ML110200355

Notification to Perform a Triennial Fire Protection Baseline Inspection, IR 05000341-11-009 DRS

ML110200355
Person / Time
Site:	Fermi
Issue date:	01/20/2011
From:	Robert Daley Engineering Branch 3
To:	Jennifer Davis Detroit Edison
References
Download: ML110200355 (10)

See also: IR 05000341/2011009

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

January 20, 2011

Mr. Jack M. Davis

Senior Vice President and

Chief Nuclear Officer

Detroit Edison Company

Fermi 2 - 210 NOC

6400 North Dixie Highway

Newport, MI 48166

SUBJECT: FERMI POWER PLANT, UNIT 2 - NOTIFICATION TO PERFORM A TRIENNIAL

FIRE PROTECTION BASELINE INSPECTION; INSPECTION REPORT

05000341/2011-009(DRS)

Dear Mr. Davis

On March 23, 2011, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire

protection baseline inspection at your Fermi Power Plant, Unit 2. This inspection will be

performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs baseline fire

protection inspection procedure.

Based on the latest revision to IP 71111.05T, dated September 30, 2010, changes were made

to the IP 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 on-site week of the

inspection starting on March 23, 2011.

The schedule for the on-site inspection activity is as follows:

y Information Gathering Visit: March 21 - 23, 2011

y B.5.b Requirements: March 23 - 25, 2011; and

y Fire Protection Inspection: April 11 - 15, 2011 and April 25 - 29, 2011

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 Fermi 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.

J. Davis -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 March 7, 2011. 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 (March 21, 2011). 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 on-site

inspection week (April 11, 2011). 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

on-site portions of the inspection.

The lead inspector for this inspection is Mr. R. Langstaff. We understand that our regulatory

contact for this inspection is Mr. R. Salmon of your organization. If there are any questions

about the inspection or the material requested, please contact the lead inspector at (630) 829-

9747 or via e-mail at Ronald.Langstaff@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 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and

its enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document

J. Davis -3-

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 by R. A. Langstaff for/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-341

License Nos. NPF-43

Enclosure: Fire Protection Inspection Document Request

cc w/encl: Distribution via ListServ

FIRE PROTECTION INSPECTION DOCUMENT REQUESTS

Inspection Report: 05000341/2011-009(DRS)

On-site Inspection Dates: March 21 - 23, 2011 (Information Gathering Visit)

March 23 - 25, 2011 (B.5.b Requirements)

April 11 - 15, 2011 (Fire Protection Inspection)

April 25 - 29, 2011 (Fire Protection Inspection)

Inspection Procedures: IP71111.05T, Fire Protection (Triennial)

IP71152, "Identification and Resolution of Problems"

Inspectors: R. A. Langstaff, Senior Reactor Inspector

(630) 829-9747

Ronald.Langstaff@nrc.gov

G. M. Hausman, Senior Reactor Inspector

(630) 829-9743

George.Hausman@nrc.gov

D. Szwarc, Reactor Inspector

(630) 829-9803

Dariusz.Szwarc@nrc.gov

Observer: N. A. Valos

(630) 829-9761

Nicholas.Valos@nrc.gov

J. S. Bowen

(301) 415-3471

Jeremy.Bowen@nrc.gov

I. Information Requested Prior To the Information Gathering Visit

The following information is requested by March 7, 2011. If you have any questions

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

should be sent to R.A. Langstaff (e-mail address Ronald.Langstaff@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.

1 Enclosure

FIRE PROTECTION INSPECTION DOCUMENT REQUESTS

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 and license.

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.

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.

II. Information Requested During the Information Gathering Visit (MARCH 21, 2011)

The following information is requested to be provided to the inspection team during the

on-site information gathering visit. Except for Item 8, it is requested that the following

information be provided on three 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.e.

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. The facilitys license, including the fire protection license condition;

b. 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;

c. All licensing correspondence associated with the comparison to Standard Review

Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing purposes;

d. Exemptions from 10 CFR 50.48 and 10 CFR Part 50, Appendix R, and associated

licensing correspondence;

e. 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

2 Enclosure

FIRE PROTECTION INSPECTION DOCUMENT REQUESTS

f. For post-1979 plants, all licensing correspondence associated with the comparison

to Standard Review Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing

purposes.

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;

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.

3 Enclosure

FIRE PROTECTION INSPECTION DOCUMENT REQUESTS

5. Operations Response for Fire Protection:

a. Pre-fire plans for selected fire zones/areas (to be determined during information

gathering visit); and

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

alarm or annunciator;

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 on-site 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);

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;

4 Enclosure

FIRE PROTECTION INSPECTION DOCUMENT REQUESTS

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 (October 2008).

9. On-site 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; and

c. A tour of alternative shutdown and risk-significant fire areas.

III. Information Requested to be Available on First Day of the Second On-site Inspection

Week (APRIL 11, 2011)

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

requested that this information be provided on three 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

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.

5 Enclosure

FIRE PROTECTION INSPECTION DOCUMENT REQUESTS

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;

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

3. Assessment and Corrective Actions:

a. 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.

6 Enclosure

J. Davis -3-

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 by R. A. Langstaff for/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-341

License Nos. NPF-43

Enclosure: Fire Protection Inspection Document Request

cc w/encl: Distribution via ListServ

DISTRIBUTION:

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DATE 01/20/11 01/20/11

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