ML19128A348
| ML19128A348 | |
| Person / Time | |
|---|---|
| Site: | Cook  (DPR-058, DPR-074) |
| Issue date: | 05/08/2019 |
| From: | Atif Shaikh Engineering Branch 3 |
| To: | Gebbie J Indiana Michigan Power Co |
| References | |
| IR 2019012 | |
| Download: ML19128A348 (11) | |
See also: IR 05000315/2019012
Text
May 8, 2019
Mr. Joel P. Gebbie
Senior VP and Chief Nuclear Officer
Indiana Michigan Power Company
Nuclear Generation Group
One Cook Place
Bridgman, MI 49106
SUBJECT: DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE
INSPECTION REQUEST FOR INFORMATION; INSPECTION
REPORT 05000315/2019012; 05000316/2019012
Dear Mr. Gebbie,
On August 26, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial Fire
Protection Baseline Inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2.
This inspection will be performed in accordance with Inspection Procedure 71111.05XT, the
NRCs baseline National Fire Protection Association 805 fire protection inspection procedure.
Inspection Procedure 71111.05XT 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 April 1, 2019.
The schedule for the onsite inspection activity is as follows:
Information Gathering Visit and B.5.b Requirements: August 26-30, 2019;
Fire Protection Inspection: September 9-13; and
Fire Protection Inspection: September 23-27, 2019.
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 Donald C. Cook Nuclear
Power Plant Fire Protection Program, 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.
J. Gebbie
-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 July 26, 2019. 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 August 26, 2019. 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 September 9, 2019.
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. Atif Shaikh. We understand that our regulatory
contact for this inspection is Mr. Michael Ellett 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 Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,
Exemptions, Requests for Withholding.
Sincerely,
/RA/
Atif Shaikh, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-315; 50-316
Enclosure:
Document Request for Fire Protection
Inspection
cc: Distribution via LISTSERV
J. Gebbie
-3-
Letter to Joel P. Gebbie from Atif Shaikh dated May 8, 2019.
SUBJECT: DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE
INSPECTION REQUEST FOR INFORMATION; INSPECTION
REPORT 05000315/2019012; 05000316/2019012
DISTRIBUTION:
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ADAMS Accession Number: ML19128A348
OFFICE
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NAME
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DATE
05/08/19
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION
Enclosure
Inspection Report: 05000315/2019012; 05000316/2019012
Onsite Inspection Dates:
August 26-27, 2019
(Information Gathering Visit)
August 28-30, 2019
(B.5.b Requirements)
September 9-13, 2019
(Fire Protection Inspection)
September 23-27, 2019
(Fire Protection Inspection)
Inspection Procedures:
71111.05XT, Fire Protection - NFPA 805 (Triennial)
71152, Identification and Resolution of Problems"
Inspectors:
630-829-9824
Atif.Shaikh@nrc.gov
George Hausman
630-829-9843
630-829-9743
Ijaz.Hafeez@nrc.gov
George.Hausman@nrc.gov
I.
Information Requested Prior To the Information Gathering Visit
The following information is requested by July 26, 2019. 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 or
Microsoft Excel 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. Design and Licensing Basis Documents:
a. Post-fire Nuclear Safety Capability, Systems, and Separation Analysis.
b. Fire Hazards Analysis and/or National Fire Protection Association (NFPA) 805
Design Basis Document.
c. Fire PRA Summary Document or full PRA Document (if summary document not
available).
d. NFPA 805 Transition Report, developed in accordance with Nuclear Energy
Institute Document 04-02.
e. Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3).
f. Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4).
g. Analysis that demonstrates nuclear safety performance criteria can be achieved
and maintained for those areas that require recovery actions.
DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION
2
h. Fire Protection Program and/or Fire Protection Plan.
i.
Copies of the current versions of the Facility Operating License and Technical
Requirements Manual.
2. Operations
a. Operating procedures to achieve and maintain nuclear safety performance
criteria from the control room, with a postulated fire in the selected fire areas.
b. 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).
