ML22343A117
| ML22343A117 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/12/2022 |
| From: | James Drake NRC/RGN-IV/DORS/EB2 |
| To: | Gerry Powell South Texas |
| Drake J | |
| References | |
| IR 2023010 | |
| Download: ML22343A117 (11) | |
See also: IR 05000498/2023010
Text
December 12, 2022
Mr. G. T. Powell
President and CEO
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, TX 77483
SUBJECT: SOUTH TEXAS PROJECT - NOTIFICATION OF AN NRC FIRE PROTECTION
BASELINE INSPECTION (NRC INSPECTION REPORT) 05000498/2023010 AND
05000499/2023010 AND REQUEST FOR INFORMATION
Dear Mr. Powell:
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 South Texas Project
in January 2023. The inspection team will be comprised of three reactor inspectors from the
NRC Region IV office and one reactor inspector from the NRC Region I office. The inspection
will be conducted in accordance with Inspection Procedure 71111, Attachment 21N.05, Fire
Protection Team Inspection, the NRCs baseline fire protection inspection procedure.
The schedule for the inspection is as follows:
Information gathering visit:
January 9 - 12, 2023
Onsite inspection:
January 30 - February 3, 2023, and February 13 - 17, 2023
The purpose of the information gathering visit is to obtain information and documentation
needed to support the inspection and to become familiar with the fire protection program, fire
protection features, post-fire safe shutdown capabilities and plant layout.
The team lead will review the initial set of documents requested in the enclosure to select the
scope of structures, systems, and components for evaluation, and identify additional
documents needed to support the inspection. The enclosure to this letter provides an initial list
of the documents the team will need for review. We request that your staff transmit 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 the NRC Region IV
office by the dates listed in the enclosure.
During the inspection planning meeting(s), the team leader will discuss the following inspection
support administrative details: (1) office space size and location; (2) specific documents
requested to be made available to the team in their office spaces; (3) arrangements for reactor
site access (including radiation protection training, security, safety, and
G. Powell
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fitness for duty requirements); and (4) the availability of knowledgeable plant staff and licensing
organization personnel to serve as points of contact during the inspection.
We request that during the on-site inspection weeks you ensure that copies of analyses,
evaluations, or documentation regarding the implementation and maintenance of the station
fire protection program, including the success path necessary to achieve and maintain the
nuclear safety performance criteria, 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 (i.e., fire protection
compliance assessment documents). Also, personnel should be available at the site during
the inspection who are knowledgeable regarding those plant systems required to achieve and
maintain safe and stable plant conditions, including the electrical aspects of the nuclear safety
capability assessment, reactor plant fire protection systems and features, and the station fire
protection program and its implementation.
PAPERWORK REDUCTION ACT STATEMENT
This letter contains mandatory information collections that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
approved these information collections (approval number 3150-0011). Send comments
regarding this information collection to the Information Services Branch, Office of the Chief
Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,
DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer,
Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of
Management and Budget, Washington, DC 20503.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct nor 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 OMB control number.
This letter and its enclosure will be made available for public inspection and copying at
http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in
accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding
G. Powell
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Your cooperation and support during this inspection will be appreciated. If you have questions
concerning this inspection or the inspection teams information or logistical needs, please contact
me, the team lead inspector, in the Region IV office at (817) 200-1558,
(817) 773-6712 (m), or James.Drake@nrc.gov.
Sincerely,
Jim Drake
Senior Reactor Inspector Engineering Branch 2
Division of Reactor Safety
Docket Nos: 05000498 and 05000499
License Nos: NPF-76 and NPF-80
Enclosure:
Triennial Fire Protection Inspection Document Request
cc w/ encl: Distribution via LISTSERV
Signed by Drake, James
on 12/12/22
SUNSI Review
By: JFD
ADAMS:
Yes
No
Sensitive
Non-Sensitive
Non-Publicly Available
Publicly Available
Keyword
OFFICE
SHP:DRSS/MLB
NAME
J. Drake
SIGNATURE
/RA/
DATE
12/12/22
Enclosure
Triennial Fire Protection Inspection Document Request
The documents and information requested below should generally be made available to
the inspection team prior to the inspection. Electronic format is the preferred format, except
where specifically noted. If electronic files are made available via a secure document
management service, then the remote document access must allow inspectors to
download, save, and print the documents.
If a secure document management service is utilized, it is recommended that a separate
folder be used corresponding to each item listed below. It is recommended that multiple
documents within each folder be individually entered and combined into a ZIP file which
is uploaded into the same folder. Documents should be identified by both document
number and noun name. Electronic media on compact disc or paper records (hard copy)
are also acceptable.
Where C-size paper drawings are requested, please prepare two copies. Retain one copy
on site for the Teams use during the inspection weeks. Send one copy to the team leader
at the NRC Region IV office.
To allow review before the on-site information gathering visit, the documents requested in
items
A.1 thru A.13 should be made available to the team no later than December 30, 2022.
