LASALLE COUNTY STATION UNITS 1 AND 2NOTIFICATION OF AN NRC T

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UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION III2443 WARRENVILLE ROAD, SUITE 210LISLE, IL 60532-4352July 26, 2011Mr. Michael J. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer (CNO), Exelon Nuclear4300 Winfield RoadWarrenville IL 60555SUBJECT:LASALLE COUNTY STATION UNITS 1 AND 2NOTIFICATION OF AN NRC TRIENNIAL FIRE PROTECTION BASELINEINSPECTION AND REQUEST FOR INFORMATION 05000373/2011009(DRS);05000374/2011009(DRS)Dear Mr. Pacilio:On October 19, 2011, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial fireprotection baseline inspection at your LaSalle County Station. This inspection will be performed in accordance with Inspection Procedure (IP) 71111.05T, the NRC’s baseline fire protectioninspection procedure.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 areasof power reactor facilities due to explosions or fires. This requirement was implemented by theissuance of the Interim Compensatory Measures Order EA-02-026, Section B.5.b and thesubsequent requirements of 10 CFR 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 October 19, 2011.The schedule for the onsite inspection activity is as follows: Information Gathering Visit: October 17 – 19, 2011; B.5.b Requirements: October 19 – 21, 2011; and Fire Protection Inspection: October 31 – November 4, 2011, and November 14 – 18, 2011.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 Nuclear PowerStation 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 ofknowledgeable office personnel and to ensure unescorted site access privileges.Experience has shown that the baseline fire protection inspections are extremely resourceintensive 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
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M. Pacilio-2-provided to the lead inspector via mail or electronically no later than September 23, 2011. The second group also lists information and areas for discussion necessary to aid the inspectionteam in choosing specific fire protection focus areas for the inspection and to ensure that theinspection team is adequately prepared for the inspection. It is requested this information beavailable during the information gathering visit (October 17, 2011). The third group of requesteddocuments 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 onsiteinspection week (October 31, 2011). The fourth group lists the information necessary to aid theinspection team in tracking issues identified as a result of the inspection. It is requested thatthis 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 tominimize the number of additional documents requested during the preparation and/or theonsite portions of the inspection.The lead inspector for this inspection is Mr. Alan K. Dahbur. We understand that our regulatorycontact for this inspection is Mr. J. Houston, NRC Coordinator, LaSalle Regulatory Assurance,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 Number3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to arequest for information or an information collection requirement unless the requesting documentdisplays a currently valid Office of Management and Budget control number.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andits enclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.htmlSincerely,(the Public Electronic Reading Room)./RA/Robert C. Daley, ChiefEngineering Branch 3Division of Reactor SafetyDocket Nos.: 50-373; 50-374License Nos.: DPR 11; DPR 18Enclosure:Fire Protection Inspection Document Requestcc w/encl:Distribution via ListServ
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FIRE PROTECTION INSPECTION DOCUMENT REQUESTSEnclosure1Inspection Report: 05000237/2011008(DRS); 05000249/2011008(DRS)Onsite Inspection Dates:October 17 – 19, 2011(Information Gathering Visit)October 19 – 21, 2011(B.5.b Requirements)October 31 – November 4, 2011(Fire Protection Inspection)November 14 - 18, 2011(Fire Protection Inspection)Inspection ProceduresIP71152, "Identification and Resolution of Problems":IP71111.05T, “Fire Protection (Triennial)”Inspectors:A. K. Dahbur(630) 829-9810Alan.Dahbur@nrc.govM. MunirR. A. Winter(630) 829-9797(630) 829-9758Mohammad.Munir@nrc.gov Robert.Winter@nrc.govI.Information Requested Prior To the Information Gathering VisitThe following information is requested by September 23, 2011. If you have anyquestions regarding this request, please call the lead inspector as soon as possible. Allinformation should be sent to A. K. 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 ofuse, if possible. Please provide four copies of each CD submitted (one for each inspector and observer).1.The most risk significant fire areas as determined by probabilistic risk analyses, if available. Otherwise, the reactor plant's Individual Plant Examination for ExternalEvents (IPEEE) for fire and results of any post-IPEEE reviews for fire.2.A copy of the current version of the Fire Protection Program (FPP), Fire HazardsAnalysis (FHA), Safe Shutdown Analysis (SSA), Updated Safety Analysis Report(USAR), Technical Specifications, license (including the fire protection license condition), and Technical Requirements Manual (TRM) or equivalent for fire protection structures, systems, and components.3.A list of fire areas requiring alternative shutdown capability, (i.e., those areas forwhich 10 CFR Part 50, Appendix R, Section III G requirements are satisfied underSection III.G.3), or where both safe shutdown trains can be affected.4.Plant operating procedures which would be used and describe shutdown for apostulated fire (for both areas requiring alternative shutdown and areas which do not require alternative shutdown). Only those procedures with actions specific to
