ML15170A394

Document Request for Appendix R Licensing Basis (Updated and Modified Request List of Documents from the Inspection Plan)

ML15170A394
Person / Time
Site:	Ginna
Issue date:	06/17/2015
From:	Richmond J Engineering Region 1 Branch 3
To:	Bradshaw C, Harding T Exelon Generation Co
Richmond J
References
Download: ML15170A394 (10)

Text

06/17/2015 Fire Protection Program Supporting Documentation The original document request, dated May 26, 2015, was based on the expectation that Ginnas fire protection program licensing basis would transition from Appendix R to NFPA-805 prior to the start of the NRC inspection. This revised document request is based on an Appendix R licensing basis by deleting documents specific to NFPA-805 (shown in strike-out) and adding additional documents specific to Appendix R (yellow highlighting). Please note that the majority of the document request list has remained unchanged.

In addition, for an Appendix R licensing basis facility, the NRC team will use Inspection Procedure 71111.05T (not 71111.05XT).

The schedule for the inspection remains unchanged, as follows:

• Information Gathering Visit: September 1 - 3, 2015

• On-Site Inspections: September 14 - 18, 2015 and September 28 - October 2, 2015 If you have any questions regarding this information request, please contact Mr. John Richmond as soon as possible, at (610) 337-5220 or via e-mail at john.richmond@nrc.gov.

Electronic format on compact disc (CD) or digital versatile disc (DVD) is the preferred media, except where specifically noted. If electronic media is made available via an internet based remote document management system, then the remote document access must allow inspectors to download, save, and print the documents in the NRC's regional office. Paper records (hard copy) are of course always acceptable. At the end of the inspection, the documents in the team's possession will not be retained.

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.

I. Information Requested Prior to the Information Gathering Visit Preferably no later than three weeks prior to the Information Gathering Visit, provide these documents to the inspection team leader in the Region 1 Office.

A. DESIGN AND LICENSING BASIS DOCUMENTS A.1 Nuclear Safety Capability Assessment Post-fire Safe Shutdown or Alternative Shutdown Analysis A.2 Fire Hazards Analysis A.3 Fire PRA Human Reliability Analysis Notebook Individual Plant Examination for External Events (IPEEE) (Fire Chapter ONLY) 1

A.4 NFPA 805 Fire Risk Evaluations Fire Probabilistic Risk Assessment (Fire PRA) Summary Document (if available)

A.5 NFPA 805 Plant Modifications Commitments (e.g., License Amendment Request (LAR) Table S-2)

A.6 NFPA 805 Implementation Items (e.g., LAR Table S-3)

C. CLASSIC FIRE PROTECTION C.1 Pre-fire plans for all fire areas (electronic copies)

Based on review of the above documents, the team leader should identify a preliminary list of fire areas being considered for inspection prior to the on-site information gathering visit. During the information gathering visit, or shortly thereafter, the fire areas selected for inspection will be determined.

II. Information Requested during the Information Gathering Visit On the first day of the Information Gathering Visit, provide these documents to the inspection team:

A. DESIGN AND LICENSING BASIS DOCUMENTS A.7 Fire Protection Program and/or Fire Protection Plan A.8 Design Basis Documents for the Fire Protection System and Nuclear Safety Capability Features Post-fire Safe Shutdown or Alternative Shutdown System A.9 LIST of nuclear safety capability or performance criteria design changes completed in the last three years (including their associated 10 CFR 50.59 and NFPA 805 plant change evaluations)

A.10 Three nuclear safety capability assessment or safe shutdown capability impact screening reviews for recent design changes, modifications, or temporary modifications (e.g., a Generic Letter 86-10 review that screened out, or an NFPA 805 plant change evaluation that screened out)

A.11 LIST of applicable NFPA codes and standards (i.e., codes of record)

A.12 NFPA Code Compliance Review Assessment Report No. 02-0950-1343 A.13 Facility Operating License A.14 Technical Specifications (electronic format only)

A.15 Technical Requirements Manual (electronic format only) 2

A.16 Updated Final Safety Analysis Report (only the Fire Protection Section)

A.17 Report or evaluation that compares the fire protection program to the NRC Branch Technical Position (BTP) 9.5-1 Appendix A A.18 COPY of exemption requests submitted but not yet approved for plant fire protection and post-fire safe shutdown or alternative shutdown features B. GENERAL PLANT DESIGN DOCUMENTS B.1 P&IDs and legend list for fire protection systems, including fire water supply, water suppression sprinklers & deluge, and CO2 & Halon systems (C-size paper drawings)

