ML110280044
| ML110280044 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/27/2011 |
| From: | O'Keefe N NRC/RGN-IV/DRS/EB-2 |
| To: | Douet J Entergy Operations |
| References | |
| IR-11-007 | |
| Download: ML110280044 (11) | |
See also: IR 05000416/2011007
Text
January 27, 2011
James R. Douet
Vice President Operations
Entergy Operations, Inc.
Grand Gulf Nuclear Station
P.O. Box 756
Port Gibson, MS
SUBJECT:
GRAND GULF NUCLEAR STATION - NOTIFICATION OF AN NRC TRIENNIAL
FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION
REPORT 05000416/2011007 AND REQUEST FOR INFORMATION
Dear Mr. Douet:
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 Grand Gulf
facility in April 2011. The inspection team will be comprised of reactor inspectors from the NRC
Region IV office. The team will conduct the inspection in accordance with the baseline
Inspection Procedure 71111.05T, "Fire Protection (Triennial)."
The schedule for the inspection is as follows:
Information gathering visit: March 15-16, 2011
Onsite inspection:
April 4 - 8, 2011
April 18 - 22, 2011
The purpose of the information gathering visit is to obtain information and documentation
needed to support the inspection, to become familiar with the fire protection programs, fire
protection features, post-fire safe shutdown capabilities and 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). Four individuals 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 our office in Arlington,
Texas, by the dates listed in the enclosure.
During the information gathering visit, the team will also discuss the following inspection support
administrative details: office space size and location; specific documents requested to be made
available to the team in their office spaces; arrangements for reactor site access; and the
availability of knowledgeable plant engineering and licensing organization personnel to serve as
points of contact during the inspection.
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON I V
612 EAST LAMAR BLVD, SUITE 400
ARLINGTON, TEXAS 76011-4125
Grand Gulf Nuclear Station
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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 for the fire protection portion of the inspection are
those documents that establish that your fire protection program satisfies the 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, please ensure the availability of appropriate personnel knowledgeable of: (1) 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.
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.
In accordance with 10 CFR 2.390 of the NRCs 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
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
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 Mateychick, the team lead inspector, in the Region IV office at (817) 276-6560, or
by email, John.Mateychick@nrc.gov
Sincerely,
/RA/
Neil O'Keefe, Chief
Engineering Branch 2
Division of Reactor Safety
Docket: 50-416
License: NPF-29
Enclosure: Triennial Fire Protection
Inspection Documentation Request List
Grand Gulf Nuclear Station
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Senior Vice President
Entergy Nuclear Operations
P.O. Box 31995
Jackson, MS 39286-1995
Senior Vice President and COO
Entergy Operations, Inc
P.O. Box 31995
Jackson, MS 39286-1995
Vice President, Oversight
Entergy Operations, Inc
P.O. Box 31995
Jackson, MS 39286-1995
Chief, Energy and Transportation Branch
Environmental Compliance and
Enforcement Division
Mississippi Department of
Environmental Quality
P.O. Box 2249
Jackson, MS 39225-2249
Interim County Administrator
Claiborne County
Board of Supervisors (James Johnston)
510 Market Street
Port Gibson, MS 39150
Manager, Licensing
Sr. Site Executive
Entergy Nuclear Operations
P.O. Box 31995
Jackson, MS 39286-1995
Senior Manager, Nuclear Safety & Licensing
Licensing /Regulatory Affairs
Entergy Nuclear Operations
P.O. Box 31995
Jackson, MS 39286-1995
Manager, Licensing
Entergy Operations, Inc
Grand Gulf Nuclear Station
P.O. Box 756
Port Gibson, MS 39150
Grand Gulf Nuclear Station
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Attorney General
Department of Justice
State of Louisiana
P.O. Box 94005
Baton Rouge, LA 70804-9005
Office of the Governor
State of Mississippi
P. O. Box 139
Jackson, MS 39205-0139
Attorney General
Assistant Attorney General
State of Mississippi
P.O. Box 220
Jackson, MS 39205
State Health Officer
State Health Board
P.O. Box 1700
Jackson, MS 39215
Associate General Counsel
Entergy Nuclear Operations
P.O. Box 31995
Jackson, MS 39286-1995
Louisiana Dept. of Environmental Quality
Radiological Emergency Planning and
Response Division
P.O. Box 4312
Baton Rouge, LA 70821-4312
Chief, Technological Hazards
Branch
FEMA Region VI
800 North Loop 288
Federal Regional Center
Denton, TX 76209
Joseph A. Aluise
Associate General Council - Nuclear
Entergy Services, Inc
639 Loyola Avenue
New Orleans, LA 70113
Grand Gulf Nuclear Station
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Chief
Technological Services Branch
FEMA Region IV
3003 Chamblee-Tucker Road
Atlanta, GA 30341
