ML18101A096

Notification of an NRC Triennial Fire Protection Baseline Inspection (NRC Inspection Report 05000382/2018007) and Request for Information

ML18101A096
Person / Time
Site:	Waterford
Issue date:	04/10/2018
From:	Greg Werner NRC/RGN-IV/DRS/EB-2
To:	Dinelli J Entergy Operations
Werner G
References
IR 2018007
Download: ML18101A096 (15)

See also: IR 05000382/2018007

Text

April 10, 2018

Mr. John Dinelli, Site Vice President

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NOTIFICATION

OF AN NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

(NRC INSPECTION REPORT 05000382/2018007) AND REQUEST FOR

INFORMATION

Dear Mr. Dinelli:

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

Region IV staff will conduct a triennial fire protection baseline inspection at the Waterford Steam

Electric Station, Unit 3 in July and August 2018. The inspection team will be comprised of

five reactor inspectors from the NRC Region IV office. The inspection will be conducted in

accordance with Inspection Procedure 71111.05XT, Fire Protection - NFPA 805 (Triennial),

the NRCs baseline fire protection inspection procedure. In addition, the inspection will review

the actions taken in response to Confirmatory Order NRC Inspection Report 05000382/2016007

and NRC Investigation Report 4-2014-017 in accordance with Inspection Procedure 92702,

Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory

Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders.

The schedule for the inspection is as follows:

• Information gathering visit: July 10 - 11, 2018

• On-site inspection: July 30, 2018 - August 3, 2018

August 13 - 17, 2018

The purpose of the information gathering visit is to obtain information and documentation

needed to support the inspection, and to become familiar with the fire protection program, fire

protection features, safe shutdown success paths, plant layout, and mitigating strategies to

address Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security

Compensatory Measures, dated February 25, 2002, and 10 CFR 50.54(hh)(2).

The team leader and one team member will participate in the information gathering visit to

select the fire areas for evaluation, identify additional documents needed to support the

inspection, obtain unescorted access, and meet with the key personnel who will support the

inspection. The fire area selection will require a walkdown of candidate fire areas 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.

During the information gathering visit, the team leader will also discuss the following inspection

support administrative details: (1) office space size and location; (2) specific documents

J. Dinelli 2

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). 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 and stable plant conditions, including the electrical aspects of the

nuclear safety capability assessment, 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 John Mateychick, the team lead inspector, in the Region IV office at (817) 200 1560 or

john.mateychick@nrc.gov.

Sincerely,

/RA James Drake Acting for/

Gregory E. Werner, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-382

License No. NPF-38

Attachments: 1. Triennial Fire Protection Inspection Document Request

2. Mitigating Strategies Document Request

3. Confirmatory Letter Document Request

Triennial Fire Protection Inspection Document Request

The documents and information requested below should generally be made available to the

inspection team during the inspection. Electronic format is the preferred format, except where

specifically noted. If electronic files are made available via the internet-based inspection

management system (IMS), then the remote document access must allow inspectors to

download, save, and print the documents in the NRCs regional office.

If IMS is utilized, it is recommended that a separate folder be used corresponding to each item

listed below and that multiple documents within each folder be combined into a ZIP file before

uploading. Electronic media on compact disc or paper records (hard copy) are also acceptable.

To allow review before the on-site information gathering visit, the following documents should be

made available to the team in the regional office no later than June 22, 2018:

• Post-fire Nuclear Safety Capability, Systems, and Separation Analysis (request A.1)

• Fire Hazards Analysis and/or NFPA 805 Design Basis Document (request A.2)

• Fire Probabilistic Risk Assessment (PRA) Summary Document or full PRA Document

(request A.3)

• NFPA 805 Transition Report, developed in accordance with NEI 04-02 (request A.4)

• Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3) (request A.5)

• Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4) (request A.6)

• Analysis that demonstrates nuclear safety performance criteria can be achieved and

maintained for those areas that require recovery actions (request A.7)

• Information concerning emergency lighting units (request C.18)

• Thermal hydraulic calculation or analysis that determines the time requirements for time-

critical manual operator actions (request E.6)

• Operating procedures to achieve and maintain nuclear safety performance criteria from

outside the control room with a postulated fire in the control room, cable spreading room,

or any area requiring recovery actions (other than recovery actions performed in the

control room or primary control stations), and any associated procedure basis

documents. (request E.8)

• Information concerning radio communications (request E.12)

• Information concerning telephone, plant pager or sound powered phone systems, if

relied upon to achieve and maintain safe and stable conditions (request E.13)

Based on a review of the above items, team leader should identify a preliminary list of fire areas

being considered for inspection prior to the on-site information gathering visit. During the

Attachment 1

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.

To allow review before the on-site inspection weeks, the following documents should be made

available to the team in the regional office no later than July 13, 2018.

