (630) 829-9741 Mohammad Munir, (630) 829-9797 I.
Information Requested Prior to the Information Gathering Visit The following information is requested by April 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. Zelig Falevits (e-mail address zxf@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 four 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.
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION Request for Information 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 (April 17-19, 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. The following fire areas were selected for this inspection: Emergency Diesel Generator 1-1 Room, (Fire Area 5); Intake Structure/Screen House (Fire Area 9); Battery Room No. 1 (Fire Area 11); and the Component Cooling Water Room (Fire Area 16).
(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 10 CFR 50.48(b)(1);
(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));
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION Request for Information 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)
If not already provided under request II.(1)(c) above, FPP documents including FHA and post-fire SSA; (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 (see list above). 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; (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;
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION Request for Information 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 (see list above);
(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 (see list above);and.
(b)
Plant operating procedures which would be used and describe shutdown for a postulated fire in selected fire zones/areas (see list above).
(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.
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION Request for Information 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 (May 7, 2007)
(1)
Design and Equipment Information (a)
Coordination calculations and/or justifications that verify fuse/breaker coordination for selected fire zones/areas (see list above) that are fed off of the same electrical buses as components in the protected safe shutdown train; (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 (see list above);
(d)
Hydraulic calculations and supporting test data which demonstrate operability for water suppression systems, if applicable, for selected fire zones/areas (see list above);
(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 (see list above); and (g)
List of all fire protection or Appendix R calculations.
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION Request for Information Enclosure 6
(2)
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.
(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).
If you have questions regarding any of the information requested, please contact the lead inspector.