Grand Gulf Nuclear Station
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Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov )
Deputy Regional Administrator (Art.Howell@nrc.gov )
DRP Director (Kriss.Kennedy@nrc.gov )
DRP Deputy Director (Troy.Pruett@nrc.gov )
DRS Director (Anton.Vegel@nrc.gov )
DRS Deputy Director (Vacant)
Senior Resident Inspector (Rich.Smith@nrc.gov )
Resident Inspector (Andy.Barrett@nrc.gov )
Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov )
Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov )
Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov )
GG Administrative Assistant (Alley.Farrell@nrc.gov )
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov )
Project Manager (Alan.Wang@nrc.gov )
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov )
RITS Coordinator (Marisa.Herrera@nrc.gov )
Regional Counsel (Karla.Fuller@nrc.gov )
Congressional Affairs Officer (Jenny.Weil@nrc.gov )
OEMail Resource
OEDO RIV Coordinator (James.Trapp@nrc.gov )
DRS/TSB STA (Dale.Powers@nrc.gov )
File located: S:\\DRS\\REPORTS\\GG TFP RFI 2011007 - JMM.docx ML110280044
SUNSI Rev Compl.
X Yes No
X Yes No
Reviewer Initials
JMM
Publicly Avail
X Yes No
Sensitive
Yes X No
Sens. Type Initials
JMM
EB2
C: EB 2
JMateychick
NOKeefe
/RA/
/RA/
1/25/11
1/26/11
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
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Enclosure
ENCLOSURE
Triennial Fire Protection Inspection Documentation Request
Please provide the following documentation items 1 - 4 prior to the onsite information-gathering
visit, preferably no later than February 28, 2011. Where practical, please provide copies
electronically.
1. The current version of your fire protection program and fire hazards analysis.
2. Post-fire safe shutdown analysis and the supporting calculations that 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 probabilistic risk assessment or portions of the plants individual plant
examination for external events report addressing fire events.
Please provide the following documentation items 5 - 47 during the information-gathering
visit or by March 25, 2011, in order to support inspection preparation. Whenever practical,
please provide copies electronically. However, drawings should be provided as paper
copies of sufficient size that all details are legible.
5. Plant layout and equipment drawings for fire areas that identify: (a) the physical plant
locations of major hot standby and cold shutdown equipment; (b) plant fire 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. The specific documents needed to support inspection preparation will be
discussed during the site visit.
6. Fire protection program implementing procedures (e.g., administrative controls, operator
response procedures for fires, fire fighting procedures, etc.).
7. 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).
8. Operating procedure(s) used to implement an alternative shutdown (III.G.3 areas)
capability with or without control room evacuation.
9. A list of equipment used to achieve and maintain hot standby and cold shutdown in the
event of a fire (safe shutdown equipment lists).
10. Piping and instrumentation (flow) diagrams showing the components used to achieve
and maintain hot standby and cold shutdown for normal and alternate shutdown. Please
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Enclosure
provide one copy 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 reactor
coolant system (RCS) makeup, RCS pressure control, decay heat removal, and
reactivity control, including the essential support systems.
11. A listing, with descriptions, of design change packages which were determined to impact
fire protection and post-fire safe shutdowns, performed since the last triennial fire
protection inspection.
12. Copies of fire protection program change evaluations (Generic Letter 86-10 evaluations)
performed since the last triennial fire protection inspection.
13. A listing of open and closed corrective action documents initiated since the last triennial
fire protection inspection, which relate to the fire protection program or equipment,
including corrective actions for fire-induced circuit failures, both single and multiple
spurious actuations. Include Corrective Action Process document number, date, and
subject.
14. A listing of the applicable codes and standards (with the versions/dates) related to the
design of plant fire protection features and evaluations of any code deviations. Copies
of these codes should be available for review.
15. Drawings of the portions of the emergency lighting system which support fire response.
16. Procedures used to remove smoke from safety-related areas and the engineering
studies or calculations which support the design basis.
17. Drawings of communication systems credited in the license basis for firefighting and
plant operations during fires where control room is occupied and/or evacuated.
18. Piping and instrumentation (flow) diagrams for the fire water system and selected
suppression systems (To be determined during information-gathering visit).
