ML23005A068
| ML23005A068 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/05/2023 |
| From: | Kevin Barclay NRC/RGN-III/DORS/EB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023010 | |
| Download: ML23005A068 (1) | |
See also: IR 05000461/2023010
Text
David Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: CLINTON POWER STATION - NOTIFICATION OF NRC FIRE PROTECTION
TEAM INSPECTION REQUEST FOR INFORMATION: INSPECTION REPORT
Dear David Rhoades:
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 Clinton Power
Station beginning March 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 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): March 6 - 10, 2023
Week 1 of onsite inspection: March 13 - 17, 2023
Week 2 of onsite inspection: March 27 - 31, 2023
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 February 13, 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 March 13, 2023.January 5, 2023
D. Rhoades - 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 Kevin Barclay. We understand that our regulatory
contact for this inspection is Chelsie Miller. If there are any questions about the inspection or the
material requested, please contact the lead inspector at 630-829-9885 or via email at
Kevin.Barclay@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, 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,
Kevin Barclay, Senior Reactor Inspector
Engineering Branch 1
Division of Operating Reactor Safety
Docket No. 50-461
License No. NPF-62
Enclosure:
Information Request for Fire Protection
Team Inspection
cc: Distribution via LISTSERV
Signed by Barclay, Kevin
on 01/05/23
D. Rhoades - 3 -
Letter to David Rhoades from Kevin Barclay dated January 5, 2023.
SUBJECT: CLINTON POWER STATION - NOTIFICATION OF NRC FIRE PROTECTION
TEAM INSPECTION REQUEST FOR INFORMATION: INSPECTION REPORT
DISTRIBUTION:
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ADAMS Accession Number: ML23005A068
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
OFFICE RIII
NAME KBarclay:gmp
DATE 01/05/2023
OFFICIAL RECORD COPY
I. Information Requested Prior to the Inspection Preparation Week
The following information is requested by February 13, 2023. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Kevin Barclay (email address) Kevin.Barclay@nrc.gov. Electronic media is
preferred (e.g., via Share File System).
1. 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 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 sections applicable to fire protection, FHA, and 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;
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;
Enclosure
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. Fire Protection Program 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 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 LERF scenarios for each unit; and
k. Risk ranking of operator actions and/or recovery actions from your site-specific PRA
sorted by Risk-Achievement Worth (RAW) and human reliability worksheets for these
items.
l. Fire Protection Program Procedures for:
i. Administrative controls (such as allowed out of service times and compensatory
measures) for fire protection systems and components; and
ii. Control of hot work and transient combustibles.
m. List of maintenance and surveillance testing procedures for alternative shutdown
capability and fire barriers, detectors, pumps, and suppression systems; and
n. List of maintenance procedures which routinely verify fuse breaker coordination in
accordance with the post-fire safe shutdown coordination analysis.
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
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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 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 the First Day of the First Onsite
Inspection Week (March 13, 2023)
The following information is requested to be provided on the first day of inspection
(searchable, if possible).
1. Design and Equipment Information (only for selected fire zone/area(s) and/or SSCs):
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
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f. List of all fire protection or Appendix R calculations.
2. Classic Fire Protection (only for selected fire zone/area(s) and/or SSCs):
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.
3. Electrical (only for selected fire zone/area(s) and/or SSCs):
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 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 for operator actions required to
achieve and maintain post-fire nuclear safety performance criteria (for selected SSCs
and fire area);
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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.).
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.
d. List of condition reports, temporary modifications, operator workarounds, and
compensatory measures for the last 3 years. (only for the selected fire protection
or post-fire SSD SSCs):
6. Maintenance and Testing (only for the selected fire protection or post-fire SSD
SSCs):
a. List of maintenance work requests, post-maintenance tests and surveillance
activities documented or performed over the last three years.
7. Aging Management Program
a. Copies of the aging management programs applicable to fire protection including but
not limited to the following:
i. Fire Protection
ii. Fire Water System
iii. Aboveground Metallic Tanks
iv. Buried and Underground Piping and Tanks
8. 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).
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