ML11126A320

Notification of NRC Triennial Fire Protection Baseline Inspection 05000237-11-008 (Drs), 05000249-11-008 (DRS)

ML11126A320
Person / Time
Site:	Dresden
Issue date:	05/06/2011
From:	Robert Daley Engineering Branch 3
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
Download: ML11126A320 (10)

See also: IR 05000237/2011008

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

May 6, 2011

Mr. Michael J. Pacilio

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer (CNO), Exelon Nuclear

4300 Winfield Road

Warrenville IL 60555

SUBJECT: DRESDEN NUCLEAR POWER STATION NOTIFICATION OF AN NRC

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

05000237/2011008(DRS); 05000249/2011008(DRS)

Dear Mr. Pacilio

On July 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire

protection baseline inspection at your Dresden Nuclear Power Station. This inspection will be

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

protection inspection procedure.

Changes were made to the IP 71111.05T, which now requires the fire protection inspection to

review your actions to mitigate postulated events that could potentially cause loss of large areas

of power reactor facilities due to explosions or fires. This requirement was implemented by the

issuance of the Interim Compensatory Measures Order EA-02-026, Section B.5.b and the

subsequent requirements of 10 CFR 50.54(hh)(2), which are collectively referred to as B.5.b

requirements. During this inspection, the B.5.b requirements review will be performed during

the first onsite week of the inspection starting on July 27, 2011.

The schedule for the onsite inspection activity is as follows:

y Information Gathering Visit: July 25 - 27, 2011

y B.5.b Requirements: July 27 - 39, 2011, and

y Fire Protection Inspection: August 8 - 12, 2011, and August 29 - September 2, 2011.

The purpose of the information gathering visit is: (1) to obtain information and documentation

needed to support the inspection; (2) to become familiar with the Dresden Nuclear Power

Station fire protection programs, fire protection features, post-fire safe shutdown capabilities,

and plant layout; and (3) to arrange administrative details, such as office space, availability of

knowledgeable office personnel and to ensure unescorted site access privileges.

Experience has shown that the baseline fire protection inspections are extremely resource

intensive both for the NRC inspectors and the licensee staff. In order to minimize the inspection

impact on the site and to ensure a productive inspection for both organizations, we have

enclosed a request for documents needed for the inspection. These documents have been

divided into four groups. The first group lists information necessary to aid the inspection team in

choosing specific focus areas for the inspection. It is requested that this information be

M. Pacilio -2-

provided to the lead inspector via mail or electronically no later than July 5, 2011. The second

group also lists information and areas for discussion necessary to aid the inspection team in

choosing specific fire protection focus areas for the inspection and to ensure that the inspection

team is adequately prepared for the inspection. It is requested this information be available

during the information gathering visit (July 25, 2011). The third group of requested documents

consists of those items that the team will review, or need access to, during the inspection.

Please have this information available by the first day of the second onsite inspection week

(August 8, 2011). The fourth group lists the information necessary to aid the inspection team in

tracking issues identified as a result of the inspection. It is requested that this information be

provided to the lead inspector as the information is generated during the inspection. It is

important that all of these documents are up to date and complete in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of

the inspection.

The lead inspector for this inspection is Ronald A. Langstaff. We understand that our regulatory

contact for this inspection is Mr. G. Ice, NRC Coordinator, Dresden Regulatory Assurance, of

your organization. If there are any questions about the inspection or the material requested,

please contact the lead inspector at (630) 829-9747 or via e-mail at Ronald.Langstaff@nrc.gov.

