ML20079J097

Notification of NRC Fire Protection Team Inspection Request for Information; Inspection Report Number 05000341/2020011

ML20079J097
Person / Time
Site:	Fermi
Issue date:	03/19/2020
From:	Atif Shaikh Engineering Branch 3
To:	Peter Dietrich DTE Energy
References
IR 2020011
Download: ML20079J097 (9)

See also: IR 05000341/2020011

Text

March 19, 2020

Mr. Peter Dietrich

Chief Nuclear Officer

DTE Energy Company

Fermi 2 - 260 TAC

6400 North Dixie Highway

Newport, MI 48166

SUBJECT: FERMI POWER PLANT, UNIT 2 - NOTIFICATION OF NRC FIRE PROTECTION

TEAM INSPECTION REQUEST FOR INFORMATION; INSPECTION REPORT

NUMBERS 05000341/2020011

Dear Mr. Dietrich,

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

Region III staff will conduct a Fire Protection Team Inspection (FPTI) at your Fermi Power Plant,

Unit 2 beginning June 29, 2020. The inspection will be conducted in accordance with IP

71111.21N.05, Fire Protection Team Inspection (FPTI), dated June 12, 2019.

The inspection will verify that plant SSCs and/or administrative controls credited in the approved

Fire Protection Program (FPP) can perform their licensing basis function.

The schedule for the inspection is as follows:

Preparation week (R-III office): June 22 - 26, 2020

Week 1 of onsite inspection: June 29 - July 3, 2020

Week 2 of onsite inspection: July 13 - 17, 2020

Experience has shown that the baseline fire protection team inspections are extremely resource

intensive, both for the NRC inspectors and the licensee staff. In order to minimize the

inspection impact on the site and to ensure a productive inspection for both organizations, we

have enclosed a request for documents needed for the inspection. These documents have

been divided into three groups. The first group lists information necessary to aid the inspection

team in choosing specific focus areas for the inspection and to ensure that the inspection team

is adequately prepared for the inspection. It is requested that this information be provided to the

lead inspector via mail or electronically no later than June 12, 2020. The second group of

requested documents consists of those items that the team will review, or need access to,

during the inspection. Please have this information available by the first day of the first onsite

inspection week June 29, 2020. The third group lists the information necessary to aid the

inspection team in tracking issues identified as a result of the inspection. It is requested that

this information be provided to the lead inspector as the information is generated during the

inspection. It is important that all of these documents are up to date and complete in order

to minimize the number of additional documents requested during the preparation and/or the

onsite portions of the inspection.

The lead inspector for this inspection is Mr. Atif Shaikh. We understand that our regulatory

contact for this inspection is Mr. Shane Gatter of your organization. If there are any questions

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

630-829-9824 or via e-mail at Atif.Shaikh@nrc.gov.

P. Dietrich

-2-

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Atif Shaikh, Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket No:

50-341

License No:

NPF- 43

Enclosure:

Information Request for Fire Protection

Team Inspection

cc: Distribution via LISTSERV

P. Dietrich

-3-

Letter to Peter Dietrich from Atif Shaikh dated March 19, 2020.

SUBJECT: FERMI POWER PLANT, UNIT 2 - NOTIFICATION OF NRC FIRE PROTECTION TEAM

INSPECTION REQUEST FOR INFORMATION; INSPECTION REPORT NUMBERS

05000341/2020011

DISTRIBUTION:

Jessie Quichocho

Omar Lopez-Santiago

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RidsNrrPMFermi2 Resource

RidsNrrDroIrib Resource

Darrell Roberts

John Giessner

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML20079J097

OFFICE

RIII

NAME

AShaikh:mb via

email

DATE

3/19/2020

OFFICIAL RECORD COPY

Fire Protection Team Inspection Supporting Documentation

Enclosure

I.Information Requested Prior To the Inspection Preparation Week

The following information is requested by June 12, 2020. If you have any questions

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

should be sent to Atif Shaikh (e-mail address Atif.Shaikh@nrc.gov). Electronic media is

preferred. The preferred file format is a searchable pdf or Microsoft Excel file on a

compact disk (CD). The CD should be indexed and hyper-linked to facilitate ease of use, if

possible. Please provide three copies of each CD submitted (one for each inspector).

1. One set of hard-copy documents for facility layout drawings which identify plant fire area

delineation; areas protected by automatic fire suppression and detection; and locations

of fire protection equipment.

