ML18324A813
| ML18324A813 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/19/2018 |
| From: | Greg Werner NRC/RGN-IV/DRS/EB-2 |
| To: | Dent J Nebraska Public Power District (NPPD) |
| Werner G | |
| References | |
| Download: ML18324A813 (14) | |
See also: IR 05000298/2019010
Text
November 19, 2018
Mr. John Dent, Jr.
Vice President-Nuclear and CNO
Nebraska Public Power District
Cooper Nuclear Station
72676 648A Avenue
P.O. Box 98
Brownville, NE 68321
SUBJECT: COOPER NUCLEAR STATION - NOTIFICATION OF AN NRC TRIENNIAL
FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION
REPORT 05000298/2019010) AND REQUEST FOR INFORMATION
Dear Mr. Dent:
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 Cooper Nuclear
Station in April and May 2019. The inspection team will be comprised of four reactor inspectors
from the NRC Region IV office. The inspection will be conducted in accordance with Inspection
Procedure 71111.05XT, Fire Protection - NFPA 805 (Triennial), the NRCs baseline fire
protection inspection procedure.
The schedule for the inspection is as follows:
- Information gathering visit: March 26 - 27, 2019
- On-site inspection: April 15 - 19, 2019
April 29 - May 3, 2019
The purpose of the information gathering visit is to obtain information and documentation
needed to support the inspection and to become familiar with the fire protection program, fire
protection features, safe shutdown success paths, plant layout, and mitigating strategies to
address Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security
Compensatory Measures, dated February 25, 2002, and 10 CFR 50.54(hh)(2).
The team leader will participate in the information gathering visit to select the fire areas for
evaluation, identify additional documents needed to support the inspection, obtain unescorted
access, and meet with the key personnel who will support the inspection. The fire area
J. Dent 2
selection will require a walkdown of candidate fire areas with key personnel from your staff. The
enclosures to this letter provide an initial list of the documents the team will need for their
review.
During the information gathering visit, the team leader 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.
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, 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 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). For the 10 CFR 50.54(hh)(2) portion of the inspection, those documents
implementing your mitigating strategies and demonstrating the management of your
commitments for the strategies are of specific interest. 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.
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 enclosures 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.
J. Dent 3
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 John Mateychick, the team lead inspector, in the Region IV office at (817) 200-1560 or
john.mateychick@nrc.gov.
Sincerely,
/RA/
Gregory E. Werner, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-298
License No. DPR-46
Enclosures:
1. Triennial Fire Protection Inspection Document Request
2. Mitigating Strategies Document Request
cc w/ Enclosures: Electronic Distribution for Cooper Nuclear Station
Triennial Fire Protection Inspection Document Request
The documents and information requested below should generally be made available to the
inspection team during 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 in the NRCs regional office.
If a secure document management service is utilized, it is recommended that a separate folder
be used corresponding to each item listed below and that multiple documents within each folder
be combined into a ZIP file before uploading. Electronic media on compact disc or paper
records (hard copy) are also acceptable.
To allow review before the on-site information gathering visit, the following documents should be
made available to the team in the regional office no later than March 15, 2019:
- Post-fire Nuclear Safety Capability, Systems, and Separation Analysis (request A.1)
- Fire Hazards Analysis and/or NFPA 805 Design Basis Document (request A.2)
- Fire Probabilistic Risk Assessment (PRA) Summary Document or full PRA Document
(request A.3)
- Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3) (request A.5)
- Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4) (request A.6)
- Analysis that demonstrates nuclear safety performance criteria can be achieved and
maintained for those areas that require recovery actions (request A.7)
Based on a review of the above seven items, team leader should identify a preliminary list of fire
areas being considered for inspection prior to the on-site information gathering visit. During the
information gathering visit, or shortly thereafter, the fire areas selected for inspection will be
determined.
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
of 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, the following documents should be made
available to the team in the regional office no later than March 28, 2019.
