ML18040A436

(Unit 1 and 2) - Notification of a Triennial Fire Protection Baseline Inspection (NRC Inspection Report Nos. 05000338/2018011 and 05000339/2018011)

ML18040A436
Person / Time
Site:	North Anna
Issue date:	02/05/2018
From:	Scott Shaeffer Division of Reactor Safety II
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
References
IR 2018011
Download: ML18040A436 (13)

See also: IR 05000338/2018011

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

February 5, 2018

Mr. Daniel G. Stoddard

Senior Vice President and

Chief Nuclear Officer

Innsbrook Technical Center

5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT: NORTH ANNA NUCLEAR PLANT (UNIT 1 AND 2) - NOTIFICATION OF A

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION

REPORT NOS. 05000338/2018011 AND 05000339/2018011)

Dear Mr. Heacock:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

staff will conduct a triennial fire protection baseline inspection at North Anna Nuclear Plant,

Units 1 and 2. The inspection team will be led by Rodney Fanner, a Senior Reactor Inspector

from the NRC Region II Office. The team will be composed of personnel from the NRC Region

II Office. The inspection will be conducted in accordance with IP 71111.05T, the NRC's

baseline fire protection inspection procedure, dated January 31, 2013.

On January 30, 2018, during a telephone conversation between Mr. D. Taylor, Licensing, and

Mr. R. Fanner of our respective staffs confirmed arrangements for an onsite information-

gathering visit and two-weeks of onsite inspection. The schedule for the inspection is as

follows:

• Information Gathering Visit: April 2 - 4, 2018

• Week 1 of onsite inspection: May 7- 11, 2018

• Week 2 of onsite inspection: May 21- 25, 2018

The purposes of the information gathering visit are to obtain information and documentation

needed to support the inspection, to become familiar with the North Anna Nuclear Plant fire

protection program, fire protection features, post-fire safe shutdown capabilities, plant layout,

mitigating strategies to address Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)

(2); and, as necessary, obtain plant specific site access training and badging for unescorted site

access.

An initial list of the documents the team will review during the conduct of the inspection is listed

in Enclosures 1 and 2. The team leader will contact you with any additional specific document

requests prior to the information gathering visit.

D. Stoddard 2

During the information gathering visit, the team will also discuss the following inspection support

administrative details: office space size and location; specific documents requested to be made

available to the team in their office spaces; arrangements for reactor site access (including

radiation protection training, security, safety and fitness for duty requirements); and the

availability of knowledgeable plant staff and licensing organization personnel to serve as points

of contact during the inspection.

We request that during the on-site inspection weeks you ensure that copies of analyses,

evaluations or documentation regarding the implementation and maintenance of the station fire

protection program, including post-fire safe shutdown capability, be readily accessible to the

team for their review. Of specific interest for the fire protection portion of the inspection are

those documents which establish that your fire protection program satisfies NRC regulatory

requirements and conforms to applicable NRC and industry fire protection guidance (i.e., fire

protection compliance assessment documents). For the 10 CFR 50.54(hh) (2) portion of the

inspection, those documents implementing your mitigating strategies and demonstrating the

management of your commitments for the strategies are of specific interest. Also, personnel

should be available at the site during the inspection that is knowledgeable regarding those plant

systems required to achieve and maintain safe shutdown conditions from inside and outside the

control room, including the electrical aspects of the relevant post-fire safe shutdown analyses,

reactor plant fire protection systems and features, and the station fire protection program and its

implementation.

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, under 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.

In accordance with 10 CFR 2.390 of the NRC Rules and Practices, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC Public Document

Room or from the Publically Available Records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.hmtl (the Public Electronic Reading Room).

D. Stoddard 3

Your cooperation and support during this inspection will be appreciated. If you have questions

concerning this inspection, or the inspection team's information or logistical needs, please

contact Rodney Fanner, the team leader, in the Region II Office at 404-997-4638 or me at

404-997-4521.

