ML16077A155

Ltr. 03/16/16 Byron Station, Units 1 and 2 - Notification of NRC Triennial Fire Protection Baseline Inspection Request for Information; Inspection Report 05000454/2016007; 05000455/2016007 (Mtj)

ML16077A155
Person / Time
Site:	Byron
Issue date:	03/16/2016
From:	Jeffers M Engineering Branch 3
To:	Bryan Hanson Exelon Generation Co
References
IR 2016007
Download: ML16077A155 (9)

See also: IR 05000454/2016007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

March 16, 2016

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: BYRON STATION, UNITS 1 AND 2 - NOTIFICATION OF NRC TRIENNIAL

FIRE PROTECTION BASELINE INSPECTION REQUEST FOR INFORMATION;

INSPECTION REPORT 05000454/2016007; 05000455/2016007

Dear Mr. Hanson:

On June 6, 2016, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire

protection baseline inspection at your Byron Station, Units 1 and 2. This inspection will be

performed in accordance with Inspection Procedure 71111.05T, the NRCs baseline fire

protection inspection procedure.

Changes were made to the Inspection Procedure 71111.05T, which now requires the fire

protection inspection to review your actions to mitigate postulated events that could potentially

cause loss of large areas of power reactor facilities due to explosions or fires. This requirement

was implemented by the issuance of the Interim Compensatory Measures Order EA-02-026,

Section B.5.b, and the subsequent requirements of Title 10, Code of Federal Regulations,

Part 50.54(hh)(2), which are collectively referred to as B.5.b requirements. During this

inspection, the B.5.b requirements review will be performed during the first onsite week of

the inspection starting on June 8, 2016.

The schedule for the onsite inspection activity is as follows:

Information Gathering Visit: June 6 - 8, 2016;

B.5.b Requirements: June 8 - 10, 2016; and

Fire Protection Inspection: June 20 - 24 and July 5 - 8, 2016.

The purpose of the information gathering visit is: (1) to obtain information and documentation

needed to support the inspection; (2) to become familiar with the Byron Stations Fire Protection

Programs, fire protection features, post-fire safe shutdown capabilities, and plant layout; and

(3) to arrange administrative details, such as office space, availability of knowledgeable office

personnel and to ensure unescorted site access privileges.

Experience has shown that the baseline fire protection 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 four groups.

B. Hanson

-2-

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

areas for the inspection. It is requested that this information be provided to the lead inspector

via mail or electronically no later than May 20, 2016. The second group also lists information

and areas for discussion necessary to aid the inspection team in choosing specific fire

protection focus areas for the inspection and to ensure that the inspection team is adequately

prepared for the inspection. It is requested this information be available during the information

gathering visit June 6, 2016. The third 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 second onsite inspection week June 20, 2016. The fourth 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. Mark Jeffers. We understand that our regulatory

contact for this inspection is Ms. Amanda Corrigan of your organization. If there are any

questions about the inspection or the material requested, please contact the lead inspector

at (630) 829-9798 or via e-mail at Mark.Jeffers@nrc.gov.

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, 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.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy

of this letter, its enclosure, and your response (if any) will be available electronically for public

inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

Sincerely,

/RA/

Mark Jeffers, Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-454; 50-455

License Nos. NPF-37; NPF-66

Enclosure:

Information Request for Fire Protection Inspection

cc: Distribution via LISTSERV

REQUEST FOR INFORMATION - FIRE PROTECTION INSPECTION

Enclosure

Inspection Report: 05000454/2016007; 05000455/2016007

Onsite Inspection Dates:

June 6 - 8, 2016, Information Gathering Visit

June 8 - 10, 2016, B.5.b Requirements

June 20 - 24, 2016, Fire Protection Inspection

July 5 - 8, 2016, Fire Protection Inspection)

Inspection Procedures:

IP 71111.05T, Fire Protection (Triennial)

IP 71152, Identification and Resolution of Problems

Inspectors:

Mark Jeffers

Reactor Inspector (Lead)

(630) 829-9798

Mark.Jeffers@nrc.gov

Alan Dahbur

Dariusz Szwarc

Senior Reactor Inspector

Senior Reactor Inspector

(630) 829-9810

(630) 829-9803

Alan.Dahbur@nrc.gov

Dariusz.Szwarc@nrc.gov

I.

