ML110550758
| ML110550758 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/24/2011 |
| From: | O'Keefe N NRC/RGN-IV/DRS/EB-2 |
| To: | Halpin E South Texas |
| References | |
| IR-11-006 | |
| Download: ML110550758 (10) | |
See also: IR 05000498/2011006
Text
UNITED STATES
NUC LE AR RE G UL AT O RY C O M M I S S I O N
R E GI ON I V
612 EAST LAMAR BLVD , SU I TE 400
AR LI N GTON , TEXAS 76011-4125
February 24, 2011
Mr. Edward D. Halpin
President and
Chief Executive Officer
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, TX 77483
SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1
AND 2 - NOTIFICATION OF AN NRC TRIENNIAL FIRE PROTECTION
BASELINE INSPECTION (NRC INSPECTION REPORT 05000498/2011006;
05000499/2011006) AND REQUEST FOR INFORMATION
Dear Mr. Halpin:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC),
Region IV staff will conduct a triennial fire protection baseline inspection at your South Texas
Project facility beginning in May 2011. The inspection team will be comprised of reactor
inspectors from the NRC Region IV office. The team will conduct the inspection in accordance
with the baseline Inspection Procedure 71111.05T, Fire Protection- (Triennial) dated
January 1, 2011.
The schedule for the inspection is as follows:
- Information gathering visit: May 24-26, 2011
- Onsite inspection: June 13 - 17, 2011
June 27 - July 1, 2011
The purposes of the information gathering visit are to obtain information and documentation
needed to support the inspection, to become familiar with the fire protection programs, 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). Four inspectors will participate in the information
gathering visit to select the fire areas for evaluation, identify additional documents needed to
support the inspection, obtain unescorted access, and meet with the key personnel who will
support the inspection. The fire area selection will require a walkdown of candidate fire areas
accompanied by key personnel from your staff. The enclosure to this letter provides an initial
list of the documents the team will need for their review. We request that your staff transmit
STP Nuclear Operating Company -2-
copies of the documents listed in the enclosure to the NRC Region IV office for team use in
preparation for the inspection. Please send this information so that it will arrive in our office in
Arlington, Texas, by the dates listed in the enclosure.
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; and the
availability of knowledgeable plant engineering, operations and licensing organization personnel
to serve as points of contact during the inspection.
We request that during the onsite inspection weeks, you ensure that copies of analyses,
evaluations, or documentation regarding the implementation and maintenance of the 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 that establish that your fire protection program satisfies the 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, please ensure the availability of appropriate personnel knowledgeable of: (1) plant
systems required to achieve and maintain safe shutdown conditions from inside and outside the
control room, (2) the electrical aspects of the post-fire safe shutdown analyses, (3) reactor plant
fire protection systems, and (4) the 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.
In accordance with 10 CFR 2.390 of the NRCs 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).
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 Greg Pick, the lead inspector, in the Region IV office at (817) 860-8270, or by email,
greg.pick@nrc.gov.
Sincerely,
/RA/
N. OKeefe, Chief
Engineering Branch 2
Division of Reactor Safety
STP Nuclear Operating Company -3-
Dockets: 50-498; 50-499
Enclosure: Triennial Fire Protection
Inspection Documentation Request List
Kevin Richards, Senior Vice President Marilyn Kistler
STP Nuclear Operating Company Staff Specialist, Licensing
South Texas Project STP Nuclear Operating Company
P.O. Box 289 South Texas Project
Wadsworth, TX 77483 P.O. Box 289
Wadsworth, TX 77483
David W. Rencurrel
Senior Vice President Units 1 and 2 Cheryl Mele
STP Nuclear Operating Company City of Austin
South Texas Project Electric Utility Department
P.O. Box 289 721 Barton Springs Road
Wadsworth, TX 77483 Austin, TX 78704
Louis Peter, Plant General Manager J. J. Nesrsta/R. K. Temple
STP Nuclear Operating Company Ed Alercon/Kevin Pollo
South Texas Project City Public Service
P.O. Box 289 P.O. Box 1771
Wadsworth, TX 77483 San Antonio, TX 78296
Tim Powell, Vice President, A. H. Gutterman, Esq..