A1-2

A. DESIGN AND LICENSING BASIS DOCUMENTS

A.1 Post-fire Nuclear Safety Capability, Systems, and Separation Analysis

A.2 Fire Hazards Analysis and/or NFPA 805 Design Basis Document

A.3 Fire PRA Summary Document or full PRA Document (if summary document not

available)

A.4 NFPA 805 Transition Report, developed in accordance with NEI 04-02

A.5 Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3)

A.6 Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4)

A.7 Analysis that demonstrates nuclear safety performance criteria can be achieved

and maintained for those areas that require recovery actions.

A.8 Fire Protection Program and/or Fire Protection Plan

A.9 List of post-fire safe shutdown components (i.e., safe shutdown equipment list)

A.10 Fire Protection System Design Basis Document

A.11 List of applicable NFPA codes and standards and issuance dates (i.e., codes of

record)

A.12 List of deviations from (a) NFPA codes of record or (b) NFPA 805 fundamental

fire protection program and design elements (i.e., NFPA 805, Chapter 3)

A.13 NFPA compliance review report

A.14 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.15 Copy of NRC Safety Evaluation Reports that form the licensing basis for:

• Fire Protection Program

• Post-fire Nuclear Safety Capability

A.16 List of nuclear safety capability design changes completed in the last 3 years

(including their associated 10 CFR 50.59 and NFPA 805 plant change

evaluations)

A.17 Facility Operating License

A.18 Technical Specifications (electronic format only)

A.19 Technical Requirements Manual (electronic format only)

A1-3

A.20 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 components

used to achieve and maintain nuclear safety performance criteria for: (electronic

format and C-size paper drawings)

• Fires outside the main control room

• Fires in areas requiring recovery actions at other than primary control stations

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 nuclear safety capability 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

C.1 Copy of fire protection program implementing procedures (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 Hydraulic calculation or analysis for fire protection water system

A1-4

C.4 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.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 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 3 years

• Summary of any unsatisfactory drill performance items for last 3 years

• Last unannounced drill critique by a qualified individual independent of the

licensees staff

C.13 For fire brigade equipment provide the following:

• Procedure for inventory and inspection

• Most recent inspection and inventory results

C.14 Fire Brigade Qualifications, including self-contained breathing apparatus, (SCBA)

and training lesson plans

C.15 Copy of the mutual aid agreement for the first-due local fire department that is

currently in effect

A1-5

C.16 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 fire

areas) 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.17 Pre-fire plans for all fire areas

C.18 For emergency lighting units, provide the following:

• Copy of performance-based emergency light assessments

• List of Preventive Maintenance tasks, frequencies, and bases

• Most recently performed monthly or quarterly functional test

• Most recently performed battery discharge performance test or conductance

measurement test

• Emergency lighting units battery loading analysis

• Vendor manual(s) for onsite inspector use

• Results of black-out testing (if performed)

• Maintenance Rule program information related to the emergency lighting

system

• Compensatory measures taken when emergency lighting units are out of

service

• Drawings showing emergency light locations and lamp orientation

C.19 Impairment Log (at start of inspection) for fire protection features that are out of

service

C.20 Fire protection screening reviews for recent design changes, modifications, or

temporary modifications (i.e., an NFPA 805 plant change evaluation that

screened out) in the last 3 years

C.21 List of penetration seal work, re-work, or installation activities, in the last 3 years

A1-6

C.22 List of fire wrap work, re-work, or installation activities, in the last 3 years

C.23 Fire protection system health reports for the two most recent quarters

C.24 Fire protection program health reports for the two most recent quarters

C.25 Emergency lighting system health reports for the two most recent quarters

C.26 LIST of fire protection system design changes completed in the last 3 years

(including their associated 10 CFR 50.59 and NFPA 805 plant change

evaluations)

C.27 List of fire protection system NFPA 805 engineering equivalency evaluations

completed in the last 3 years.

C.28 Licensee evaluations of industry operating experience concerning fire protection

issues completed in the last 3 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 Nuclear safety circuit coordination analysis for fuse and breaker coordination of

nuclear safety capability components (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 nuclear safety capability

components.

D.5 Electrical system health reports for the two most recent quarters

D.6 Last surveillance demonstrating operability of those components operated from

the primary control stations

D.7 Schematic or elementary diagrams for circuits to be reviewed (samples to be

identified by the inspector) (C-size paper drawings)

D.8 Cable routing for components and equipment credited for post-fire nuclear safety

capability systems and components (only for selected fire areas)

D.9 List of post-fire nuclear safety capability system and component design changes

completed in the last 3 years.

D.10 List of identified fire induced circuit failure configurations (only for selected fire

areas)

A1-7

E. OPERATIONS

E.1 List of calculations and engineering analyses, studies, or evaluations for the

nuclear safety capability methodology

E.2 List of licensed operator Job Performance Measures (JPMs) for operator actions

required to achieve and maintain post-fire nuclear safety performance criteria.

E.3 List of non-licensed operator training associated with non-licensed operator

actions to achieve and maintain post-fire nuclear safety performance criteria

(including JPMs, in-field training walkdowns, simulations, or initial qualification)

E.4 Lesson plans for post-fire nuclear safety capability training for licensed and non-

licensed operators

E.5 For recovery actions, provide the following:

• Manual Action Feasibility Study

• Operator Time Critical Action Program

• Time lines for time-critical recovery 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 nuclear safety performance

criteria from the control room with a postulated fire in the selected fire areas.

