IR 05000424/2020011

NRC Triennial Fire Protection Inspection Report 05000424/2020011 and 05000425/2020011

ML20300A460
Person / Time
Site:	Vogtle
Issue date:	10/26/2020
From:	Scott Shaeffer NRC/RGN-II/DRS/EB2
To:	Pitts R Southern Nuclear Operating Co
References
IR 2020011
Download: ML20300A460 (12)

Text

October 26, 2020

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION REPORT NO. 05000424/2020011 AND 05000425/2020011) AND REQUEST FOR INFORMATION (RFI)

Dear Mr. Pitts:

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

Region II staff will conduct a triennial fire protection baseline inspection at the Vogtle Electric Generating Plant in November and December 2020. The inspection team will be comprised of four inspectors from the NRC Region II office. The inspection will be conducted in accordance with Inspection Procedure 71111, Attachment 21N.05, Fire Protection Team Inspection, the NRCs baseline fire protection inspection procedure.

The schedule for the inspection is as follows:

• Week 1 of onsite inspection: November 30 - December 4, 2020

• Week 2 of onsite inspection December 14 - December 18, 2020 The inspection scope will require a walkdown of candidate fire areas/fire zones in company with key personnel from your staff. The enclosure to this letter provides an initial list of the documents the team will need for their review. We request that your staff transmit copies of the documents listed in the enclosure to the NRC Region II office for team use in preparation for the inspection. Please send this information so that it will arrive in the NRC Region II office by the dates listed in the enclosure. During scheduled phone calls, the team leader will discuss the following inspection support administrative details: (1) office space size and location; (2) specific documents requested to be made available to the team in their office spaces; (3) arrangements for reactor site access (including radiation protection training, security, safety, and fitness for duty requirements); and (4) 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 the success path necessary to achieve and maintain the nuclear safety performance criteria, 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). Also, personnel should be available at the site during the inspection who are knowledgeable regarding those plant systems required to achieve and maintain safe and stable plant conditions, including the electrical aspects of the fire protection plan, 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.

This letter and its enclosure 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.

Your cooperation and support during this inspection will be appreciated. If you have questions concerning this inspection or the inspection teams information or logistical needs, please contact Larry Jones, the team lead inspector, in the Region II office at (404) 997-4837 or larry.jones@nrc.gov or me at (404) 997-4521.

Sincerely,

/RA/

Scott Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-424, 50-425 License Nos. NPF-68, NPF-81 Enclosures:

Triennial Fire Protection Inspection Document Request cc w/enclosure: via ListsServ SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION REPORT NO. 05000424/2020011 AND 05000425/2020011) AND REQUEST FOR INFORMATION (RFI) dated October 26, 2020 Adams Accession : ML20300A460 SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials Publicly Avail Yes No Sensitive Yes No Sens. Type Initials RII:DRS/EB2 RII:DRS/EB2 S. Shaeffer L. Jones 10/26 /2020 10/26/2020 OFFICIAL RECORD COPY

Triennial Fire Protection Inspection Document Request The documents and information requested below should generally be made available to the inspection team prior to the inspection. Electronic format is the preferred format, except where specifically noted. If electronic files are made available via a secure document management service, then the remote document access must allow inspectors to download, save, and print the documents in the NRCs regional office.

If a secure document management service is utilized, it is recommended that a separate folder be used corresponding to each item listed below. Documents should be identified by both document number and noun name. Electronic media on compact disc or paper records (hard copy) are also acceptable.

To allow review for the team leader to identify a preliminary list of fire areas before in-office preparation, the documents requested in items A.1 thru A.22 should be made available to the team in the regional office no later than November 10, 2020.

Based on a review of the above items, the team leader will identify, the samples selected for inspection no later than November 18, 2020.

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.

Enclosure

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 The current version of the Fire Protection Program and Fire Hazards Analysis A.2 Post-fire safe shutdown analysis and the supporting calculations that demonstrate acceptable plant response.

A.3 The fire probabilistic risk assessment or portions of the plants individual plant examination for external events (IPEEE) report addressing fire events. Also, include the results of any post-IPEEE reviews and listings of actions taken/plant modifications conducted in response to IPEEE information that relate to fire risk A.4 Licensing basis documents for fire protection (safety evaluation reports, pertinent sections of the final safety analysis report, exemptions, deviations, letters to/from the NRC regarding fire protection/fire safe shutdown, etc.)

