ML13282A500

Notification of NRC Triennial Fire Protection Baseline Inspection (NRC Inspection Report 05000445-14-008 and 05000446-14-008) and Request for Information

ML13282A500
Person / Time
Site:	Comanche Peak
Issue date:	10/09/2013
From:	Geoffrey Miller NRC/RGN-IV/DRS/EB-2
To:	Flores R Luminant Generation Co
References
Download: ML13282A500 (9)

See also: IR 05000445/2014008

Text

UNITE D S TATE S

NUC LEAR RE GULATOR Y C OMMI S SI ON

R E G IO N I V

1600 EAST LAMAR BLVD

AR L INGTON , TEXAS 7 60 11 - 4511

October 9, 2013

Rafael Flores, Senior Vice President

and Chief Nuclear Officer

Attention: Regulatory Affairs

Luminant Generation Company LLC

Comanche Peak Nuclear Power Plant

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE

INSPECTION (NRC INSPECTION REPORT 05000445/2014008 and

05000446/2014008) AND REQUEST FOR INFORMATION

Dear Mr. Flores:

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 the Comanche Peak

Nuclear Power Plant in January and February of 2014. The inspection team will be comprised

of four reactor inspectors from the NRC Region IV office. The inspection will be conducted in

accordance with Inspection Procedure 71111.05T, "Fire Protection (Triennial)," the NRCs

baseline fire protection inspection procedure.

The schedule for the inspection is as follows:

Information gathering visit: January 8 - 9, 2014

Onsite inspection: January 27 - 31, 2014

February 10 - 14, 2014

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, plant layout, and mitigating strategies

to address Section B.5.b of the NRC Order EA-02-026, Order for Interim Safeguards and

Security Compensatory Measures, dated February 25, 2002, and 10 CFR 50.54(hh)(2).

R. Flores -2-

Three individuals 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 in company with 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 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 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 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 appropriate personnel are available to support the team at the site

during the inspection. These personnel should be knowledgeable of the plant systems required

to achieve and maintain safe shutdown conditions from inside and outside the control room, the

electrical aspects of the post-fire safe shutdown analyses, the reactor plant fire protection

systems, and the fire protection program and its implementation and the B.5.b program

implementation should be available to support the team at the site during the inspection.

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 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).

R. Flores -3-

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 Eduardo D. Uribe, the team lead inspector, in the Region IV office at (817) 200-1534, or

by email, Eduardo.Uribe@nrc.gov.

Sincerely,

/RA/

Geoffrey B. Miller, Chief

Engineering Branch 2

Division of Reactor Safety

Docket: 50-445/50-446

License No.: NPF-87/NPF-89

Enclosure: Triennial Fire Protection Inspection Documentation Request

cc w/enclosure: Electronic Distribution for the Comanche Peak Nuclear Power Plant

Electronic Distribution to the Comanche Peak Nuclear Power Plant

R. Flores -4-

Electronic distribution by RIV:

Acting Regional Administrator (Steven.Reynolds@nrc.gov)

Acting Deputy Regional Administrator (Thomas.Bergman@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov)

DRS Director (Tom.Blount@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (John.Kramer@nrc.gov)

Resident Inspector (Rayomand.Kumana@nrc.gov)

Administrative Assistant - Vacant

Branch Chief, DRP/A (Wayne.Walker@nrc.gov)

Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)

Project Engineer, DRP/A (Jason.Dykert@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV/ETA: OEDO (Daniel.Rich@nrc.gov)

R:\_REACTORS\_CPSES\2013\CP 2014008 TFP RFI-EDU.docx ML

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials EDU

Publicly Avail Yes No Sensitive Yes No Sens. Type Initials EDU

RIV: DRS/EB2/RI C:DRP/A C: EB2

EDUribe WCWalker GBMiller

/RA/ /RA/ /RA/

10/8/13 10/8/13 10/8/13

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE

Triennial Fire Protection Inspection Documentation Request

Please provide the following documentation (items 1 - 5) prior to the onsite information

gathering visit, preferably no later than December 20, 2013. Whenever practical, please provide

copies electronically. Please provide an index of the requested documents which includes a

brief description of what the documents are related to, 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 (IPEEE) report addressing fire events. Also, include the results of any

post-IPEEE reviews, and listings of actions taken/plant modifications conducted in response

to probabilistic risk assessment updates.

