ML080350699

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Notification to Conduct a Triennial Fire Protection Baseline Inspection While Transition to 10 CFR Part 50.48(c) Is in Progress IR 05000263-08-006
ML080350699
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 02/04/2008
From: Julio Lara
Engineering Branch 3
To: O'Connor T
Nuclear Management Co
References
IR-08-006
Download: ML080350699 (10)


See also: IR 05000263/2008006

Text

February 4, 2008

Mr. Timothy J. OConnor

Site Vice President

Monticello Nuclear Generating Plant

Nuclear Management Company, LLC

2807 West County Road 75

Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT

NOTIFICATION TO CONDUCT A TRIENNIAL FIRE PROTECTION BASELINE

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

PROGRESS INSPECTION REPORT 05000263/2008006(DRS)

Dear Mr. OConnor:

On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire

protection baseline inspection at the Monticello Nuclear Generating Plant. 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 from code requirements. The

inspectors will not routinely inspect for or evaluate circuit related issues.

The schedule for the inspection is as follows:

y

Information gathering visit - February 27 - 29, 2008; and

y

On-site inspection activity - March 31 - April 4, 2008, and April 14 - 18, 2008.

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

needed to support the inspection; (2) become familiar with the Monticello Nuclear Generating

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

plant layout; and (3) arrange administrative details such as office space, availability of

knowledgeable office personnel, and to ensure unescorted site access privileges.

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

T. OConner

-2-

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 February 11, 2008. The

second group lists information necessary to ensure that the inspection team is adequately

prepared for the inspection. This information should be available on-site no later than

February 27, 2008. The third group of requested documents are those items that the inspection

team will review, or need access to, during the inspection. Please have this information

available by the first day of the on-site portion of the inspection (March 31, 2008). 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. George M. Hausman. We understand that our initial

regulatory contact for this inspection is Mr. Ronald Baumer of your organization. If there are

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

at (630) 829-9743 or via e-mail at gmh1@nrc.gov.

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), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Julio F. Lara, Chief

Engineering Branch 3

Division of Reactor Safety

Docket No.:

50-263

License No.: DPR-22

Enclosure:

Fire Protection Inspection Document Request

cc w/encl:

M. Sellman, President and Chief Executive Officer

D. Koehl, Chief Nuclear Officer

Manager, Nuclear Safety Assessment

J. Rogoff, Vice President, Counsel, and Secretary

Nuclear Asset Manager, Xcel Energy, Inc.

State Liaison Officer, Minnesota Department of Health

R. Nelson, President

Minnesota Environmental Control Citizens

Association (MECCA)

Commissioner, Minnesota Pollution Control Agency

R. Hiivala, Auditor/Treasurer,

Wright County Government Center

Commissioner, Minnesota Department of Commerce

Manager - Environmental Protection Division

Minnesota Attorney Generals Office

T. OConnor

-2-

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 February 11, 2008. The second group lists

information necessary to ensure that the inspection team is adequately prepared for the inspection.

This information should be available on-site no later than February 27, 2008. The third group of

requested documents is those items that the inspection team will review, or need access to, during the

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

(March 31, 2008). 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. George M. Hausman. We understand that our initial

regulatory contact for this inspection is Mr. Ronald Baumer of your organization. If there are any

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

(630) 829-9743 or via e-mail at gmh1@nrc.gov.

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), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

Julio F. Lara, Chief

Engineering Branch 3

Division of Reactor Safety

Docket No.:

50-263

License No.:

DPR-22

Enclosure:

Fire Protection Inspection Document Request

cc w/encl:

M. Sellman, President and Chief Executive Officer

D. Koehl, Chief Nuclear Officer

Manager, Nuclear Safety Assessment

J. Rogoff, Vice President, Counsel, and Secretary

Nuclear Asset Manager, Xcel Energy, Inc.

