ML103510599
| ML103510599 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/16/2010 |
| From: | Nease R NRC/RGN-II/DRS/EB2 |
| To: | Jerrica Johnson Southern Nuclear Operating Co |
| References | |
| IR-11-009 | |
| Download: ML103510599 (10) | |
See also: IR 05000348/2011009
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
December 16, 2010
Mr. J. Randy Johnson
Vice President - Farley
Southern Nuclear Operating Company, Inc.
7388 North State Highway 95
Columbia, AL 36319
SUBJECT: JOSEPH M. FARLEY NUCLEAR PLANT- NOTIFICATION OF CONDUCT OF A
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION WHILE TRANSITION
TO 10 CFR PART 50.48(c) IS IN PROGRESS (NRC INSPECTION REPORT
NO. 05000348/2011009 AND 05000364/2011009)
Dear Mr. Johnson:
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 Joseph M. Farley
Nuclear Plant, in March 2011. The inspection team will be led by Mr. Necota Staples, NRC
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 December 10, 2010, during a telephone conversation between Mr. Bill Oldfield (Farley
Licensing Manager) of your staff, and Mr. Staples, 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: February 15 - 17, 2010
- Week 1 of onsite inspection: March 07 -11, 2010
- Week 2 of onsite inspection: March 21 - March 25, 2010
The purposes of the information gathering visit are to obtain information and documentation
needed to support the inspection, to become familiar with the Farley Nuclear Plant
fire protection programs, fire protection features, and 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). The types of
documents the team will be interested in reviewing, and possibly obtaining, are listed in
Enclosures 1 and 2. Please contact Mr. Staples prior to preparing copies of the materials listed
SNOPCO 2
in the Enclosures. 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 their
office space; arrangements for unescorted 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 Farley 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 that 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 Farley 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 Mr. Staples at (404) 997-4644, or me at (404) 997-4530.
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
SNOPCO 3
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html 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 No.: 50-348, 50-364
Enclosures: 1. Triennial Fire Protection Inspection Support Documentation
2. Mitigating Strategies Support Documentation
cc w/encl. (See page 4)
SNOPCO 4
cc w/encl: Paula Marino
B. D. McKinney, Jr. Vice President
Regulatory Response Manager Engineering
Southern Nuclear Operating Company, Inc. Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Electronic Mail Distribution
M. J. Ajluni Moanica Caston
Nuclear Licensing Director Vice President and General Counsel
Southern Nuclear Operating Company, Inc. Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Electronic Mail Distribution
T. D. Honeycutt Chris Clark
Regulatory Response Supervisor Commissioner
Southern Nuclear Operating Company, Inc. Georgia Department of Natural Resources
Electronic Mail Distribution Electronic Mail Distribution
Todd L. Youngblood John G. Horn
Plant Manager Site Support Manager
Joseph M. Farley Nuclear Plant Joseph M. Farley Nuclear Plant
Electronic Mail Distribution Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution
R. D. Baker
Licensing Supervisor Ted V. Jackson
Southern Nuclear Operating Company, Inc. Emergency Response and Radiation
Electronic Mail Distribution Program Manager
Environmental Protection Division
E. G. Anners Georgia Department of Natural Resources
Licensing Engineer Electronic Mail Distribution
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Tom W. Pelham
Performance Improvement Supervisor
Jeffrey T. Gasser Joseph M. Farley Nuclear Plant
Chief Nuclear Officer Southern Nuclear Operating Company, Inc.
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
Cynthia A. Sanders
N. J. Stringfellow Radioactive Materials Program Manager
Licensing Manager Environmental Protection Division
Southern Nuclear Operating Company, Inc. Georgia Department of Natural Resources
Electronic Mail Distribution Electronic Mail Distribution
L. Mike Stinson James C. Hardeman
Vice President Environmental Radiation Program Manager
Fleet Operations Support Environmental Protection Division
Southern Nuclear Operating Company, Inc. Georgia Department of Natural Resources
Electronic Mail Distribution Electronic Mail Distribution
William D. Oldfield
Principal Licensing Engineer
Joseph M. Farley Nuclear Plant
Electronic Mail Distribution
SNOPCO 5
(cc w/encl contd)
Senior Resident Inspector
U.S. Nuclear Regulatory Commission
Joseph M. Farley Nuclear Plant
U.S. NRC
7388 N. State Highway 95
Columbia, AL 36319
Mr. Mark Culver
Chairman
Houston County Commission
P. O. Box 6406
Dothan, AL 36302
James A. Sommerville
Program Coordination Branch Chief
Environmental Protection Division
Georgia Department of Natural Resources
Electronic Mail Distribution
James L. McNees, CHP
Director
Office of Radiation Control
Alabama Dept. of Public Health
P. O. Box 303017
Montgomery, AL 36130-3017
State Health Officer
Alabama Dept. of Public Health
Electronic Mail Distribution
F. Allen Barnes
Director
Environmental Protection Division
Georgia Department of Natural Resources
Electronic Mail Distribution
_________________________ G SUNSI REVIEW COMPLETE
OFFICE RII:DRS RII:DRS RII:DRP
SIGNATURE
NAME STAPLES NEASE SHAEFFER
DATE 12/ /2010 12/ /2010 12/ /2010 12/ /2010 12/ /2010 12/ /2010 12/ /2010
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
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 on CD-ROM or DVD-
ROM is .pdf). The CD/DVD-ROM should be indexed, hyperlinked, readable, and
searchable 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 or electronic information.
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 used to, and describing shutdown from inside the control
room with a postulated fire occurring in any plant area outside the control room.
Enclosure 1
2
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) 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 Ill.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 Ill.G.2.a), 20-foot separation along with detection and
suppression (Section IIl.G.2.b), 1-hour rated fire barriers with detection and suppression
(Section lII.G.2.c), or alternative shutdown capability (Section lll.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/NCRs/EARs] 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).
Enclosure 1
2
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.
Enclosure 1
Mitigating Strategies 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 visit. The current
version of these documents is expected unless specified otherwise. Electronic media is
preferred, if readily available. (The preferred file format on CD-ROM or DVDROM is
.pdf). The CD/DVD-ROM should be indexed, hyperlinked, readable, and searchable to
facilitate ease of use. Please provide 5 copies of each CD/DVD-ROM submitted). The
lead inspector will discuss specific information needs with the licensee staff and may
request additional documents or electronic information.
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. 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 2