**ATTACHMENT 71111.05AQ**

INSPECTABLE AREA: Fire Protection (Annual/Quarterly)

CORNERSTONES: Initiating Events

> Mitigating Systems

INSPECTION BASES: Fire can be a significant contributor to reactor plant
risk. In many cases, the risk posed by fires is comparable to or exceeds
the risk from internal events. The fire protection program shall extend
the concept of defense in depth (DID) to fire protection in plant areas
important to safety by:

(1) preventing fires from starting,

(2) rapidly detecting, controlling, and extinguishing those fires that
    do occur, and

(3) providing protection for structures, systems, and components
    important to safety so that a fire that is not promptly extinguished
    by fire suppression activities will not prevent the safe shutdown of
    the reactor plant.

LEVEL OF EFFORT: [Quarterly Inspection]{.underline}: The resident
inspector will perform a DID walkdown of four to six plant areas
important to safety (on a plant specific basis) each calendar quarter
per Section 02.01.

> [Annual Inspection]{.underline}: Each year, the resident inspector
> will evaluate the fire brigade performance by observing selected fire
> drills. Fire brigade drill may be announced or unannounced.
> Observation of the fire brigade response to an actual fire can be
> considered as part of the evaluation.

71111.05AQ-01 INSPECTION OBJECTIVES

01.01 The inspectors will evaluate the licensee=s fire protection
program for operational status, and material condition and verify the
adequacy of:

-   controls for combustibles and ignition sources within the plant;

-   fire detection and suppression capability;

-   material condition of passive fire protection features;

-   compensatory measures in place for out-of-service, degraded or
    inoperable fire protection equipment, systems or features; and

-   procedures, equipment, fire barriers, and systems so that the
    post-fire capability to safely shut down the plant is ensured.

01.02 To assess the performance of the fire brigade.

71111.05AQ-02 INSPECTION REQUIREMENTS

02.01 [Quarterly Inspection]{.underline}. The inspector should review
the fire plan for the area selected against the fire protection program
defined hazards and DID features to verify that the fire plan is
adequate. The fire plan should then be used as a tool in evaluating the
attributes below for the selected fire areas. For the areas selected
evaluate the following :

a.  [Control of Transient Combustibles and Ignition
    Sources]{.underline}. Verify the following:

    1.  Transient combustible materials are being controlled in
        accordance with the licensee=s administrative control
        procedures.

    2.  Hot work, welding, or cutting is being done in accordance with
        the licensee=s administrative control procedures.

b.  [Fire Detection Systems]{.underline}.

    1.  Verify the physical condition of the fire detection devices and
        note any that show physical damage, blockage or potential
        interference with functionality (see Compensatory Measures
        section below).

c.  [Water-based Fire Suppression Systems]{.underline}. Verify the
    following:

    1.  Sprinkler heads and nozzles are not obstructed by major overhead
        equipment (e.g., ventilation ducts).

    2.  Water supply control valves to the system are open and the fire
        water supply and pumping capability is operable and capable of
        supplying the water supply demand of the system (Verify through
        visual observation or surveillance record).

    3.  Material conditions such as mechanical damage, painted sprinkler
        heads, corrosion, etc. will not affect performance of the system

d.  [Gaseous Fire Suppression Systems]{.underline}. Verify the
    following:

    1.  Gaseous suppression system (e.g. Halon or CO2) nozzles are not
        obstructed or blocked by plant equipment such that gas dispersal
        would be significantly impeded.

    2.  Suppression agent charge pressure is within the normal band,
        extinguishing agent supply valves are open, and the system is in
        the appropriate mode.

    3.  Dampers/doors are unobstructed so that they will be permitted to
        close automatically upon actuation of the gaseous system.

    4.  Room penetration seals are sealed and in good condition.

    5.  Material conditions such as mechanical damage, corrosion, damage
        to doors or dampers, open penetrations, or nozzles blocked by
        plant equipment that may affect performance of the system.

e.  [Manual Firefighting Equipment and Capability]{.underline}. Verify
    the following:

    1.  Portable fire extinguishes are provided at their designated
        locations in or near the area being inspected, and access to the
        fire extinguishers is unobstructed by plant equipment or other
        work related activities.