A.5 List of post-fire safe shutdown systems and components (i.e., safe shutdown equipment list).

A.6 List of fire areas with automatic fire suppression systems A.7 A list, with descriptions, of design change packages performed since the last fire protection team inspection associated with fire protection or post-fire safe shutdown systems.

A.8 A list, with descriptions, of any fire protection program changes and evaluations (not limited to Generic Letter 86-10 evaluations) performed since the last fire protection team inspection or LIST of deviations from (a) NFPA codes of record, A.9 Fire Protection System(s) Design Basis Document.

A.10 List of applicable NFPA codes and standards and issuance dates (i.e., codes of record).

A.11 A list or document identifying any deviations from the NFPA codes of record.

A.12 Facility Operating License.

A.13 Technical Specifications (electronic format only).

A.14 Updated Final Safety Analysis Report (electronic format only).

A.15 COPY of NRC Safety Evaluation Reports that form the licensing basis for:

• Fire Protection Program; and

• Post-fire Nuclear Safety Capability.

A.16 COPY of NRC approved exemptions for plant fire protection and post-fire nuclear safety capability features.

A.17 COPY of exemption requests submitted but not yet approved for plant fire protection and post-fire nuclear safety capability features.

A.18 LIST of nuclear safety capability design changes completed in the last three years (including their associated 10 CFR 50.59 evaluations).

A.19 List of the top 25 highest fire CDF scenarios for each unit A.20 List of the top 25 highest fire LERF scenarios for each unit A.21 From your most recent PRA including external events and fires:

a. Two risk rankings of components from your site-specific PRA: one sorted by Risk Achievement Worth (RAW), and the other sorted by Birnbaum Importance b. A list of the top 500 cut-sets A.22 Copy of the Quality Assurance Program Manual (including specific fire protection QA manual, if applicable)

B. GENERAL PLANT DESIGN DOCUMENTS (for the selected sampless)

B.1 Piping and instrumentation diagrams (P&IDs) and legend list for components used to achieve and maintain post-fire safe shutdown. These should include the systems used for reactor coolant system makeup, reactor coolant system pressure control, decay heat removal, and reactivity control, including the essential support systems.

B.2 Piping and instrumentation diagrams and legend list for fire protection systems, including the fire water supply; water suppression sprinklers; and deluge, CO2, and Halon systems (electronic format and C-size paper drawings).

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

B.4 AC and DC electrical system single line diagrams, from off-site power down to the highest safety-related bus level (typically 4kV, EDG bus) (electronic format and C-size paper drawings).

B.5 Single line diagrams for motor control centers (MCCs) that supply post-fire nuclear safety component loads (only for selected fire areas) (electronic format and C-size paper drawings).

B.6 Equipment location drawings which identify the physical plant locations of post-fire safe shutdown equipment (electronic format and C-size paper drawings).

B.7 Plant layout drawings which identify: (electronic format and C-size paper drawings)

• Plant fire area boundaries

• Combustible control zone drawings

• Areas protected by automatic fire suppression and detection

• Locations of fire protection equipment C. CLASSIC FIRE PROTECTION (for the selected samples)

C.1 Copy of fire protection program implementing procedures for the selected administrative program (e.g., administrative controls, surveillance testing, and 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 Last two completed surveillances of fire protection features in the selected fire areas (detection, suppression, damper inspections, damper tests, penetration inspections, barrier inspections, etc.).

C.4 List of routine tests, surveillances, and preventive maintenance on fire pumps, including pump controllers and batteries.

C.5 Last two completed annual fire pump pressure and flow tests.

C.6 Last two completed monthly and/or quarterly fire pump tests.

C.7 Last two completed fire loop flow tests and loop flushes.

C.8 Last five hot work permits (at power).

C.9 Last five transient combustible permits (at power).

C.10 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 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

• Last unannounced drill critique by a qualified individual independent of the licensees staff C.11 For fire brigade equipment provide the following:

• Procedure for inventory and inspection

• Most recent inspection and inventory results C.12 Fire Brigade Qualifications, including self-contained breathing apparatus, (SCBA)

and training lesson plans.

C.13 Copy of the mutual aid agreement for the first-due local fire department that is currently in effect.

