ML072320049
| ML072320049 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/17/2007 |
| From: | Julio Lara Engineering Branch 3 |
| To: | Crane C Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-07-008 | |
| Download: ML072320049 (11) | |
See also: IR 05000454/2007008
Text
August 17, 2007
Mr. Christopher M. Crane
President and Chief Nuclear Officer
Exelon Nuclear
Exelon Generation Company, LLC
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: BYRON STATION, UNITS 1 AND 2
NOTIFICATION TO CONDUCT A TRIENNIAL FIRE PROTECTION BASELINE
INSPECTION REPORT 05000454/2007008(DRS); 05000455/2007008(DRS)
Dear Mr. Crane:
On November 13, 2007, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial
fire protection baseline inspection at the Byron Station, Units 1 and 2. The inspection will be
conducted in accordance with Inspection Procedure 71111.05T, the NRCs baseline fire
protection inspection procedure.
The schedule for the inspection is as follows:
- Information gathering visit - October 31 - November 2, 2007
- On-site inspection activity - November 13 - 16, 2007, and November 26 - 30, 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 Byron Stations 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 October 1, 2007. The
second 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
October 31, 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 (November 13, 2007). The
fourth group lists information necessary to aid the inspection team in tracking issues identified
C. Crane -2-
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
regulatory contact for this inspection is Ms. Tracy Hulbert 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 Part 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. 50-454; 50-455
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Site Vice President - Byron Station
Plant Manager - Byron Station
Regulatory Assurance Manager - Byron Station
Chief Operating Officer
Senior Vice President - Nuclear Services
Vice President - Operations Support
Vice President - Licensing and Regulatory Affairs
Director Licensing
Manager Licensing - Braidwood and Byron
Senior Counsel, Nuclear
Document Control Desk - Licensing
Assistant Attorney General
Illinois Emergency Management Agency
State Liaison Officer, State of Illinois
State Liaison Officer, State of Wisconsin
Chairman, Illinois Commerce Commission
B. Quigley, Byron Station
C. Crane -2-
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
regulatory contact for this inspection is Ms. Tracy Hulbert 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 Part 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,
Julio F. Lara, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-454; 50-455
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Site Vice President - Byron Station
Plant Manager - Byron Station
Regulatory Assurance Manager - Byron Station
Chief Operating Officer
Senior Vice President - Nuclear Services
Vice President - Operations Support
Vice President - Licensing and Regulatory Affairs
Director Licensing
Manager Licensing - Braidwood and Byron
Senior Counsel, Nuclear
Document Control Desk - Licensing
Assistant Attorney General
Illinois Emergency Management Agency
State Liaison Officer, State of Illinois
State Liaison Officer, State of Wisconsin
Chairman, Illinois Commerce Commission
B. Quigley, Byron Station
DOCUMENT NAME: C:\FileNet\ML072320049.wpd
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy
OFFICE RIII E RIII RIII RIII
NAME GHausman: ls RSkokowski JLara
DATE 08/14/07 08/16/07 08/17/07
OFFICIAL RECORD COPY
Letter to Mr. C. Crane from Mr. J. F. Lara dated August 17, 2007
SUBJECT: BYRON STATION, UNITS 1 AND 2
NOTIFICATION TO CONDUCT A TRIENNIAL FIRE PROTECTION BASELINE
INSPECTION REPORT 05000454/2007008(DRS); 05000455/2007008(DRS)
DISTRIBUTION:
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MAS
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RML2
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SRI Byron
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TXN
ROPreports@nrc.gov
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
Inspection Report: 05000454/2007008(DRS); 05000455/2007008(DRS)
Inspection Dates: October 31 - November 2, 2007 (Information Gathering Visit)
November 13 - 16, 2007 (On-site Inspection Activity)
November 26 - 30, 2007 (On-site Inspection Activity)
Inspection Procedures: IP 71111.05T, Fire Protection (Triennial)
IP 71152, "Identification and Resolution of Problems"
Inspectors: Lead Inspector: George M. Hausman, (630) 829-9743
Team Members: Benny Jose, (630) 829-9756
Darrell L. Schrum, (630) 829-9741
I. Information Requested Prior to the Information Gathering Visit
The following information is requested by October 1, 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 may 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 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.
(5) A copy of the current plant drawings referred to as Horse Notes, if available.
1 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
II. Information Requested During the Information Gathering Visit
(October 31 - November 2, 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)); and
(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.
2 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
(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-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; and
(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;
(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;
3 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
(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.
(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
4 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
(c) A tour of alternative shutdown and risk significant fire areas.
III. Information Requested to be Available on First Day of Inspection
(November 13, 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;
(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);
5 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
INITIAL REQUEST
(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).
6 Enclosure