ML19295C482

Notification of an NRC Fire Protection Baseline Inspection (NRC Inspection Report 05000498/2020011 and 05000499/2020011) and Request for Information

ML19295C482
Person / Time
Site:	South Texas
Issue date:	10/21/2019
From:	Nick Taylor Division of Reactor Safety IV
To:	Gerry Powell South Texas
Taylor N
References
IR 2020011
Download: ML19295C482 (11)

See also: IR 05000498/2020011

Text

October 21, 2019

Mr. G. T. Powell

President and CEO

STP Nuclear Operating Company

P.O. Box 289

Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - NOTIFICATION OF AN

NRC FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION

REPORT 05000498/2020011 AND 05000499/2020011) AND REQUEST FOR

INFORMATION

Dear Mr. Powell:

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 South Texas

Project, Units 1 and 2 in January and February 2020. The inspection team will be comprised of

three reactor inspectors from the NRC Region IV office. The inspection will be conducted in

accordance with Inspection Procedure 71111, Attachment 21N.05, Fire Protection Team

Inspection, the NRCs baseline fire protection inspection procedure.

The schedule for the inspection is as follows:

Information gathering visit: January 7 and 8, 2020

Onsite inspection: January 27 - 31, 2020, and February 10 - 14, 2020

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, and plant layout.

The team lead 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.

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

support administrative details: (1) office space size and location; (2) specific documents

requested to be made available to the team in their office spaces; (3) arrangements for reactor

G. Powell

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site access (including radiation protection training, security, safety, and fitness-for-duty

requirements); and (4) the availability of knowledgeable plant staff 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 stations

fire protection program, including the success path necessary to achieve and maintain the

nuclear safety performance criteria, 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 (i.e., fire protection compliance

assessment documents). Also, personnel should be available at the site during the inspection

who are knowledgeable regarding those plant systems required to achieve and maintain safe

and stable plant conditions, including the electrical aspects of the nuclear safety capability

assessment, reactor plant fire protection systems and features, and the stations fire protection

program and its implementation.

This letter does not contain new or amended information collections that are subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and

Budget (OMB) approved these information collections (approval number 3150-0011). The NRC

may not conduct nor 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 OMB control number.

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

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 John Mateychick, the team lead inspector, in the Region IV office at (817) 200-1560 or

John.Mateychick@nrc.gov.

Sincerely,

/RA/

Nicholas H. Taylor, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-498 and 50-499

License Nos. NPF-76 and NPF-80

Enclosure:

Triennial Fire Protection Inspection Document Request

cc w/enclosure: Electronic Distribution for South Texas Project

ML19295C482

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: JMM Yes No

Publicly Available Sensitive NRC-002

OFFICE

SRI:EB2

C:EB2

NAME

JMateychick

NTaylor

SIGNATURE

/RA per NHT/

/RA/

DATE

10/21/2019

10/21/2019

Enclosure

Triennial Fire Protection Inspection Document Request

The documents and information requested below should generally be made available to the

inspection team prior to the inspection. Electronic format is the preferred format, except where

specifically noted. If electronic files are made available via a secure document management

service, then the remote document access must allow inspectors to download, save, and print

the documents in the NRCs regional office.

If a secure document management service is utilized, it is recommended that a separate folder

be used corresponding to each item listed below. Multiple documents within each folder be

individually entered and also combined into a ZIP file which is uploading in the same folder.

Documents should be identified by both document number and noun name. Electronic media

on compact disc or paper records (hard copy) are also acceptable.

To allow review before the onsite information gathering visit, the documents requested in

items A.1 thru A.8 should be made available to the team in the regional office no later than

December 27, 2019.

Based on a review of the above eight items, team lead should identify a preliminary list of fire

areas being considered for inspection prior to the onsite information gathering visit. During the

information gathering visit, or shortly thereafter, the fire areas selected for inspection will be

determined.

This document request is based on typical documents that a generic plant might have. As such,

this generic document request is not meant to imply that any specific plant is required to have all

of the listed documents. It is recognized that some documents listed below may not be

available for your plant. In addition, the document titles listed below are based on typical

industry document names; your plant-specific document titles may vary.

To allow review before the onsite inspection weeks, the documents listed in the attachment

should be made available to the team in the regional office no later than January 10, 2020.

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A.

DESIGN AND LICENSING BASIS DOCUMENTS

A.1

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

A.2

Post-fire safe shutdown analysis and the supporting calculations that

demonstrate acceptable plant response.

A.3

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.

A.4

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.).

A.5

List of post-fire safe shutdown systems and components (i.e., safe shutdown

equipment list).

A.6

List of fire areas with automatic fire suppression systems.

A.7

A list, with descriptions, of design change packages performed since the last fire

protection team inspection associated with fire protection or post-fire safe

shutdown systems.