II.
Information Requested During the Information Gathering Visit (August 26, 2019)
The following information is requested to be provided to the inspection team during the
onsite information gathering visit. Except for Item 7, 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 (Item 7) provided on one separate CD.
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. Design and Licensing Basis Documents:
a. List of post-fire safe shutdown components (i.e., safe shutdown equipment list).
b. Fire protection system design basis document.
c. List of applicable NFPA codes and standards and issuance dates (i.e., codes of
record).
d. 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).
e. NFPA Compliance Review Report.
f. Report or evaluation that compares the Fire Protection Program to the U.S.
Nuclear Regulatory Commission (NRC) Branch Technical Position (BTP) 9.5-1
Appendix A.
g. Copy of licensee submittals and NRC Safety Evaluation Reports that are
specifically listed in the facility operating license for the approved Fire Protection
Program.
h. Copy of NRC Safety Evaluation Reports that form the licensing basis for the Fire
Protection Program and post-fire nuclear safety capability.
DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION
3
i.
Copy of NRC-approved exemptions for plant fire protection and post-fire nuclear
safety capability features.
j.
Copy of exemption requests submitted but not yet approved for plant fire
protection and post-fire nuclear safety capability features.
k. List of nuclear safety capability design changes completed in the last 3 years
(including their associated Title 10 of the Code of Federal Regulations (CFR),
Part 50.59 and NFPA 805 plant change evaluations).
3. General Plant Design Documents (available onsite for inspector review)
a. Piping and instrumentation diagrams (P&IDs) and legend list for components
used to achieve and maintain nuclear safety performance criteria for: (C-size
paper drawings)
i. Fires outside the main control room; and
ii. Fires in areas requiring recovery actions at other than primary control
stations.
b. P&IDs and legend list for fire protection systems, including fire water supply,
water suppression sprinklers & deluge, and carbon dioxide (CO2) and Halon
systems (C-size paper drawings).
c. Yard layout drawings for underground fire protection buried piping (C-size paper
drawings).
d. AC and DC electrical system single line diagrams, from off-site power down to
the highest safety-related bus level (typically 4kV, EDG bus) (C-size paper
drawings).
e. Single line diagrams for motor control centers that supply post-fire nuclear safety
component loads (only for selected fire areas) (C-size paper drawings).
f. Equipment location drawings which identify the physical plant locations of
post-fire nuclear safety capability equipment (C-size paper drawings).
g. Logic diagrams showing the components used to achieve and maintain hot
standby and cold shutdown.
4. Operations
a. List of calculations and engineering analyses, studies, or evaluations for the
nuclear safety capability methodology.
b. For recovery actions, provide the following:
i. Manual Action Feasibility Study;
ii. Operator Time Critical Action Program;
DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION
4
iii. Time lines for time-critical recovery actions; and
iv. Time line validations.
c. Thermal hydraulic calculation or analysis that determines the time requirements
for time-critical manual operator actions.
5. Administrative Control, Oversight, and Corrective Action Programs
a. Corrective actions associated with operator actions to achieve and maintain
post-fire nuclear safety performance criteria.
b. List of open and closed condition reports for the fire protection system for the last
3 years.
c. 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.
d. List of procedures that control the configuration of the Fire Protection Program,
features, and post-fire nuclear safety capability methodology and system design.
6. 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 personnel.
7. B.5.b Mitigating Strategies Documents (provided on one separate compact disk on
August 26, 2019.
a. List of all changes to regulatory commitments made to meet the requirements of
10 CFR 50.54(hh)(2).
b. List of procedures and guidelines that were revised or generated to implement
the mitigating 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, 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.
DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION
5
d. List of engineering evaluations or calculations that were used to verify the
engineering bases for the mitigating strategies.
e. 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).
f. List of modification packages or summary descriptions of modifications with
simplified drawings, for necessary facility changes to implement the mitigating
strategies.
g. List of routine tests, surveillances, and preventive maintenance for equipment
and tools needed to implement 10 CFR 50.54(hh)(2) strategies.
h. For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies,
provide the following:
i. Procedures for inventory and inspection; and
ii. Most recent inspection and inventory results.
i.
