ML19295C482
| ML19295C482 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/21/2019 |
| From: | Nick Taylor Division of Reactor Safety IV |
| To: | Gerry Powell South Texas |
| Taylor N | |
| References | |
| IR 2020011 | |
| Download: ML19295C482 (11) | |
See also: IR 05000498/2020011
Text
October 21, 2019
Mr. G. T. Powell
President and CEO
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, TX 77483
SUBJECT: SOUTH TEXAS PROJECT, UNITS 1 AND 2 - NOTIFICATION OF AN
NRC FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION
REPORT 05000498/2020011 AND 05000499/2020011) AND REQUEST FOR
INFORMATION
Dear Mr. Powell:
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 South Texas
Project, Units 1 and 2 in January and February 2020. The inspection team will be comprised of
three reactor inspectors from the NRC Region IV office. The inspection will be conducted in
accordance with Inspection Procedure 71111, Attachment 21N.05, Fire Protection Team
Inspection, the NRCs baseline fire protection inspection procedure.
The schedule for the inspection is as follows:
- Information gathering visit: January 7 and 8, 2020
- Onsite inspection: January 27 - 31, 2020, and February 10 - 14, 2020
The purpose of the information gathering visit is to obtain information and documentation
needed to support the inspection and to become familiar with the fire protection program, fire
protection features, post-fire safe shutdown capabilities, and plant layout.
The team lead will participate in the information gathering visit to select the fire areas for
evaluation, identify additional documents needed to support the inspection, obtain unescorted
access, and meet with the key personnel who will support the inspection. The fire area
selection will require a walkdown of candidate fire areas in company with key personnel from
your staff. The enclosure to this letter provides an initial list of the documents the team will need
for their review. We request that your staff transmit copies of the documents listed in the
enclosure to the NRC Region IV office for team use in preparation for the inspection. Please
send this information so that it will arrive in the NRC Region IV office by the dates listed in the
enclosure.
During the information gathering visit, the team lead will also discuss the following inspection
support administrative details: (1) office space size and location; (2) specific documents
requested to be made available to the team in their office spaces; (3) arrangements for reactor
G. Powell 2
site access (including radiation protection training, security, safety, and fitness-for-duty
requirements); and (4) the availability of knowledgeable plant staff and licensing organization
personnel to serve as points of contact during the inspection.
We request that during the onsite inspection weeks you ensure that copies of analyses,
evaluations, or documentation regarding the implementation and maintenance of the stations
fire protection program, including the success path necessary to achieve and maintain the
nuclear safety performance criteria, 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 (i.e., fire protection compliance
assessment documents). Also, personnel should be available at the site during the inspection
who are knowledgeable regarding those plant systems required to achieve and maintain safe
and stable plant conditions, including the electrical aspects of the nuclear safety capability
assessment, reactor plant fire protection systems and features, and the stations fire protection
program and its implementation.
This letter does not contain new or amended information collections that are subject to the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and
Budget (OMB) approved these information collections (approval number 3150-0011). The NRC
may not conduct nor 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 OMB control number.
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Your cooperation and support during this inspection will be appreciated. If you have questions
concerning this inspection or the inspection teams information or logistical needs, please
contact John Mateychick, the team lead inspector, in the Region IV office at (817) 200-1560 or
John.Mateychick@nrc.gov.
Sincerely,
/RA/
Nicholas H. Taylor, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-498 and 50-499
License Nos. NPF-76 and NPF-80
Enclosure:
Triennial Fire Protection Inspection Document Request
cc w/enclosure: Electronic Distribution for South Texas Project
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: JMM Yes No Publicly Available Sensitive NRC-002
OFFICE SRI:EB2 C:EB2
NAME JMateychick NTaylor
SIGNATURE /RA per NHT/ /RA/
DATE 10/21/2019 10/21/2019
Triennial Fire Protection Inspection Document Request
The documents and information requested below should generally be made available to the
inspection team prior to the inspection. Electronic format is the preferred format, except where
specifically noted. If electronic files are made available via a secure document management
service, then the remote document access must allow inspectors to download, save, and print
the documents in the NRCs regional office.
