ML25182A059

RFI for Fire Protection Inspection

ML25182A059
Person / Time
Site:	Palisades
Issue date:	07/01/2025
From:	Alan Dahbur NRC/RGN-III/DORS/EB2
To:	Mlynarek M Holtec Decommissioning International
References
Download: ML25182A059 (1)

Text

Mike Mlynarek Site Vice President Holtec Decommissioning International, LLC 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

Dear Mike Mlynarek:

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 Palisades Nuclear Plant, beginning August 18, 2025. 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 function.

The schedule for the inspection is as follows:

Preparation week (RIII office): August 11-15, 2025 Week 1 of onsite inspection: August 18-22, 2025 In-office inspection week: August 25-September 05, 2025 Week 2 of onsite inspection: September 08-12, 2025 Experience has shown that the baseline FPTIs are 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 July 25, 2025.

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, August 18, 2025.

July 1, 2025

M. Mlynarek 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 Alan Dahbur. We understand that our regulatory contact for this inspection is Amy Filbrandt of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at 630-829-9810 or via email at Alan.Dahbur@nrc.gov.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at https://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Alan Dahbur, Senior Reactor Inspector Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000255 License No. DPR-20

Enclosure:

Information Request for Fire Protection Team Inspection cc: Distribution via LISTSERV Signed by Dahbur, Alan on 07/01/25

M. Mlynarek 3

Letter to Mike Mlynarek from Alan Dahbur dated July 1, 2025.

SUBJECT:

PALISADES NUCLEAR PLANT - NOTIFICATION OF NRC FIRE PROTECTION TEAM INSPECTION REQUEST FOR INFORMATION Distribution:

Tim Steadham RidsNrrPMPalisades Resource RidsNrrDorlLpl3 RidsNrrDroIrib Resource Jack Giessner Mohammed Shuaibi Diana Betancourt-Roldan John Pelchat David Curtis Jared Heck R3-DORS ADAMS Accession Number: ML25182A059 Publicly Available Non-Publicly Available Sensitive Non-Sensitive OFFICE RIII NAME ADahbur:anm DATE 07/01/2025 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 (electronic copy) is requested by July 25, 2025.

If you have any questions regarding this request, please call the lead inspector as soon as possible. All information should be sent to Alan Dahbur (email address Alan.Dahbur@nrc.gov). Electronic or digital (online) media is preferred (e.g., via Share File System).

1. Design and Licensing Basis Documents 2.

Set of 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.

3. 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.

The final safety analysis report (FSAR) sections applicable to fire protection, FHA, and SSA in effect at the time of original licensing; and c.

List and status of all modifications required per the approved Fire Protection Program for transitioning to NFPA-805 (completed, cancelled and open).

4. Fire Protection Program:

a.

A listing of changes made to the FPP since the last NRC fire protection inspection (completed in May of 2018);

b. Fire Protection Program and/or Post-Fire Safe Shutdown Analysis document; c.

Fire Probabilistic Risk Assessment (PRA) Summary Report or full PRA document (if summary document not available);

d. List of the top 25 highest fire CDF scenarios; e.

List of Fire Areas/Zones ranked by contribution to CDF (i.e., ranking of highest to lowest risk fire areas/zones);

f.

List of the top 25 highest fire LERF scenarios;

g. List of Fire Areas/Zones that were determined to meet the Deterministic Approach and the Performance-Based Approach;

h. List of multiple spurious operation evaluations (if available);

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REQUEST FOR INFORMATION 2

i.

List of Plant Change Evaluations; and j.

Risk ranking of operator actions and/or recovery actions from your site-specific PRA sorted by RAW and human reliability worksheets for these items.

5. Facility Information:

a.

Piping and instrumentation (flow) diagrams showing the components used to achieve and maintain hot standby 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 125Vdc systems as applicable; and d.

(if available) Logic diagrams showing the components used to achieve and maintain hot standby.

6. Corrective Actions:

a.

Listing of open and closed fire protection condition reports (i.e., problem identification forms and their resolution reports) since the last triennial fire protection inspection completed in May of 2018; b.

List of open and closed condition reports for post-fire nuclear safety capability issues the last triennial fire protection inspection completed in May of 2018. 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; and c.

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.

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REQUEST FOR INFORMATION 3

II.

Information Requested to Be Available on First Day of the FIRST ONSITE Inspection Week (August 18, 2025)

The following information is requested to be provided on the first day of inspection. It is requested that this information be provided electronically (searchable, if possible).

1. Program Procedures:

a.

List of maintenance procedures which routinely verify fuse breaker coordination in accordance with the post-fire safe shutdown coordination analysis (if available).

2.

Design and Equipment Information:

a. Coordination calculations and/or justifications that verify fuse/breaker coordination for SSCs that are fed off the same electrical buses as components in the protected safe shutdown train; b.

Copies of selected fire protection and post-fire safe shutdown related design change package (including their associated 10 CFR 50.59 evaluations) and Plant Change evaluations; c.

Alternating current (ac) coordination calculations for 4160Vac down to 480Vac electrical systems; and

d. List of all fire protection calculations.

3. Assessment and Corrective Actions:

The most recent fire protection Quality Assurance (QA) audits and/or fire protection self-assessments.

4. Any updates to information previously provided.

5.

Electrical:

a.

Maintenance procedures that verify breaker over-current trip settings to ensure coordination remains functional, for post-fire nuclear safety capability components; b.

Schematic or elementary diagrams for circuits (only for selected SSCs) to be reviewed (C-size paper drawings);

c.

Cable routing for selected SSCs credited for post-fire nuclear safety capability systems and components; and

d. List of identified fire induced circuit failure analyses for selected SSCs.

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REQUEST FOR INFORMATION 4

6. Operations a.

List of procedures that implement Recovery Actions and Repairs (if applicable for selected fire area);

b. For 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.

Last surveillance demonstrating operability of those components operated from the primary control stations; e.

Environmental and habitability evaluations for post-fire operator actions (temperature, smoke, humidity, SCBAs, etc.).

7. 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).

3. Facility Information a.

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 5

b.

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);

c.

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);

d.

Equipment location drawings which identify the physical plant locations of post-fire nuclear safety capability equipment (C-size paper drawings);

e.

Logic diagrams showing the components used to achieve and maintain hot standby (if available).