2. Licensing Information:

a.

All Nuclear Regulatory Commission (NRC) Safety Evaluation Reports (SERs)

applicable to fire protection (specifically including those SERs referenced by

the plant fire protection license condition) and all licensing correspondence

referenced by the SERs;

b.

All licensing correspondence associated with the comparison to Standard Review

Plan (NUREG-0800), Section 9.5.1 or equivalent for licensing purposes;

c.

Exemptions from 10 CFR 50.48 and 10 CFR Part 50, Appendix R, and associated

licensing correspondence;

d.

For pre-1979 plants, all licensing correspondence associated with those

sections of 10 CFR Part 50, Appendix R, that are not applicable to the plant under

10 CFR 50.48(b)(1). Specifically, the licensing correspondence associated with

those fire protection features proposed or implemented by the licensee that have

been accepted by the NRC staff as satisfying the provisions of Appendix A to

Branch Technical Position (BTP) APCSB 9.5-1 reflected in the NRC fire protection

SERs issued before February 19, 1981, (10 CFR 50.48(b)(1)(i)); or those fire

protection features, which were accepted by the NRC staff in comprehensive fire

protection SERs issued before Appendix A to BTP APCSB 9.5-1 was published in

August 1976 (10 CFR 50.48(b)(1)(ii)); and

e.

The final safety analysis report (FSAR) sections applicable to fire protection, FHA,

and SSA in effect at the time of original licensing.

3. Fire Protection Program:

a.

A listing of changes made to the FPP since the last triennial fire protection

inspection;

Fire Protection Team Inspection Supporting Documentation

2

b.

For pre-1979 plants, a listing of the protection methodologies identified under

10 CFR Part 50, Appendix R, Section III.G used to achieve compliance for fire

zones/areas. That is, please specify whether 3-hour rated fire barriers;

(Section III.G.2.a), 20 foot separation along with detection and suppression;

(Section III.G.2.b), 1-hour rated fire barriers with detection and suppression;

(Section III.G.2.c), or alternative shutdown capability; (Section III.G.3) is used as a

strategy for each selected fire zone/area;

c.

A list of Generic Letter 86-10 evaluations (i.e., a list of adverse to safe-shutdown

evaluations);

d.

A list of applicable codes and standards related to the design of plant fire

protection features. The list should include National Fire Protection Association

(NFPA) code versions committed to (i.e., the NFPA Codes of Record);

e.

List of plant deviations from code commitments and associated evaluations;

f.

Fire Protection Program and/or Fire Protection Plan document;

g.

(If available) Fire Probabilistic Risk Assessment (PRA) Summary Report or full

PRA document (if summary document not available);

h.

List of the top 25 highest fire CDF scenarios for each unit;

i.

List of Fire Areas/Zones ranked by contribution to CDF. i.e., ranking of highest to

lowest risk fire areas/zones;

j.

List of the top 25 highest fire LERF scenarios for each unit; and

k.

Risk ranking of operator actions and/or recovery actions from your site-specific

PRA sorted by RAW and human reliability worksheets for these items.

4. Facility Information:

a.

Piping and instrumentation (flow) diagrams showing the components used to

achieve and maintain hot standby and cold shutdown for fires outside the control

room, and those components used for those areas requiring alternative shutdown

capability;

b.

One-line schematic drawings of the electrical distribution system for 4160 Volts

alternating current (Vac) down to 480Vac;

c.

One-line schematic drawings of the electrical distribution system for 250 Volts

direct current (Vdc) and 125Vdc systems as applicable;

d.

Logic diagrams showing the components used to achieve and maintain hot

standby and cold shutdown; and

e.

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

compact disc, if available).

Fire Protection Team Inspection Supporting Documentation

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5.

Operations Response for Fire Protection:

a.

Plant operating procedures which specify the initial operations response to a fire

alarm or annunciator.

6. Corrective Actions:

a.

Listing of open and closed fire protection condition reports (i.e., problem

identification forms and their resolution reports) since the date of the last triennial

fire protection inspection; and

b.

List of current fire impairments, including duration.

7. General Information:

a.

A listing of abbreviations and/or designators for plant systems;

b.

Organization charts of site personnel down to the level of fire protection staff

personnel; and

c.

A phone list for onsite licensee personnel.

II. Information Requested to be Available on First Day of the FIRST ONSITE Inspection

Week (JUNE 29, 2020)

The following information is requested to be provided on the first day of inspection. It is

requested that this information be provided on three sets of CDs (searchable, if possible).

