**NRC INSPECTION MANUAL** SFPT

INSPECTION PROCEDURE 64705

PART 52, FIRE PROTECTION OPERATIONAL PROGRAM

PROGRAM APPLICABILITY: 2504

64705-01 INSPECTION OBJECTIVES

This inspection is performed during the plant construction and startup
phases, prior to fuel load of the plant, to verify the operational
readiness of the Fire Protection Program (FPP) as specified in the final
safety analysis report (FSAR), and as required to transition to power
operations. This inspection procedure addresses FPP features that are
not examined by the Inspections, Tests And Acceptance Criteria (ITAAC)
procedures.

64705-02 INSPECTION REQUIREMENTS

02.01 Verify that the COL holder has effectively implemented the
operational features of the FPP to protect SSCs important to safety from
the effects of fire and explosion and to ensure that a FP system failure
or inadvertent operation does not adversely impact the ability of the
SSCs important to safety to perform their safety function.

02.02 Verify the adequacy and operational readiness of FPP
administrative policies, procedures and programs to ensure the
protection of SSCs important to safety during and after a fire.

02.03 Verify that the FPP complies with the requirements of 10 CFR 50.48
for operational aspects of the program that are not assessed by the
ITAAC inspections.

64705-03 INSPECTION GUIDANCE

03.01 The inspection should utilize a multi-disciplined team of
inspectors, including a Fire Protection (FP) engineer and regional
inspectors. In accordance with the scope and focus of the inspection,
the members of the team should have experience in the following
disciplines: fire protection; plant operations; abnormal and emergency
operating procedures; fire response procedures; quality assurance (QA);
and configuration control. The inspection team leader will develop an
initial inspection plan outline and provide it to each team member.

03.02 The following information should be requested from the licensee as
appropriate to support the scope and focus of the planned inspection:

a\. Description of the license holder's FP and engineering organization,
detailing the responsibilities', and authorities' of each position. The
documents should also include managerial points of contact for
engineering and operating organizations and should detail the
availability of knowledgeable operating and engineering organization
personnel who are to be identified as technical points of contact during
the inspection.

b\. A summary description of the FPP plant change evaluation process,
including methodologies and acceptance criteria.

c\. Specific unique licensee commitments and NRC approvals related to
programmatic aspects of the FPP, e.g., deviations from regulatory
requirements.

d\. Sample procedure describing required fire brigade and operator
actions in the event of a fire in a typical fire area.

e\. Description of pre-operational and startup testing for FPP SSCs

f\. Summary description of fire brigade qualification and training
program, including drills and drill critiques (including drills with
off-site responders).

g\. If available, provide fire protection SERs, FSAR, fire hazard
analysis (FHA), fire protection administrative procedures (i.e., general
employee training, pre-fire plans, documents pertaining to fire watch
training, control of ignition sources and combustibles, etc.), design
certifications for FP systems, the COL, and a current approved
controlled copy of the fire protection plan.

03.03 Prior to conducting the inspection, team members should review the
approved FPP description in the FSAR including the FHA, the safety
evaluation report for the design certification document (if applicable),
and the License, as appropriate for the scope and focus of the
inspection.

a\. Review the FPP organization to verify that the staffing levels and
qualifications are appropriate and in accordance with the approved FPP
and that adequate management oversight is provided.

b\. Review FPP procedures and programs to verify that they adequately
implement the programmatic commitments in the FSAR and SERs.

c\. Verify that general employee fire training includes employee
knowledge of combustible and ignition source control procedures, classes
of fire (by fuel type), extinguishing agent selection based on fire
classification, and site-specific fire reporting procedures.

d\. Verify that fire watch training includes annotation of fire watch
tour and work control logs, control of work in accordance with work
permits, plant area specific combustible control, fire reporting, proper
use of extinguishing agents, and knowledge of fire hazards associated
with activities such as welding, grinding and cutting.

