ML101060442

Notification of Conduct of Triennial Fire Protection Baseline Inspection While Transition to 10 CFR Part 50.48(c) Is in Progress (IR 05000395-10-008)

ML101060442
Person / Time
Site:	Summer
Issue date:	04/14/2010
From:	Nease R NRC/RGN-II/DRS/EB2
To:	Gatlin T South Carolina Electric & Gas Co
References
IR-10-008
Download: ML101060442 (9)

See also: IR 05000395/2010008

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

SAM NUNN ATLANTA FEDERAL CENTER

61 FORSYTH STREET, SW, SUITE 23T85

ATLANTA, GEORGIA 30303-8931

April 14, 2010

Mr. Thomas D. Gatlin

Vice President - Nuclear Operations

South Carolina Electric & Gas Company

Virgil C. Summer Nuclear Station

P.O. Box 88

Jenkinsville, SC 29065

SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION- 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. 05000395/2010008)

Dear Mr. Gatlin:

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 Virgil C. Summer

Nuclear Station, in June and July 2010. The inspection team will be led by Mr. Necota Staples,

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 March 03, 2010, during a telephone conversation between Mr. Arnie Cribb (Summer

Licensing Supervisor) of your staff, and Mr. Staples, 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: May 25 - 27, 2010

• Week 1 of onsite inspection: June 14 -18, 2010

• Week 2 of onsite inspection: June 28 - July 02, 2010

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

needed to support the inspection, to become familiar with the Summer Nuclear Station 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). The types of documents the

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

Please contact Mr. Staples prior to preparing copies of the materials listed in the Enclosures.

SCE&G 2

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

those documents required for inspection preparation.

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 Summer 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 Summer 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 Mr. Staples at (404) 997-4644, or me at (404) 997-4530.

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

SCE&G 3

(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/

Rebecca L. Nease, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No.: 50-395

License No.: NPF-12

Enclosures: 1. Triennial Fire Protection Inspection Support Documentation

2. Mitigating Strategies Support Documentation

cc w/encl. (See page 4)

SCE&G 4

cc w/encl:

R. J. White Robert M. Fowlkes

Nuclear Coordinator General Manager

S.C. Public Service Authority Mail Code 802 Engineering Services

Electronic Mail Distribution South Carolina Electric & Gas Company

Electronic Mail Distribution

Kathryn M. Sutton, Esq.

Morgan, Lewis & Bockius LLP David A. Lavigne

Electronic Mail Distribution General Manager

Operational Readiness

Susan E. Jenkins South Carolina Electric & Gas Company

Director, Division of Waste Management Virgil C. Summer Nuclear Station

Bureau of Land and Waste Management P.O. Box 88

S.C. Department of Health and Jenkinsville, SC 29065

Environmental Control

Electronic Mail Distribution Senior Resident Inspector

Virgil C. Summer Nuclear Station

R. Mike Gandy U.S. NRC

Division of Radioactive Waste Mgmt. 576 Stairway Road

S.C. Department of Health and Jenkinsville, SC 29065

Environmental Control

Electronic Mail Distribution Robin R. Haselden

General Manager

Andy T. Barbee Organizational Development &

Director Effectiveness

Nuclear Training South Carolina Electric & Gas Company

South Carolina Electric & Gas Company Electronic Mail Distribution

Electronic Mail Distribution

George A. Lippard, III

Bruce L. Thompson General Manager

Manager Nuclear Plant Operations

Nuclear Licensing (Mail Code 830) South Carolina Electric & Gas Company

South Carolina Electric & Gas Company Electronic Mail Distribution

Electronic Mail Distribution

Robert L. Justice

Manager

Nuclear Operations

South Carolina Electric & Gas Company

Electronic Mail Distribution

_________________________ G SUNSI REVIEW COMPLETE

OFFICE RII:DRS RII:DRS RII:DRP RII:DRS

SIGNATURE RA RA RA RA

NAME STAPLES WALKER MCCOY NEASE

DATE 3/8/2010 4/8/2010 3/16/2010 4/14/2010

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 DVD-

ROM 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.

Enclosure 1

2

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).

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,

Enclosure 1

3

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