ML22214A704

Reissue - Davis-Besse Nuclear Power Station, Unit 1 Notification of Nrc Fire Protection Team Inspection Request for Information: Inspection Report 05000346/2022011

ML22214A704
Person / Time
Site:	Davis Besse
Issue date:	08/02/2022
From:	Benny Jose Engineering Branch 3
To:	Tony Brown Energy Harbor Nuclear Corp
References
IR 2022011
Download: ML22214A704 (9)

See also: IR 05000346/2022011

Text

August 2, 2022

Mr. Terry Brown

Site Vice President

Energy Harbor Nuclear Corp.

Davis-Besse Nuclear Power Station

5501 N. State Rte. 2, Mail Stop A-DB-3080

Oak Harbor, OH 43449-9760

SUBJECT: REISSUE - DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1

NOTIFICATION OF NRC FIRE PROTECTION TEAM INSPECTION

REQUEST FOR INFORMATION: INSPECTION REPORT 05000346/2022011

Dear Mr. Brown:

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

Region III staff will conduct a Fire Protection Team Inspection (FPTI) at your Davis-Besse

Nuclear Power Station, beginning October 3, 2022. The inspection will be conducted in

accordance with IP 71111.21N.05, Fire Protection Team Inspection (FPTI), dated

June 12, 2019.

The inspection will verify that plant Systems, Structures, and Components (SSCs) and/or

administrative controls credited in the approved Fire Protection Program (FPP) can perform

their licensing basis functions.

The schedule for the inspection is as follows:

Preparation week (R-III office): September 26, 2022

Week 1 of onsite inspection: October 03 - 07, 2022

Week 2 of onsite inspection: October 17 - 21, 2022

Experience has shown that the baseline fire protection team 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 three groups.

The first group lists information necessary to aid the inspection team in choosing specific focus

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

inspection. It is requested that this information be provided to the lead inspector via mail or

electronically no later than September 05, 2022.

The second 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 first onsite inspection week October 03, 2022.

T. Brown -2-

The third 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 Mr. B. Jose. If there are any questions about the

inspection or the material requested, please contact the lead inspector at 630-829-9756 or via

Cell Phone, 847-715-8887 or via e-mail at Benny.Jose@nrc.gov. 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 Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding.

Sincerely,

Signed by Jose, Benny

on 08/02/22

Benny Jose, Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket No. 05000346

License No. NPF-3

Enclosure:

Information Request for Fire Protection

Team Inspection

cc: Distribution via LISTSERV

T. Brown -3-

Letter to Terry Brown from Benny Jose dated August 2, 2022.

SUBJECT: REISSUE - DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1

NOTIFICATION OF NRC FIRE PROTECTION TEAM INSPECTION

REQUEST FOR INFORMATION: INSPECTION REPORT 05000346/2022011

DISTRIBUTION:

Jessie Quichocho

Robert Orlikowski

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RidsNrrPMDavisBesse Resource

RidsNrrDroIrib Resource

John Giessner

Mohammed Shuaibi

Diana Betancourt-Roldan

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML22214A704

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME BJose:jw

DATE 08/02/2022

OFFICIAL RECORD COPY

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

I. Information Requested Prior to the Inspection Preparation Week

The following information is requested by September 05, 2022. If you have any questions

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

should be sent to Benny Jose (e-mail address) Benny.Jose@nrc.gov. Electronic media is

preferred (e.g., via Share File System or BOX).

1. Design and Licensing Basis Documents

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

b. Fire Hazards Analysis and/or National Fire Protection Association (NFPA)

805 Design Basis Document.

c. Fire Probabilistic Risk Assessment (PRA) Summary Document or full PRA

Document (if summary document not available).

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

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

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

g. Analysis that demonstrates nuclear safety performance criteria can be achieved

and maintained for those areas that require recovery actions.

h. Fire Protection Program (FPP) and/or Fire Protection Plan.

i. Copies of the current versions of the Facility Operating License and Technical

Requirements Manual.

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

k. Fire protection system design basis document.

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

record).

m. List of deviations from (a) NFPA codes of record, or (b) NFPA 805 fundamental

FPP and design elements (i.e., NFPA 805, Chapter 3).

n. NFPA Compliance Review Report.

o. Report or evaluation that compares the FPP to the Nuclear Regulatory

Commission (NRC) Branch Technical Position (BTP) 9.5-1 Appendix A.

p. Copy of licensee submittals and NRC safety evaluation reports that are

specifically listed in the facility operating license for the approved FPP.

Enclosure

NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

q. Copy of NRC Safety Evaluation Reports that form the licensing basis for the FPP

and post-fire nuclear safety capability.

r. Copy of NRC approved exemptions for plant fire protection and post-fire nuclear

safety capability features.

s. Copy of exemption requests submitted but not yet approved for plant fire protection

and post-fire nuclear safety capability features.

t. List of nuclear safety capability design changes completed in the last three years

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

2. Operations

a. Operating procedures to achieve and maintain nuclear safety performance criteria

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

b. Operating procedures to achieve and maintain nuclear safety performance criteria

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

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

performed in the control room or primary control stations).

