IR 05000280/2018007

(Unit 1 and Unit 2) - Notification of a Triennial Fire Protection Baseline Inspection, U.S. Nuclear Regulatory Commission Inspection Report Nos. 05000280/2018007 and 05000281/2018007

ML17335A202
Person / Time
Site:	Surry
Issue date:	11/29/2017
From:	Shaeffer S M Division of Reactor Safety II
To:	Stoddard D G Virginia Electric & Power Co (VEPCO)
References
IR 2018007
Download: ML17335A202 (13)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 November 29, 2017

Mr. Daniel Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT: SURRY NUCLEAR PLANT (UNIT 1 AND UNIT 2) - NOTIFICATION OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION, U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NOS. 05000280/2018007 AND 05000281/2018007

Dear Mr. Stoddard:

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

staff will conduct a triennial fire protection baseline inspection at Surry Nuclear Plant, Units 1 and 2. Rodney Fanner, Senior Reactor Inspector, will be the inspection team leader from the NRC Region II office. The additional team members will be composed of personnel from the NRC Region II office. The inspection will be co nducted in accordance with IP 71111.05T, the NRC's baseline fire protection inspection procedure, dated January 31, 2013.

On November 16, 2017, during a telephone conversation between Mr. Barry Garber, Licensing, and Mr. Rodney Fanner, the respective staff confirmed arrangements for an information gathering onsite visit and a two-week onsite inspection. The schedule for the inspection is as follows:

• Information gathering visit: January 16 - 18, 2018

• Week 1 of onsite inspection: February 26 - March 02, 2018

• Week 2 of onsite inspection: March 12 - 16, 2018 The purposes of the information gathering visit are to obtain information and documentation needed to support the inspection, to become familiar with the Surry Nuclear Plant fire protection program, fire protection features, post-fire safe shutdown capabilities, plant layout, mitigating strategies to address Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2), and, as necessary, obtain plant specific site access training and badging for unescorted site access.

An initial list of the documents the team will review during the conduct of the inspection is listed in Enclosures 1 and 2. The team leader will contact you with any additional specific document requests prior to the information-gathering visit. During the information-gathering visit, the team will also discuss the following inspection support administrative details: office space and location; specific documents requested to be made available to the team in their office spaces; arrangements for reactor site access (including radiation protection training, security, safety, and fitness for duty requirements); and 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 post-fire safe shutdown capability, 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). For the 10 CFR 50.54(hh)(2) portion of the inspection, those documents implementing your mitigating strategies and demonstrating the management of your commitments for the strategies are of specific interest. Also, personnel should be available at the site during the inspection who are knowledgeable regarding those plant systems required to achieve and maintain safe shutdown conditions from inside and outside the control room, including the electrical aspects of the relevant post-fire safe shutdown analyses, 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.

In accordance with 10 CFR 2.390 of the NRC Rules and Practices, a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Reco rds System (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.hmtl (the Public Electronic Reading Room). Your cooperation and support during this inspection will be appreciated. If you have questions concerning this inspection, or the inspection team's information or logistical needs, please contact Rodney Fanner, the team leader in the Region II office at 404-997-4683 or me at 404-

997-4521.

Sincerely,/RA/

Scott M. Shaeffer, Chief Engineering Branch 2

Division of Reactor Safety

Docket Nos.: 50-280; 50-281 License No.: DPR-32 and DPR-37

Enclosures:

1. Triennial Fire Protection Inspection Supporting Documentation 2. Mitigating Strategies Supporting Documentation

cc: Distribution via Listserv

____________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS RII:DRS SIGNATURE RJF2 SMS NAME RFANNER SSHAEFFER DATE 11/ 29/2017 11/29/2017 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO Enclosure 1 TRIENNIAL FIRE PROTECTION INSPECTION SUPPORTING DOCUMENTATION The documents and information requested below should generally be made available to the inspection team during the on-site information-gathering visit for the team's use both on-site and off-site during the inspection. Electronic format is the preferred media, except where specifically noted, if readily available the preferred file format is searchable PDF files. 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. Electronic media on com pact disc or paper records (hard copy) are acceptable. At the end of the inspection, the documents in the team's possession will not be retained. Approximately three weeks before the on-site information-gathering visit, the following documents should be made available to the team leader for review in the regional office:

• Post-fire Safe Shutdown or Alternative Shutdown Analysis (request A.1)

• Fire Hazards Analysis (request A.2)

• Individual Plant Examination for External Events (Fire Chapter ONLY) (request A.3)

Based on review of the above three documents, the team leader will 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.

