ML12082A166
| ML12082A166 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/21/2012 |
| From: | Hironori Peterson Engineering Branch 3 |
| To: | Schimmel M Northern States Power Co |
| Zelig Falevits | |
| References | |
| IR-12-008 | |
| Download: ML12082A166 (10) | |
See also: IR 05000282/2012008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
March 21, 2012
Mr. Mark A. Schimmel
Site Vice President
Prairie Island Nuclear Generating Plant
Northern States Power Company, Minnesota
1717 Wakonade Drive East
Welch, MN 55089
SUBJECT: PRAIRIE ISLAND NUCLEAR GENERATING PLANT
NOTIFICATION OF AN NRC TRIENNIAL FIRE PROTECTION
BASELINE INSPECTION 05000282/2012008; 05000306/2012008(DRS)
Dear Mr. Schimmel:
On May 21, 2012, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial Fire
Protection Baseline Inspection at your Prairie Island Nuclear Generating Plant. This inspection
will be performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs Baseline
Fire Protection Inspection Procedure for plants in the process of implementing the National Fire
Protection Association (NFPA) Standard 805 (10 CFR 50.48(c)). 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.
Based on the latest revision to IP 71111.05T dated April 19, 2011, (Effective Date
August 1, 2011), changes were made to the IP, which 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 May 23, 2012.
The schedule for the on-site inspection activity is as follows:
Information Gathering Visit: May 21 - 23, 2012;
B.5.b Requirements: May 23 - 25, 2012; and
Fire Protection Inspection: June 4 - 8, and June 18 - 22, 2012.
M. Schimmel -2-
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 Prairie Island Nuclear
Generating Plants 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. It is requested that this information be provided to the lead
inspector via mail or electronically no later than April 16, 2012. 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 (May 21 - 23, 2012). 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 (June 4, 2012). 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. Zelig Falevits. We understand that our regulatory
contact for this inspection is Mr. John Anderson of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector at (630) 829-
9717 or via e-mail at Zelig.Falevits@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.
M. Schimmel -2-
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 NRC's 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).
Sincerely,
/RA/
Hironori Peterson Chief
Engineering Branch 3
Division of Reactor Safety
Docket No.: 50-282; 50-306
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Distribution via ListServ'
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Inspection Report 05000282/2012008; 05000306/2012008(DRS)
On-site Inspection Dates: May 21 - 23, 2012 (Information Gathering Visit)
May 23 - 25, 2012 (B.5.b Requirements)
June 4 - 8, 2012 (Fire Protection Inspection)
June 18 - 22, 2012 (Fire Protection Inspection)
Inspection Procedures: IP 71111.05T, Fire Protection Triennial
IP 71152, "Problem Identification and Resolution"
Inspectors: Zelig Falevits, Lead Inspector
(630) 829-9717
Zelig.Falevits@nrc.gov
Benny Jose Robert A. Winter
(630) 829-9756 (630) 829-9758
Benny.Jose@nrc.gov Robert.Winter@nrc.gov
I. Information Requested Prior To the Information Gathering Visit
The following information is requested by April 16, 2012. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Mr. Zelig Falevits (e-mail address Zelig.Falevits@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 and for a senior
reactor analysis). Please provide the B.5.b Mitigating Strategies information (Items B.1
through B.11) on a separate CD.
A. Fire Protection Program Supporting Documentation
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 (TS), license (including the
fire protection license condition), and technical requirements manual (TRM)
or equivalent for fire protection structures, systems, and components.
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 REQUEST
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. In
addition, please include those procedures which operators would use for
initial response to a fire, such as annunciator or alarm response procedures,
the procedure used for activating the fire brigade, and the procedure which
directs operators to the applicable safe shutdown procedure.
5. A copy of the current fire protection system Health Report, if available.
6. A copy of the current plant drawings referred to as Horse Notes, if available.
7. Status of NFPA 805 (10 CFR Part 50.48(c)) implementation.
B. Mitigating Strategies Supporting Documentation
1. A list of all modifications to regulatory commitments made to meet the
requirements of Section B.5.b of the Interim Compensatory Measure (ICM)
Order, EA-02-026, dated February 25, 2002, the subsequently imposed
license conditions, and Title 10 of the Code of Federal Regulations (10 CFR)
Part 50.54(hh)(2).
2. Copies of procedures and/or 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 (NEI) 06-12 and the site-specific
procedures or guidelines that are used to implement each strategy.
4. Engineering evaluations and calculations that were used to verify engineering
bases for the mitigation strategies.
5. Piping and instrumentation diagrams or simplified flow diagrams for systems
relied on in the mitigation strategies. These could be of the type used for
training.
6. A list of modification packages or simplified drawings/descriptions of
modifications made to plant systems to implement the mitigation strategies.
7. Copies of procedures used to inventory equipment (e.g., hoses, fittings,
pumps, etc.) required to implement the mitigation strategies.