Sincerely,

/RA/

Scott M. Shaeffer, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos.: 50-338; 50-339

License No.: DPR-32 and DPR-37

Enclosures:

1. Triennial Fire Protection Inspection Supporting Documentation

2. Mitigating Strategies Supporting Documentation

cc: Distribution via Listserv

_ _____________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED

OFFICE RII:DRS RII:DRS

SIGNATURE RJF2 SMS

NAME R. Fanner S. Shaeffer

DATE 1/30/2018 2/5/2018

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

Triennial Fire Protection Inspection Supporting Documentation

The documents and information requested below should generally be made available to the

inspection team during the on-site information gathering visit for the team's use both on-site and

off-site during the inspection. Electronic format is the preferred media, except where specifically

noted, if readily available (The preferred file format is searchable .pdf files). If electronic media

is made available via an internet based remote document management system, then the remote

document access must allow inspectors to download, save, and print the documents in the

NRC's regional office. Electronic media on compact disc or paper records (hard copy) are

acceptable. At the end of the inspection, the documents in the team's possession will not be

retained.

Approximately three weeks before the on-site information gathering visit, the following

documents should be made available to the team leader for review in the regional office:

• Post-fire Safe Shutdown or Alternative Shutdown Analysis (request A.1)

• Fire Hazards Analysis (request A.2)

• Individual Plant Examination for External Events (Fire Chapter ONLY) (request A.3)

Based on review of the above three documents, the team leader will identify a preliminary list of

fire areas being considered for inspection prior to the on-site information gathering visit. During

the information gathering visit, or shortly thereafter, the fire areas selected for inspection will be

determined.

This document request is based on typical documents that a generic plant might have. As such,

this generic document request is not meant to imply that any specific plant is required to have all

of the listed documents. It is recognized that some documents listed below may not be

available for your plant. In addition, the document titles listed below are based on typical

industry document names; your plant specific document titles may vary.

A. DESIGN AND LICENSING BASIS DOCUMENTS

A.1 Post-fire Safe Shutdown or Alternative Shutdown Analysis.

A.2 Fire Hazards Analysis.

A.3 Individual Plant Examination for External Events (IPEEE) (Fire Chapter ONLY),

including:

• Results of any post-IPEEE reviews; and

• LIST of actions taken or plant modifications performed in response to the IPEEE

results.

A.4 Fire Protection Program and/or Fire Protection Plan.

Enclosure 1

2

A.5 LIST of post-fire safe shutdown or alternative shutdown systems (i.e., safe shutdown

equipment list).

A.6 Fire Protection System Design Basis Document.

A.7 Post-fire Safe Shutdown or Alternative Shutdown Design Basis Document.

A.8 LIST of applicable NFPA codes and standards and issuance dates (i.e., codes of

record).

A.9 LIST of deviations from NFPA codes of record.

A.10 NFPA Compliance Review Report.

A.11 Report or evaluation that compares the fire protection program to the NRC Branch

Technical Position (BTP) 9.5-1 Appendix A.

A.12 Electronic copy of licensee submittals and NRC safety evaluation reports that are

specifically listed in the facility operating license for the approved fire protection

program.

A.13 NRC Safety Evaluation Reports for fire protection program and post-fire safe

shutdown or alternative shutdown features.

A.14 NRC approved exemptions for plant fire protection and post-fire safe shutdown or

alternative shutdown features.

A.15 Exemption requests submitted but not yet approved for plant fire protection and post-

fire safe shutdown or alternative shutdown features.

A.16 Facility Operating License (electronic format only).

A.17 Technical Specifications (electronic format only).

A.18 Technical Requirements Manual (electronic format only).

A.19 Updated Final Safety Analysis Report (electronic format only).

B. GENERAL PLANT DESIGN DOCUMENTS

B.1 Piping and instrumentation diagrams (P&IDs) and legend list for post-fire safe

shutdown or alternative shutdown systems (C-size paper drawings and electronic

copy).

