ML12348A111

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Notification of Conduct of a Triennial Fire Protection Baseline Inspection (NRC Inspection Report No. 05000413/2013007 and 05000414/2013007)
ML12348A111
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 12/11/2012
From: Mark King
NRC/RGN-II/DRS/EB2
To: Henderson K
Duke Energy Corp
References
IR-13-007
Download: ML12348A111 (10)


See also: IR 05000413/2013007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

December 11, 2012

Mr. Kelvin Henderson

Site Vice President

Duke Energy Corporation

Catawba Nuclear Station

4800 Concord Road

York, SC 29745-9635

SUBJECT: CATAWBA NUCLEAR PLANT - NOTIFICATION OF CONDUCT OF A

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION

REPORT NO. 05000413/2013007 AND 05000414/2013007)

Dear Mr. Henderson:

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 Catawba Nuclear

Plant in April and May 2013. The inspection team will be led by Mr. David Jones, NRC Senior

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 71111.05T, the NRCs baseline fire protection inspection procedure dated January 1,

2012.

On November 29, 2012, during a conversation between Ms. A. Driver of your staff and Mr.

Jones, 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: April 2 - 4, 2013
  • Week 1 of onsite inspection: April 22 - April 26, 2013
  • Week 2 of onsite inspection: May 6 - 10, 2013

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

needed to support the inspection, to become familiar with the Catawba Nuclear Plant fire

protection program, fire protection features, and post-fire safe shutdown capabilities and plant

layout, mitigating strategies to address Section B.5.b of NRC Order EA-02-026, Order for

Interim Safeguards and Security Compensatory Measures, dated February 25, 2002, and Title

10 of the Code of Federal Regulations (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. Jones prior to preparing copies of the materials listed in the Enclosures. The

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

documents required for inspection preparation.

K. Henderson 2

During the information gathering visit, Mr. Jones will 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, operations 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 Catawba 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 that 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 Catawba 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. Jones at (404) 997-4631, or me at (404) 997-4511.

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

K. Henderson 3

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading

Room).

Sincerely,

/RA/

Michael F. King, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No.: 50-413 & 414

License No.: NPF-35 & 52

Enclosures:

1. Triennial Fire Protection Program Supporting Documentation

2. Mitigating Strategies Supporting Documentation

cc: (See page 4)

_________________________ xG SUNSI REVIEW COMPLETE G FORM 665 ATTACHED

OFFICE RII:DRS RII;:DRS

SIGNATURE RA RA

NAME JONES KING

DATE 12/11 /2012 12/ 11 /2012

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

K. Henderson 4

cc: Lara S. Nichols

Scott L. Batson Deputy General Counsel

Plant Manager Duke Energy Corporation

Catawba Nuclear Station Electronic Mail Distribution

Duke Energy Corporation

Electronic Mail Distribution David A. Cummings

Associate General Counsel

William M. Suslick General Office

Design Engineering Manager Duke Energy Corporation

Catawba Nuclear Station Electronic Mail Distribution

Duke Energy Corporation

Electronic Mail Distribution Beth J. Horsley

Wholesale Customer Relations

Steven B. Putnam Duke Energy Corporation

Organizational Effectiveness Manager Electronic Mail Distribution

Catawba Nuclear Station

Duke Energy Corporation Sandra Threatt, Manager

Electronic Mail Distribution Nuclear Response and Emergency

Environmental Surveillance

Randall D. Hart Bureau of Land and Waste Management

Regulatory Compliance Manager Department of Health and Environmental

Catawba Nuclear Station Control

Duke Energy Corporation Electronic Mail Distribution

Electronic Mail Distribution

Division of Radiological Health

Joseph Michael Frisco, Jr. TN Dept. of Environment & Conservation

Vice President, Nuclear Design Engineering 401 Church Street

General Office Nashville, TN 37243-1532

Duke Energy Corporation

Electronic Mail Distribution Senior Resident Inspector

U.S. Nuclear Regulatory Commission

M. Christopher Nolan Catawba Nuclear Station

Director - Regulatory Affairs U.S. NRC

General Office 4830 Concord Road

Duke Energy Corporation York, SC 29745

Electronic Mail Distribution

David A. Repka

David A. Cummings (acting) Winston Strawn LLP

Fleet Regulatory Compliance & Licensing Electronic Mail Distribution

Manager

General Office County Manager of York County

Duke Energy Corporation York County Courthouse

Electronic Mail Distribution P. O. Box 66

York, SC 29745-0066

Alicia Richardson

Licensing Administrative Assistant Piedmont Municipal Power Agency

General Office Electronic Mail Distribution

Duke Energy Corporation

Electronic Mail Distribution

(cc contd - See page 5)