A.8

A list, with descriptions, of any fire protection program changes and evaluations

(not limited to Generic Letter 86-10 evaluations) performed since the last fire

protection team inspection.

A.9

Fire Protection System(s) Design Basis Document.

A.10

List of applicable NFPA codes and standards and issuance dates (i.e., codes of

record).

A.11

A list or document identifying any deviations from the NFPA codes of record.

A.12

Facility Operating License.

A.13

Technical Specifications (electronic format only).

A.14

Updated Final Safety Analysis Report (electronic format only).

B.

GENERAL PLANT DESIGN DOCUMENTS

B.1

Piping and instrumentation diagrams (P&IDs) and legend list for components

used to achieve and maintain post-fire safe shutdown. 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.

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B.2

Piping and instrumentation diagrams and legend list for fire protection systems,

including the fire water supply; water suppression sprinklers; and deluge, CO2,

and Halon systems (electronic format and C-size paper drawings).

B.3

Yard layout drawings for underground fire protection buried piping (electronic

format and C-size paper drawings).

B.4

AC and DC electrical system single line diagrams, from off-site power down to

the highest safety-related bus level (typically 4kV, EDG bus) (electronic format

and C-size paper drawings).

B.5

Single line diagrams for motor control centers (MCCs) that supply post-fire

nuclear safety component loads (only for selected fire areas) (electronic format

and C-size paper drawings).

B.6

Equipment location drawings which identify the physical plant locations of post-

fire safe shutdown equipment (electronic format and C-size paper drawings).

B.7

Plant layout drawings which identify: (electronic format and C-size paper

drawings)

Plant fire area boundaries

Combustible control zone drawings

Areas protected by automatic fire suppression and detection

Locations of fire protection equipment

C.

CLASSIC FIRE PROTECTION

C.1

Copy of the fire protection program implementing procedures (e.g., administrative

controls, surveillance testing, and fire brigade).

C.2

List of calculations and engineering analyses, studies, or evaluations for the fire

protection system, including the fire water system.

C.3

Last two completed surveillances of fire protection features in the selected fire

areas (detection, suppression, damper inspections, damper tests, penetration

inspections, barrier inspections, etc.).

C.4

List of routine tests, surveillances, and preventive maintenance on fire pumps,

including pump controllers and batteries.

C.5

Last two completed annual fire pump pressure and flow tests.

C.6

Last two completed monthly and/or quarterly fire pump tests.

C.7

Last two completed fire loop flow tests and loop flushes.

C.8

Last five hot work permits (at power).

C.9

Last five transient combustible permits (at power).

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C.10

For Fire Brigade Drills, provide the following:

Last five fire brigade drill critiques

Last drill critique for a drill with off-site fire department support

Last unannounced drill critique

Last back-shift drill critique

Dates, shifts, and locations of unannounced drills for last three years

Summary of any unsatisfactory drill performance items for last three years

Last unannounced drill critique by a qualified individual independent of

the licensees staff

C.11

For fire brigade equipment provide the following:

Procedure for inventory and inspection

Most recent inspection and inventory results

C.12

Fire Brigade Qualifications, including self-contained breathing apparatus, (SCBA)

and training lesson plans.

C.13

Copy of the mutual aid agreement for the first-due local fire department that is

currently in effect.

C.14

Copy of the evaluation or analysis of the effects of fire suppression activities on

the ability to achieve the nuclear safety performance criteria (only for selected fire

areas) demonstrating:

The automatic or manually actuation of a suppression system, due to a

fire in a single location, will not indirectly cause damage to the success

path

The inadvertent actuation or rupture of a suppression system will not

indirectly cause damage to the success path

Adequate drainage for areas protected by water suppression systems

The hydrostatic rating of any floor penetration seals installed within the

fire areas that are credited with keeping water from leaking into fire areas

below

C.15

Pre-fire plans for all fire areas.

C.16

Impairment Log (at start of inspection) for fire protection features that are out of

service.

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C.17

List of penetration seal work, re-work, or installation activities, in the last

three years.

C.18

List of fire wrap work, re-work, or installation activities, in the last three years.

C.19

Fire protection system health reports for the two most recent quarters.

C.20

Fire protection program health reports for the two most recent quarters.

C.21

Emergency lighting system health reports for the two most recent quarters.

C.22

List of fire protection system design changes completed in the last three years.

C.23

List of fire protection system engineering equivalency evaluations completed in

the last three years.

C.24

Licensee evaluations of industry operating experience concerning fire protection

issues completed in the last three years.

C.25

List of fire event analysis reports for the last three years.

C.26

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, procedures, or

similar documents.

C.27

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

personnel.

C.28

A contact list of key site personnel who will be supporting this inspection, giving

the office location and phone number onsite.

