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=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 October 26,2017 Mr. Keith Polson, Senior VP and Chief Nuclear Officer DTE Energy Company Fermi 2 210 NOC 6400 North Dixie Highway Newport, MI 48166 SUBJECT: FERMI POWER PLANT, UNIT 2TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000341/2017012
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION
 
==REGION III==
2443 WARRENVILLE RD. SUITE 210
==SUBJECT:==
FERMI POWER PLANT, UNIT 2TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000341/2017012


==Dear Mr. Polson:==
==Dear Mr. Polson:==
On September 14, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Fire Protection Inspection at your Fermi Power Plant, Unit 2 (Fermi 2). The enclosed inspection report documents the inspection results, which were discussed on September 25, 2017, with Mr. K. Polson, and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No findings were identified during this inspection. 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 10 CFR  
On September 14, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Fire Protection Inspection at your Fermi Power Plant, Unit 2 (Fermi 2). The enclosed inspection report documents the inspection results, which were discussed on September 25, 2017, with Mr. K. Polson, and other members of your staff.
 
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
 
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
 
No findings were identified during this inspection.
 
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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.


Sincerely,
Sincerely,
/RA/ Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50341 License No. NPF43 Enclosure: IR 05000341/2017012 cc: Distribution via LISTSERV
/RA/
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-341 License No. NPF-43 Enclosure:
IR 05000341/2017012 cc: Distribution via LISTSERV


=SUMMARY=
=SUMMARY=
Inspection Report 05000341/2017012; 08/14/201709/25/2017; Fermi Power Plant, Unit 2; Routine Triennial Fire Protection Baseline Inspection. This report covers a 2-week announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III based engineering inspectors. The U.S. Nuclear program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-Revision 6, dated July 2016.
Inspection Report 05000341/2017012; 08/14/201709/25/2017; Fermi Power Plant, Unit 2;
 
Routine Triennial Fire Protection Baseline Inspection.
 
This report covers a 2-week announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III based engineering inspectors. The U.S. Nuclear Regulatory Commissions program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 2016.


===NRC-Identified===
===NRC-Identified===
and Self-Revealed Findings No findings were identified.
and Self-Revealed Findings No findings were identified.


=== Licensee-Identified Violations===
===
Licensee-Identified Violations===
 
No violations were identified.
No violations were identified.
3


=REPORT DETAILS=
=REPORT DETAILS=


===1. ===
==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events and Mitigating Systems
Cornerstones: Initiating Events and Mitigating Systems
{{a|1R05}}
{{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection==
{{IP sample|IP=IP 71111.05T}}
{{IP sample|IP=IP 71111.05T}}
The purpose of the Triennial Fire Protection Baseline Inspection was to conduct a design-based, plant specific, risk-Fire Protection Program-in-depth elements used to mitigate the consequences of a fire. The Fire Protection Program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by: preventing fires from starting; rapidly detecting, controlling and extinguishing fires that do occur; providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe-shutdown of the reactor plant; and taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires. Fire Protection Program, post-fire safe shut-down (SSD) systems, and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee had implemented a Fire Protection Program that:
The purpose of the Triennial Fire Protection Baseline Inspection was to conduct a design-based, plant specific, risk-informed, onsite inspection of the licensees Fire Protection Programs defense-in-depth elements used to mitigate the consequences of a fire. The Fire Protection Program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by:
preventing fires from starting; rapidly detecting, controlling and extinguishing fires that do occur; providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe-shutdown of the reactor plant; and taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.
 
The inspectors evaluation focused on the design, operational status, and material condition of the reactor plants Fire Protection Program, post-fire safe shut-down (SSD)systems, and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee had implemented a Fire Protection Program that:
: (1) provided adequate controls for combustibles and ignition sources inside the plant;
: (1) provided adequate controls for combustibles and ignition sources inside the plant;
: (2) provided adequate fire detection and suppression capability;
: (2) provided adequate fire detection and suppression capability;
Line 51: Line 74:
: (5) ensured that procedures, equipment, fire barriers and systems exist so that the post-fire capability to safely shut down the plant was ensured;
: (5) ensured that procedures, equipment, fire barriers and systems exist so that the post-fire capability to safely shut down the plant was ensured;
: (6) included feasible and reliable operator manual actions when appropriate to achieve SSD; and
: (6) included feasible and reliable operator manual actions when appropriate to achieve SSD; and
: (7) identified fire protection issues at an appropriate threshold and ensured these issues Problem Identification and Resolution Program. -fire SSD systems for selected risk-significant fire areas. Inspector emphasis was placed on determining that the post-fire SSD capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire SSD success path B.5.b-related license conditions and the requirements of Title 10 of the Code of Federal Regulations (CFR), Part 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the Attachment to this report.
: (7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensees Problem Identification and Resolution Program.
 
