ML11126A320
| ML11126A320 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/06/2011 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| Download: ML11126A320 (10) | |
See also: IR 05000237/2011008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
May 6, 2011
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville IL 60555
SUBJECT: DRESDEN NUCLEAR POWER STATION NOTIFICATION OF AN NRC
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
05000237/2011008(DRS); 05000249/2011008(DRS)
Dear Mr. Pacilio
On July 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire
protection baseline inspection at your Dresden Nuclear Power Station. This inspection will be
performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs baseline fire
protection inspection procedure.
Changes were made to the IP 71111.05T, which now requires the fire protection inspection to
review your actions to mitigate postulated events that could potentially cause loss of large areas
of power reactor facilities due to explosions or fires. This requirement was implemented by the
issuance of the Interim Compensatory Measures Order EA-02-026, Section B.5.b and the
subsequent requirements of 10 CFR 50.54(hh)(2), which are collectively referred to as B.5.b
requirements. During this inspection, the B.5.b requirements review will be performed during
the first onsite week of the inspection starting on July 27, 2011.
The schedule for the onsite inspection activity is as follows:
y Information Gathering Visit: July 25 - 27, 2011
y B.5.b Requirements: July 27 - 39, 2011, and
y Fire Protection Inspection: August 8 - 12, 2011, and August 29 - September 2, 2011.
The purpose of the information gathering visit is: (1) to obtain information and documentation
needed to support the inspection; (2) to become familiar with the Dresden Nuclear Power
Station fire protection programs, fire protection features, post-fire safe shutdown capabilities,
and plant layout; and (3) to arrange administrative details, such as office space, availability of
knowledgeable office personnel and to ensure unescorted site access privileges.
Experience has shown that the baseline fire protection inspections are extremely resource
intensive both for the NRC inspectors and the licensee staff. In order to minimize the inspection
impact on the site and to ensure a productive inspection for both organizations, we have
enclosed a request for documents needed for the inspection. These documents have been
divided into four groups. The first group lists information necessary to aid the inspection team in
choosing specific focus areas for the inspection. It is requested that this information be
M. Pacilio -2-
provided to the lead inspector via mail or electronically no later than July 5, 2011. The second
group also lists information and areas for discussion necessary to aid the inspection team in
choosing specific fire protection focus areas for the inspection and to ensure that the inspection
team is adequately prepared for the inspection. It is requested this information be available
during the information gathering visit (July 25, 2011). The third group of requested documents
consists of those items that the team will review, or need access to, during the inspection.
Please have this information available by the first day of the second onsite inspection week
(August 8, 2011). The fourth group lists the information necessary to aid the inspection team in
tracking issues identified as a result of the inspection. It is requested that this information be
provided to the lead inspector as the information is generated during the inspection. It is
important that all of these documents are up to date and complete in order to minimize the
number of additional documents requested during the preparation and/or the onsite portions of
the inspection.
The lead inspector for this inspection is Ronald A. Langstaff. We understand that our regulatory
contact for this inspection is Mr. G. Ice, NRC Coordinator, Dresden Regulatory Assurance, of
your organization. If there are any questions about the inspection or the material requested,
please contact the lead inspector at (630) 829-9747 or via e-mail at Ronald.Langstaff@nrc.gov.
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.
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 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).
Sincerely,
/RA/ by R. A. Langstaff For/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos.: 50-237; 50-249
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Distribution via ListServ
FIRE PROTECTION INSPECTION
DOCUMENT REQUESTS
Inspection Report: 05000237/2011008(DRS); 05000249/2011008(DRS)
Onsite Inspection Dates: July 25 - 27, 2011 (Information Gathering Visit)
July 27 - 29, 2011 (B.5.b Requirements)
August 8 - 12, 2011 (Fire Protection Inspection)
August 29 - September 2, 2011 (Fire Protection Inspection)
Inspection Procedures: IP71111.05T, Fire Protection (Triennial)
IP71152, "Identification and Resolution of Problems"
Inspectors: R. A. Langstaff
(630) 829-9747
Ronald.Langstaff@nrc.gov
Z. Falevits R. A. Winter
(630) 829-9717 (630) 829-9758
Zelig.Falevits@nrc.gov Robert.Winter@nrc.gov
Observer: J. S. Bowen
(301) 415-3471
Jeremy.Bowen@nrc.gov
I. Information Requested Prior To the Information Gathering Visit
The following information is requested by July 5, 2011. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All
information should be sent to R.A. Langstaff (e-mail address
Ronald.Langstaff@nrc.gov). Electronic media is preferred. The preferred file format is a
searchable pdf file on a compact disk (CD). The CD should be indexed and hyper-
linked to facilitate ease of use, if possible. Please provide four copies of each CD
submitted (one for each inspector and observer).
1. The most risk significant fire areas as determined by probabilistic risk analyses, if
available. Otherwise, the reactor plant's Individual Plant Examination for External
Events (IPEEE) for fire and results of any post-IPEEE reviews for fire.
