ML15204A829

IR 05000440/2015008, 09/21/15, Perry Nuclear Power Plant - Notification of NRC Triennial Fire Protection Baseline

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

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

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

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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

Enclosure

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.

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

2

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;

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

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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;

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

4

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);

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

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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.

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

6

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.

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

7

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.

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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OFFICE

RIII

RIII

RIII

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NAME

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GHausman for

RDaley

DATE

07/23/15

07/23/15

OFFICIAL RECORD COPY