ATTACHMENT 71111.05TTP

INSPECTABLE AREA: Fire Protection-NFPA 805 Transition Period (Triennial)

INSPECTION BASES: Fire can be a significant contributor to 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: Triennial Inspection: Every 3 years, an inspection team
that should include a fire protection specialist, a reactor operations
engineer, and an electrical engineer will conduct a design-based, plant
specific, risk-informed, onsite inspection of the DID elements used to
mitigate the consequences of a fire. Effort will include a review of
licensee=s problem identification and resolution of fire protection
program.

CHANGES IN SCOPE:

> NFPA-805 Guidance in this procedure is applicable to triennial
> inspections of licensees committed to transition to NFPA 805
> APerformance-Based Standard for Fire Protection for Light Water
> Reactor Electric Generating Plants, 2001 Edition@ in accordance with
> Code of Federal Regulations 10 CFR 50.48(c). NFPA 805 requires an
> in-depth nuclear safety circuit analysis for equipment identified for
> nuclear safety functions such as the safe shutdown. Associated with
> this new rule is the interim enforcement policy regarding enforcement
> discretion for circuit related findings identified prior to and during
> the licensee=s transition to NFPA 805. The discretion policy described
> in the NRC Enforcement Policy, NUREG-1600, effective January 14, 2005.
> With this procedure the NRC reduces the scope of the typical triennial
> inspections by specifically excluding the subject circuit
> configurations from the inspection. Compensatory measures shall be in
> place for all circuit related findings identified in conjunction with
> the NFPA 805 transition process. Enforcement discretion is not
> applicable where the inspection identifies inadequate compensatory
> measures.
>
> Manual Actions For triennial inspections conducted at plants in the
> process of transition to NFPA 805, the scope of the typical triennial
> inspection was changed with this procedure by including inspection
> guidance for operator manual actions associated with licensee
> initiated compensatory measures. These compensatory measures shall be
> in place while the underlying performance deficiency ( e.g. failure to
> meet the requirements of the Code of Federal Regulation 10 CFR 50,
> Appendix R, Section III.G.2) is being assessed as part of the
> licensees= plant wide fire risk evaluation process. The background,
> objectives, and specific guidance to assess manual action feasibility
> and reliability are provided in Enclosure 2 to this document.

71111.05-01 INSPECTION OBJECTIVES

01.01 The inspection team will evaluate the licensee=s fire protection
program from design, operational status, and material condition points
of view by verifying that the licensee=s program includes:

a.  adequate controls for combustibles and ignition sources within the
    plant;

b.  adequate fire detection and suppression capability;

c.  passive fire protection features in good material condition;

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

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

f.  feasible and reliable manual actions where applicable as
    compensatory measures to achieve safe shutdown.

Generally the fire protection program will be assessed against the
requirements of the Code of Federal Regulations, 10 CFR Part 50.48(a)
and (b) while the licensee is in the process of transition to implement
the requirements of 10 CFR 50.48(c).

Inspection Procedure 71111.05AQ, Fire Protection (Annual /Quarterly) is
designed to complement the triennial inspection specifically in the
areas of fire brigade capability and water supply and delivery system
maintenance and adequacy. However, the team should consider the need for
additional evaluations in these areas based on previous assessments and
potential issues.

71111.05-02 INSPECTION REQUIREMENTS

02.01 [Inspection Preparation]{.underline}. Every three years, an
inspection team will select three to five risk-significant fire
areas/zones (considering team makeup, scope, and resources) and conduct
risk-informed inspection of selected aspects of the licensee=s fire
protection program. The number of fire areas inspected can be adjusted
during the course of the inspection based on the complexity of
developing issues being worked by the inspection team.

