ML21011A197

Unit 2, and Unit 3 - Notification of an NRC Fire Protection Baseline Inspection (NRC Inspection Report 05000528/2021012, 05000529/2021012 and 05000530/2021012) and Request for Information

ML21011A197
Person / Time
Site:	Palo Verde
Issue date:	01/12/2021
From:	Greg Pick Division of Reactor Safety IV
To:	Lacal M Arizona Public Service Co
References
IR 2021012
Download: ML21011A197 (11)

See also: IR 05000528/2021012

Text

January 12, 2021

Mrs. Maria L. Lacal

Executive Vice President/

Chief Nuclear Officer

Arizona Public Service Company

P.O. Box 52034, MS 7602

Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION, UNIT 1, UNIT 2,

AND UNIT 3 - NOTIFICATION OF AN NRC FIRE PROTECTION BASELINE

INSPECTION (NRC INSPECTION REPORT 05000528/2021012,

05000529/2021012 AND 05000530/2021012) AND REQUEST FOR

INFORMATION

Dear Mrs. Lacal:

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 Palo Verde

Nuclear Generating Station, Units 1, 2, and 3, in March and April 2021. The inspection team will

be comprised of three reactor inspectors from the NRC Region IV office. The inspection will be

conducted in accordance with Inspection Procedure 71111, Attachment 21N.05, Fire Protection

Team Inspection, the NRCs baseline fire protection inspection procedure.

The schedule for the inspection is as follows:

• Remote Inspection Planning Week: March 1 - 5, 2021

• Onsite Inspection: March 29 - April 2, and April 12 - 16, 2021

The team lead will review the initial set of documents requested in the enclosure to select the

scope of structures, systems, and components for evaluation and identify additional documents

needed to support the inspection. The enclosure to this letter provides an initial list of the

documents the team lead will need for review. We request that your staff transmit copies of the

documents listed in the enclosure to the NRC Region IV office for team use in preparation for

the inspection. Please send this information so that it will arrive in the NRC Region IV office by

the dates listed in the enclosure.

M. Lacal 2

During the remote inspection planning meeting, the team lead will also discuss the following

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

documents 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.

Because of the current pandemic, we will be assessing and minimizing our onsite time. We

anticipate that the first week will be onsite to accomplish a minimum amount of walkdowns. We

request that, during the on-site and in-office 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 that

establish 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). 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.

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections (approval number 3150-0011). Send comments

regarding this information collection to the Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,

DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office

of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, Washington, DC 20503.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct nor 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 OMB 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 Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

M. Lacal 3

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 me, the team lead inspector, in

the Region IV office at (817) 200-1270 or Greg.Pick@nrc.gov.

Sincerely,

Greg Pick, Senior Reactor Inspector

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-528; 50-529; 50-530

License Nos. NPF-41; NPF-51; NPF-74

Enclosure:

Triennial Fire Protection Inspection

Document Request

cc w/ encl: Distribution via LISTSERV

ML21011A197

Non-Sensitive Publicly Available

SUNSI Review

GP Sensitive Non-Publicly Available

OFFICE SRI:EB2

NAME GPick

DATE 1/12/2021

Triennial Fire Protection Inspection Document

Request

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

inspection team prior to the inspection. Electronic format is the preferred format, except where

specifically noted. If electronic files are made available via a secure document management

service, then the remote document access must allow inspectors to download, save, and print

the documents.

If a secure document management service is utilized, it is recommended that a separate folder

be used corresponding to each item listed below. It is recommended that multiple documents

within each folder be individually entered and combined into a ZIP file that is uploaded into the

same folder. Documents should be identified by both document number and noun name.

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

Where C-size paper drawings are requested, please prepare two copies. Retain one copy on

site for the Teams use during the inspection weeks. Send one copy to the team leader at the

NRC Region IV office.

To allow review before the remote inspection planning meeting, the documents requested in

items A.1 thru A.13 should be made available to the team no later than February 12, 2021.

Based on review of the documentation, the team leader will identify the initial selection of

inspection sample systems and/or fire areas during the remote inspection planning meeting.

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

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, all the requested documents should be

made available to the team no later than March 15, 2021.