1. Program Procedures:

a.

Procedures for:

i. Administrative controls (such as allowed out of service times and

compensatory measures) for fire protection systems and components;

ii. Control of transient combustibles; and

iii. Control of hot work.

b.

List of maintenance and surveillance testing procedures for alternative shutdown

capability and fire barriers, detectors, pumps, and suppression systems; and

c.

List of maintenance procedures which routinely verify fuse breaker coordination

in accordance with the post-fire safe shutdown coordination analysis.

2. Design and Equipment Information (for only selected fire zone/area(s) and/or SSCs

to be determined during inspection preparation week):

a.

Coordination calculations and/or justifications that verify fuse/breaker

coordination for SSCs that are fed off of the same electrical buses as

components in the protected safe shutdown train;

Fire Protection Team Inspection Supporting Documentation

4

b.

Copies of significant fire protection and post-fire safe shutdown related design

change package descriptions (including their associated 10 CFR 50.59

evaluations) and Generic Letter (GL) 86-10 (or adverse to safe shutdown)

evaluations;

c.

Gaseous suppression system pre-operational testing, if applicable, for selected

fire zones/areas;

d.

Hydraulic calculations and supporting test data which demonstrate operability for

water suppression systems;

e.

Alternating current (ac) coordination calculations for 4160Vac down to 480Vac

electrical systems; and

f.

List of all fire protection or Appendix R calculations.

3. Assessment and Corrective Actions:

a.

The three most recent fire protection Quality Assurance (QA) audits and/or fire

protection self-assessments.

4. Any updates to information previously provided.

5. Classic Fire Protection (for only selected fire zone/area(s) and/or SSCs to be

determined during inspection preparation week):

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

controls, surveillance testing, and fire brigade);

b. Pre-fire plans for selected fire area(s); and

c. List of fire protection system design changes completed in the last three years.

6. Electrical (for only selected fire zone/area(s) and/or SSCs to be determined during

inspection preparation week):

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

shutdown components;

b. Administrative or configuration control procedures that govern fuse replacement

(e.g., fuse control procedures);

c. Maintenance procedures that verify breaker over-current trip settings to ensure

coordination remains functional, for post-fire nuclear safety capability components;

d. Last surveillance demonstrating operability of those components operated from the

primary control stations;

Fire Protection Team Inspection Supporting Documentation

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e. Schematic or elementary diagrams for circuits (only for selected SSCs) to be

reviewed (C-size paper drawings);

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

capability systems and components;

g. List of post-fire nuclear safety capability system and component design changes

completed, in the last three years; and

h. List of identified fire induced circuit failure analyses.

7. Operations:

a. List of procedures that implement Cold Shutdown Repairs (if applicable for selected

fire area);

b. For Cold Shutdown Repairs, provide the following:

i. Procedure for inventory and inspection (i.e., needed tools, material, etc.); and

ii. Most recent inspection and inventory results.

c. List of licensed operator Job Performance Measures (JPMs) for operator actions

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

selected SSCs and fire area);

d. For Radio communications, provide the following:

i. Communications Plan for firefighting and post-fire safe shutdown manual actions;

ii. Repeater locations;

iii. Cable routing for repeater power supply cables;

iv. Radio coverage test results; and

v. Radio Dead Spot locations in the plant.

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

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

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

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

last three years;

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

capability methodology for the last three years; and

c. List of fire event analysis reports for the last three years.

9. Any updates to information previously provided.

Fire Protection Team Inspection Supporting Documentation

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III.Information Requested to Be Provided Throughout the Inspection

1. Copies of any corrective action documents generated as a result of the inspection

teams questions or queries during this inspection.

2. Copies of the list of questions submitted by the inspection team members and the

status/resolution of the information requested (provided daily during the inspection to

each inspection team member).

PAPERWORK REDUCTION ACT STATEMENT

This letter contains voluntary information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections (approval number 3150-0011). The burden to the public

for these information collections is estimated to average 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per response. Send

comments regarding this information collection to the Information Services Branch, Office of the

Chief Information Officer, Mail Stop: O-1F13, U.S. Nuclear Regulatory Commission,

Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk

Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of

Management and Budget, Washington, DC 20503.

Public Protection Notification

The NRC may not conduct nor sponsor, and a person is not required to respond to, a request

for information or an information collection requirement unless the requesting document

displays a currently valid OMB control number.