ML14098A172

IR 05000498-14-008 and 05000499-14-008, South Texas Project Nuclear Power Plant, Units 1 & 2, Notification of an NRC Triennial Fire Protection Baseline and Request for Information

ML14098A172
Person / Time
Site:	South Texas
Issue date:	04/08/2014
From:	John Dixon NRC/RGN-IV/DRS/EB-2
To:	Koehl D South Texas
Dixon J
References
IR-14-008
Download: ML14098A172 (8)

See also: IR 05000498/2014008

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

April 8, 2014

Mr. Dennis L. Koehl

President & CEO/CNO

STP Nuclear Operating Company

P.O. Box 289

Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT NUCLEAR POWER PLANT, UNITS 1 AND 2 -

NOTIFICATION OF AN NRC TRIENNIAL FIRE PROTECTION BASELINE

INSPECTION (NRC INSPECTION REPORT 05000498/05000499/2014008)

AND REQUEST FOR INFORMATION

Dear Mr. Koehl:

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 South Texas

Project Nuclear Power Plant, Units 1 and 2, in September, 2014. The inspection team will be

comprised of four inspectors from the NRC Region IV office. The inspection will be conducted

in accordance with Inspection Procedure 71111.05T, Fire Protection (Triennial), the NRCs

baseline fire protection inspection procedure.

The schedule for the inspection is:

Information gathering visit:

August 18 - 22, 2014

Onsite inspection:

September 8 - 12, 2014

September 22 - 26, 2014

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, plant layout, and mitigating strategies

to address Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2).

Two inspectors 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.

D. Koehl

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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 that appropriate personnel are available to support the team at the

site during the inspection. These personnel should be knowledgeable of the plant systems

required to achieve and maintain safe shutdown conditions from inside and outside the control

room, the electrical aspects of the post-fire safe shutdown analyses, the reactor plant fire

protection systems, and the 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 under 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 Sam Graves, the team lead inspector, in the Region IV office at (817) 200-1102 or

samuel.graves@nrc.gov.

Sincerely,

/RA/

John L. Dixon Jr., Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-498; 50-499

License Nos. NPF-76; NPF-80

Enclosure: Triennial Fire Protection Inspection Documentation Request

Electronic Distribution to South Texas Project Nuclear Power Plant

D. Koehl

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Electronic distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Steven.Reynolds@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov)

Acting DRS Director (Jeff.Clark@nrc.gov)

Acting DRS Deputy Director (Geoffrey.Miller@nrc.gov)

Senior Resident Inspector (Alfred.Sanchez@nrc.gov)

Resident Inspector (Nick.Hernandez@nrc.gov)

Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)

Senior Project Engineer, DRP/B (David.Proulx@nrc.gov)

Project Engineer, DRP/B (David.You@nrc.gov)

STP Administrative Assistant (Lynn.Wright@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)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV/ETA: OEDO (Joseph.Nick@nrc.gov)

File located:

R:\\_REACTORS\\_STP\\2014\\STP 2014008-RFI-STG 140408.pdf ML14098A172

SUNSI Rev Compl.

Yes No

ADAMS

Yes No

Reviewer Initials

STG

Publicly Avail

Yes No

Sensitive

Yes No

Sens. Type Initials

STG

SRI: DRS/EB2

C: EB2

SGraves

JDixon

/RA/

/RA/

03/24/14

04/08/14

OFFICIAL RECORD COPY

T=Telephone E=E-mail F=Fax

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Enclosure

ENCLOSURE

Triennial Fire Protection Inspection Documentation Request

For all documents requested (items 1 - 52) please provide an indexed table of the requested

documents which includes a title of the document, a brief description of the document and the

numerical heading associated with the request (i.e., where it can be found in the list of

documents requested). Where information is provided that includes tables and/or lists of data or

other such information, please do not scan such tables and/or lists as images. The preferred

file format is a searchable portable document format (pdf) file on transportable media (CD/DVD).

The information should be indexed and hyperlinked to facilitate use. Please identify and

describe each request items documents in a separate folder on the media (e.g., Item 1, Item 2,

etc.). Each document should be listed in a table as follows:

ITEM X (where X equals 1 through 52)

Document

Number

Title

Description

Revision

No. 1

No. 2

No. 3

etc

Please provide the following documentation (items 1 - 5) prior to the onsite information

gathering visit, preferably no later than July 28, 2014. Whenever practical, please provide

copies electronically.

1. The current version of the fire protection program and fire hazards analysis.

2. Post-fire safe shutdown analysis and the supporting calculations that demonstrate

acceptable plant response.

