ML16356A042
| ML16356A042 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/20/2016 |
| From: | Dariusz Szwarc NRC/RGN-III |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2017008 | |
| Download: ML16356A042 (9) | |
See also: IR 05000461/2017008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, IL 60532-4352
December 20, 2016
Mr. Bryan C. Hanson
Senior VP, Exelon Generation Company, LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: CLINTON POWER STATION - NOTIFICATION OF NRC TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION AND REQUEST FOR INFORMATION
Dear Mr. Hanson:
On March 20, 2017, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial Fire
Protection Baseline Inspection at your Clinton Power Station. This inspection will be performed
in accordance with Inspection Procedure 71111.05T, the NRCs Baseline Fire Protection
Inspection Procedure.
Changes were made to the Inspection Procedure 71111.05T which now requires the Fire
Protection Inspection to review your actions to mitigate postulated events that could potentially
cause loss of large areas of power reactor facilities due to explosions or fires. This requirement
was implemented by the issuance of the Interim Compensatory Measures Order EA-02-026,
Section B.5.b and the subsequent requirements of Title 10 of the Code of Federal Regulations
(CFR), Part 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 March 22, 2017.
The schedule for the onsite inspection activity is as follows:
Information Gathering Visit: March 20 - 22, 2017;
B.5.b Requirements: March 22 - 24, 2017; and
Fire Protection Inspection: April 3 - 7, 2017 and April 17 - 21, 2017.
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 Clinton Power Station Fire
Protection Programs, fire protection features, post-fire safe shutdown capabilities, and plant
layout; and (3) to arrange administrative details, such as office space, availability of
knowledgeable office personnel and to ensure unescorted site access privileges.
Experience has shown that the Baseline Fire Protection Inspections are extremely resource intensive
both for the NRC inspectors and the licensee staff. In order to minimize the inspection impact on the
site and to ensure a productive inspection for both organizations, we have enclosed a request for
documents needed for the inspection. These documents have been divided into four groups.
The first group lists information necessary to aid the inspection team in choosing specific
focus areas for the inspection. It is requested that this information be provided to the
lead inspector via mail or electronically no later than February 27, 2017.
B. Hanson
-2-
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 on March 20, 2017.
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 of April 3, 2017.
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. Dariusz Szwarc. We understand that our regulatory
contact for this inspection is Mr. D. Avery of your organization. If there are any questions about
the inspection or the material requested, please contact the lead inspector at 630-829-9803 or
via e-mail at Dariusz.Szwarc@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 Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy
of this letter, its enclosure, and your response (if any) will be available electronically for public
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
component of the NRC's Agencywide Documents Access and Management 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/
Dariusz Szwarc, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-461
License No. NPF-62
Enclosure:
Fire Protection Inspection Document Request
cc: Distribution via LISTSERV
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000461/2017008
Onsite Inspection Dates:
March 20 - 22, 2017
(Information Gathering Visit)
March 22 - 24, 2017
(B.5.b Requirements)
April 3 - 7, 2017
(Fire Protection Inspection)
April 17 - 21, 2017
(Fire Protection Inspection)
Inspection Procedures:
IP71111.05T, Fire Protection (Triennial)
IP71152, "Identification and Resolution of Problems"
Inspectors:
Senior Reactor Inspector (Lead)
630-829-9803
Dariusz.Szwarc@nrc.gov
Senior Reactor Inspector
Reactor Inspector
630-829-9824
630-829-9744
Atif.Shaikh@nrc.gov
John.Robbings@nrc.gov
Observer:
Reactor Inspector
630-829-9741
Jorge.Corujo-Sandin@nrc.gov
I.
Information Requested Prior to the Information Gathering Visit
The following information is requested by February 27, 2017. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Mr. Dariusz Szwarc (e-mail address Dariusz.Szwarc@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).
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, Safe Shutdown Analysis, Updated Safety Analysis Report, Technical
Specifications, license (including the fire protection license condition), and Technical
Requirements Manual 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 Title 10 of the Code of Federal Regulations (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
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.
5. Analysis performed in support of plant evaluation regarding multiple spurious
operation (MSO), which includes the following:
a. List of identified multiple spurious fire-induced circuit failure configurations.
b. List of the generic and plant specific MSOs.
c. Results of expert panel process and associated review/evaluation of the generic
and plant specific MSOs and existing safe shutdown analysis.
d. Evaluations and corrective actions taken for resolution of MSO issues.
II.
