ML080650306

IR 05000269-08-007, IR 05000270-08-007, IR 05000287-08-007, Notification of Triennial Fire Protection Baseline Inspection

ML080650306
Person / Time
Site:	Oconee
Issue date:	02/29/2008
From:	Sandra Walker NRC/RGN-II/DRS/EB2
To:	Baxter D Duke Energy Carolinas, Duke Power Co
References
IR-08-007
Download: ML080650306 (7)

See also: IR 05000269/2008007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

SAM NUNN ATLANTA FEDERAL CENTER

61 FORSYTH STREET, SW, SUITE 23T85

ATLANTA, GEORGIA 30303-8931

February 29, 2008

Mr. David A. Baxter

Site Vice President

Duke Power Company, LLC d/b/a Duke Energy Carolinas, LLC

Oconee Nuclear Station

7800 Rochester Highway

Seneca, SC 29672

SUBJECT: NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

(NRC INSPECTION REPORT 05000269/2008007, 05000270/2008007 AND

05000287/2008007)

Dear Mr. Baxter:

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 Oconee Nuclear

Station, Units 1, 2 and 3 in July 2008. The inspection will be led by Mr. Reinaldo Rodriguez,

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 71111.05TTP, the NRCs baseline fire protection inspection procedure for plants in

the process of implementing 10 CFR 50.48(c) and National Fire Protection Association

Standard (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. Inspection of circuit analysis is not included in the inspection procedure;

however, electrical topics will be addressed by the team.

On February 21, 2008, during a telephone conversation, between Mr. Jim Weast, of your staff,

and Mr. Rodriguez, of the NRC Region II Office, 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:

• Information gathering visit: July 1 - 3, 2008

• Week 1 of onsite inspection: July 21 - 25, 2008

• Week 2 of onsite inspection: August 4 - 8, 2008

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

needed to support the inspection, and to become familiar with the Oconee Nuclear Station fire

protection program, fire protection features, post-fire shutdown capabilities and plant layout.

The types of documents the team will be interested in reviewing, and possibly obtaining, are

listed in the Enclosure.

Duke 2

Please contact Mr. Rodriguez prior to preparing copies of the materials listed in the Enclosure.

The inspection team will try to minimize your administrative burden by specifically identifying

those documents required for inspection preparation.

During the information gathering visit, the team will also discuss the following administrative

details - office space; specific documents to be made available to the team in its office space;

arrangements for reactor 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 Oconee Nuclear Station

fire protection program, including post-fire safe shutdown capability, be readily accessible to the

team for its review. Of specific interest are those documents which establish that your fire

protection program satisfies NRC regulatory requirements and conforms to applicable NRC and

industry fire protection guidance. 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 Oconee Nuclear Station fire protection program and its

implementation.

Your cooperation and support during this inspection will be appreciated. If you have questions

concerning this inspection, or the inspection teams information or logistical needs, please

contact Mr. Rodriguez at (404) 562-4498, or me at (404) 562-4639.

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).

Sincerely,

/RA/

Shakur Walker, Acting Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos.: 50-269, 50-270, 50-287

License Nos.: DPR-38, DPR-47, DRP-55

Enclosure: Triennial Fire Protection Inspection Support Documentation

cc w/encl: (See page 3)

Duke 3

cc w/encl:

B. G. Davenport

Compliance Manager (ONS)

Duke Power Company, LLC d/b/a Duke Energy Carolinas, LLC

Electronic Mail Distribution

Lisa F. Vaughn

Associate General Counsel

Duke Energy Corporation

526 South Church Street-EC07H

Charlotte, NC 28202

Kathryn B. Nolan

Senior Counsel

Duke Energy Corporation

526 South Church Street-EC07H

Charlotte, NC 28202

David A. Repka

Winston Strawn LLP

Electronic Mail Distribution

Beverly Hall

Chief

Radiation Protection Section

N.C. Department of Environmental Commerce & Natural Resources

Electronic Mail Distribution

Henry J. Porter

Assistant Director

Division of Radioactive Waste Mgmt.