    2.  The general condition of fire extinguishes is satisfactory
        (e.g., pressure gauge reads in the acceptable range, nozzles are
        clear and unobstructed, charge test records indicate testing
        within the normal periodicity).

    3.  Fire hoses are installed at their designated locations and the
        general condition of hoses and hose stations is satisfactory
        (e.g., no holes in or chafing of the hose, nozzle not
        mechanically damaged and not obstructed, valve hand wheels in
        place), and access to the hose stations is unobstructed.

    4.  Water supply control valves to the standpipe system are open and
        the fire water supply and pumping capability is operable and
        capable of supplying the water flow and pressure demand.

    5.  Access to manual actuators for fixed suppression systems (e.g.
        gaseous systems, dry water systems) is unobstructed by plant
        equipment or work-related activities.

f.  [Passive Fire Protection Features]{.underline}. Verify the
    following:

    1.  Electrical raceway fire barrier systems such as cable tray fire
        wraps, blanket material are in good condition with no cracks,
        gouges, or holes in the barrier material, and no gaps in the
        material at joints or seams, and that banding, wire tie, and
        other fastener pattern and spacing appears appropriate.

    2.  Fire doors close without gapping (e.g. due to fire door damage
        from previous obstructions), and that the door latching hardware
        functions securely.

    3.  Ventilation system fire dampers material conditions including
        fusible links, where applicable, to ensure unobstructed
        operability. For those dampers which can not be readily observed
        in the selected plant areas, review the licensee=s surveillance
        efforts directed towards verifying the continuing operability of
        ventilation fire dampers.

    4.  Structural steel fire proofing, such as fibrous or concrete
        encapsulation, is installed in such a way that the structural
        steel is uniformly covered (no bare areas).

    5.  Fire barrier and fire area/room/zone electrical and piping
        penetration seals are not missing from locations where they are
        needed to complete a fire barrier wall, and determine that seals
        appear to be properly installed and in good condition.

    6.  Reactor coolant pump oil collection systems designed to collect
        oil leakage and spray from all potential reactor coolant pump
        oil system leakage points have been installed and properly
        maintained. (Time permitting, the actual installation should be
        verified during outages after work on the pumps has been
        completed)

g.  [Compensatory Measures]{.underline}. Verify the following:

    1.  Compensatory measures are put in place by the licensee for
        out-of-service, degraded or inoperable fire protection
        equipment, systems or features (e.g. detection and suppression
        systems and equipment, passive fire barrier features, or safe
        shutdown functions or capabilities). Fire watch is often the
        compensatory measure of choice for a large variety of fire
        protection malfunctions and deficiencies. Assure that the fire
        watch or other compensatory measure is commensurate with the
        significance of the deficiency.

    2.  Licensee=s plans for permanent corrective actions including
        effectiveness in returning the equipment to service in a
        reasonable period of time.

02.02 [Annual Inspection]{.underline}. The annual inspection evaluates
the licensees= fire brigade performance. While the evaluation is an
annual process, observation and evaluation of all the important drill
activities as part of single drill may not be effectively accomplished.
Therefore, inspectors may need to observe the conduct of several fire
brigade drill segments (announced and unannounced) through the year to
be able to formulate an appropriate assessment for the period. Licensee
fire brigade capability to meet 10 CFR 50, Appendix R, Section III H and
I requirements for training, dedicated size and membership, equipment,
etc., can be verified independent of drills. This review is conducted to
ensure the capability of the fire brigade members, the leadership
ability of the brigade leader, use of turnout gear and fire-fighting
equipment, and the effectiveness of the team operation.

