ML110180664

IR 05000302-11-008, on 01/06/11, Crystal River Nuclear Plant, Unit 3

ML110180664
Person / Time
Site:	Crystal River
Issue date:	01/18/2011
From:	Nease R NRC/RGN-II/DRS/EB2
To:	Franke J Florida Power Corp
References
IR-11-008
Download: ML110180664 (8)

See also: IR 05000302/2011008

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

January 18, 2011

Mr. Jon A. Franke

Vice President, Crystal River Nuclear Plant

Crystal River Nuclear Plant (NA2C)

15760 W. Power Line Street

Crystal River, FL 34428-6708

SUBJECT: CRYSTAL RIVER NUCLEAR PLANT, UNIT 3 - NOTIFICATION OF CONDUCT

OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION WHILE

TRANSITION TO 10 CFR PART 50.48(c) IS IN PROGRESS (NRC INSPECTION

REPORT NO. 05000302/2011008)

Dear Mr. Franke:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

Region II staff will conduct a triennial fire protection baseline inspection at Crystal River Nuclear

Plant, Unit 3 in May 2011. The inspection team will be led by Mrs. LaDonna Suggs, NRC

Reactor Inspector, of the Region II Office. The team will be composed of personnel from the

NRC Region II Office. The inspection will be conducted in accordance with Inspection

Procedure 71111.05TTP, the NRCs baseline fire protection inspection procedure for plants in

the process of implementing 10 CFR 50.48(c) and National Fire Protection Association

Standard (NFPA) 805. 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. Inspection of circuit analysis is not included in the inspection procedure;

however, electrical topics will be addressed by the team.

On January 06, 2011, during a telephone conversation between Mr. Dennis Herrin (Crystal

River Lead Compliance Engineer - Licensing & Regulatory Programs) of your staff, and Mrs.

Suggs, our respective staffs confirmed arrangements for a three-day information gathering

onsite visit and a two-week onsite inspection. The schedule for the inspection is as follows:

• Information gathering visit: March 15 - 17, 2011

• Week 1 of onsite inspection: April 4 - 8, 2011

• Week 2 of onsite inspection: April 18 - 22, 2011

The purposes of the information gathering visit are to obtain information and documentation

needed to support the inspection, to become familiar with the Crystal River Nuclear Plant, Unit 3

fire protection program, 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). The types of documents the

team will be interested in reviewing, and possibly obtaining, are listed in Enclosures 1 and 2.

Please contact Mrs. Suggs prior to preparing copies of the materials listed in the Enclosures.

The inspection team will try to minimize your administrative burden by specifically identifying

those documents required for inspection preparation.

FPC 2

During the information gathering visit, the team will also discuss the following inspection support

administrative details: office space; specific documents to be made available to the team in their

office space; arrangements for unescorted site access (including radiation protection training,

security, safety and fitness for duty requirements); 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 inspection weeks you ensure that copies of analyses, evaluations or

documentation regarding the implementation and maintenance of the Crystal River 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 which establish that your fire protection program satisfies 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, personnel should be available at the site during the inspection who are knowledgeable

regarding those plant systems required to achieve and maintain safe shutdown conditions from

inside and outside the control room (including the electrical aspects of the relevant post-fire safe

shutdown analyses), reactor plant fire protection systems and features, and the Crystal River

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.

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 Mrs. Suggs at (404) 997-4539, or me at (404) 562-4530.

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 NRCs document system

FPC 3

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading

Room).

Sincerely,

/RA/

Rebecca L. Nease, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No.: 50-302

License No.: DPR-72

Enclosures: 1. Triennial Fire Protection Inspection Support Documentation

2. Mitigating Strategies Support Documentation

cc w/encl. (See page 4)

FPC 4

cc w/encls: Joseph W. Donahue

R. J. Duncan, II Vice President

Vice President Nuclear Oversight

Nuclear Operations Carolina Power and Light Company

Carolina Power & Light Company Electronic Mail Distribution

Electronic Mail Distribution

Jack E. Huegel

Brian C. McCabe Manager, Nuclear Oversight

Manager, Nuclear Regulatory Affairs Crystal River Nuclear Plant

Progress Energy Carolinas, Inc. Electronic Mail Distribution

Electronic Mail Distribution

David T. Conley

James W. Holt Associate General Counsel

Plant General Manager Legal Dept.