This letter does not contain new or amended information collection requirements subject to

the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control Number

3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to a

request for information or an information collection requirement unless the requesting document

displays a currently valid Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and

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

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

system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ by R. A. Langstaff For/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos.: 50-237; 50-249

License Nos.: DPR 19; DPR 25

Enclosure: Fire Protection Inspection Document Request

cc w/encl: Distribution via ListServ

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

Inspection Report: 05000237/2011008(DRS); 05000249/2011008(DRS)

Onsite Inspection Dates: July 25 - 27, 2011 (Information Gathering Visit)

July 27 - 29, 2011 (B.5.b Requirements)

August 8 - 12, 2011 (Fire Protection Inspection)

August 29 - September 2, 2011 (Fire Protection Inspection)

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

IP71152, "Identification and Resolution of Problems"

Inspectors: R. A. Langstaff

(630) 829-9747

Ronald.Langstaff@nrc.gov

Z. Falevits R. A. Winter

(630) 829-9717 (630) 829-9758

Zelig.Falevits@nrc.gov Robert.Winter@nrc.gov

Observer: J. S. Bowen

(301) 415-3471

Jeremy.Bowen@nrc.gov

I. Information Requested Prior To the Information Gathering Visit

The following information is requested by July 5, 2011. If you have any questions

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

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

Ronald.Langstaff@nrc.gov). Electronic media is preferred. The preferred file format is a

searchable pdf file on a compact disk (CD). The CD should be indexed and hyper-

linked to facilitate ease of use, if possible. Please provide four copies of each CD

submitted (one for each inspector and observer).

1. The most risk significant fire areas as determined by probabilistic risk analyses, if

available. Otherwise, the reactor plant's Individual Plant Examination for External

Events (IPEEE) for fire and results of any post-IPEEE reviews for fire.

2. A copy of the current version of the Fire Protection Program (FPP), Fire Hazards

Analysis (FHA), Safe Shutdown Analysis (SSA), Updated Safety Analysis Report

(USAR), Technical Specifications, license (including the fire protection license

condition), and Technical Requirements Manual (TRM) or equivalent for fire

protection structures, systems, and components.

3. A list of fire areas requiring alternative shutdown capability, (i.e., those areas for

which 10 CFR Part 50, Appendix R, Section III G requirements are satisfied under

Section III.G.3), or where both safe shutdown trains can be affected.

1 Enclosure

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

4. Plant operating procedures which would be used and describe shutdown for a

postulated fire (for both areas requiring alternative shutdown and areas which do

not require alternative shutdown). Only those procedures with actions specific to

shutdown in the event of a fire need be included. In addition, please include those

procedures which operators would use for initial response to a fire, such as

annunciator or alarm response procedures, the procedure used for activating the

fire brigade, and the procedure which directs operators to the applicable safe

shutdown procedure.

II. Information Requested During the Information Gathering Visit (July 25, 2011)

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

onsite information gathering visit. Except for Item 1, it is requested that the following

information be provided on four sets of CDs (searchable, if possible) with the B.5.b

Mitigating Strategies information (Items 8.a through 8.h) provided on one separate CDs.

In addition, one set of hard copy drawings are requested for Items 4.a. through 4.d.

1. One set of hard-copy documents for facility layout drawings which identify plant fire

area delineation; areas protected by automatic fire suppression and detection; and

locations of fire protection equipment.

2. Licensing Information:

a. All Nuclear Regulatory Commission (NRC) Safety Evaluation Reports (SERs)

applicable to fire protection (specifically including those SERs referenced by

the plant fire protection license condition) and all licensing correspondence

referenced by the SERs;

b. All licensing correspondence associated with the comparison to Standard

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

purposes;

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

associated licensing correspondence;

d. For pre-1979 plants, all licensing correspondence associated with those

sections of 10 CFR Part 50, Appendix R, that are not applicable to the plant

under 10 CFR 50.48(b)(1). Specifically, the licensing correspondence

associated with those fire protection features proposed or implemented by the

licensee that have been accepted by the NRC staff as satisfying the provisions

of Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 reflected in

the NRC fire protection SERs issued before February 19, 1981, (10 CFR

50.48(b)(1)(i)); or those fire protection features, which were accepted by the

NRC staff in comprehensive fire protection SERs issued before Appendix A to

BTP APCSB 9.5-1 was published in August 1976 (10 CFR 50.48(b)(1)(ii)); and

e. The final safety analysis report (FSAR) sections applicable to fire protection,

FHA, and SSA in effect at the time of original licensing.

