ML102140458
| ML102140458 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/02/2010 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| Download: ML102140458 (10) | |
See also: IR 05000454/2010006
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
August 2, 2010
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville IL 60555
SUBJECT: BYRON STATION - NOTIFICATION TO PERFORM A TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION; INSPECTION REPORT
05000454/2010-006(DRS); 05000455/2010-006(DRS)
Dear Mr. Pacilio:
On October 6, 2010, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire
protection baseline inspection at your Byron Station. This inspection will be performed in
accordance with Inspection Procedure (IP) 71111.05T, the NRCs baseline fire protection
inspection procedure.
Based on the latest revision to IP 71111.05T, dated December 24, 2009, changes were made to
the IP which now requires the fire protection inspection to review your actions to mitigate
postulated events that could potentially cause loss of large areas of power reactor facilities due
to explosions or fires. This requirement was implemented by the issuance of the Interim
Compensatory Measures Order EA-02-026, Section B.5.b and the subsequent requirements of
10 CFR 50.54(hh)(2), which are collectively referred to as B.5.b requirements. During this
inspection, the B.5.b requirements review will be performed during the first on-site week of the
inspection starting on October 6, 2010.
The schedule for the on-site inspection activity is as follows:
- Information Gathering Visit: October 4 - 5, 2010;
- B.5.b Requirements: October 6 - 8, 2010;
- Fire Protection Inspection: October 6 - 8, 2010; October 18 - 22, 2010;
and November 1 - 5, 2010
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 Byron Station 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 and become familiar with the licensing basis.
M Pacilio -2-
It is requested that this information be provided to the lead inspector via mail or electronically no
later than September 20, 2010. The second group also lists information and areas for
discussion necessary to aid the inspection team in choosing specific fire protection focus areas
for the inspection and to ensure that the inspection team is adequately prepared for the
inspection. It is requested this information be available during the information gathering visit
(October 4 - 5, 2010). 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 second on-site inspection week (October 18, 2010). 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. R.A. Langstaff. We understand that our regulatory
contact for this inspection is Ms. T. Hulbert of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector at (630) 829-
9747 or via e-mail at ronald.langstaff@nrc.gov.
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.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any), will be available electronically for public inspection in
the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-454; 50-455
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Distribution via ListServ
FIRE PROTECTION INSPECTION DOCUMENT REQUESTS
Inspection Report: 05000454/2010-006(DRS); 05000455/2010-006(DRS)
On-site Inspection Dates: October 4 - 5, 2010 (Information Gathering Visit)
October 6 - 8, 2010 (B.5.b Requirements)
October 6 - 8, 2010 (Fire Protection Inspection)
October 18 - 22, 2010 (Fire Protection Inspection)
November 1 - 5, 2010 (Fire Protection Inspection)
Inspection Procedures: IP71111.05T, Fire Protection (Triennial)
IP71152, "Identification and Resolution of Problems"
Inspectors: R. A. Langstaff, lead
(630) 829-9747
ronald.langstaff@nrc.gov
A. K. Dahbur R. A. Winter
(630) 829-9810 (630) 829-9758
alan.dahbur@nrc.gov robert.winter@nrc.gov
Observers: N. B. Melly
(301) 251-7916
nicholas.melly@nrc.gov
I. Information Requested Prior To the Information Gathering Visit
The following information is requested by September 20, 2010. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Mr. R.A. Langstaff (e-mail address ronald.langstaff@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).
1. The most risk significant fire areas as determined by probabilistic risk analyses, if
available. Otherwise, the reactor plant's Individual Plant Examination for External
Events (IPEEE) for fire and results of any post-IPEEE reviews for fire.
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.
1 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUESTS
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. 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 50.48 and 10 CFR Part 50, Appendix R, and associated
licensing correspondence;
II. Information Requested During the Information Gathering Visit (October 4, 2010)
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 three sets of CDs (searchable, if possible) with the B.5.b
Mitigating Strategies information (Items 7.a. through 7.h.) provided on separate CDs. In
addition, one set of hard copy drawings are requested for Items 3.a. through 3.e.
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. Fire Protection Program:
a. A listing of changes made to the FPP since the last triennial fire protection
inspection;
b. 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 as a strategy for each selected fire
zone/area;
2 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUESTS
c. A list of Generic Letter 86-10 evaluations (i.e., a list of adverse to safe-shutdown
evaluations);
d. 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); and
e. List of plant deviations from code commitments and associated evaluations.