Technical Support and Oversight Morgan, Lewis & Bockius LLP
STP Nuclear Operating Company 1111 Pennsylvania Avenue, NW
South Texas Project Washington, DC 20004
P.O. Box 289
Wadsworth, TX 77483 Richard A. Ratliff, P.E., L.M.P.
Radiation Safety Licensing Branch Manager
A. W. Harrison, Manager, Licensing Division for Regulatory Services
STP Nuclear Operating Company Texas Department of State Health
South Texas Project Mail Code 2385
P.O. Box 289 P.O. Box 149347
Wadsworth, TX 77483 Austin, TX 78714-9347
Charles T. Bowman, General Manager, Brian Almon
Nuclear Safety Assurance Public Utility Commission of Texas
STP Nuclear Operating Company P.O. Box 13326
South Texas Project Austin, TX 78711-3326
P.O. Box 289
Wadsworth, TX 77483
STP Nuclear Operating Company -4-
Environmental and Natural Resources Kevin Howell/Catherine Callaway/Jim von
Policy Director, Office of the Governor Suskil
P.O. Box 12428 NRG Energy, Inc.
Austin, TX 78711-3189 1301 McKinney, Suite 2300
Houston, TX 77010
Mr. Nate McDonald
Judge, Matagorda County Peter G. Nemeth
Matagorda County Courthouse Crain, Caton, & James, P.C.
1700 Seventh Street P.O. Box 289
Bay City, TX 77414 Mail Code: N5005
Wadsworth, TX 77483
Anthony P. Jones, Chief Boiler Inspector
Texas Department of Licensing and Chief, Technological Hazards
Regulation Branch
Boiler Division FEMA Region VI
E.O. Thompson State Office Building 800 North Loop 288
P.O. Box 12157 Federal Regional Center
Austin, TX 78711 Denton, TX 76201-3698
Susan M. Jablonski Chairperson
Office of Permitting, Remediation and Radiological Assistance Committee
Registration FEMA Region VI
Texas Commission on Environmental 800 North Loop 288
Quality Federal Regional Center
MC-122 Denton, TX 76201-3698
P.O. Box 13087
Austin, TX 78711-3087 C. Kierksey
City of Austin
Ted Enos Electric Utility Department
4200 South Hulen, Suite 422 721 Barton Springs Road
Fort Worth, TX 76109 Austin, TX 78704
STP Nuclear Operating Company -5-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Art.Howell@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
DRP Deputy Director (Troy.Pruett@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Vacant)
Senior Resident Inspector (John.Dixon@nrc.gov)
Resident Inspector (Binesh.Tharakan@nrc.gov)
Branch Chief, DRP/A (Wayne.Walker@nrc.gov)
Senior Project Engineer, DRP/A (David.Proulx@nrc.gov)
STP Administrative Assistant (Lynn.Wright@nrc.gov)
Project Engineer, DRP/A (Laura.Micewski@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Mohan.Thadani@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource
Inspection Reports/MidCycle and EOC Letters to the following:
ROPreports
Only inspection reports to the following:
OEDO RIV Coordinator (James.Trapp@nrc.gov)
DRS/TSB STA (Dale.Powers@nrc.gov)
R:\Reactors\STP\STP TFP RFI_GAP.Docx ADAMS ML
ADAMS: No Yes SUNSI Review Complete Reviewer Initials: GAP
Publicly Available Non-Sensitive
Non-publicly Available Sensitive
SRI/DRS/EB2 C:DRS/EB2
GPick NOKeefe
/RA/ /RA/
02/24/2011 02/24/2011
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
ENCLOSURE
Triennial Fire Protection Inspection Documentation Request
Please provide the following documents (items 1 - 4) prior to the onsite information-gathering
visit, preferably no later than May 20, 2011. Where practical, please provide copies
electronically. Please provide an index of the requested documents which includes a brief
description of what the document is, and the numerical heading associated with the request
(i.e., where it can be found in the list of documents requested).
1. The current version of your fire protection program and fire hazards analysis.
2. Post-fire safe shutdown analysis and the supporting calculations that demonstrate
acceptable plant response.
