ML101241166

Notification of Conduct of a Triennial Fire Protection Baseline Inspection

ML101241166
Person / Time
Site:	Millstone
Issue date:	05/04/2010
From:	Rogge J Engineering Region 1 Branch 3
To:	Heacock D Dominion Resources
References
FOIA/PA-2011-0115
Download: ML101241166 (9)

Text

Mr. David A. Heacock UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406-1415 May 4, 2010 President and Chief Nuclear Officer Dominion Resources 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT 2 AND 3 - NOTIFICATION OF CONDUCT OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

Dear Mr. Heacock:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC) staff will conduct a triennial fire protection baseline inspection at the Millstone Power Station Unit 2 and 3. The inspection team will be led by Larry Scholl from the NRC Region I office. The team will be composed of personnel from the NRC Region I office. The inspection will be conducted in accordance with NRC inspection procedure 71111.05T, NRC's baseline fire protection inspection procedure.

Additionally, the NRC is assessing the effectiveness of the regulatory infrastructure in the areas of fire induced circuit failure and operator manual actions to mitigate fire-induced spurious actuations. In support of this assessment, Temporary Instruction (TI) 2515/181, "Validate the Effectiveness of the Regulatory Infrastructure Related to Fire-Induced Circuit Failures and Operator Manual Actions," is being performed at two operating nuclear power reactor licensees that are maintaining their current fire protection program and are not transitioning to National Fire Protection Association (NFPA) 805. Representative sites are being selected to support the NRC's timeline for validating the regulatory infrastructure, and Millstone Power Station Unit 2 was selected as one of these sites. The team will be assisted by the Office of Nuclear Reactor Regulation (NRR) in the performance of this assessment.

The schedule for the inspection is as follows:

Information gathering visit - Week of July 5, 2010 Weeks of onsite inspection - July 19 and August 2,2010 The purposes of the information gathering visit are to obtain information and documentation needed to support the inspection, to become familiar with the station fire protection programs, fire protection features, post-fire safe shutdown capabilities and plant layout, mitigating strategies to address Section B.5.b of the Interim Compensatory Measures Order, EA-02-026, of February 25, 2002, 10 CFR 50.54(hh )(2); and, as necessary, obtain plant specific site access training and badging for unescorted access.

D. Heacock 2

A list of the types of documents the team may be interested in reviewing and possibly obtaining for each Unit, are listed in Enclosures 1 and 2 and the documents needed to support completion of TI-181 for Unit 2 are listed in Enclosure 3. The team leader will contact you with specific document requests prior to the information gathering visit.

During the information gathering visit, the team will also discuss the following inspection support administrative details: office space size and location; specific documents requested to be made available to the team in their office spaces; 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 onsite inspection week you ensure that copies of analyses, evaluations, or documentation regarding the implementation and maintenance of the Millstone Power Station fire protection program, including post-fire safe shutdown capability, be readily accessible to the team for their review. Of specific interest for the fire protection portion of the inspection are those documents which establish that your fire protection program satisfies NRC regulatory requirements and conforms to applicable NRC and industry fire protection guidance.

For the B.5.b portion of the inspection, those documents implementing your mitigating strategies and demonstrating the management of your commitments for the strategies are of specific interest. 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 Millstone Power Station fire protection program and its implementation.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

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 Larry Scholl, the team leader in the Region I Office at (610) 337-5144.

Docket Nos.

50-336; 50-423 License Nos. DPR-65, NPF-49 Sincerely, d:-::~

Engineering Branch 3 Division of Reactor Safety

D. Heacock 2

A list of the types of documents the team may be interested in reviewing and possibly obtaining for each Unit, are listed in Enclosures 1 and 2 and the documents needed to support completion of TI-181 for Unit 2 are listed in Enclosure 3. The team leader will contact you with specific document requests prior to the information gathering visit.