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 Post-fire Safe Shutdown or Alternative Shutdown Analysis. A.2 Fire Hazards Analysis.

A.3 Individual Plant Examination for External Events (IPEEE) (Fire Chapter ONLY), including:

• Results of any post-IPEEE reviews; and

• LIST of actions taken or plant modifications performed in response to the IPEEE results. A.4 Fire Protection Program and/or Fire Protection Plan.A.5 LIST of post-fire safe shutdown or alternative shutdown systems (i.e., safe shutdown equipment list). A.5 Fire Protection System Design Basis Document. A.6 Post-fire Safe Shutdown or Alternative Shutdown Design Basis Document.

2 A.7 LIST of applicable NFPA codes and standards and issuance dates (i.e., codes of record). A.8 LIST of deviations from NFPA codes of record. A.9 NFPA Compliance Review Report. A.10 Report or evaluation that compares the fire protection program to the NRC Branch Technical Position (BTP) 9.5-1 Appendix A. A.11 Electronic copy of licensee submittals and NRC safety evaluation reports that are specifically listed in the facility operating license for the approved fire protection program. A.12 NRC Safety Evaluation Reports for fire protection program and post-fire safe shutdown or alternative shutdown features. A.13 NRC approved exemptions for plant fire protection and post-fire safe shutdown or alternative shutdown features. A.14 Exemption requests submitted but not yet approved for plant fire protection and post-fire safe shutdown or alternative shutdown features. A.15 Facility Operating License (electronic format only).

A.16 Technical Specifications (electronic format only).

A.17 Technical Requirements Manual (electronic format only).

A.18 Updated Final Safety Analysis Report (electronic format only).

B. GENERAL PLANT DESIGN DOCUMENTS B.1 Piping and instrumentation diagrams (P&IDs) and legend list for post-fire safe shutdown or alternative shutdown system s (C-size paper drawings and electronic copy). B.2 P&IDs and legend list for fire protection systems, including fire water supply, water suppression sprinklers & deluge, and CO2 and Halon systems (C-size paper drawings and electronic copy). B.3 AC and DC electrical system single line di agrams, from off-site power down to the highest safety-related bus level (typically 4kV, EDG bus) (C-size paper drawings and electronic copy ). B.4 Single line diagrams for motor control centers (MCCs) that supply post-fire safe shutdown or alternative shutdown loads (only for selected fire areas) (C-size paper drawings and electronic copy ).

3 B.5 Equipment location drawings, which identify the physical plant locations of, post-fire safe shutdown or alternative shutdown equipment (C-size paper drawings and electronic copy). B.6 Plant layout drawings, which identify: (C-size paper drawings and electronic copy)

• Plant fire area boundaries;

• Combustible control zone drawings;

• Areas protected by automatic fire suppression and detection; and

• Locations of fire protection equipment.

C. CLASSICAL FIRE PROTECTION C.1 Fire protection program implementing procedures (e.g., administrative controls, surveillance testing, 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 Hydraulic calculation or analysis for fire protection water system in the selected fire areas. C.4 Last two completed surveillance's records of fire protection features in the selected fire areas (detection, suppression, damper inspections, damper tests, penetration inspections, barrier inspections, etc.). C.5 LIST of routine tests, surveillances, and preventive maintenance on fire pumps, including pump controllers and batteries. C.6 Last two completed annual fire pump pressure and flow tests.

C.7 Last two completed monthly and/or quarterly fire pump tests.

C.8 Last two completed fire loop flow tests and loop flushes.

C.9 CO2 and Halon initial discharge testing or calculation that determined appropriate concentrations and soak or hold times can be achieved (only for selected fire areas). C.10 Last five hot work permits (at power).

C.11 Last five transient combustible permits (at power).

C.12 For Fire Brigade Drills, provide the following:

• Last drill critique for a drill with off-site fire department support;

• Summary of any unsatisfactory drill performance items for last three years; and

• Last unannounced drill critique by a qualified individual independent of the licensee's staff.