If a secure document management service is utilized, it is recommended that a separate folder
be used corresponding to each item listed below. Multiple documents within each folder be
individually entered and also combined into a ZIP file which is uploading in the same folder.
Documents should be identified by both document number and noun name. Electronic media
on compact disc or paper records (hard copy) are also acceptable.
To allow review before the onsite information gathering visit, the documents requested in
items A.1 thru A.8 should be made available to the team in the regional office no later than
December 27, 2019.
Based on a review of the above eight items, team lead should identify a preliminary list of fire
areas being considered for inspection prior to the onsite information gathering visit. During the
information gathering visit, or shortly thereafter, the fire areas selected for inspection will be
determined.
This document request is based on typical documents that a generic plant might have. As such,
this generic document request is not meant to imply that any specific plant is required to have all
of the listed documents. It is recognized that some documents listed below may not be
available for your plant. In addition, the document titles listed below are based on typical
industry document names; your plant-specific document titles may vary.
To allow review before the onsite inspection weeks, the documents listed in the attachment
should be made available to the team in the regional office no later than January 10, 2020.
Enclosure
A. DESIGN AND LICENSING BASIS DOCUMENTS
A.1 The current version of the Fire Protection Program and Fire Hazards Analysis.
A.2 Post-fire safe shutdown analysis and the supporting calculations that
demonstrate acceptable plant response.
A.3 The fire probabilistic risk assessment or portions of the plants individual plant
examination for external events (IPEEE) report addressing fire events. Also,
include the results of any post-IPEEE reviews and listings of actions taken/plant
modifications conducted in response to IPEEE information that relate to fire risk.
A.4 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.).
A.5 List of post-fire safe shutdown systems and components (i.e., safe shutdown
equipment list).
A.6 List of fire areas with automatic fire suppression systems.
A.7 A list, with descriptions, of design change packages performed since the last fire
protection team inspection associated with fire protection or post-fire safe
shutdown systems.
A.8 A list, with descriptions, of any fire protection program changes and evaluations
(not limited to Generic Letter 86-10 evaluations) performed since the last fire
protection team inspection.
A.9 Fire Protection System(s) Design Basis Document.
A.10 List of applicable NFPA codes and standards and issuance dates (i.e., codes of
record).
A.11 A list or document identifying any deviations from the NFPA codes of record.
A.12 Facility Operating License.
A.13 Technical Specifications (electronic format only).
A.14 Updated Final Safety Analysis Report (electronic format only).
B. GENERAL PLANT DESIGN DOCUMENTS
B.1 Piping and instrumentation diagrams (P&IDs) and legend list for components
used to achieve and maintain post-fire safe shutdown. 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.
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B.2 Piping and instrumentation diagrams and legend list for fire protection systems,
including the fire water supply; water suppression sprinklers; and deluge, CO2,
and Halon systems (electronic format and C-size paper drawings).
B.3 Yard layout drawings for underground fire protection buried piping (electronic
format and C-size paper drawings).
B.4 AC and DC electrical system single line diagrams, from off-site power down to
the highest safety-related bus level (typically 4kV, EDG bus) (electronic format
and C-size paper drawings).
B.5 Single line diagrams for motor control centers (MCCs) that supply post-fire
nuclear safety component loads (only for selected fire areas) (electronic format
and C-size paper drawings).
B.6 Equipment location drawings which identify the physical plant locations of post-
fire safe shutdown equipment (electronic format and C-size paper drawings).
B.7 Plant layout drawings which identify: (electronic format and C-size paper
drawings)
- Plant fire area boundaries
- Combustible control zone drawings
- Areas protected by automatic fire suppression and detection
- Locations of fire protection equipment
C. CLASSIC FIRE PROTECTION
C.1 Copy of the fire protection program implementing procedures (e.g., administrative
controls, surveillance testing, and fire brigade).
C.2 List of calculations and engineering analyses, studies, or evaluations for the fire
protection system, including the fire water system.
