ML100290033
| ML100290033 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/27/2010 |
| From: | Nease R NRC/RGN-II/DRS/EB2 |
| To: | Morris J Duke Energy Carolinas |
| References | |
| IR-10-006 | |
| Download: ML100290033 (7) | |
See also: IR 05000413/2010006
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
SAM NUNN ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW, SUITE 23T85
ATLANTA, GEORGIA 30303-8931
January 27, 2010
Mr. J. R. Morris
Site Vice President
Duke Energy Carolinas, LLC
Catawba Nuclear Station
4800 Concord Road
York, SC 29745-9635
SUBJECT: CATAWBA NUCLEAR STATION, UNITS 1 AND 2 - NOTIFICATION OF
CONDUCT OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
WHILE TRANSITION TO 10 CFR PART 50.48(c) IS IN PROGRESS (NRC
INSPECTION REPORT NOS. 05000413/2010006 AND 05000414/2010006)
Dear Mr. Morris:
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 Catawba Nuclear
Station, Units 1 and 2, in April and May 2010. 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 71111.05TTP, 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, dated December 24, 2009. 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 January 21, 2010, during a telephone conversation between Mr. Marc Sawicki (Catawba
Regulatory Compliance Engineer) 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: April 6-8, 2010
- Week 1 of onsite inspection: April 26-30, 2010
- Week 2 of onsite inspection: May 10-14, 2010
The purposes of the information gathering visit are to obtain information and documentation
needed to support the inspection, to become familiar with the Catawba Nuclear Station, Units 1
and 2 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 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 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.
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 Catawba 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 Catawba 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) 562-4673, or me at (404) 562-4530.
In accordance with 10 CFR 2.390 of the NRC's "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/
Rebecca L. Nease, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos.: 50-413, 50-414, 72-45
Enclosures: 1. Triennial Fire Protection Inspection Support Documentation
2. Mitigating Strategies Support Documentation
cc w/encl. (See page 3)
cc w/encl: Susan E. Jenkins
Randy D. Hart Director, Division of Waste Management
Regulatory Compliance Manager Bureau of Land and Waste Management
Duke Energy Carolinas, LLC S.C. Department of Health and
Electronic Mail Distribution Environmental Control
Electronic Mail Distribution
R. L. Gill, Jr.
Manager R. Mike Gandy
Nuclear Regulatory Issues & Industry Affairs Division of Radioactive Waste Mgmt.
Duke Energy Carolinas, LLC S.C. Department of Health and
Electronic Mail Distribution Environmental Control
Electronic Mail Distribution
Dhiaa M. Jamil
Group Executive and Chief Nuclear Officer W. Lee Cox, III
Duke Energy Carolinas, LLC Section Chief
Electronic Mail Distribution Radiation Protection Section
N.C. Department of Environmental
Kathryn B. Nolan Commerce & Natural Resources
Senior Counsel Electronic Mail Distribution
Duke Energy Corporation
526 South Church Street-EC07H Vanessa Quinn
Charlotte, NC 28202 Federal Emergency Management Agency
500 C Street, SW
Lisa F. Vaughn Room 840
Associate General Counsel Washington, DC 20472
Duke Energy Corporation
526 South Church Street-EC07H Steve Weatherman, Operations Analyst
Charlotte, NC 28202 North Carolina Electric Membership
Corporation
Senior Resident Inspector Electronic Mail Distribution
U.S. Nuclear Regulatory Commission
Catawba Nuclear Station County Manager of York County
U.S. NRC York County Courthouse
4830 Concord Road York, SC 29745
York, SC 29745
Piedmont Municipal Power Agency
David A. Repka Electronic Mail Distribution
Winston Strawn LLP
Electronic Mail Distribution Peggy Force
Assistant Attorney General
North Carolina MPA-1 State of North Carolina
Suite 600 P.O. Box 629
P.O. Box 29513 Raleigh, NC 27602
Raleigh, NC 27525-0513
_________________________ XG SUNSI REVIEW COMPLETE
OFFICE RII:DRS RII:DRS RII:DRP RII:DRS
NAME MThomas SWalker JBartley RNease
DATE 1/26/2010 1/26/2010 1/27/2010
E-MAIL COPY? YES NO YES N 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 on CD-ROM or DVD-
ROM 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 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 used to, and describing 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 1
2
14. Maintenance and surveillance testing procedures for alternative shutdown capability
(including Appendix R emergency lights and communication systems) 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 Ill.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 Ill.G.2.a), 20-foot separation along with detection and
suppression (Section IIl.G.2.b), 1-hour rated fire barriers with detection and suppression
(Section lII.G.2.c), or alternative shutdown capability (Section lll.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.
Enclosure 1
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.
Enclosure 2