2. A copy of the current version of the Fire Protection Program (FPP), Fire Hazards
Analysis (FHA), Safe Shutdown Analysis (SSA), Updated Safety Analysis Report
(USAR), Technical Specifications, license (including the fire protection license
condition), and Technical Requirements Manual (TRM) or equivalent for fire
protection structures, systems, and components.
3. A list of fire areas requiring alternative shutdown capability, (i.e., those areas for
which 10 CFR Part 50, Appendix R, Section III G requirements are satisfied under
Section III.G.3), or where both safe shutdown trains can be affected.
1 Enclosure
FIRE PROTECTION INSPECTION
DOCUMENT REQUESTS
4. Plant operating procedures which would be used and describe shutdown for a
postulated fire (for both areas requiring alternative shutdown and areas which do
not require alternative shutdown). Only those procedures with actions specific to
shutdown in the event of a fire need be included. In addition, please include those
procedures which operators would use for initial response to a fire, such as
annunciator or alarm response procedures, the procedure used for activating the
fire brigade, and the procedure which directs operators to the applicable safe
shutdown procedure.
II. Information Requested During the Information Gathering Visit (July 25, 2011)
The following information is requested to be provided to the inspection team during the
onsite information gathering visit. Except for Item 1, it is requested that the following
information be provided on four sets of CDs (searchable, if possible) with the B.5.b
Mitigating Strategies information (Items 8.a through 8.h) provided on one separate CDs.
In addition, one set of hard copy drawings are requested for Items 4.a. through 4.d.
1. One set of hard-copy documents for facility layout drawings which identify plant fire
area delineation; areas protected by automatic fire suppression and detection; and
locations of fire protection equipment.
2. Licensing Information:
a. All Nuclear Regulatory Commission (NRC) Safety Evaluation Reports (SERs)
applicable to fire protection (specifically including those SERs referenced by
the plant fire protection license condition) and all licensing correspondence
referenced by the SERs;
b. All licensing correspondence associated with the comparison to Standard
Review Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing
purposes;
c. Exemptions from 10 CFR 50.48 and 10 CFR Part 50, Appendix R, and
associated licensing correspondence;
d. For pre-1979 plants, all licensing correspondence associated with those
sections of 10 CFR Part 50, Appendix R, that are not applicable to the plant
under 10 CFR 50.48(b)(1). Specifically, the licensing correspondence
associated with those fire protection features proposed or implemented by the
licensee that have been accepted by the NRC staff as satisfying the provisions
of Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 reflected in
the NRC fire protection SERs issued before February 19, 1981, (10 CFR
50.48(b)(1)(i)); or those fire protection features, which were accepted by the
NRC staff in comprehensive fire protection SERs issued before Appendix A to
BTP APCSB 9.5-1 was published in August 1976 (10 CFR 50.48(b)(1)(ii)); and
e. The final safety analysis report (FSAR) sections applicable to fire protection,
FHA, and SSA in effect at the time of original licensing.
2 Enclosure
FIRE PROTECTION INSPECTION
DOCUMENT REQUESTS
3. Fire Protection Program:
a. A listing of changes made to the FPP since the last triennial fire protection
inspection;
b. For pre-1979 plants, a listing of the protection methodologies identified under
10 CFR Part 50, Appendix R, Section III.G used to achieve compliance for
selected fire zones/areas (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
as a strategy for each selected fire zone/area;
c. A list of Generic Letter 86-10 evaluations (i.e., a list of adverse to safe
shutdown evaluations);
d. A list of applicable codes and standards related to the design of plant fire
protection features. The list should include National Fire Protection
Association (NFPA) code versions committed to (i.e., the NFPA Codes of
Record); and
e. List of plant deviations from code commitments and associated evaluations.
4. Facility Information:
a. Piping and instrumentation (flow) diagrams showing the components used to
achieve and maintain hot standby and cold shutdown for fires outside the
control room, those components used for those areas requiring alternative
shutdown capability, and systems relied upon for B.5.b mitigation strategies.
These can be of the type that are used for training;
b. One-line schematic drawings of the electrical distribution system for 4160
Volts alternating current (Vac) down to 480Vac;
c. One-line schematic drawings of the electrical distribution system for 250 Volts
direct current (Vdc) and 125Vdc systems as applicable;
d. Logic diagrams showing the components used to achieve and maintain hot
standby and cold shutdown; and
e. Safe shutdown cable routing database (requested electronically such as on
compact disc, if available.
3 Enclosure
FIRE PROTECTION INSPECTION
DOCUMENT REQUESTS
5. Operations Response for Fire Protection:
a. Pre-fire plans for selected fire zones/areas (to be determined during
information gathering visit);
b. Plant operating procedures which specify the initial operations response to a
fire alarm or annunciator; and
c. Procedure for calling out the fire brigade and requesting off-site assistance.
6. Corrective Actions:
a. Listing of open and closed fire protection condition reports (i.e., problem
identification forms and their resolution reports) since the date of the last
triennial fire protection inspection; and
b. List of current fire impairments, including duration.
7. General Information:
a. A listing of abbreviations and/or designators for plant systems;
b. Organization charts of site personnel down to the level of fire protection staff
personnel; and
c. A phone list for onsite licensee personnel.
