ML091250202
| ML091250202 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  (DPR-049) |
| Issue date: | 05/05/2009 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Richard Anderson Duane Arnold |
| References | |
| IR-09-006 | |
| Download: ML091250202 (8) | |
See also: IR 05000331/2009006
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
May 5, 2009
Mr. Richard L. Anderson
Vice President
Duane Arnold Energy Center
3277 DAEC Road
Palo, IA 52324-9785
SUBJECT:
DUANE ARNOLD ENERGY CENTER - NOTIFICATION TO PERFORM
A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION WHILE
TRANSITION TO 10 CFR PART 50.48(C) IS IN PROGRESS
INSPECTION REPORT 05000331/2009006(DRS)
Dear Mr. Anderson:
On August 31, 2009, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire
protection baseline inspection at the Duane Arnold Energy Center. This inspection will be
performed in accordance with Inspection Procedure 71111.05TTP, the NRCs baseline fire
protection inspection procedure for plants in the process of implementing the National Fire
Protection Association (NFPA) Standard 805 (10 CFR Part 50.48(c)). 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:
y
Information gathering visit: August 19 - 21, 2009
y
On-site inspection activity: August 31 through September 4, 2009, and September 14-18, 2009
The purpose of the information gathering visit is: (1) to obtain information and documentation
needed to support the inspection; (2) to become familiar with the Duane Arnold Energy Centers fire
protection programs, fire protection features, post-fire safe shutdown capabilities, and plant layout;
and (3) to 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 June 26, 2009. The second group also lists information and areas for
discussion necessary to aid the inspection team in choosing specific focus areas for the inspection and
to ensure that the inspection team is adequately prepared for the
R. Anderson
-2-
inspection. It is requested this information be available during the information gathering visit
(August 19 - 21, 2009). The third group of requested documents consists of those items that
the 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 (August 31, 2009). 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 lead inspector for this inspection is Mr. Zelig Falevits. We understand that our regulatory
contact for this inspection is Mr. Bob Murrell 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 Zelig.Falevits@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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by R. A. Langstaff Acting For/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-331;72-032
License No. DPR-49
Enclosure:
Fire Protection Inspection Document Request
cc w/encl:
M. Nazar, Senior Vice President and
Chief Nuclear Officer
M. Ross, Managing Attorney
A. Khanpour, Vice President, Nuclear Engineering
D. Curtland, Plant Manager
S. Catron, Manager, Regulatory Affairs
M. Mashhadi, Senior Attorney
T. Jones, Vice President, Nuclear Operations,
Midwest Region
P. Wells, Vice President, Nuclear Safety Assessment
R. Hughes, Director, Licensing and Performance Improvement
D. McGhee, Iowa Dept. of Public Health
Chairman, Linn County, Board of Supervisors
R. McCabe, Chairman, Regional Assistance Committee,
DHS/FEMA Region VII
M. Rasmusson, State Liaison Officer
R. Anderson
-2-
inspection. It is requested this information be available during the information gathering visit (August 19 - 21,
2009). The third group of requested documents consists of those items that the 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 (August 31, 2009). 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 lead inspector for this inspection is Mr. Zelig Falevits. We understand that our regulatory contact for this
inspection is Mr. Bob Murrell 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 Zelig.Falevits@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). ADAMS is accessible from the NRC Web
site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by R. A. Langstaff Acting For/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-331;72-032
License No. DPR-49
Enclosure:
Fire Protection Inspection Document Request
cc w/encl:
M. Nazar, Senior Vice President and
Chief Nuclear Officer
M. Ross, Managing Attorney
A. Khanpour, Vice President, Nuclear Engineering
D. Curtland, Plant Manager
S. Catron, Manager, Regulatory Affairs
M. Mashhadi, Senior Attorney
T. Jones, Vice President, Nuclear Operations,
Midwest Region
P. Wells, Vice President, Nuclear Safety Assessment
R. Hughes, Director, Licensing and Performance Improvement
D. McGhee, Iowa Dept. of Public Health
Chairman, Linn County, Board of Supervisors
R. McCabe, Chairman, Regional Assistance Committee,
DHS/FEMA Region VII
M. Rasmusson, State Liaison Officer
DISTRIBUTION
See next page
DOCUMENT NAME: G:\\DRS\\Work in Progress\\Ltr 050509 DAEC Request for Information ZXF.doc
9 Publicly Available
9 Non-Publicly Available 9 Sensitive
9 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
E RIII
RIII
RIII
RIII
NAME
ZFalevits: ls
RDaley
DATE
05/04/09
05/04/09
OFFICIAL RECORD COPY
Letter to Mr. Richard L. Anderson from Mr. Robert C. Daley dated May 5, 2009.
