ML16099A296

Notification of NRC Triennial Fire Protection Baseline Inspection Request for Information 05000315/2016009; 05000316/2016009

ML16099A296
Person / Time
Site:	Cook
Issue date:	04/08/2016
From:	Dariusz Szwarc Engineering Branch 3
To:	Gebbie J Indiana Michigan Power Co
References
IR 2016009
Download: ML16099A296 (12)

See also: IR 05000315/2016009

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

April 8, 2016

Mr. Joel Gebbie

Senior VP and Chief Nuclear Officer

Indiana Michigan Power Company

Nuclear Generation Group

One Cook Place

Bridgman, MI 49106

SUBJECT: DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NOTIFICATION

OF NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REQUEST

FOR INFORMATION 05000315/2016009; 05000316/2016009

Dear Mr. Gebbie:

On August 1, 2016, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fire

protection baseline inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2.

This inspection will be performed in accordance with Inspection Procedure 71111.05XT, the

NRCs baseline National Fire Protection Association 805 Fire Protection Inspection Procedure.

Inspection Procedure 71111.05XT 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 the 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 August 3, 2016.

The schedule for the onsite inspection activity is as follows:

Information Gathering Visit: August 1 - 3, 2016;

B.5.b Requirements: August 3 - 5, 2016; and

Fire Protection Inspection: August 15 - 19 and August 29 - September 2, 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 Donald C. Cook Nuclear

Power Plants Fire Protection Program, 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.

J. Gebbie

-2-

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.

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 July 15, 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

(August 1, 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 (August 15, 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. Dariusz Szwarc. We understand that our regulatory

contact for this inspection is Mr. Mr. Richard A. Wynegar of your organization. If there are any

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

630-829-9803 or via e-mail at Dariusz.Szwarc@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, Part 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

J. Gebbie

-3-

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/

Dariusz Szwarc, Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-315; 50-316

License Nos. DPR-58; DPR-74

Enclosure:

Request for Information - Triennial Fire

Protection Inspection

cc: Distribution via LISTSERV

REQUEST FOR INFORMATION - TRIENNIAL FIRE PROTECTION INSPECTION

Enclosure

Inspection Report: 05000315/2016009; 05000316/2016009

Onsite Inspection Dates:

August 1 - 3, 2016; Information Gathering Visit

August 3 - 5, 2016; B.5.b Requirements

August 15 - 19, 2016; Fire Protection Inspection

August 29 - September 2, 2016; Fire Protection Inspection

Inspection Procedures:

IP 71111.05XT, Fire Protection - NFPA 805 (Triennial)

IP 71152, "Identification and Resolution of Problems"

Inspectors:

Dariusz Szwarc (Lead)

Ijaz Hafeez

Senior Reactor Inspector

Reactor Inspector

630-829-9803

630-829-9843

Dariusz.Szwarc@nrc.gov

Ijaz.Hafeez@nrc.gov

Mark Jeffers

Reactor Inspector

630-829-9798

Mark.Jeffers@nrc.gov

Accompanying Personnel: Harold Barrett

Senior Fire Protection Engineer

Office of Nuclear Reactor Regulation

301-415-1402

Harold.Barrett@nrc.gov

I.

Information Requested Prior To the Information Gathering Visit

The following information is requested by July 15, 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. Dariusz Szwarc via e-mail (Dariusz.Szwarc@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. Design and Licensing Basis Documents:

a. Post-fire Nuclear Safety Capability, Systems, and Separation Analysis;

b. Fire Hazards Analysis and/or National Fire Protection Association 805 Design

Basis Document;

c. Fire Probabilistic Risk Assessment Summary Document or full Probabilistic Risk

Assessment Document (if summary document not available);

d. NFPA 805 Transition Report, developed in accordance with Nuclear Energy

Institute Document 04-02;

REQUEST FOR INFORMATION - TRIENNIAL FIRE PROTECTION INSPECTION

2

e. Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3);

f. Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4);

g. Analysis that demonstrates nuclear safety performance criteria can be achieved

and maintained for those areas that require recovery actions;

h. Fire Protection Program and/or Fire Protection Plan; and

i.

Copies of the current versions of the Facility Operating License and Technical

Requirements Manual.

2. Operations:

a. Operating procedures to achieve and maintain nuclear safety performance

criteria from the control room, with a postulated fire in the selected fire areas; and

b. 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).