3. 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 IPEEE information that relate to fire risk.

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 - 48) prior to the week of August 25,

2014, 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.

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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 procedures used to implement an alternative shutdown capability with or without

control room evacuation (III.G.3 areas).

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 alternative 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 makeup, reactor coolant system pressure control, decay heat removal, and reactivity

control, including the essential support systems.

12. A listing, with descriptions, of design change packages performed since the last triennial fire

protection inspection which were determined to impact fire protection and post-fire safe

shutdowns.

13. Fire protection program change evaluations (Generic Letter 86-10 evaluations or similar)

performed since the last triennial fire protection inspection.

14. Procedures/instructions that control the configuration of the plants fire protection program,

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

procedures/instructions that govern the implementation of plant modifications, maintenance,

and special operations and their impact on fire protection.

15. 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 the corrective action program document

number, date, and subject.

16. 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.

17. Drawings of the portions of the emergency lighting system which support fire response.

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18. Procedures used to remove smoke from safety-related areas and the engineering studies or

calculations which support the design basis.

19. Drawings of communication systems credited in the license basis for firefighting and plant

operations during fires where the Control Room is occupied and/or evacuated.

20. Piping and instrumentation (flow) diagrams for the fire water and sprinkler systems.

21. 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.

22. Maintenance rule performance criteria 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.

23. 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, or similar documents.

24. 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.

25. 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.

26. 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 (reactor coolant system makeup, reactor coolant system pressure

control, decay heat removal, and reactivity control, including the essential support systems).

27. 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).

28. A list of automatic and manually initiated gaseous fire suppression systems in the plant,

giving their location and the key equipment being protected.

29. A list of repairs (and the procedure that controls the repairs) needed to reach and/or

maintain hot or cold shutdown.

30. A list of high to low pressure interface valves.

31. Procedures governing the training and operation of the fire brigade.

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32. Organization charts of site personnel down to the level of fire protection staff personnel.

33. A contact list of key site personnel who will be supporting this inspection, giving the office

location and phone number onsite.

34. The team would like to observe an unannounced fire brigade drill in the plant, if possible,

during the week of September 22, 2014. Please put us in contact with the appropriate

personnel for planning fire brigade drills during the onsite information gathering trip.

35. The team would like to perform a walkthrough of the alternative shutdown procedure with

qualified operators in the plant during the week of September 8, 2014. 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 with the appropriate personnel for

planning the walkthroughs during the onsite information gathering trip.

The following documents (items 36 - 48) involve B.5.b [10 CFR 50.54(hh)(2)] mitigating

strategies.

36. License condition that incorporated the requirements issued to address 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 10 CFR 50.54(hh)(2).

37. 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 10 CFR 50.54(hh)(2).

38. A list of procedures/guidelines which were revised or generated to implement the mitigation

strategies. These could be extensive damage mitigation guidelines, severe accident

management guidelines, emergency operating procedures, abnormal operating procedures,

etc.

39. 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.

40. A list of engineering evaluations/calculations that were used to verify engineering bases for

the mitigation strategies.

41. Piping and instrumentation diagrams or simplified flow diagrams for systems relied upon in

the mitigation strategies. These could be the type used for training.

42. A list of modification packages and simplified drawings/descriptions of modifications that

were made to plant systems to implement the mitigation strategies.

43. Procedures used to inventory equipment (hoses, fittings, pumps, etc.) required to be used to

implement the mitigation strategies.

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44. 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.

45. Site general arrangement drawing(s) that show the majority of buildings/areas referenced in

B.5.b documents.

46. Training records and lesson plans related to the B.5.b [10 CFR 50.54(hh)(2)] mitigating

strategies.

47. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments) required

to implement any mitigating strategies.

48. 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 September 8, 2014. Please put us in contact

with the appropriate personnel for planning the walkthrough during the onsite information

gathering trip.

The following documentation needs (items 49 - 52) will be dependent upon sample selections

and will be finalized during discussions with your staff. Please provide the requested

documents prior to the week of August 25, 2014. Whenever practical, please provide copies

electronically. Drawings should be provided as paper copies of sufficient size such that all

details are legible.

49. Pre-fire plans for the selected fire areas (areas to be selected by the team during the onsite

information gathering trip).

50. List of identified fire-induced circuit failure configurations that could prevent operation or

cause maloperation of equipment credited for safe shutdown in the event of a fire (for the

selected fire areas). 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.

51. 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.

52. Drawings showing the location details for detection and suppression systems in the selected

fire areas.