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

nuclear safety capability methodology.

d. For recovery actions, provide the following:

i. Manual Action Feasibility Study;

ii. Operator Time Critical Action Program;

iii. Timelines for time-critical recovery actions; and

iv. Timeline validations.

e. Thermal hydraulic calculation or analysis that determines the time requirements for

time-critical manual operator actions.

3. Facility Information

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.

4. General Plant Design Documents (available onsite for inspector review)

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

used to achieve and maintain nuclear safety performance criteria for: (C-size

paper drawings)

i. Fires outside the main control room; and

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

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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

b. P&IDs and legend list for fire protection systems, including fire water supply,

water suppression sprinklers & deluge, and carbon dioxide (CO2) and Halon

systems (C size paper drawings).

c. Yard layout drawings for underground fire protection buried piping (C-size paper

drawings).

d. AC and DC electrical system single line diagrams, from off-site power down to the

highest safety-related bus level (typically 4kV, EDG bus) (C-size paper drawings).

e. Single line diagrams for motor control centers (MCCs) that supply post-fire nuclear

safety component loads (only for selected fire areas) (C-size paper drawings).

f. Equipment location drawings which identify the physical plant locations of post-fire

nuclear safety capability equipment (C-size paper drawings).

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

standby and cold shutdown.

5. Administrative Control, Oversight, and Corrective Action Programs

a. Corrective actions associated with operator actions to achieve and maintain

post-fire nuclear safety performance criteria.

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

three years.

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

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

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

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

training, timeline evaluations for operator actions, and supporting engineering

evaluations, analysis, or calculations.

d. List of procedures that control the configuration of the FPP, features, and post-fire

nuclear safety capability methodology and system design.

6. 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 personnel.

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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

II. Information Requested to Be Available on first Day of the first Onsite Inspection

Week (October 03, 2022)

1. Classic Fire Protection

a. Copy of FPP implementing procedures (e.g., administrative controls, surveillance

testing, and fire brigade).

b. List of calculations and engineering analyses, studies, or evaluations for the fire

protection system, including the fire water system.

c. Hydraulic calculations or analyses for fire protection water system.

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

ability to achieve the nuclear safety performance criteria (only for selected fire

areas), including:

i. An automatic or manually actuated suppression system, due to a fire in a

single location, will not indirectly cause damage to the success path;

ii. Inadvertent actuation or rupture of a suppression system will not indirectly

cause damage to the success path;

iii. Demonstration of adequate drainage for areas protected by water suppression

systems; and

iv. Hydrostatic rating of any floor penetration seals installed within the fire areas

that are credited with keeping water from leaking into fire areas below.

e. Pre-fire plans for selected fire areas.

f. List of fire protection system design changes completed in the last three years

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

evaluations).

g. List of fire protection system NFPA 805 engineering equivalency evaluations

completed in the last three years.

h. Copy of any test, surveillance, or maintenance procedure (current revision),

including any associated data forms, for any requested last performed test,

surveillance, or maintenance.

2. Electrical

a. Nuclear safety circuit coordination analysis for fuse and breaker coordination of

nuclear safety capability components (only for selected fire areas).

b. Administrative or configuration control procedures that govern fuse replacement

(e.g., fuse control procedures).

c. Maintenance procedures that verify breaker over-current trip settings to ensure

coordination remains functional, for post-fire nuclear safety capability components.

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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

d. Last surveillance demonstrating operability of those components operated from

the primary control stations.

e. Schematic or elementary diagrams for circuits to be reviewed (C-size paper

drawings).

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

capability systems and components (only for selected fire areas).

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

completed, in the last three years.

h. List of identified fire induced circuit failure analyses (only for selected fire areas).

3. Operations

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

i. Procedure for inventory and inspection; and

ii. Most recent inspection and inventory results.

b. List of procedures that implement Cold Shutdown Repairs.

c. For Cold Shutdown Repairs, provide the following:

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

ii. Most recent inspection and inventory results.

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

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

e. List of non-licensed operator training associated with non-licensed operator

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

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

f. Lesson plans for post-fire nuclear safety capability training for licensed and

non-licensed operators.

g. For Radio communications, provide the following:

i. Communications Plan for firefighting and post-fire safe shutdown manual

actions;

ii. Repeater locations;

iii. Cable routing for repeater power supply cables;

iv. Radio coverage test results; and

v. Radio Dead Spot locations in the plant.

h. Environmental and habitability evaluations for post-fire operator actions

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

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NOTIFICATION OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION

REQUEST FOR INFORMATION

4. Administrative Control, Oversight, and Corrective Action Programs

a. Self-assessments, peer assessments, and audits of fire protection activities

for the last three years.

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

capability methodology for the last three years.

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

5. Any updates to information previously provided.

III. 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.

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