8. A list of B.5.b strategies, if any, that have implementing details that differ from
those documented in the submittals and the safety evaluation.
9. A copy of site general arrangement drawing(s) that show the majority of
buildings/areas referenced in B.5.b documents.
2 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
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.
12. 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.
II. Information Requested During the Information Gathering Visit (May 21 - 23, 2012)
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 four sets of CDs (searchable, if possible). In addition, two
sets of hard copy drawings are requested for Item 4.a. through Item 4.f.
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. Licensing Information:
a. 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;
b. All licensing correspondence associated with the comparison to Standard
Review Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing
purposes;
c. Exemptions from 10 CFR 50.48 and 10 CFR Part 50, Appendix R, and
associated licensing correspondence;
d. For pre-1979 plants, all licensing correspondence associated with those
sections of 10 CFR Part 50, Appendix R, that are not applicable to the plant
under 10 CFR 50.48(b)(1). Specifically, the licensing correspondence
associated with those fire protection features proposed or implemented by the
licensee that have been accepted by the NRC staff as satisfying the provisions
of Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 reflected in
the NRC fire protection SERs issued before February 19, 1981, (10 CFR
Part 50.48(b)(1)(i)); or those fire protection features, which were accepted by
the NRC staff in comprehensive fire protection SERs issued before
Appendix A to BTP APCSB 9.5-1 was published in August 1976 (10 CFR
Part 50.48(b)(1)(ii));
e. For post-1979 plants, all licensing correspondence associated with the
comparison to Standard Review Plan (NUREG-0800), Section 9.5.1 or
equivalent for licensing purposes;
3 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
f. For NFPA 805 transition plants provide: (1) all correspondence to and
responses from the NRC; (2) a list of all areas showing assessment review
status; (3) assessments for all areas that have been completed; and (4) a list
of all identified non-conformances, and their respective compensatory
measure(s); and
g. The final safety analysis report (FSAR) sections applicable to fire protection,
FHA, and SSA in effect at the time of original licensing.
3. Fire Protection Program:
a. A listing of changes made to the FPP (including associated adverse to SSA)
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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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;
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.
4. 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 and 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. Plant layout and equipment drawings which identify the physical plant
locations of hot standby and cold shutdown equipment for selected fire
zones/areas (to be determined during information gathering visit);
c. Plant layout drawings which identify the general location of the post-fire
emergency lighting units;
d. One-line schematic drawings of the electrical distribution system for
4160 Volts alternating current (Vac) down to 480Vac;
4 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
e. One-line schematic drawings of the electrical distribution system for 250 Volts
direct current (Vdc) and 125Vdc systems as applicable;
f. Logic diagrams showing the components used to achieve and maintain hot
standby and cold shutdown; and
g. Safe shutdown cable routing database (requested electronically such as on
compact disc, if available).
5. Operations Response for Fire Protection:
a. Pre-fire plans for selected fire zones/areas (to be determined during
information gathering visit);
b. Plant operating procedures which specify the initial operations response to a
fire alarm or annunciator; and
c. Procedure for calling out the fire brigade and requesting off-site assistance.
6. 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. Listing of current fire impairments, including durations.
7. 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.
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;
c. Informal discussion on the status of NFPA-805 transition and associated risk
insights identified; and
5 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
d. 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 (June 4, 2012)
The following information is requested to be provided on the first day of inspection. It is
requested that this information be provided on four sets of CDs (searchable, if possible).
1. Program Procedures:
a. Procedures for:
i. Administrative controls (such as allowed out of service times and
compensatory measures) for fire protection systems and components;
ii. Control of transient combustibles; and
iii. 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 Part 50.59
evaluations) and Generic Letter (GL) 86-10 (or adverse to safe shutdown)
evaluations;
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;
f. Vendor manuals and information for fire protection equipment (such as detection,
suppression systems, fire pumps), applicable to selected fire zones/areas (to be
determined during information gathering visit). It is acceptable to make
vendor manuals available to the inspectors in lieu of providing a copy; and
6 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
g. List of all fire protection or Appendix R calculations.
3. Assessment and Corrective Actions:
a. The three most recent fire protection Quality Assurance (QA) audits and/or fire
protection self-assessments; and
b. Corrective action documents (e.g., condition reports, including status of
corrective actions) generated as a result of 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.
7 Enclosure
M. Schimmel -3-
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 NRC's 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).
Sincerely,
/RA/
Hironori Peterson, Chief
Engineering Branch 3
Division of Reactor Safety
Docket No.: 50-282; 50-306
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Distribution via ListServ'
DISTRIBUTION:
Breeda Reilly
RidsNrrPMPrairieIsland Resource
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RidsNrrDirsIrib Resource
Chuck Casto
Cynthia Pederson
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DRPIII
DRSIII
Patricia Buckley
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OFFICE RIII E RIII RIII RIII RIII
NAME ZFalevits:ls PHironori
DATE 03/21/12 03/21/12
OFFICIAL RECORD COPY