C.14 Copy of the evaluation or analysis of the effects of fire suppression activities on the ability to achieve the nuclear safety performance criteria (only for selected suppression systems) demonstrating:

• The automatic or manually actuation of a suppression system, due to a fire in a single location, will not indirectly cause damage to the success path

• The inadvertent actuation or rupture of a suppression system will not indirectly cause damage to the success path

• Adequate drainage for areas protected by water suppression systems

• The 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.15 Pre-fire plans for all fire areas.

C.16 Impairment Log (at start of inspection) for fire protection features that are out of service.

C.17 List of penetration seal work, re-work, or installation activities, in the last three years.

C.18 List of fire wrap work, re-work, or installation activities, in the last three years.

C.19 Fire protection system health reports for the two most recent quarters.

C.20 Fire protection program health reports for the two most recent quarters.

C.21 Emergency lighting system health reports for the two most recent quarters.

C.22 List of fire protection system design changes completed in the last three years.

C.23 List of fire protection system engineering equivalency evaluations completed in the last three years.

C.24 Licensee evaluations of industry operating experience concerning fire protection issues completed in the last three years.

C.25 List of fire event analysis reports for the last three years.

C.26 Fire protection program requirements (e.g., limiting conditions for operation, surveillance test requirements) covered by technical specifications, the technical requirements manual, the updated final safety analysis report, procedures or similar documents.

C.27 Organization charts of site personnel down to the level of fire protection staff personnel.

C.28 A contact list of key site personnel who will be supporting this inspection, giving the office location and phone number onsite.

D. ELECTRICAL D.1 Administrative or configuration control procedures that govern fuse replacement (e.g., fuse control procedures)

E. OPERATIONS E.1 The team would like to perform a walkthrough of a sample of post-fire safe shutdown procedures with qualified operators in the plant during the weeks of inspection. Please put us in contact with the appropriate personnel for planning the walkthroughs during the onsite information gathering trip.

E.2 List of licensed operator Job Performance Measures (JPMs) for operator actions required to achieve and maintain post-fire safe shutdown.

E.3 List of non-licensed operator training associated with non-licensed operator actions to achieve and maintain post-fire nuclear safe shutdown (including JPMs, in-field training walkdowns, simulations, or initial qualification).

E.4 Lesson plans for post-fire safe shutdown training for licensed and non-licensed operators.

E.5 For local manual operator actions (Recovery Actions), provide the following:

• Manual Action Feasibility Study

• Operator Time Critical Action Program

• Time lines for time-critical manual actions

• Time line validations E.6 Thermal hydraulic calculation or analysis that determines the time requirements for time-critical manual operator actions.

E.7 Operating procedures to achieve and maintain post-fire safe shutdown with a postulated fire in the selected fire areas.

E.13 Environmental and habitability evaluations for post-fire safe shutdown operator actions (temperature, smoke, humidity, SCBAs, etc.).

F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION PROGRAMS F.1 Copies of procedures that control the configuration of the fire protection program, features, and post-fire safe shutdown methodology and system design. Also, copies of procedures that govern the implementation of plant modifications, maintenance, and special operations and their impact on fire protection.

F.2 List of open and closed condition reports for the fire protection systems for the last three years.

F.3 List of open and closed condition reports associated with the post-fire safe shutdown analysis for the last three years.

F.4 List of open and closed condition reports associated with operator actions to achieve and maintain post-fire safe shutdown for the last three years.

F.5 List of open and closed condition reports associated with the fire protection program including plant change evaluations, post-fire operating procedures and/or training, timeline evaluations for operator actions, and supporting engineering evaluations, analysis, or calculations for the last three years.

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

F.7 Self-assessments, peer assessments, and audits of fire protection activities for the last three years.

F.8 Self-assessments, peer assessments, and audits of post-fire nuclear safety capability methodology for the last three years.

F.9 Provide administrative procedures that control temporary modifications, permanent plant changes, design changes, procedure changes, ageing management changes, equivalency evaluations, suitability analyses, calculations, commercial grade dedication, safety-security interface, and repairs.

F.10 Provide procedures that control the following: combustible controls, hot work, monitoring, compensatory measures, work-around, and operability determination.

G. Aging Management Program G.1 Copies of the aging management programs applicable to fire protection including but not limited to the following:

• Fire Protection

• Fire Water System

• Aboveground Metallic Tanks

• Buried and Underground Piping and Tanks G.2 Copies of procedures, work orders, preventive maintenance tasks, or other documents which implement the commitments made as part of the license extension related to fire protection.

G.3 List of aging management activities related to fire protection performed to date.

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