II.

Information Requested During the Information Gathering Visit (August 1, 2016)

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

onsite information gathering visit. Except for Item 7, 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 (Item 7) provided on one separate CD.

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. Design and Licensing Basis Documents:

a. List of post-fire safe shutdown components (i.e., safe shutdown equipment list);

b. Fire protection system design basis document;

c. List of applicable NFPA codes and standards and issuance dates (i.e., codes

of record);

d. 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);

e. NFPA Compliance Review Report;

f. Report or evaluation that compares the fire protection program to the

U. S. Nuclear Regulatory Commission (NRC) Branch Technical Position 9.5-1,

Appendix A;

REQUEST FOR INFORMATION - TRIENNIAL FIRE PROTECTION INSPECTION

3

g. Copy of licensee submittals and NRC safety evaluation reports that are

specifically listed in the facility operating license for the approved Fire Protection

Program;

h. Copy of NRC Safety Evaluation Reports that form the licensing basis for the Fire

Protection Program and post-fire nuclear safety capability;

i.

Copy of NRC approved exemptions for plant fire protection and post-fire nuclear

safety capability features;

j.

Copy of exemption requests submitted but not yet approved for plant fire

protection and post-fire nuclear safety capability features; and

k. List of nuclear safety capability design changes completed in the last 3 years

(including their associated Title 10, Code of Federal Regulations (CFR),

Part 50.59 and NFPA 805 plant change evaluations).

3. General Plant Design Documents (available onsite for inspector review):

a. Piping and instrumentation diagrams (P&IDs) and legend list for components

used to achieve and maintain nuclear safety performance criteria for: (C-size

paper drawings):

i.

Fires outside the main control room; and

ii.

Fires in areas requiring recovery actions at other than primary control

stations;

b. P&IDs and legend list for fire protection systems, including fire water supply,

water suppression sprinklers & deluge, and carbon dioxide and Halon systems

(C-size paper drawings);

c. Yard layout drawings for underground fire protection buried piping (C-size

paper drawings);

d. Alternating Current and Direct Current electrical system single line diagrams,

from offsite power down to the highest safety-related bus level (typically 4kV,

emergency diesel generator bus) (C-size paper drawings);

e. Single line diagrams for motor control centers that supply post-fire nuclear safety

component loads (only for selected fire areas) (C-size paper drawings);

f. Equipment location drawings which identify the physical plant locations of post-

fire nuclear safety capability equipment (C-size paper drawings); and

g. Logic diagrams showing the components used to achieve and maintain hot

standby and cold shutdown.

4. Operations:

a. List of calculations and engineering analyses, studies, or evaluations for the

nuclear safety capability methodology;

REQUEST FOR INFORMATION - TRIENNIAL FIRE PROTECTION INSPECTION

4

b. For recovery actions, provide the following:

i.

Manual Action Feasibility Study;

ii.

Operator Time Critical Action Program;

iii.

Time lines for time-critical recovery actions; and

iv.

Time line validations;

c. Thermal hydraulic calculation or analysis that determines the time requirements

for time-critical manual operator actions.

5. Administrative Control, Oversight, and Corrective Action Programs:

a. Corrective actions associated with operator actions to achieve and maintain

post-fire nuclear safety performance criteria;

b. List of open and closed condition reports for the fire protection system for the

last 3 years;

c. List of open and closed condition reports for post-fire nuclear safety capability

issues for the last 3 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; and

d. List of procedures that control the configuration of the Fire Protection Program,

features, and post-fire nuclear safety capability methodology and system design.

6. 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 personnel.

7. B.5.b Mitigating Strategies Documents (provided on one separate compact disk on

August 1, 2016):

a. List of all changes to regulatory commitments made to meet the requirements

of 10 CFR 50.54(hh)(2);

b. List of procedures and guidelines that were revised or generated to implement

the mitigating strategies. These could be extensive damage mitigation

guidelines, severe accident management guidelines, emergency operating

procedures, abnormal operating procedures, etc.;

REQUEST FOR INFORMATION - TRIENNIAL FIRE PROTECTION INSPECTION

5

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

in Nuclear Energy Institute Document 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;

d. List of engineering evaluations or calculations that were used to verify the

engineering bases for the mitigating strategies;

e. P&IDs and legend list or simplified flow diagrams for systems relied upon in the

mitigating strategies. These could be the type used for training (C size paper

drawings);

f. List of modification packages or summary descriptions of modifications with

simplified drawings, for necessary facility changes to implement the mitigating

strategies;

g. List of routine tests, surveillances, and preventive maintenance for equipment

and tools needed to implement 10 CFR 50.54(hh)(2) strategies;

h. For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies,

provide the following:

i.