As part of the observation of fire brigade drills verify that the fire
brigade considers the following aspects when it responds and conducts
their fire fighting activities:

a.  The specified number of individuals assigned to the fire brigade
    response including the fire brigade leader. (Minimum five dedicated
    members with no ancillary duties.)

b.  Each member sets out his/her designated protective clothing and
    turnout gear, and is properly dons the gear. (Identify the required
    gear and verify availability of correct sizes.)

c.  Self-contained breathing apparatus (SCBA) are available and are
    properly worn and used. Evaluate the SCBA program including storage,
    training, expectations for use, and maintenance. Findings in this
    area should be assessed for significance using IMC 0609 Appendix B,
    Emergency Preparedness SDP.

d.  Control room personnel follows procedure for verification of the
    fire and initiation of response, including identification of fire
    location, dispatching fire brigade, and sounding alarms. Emergency
    action levels are declared and notification are made in accordance
    with NUREG 0654 and 10 CFR 50.

e.  Fire brigade leader exhibits command of the fire brigade and has a
    copy of the pre-fire plans or strategy. Manager in charge of the
    response, for example, the shift supervisor or SRO (not the fire
    brigade leader), has access to pre-fire plans or strategy and
    applicable procedures.

f.  Starting at the dress-out area fire brigade leader maintains
    control. Members are briefed, discuss plan of attack, receive
    individual assignments, complete communications checks, and
    generally get ready to combat the fire. Plan of attack discussion
    should be consistent with the pre-fire plans or strategies and
    include potential hazzards in the fire area.

g.  Fire brigade arrives at the fire scene in a timely manner, taking
    the appropriate access route specified in the strategies and
    procedures. (For fire drills conducted in the radiation control
    areas, the specified most direct route may not be followed by the
    brigade.)

> Control/command is set up near the location of the fire after
> assessing the fire, and communications are established with the
> control room and fire brigade members.
>
> Radio communications between the command post, control room, and plant
> operators and among fire brigade members remain efficient and
> effective for the duration of the drill.

h.  Fire hose lines are capable of reaching all necessary fire hazard
    locations, the lines are laid out without flow constrictions and the
    hose is simulated as being charged with water.

i.  The fire area of concern is entered in a controlled manner following
    the two-person rule; two fire brigade members enter while two remain
    outside the area of concern. Additionally, the fire brigade members
    stay low to the floor and feel the door for heat prior to entry into
    the fire area of concern.

j.  The fire brigade brings sufficient fire-fighting equipment to the
    scene to properly perform its fire-fighting duties.

k.  Members of the fire brigade check for fire victims and propagation
    into other plant areas.

l.  Effective smoke removal operations are simulated in accordance with
    pre-fire plans and strategies by aligning ventilation in the fire
    area or by placing smoke removal units at the proper doors. Areas
    protected by gaseous suppression systems should not be ventilated
    before the brigade confirms that the fire is extinguished. If the
    simulation of smoke removal is not part of the drill verify
    availability and condition of such equipment (e.g. fans, hoses,
    etc.)

m.  The fire-fighting pre-fire plan strategies were utilized.

n.  The licensee=s drill scenario was followed, and the acceptance
    criteria for the drill objectives were met.

o.  The licensee performs a post-drill critique to discuss any failures
    and weaknesses associated with the fire drill performance. Training
    and other improvement needs are identified.

p.  At the conclusion of the drill, all fire fighting equipment is
    returned a condition of readiness to respond to an actual fire.

02.03 [Identification and Resolution of Problems]{.underline}. During
quarterly and annual resident inspection, verify that the licensee is
identifying issues related to this inspection area at an appropriate
threshold and entering them in the corrective action program. For a
sample of selected issues documented in the corrective action program,
verify that the corrective actions are appropriate. See Inspection
Procedure 71152, AIdentification and Resolution of Problems,@ for
additional guidance.

71111.05AQ-03 INSPECTION GUIDANCE

[General Guidance]{.underline}

For those fire protection structures, systems, and components installed
to satisfy NRC requirements designed to NFPA codes and standards, the
code edition in force at the time of the design and installation is the
code of record to which the design is evaluated.

Deviations from the codes should be identified and justified in the FSAR
or FHA. A licensee may apply the equivalency concept in meeting the
provisions of the NFPA codes and standards. When the licensee states
that its design \"meets the NFPA code(s)\" or \"meets the intent of the
NFPA code(s)\" and does not identify any deviations from such codes, the
NRC expects that the design conforms to the codes and the design is
subject to inspection against the NFPA codes.

The AAuthority Having Jurisdiction@ as described in NFPA documents
refers to the Director, Office of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission, or designee, consistent with the
authority specified in 10 CFR 1.43.