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.
j.
Site general arrangement drawings that show the majority of buildings and areas
referenced in 10 CFR 50.54(hh)(2) documents.
k. Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2).
l.
Copies of memoranda of understanding (e.g., with local fire departments)
required to implement any mitigating strategies.
8. 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 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.
DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION
6
III.
Information Requested to be Available on first Day of the Second Onsite
Inspection Week (September 9, 2019)
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. Classic Fire Protection
a. Copy of Fire Protection Program implementing procedures (e.g., administrative
controls, surveillance testing, and fire brigade).
b. List of calculations and engineering analyses, studies, or evaluations for the fire
protection system, including the fire water system.
c. Hydraulic calculations or analyses for fire protection water system.
d. 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:
i. An automatic or manually actuated suppression system, due to a fire in a
single location, will not indirectly cause damage to the success path; and
ii. Inadvertent actuation or rupture of a suppression system will not indirectly
cause damage to the success path; and
iii. Demonstration of adequate drainage for areas protected by water
suppression systems;
iv. Hydrostatic rating of any floor penetration seals installed within the fire areas
that are credited with keeping water from leaking into fire areas below.
e. Pre-fire plans for selected fire areas.
f. List of fire protection system design changes completed in the last 3 years
(including their associated 10 CFR 50.59 and NFPA 805 plant change
evaluations).
g. List of fire protection system NFPA 805 engineering equivalency evaluations
completed in the last 3 years.
h. Copy of any test, surveillance, or maintenance procedure (current revision),
including any associated data forms, for any requested "last performed" test,
surveillance, or maintenance.
2. Electrical
a. Nuclear safety circuit coordination analysis for fuse and breaker coordination of
nuclear safety capability components (only for selected fire areas).
DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION
7
b. Administrative or configuration control procedures that govern fuse replacement
(e.g., fuse control procedures).
c. Maintenance procedures that verify breaker over-current trip settings to
ensure coordination remains functional, for post-fire nuclear safety capability
components.
d. Last surveillance demonstrating operability of those components operated from
the primary control stations.
e. Schematic or elementary diagrams for circuits to be reviewed (C-size paper
drawings).
f. Cable routing for components and equipment credited for post-fire nuclear safety
capability systems and components (only for selected fire areas).
g. List of post-fire nuclear safety capability system and component design changes
completed, in the last 3 years.
h. List of identified fire induced circuit failure analyses (only for selected fire areas).
3. Operations
a. For safe shutdown equipment and tools, provide the following:
i. Procedure for inventory and inspection; and
ii. Most recent inspection and inventory results.
b. List of procedures that implement Cold Shutdown Repairs.
c. For Cold Shutdown Repairs, provide the following:
i. Procedure for inventory and inspection (i.e., needed tools, material, etc.); and
ii. Most recent inspection and inventory results.
d. List of licensed operator Job Performance Measures (JPMs) for operator actions
required to achieve and maintain post-fire nuclear safety performance criteria.
e. 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).
f. Lesson plans for post-fire nuclear safety capability training for licensed and
non-licensed operators.
g. For Radio communications, provide the following:
i. Communications Plan for firefighting and post-fire safe shutdown manual
actions;
DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION
8
ii. Repeater locations;
iii. Cable routing for repeater power supply cables;
iv. Radio coverage test results; and
v. Radio Dead Spot locations in the plant.
h. Environmental and habitability evaluations for post-fire operator actions
(temperature, smoke, humidity, SCBAs, etc.).
4. Administrative Control, Oversight, and Corrective Action Programs
a. Self-assessments, peer assessments, and audits of fire protection activities for
the last 3 years.
b. Self-assessments, peer assessments, and audits of post-fire nuclear safety
capability methodology for the last 3 years.
c. List of fire event analysis reports for the last 3 years.
5. 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.