ML103010271

Notification of Conduct of a Triennial Fire Protection Baseline Inspection (IR 05000327-11-006 and 05000328-11-006)

ML103010271
Person / Time
Site:	Sequoyah
Issue date:	10/28/2010
From:	Nease R NRC/RGN-II/DRS/EB2
To:	Krich R Tennessee Valley Authority
References
Download: ML103010271 (7)

See also: IR 05000327/2011006

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

October 28, 2010

Mr. R. M. Krich

Vice President, Nuclear Licensing

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT - NOTIFICATION OF CONDUCT OF A

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION

REPORT NO. 05000327/2011006 AND 05000328/2011006)

Dear Mr. Krich:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

Region II staff will conduct a triennial fire protection baseline inspection at the Sequoyah

Nuclear Plant in January and February 2011. The inspection team will be led by Mr. McKenzie

Thomas, NRC Senior Reactor Inspector, of the Region II Office. The team will be composed of

personnel from the NRC Region II Office. The inspection will be conducted in accordance with

Inspection Procedure 71111.05T, the NRCs triennial fire protection inspection procedure, dated

September 30, 2010. The inspection guidance will concentrate on the fire protection program

infrastructure and the adequacy of compensatory measures implemented for identified

departures from code requirements. Inspection of circuit analysis is included in the inspection

procedure.

On October 19, 2010, during a telephone conversation between Ms. Beth Wetzel (Sequoyah

Licensing and Industry Affairs Manager) of your staff, and Mr. Thomas, our respective staffs

confirmed arrangements for a three-day information gathering onsite visit and a two-week onsite

inspection. The schedule for the inspection is as follows:

Information gathering visit: January 4 - 6, 2011

Week 1 of onsite inspection: January 24 - 28, 2011

Week 2 of onsite inspection: February 7 - 11, 2011

The purposes of the information gathering visit are to obtain information and documentation

needed to support the inspection, to become familiar with the Sequoyah Nuclear Plant fire

protection program, fire protection features, post-fire safe shutdown capabilities, 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). The types of documents the

team will be interested in reviewing, and possibly obtaining, are listed in Enclosures 1 and 2.

Please contact Mr. Thomas at (404) 997-4673 prior to preparing copies of the materials listed in

the Enclosures. The inspection team will try to minimize your administrative burden by

specifically identifying those documents required for inspection preparation.

TVA

2

During the information gathering visit, the team will also discuss the following inspection support

administrative details: office space; specific documents to be made available to the team in their

office space; arrangements for unescorted site access (including radiation protection training,

security, safety and fitness for duty requirements); 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 inspection weeks you ensure that copies of analyses, evaluations or

documentation regarding the implementation and maintenance of the Sequoyah Nuclear Plant

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 which establish that your fire protection program satisfies 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, personnel should be available at the site during the inspection who are knowledgeable

regarding those plant systems required to achieve and maintain safe shutdown conditions from

inside and outside the control room (including the electrical aspects of the relevant post-fire safe

shutdown analyses), reactor plant fire protection systems and features, and the Sequoyah

Nuclear Plant 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, 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.

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 Mr. Thomas at (404) 997-4673, or me at (404) 997-4530.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosures 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).

Sincerely,

/RA/

Rebecca L. Nease, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos.: 50-327, 50-328,72-034

License Nos.: DPR-77, DPR-79

Enclosures:

1. Triennial Fire Protection Inspection Support Documentation

2. Mitigating Strategies Support Documentation

cc w/encls: (See page 3)

TVA

3

cc w/encls:

C.R. Church

Vice President

Sequoyah Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Soddy-Daisy, TN 37384-2000

K. Langdon

Plant Manager

Sequoyah Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Soddy Daisy, TN 37384-2000

B. A. Wetzel

Manager

Licensing and Industry Affairs

Sequoyah Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Soddy Daisy, TN 37384-2000

E. J. Vigluicci

Assistant General Counsel

Tennessee Valley Authority

6A West Tower

400 West Summit Hill Drive

Knoxville, TN 37902

County Mayor

Hamilton County

Hamilton County Courthouse

Chattanooga, TN 37402-2801

Division of Radiological Health

TN Dept. of Environment & Conservation

401 Church Street

Nashville, TN 37243-1532

Senior Resident Inspector

U.S. Nuclear Regulatory Commission

Sequoyah Nuclear Plant

2600 Igou Ferry Road

Soddy Daisy, TN 37379-3624

Ann Harris

341 Swing Loop

Rockwood, TN 37854

_________________________

G SUNSI REVIEW COMPLETE

OFFICE

RII:DRS

RII:DRP

RII:DRS

SIGNATURE

RA

RA

RA

NAME

MThomas

EGuthrie

RNease

DATE

10/28/2010

10/ 28 /2010

10/ 28 /2010

10/ /2010

10/ /2010

10/ /2010

10/

E-MAIL COPY?

