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| {{#Wiki_filter:June 17, 2021 | | {{#Wiki_filter: |
| Mr. Rod Penfield
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| Site Vice President
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| Energy Harbor Nuclear Corp.
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| Perry Nuclear Power Plant
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| 10 Center Road,
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| Perry, OH 44081
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| SUBJECT: PERRY NUCLEAR POWER PLANTNOTIFICATION OF NRC FIRE
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| PROTECTION TEAM INSPECTION REQUEST FOR INFORMATION;
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| INSPECTION REPORT 05000440/2021010
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| Dear Mr. Penfield:
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| The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
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| Region III staff will conduct a Fire Protection Team Inspection at your Perry Nuclear Power
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| Plant beginning September 13, 2021. The inspection will be conducted in accordance with
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| Inspection Procedure 71111.21N.05, Fire Protection Team Inspection, dated June 12, 2019.
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| The inspection will verify that plant SSCs and/or administrative controls credited in the approved
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| Fire Protection Program can perform their licensing basis function.
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| The schedule for the inspection is as follows:
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| Preparation week (R-III office): September 6 - 10, 2021
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| Week 1 of onsite inspection: September 13 - 17, 2021
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| Week 2 of onsite inspection: September 27 - October 1, 2021
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| Experience has shown that the baseline fire protection team inspections are extremely resource
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| intensive, both for the NRC inspectors and the licensee staff. In order to minimize the
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| inspection impact on the site and to ensure a productive inspection for both organizations, we
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| have enclosed a request for documents needed for the inspection. These documents have
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| been divided into three groups.
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| The first group lists information necessary to aid the inspection team in choosing specific
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| focus areas for the inspection and to ensure that the inspection team is adequately
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| prepared for the inspection. It is requested that this information be provided to the lead
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| inspector via mail or electronically no later than August 20, 2021.
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| The second group of requested documents consists of those items that the team will
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| review, or need access to, during the inspection. Please have this information available
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| by the first day of the first onsite inspection week September 13, 2021.
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| R. Penfield -2-
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| The third group lists the information necessary to aid the inspection team in tracking
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| issues identified as a result of the inspection. It is requested that this information be
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| provided to the lead inspector as the information is generated during the inspection. It is
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| important that all of these documents are up to date and complete in order to minimize
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| the number of additional documents requested during the preparation and/or the onsite
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| portions of the inspection.
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| The lead inspector for this inspection is Mr. A. Dahbur. We understand that our regulatory
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| contact for this inspection is Mr. G. Dujanevic of your organization. If there are any questions
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| about the inspection or the material requested, please contact the lead inspector at
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| 630-829-9810 or via e-mail at Alan.Dahbur@nrc.gov.
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| This letter does not contain new or amended information collection requirements subject to the
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| Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
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| requirements were approved by the Office of Management and Budget, Control Number
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| 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to,
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| a request for information or an information collection requirement unless the requesting
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| document displays a currently valid Office of Management and Budget Control Number.
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| This letter and its enclosure will be made available for public inspection and copying at
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| http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in
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| accordance with Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,
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| Exemptions, Requests for Withholding.
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| Sincerely,
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| /RA/
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| Alan Dahbur, Senior Reactor Inspector
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| Engineering Branch 3
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| Division of Reactor Safety
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| Docket No. 50-440
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| License No. NPF-58
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| Enclosure:
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| Fire Protection Team Inspection
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| Supporting Documentation
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| cc: Distribution via LISTSERV
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| R. Penfield -3-
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| Letter to Rod Penfield from Alan Dahbur dated June 17, 2021.
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| SUBJECT: PERRY NUCLEAR POWER PLANTNOTIFICATION OF NRC FIRE
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| PROTECTION TEAM INSPECTION REQUEST FOR INFORMATION;
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| INSPECTION REPORT 05000440/2021010
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| DISTRIBUTION:
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| Jessie Quichocho
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| Aaron McCraw
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| RidsNrrPMPerry Resource
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| RidsNrrDorlLpl3
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| RidsNrrDroIrib Resource
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| John Giessner
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| Mohammed Shuaibi
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| Jamnes Cameron
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| Allan Barker
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| DRPIII
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| DRSIII
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| ADAMS Accession Number: ML21168A066
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| Publicly Available Non-Publicly Available Sensitive Non-Sensitive
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| OFFICE RIII
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| NAME ADahbur:mb
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| DATE 06/17/2021
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| OFFICIAL RECORD COPY
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| FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
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| I. Information Requested prior to the Inspection Preparation Week
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| The following information is requested by August 20, 2021. If you have any questions
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| regarding this request, please call the lead inspector as soon as possible. All information
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| should be sent to Alan Dahbur (e-mail address Alan.Dahbur@nrc.gov). Electronic media is
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| preferred. The preferred file format is a searchable pdf or Microsoft Excel file on a
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| compact disk (CD). The CD should be indexed and hyper-linked to facilitate ease of use, if
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| possible. Please provide three copies of each CD submitted (one for each inspector).
