ML23005A068

Notification of NRC Fire Protection Team Inspection Request for Information: Inspection Report 05000461/2023010

ML23005A068
Person / Time
Site:	Clinton
Issue date:	01/05/2023
From:	Kevin Barclay NRC/RGN-III/DORS/EB1
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023010
Download: ML23005A068 (1)

See also: IR 05000461/2023010

Text

David Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: CLINTON POWER STATION - NOTIFICATION OF NRC FIRE PROTECTION

TEAM INSPECTION REQUEST FOR INFORMATION: INSPECTION REPORT

05000461/2023010

Dear David Rhoades:

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

Region III staff will conduct a Fire Protection Team Inspection (FPTI) at your Clinton Power

Station beginning March 13, 2023. The inspection will be conducted in accordance with

IP 71111.21N.05, Fire Protection Team Inspection (FPTI), dated June 12, 2019.

The inspection will verify that plant Systems, Structures, and Components (SSCs) and/or

administrative controls credited in the approved Fire Protection Program (FPP) can perform

their licensing basis functions.

The schedule for the inspection is as follows:

Preparation week (R-III office): March 6 - 10, 2023

Week 1 of onsite inspection: March 13 - 17, 2023

Week 2 of onsite inspection: March 27 - 31, 2023

Experience has shown that the baseline fire protection team 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 three groups.

The first group lists information necessary to aid the inspection team in choosing specific focus

areas for the inspection and to ensure that the inspection team is adequately prepared for the

inspection. It is requested that this information be provided to the lead inspector via mail or

electronically no later than February 13, 2023.

The second group of requested documents consists of those items that the team will review, or

need access to, during the inspection. Please have this information available by the first day of

the first onsite inspection week March 13, 2023.January 5, 2023

D. Rhoades - 2 -

The third group lists the information necessary to aid the inspection team in tracking issues

identified as a result of the inspection. It is requested that this information be provided to the

lead inspector as the information is generated during the inspection.

It is important that all of these documents are up-to-date and complete in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of

the inspection.

The lead inspector for this inspection is Kevin Barclay. We understand that our regulatory

contact for this inspection is Chelsie Miller. If there are any questions about the inspection or the

material requested, please contact the lead inspector at 630-829-9885 or via email at

Kevin.Barclay@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.

This letter, its enclosure, 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 Title 10 of the Code of Federal Regulations 2.390, Public

Inspections, Exemptions, Requests for Withholding.

Sincerely,

Kevin Barclay, Senior Reactor Inspector

Engineering Branch 1

Division of Operating Reactor Safety

Docket No. 50-461

License No. NPF-62

Enclosure:

Information Request for Fire Protection

Team Inspection

cc: Distribution via LISTSERV

Signed by Barclay, Kevin

on 01/05/23

D. Rhoades - 3 -

Letter to David Rhoades from Kevin Barclay dated January 5, 2023.

SUBJECT: CLINTON POWER STATION - NOTIFICATION OF NRC FIRE PROTECTION

TEAM INSPECTION REQUEST FOR INFORMATION: INSPECTION REPORT

05000461/2023010

DISTRIBUTION:

Jessie Quichocho

Marc Ferdas

RidsNrrDorlLpl3

RidsNrrPMClinton Resource

RidsNrrDroIrib Resource

John Giessner

Julio Lara

Diana Betancourt-Roldan

Allan Barker

R3-DORS

ADAMS Accession Number: ML23005A068

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME KBarclay:gmp

DATE 01/05/2023

OFFICIAL RECORD COPY

I. Information Requested Prior to the Inspection Preparation Week

The following information is requested by February 13, 2023. If you have any questions

regarding this request, please call the lead inspector as soon as possible. All information

should be sent to Kevin Barclay (email address) Kevin.Barclay@nrc.gov. Electronic media is

preferred (e.g., via Share File System).

1. 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 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 Title 10 of the Code of Federal Regulations (10 CFR) 50.48 and

10 CFR Part 50, Appendix R, and associated licensing correspondence;

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 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 Fire Protection Program (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 fire

zones/areas. 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;

Enclosure

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);

e. List of plant deviations from code commitments and associated evaluations;

f. Fire Protection Program and/or Fire Protection Plan document;

g. (If available) Fire Probabilistic Risk Assessment (PRA) Summary Report or full PRA

document (if summary document not available);

h. List of the top 25 highest fire CDF scenarios for each unit;

i. List of Fire Areas/Zones ranked by contribution to CDF (i.e., ranking of highest to

lowest risk fire areas/zones);

j. List of the top 25 highest fire LERF scenarios for each unit; and

k. Risk ranking of operator actions and/or recovery actions from your site-specific PRA

sorted by Risk-Achievement Worth (RAW) and human reliability worksheets for these

items.

l. Fire Protection Program Procedures for:

i. Administrative controls (such as allowed out of service times and compensatory

measures) for fire protection systems and components; and

ii. Control of hot work and transient combustibles.

m. List of maintenance and surveillance testing procedures for alternative shutdown

capability and fire barriers, detectors, pumps, and suppression systems; and

n. List of maintenance procedures which routinely verify fuse breaker coordination in

accordance with the post-fire safe shutdown coordination analysis.