YES

NO YES

NO YES

NO YES

YES

NO YES

NO

Enclosure 1

Triennial Fire Protection Inspection Support Documentation

Note: This is a broad list of the documents the NRC inspection team may be interested in

reviewing, and possibly obtaining, during the information gathering site visit. The current

version of these documents is expected unless specified otherwise. Electronic media is

preferred, if readily available. (The preferred file format on CD-ROM or DVDROM is .pdf).

The CD/DVD-ROM should be indexed, hyperlinked, readable, and searchable to facilitate ease

of use. Please provide 5 copies of each CD/DVD-ROM submitted). Information in lists should

contain enough information to be easily understood by someone who has knowledge of the

technology. The lead inspector will discuss specific information needs with the licensee staff

and may request additional documents or electronic information.

1. The current version of the Fire Protection Program and Fire Hazards Analysis.

2. Corrective Action closeouts as part of operator manual actions corrective actions.

3. List of identified fire-induced circuit failure configurations for select fire areas.

4. Corrective actions for fire-induced circuit failures, both single and multiple spurious

actuations for select fire areas.

5. Cable routing for components and equipment credited for safe shutdown for select fire

areas.

6. List of protected safe shutdown train equipment for select fire areas.

7. Current versions of the fire protection program implementing procedures (e.g.,

administrative controls, surveillance testing, fire brigade).

8. Fire brigade training program and pre-fire plans.

9. Post-fire safe shutdown systems and separation analysis.

10. Post-fire alternative shutdown analysis.

11. 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.

12. Plant layout and equipment drawings which identify the physical plant locations of hot

standby and cold shutdown equipment.

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

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

14. Plant layout drawings which identify the general location of the post-fire emergency

lighting.

2

Enclosure 1

15. Plant operating procedures which would be used and describe shutdown from inside

the control room with a postulated fire occurring in any plant area outside the control

room, procedures which would be used to implement alternative shutdown capability in

the event of a fire in either the control or cable spreading room.

16. Maintenance and surveillance testing procedures for alternative shutdown capability

and fire barriers, detectors, pumps and suppression systems.

17. Maintenance procedures which routinely verify fuse breaker coordination in accordance

with the post-fire safe shutdown coordination analysis.

18. A list of significant fire protection and post-fire safe shutdown related design change

packages and Generic Letter 86-10 evaluations.

19. The reactor plant's IPEEE, results of any post-IPEEE reviews, and listings of actions

taken/plant modifications conducted in response to IPEEE information.

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

22. If applicable, layout/arrangement drawings of potential reactor coolant/recirculation

pump lube oil system leakage points and associated lube oil collection systems.

23. 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.).

24. Procedures/instructions that control the configuration of the reactor plant's fire

protection program, features, and post-fire safe shutdown methodology and system

design.

25. A list of applicable codes and standards related to the design of plant fire protection

features and evaluations of code deviations.

26. Procedures/instructions that govern the implementation of plant modifications,

maintenance, and special operations, and their impact on fire protection.

27. 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 previous NRC fire protection triennial inspection.

28. Recent QA surveillances of fire protection activities.

29.

A listing of open and closed fire protection problem identification and resolution reports

(also known as condition reports/problem evaluation reports/NCRs) since the last

triennial inspection.

Enclosure 2

Mitigating Strategies Support Documentation

Note: This is a broad list of the documents the NRC inspection team may be interested

in reviewing, and possibly obtaining, during the information gathering visit. The current

version of these documents is expected unless specified otherwise. Electronic media is

preferred, if readily available. (The preferred file format on CD-ROM or DVDROM is

.pdf). The CD/DVD-ROM should be indexed, hyperlinked, readable, and searchable to

facilitate ease of use. Please provide 5 copies of each CD/DVD-ROM submitted). The

lead inspector will discuss specific information needs with the licensee staff and may

request additional documents or electronic information.

1. 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).

2. Copies of procedures/guidelines that 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.

3. 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.

4. Engineering evaluations/calculations that were used to verify engineering bases for the

mitigation strategies.

5. Piping and instrumentation diagram (P&ID) or simplified flow diagrams for systems relied

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

6. A modification package or simplified drawings/descriptions of modifications that were

made to plant systems to implement the mitigation strategies.

7. Copies of procedures used to inventory equipment (hoses, fittings, pumps, etc.) required

to be used to implement the mitigation strategies.

8. A list of B.5.b strategies, if any, which have implementing details that differ from that

documented in the submittals and the safety evaluation report.

9. A copy of site general arrangement drawing(s) that show the majority of buildings/areas

referenced in B.5.b documents.

10. Training records/training matrix/lesson plans related to B.5.b.

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

required to implement any mitigating strategies.