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FIRE PROTECTION INSPECTION DOCUMENT REQUESTSEnclosure2shutdown in the event of a fire need be included. In addition, please include thoseprocedures which operators would use for initial response to a fire, such asannunciator or alarm response procedures, the procedure used for activating thefire brigade, and the procedure which directs operators to the applicable safe shutdown procedure.II.Information Requested During the Information Gathering Visit (October 17, 2011)The following information is requested to be provided to the inspection team during theonsite information gathering visit. Except for Item 1, it is requested that the followinginformation 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 CDs.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; andlocations 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 bythe plant fire protection license condition) and all licensing correspondencereferenced 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, andassociated licensing correspondence;d. For pre-1979 plants, all licensing correspondence associated with thosesections of 10 CFR Part 50, Appendix R, that are not applicable to the plantunder 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 provisionsof Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 reflected inthe 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 toBTP APCSB 9.5-1 was published in August 1976 (10 CFR 50.48(b)(1)(ii));e. For post-1979 plants, all licensing correspondence associated with the comparison to Standard Review Plan (NUREG-0800), Section 9.5.1 orequivalent for licensing purposes; and
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FIRE PROTECTION INSPECTION DOCUMENT REQUESTSEnclosure3f.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;b. For pre-1979 plants, a listing of the protection methodologies identified under10 CFR Part 50, Appendix R, Section III.G used to achieve compliance forselected 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 safeshutdown evaluations);d. A list of applicable codes and standards related to the design of plant fireprotection features. The list should include National Fire ProtectionAssociation (NFPA) code versions committed to (i.e., the NFPA Codes of Record); ande. List of plant deviations from code commitments and associated evaluations.4.Facility Information:a. Piping and instrumentation (flow) diagrams showing the components used toachieve 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 4160Volts alternating current (Vac) down to 480Vac;c. One-line schematic drawings of the electrical distribution system for 250 Voltsdirect current (Vdc) and 125Vdc systems as applicable;d. Logic diagrams showing the components used to achieve and maintain hotstandby and cold shutdown; ande. Safe shutdown cable routing database (requested electronically such as on compact disc, if available.
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FIRE PROTECTION INSPECTION DOCUMENT REQUESTSEnclosure45.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; andc. 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., problemidentification forms and their resolution reports) since the date of the lasttriennial 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 staffpersonnel; andc. 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, datedFebruary 25, 2002, the subsequently imposed license conditions, and10 CFR 50.54(hh)(2);b. Copies of procedures/guidelines that were revised or generated to implementthe mitigation strategies. These could be extensive damage mitigation guidelines (EDMGs), severe accident management guidelines (SAMGs),emergency operating procedures (EOPs), abnormal operating procedures(AOPs), etc.;c. A matrix that shows the correlation between the mitigation strategies identified in Nuclear Energy Institute 06-12 and the site-specific procedures orguidelines that are used to implement each strategy;d. A listing of engineering evaluations/calculations that were used to verifyengineering 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;
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FIRE PROTECTION INSPECTION DOCUMENT REQUESTSEnclosure5f.A list of B.5.b mitigating strategies, if any, which have implementing detailsthat differ from that documented in the submittals and the safety evaluation report;g.Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments) required to implement any mitigating strategies; andh.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(October 2008).9.Onsite Discussions:In addition, during the information gathering visit, it is requested that licensee staffbe available for the following:a.Informal discussion on plant procedures operators would use in the event offire or explosion (including B.5.b mitigation strategies) and under whatconditions would the plant be shutdown using alternative shutdown methodology;b.Informal discussion on the plant’s safe shutdown cable routing database and the plant-wide cable routing database, as applicable; andc.A tour of alternative shutdown and risk significant fire areas.III.Information Requested to be Available on First Day of the Second OnsiteInspection Week (October 31, 2011)The following information is requested to be provided on the first day of inspection. It isrequested 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 componentsii. Control of transient combustiblesiii. Control of hot workb. List of maintenance and surveillance testing procedures for alternative shutdown capability and fire barriers, detectors, pumps, and suppressionsystems; andc. List of maintenance procedures which routinely verify fuse breaker coordination in accordance with the post-fire safe shutdown coordination analysis.
