ML091730506

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Pant - Notification of Triennial Fire Protection Baseline Inspection While Transition to 10 CFR Part 50.48(c) Is in Progress (NRC Inspection Report No. 05000259-09-009, 05000260-09-009, and 05000296-09-009
ML091730506
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 06/22/2009
From: Nease R
NRC/RGN-II/DRS/EB2
To: Swafford P
Tennessee Valley Authority
References
IR-09-009
Download: ML091730506 (7)


See also: IR 05000259/2009009

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

SAM NUNN ATLANTA FEDERAL CENTER

61 FORSYTH STREET, SW, SUITE 23T85

ATLANTA, GEORGIA 30303-8931

June 22, 2009

Mr. Preston D. Swafford

Chief Nuclear Officer and Executive Vice President

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT - NOTIFICATION OF TRIENNIAL FIRE

PROTECTION BASELINE INSPECTION WHILE TRANSITION TO 10 CFR

PART 50.48(c) IS IN PROGRESS (NRC INSPECTION REPORT NO.

05000259/2009009, 05000260/2009009, AND 05000296/2009009)

Dear Mr. Swafford:

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 Browns Ferry Nuclear

Plant, Units 1, 2, and 3 in September and October 2009. The inspection team will be led by Mr.

McKenzie Thomas, NRC Senior 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 June 5, 2009, during a telephone conversation between Mr. Russ Godwin (Site Licensing

Manager) of your staff, and Mr. Thomas, 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:

September 1-3, 2009

Week 1 of onsite inspection: September 21-25, 2009

Week 2 of onsite inspection: October 5-9, 2009

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

needed to support the inspection, and to become familiar with the Browns Ferry Nuclear Plant

TVA

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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. Thomas 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.

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 Browns Ferry 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 Browns Ferry 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. Thomas at (404) 562-4673, or me at (404) 562-4530.

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/

Rebecca L. Nease, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos.: 50-259, 50-260, 50-296

License Nos.: DPR-33, DPR-52, DPR-68

Enclosure:

Triennial Fire Protection Inspection Support Documentation

cc w/encl. (See page 3)

TVA

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cc w/encl:

Ashok S. Bhatnagar

Senior Vice President

Nuclear Generation Development and

Construction

Tennessee Valley Authority

Electronic Mail Distribution

Preston D. Swafford

Chief Nuclear Officer and Executive Vice

President

Tennessee Valley Authority

Electronic Mail Distribution

William R. Campbell

Senior Vice President

Fleet Engineering

Tennessee Valley Authority

6A Lookout Place

1101 Market Place

Chattanooga, TN 37402-2801

Thomas Coutu

Vice President

Nuclear Support

Tennessee Valley Authority

Electronic Mail Distribution

R. G. (Rusty) West

Site Vice President

Browns Ferry Nuclear Plant

Tennessee Valley Authority

Electronic Mail Distribution

Frederick Russell Godwin

Manager, Licensing and Industry Affairs

Browns Ferry Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Decatur, AL 35609

James J. Randich

Plant Manager

Browns Ferry Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Decatur, AL 35609

General Counsel

Tennessee Valley Authority

Electronic Mail Distribution

Larry E. Nicholson

General Manager

Performance Improvement

Tennessee Valley Authority

Electronic Mail Distribution

Michael A. Purcell

Senior Licensing Manager

Nuclear Power Group

Tennessee Valley Authority

Electronic Mail Distribution

Michael J. Lorek

Vice President - Nuclear Oversight

Tennessee Valley Authority

Electronic Mail Distribution

Fredrick C. Mashburn

Acting Manager

Corporate Nuclear Licensing and Industry

Affairs

Tennessee Valley Authority

Electronic Mail Distribution

Robert J. Whalen

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-280

Senior Resident Inspector

Browns Ferry Nuclear Plant

U.S. Nuclear Regulatory Commission

10833 Shaw Road

Athens, AL 35611-6970

Kirksey E. Whatley

Director

Office of Radiation Control

Alabama Dept. of Public Health

Electronic Mail Distribution

Chairman

Limestone County Commission

310 West Washington Street

Athens, AL 35611

Dr. D. E. Williamson

State Health Officer

Alabama Dept. of Public Health

Electronic Mail Distribution

_________________________

XG SUNSI REVIEW COMPLETE by

MT 6/22/2009

OFFICE

RII:DRS

RII:DRP

RII:DRS

SIGNATURE

RA

RA

RA

NAME

MThomas

EGuthrie

RNease

DATE

6/18/2009

6/19/2009

6/22/2009

E-MAIL COPY?

YES

NO YES

NO YES

NO YES

NO YES

NO YES

NO

Enclosure

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 CD/DVD-ROM. The CD/DVD-ROM should be indexed and hyperlinked to

facilitate ease of use. Please provide 5 copies of each CD/DVD-ROM submitted.)

Information in lists should contain enough information to be easily understood by

someone who has 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 that describe and are used to shutdown from inside the

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

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Enclosure

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 investigation reports/problem

evaluation reports/NCRs] associated with fire protection or Appendix R safe shutdown

for the past three years.

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).

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Enclosure

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.