Information Requested Prior To the Information Gathering Visit

The following information is requested by May 20, 2016. If you have any questions

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

information should be sent to Mr. Mark Jeffers (e-mail: Mark.Jeffers@nrc.gov).

Electronic media is preferred. The preferred file format is a searchable pdf 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. The most risk significant fire areas as determined by probabilistic risk analyses, if

available. Otherwise, the reactor plant's Individual Plant Examination for External

Events for fire and results of any post- Individual Plant Examination for External

Events reviews for fire.

2. A copy of the current version of the Fire Protection Program, fire hazards analysis,

safe shutdown analysis, updated safety analysis report, technical specifications,

license (including the fire protection license condition), and technical requirements

manual or equivalent for fire protection structures, systems, and components.

3. A list of fire areas requiring alternative shutdown capability, (i.e., those areas

for which Title 10, Code of Federal Regulations [CFR], Part 50, Appendix R,

Section III G, requirements are satisfied under Section III.G.3), or where both

safe shutdown trains can be affected.

REQUEST FOR INFORMATION - FIRE PROTECTION INSPECTION

2

4. Plant operating procedures which would be used and describe shutdown for a

postulated fire (for both areas requiring alternative shutdown and areas which do

not require alternative shutdown). Only those procedures with actions specific to

shutdown in the event of a fire need be included. In addition, please include

those procedures which operators would use for initial response to a fire, such as

annunciator or alarm response procedures, the procedure used for activating the fire

brigade, and the procedure which directs operators to the applicable safe shutdown

procedure.

5. Analysis performed in support of plant evaluation regarding multiple spurious

operation (MSO), which includes the following:

a. List of identified multiple spurious fire-induced circuit failure configurations.

b. List of the generic and plant specific MSOs.

c. Results of expert panel process and associated review/evaluation of the generic

and plant specific MSOs and existing safe shutdown analysis.

d. Evaluations and corrective actions taken for resolution of MSO issues.

II.

Information Requested During the Information Gathering Visit (June 6, 2016)

The following information is requested to be provided to the inspection team during the

onsite information gathering visit. Except for Item 8, it is requested that the following

information be provided on three sets of CDs (searchable, if possible) with the B.5.b

Mitigating Strategies information (Items 8.a through 8.h) provided on one separate CD.

In addition, one set of hard copy drawings are requested for Items 4.a. through 4.d.

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 Part 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 APCSB 9.5-1 reflected in the NRC fire protection

REQUEST FOR INFORMATION - FIRE PROTECTION INSPECTION

3

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 Branch Technical Position

APCSB 9.5-1 was published in August 1976 (10 CFR 50.48(b)(1)(ii)); and

e. The final safety analysis report 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 Fire Protection Program since the last

triennial fire protection inspection;

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 selected fire zones/areas (to be determined during information

gathering visit). 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 code versions committed to (i.e., the National Fire Protection

Association Codes of Record); and

e. List of plant deviations from code commitments and associated evaluations.

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, those components used for those areas requiring alternative

shutdown capability, and systems relied upon for B.5.b mitigation strategies.

These can be of the type that are used for training;

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 and 125 Volts direct current 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).

REQUEST FOR INFORMATION - FIRE PROTECTION INSPECTION

4

5. Operations Response for Fire Protection:

a. Pre-fire plans for selected fire zones/areas (to be determined during

information gathering visit);

b. Plant operating procedures which specify the initial operations response to

a fire alarm or annunciator; and

c. Procedure for calling out the fire brigade and requesting offsite assistance.