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, and

those components used for those areas requiring alternative shutdown capability;

b. One-line schematic drawings of the electrical distribution system for 4160 Volts

alternating current (Vac) down to 480Vac;

c. One-line schematic drawings of the electrical distribution system for 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

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e. Safe shutdown cable routing database (requested electronically, such as on compact

disc, if available).

5. Operations Response for Fire Protection:

a. Plant operating procedures which specify the initial operations response to a fire

alarm or annunciator.

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 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.

II. Information Requested to Be Available the First Day of the First Onsite

Inspection Week (March 13, 2023)

The following information is requested to be provided on the first day of inspection

(searchable, if possible).

1. Design and Equipment Information (only for selected fire zone/area(s) and/or SSCs):

a. Coordination calculations and/or justifications that verify fuse/breaker coordination for

SSCs 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;

d. Hydraulic calculations and supporting test data which demonstrate operability for

water suppression systems;

e. Alternating current (ac) coordination calculations for 4160Vac down to 480Vac

electrical systems; and

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f. List of all fire protection or Appendix R calculations.

2. Classic Fire Protection (only for selected fire zone/area(s) and/or SSCs):

a. Copy of FPP implementing procedures (e.g., administrative controls, surveillance

testing, and fire brigade);

b. Pre-fire plans for selected fire area(s); and

c. List of fire protection system design changes completed in the last 3 years.

3. Electrical (only for selected fire zone/area(s) and/or SSCs):

a. Nuclear safety circuit coordination analysis for fuse and breaker coordination of safe

shutdown components;

b. Administrative or configuration control procedures that govern fuse replacement

(e.g., fuse control procedures);

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

coordination remains functional, for post-fire nuclear safety capability components;

d. Last surveillance demonstrating operability of those components operated from the

primary control stations;

e. Schematic or elementary diagrams for circuits (only for selected SSCs) to be

reviewed (C-size paper drawings);

f. Cable routing for components and equipment credited for post-fire nuclear safety

capability systems and components;

g. List of post-fire nuclear safety capability system and component design changes

completed in the last 3 years; and

h. List of identified fire induced circuit failure analyses.

4. Operations:

a. List of procedures that implement Cold Shutdown Repairs (if applicable for selected

fire area);

b. For Cold Shutdown Repairs, provide the following:

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

ii. Most recent inspection and inventory results.

c. List of licensed operator Job Performance Measures for operator actions required to

achieve and maintain post-fire nuclear safety performance criteria (for selected SSCs

and fire area);

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d. For Radio communications, provide the following:

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

ii. Repeater locations;

iii. Cable routing for repeater power supply cables;

iv. Radio coverage test results; and

v. Radio Dead Spot locations in the plant.

e. Environmental and habitability evaluations for post-fire operator actions

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

5. Administrative Control, Oversight, and Corrective Action Programs:

a. Self-assessments, peer assessments, and audits of fire protection activities for

the last 3 years;

b. Self-assessments, peer assessments, and audits of post-fire nuclear safety

capability methodology for the last 3 years; and

c. List of fire event analysis reports for the last 3 years.

d. List of condition reports, temporary modifications, operator workarounds, and

compensatory measures for the last 3 years. (only for the selected fire protection

or post-fire SSD SSCs):

6. Maintenance and Testing (only for the selected fire protection or post-fire SSD

SSCs):

a. List of maintenance work requests, post-maintenance tests and surveillance

activities documented or performed over the last three years.

7. Aging Management Program

a. Copies of the aging management programs applicable to fire protection including but

not limited to the following:

i. Fire Protection

ii. Fire Water System

iii. Aboveground Metallic Tanks

iv. Buried and Underground Piping and Tanks

8. Any updates to information previously provided.

III. Information Requested to Be Provided Throughout the Inspection

1. Copies of any corrective action documents generated as a result of the inspection

teams questions or queries during this inspection.

2. Copies of the list of questions submitted by the inspection team members and the

status/resolution of the information requested (provided daily during the inspection to

each inspection team member).

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