During the information gathering visit, the team will also discuss the following inspection support administrative details: office space size and location; specific documents requested to be made available to the team in their office spaces; 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 onsite inspection week you ensure that copies of analyses, evaluations, or documentation regarding the implementation and maintenance of the Millstone Power Station fire protection program, including post-fire safe shutdown capability, be readily accessible to the team for their review. Of specific interest for the fire protection portion of the inspection are those documents which establish that your fire protection program satisfies NRC regulatory requirements and conforms to applicable NRC and industry fire protection guidance.

For the B.5.b portion of the inspection, those documents implementing your mitigating strategies and demonstrating the management of your commitments for the strategies are of specific interest. 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 Millstone Power Station fire protection program and its implementation.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

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 Larry Scholl, the team leader in the Region I Office at (610) 337-5144.

Docket Nos.

50-336; 50-423 License Nos. DPR-65, NPF-49 Sincerely, IRA!

John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety SUNSI Review Complete:

JFR (Reviewer's Initials)

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D. Christian 3

Enclosure:

1) List of Reactor Fire Protection Program Supporting Documentation

2) Mitigating Strategies Supporting Documentation

3) TI 2515/181 Supporting Documentation cc:

Distribution via ListServ

D. Heacock 4

Distribution w/encl:

S. Collins, RA (R10RAMAIL RESOURCE)

M. Dapas, DRA (R10RAMAIL RESOURCE)

D. Lew, DRP (R1DRPMAIL RESOURCE)

J. Clifford, DRP (R1 DRPMAIL RESOURCE)

D. Roberts, DRS (R1DRSMaii RESOURCE)

P. Wilson, DRS (R1DRSMaii RESOURCE)

D. Jackson, DRP T. Setzer, DRP J. Heinly, DRP B. Sienel, DRP S. Shaffer, DRP, SRI B. Haagensen, RI J. Krafty, DRP, RI C. Kowalyshyn, OA L. Trocine, RI OEDO D. Bearde, DRS RidsNRRPM Millstone Resource RidsNRRDor1Lp11-2 Resource J. Rogge, DRS L. Scholl, DRS

ENCLOSURE 1 Reactor Fire Protection Program Supporting 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.]

1.

The current version of the Fire Protection Program and Fire Hazards Analysis.

2.

Current versions of the fire protection program implementing procedures (e.g.,

administrative controls, surveillance testing, and fire brigade.)

3.

Fire brigade training program and pre-fire plans.

4.

Post-fire safe shutdown systems and separation analysis.

5.

Post-fire alternative shutdown analysis.

6.

Piping and instrumentation (flow) diagrams showing the systems and 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.

7.

Plant layout drawings which identify the physical plant locations of hot standby and cold shutdown equipment.

8.

Plant layout drawings which identify plant fire area delineation, areas protected by automatic fire suppression and detection, and the locations of fire protection equipment.

9.

Plant layout drawings which identify the location of post-fire emergency lighting units.

10.

Plant operating procedures which would be used for shutdown from the control room with a postulated fire occurring in any plant area outside the control room, and procedures which would be used to implement alternative shutdown capability in the event of a fire in either the control or cable spreading room.

11.

Copy of most recently completed maintenance and surveillance testing procedures for alternative shutdown capability components, fire barriers, fire detectors, fire pumps and suppression systems.

12.

Maintenance procedures which routinely verify fuse and circuit breaker coordination in accordance with the post-fire safe shutdown coordination analysis.

13.

A sample of significant fire protection and post-fire safe shutdown related design change packages (including their associated 10 CFR 50.59 evaluations) and Generic Letter 86-10 evaluations.

14.

The reactor plant's IPEEE, results of any post-IEEE reviews, and listings of actions taken/plant modifications conducted in response to IEEE information.

D. Heacock 2

15.

Temporary modification procedures.

16.

Organization charts of site personnel down to the level of fire protection staff personnel.

17.

Layout/arrangement drawings of potential reactor coolant pump lube oil system leakage points and associated lube oil collection systems.

18.

A listing of the SERs which form the licensing basis for the reactor plant's post-fire safe shutdown configuration.

19.