In addition, the inspectors review and assessment focused on the licensees post-fire SSD systems for selected risk-significant fire areas. Inspector emphasis was placed on determining that the post-fire SSD capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire SSD success path was available. The inspectors review and assessment also focused on the licensees B.5.b-related license conditions and the requirements of Title 10 of the Code of Federal Regulations (CFR), Part 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the to this report.
 
The fire areas and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas selected constituted three inspection samples and the B.5.b mitigating strategies selected constituted two inspection sample, respectively, as defined in Inspection Procedure 71111.05T.


4 The fire areas and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas selected constituted three inspection samples and the B.5.b mitigating strategies selected constituted two inspection sample, respectively, as defined in Inspection Procedure 71111.05T. Fire Area Description 02AB Auxiliary Building Mezzanine and Cable Tray Area 13AB Auxiliary Building Ventilation Area 11ABE Division I Miscellaneous Room Elevation 643
Fire Area             Description 02AB                   Auxiliary Building Mezzanine and Cable Tray Area 13AB                   Auxiliary Building Ventilation Area 11ABE                 Division I Miscellaneous Room Elevation 643


===.1 Protection of Safe Shutdown Capabilities===
===.1 Protection of Safe Shutdown Capabilities===


====a. Inspection Scope====
====a. Inspection Scope====
For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, SSD analysis, and supporting drawings and documentation to verify that SSD capabilities were properly protected. l procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire SSD analysis and procedures.
For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, SSD analysis, and supporting drawings and documentation to verify that SSD capabilities were properly protected.
 
The inspectors also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire SSD analysis and procedures.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as U.S. Nuclear Regulatory Commission (NRC) Safety Evaluation Reports, and deviations from NRC regulations and National Fire Protection Association standards to verify that fire protection features met license commitments. The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area. The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.
For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as U.S. Nuclear Regulatory Commission (NRC) Safety Evaluation Reports, and deviations from NRC regulations and National Fire Protection Association standards to verify that fire protection features met license commitments.
 
The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area.
 
The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
SSD to determine if the licensee had properly identified the components and systems necessary to achieve and maintain SSD conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions. The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate SSD procedure actions and that equipment labeling was consistent with the alternate SSD procedure. The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls.
The inspectors reviewed the licensees systems required to achieve alternative SSD to determine if the licensee had properly identified the components and systems necessary to achieve and maintain SSD conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.
 
The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate SSD procedure actions and that equipment labeling was consistent with the alternate SSD procedure. The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors verified that the licensee performed a post-fire SSD analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining SSD. Additionally, the inspectors verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact SSD due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent SSD. The inspectors' review considered fire and cable attributes, potential undesirable consequences, and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events. The inspectors also reviewed cable raceway drawings for a sample of components required for post-fire SSD to verify that cables were routed as described in the cable routing matrices. The inspectors reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire SSD activities would not be impacted due to a lack of coordination. Additionally, the inspectors reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire SSD were properly maintained in accordance with procedural requirements. The inspectors verified for cables that are important to SSD, but not part of the success path, and that do not meet the separation/protection requirements of Section III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the cable failure modes. In addition, the inspectors have verified that the licensee has either:
The inspectors verified that the licensee performed a post-fire SSD analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining SSD. Additionally, the inspectors verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact SSD due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent SSD.
 
The inspectors' review considered fire and cable attributes, potential undesirable consequences, and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.
 
The inspectors also reviewed cable raceway drawings for a sample of components required for post-fire SSD to verify that cables were routed as described in the cable routing matrices.
 
The inspectors reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire SSD activities would not be impacted due to a lack of coordination. Additionally, the inspectors reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire SSD were properly maintained in accordance with procedural requirements.
 
The inspectors verified for cables that are important to SSD, but not part of the success path, and that do not meet the separation/protection requirements of Section III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the cable failure modes. In addition, the inspectors have verified that the licensee has either:
: (1) determined that there is not a credible fire scenario (through fire modeling),
: (1) determined that there is not a credible fire scenario (through fire modeling),
: (2) implemented feasible and reliable manual actions to assure SSD capability, or
: (2) implemented feasible and reliable manual actions to assure SSD capability, or
Line 111: Line 154:
The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative SSD functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.
The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative SSD functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.