B.2 Yard layout drawings for underground fire protection buried piping. (C-size paper drawings)

B.3 Plant layout or hazard barrier drawings showing the fire area boundaries and combustible control zones (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 (e.g., typically 4kV diesel bus), (C-size paper drawings)

C. CLASSIC FIRE PROTECTION C.2 Impairment Log for fire protection features that are out of service C.3 COPY of fire protection program implementing procedures (e.g., administrative controls, surveillance testing, fire brigade)

C.4 LIST of calculations and engineering analyses, studies, or evaluations for the fire protection system, including the fire water system C.5 Hydraulic calculation or analysis for fire protection water system C.6 Design Analysis DA-ME-2001-031, Evaluation of Suppression System Flow and Pressure Requirements C.7 LIST of routine tests, surveillances, and preventive maintenance on fire pumps, including pump controllers and batteries C.8 Last two completed annual or 24 month fire pump pressure and flow tests C.9 Last two completed monthly or quarterly fire pump tests C.10 Last two completed fire loop flow tests and loop flushes 3

C.11 COPY of the complete test, surveillance, or maintenance procedure (current document control copy), including any associated data forms, for the completed surveillances requested above in C.8, C.9, and C.10 C.12 LIST of penetration seal work, re-work, or installation activities, in the last three years C.13 LIST of fire wrap work, re-work, or installation activities, in the last three years C.14 Last five hot work permits (at power)

C.15 Last five transient combustible permits (at power)

C.16 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 which was critiqued by a qualified individual independent of the licensee's staff;

• Last unannounced drill critique;

• Last back-shift drill critique;

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

• Summary of any unsatisfactory drill performance items for last three years C.17 For Fire Brigade Equipment, provide the following:

• Procedure for inventory and inspection; and

• Most recent inspection and inventory results C.18 LIST of fire brigade training lesson plans C.19 For credited radio communications, provide the analysis or evaluation which demonstrates the adequacy and availability of the radio communications for a post-fire safe shutdown scenario, for all fire areas (e.g., power supply availability, radio coverage tests, etc.)

C.20 For Emergency Lighting Units (ELU), provide the following:

• COPY of performance based emergency lighting assessments;

• LIST of Preventive Maintenance tasks and frequencies;

• Most recently performed monthly or quarterly functional test;

• Most recently performed battery discharge performance test;

• ELU battery loading analysis, for ELUs that supply more than two light heads;

• vendor manual(s) for on-site inspector use; and

• Compensatory measures taken when ELUs are out of service C.21 Fire protection system health reports for the two most recent quarters C.22 Fire protection program health report for the two most recent quarters C.23 Emergency lighting system health reports for the two most recent quarters 4

C.24 Three fire protection system impact screening reviews for recent design changes, modifications, or temporary modifications (e.g., a Generic Letter 86-10 review that screened out, or an NFPA 805 plant change evaluation that screened out)

C.25 LIST of fire protection system design changes completed in the last three years (including their associated 10 CFR 50.59 and Generic Letter 86-10 evaluations or NFPA 805 plant change evaluations)

C.26 LIST of fire protection system NFPA 805 engineering equivalency evaluations completed in the last three years C.27 Licensee evaluation of industry operating experience:

• NRC Information Notice (IN) 2013-06, Corrosion in Fire Protection Piping Due to Air and Water Interaction;

• NRC IN 2015-02, Antifreeze Agents in Fire Water Sprinkler Systems D. ELECTRICAL D.1 Identify whether the cables in the plant are predominantly Thermoset or Thermoplastic D.2 Maintenance procedures that verify breaker over-current trip settings to ensure coordination remains functional, for nuclear safety capability components post-fire safe shutdown or alternative shutdown equipment D.3 Electrical system health reports for the two most recent quarters D.4 Last surveillance demonstrating operability of those components operated from the primary control stations D.5 LIST of nuclear safety capability system and component post-fire safe shutdown or alternative shutdown design changes completed, in the last three years D.6 Administrative or configuration control procedures that govern fuse replacement (e.g.,

fuse control procedures)

D.7 Multiple Spurious Operation (MSO) Expert Panel Report D.8 LIST of corrective actions planned or taken as a result of the MSO report E. OPERATIONS E.1 LIST of calculations and engineering analyses, studies, or evaluations for the nuclear safety capability methodology safe shutdown or alternative shutdown methodology E.2 Thermal hydraulic calculation or analysis that determined the time requirements for time-critical operator actions 5