S.C. Department of Health and Environmental Control

Electronic Mail Distribution

Lyle Graber

LIS

NUS Corporation

Electronic Mail Distribution

R. L. Gill, Jr.

Manager

Nuclear Regulatory Issues and Industry Affairs

Duke Power Company, LLC d/b/a Duke Energy Carolinas, LLC

526 South Church Street

Charlotte, NC 28201-0006

(cc w/encl contd - See page 4)

Duke 4

(cc w/encl contd)

Charles Brinkman

Director

Washington Operations

Westinghouse Electric Company

12300 Twinbrook Parkway, Suite 330

Rockville, MD 20852

Dhiaa M. Jamil

Group Executive and Chief Nuclear Officer

Duke Energy Carolinas, LLC

P.O. Box 1006 - EC03XM

526 South Church St.

Charlotte, NC 28201-1006

Distribution w/encl:

RIDSNRRDIRS

PUBLIC

L. Olshan, NRR

_________________________

OFFICE RII:DRS RII:DRS RII:DRP

SIGNATURE RA RA

NAME R. RODRIGUEZ S. WALKER J. MOORMAN

DATE 2/28/2008 2/29/2008

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES N

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 is searchable .pdf

files on CDROM. The CDROM should be indexed and hyperlinked to facilitate ease of

use. Please provide 5 copies of each CDROM 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.

1. The Fire Protection Program document and the Fire Hazards Analysis.

2. The Fire Protection Program implementing procedures (e.g., administrative controls,

surveillance testing, fire brigade).

3. The fire brigade training program document and the pre-fire plans for the selected fire

areas/zones (to be determined during information gathering visit).

4. The post-fire safe shutdown analysis, including system and separation analyses.

5. The alternative shutdown analysis.

6. Piping and instrumentation (flow) diagrams for the fire suppression systems.

7. Piping and instrumentation (flow) diagrams for the systems and components used to

achieve and maintain hot standby, and cold shutdown, for fires involving shutdown from

the control room.

8. Piping and instrumentation (flow) diagrams for the systems and components used to

achieve and maintain hot standby, and cold shutdown, for fires in areas requiring

alternative or dedicated shutdown capability.

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

standby and cold shutdown equipment.

10. Plant layout drawings which identify plant fire area and/or fire zone delineation, areas

protected by automatic fire suppression and detection, and the locations of fire

protection equipment for the selected fire areas/zones (to be determined during

information gathering visit).

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

lighting units.

12. Plant operating procedures that describe and are used to shutdown from inside the

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

13. Plant operating procedures used to implement the alternative shutdown capability from

outside the control room with a fire in either the control or cable spreading room (or any

other alternative shutdown area).

Enclosure

2

14. Maintenance and surveillance testing procedures for alternative shutdown capability

(including Appendix R emergency lights and communication systems) and fire barriers,

detectors, fire pumps and fire suppression systems.

15. Calculations and/or justifications that verify fuse/breaker coordination for the selected fire

areas/zones (to be determined during information gathering visit) that are fed off the

same electrical buses as components in the protected train. Also, a list of the

maintenance procedures used to routinely verify fuse/breaker coordination in

accordance with the post-fire safe shutdown coordination analysis.

16. A list of the significant fire protection and post-fire safe shutdown design change

descriptions (including their associated 10 CFR 50.59 evaluations) and Generic Letter

(GL) 86-10 evaluations.

17. A list of the protection methodologies (as identified in 10 CFR Part 50, Appendix R,

Section III.G) used to achieve regulatory compliance for the selected fire areas/zones (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-hour rated fire barriers with detection and suppression

(Section III.G.2.c), or alternative shutdown capability (Section III.G.3) is used for the

selected fire areas/zones.

18. Procedures or instructions that govern the implementation of plant modifications,

temporary modifications, maintenance, and special operations, and their impact on fire

protection.

19. Organization chart(s) of site personnel down to the level of the fire protection staff.

20. Procedures or instructions that control the configuration of the fire protection program,

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

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

features and evaluations of code deviations (i.e., a listing of the NFPA code editions

committed to (Code of Record)).

22. The three most recent fire protection QA audits and/or fire protection self-assessments.

23. A list of open and closed fire protection problem identification and resolution reports

[also known as action reports/condition reports/problem investigation

reports/NCRs/EARs] associated with fire protection or Appendix R safe shutdown for the

past three years.

24. A list of plant fire protection licensing basis documents (i.e., a list of the SERs and

change evaluations which form the licensing basis for the facilitys post-fire safe

shutdown configuration).

25. A list of fire protection or Appendix R calculations.

26. A list of fire impairments identified during the previous year.

27. A list of abbreviations/designators for plant systems.