B.2 P&IDs and legend list for fire protection systems, including fire water supply, water

suppression sprinklers & deluge, and CO2 and Halon systems (C-size paper

drawings and electronic copy).

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B.3 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 and

electronic copy ).

B.4 Single line diagrams for motor control centers (MCCs) that supply post-fire safe

shutdown or alternative shutdown loads (only for selected fire areas) (C-size paper

drawings and electronic copy ).

B.5 Equipment location drawings which identify the physical plant locations of post-fire

safe shutdown or alternative shutdown equipment (C-size paper drawings and

electronic copy).

B.6 Plant layout drawings which identify: (C-size paper drawings and electronic copy)

• Plant fire area boundaries;

• Combustible control zone drawings;

• Areas protected by automatic fire suppression and detection; and

• Locations of fire protection equipment.

C. CLASSICAL FIRE PROTECTION

C.1 Fire protection program implementing procedures (e.g., administrative controls,

surveillance testing, fire brigade).

C.2 LIST of calculations and engineering analyses, studies, or evaluations for the fire

protection system, including the fire water system.

C.3 Hydraulic calculation or analysis for fire protection water system in the selected fire

areas.

C.4 Last two completed surveillance's records of fire protection features in the selected

fire areas (detection, suppression, damper inspections, damper tests, penetration

inspections, barrier inspections, etc.).

C.5 LIST of routine tests, surveillances, and preventive maintenance on fire pumps,

including pump controllers and batteries.

C.6 Last two completed annual fire pump pressure and flow tests.

C.7 Last two completed monthly and/or quarterly fire pump tests.

C.8 Last two completed fire loop flow tests and loop flushes.

C.9 CO2 and Halon initial discharge testing or calculation that determined appropriate

concentrations and soak or hold times can be achieved (only for selected fire areas).

C.10 Last five hot work permits (at power).

C.11 Last five transient combustible permits (at power).

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C.12 For Fire Brigade Drills, provide the following:

• Last drill critique for a drill with off-site fire department support;

• Summary of any unsatisfactory drill performance items for last three years; and

• Last unannounced drill critique by a qualified individual independent of the

licensee's staff.

C.13 For fire brigade equipment provide the following:

• Procedure for inventory and inspection; and

• Most recent inspection and inventory results.

C.14 Fire Brigade Medical Evaluations and Qualifications, including self-contained

breathing apparatus (SCBA) and training lesson plans.

C.15 Electronic copy of the mutual aid agreement for the first-due local fire department

that is currently in effect.

C.16 Flooding analysis for selected fire areas which demonstrates:

• a fire water pipe break in the selected fire areas, wont affect safe shutdown (SSD)

capability for equipment in the selected fire areas;

• a fire water pipe break in an adjacent fire area, wont affect SSD capability for

equipment in the selected fire areas;

• hydrostatic rating of any floor penetration seals installed within the fire areas that

are credited with keeping water from leaking into fire areas below.

C.17 Pre-fire plans for the selected fire areas and their adjacent fire areas.

C.18 For Emergency Lighting Units (ELU), provide the following:

• LIST of Preventive Maintenance tasks, frequencies, and bases;

• Most recently performed monthly or quarterly functional test;

• Most recently performed battery discharge performance test; if applicable

• ELU battery loading analysis;

• vendor manual(s);

• results of black-out testing (if performed);

• Maintenance Rule program information related to the ELU, if applicable; and

• Compensatory measures taken when ELU are out of service.

C.19 Fire Impairment Log (for period of 3 months before the start of inspection), for fire

protection features that are out of service.

C.20 LIST of Fire Protection screening reviews since the last inspection for recent design

changes, modifications, or temporary modifications (e.g., a Generic Letter 86-10

review that screened out).

C.21 LIST of fire protection system design changes completed in the last three years

(including their associated 10 CFR 50.59 and Generic Letter 86-10 evaluations).

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C.22 LIST of penetration seal work, re-work, or installation activities, in the last three years.

C.23 LIST of fire wrap work, re-work, or installation activities, in the last three years.

