ML071420152

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Notification of an NRC Triennial Fire Protection Baseline Inspection 05000528-07008; 05000529-07-008; and 05000530-07-008 - Letter
ML071420152
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 05/21/2007
From: Laura Smith
Division of Reactor Safety IV
To: Edington R
Arizona Public Service Co
References
IR-07-008
Download: ML071420152 (8)


See also: IR 05000528/2007008

Text

May 21, 2007

Randall K. Edington

Senior Vice President, Nuclear

Mail Station 7602

Arizona Public Service Company

P.O. Box 52034

Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION - NOTIFICATION OF AN

NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

05000528/2007008; 05000529/2007008; AND 05000530/2007008

Dear Mr. Edington:

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 Palo Verde

Nuclear Generating Station in July and August 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 71111.05T, "Fire Protection (Triennial),"

the NRCs baseline fire protection inspection procedure.

The schedule for the inspection is as follows:

  • Information gathering visit: July 10 - 11, 2007
  • Onsite inspection: July 23 - 27, and August 13 - 17, 2007

Members of the inspection team will visit the Palo Verde Nuclear Generating Station on

July 10 and 11, 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 that will be required by three separate dates to allow for effective preparation by the

team prior to the first onsite week. We would appreciate it if you could send this information as

requested in the enclosure. Please note that several documents are requested by

June 18, 2007, to assist in our contractors preparation and by June 25, 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

Arizona Public Service Company -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 is appreciated. If you have questions

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

contact Mr. Greg Pick at 817-860-8270.

Sincerely,

/RA/

Linda J. Smith, Chief

Engineering Branch 2

Division of Reactor Safety

Dockets: 50-528; 50-529; 50-530

Licenses: NPF-41; NPF-51; NPF-74

Enclosure:

Triennial Fire Protection Inspection

Documentation Requested

cc:

Steve Olea

Arizona Corporation Commission

1200 W. Washington Street

Phoenix, AZ 85007

Douglas K. Porter, Senior Counsel

Southern California Edison Company

Law Department, Generation Resources

P.O. Box 800

Rosemead, CA 91770

Chairman

Maricopa County Board of Supervisors

301 W. Jefferson, 10th Floor

Phoenix, AZ 85003

Aubrey V. Godwin, Director

Arizona Radiation Regulatory Agency

4814 South 40 Street

Phoenix, AZ 85040

Arizona Public Service Company -3-

Scott Bauer, Acting General Manager

Regulatory Affairs and

Performance Improvement

Palo Verde Nuclear Generating Station

Mail Station 7636

P.O. Box 52034

Phoenix, AZ 85072-2034

Jeffrey T. Weikert

Assistant General Counsel

El Paso Electric Company

Mail Location 167

123 W. Mills

El Paso, TX 79901

John W. Schumann

Los Angeles Department of Water & Power

Southern California Public Power Authority

P.O. Box 51111, Room 1255-C

Los Angeles, CA 90051-0100

John Taylor

Public Service Company of New Mexico

2401 Aztec NE, MS Z110

Albuquerque, NM 87107-4224

Geoffrey M. Cook

Southern California Edison Company

5000 Pacific Coast Hwy, Bldg. N50

San Clemente, CA 92672

Robert Henry

Salt River Project

6504 East Thomas Road

Scottsdale, AZ 85251

Brian Almon

Public Utility Commission

William B. Travis Building

P.O. Box 13326

1701 North Congress Avenue

Austin, TX 78701-3326

Arizona Public Service Company -4-

Karen O'Regan

Environmental Program Manager

City of Phoenix

Office of Environmental Programs

200 West Washington Street

Phoenix, AZ 85003

Matthew Benac

Assistant Vice President

Nuclear & Generation Services

El Paso Electric Company

340 East Palm Lane, Suite 310

Phoenix, AZ 85004

Arizona Public Service Company -5-

Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (RJC1)

Senior Resident Inspector (GXW2)

Branch Chief, DRP/D (NFO)

Senior Project Engineer, DRP/D (RLN1)

Senior Project Engineer, DRP/D (GEW)

Team Leader, DRP/TSS (FLB2)

RITS Coordinator (MSH3)

DRS STA (DAP)

V. Dricks, PAO (VLD)

D. Cullison, OEDO RIV Coordinator (DGC)

ROPreports

PV Site Secretary (PRC)

SUNSI Review Completed: JLS ADAMS: O Yes G No Initials: JLS

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

SRI:EB2 C:EB2

GAPick LJSmith

/RA/ GAPick for

5/21/2007 5/21/2007

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

ENCLOSURE

Triennial Fire Protection Inspection Documentation Requested

Please provide the following documentation no later than June 18, 2007, to our contractor,

Ken Sullivan, at Brookhaven National Laboratory. Since the inspection team also needs this

information, please send a copy to Region IV by July 13, 2007, along with the other requested

information below beginning at Item 8. Where practical, please provide copies electronically on

compact discs.

1. A list of equipment used to achieve and maintain hot and cold shutdowns in the event of

a fire (safe shutdown equipment lists).

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

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

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

3. 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.

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

preferably no later than June 25, 2007. Where practical, please provide copies electronically on

compact discs.

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

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

acceptable plant response.

6. 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.).

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

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

July 10 and 11, 2007, or via mail by noon on July 13, 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.

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

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

-1- Enclosure

9. 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).

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

capability with or without control room evacuation.

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

information-gathering trip).

12. 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.

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

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

protection.

14. Procedures related to the corrective action program. Also a summary list with a short

subject description of corrective action program documents (CRDRs) related to fire

protection equipment, the fire protection program, fire barriers, procedure issues, et

cetera (i.e., a broad search of any areas discussed and evaluated as part of this

inspection).

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

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

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

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

the fire protection program or equipment.

18. 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.

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

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

studies or calculations which support the design basis.

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

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

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

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

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

-2- Enclosure

24. 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.

25. 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.

26. 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 January 1, 2004.

27. 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.

28. 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).

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

giving location and the key equipment being protected.

30. 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.

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

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

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.

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

week of August 13, 2007. Please provide contact information for the appropriate

personnel for planning drills during the onsite information gathering trip.

36. 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 July 23, 2007.

-3- Enclosure