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| issue date = 07/23/2015 | | issue date = 07/23/2015 | ||
| title = IR 05000440/2015008, 09/21/15, Perry Nuclear Power Plant - Notification of NRC Triennial Fire Protection Baseline | | title = IR 05000440/2015008, 09/21/15, Perry Nuclear Power Plant - Notification of NRC Triennial Fire Protection Baseline | ||
| author name = Daley R | | author name = Daley R | ||
| author affiliation = NRC/RGN-III/DRS/EB3 | | author affiliation = NRC/RGN-III/DRS/EB3 | ||
| addressee name = Harkness E | | addressee name = Harkness E | ||
Line 14: | Line 14: | ||
| page count = 11 | | page count = 11 | ||
}} | }} | ||
See also: [[ | See also: [[see also::IR 05000440/2015008]] | ||
=Text= | =Text= | ||
{{#Wiki_filter:UNITED STATES | {{#Wiki_filter:UNITED STATES | ||
NUCLEAR REGULATORY COMMISSION | |||
REGION III | |||
2443 WARRENVILLE RD. SUITE 210 | |||
-4352 | LISLE, IL 60532-4352 | ||
July 23, 2015 | |||
Mr. Ernest Harkness | |||
Site Vice President | |||
FirstEnergy Nuclear Operating Company | |||
Perry Nuclear Power Plant | |||
-PY- | P. O. Box 97, 10 Center Road, A-PY-A290 | ||
-0097 SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC TRIENNIAL | Perry, OH 44081-0097 | ||
SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC TRIENNIAL FIRE | |||
PROTECTION BASELINE INSPECTION REQUEST FOR INFORMATION | |||
05000440/2015008 | |||
Dear Mr. Harkness: | |||
On September 21, 2015, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial | |||
fire protection baseline inspection at your Perry Nuclear Power Plant. This inspection will be | |||
performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs baseline fire | |||
protection inspection procedure. | |||
Changes were made to the IP 71111.05T, which now requires the fire protection inspection to | |||
. | review your actions to mitigate postulated events that could potentially cause loss of large areas | ||
of power reactor facilities due to explosions or fires. This requirement was implemented by the | |||
issuance of the Interim Compensatory Measures Order EA-02-026, Section B.5.b and the | |||
subsequent requirements of 10 CFR 50.54(hh)(2), which are collectively referred to as B.5.b | |||
requirements. During this inspection, the B.5.b requirements review will be performed during | |||
- 23, 2015; | the first onsite week of the inspection starting on September 23, 2015. | ||
: | The schedule for the onsite inspection activity is as follows: | ||
- 25, 2015; and | Information Gathering Visit: September 21 - 23, 2015; | ||
B.5.b Requirements: September 23 - 25, 2015; and | |||
: | Fire Protection Inspection: October 5 - 9 and October 19 - 23, 2015. | ||
- 9 and October 19 | The purpose of the information gathering visit is: (1) to obtain information and documentation | ||
- 23, 2015. The purpose of the information gathering visit is: | needed to support the inspection; (2) to become familiar with the Perry Nuclear Power Plant fire | ||
protection programs, fire protection features, post-fire safe shutdown capabilities, and plant | |||
needed to support the inspection; (2) to become familiar with the | layout; and (3) to arrange administrative details, such as office space, availability of | ||
knowledgeable office personnel and to ensure unescorted site access privileges. | |||
-fire safe shutdown capabilities, and plant layout; and (3) to arrange administrative details | |||
, such as office space, availability of knowledgeable office personnel and to ensure unescorted site access privileges. | |||
in accordance with the post | E. Harkness -2- | ||
-fire safe shutdown coordination analysis. | Experience has shown that the baseline fire protection 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 | |||
-fire safe shutdown related design change package descriptions (including their associated | divided into four groups. The first group lists information necessary to aid the inspection team | ||
10 CFR 50.59 evaluations) and Generic Letter | in choosing specific focus areas for the inspection. It is requested that this information be | ||
provided to the lead inspector via mail or electronically no later than September 11, 2015. | |||
The second group also lists information and areas for discussion necessary to aid the inspection | |||
-operational testing, if applicable, for selected fire zones/areas (to be determined during information gathering visit | team in choosing specific fire protection focus areas for the inspection and to ensure that the | ||
); d. Hydraulic calculations and supporting test data which demonstrate operability for water suppression systems, if applicable, for selected fire zones/areas (to be determined during information gathering visit | inspection team is adequately prepared for the inspection. It is requested this information be | ||
