ML22214A704
| ML22214A704 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/02/2022 |
| From: | Benny Jose Engineering Branch 3 |
| To: | Tony Brown Energy Harbor Nuclear Corp |
| References | |
| IR 2022011 | |
| Download: ML22214A704 (9) | |
See also: IR 05000346/2022011
Text
Mr. Terry Brown
Site Vice President
Energy Harbor Nuclear Corp.
Davis-Besse Nuclear Power Station
5501 N. State Rte. 2, Mail Stop A-DB-3080
Oak Harbor, OH 43449-9760
SUBJECT: REISSUE - DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1
NOTIFICATION OF NRC FIRE PROTECTION TEAM INSPECTION
REQUEST FOR INFORMATION: INSPECTION REPORT 05000346/2022011
Dear Mr. Brown:
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 (FPTI) at your Davis-Besse
Nuclear Power Station, beginning October 3, 2022. The inspection will be conducted in
accordance with IP 71111.21N.05, Fire Protection Team Inspection (FPTI), dated
June 12, 2019.
The inspection will verify that plant Systems, Structures, and Components (SSCs) and/or
administrative controls credited in the approved Fire Protection Program (FPP) can perform
their licensing basis functions.
The schedule for the inspection is as follows:
Preparation week (R-III office): September 26, 2022
Week 1 of onsite inspection: October 03 - 07, 2022
Week 2 of onsite inspection: October 17 - 21, 2022
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 September 05, 2022.
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 first onsite inspection week October 03, 2022.
August 2, 2022
T. Brown
- 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 Mr. B. Jose. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 630-829-9756 or via
Cell Phone, 847-715-8887 or via e-mail at Benny.Jose@nrc.gov. This letter, its enclosure, and
your response (if any) 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 (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Benny Jose, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket No. 05000346
License No. NPF-3
Enclosure:
Information Request for Fire Protection
Team Inspection
cc: Distribution via LISTSERV
Signed by Jose, Benny
on 08/02/22
T. Brown
- 3 -
Letter to Terry Brown from Benny Jose dated August 2, 2022.
SUBJECT: REISSUE - DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1
NOTIFICATION OF NRC FIRE PROTECTION TEAM INSPECTION
REQUEST FOR INFORMATION: INSPECTION REPORT 05000346/2022011
DISTRIBUTION:
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RidsNrrPMDavisBesse Resource
RidsNrrDroIrib Resource
DRPIII
DRSIII
ADAMS Accession Number: ML22214A704
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
BJose:jw
DATE
08/02/2022
OFFICIAL RECORD COPY
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
Enclosure
I.
Information Requested Prior to the Inspection Preparation Week
The following information is requested by September 05, 2022. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Benny Jose (e-mail address) Benny.Jose@nrc.gov. Electronic media is
preferred (e.g., via Share File System or BOX).
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 Probabilistic Risk Assessment (PRA) Summary Document or full PRA
Document (if summary document not available).
d.
NFPA 805 Transition Report, developed in accordance with NEI 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.
h.
Fire Protection Program (FPP) and/or Fire Protection Plan.
i.
Copies of the current versions of the Facility Operating License and Technical
Requirements Manual.
j.
List of post-fire safe shutdown components (i.e., safe shutdown equipment list).
k.
Fire protection system design basis document.
l.
List of applicable NFPA codes and standards and issuance dates (i.e., codes of
record).
m.
List of deviations from (a) NFPA codes of record, or (b) NFPA 805 fundamental
FPP and design elements (i.e., NFPA 805, Chapter 3).
n.
NFPA Compliance Review Report.
o.
Report or evaluation that compares the FPP to the Nuclear Regulatory
Commission (NRC) Branch Technical Position (BTP) 9.5-1 Appendix A.
p.
Copy of licensee submittals and NRC safety evaluation reports that are
specifically listed in the facility operating license for the approved FPP.
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
2
q.
Copy of NRC Safety Evaluation Reports that form the licensing basis for the FPP
and post-fire nuclear safety capability.
r.
Copy of NRC approved exemptions for plant fire protection and post-fire nuclear
safety capability features.
s.
Copy of exemption requests submitted but not yet approved for plant fire protection
and post-fire nuclear safety capability features.
t.
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).
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).
c.
List of calculations and engineering analyses, studies, or evaluations for the
nuclear safety capability methodology.
d.
For recovery actions, provide the following:
i.
Manual Action Feasibility Study;
ii.
Operator Time Critical Action Program;
iii.
Timelines for time-critical recovery actions; and
iv.
Timeline validations.
e.
Thermal hydraulic calculation or analysis that determines the time requirements for
time-critical manual operator actions.
3. Facility Information
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.
4.
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.
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
3
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 (MCCs) 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.
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
three 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 FPP, 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.
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
4
II.
Information Requested to Be Available on first Day of the first Onsite Inspection
Week (October 03, 2022)
1. Classic Fire Protection
a.
Copy of FPP 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;
ii.
Inadvertent actuation or rupture of a suppression system will not indirectly
cause damage to the success path;
iii.
Demonstration of adequate drainage for areas protected by water suppression
systems; and
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 three 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 three 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).
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.
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
5
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 three 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;
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.).
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
6
4.
Administrative Control, Oversight, and Corrective Action Programs
a.
Self-assessments, peer assessments, and audits of fire protection activities
for the last three years.
b.
Self-assessments, peer assessments, and audits of post-fire nuclear safety
capability methodology for the last three years.
c.
List of fire event analysis reports for the last three years.
5.
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).
If you have questions regarding the information requested, please contact the lead inspector.