ML12348A393
| ML12348A393 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/13/2012 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Lieb R FirstEnergy Nuclear Operating Co |
| Ronald Langstaff | |
| References | |
| IR-13-008 | |
| Download: ML12348A393 (10) | |
See also: IR 05000346/2013008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
December 13, 2012
Mr. Raymond Lieb
Site Vice President
FirstEnergy Nuclear Operating Company
Davis-Besse Nuclear Power Station
5501 North State Route 2, Mail Stop A-DB-3080
Oak Harbor, OH 43449-9760
SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION - NOTIFICATION OF NRC
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REQUEST FOR
INFORMATION 05000346/2013-008(DRS)
Dear Mr. Lieb:
On February 25, 2013, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire
protection baseline inspection at your Davis-Besse Nuclear Power Station. This inspection will
be performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs baseline fire
protection inspection procedure. 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. The inspectors will not routinely inspect for or evaluate circuit related issues.
Based on a recent change to IP 71111.05T, changes were made to the IP 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
February 27, 2013.
The schedule for the onsite inspection activity is as follows:
- Information Gathering Visit: February 25 - February 27, 2013;
- B.5.b Requirements: February 27 - March 1, 2013; and
- Fire Protection Inspection: March 11 - March 15, 2013 and March 25 - March 29, 2013.
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 Davis-Besse 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
R. Lieb -2-
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 (February 11, 2013). 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 (February 25, 2013). 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 (March 11, 2013). 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 Mr. R. Langstaff. We understand that our regulatory
contact for this inspection is Mr. G. Wolf 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/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-346
License Nos. NPF-3
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Distribution via ListServ'
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Inspection Report: 05000346/2013008(DRS)
Onsite Inspection Dates: February 25 - 27, 2013 (Information Gathering Visit)
February 27 - March 1, 2013 (B.5.b Requirements)
March 11 - 15, 2013 (Fire Protection Inspection)
March 25 - 29, 2013 (Fire Protection Inspection)
Inspection Procedures: Inspection Procedure 71111.05T, Fire Protection (Triennial)
Inspection Procedure 71152, "Identification and Resolution of
Problems"
Inspectors: Ronald Langstaff
(630) 829-9747
Ronald.Langstaff@nrc.gov
Alan Dahbur Robert Winter
(630) 829-9810 (630) 829-9758
Alan.Dahbur@nrc.gov Robert.Winter@nrc.gov
I. Information Requested Prior To the Information Gathering Visit
The following information is requested by February 11, 2013. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All
information should be sent to Mr. R. 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 three copies of each CD
submitted (one for each inspector).
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.
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.
1 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
II. Information Requested During the Information Gathering Visit (02/25/2013)
The following information is requested to be provided to the inspection team during the
onsite information gathering visit. Except for Item 8, it is requested that the following
information be provided on three sets of CDs (searchable, if possible) with the B.5.b
Mitigating Strategies information (Items 8.a through 8.h) provided on one separate CD. 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.
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;
2 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
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.
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
3 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
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;
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 (05/14/2010).
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;
c. Informal discussion on the status of NFPA-805 transition and associated risk
insights identified;
d. A tour of alternative shutdown and risk significant fire areas; and
e. A discussion of scheduling of fire drills which may occur during the inspection so
that the inspectors may be able to observe a fire drill.
4 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
III. Information Requested to be Available on First Day of the Second Onsite Inspection
Week (March 11, 2013)
The following information is requested to be provided on the first day of inspection. It is
requested that this information be provided on three 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.
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.
5 Enclosure
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
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
R. Lieb -2-
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 (February 11, 2013). 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 (February 25, 2013).
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 (March
11, 2013). 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 Mr. R. Langstaff. We understand that our regulatory contact for this
inspection is Mr. G. Wolf 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/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-346
License Nos. NPF-3
Enclosure: Fire Protection Inspection Document Request
cc w/encl: Distribution via ListServ'
DOCUMENT NAME: Ltr 121312 Davis-Besse FP RFI RAL.docx
Publicly Available Non-Publicly Available Sensitive 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 RIII
NAME RALangstaff:ls RCDaley
DATE 12/13/12 12/13/12
OFFICIAL RECORD COPY
Letter to Mr. Raymond Lieb from Mr. Robert C. Daley date December 13, 2012.
SUBJECT: DAVIS BESSE NUCLEAR POWER STATION - NOTIFICATION OF NRC
TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REQUEST FOR
INFORMATION 05000346/2013-008(DRS)
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