State Liaison Officer, Minnesota Department of Health

R. Nelson, President

Minnesota Environmental Control Citizens

Association (MECCA)

Commissioner, Minnesota Pollution Control Agency

R. Hiivala, Auditor/Treasurer,

Wright County Government Center

Commissioner, Minnesota Department of Commerce

Manager - Environmental Protection Division

Minnesota Attorney Generals Office

DISTRIBUTION

See next page

DOCUMENT NAME: G:\\DRS\\Work in Progress\\Ltr 01 08 Monticello FPI Triennial Notification Ltr GMH.doc

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

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NAME

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DATE

02/04/2008

02/04/2008

OFFICIAL RECORD COPY

Letter to Mr. Timothy J. OConnor from Julio F. Lara dated February 4, 2008

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT

NOTIFICATION TO CONDUCT A TRIENNIAL FIRE PROTECTION BASELINE

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

PROGRESS INSPECTION REPORT 05000263/2008006(DRS)

DISTRIBUTION:

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MAS

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ROPreports@nrc.gov

FIRE PROTECTION INSPECTION DOCUMENT REQUEST

INITIAL REQUEST

1

Enclosure

Inspection Report: 05000263/2008006(DRS)

Inspection Dates:

February 27 - 29, 2008

(Information Gathering Visit)

March 31 - April 4, 2008

(On-site Inspection Activity)

April 14 - 18, 2008

(On-site Inspection Activity)

Inspection Procedures:

IP 71111.05TTP, Fire Protection-NFPA Transition Period

(Triennial) IP 71152, "Identification and Resolution of Problems"

Inspectors:

Lead Inspector:

George M. Hausman, (630) 829-9743

Team Members:

Benny Jose, (630) 829-9756

Robert A.Winter, (630) 829-9758

I

INFORMATION REQUESTED PRIOR TO THE INFORMATION GATHERING VISIT

The following information is requested by February 11, 2008. If you have any questions

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

ensure that the information to be provided in lists contain enough information to be easily

understood by someone who has a knowledge of the technology. All information should be

sent to Mr. George M. Hausman (e-mail address gmh1@nrc.gov). Electronic media is

preferred, if readily available. The preferred file format is a searchable .pdf file on a

CDROM. The CDROM should be indexed and hyper-linked to facilitate ease of use, if

possible. Please provide four copies of each CDROM submitted (one for each inspector

and for a senior reactor analysis).

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 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.

3. 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.

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

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

FIRE PROTECTION INSPECTION DOCUMENT REQUEST

INITIAL REQUEST

2

Enclosure

II STATUS OF 10 CFR 50.48(C), NFPA 805 IMPLEMENTATION INFORMATION

REQUESTED DURING THE INFORMATION GATHERING VISIT

(FEBRUARY 27 - 29, 2008)

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

on-site information gathering visit as one set of hard-copy documents. In addition, the

requested information is to be provided as a file searchable compact disc (CD), if possible.

If a CD(s) can be provided, three sets (one for each inspector) are requested.

1. 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 other associated licensing

correspondence applicable to fire protection;

c.

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

license condition;

d.

Exemptions from 10 CFR 50.48 and 10 CFR Part 50, Appendix R, and associated

licensing correspondence;

e.

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);

f.

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

10 CFR 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 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 50.48(b)(1)(ii));

g.

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

h.

For plants intending to transition to NFPA 805, 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).

FIRE PROTECTION INSPECTION DOCUMENT REQUEST

INITIAL REQUEST

3

Enclosure

2. Fire Protection Program:

a.

If not already provided under request II.(1)(c) above, FPP documents including

FHA and post-fire SSA;

b.

A listing of changes made to the FPP (including associated adverse to SSA);

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 foot

separation along with detection and suppression; (Section III.G.2.b), 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated

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

shutdown capability; (Section III.G.3) is used for each selected fire zone/area;

d.

A list of Generic Letter 86-10 evaluations (i.e., a list of adverse to safe shutdown

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; and

g.

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

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

equipment.

3. 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 480 Vac;

e.

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

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

f.

Safe shutdown cable routing database (requested electronically such as on

compact disc, if available.

FIRE PROTECTION INSPECTION DOCUMENT REQUEST

INITIAL REQUEST

4

Enclosure

4. 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).

5. 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.

6. General Information:

a.

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

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.

7. 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

A tour of alternative shutdown and risk significant fire areas.

III. Information Requested to be Available on First Day of Inspection (March 31, 2008)

1. Procedures:

a.

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

testing, fire brigade);

FIRE PROTECTION INSPECTION DOCUMENT REQUEST

INITIAL REQUEST

5

Enclosure

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

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 Part 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 4160 Vac down to 480 Vac

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); 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.

6

Enclosure

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).