2 Enclosure

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

3. Fire Protection Program:

a. A listing of changes made to the FPP since the last triennial fire protection

inspection;

b. For pre-1979 plants, a listing of the protection methodologies identified under

10 CFR Part 50, Appendix R, Section III.G used to achieve compliance for

selected fire zones/areas (to be determined during information gathering

visit). That is, please specify whether 3-hour rated fire barriers;

(Section III.G.2.a), 20 foot separation along with detection and suppression;

(Section III.G.2.b), 1-hour rated fire barriers with detection and suppression;

(Section III.G.2.c), or alternative shutdown capability; (Section III.G.3) is used

as a strategy for each selected fire zone/area;

c. A list of Generic Letter 86-10 evaluations (i.e., a list of adverse to safe

shutdown evaluations);

d. A list of applicable codes and standards related to the design of plant fire

protection features. The list should include National Fire Protection

Association (NFPA) code versions committed to (i.e., the NFPA Codes of

Record); and

e. List of plant deviations from code commitments and associated evaluations.

4. Facility Information:

a. Piping and instrumentation (flow) diagrams showing the components used to

achieve and maintain hot standby and cold shutdown for fires outside the

control room, those components used for those areas requiring alternative

shutdown capability, and systems relied upon for B.5.b mitigation strategies.

These can be of the type that are used for training;

b. One-line schematic drawings of the electrical distribution system for 4160

Volts alternating current (Vac) down to 480Vac;

c. One-line schematic drawings of the electrical distribution system for 250 Volts

direct current (Vdc) and 125Vdc systems as applicable;

d. Logic diagrams showing the components used to achieve and maintain hot

standby and cold shutdown; and

e. Safe shutdown cable routing database (requested electronically such as on

compact disc, if available.

3 Enclosure

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

5. Operations Response for Fire Protection:

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

information gathering visit);

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

fire alarm or annunciator; and

c. Procedure for calling out the fire brigade and requesting off-site assistance.

6. Corrective Actions:

a. Listing of open and closed fire protection condition reports (i.e., problem

identification forms and their resolution reports) since the date of the last

triennial fire protection inspection; and

b. List of current fire impairments, including duration.

7. General Information:

a. A listing of abbreviations and/or designators for plant systems;

b. Organization charts of site personnel down to the level of fire protection staff

personnel; and

c. A phone list for onsite licensee personnel.

8. B.5.b Mitigating Strategies:

a. A list of all modifications to regulatory commitments made to meet the

requirements of Section B.5.b of the ICM Order, EA-02-026, dated

February 25, 2002, the subsequently imposed license conditions, and

10 CFR 50.54(hh)(2);

b. Copies of procedures/guidelines that were revised or generated to implement

the mitigation strategies. These could be extensive damage mitigation

guidelines (EDMGs), severe accident management guidelines (SAMGs),

emergency operating procedures (EOPs), abnormal operating procedures

(AOPs), etc.;

c. A matrix that shows the correlation between the mitigation strategies identified

in Nuclear Energy Institute 06-12 and the site-specific procedures or

guidelines that are used to implement each strategy;

d. A listing of engineering evaluations/calculations that were used to verify

engineering bases for the mitigation strategies;

e. Copies of procedures used to inventory equipment (hoses, fittings, pumps,

etc.) required to be used to implement the mitigation strategies;

4 Enclosure

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

f. A list of B.5.b mitigating strategies, if any, which have implementing details

that differ from that documented in the submittals and the safety evaluation

report;

g. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire

departments) required to implement any mitigating strategies; and

h. A list of changes made to B.5.b mitigating strategies and associated

procedures since the previous NRC inspection of B.5.b mitigating strategies

(October 2008).

9. Onsite Discussions:

In addition, during the information gathering visit, it is requested that licensee staff

be available for the following:

a. Informal discussion on plant procedures operators would use in the event of

fire or explosion (including B.5.b mitigation strategies) and under what

conditions would the plant be shutdown using alternative shutdown

methodology;

b. Informal discussion on the plants safe shutdown cable routing database and

the plant-wide cable routing database, as applicable; and

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

III. Information Requested to be Available on First Day of the Second ONSITE

Inspection Week (August 8, 2011)

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

requested that this information be provided on four sets of CDs (searchable, if possible).

