ML21278A444
| ML21278A444 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/05/2021 |
| From: | Jasmine Gilliam Engineering Branch 3 |
| To: | Corbin D Entergy Nuclear Operations |
| References | |
| IR 2021010 | |
| Download: ML21278A444 (8) | |
See also: IR 05000255/2021010
Text
Mr. Darrell Corbin
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: PALISADES NUCLEAR PLANT NOTIFICATION OF NRC FIRE
PROTECTION TEAM INSPECTION REQUEST FOR INFORMATION;
INSPECTION REPORT 05000255/2021010
Dear Mr. Corbin:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
Region III staff will conduct a Fire Protection Team Inspection at your Palisades Nuclear Plant
beginning November 29, 2021. The inspection will be conducted in accordance with Inspection
Procedure 71111.21N.05, Fire Protection Team Inspection, dated June 12, 2019.
The inspection will verify that plant Structures, Systems, and Components (SSCs) and/or
administrative controls credited in the approved Fire Protection Program can perform their
licensing basis function.
The schedule for the inspection is as follows:
Preparation week (R-III office):
November 15 - 19, 2021
Onsite inspection:
November 29 - December 3, 2021
Experience has shown that the baseline fire protection team 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 three groups:
The first group lists information necessary to aid the inspection team in choosing specific
focus areas for the inspection and to ensure that the inspection team is adequately
prepared for the inspection. It is requested that this information be provided to the lead
inspector via mail or electronically no later than November 9, 2021.
The second 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 onsite inspection week November 29, 2021.
October 5, 2021
D. Corbin
-2-
The third 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 Ms. J. Gilliam. We understand that our regulatory
contact for this inspection is Ms. B. Dotson of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector at
630-829-9831 or via e-mail at Jasmine.Gilliam@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,
Jasmine Gilliam, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket No. 05000255
License No. DPR-20
Enclosure:
Fire Protection Team Inspection Supporting
Documentation
cc: Distribution via LISTSERV
Signed by Gilliam, Jasmine
on 10/05/21
D. Corbin
-3-
Letter to Darrell Corbin from Jasmine Gilliam dated October 5, 2021.
SUBJECT: PALISADES NUCLEAR PLANT NOTIFICATION OF NRC FIRE
PROTECTION TEAM INSPECTION REQUEST FOR INFORMATION;
INSPECTION REPORT 05000255/2021010
DISTRIBUTION:
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RidsNrrDroIrib Resource
DRPIII
DRSIII
ADAMS Accession Number: ML21278A444
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
JGilliam:mb
DATE
10/05/2021
OFFICIAL RECORD COPY
FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
Enclosure
I.
Information Requested prior to the Inspection Preparation Week
The following information is requested by November 9, 2021. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Jasmine Gilliam (Jasmine.Gilliam@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.
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 Title 10 of the Code of Federal Regulations (CFR), Part 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 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 Hazard
analysis (FHA), and Safe shutdown analysis (SSA) 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.
A list of applicable codes and standards related to the design of plant fire protection
features. The list should include National Fire Protection Association (NFPA) code
versions committed to (i.e., the NFPA Codes of Record);
c.
List of plant deviations from code commitments and associated evaluations; and
FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
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d.
Fire Protection Program and/or Fire Protection Plan document.
4.
Operations Response for Fire Protection:
a.
Plant operating procedures which specify the initial operations response to a fire
alarm or annunciator.
5.
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.
6.
Classic Fire Protection for the fire areas/ zones associated with the Spent Fuel Pool
(SFP) and SFP support systems:
a.
Copy of Fire Protection Program implementing procedures (e.g., administrative
controls, surveillance testing, and fire brigade);
b.
Pre-fire plans for selected fire area(s); and
c.
List of fire protection system design changes completed in the last 3 years.
7.
Aging Management:
a.
Implementing procedures associated with replacing all sprinkler heads or testing of a
representative sample of sprinkler heads prior to the end of their 50-year service life.
(Commitment 25 of Appendix A in NUREG-1871, Safety Evaluation Report Related
to the License Renewal of Palisades Nuclear Plant).
b.
For the sprinkler heads located or covering the fuel pool area or fuel pool cooling
equipment, provide an explanation of how Commitment 25 was met. A listing of
sprinkler heads and a work order number or justification for not replacing would meet
this request.
c.
Copies of aging related corrective actions documents specific to the fire protection
system including fire doors, piping, pumps, detectors, and sprinkler (for the last three
years). A search of corrective actions documents should include keywords such as:
aging, age management, degradation, wear, peeling, chipping, leak,
crack, corrosion, rust, leaching, embrittlement, fatigue, blister, spalling,
oxidation, loss of function, failed acceptance criteria, flow-accelerated, or other
site specific terms/codes used in aging monitoring as appropriate.
8.
General Information:
a.
A listing of abbreviations and/or designators for plant systems;
FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
3
b.
Organization charts of site personnel down to the level of fire protection staff
personnel; and
c.
A phone list for onsite licensee personnel.
II.
Information Requested to Be Available on First Day of the ONSITE Inspection
Week (NOVEMBER 29, 2021)
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; and
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 for fire zone/ area(s) associated with the SFP and
support systems):
a.
Coordination calculations and/or justifications that verify fuse/breaker coordination
for SSCs 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 86-10 (or adverse to safe shutdown) evaluations;
c.
Gaseous suppression system pre-operational testing, if applicable, for selected fire
zones/areas;
d.
Hydraulic calculations and supporting test data which demonstrate operability for
water suppression systems;
e.
Alternating current (ac) coordination calculations for 4160 Vac down to 480 Vac
electrical systems; and
f.
List of all fire protection or Appendix R calculations.
3.
Electrical for the fire zone/ areas associated with SFP and SFP support systems:
FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
4
a.
Nuclear safety circuit coordination analysis for fuse and breaker coordination of safe
shutdown components;
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 (only for selected SSCs) to be
reviewed (C-size paper drawings);
f.
Cable routing for components and equipment credited for post-fire nuclear safety
capability systems and components;
g.
List of post-fire nuclear safety capability system and component design changes
completed, in the last 3 years; and
h.
List of identified fire induced circuit failure analyses.
4.
Operations:
a.
List of licensed operator Job Performance Measures for operator actions required to
achieve and maintain post-fire nuclear safety performance criteria for the SFP and
SFP support systems and fire area;
b.
For Radio communications, provide the following:
i.
Communications Plan for firefighting and post-fire safe shutdown manual
actions;
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.
c.
Environmental and habitability evaluations for post-fire operator actions
(temperature, smoke, humidity, SCBAs, etc.).
5.
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; and
c.
List of fire event analysis reports for the last 3 years; and
FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
5
d.
The three most recent fire protection Quality Assurance audits and/or fire protection
self-assessments.
6.
Any updates to information previously provided.
III. 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).