ML20079J097
| ML20079J097 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/19/2020 |
| From: | Atif Shaikh Engineering Branch 3 |
| To: | Peter Dietrich DTE Energy |
| References | |
| IR 2020011 | |
| Download: ML20079J097 (9) | |
See also: IR 05000341/2020011
Text
March 19, 2020
Mr. Peter Dietrich
Chief Nuclear Officer
DTE Energy Company
Fermi 2 - 260 TAC
6400 North Dixie Highway
Newport, MI 48166
SUBJECT: FERMI POWER PLANT, UNIT 2 - NOTIFICATION OF NRC FIRE PROTECTION
TEAM INSPECTION REQUEST FOR INFORMATION; INSPECTION REPORT
NUMBERS 05000341/2020011
Dear Mr. Dietrich,
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 Fermi Power Plant,
Unit 2 beginning June 29, 2020. 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 SSCs and/or administrative controls credited in the approved
Fire Protection Program (FPP) can perform their licensing basis function.
The schedule for the inspection is as follows:
Preparation week (R-III office): June 22 - 26, 2020
Week 1 of onsite inspection: June 29 - July 3, 2020
Week 2 of onsite inspection: July 13 - 17, 2020
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 June 12, 2020. 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 June 29, 2020. 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. Atif Shaikh. We understand that our regulatory
contact for this inspection is Mr. Shane Gatter of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector at
630-829-9824 or via e-mail at Atif.Shaikh@nrc.gov.
P. Dietrich
-2-
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 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA/
Atif Shaikh, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket No:
50-341
License No:
NPF- 43
Enclosure:
Information Request for Fire Protection
Team Inspection
cc: Distribution via LISTSERV
P. Dietrich
-3-
Letter to Peter Dietrich from Atif Shaikh dated March 19, 2020.
SUBJECT: FERMI POWER PLANT, UNIT 2 - NOTIFICATION OF NRC FIRE PROTECTION TEAM
INSPECTION REQUEST FOR INFORMATION; INSPECTION REPORT NUMBERS
DISTRIBUTION:
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ADAMS Accession Number: ML20079J097
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DATE
3/19/2020
OFFICIAL RECORD COPY
Fire Protection Team Inspection Supporting Documentation
Enclosure
I.Information Requested Prior To the Inspection Preparation Week
The following information is requested by June 12, 2020. If you have any questions
regarding this request, please call the lead inspector as soon as possible. All information
should be sent to Atif Shaikh (e-mail address Atif.Shaikh@nrc.gov). Electronic media is
preferred. The preferred file format is a searchable pdf or Microsoft Excel file on a
compact disk (CD). The CD should be indexed and hyper-linked to facilitate ease of use, if
possible. Please provide three copies of each CD submitted (one for each inspector).
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.
3. Fire Protection Program:
a.
A listing of changes made to the FPP since the last triennial fire protection
inspection;
Fire Protection Team Inspection Supporting Documentation
2
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 fire
zones/areas. 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);
e.
List of plant deviations from code commitments and associated evaluations;
f.
Fire Protection Program and/or Fire Protection Plan document;
g.
(If available) Fire Probabilistic Risk Assessment (PRA) Summary Report or full
PRA document (if summary document not available);
h.
List of the top 25 highest fire CDF scenarios for each unit;
i.
List of Fire Areas/Zones ranked by contribution to CDF. i.e., ranking of highest to
lowest risk fire areas/zones;
j.
List of the top 25 highest fire LERF scenarios for each unit; and
k.
Risk ranking of operator actions and/or recovery actions from your site-specific
PRA sorted by RAW and human reliability worksheets for these items.
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, and those components used for those areas requiring alternative shutdown
capability;
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).
Fire Protection Team Inspection Supporting Documentation
3
5.
Operations Response for Fire Protection:
a.
Plant operating procedures which specify the initial operations response to a fire
alarm or annunciator.
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.
II. Information Requested to be Available on First Day of the FIRST ONSITE Inspection
Week (JUNE 29, 2020)
The following information is requested to be provided on the first day of inspection. It is
requested that this information be provided on three 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; and
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.
2. Design and Equipment Information (for only selected fire zone/area(s) and/or SSCs
to be determined during inspection preparation week):
a.
Coordination calculations and/or justifications that verify fuse/breaker
coordination for SSCs that are fed off of the same electrical buses as
components in the protected safe shutdown train;
Fire Protection Team Inspection Supporting Documentation
4
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;
d.
Hydraulic calculations and supporting test data which demonstrate operability for
water suppression systems;
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:
a.
The three most recent fire protection Quality Assurance (QA) audits and/or fire
protection self-assessments.
4. Any updates to information previously provided.
5. Classic Fire Protection (for only selected fire zone/area(s) and/or SSCs to be
determined during inspection preparation week):
a. Copy of fire protection program implementing procedures (e.g., administrative
controls, surveillance testing, and fire brigade);
b. Pre-fire plans for selected fire area(s); and
c. List of fire protection system design changes completed in the last three years.
6. Electrical (for only selected fire zone/area(s) and/or SSCs to be determined during
inspection preparation week):
a. Nuclear safety circuit coordination analysis for fuse and breaker coordination of safe
shutdown components;
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;
d. Last surveillance demonstrating operability of those components operated from the
primary control stations;
Fire Protection Team Inspection Supporting Documentation
5
e. Schematic or elementary diagrams for circuits (only for selected SSCs) to be
reviewed (C-size paper drawings);
f. Cable routing for components and equipment credited for post-fire nuclear safety
capability systems and components;
g. List of post-fire nuclear safety capability system and component design changes
completed, in the last three years; and
h. List of identified fire induced circuit failure analyses.
7. Operations:
a. List of procedures that implement Cold Shutdown Repairs (if applicable for selected
fire area);
b. 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.
c. List of licensed operator Job Performance Measures (JPMs) for operator actions
required to achieve and maintain post-fire nuclear safety performance criteria (for
selected SSCs and fire area);
d. 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.
e. Environmental and habitability evaluations for post-fire operator actions
(temperature, smoke, humidity, SCBAs, etc.).
8. 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; and
c. List of fire event analysis reports for the last three years.
9. Any updates to information previously provided.
Fire Protection Team Inspection Supporting Documentation
6
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).
PAPERWORK REDUCTION ACT STATEMENT
This letter contains voluntary 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). The burden to the public
for these information collections is estimated to average 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per response. Send
comments regarding this information collection to the Information Services Branch, Office of the
Chief Information Officer, Mail Stop: O-1F13, 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.