C.3 Last two completed surveillances of fire protection features in the selected fire
areas (detection, suppression, damper inspections, damper tests, penetration
inspections, barrier inspections, etc.).
C.4 List of routine tests, surveillances, and preventive maintenance on fire pumps,
including pump controllers and batteries.
C.5 Last two completed annual fire pump pressure and flow tests.
C.6 Last two completed monthly and/or quarterly fire pump tests.
C.7 Last two completed fire loop flow tests and loop flushes.
C.8 Last five hot work permits (at power).
C.9 Last five transient combustible permits (at power).
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C.10 For Fire Brigade Drills, provide the following:
- Last five fire brigade drill critiques
- Last drill critique for a drill with off-site fire department support
- Last unannounced drill critique
- Last back-shift drill critique
- Dates, shifts, and locations of unannounced drills for last three years
- Summary of any unsatisfactory drill performance items for last three years
- Last unannounced drill critique by a qualified individual independent of
the licensees staff
C.11 For fire brigade equipment provide the following:
- Procedure for inventory and inspection
- Most recent inspection and inventory results
C.12 Fire Brigade Qualifications, including self-contained breathing apparatus, (SCBA)
and training lesson plans.
C.13 Copy of the mutual aid agreement for the first-due local fire department that is
currently in effect.
C.14 Copy of the evaluation or analysis of the effects of fire suppression activities on
the ability to achieve the nuclear safety performance criteria (only for selected fire
areas) demonstrating:
- The automatic or manually actuation of a suppression system, due to a
fire in a single location, will not indirectly cause damage to the success
path
- The inadvertent actuation or rupture of a suppression system will not
indirectly cause damage to the success path
- Adequate drainage for areas protected by water suppression systems
- The hydrostatic rating of any floor penetration seals installed within the
fire areas that are credited with keeping water from leaking into fire areas
below
C.15 Pre-fire plans for all fire areas.
C.16 Impairment Log (at start of inspection) for fire protection features that are out of
service.
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C.17 List of penetration seal work, re-work, or installation activities, in the last
three years.
C.18 List of fire wrap work, re-work, or installation activities, in the last three years.
C.19 Fire protection system health reports for the two most recent quarters.
C.20 Fire protection program health reports for the two most recent quarters.
C.21 Emergency lighting system health reports for the two most recent quarters.
C.22 List of fire protection system design changes completed in the last three years.
C.23 List of fire protection system engineering equivalency evaluations completed in
the last three years.
C.24 Licensee evaluations of industry operating experience concerning fire protection
issues completed in the last three years.
C.25 List of fire event analysis reports for the last three years.
C.26 Fire protection program requirements (e.g., limiting conditions for operation,
surveillance test requirements) covered by technical specifications, the technical
requirements manual, the updated final safety analysis report, procedures, or
similar documents.
C.27 Organization charts of site personnel down to the level of fire protection staff
personnel.
C.28 A contact list of key site personnel who will be supporting this inspection, giving
the office location and phone number onsite.
C.29 The team would like to observe an unannounced fire brigade drill in the plant, if
possible, during the week of February 10, 2020. Please put us in contact with
the appropriate personnel for planning fire brigade drills during the onsite
information gathering trip.
D. ELECTRICAL
D.1 Administrative or configuration control procedures that govern fuse replacement
(e.g., fuse control procedures).
D.2 Maintenance procedures that verify breaker over-current trip settings to ensure
coordination remains functional for post-fire nuclear safety capability
components.
D.3 Electrical system health reports for the two most recent quarters.
D.4 Surveillance procedures and last surveillance demonstrating operability of
components required for alternative shutdown.
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D.5 Schematic or elementary diagrams for circuits to be reviewed (samples to be
identified by the inspector) (C-size paper drawings).
D.6 Cable routing for components and equipment credited for post-fire safe shutdown
systems and components (samples to be identified by the inspector).