4 C.13 For fire brigade equipment, provide the following:

• Procedure for inventory and inspection; and

• Most recent inspection and inventory results.

C.14 Fire Brigade Medical Evaluations and Qualifications, including self-contained breathing apparatus (SCBA) and training lesson plans. C.15 Electronic copy of the mutual aid agreement for the "first-due" local fire department that is currently in effect. C.16 Flooding analysis for selected fire areas, which demonstrates:

• a fire water pipe break in the selected fire areas, won't affect safe shutdown (SSD) capability for equipment in the selected fire areas;

• a fire water pipe break in an adjacent fire area, won't affect SSD 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 fire areas below.

C.17 Pre-fire plans for the selected fire areas and their adjacent fire areas. C.18 For Emergency Lighting Units (ELU), provide the following:

• LIST of Preventive Maintenance tasks, frequencies, and bases;

• Most recently performed monthly or quarterly functional test;

• Most recently performed battery discharge performance test; if applicable

• ELU battery loading analysis;

• vendor manual(s);

• results of black-out testing (if performed);

• Maintenance Rule program information related to the ELU, if applicable; and

• Compensatory measures taken when ELU are out of service.

C.19 Impairment Log (for period of 3 months before the start of inspection), for fire protection features that are out of service. C.20 LIST of Fire Protection screening reviews since the last inspection for recent design changes, modifications, or temporary modifications (e.g., a Generic Letter 86-10 review that screened out). C.21 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.22 LIST of penetration seal work, re-work, or installation activities, in the last three years. C.23 LIST of fire wrap work, re-work, or installation activities, in the last three years. C.24 Fire protection system health repor ts for the two most recent years. C.25 Fire protection program health report for the two most recent years.

5 C.26 Emergency lighting system health reports for the two most recent years. C.27 Licensee evaluation of industry operating experience, related to the Fire Protection Program for the three most recent years.

D. ELECTRICAL D.1 Identify whether the cables in the selected fire areas are predominantly Thermoset or Thermoplastic. Specifically identify any Thermoplastic cable in the selected fire areas. D.2 Breaker and fuse coordination calculation for post-fire safe shutdown or alternative shutdown equipment (only for selected fire areas). D.3 Administrative or configuration control procedures that govern fuse replacement (e.g., fuse control procedures). D.4 Maintenance procedures that verify breaker over-current trip settings to ensure coordination remains functional, for post-fire safe shutdown or alternative shutdown equipment. D.5 Electrical system health reports for the two most recent years.

D.6 Last completed preventive maintenance of those components as tested from the safe shutdown or alternative shutdown panel. D.7 Schematic or elementary diagrams for circuits to be reviewed, as requested by inspector (C-size paper drawings and electronic copy). D.8 Cable routing for components and equipment credited for post-fire safe shutdown or alternative shutdown (only for selected fire areas). D.9 LIST of post-fire safe shutdown or alternative shutdown design changes completed, since the last inspection.

E. SPURIOUS FIRE INDUCED CIRCUIT FAULTS E.1 LIST of identified fire induced circuit failure configurations (only for selected fire areas). E.2 Multiple Spurious Operation (MSO) Expert Panel Report. E.3 Corrective actions for fire-induced circuit failures, both single and multiple spurious actuations for the selected fire areas.

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

6 F.2 LIST of licensed operator Job Performance Measures (JPMs) for operator manual actions required by post-fire safe shutdown or alternative shutdown. F.3 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 JPMs, in-field training walkdowns, simulations, or initial qualification). F.4 LIST of lesson plans for post-fire safe shutdown or alternative shutdown training for licensed and non-licensed operators. F.5 For operator manual actions (OMAs) provide the following:

• Manual Action Feasibility Study;

• Operator Time Critical Action Program;

• Time lines for time-critical OMAs; and

• Time line validations.

• Environmental and habitability evaluations for post-fire operator manual actions (temperature, smoke, humidity, SCBAs, etc.).