Crystal River Nuclear Plant (NA2C) Progress Energy Service Company, LLC

Electronic Mail Distribution Electronic Mail Distribution

Stephen J. Cahill Mark Rigsby

Engineering Manager Manager, Support Services - Nuclear

Crystal River Nuclear Plant (NA2C) Crystal River Nuclear Plant (NA2C)

Electronic Mail Distribution Electronic Mail Distribution

R. Alexander Glenn Senior Resident Inspector

Associate General Counsel U.S. Nuclear Regulatory Commission

(MAC - BT15A) Crystal River Nuclear Generating Plant

Florida Power Corporation U.S. NRC

Electronic Mail Distribution 6745 N Tallahassee Rd

Crystal River, FL 34428

Christos Kamilaris

Director Attorney General

Fleet Support Services Department of Legal Affairs

Carolina Power & Light Company The Capitol PL-01

Electronic Mail Distribution Tallahassee, FL 32399-1050

William A. Passetti Ruben D. Almaguer

Chief Director

Florida Bureau of Radiation Control Division of Emergency Preparedness

Department of Health Department of Community Affairs

Electronic Mail Distribution Electronic Mail Distribution

Daniel R. Westcott Chairman

Supervisor Board of County Commissioners

Licensing & Regulatory Programs Citrus County

Crystal River Nuclear Plant (NA1B) 110 N. Apopka Avenue

Electronic Mail Distribution Inverness, FL 36250

_________________________ G SUNSI REVIEW COMPLETE

OFFICE RII;DRS RII:DRP RII:DRS

SIGNATURE RA RA RA

NAME SUGGS RICH NEASE

DATE 1/18/2011 1/18/2011 1/18/2011 1/ /2011 1/ /2011 1/ /2011 1/ /2011

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

Triennial Fire Protection Inspection Support Documentation

Note: This is a broad list of the documents the NRC inspection team may be interested in

reviewing, and possibly obtaining, during the information gathering site visit. The current

version of these documents is expected unless specified otherwise. Electronic media is

preferred, if readily available. (The preferred file format on CD-ROM or DVDROM is .pdf).

The CD/DVD-ROM should be indexed, hyperlinked, readable, and searchable to facilitate ease

of use. Please provide 5 copies of each CD/DVD-ROM submitted). Information in lists should

contain enough information to be easily understood by someone who has knowledge of the

technology. The lead inspector will discuss specific information needs with the licensee staff

and may request additional documents or electronic information.

1. The Fire Protection Program document and the Fire Hazards Analysis.

2. The Fire Protection Program implementing procedures (e.g., administrative controls,

surveillance testing, fire brigade).

3. The fire brigade training program document and the pre-fire plans for the selected fire

areas/zones (to be determined during information gathering visit).

4. The post-fire safe shutdown analysis, including system and separation analyses.

5. The alternative shutdown analysis.

6. Piping and instrumentation (flow) diagrams for the fire suppression systems.

7. Piping and instrumentation (flow) diagrams for the systems and components used to

achieve and maintain hot standby, and cold shutdown, for fires involving shutdown from

the control room.

8. Piping and instrumentation (flow) diagrams for the systems and components used to

achieve and maintain hot standby, and cold shutdown, for fires in areas requiring

alternative or dedicated shutdown capability.

9. Plant layout and equipment drawings which identify the physical plant locations of hot

standby and cold shutdown equipment.

10. Plant layout drawings which identify plant fire area and/or fire zone delineation, areas

protected by automatic fire suppression and detection, and the locations of fire

protection equipment for the selected fire areas/zones (to be determined during

information gathering visit).

11. Plant layout drawings which identify the general location of the post-fire emergency

lighting units.