The initial selection of areas to be inspected should be based on inputs
from a senior reactor analyst (SRA), a fire protection specialist and an
electrical/instrumentation and control specialist. For each area the
selection process will consider but will not be limited to the
following:

a.  review of the fire risk analyses;

b.  potential ignition sources;

c.  configuration and characteristics of combustible materials;

d.  licensee=s fire protection and fire fighting capability;

e.  compensatory measures for the temporary correction of licensee or
    inspector identified findings are in place in the form of operator
    manual actions or other acceptable means as discussed in RIS-05-030,
    ACompensatory Measures to Satisfy Fire Protection Requirements.@

02.02 [Inspection Activities]{.underline}. The inspection guidance is
designed to demonstrate that the systems required to achieve and
maintain post-fire safe shutdown (SSD) are capable of controlling
reactivity, reactor coolant makeup, reactor heat removal, process
monitoring and support system functions; and that licensees= engineering
and/or licensing justifications (e.g., NRC guidance documents, license
amendments, technical specifications, SERs, exemptions, deviations)
support the appropriate selection of the designated systems/equipment
and associated support functions.

The verification of fixed fire protection systems including
installation, design, testing, and adequacy to control and/or suppress
fires associated with the hazards of each selected area will be done
against the code of record.

If a fire brigade drill is observed, consider the lines of inspection
inquiry of IP71111.05AQ.

Additionally, verify that the increased number of manual actions or
other compensatory measures to compensate for findings identified in the
course of configuration assessment do not affect fire brigade staffing
and the brigade=s ability for timely response.

Manual actions not supported by an NRC approved exemption or deviation
will be accepted only as temporary compensatory measures and as such
they will be evaluated using guidance provided in Enclosure 2 to this
procedure.

a.  [Shutdown From Outside Main Control Room.]{.underline}

> Verify that hot and cold shutdown can be achieved and maintained from
> outside the control room with or without the availability of offsite
> power for fires in areas where post-fire SSD relies on shutdown from
> outside the control room.

b.  [Protection of Safe Shutdown Capabilities.]{.underline}

> Verify that the fire protection features in place to protect safe
> shutdown capability, including power, control, and instrumentation
> cables, satisfy the separation and design requirements of Section
> III.G of Appendix R (or, for reactor plants reviewed under the
> Standard Review Plan, license specific separation requirements).
>
> (Note, this is an area for the licensees to identify and compensate
> non-conforming configurations. If the licensees have completed their
> assessment of the area(s), the inspectors should validate by
> identifying and comparing 1 to 3 non-conformances against the
> licensees= findings. If the area(s) have not been assessed by the
> licensees, it should be so noted in the inspection report with no
> additional inspection in these areas).

c.  [Passive Fire Protection.]{.underline}

> Verify through observation of material conditions that the fire
> ratings of fire area boundaries, raceway fire barriers, and equipment
> fire barriers appear to be appropriate for the fire hazards in the
> area.
>
> Verify through review of installation/repair records that material of
> an appropriate fire rating (equal to the overall rating of the barrier
> itself) has been used to fill openings and penetrations and that the
> installation meets engineering design.
>
> Verify through review of installation/repair records that material of
> an appropriate fire rating has been used as fire protection wraps and
> that the installation meets engineering design.
>
> For unusual installation configurations and/or application of unusual
> materials verify appropriate fire test data.

d.  [Active Fire Protection.]{.underline}

> Verify and review the material condition, operational lineup,
> operational effectiveness, and design of fire detection systems, fire
> suppression systems, manual fire fighting equipment, and fire brigade
> capabilities.
>
> Verify automatic and manual detection and suppression systems are
> installed, tested, and maintained in accordance with the code of
> record and would adequately control and/or extinguish fires associated
> with the hazards of each selected area.
>
> Verify that the design capability of suppression agent delivery
> systems meet the requirements of the fire hazards.

e.  [Protection From Damage From Fire Suppression
    Activities.]{.underline}

> Verify that redundant trains of systems required for hot shutdown,
> which are located in the same fire area, are not subject to damage
> from fire suppression activities or from the rupture or inadvertent
> operation of fire suppression systems, and that the licensee has
> addressed each of the following:

1.  A fire in a single location that may, indirectly, through the
    production of smoke, heat, or hot gases, cause activation of
    automatic fire suppression that could potentially damage all
    redundant trains;

2.  A fire in a single location (or inadvertent manual or automatic
    actuation, or rupture of a fire suppression system) that may
    indirectly cause damage to all redundant trains (e.g.,
    sprinkler-caused flooding of other than the locally affected train).