E.8 Operating procedures to achieve and maintain nuclear safety performance

criteria from outside the control room with a postulated fire in the control room,

cable spreading room, or any area requiring recovery actions (other than

recovery actions performed in the control room or primary control stations), and

any associated procedure basis documents.

E.9 For safe shutdown equipment and tools, provide the following:

• Procedure for inventory and inspection

• Most recent inspection and inventory results

E.10 List of procedures that implement cold shutdown repairs.

E.11 For cold shutdown repairs, provide the following:

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

• Most recent inspection and inventory results

A1-8

E.12 For radio communications, provide the following:

• Communications Plan for firefighting and post-fire safe shutdown manual

actions

• Repeater locations

• Cable routing for repeater power supply cables

• Radio coverage test results

• Radio Dead Spot locations in the plant

E.13 For telephone, plant pager, or sound powered phone systems, if relied upon to

achieve and maintain safe and stable conditions, provide the following:

• Communications Plan for firefighting and post-fire safe shutdown manual

actions

• Locations of phone, pager units, sound powered phone jacks and sound

powered phone headsets

• Cable routing including power supply cables

E.14 Environmental and habitability evaluations for post-fire operator actions

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

F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION

PROGRAMS

F.1 Corrective actions for fire-induced circuit failures (including but not limited to

NRC IN 92-18), both single and multiple spurious actuations (only for selected

fire areas).

F.2 Corrective actions associated with operator actions to achieve and maintain post-

fire nuclear safety performance criteria.

F.3 Self assessments, peer assessments, and audits of fire protection activities for

the last 3 years

F.4 Self assessments, peer assessments, and audits of post-fire nuclear safety

capability methodology for the last 3 years

F.5 List of open and closed condition reports for the fire protection system for the last

3 years

F.6 List of fire event analysis reports for the last 3 years

F.7 List of open and closed condition reports for emergency lighting units for the last

3 years

A1-9

F.8 List of open and closed condition reports for post-fire nuclear safety capability

issues for the last 3 years. This includes issues affecting the nuclear safety

capability analysis, fire hazards analysis, NFPA 805 design basis, fire risk

evaluations, plant change evaluations, post-fire operating procedures and/or

training, timeline evaluations for operator actions, and supporting engineering

evaluations, analysis, or calculations.

F.9 List of procedures that control the configuration of the fire protection program,

features, and post-fire nuclear safety capability methodology and system design.

A1-10

Mitigating Strategies Document Request

G. 10 CFR 50.54(hh)(2) MITIGATING STRATEGIES DOCUMENTS

G.1 List of all changes to regulatory commitments made to meet the requirements of,

Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and

Security Compensatory Measures, dated February 25, 2002, and Title 10 of the

Code of Federal Regulations (10 CFR) 50.54(hh)(2).

G.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.

G.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 and 3 Submittal

Guideline, issued December 2006, and the site-specific procedures or

guidelines that are used to implement each strategy.

G.4 List of engineering evaluations or calculations that were used to verify the

engineering bases for the mitigating strategies.

G.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 (electronic format and C-size paper drawings).

G.6 List of modification packages or summary descriptions of modifications with

simplified drawings, for necessary facility changes to implement the mitigating

strategies.

G.7 List of routine tests, surveillances, and preventive maintenance for equipment

and tools needed to implement 10 CFR 50.54(hh)(2) strategies.

G.8 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies,

provide the following:

• Procedures for inventory and inspection

• Most recent inspection and inventory results

G.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.

G.10 Site general arrangement drawings that show the majority of buildings and areas

referenced in 10 CFR 50.54(hh)(2) documents (electronic format and C-size

paper drawings).

G.11 Training records, training matrix, and lesson plans related to

10 CFR 50.54(hh)(2).

G.12 Copies of memoranda of understanding (MOU) (e.g., with local fire departments)

required to implement any mitigating strategies.

Attachment 2

Confirmatory Letter Document Request

H. Waterford Steam Electric Station - Confirmatory Order NRC Inspection

Report 05000382/2016007 and NRC Investigation Report 4-2014-017

H1. Updated Fire Watch Procedures from the Order

H2. Additional Procedures, including new requirement for Fire Watch oversight

monitoring since the Order

H3. Training Programs and Procedure Implementing lessons learned from the Orders

H4. Maintenance activities and Supervisory Monitoring program being implemented

to address the Fire Watch program from the Order

H5. Documented Lessons Learned from the Order

H6. Corrective Actions for the implementation of the Order actions

H7. Assessment activities associated with the Order

H8. Root Cause Analysis associated with Order

Attachment 3

ML18101A096

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002

By: JMM Yes No Publicly Available Sensitive

OFFICE SRI:EB2 C:EB2

NAME JMateychick GWerner

SIGNATURE /RA/ /RA/JFD for

DATE 04/10/18 04/10/18