ML16112A273
| ML16112A273 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/21/2016 |
| From: | Greg Werner NRC/RGN-IV/DRS/EB-2 |
| To: | Limpias O Nebraska Public Power District (NPPD) |
| References | |
| IR 2016008 | |
| Download: ML16112A273 (15) | |
See also: IR 05000298/2016008
Text
April 21, 2016
Mr. Oscar A. Limpias
Vice President-Nuclear and CNO
Nebraska Public Power District
Cooper Nuclear Station
72676 648A Avenue
P.O. Box 98
Brownville, NE 68321
SUBJECT: COOPER NUCLEAR STATION - NOTIFICATION OF NRC TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION (05000298/2016008) AND REQUEST
FOR INFORMATION
Dear Mr. Limpias:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
Region IV staff will conduct a triennial fire protection baseline inspection at the Cooper Nuclear
Station facility in August 2016. The inspection team will be comprised of four reactor inspectors
from the NRC Region IV office. The inspection will be conducted in accordance with Inspection
Procedure 71111.05XT, "Fire Protection - NFPA 805 (Triennial)," the NRCs baseline fire
protection inspection procedure.
The schedule for the inspection is as follows:
- Information gathering visit: July 12 -13, 2016
- Onsite inspection: August 8 - 12, 2016
August 22 - 26, 2016
The purpose of the information gathering visit is to obtain information and documentation
needed to support the inspection and to become familiar with the fire protection program, fire
protection features, post-fire safe shutdown capabilities, plant layout, and mitigating strategies
to address Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security
Compensatory Measures, dated February 25, 2002, and 10 CFR 50.54(hh)(2).
Initial lists of the documents the team will review during the conduct of the inspection are listed
in Attachments 1 and 2. The team leader will contact you with any additional specific document
requests prior to the information gathering visit.
O. Limpias -2-
During the information gathering visit, the team will also discuss the following inspection support
administrative details: (1) office space size and location; (2) specific documents requested to be
made available to the team in their office spaces; (3) arrangements for reactor site access
(including radiation protection training, security, safety, and fitness for duty requirements); and
(4) the availability of knowledgeable plant staff and licensing organization personnel to serve as
points of contact during the inspection.
We request that your staff transmit copies of the documents listed in the enclosure to the NRC
Region IV office for team use in preparation for the inspection. Please send this information so
that it will arrive in our office in Arlington, Texas, by the dates listed in the enclosure.
We request that during the onsite inspection weeks, you ensure that copies of analyses,
evaluations, or documentation regarding the implementation and maintenance of the 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 that establish that your fire protection program satisfies the NRC regulatory
requirements and conforms to applicable NRC and industry fire protection guidance. For
the 10 CFR 50.54(hh)(2) 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, please ensure the availability of appropriate personnel
knowledgeable of: (1) plant systems required to achieve and maintain safe shutdown conditions
from inside and outside the control room, (2) the electrical aspects of the post-fire safe
shutdown analyses, (3) reactor plant fire protection systems, (4) the fire protection program and
its implementation, and (5) the 10 CFR 50.54(hh)(2) program implementation should be
available to support the team at the site during the inspection.
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 NRCs Rules of Practice and Procedure, 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).
O. Limpias -3-
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 John Mateychick, the team lead inspector, in the Region IV office at (817) 200-1560, or
email, John.Mateychick@nrc.gov.