7 The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.
The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.


====b. Findings====
====b. Findings====
Line 119: Line 162:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative SSD functions. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.
The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative SSD functions.
 
As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire SSD equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing SSD functions or capabilities). The inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.
The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire SSD equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing SSD functions or capabilities).
 
The inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed changes to the approved Fire Protection Program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire SSD analysis and procedures.
The inspectors reviewed changes to the approved Fire Protection Program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The inspectors also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire SSD analysis and procedures.


====b. Findings====
====b. Findings====
Line 159: Line 206:


====a. Inspection Scope====
====a. Inspection Scope====
by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b-related license conditions, and 10 CFR 50.54(hh)(2) by determining that: procedures were being maintained and adequate; equipment was properly staged, maintained, and tested; station personnel were knowledgeable and could implement the procedures; and additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b-related equipment. -related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction 2515/171 or subsequent performances of these inspections.
The inspectors reviewed the licensees preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b-related license conditions, and 10 CFR 50.54(hh)(2) by determining that:
procedures were being maintained and adequate; equipment was properly staged, maintained, and tested; station personnel were knowledgeable and could implement the procedures; and additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b-related equipment.
 
The inspectors reviewed the licensees B.5.b-related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction 2515/171 or subsequent performances of these inspections.
 
The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3-1 of Nuclear Energy Institute 06-12, B.5.b Phase II and III Submittal Guidance, Revision 2, are evaluated each time due to the mitigation strategies scenario selected.


9 The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3-1 of Nuclear Energy Institute 06-and , are evaluated each time due to the mitigation  NEI 06-12, Revision 2, Section Licensee Strategy (Table) 3.4.8 Venting Primary Containment without AC Power (A.5-8) 3.4.9 Drywell Injection (A.5-9)
NEI 06-12, Revision 2,     Licensee Strategy (Table)
Section 3.4.8             Venting Primary Containment without AC Power (A.5-8)3.4.9             Drywell Injection (A.5-9)


====b. Findings====
====b. Findings====
One finding was identified which is discussed in Inspection Report 05000341/2016407.
One finding was identified which is discussed in Inspection Report 05000341/2016407.


===4. ===
==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
{{a|4OA2}}
{{a|4OA2}}
Line 172: Line 226:


====a. Inspection Scope====
====a. Inspection Scope====
Corrective Action Program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the Fire Protection Program at an appropriate threshold and entering them in the Corrective Action Program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non-conformance documents.
The inspectors reviewed the licensees Corrective Action Program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the Fire Protection Program at an appropriate threshold and entering them in the Corrective Action Program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non-conformance documents.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==


===.1 Exit Meeting Summary The inspectors presented the inspection results to Mr. M. Caragher, Mr. K. Polson, and other members of the licensee staff on September 14, 2017, and on September 25, 2017, respectively.===
===.1 Exit Meeting Summary===
The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:
 
The inspectors presented the inspection results to Mr. M. Caragher, Mr. K. Polson, and other members of the licensee staff on September 14, 2017, and on September 25, 2017, respectively. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
 
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
Licensee  
 
: [[contact::K. Polson]], Site Vice President  
Licensee
: [[contact::M. Caragher]], Executive Director, Nuclear Production (Plant Manager)  
: [[contact::K. Polson]], Site Vice President
: [[contact::L. Bennett]], Director, Nuclear Operations  
: [[contact::M. Caragher]], Executive Director, Nuclear Production (Plant Manager)
: [[contact::W. Colonnelo]], Nuclear Projects  
: [[contact::L. Bennett]], Director, Nuclear Operations
: [[contact::K. Dittman]], Plant Support Engineering  
: [[contact::W. Colonnelo]], Nuclear Projects
: [[contact::A. Emerson]], Engineering  
: [[contact::K. Dittman]], Plant Support Engineering
: [[contact::R. Harris]], Fire Protection, Plant Support Engineering  
: [[contact::A. Emerson]], Engineering
: [[contact::K. Hullum-Lawson]], Manager, Plant Support Engineering  
: [[contact::R. Harris]], Fire Protection, Plant Support Engineering
: [[contact::J. Louwers]], Manager, Nuclear Quality Assurance  
: [[contact::K. Hullum-Lawson]], Manager, Plant Support Engineering
: [[contact::S. Maglio]], Manager, Licensing  
: [[contact::J. Louwers]], Manager, Nuclear Quality Assurance
: [[contact::K. Mann]], Supervisor, Regulatory Compliance  
: [[contact::S. Maglio]], Manager, Licensing
: [[contact::J. May]], Manager, Chemistry  
: [[contact::K. Mann]], Supervisor, Regulatory Compliance
: [[contact::D. Noetzel]], Director, Nuclear Engineering
: [[contact::J. May]], Manager, Chemistry
: [[contact::K. Polson]], Site Vice President  
: [[contact::D. Noetzel]], Director, Nuclear Engineering
: [[contact::G. Strobel]], Director, Outage & Work Management  
: [[contact::M. OConnor]], Manager, Security
: [[contact::P. Summers]], Director, Nuclear Support  
: [[contact::K. Polson]], Site Vice President
: [[contact::S. Wood]], Plant Support Engineering  
: [[contact::G. Strobel]], Director, Outage & Work Management
: [[contact::U.S. Nuclear Regulatory Commission J. Nance]], Acting Senior Resident Inspector  
: [[contact::P. Summers]], Director, Nuclear Support
: [[contact::P. Smagacz]], Resident Inspector  
: [[contact::S. Wood]], Plant Support Engineering
U.S. Nuclear Regulatory Commission
: [[contact::J. Nance]], Acting Senior Resident Inspector
: [[contact::P. Smagacz]], Resident Inspector
 