The main focus of the quarterly inspections is on the material condition
and operational status of fire detection and suppression systems and
equipment, and fire barriers used to prevent fire damage or fire
propagation

[Specific Guidance]{.underline}

03.01 [Quarterly Inspection]{.underline}. The resident inspector should
not attempt to address all plant areas during each inspection. The
routine plant DID walkdown should focus on four to six plant areas
important safety. The resident inspector should note transient
combustibles and ignition sources (and compare these with the limits
provided in licensee administrative procedures). The resident inspector
should also note the material condition and operational status (rather
than the design) of fire detection and suppression systems, and fire
barriers used to prevent fire damage or fire propagation.

The fire plan should define the hazards and fire protection DID features
to assist the inspector in determining whether the attributes of the
fire area are within the limits of the licensing basis defined in the
fire protection program. The required content of the fire plans will be
defined in the fire protection program and will include information such
as fire hazards, locations of hose stations and extinguishers, locations
of sprinkler isolation valves, important equipment in the area, etc. The
plan can be a great help in distinguishing what combustibles are
transient combustibles (not on the plan, it is probably transient). The
accuracy of the fire plan is important because it will be an important
tool in providing information and guidance to the fire brigade team
leader in determining the most likely locations of the fire in the fire
area and the best strategy for approaching the fire.

03.02 [Annual Inspection]{.underline}. Follow the guidance provided in
section 02.02 of this procedure.

71111.05AQ-04 RESOURCE ESTIMATE

The resource to perform this inspection procedure is estimated to be, on
average, 35 hours per year for quarterly and annual inspection including
time allocated for annual observation of a fire drill.

71111.05AQ-05 COMPLETION STATUS

Inspection of the minimum sample size will constitute completion of this
procedure in the Reactor Programs System (RPS). That minimum sample size
will consist of one sample representing observation of selected fire
drills in accordance with Section 02.02, and 16 samples per year
representing tours of plant areas important to safety in accordance with
Section 02.01.

END

Attachment 1

Revision History For IP 71111.05AQ

+--------+--------+----------------------+------+-------+--------------+
| Comm   | Issue  | Description of       | Trai | Tra   | Comment      |
| itment | Date   | Change               | ning | ining | Resolution   |
| Tr     |        |                      | Ne   | Compl | Accession    |
| acking |        |                      | eded | etion | Number       |
| Number |        |                      |      | Date  |              |
+--------+--------+----------------------+------+-------+--------------+
| N/A    | 08     | Researched           | N/A  | N/A   | N/A          |
|        | /31/06 | commitments back     |      |       |              |
|        |        | four years - none    |      |       |              |
|        |        | found.               |      |       |              |
+--------+--------+----------------------+------+-------+--------------+
| N/A    | 07     | Updated guidance to  | No   | N/A   | None         |
|        | /07/05 | assess fire brigade  |      |       |              |
|        |        | performance          |      |       |              |
+--------+--------+----------------------+------+-------+--------------+
| N/A    | 09     | Added ACompletion    | No   | N/A   | None         |
|        | /05/06 | Status@ identifying  |      |       |              |
|        |        | a sample size of 24. |      |       |              |
|        | CN     |                      |      |       |              |
|        | 06-022 |                      |      |       |              |
+--------+--------+----------------------+------+-------+--------------+
| N/A    | 01     | 2007 ROP             | No   | N/A   | N/A          |
|        | /31/08 | Re-alignment reduced |      |       |              |
|        |        | the sample size to   |      |       |              |
|        | CN     | 16 and resource      |      |       |              |
|        | 08-005 | hours to 35 hours.   |      |       |              |
|        |        | Replace Atour@ with  |      |       |              |
|        |        | Aperform a           |      |       |              |
|        |        | defense-in-depth     |      |       |              |
|        |        | (DID) walkdown.@     |      |       |              |
|        |        | (ROPFF 1155)         |      |       |              |
+--------+--------+----------------------+------+-------+--------------+
|        |        |                      |      |       |              |
+--------+--------+----------------------+------+-------+--------------+
|        |        |                      |      |       |              |
+--------+--------+----------------------+------+-------+--------------+