Based on review of the documentation, the team leader will identify the scope for the
inspection prior to the end of the on-site information gathering visit or in-office review of the
information obtained.
This document request is based on typical documents that a generic plant might have. As
such, this generic document request is not meant to imply that any specific plant is required
to have all the listed documents. It is recognized that some documents listed below may
not be available for your plant. In addition, the document titles listed below are based on
typical industry document names; your plant-specific document titles may vary.
To allow review before the on-site inspection weeks, all requested documents should be
made available to the team no later than January 16, 2023.
A.
DESIGN AND LICENSING BASIS DOCUMENTS
A.1
Post-fire Nuclear Safety Capability, Systems, and Separation Analysis
A.2
Fire Hazards Analysis and/or NFPA 805 Design Basis Document
A.3
Fire Probabilistic Risk Assessment (PRA) Summary Document or full
PRA Document
A.4
NFPA 805 Transition Report, developed in accordance with NEI 04-02
A.5
Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3)
A.6
Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4)
2
A.7
Facility Operating License.
A.8
Technical Specifications (electronic format only).
A.9
Updated Final Safety Analysis Report (electronic format only).
A.10
A list of the ten most risk significant plant systems for core damage
frequency from the fire protection probabilistic risk assessment.
A.11
A list of the ten most risk significant plant systems for large early
release frequency from the fire protection probabilistic risk
assessment.
A.12
Plant layout drawings which identify: (electronic format and C-size
paper drawings)
Plant fire area boundaries
Combustible control zone drawings
Areas protected by automatic fire suppression and detection
A.13
For recovery actions, provide the following:
Manual Action Feasibility Study
Operator Time Critical Action Program
Timelines for time-critical manual actions
Timeline validations
B.
GENERAL PLANT DESIGN DOCUMENTS
B.1
Piping and instrumentation diagrams (P&IDs) and legend list for
components used to achieve and maintain post-fire safe shutdown for the
sample systems or fire areas selected (electronic format and C-size paper
drawings).
B.2
Piping and instrumentation diagrams and legend list for fire protection
systems, including the fire water supply; water suppression sprinklers;
and deluge, gaseous suppression systems for the sample systems or fire
areas selected (electronic format and C-size paper drawings).
B.3
AC and DC electrical system single line diagrams, from off-site power
down to the highest safety-related bus level (typically 4kV, EDG bus)
(electronic format and C-size paper drawings).
B.4
Single line diagrams for motor control centers (MCCs) that supply post-
fire nuclear safety component loads for the sample systems or fire areas
selected (electronic format and C-size paper drawings).
B.5
Equipment location drawings which identify the physical plant locations of
post- fire safety shutdown equipment for the sample systems or fire area
selected (electronic format and C-size paper drawings
3
C.
CLASSIC FIRE PROTECTION
C.1
Copy of fire protection program implementing procedures (e.g.,
administrative controls, surveillance testing, and fire brigade).
C.2
List, with descriptions, of calculations and engineering analyses,
studies, or evaluations for the fire protection system, including the fire
water system.
C.3
Last two completed surveillances of fire protection features for the
sample systems or features within the fire areas selected (detection,
suppression, damper inspections, damper tests, penetration inspections,
barrier inspections, etc.).
C.4
List, with descriptions, of routine tests, surveillances, and
preventive maintenance on fire pumps, including pump
controllers and batteries.
C.5
Last two completed annual fire pump pressure and flow tests with a
complete copy of the test procedure.
C.6
Last two completed monthly and/or quarterly fire pump tests with a
complete copy of the test procedure.
C.7
Last two completed fire water system flow tests and flushes with a complete
copy of the test procedure.
C.8
For Fire Brigade Drills, provide the following:
Last five fire brigade drill critiques
Last drill critique for a drill with off-site fire department support
Last unannounced drill critique
Last back-shift drill critique
Dates, shifts, and locations of unannounced drills for last three years
Summary of any unsatisfactory drill performance items for last three years
Last unannounced drill critique by a qualified individual independent
of the licensees staff
C.9
For fire brigade equipment provide the following:
Procedure for inventory and inspection
Most recent inspection and inventory results
4
C.10
Fire Brigade Qualifications, including self-contained breathing apparatus
(SCBA), and training lesson plans.
C.11
Copy of the evaluation or analysis of the effects of fire suppression
activities on the ability to achieve the nuclear safety performance criteria
for the sample systems or fire areas selected demonstrating:
The automatic or manually actuation of a suppression system, due to a
fire in a single location, will not indirectly cause damage to the success
path
The inadvertent actuation or rupture of a suppression system
will not indirectly cause damage to the success path
Adequate drainage for areas protected by water suppression systems
The hydrostatic rating of any floor penetration seals installed within
the fire areas that are credited with keeping water from leaking into fire
areas below
C.12
Pre-fire plans for all fire areas.
C.13
Impairment Log (at start of inspection) for fire protection features that are
out of service.