D.7 For emergency lighting units, provide the following:
- List of Preventive Maintenance tasks, frequencies, and bases
- Most recently performed monthly or quarterly functional test
- Most recently performed battery discharge performance test or
conductance measurement test
- Emergency lighting unit battery loading analysis
- Vendor manual(s) for onsite inspector use
- Results of black-out testing (if performed)
- Maintenance Rule program information related to the emergency lighting
system
- Compensatory measures taken when emergency lighting units are out of
service
- Drawings showing emergency light locations and lamp orientation
E. OPERATIONS
E.1 The team would like to perform a walkthrough of a sample of post-fire safe
shutdown procedures with qualified operators in the plant during the week of
January 27, 2020. Please put us in contact with the appropriate personnel for
planning the walkthroughs during the onsite information gathering trip.
E.2 List of licensed operator Job Performance Measures (JPMs) for operator actions
required to achieve and maintain post-fire safe shutdown.
E.3 List of non-licensed operator training associated with non-licensed operator
actions to achieve and maintain post-fire nuclear safe shutdown (including JPMs,
in-field training walkdowns, simulations, or initial qualification).
E.4 Lesson plans for post-fire safe shutdown training for licensed and non-licensed
operators.
E.5 For local manual operator actions, provide the following:
- Manual Action Feasibility Study
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- Operator Time Critical Action Program
- Time lines for time-critical manual actions
- Time line validations
E.6 Thermal hydraulic calculation or analysis that determines the time requirements
for time-critical manual operator actions.
E.7 Operating procedures to achieve and maintain post-fire safe shutdown with a
postulated fire in the selected fire areas.
E.8 For safe shutdown equipment and tools, provide the following:
- Procedure for inventory and inspection
- Most recent inspection and inventory results
E.9 List of procedures that implement cold shutdown repairs.
E.10 For cold shutdown repairs, provide the following:
- Procedure for inventory and inspection (i.e., needed tools, material, etc.)
- Most recent inspection and inventory results
E.11 For radio communications, provide the following:
- Communications Plan for firefighting and post-fire safe shutdown manual
actions
- Repeater locations
- Cable routing for repeater power supply cables
- Radio coverage test results
- Radio Dead Spot locations in the plant
E.12 For telephone, plant pager or sound powered phone systems, if relied upon to
achieve and maintain post-fire safe shutdown, provide the following:
- Communications Plan for firefighting and post-fire safe shutdown manual
actions
- Locations of phone, pager units, sound powered phone jacks, and sound
powered phone headsets
- Cable routing including power supply cables
E.13 Environmental and habitability evaluations for post-fire safe shutdown operator
actions (temperature, smoke, humidity, SCBAs, etc.).
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F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION
PROGRAMS
F.1 Copies of procedures that control the configuration of the fire protection program,
features, and post-fire safe shutdown methodology and system design. Also,
copies of procedures that govern the implementation of plant modifications,
maintenance, and special operations and their impact on fire protection.
F.2 List of open and closed condition reports for the fire protection systems for the
last three years.
F.3 List of open and closed condition reports associated with the post-fire safe
shutdown analysis for the last three years.
F.4 List of open and closed condition reports associated with operator actions to
achieve and maintain post-fire safe shutdown for the last three years.
F.5 List of open and closed condition reports associated with the fire protection
program including plant change evaluations, post-fire operating procedures
and/or training, timeline evaluations for operator actions, and supporting
engineering evaluations, analysis, or calculations for the last three years.
F.6 List of open and closed condition reports for emergency lighting units for the last
three years.
F.7 Self-assessments, peer assessments, and audits of fire protection activities for
the last three years.
F.8 Self-assessments, peer assessments, and audits of post-fire nuclear safety
capability methodology for the last three years.
G. AGING MANAGEMENT PROGRAM
G.1 Copies of the aging management programs applicable to fire protection including
but not limited to the following:
- Fire Protection
- Fire Water System
- Aboveground Metallic Tanks
- Buried and Underground Piping and Tanks
G.2 Copies of procedures, work orders, preventive maintenance tasks, or other
documents which implement the commitments made as part of the license
extension related to fire protection.
G.3 List of aging management activities related to fire protection performed to date.
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