ML22307A176

Notification of an NRC Fire Protection Team Inspection (Fpti)

ML22307A176
Person / Time
Site:	Brunswick
Issue date:	11/07/2022
From:	Gerald Mccoy NRC/RGN-II/DRS/EB2
To:	Krakuszeski J Duke Energy Progress
References
IR 2023011
Download: ML22307A176 (1)

Text

November 7, 2022 John A. Krakuszeski Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd. SE (M/C BNP001)

Southport, NC 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - NOTIFICATION OF AN NRC FIRE PROTECTION TEAM INSPECTION (FPTI) (NRC INSPECTION REPORT 05000324/2023011 and 05000325/2023011) AND REQUEST FOR INFORMATION (RFI)

Dear Mr. Krakuszeski:

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

Region II staff will conduct a fire protection team inspection (FPTI) at the Brunswick Steam Electric Plant, Units 1 and 2, in February 2023. The inspection team will be led by Mr. William Monk, a Senior Reactor Inspector from the NRC Region II Office. The inspection team will be comprised of four inspectors from the NRC Region II 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.

On 31 October 2022, during e-mail and phone call exchanges between Mr. Thomas Sherrill of your staff and Mr. Monk, our respective staffs confirmed arrangements for a two-week onsite inspection. The schedule for the inspection is as follows:

Week 1 of onsite inspection: 30 JAN - 03 FEB 2023 In-Office Review: 06 FEB - 10 FEB 2023 Week 2 of onsite inspection: 13 FEB - 17 FEB 2023 The team lead (TL) and senior reactor analyst (SRA) will work with your staff prior to the start of the inspection to select the scope of structures, systems, and components (SSCs) for evaluation; identify additional documents needed to support the inspection; and obtain unescorted plant access.

The enclosure to this letter provides an initial list of the documents the team will need for their review. We request that your staff transmit copies of the documents listed in the enclosure to the NRC Region II office for team use in preparation for the inspection. Please send this information so that it will arrive in the NRC Region II office by the dates listed in the enclosure.

J. Krakuszeski 2 During the weeks leading up to the inspection, the team leader will discuss with your staff 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.

We request that during the on-site inspection weeks you ensure that copies of analyses, evaluations, or documentation regarding the implementation and maintenance of the station fire protection program (FPP), including the success path necessary to achieve and maintain the nuclear safety performance criteria / safe shutdown, be readily accessible to the team for their review. Of specific interest for the fire protection portion of the inspection are those documents which establish that your fire protection program satisfies NRC regulatory requirements and conforms to applicable NRC and industry fire protection guidance (i.e., fire protection compliance assessment documents). 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 / safe shutdown, reactor plant fire protection systems and features, and the station fire protection program and its implementation.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget under control number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

This letter and its enclosure will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Your cooperation and support during this inspection will be appreciated. If you have questions concerning this inspection or the inspection teams information or logistical needs, please contact William Monk, the team lead inspector, in the Region II office at (404) 997-4579 or william.monk@nrc.gov, or me at (404) 997-4551.

Sincerely, Signed by McCoy, Gerald on 11/07/22 Gerald J. McCoy, Branch Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-324 & 50-325 License No. DPR-71 & DPR-62

Enclosures:

Fire Protection Team Inspection Document Request cc w/enclosure: via ListServ

J. Krakuszeski 3

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - NOTIFICATION OF AN NRC FIRE PROTECTION TEAM INSPECTION (FPTI) (NRC INSPECTION REPORT 05000324/2023011 and 05000325/2023011) AND REQUEST FOR INFORMATION (RFI) dated November7, 2022 ADAMS Accession :ML_22307A176 SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials Publicly Avail Yes No Sensitive Yes No Sens. Type Initials RII: DRS/EB2 RII: DRS/EB2 G. McCoy W. Monk 11/7/2022 11/3/2022 OFFICIAL RECORD COPY

Fire Protection Team Inspection (FPTI) Document Request The initial request for information (i.e., first RFI) concentrates on providing the inspection team with the general information necessary to select appropriate samples to develop a site-specific inspection plan. The first RFIs requested information is specified below in items A.1 thru A.22, and is requested to be provided by December 16, 2022, or sooner, to facilitate the selection of the specific items that will be reviewed during the onsite inspection weeks.

Electronic format is the preferred format, except where specifically noted. If electronic files are made available via a secure document management service (i.e., Certrec), then the remote document access must allow inspectors to download, save, and print the documents in the NRCs regional office or site Residents office.

If a secure document management service is utilized, it is recommended that a separate folder be used corresponding to each item listed below. Documents should be identified by both document number and noun name. Electronic media on compact disc or paper records (hard copy) are also acceptable.

The inspection team will examine the returned documentation from the first RFI and identify/select specific inspection samples to provide a more focused follow-up request to develop the second RFI. The inspection team will submit the specific selected samples to your staff by December 23, 2022. We request that the additional information provided from the second RFI be made available by January 20, 2023.

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.

Enclosure

A. DESIGN AND LICENSING BASIS DOCUMENTS - NFPA 805 LICENSEE A.1 The current version of the Fire Protection Program/Plan and Fire Hazards Analysis (FHA).

A.2 Post-fire safe shutdown analysis (or Post-fire Nuclear Safety Capability, Systems, and Separation Analysis Fire) and the supporting calculations that demonstrate acceptable plant response.

A.3 Fire PRA Summary Report, and list of Fire PRA calculations.

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

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

A.6 List of fire areas with automatic fire suppression systems and types (i.e., wet pipe, CO2, Halon, etc.).

A.7 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 List, with descriptions, of any fire protection program changes and evaluations (not limited to GL 86-10 evaluations) performed since the last fire protection team inspection.

A.9 Fire Protection System(s) Design Basis Document. NFPA 805 Report.

A.10 List of applicable NFPA codes and standards and issuance dates (i.e., NFPA codes of record).

A.11 A list or document identifying any deviations from the NFPA codes of record.

A.12 Facility Operating License (FOL) - Fire Protection Requirements Only.

A.13 Sites Technical Specifications (electronic format only).

A.14 Updated Final Safety Analysis Report (UFSAR) Fire Protection (electronic format only).

o Section 9.10, Fire Protection o Section 18.2.7, Fire Protection Program A.15 COPY of NRC Safety Evaluation Reports that form the licensing basis for:

o Fire Protection Program and Post-fire Nuclear Safety Capability / Safe Shutdown.

A.16 COPY of NRC approved exemptions for plant fire protection and post-fire nuclear safety capability features.

A.17 COPY of exemption requests submitted, but not yet approved for plant fire protection and post-fire nuclear safety capability features.

A.18 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).

A.19 List of the top 25 highest fire CDF scenarios for each unit.

A.20 List of the top 25 highest fire LERF scenarios for each unit.

A.21 From your most recent PRA including external events and fires:

o Two risk rankings of components from your site-specific PRA: one sorted by Risk Achievement Worth (RAW), and the other sorted by Birnbaum Importance o A list of the top 500 cut-sets A.22 Copy of the Quality Assurance (QA) Program Manual (including specific fire protection QA manual, if applicable).

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