ML101450494

Notification to Perform a Triennial Fire Protection Baseline Inspection While Transition to 10 CFR Part 50.48(C) Is in Progress, IR 05000255-10-008 (DRS)

ML101450494
Person / Time
Site:	Palisades
Issue date:	05/24/2010
From:	Robert Daley Engineering Branch 3
To:	Schwarz C Entergy Nuclear Operations
References
IR-10-008
Download: ML101450494 (10)

See also: IR 05000255/2010008

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

May 24, 2010

Mr. Christopher J. Schwarz

Vice President, Operations

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANT - NOTIFICATION TO

PERFORM A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

WHILE TRANSITION TO 10 CFR PART 50.48(C) IS IN PROGRESS;

INSPECTION REPORT 05000255/2010008(DRS)

Dear Mr. Schwarz:

On August 16, 2010, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire

protection baseline inspection at the Palisades Nuclear Plant. This inspection will be performed

in accordance with Inspection Procedure (IP) 71111.05TTP, the NRCs baseline fire protection

inspection procedure for plants in the process of implementing the National Fire Protection

Association (NFPA) Standard 805 (10 CFR 50.48(c)). 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. The inspectors will not routinely inspect for or evaluate

circuit related issues.

Based on the latest revision to IP 71111.05TTP dated December 24, 2009, changes were made

to the IP, which now requires the fire protection inspection to review your actions to mitigate

postulated events that could potentially cause loss of large areas of power reactor facilities due

to explosions or fires. This requirement was implemented by the issuance of the Interim

Compensatory Measures Order EA-02-026, Section B.5.b and the subsequent requirements

of 10 CFR 50.54(hh)(2), which are collectively referred to as B.5.b requirements. During this

inspection, the B.5.b requirements review will begin following the information gathering visit.

The schedule for the on-site inspection activity is as follows:

y Information Gathering Visit: August 3 - 5, 2010;

y B.5.b Requirements: August 5 - 6, 2010; and

y Fire Protection Inspection: August 16 - 20, 2010, and August 30 - September 3, 2010.

C. Schwarz -2-

The purpose of the information gathering visit is: (1) to obtain information and documentation

needed to support the inspection; and (2) to become familiar with the Palisades Nuclear Plants

fire protection programs, fire protection features, post-fire safe shutdown capabilities, plant

layout, 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); and, as necessary, obtain plant

specific site access training and badging for unescorted site access.

Experience has shown that the baseline fire protection inspections are extremely resource

intensive both for the NRC inspectors and the licensee staff. In order to minimize the inspection

impact on the site and to ensure a productive inspection for both organizations, we have

enclosed a request for documents needed for the inspection. These documents have been

divided into four groups. The first group lists information necessary to aid the inspection team in

choosing specific focus areas for the inspection. It is requested that this information be

provided to the lead inspector via mail or electronically no later than July12, 2010. The second

group also lists information and areas for discussion necessary to aid the inspection team in

choosing specific fire protection focus areas for the inspection and to ensure that the inspection

team is adequately prepared for the inspection. It is requested this information be available

during the information gathering visit (August 3 - 5, 2010). The third group of requested

documents consists of those items that the team will review, or need access to, during the

inspection. Please have this information available by the first day of the second on-site

inspection week (August 16 - 20, 2010). The fourth group lists the information necessary to aid

the inspection team in tracking issues identified as a result of the inspection. It is requested that

this information be provided to the lead inspector as the information is generated during the

inspection. It is important that all of these documents are up to date and complete in order to

minimize the number of additional documents requested during the preparation and/or the on-

site portions of the inspection.

The lead inspector for this inspection is Mr. Benny Jose. We understand that our regulatory

contact for this inspection is Ms. Barbara Dotson of your organization. If there are any

questions about the inspection or the material requested, please contact the lead inspector at

(630) 829-9756 or via e-mail at Benny.Jose@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.

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.

