ML19105B142

Notification of Conduct of Triennial Fire Protection Baseline Inspection

ML19105B142
Person / Time
Site:	Millstone
Issue date:	04/11/2019
From:	Christopher Cahill Engineering Region 1 Branch 2
To:	Stoddard D Dominion Energy
Cahill C
References
Download: ML19105B142 (11)

Text

[Type here]

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 April 11, 2019 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Dominion Energy, Inc.

Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNITS 2 AND 3 - NOTIFICATION OF CONDUCT OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

Dear Mr. Stoddard:

The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff will conduct a triennial fire protection baseline inspection at Millstone Power Station, Units 2 and 3, beginning in July 2019. The inspection team will be led by Ms. Carey Bickett. The inspection will be conducted in accordance with Inspection Procedure 71111.05T, the NRC's baseline fire protection inspection procedure.

The schedule for the inspection is as follows:

Information Gathering Visit: July 9 - 11, 2019 On-Site Inspection: Weeks of July 22, 2019 and August 5, 2019 The purpose for the information gathering visit is to obtain information and documentation needed to support the inspection; to become familiar with the station fire protection programs, fire protection features, post-fire safe shutdown capabilities, plant layout, and mitigating strategies to address Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2); and obtain plant specific site access training and badging for unescorted access.

An initial list of the documents that the team will review during the conduct of the inspection are listed in Enclosures 1 and 2. The team leader will contact you with any additional specific document requests prior to the information gathering visit. Your cooperation and support during this inspection will be appreciated.

If you have questions concerning this inspection, or the inspection team's information request or logistical needs, please contact Ms. Carey Bickett, Team Leader at (610) 337-5317, or via e-mail at carey.bickett@nrc.gov.

D. Stoddard 2 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.

This letter, its enclosures, 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Christopher G. Cahill, Acting Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49

Enclosures:

1. Fire Protection Program Supporting Documentation

2. Mitigating Strategies Supporting Documentation cc: Distribution via ListServ

ML19105B142 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DRS RI/DRS NAME CBickett CCahill DATE 4/9/19 4/11/19 Fire Protection Program Supporting Documentation If you have any questions regarding this information request, please contact Ms. Carey Bickett at (610) 337-5317 or via e-mail at carey.bickett@nrc.gov.

Electronic format is preferred, except where specifically noted. 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. Paper records (hard copy) are acceptable. At the end of the inspection, the documents in the teams possession will not be retained.

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.

Due to the differences in both the design and operation between Millstone Units 2 and 3, the information is requested to be provided separately for each unit.

I. Information Requested Prior to the Information Gathering Visit Preferably no later than three weeks prior to the Information Gathering Visit, provide these documents to the inspection team leader in the Region I Office.

A. DESIGN AND LICENSING BASIS DOCUMENTS A.1 Post-Fire Safe Shutdown or Alternative Shutdown Analysis A.2 Fire Hazards Analysis A.3 Fire Probabilistic Risk Assessment (Fire PRA) Summary Document. If a Fire PRA is not available, please provide the Individual Plant Examination for External Events (Fire Chapter Only)

C. CLASSIC FIRE PROTECTION C.1. Pre-fire plans for all fire areas Based on review of the above documents, the team leader should 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.

Enclosure 1

2 II. Information Requested during the Information Gathering Visit On the first day of the information gathering visit, provide these documents to the inspection team:

A. DESIGN AND LICENSING BASIS DOCUMENTS A.5 Fire Protection Program and/or Fire Protection Plan A.6 Design Basis Document(s) for the following:

Fire Protection System Post-fire Safe Shutdown or Alternative Shutdown System A.7 LIST of applicable National Fire Protection Association (NFPA) codes and standards (i.e., codes of record)

A.8 NFPA Compliance Review Report (if available)

A.9 Report or evaluation that compares the fire protection program to the NRC Branch Technical Position (BTP) 9.5-1 Appendix A A.10 COPY of exemption requests submitted but not yet approved for plant fire protection and post-fire safe shutdown or alternative shutdown features A.11 Facility Operating License A.12 Technical Requirements Manual (electronic format only)

A.13 Updated Final Safety Analysis Report (Fire Protection Section only)

B. GENERAL PLANT DESIGN DOCUMENTS B.1 Piping and instrumentation diagrams for post-fire safe shutdown or alternative shutdown systems only (C-size paper drawings)