Enclosure 1
A. DESIGN AND LICENSING BASIS DOCUMENTS
A.1 Post-fire Nuclear Safety Capability, Systems, and Separation Analysis
A.2 Fire Hazards Analysis and/or NFPA 805 Design Basis Document
A.3 Fire PRA Summary Document or full PRA Document (if summary document not
available)
A.4 NFPA 805 Transition Report, developed in accordance with NEI 04-02
A.5 Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3)
A.6 Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4)
A.7 Analysis that demonstrates nuclear safety performance criteria can be achieved
and maintained for those areas that require recovery actions
A.8 Fire Protection Program and/or Fire Protection Plan
A.9 List of post-fire safe shutdown components (i.e., safe shutdown equipment list)
A.10 Fire Protection System Design Basis Document
A.11 List of applicable NFPA codes and standards and issuance dates (i.e., codes of
record)
A.12 List of deviations from (a) NFPA codes of record or (b) NFPA 805 fundamental
fire protection program and design elements (i.e., NFPA 805, Chapter 3)
A.13 NFPA compliance review report
A.14 Copy of licensee submittals and NRC safety evaluation reports that are
specifically listed in the facility operating license for the approved fire protection
program
A.15 Copy of NRC Safety Evaluation Reports that form the licensing basis for:
- Post-fire Nuclear Safety Capability
A.16 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.17 Facility Operating License
A.18 Technical Specifications (electronic format only)
A.19 Technical Requirements Manual (electronic format only)
2
A.20 Updated Final Safety Analysis Report (electronic format only)
B. GENERAL PLANT DESIGN DOCUMENTS
B.1 Piping and instrumentation diagrams (P&IDs) and legend list for components
used to achieve and maintain nuclear safety performance criteria for: (electronic
format and C-size paper drawings)
- Fires outside the main control room
- Fires in areas requiring recovery actions at other than primary control
stations
B.2 Piping and instrumentation diagrams and legend list for fire protection systems,
including the fire water supply; water suppression sprinklers; and deluge, CO2,
and Halon systems (electronic format and C-size paper drawings)
B.3 Yard layout drawings for underground fire protection buried piping (electronic
format and C-size paper drawings)
B.4 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.5 Single line diagrams for motor control centers (MCCs) that supply post-fire
nuclear safety component loads (only for selected fire areas) (electronic format
and C-size paper drawings)
B.6 Equipment location drawings which identify the physical plant locations of post-
fire nuclear safety capability equipment (electronic format and C-size paper
drawings)
B.7 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
- Locations of fire protection equipment
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 of calculations and engineering analyses, studies, or evaluations for the fire
protection system, including the fire water system
C.3 Hydraulic calculation or analysis for fire protection water system
3
C.4 Last two completed surveillances of fire protection features in the selected fire
areas (detection, suppression, damper inspections, damper tests, penetration
inspections, barrier inspections, etc.)
C.5 List of routine tests, surveillances, and preventive maintenance on fire pumps,
including pump controllers and batteries
C.6 Last two completed annual fire pump pressure and flow tests
C.7 Last two completed monthly and/or quarterly fire pump tests
C.8 Last two completed fire loop flow tests and loop flushes
C.9 CO2 and Halon initial discharge testing or calculation that determined appropriate
concentrations and soak or hold times can be achieved (only for selected fire
areas)
C.10 Last five hot work permits (at power)
C.11 Last five transient combustible permits (at power)
C.12 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
C.13 For fire brigade equipment provide the following:
- Procedure for inventory and inspection
- Most recent inspection and inventory results
C.14 Fire Brigade Qualifications, including self-contained breathing apparatus, (SCBA)
and training lesson plans
C.15 Copy of the mutual aid agreement for the first-due local fire department that is
currently in effect
4
C.16 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) 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.17 Pre-fire plans for all fire areas
C.18 For emergency lighting units, provide the following:
- Copy of performance-based emergency light assessments
- List of Preventive Maintenance tasks, frequencies, and bases
- Most recently performed monthly or quarterly functional test
- Most recently performed battery discharge performance test or
conductance measurement test
- Emergency lighting units battery loading analysis
- Vendor manual(s) for on-site inspector use
- Results of black-out testing (if performed)
- Maintenance Rule program information related to the emergency lighting
system
- Compensatory measures taken when emergency lighting units are out of
service
- Drawings showing emergency light locations and lamp orientation
C.19 Impairment Log (at start of inspection) for fire protection features that are out of
service
C.20 Fire protection screening reviews for recent design changes, modifications, or
temporary modifications (i.e., an NFPA 805 plant change evaluation that
screened out) in the last three years
5
C.21 List of penetration seal work, re-work, or installation activities, in the last three
years
C.22 List of fire wrap work, re-work, or installation activities, in the last three years
C.23 Fire protection system health reports for the two most recent quarters
C.24 Fire protection program health reports for the two most recent quarters
C.25 Emergency lighting system health reports for the two most recent quarters
C.26 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)
C.27 List of fire protection system NFPA 805 engineering equivalency evaluations
completed in the last three years
C.28 Licensee evaluations of industry operating experience concerning fire protection
issues completed in the last three years
D. ELECTRICAL
D.1 Identify whether the cables in the selected fire areas are predominantly
thermoset or thermoplastic. Specifically identify any thermoplastic cable in the
selected fire areas
D.2 Nuclear safety circuit coordination analysis for fuse and breaker coordination of
nuclear safety capability components (only for selected fire areas)
D.3 Administrative or configuration control procedures that govern fuse replacement
(e.g., fuse control procedures)
D.4 Maintenance procedures that verify breaker over-current trip settings to ensure
coordination remains functional for post-fire nuclear safety capability components
D.5 Electrical system health reports for the two most recent quarters
D.6 Last surveillance demonstrating operability of those components operated from
the primary control stations
D.7 Schematic or elementary diagrams for circuits to be reviewed (samples to be
identified by the inspector) (C-size paper drawings)
D.8 Cable routing for components and equipment credited for post-fire nuclear safety
capability systems and components (only for selected fire areas)
D.9 List of post-fire nuclear safety capability system and component design changes
completed in the last three years
6
D.10 List of identified fire induced circuit failure configurations (only for selected fire
areas)
E. OPERATIONS
E.1 List of calculations and engineering analyses, studies, or evaluations for the
nuclear safety capability methodology
E.2 List of licensed operator Job Performance Measures (JPMs) for operator actions
required to achieve and maintain post-fire nuclear safety performance criteria
E.3 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)
E.4 Lesson plans for post-fire nuclear safety capability training for licensed and non-
licensed operators
E.5 For recovery actions, provide the following:
- Manual Action Feasibility Study
- Operator Time Critical Action Program
- Time lines for time-critical recovery actions
- Time line validations
E.6 Thermal hydraulic calculation or analysis that determines the time requirements
for time-critical manual operator actions
E.7 Operating procedures to achieve and maintain nuclear safety performance
criteria from the control room with a postulated fire in the selected fire areas
E.8 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) and
any associated procedure basis documents
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 of procedures that implement cold shutdown repairs
E.11 For cold shutdown repairs, provide the following:
- Procedure for inventory and inspection (i.e., needed tools, material, etc.)