19. A listing of maintenance and surveillance testing procedures for alternative shutdown
capability, fire barriers, fire detectors, fire pumps, suppression systems and emergency
lighting. Also, include a list of maintenance and surveillance testing procedures which
verify fuse and breaker coordination in accordance with the post-fire safe shutdown
coordination analysis.
20. Maintenance rule performance criterion, and a summary of the performance history for
systems or functions monitored within the maintenance rule program that support the fire
protection program or involve safe shutdown equipment, over the period since the last
triennial fire protection inspection.
21. A copy of fire protection program requirements (e.g., limiting conditions for operation,
surveillance test requirements) covered by technical specifications, technical
requirements manual, updated final safety analysis report, or similar documents.
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Enclosure
22. 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 since the last triennial fire protection inspection.
23. 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.
24. Corrective action taken or planned associated with NCVs05000416/2008006-01, 05000416/2008006-02, 05000416/2008006-03 and 05000416/2008006-04.
25. Electronic copies of operator study guides (i.e., 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 AC and vital DC electrical distribution systems.
These should depict how power gets from the switchyard to the engineered safety
feature loads (480V and 4160V).
27. A list of automatic and manually initiated gaseous fire suppression systems in the plant,
giving location and the key equipment being protected.
28. A list of repairs (and the procedure that controls the actions) needed to: a) reach and/or
maintain hot shutdown and b) reach and/or maintain cold shutdown.
29. A list of high to low pressure interface valves.
30. A copy of procedures governing the training and operation of the fire brigade.
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.
33. The team would like to observe an unannounced fire brigade drill in the plant, if possible,
during the week of April 18, 2011. Please put us in contact, during the onsite information
gathering trip, with the appropriate personnel for planning drills.
34. The team would like to perform a walkthrough of the procedure for control room
evacuation due to fire with qualified operators in the plant during the week of April 4,
2011. Please put us in contact, during the onsite information gathering trip, with the
appropriate personnel for planning the walkthrough.
The following documents (items 35 - 48) involve B.5.b mitigating strategies.
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Enclosure
35. A copy of the license condition that incorporated the requirements issued to address the
requirements of Section B.5.b of the ICM Order, EA-02-026, dated February 25, 2002,
and 10 CFR 50.54(hh)(2).
36. 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).
37. A list of procedures/guidelines which 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.
38. 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.
39. A list of engineering evaluations/calculations that were used to verify engineering bases
for the mitigation strategies.
40. Copies of piping and instrumentation diagrams (P&ID) or simplified flow diagrams for
systems relied upon in the mitigation strategies. These could be the type used for
training.
41. A list of modification packages and simplified drawings/descriptions of modifications that
were made to plant systems to implement the mitigation strategies.
42. Copies of procedure(s) used to inventory equipment (hoses, fittings, pumps, etc.)
required to be used to implement the mitigation strategies.
43. A list of B.5.b strategies, if any, which have implementing details that differ from that
documented in the submittals to the NRC and the safety evaluation report.
44. A copy of site general arrangement drawing(s) that show the majority of buildings/areas
referenced in B.5.b documents.
45. Training records/ training matrix/ lesson plans related to B.5.b.
46. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments)
required to implement any mitigating strategies.
47. The team would like to perform a walkthrough of the procedure implementing a sample
mitigating strategy (to be selected by the inspector during the information gathering visit)
and the inventory equipment (hoses, fittings, pumps, etc.) required to be used to
implement the mitigation strategies during the week of April 4, 2011. Please put us in
contact with the appropriate personnel for planning the walkthrough during the onsite
information gathering trip
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Enclosure
The following documentation needs (items 48 - 50) will be dependent upon sample selections,
and will be finalized during discussions with your staff. Please provide the required documents
prior to the week of April 4, 2011. Whenever practical, please provide copies electronically.
Drawings should be provided as paper copies of sufficient size such that all details are legible.
48. Pre-fire plans for the selected fire areas (areas to be selected by the team during the
information-gathering trip).
49. List of identified fire induced circuit failure configurations (for the selected fire areas) that
could prevent operation or cause maloperation of equipment credited for safe shutdown
in the event of a fire. Include failure configurations associated with hot shorts, open
circuits, or shorts to ground identified as potentially causing spurious or multiple spurious
actuations or maloperations of this equipment.
-
50. Cable routing information for components and equipment, credited for safe shutdown in
the selected fire areas. This information request item will be discussed and finalized with
your staff during the information gathering visit.