ML110180664
| ML110180664 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/18/2011 |
| From: | Nease R NRC/RGN-II/DRS/EB2 |
| To: | Franke J Florida Power Corp |
| References | |
| IR-11-008 | |
| Download: ML110180664 (8) | |
See also: IR 05000302/2011008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
January 18, 2011
Mr. Jon A. Franke
Vice President, Crystal River Nuclear Plant
Crystal River Nuclear Plant (NA2C)
15760 W. Power Line Street
Crystal River, FL 34428-6708
SUBJECT: CRYSTAL RIVER NUCLEAR PLANT, UNIT 3 - 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. 05000302/2011008)
Dear Mr. Franke:
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 Crystal River Nuclear
Plant, Unit 3 in May 2011. The inspection team will be led by Mrs. LaDonna Suggs, 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 January 06, 2011, during a telephone conversation between Mr. Dennis Herrin (Crystal
River Lead Compliance Engineer - Licensing & Regulatory Programs) of your staff, and Mrs.
Suggs, 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: March 15 - 17, 2011
- Week 1 of onsite inspection: April 4 - 8, 2011
- Week 2 of onsite inspection: April 18 - 22, 2011
The purposes of the information gathering visit are to obtain information and documentation
needed to support the inspection, to become familiar with the Crystal River Nuclear Plant, Unit 3
fire protection program, fire protection features, post-fire safe shutdown capabilities,plant layout,
and 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 Mrs. Suggs prior to preparing copies of the materials listed in the Enclosures.
The inspection team will try to minimize your administrative burden by specifically identifying
those documents required for inspection preparation.
FPC 2
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 Crystal River 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 Crystal River
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 Mrs. Suggs at (404) 997-4539, 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
FPC 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.: 50-302
License No.: DPR-72
Enclosures: 1. Triennial Fire Protection Inspection Support Documentation
2. Mitigating Strategies Support Documentation
cc w/encl. (See page 4)
FPC 4
cc w/encls: Joseph W. Donahue
R. J. Duncan, II Vice President
Vice President Nuclear Oversight
Nuclear Operations Carolina Power and Light Company
Carolina Power & Light Company Electronic Mail Distribution
Electronic Mail Distribution
Jack E. Huegel
Brian C. McCabe Manager, Nuclear Oversight
Manager, Nuclear Regulatory Affairs Crystal River Nuclear Plant
Progress Energy Carolinas, Inc. Electronic Mail Distribution
Electronic Mail Distribution
David T. Conley
James W. Holt Associate General Counsel
Plant General Manager Legal Dept.
Crystal River Nuclear Plant (NA2C) Progress Energy Service Company, LLC
Electronic Mail Distribution Electronic Mail Distribution
Stephen J. Cahill Mark Rigsby
Engineering Manager Manager, Support Services - Nuclear
Crystal River Nuclear Plant (NA2C) Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution Electronic Mail Distribution
R. Alexander Glenn Senior Resident Inspector
Associate General Counsel U.S. Nuclear Regulatory Commission
(MAC - BT15A) Crystal River Nuclear Generating Plant
Florida Power Corporation U.S. NRC
Electronic Mail Distribution 6745 N Tallahassee Rd
Crystal River, FL 34428
Christos Kamilaris
Director Attorney General
Fleet Support Services Department of Legal Affairs
Carolina Power & Light Company The Capitol PL-01
Electronic Mail Distribution Tallahassee, FL 32399-1050
William A. Passetti Ruben D. Almaguer
Chief Director
Florida Bureau of Radiation Control Division of Emergency Preparedness
Department of Health Department of Community Affairs
Electronic Mail Distribution Electronic Mail Distribution
Daniel R. Westcott Chairman
Supervisor Board of County Commissioners
Licensing & Regulatory Programs Citrus County
Crystal River Nuclear Plant (NA1B) 110 N. Apopka Avenue
Electronic Mail Distribution Inverness, FL 36250
_________________________ G SUNSI REVIEW COMPLETE
OFFICE RII;DRS RII:DRP RII:DRS
NAME SUGGS RICH NEASE
DATE 1/18/2011 1/18/2011 1/18/2011 1/ /2011 1/ /2011 1/ /2011 1/ /2011
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 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). 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.
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).
Enclosure 1
2
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).
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