03.04 Verify that the implementation of the FPP includes administrative
controls to minimize fire hazards in the areas containing SSCs important
to safety through combustible and ignition source control.

a\. Control of Combustibles - Verify that the license holder's
administrative control procedures control transient combustible
materials. Fire prevention procedures should consider potential
vulnerabilities associated with large quantities of combustible material
being temporarily or permanently stored in or adjacent to critical plant
areas (e.g., ion exchange resins, lubrication oil, wooden scaffolding,
anti-contamination clothing).

b\. Control of Ignition Sources - (e.g. welding, brazing, flame cutting)
Verify that the license holder's administrative control procedures
control all welding, brazing, flame cutting, and other hot work
performed in the plant. NFPA 51B, "Standard for Fire Prevention in Use
of Cutting and Welding Processes." includes provisions for safeguarding
the hazards associated with welding and cutting operations.

[]{.mark}

03.05 Verify that the license holder has established a qualified plant
fire brigade program with appropriate procedures. Also, verify that the
fire brigade is appropriately equipped (i.e., turnout gear, extra hose,
communications equipment, pre-fire plans, etc.) for fighting fires.

a\. Verify that the fire brigade includes the required number of trained
fire fighting personnel whose expected responsibilities during a fire
event do not conflict with their fire brigade duties.

b\. Verify that fire fighting pre-plans identify the plant areas
containing SSCs important to safety and the locations and layout of
equipment, including power and communication (information and control)
cables, important to safety within those areas. []{.mark}Verify that the
pre-fire planning identifies hazards (i.e., energized equipment,
radiation/contaminated areas, etc.) as necessary.

c\. Verify that fire fighting planning identifies recommended
suppression agent and fire fighting precautions (e.g., considerations to
be taken when applying specific suppression agents in specific plant
locations) for specific plant areas and equipment.

d\. Verify that fire fighting planning addresses expected requirements
for smoke removal during and after the fire.

e\. Verify that fire fighting planning prepares the fire brigade members
to overcome potential security related access problems (such as locked
or electrically failed-shut doors) and health physics related issues
affecting access for fires in radiologically controlled/high radiation
areas. []{.mark} Verify that enhanced modes of security response will
not impede the fire brigade's ability to respond to a fire.

f\. Verify that fire drill procedures include requirements for the
number and identity of participants; effective/challenging scenarios;
qualification of participants; procedures on documentation; and drill
reports with critiques.

g\. Verify that the implementation of the FPP includes a procedure to
ensure that specified fire fighting agents are available in appropriate
quantities for the expected fires.

h\. Verify that the pre-fire plans include fire brigade fire fighting
strategies appropriate for the expected fire hazards in each fire area
containing important-to-safety equipment and cables.

i\. Verify that the offsite fire fighting organization can provide
adequate backup and support for the plant fire brigade, that procedures
are in place for coordinating fire fighting activities, including
drills, and that the offsite organization will receive appropriate
training for dealing with nuclear plant fires and plant-specific
conditions.

03.06 Verify that the license holder has effectively implimented a QA
program that provides assurance that the FP systems are designed,
fabricated, erected, tested, maintained, and operated so that they will
function as intended.

03.07 Verify license holder's operational readiness of the FPP.

a\. Verify that the permanent FPP is in place and operational according
to program requirements.

b\. Verify that punch list items for construction and installation of FP
systems that have been transferred to the operations organization for
completion are either completed or are converted to maintenance work
order items with appropriate expected completion times. Assess the
status of punch list items which constitute incomplete construction work
for which management controls and possible temporary compensatory
measures are required to ensure operational readiness. Evaluate
management oversight and involvement in daily work activities.

03.08 Verify that the license holder has implemented an appropriate
change evaluation program for the FPP that conforms to 10 CFR § 50.59,
\"Changes, Tests and Experiments."

a\. Verify that the implementation of the engineering design change
process for the FPP is sufficient to ensure that unapproved FPP
modifications are not made.

b\. Verify that the guidance contained in the procedures is sufficient
to evaluate the engineering design changes for the FPP to ensure that
plant safety is maintained. Guidance should include acceptance criteria
for changes that do not require review and approval by the NRC.

c\. Verify that the change process requires reporting all changes to the
FSAR as required by 10 CFR § 50.71(e), Maintenance of Records, Making of
Reports.

d\. Verify that the training and qualification requirements for
personnel that prepare, review, or approve 10 CFR § 50.59 safety
evaluations and applicability determinations, and for personnel that
conduct 10 CFR § 50.59 training are in accordance with commitments.