- Most recent inspection and inventory results
7
E.12 For radio communications, provide the following:
- Communications Plan for firefighting and post-fire safe shutdown manual
actions
- Repeater locations
- Cable routing for repeater power supply cables
- Radio coverage test results
- Radio Dead Spot locations in the plant
E.13 For telephone, plant pager or sound powered phone systems, if relied upon to
achieve and maintain safe and stable conditions, provide the following:
- Communications Plan for firefighting and post-fire safe shutdown manual
actions
- Locations of phone, pager units, sound powered phone jacks and sound
powered phone headsets
- Cable routing including power supply cables
E.14 Environmental and habitability evaluations for post-fire operator actions
(temperature, smoke, humidity, SCBAs, etc.)
F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION
PROGRAMS
F.1 Corrective actions for fire-induced circuit failures (including but not limited to NRC
IN 92-18), both single and multiple spurious actuations (only for selected fire
areas)
F.2 Corrective actions associated with operator actions to achieve and maintain post-
fire nuclear safety performance criteria
F.3 Self assessments, peer assessments, and audits of fire protection activities for
the last three years
F.4 Self assessments, peer assessments, and audits of post-fire nuclear safety
capability methodology for the last three years
F.5 List of open and closed condition reports for the fire protection system for the last
three years
F.6 List of fire event analysis reports for the last three years
F.7 List of open and closed condition reports for emergency lighting units for the last
three years
8
F.8 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.
F.9 List of procedures that control the configuration of the fire protection program,
features, and post-fire nuclear safety capability methodology and system design
9
Mitigating Strategies Document Request
G. 10 CFR 50.54(hh)(2) MITIGATING STRATEGIES DOCUMENTS
G.1 List of all changes to regulatory commitments made to meet the requirements of,
Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and
Security Compensatory Measures, dated February 25, 2002, and Title 10 of the
Code of Federal Regulations (10 CFR) 50.54(hh)(2).
G.2 List of procedures and guidelines that were revised or generated to implement
the mitigating strategies. These could be extensive damage mitigation guidelines
(EDMGs), severe accident management guidelines (SAMGs), emergency
operating procedures (EOPs), abnormal operating procedures (AOPs), etc.
G.3 A matrix that shows the correlation between the mitigation strategies identified in
Nuclear Energy Institute, 06-12, Revision 2, B.5.b Phase 2 & 3 Submittal
Guideline, issued December 2006, and the site-specific procedures or
guidelines that are used to implement each strategy.
G.4 List of engineering evaluations or calculations that were used to verify the
engineering bases for the mitigating strategies.
G.5 Piping and instrumentation diagrams (P&ID) and legend list or simplified flow
diagrams for systems relied upon in the mitigating strategies. These could be the
type used for training (electronic format and C-size paper drawings).
G.6 List of modification packages or summary descriptions of modifications with
simplified drawings, for necessary facility changes to implement the mitigating
strategies.
G.7 List of routine tests, surveillances, and preventive maintenance for equipment
and tools needed to implement 10 CFR 50.54(hh)(2) strategies.
G.8 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies,
provide the following:
- Procedures for inventory and inspection
- Most recent inspection and inventory results
G.9 List of 10 CFR 50.54(hh)(2) strategies, if any, which have implementing details
that differ from that documented in the submittals or the safety evaluation report.
G.10 Site general arrangement drawings that show the majority of buildings and areas
referenced in 10 CFR 50.54(hh)(2) documents (electronic format and C-size
paper drawings).
G.11 Training records, training matrix, and lesson plans related to
10 CFR 50.54(hh)(2).
G.12 Copies of memoranda of understanding (MOU) (e.g., with local fire departments)
required to implement any mitigating strategies.
Enclosure 2
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002
By: JMM Yes No Publicly Available Sensitive
OFFICE SRI:EB2 C:EB2
NAME JMateychick GWerner
SIGNATURE /RA/ /RA/
DATE 11/19/2018 11/19/2018