ML113060325

IR 05000382-12-007, 02/2012, Waterford Steam Electric Station, Unit 3- Notification of NRC Triennial Fire Protection Baseline Inspection

ML113060325
Person / Time
Site:	Waterford
Issue date:	11/02/2011
From:	O'Keefe N NRC/RGN-IV/DRS/EB-2
To:	Jacobs D Entergy Operations
References
IR-12-007
Download: ML113060325 (8)

See also: IR 05000382/2012007

Text

UNITED STATES

NUC LE AR RE G ULATO 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

November 2, 2011

Donna Jacobs, Vice President, Operations

Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3

17265 River Road

Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NOTIFICATION OF NRC

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (05000382/2012007)

Dear Ms. Jacobs:

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 Waterford 3

facility in February 2012. The inspection team will be comprised of five reactor inspectors from

the NRC Region IV office. The inspection will be conducted in accordance with Inspection

Procedure 71111.05T, Fire Protection (Triennial), the NRC=s baseline fire protection inspection

procedure.

The schedule for the inspection is as follows:

$ Information gathering visit: January 10-12, 2012

$ Onsite inspection: January 30 to February 3, 2012

February 13 - 17, 2012

Members of the inspection team will visit your Waterford 3 facility on January 10-12, 2012, to

meet with selected members of your staff in order to gather information and documentation

needed to support the inspection, to obtain unescorted access to the facility, to discuss office

space assigned to the team, to become familiar with your fire protection program, and to select

the fire areas of interest for the inspection.

Experience has shown that this inspection is resource intensive both for the NRC inspectors

and your staff. In order to minimize the impact to your onsite resources and to ensure a

productive inspection, we have enclosed a request for documents needed for this inspection.

Please note that some of the documents are requested to be provided prior to the information

gathering visit.

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

Entergy Operations, Inc. -2-

team for their review. Of specific interest are those documents that establish that your fire

protection program satisfies NRC regulatory requirements and conforms to applicable NRC

and industry fire protection guidance. Also, appropriate personnel knowledgeable of: (1) those

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, (4) the fire protection program and its implementation

and (5) the operational implementation of fire response procedures should be available to

support the team at the site during the inspection.

We have discussed the schedule for these inspection activities with your staff and understand

that our regulatory contact for this inspection will be Jim Pollock of your licensing organization.

If there are any questions about this inspection or the material requested, please contact the

lead inspector, Greg Pick, at 817 860-8270 or by email at greg.pick@nrc.gov.

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.

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).

Sincerely,

/RA/

Neil OKeefe, Chief

Engineering Branch 2

Division of Reactor Safety

Docket: 50-382

License: NPF-38

Enclosure: Triennial Fire Protection

Inspection Documentation Request List

cc w/encl:

Distribution via listserv for Waterford Steam Electric Station

Entergy Operations, Inc. -3-

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 (Tom.Blount@nrc.gov)

Senior Resident Inspector (Marlone.Davis@nrc.gov)

Resident Inspector (Dean.Overland@nrc.gov)

Acting Branch Chief, DRP/E (James.Drake@nrc.gov)

Senior Project Engineer, DRP/E (Ray.Azua@nrc.gov)

Project Engineer (Jim.Melfi@nrc.gov)

Project Engineer (Chris.Smith@nrc.gov)

Project Engineer (Daniel.Bradley@nrc.gov)

WAT Administrative Assistant (Linda.Dufrene@nrc.gov)

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

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

Project Manager (Kaly.Kalyanam@nrc.gov)

Acting Branch Chief, DRS/TSB (Dale.Powers@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

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

R:\_REACTORS\_WAT\WAT 2012007 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/SGraves for

/RA/ /RA/

11/2/2011 11/2/2011

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

ENCLOSURE

Triennial Fire Protection Inspection Documentation Request

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

visit, preferably no later than December 23, 2011. Where practical, please provide copies

electronically unless specified otherwise with folders indexed by request number. If documents

are provided as stored in your electronic records system without titles, please provide

titles/descriptions in the electronic file name or, as a minimum, an index by number with the

appropriate title/description.

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 probabilistic risk assessment updates.

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 6-48) 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).

-1- Enclosure

9. Operating procedure(s) used to implement an alternative shutdown (III.G.3 areas)

capability with or without control room evacuation.

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 makeup, reactor coolant system 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 (April 1, 2009).

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

performed since the last triennial fire protection inspection (April 1, 2009).

14. Procedures/instructions that control the configuration of the plant's fire protection

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

procedures/instructions that govern the implementation of plant modifications,

maintenance, and special operations, and their impact on fire protection.

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

fire protection inspection(April 1, 2009), 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), and including corrective actions

for operator manual actions. Include Corrective Action Process document number, date,

and subject

16. 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.

17. Drawings of the portions of the emergency lighting system that support fire response.

18. Procedures used to remove smoke from safety-related areas and the engineering

studies or calculations that support the design basis.

19. Drawings of communication systems credited in the license basis for firefighting and

plant operations during fires where control room is occupied and/or evacuated.

20. Piping and instrumentation (flow) diagrams for the fire water and sprinkler systems.

21. A listing of maintenance and surveillance testing procedures for alternative shutdown

capability and fire barriers, detectors, pumps and suppression systems. Also, include a

-2- Enclosure

list of maintenance and surveillance testing procedures that verify fuse and breaker

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

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 April 1, 2009.

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 (April 1, 2009).

25. A list of manual actions taken outside the control room that 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 procedure that controls 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 13, 2011. Please put us in contact, during the onsite

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

-3- Enclosure

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 30, 2011. 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 ICM Order, EA-02-026, dated February 25, 2002,

and 10 CFR 50.54(hh)(2).

37. A list of the original and any modifications to the 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).

38. A list of procedures/guidelines that was 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. Engineering evaluations/calculations that were used to verify engineering bases for the

mitigation strategies.

41. Copies of piping and instrumentation diagrams 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 your B.5.b strategies documented in the submittals to the NRC and the safety

evaluation report. In addition, please list any strategies that have implementing details

that differ from that originally submitted

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.

-4- Enclosure

48. 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 January 30, 2011. Please put us

in contact with the appropriate personnel for planning the walkthrough during the onsite

information gathering trip.

The following documentation needs (items 49-51) 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 23, 2011. 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.

-5- Enclosure