3.  Adequate drainage is provided in areas protected by water
    suppression systems.

    f.  [Alternative Shutdown Capability.]{.underline}

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1.  [Methodology]{.underline}

> Verify that the licensee\'s alternative shutdown methodology has
> properly identified the components and systems necessary to achieve
> and maintain safe shutdown conditions for each fire area, room and/or
> zone selected for review. Specifically determine the adequacy of the
> systems selected for reactivity control, reactor coolant makeup,
> reactor heat removal, process monitoring and support system functions.
>
> If the above high level performance criteria are not met, review the
> licensee=s engineering and/or licensing justifications (e.g., NRC
> guidance documents, license amendments, technical specifications,
> SERs, exemptions, deviations).
>
> Verify that hot and cold shutdown from outside the control room can be
> achieved and maintained with off-site power available or not
> available.
>
> Verify that the transfer of control from the control room to the
> alternative location has been demonstrated and if by the time of the
> inspection the licensee identified that the activity could be affected
> by fire‑induced circuit faults, determine that appropriate
> compensatory measures are in place.

2.  [Operational Implementation]{.underline}

> Verify that the training program for licensed and non‑licensed
> personnel includes alternative or dedicated safe shutdown capability.
>
> Verify that personnel required to achieve and maintain the plant in
> hot shutdown following a fire using the alternative shutdown system
> are properly trained and are available at all times from normal onsite
> staff, exclusive of the fire brigade.
>
> Verify that adequate procedures for use of the alternative shutdown
> system exist.
>
> Verify the implementation and human factors adequacy of the
> alternative shutdown procedures by independently \"walking through\"
> the procedural steps.
>
> Verify that the operators can reasonably be expected to perform the
> procedures within applicable shutdown time requirements.
>
> Verify that the licensee conducts periodic operational tests of the
> alternative shutdown transfer capability and instrumentation and
> control functions, and the tests are adequate to prove the
> functionality of the alternative shutdown capability.
>
> Verify the adequacy of compensatory measures where such measures have
> been implemented.

f.  [Circuit Analyses.]{.underline}

> This segment is suspended for plants in transition.

g.  [Communications]{.underline}

> Verify through inspection of the contents of designated emergency
> storage lockers and review of emergency control station alternative
> shutdown procedures, that portable radio communications and/or fixed
> emergency communications systems are available, operable, and adequate
> for the performance. Assess the capability of the communication
> systems to support the operators in the conduct and coordination of
> their required actions (e.g., consider ambient noise levels, clarity
> of reception, reliability, and coverage patterns). If specific, issues
> arise relating to alternative shutdown communications adequacy, then,
> observe a licensee conducted communications test in the subject plant
> area or areas.
>
> Verify that communication equipment such as repeaters, transmitters
> etc. would not be affected by a fire.

h.  [Emergency Lighting]{.underline}.

> Review emergency lighting provided, either in fixed or portable form,
> along access routes and egress routes, at control stations, plant
> parameter monitoring locations, and at manual operating stations:

1.  If emergency lights are powered from a central battery or batteries,
    verify that the distribution system contains protective devices so
    that a fire in the area will not cause loss of emergency lighting in
    any unaffected area needed for safe shutdown operations.

2.  Verify that battery power supplies are rated with at least an 8‑hour
    capacity.

3.  Verify the operability testing and maintenance of the lighting units
    follow licensee procedures and accepted industry practice.

4.  Verify that sufficient illumination is provided to permit access to
    and verification of components for the monitoring of safe shutdown
    indications and/or the proper operation of safe shutdown equipment.

5.  Verify that emergency lighting unit batteries are being maintained
    consistent with the manufacturers recommendations.

    f.  [Cold Shutdown Repairs.]{.underline}

> Verify that the licensee has dedicated repair procedures, equipment,
> and materials to accomplish repairs of components required for cold
> shutdown which might be damaged, that these components can be made
> operable, and that cold shutdown can be achieved within time frames
> specified by Appendix R to 10 CFR Part 50 (or, for reactor plants
> reviewed under the Standard Review Plan, license specific
> requirements). Verify that the repair equipment, components, tools,
> and materials (e.g., pre-cut cable connectors with prepared attachment
> lugs) are available and accessible on site.

g.  [Compensatory Measures.]{.underline}

> Verify that compensatory measures are in place for out-of-service,
> degraded, or inoperable fire protection and post-fire safe shutdown
> equipment, systems, or features (e.g. detection and suppression
> systems and equipment, passive fire barriers, or pumps, valves or
> electrical devices providing safe shutdown functions or capabilities).
> Short term compensatory measures should compensate for the degraded
> function or feature until appropriate corrective action can be taken.
> Review licensee effectiveness in returning the equipment to service in
> a reasonable period of time (typically days or weeks).