03.09 Verify that the pre-operational and startup testing program for FP
systems and components provide assurance that the equipment is ready for
plant commercial operation.

a\. Verify that the pre-operational tests planned or performed
demonstrate that FP systems and equipment are ready for startup testing.

b\. Verify that the startup tests planned or performed demonstrate that
FP systems and equipment are ready for full operation to support plant
commercial operation.

c\. Review test data and results to evaluate the performance and
integrity of the as-built FP systems and components. This includes test
acceptance criteria and test procedures. Written test procedures for
startup tests should incorporate the requirements and acceptance limits
contained in applicable design documents.

64704-04 RESOURCE ESTIMATE

Approximately 180 hours of direct inspection effort should be required
to implement this inspection procedure. The inspection of the licensee's
operational readiness of the FPP will require three individuals with the
knowledge base outlined above. The actual hours required to complete
this inspection may vary from the estimate. The 180 inspection hours are
an estimate for planning, budgeting and scheduling purposes.

64704-05 REFERENCES

Regulations:

Code of Federal Regulations, Title 10, ‟Energy," Section 50.48, ‟Fire
protection."

Code of Federal Regulations, Title 10, ‟Energy," Section 50.59,
‟Changes, tests, and experiments."

Code of Federal Regulations, Title 10, ‟Energy," Part 50, Appendix A,
‟General Design Criterion 3 - Fire Protection."

Code of Federal Regulations, Title 10, ‟Energy," Part 50, Appendix B,
‟Quality Assurance Criteria for Nuclear Power Plants and Fuel
reprocessing Plants."

Code of Federal Regulations, Title 10, ‟Energy," Part 52, ‟Early Site
Permits; Standard Design Certifications; and Combined Licenses for
Nuclear Power Plants."

Regulatory Guides:

Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants,"
Revision 1 (in preparation).

Generic Letter:

Generic Letter 77-02, "Fire Protection Functional Responsibilities,"
August 1977. (ML010850152)

National Fire Protection Association Codes and Standards:

NFPA 1, Uniform Fire Code," National Fire Protection Association,
Quincy, Massachusetts.

NFPA 51B, "Standard for Fire Prevention During Welding, Cutting, and
Other Hot Work," National Fire Protection Association, Quincy,
Massachusetts.

NFPA 600, "Standard on Industrial Fire Brigades," National Fire
Protection Association, Quincy, Massachusetts.

64704-06 PROCEDURE COMPLETION

The procedure is completed when the plant is transitioned to inspection
under the ROP. Inspection sample size shall be determined based on the
plant design, and the licensee's performance.

END

Attachment 1: Revision History

Attachment 1

REVISION HISTORY FOR IP64705

+---------+-------+---------------------+-------+--------+------------+
| Com     | Issue | Description of      | Tra   | Tr     | Comment    |
| mitment |       | Change              | ining | aining | Resolution |
|         | Date  |                     |       |        |            |
| T       |       |                     | Req   | Comp   | Accession  |
| racking |       |                     | uired | letion | Number     |
|         |       |                     |       |        |            |
| Number  |       |                     |       | Date   |            |
+---------+-------+---------------------+-------+--------+------------+
|         |       | Completed 4 year    | None  | N/A    | N/A        |
|         |       | historical CN       |       |        |            |
|         |       | search. Completed   |       |        |            |
|         |       | incorporation of    |       |        |            |
|         |       | comments from all 4 |       |        |            |
|         |       | regions.            |       |        |            |
+---------+-------+---------------------+-------+--------+------------+
|         | 10/   | Initial Issue to    | None  | N/A    | M          |
|         | 03/07 | support inspections |       |        | L070570153 |
|         |       | of operational      |       |        |            |
|         | CN    | programs described  |       |        |            |
|         | 0     | in IMC 2504,        |       |        |            |
|         | 7-030 | NON-ITAAC           |       |        |            |
|         |       | INSPECTIONS.        |       |        |            |
+---------+-------+---------------------+-------+--------+------------+
|         |       |                     |       |        |            |
+---------+-------+---------------------+-------+--------+------------+