C.14
List of penetration seal work, re-work, or installation activities, in the last
three years.
C.15
List of fire wrap work, re-work, or installation activities, in the last three years.
C.16
Fire protection system health reports for the two most recent quarters.
C.17
Fire protection program health reports for the two most recent quarters.
C.18
Licensee evaluations of industry operating experience concerning fire
protection issues completed in the last three years.
C.19
List of fire event analysis reports for the last three years.
C.20
Fire protection program requirements (e.g., limiting conditions for
operation, surveillance test requirements) covered by technical
specifications, the technical requirements manual, the updated final safety
analysis report, procedures or similar documents.
C.21
Fire Protection System(s) Design Basis Document.
C.22
List of applicable NFPA codes and standards and issuance dates (i.e.,
codes of record).
C.23
A list or document identifying any deviations from the NFPA codes of record.
5
C.24
Organization charts of site personnel down to the level of fire protection
staff personnel.
C.25
A contact list of key site personnel who will be supporting this inspection,
giving the office location and phone number.
C.26
The team would like to observe an unannounced fire brigade drill in the
plant, if possible, during the week of July 11, 2022. Please put us in
contact with the appropriate personnel for planning fire brigade drills during
the onsite information gathering trip.
C.27
The team would like to perform a walkdown of the sample fire protection
systems and/or fire areas with fire protection personnel in the plant during
the week of June 27, 2022. Please put us in contact with the appropriate
personnel for planning the walkdowns during the onsite information
gathering trip.
D.
ELECTRICAL
D.1
Electrical system health reports for the two most recent quarters.
D.2
Surveillance procedures and last surveillance demonstrating
operability of components required for alternative shutdown.
E.
OPERATIONS
E.1
The team would like to perform a walkthrough of a sample of post-fire
safe shutdown procedures with qualified operators in the plant during
the week of June 27, 2022. Please put us in contact with the
appropriate personnel for planning the walkthroughs during the onsite
information gathering trip.
E.2
List, with descriptions, of licensed operator Job Performance Measures
(JPMs) for operator actions required to achieve and maintain post-fire
E.3
List, with descriptions, of non-licensed operator training associated with
non- licensed operator actions to achieve and maintain post-fire
nuclear safe shutdown (including JPMs, in-field training walkdowns,
simulations, or initial qualification).
E.4
Lesson plans for post-fire safe shutdown training for licensed and non-
licensed operators.
E.5
Thermal hydraulic calculation or analysis that determines the time
requirements for time-critical manual operator actions.
E.6
Operating procedures to achieve and maintain post-fire safe shutdown
from the control room and requiring a control room evacuation.
6
E.7
For safe shutdown equipment and tools, provide the following:
Procedure for inventory and inspection
Most recent inspection and inventory results
.
E.8
List, with descriptions, of procedures that implement cold shutdown repairs
E.9
For cold shutdown repairs, if required, provide the following:
Procedure for inventory and inspection (i.e., needed tools, material, etc.)
Most recent inspection and inventory results
F.
ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE
ACTION PROGRAMS
F.1
Copies of procedures that control the configuration of the fire protection
program, features, and post-fire safe shutdown methodology and system
design. Also, copies of procedures that govern the implementation of plant
modifications, maintenance, and special operations and their impact on fire
protection.
F.2
List of open and closed condition reports for the fire protection systems
for the last three years.
F.3
List of open and closed condition reports associated with the post-fire
safe shutdown analysis for the last three years.
F.4
List of open and closed condition reports associated with operator
actions to achieve and maintain post-fire safe shutdown for the last
three years.
F.5
List of open and closed condition reports associated with the fire
protection program including plant change evaluations, post-fire
operating procedures and/or training, timeline evaluations for
operator actions, and supporting engineering evaluations, analysis, or
calculations for the last three years.
F.6
List of open and closed condition reports for emergency lighting units for
the last three years.
F.7
Self-assessments, peer assessments, and audits of fire protection
activities for the last three years.
F.8
Self-assessments, peer assessments, and audits of post-fire nuclear
safety capability methodology for the last three years.
F.9
Provide administrative procedures that control temporary modifications,
permanent plant changes, design changes, procedure changes, ageing
management changes, equivalency evaluations, suitability analyses,
calculations, commercial grade dedication, safety-security interface, and
repairs.
7
F.10
Provide procedures that control the following: combustible controls, hot
work, monitoring, compensatory measures, and workarounds.
F.11
Last five hot work permits (at power).
F.12
Last five transient combustible permits (at power).
G.
AGING MANAGEMENT PROGRAM
G.1
Copies of the aging management programs applicable to fire protection
including but not limited to the following:
Fire Protection
Fire Water System
Aboveground Metallic Tanks
Buried and Underground Piping and Tanks
G.2
Copies of procedures, work orders, preventive maintenance tasks, or
other documents which implement the commitments made as part of
the license extension related to fire protection.
G.3
List of aging management activities related to fire protection performed to date.