ML062620505

Notification of an NRC Triennial Fire Protection Baseline Inspection While Transition to 10 CFR Part 50.48 (C) Is in Progress. (05000483-06-008)

ML062620505
Person / Time
Site:	Callaway
Issue date:	09/19/2006
From:	Laura Smith Division of Reactor Safety IV
To:	Naslund C Union Electric Co
References
IR-06-008
Download: ML062620505 (8)

See also: IR 05000483/2006008

Text

September 19, 2006

Charles D. Naslund, Senior Vice

President and Chief Nuclear Officer

Union Electric Company

P.O. Box 620

Fulton, MO 65251

SUBJECT: CALLAWAY PLANT - NOTIFICATION OF AN NRC TRIENNIAL FIRE

PROTECTION BASELINE INSPECTION WHILE TRANSITION TO 10 CFR

PART 50.48 (c) IS IN PROGRESS. (05000483/2006008)

Dear Mr. Naslund:

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 Callaway Plant

in October and November of 2006. The inspection team will be comprised of reactor inspectors

from the NRC Region IV office and a contractor. 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), 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 for code requirements. The inspectors will not

routinely inspect for or evaluate circuit related issues.

The schedule for the inspection is as follows:

• Information gathering visit: October 23 - 25, 2006

• Onsite inspection: November 13 - 17, 2006

November 27 - December 1, 2006

Members of the inspection team will visit the Callaway Plant on October 23 - 25, 2006, to gather

information and documents needed to support the inspection, obtain unescorted access, to

become familiar with your fire protection program, and to select the fire areas of interest for the

inspection. The enclosure to this letter provides a list of documents the team will need to

review. You are requested to transmit copies of some of the documents to the NRC Region IV

office for team use in preparation for the inspection by the dates listed.

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

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

Union Electric Company -2-

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, and (4) the fire protection program and its

implementation should be available to support the team at the site during the inspection.

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 John M. Mateychick at 817-276-6560.

Sincerely,

John M. Mateychick for

Linda J. Smith, Chief

Engineering Branch 2

Division of Reactor Safety

Docket: 50-483

License: NPF-30

cc w/enclosure:

Professional Nuclear Consulting, Inc.

19041 Raines Drive

Derwood, MD 20855

John ONeill, Esq.

Pillsbury Winthrop Shaw Pittman LLP

2300 N. Street, N.W.

Washington, DC 20037

Keith A. Mills, Supervising Engineer,

Regional Regulatory Affairs/

Safety Analysis

AmerenUE

P.O. Box 620

Fulton, MO 65251

Missouri Public Service Commission

Governors Office Building

200 Madison Street

P.O. Box 360

Jefferson City, MO 65102

Union Electric Company -3-

H. Floyd Gilzow

Deputy Director for Policy

Missouri Department of Natural Resources

P. O. Box 176

Jefferson City, MO 65102-0176

Rick A. Muench, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

Dan I. Bolef, President

Kay Drey, Representative

Board of Directors Coalition

for the Environment

6267 Delmar Boulevard

University City, MO 63130

Les H. Kanuckel, Manager

Quality Assurance

AmerenUE

P.O. Box 620

Fulton, MO 65251

Director, Missouri State Emergency

Management Agency

P.O. Box 116

Jefferson City, MO 65102-0116

Keith D. Young, Manager

Regulatory Affairs

AmerenUE

P.O. Box 620

Fulton, MO 65251

David E. Shafer

Superintendent, Licensing

Regulatory Affairs

AmerenUE

P.O. Box 66149, MC 470

St. Louis, MO 63166-6149

Certrec Corporation

4200 South Hulen, Suite 630

Fort Worth, TX 76109

Union Electric Company -4-

Keith G. Henke, Planner

Division of Community and Public Health

Office of Emergency Coordination

930 Wildwood, P.O. Box 570

Jefferson City, MO 65102

Union Electric Company -5-

Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (RJC1)

Senior Resident Inspector (MSP)

Branch Chief, DRP/B (WBJ)

Senior Project Engineer, DRP/B (RAK1)

Team Leader, DRP/TSS (RLN1)

RITS Coordinator (KEG)

