ML110550758

Notification of an NRC Triennial Fire Protection Baseline Inspection (NRC Inspection Report 05000498-11-006; 05000499-11-006) and Request for Information

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

Licenses: NPF-76; NPF-80

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