Procedures for inventory and inspection; and

ii.

Most recent inspection and inventory results;

i.

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;

j.

Site general arrangement drawings that show the majority of buildings and areas

referenced in 10 CFR 50.54(hh)(2) documents;

k. Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2);

l.

Copies of memoranda of understanding (e.g., with local fire departments) required

to implement any mitigating strategies.

8. 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 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.

REQUEST FOR INFORMATION - TRIENNIAL FIRE PROTECTION INSPECTION

6

III.

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

Inspection Week (August 15, 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. Classic Fire Protection:

a. Copy of fire protection program implementing procedures (e.g., administrative

controls, surveillance testing, and fire brigade);

b. List of calculations and engineering analyses, studies, or evaluations for the fire

protection system, including the fire water system;

c. Hydraulic calculations or analyses for fire protection water system;

d. 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), including:

i.

An automatic or manually actuated suppression system, due to a fire

in a single location, will not indirectly cause damage to the success

path;

ii.

Inadvertent actuation or rupture of a suppression system will not

indirectly cause damage to the success path;

iii.

Demonstration of adequate drainage for areas protected by water

suppression systems; and

iv.

Hydrostatic rating of any floor penetration seals installed within the fire

areas that are credited with keeping water from leaking into fire areas

below;

e. Pre-fire plans for selected fire areas;

f. List of fire protection system design changes completed in the last 3 years

(including their associated 10 CFR 50.59 and NFPA 805 plant change

evaluations);

g. List of fire protection system NFPA 805 engineering equivalency evaluations

completed in the last 3 years; and

h. Copy of any test, surveillance, or maintenance procedure (current revision),

including any associated data forms, for any requested "last performed" test,

surveillance, or maintenance.

2. Electrical:

a. Nuclear safety circuit coordination analysis for fuse and breaker coordination of

nuclear safety capability components (only for selected fire areas);

REQUEST FOR INFORMATION - TRIENNIAL FIRE PROTECTION INSPECTION

7

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;

e. Schematic or elementary diagrams for circuits to be reviewed (C-size paper

drawings);

f. Cable routing for components and equipment credited for post-fire nuclear safety

capability systems and components (only for selected fire areas);

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 (only for selected fire areas).

3. Operations:

a. For safe shutdown equipment and tools, provide the following:

i.

Procedure for inventory and inspection; and

ii.

Most recent inspection and inventory results;

b. List of procedures that implement Cold Shutdown Repairs;

c. 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;

d. List of licensed operator Job Performance Measures for operator actions

required to achieve and maintain post-fire nuclear safety performance criteria;

e. List of non-licensed operator training associated with non-licensed operator

actions to achieve and maintain post-fire nuclear safety performance criteria

(including Job Performance Measures, in-field training walkdowns, simulations,

or initial qualification);

f. Lesson plans for post-fire nuclear safety capability training for licensed and non-

licensed operators;

g. For Radio communications, provide the following:

i.

Communications Plan for firefighting and post-fire safe shutdown

manual actions;

REQUEST FOR INFORMATION - TRIENNIAL FIRE PROTECTION INSPECTION

8

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;

h. Environmental and habitability evaluations for post-fire operator actions

(temperature, smoke, humidity, SCBAs, etc.).

4. Administrative Control, Oversight, and Corrective Action Programs:

a. Self-assessments, peer assessments, and audits of fire protection activities for

the last 3 years;

b. Self-assessments, peer assessments, and audits of post-fire nuclear safety

capability methodology for the last 3 years; and

c. List of Fire Event Analysis Reports for the last 3 years.

5. 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; and

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.

J. Gebbie

-3-

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/

Dariusz Szwarc, Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-315; 50-316

License Nos. DPR-58; DPR-74

Enclosure:

Request for Information - Triennial Fire

Protection Inspection

cc: Distribution via LISTSERV

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DATE

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