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| 1. One set of hard-copy documents for facility layout drawings which identify plant fire area
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| delineation; areas protected by automatic fire suppression and detection; and locations
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| of fire protection equipment.
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| 2. Licensing Information:
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| a. All Nuclear Regulatory Commission (NRC) Safety Evaluation Reports (SERs)
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| applicable to fire protection (specifically including those SERs referenced by the
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| plant fire protection license condition) and all licensing correspondence referenced
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| by the SERs;
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| b. All licensing correspondence associated with the comparison to Standard Review
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| Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing purposes;
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| c. Exemptions from Title 10 of the Code of Federal Regulations (CFR), Part 50.48 and
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| 10 CFR Part 50, Appendix R, and associated licensing correspondence;
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| d. For pre-1979 plants, all licensing correspondence associated with those sections of
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| 10 CFR Part 50, Appendix R, that are not applicable to the plant under
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| 10 CFR 50.48(b)(1). Specifically, the licensing correspondence associated with
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| those fire protection features proposed or implemented by the licensee that have
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| been accepted by the NRC staff as satisfying the provisions of Appendix A to Branch
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| Technical Position APCSB 9.5-1 reflected in the NRC fire protection SERs issued
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| before February 19, 1981, (10 CFR 50.48(b)(1)(i)); or those fire protection features,
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| which were accepted by the NRC staff in comprehensive fire protection SERs issued
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| before Appendix A to Branch Technical Position APCSB 9.5-1 was published in
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| August 1976 (10 CFR 50.48(b)(1)(ii)); and
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| e. The final safety analysis report sections applicable to fire protection, FHA, and SSA
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| in effect at the time of original licensing.
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| 3. Fire Protection Program:
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| a. A listing of changes made to the Fire Protection Program since the last triennial fire
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| protection inspection;
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| b. For pre-1979 plants, a listing of the protection methodologies identified under
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| 10 CFR Part 50, Appendix R, Section III.G used to achieve compliance for
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| fire zones/areas. That is, please specify whether 3-hour rated fire barriers;
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| (Section III.G.2.a), 20-foot separation along with detection and suppression;
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| (Section III.G.2.b), 1-hour rated fire barriers with detection and suppression;
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| Enclosure
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| FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
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| (Section III.G.2.c), or alternative shutdown capability; (Section III.G.3) is used as a
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| strategy for each selected fire zone/area;
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| c. A list of Generic Letter 86-10 evaluations (i.e., a list of adverse to safe shutdown
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| evaluations);
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| d. A list of applicable codes and standards related to the design of plant fire protection
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| features. The list should include National Fire Protection Association (NFPA) code
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| versions committed to (i.e., the NFPA Codes of Record);
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| e. List of plant deviations from code commitments and associated evaluations;
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| f. Fire Protection Program and/or Fire Protection Plan document;
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| g. (If available) Fire Probabilistic Risk Assessment (PRA) Summary Report or full PRA
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| document (if summary document not available);
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| h. List of the top 25 highest fire CDF scenarios for each unit;
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| i. List of Fire Areas/Zones ranked by contribution to CDF, (i.e., ranking of highest to
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| lowest risk fire areas/zones);
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| j. List of the top 25 highest fire LERF scenarios for each unit; and
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| k. Risk ranking of operator actions and/or recovery actions from your site-specific PRA
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| sorted by RAW and human reliability worksheets for these items.
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| 4. Facility Information:
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| a. Piping and instrumentation (flow) diagrams showing the components used to achieve
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| and maintain hot standby and cold shutdown for fires outside the control room, and
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| those components used for those areas requiring alternative shutdown capability;
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| b. One-line schematic drawings of the electrical distribution system for 4160 Volts
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| alternating current (Vac) down to 480 Vac;
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| c. One-line schematic drawings of the electrical distribution system for 250 Volts direct
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| current (Vdc) and 125 Vdc systems as applicable;
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| d. Logic diagrams showing the components used to achieve and maintain hot standby
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| and cold shutdown; and
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| e. Safe shutdown cable routing database (requested electronically, such as on compact
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| disc, if available).
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| 5. Operations Response for Fire Protection:
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| a. Pre-fire plans for fire zones/areas; and
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| 2
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| FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
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| b. Plant operating procedures which specify the initial operations response to a fire
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| alarm or annunciator.
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| 6. Corrective Actions:
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| a. Listing of open and closed fire protection condition reports (i.e., problem identification
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| forms and their resolution reports) since the date of the last triennial fire protection
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| inspection; and
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| b. List of current fire impairments, including duration.
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| 7. General Information:
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| a. A listing of abbreviations and/or designators for plant systems;
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| b. Organization charts of site personnel down to the level of fire protection staff
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| personnel; and
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| c. A phone list for onsite licensee personnel.