F.6 Thermal hydraulic calculation or analysis that determines the time requirements for time-critical manual operator actions. F.7 Operating procedures for post-fire safe shutdown from the control room with a postulated fire in the selected fire areas. F.8 Operating procedures for post-fire safe shutdown or alternative shutdown from outside the control room. F.9 For safe shutdown equipment and tools, provide the following:

• Procedure for inventory and inspection; and

• Most recent inspection and inventory results.

F.10 LIST of procedures that implement Cold Shutdown Repairs. F.11 For Cold Shutdown Repairs, provide the following:

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

• Most recent inspection and inventory results.

F.12 Calculation or analysis that demonstrates pressurizer level will remain within the indicating range for a PWR, or reactor water level will remain above the top of active fuel for a BWR, at the safe shutdown or alternative shutdown panel, in accordance with the requirements of 10 CFR 50 Appendix R III.L performance goals.

7 F.13 For Radio communications, provide the following:

• Communications Plan for fire fighting and post-fire safe shutdown manual actions;

• Repeater locations;

• Cable routing for repeater power supply cables;

• Radio coverage test results; and

• Radio Dead Spot locations in the plant.

F.14 NRC approved exemption requests for operator manual actions for 10 CFR 50 Appendix R III.G.2 fire areas. F.15 Exemption requests submitted but not yet approved, for operator manual actions for 10 CFR 50 Appendix R III.G.2 fire areas.

G. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION PROGRAMS G.1 Corrective actions for fire-induced circui t failures (including but not limited to NRC IN 92-18), both single and multiple spurious actuations (only for selected fire areas). G.2 Corrective actions associated with post-fire safe shutdown or alternative shutdown operator manual actions. (include applicable administrative procedures)

G.3 Internal and external self-assessments, peer assessments, and audits of fire protection activities for the last three years. (include applicable admin procedure) G.4 Internal and external self-assessments, peer assessments, and audits of post-fire safe shutdown or alternative shutdown capabilities for the last three years. G.5 LIST of condition reports for the fire protection system for the last three years. G.6 LIST of condition reports for emergency lighting units for the last three years. G.7 LIST of condition reports for post-fire safe shutdown (SSD) or alternative shutdown (ASD) issues for the last three years. This includes issues affecting the SSD or ASD analysis, fire hazards analysis, SSD or ASD operating procedures and/or training, timeline evaluations for operator actions, and supporting engineering evaluations, analysis, or calculations. G.8 LIST of all Generic Letter 86 - 10 evaluations. G.9 Copy of all Generic Letter 86 - 10 evaluations performed in the last three years. G.10 All fire loading calculations and evaluations performed (only for selected fire areas and their adjacent fire areas).

Enclosure 2 MITIGATING STRATEGIES SUPPORTING DOCUMENTATION 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 Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh) (2). H.2 LIST of procedures and guidelines that were revised or generated to implement the mitigating strategies. These could be extensive damage mitigation guidelines (EDMGs), severe accident management guidelines (SAMGs), emergency operating procedures (EOPs), abnormal operating procedures (AOPs), etc. H.3 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. H.4 LIST of engineering evaluations or calculations that were used to verify the engineering bases for the mitigating strategies. H.5 Piping and instrumentation diagrams (P&ID) and legend list or simplified flow diagrams for systems relied upon in the mitigating strategies. These could be the type used for training. (C-size paper drawings and electronic copy) H.6 LIST of modification packages or summary descriptions of modifications with simplified drawings, for necessary facility changes to implement the mitigating strategies. H.7 LIST of routine tests, surveillances, and preventive maintenance for equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies. H.8 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies, provide the following:

• Procedures for inventory, testing, and inspection; and

• Most recent inspection, inventory, and testing results.

• Copies of the last two completed performance tests, surveillances, and preventative maintenance performed on the pumps, including the pump controllers and batteries.

H.9 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.

2 H.10 Site general arrangement drawings that show the majority of buildings and areas referenced in 10 CFR 50.54(hh)(2) documents (C-size paper drawings and electronic

copy). H.11 Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2). H.12 Copies of memoranda of understanding (MOU) (e.g., with local fire departments) required to implement any mitigating strategies. H.13 Docketed correspondence for 10 CFR 50.54(hh) to include license amendment requests (LARS); Safety Evaluation Reports (SER); Request for Information (RFI) and associated responses; and other pertinent documents.