); e. Alternating current (ac) coordination calculations for 4160Vac down to 480Vac electrical systems; | available during the information gathering visit (September 21, 2015). The third 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 second | |||
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REQUEST FOR INFORMATION | onsite inspection week (October 5, 2015). The fourth 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 | |||
-assessments. | onsite portions of the inspection. | ||
The lead inspector for this inspection is Mr. Dariusz Szwarc. We understand that our regulatory | |||
contact for this inspection is Mr. David Lockwood of your organization. If there are any | |||
questions about the inspection or the material requested, please contact the lead inspector at | |||
(630) 829-9803 or via e-mail at dariusz.szwarc@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 | |||
-rm/adams.html | 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. | |||
/RA George Hausman Acting for/ | In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public | ||
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy | |||
of this letter, its enclosure, and your response (if any) will be available electronically for public | |||
E. Harkness -3- | |||
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) | |||
-440 License No. NPF | component of the NRC's Agencywide Documents Access and Management System (ADAMS). | ||
-58 Enclosure: | ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html | ||
(the Public Electronic Reading Room). | |||
Sincerely, | |||
/RA George Hausman Acting for/ | |||
Robert C. Daley, Chief | |||
Engineering Branch 3 | |||
Division of Reactor Safety | |||
RidsNrrDorlLpl3 | Docket No. 50-440 | ||
-2 Resource | License No. NPF-58 | ||
Enclosure: Fire Protection Inspection | |||
Document Request | |||
cc w/encl: Distribution via LISTSERV | |||
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION | |||
REQUEST FOR INFORMATION | |||
Inspection Report: 05000440/2015008 | |||
Onsite Inspection Dates: September 21 - 23, 2015 (Information Gathering Visit) | |||
September 23 - 25, 2015 (B.5.b Requirements) | |||
October 5 - 9, 2015 (Fire Protection Inspection) | |||
October 19 - 23, 2015 (Fire Protection Inspection) | |||
Inspection Procedures: IP71111.05T, Fire Protection (Triennial) | |||
IP71152, "Identification and Resolution of Problems" | |||
Inspectors: Dariusz Szwarc Alan Dahbur | |||
OFFICE RIII | Senior Reactor Inspector (Lead) Senior Reactor Inspector | ||
(630) 829-9803 (630) 829-9810 | |||
dariusz.szwarc@nrc.gov alan.dahbur@nrc.gov | |||
George Hausman Robert Winter | |||
Senior Reactor Inspector Reactor Inspector | |||
(630) 829-9743 (630) 829-9758 | |||
george.hausman@nrc.gov robert.winter@nrc.gov | |||
I. Information Requested Prior To the Information Gathering Visit | |||
The following information is requested by September 11, 2015. If you have any questions | |||
regarding this request, please call the lead inspector as soon as possible. All information | |||
should be sent to Mr. Dariusz Szwarc (e-mail address dariusz.szwarc@nrc.gov). Electronic | |||
media is preferred. The preferred file format is a searchable pdf file on a compact | |||
disk (CD). The CD should be indexed and hyper-linked to facilitate ease of use, if possible. | |||
Please provide four copies of each CD submitted (one for each inspector). | |||
1. The most risk significant fire areas as determined by probabilistic risk analyses, if | |||
available. Otherwise, the reactor plant's Individual Plant Examination for External | |||
Events (IPEEE) for fire and results of any post-IPEEE reviews for fire. | |||
2. A copy of the current version of the fire protection program (FPP), fire hazards | |||
analysis (FHA), safe shutdown analysis (SSA), updated safety analysis report (USAR), | |||
technical specifications, license (including the fire protection license condition), and | |||
technical requirements manual (TRM) or equivalent for fire protection structures, | |||
systems, and components. | |||
3. A list of fire areas requiring alternative shutdown capability, (i.e., those areas for which | |||
10 CFR Part 50, Appendix R, Section III G requirements are satisfied under | |||
Section III.G.3), or where both safe shutdown trains can be affected. | |||
Enclosure | |||
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION | |||
REQUEST FOR INFORMATION | |||
4. Plant operating procedures which would be used and describe shutdown for a | |||
postulated fire (for both areas requiring alternative shutdown and areas which do not | |||
require alternative shutdown). Only those procedures with actions specific to shutdown | |||
in the event of a fire need be included. In addition, please include those procedures | |||
which operators would use for initial response to a fire, such as annunciator or alarm | |||
response procedures, the procedure used for activating the fire brigade, and the | |||