5. A copy of the documents that support your multiple spurious operation evaluations (i.e.,

expert panel reports, evaluation packages, etc.).

Please provide the following documentation (items 6- 48) prior to the week of January 13, 2014,

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; (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.

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10. A list of equipment used to achieve and maintain hot standby and cold shutdown in the

event of a fire (safe shutdown equipment list).

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 the last triennial fire protection

inspection.

13. Copies of fire protection program change evaluations (Generic Letter 86-10 evaluations)

performed since the last triennial fire protection inspection.

14. A listing of open and closed corrective action documents initiated since the last triennial fire

protection inspection, 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 which support fire response.

17. Procedures used to remove smoke from safety-related areas and the engineering studies or

calculations which 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 which verify fuse and breaker

coordination in accordance with the post-fire safe shutdown coordination analysis.

21. Results of the last performance and trending of the fire pump flow tests and yard loop flow

test.

22. Maintenance rule performance criterion 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 the last

triennial fire protection inspection.

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23. 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.

24. 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 the last triennial fire protection inspection.

25. 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.

26. 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).

27. 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).

28. A list of automatic and manually initiated gaseous fire suppression systems in the plant,

giving location and the key equipment being protected.

29. A list of repairs (and the procedures that control the actions) needed to: a) reach and/or

maintain hot shutdown, and b) reach and/or maintain cold shutdown.

30. A list of high to low pressure interface valves.

31. A copy of procedures governing the training and operation of the fire brigade.

32. Organization charts of site personnel down to the level of fire protection staff personnel.

33. A contact list of key site personnel who will be supporting this inspection, giving location of

their office and phone number onsite.

34. The team would like to observe an unannounced fire brigade drill in the plant, if possible,

during the week of February 10, 2014. Please put us in contact, during the onsite

information gathering trip, with the appropriate personnel for planning drills.

35. 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 January 27, 2014.

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The team would like to perform a walkthrough of a sample of manual actions required for

other fires not requiring control room evacuation. Please put us in contact, during the onsite

information gathering trip, with the appropriate personnel for planning the walkthrough.

The following documents (items 36 - 48) involve B.5.b mitigating strategies.

36. A copy of the license condition that incorporated the requirements issued to address the

requirements of Section B.5.b of the NRC Order EA-02-026, Order for the NRC Interim

Safeguards and Security Compensatory Measures, dated February 25, 2002, and 10 CFR

50.54(hh)(2).

37. A list of all modifications to regulatory commitments made to meet the requirements of

Section B.5.b of the NRC Order EA-02-026, Order for the NRC Interim Safeguards and

Security Compensatory Measures, dated February 25, 2002; the subsequently imposed

license conditions; and 10 CFR 50.54(hh)(2).

38. 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.

39. 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.

40. A list of engineering evaluations/calculations that were used to verify engineering bases for

the mitigation strategies.

41. 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.

42. A list of modification packages and simplified drawings/descriptions of modifications that

were made to plant systems to implement the mitigation strategies.

43. Copies of procedure(s) used to inventory equipment (hoses, fittings, pumps, etc.) required to

be used to implement the mitigation strategies.

44. 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.

45. A copy of site general arrangement drawing(s) that show the majority of buildings/areas

referenced in B.5.b documents.

46. Training records/ training matrix/ lesson plans related to B.5.b.

47. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments) required

to implement any mitigating strategies.

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48. The team would like to perform a walkthrough of the procedure implementing a sample

mitigating strategies and the inventory equipment (hoses, fittings, pumps, etc.) required to

be used to implement the mitigation strategies during the week of February 10, 2014.

Please put us in contact with the appropriate personnel for planning the walkthrough during

the onsite information gathering trip.

The following documentation needs (items 49 - 52) 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 January 17, 2014. Whenever practical, please provide copies electronically.

Drawings should be provided as paper copies of sufficient size such that all details are legible.

49. Pre-fire plans for the selected fire areas (areas to be selected by the team during the

information-gathering trip).

50. 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.

51. 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.

52. Drawings showing the location details for detection and suppression systems in the selected

fire areas.

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