12. Plant operating procedures used to, and describing shutdown from inside the control

room with a postulated fire occurring in any plant area outside the control room.

13. Plant operating procedures used to implement the alternative shutdown capability from

outside the control room with a fire in either the control or cable spreading room (or any

other alternative shutdown area).

Enclosure 1

2

14. Maintenance and surveillance testing procedures for alternative shutdown capability

(including Appendix R emergency lights and communication systems) fire barriers,

detectors, fire pumps and fire suppression systems.

15. Calculations and/or justifications that verify fuse/breaker coordination for the selected fire

areas/zones (to be determined during information gathering visit) that are fed off the

same electrical buses as components in the protected train. Also, a list of the

maintenance procedures used to routinely verify fuse/breaker coordination in

accordance with the post-fire safe shutdown coordination analysis.

16. A list of the significant fire protection and post-fire safe shutdown design change

descriptions (including their associated 10 CFR 50.59 evaluations) and Generic Letter

(GL) 86-10 evaluations.

17. A list of the protection methodologies (as identified in 10 CFR Part 50, Appendix R,

Section Ill.G) used to achieve regulatory compliance for the selected fire areas/zones (to

be determined during information gathering visit). That is, please specify whether 3-hour

rated fire barriers (Section Ill.G.2.a), 20-foot separation along with detection and

suppression (Section IIl.G.2.b), 1-hour rated fire barriers with detection and suppression

(Section lII.G.2.c), or alternative shutdown capability (Section lll.G.3) is used for the

selected fire areas/zones.

18. Procedures or instructions that govern the implementation of plant modifications,

temporary modifications, maintenance, and special operations, and their impact on fire

protection.

19. Organization chart(s) of site personnel down to the level of the fire protection staff.

20. Procedures or instructions that control the configuration of the fire protection program,

features, and post-fire safe shutdown methodology and system design.

21. A list of applicable codes and standards related to the design of plant fire protection

features and evaluations of code deviations (i.e., a listing of the NFPA code editions

committed to (Code of Record)).

22. The three most recent fire protection QA audits and/or fire protection self-assessments.

23. A list of open and closed fire protection problem identification and resolution reports

[also known as action reports/condition reports/problem investigation

reports/NCRs/EARs] associated with fire protection or Appendix R safe shutdown for the

past three years.

24. A list of plant fire protection licensing basis documents (i.e., a list of the SERs and

change evaluations which form the licensing basis for the facilitys post-fire safe

shutdown configuration).

25. A list of fire protection or Appendix R calculations,

26. A list of fire impairments identified during the previous year.

27. A list of abbreviations/designators for plant systems.

Enclosure 1

Mitigating Strategies Support Documentation

Note: This is a broad list of the documents the NRC inspection team may be interested in

reviewing, and possibly obtaining, during the information gathering visit. The current version of

these documents is expected unless specified otherwise. Electronic media is preferred, if

readily available. (The preferred file format on CD-ROM or DVDROM is .pdf). The CD/DVD-

ROM should be indexed, hyperlinked, readable, and searchable to facilitate ease of use.

Please provide 5 copies of each CD/DVD-ROM submitted). The lead inspector will discuss

specific information needs with the licensee staff and may request additional documents or

electronic information.

1. 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).

2. Copies of procedures/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 06-12 and the site-specific procedures or guidelines that are

used to implement each strategy.

4. Engineering evaluations/calculations that were used to verify engineering bases for the

mitigation strategies.

5. Piping and instrumentation diagram (P&ID) or simplified flow diagrams for systems relied

upon in the mitigation strategies. These could be the type used for training.

6. A modification package or simplified drawings/descriptions of modifications that were

made to plant systems to implement the mitigation strategies.

7. Copies of procedures used to inventory equipment (hoses, fittings, pumps, etc.) required

to be used to implement the mitigation strategies.

8. A list of B.5.b strategies, if any, which have implementing details that differ from that

documented in the submittals and the safety evaluation report.

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

referenced in B.5.b documents.

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.

Enclosure 2