Sincerely,
/RA/
Gregory E. Werner, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-298
License No. DPR-46
Enclosures:
1. Triennial Fire Protection Inspection
Documentation Request
2. Mitigating Strategies Supporting
Documentation
cc w/enclosures:
Electronic Distribution for Cooper Nuclear Station
SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:
By: JMateychick Yes No Non-Publicly Available Sensitive NRC-002
OFFICE RI:EB2 C:EB2
NAME JMateychick GWerner
SIGNATURE /RA/ /RA/
DATE 4/18/16 4/21/16
Letter to Oscar A. Limpias from Gregory E. Werner, dated April 21, 2016
SUBJECT: COOPER NUCLEAR STATION - NOTIFICATION OF NRC TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION (05000298/2016008) AND REQUEST
FOR INFORMATION
Electronic distribution by RIV:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)
DRP Director (Troy.Pruett@nrc.gov)
DRP Deputy Director (Ryan.Lantz@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Patricia.Voss@nrc.gov)
Resident Inspector (Christopher.Henderson@nrc.gov)
Branch Chief, DRP/C (Greg.Warnick@nrc.gov)
Senior Project Engineer (Cale.Young@nrc.gov)
Project Engineer (Michael.Stafford@nrc.gov)
Project Engineer (Lindsay.Brandt@nrc.gov)
Administrative Assistant (Amy.Elam@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Project Manager (Alan.Wang@nrc.gov)
Team Leader, DRS/IPAT (Thomas.Hipschman@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Senior Congressional Affairs Officer (Jenny.Weil@nrc.gov)
Congressional Affairs Officer (Angel.Moreno@nrc.gov)
RIV/ETA: OEDO (Jeremy.Bowen@nrc.gov)
Fire Protection Program Documentation Request
The documents and information requested below should generally be made available to the
inspection team during the inspection. Electronic format is the preferred media, except where
specifically noted. If electronic media is made available via the internet-based inspection
management system (IMS), then the remote document access must allow inspectors to
download, save, and print the documents in the NRC's regional office.
If IMS is utilized, it is recommended that a separate folder be used corresponding to each
request item listed below and that multiple documents being uploaded into a folder be combined
into a ZIP file before uploading to IMS. Electronic media on compact disc or paper records
(hard copy) are acceptable.
To allow review before the on-site information gathering visit, the following documents should be
made available to the team in the regional office no later than July 1, 2016:
- Post-fire Nuclear Safety Capability, Systems, and Separation Analysis (request A.1)
- Fire Hazards Analysis and/or National Fire Protection Association (NFPA) 805 Design
Basis Document (request A.2)
- Fire Probabilistic Risk Assessment (PRA) Summary Document or full PRA Document
(request A.3)
- Fire Risk Evaluations (i.e., NFPA 805, Section 2.4.3) (request A.5)
- Plant Change Evaluations (i.e., NFPA 805, Section 2.4.4) (request A.6)
- Analysis that demonstrates nuclear safety performance criteria can be achieved and
maintained for those areas that require recovery actions (request A.7)
- List of completed modifications
- List of planned modifications
- Lists of open variations from deterministic requirements (VFDRs) and any compensatory
actions
Based on review of the above ten documents, 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.
-1- Enclosure 1
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. To allow review before
the on-site inspection weeks, the following documents should be made available to the team in
the regional office no later than July 18, 2016:
A. DESIGN AND LICENSING BASIS DOCUMENTS
A.1 Post-fire Nuclear Safety Capability, Systems, and Separation Analysis.
A.2 Fire Hazards Analysis and/or NFPA 805 Design Basis Document.
A.3 Fire PRA Summary Document or full PRA Document (if summary document not
available).
A.4 NFPA 805 Transition Report, developed in accordance with NEI 04-02.
A.5 Fire risk evaluations (i.e., NFPA 805, Section 2.4.3).
A.6 Plant change evaluations (i.e., NFPA 805, Section 2.4.4).
A.7 Analysis that demonstrates nuclear safety performance criteria can be achieved and
maintained for those areas that require recovery actions.
A.8 Fire Protection Program and/or Fire Protection Plan.
A.9 LIST of post-fire safe shutdown components (i.e., safe shutdown equipment list).
A.10 Fire Protection System Design Basis Document.
A.11 LIST of applicable NFPA codes and standards and issuance dates (i.e., codes of
record).
A.12 LIST of deviations from (a) NFPA codes of record, or (b) NFPA 805 fundamental fire
protection program and design elements (i.e., NFPA 805, Chapter 3).
A.13 NFPA Compliance Review Report.
A.14 COPY of licensee submittals and NRC safety evaluation reports that are specifically
listed in the facility operating license for the approved fire protection program.
A.15 COPY of NRC safety evaluation reports that form the licensing basis for:
- Post-fire Nuclear Safety Capability
-2-
A.16 LIST of nuclear safety capability design changes completed in the last three years
(including their associated 10 CFR 50.59 and NFPA 805 plant change evaluations).
A.17 Facility Operating License.
A.18 Technical Specifications (electronic format only).
A.19 Technical Requirements Manual (electronic format only).
A.20 Updated Final Safety Analysis Report (electronic format only).