C.29

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

possible, during the week of February 10, 2020. Please put us in contact with

the appropriate personnel for planning fire brigade drills during the onsite

information gathering trip.

D.

ELECTRICAL

D.1

Administrative or configuration control procedures that govern fuse replacement

(e.g., fuse control procedures).

D.2

Maintenance procedures that verify breaker over-current trip settings to ensure

coordination remains functional for post-fire nuclear safety capability

components.

D.3

Electrical system health reports for the two most recent quarters.

D.4

Surveillance procedures and last surveillance demonstrating operability of

components required for alternative shutdown.

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D.5

Schematic or elementary diagrams for circuits to be reviewed (samples to be

identified by the inspector) (C-size paper drawings).

D.6

Cable routing for components and equipment credited for post-fire safe shutdown

systems and components (samples to be identified by the inspector).

D.7

For emergency lighting units, provide the following:

List of Preventive Maintenance tasks, frequencies, and bases

Most recently performed monthly or quarterly functional test

Most recently performed battery discharge performance test or

conductance measurement test

Emergency lighting unit battery loading analysis

Vendor manual(s) for onsite inspector use

Results of black-out testing (if performed)

Maintenance Rule program information related to the emergency lighting

system

Compensatory measures taken when emergency lighting units are out of

service

Drawings showing emergency light locations and lamp orientation

E.

OPERATIONS

E.1

The team would like to perform a walkthrough of a sample of post-fire safe

shutdown procedures with qualified operators in the plant during the week of

January 27, 2020. Please put us in contact with the appropriate personnel for

planning the walkthroughs during the onsite information gathering trip.

E.2

List of licensed operator Job Performance Measures (JPMs) for operator actions

required to achieve and maintain post-fire safe shutdown.

E.3

List of non-licensed operator training associated with non-licensed operator

actions to achieve and maintain post-fire nuclear safe shutdown (including JPMs,

in-field training walkdowns, simulations, or initial qualification).

E.4

Lesson plans for post-fire safe shutdown training for licensed and non-licensed

operators.

E.5

For local manual operator actions, provide the following:

Manual Action Feasibility Study

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Operator Time Critical Action Program

Time lines for time-critical manual actions

Time line validations

E.6

Thermal hydraulic calculation or analysis that determines the time requirements

for time-critical manual operator actions.

E.7

Operating procedures to achieve and maintain post-fire safe shutdown with a

postulated fire in the selected fire areas.

E.8

For safe shutdown equipment and tools, provide the following:

Procedure for inventory and inspection

Most recent inspection and inventory results

E.9

List of procedures that implement cold shutdown repairs.

E.10

For cold shutdown repairs, provide the following:

Procedure for inventory and inspection (i.e., needed tools, material, etc.)

Most recent inspection and inventory results

E.11

For radio communications, provide the following:

Communications Plan for firefighting and post-fire safe shutdown manual

actions

Repeater locations

Cable routing for repeater power supply cables

Radio coverage test results

Radio Dead Spot locations in the plant

E.12

For telephone, plant pager or sound powered phone systems, if relied upon to

achieve and maintain post-fire safe shutdown, provide the following:

Communications Plan for firefighting and post-fire safe shutdown manual

actions

Locations of phone, pager units, sound powered phone jacks, and sound

powered phone headsets

Cable routing including power supply cables

E.13

Environmental and habitability evaluations for post-fire safe shutdown operator

actions (temperature, smoke, humidity, SCBAs, etc.).

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F.

ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION

PROGRAMS

F.1

Copies of procedures that control the configuration of the fire protection program,

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

copies of procedures that govern the implementation of plant modifications,

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

F.2

List of open and closed condition reports for the fire protection systems for the

last three years.

F.3

List of open and closed condition reports associated with the post-fire safe

shutdown analysis for the last three years.

F.4

List of open and closed condition reports associated with operator actions to

achieve and maintain post-fire safe shutdown for the last three years.

F.5

List of open and closed condition reports associated with the fire protection

program including plant change evaluations, post-fire operating procedures

and/or training, timeline evaluations for operator actions, and supporting

engineering evaluations, analysis, or calculations for the last three years.

F.6

List of open and closed condition reports for emergency lighting units for the last

three years.

F.7

Self-assessments, peer assessments, and audits of fire protection activities for

the last three years.

F.8

Self-assessments, peer assessments, and audits of post-fire nuclear safety

capability methodology for the last three years.

G.

AGING MANAGEMENT PROGRAM

G.1

Copies of the aging management programs applicable to fire protection including

but not limited to the following:

Fire Protection

Fire Water System

Aboveground Metallic Tanks

Buried and Underground Piping and Tanks

G.2

Copies of procedures, work orders, preventive maintenance tasks, or other

documents which implement the commitments made as part of the license

extension related to fire protection.

G.3

List of aging management activities related to fire protection performed to date.