ML072150184

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Notification of Triennial Fire Portection Baseline Inspection (NRC Inspection Report 05000261/2007007)
ML072150184
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 08/01/2007
From: Payne D
NRC/RGN-II/DRS/EB2
To: Walt T
Carolina Power & Light Co
References
IR-07-007
Download: ML072150184 (8)


See also: IR 05000261/2007007

Text

August 1, 2007

Carolina Power and Light Company

ATTN: Mr. T. D. Walt

Vice President

H. B. Robinson Steam Electric Plant Unit 2

3581 West Entrance Road

Hartsville, SC 29550

SUBJECT: NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

(NRC INSPECTION REPORT 05000261/2007007)

Dear Mr. Walt:

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

Region II staff will conduct a triennial fire protection baseline inspection at the H. B. Robinson

Steam Electric Plant, Unit 2 in October 2007. The inspection team will be led by Mr. Reinaldo

Rodriguez, NRC Reactor Inspector, of the Region II Office. The team will be composed of

personnel from the NRC Region II Office. 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) and National Fire Protection Association

Standard (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. Inspection of circuit analysis is not included in the inspection procedure,

however, electrical topics will be addressed by the team.

On August 1, 2007, during a telephone conversation between Mr. Richard Hightower, of your

staff, and Mr. Shakur Walker, of the NRC Region II Office, our respective staffs confirmed

arrangements for a three-day information gathering onsite visit and a two-week onsite

inspection. The schedule for the inspection is as follows:

  • Information gathering visit: October 2 - 4, 2007
  • Week 1 of onsite inspection: October 22 - 26, 2007
  • Week 2 of onsite inspection: November 5 - 9, 2007

The purposes of the information gathering visit are to obtain information and documentation

needed to support the inspection, and to become familiar with the H.B. Robinson Steam Electric

Plant fire protection program, fire protection features, post-fire safe shutdown capabilities and

plant layout. The types of documents the team will be interested in reviewing, and possibly

obtaining, are listed in the Enclosure.

Please contact Mr. Rodriguez prior to preparing copies of the materials listed in the Enclosure.

The inspection team will try to minimize your administrative burden by specifically identifying

those documents required for inspection preparation.

CP&L 2

During the information gathering visit, the team will also discuss the following inspection support

administrative details - office space; specific documents to be made available to the team in its

office space; arrangements for reactor site access (including radiation protection training,

security, safety and fitness for duty requirements); and the availability of knowledgeable plant

engineering and licensing organization personnel to serve as points of contact during the

inspection.

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

documentation regarding the implementation and maintenance of the H.B. Robinson Steam

Electric Plant fire protection program, including post-fire safe shutdown capability, be readily

accessible to the team for its review. Of specific interest are those documents which establish

that your fire protection program satisfies NRC regulatory requirements and conforms to

applicable NRC and industry fire protection guidance. Also, personnel should be available at

the site during the inspection who are knowledgeable regarding those plant systems required to

achieve and maintain safe shutdown conditions from inside and outside the control room

(including the electrical aspects of the relevant post-fire safe shutdown analyses), reactor plant

fire protection systems and features, and the H. B. Robinson Steam Electric Plant fire

protection program and its implementation.

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 Mr. Rodriguez at (404) 562-4498, or me at (404) 562-4669.

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 NRCs document system

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

D. Charles Payne, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No.: 50-261

License No.: DPR-23

Enclosure: Triennial Fire Protection Inspection Support Documentation

cc w/encl: (See page 3)

CP&L 3

cc w/encl:

Director, Site Operations

Carolina Power & Light Company

H. B. Robinson Steam Electric Plant

Electronic Mail Distribution

Ernest J. Kapopoulos, Jr.

Plant General Manager

Carolina Power & Light Company

H. B. Robinson Steam Electric Plant

Electronic Mail Distribution

Paul Fulford, Manager

Performance Evaluation and

Regulatory Affairs PEB 5

Electronic Mail Distribution

C. T. Baucom, Supervisor

Licensing/Regulatory Programs

Carolina Power & Light Company

H. B. Robinson Steam Electric Plant

Electronic Mail Distribution

J. F. Lucas, Manager

Support Services - Nuclear

Carolina Power & Light Company

H. B. Robinson Steam Electric Plant

Electronic Mail Distribution

Henry J. Porter, Director

Div. of Radioactive Waste Mgmt.

Dept. of Health and Environmental

Control

Electronic Mail Distribution

R. Mike Gandy

Division of Radioactive Waste Mgmt.

S. C. Department of Health and

Environmental Control

Electronic Mail Distribution

Beverly Hall, Chief Radiation

Protection Section

N. C. Department of Environment,

Health and Natural Resources

Electronic Mail Distribution

(cc w/encl contd - See page 4)

CP&L 4

(cc w/encl contd)

David T. Conley

Associate General Counsel - Legal Dept.

