ML11298A314

Fire Protection Request for Information

ML11298A314
Person / Time
Site:	Duane Arnold
Issue date:	10/25/2011
From:	Robert Daley Engineering Branch 3
To:	Wells P NextEra Energy Duane Arnold
References
IR-11-007
Download: ML11298A314 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 October 25, 2011 Mr. Peter Wells Vice President NextEra Energy Duane Arnold, LLC 3277 DAEC Road Palo, IA 52324-9785

SUBJECT:

DUANE ARNOLD ENERGY CENTER - NOTIFICATION TO PERFORM A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION WHILE TRANSITION TO 10 CFR 50.48(C) IS IN PROGRESS; INSPECTION REPORT 05000331/2012007(DRS)

Dear Mr. Wells:

On January 9, 2012, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire protection baseline inspection at your Duane Arnold Energy Center. This inspection will be performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs baseline fire protection inspection procedure for plants in the process of implementing the National Fire Protection Association (NFPA) Standard 805 (10 CFR 50.48(c)). 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.

Based on the latest revision to IP 71111.05T dated April 19, 2011, (Effective Date August 1, 2011), changes were made to the IP which 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 on-site week of the inspection starting on January 11, 2012.

The schedule for the on-site inspection activity is as follows:

y Information Gathering Visit: January 9 - 11, 2012; y

B.5.b Requirements: January 11 - 13, 2012; and y

Fire Protection Inspection: January 23 - 27, 2012, and February 6 - 10, 2012.

P. Wells 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 Duane Arnold Energy Centers 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 provided to the lead inspector via mail or electronically no later than December 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 (January 9 - 11, 2012). 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 on-site inspection week (January 23, 2012).

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 on-site portions of the inspection.

The lead inspector for this inspection is Mr. George M. Hausman. We understand that our regulatory contact for this inspection is Ms. Laura B. Swenzinski of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at (630) 829-9743 or via e-mail at George.Hausman@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.

P. Wells 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/

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No.:

50-331 License No.: DPR-49

Enclosure:

Fire Protection Inspection Document Request cc w/encl:

Distribution via ListServ

FIRE PROTECTION INSPECTION DOCUMENT REQUEST 1

Enclosure Inspection Report: 05000331/2012007(DRS)

On-site Inspection Dates:

January 9 - 11, 2012 (Information Gathering Visit)

January 11 - 13, 2012 (B.5.b Requirements)

January 23 - 27, 2012 (Fire Protection Inspection)

February 6 - 10, 2012 (Fire Protection Inspection)

Inspection Procedures:

IP 71111.05T, Fire Protection Triennial IP 71152, "Problem Identification and Resolution" Inspectors:

George M. Hausman, Lead Inspector (630) 829-9743 George.Hausman@nrc.gov Mohammad Munir Robert A. Winter (630) 829-9797 (630) 829-9758 Mohammad.Munir@nrc.gov Robert.Winter@nrc.gov I.

Information Requested Prior To the Information Gathering Visit The following information is requested by December 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 Mr. George M. Hausman (e-mail address George.Hausman@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 for a senior reactor analysis). Please provide the B.5.b Mitigating Strategies information (Items B.1 through B.11) on a separate CD.

A.

Fire Protection Program Supporting Documentation

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 (TS), 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.

FIRE PROTECTION INSPECTION DOCUMENT REQUEST 2

Enclosure

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.

5. A copy of the current fire protection system Health Report, if available.

6. A copy of the current plant drawings referred to as Horse Notes, if available.

7. Status of NFPA 805 (10 CFR Part 50.48(c)) implementation.

B.

Mitigating Strategies Supporting Documentation

1. A list of all modifications to regulatory commitments made to meet the requirements of Section B.5.b of the Interim Compensatory Measure (ICM)

Order, EA-02-026, dated February 25, 2002, the subsequently imposed license conditions, and Title 10 of the Code of Federal Regulations (10 CFR)

Part 50.54(hh)(2).

2. Copies of procedures and/or 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 (NEI) 06-12 and the site-specific procedures or guidelines that are used to implement each strategy.

4. Engineering evaluations and calculations that were used to verify engineering bases for the mitigation strategies.

5. Piping and instrumentation diagrams or simplified flow diagrams for systems relied on in the mitigation strategies. These could be of the type used for training.

6. A list of modification packages or simplified drawings/descriptions of modifications made to plant systems to implement the mitigation strategies.