1. Program Procedures:

a. Procedures for:

i. Administrative controls (such as allowed out of service times and

compensatory measures) for fire protection systems and components

ii. Control of transient combustibles

iii. Control of hot work

b. List of maintenance and surveillance testing procedures for alternative

shutdown capability and fire barriers, detectors, pumps, and suppression

systems; and

c. List of maintenance procedures which routinely verify fuse breaker coordination

in accordance with the post-fire safe shutdown coordination analysis.

5 Enclosure

FIRE PROTECTION INSPECTION

DOCUMENT REQUESTS

2. Design and Equipment Information:

a. Coordination calculations and/or justifications that verify fuse/breaker

coordination for selected fire zones/areas (to be determined during

information gathering visit) that are fed off of the same electrical buses as

components in the protected safe shutdown train;

b. Copies of significant fire protection and post-fire safe shutdown related design

change package descriptions (including their associated 10 CFR 50.59

evaluations) and Generic Letter (GL) 86-10 (or adverse to safe shutdown)

evaluations;

c. Gaseous suppression system pre-operational testing, if applicable, for selected

fire zones/areas (to be determined during information gathering visit);

d. Hydraulic calculations and supporting test data which demonstrate operability

for water suppression systems, if applicable, for selected fire zones/areas (to

be determined during information gathering visit);

e. Alternating current (ac) coordination calculations for 4160Vac down to 480Vac

electrical systems; and

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

3. Assessment and Corrective Actions:

The three most recent fire protection Quality Assurance (QA) audits and/or fire

protection self-assessments.

4. Any updates to information previously provided.

IV. Information Requested to Be Provided Throughout the Inspection

1. Copies of any corrective action documents generated as a result of the inspection

teams questions or queries during this inspection.

2. Copies of the list of questions submitted by the inspection team members and the

status/resolution of the information requested (provided daily during the inspection to

each inspection team member).

If you have questions regarding the information requested, please contact the lead inspector.

6 Enclosure

M. Pacilio -2-

provided to the lead inspector via mail or electronically no later than July 5, 2011. The second group also

lists information and areas for discussion necessary to aid the inspection team in choosing specific fire

protection focus areas for the inspection and to ensure that the inspection team is adequately prepared

for the inspection. It is requested this information be available during the information gathering visit (July

25, 2011). The third group of requested documents consists of those items that the team will review, or

need access to, during the inspection. Please have this information available by the first day of the

second onsite inspection week (August 8, 2011). The fourth group lists the information necessary to aid

the inspection team in tracking issues identified as a result of the inspection. It is requested that this

information be provided to the lead inspector as the information is generated during the inspection. It is

important that all of these documents are up to date and complete in order to minimize the number of

additional documents requested during the preparation and/or the onsite portions of the inspection.

The lead inspector for this inspection is Ronald A. Langstaff. We understand that our regulatory contact

for this inspection is Mr. G. Ice, NRC Coordinator, and Dresden Regulatory Assurance, of your

organization. If there are any questions about the inspection or the material requested, please contact

the lead inspector at (630) 829-9747 or via e-mail at Ronald.Langstaff@nrc.gov.

This letter does not contain new or amended information collection requirements subject to

the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The

NRC may not conduct or sponsor, and a person is not required to respond to a request for information or

an information collection requirement unless the requesting document displays a currently valid Office of

Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure

will be available electronically for public inspection in the NRC Public Document Room or from the

Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA by R. A. Langstaff For/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos.: 50-237; 50-249

License Nos.: DPR 19; DPR 25

Enclosure: Fire Protection Inspection Document Request

cc w/encl: Distribution via ListServ

Distribution:

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OFFICE RIII RIII

NAME RLangstaff:ls RDaley

DATE 05/06/11 05/06/11

OFFICIAL RECORD COPY

Letter to Mr. Michael Pacilio from Mr. Robert C. Daley dated May 6, 2011.

SUBJECT: DRESDEN Nuclear Power Station NOTIFICATION OF AN NRC TRIENNIAL

FIRE PROTECTION BASELINE INSPECTION 05000237/2011008(DRS);

05000249/2011008(DRS)

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