C. Schwarz -3-

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 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/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket No. 50-255

License No. DPR-20

Enclosure: Fire Protection Inspection Document Request

cc w/encl: Distribution via ListServ

FIRE PROTECTION INSPECTION DOCUMENT REQUEST

Inspection Report: 05000255/2010008(DRS)

On-site Inspection Dates: August 3 - 6, 2010 (Information Gathering Visit)

August 5 - 6, 2010 (B.5.b Requirements)

August 16 - 20, 2010 (Fire Protection Inspection)

August 30 - September 3, 2010 (Fire Protection Inspection)

Inspection Procedures: IP 71111.05TTP, Fire Protection-NFPA 805 Transition Period

(Triennial)

IP 71152, "Identification and Resolution of Problems"

Inspectors: Benny Jose, Lead Inspector

(630) 829-9756

Benny.Jose@nrc.gov

Robert Winter Zelig Falevits

(630) 829-9758 (630) 829-9717

Robert.Winter@nrc.gov Zelig.Falevits@nrc.gov

I. Information Requested Prior To the Information Gathering Visit

The following information is requested by July 12, 2010. If you have any questions

regarding this request, please call the lead inspector as soon as possible. All information

should be sent to Mr. Benny Jose (e-mail address Benny.Jose@nrc.gov). Electronic media

is preferred. The preferred file format is a searchable pdf file on a compact disk (CD). The

CD should be indexed and hyper-linked to facilitate ease of use, if possible. Please provide

four copies of each CD submitted (one for each inspector and for a senior reactor analyst).

1. The reactor plant's Individual Plant Examination for External Events (IPEEE) for fire,

results of any post-IPEEE reviews for fire, and listings of actions taken and/or plant

modifications conducted in response to IPEEE information for fire. Alternatively,

probabilistic risk analyses for fire and associated information, if it exists and is more

recent than the IPEEE.

2. A copy of the current version of the fire protection program (FPP), fire hazards analysis

(FHA), safe shutdown analysis (SSA), updated safety analysis report (USAR), Technical

Specifications and license.

3. A list of fire areas requiring alternative shutdown capability, (i.e., those areas for which

10 CFR Part 50, Appendix R, Section III G requirements are satisfied under

Section III.G.3), or where both safe shutdown trains can be affected.

4. Plant operating procedures which would be used and describe shutdown for a

postulated fire (for both areas requiring alternative shutdown and areas which do not

require alternative shutdown). Only those procedures with actions specific to shutdown

in the event of a fire need be included.

1 Enclosure

FIRE PROTECTION INSPECTION DOCUMENT REQUEST

5. A copy of the current fire protection system Health Report, if available.

6. A copy of the current plant drawings referred to as Horse Notes, if available.

7. Status of NFPA 805 (10 CFR Part 50.48(c)) implementation.

8. Copy of the B.5.b mitigating strategies.

9. Copy of the procedures for the storage, maintenance, and testing of B.5.b related

equipment.

10. A list of the mitigating strategies for which you have modified the regulatory commitment

since the last performance of this inspection (or the performance of TI 2515/171), if any.

11. Copy of the lesson plans for B.5.b operator training.

II. Information Requested During the Information Gathering Visit (August 3-6, 2010)

The following information is requested to be provided to the inspection team during the

on-site information gathering visit. Except for Item 1, it is requested that the following

information be provided on four sets of CDs (searchable, if possible). In addition, two sets

of hard copy drawings are requested for Items 4.a. through 4.f.

1. One set of hard-copy documents for facility layout drawings, which identify plant fire area

delineation; areas protected by automatic fire suppression and detection; and locations

of fire protection equipment.