E.3 Operating procedures to achieve and maintain nuclear safety performance criteria from the control room, for a postulated fire in the selected fire areas Operating procedures for post-fire safe shutdown from the main control room (e.g.,

with a postulated fire in a 10 CFR 50 Appendix R III.G.2 fire area)

E.4 Operating procedures to achieve and maintain nuclear safety performance criteria from outside the control room, for a postulated fire in the control room, cable spreading room, or any area requiring recovery actions (other than recovery actions performed in the control room or primary control stations)

Operating procedures for post-fire safe shutdown from outside the control room (e.g.,

with a postulated fire in a 10 CFR 50 Appendix R III.G.3 fire area)

E.5 For post-fire operator manual actions (OMAs), provide the following:

• Manual Action Feasibility Study;

• Operator Time Critical Action Program;

• Time lines for time-critical recovery actions OMAs; and

• Time line validations E.6 Environmental and habitability evaluations for post-fire operator actions (temperature, smoke, humidity, SCBAs, etc.)

E.7 LIST of licensed operator Job Performance Measures (JPMs) for operator actions required to achieve and maintain nuclear safety performance criteria by post-fire safe shutdown or alternative shutdown E.8 LIST of non-licensed operator training associated with operator actions to achieve and maintain nuclear safety performance criteria which would be performed by a non-licensed operator (including JPMs, in-field training walkdowns, simulations, or initial qualification)

LIST of non-licensed operator training associated with post-fire safe shutdown or alternative shutdown manual actions which would be performed by a non-licensed operator (including JPMs, in-field training walkdowns, simulations, or initial qualification)

E.9 Lesson plans for post-fire nuclear safety capability post-fire safe shutdown or alternative shutdown training for licensed and non-licensed operators E.10 For safe shutdown equipment and tools, provide the following:

• Procedure for inventory and inspection; and

• Most recent inspection and inventory results E.11 LIST of procedures that implement Cold Shutdown Repairs E.12 For Cold Shutdown Repairs, provide the following:

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

• Most recent inspection and inventory results 6

E.13 Licensee evaluation of industry operating experience:

• NRC IN 2014-10, Potential Circuit Failure-Induced Secondary Fires or Equipment Damage E.14 Calculation or analysis that demonstrates pressurizer level will remain within the indicating range of the safe shutdown or alternative shutdown panel instruments, in accordance with the requirements of 10 CFR 50, Appendix R, III.L performance goals E.15 COPY of NRC approved exemption requests for operator manual actions for 10 CFR 50 Appendix R III.G.2 fire areas F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION PROGRAMS F.1 Corrective actions for fire-induced circuit failures (including but not limited to NRC IN 92-18), both single and multiple spurious actuations F.2 Corrective actions associated with operator actions to achieve and maintain post-fire nuclear safety performance criteria post-fire safe shutdown or alternative shutdown operator manual actions F.3 Self assessments, peer assessments, and audits of fire protection activities for the last three years F.4 Self assessments, peer assessments, and audits of the nuclear safety capability methodology and nuclear safety performance criteria post-fire safe shutdown or alternative shutdown capabilities for the last three years F.5 LIST of open and closed condition reports for the fire protection system for the last three years F.6 LIST of fire event analysis reports for the last three years F.7 LIST of open and closed condition reports for emergency lighting units for the last three years F.8 LIST of open and closed condition reports for nuclear safety capability issues for the last three years. This includes issues affecting the nuclear safety capability analysis, fire hazards analysis, NFPA 805 design basis, fire risk evaluations, plant change evaluations, post-fire operating procedures and/or training, time line evaluations for operator actions, and supporting engineering evaluations, analysis, or calculations LIST of open and closed condition reports for post-fire safe shutdown (SSD) or alternative shutdown (ASD) issues for the last three years. This includes issues affecting the SSD or ASD analysis, fire hazards analysis, SSD or ASD operating procedures and/or training, timeline evaluations for operator actions, and supporting engineering evaluations, analysis, or calculations F.9 LIST of procedures that control the configuration of the fire protection program, features, and post-fire nuclear safety capability methodology and system design 7

F.10 LIST of all Generic Letter 86-10 evaluations F.11 COPY of all Generic Letter 86-10 evaluations performed in the last three years III. Information Requested to be Available On-site, the First Day of the Inspection On the first day of the on-site inspection, provide these documents to the inspection team:

C. CLASSIC FIRE PROTECTION C.28 For the specific Penetration Seals selected during the Information Gathering Visit, provide:

• Qualification Records;

• Design specifications;

• Installation details; and

• Inspection record which verified proper installation C.29 For the specific Fire Wraps selected during the Information Gathering Visit, provide:

• Qualification Records;

• Design specifications;

• Installation details; and

• Inspection record which verified proper installation C.30 For the specific fire areas selected for inspection during the Information Gathering Visit, provide the Analysis of the effects of fire suppression activities on the ability to achieve the nuclear safety performance criteria, including which demonstrates:

• An automatic or manually actuated suppression system, due to a fire in a single location, will not indirectly cause damage to the success path;

• inadvertent actuation or rupture of a suppression system will not indirectly cause damage to the success path;

• demonstration of adequate drainage for areas protected by water suppression systems; and

• hydrostatic rating of any floor penetration seals installed within the fire areas that are credited with keeping water from leaking into fire areas below

• a fire water pipe break in the selected fire areas, wont effect safe shutdown (SSD) capability for equipment in the selected fire areas;

• a fire water pipe break in an adjacent fire area, wont effect SSD capability for equipment in the selected fire areas; and

• hydrostatic rating of any floor penetration seals installed within the fire areas that are credited with keeping water from leaking into the fire areas below 8

C.31 For the specific fire areas selected for inspection during the Information Gathering Visit, provide:

• Last two completed surveillance's of fire protection features (e.g., detection, suppression, damper inspections, damper tests, penetration inspections, barrier inspections, etc.)

C.32 COPY of the complete test, surveillance, or maintenance procedure (current document control copy), including any associated data forms, for the completed surveillances requested above in C.31 C.33 For the specific fire areas selected for inspection during the Information Gathering Visit, if any of the selected fire areas use CO2 or Halon, then provide:

• The initial discharge testing, calculation, or analysis that determined appropriate concentrations and soak or hold times can be achieved D. ELECTRICAL D.7 For the specific fire areas selected for inspection during the Information Gathering Visit, specifically identify:

• Any Thermoplastic Cable in the selected areas D.8 For the specific electrical circuits selected for inspection during the Information Gathering Visit, provide:

• Schematic or elementary diagrams for circuits to be reviewed (C-size paper drawings)

D.9 For the specific fire areas selected for inspection during the Information Gathering Visit, provide:

• Breaker and fuse coordination calculations or analysis for nuclear safety capability components post-fire safe shutdown or alternative shutdown equipment in the selected areas D.10 Cable routing information, as requested during the Information Gathering Visit D.11 LIST of identified fire-induced circuit failure configurations (only for selected fire areas) 9

Mitigating Strategies Supporting Documentation On the first day of the Information Gathering Visit, provide these documents:

G. 10 CFR 50.54(hh)(2) MITIGATING STRATEGIES DOCUMENTS G.1 LIST of all changes to regulatory commitments made to meet the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2)

G.2 LIST of procedures and guidelines that were revised or generated to implement the mitigating strategies. These could be extensive damage mitigation guidelines (EDMGs), severe accident management guidelines (SAMGs), emergency operating procedures (EOPs), abnormal operating procedures (AOPs), etc.

G.3 A matrix that shows the correlation between the mitigation strategies identified in Nuclear Energy Institute 06-12, Revision 2, "B.5.b Phase 2 & 3 Submittal Guideline,"

issued December 2006, and the site-specific procedures or guidelines that are used to implement each strategy G.4 LIST of engineering evaluations or calculations that were used to verify the engineering bases for the mitigating strategies G.5 Piping and instrumentation diagrams (P&ID) and legend list or simplified flow diagrams for systems relied upon in the mitigating strategies. These could be the type used for training (C-size paper drawings)

G.6 LIST of modification packages or summary descriptions of modifications with simplified drawings, for necessary facility changes to implement the mitigating strategies G.7 LIST of routine tests, surveillances, and preventive maintenance for equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies G.8 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies, provide the following:

• Procedures for inventory and inspection; and

• Most recent inspection and inventory results G.9 LIST of 10 CFR 50.54(hh)(2) strategies, if any, which have implementing details that differ from that documented in the submittals or the safety evaluation report G.10 Site general arrangement drawings that show the majority of buildings and areas referenced in 10 CFR 50.54(hh)(2) documents (C-size paper drawings)

G.11 Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2)

G.12 Copies of Memoranda of Understanding (MOU) (e.g., with local fire departments) required to implement any mitigating strategies 10 ML15170A394