Procedures/instructions that control the configuration of the reactor plant's fire protection program, features and post-fire safe shutdown methodology and system design.

20.

A list of applicable codes and standards related to the design of plant fire protection features and evaluations of code deviations.

21.

Procedures/instructions that govern the implementation of plant modifications, maintenance, and special operations, and their impact on fire protection.

22.

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

23.

Recent (last 12 months) QA surveillances of fire protection activities.

24.

A listing of open fire protection and fire safe shutdown related condition reports and a listing of fire protection and fire safe shutdown condition reports closed in the past three years.

25.

Listing of plant fire protection licensing basis documents.

26.

A listing of the NFPA code versions committed to (NFPA codes of record).

27.

A listing of plant deviations from code commitments.

28.

Fire protection system health reports (last 2).

29.

Actual copies of Generic Letter 86-10 evaluations.

30.

Lesson plans and related training information for licensed and non-licensed operators for post-fire safe shutdown (including alternative shutdown).

31.

. Electronic copy of current versions of the Updated Final Safety Analysis Report (FSAR),

Technical Specifications, and Operating License.

32.

Copies of AC and DC electrical system one line diagrams. (From offsite power grid connections down to the 120 volt level.)

ENCLOSURE 2 Mitigating Strategies Supporting 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.]

1.

A list of all modifications to regulatory commitments made to meet the requirements of Section B.5.b of the ICM Order, EA-02-026, dated February 25,2002, the subsequently imposed license conditions, and 10 CFR 50.54(hh)(2).

2.

Copies of procedures/guidelines that were revised or generated to implement the mitigation strategies.

These could be extensive damage mitigation guidelines (EDMGs), severe accident management guidelines (SAMGs), emergency operating procedures (EOPs), abnormal operating procedures (AOPs), etc.

3.

A matrix that shows the correlation between the mitigation strategies identified in Nuclear Energy Institute 06-12 and the site-specific procedures or guidelines that are used to implement each strategy.

4.

Engineering evaluations/calculations that were used to verify engineering bases for the mitigation strategies.

5.

Piping and instrumentation diagram (P&ID) or simplified flow diagrams for systems relied upon in the mitigation strategies. These could be the type used for training.

6.

A modification package or simplified drawings/descriptions of modifications that were made to plant systems to implement the mitigation strategies.

7.

Last completed copies of procedures used to inventory equipment (hoses, fittings, pumps, etc.) required to be used to implement the mitigation strategies.

8.

A list of B.5.b strategies, if any, which have implementing details that differ from that documented in the submittals and the safety evaluation report.

9.

A copy of site general arrangement drawing(s) that show the majority of buildings/areas referenced in B.5.b documents.

10.

Training records/ training matrix! lesson plans related to B.5.b.

11.

Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments) required to implement any mitigating strategies.

ENCLOSURE 3 TI 2515/181 Supporting Documentation (Unit 2)

[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.]

1.

General information needed to support completion of the TI:

(a) List of protected equipment required for safe shutdown.

(b) Cable routing for equipment required for safe shutdown.

(c) List of protected equipment important for safe shutdown.

(d) Cable routing for equipment important for safe shutdown.

2.

Analyses the licensee performed in support of their evaluation regarding the close out of noncompliances associated with EGM 07-004, which may include the following:

(a) List of identified single spurious fire-induced circuit failure configurations.

(b) List of corrective actions for single spurious fire-induced circuit failures.

(c) List of single spurious actuations evaluated arid the results of the evaluations.

3. Analyses the licensee performed in support of their evaluation regarding the close out of noncompliances associated with EGM 09-002, which may include the following:

(a) List of identified multiple spurious fire-induced circuit failure configurations.

(b) List of corrective actions for multiple spurious fire-induced circuit failures.

(c) List of single spurious actuations evaluated and the results of the evaluations.

(d) List of generic multiple spurious actuations that have been screened out.

(e) Documented results of Expert Panel Review of multiple spurious actuations and the existing safe shutdown analysis.