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| II. Information Requested to Be Available on First Day of the FIRST ONSITE Inspection
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| Week (SEPTEMBER 13, 2021)
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| The following information is requested to be provided on the first day of inspection. It is
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| requested that this information be provided on three sets of CDs (searchable, if possible).
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| 1. Program Procedures:
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| a. Procedures for:
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| i. Administrative controls (such as allowed out of service times and compensatory
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| measures) for fire protection systems and components;
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| ii. Control of transient combustibles; and
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| iii. Control of hot work.
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| b. List of maintenance and surveillance testing procedures for alternative shutdown
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| capability and fire barriers, detectors, pumps, and suppression systems; and
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| c. List of maintenance procedures which routinely verify fuse breaker coordination in
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| accordance with the post-fire safe shutdown coordination analysis.
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| 2. Design and Equipment Information (for only selected fire zone/area(s) and/or SSCs
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| to be determined during inspection preparation week):
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| a. Coordination calculations and/or justifications that verify fuse/breaker coordination for
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| SSCs that are fed off of the same electrical buses as components in the protected
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| safe shutdown train;
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| 3
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| FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
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| b. Copies of significant fire protection and post-fire safe shutdown related design
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| change package descriptions (including their associated 10 CFR 50.59 evaluations)
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| and Generic Letter 86-10 (or adverse to safe shutdown) evaluations;
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| c. Gaseous suppression system pre-operational testing, if applicable, for selected fire
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| zones/areas;
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| d. Hydraulic calculations and supporting test data which demonstrate operability for
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| water suppression systems;
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| e. Alternating current (ac) coordination calculations for 4160 Vac down to 480 Vac
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| electrical systems; and
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| f. List of all fire protection or Appendix R calculations.
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| 3. Assessment and Corrective Actions:
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| The three most recent fire protection Quality Assurance audits and/or fire protection
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| self-assessments.
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| 4. Any updates to information previously provided.
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| 5. Classic Fire Protection (for only selected fire zone/area(s) and/or SSCs to be
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| determined during inspection preparation week):
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| a. Copy of fire protection program implementing procedures (e.g., administrative
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| controls, surveillance testing, and fire brigade);
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| b. Pre-fire plans for selected fire area(s); and
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| c. List of fire protection system design changes completed in the last 3 years.
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| 6. Electrical (for only selected fire zone/area(s) and/or SSCs to be determined during
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| inspection preparation week):
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| a. Nuclear safety circuit coordination analysis for fuse and breaker coordination of safe
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| shutdown components;
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| b. Administrative or configuration control procedures that govern fuse replacement
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| (e.g., fuse control procedures);
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| c. Maintenance procedures that verify breaker over-current trip settings to ensure
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| coordination remains functional, for post-fire nuclear safety capability components;
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| d. Last surveillance demonstrating operability of those components operated from the
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| primary control stations;
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| e. Schematic or elementary diagrams for circuits (only for selected SSCs) to be
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| reviewed (C-size paper drawings);
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| 4
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| FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
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| f. Cable routing for components and equipment credited for post-fire nuclear safety
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| capability systems and components;
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| g. List of post-fire nuclear safety capability system and component design changes
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| completed, in the last 3 years; and
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| h. List of identified fire induced circuit failure analyses.
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| 7. Operations:
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| a. List of procedures that implement Cold Shutdown Repairs (if applicable for selected
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| fire area);
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| b. For Cold Shutdown Repairs, provide the following:
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| i. Procedure for inventory and inspection (i.e., needed tools, material, etc.); and
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| ii. Most recent inspection and inventory results.
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| c. List of licensed operator Job Performance Measures for operator actions required to
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| achieve and maintain post-fire nuclear safety performance criteria (for selected SSCs
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| and fire area);
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| d. For Radio communications, provide the following:
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| i. Communications Plan for firefighting and post-fire safe shutdown manual actions;
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| ii. Repeater locations;
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| iii. Cable routing for repeater power supply cables;
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| iv. Radio coverage test results; and
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| v. Radio Dead Spot locations in the plant.
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| e. Environmental and habitability evaluations for post-fire operator actions
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| (temperature, smoke, humidity, SCBAs, etc.).
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| 8. Administrative Control, Oversight, and Corrective Action Programs:
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| a. Self-assessments, peer assessments, and audits of fire protection activities for the
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| last 3 years;
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| b. Self-assessments, peer assessments, and audits of post-fire nuclear safety
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| capability methodology for the last 3 years; and
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| c. List of fire event analysis reports for the last 3 years.
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| 9. Any updates to information previously provided.
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| III. Information Requested to Be Provided Throughout the Inspection
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| 1. Copies of any corrective action documents generated as a result of the inspection
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| teams questions or queries during this inspection.
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| 5
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| FIRE PROTECTION TEAM INSPECTION SUPPORTING DOCUMENTATION
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| 2. Copies of the list of questions submitted by the inspection team members and the
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| status/resolution of the information requested (provided daily during the inspection
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| to each inspection team member).
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| 6
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| }} | | }} |