SUBJECT:
DUANE ARNOLD ENERGY CENTER NOTIFICATION TO PERFORM
A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION WHILE
TRANSITION TO 10 CFR PART 50.48(C) IS IN PROGRESS
INSPECTION REPORT 05000331/2009006(DRS)
DISTRIBUTION:
RidsNrrDorlLpl3-1 Resource
RidsNrrPMDuaneArnold Resource
RidsNrrDirsIrib Resource
Patrick Hiland
Kenneth Obrien
Allen Barker
DRPIII
DRSIII
Patricia Buckley
ROPreports Resource
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Enclosure
1
Inspection Report: 05000331/2009006(DRS)
Inspection Dates:
August 19-21, 2009, (Information Gathering Visit)
August 31 through September 4, 2009, (On-site Inspection
Activity)
September 14-8, 2009, (On-site Inspection Activity)
Inspection Procedures:
IP 71111.05TTP, Fire Protection-NFPA 805 Transition Period
(Triennial)
IP 71152, "Identification and Resolution of Problems"
Inspectors:
Zelig Falevits, Lead Inspector
(630) 829-9717
Zelig.Falevits@nrc.gov
George M. Hausman
Robert A. Winter
(630) 829-9747
(630) 829-9758
George.Hausman@nrc.gov
Robert.Winter@nrc.gov
I. Information Requested Prior to the Information Gathering Visit
The following information is requested by June 26, 2009. If you have any questions regarding
this request, please call the lead inspector as soon as possible. All information should be sent
to Mr. Zelig Falevits (e-mail address Zelig.Falevits@nrc.gov). Electronic media is preferred. The
preferred file format is a searchable pdf file on a compact disk (CD). The CD should be
indexed and hyper-linked to facilitate ease of use, if possible. Please provide four copies of
each CD 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 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.
3. 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.
4. Plant operating procedures, which would be used and describe shutdown for a
postulated fire (for both areas requiring alternative shutdown and areas which do not
require alternative shutdown). Only those procedures with actions specific to shutdown
in the event of a fire need be included.
5. A copy of the current fire protection system Health Report, if available.
6. A copy of the current plant drawings referred to as Horse Notes, if available.
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Enclosure
2
7. Status of NFPA 805 (10 CFR Part 50.48(c)) implementation.
I. Information Requested During the Information Gathering Visit (August 19-21, 2009)
The following information is requested to be provided to the inspection team during the
on-site information gathering visit. Except for Item 1, it is requested that the following
information be provided on four sets of CDs (searchable, if possible). In addition, two sets
of hard copy drawings are requested for Items 4.a. through 4.f.
1. One set of hard-copy documents for facility layout drawings, which identify plant fire area
delineation; areas protected by automatic fire suppression and detection; and locations
of fire protection equipment.
2. 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 licensing correspondence
referenced by the SERs;
c.
All licensing correspondence associated with the comparison to Standard Review
Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing purposes;
d.
Exemptions from 10 CFR Part 50.48 and 10 CFR Part 50, Appendix R, and
associated licensing correspondence;
e.
The FPP and applicable portions of the USAR, as referenced by the fire protection
license condition;
f.
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
Part 50.48(b)(1);
g.
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
Part 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 Part 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 Part 50.48(b)(1)(ii));
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Enclosure
3
h.
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
i.
For NFPA 805 transition plants 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; and (4) a list of all
identified non-conformances, and their respective compensatory measure(s).
3. Fire Protection Program:
a.
If not already provided under request II.(2)(e) above, FPP documents including
b.
A listing of changes made to the FPP (including associated adverse to SSA) since
the last triennial fire protection inspection;
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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated
fire barriers with detection and suppression; (Section III.G.2.c), or alternative
shutdown capability; (Section III.G.3) is used as a strategy 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.
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.
4. 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);
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Enclosure
4
c.
Plant layout drawings, which identify the general location of the post-fire
emergency lighting units;
d.
One-line drawings of the electrical distribution system for 4160 Volts alternating
current (Vac) down to 480Vac;
e.
One-line drawings of the electrical distribution system for 250 Volts direct
current (Vdc) and 125Vdc systems as applicable;
f.
Logic diagrams showing the components used to achieve and maintain hot
standby and cold shutdown; and
g.
Safe shutdown cable routing database (requested electronically such as on
compact disc, if available.
5. 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).
6. 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.
7. 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.
8. 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;
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Enclosure
5
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.
II. Information Requested to be Available on First Day of Inspection (August 31, 2009)
The following information is requested to be provided on the first day of inspection. It is
requested that this information be provided on four sets of CDs (searchable, if possible).
1. Program 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);
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Enclosure
6
e.
Alternating current (ac) coordination calculations for 4160Vac down to 480Vac
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). It is acceptable to make vendor
manuals available to the inspectors in lieu of providing a copy; 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.
4. Any updates to information previously provided.
III. 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).