B.2 Piping and Instrumentation Diagrams and legend list for fire protection systems, including fire water supply, water suppression sprinklers & deluge, and CO2 & halon systems (C-size paper drawings)

B.3 Yard layout drawings for underground fire protection buried piping (C-size paper drawings)

B.4 Plant layout or hazard barrier drawings showing the fire area boundaries and combustible control zones (C-size paper drawings)

B.5 Alternating Current (AC) and direct current (DC) electrical system single line diagrams, from off-site power down to the highest safety-related bus level (e.g.,

typically 4kV diesel bus) (C-size paper drawings)

3 C. CLASSIC FIRE PROTECTION C.2 Impairment Log for fire protection features that are out of service C.3 COPY of fire protection program implementing procedures (e.g., administrative controls, surveillance testing, and fire brigade)

C.4 LIST of calculations and engineering analyses, studies, or evaluations for the fire protection system, including the fire water system C.5 Hydraulic calculation or analysis for fire protection water system C.6 Last two completed annual or 24-month fire pump pressure and flow tests. Include a copy of the most current revision of the test(s) if the procedure has been revised since the last performance of the test(s).

C.7 Last two completed monthly or quarterly fire pump tests. Include a copy of the most current revision of the test(s) if the procedure has been revised since the last performance of the test(s).

C.8 Last two completed fire loop flow tests and loop flushes. Include a copy of the most current revision of the test(s) if the procedure has been revised since the last performance of the test(s).

C.9 LIST of penetration seal work, re-work, or installation activities, in the last three years.

C.10 LIST of fire wrap work, re-work, or installation activities, in the last three years.

C.11 Last five hot work permits (at power).

C.12 Last five transient combustible permits (at power).

C.13 For Fire Brigade Drills, provide the following:

Last five fire brigade drill critiques Last drill critique for a drill with off-site fire department support Last unannounced drill which was critiqued by a qualified individual independent of the licensee's staff Last unannounced drill critique Last back-shift drill critique Dates, shifts, and locations of unannounced drills for last three years Summary of any unsatisfactory drill performance items for last three years C.14 For Fire Brigade Equipment, provide the following:

Procedure for inventory and inspection Most recent inspection and inventory results C.15 For emergency lighting units, provide the following:

LIST of preventive maintenance tasks and frequencies Most recently performed monthly or quarterly functional test

4 Most recently performed battery discharge performance test Emergency lighting unit battery loading analysis, for emergency lighting units that supply more than two light heads Vendor manual(s) for on-site inspector use Compensatory measures taken when emergency lighting units are out of service C.16 COPY of system health reports for the two most recent quarters, for the following:

Fire Protection System Fire Protection Program Emergency Lighting System C.17 LIST of all fire protection system impact screening reviews for design changes, modifications, or temporary modifications completed in the last three years (e.g., a Generic Letter 86-10 review that screened out). Include a short description/title of each change.

C.18 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)

C.19 Licensee evaluation of industry operating experience:

NRC IN 2009-29, Fire Pumps Fail to Start due to a Fire NRC IN 2016-08, Inadequate Work Practices Resulting in Faulted Circuit Breaker Connections NRC IN 2017-04, High Energy Arc Faults in Electrical Equipment Containing Aluminum Components NRC IN 2018-09, Electrical Arc Flash Caused by Foreign Material Damages Fire Door D. ELECTRICAL D.1 Last surveillance demonstrating operability of those components operated from the safe shutdown or alternative shutdown panel.

D.2 LIST of post-fire safe shutdown or alternative shutdown design changes completed in the last three years.

E. OPERATIONS E.1 LIST of calculations and engineering analyses, studies, or evaluations for the safe shutdown or alternative shutdown methodology.

E.2 Thermal hydraulic calculation or analysis that determined the time requirements for time-critical operator actions.

E.3 Calculation or analysis that demonstrates reactor water level will remain above the top of active fuel at the safe shutdown or alternative shutdown panel, in accordance with the requirements of 10 CFR Part 50, Appendix R, III.L performance goals.

E.4 Operating procedures for post-fire safe shutdown from the main control room (e.g., with a postulated fire in a 10 CFR Part 50 Appendix R III.G.2 fire area)

5 E.5 Operating procedures for post-fire safe shutdown from outside the main control room (e.g., with a postulated fire in a 10 CFR Part 50 Appendix R III.G.3 fire area)

E.6 For post-fire manual operator actions, provide the following:

Manual Action Feasibility Study Operator Time Critical Action Program Time lines for time-critical operator manual actions Time line validations E.7 Environmental and habitability evaluations for post-fire operator actions (temperature, smoke, humidity, self-contained breathing apparatus, etc.)