B. GENERAL PLANT DESIGN DOCUMENTS
B.1 Piping and instrumentation diagrams and legend list for components used to achieve
and maintain nuclear safety performance criteria for (electronic format and C-size
paper drawings):
- Fires outside the main control room
- Fires in areas requiring recovery actions at other than primary control stations
B.2 Piping and instrumentation diagrams and legend list for fire protection systems,
including fire water supply, water suppression sprinklers, and deluge, and CO2, and
halon systems (electronic format and C-size paper drawings).
B.3 Yard layout drawings for underground fire protection buried piping (electronic format
and 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 (typically 4kV, EDG bus) (electronic format and C-size
paper drawings).
B.5 Single line diagrams for motor control centers (MCCs) that supply post-fire nuclear
safety component loads (only for selected fire areas) (electronic format and C-size
paper drawings).
B.6 Equipment location drawings that identify the physical plant locations of post-fire
nuclear safety capability equipment (electronic format and C-size paper drawings).
B.7 Plant layout drawings that identify (electronic format and C-size paper drawings):
- Plant fire area boundaries
- Combustible control zone drawings
- Areas protected by automatic fire suppression and detection
- Locations of fire protection equipment
-3-
C. CLASSIC FIRE PROTECTION
C.1 COPY of fire protection program implementing procedures (e.g., administrative
controls, surveillance testing, and fire brigade).
C.2 LIST of calculations and engineering analyses, studies, or evaluations for the fire
protection system, including the fire water system.
C.3 Hydraulic calculation or analysis for fire protection water system.
C.4 Last two completed surveillances of fire protection features in the selected fire areas
(detection, suppression, damper inspections, damper tests, penetration inspections,
barrier inspections, etc.).
C.5 LIST of routine tests, surveillances, and preventive maintenance on fire pumps,
including pump controllers and batteries.
C.6 Last two completed annual fire pump pressure and flow tests.
C.7 Last two completed monthly and/or quarterly fire pump tests.
C.8 Last two completed fire loop flow tests and loop flushes.
C.9 CO2 and Halon initial discharge testing or calculation that determined appropriate
concentrations and soak or hold times can be achieved (only for selected fire areas).
C.10 Last five hot work permits (at power).
C.11 Last five transient combustible permits (at power).
C.12 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 critique
- Last back-shift drill critique
- Dates, shifts, and locations of unannounced drills for last three years
- Summary of any unsatisfactory drill performance items for last three years
- Last unannounced drill critique by a qualified individual independent of the
licensee's staff
-4-
C.13 For fire brigade equipment provide the following:
- Procedure for inventory and inspection
- Most recent inspection and inventory results
C.14 Fire brigade qualifications, including self-contained breathing apparatus (SCBA) and
training lesson plans.
C.15 COPY of the mutual aid agreement for the first-due local fire department that is
currently in effect
C.16 COPY of the evaluation or analysis of the effects of fire suppression activities on the
ability to achieve the nuclear safety performance criteria (only for selected fire areas),
including:
- 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.
- Hydrostatic rating of any floor penetration seals installed within the fire areas that
are credited with keeping water from leaking into fire areas below.
C.17 Pre-fire plans for all fire areas.
C.18 For emergency lighting units provide the following:
- COPY of performance-based emergency light assessments
- LIST of preventive maintenance tasks, frequencies, and bases
- Most recently performed monthly or quarterly functional test
- Most recently performed battery discharge performance test or conductance
measurement test
- Emergency lighting unit battery loading analysis
- Vendor manual(s) for on-site inspector use
- Results of black-out testing (if performed)
- Maintenance rule program information related to the emergency lighting unit
-5-
- Compensatory measures taken when emergency lighting units are out of service
- Drawings showing emergency light locations and lamp orientation
C.19 Impairment log (at start of inspection), for fire protection features that are out of
service.
C.20 Three fire protection screening reviews for recent design changes, modifications, or
temporary modifications (i.e., an NFPA 805 plant change evaluation that screened
out).
C.21 LIST of penetration seal work, re-work, or installation activities, in the last three years.
C.22 LIST of fire wrap work, re-work, or installation activities, in the last three years.
C.23 Fire protection system health reports for the two most recent quarters.
C.24 Fire protection program health report for the two most recent quarters.
