ML18176A374

Notification of Triennial Fire Protection Baseline Inspection and Request for Information; Inspection Report 05000440/2018011 (DRS-A.Dahbur)

ML18176A374
Person / Time
Site:	Perry
Issue date:	06/25/2018
From:	Alan Dahbur Engineering Branch 3
To:	Hamilton D FirstEnergy Nuclear Operating Co
References
IR 2018011
Download: ML18176A374 (10)

See also: IR 05000440/2018011

Text

June 25, 2018

Mr. David B. Hamilton

Site Vice President

FirstEnergy Nuclear Operating Company

Perry Nuclear Power Plant

Reg Affairs-A210

10 Center Road, P.O. Box 97

Perry, OH 44081-0097

SUBJECT: PERRY NUCLEAR POWER PLANTNOTIFICATION OF NRC TRIENNIAL FIRE

PROTECTION BASELINE INSPECTION AND REQUEST FOR INFORMATION;

INSPECTION REPORT 05000440/2018011

Dear Mr. Hamilton:

On September 17, 2018, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial

Fire Protection Baseline Inspection at your Perry Nuclear Power Plant. This inspection will be

performed in accordance with Inspection Procedure (IP) 71111.05T, the NRCs Baseline Fire

Protection IP.

Changes were made to the IP 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 of the 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 September 19, 2018.

The schedule for the onsite inspection activity is as follows:

Information Gathering Visit: September 17-18, 2018;

B.5.b Requirements:

September 19-21, 2018; and

Fire Protection Inspection:

October 1-5, 2018, and October 15-19, 2018.

D. Hamilton

-2-

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 Perry Nuclear Power Plant 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.

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 August 24, 2018.

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 on

September 17, 2018.

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 beginning October 1, 2018.

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. Alan Dahbur. We understand that our regulatory

contact for this inspection is Mr. George Dujanovic of your organization. If there are any

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

630-829-9810 or via e-mail at Alan.Dahbur@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.

D. Hamilton

-3-

This letter and its enclosure 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 Dariusz Szwarc Acting for/

Alan Dahbur, Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket No. 50-440

License No. NPF-58

Enclosure:

Document Request for Fire Protection

Inspection

cc: Distribution via LISTSERV

D. Hamilton

-4-

Letter to David B. Hamilton from Alan Dahbur dated June 25, 2018

SUBJECT: PERRY NUCLEAR POWER PLANTNOTIFICATION OF NRC TRIENNIAL FIRE

PROTECTION BASELINE INSPECTION AND REQUEST FOR INFORMATION;

INSPECTION REPORT 05000440/2018011

DISTRIBUTION:

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ADAMS Accession Number ML: 18176A374

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DATE

06/25/18

OFFICIAL RECORD COPY

DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION

Enclosure

Inspection Report: 05000440/2018011

Onsite Inspection Dates:

September 17-18, 2018

(Information Gathering Visit)

September 19-21, 2018

(B.5.b Requirements)

October 1-5, 2018

(Fire Protection Inspection)

October 15-19, 2018

(Fire Protection Inspection)

Inspection Procedures:

IP 71111.05T, Fire Protection (Triennial)

IP 71152, Identification and Resolution of Problems

Inspectors:

Alan Dahbur, Lead Inspector

630-829-9810

Alan.Dahbur@nrc.gov

Atif Shaikh,

Ijaz Hafeez,

Senior Reactor Inspector

Reactor Inspector

630-829-9824

630-829-9843

Atif.Shaikh@nrc.gov

Ijaz.Hafeez@nrc.gov

I.

Information Requested Prior To the Information Gathering Visit

The following information is requested by August 24, 2018. If you have any questions

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

information should be sent to Alan Dahbur (e-mail address Alan Dahbur@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 of the 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.

DOCUMENT REQUEST FOR 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 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:

6.

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

a. List of the generic and plant specific MSOs.

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

generic and plant specific MSOs and existing safe shutdown analysis.

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

II.

Information Requested During the Information Gathering Visit

(September 17, 2018)

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 U.S. 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 APCSB 9.5-1

DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION

3

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 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, fire

hazards analysis, and safe shutdown analysis 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 480 Vac;

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

DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION

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e. Safe shutdown cable routing database (requested electronically, such as on

compact disc, if available).

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 off-site 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;

DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION

5

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;

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

(April 29, 2014).

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 (October 1, 2018)

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

DOCUMENT REQUEST FOR FIRE PROTECTION INSPECTION

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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:

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:

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.