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.

8. B.5.b Mitigating Strategies:

a. A list of all modifications to regulatory commitments made to meet

the requirements of Section B.5.b of the ICM Order, EA-02-026, dated

February 25, 2002, the subsequently imposed license conditions, and

10 CFR 50.54(hh)(2);

b. Copies of procedures/guidelines that were revised or generated to implement

the mitigation strategies. These could be extensive damage mitigation

guidelines, severe accident management guidelines, emergency operating

procedures, abnormal operating procedures, etc.;

c. A matrix that shows the correlation between the mitigation strategies

identified in Nuclear Energy Institute 06-12 and the site-specific procedures

or guidelines that are used to implement each strategy;

d. A listing of engineering evaluations/calculations that were used to verify

engineering bases for the mitigation strategies;

e. Copies of procedures used to inventory equipment (hoses, fittings, pumps,

etc.) required to be used to implement the mitigation strategies;

f. A list of B.5.b mitigating strategies, if any, which have implementing details

that differ from that documented in the submittals and the safety evaluation

report;

REQUEST FOR INFORMATION - FIRE PROTECTION INSPECTION

5

g. Copies of Memoranda of Understanding (e.g., with local fire departments)

required to implement any mitigating strategies; and

h. A list of changes made to B.5.b mitigating strategies and associated

procedures since the previous NRC inspection of B.5.b mitigating strategies.

9. Onsite Discussions:

In addition, during the information gathering visit, it is requested that licensee staff be

available for the following:

a. Informal discussion on plant procedures operators would use in the event

of fire or explosion (including B.5.b mitigation strategies) and under what

conditions would the plant be shutdown using alternative shutdown

methodology;

b. Informal discussion on the plants safe shutdown cable routing database and

the plant-wide cable routing database, as applicable; and

c. A tour of alternative shutdown and risk significant fire areas.

d. A discussion of scheduling of fire drills which may occur during the inspection

so that the inspectors may be able to observe a fire drill, if possible.

III.

Information Requested to be Available on first Day of the Second Onsite

Inspection Week (June 20, 2016)

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

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.

REQUEST FOR INFORMATION - FIRE PROTECTION INSPECTION

6

2. Design and Equipment Information:

a. Coordination calculations and/or justifications that verify fuse/breaker

coordination for selected fire zones/areas (to be determined during

information gathering visit) that are fed off of the same electrical buses as

components in the protected safe shutdown train;

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 86-10 (or adverse to safe

shutdown) evaluations;

c. Gaseous suppression system pre-operational testing, if applicable, for

selected fire zones/areas (to be determined during information gathering

visit);

d. Hydraulic calculations and supporting test data which demonstrate operability

for water suppression systems, if applicable, for selected fire zones/areas

(to be determined during information gathering visit);

e. Alternating current 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 audits and/or fire

protection self-assessments.

4. Any updates to information previously provided.

IV.

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.

B. Hanson

-2-

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

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

electronically no later than May 20, 2016. The second group also lists information and areas for

discussion necessary to aid the inspection team in choosing specific fire protection focus areas for the

inspection and to ensure that the inspection team is adequately prepared for the inspection. It is

requested this information be available during the information gathering visit June 6, 2016. The third

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 second onsite inspection

week June 20, 2016. The fourth 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. Mark Jeffers. We understand that our regulatory contact for

this inspection is Ms. Amanda Corrigan of your organization. If there are any questions about the

inspection or the material requested, please contact the lead inspector at (630) 829-9798 or via e-mail at

Mark.Jeffers@nrc.gov.

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, 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.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections,

Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the NRCs

Public Document Room or from the Publicly Available Records (PARS) component of the NRC's

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark Jeffers, Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-454; 50-455

License Nos. NPF-37; NPF-66

Enclosure:

Information Request for Fire Protection Inspection

cc: Distribution via LISTSERV

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