ML22362A071
| ML22362A071 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/28/2022 |
| From: | Ijaz Hafeez NRC/RGN-III/DORS/EB2 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| IR 2023010 | |
| Download: ML22362A071 (9) | |
See also: IR 05000341/2023010
Text
Mr. Peter Dietrich
Senior VP and Chief Nuclear Officer
DTE Electric Company
Fermi 2 - 260 TAC
6400 North Dixie Highway
Newport, MI 48166
SUBJECT: FERMI POWER PLANT, UNIT 2 - NOTIFICATION OF NRC FIRE PROTECTION
TEAM INSPECTION REQUEST FOR INFORMATION; INSPECTION REPORT
NUMBERS 05000341/2023010
Dear Mr. Dietrich:
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 Fermi Power Plant,
Unit 2 beginning February 13, 2023. 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 structures, systems, and components (SSCs) and/or
administrative controls credited in the approved Fire Protection Program (FPP) can perform
their licensing basis function.
The schedule for the inspection is as follows:
Preparation week (R-III office): February 06 - 10, 2023
Week 1 of onsite inspection: February 13 - 17, 2023
Week 2 of onsite inspection: February 27 - March 3, 2023
Experience has shown that the baseline FPTIs 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 January 30, 2023. 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
February 13, 2023. 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.
December 28, 2022
P. Dietrich
2
The lead inspector for this inspection is Mr. I. Hafeez. We understand that our regulatory
contact for this inspection is Mr. S. Gatter of your organization. If there are any questions about
the inspection or the material requested, please contact the lead inspector at 630-829-9843 or
via e-mail at Ijaz.Hafeez@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 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Ijaz Hafeez, Senior Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Docket No. 50-341
License No. NPF-43
Enclosure:
Information Request for Fire Protection
Team Inspection
cc: Distribution via LISTSERV
Signed by Hafeez, Ijaz
on 12/28/22
P. Dietrich
3
Letter to Peter Dietrich from Ijaz Hafeez dated December 28, 2022.
SUBJECT: FERMI POWER PLANT, UNIT 2 - NOTIFICATION OF NRC FIRE PROTECTION
TEAM INSPECTION REQUEST FOR INFORMATION; INSPECTION REPORT
NUMBERS 05000341/2023010
DISTRIBUTION:
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RidsNrrPMFermi2 Resource
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R3-DORS
ADAMS Accession Number: ML22362A071
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
IHafeez:mb
DATE
12/28/2022
OFFICIAL RECORD COPY
Enclosure
FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
I.
Information Requested Prior to the Inspection Preparation Week
The following information is requested by January 30, 2023. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Ijaz Hafeez (e-mail address Ijaz.Hafeez@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 (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 (BTP) 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 BTP APCSB 9.5-1 was published in
August 1976 (10 CFR 50.48(b)(1)(ii)); and
e.
The final safety analysis report (FSAR) sections applicable to fire protection, fire
hazards 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 (FPP) since the last
triennial fire protection inspection;
2
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 fire
zones/areas. 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
(NFPA) code versions committed to (i.e., the NFPA Codes of Record);
e.
List of plant deviations from code commitments and associated evaluations;
f.
FPP and/or Fire Protection Plan document;
g.
(If available) Fire Probabilistic Risk Assessment (PRA) Summary Report or full
PRA document (if summary document not available);
h.
List of the top 25 highest fire core damage frequency (CDF) scenarios for each
unit;
i.
List of Fire Areas/Zones ranked by contribution to CDF (i.e., ranking of highest to
lowest risk fire areas/zones);
j.
List of the top 25 highest fire large early release frequency (LERF) scenarios for
each unit; and
k.
Risk ranking of operator actions and/or recovery actions from your site-specific
PRA sorted by risk assessment worth (RAW) and human reliability worksheets for
these items.
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, and those components used for those areas requiring alternative shutdown
capability;
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
3
e.
Safe shutdown cable routing database (requested electronically, such as on
compact disc, if available).
5.
Operations Response for Fire Protection:
a.
Plant operating procedures which specify the initial operations response to a fire
alarm or annunciator.
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.
II.
Information Requested to be Available on First Day of the FIRST ONSITE Inspection
Week (FEBRUARY 13, 2023)
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 only selected fire zone/area(s) and/or SSCs
to be determined during inspection preparation week):
4
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 (GL) 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 4160Vac down to 480Vac
electrical systems; and
f.
List of all fire protection or Appendix R calculations.
3.
Assessment and Corrective Actions:
The three most recent fire protection Quality Assurance (QA) audits and/or fire
protection self-assessments.
4.
Any updates to information previously provided.
5.
Classic Fire Protection (for only selected fire zone/area(s) and/or SSCs to be
determined during inspection preparation week):
a.
Copy of FPP 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.
6.
Electrical (for only selected fire zone/area(s) and/or SSCs to be determined during
inspection preparation week):
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;
5
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.
7.
Operations
a.
List of procedures that implement Cold Shutdown Repairs (if applicable for
selected fire area);
b.
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.
c.
List of licensed operator Job Performance Measures (JPMs) for operator actions
required to achieve and maintain post-fire nuclear safety performance criteria (for
selected SSCs and fire area);
d.
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.
e.
Environmental and habitability evaluations for post-fire operator actions
(temperature, smoke, humidity, SCBAs, etc.).
8.
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.
9.
Any updates to information previously provided.
6
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).