procedure which directs operators to the applicable safe shutdown procedure. | |||
5. Analysis performed in support of plant evaluation regarding multiple spurious operation | |||
(MSO), which includes the following: | |||
a. List of identified multiple spurious fire-induced circuit failure configurations; | |||
b. List of the generic and plant specific MSOs; | |||
c. Results of expert panel process and associated review/evaluation of the generic and | |||
plant-specific MSOs and existing safe shutdown analysis; and | |||
d. Evaluations and corrective actions taken for resolution of MSO issues. | |||
II. Information Requested During the Information Gathering Visit (SEPTEMBER 21, 2015) | |||
The following information is requested to be provided to the inspection team during the | |||
onsite information gathering visit. Except for Item 8, it is requested that the following | |||
information be provided on four sets of CDs (searchable, if possible) with the B.5.b | |||
Mitigating Strategies information (Items 8.a through 8.h) provided on one separate CD. | |||
In addition, one set of hard copy drawings are requested for Items 4.a. through 4.d. | |||
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 10 CFR 50.48 and 10 CFR Part 50, Appendix R, and associated | |||
licensing correspondence; | |||
2 | |||
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION | |||
REQUEST FOR INFORMATION | |||
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, FHA, | |||
and SSA in effect at the time of original licensing. | |||
3. Fire Protection Program: | |||
a. A listing of changes made to the 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 | |||
selected fire zones/areas (to be determined during information gathering visit). | |||
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); and | |||
e. List of plant deviations from code commitments and associated evaluations. | |||
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, those components used for those areas requiring alternative shutdown | |||
capability, and systems relied upon for B.5.b mitigation strategies. These can be | |||
of the type that are used for training; | |||
3 | |||
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION | |||
REQUEST FOR INFORMATION | |||
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 | |||
e. Safe shutdown cable routing database (requested electronically, such as on | |||
compact disc, if available). | |||
5. Operations Response for Fire Protection: | |||
a. Pre-fire plans for selected fire zones/areas (to be determined during information | |||
gathering visit); | |||
b. Plant operating procedures which specify the initial operations response to a fire | |||
alarm or annunciator; and | |||
c. Procedure for calling out the fire brigade and requesting off-site assistance. | |||
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. | |||
8. B.5.b Mitigating Strategies: | |||
a. A list of all modifications to regulatory commitments made to meet the | |||
requirements of Section B.5.b of the ICM Order, EA-02-026, dated | |||
February 25, 2002, the subsequently imposed license conditions, and | |||
10 CFR 50.54(hh)(2); | |||
4 | |||
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION | |||
REQUEST FOR INFORMATION | |||
b. Copies of procedures/guidelines that were revised or generated to implement the | |||
mitigation strategies. These could be extensive damage mitigation guidelines | |||
(EDMGs), severe accident management guidelines (SAMGs), emergency | |||
operating procedures (EOPs), abnormal operating procedures (AOPs), etc.; | |||
c. A matrix that shows the correlation between the mitigation strategies identified in | |||
Nuclear Energy Institute 06-12 and the site-specific procedures or guidelines that | |||
are used to implement each strategy; | |||
d. A listing of engineering evaluations/calculations that were used to verify | |||
engineering bases for the mitigation strategies; | |||
e. Copies of procedures used to inventory equipment (hoses, fittings, pumps, etc.) | |||
required to be used to implement the mitigation strategies; | |||
f. A list of B.5.b mitigating strategies, if any, which have implementing details that | |||
differ from that documented in the submittals and the safety evaluation report; | |||
g. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments) | |||
required to implement any mitigating strategies; and | |||
h. A list of changes made to B.5.b mitigating strategies and associated procedures | |||
since the previous NRC inspection of B.5.b mitigating strategies (March 13, 2012). | |||
9. Onsite Discussions: | |||
In addition, during the information gathering visit, it is requested that licensee staff be | |||
available for the following: | |||
a. Informal discussion on plant procedures operators would use in the event of fire or | |||
explosion (including B.5.b mitigation strategies) and under what conditions would | |||