C.24 Fire protection system health reports for the two most recent years.

C.25 Fire protection program health report for the two most recent years.

C.26 Emergency lighting system health reports for the two most recent years.

C.27 Licensee evaluation of industry operating experience, related to the Fire Protection

Program for the three most recent years.

D. ELECTRICAL

D.1 Identify whether the cables in the selected fire areas are predominantly Thermoset or

Thermoplastic. Specifically identify any Thermoplastic cable in the selected fire

areas.

D.2 Breaker and fuse coordination calculation for post-fire safe shutdown or alternative

shutdown equipment (only for selected fire areas).

D.3 Administrative or configuration control procedures that govern fuse replacement (e.g.,

fuse control procedures).

D.4 Maintenance procedures that verify breaker over-current trip settings to ensure

coordination remains functional, for post-fire safe shutdown or alternative shutdown

equipment.

D.5 Electrical system health reports for the two most recent years.

D.6 Last completed preventive maintenance of those components as tested from the safe

shutdown or alternative shutdown panel.

D.7 Schematic or elementary diagrams for circuits to be reviewed, as requested by

inspector (C-size paper drawings and electronic copy).

D.8 Cable routing for components and equipment credited for post-fire safe shutdown or

alternative shutdown (only for selected fire areas).

D.9 LIST of post-fire safe shutdown or alternative shutdown design changes completed,

since the last inspection.

E. SPURIOUS FIRE INDUCED CIRCUIT FAULTS

E.1 LIST of identified fire induced circuit failure configurations (only for selected fire

areas).

E.2 Multiple Spurious Operation (MSO) Expert Panel Report.

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E.3 Corrective actions for fire-induced circuit failures, both single and multiple spurious

actuations for the selected fire areas.

F. OPERATIONS

F.1 LIST of calculations and engineering analyses, studies, or evaluations for the safe

shutdown or alternative shutdown methodology.

F.2 LIST of licensed operator Job Performance Measures (JPMs) for operator manual

actions required by post-fire safe shutdown or alternative shutdown.

F.3 LIST of non-licensed operator training associated with post-fire safe shutdown or

alternative shutdown manual actions which would be performed by a non-licensed

operator (including JPMs, in-field training walkdowns, simulations, or initial

qualification).

F.4 LIST of lesson plans for post-fire safe shutdown or alternative shutdown training for

licensed and non-licensed operators.

F.5 For operator manual actions (OMAs) provide the following:

• Manual Action Feasibility Study;

• Operator Time Critical Action Program;

• Time lines for time-critical OMAs; and

• Time line validations.

• Environmental and habitability evaluations for post-fire operator manual actions

(temperature, smoke, humidity, SCBAs, etc.).

F.6 Thermal hydraulic calculation or analysis that determines the time requirements for

time-critical manual operator actions.

F.7 Operating procedures for post-fire safe shutdown from the control room with a

postulated fire in the selected fire areas.

F.8 Operating procedures for post-fire safe shutdown or alternative shutdown from

outside the control room.

F.9 For safe shutdown equipment and tools, provide the following:

• Procedure for inventory and inspection; and

• Most recent inspection and inventory results.

F.10 LIST of procedures that implement Cold Shutdown Repairs.

F.11 For Cold Shutdown Repairs, provide the following:

• Procedure for inventory and inspection (i.e., needed tools, material, etc.); and

• Most recent inspection and inventory results.

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F.12 Calculation or analysis that demonstrates pressurizer level will remain within the

indicating range for a PWR, or reactor water level will remain above the top of active

fuel for a BWR, at the safe shutdown or alternative shutdown panel, in accordance

with the requirements of 10 CFR 50 Appendix R III.L performance goals.

F.13 For Radio communications, provide the following:

• Communications Plan for firefighting and post-fire safe shutdown manual actions;

• Repeater locations;

• Cable routing for repeater power supply cables;

• Radio coverage test results; and

• Radio Dead Spot locations in the plant.