8. B.5.b Mitigating Strategies:
a. 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);
b. 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.;
c. 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;
d. A listing of engineering evaluations/calculations that were used to verify
engineering bases for the mitigation strategies;
e. Copies of procedures used to inventory equipment (hoses, fittings, pumps,
etc.) required to be used to implement the mitigation strategies;
4 Enclosure
FIRE PROTECTION INSPECTION
DOCUMENT REQUESTS
f. A list of B.5.b mitigating strategies, if any, which have implementing details
that differ from that documented in the submittals and the safety evaluation
report;
g. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire
departments) required to implement any mitigating strategies; and
h. A list of changes made to B.5.b mitigating strategies and associated
procedures since the previous NRC inspection of B.5.b mitigating strategies
(October 2008).
9. Onsite Discussions:
In addition, during the information gathering visit, it is requested that licensee staff
be available for the following:
a. Informal discussion on plant procedures operators would use in the event of
fire or explosion (including B.5.b mitigation strategies) and under what
conditions would the plant be shutdown using alternative shutdown
methodology;
b. Informal discussion on the plants safe shutdown cable routing database and
the plant-wide cable routing database, as applicable; and
c. A tour of alternative shutdown and risk significant fire areas.
III. Information Requested to be Available on First Day of the Second ONSITE
Inspection Week (August 8, 2011)
The following information is requested to be provided on the first day of inspection. It is
requested that this information be provided on four sets of CDs (searchable, if possible).
1. Program Procedures:
a. Procedures for:
i. Administrative controls (such as allowed out of service times and
compensatory measures) for fire protection systems and components
ii. Control of transient combustibles
iii. Control of hot work
b. List of maintenance and surveillance testing procedures for alternative
shutdown capability and fire barriers, detectors, pumps, and suppression
systems; and
c. List of maintenance procedures which routinely verify fuse breaker coordination
in accordance with the post-fire safe shutdown coordination analysis.
5 Enclosure
FIRE PROTECTION INSPECTION
DOCUMENT REQUESTS
2. Design and Equipment Information:
a. Coordination calculations and/or justifications that verify fuse/breaker
coordination for selected fire zones/areas (to be determined during
information gathering visit) that are fed off of the same electrical buses as
components in the protected safe shutdown train;
b. Copies of significant fire protection and post-fire safe shutdown related design
change package descriptions (including their associated 10 CFR 50.59
evaluations) and Generic Letter (GL) 86-10 (or adverse to safe shutdown)
evaluations;
c. Gaseous suppression system pre-operational testing, if applicable, for selected
fire zones/areas (to be determined during information gathering visit);
d. Hydraulic calculations and supporting test data which demonstrate operability
for water suppression systems, if applicable, for selected fire zones/areas (to
be determined during information gathering visit);
e. Alternating current (ac) coordination calculations for 4160Vac down to 480Vac
electrical systems; and
f. List of all fire protection or Appendix R calculations.
3. Assessment and Corrective Actions:
The three most recent fire protection Quality Assurance (QA) audits and/or fire
protection self-assessments.
4. Any updates to information previously provided.
IV. Information Requested to Be Provided Throughout the Inspection
1. Copies of any corrective action documents generated as a result of the inspection
teams questions or queries during this inspection.
2. Copies of the list of questions submitted by the inspection team members and the
status/resolution of the information requested (provided daily during the inspection to
each inspection team member).
If you have questions regarding the information requested, please contact the lead inspector.
6 Enclosure
M. Pacilio -2-
provided to the lead inspector via mail or electronically no later than July 5, 2011. The second group also
lists information and areas for discussion necessary to aid the inspection team in choosing specific fire
protection focus areas for the inspection and to ensure that the inspection team is adequately prepared
for the inspection. It is requested this information be available during the information gathering visit (July
25, 2011). The third group of requested documents consists of those items that the team will review, or
need access to, during the inspection. Please have this information available by the first day of the
second onsite inspection week (August 8, 2011). The fourth group lists the information necessary to aid
the inspection team in tracking issues identified as a result of the inspection. It is requested that this
information be provided to the lead inspector as the information is generated during the inspection. It is
important that all of these documents are up to date and complete in order to minimize the number of
additional documents requested during the preparation and/or the onsite portions of the inspection.
The lead inspector for this inspection is Ronald A. Langstaff. We understand that our regulatory contact
for this inspection is Mr. G. Ice, NRC Coordinator, and Dresden Regulatory Assurance, of your
organization. If there are any questions about the inspection or the material requested, please contact
the lead inspector at (630) 829-9747 or via e-mail at Ronald.Langstaff@nrc.gov.
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.
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 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).
Sincerely,
/RA by R. A. Langstaff For/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos.: 50-237; 50-249
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Distribution via ListServ
Distribution:
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OFFICE RIII RIII
NAME RLangstaff:ls RDaley
DATE 05/06/11 05/06/11
OFFICIAL RECORD COPY
Letter to Mr. Michael Pacilio from Mr. Robert C. Daley dated May 6, 2011.
SUBJECT: DRESDEN Nuclear Power Station NOTIFICATION OF AN NRC TRIENNIAL
FIRE PROTECTION BASELINE INSPECTION 05000237/2011008(DRS);
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