3. Copies of the licensing basis documents for fire protection (safety evaluation reports,
pertinent sections of the final safety analysis report, exemptions, deviations, letters
to/from the NRC regarding fire protection/fire safe shutdown, etc.).
4. The fire probabilistic risk assessment or portions of the plants individual plant
examination for external events report addressing fire events. Also, include the results
of any post-IPEEE reviews, and listings of actions taken/plant modifications conducted in
response to IPEEE information.
5. A copy of the documents that support your multiple spurious operation evaluations (i.e.,
expert panel reports, evaluation packages, et cetera).
Please provide the following documentation (items 5 - 47) during the information-gathering visit
in order to support inspection preparation. Whenever practical, please provide copies
electronically. Drawings should be provided as paper copies of sufficient size such that all
details are legible.
6. Plant layout and equipment drawings for fire areas that identify: (a) the physical plant
locations of major hot standby and cold shutdown equipment; (b) plant fire area and/or
fire zone delineation; and (c) the locations of fire protection equipment, such as
detection, suppression, and post-fire emergency lighting units; and (d) fire area
boundaries. The specific documents needed to support inspection preparation will be
discussed during the site visit.
7. Fire protection program implementing procedures (e.g., administrative controls, operator
response procedures for fires, fire fighting procedures, etc.).
8. Operating procedures used for achieving and maintaining hot and cold shutdown
conditions from the control room in the event of a fire outside the control room (III.G.2
areas).
9. Operating procedure(s) used to implement an alternative shutdown (III.G.3 areas)
capability with or without control room evacuation.
-1- Enclosure
10. A list of equipment used to achieve and maintain hot standby and cold shutdown in the
event of a fire (safe shutdown equipment lists).
11. Piping and instrumentation (flow) diagrams showing the components used to achieve
and maintain hot standby and cold shutdown for normal and alternate shutdown. Please
provide one copy of the piping and instrumentation (flow) diagrams for these systems of
a size sufficient to read all details. These should include the systems used for reactor
coolant system (RCS) makeup, RCS pressure control, decay heat removal, and
reactivity control, including the essential support systems.
12. A listing, with descriptions, of design change packages which were determined to impact
fire protection and post-fire safe shutdowns, performed since June 1, 2008.
13. Copies of fire protection program change evaluations (Generic Letter 86-10 evaluations)
performed since June 1, 2008.
14. A listing of open and closed corrective action documents initiated since June 1, 2008,
which relate to the fire protection program or equipment, including corrective actions for
fire-induced circuit failures, both single and multiple spurious actuations (for the selected
fire areas). Include Corrective Action Process document number, date, and subject.
15. A listing of the applicable codes and standards (with the versions/dates) related to the
design of plant fire protection features and evaluations of any code deviations. Copies
of these codes should be available for review.
16. Drawings of the portions of the emergency lighting system that support fire response.
17. Procedures used to remove smoke from safety-related areas and the engineering
studies or calculations that support the design basis.
18. Drawings of communication systems credited in the license basis for firefighting and
plant operations during fires where control room is occupied and/or evacuated.
19. Piping and instrumentation (flow) diagrams for the fire water and sprinkler systems.
20. A listing of maintenance and surveillance testing procedures for alternative shutdown
capability and fire barriers, detectors, pumps and suppression systems. Also, include a
list of maintenance and surveillance testing procedures used to verify fuse and breaker
coordination in accordance with the post-fire safe shutdown coordination analysis.
21. Maintenance rule performance criteria, and a summary of the performance history for
systems or functions monitored within the maintenance rule program that support the fire
protection program or involve safe shutdown equipment, over the period since June 1,
2008.
-2- Enclosure
22. A copy of fire protection program requirements (e.g., limiting conditions for operation,
surveillance test requirements) covered by Technical Specifications, Technical
Requirements Manual, Updated Final Safety Analysis Report, or similar documents.
23. Copies of internal and external self-assessments, audits, peer-assessments or similar
reviews related to post-fire safe shutdown capability or the fire protection program
completed since June, 2008.
