ML16242A071

Notification of NRC Triennial Fire Protection Baseline Inspection Request for Information 05000237/2017007; 05000249/2017007

ML16242A071
Person / Time
Site:	Dresden
Issue date:	08/26/2016
From:	Dariusz Szwarc Engineering Branch 3
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2017007
Download: ML16242A071 (10)

See also: IR 05000237/2017007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

August 26, 2016

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Co., LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - NOTIFICATION OF

NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REQUEST FOR

INFORMATION 05000237/2017007; 05000249/2017007

Dear Mr. Hanson:

On January 17, 2017, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial

Fire Protection Baseline Inspection at your Dresden Nuclear Power Station, Units 2 and 3.

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 (CFR),

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 January 18, 2017.

The schedule for the onsite inspection activity is as follows:

Information Gathering Visit: January 17, 2017;

B.5.b Requirements: January 18 - 20, 2017; and

Fire Protection Inspection: January 30 - February 3, 2017 and February 13 - 17, 2017.

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 Dresden 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.

B. Hanson

-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 December 19, 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 on

January 17, 2017.

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 of January 30, 2017.

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. D.J. Walker of your organization. If there are

and 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.

B. Hanson

-3-

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/

Dariusz Szwarc

Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-237, 50-249

License Nos. DPR-19; DPR-25

Enclosure:

Triennial Fire Protection Baseline Inspection

Document Request

cc: Distribution via LISTSERV

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION DOCUMENT REQUEST

Enclosure

Inspection Report: 05000237/2017007; 05000245/2017007

Onsite Inspection Dates:

January 17, 2017

(Information Gathering Visit)

January 18 - 20, 2017

(B.5.b Requirements)

January 30 - February 3, 2017 (Fire Protection Inspection)

February 13 - 17, 2017

(Fire Protection Inspection)

Inspection Procedures:

IP71111.05T, Fire Protection (Triennial)

IP71152, "Identification and Resolution of Problems"

Inspectors:

Dariusz Szwarc

Senior Reactor Inspector (Lead)

630-829-9803

Dariusz.Szwarc@nrc.gov

Alan Dahbur

Ijaz (Jessie) Hafeez

Senior Reactor Inspector

Reactor Inspector

630-829-9810

630-829-9843

Alan.Dahbur@nrc.gov

Ijaz.Hafeez@nrc.gov

Observer:

Tyrone Ospino

Reactor Engineer

(630) 829-9626

Tyrone.Ospino@nrc.gov

I.

Information Requested Prior To the Information Gathering Visit:

The following information is requested by December 19, 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 (e-mail address Dariusz.Szwarc@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 four 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.

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION DOCUMENT REQUEST

2

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.

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 (January 17, 2017):

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 four 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;

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION DOCUMENT REQUEST

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d. 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 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. 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;

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION DOCUMENT REQUEST

4

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).

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;

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION DOCUMENT REQUEST

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 SER;

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 (June 16, 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 (January 30, 2017):

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

requested that this information be provided on four 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.

TRIENNIAL FIRE PROTECTION BASELINE INSPECTION DOCUMENT REQUEST

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:

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

self-assessments.

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

-3-

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/

Dariusz Szwarc

Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-237, 50-249

License Nos. DPR-19; DPR-25

Enclosure:

Triennial Fire Protection Baseline Inspection

Document Request

cc: Distribution via LISTSERV

DISTRIBUTION:

Jeremy Bowen

RidsNrrDorlLpl3-2 Resource

RidsNrrPMDresden Resource

RidsNrrDirsIrib Resource

Cynthia Pederson

Darrell Roberts

Richard Skokowski

Allan Barker

Carole Ariano

Linda Linn

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DATE

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