E.8 LIST of licensed operator job performance measures for operator manual actions required by post-fire safe shutdown or alternative shutdown.

E.9 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 job performance measures, in-field training walkdowns, simulations, or initial qualification).

E.10 Lesson plans for post-fire safe shutdown or alternative shutdown training for licensed and non-licensed operators.

E.11 For safe shutdown equipment and tools, provide the following:

Procedure for inventory and inspection Most recent inspection and inventory results E.12 LIST of procedures that implement Cold Shutdown Repairs.

E.13 For Cold Shutdown Repairs, provide the following:

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

Most recent inspection and inventory results.

E.14 COPY of NRC approved exemption requests for operator manual actions for 10 CFR Part 50 Appendix R III.G.2 fire areas.

F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION PROGRAMS F.1 LIST of corrective actions associated with post-fire safe shutdown or alternative shutdown operator manual actions for the last three years.

F.2 COPY of self-assessments, peer assessments, and audits of fire protection activities for the last three years.

F.3 COPY of self-assessments, peer assessments, and audits of the post-fire safe shutdown or alternative shutdown capabilities for the last three years.

F.4 LIST of open and closed condition reports for the fire protection system for the last three years.

6 F.5 LIST of open and closed condition reports for emergency lighting units for the last three years.

F.6 LIST of open and closed condition reports for post-fire safe shutdown or alternative shutdown issues for the last three years. This includes issues affecting the safe shutdown or alternative shutdown analysis, fire hazards analysis, safe shutdown or alternative shutdown operating procedures and/or training, timeline evaluations for operator actions, and supporting engineering evaluations, analysis, or calculations.

F.7 COPY of all Generic Letter 86-10 evaluations performed in the last three years.

F.8 COPY of the following condition reports:

1042283 1043063 1043417 1043422 1043425 1043455 1043458 1043959 1044278 1044301 1044326 1044332 1044334 1044348 1044422 1044536 1044760 III. Information Requested to be Available On-site on the First Day of the Inspection On the first day of the on-site inspection, provide these documents to the inspection team:

C. CLASSIC FIRE PROTECTION C.20 For the specific Penetration Seals selected during the information gathering visit, provide:

Qualification Records Design Specifications Installation details Inspection record which verified proper installation C.21 For the specific Fire Wraps selected during the information gathering visit, provide:

Qualification Records Design Specifications Installation details Inspection record which verified proper installation C.22 For the specific fire areas selected for inspection during the information gathering visit, provide the analysis of the effects of fire suppression activities which demonstrates the following:

A fire water pipe break in the selected fire areas, will not affect safe shutdown capability for equipment located in the selected fire areas A fire water pipe break in an adjacent fire area, will not affect safe shutdown 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 the fire areas below

7 C.23 For the specific fire areas selected for inspection during the information gathering visit, provide the last two completed surveillances of fire protection features (e.g.,

detection, suppression, damper inspections, damper tests, penetration inspections, barrier inspections, etc.)

C.24 COPY of the most current revision of the test, surveillance, or maintenance procedure for the items in C.27 if the procedure has been revised since the last performance of those tests.

C.25 For the specific fire areas selected for inspection during the information gathering visit, if any of the selected fire areas use CO2 or Halon, then provide the initial discharge testing, calculation, or analysis that determined appropriate concentrations and soak or hold times can be achieved D. ELECTRICAL D.3 For the specific electrical circuits selected for inspection during the information gathering visit, provide:

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

Cable block diagrams for circuits to be reviewed (C-size paper drawings)

D.4 For the specific fire areas selected for inspection during the information gathering visit, provide breaker and fuse coordination calculations or analysis for post-fire safe shutdown or alternative shutdown equipment in the selected areas D.5 Cable routing information, as requested during the information gathering visit.

Mitigating Strategies Supporting Documentation On the first day of the information gathering visit, provide these documents:

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 10 CFR 50.54(hh)(2).

H.2 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. If this is not available, provide a LIST of site-specific procedures or guidelines that are used to implement each strategy.

H.3 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies, provide the following:

LIST of routine tests, surveillances, and preventive maintenance COPY of the most recent inspection and inventory results H.4 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.

H.5 Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2).

H.6 Copies of memoranda of understanding (MOU) (e.g., with local fire departments) required to implement any mitigating strategies.

Enclosure 2