==LIST OF ITEMS==
==LIST OF ITEMS==
OPENED, CLOSED AND DISCUSSED Opened, Closed and  
 
===OPENED, CLOSED AND DISCUSSED===
 
Opened, Closed and  
===Discussed===
===Discussed===
None LIST OF ACRONYMS USED CFR Code of Federal Regulations NRC U.S. Nuclear Regulatory Commission SSD Safe Shutdown
 
None
LIST OF ACRONYMS USED
CFR             Code of Federal Regulations
NRC             U.S. Nuclear Regulatory Commission
SSD             Safe Shutdown


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
The following is a list of documents reviewed during the inspection.
 
: Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
: Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
: CALCULATIONS Number Description or Title Revision
: DC-5713 Hydraulic Evaluation of the Fire Distribution Loop, Volume I E
: DC-2574 Emergency Lighting for Appendix R Fire Protection and Station Blackout P
: DC-4921 Volume I, Appendix R Calculations H
: TE-A30-17-063 Flange Rigging Plan 0
: CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION Number Description or Title Date 17-26214 Control Room Envelope Damper Access Panel Screws Missing 08/15/2017 17-26847 Aluminum drip pan found behind MPU 3 08/15/2017 17-26857 Yellow Herculite material attached to conduit penetrations 08/15/2017 17-26871 NRC FP Triennial: Trash left in area 08/15/2017 17-26948 Identification methods for non-required fire wrapping 08/18/2017 17-26953 Repair AB4 Ventilation Rm Gypsum Wall 08/18/2017 17-27016 Radio equipment not tagged for extended use 08/25/2017 17-27116 Repair Penetration P-150 08/25/2017 17-27117 Cable Tray Fire Wrap 2C-012 Needs Repaired 08/25/2017 17-27118 PVC Piping in MCC Area 3rd Floor Aux Building 08/25/2017 17-27136
: AB-4 Block wall mortar joint needs repair 08/25/2017 17-27137 Review of IN13-06 response 08/25/2017 17-27146
: Fire Penetration Seal T2235X110 Needs Repair
: 08/25/2017 17-27147 Potential Inadequate Remedial Actions and Extent of Condition for CARD 14-26765 08/25/2017 17-27148 Review
: FPEE-16-0001 to determine if the addition of steps to 20.000.18 have an impact on time critical operator actions 08/25/2017 17-27149 Recommendation to Review MSO Report for addition of additional MSO Scenarios 08/25/2017 17-27150 Revise FPEEs 08/26/2017 17-27173 Conduit wrapped in silver duct tape 08/25/2017 17-27206 Enhancement to operator manual feasibility 08/25/2017 17-27207 Investigate Feasibility of Actions from CARD 14-27205 08/25/2017 17-27226 Enhance Seal Spec 3071-198 08/29/2017 17-27230 Lack of Documentation in
: DC-4921 related to implementation of MSO Modification 08/29/2017 17-27236 Pre-Fire plans does not have all the communications 08/29/2017 17-27243 29.EDM.10 Dedicated scaffolding 08/29/2017 17-27290 Fire Door R3-12 Does Not Close Automatically 08/31/2017 17-27334 Enhancement to 20.000.18 08/31/2017
}}
}}