C.25 Emergency lighting system health reports for the two most recent quarters.
C.26 LIST of fire protection system design changes completed in the last three years
(including their associated 10 CFR 50.59 and NFPA 805 plant change evaluations).
C.27 LIST of fire protection system, NFPA 805 engineering equivalency evaluations
completed in the last three years.
C.28 Licensee evaluation of industry operating experience concerning fire protection
issues completed in the last three years.
D. ELECTRICAL
D.1 Identify whether the cables in the selected fire areas are predominantly thermoset or
thermoplastic. Specifically identify any thermoplastic cable in the selected fire areas.
D.2 Nuclear safety circuit coordination analysis for fuse and breaker coordination of
nuclear safety capability components (only for selected fire areas).
D.3 Administrative or configuration control procedures that govern fuse replacement
(e.g., fuse control procedures).
D.4 Maintenance procedures that verify breaker over-current trip settings to ensure
coordination remains functional, for post-fire nuclear safety capability components.
D.5 Electrical system health reports for the two most recent quarters.
D.6 Last surveillance demonstrating operability of those components operated from the
primary control stations.
-6-
D.7 Schematic or elementary diagrams for circuits to be reviewed (samples to be
identified by the inspector) (C-size paper drawings).
D.8 Cable routing for components and equipment credited for post-fire nuclear safety
capability systems and components (only for selected fire areas).
D.9 LIST of post-fire nuclear safety capability system and component design changes
completed, in the last three years.
D.10 LIST of identified fire induced circuit failure configurations (only for selected fire
areas).
E. OPERATIONS
E.1 LIST of calculations and engineering analyses, studies, or evaluations for the nuclear
safety capability methodology.
E.2 LIST of licensed operator job performance measures (JPMs) for operator actions
required to achieve and maintain post-fire nuclear safety performance criteria.
E.3 LIST of non-licensed operator training associated with non-licensed operator actions
to achieve and maintain post-fire nuclear safety performance criteria (including JPMs,
in-field training walkdowns, simulations, or initial qualification).
E.4 Lesson plans for post-fire nuclear safety capability training for licensed and non-
licensed operators.
E.5 For recovery actions provide the following:
- Manual Action Feasibility Study
- Operator Time Critical Action Program
- Time lines for time-critical recovery actions
- Time line validations
E.6 Thermal hydraulic calculation or analysis that determines the time requirements for
time-critical manual operator actions.
E.7 Operating procedures to achieve and maintain nuclear safety performance criteria
from the control room, with a postulated fire in the selected fire areas.
E.8 Operating procedures to achieve and maintain nuclear safety performance criteria
from outside the control room, with 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) and any associated
procedure basis documents.
-7-
E.9 For safe shutdown equipment and tools provide the following:
- Procedure for inventory and inspection
- Most recent inspection and inventory results
E.10 LIST of procedures that implement cold shutdown repairs.
E.11 For cold shutdown repairs provide the following:
- Procedure for inventory and inspection (i.e., needed tools, material, etc.)
- Most recent inspection and inventory results
E.12 For radio communications provide the following:
- Communications plan for firefighting and post-fire safe shutdown manual actions
- Repeater locations
- Cable routing for repeater power supply cables
- Radio coverage test results
- Radio dead spot locations in the plant
E.13 For telephone, plant pager or sound power phone systems, if relied credited for post-
fire safe shutdown, provide the following:
- Communications Plan for firefighting and post-fire safe shutdown manual actions
- Locations of phone, pager units, sound-powered phone jacks and
sound-powered phone headsets
- Cable routing including power supply cables
E.14 Environmental and habitability evaluations for post-fire operator actions (temperature,
smoke, humidity, SCBAs, etc.).
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 (only for selected fire areas).
F.2 Corrective actions associated with operator actions to achieve and maintain post-fire
nuclear safety performance criteria.
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 post-fire nuclear safety capability
methodology for the last three years.
-8-
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 post-fire 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, 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.
-9-
MITIGATING STRATEGIES SUPPORTING DOCUMENTATION
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
Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security
Compensatory Measures, dated February 25, 2002, and 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 and legend list or simplified flow diagrams for
systems relied upon in the mitigating strategies. These could be the type used for
training (electronic format and 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
- 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 (electronic format and 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.
-1- Enclosure 2