24. A list of manual actions taken outside the control room which are credited to mitigate the
consequences of fires in III.G.2 areas (non-alternative shutdown areas). The list should
group actions by the initiating fire area or zone and indicate where the action must take
place.
25. Electronic copies of operator study guides (i.e., lesson plan text and graphics) or design
basis documents that describe the purpose/function/operating characteristics of the safe
shutdown systems (RCS makeup, RCS pressure control, decay heat removal, and
reactivity control, including the essential support systems).
26. Two copies of one-line diagrams of the AC and vital DC electrical distribution systems.
These should depict how power gets from the switchyard to the engineered safety
feature loads (480V and 4160V).
27. A list of automatic and manually initiated gaseous fire suppression systems in the plant,
giving location and the key equipment being protected.
28. A list of repairs (and the procedure that controls the actions) needed to: a) reach and/or
maintain hot shutdown and b) reach and/or maintain cold shutdown.
29. A list of high to low pressure interface valves.
30. A copy of procedures governing the training and operation of the fire brigade.
31. Organization charts of site personnel down to the level of fire protection staff personnel.
32. A contact list of key site personnel who will be supporting this inspection, giving location
of their office and phone number onsite.
33. The team would like to observe an unannounced fire brigade drill in the plant, if possible,
during the week of June 27, 2011. Please put us in contact, during the onsite
information gathering trip, with the appropriate personnel for planning drills.
34. The team would like to perform a walkthrough of the procedure for control room
evacuation due to fire with qualified operators in the plant during the week of June 13,
2011. Please put us in contact, during the onsite information gathering trip, with the
appropriate personnel for planning the walkthrough.
-3- Enclosure
The following documents (items 35 - 48) involve B.5.b mitigating strategies.
35. A copy of the license condition that incorporated the requirements issued to address the
requirements of Section B.5.b of the ICM Order, EA-02-026, dated February 25, 2002,
and 10 CFR 50.54(hh)(2).
36. 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).
37. A list of procedures/guidelines which 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.
38. 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.
39. A list of engineering evaluations/calculations that were used to verify engineering bases
for the mitigation strategies.
40. Copies of piping and instrumentation diagrams (P&ID) or simplified flow diagrams for
systems relied upon in the mitigation strategies. These could be the type used for
training.
41. A list of modification packages and simplified drawings/descriptions of modifications that
were made to plant systems to implement the mitigation strategies.
42. Copies of procedure(s) used to inventory equipment (hoses, fittings, pumps, etc.)
required to be used to implement the mitigation strategies.
43. A list of B.5.b strategies, if any, which have implementing details that differ from that
documented in the submittals to the NRC and the safety evaluation report.
44. A copy of site general arrangement drawing(s) that show the majority of buildings/areas
referenced in B.5.b documents.
45. Training records/ training matrix/ lesson plans related to B.5.b.
46. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments)
required to implement any mitigating strategies.
47. The team would like to perform a walkthrough of the procedure implementing a sample
mitigating strategy (to be selected by the inspector during the information gathering visit)
and the inventory equipment (hoses, fittings, pumps, etc.) required to be used to
implement the mitigation strategies during the week of June 13, 2011. Please put us in
contact with the appropriate personnel for planning the walkthrough during the onsite
information gathering trip
-4- Enclosure
The following documentation needs (items 48 - 50) will be dependent upon sample selections,
and will be finalized during discussions with your staff. Please provide the required documents
prior to the week of June 13, 2011. Whenever practical, please provide copies electronically.
Drawings should be provided as paper copies of sufficient size such that all details are legible.
48. Pre-fire plans for the selected fire areas (areas to be selected by the team during the
information-gathering trip).
49. List of identified fire induced circuit failure configurations (for the selected fire areas) that
could prevent operation or cause maloperation of equipment credited for safe shutdown
in the event of a fire. Include failure configurations associated with hot shorts, open
circuits, or shorts to ground identified as potentially causing spurious or multiple spurious
actuations or maloperations of this equipment.
50. Cable routing information for components and equipment, credited for safe shutdown in
the selected fire areas. This information request item will be discussed and finalized
with your staff during the information gathering visit.
-5- Enclosure