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, those components used for those areas requiring alternative shutdown
capability, and systems relied upon for B.5.b mitigation strategies. These can be of
the type that are used for training;
b. One-line schematic drawings of the electrical distribution system for 4160 Volts
alternating current (Vac) down to 480Vac;
c. One-line schematic drawings of the electrical distribution system for 250 Volts
direct current (Vdc) and 125Vdc systems as applicable;
d. Logic diagrams showing the components used to achieve and maintain hot
standby and cold shutdown; and
e. 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 specify the initial operations response to a fire
alarm or annunciator;
c. Procedure for calling out the fire brigade and requesting off-site assistance.
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. List of current fire impairments, including duration.
3 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUESTS
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. B.5.b Mitigating Strategies:
a. 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);
b. 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.;
c. 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;
d. A listing of engineering evaluations/calculations that were used to verify
engineering bases for the mitigation strategies;
e. Copies of procedures used to inventory equipment (hoses, fittings, pumps, etc.)
required to be used to implement the mitigation strategies;
f. A list of B.5.b mitigating strategies, if any, which have implementing details that
differ from that documented in the submittals and the safety evaluation report;
g. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments)
required to implement any mitigating strategies; and
h. A list of changes made to B.5.b mitigating strategies and associated procedures
since the previous NRC inspection of B.5.b mitigating strategies (August 2008).
4 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUESTS
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 or
explosion (including B.5.b mitigation strategies) 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
c. A tour of alternative shutdown and risk significant fire areas.
III. Information Requested to be Available on First Day of the Second On-site Inspection
Week (October 18, 2010)
The following information is requested to be provided on the first day of inspection. It is
requested that this information be provided on three sets of CDs (searchable, if possible).
1. Program Procedures:
a. Procedures for:
- Administrative controls (such as allowed out of service times and
compensatory measures) for fire protection systems and components;
- Control of transient combustibles; and
- Control of hot work.
b. List of maintenance and surveillance testing procedures for alternative shutdown
capability and fire barriers, detectors, pumps, and suppression systems; and
c. List of maintenance procedures which routinely verify fuse breaker coordination
in accordance with the post-fire safe shutdown coordination analysis.
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 50.59
evaluations) and Generic Letter (GL) 86-10 (or adverse to safe shutdown)
evaluations;
5 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUESTS
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);
e. Alternating current (ac) coordination calculations for 4160Vac down to 480Vac
electrical systems; and
f. List of all fire protection or Appendix R calculations.
3. Assessment and Corrective Actions:
The three most recent fire protection Quality Assurance (QA) audits and/or fire
protection self-assessments.
4. Any updates to information previously provided.
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).
If you have questions regarding the information requested, please contact the lead inspector.
6 Enclosure
M Pacilio -2-
It is requested that this information be provided to the lead inspector via mail or electronically no later
than September 20, 2010. The second group also lists information and areas for discussion necessary
to aid the inspection team in choosing specific fire protection focus areas for the inspection and to ensure
that the inspection team is adequately prepared for the inspection. It is requested this information be
available during the information gathering visit (October 4 - 5, 2010). 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 second on-site inspection week (October 18,
2010). 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. R.A. Langstaff. We understand that our regulatory contact for
this inspection is Ms. T. Hulbert of your organization. If there are any questions about the inspection or
the material requested, please contact the lead inspector at (630) 829-9747 or via e-mail at
ronald.langstaff@nrc.gov.
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.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and
your response (if any), will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide
Documents Access and Management System (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-454; 50-455
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Distribution via ListServ
DOCUMENT NAME: G:\DRS\Work in Progress\Ltr. 080210 Byron Fire Protection RFI RAL.docx
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 RIII
NAME RLangstaff:ls RCDaley
DATE 08/02/10 08/02/10
OFFICIAL RECORD COPY
Letter to Mr. Michael Pacilio from Mr. Robert C. Daley dated August 2, 2010.
SUBJECT: BYRON STATION - NOTIFICATION TO PERFORM A TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION; INSPECTION REPORT
05000454/2010-006(DRS); 05000455/2010-006(DRS)
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