ML081430193

Notification of Conduct of a Triennial Fire Protection Baseline Inspection

ML081430193
Person / Time
Site:	Three Mile Island
Issue date:	05/22/2008
From:	Rogge J Engineering Region 1 Branch 3
To:	Pardee C AmerGen Energy Co, Exelon Generation Co
References
Download: ML081430193 (7)

Text

May 22, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC Chief Nuclear Officer AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

THREE MILE ISLAND STATION, UNIT 1 - NOTIFICATION OF CONDUCT OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

Dear Mr. Pardee:

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

Region I staff will conduct a triennial fire protection baseline inspection at Three Mile Island Station, Unit 1 beginning in August 2008. The inspection team will be led by Dan Orr from the NRC Region I office. The team will be composed of personnel from the NRC Region I. The inspection will be conducted in accordance with NRC inspection procedure 71111.05T, the NRCs baseline fire protection inspection procedure.

The schedule for the inspection is as follows:

• Information gathering visit - Week of August 4, 2008

• Weeks of onsite inspection - August 25 - 29 and September 8 - 12, 2008 The purpose of the information gathering visit is to obtain information and documentation needed to support the inspection, to become familiar with the station fire protection programs, fire protection features, and post-fire safe shutdown capabilities and plant layout, and as necessary, obtain plant specific site access training and badging for unescorted access. A list of the types of documents the team may be interested in reviewing and possibly obtaining, are listed in Enclosure 1. The team leader will contact you with specific document requests prior to the information gathering visit.

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, 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.

Mr. C. Pardee 2 We request that during the onsite inspection weeks you ensure that copies of analyses, evaluations, or documentation regarding the implementation and maintenance of the Three Mile Island Station, Unit 1 fire protection program, including post-fire safe shutdown capability, be readily accessible to the team for their review. Of specific interest are those documents which establish that your fire protection program satisfies NRC regulatory requirements and conforms to applicable NRC and industry fire protection guidance. 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 Three Mile Island Station, Unit 1 fire protection program and its implementation.

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 Dan Orr, the team leader in the Region I office at (610) 337-5048.

Sincerely,

/RA/

John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-289 License No. DPR-50

Enclosure:

List of Reactor Fire Protection Program Supporting Documents

Mr. C. Pardee 2 We request that during the onsite inspection weeks you ensure that copies of analyses, evaluations, or documentation regarding the implementation and maintenance of the Three Mile Island Station, Unit 1 fire protection program, including post-fire safe shutdown capability, be readily accessible to the team for their review. Of specific interest are those documents which establish that your fire protection program satisfies NRC regulatory requirements and conforms to applicable NRC and industry fire protection guidance. 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 Three Mile Island Station, Unit 1 fire protection program and its implementation.

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 Dan Orr, the team leader in the Region I office at (610) 337-5048.

Sincerely,

/RA/

John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-289 License No. DPR-50

Enclosure:

List of Reactor Fire Protection Program Supporting Documents SUNSI Review Complete: JR (Reviewers Initials) ADAMS ACC#ML081430193 DOCUMENT NAME: G:\DRS\Engineering Branch 3\Orr\TMI FP Triennial\TMI Fire Protection 90 Day Letter.doc After declaring this document An Official Agency Record it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRS RI/DRS RI/DRS NAME DOrr/JR for JRogge/JR RBellamy/RB DATE 05/22/08 05/22/08 05/22/08 OFFICIAL RECORD COPY

Mr. C. Pardee 3 cc w/encl: (via E-mail)

C. Crane, Executive Vice President and Chief Operating Officer, Exelon Generation W. Noll, Site Vice President - TMI Unit 1, AmerGen T. Dougherty, Plant Manager - TMI, Unit 1, AmerGen Manager, Regulatory Assurance - TMI, Unit 1, AmerGen Senior Vice President - Nuclear Services, AmerGen Senior Vice President - Mid-Atlantic Operations, AmerGen Senior Vice President - Operations Support, AmerGen Vice President - Licensing and Regulatory Affairs, AmerGen Director, Licensing - AmerGen Manager, Licensing - TMI, AmerGen J. Fewell, Esq., Associate General Counsel, Exelon Correspondence Control Desk - AmerGen Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry Township R. Janati, Director, Bureau of Radiation Protection, State of PA D. Allard, Director, PA DEP J. Johnsrud, National Energy Committee E. Epstein, TMI-Alert (TMIA)

J. Powers, Director, PA Office of Homeland Security R. French, Director, PA Emergency Management Agency

Mr. C. Pardee 4 Distribution w/encl:

S. Collins, RA M. Dapas, DRA M. Gamberoni, DRS D. Roberts, DRS J. Rogge, DRS D. Orr, DRS D. Lew, DRP J. Clifford, DRP R. Bellamy, DRP S. Barber, DRP A. Rosebrook, DRP D. Kern, DRP, Sr. Resident Inspector J. Brand, DRP, Resident Inspector C. LaRegina, DRP, OA S. Williams, RI OEDO P. Bamford, PM, NRR G. Miller, NRR, Backup R. Nelson, NRR H. Chernoff, NRR Region I Docket Room (with concurrences)

ENCLOSURE Reactor Fire Protection Program Supporting 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.]

1. The current version of the Fire Protection Program and Fire Hazards Analysis.

2. Current versions of the fire protection program implementing procedures (e.g.,

administrative controls, surveillance testing, and fire brigade.)

3. Fire brigade training program and pre-fire plans.

4. Post-fire safe shutdown systems and separation analysis.

5. Post-fire alternative shutdown analysis.

6. Piping and instrumentation (flow) diagrams showing the systems and 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.

7. Plant layout and equipment drawings which identify the physical plant locations of hot standby and cold shutdown equipment.

8. Plant layout drawings which identify plant fire area delineation, areas protected by automatic fire suppression and detection, and the locations of fie protection equipment.

9. Plant layout drawings which identify the location of the post-fire emergency lighting units.

10. Plant operating procedures which would be used for shutdown from the control room with a postulated fire occurring in any plant area outside the control room, and procedures which would be used to implement alternative shutdown capability in the event of a fie in either the control or cable spreading room.

11. Maintenance and surveillance testing procedures for alternative shutdown capability and fire barriers, detectors, pumps and suppression systems. (Last completed copy.)

12. Maintenance procedures which routinely verify fuse breaker coordination in accordance with the post-fire safe shutdown coordination analysis.

13. A list of fire protection and post-fire safe shutdown related design change packages (including their associated 10 CFR 50.59 evaluations) and Generic Letter 86-10 evaluations.

14. The reactor plants IPEEE, results of any post-IPEEE reviews, and listings of actions taken or plant modifications conducted in response to IPEEE information.

Enclosure

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15. Copies of AC and DC electrical system one line diagrams. (From offsite power grid connections down to the 120 volt level.)

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

17. A listing of the SERs which form the licensing basis for the reactor plants post-fire safe shutdown configuration.

18. A list of applicable codes and standards related to the design of plant fie protection features and evaluations of code deviations.

19. Procedures and instructions that govern the implementation of plant modifications, temporary modifications, maintenance, and special operations, and their impact on fire protection.

20. The three most recent fire protection QA audits and fire protection self-assessments.

21. Recent QA surveillances of fire protection activities.

22. A listing of open fire protection and fire safe shutdown related condition reports.

23. A listing of fire protection and fie safe shutdown condition reports closed in the past three years.

24. Fire protection system health reports (last 2).

25. Lesson plans and related training information for licensed and non-licensed operators for post-fire safe shutdown (including alternative shutdown).

Enclosure