ML17348A526
| ML17348A526 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/13/2017 |
| From: | Atif Shaikh Division of Reactor Safety III |
| To: | Arnone C Entergy Nuclear Operations |
| References | |
| IR 2018011 | |
| Download: ML17348A526 (9) | |
See also: IR 05000255/2018011
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, ILLINOIS 60532-4352
December 13, 2017
Mr. Charles Arnone
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: PALISADES NUCLEAR PLANTNOTIFICATION OF NRC TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION AND REQUEST FOR INFORMAITON
Dear Mr. Arnone:
On March 5, 2018 the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial Fire
Protection Baseline Inspection at your Palisades Nuclear Plant. This inspection will be
performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs Baseline Fire
Protection IP.
Changes were made to the IP 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, 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 5, 2018.
The schedule for the onsite inspection activity is as follows:
Information Gathering Visit: March 5-6, 2018;
B.5.b Requirements: March 6-9, 2018; and
Fire Protection Inspection: March 19-23, 2018, and April 2-6, 2018.
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 Palisades Nuclear Plant 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.
C. Arnone -2-
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 2, 2018.
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 5, 2018.
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 beginning March 19, 2018.
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 Atif Shaikh. We understand that our regulatory contact
for this inspection is Barb Dotson of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 630-829-9824 or via
e-mail at Atif.Shaikh@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.
This letter and its enclosure will be made available for public inspection and copying at
http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in
accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Atif A. Shaikh, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure:
Fire Protection Inspection Request for Information
cc: Distribution via LISTSERV
C. Arnone -3-
Letter to Charles Arnone from Atif A. Shaikh dated December 13, 2017
SUBJECT: PALISADES NUCLEAR PLANTNOTIFICATION OF NRC TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION AND REQUEST FOR INFORMAITON
DISTRIBUTION:
RidsNrrPMPalisades Resource
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RidsNrrDirsIrib Resource
Cynthia Pederson
Kenneth OBrien
DRPIII
DRSIII
ADAMS Accession Number ML17348A526
OFFICE RIII RIII RIII RIII
NAME AShaikh:cl
DATE 12/13/17
OFFICIAL RECORD COPY
FIRE PROTECTION INSPECTION REQUEST FOR INFORMATION
Inspection Report: 05000255/2018011
Onsite Inspection Dates: March 5-6, 2018 (Information Gathering Visit)
March 6-9, 2018 (B.5.b Requirements)
March 19-23, 2018 (Fire Protection Inspection)
April 2-6, 2018 (Fire Protection Inspection)
Inspection Procedures: IP71111.05T, Fire Protection (Triennial)
IP71152, Identification and Resolution of Problems
Inspectors: Atif Shaikh, Lead Inspector
(630) 829-9824
Atif.Shaikh@nrc.gov
Ijaz Hafeez, Inspector Darius Szwarc, Senior Inspector
630-829-9843 630-829-9803
Ijaz.Hafeez@nrc.gov Darius.Szwarc@nrc.gov
I. Information Requested Prior To the Information Gathering Visit
The following information is requested by February 2, 2018. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All
information should be sent to Atif Shaikh (e-mail address Atif.Shaikh@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 for fire and results of any post-Individual Plant Examination for External
Events reviews for fire.
2. A copy of the current version of the Fire Protection Program, 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.
Enclosure
FIRE PROTECTION INSPECTION REQUEST FOR INFORMATION
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 the
procedure which directs operators to the applicable safe shutdown procedure.
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 5, 2018)
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 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
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FIRE PROTECTION INSPECTION REQUEST FOR INFORMATION
fire protection SERs issued before Appendix A to Branch Technical Position
APCSB 9.5-1 was published in August 1976 (10 CFR 50.48(b)(1)(ii)); and
e. 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.
3. Fire Protection Program:
a. A listing of changes made to the Fire Protection Program 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;
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 (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).
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FIRE PROTECTION INSPECTION REQUEST FOR INFORMATION
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
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;
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FIRE PROTECTION INSPECTION REQUEST FOR INFORMATION
g. Copies of Memoranda of Understanding (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 (April 29, 2014).
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; 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 (March 19, 2018)
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;
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FIRE PROTECTION INSPECTION REQUEST FOR INFORMATION
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 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 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:
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.
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