the plant be shutdown using alternative shutdown methodology; | |||
b. Informal discussion on the plants safe shutdown cable routing database and the | |||
plant-wide cable routing database, as applicable; | |||
c. A tour of alternative shutdown and risk significant fire areas; and | |||
d. A discussion of scheduling of fire drills which may occur during the inspection so | |||
that the inspectors may be able to observe a fire drill, if possible. | |||
5 | |||
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION | |||
REQUEST FOR INFORMATION | |||
III. Information Requested to be Available on First Day of the Second ONSITE Inspection | |||
Week (OCTOBER 5, 2015) | |||
The following information is requested to be provided on the first day of inspection. It is | |||
requested that this information be provided on four 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: | |||
a. Coordination calculations and/or justifications that verify fuse/breaker | |||
coordination for selected fire zones/areas (to be determined during | |||
information gathering visit) 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 (to be determined during information gathering visit); | |||
d. Hydraulic calculations and supporting test data which demonstrate operability for | |||
water suppression systems, if applicable, for selected fire zones/areas (to be | |||
determined during information gathering visit); | |||
e. Alternating current (ac) coordination calculations for 4160Vac down to 480Vac | |||
electrical systems; and | |||
f. List of all fire protection or Appendix R calculations. | |||
6 | |||
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION | |||
REQUEST FOR INFORMATION | |||
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. | |||
IV. 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. | |||
7 | |||
E. Harkness -3- | |||
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) | |||
component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS | |||
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic | |||
Reading Room). | |||
Sincerely, | |||
/RA George Hausman Acting for/ | |||
Robert C. Daley, Chief | |||
Engineering Branch 3 | |||
Division of Reactor Safety | |||
Docket No. 50-440 | |||
License No. NPF-58 | |||
Enclosure: Fire Protection Inspection | |||
Document Request | |||
cc w/encl: Distribution via LISTSERV | |||
DISTRIBUTION w/encl: | |||
Kimyata MorganButler | |||
RidsNrrPMPerry Resource | |||
RidsNrrDorlLpl3-2 Resource | |||
RidsNrrDirsIrib Resource | |||
Cynthia Pederson | |||
Darrell Roberts | |||
Richard Skokowski | |||
Allan Barker | |||
Carole Ariano | |||
Linda Linn | |||
DRPIII | |||
DRSIII | |||
Jim Clay | |||
Carmen Olteanu | |||
ROPreports.Resource@nrc.gov | |||
ADAMS Accession Number ML15204A829 | |||
Publicly Available Non-Publicly Available Sensitive Non-Sensitive | |||
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy | |||
OFFICE RIII RIII RIII RIII | |||
NAME DSzwarc:jw GHausman for | |||
RDaley | |||
DATE 07/23/15 07/23/15 | |||
OFFICIAL RECORD COPY | |||
}} | }} |
Latest revision as of 23:25, 4 December 2019
ML15204A829 | |
Person / Time | |
---|---|
Site: | Perry |
Issue date: | 07/23/2015 |
From: | Robert Daley Engineering Branch 3 |
To: | Harkness E FirstEnergy Nuclear Operating Co |
References | |
IR 2015008 | |
Download: ML15204A829 (11) | |
See also: IR 05000440/2015008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, IL 60532-4352
July 23, 2015
Mr. Ernest Harkness
Site Vice President
FirstEnergy Nuclear Operating Company
Perry Nuclear Power Plant
P. O. Box 97, 10 Center Road, A-PY-A290
Perry, OH 44081-0097
SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC TRIENNIAL FIRE
PROTECTION BASELINE INSPECTION REQUEST FOR INFORMATION
Dear Mr. Harkness:
On September 21, 2015, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial
fire protection baseline inspection at your Perry Nuclear Power Plant. This inspection will be
performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs baseline fire
protection inspection procedure.
Changes were made to the IP 71111.05T, which now requires the fire protection inspection to
review your actions to mitigate postulated events that could potentially cause loss of large areas
of power reactor facilities due to explosions or fires. This requirement was implemented by the
issuance of the Interim Compensatory Measures Order EA-02-026, Section B.5.b and the
subsequent requirements of 10 CFR 50.54(hh)(2), which are collectively referred to as B.5.b
requirements. During this inspection, the B.5.b requirements review will be performed during
the first onsite week of the inspection starting on September 23, 2015.
The schedule for the onsite inspection activity is as follows:
Information Gathering Visit: September 21 - 23, 2015;
B.5.b Requirements: September 23 - 25, 2015; and
Fire Protection Inspection: October 5 - 9 and October 19 - 23, 2015.