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FIRE PROTECTION INSPECTION DOCUMENT REQUESTSEnclosure62.Design and Equipment Information:d. Coordination calculations and/or justifications that verify fuse/breakercoordination for selected fire zones/areas (to be determined duringinformation gathering visit) that are fed off of the same electrical buses ascomponents in the protected safe shutdown train;e. Copies of significant fire protection and post-fire safe shutdown related design change package descriptions (including their associated 10 CFR 50.59evaluations) and Generic Letter (GL) 86-10 (or adverse to safe shutdown)evaluations;f. Gaseous suppression system pre-operational testing, if applicable, for selected fire zones/areas (to be determined during information gathering visit);g. Hydraulic calculations and supporting test data which demonstrate operabilityfor water suppression systems, if applicable, for selected fire zones/areas (to be determined during information gathering visit);h. Alternating current (ac) coordination calculations for 4160Vac down to 480Vacelectrical systems; andi. List of all fire protection or Appendix R calculations.3.Assessment and Corrective Actions:The three most recent fire protection Quality Assurance (QA) audits and/or fireprotection self-assessments.4.Any updates to information previously provided.IV.Information Requested to Be Provided Throughout the Inspection1.Copies of any corrective action documents generated as a result of the inspection team’s questions or queries during this inspection.2.Copies of the list of questions submitted by the inspection team members and thestatus/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.
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M. Pacilio-2-provided to the lead inspector via mail or electronically no later than September 23, 2011. 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 adequatelyprepared for the inspection. It is requested this information be available during the information gatheringvisit (October 17, 2011). The third group of requested documents consists of those items that the teamwill review, or need access to, during the inspection. Please have this information available by the firstday of the second onsite inspection week (October 31, 2011). The fourth group lists the information necessary to aid the inspection team in tracking issues identified as a result of the inspection. It isrequested 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 portionsof the inspection.The lead inspector for this inspection is Mr. Alan Dahbur. We understand that our regulatory contact forthis inspection is Mr. J. Houston, NRC Coordinator, and LaSalle Regulatory Assurance, of yourorganization. If there are any questions about the inspection or the material requested, please contactthe 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 oran information collection requirement unless the requesting document displays a currently valid Office ofManagement and Budget control number.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS isaccessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public ElectronicReading Room).Sincerely,Robert C. Daley, ChiefEngineering Branch 3Division of Reactor SafetyDocket Nos.:50-373; 50-374License Nos.: DPR 11; DPR 18Enclosure:Fire Protection Inspection Document Requestcc w/encl:Distribution via ListServDistribution:See next pageDOCUMENT NAME: G:\DRSIII\DRS\Work in Progress\Ltr 072611 LAS Fire Protection RFI AKD.docx Publicly Available Non-Publicly Available Sensitive Non-SensitiveTo receive a copy of this document, indicate in the concurrence box “C” = Copy without attach/encl; “E” = Copy with attach/encl “N” = No copyOFFICERIIIRIIINAMEADahbur:lsRDaleyDATE07/25/1107/26/11OFFICIAL RECORD COPY
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Letter to Mr. Michael Pacilio from Mr. Robert C. Daley dated July 26, 2011.SUBJECT:LASALLE COUNTY STATION NOTIFICATION OF AN NRC TRIENNIALFIRE PROTECTION BASELINE INSPECTION AND REQUEST FORINFORMATION 05000373/2008007(DRS); 05000374/2008007(DRS)DISTRIBUTION:Daniel MerzkeRidsNrrDorlLpl3-2 ResourceRidsNrrPMLaSalleRidsNrrDirsIrib ResourceCynthia PedersonSteven OrthJared HeckAllan BarkerCarole ArianoLinda LinnDRPIIIDRSIIIPatricia BuckleyTammy TomczakROPreports Resource