Information Requested During the Information Gathering Visit (March 20, 2017)
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 four sets of CDs (searchable, if possible) with the B.5.b
Mitigating Strategies information (Items 8.a through 8.h) provided on one separate 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. Deviations from 10 CFR 50.48 and other regulatory requirements, and
associated licensing correspondence; and
d. The Final Safety Analysis Report sections applicable to fire protection, Fire
Hazards Analysis, and Safe Shutdown Analysis in effect at the time of original
licensing.
e. Report or evaluation that compares the FPP to the NRC Branch Technical
Position 9.5-1 Appendix A.
3. Fire Protection Program:
a. A listing of changes made to the FPP since the last Triennial Fire Protection
Inspection;
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
3
b. A listing of the protection methodologies identified under 10 CFR Part 50,
Appendix R,Section III.G, used to achieve compliance for selected fire
zones/areas (to be determined during information gathering visit). That is, please
specify whether 3-hour rated fire barriers; (Section III.G.2.a), 20 foot separation
along with detection and suppression; (Section III.G.2.b), 1-hour rated fire barriers
with detection and suppression; (Section III.G.2.c), or alternative shutdown
capability; (Section III.G.3) is used as a strategy for each selected fire zone/area;
c. A list of Generic Letter 86-10 evaluations (i.e., a list of adverse to safe-shutdown
evaluations);
d. A list of applicable codes and standards related to the design of plant fire
protection features. The list should include National Fire Protection Association
code versions committed to (i.e., the National Fire Protection Association 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 down to 480 Volts alternating current;
c. One-line schematic drawings of the electrical distribution system for 250 Volts
direct current and 125 Volts direct current 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;
c. Procedure which directs operators to the applicable safe shutdown procedure;
and
d. Procedure for calling out the fire brigade and requesting off-site assistance.
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
4
6. Corrective Actions:
a. Listing of open and closed fire protection condition reports (i.e., problem
identification forms and their resolution reports) since the date of the Last
Triennial Fire Protection Inspection; and
b. List of current fire impairments, including duration.
7. General Information:
a. A listing of abbreviations and/or designators for plant systems;
b. Organization charts of site personnel down to the level of fire protection staff
personnel; and
c. A phone list for onsite licensee personnel.
8. B.5.b Mitigating Strategies:
a. A list of all modifications to regulatory commitments made to meet the
requirements of Section B.5.b of the ICM Order, EA-02-026, dated
February 25, 2002, the subsequently imposed license conditions, and
10 CFR 50.54(hh)(2);
b. Copies of procedures/guidelines that were revised or generated to implement the
mitigation strategies. These could be Extensive Damage Mitigation Guidelines,
Severe Accident Management Guidelines, Emergency Operating Procedures,
Abnormal Operating Procedures, 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.
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
5
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.
Operators should be available on March 22 and 23 to walk down selected B.5.b
mitigation strategies;
b. Informal discussion on the plants safe shutdown cable routing database and the
plant-wide cable routing database, as applicable; and
c. A tour of alternative shutdown and risk significant fire areas.
d. 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, if possible.
III.
Information Requested to be Available on first Day of the Second Onsite
Inspection Week (April 3, 2017)
The following information is requested to be provided on the first day of inspection. It is
requested that this information be provided on four sets of CDs (searchable, if possible).
1. Program Procedures:
a. Procedures for:
i.
Administrative controls (such as allowed out of service times and
compensatory measures) for fire protection systems and components
ii.
Control of transient combustibles
iii.
Control of hot work
b. List of maintenance and surveillance testing procedures for alternative shutdown
capability and fire barriers, detectors, pumps, and suppression systems; and
c. List of maintenance procedures which routinely verify fuse breaker coordination
in accordance with the post-fire safe shutdown coordination analysis.
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);
FIRE PROTECTION INSPECTION DOCUMENT REQUEST
6
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 coordination calculations for 4160 Volts alternating current
down to 480 Volts alternating current electrical systems; and
f. List of all fire protection calculations.
3. Assessment and Corrective Actions:
a. The three most recent fire protection Quality Assurance 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.
B. Hanson
-3-
Letter to Bryan C. Hanson from Dariusz Szwarc dated December 20, 2016
SUBJECT: CLINTON POWER STATION - NOTIFICATION OF NRC TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION AND REQUEST FOR INFORMATION
cc: Distribution via LISTSERV
DISTRIBUTION:
RidsNrrDorlLpl3-2 Resource
RidsNrrPMClinton Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
DRSIII
DRPIII
ADAMS Accession Number ML16356A042
OFFICE
RIII
RIII
RIII
RIII
NAME
DSzwarc:cl
DATE
12/20/16
OFFICIAL RECORD COPY