The purpose of the information gathering visit is: (1) to obtain information and documentation
needed to support the inspection; (2) to become familiar with the Perry Nuclear Power Plant fire
protection programs, fire protection features, post-fire safe shutdown capabilities, and plant
layout; and (3) to arrange administrative details, such as office space, availability of
knowledgeable office personnel and to ensure unescorted site access privileges.
E. Harkness -2-
Experience has shown that the baseline fire protection 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 four groups. The first group lists information necessary to aid the inspection team
in choosing specific focus areas for the inspection. It is requested that this information be
provided to the lead inspector via mail or electronically no later than September 11, 2015.
The second group also lists information and areas for discussion necessary to aid the inspection
team in choosing specific fire protection focus areas for the inspection and to ensure that the
inspection team is adequately prepared for the inspection. It is requested this information be
available during the information gathering visit (September 21, 2015). The third 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 second
onsite inspection week (October 5, 2015). The fourth 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. Dariusz Szwarc. We understand that our regulatory
contact for this inspection is Mr. David Lockwood of your organization. If there are any
questions about the inspection or the material requested, please contact the lead inspector at
(630) 829-9803 or via e-mail at dariusz.szwarc@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.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy
of this letter, its enclosure, and your response (if any) will be available electronically for public
E. Harkness -3-
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
component of the NRC's Agencywide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
(the Public Electronic Reading Room).
Sincerely,
/RA George Hausman Acting for/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosure: Fire Protection Inspection
Document Request
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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
Inspection Report: 05000440/2015008
Onsite Inspection Dates: September 21 - 23, 2015 (Information Gathering Visit)
September 23 - 25, 2015 (B.5.b Requirements)
October 5 - 9, 2015 (Fire Protection Inspection)
October 19 - 23, 2015 (Fire Protection Inspection)
Inspection Procedures: IP71111.05T, Fire Protection (Triennial)
IP71152, "Identification and Resolution of Problems"
Inspectors: Dariusz Szwarc Alan Dahbur
Senior Reactor Inspector (Lead) Senior Reactor Inspector
(630) 829-9803 (630) 829-9810
dariusz.szwarc@nrc.gov alan.dahbur@nrc.gov
George Hausman Robert Winter
Senior Reactor Inspector Reactor Inspector
(630) 829-9743 (630) 829-9758
george.hausman@nrc.gov robert.winter@nrc.gov
I. Information Requested Prior To the Information Gathering Visit
The following information is requested by September 11, 2015. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Mr. Dariusz Szwarc (e-mail address dariusz.szwarc@nrc.gov). Electronic
media is preferred. The preferred file format is a searchable pdf file on a compact
disk (CD). The CD should be indexed and hyper-linked to facilitate ease of use, if possible.
Please provide four copies of each CD submitted (one for each inspector).
1. The most risk significant fire areas as determined by probabilistic risk analyses, if
available. Otherwise, the reactor plant's Individual Plant Examination for External
Events (IPEEE) for fire and results of any post-IPEEE reviews for fire.
2. A copy of the current version of the fire protection program (FPP), fire hazards
analysis (FHA), safe shutdown analysis (SSA), updated safety analysis report (USAR),
technical specifications, license (including the fire protection license condition), and
technical requirements manual (TRM) or equivalent for fire protection structures,
systems, and components.
3. A list of fire areas requiring alternative shutdown capability, (i.e., those areas for which
10 CFR Part 50, Appendix R, Section III G requirements are satisfied under
Section III.G.3), or where both safe shutdown trains can be affected.
Enclosure
NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
4. Plant operating procedures which would be used and describe shutdown for a
postulated fire (for both areas requiring alternative shutdown and areas which do not
require alternative shutdown). Only those procedures with actions specific to shutdown
in the event of a fire need be included. In addition, please include those procedures
which operators would use for initial response to a fire, such as annunciator or alarm
response procedures, the procedure used for activating the fire brigade, and the
procedure which directs operators to the applicable safe shutdown procedure.
5. Analysis performed in support of plant evaluation regarding multiple spurious operation
(MSO), which includes the following:
a. List of identified multiple spurious fire-induced circuit failure configurations;
b. List of the generic and plant specific MSOs;
c. Results of expert panel process and associated review/evaluation of the generic and
plant-specific MSOs and existing safe shutdown analysis; and
d. Evaluations and corrective actions taken for resolution of MSO issues.
