ML12292A066
| ML12292A066 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/18/2012 |
| From: | Geoffrey Miller NRC/RGN-IV/DRS/EB-2 |
| To: | Edington R Arizona Public Service Co |
| References | |
| IR-13-008 | |
| Download: ML12292A066 (9) | |
See also: IR 05000528/2012008
Text
October 18, 2012
Randall K. Edington, Executive
Vice President, Nuclear/CNO
Arizona Public Service Company
Mail Station 7602
P.O. Box 52034
Phoenix, AZ 85072-2034
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION - NOTIFICATION OF NRC
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (05000528/2013008,
05000529/2013008, AND 05000530/2013008) AND REQUEST FOR
INFORMATION
Dear Mr. Edington:
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 the Palo Verde
Nuclear Generating Station Units 1, 2, and 3 in January and February 2013. The inspection
team will be comprised of five reactor inspectors from the NRC Region IV office. The inspection
will be conducted in accordance with Inspection Procedure 71111.05T, "Fire Protection
(Triennial)," the NRC=s baseline fire protection inspection procedure.
The schedule for the inspection is as follows:
$
Information gathering visit:
January 9 - 10, 2013
$
Onsite inspection:
January 28 - February 1, 2013
February 11 - 15, 2013
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 (ICM)
Order EA-02-026, of February 25, 2002, Part 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.
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON I V
612 EAST LAMAR BLVD, SUITE 400
ARLINGTON, TEXAS 76011-4125
R. Edington
- 2 -
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.
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, (4) the fire protection program and its implementation
and (5) the B.5.b program 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 NRC's 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) 200-1560, or
by email, John.Mateychick@nrc.gov
R. Edington
- 3 -
Sincerely,
/RA/
Geoffrey B. Miller, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos.: 50-528, 50-529, 50-530
License Nos.: NPF-41, NPF-51, NPF-74
Enclosure: Triennial Fire Protection Inspection Documentation Request
Electronic Distribution for Palo Verde Nuclear Generating Station
R. Edington
- 4 -
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Art.Howell@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
Acting DRP Deputy Director (Allen.Howe@nrc.gov)
Acting DRS Director (Tom.Blount@nrc.gov)
Acting DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Tony.Brown@nrc.gov)
Resident Inspector (Mica.Baquera@nrc.gov)
Resident Inspector (Dustin.Reinert@nrc.gov)
Branch Chief, DRP/D (Ryan.Lantz@nrc.gov)
Senior Project Engineer (Nick.Taylor@nrc.gov)
Project Engineer, DRP/D (David.You@nrc.gov)
Project Engineer, DRP/D (Brian.Parks@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Balwant.Singal@nrc.gov)
Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource
File located: R:\\REACTORS\\PV\\2013\\PV 2013008 FPT RFI - JMM
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
RIV: DRS/EB2/SRI
C: EB2
JMMateychick
GBMiller
/RA/
/RA/
10/17/12
10/18/12
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
- 1 -
Enclosure
ENCLOSURE
Triennial Fire Protection Inspection Documentation Request
Please provide the following documentation (items 1 - 5) prior to the onsite information
gathering visit, preferably no later than December 21, 2012. Where practical, please provide
copies electronically. Please provide an index of the requested documents which includes a
brief description of what the document is, and the numerical heading associated with the
request (i.e., where it can be found in the list of documents requested).
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 (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 probabilistic risk assessment updates.
5. A copy of the documents that support your multiple spurious operation evaluations (i.e.,
expert panel reports, evaluation packages, etc.).
Please provide the following documentation (items 6- 47) prior to the week of January 14,
2012, to support inspection preparation. Whenever practical, please provide copies
electronically. Drawings should be provided as paper copies of sufficient size such that all
details are legible.
6. 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; (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.
7. Fire protection program implementing procedures (e.g., administrative controls, operator
response procedures for fires, fire fighting procedures, etc.).
8. 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).
9. Operating procedure(s) used to implement an alternative shutdown (III.G.3 areas) capability
with or without control room evacuation.
- 2 -
Enclosure
10. A list of equipment used to achieve and maintain hot standby and cold shutdown in the
event of a fire (safe shutdown equipment list).
11. Piping and instrumentation (flow) diagrams showing the components used to achieve and
maintain hot standby and cold shutdown for normal and alternate shutdown. Please 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.
12. 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.
13. Copies of fire protection program change evaluations (Generic Letter 86-10 evaluations)
performed since the last triennial fire protection inspection.
14. 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 (for the selected fire areas). Include Corrective Action Process document
number, date, and subject.
15. 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.
16. Drawings of 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. A listing of maintenance and surveillance testing procedures for alternative shutdown
capability and fire barriers, detectors, pumps and suppression systems. 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.
21. 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.
- 3 -
Enclosure
22. 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.
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 since the last triennial fire protection inspection.
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.
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 February 11, 2013. 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 January 28, 2013. The
team would like to perform a walkthrough of a sample of manual actions required for other
fires not requiring control room evacuation. Please put us in contact, during the onsite
information gathering trip, with the appropriate personnel for planning the walkthrough.
- 4 -
Enclosure
The following documents (items 35 - 47) involve B.5.b mitigating strategies.
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 strategies and the inventory equipment (hoses, fittings, pumps, etc.) required to
be used to implement the mitigation strategies during the week of February 11, 2013.
Please put us in contact with the appropriate personnel for planning the walkthrough during
the onsite information gathering trip
- 5 -
Enclosure
The following documentation needs (items 48 - 51) will be dependent upon sample selections,
and will be finalized during discussions with your staff during the information gathering visit.
Please provide the required documents prior to the week of January 21, 2013. 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.
51. Drawings showing the location details for detection and suppression systems in the selected
fire areas.