2. Licensing Information:

a. The facilitys license, including the fire protection license condition;

b. All Nuclear Regulatory Commission (NRC) Safety Evaluation Reports (SERs)

applicable to fire protection, (specifically including those SERs referenced by the

plant fire protection license condition) and all licensing correspondence referenced

by the SERs;

c. All licensing correspondence associated with the comparison to Standard Review

Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing purposes;

d. Exemptions from 10 CFR Part 50.48 and 10 CFR Part 50, Appendix R, and

associated licensing correspondence;

e. The FPP and applicable portions of the USAR, as referenced by the fire protection

license condition;

f. For pre-1979 plants (i.e., Appendix R plants), a listing of all 10 CFR Part 50,

Appendix R Sections and paragraphs that are applicable to the plant under

10 CFR 50.48(b)(1);

g. For pre-1979 plants, all licensing correspondence associated with those sections

of 10 CFR Part 50, Appendix R, that are not applicable to the plant under

2 Enclosure

FIRE PROTECTION INSPECTION DOCUMENT REQUEST

10 CFR Part 50.48(b)(1). Specifically, the licensing correspondence associated

with those fire protection features proposed or implemented by the licensee that

have been accepted by the NRC staff as satisfying the provisions of Appendix A to

Branch Technical Position (BTP) APCSB 9.5-1 reflected in the NRC fire protection

SERs issued before February 19, 1981, (10 CFR Part 50.48(b)(1)(i)); or those fire

protection features, which were accepted by the NRC staff in comprehensive fire

protection SERs issued before Appendix A to BTP APCSB 9.5-1 was published in

August 1976 (10 CFR Part 50.48(b)(1)(ii));

h. For post-1979 plants, all licensing correspondence associated with the comparison

to Standard Review Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing

purposes; and

i. For NFPA 805 transition plants provide: (1) all correspondence to and responses

from the NRC; (2) a list of all areas showing assessment review status;

(3) assessments for all areas that have been completed; and (4) a list of all

identified non-conformances, and their respective compensatory measure(s).

3. Fire Protection Program:

a. If not already provided under Request II.(2)(e) above, FPP documents including

FHA and post-fire SSA;

b. A listing of changes made to the FPP since the last triennial fire protection

inspection;

c. For pre-1979 plants, a listing of the protection methodologies identified under

10 CFR Part 50, Appendix R, Section III.G used to achieve compliance for selected

fire zones/areas (to be determined during information gathering visit). That is,

please specify whether 3-hour rated fire barriers; (Section III.G.2.a), 20 feet

separation along with detection and suppression; (Section III.G.2.b), 1-hour rated

fire barriers with detection and suppression; (Section III.G.2.c), or alternative

shutdown capability; (Section III.G.3) is used as a strategy for each selected fire

zone/area;

d. A list of Generic Letter 86-10 evaluations;

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

protection features. The list should include National Fire Protection Association

(NFPA) code versions committed to (i.e., the NFPA codes of record);

f. List of plant deviations from code commitments and associated evaluations.

3 Enclosure

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

4. Facility Information:

a. Piping and instrumentation (flow) diagrams showing the 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;

b. Plant layout and equipment drawings which identify the physical plant

locations of hot standby and cold shutdown equipment for selected fire

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

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

emergency lighting units;

d. One-line schematic drawings of the electrical distribution system for 4160

Volts alternating current (Vac) down to 480Vac;

e. One-line schematic drawings of the electrical distribution system for 250 Volts

direct current (Vdc) and 125Vdc systems as applicable;

f. Logic diagrams showing the components used to achieve and maintain hot

standby and cold shutdown; and

g. Safe shutdown cable routing database (requested electronically such as on

compact disc, if available.

5. Operations Response for Fire Protection:

a. Pre-fire plans for selected fire zones/areas (to be determined during information

gathering visit); and

b. Plant operating procedures which would be used and describe shutdown for a

postulated fire in selected fire zones/areas (to be determined during information

gathering visit).

6. Corrective Actions:

a. Listing of open and closed fire protection condition reports (i.e., problem

identification forms and their resolution reports) since the date of the last triennial

fire protection inspection; and

b. Listing of fire impairments since the date of the last triennial fire protection

inspection.

7. General Information:

a. A listing of abbreviations and/or designators for plant systems;

4 Enclosure

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

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

personnel; and

c. A phone list for on-site licensee personnel.