Progress Energy Service Company, LLC

Electronic Mail Distribution

John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge

2300 N. Street, NW

Washington, DC 20037-1128

Chairman of the North Carolina

Utilities Commission

c/o Sam Watson, Staff Attorney

Electronic Mail Distribution

Robert P. Gruber

Executive Director

Public Staff - NCUC

4326 Mail Service Center

Raleigh, NC 27699-4326

Public Service Commission

State of South Carolina

P. O. Box 11649

Columbia, SC 29211

Distribution w/encl:

L. Regner, NRR

RIDSNRRDIRS

PUBLIC

_________________________

OFFICE RII:DRS RII:DRS RII:DRP

SIGNATURE RA RA RA

NAME RODRIGUEZ WALKER MUSSER

DATE 7/31/2007 7/31/2007 7/31/2007 8/ /2007 8/ /2007 8/ /2007 8/ /2007

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

Triennial Fire Protection Inspection Support Documentation

Note: This is a broad list of the documents the NRC inspection team may be interested

in reviewing, and possibly obtaining, during the information gathering site visit. The

current version of these documents is expected unless specified otherwise. Electronic

media is preferred, if readily available. (The preferred file format is searchable .pdf

files on CDROM. The CDROM should be indexed and hyperlinked to facilitate ease of

use. Please provide 5 copies of each CDROM submitted.) Information in lists should

contain enough information to be easily understood by someone who has a knowledge

of the technology. The lead inspector will discuss specific information needs with the

licensee staff and may request additional documents.

1. The Fire Protection Program document and the Fire Hazards Analysis.

2. The fire protection program implementing procedures (e.g., administrative controls,

surveillance testing, fire brigade).

3. The fire brigade training program document and the pre-fire plans for the selected fire

areas/zones (to be determined during information gathering visit).

4. The post-fire safe shutdown analysis, including system and separation analyses.

5. The alternative shutdown analysis.

6. Piping and instrumentation (flow) diagrams for the fire suppression systems.

7. Piping and instrumentation (flow) diagrams for the systems and components used to

achieve and maintain hot standby, and cold shutdown, for fires involving shutdown from

the control room.

8. Piping and instrumentation (flow) diagrams for the systems and components used to

achieve and maintain hot standby, and cold shutdown, for fires in areas requiring

alternative or dedicated shutdown capability.

9. Plant layout and equipment drawings which identify the physical plant locations of hot

standby and cold shutdown equipment.

10. Plant layout drawings which identify plant fire area and/or fire zone delineation, areas

protected by automatic fire suppression and detection, and the locations of fire

protection equipment for the selected fire areas/zones (to be determined during

information gathering visit).

11. Plant layout drawings which identify the general location of the post-fire emergency

lighting units.

12. Plant operating procedures used to, and describing, shutdown from inside the control

room with a postulated fire occurring in any plant area outside the control room.

Enclosure

2

13. Plant operating procedures used to implement the alternative shutdown capability from

outside the control room with a fire in either the control or cable spreading room (or any

other alternative shutdown area).

14. Maintenance and surveillance testing procedures for alternative shutdown capability

(including Appendix R emergency lights and communication systems) and fire barriers,

detectors, fire pumps and fire suppression systems.

15. Calculations and/or justifications that verify fuse/breaker coordination for the selected

fire areas/zones (to be determined during information gathering visit) that are fed off the

same electrical buses as components in the protected train. Also, a list of the

maintenance procedures used to routinely verify fuse/breaker coordination in

accordance with the post-fire safe shutdown coordination analysis.

16. A list of the significant fire protection and post-fire safe shutdown design change

descriptions (including their associated 10 CFR 50.59 evaluations) and Generic Letter

(GL) 86-10 evaluations.

17. A list of the protection methodologies (as identified in 10 CFR Part 50, Appendix R,

Section III.G) used to achieve regulatory compliance for the selected fire areas/zones

(to be determined during information gathering visit). 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 the

selected fire areas/zones.

18. Procedures or instructions that govern the implementation of plant modifications,

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

protection.

19. Organization chart(s) of site personnel down to the level of the fire protection staff.

20. Procedures or instructions that control the configuration of the fire protection program,

features, and post-fire safe shutdown methodology and system design.

21. A list of applicable codes and standards related to the design of plant fire protection

features and evaluations of code deviations (i.e., a listing of the NFPA code editions

committed to (Code of Record)).

22. The three most recent fire protection QA audits and/or fire protection self-assessments.

23. A list of open and closed fire protection problem identification and resolution reports

[also known as action reports/condition reports/problem reports/problem investigation

reports/NCRs/EARs] associated with fire protection or Appendix R safe shutdown for the

past three years.

Enclosure

3

24. A list of plant fire protection licensing basis documents (i.e., a list of the SERs and

change evaluations which form the licensing basis for the facilitys post-fire safe

shutdown configuration).

25. A list of fire protection or Appendix R calculations.

26. A list of fire impairments identified during the previous year.

27. A list of abbreviations/designators for plant systems.

Enclosure