DRS STA (DAP)

S. O'Connor, OEDO RIV Coordinator (SCO)

ROPreports

CWY Site Secretary (DVY)

SUNSI Review Completed: ADAMS: Yes G No Initials: LJS

Publicly Available G Non-Publicly Available G Sensitive Non-Sensitive

R:\_REACTORS\CW\2006\CW FPT Notification Letter.wpd

RIV: DRS/EB2/SRI C: EB2

JMMateychick LJSmith

/RA/ /RA/

09/18/2006 09/18/2006

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

ENCLOSURE

Triennial Fire Protection Inspection Documentation Requested

Please provide the following documentation prior to the onsite information gathering trip,

preferably no later than October 10, 2006. Where practical, please provide copies electronically

on compact discs.

1. The current version of your fire protection program and fire hazards analysis.

2. Post-fire safe shutdown analysis and any supporting calculations which 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 PRA or portions of the plants IPEEE addressing fire events.

Please provide the following documentation during the onsite information gathering trip

October 23 - 25, 2006. Where practical, please provide copies electronically on compact discs.

However, drawings should be provided as paper copies of sufficient size that all details are

legible. Fire protection program implementing procedures (e.g., administrative controls,

surveillance testing).

5. 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).

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

capability with or without control room evacuation.

7. Pre-fire plans for the selected fire areas (areas to be selected by the team during the

information-gathering trip).

8. A list of equipment used to achieve and maintain hot standby and cold shutdowns in the

event of a fire (safe shutdown equipment lists), and two copies 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 RCS makeup, RCS pressure control, decay

heat removal, and reactivity control, including the essential support systems.

9. Piping and instrumentation (flow) diagrams showing the components used to achieve

and maintain hot standby and cold shutdowns for fires outside the control room and

those components used for those areas requiring alternative shutdown capability.

10. Plant layout and equipment drawings for the selected fire areas that identify (a) the

physical plant locations of major hot standby and cold shutdown equipment; (b) plant fire

Enclosure

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.

11. Procedures/instructions that govern the implementation of plant modifications,

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

protection.

12. A listing of design change packages, which were determined to impact fire protection

and post-fire safe shutdowns, performed in the last 3 years.

13. A listing of Generic Letter 86-10 evaluations performed in the last 3 years.

14. A listing of open and closed fire protection condition reports initiated in the last 3 years

which relate to the fire protection program or equipment.

15. A listing of the applicable codes and standards (e.g. NFPA) related to the design of

plant fire protection features and evaluations of any code deviations.

16. Drawings the portions of the emergency lighting system which support fire response.

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

studies or calculations which support the design basis.

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

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

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

20. Maintenance and surveillance testing procedures for alternative shutdown capability and

fire barriers, detectors, pumps and suppression systems.

21. Maintenance Rule performance criteria and 3 years worth of performance history for fire

protection program systems or functions monitored within the Maintenance Rule

program.

22. A copy of fire protection program requirements (e.g. limiting conditions for operation,

surveillance test requirements) covered by Technical Specifications, Technical

Requirements Manual, UFSAR, or similar documents.

23. 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 within the last 3 years.

24. A list of manual actions taken outside the control room which 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.

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25. Electronic copies of operator study guides (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).

26. Two copies of one-line diagrams of the electrical distribution system. These should

depict how power gets from the switchyard to ESF loads (480V and 4160V). Also,

include the vital DC distribution system one-line diagrams.

27. Please provide a list of automatic and manually initiated gaseous fire suppression

systems in the plant, giving location and the key equipment being protected.

28. Please provide a list of repairs (and the procedure that controls the actions) needed to:

a) reach and/or maintain hot shutdown; b) reach and/or maintain cold shutdowns.

28. A list of high to low pressure interface valves.

29. A copy of procedures governing the training and operation of the fire brigade.

30. The team would like to observe a fire brigade drill in the plant, if possible, during the

week of November 27, 2006. Please put us in contact with the appropriate personnel

for planning drills during the onsite information gathering trip October 23 - 25, 2006.

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

32. A contact list of key site personnel who will be supporting this inspection, giving location

of their office and phone number onsite.

-3- Enclosure