7. Copies of procedures used to inventory equipment (e.g., hoses, fittings, pumps, etc.) required to implement the mitigation strategies.

8. A list of B.5.b strategies, if any, that have implementing details that differ from those documented in the submittals and the safety evaluation.

FIRE PROTECTION INSPECTION DOCUMENT REQUEST 3

Enclosure

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.

12. 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.

II.

Information Requested During the Information Gathering Visit (January 9 - 11, 2012)

The following information is requested to be provided to the inspection team during the on site information gathering visit. Except for Item 1, it is requested that the following information be provided on four sets of CDs (searchable, if possible). In addition, two sets of hard copy drawings are requested for Item 4.a. through Item 4.f.

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 Part 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 Part 50.48(b)(1)(ii));

FIRE PROTECTION INSPECTION DOCUMENT REQUEST 4

Enclosure

e.

For post-1979 plants, all licensing correspondence associated with the comparison to Standard Review Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing purposes;

f.

For NFPA 805 transition plants provide: (1) all correspondence to and responses from the NRC; (2) a list of all areas showing assessment review status; (3) assessments for all areas that have been completed; and (4) a list of all identified non-conformances, and their respective compensatory measure(s); and

g.

The final safety analysis report (FSAR) sections applicable to fire protection, FHA, and SSA in effect at the time of original licensing.

3.

Fire Protection Program:

a.

A listing of changes made to the FPP (including associated adverse to SSA) 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 and 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.

Plant layout and equipment drawings which identify the physical plant locations of hot standby and cold shutdown equipment for selected fire zones/areas (to be determined during information gathering visit);

FIRE PROTECTION INSPECTION DOCUMENT REQUEST 5

Enclosure

c.

Plant layout drawings which identify the general location of the post-fire emergency lighting units;

d.

One-line schematic drawings of the electrical distribution system for 4160 Volts alternating current (Vac) down to 480Vac;

e.

One-line schematic drawings of the electrical distribution system for 250 Volts direct current (Vdc) and 125Vdc systems as applicable;

f.

Logic diagrams showing the components used to achieve and maintain hot standby and cold shutdown; and

g.

Safe shutdown cable routing database (requested electronically such as on compact disc, if available.

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.

Listing of current fire impairments, including durations.

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 on-site licensee personnel.

8.

On-site 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;

FIRE PROTECTION INSPECTION DOCUMENT REQUEST 6

Enclosure

b.

Informal discussion on the plants safe shutdown cable routing database and the plant-wide cable routing database, as applicable;

c.

Informal discussion on the status of NFPA-805 transition and associated risk insights identified; and

d.

A tour of alternative shutdown and risk significant fire areas.

III.

Information Requested to be Available on First Day of the Second On-site Inspection Week (January 23, 2012)

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; and 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.

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 Part 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);

FIRE PROTECTION INSPECTION DOCUMENT REQUEST 7

Enclosure

e.

Alternating current (ac) coordination calculations for 4160Vac down to 480Vac electrical systems;

f.

Vendor manuals and information for fire protection equipment (such as detection, suppression systems, fire pumps), applicable to selected fire zones/areas (to be determined during information gathering visit). It is acceptable to make vendor manuals available to the inspectors in lieu of providing a copy; and

g.

List of all fire protection or Appendix R calculations.

3. Assessment and Corrective Actions:

a.

The three most recent fire protection Quality Assurance (QA) audits and/or fire protection self-assessments; and

b.

Corrective action documents (e.g., condition reports, including status of corrective actions) generated as a result of 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.

P. Wells 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/

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No.:

50-331 License No.:

DPR-49

Enclosure:

Fire Protection Inspection Document Request cc w/encl:

Distribution via ListServ DISTRIBUTION:

Daniel Merzke RidsNrrDorlLpl3-1 Resource RidsNrrPMDuaneArnold Resource RidsNrrDirsIrib Resource Cynthia Pederson Jennifer Uhle Steven Orth Jared Heck Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource G:\\DRSIII\\DRS\\Work in Progress\\Ltr 10__11 Duane Arnold FP Request for Information GMH.docx 9 Publicly Available 9 Non-Publicly Available 9 Sensitive 9 Non-Sensitive To receive a copy of this document, indicate in the concurrence box C = Copy without attach/encl E = Copy with attach/encl N = No copy OFFICE RIII E

RIII RIII RIII RIII NAME GHausman:ls RDaley DATE 10/25/11 10/25/11 OFFICIAL RECORD COPY