K. Henderson 5

(cc contd)

Vanessa Quinn

Federal Emergency Management Agency

Radiological Emergency Preparedness

Program

1800 S. Bell Street

Arlington, VA 20598-3025

Letter to Kelvin Henderson from Michael F. King dated December 11, 2012

SUBJECT: CATAWBA NUCLEAR PLANT- NOTIFICATION OF CONDUCT OF A

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION

REPORT NO. 05000413/203007 AND 05000414/2013007)

Distribution:

RIDSNRRDIRS

PUBLIC

RidsNrrPMCatawba Resource

Triennial 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. 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. 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 current version of the fire protection program and fire hazards analysis.

2. Corrective action closeouts as part of operator manual actions corrective actions.

3. List of identified fire induced circuit failure configurations for the selected fire

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

4. Corrective actions for fire-induced circuit failures, both single and multiple spurious

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

gathering visit).

5. Cable routing for components and equipment credited for safe shutdown for the selected

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

6. List of protected safe shutdown train equipment for the selected fire areas/zones (to be

determined during information gathering visit).

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

administrative controls, surveillance testing, fire brigade).

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

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

10. Post-fire alternative shutdown analysis.

11. Piping and instrumentation 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.

12. Plant layout and equipment drawings which identify the physical plant locations of hot

standby and cold shutdown equipment.

13. Plant layout drawings which identify plant fire area delineation, areas protected by

automatic fire suppression and detection, and the locations of fire protection equipment.

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

lighting.

Enclosure 1

2

15. Plant operating procedures which would be used and describe shutdown from inside

the control room with a postulated fire occurring in any plant area outside the control

room, procedures which would be used to implement alternative shutdown capability in

the event of a fire in the control or cable spreading room.

16. Maintenance and surveillance testing procedures for alternative shutdown capability

and fire barriers, detectors, pumps and suppression systems.

17. Maintenance procedures that routinely verify fuse breaker coordination in accordance

with the post-fire safe shutdown coordination analysis.

18. A list of significant fire protection and post-fire safe shutdown related design change

packages and evaluations according to Generic Letter 86-10, Implementation of Fire

Protection Requirements.

19. The reactor plant's Individual Plant Examination for External Events (IPEEE), results of

any post-IPEEE reviews, and listings of actions taken/plant modifications conducted in

response to IPEEE information.

21. Organization charts of site personnel (including fire protection staff personnel).

22. If applicable, drawings of potential reactor coolant/recirculation pump lube oil system

leakage points and associated lube oil collection systems.

23. 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.).

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

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

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

features and evaluations of code deviations.

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

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

27. 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 previous NRC fire protection triennial inspection.

28. Recent quality assurance surveillances of fire protection activities.

29. A listing of open and closed fire protection condition reports (problem reports/nuclear

condition reports/event analysis reports/problem identification, and resolution reports)

since the last triennial inspection.

Enclosure 1

Mitigating Strategies 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. 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 NRC Order, EA-02-026, Order for NRC Interim Safeguards and

Security Compensatory Measures, dated February 25, 2002, the subsequently

imposed license conditions, and Title 10 of the Code of Federal Regulations (10 CFR)

50.54(hh)(2).

2. Lists 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, Revision 2, B.5.b Phase 2 & 3 Submittal Guideline,

issued December 2006, and the site-specific procedures or guidelines 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 for systems relied upon in the mitigation strategies.

These could be of the type used for training.

6. A list of modification packages or simplified drawings or 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 implement the mitigation strategies.

8. A list of B.5.b strategies, if any, that have implementing details that differ from those

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, and 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