F.14 NRC approved exemption requests for operator manual actions for

10 CFR 50 Appendix R III.G.2 fire areas.

F.15 Exemption requests submitted but not yet approved, for operator manual actions for

10 CFR 50 Appendix R III.G.2 fire areas.

G. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION PROGRAMS

G.1 Corrective actions for fire-induced circuit failures (including but not limited to NRC

IN 92-18), both single and multiple spurious actuations (only for selected fire areas).

G.2 Corrective actions associated with post-fire safe shutdown or alternative shutdown

operator manual actions.

G.3 Internal and external self assessments, peer assessments, and audits of fire

protection activities for the last three years.

G.4 Internal and external self assessments, peer assessments, and audits of post-fire

safe shutdown or alternative shutdown capabilities for the last three years.

G.5 LIST of condition reports for the fire protection system for the last three years.

G.6 LIST of condition reports for emergency lighting units for the last three years.

G.7 LIST of condition reports for post-fire safe shutdown (SSD) or alternative shutdown

(ASD) issues for the last three years. This includes issues affecting the SSD or ASD

analysis, fire hazards analysis, SSD or ASD operating procedures and/or training,

timeline evaluations for operator actions, and supporting engineering evaluations,

analysis, or calculations.

G.8 LIST of all Generic Letter 86 - 10 evaluations. (If applicable, copy of all Generic Letter

86 - 10 evaluations performed in the last three years.

G.9 All fire loading calculations and evaluations performed (only for selected fire areas

and their adjacent fire areas).

G.10 Administrative control, corrective action, and oversight program implementing

procedures.

Mitigating Strategies Supporting Documentation

H. 10 CFR 50.54(hh)(2) MITIGATING STRATEGIES DOCUMENTS

H.1 LIST of all changes to regulatory commitments made to meet the requirements of

Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2).

H.2 LIST of procedures and guidelines that were revised or generated to implement the

mitigating strategies. These could be extensive damage mitigation guidelines

(EDMGs), severe accident management guidelines (SAMGs), emergency operating

procedures (EOPs), abnormal operating procedures (AOPs), etc.

H.3 A matrix that shows the correlation between the mitigation strategies identified in

Nuclear Energy Institute 06-12, Revision 2, "B.5.b Phase 2 & 3 Submittal Guideline,"

issued December 2006, and the site-specific procedures or guidelines that are used

to implement each strategy.

H.4 LIST of engineering evaluations or calculations that were used to verify the

engineering bases for the mitigating strategies.

H.5 Piping and instrumentation diagrams (P&ID) and legend list or simplified flow

diagrams for systems relied upon in the mitigating strategies. These could be the

type used for training. (C-size paper drawings and electronic copy)

H.6 LIST of modification packages or summary descriptions of modifications with

simplified drawings, for necessary facility changes to implement the mitigating

strategies.

H.7 LIST of routine tests, surveillances, and preventive maintenance for equipment and

tools needed to implement 10 CFR 50.54(hh)(2) strategies.

H.8 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies,

provide the following:

• Procedures for inventory, testing, and inspection; and

• Most recent inspection, inventory, and testing results.

• Copies of the last two completed performance tests, surveillances, and

preventative maintenance performed on the pumps, including the pump

controllers and batteries.

H.9 LIST of 10 CFR 50.54(hh)(2) strategies, if any, which have implementing details that

differ from that documented in the submittals or the safety evaluation report.

Enclosure 2

2

H.10 Site general arrangement drawings that show the majority of buildings and areas

referenced in 10 CFR 50.54(hh)(2) documents (C-size paper drawings and electronic

copy).

H.11 Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2).

H.12 Copies of memoranda of understanding (MOU) (e.g., with local fire departments)

required to implement any mitigating strategies.

H.13 Docketed correspondence for 10 CFR 50.54(hh) to include license amendment

requests (LARS); Safety Evaluation Reports (SER); Request for Information (RFI)

and associated responses; and other pertinent documents.