A. DESIGN AND LICENSING BASIS DOCUMENTS

A.1 The current version of the Fire Protection Program and Fire Hazards Analysis.

A.2 Post-fire safe shutdown analysis and the supporting calculations that

demonstrate acceptable plant response.

A.3 The fire protection probabilistic risk assessment or portions of the plants

individual plant examination for external events (IPEEE) report addressing fire

events. Also, include the results of any post-IPEEE reviews and listings of

actions taken/plant modifications conducted in response to IPEEE information

that relate to fire risk.

A.4 Licensing basis documents for fire protection (safety evaluation reports, pertinent

sections of the final safety analysis report, exemptions, deviations, letters to/from

the NRC regarding fire protection/fire safe shutdown, etc.).

Enclosure

A.5 List of post-fire safe shutdown systems and components (i.e., safe shutdown

equipment list).

A.6 List of fire areas with automatic fire suppression systems.

A.7 A list, with descriptions, of design change packages performed since the last fire

protection team inspection associated with fire protection or post-fire safe

shutdown systems.

A.8 A list, with descriptions, of any fire protection program changes and evaluations

(not limited to Generic Letter 86-10 evaluations) performed since the last fire

protection team inspection.

A.9 Facility Operating License.

A.10 Technical Specifications (electronic format only).

A.11 Updated Final Safety Analysis Report (electronic format only).

A.12 A list of the ten most risk significant plant systems for core damage frequency

from the fire protection probabilistic risk assessment (if available) or the internal

events probabilistic risk assessment.

A.13 A list of the ten most risk significant plant systems for large early release

frequency from the fire protection probabilistic risk assessment (if available) or

the internal events probabilistic risk assessment.

A.14 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

A.15 For local manual operator actions, provide the following:

• Manual Action Feasibility Study

• Operator Time Critical Action Program

• Time lines for time-critical manual actions

• Time line validations

B. GENERAL PLANT DESIGN DOCUMENTS

B.1 Piping and instrumentation diagrams (P&IDs) and legend list for components

used to achieve and maintain post-fire safe shutdown for the sample systems or

fire areas selected (electronic format and C-size paper drawings).

B.2 Piping and instrumentation diagrams and legend list for fire protection systems,

including the fire water supply; water suppression sprinklers; and deluge,

gaseous suppression systems for the sample systems or fire areas selected

(electronic format and C-size paper drawings).

2

B.3 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.4 Single line diagrams for motor control centers (MCCs) that supply post-fire

nuclear safety component loads for the sample systems or fire areas selected

(electronic format and C-size paper drawings).

B.5 Equipment location drawings which identify the physical plant locations of post-

fire safety shutdown equipment for the sample systems or fire areas selected

(electronic format and C-size paper drawings).

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, with descriptions, of calculations and engineering analyses, studies, or

evaluations for the fire protection system, including the fire water system.

C.3 Last two completed surveillances of fire protection features for the sample

systems or fire areas selected (detection, suppression, damper inspections,

damper tests, penetration inspections, barrier inspections, etc.).

C.4 List, with descriptions, of routine tests, surveillances, and preventive

maintenance on fire pumps, including pump controllers and batteries.

C.5 Last two completed annual fire pump pressure and flow tests with a complete

copy of the test procedure.

C.6 Last two completed monthly and/or quarterly fire pump tests with a complete

copy of the test procedure.

C.7 Last two completed fire water system flow tests and flushes with a complete copy

of the test procedure.

C.9 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 three years

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

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

licensees staff

3

C.10 For fire brigade equipment provide the following:

• Procedure for inventory and inspection

• Most recent inspection and inventory results

C.11 Fire Brigade Qualifications, including self-contained breathing apparatus (SCBA)

and training lesson plans.

C.12 Copy of the evaluation or analysis of the effects of fire suppression activities on

the ability to achieve and maintain the plant in stable conditions for the sample

systems or fire areas selected 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.13 Pre-fire plans for all fire areas.

C.14 Impairment Log (at start of inspection) for fire protection features that are out of

service.

C.15 List of penetration seal work, re-work, or installation activities, in the last three

years.

C.16 List of fire wrap work, re-work, or installation activities, in the last three years.