Revision as of 10:24, 29 October 2019

Unit 2 - Triennial Fire Protection Inspection Report 05000341/2017012 (DRS-A.Dahbur)
ML17300B224
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 10/26/2017
From: Robert Daley
Engineering Branch 3
To: Polson K
DTE Energy
References
IR 2017012
Download: ML17300B224 (15)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

SUBJECT:

FERMI POWER PLANT, UNIT 2TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000341/2017012

Dear Mr. Polson:

On September 14, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Fire Protection Inspection at your Fermi Power Plant, Unit 2 (Fermi 2). The enclosed inspection report documents the inspection results, which were discussed on September 25, 2017, with Mr. K. Polson, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

No findings were identified during this inspection.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-341 License No. NPF-43 Enclosure:

IR 05000341/2017012 cc: Distribution via LISTSERV

SUMMARY

Inspection Report 05000341/2017012; 08/14/201709/25/2017; Fermi Power Plant, Unit 2;

Routine Triennial Fire Protection Baseline Inspection.

This report covers a 2-week announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III based engineering inspectors. The U.S. Nuclear Regulatory Commissions program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 2016.

NRC-Identified

and Self-Revealed Findings No findings were identified.

=

Licensee-Identified Violations===

No violations were identified.

REPORT DETAILS

1.

REACTOR SAFETY

Cornerstones: Initiating Events and Mitigating Systems

1R05 Fire Protection

Main article: IP 71111.05T

The purpose of the Triennial Fire Protection Baseline Inspection was to conduct a design-based, plant specific, risk-informed, onsite inspection of the licensees Fire Protection Programs defense-in-depth elements used to mitigate the consequences of a fire. The Fire Protection Program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by:

preventing fires from starting; rapidly detecting, controlling and extinguishing fires that do occur; providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe-shutdown of the reactor plant; and taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.

The inspectors evaluation focused on the design, operational status, and material condition of the reactor plants Fire Protection Program, post-fire safe shut-down (SSD)systems, and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee had implemented a Fire Protection Program that:

(1) provided adequate controls for combustibles and ignition sources inside the plant;
(2) provided adequate fire detection and suppression capability;
(3) maintained passive fire protection features in good material condition;
(4) established adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems or features;
(5) ensured that procedures, equipment, fire barriers and systems exist so that the post-fire capability to safely shut down the plant was ensured;
(6) included feasible and reliable operator manual actions when appropriate to achieve SSD; and
(7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensees Problem Identification and Resolution Program.

In addition, the inspectors review and assessment focused on the licensees post-fire SSD systems for selected risk-significant fire areas. Inspector emphasis was placed on determining that the post-fire SSD capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire SSD success path was available. The inspectors review and assessment also focused on the licensees B.5.b-related license conditions and the requirements of Title 10 of the Code of Federal Regulations (CFR), Part 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the to this report.

The fire areas and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas selected constituted three inspection samples and the B.5.b mitigating strategies selected constituted two inspection sample, respectively, as defined in Inspection Procedure 71111.05T.

Fire Area Description 02AB Auxiliary Building Mezzanine and Cable Tray Area 13AB Auxiliary Building Ventilation Area 11ABE Division I Miscellaneous Room Elevation 643

.1 Protection of Safe Shutdown Capabilities

a. Inspection Scope

For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, SSD analysis, and supporting drawings and documentation to verify that SSD capabilities were properly protected.

The inspectors also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire SSD analysis and procedures.

b. Findings

No findings were identified.

.2 Passive Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as U.S. Nuclear Regulatory Commission (NRC) Safety Evaluation Reports, and deviations from NRC regulations and National Fire Protection Association standards to verify that fire protection features met license commitments.

The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area.

The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.

b. Findings

No findings were identified.

.3 Active Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and detection systems. The inspectors observed the material condition and configuration of the installed fire detection and suppression systems. The inspectors reviewed design documents and supporting calculations. In addition, the inspectors reviewed license basis documentation, such as, NRC Safety Evaluation Reports, deviations from NRC regulations, and National Fire Protection Association standards to verify that fire suppression and detection systems met license commitments. The inspectors reviewed fire brigade drill records and walked down pre-fire plans for select areas.

b. Findings

No findings were identified

.4 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.

b. Findings

No findings were identified.

.5 Alternative Shutdown Capability

a. Inspection Scope

The inspectors reviewed the licensees systems required to achieve alternative SSD to determine if the licensee had properly identified the components and systems necessary to achieve and maintain SSD conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.