II. Information Requested During the Information Gathering Visit (SEPTEMBER 21, 2015)
The following information is requested to be provided to the inspection team during the
onsite information gathering visit. Except for Item 8, it is requested that the following
information be provided on four sets of CDs (searchable, if possible) with the B.5.b
Mitigating Strategies information (Items 8.a through 8.h) provided on one separate CD.
In addition, one set of hard copy drawings are requested for Items 4.a. through 4.d.
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 10 CFR 50.48 and 10 CFR Part 50, Appendix R, and associated
licensing correspondence;
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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
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, FHA,
and SSA in effect at the time of original licensing.
3. Fire Protection Program:
a. A listing of changes made to the 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
selected fire zones/areas (to be determined during information gathering visit).
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); and
e. List of plant deviations from code commitments and associated evaluations.
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, those components used for those areas requiring alternative shutdown
capability, and systems relied upon for B.5.b mitigation strategies. These can be
of the type that are used for training;
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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
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
e. Safe shutdown cable routing database (requested electronically, such as on
compact disc, if available).
5. Operations Response for Fire Protection:
a. Pre-fire plans for selected fire zones/areas (to be determined during information
gathering visit);
b. Plant operating procedures which specify the initial operations response to a fire
alarm or annunciator; and
c. Procedure for calling out the fire brigade and requesting off-site assistance.
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.
8. B.5.b Mitigating Strategies:
a. A list of all modifications to regulatory commitments made to meet the
requirements of Section B.5.b of the ICM Order, EA-02-026, dated
February 25, 2002, the subsequently imposed license conditions, and
10 CFR 50.54(hh)(2);
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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
b. Copies of procedures/guidelines that were revised or generated to implement the
mitigation strategies. These could be extensive damage mitigation guidelines
(EDMGs), severe accident management guidelines (SAMGs), emergency
operating procedures (EOPs), abnormal operating procedures (AOPs), etc.;
c. A matrix that shows the correlation between the mitigation strategies identified in
Nuclear Energy Institute 06-12 and the site-specific procedures or guidelines that
are used to implement each strategy;
d. A listing of engineering evaluations/calculations that were used to verify
engineering bases for the mitigation strategies;
e. Copies of procedures used to inventory equipment (hoses, fittings, pumps, etc.)
required to be used to implement the mitigation strategies;
f. A list of B.5.b mitigating strategies, if any, which have implementing details that
differ from that documented in the submittals and the safety evaluation report;
g. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments)
required to implement any mitigating strategies; and
h. A list of changes made to B.5.b mitigating strategies and associated procedures
since the previous NRC inspection of B.5.b mitigating strategies (March 13, 2012).
9. Onsite Discussions:
In addition, during the information gathering visit, it is requested that licensee staff be
available for the following:
a. Informal discussion on plant procedures operators would use in the event of fire or
explosion (including B.5.b mitigation strategies) and under what conditions would
the plant be shutdown using alternative shutdown methodology;
b. Informal discussion on the plants safe shutdown cable routing database and the
plant-wide cable routing database, as applicable;
c. A tour of alternative shutdown and risk significant fire areas; and
d. A discussion of scheduling of fire drills which may occur during the inspection so
that the inspectors may be able to observe a fire drill, if possible.
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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
III. Information Requested to be Available on First Day of the Second ONSITE Inspection
Week (OCTOBER 5, 2015)
The following information is requested to be provided on the first day of inspection. It is
requested that this information be provided on four 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:
a. Coordination calculations and/or justifications that verify fuse/breaker
coordination for selected fire zones/areas (to be determined during
information gathering visit) 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 (to be determined during information gathering visit);
d. Hydraulic calculations and supporting test data which demonstrate operability for
water suppression systems, if applicable, for selected fire zones/areas (to be
determined during information gathering visit);
e. Alternating current (ac) coordination calculations for 4160Vac down to 480Vac
electrical systems; and
f. List of all fire protection or Appendix R calculations.
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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION
REQUEST FOR INFORMATION
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.
IV. 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.
7
E. Harkness -3-
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
Sincerely,
/RA George Hausman Acting for/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosure: Fire Protection Inspection
Document Request
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RidsNrrPMPerry Resource
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DRPIII
DRSIII
ROPreports.Resource@nrc.gov
ADAMS Accession Number ML15204A829
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE RIII RIII RIII RIII
NAME DSzwarc:jw GHausman for
RDaley
DATE 07/23/15 07/23/15
OFFICIAL RECORD COPY