C.17 Fire protection system health reports for the two most recent quarters.

C.18 Fire protection program health reports for the two most recent quarters.

C.19 Licensee evaluations of industry operating experience concerning fire protection

issues completed in the last three years.

C.20 List of fire event analysis reports for the last three years.

C.21 Fire protection program requirements (e.g., limiting conditions for operation,

surveillance test requirements) covered by technical specifications, the technical

requirements manual, the updated final safety analysis report, procedures or

similar documents.

C.22 Fire Protection System(s) Design Basis Document.

C.23 List of applicable NFPA codes and standards and issuance dates (i.e., codes of

record).

C.24 A list or document identifying any deviations from the NFPA codes of record.

4

C.25 Organization charts of site personnel down to the level of fire protection staff

personnel.

C.26 A contact list of key site personnel who will be supporting this inspection, giving

the office location and phone number onsite.

D. ELECTRICAL

D.1 Electrical system health reports for the two most recent quarters.

D.2 Surveillance procedures and last surveillance demonstrating operability of

components required for alternative shutdown.

E. OPERATIONS

E.1 The team would like to perform a walkthrough of a sample of post-fire safe

shutdown procedures with qualified operators in the plant during the week of

March 29, 2021. Please put us in contact with the appropriate personnel for

planning the walkthroughs during the onsite information gathering trip.

E.2 List, with descriptions, of licensed operator Job Performance Measures (JPMs)

for operator actions required to achieve and maintain post-fire safe shutdown.

E.3 List, with descriptions, of nonlicensed operator training associated with

nonlicensed operator actions to achieve and maintain post-fire nuclear safe

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

qualification).

E.4 Lesson plans for post-fire safe shutdown training for licensed and nonlicensed

operators.

E.7 Thermal hydraulic calculation or analysis that determines the time requirements

for time-critical manual operator actions.

E.8 Operating procedures to achieve and maintain post-fire safe shutdown from the

control room and requiring a control room evacuation.

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, with descriptions, of procedures that implement cold shutdown repairs.

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

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

• Most recent inspection and inventory results

5

F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION

PROGRAMS

F.1 Copies of procedures that control the configuration of the fire protection program,

features, and post-fire safe shutdown methodology and system design. Also,

copies of procedures that govern the implementation of plant modifications,

maintenance, and special operations and their impact on fire protection.

F.2 List, with descriptions, of open and closed condition reports for the fire protection

systems for the last 3 years.

F.3 List, with descriptions, of open and closed condition reports associated with the

post-fire safe shutdown analysis for the last 3 years.

F.4 List, with descriptions, of open and closed condition reports associated with

operator actions to achieve and maintain post-fire safe shutdown for the last

3 years.

F.5 List, with descriptions, of open and closed condition reports associated with the

fire protection program including plant change evaluations, post-fire operating

procedures and/or training, timeline evaluations for operator actions, and

supporting engineering evaluations, analysis, or calculations for the last 3 years.

F.6 List, with descriptions, of open and closed condition reports for emergency

lighting units for the last 3 years.

F.7 Self-assessments, peer assessments, and audits of fire protection activities for

the last 3 years.

F.8 Self-assessments, peer assessments, and audits of post-fire nuclear safety

capability methodology for the last 3 years.

F.9 Provide administrative procedures that control temporary modifications,

permanent plant changes, design changes, procedure changes, ageing

management changes, equivalency evaluations, suitability analyses,

calculations, commercial grade dedication, safety-security interface, and repairs.

F.10 Provide procedures that control the following: combustible controls, hot work,

monitoring, compensatory measures, and work-around.

F.11 Last five hot work permits (at power).

F.12 Last five transient combustible permits (at power).

6

G. Aging Management Program

G.1 Copies of the aging management programs applicable to fire protection including

but not limited to the following:

• Fire Protection

• Fire Water System

• Aboveground Metallic Tanks

• Buried and Underground Piping and Tanks

G.2 Copies of procedures, work orders, preventive maintenance tasks, or other

documents which implement the commitments made as part of the license

extension related to fire protection.

G.3 List of aging management activities related to fire protection performed to date.

7