The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate SSD procedure actions and that equipment labeling was consistent with the alternate SSD procedure. The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls.

b. Findings

No findings were identified

.6 Circuit Analyses

a. Inspection Scope

The inspectors verified that the licensee performed a post-fire SSD analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining SSD. Additionally, the inspectors verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact SSD due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent SSD.

The inspectors' review considered fire and cable attributes, potential undesirable consequences, and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.

The inspectors also reviewed cable raceway drawings for a sample of components required for post-fire SSD to verify that cables were routed as described in the cable routing matrices.

The inspectors reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire SSD activities would not be impacted due to a lack of coordination. Additionally, the inspectors reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire SSD were properly maintained in accordance with procedural requirements.

The inspectors verified for cables that are important to SSD, but not part of the success path, and that do not meet the separation/protection requirements of Section III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the cable failure modes. In addition, the inspectors have verified that the licensee has either:

(1) determined that there is not a credible fire scenario (through fire modeling),
(2) implemented feasible and reliable manual actions to assure SSD capability, or
(3) performed a circuit fault analysis demonstrating no potential impact on SSD capability exists.

b. Findings

No findings were identified.

.7 Communications

a. Inspection Scope

The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative SSD functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.

The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.

b. Findings

No findings were identified.

.8 Emergency Lighting

a. Inspection Scope

The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative SSD functions.

As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.

b. Findings

No findings were identified.

.9 Cold Shutdown Repairs

a. Inspection Scope

For the three fire areas that were selected, the licensee did not credit any repairs in order to achieve cold shutdown. Therefore, no reviews were performed by the inspectors for this procedure section.

b. Findings

No findings were identified

.10 Compensatory Measures

a. Inspection Scope

The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire SSD equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing SSD functions or capabilities).

The inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.

b. Findings

No findings were identified.

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The inspectors reviewed changes to the approved Fire Protection Program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The inspectors also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire SSD analysis and procedures.

b. Findings

No findings were identified.

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The inspectors reviewed the licensee's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. A sample of hot work and transient combustible control permits were also reviewed. The inspectors performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.

b. Findings

No findings were identified.

.13 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensees preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b-related license conditions, and 10 CFR 50.54(hh)(2) by determining that:

procedures were being maintained and adequate; equipment was properly staged, maintained, and tested; station personnel were knowledgeable and could implement the procedures; and additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b-related equipment.

The inspectors reviewed the licensees B.5.b-related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction 2515/171 or subsequent performances of these inspections.

The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3-1 of Nuclear Energy Institute 06-12, B.5.b Phase II and III Submittal Guidance, Revision 2, are evaluated each time due to the mitigation strategies scenario selected.

NEI 06-12, Revision 2, Licensee Strategy (Table)

Section 3.4.8 Venting Primary Containment without AC Power (A.5-8)3.4.9 Drywell Injection (A.5-9)

b. Findings

One finding was identified which is discussed in Inspection Report 05000341/2016407.

4.

OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

Main article: IP 71152

a. Inspection Scope

The inspectors reviewed the licensees Corrective Action Program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the Fire Protection Program at an appropriate threshold and entering them in the Corrective Action Program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non-conformance documents.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

The inspectors presented the inspection results to Mr. M. Caragher, Mr. K. Polson, and other members of the licensee staff on September 14, 2017, and on September 25, 2017, respectively. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Polson, Site Vice President
M. Caragher, Executive Director, Nuclear Production (Plant Manager)
L. Bennett, Director, Nuclear Operations
W. Colonnelo, Nuclear Projects
K. Dittman, Plant Support Engineering
A. Emerson, Engineering
R. Harris, Fire Protection, Plant Support Engineering
K. Hullum-Lawson, Manager, Plant Support Engineering
J. Louwers, Manager, Nuclear Quality Assurance
S. Maglio, Manager, Licensing
K. Mann, Supervisor, Regulatory Compliance
J. May, Manager, Chemistry
D. Noetzel, Director, Nuclear Engineering
M. OConnor, Manager, Security
K. Polson, Site Vice President
G. Strobel, Director, Outage & Work Management
P. Summers, Director, Nuclear Support
S. Wood, Plant Support Engineering

U.S. Nuclear Regulatory Commission

J. Nance, Acting Senior Resident Inspector
P. Smagacz, Resident Inspector

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened, Closed and

Discussed

None

LIST OF ACRONYMS USED

CFR Code of Federal Regulations

NRC U.S. Nuclear Regulatory Commission

SSD Safe Shutdown

LIST OF DOCUMENTS REVIEWED

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