8. On-site Discussions:

In addition, during the information gathering visit, it is requested that licensee staff be

available for the following:

a. Informal discussion on plant procedures operators would use in the event of fire

and under what conditions would the plant be shutdown using alternative shutdown

methodology;

b. Informal discussion on the plants safe shutdown cable routing database and the

plant-wide cable routing database, as applicable; and

c. A tour of alternative shutdown and risk significant fire areas.

III. Information Requested to be Available on First Day of the Second On-site Inspection

Week (August 16, 2010)

The following information is requested to be provided on the first day of inspection. It is

requested that this information be provided on four sets of CDs (searchable, if possible).

1. Program Procedures:

a. List of the FPP implementing procedures (e.g., administrative controls, surveillance

testing, fire brigade);

b. List of maintenance and surveillance testing procedures for alternative shutdown

capability and fire barriers, detectors, pumps, and suppression systems;

c. List of maintenance procedures which routinely verify fuse breaker coordination

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

d. List of procedures and/or instructions that control the configuration of the reactor

plant's FPP, features, and post-fire safe shutdown methodology and system

design; and

e. List of procedures and/or instructions that govern the implementation of plant

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

protection.

2. Design and Equipment Information:

a. Coordination calculations and/or justifications that verify fuse/breaker coordination

for selected fire zones/areas (to be determined during information gathering

5 Enclosure

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

visit) that are fed off of the same electrical buses as components in the protected

safe shutdown train;

b. Copies of significant fire protection and post-fire safe shutdown related design

change package descriptions (including their associated 10 CFR 50.59

evaluations) and Generic Letter (GL) 86-10 (or adverse to safe shutdown)

evaluations;

c. Gaseous suppression system pre-operational testing, if applicable, for selected fire

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

d. Hydraulic calculations and supporting test data which demonstrate operability for

water suppression systems, if applicable, for selected fire zones/areas (to be

determined during information gathering visit);

e. Alternating current (ac) coordination calculations for 4160Vac down to 480Vac

electrical systems;

f. Vendor manuals and information for fire protection equipment (such as detection,

suppression systems, fire pumps), applicable to selected fire zones/areas (to be

determined during information gathering visit). It is acceptable to make vendor

manuals available to the inspectors in lieu of providing a copy; and

g. List of all fire protection or Appendix R calculations.

3. Assessment and Corrective Actions:

a. The three most recent fire protection Quality Assurance (QA) audits and/or fire

protection self-assessments; and

b. Corrective action documents (e.g., condition reports, including status of corrective

actions) generated as a result of the three most recent fire protection Quality

Assurance (QA) audits and/or fire protection self-assessments.

4. Any updates to information previously provided.

IV. Information Requested to Be Provided Throughout the Inspection

1. Copies of any corrective action documents generated as a result of the inspection

teams questions or queries during this inspection.

2. Copies of the list of questions submitted by the inspection team members and the

status/resolution of the information requested (provided daily during the inspection to

each inspection team member).

If you have questions regarding the information requested, please contact the lead inspector.

6 Enclosure

C. Schwarz -3-

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 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/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket No. 50-255

License No. DPR-20

Enclosure: Fire Protection Inspection Document Request

cc w/encl: Distribution via ListServ

DISTRIBUTION:

Susan Bagley

RidsNrrPMPalisades

RidsNrrDorlLpl3-1 Resource

RidsNrrDirsIrib Resource

Cynthia Pederson

Steven Orth

Jared Heck

Allan Barker

Carole Ariano

Linda Linn

DRPIII

DRSIII

Patricia Buckley

Tammy Tomczak

ROPreports Resource

DOCUMENT NAME: G:\DRS\Work in Progress\Ltr. 05__10 Palisades FPI RFI BXJ.docx

9 Publicly Available 9 Non-Publicly Available 9 Sensitive 9 Non-Sensitive

To receive a copy of this document, indicate in the concurrence box C = Copy without attach/encl; E = Copy with attach/encl N = No copy

OFFICE RIII RIII

NAME BJose:ls RDaley

DATE 05/19/10 05/24/10

OFFICIAL RECORD COPY