02.0.3 [Identification and Resolution of Problems]{.underline}. The team
should 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.

71111.05-03 INSPECTION GUIDANCE

03.01 [Inspection Preparation]{.underline}. Inspection Team and
Responsibilities The team assigned to conduct the multi-disciplinary
triennial fire protection inspection would include a fire protection
inspector, an electrical inspector, and a reactor systems/mechanical
systems inspector.

a.  [Reactor Operations Inspector (ROI)]{.underline}. The reactor
    systems/mechanical systems inspector (RSI) will assess the
    capability of reactor and balance-of-plant systems, equipment,
    operating personnel, and procedures to achieve and maintain
    post-fire safe shutdown and minimize the release of radioactivity to
    the environment in the event of fire. Therefore, the inspection team
    leader will ensure that he is knowledgeable regarding integrated
    plant operations, maintenance, testing, surveillance and quality
    assurance, reactor normal and off-normal operating procedures, and
    BWR and/or PWR nuclear and balance-of-plant systems design.

b.  [Electrical Inspector (EI)]{.underline}. The EI will identify
    electrical separation requirements for redundant train power,
    control, and instrumentation cables. He will review alternative
    shutdown panel electrical isolation design to establish the panels=
    electrical independence from postulated fire areas. Therefore, the
    inspection team leader will ensure that he is knowledgeable
    regarding reactor plant electrical and instrumentation and control
    (I&C) design and is familiar with industry ampacity derating
    standards.

c.  [Fire Protection Inspector (FPI)]{.underline}. The FPI will work
    with other team members in determining the effectiveness of the fire
    barriers and systems that establish the reactor plant=s post-fire
    safe shutdown configuration and maintain it free of fire damage. He
    will determine whether suitable fire protection features
    (suppression, separation distance, fire barriers, etc.) are provided
    for the separation of equipment and cables required to ensure plant
    safety. Therefore, the inspection team leader will ensure he is
    knowledgeable regarding reactor plant fire protection systems,
    features and procedures.

03.02 [Regulatory Requirements and Licensing Bases]{.underline}. The
regulatory requirements and licensing bases against which post-fire safe
shutdown capability is assessed are listed below. However, it is
recognized that the plant under inspection using this procedure has
committed to transition to a fire protection program identified under 10
CFR 50.48(c) and at the time of the inspection the licensee is at some
intermediate point of the multi-year transition process. As such,
circuit related findings are covered by an enforcement discretion
detailed in SECY 04-0050, dated March 29, 2004.

a.  [Part 10 of the Code of Federal Regulations]{.underline}. 10 CFR
    50.48(a), Fire Protection, requires each operating nuclear power
    plant to have a fire protection plan which satisfies the
    requirements of Criterion 3 of Appendix A (GDC3) to 10 CFR 50. The
    NRC has identified that an acceptable plan is one that meets the
    requirements of Appendix R to 10 CFR 50, or a plan that satisfies
    the requirements of standard review plan (SRP) Section 9.5-1.

b.  [Plants licensed before January 1, 1979]{.underline}. These plants
    are subject to the requirements of 10 CFR Section 50.48 and Appendix
    R to 10 CFR Part 50. Appendix R, Sections III.G, III.J, III.L, and
    III.O were backfit on plants licensed before January 1, 1979.
    Licensees were required to meet the separation requirements of
    Section III.G.2, the alternative or dedicated shutdown capability
    requirements of Sections III.G.3 and III.L, or to request an
    exemption in accordance with 10 CFR 50.48. Alternative or dedicated
    safe shutdown capabilities were required to be submitted to the
    Office of Nuclear Reactor Regulation (NRR) for review. NRR approvals
    are documented in SERs.

c.  [Plants licensed after January 1, 1979]{.underline}. These plants
    are subject to requirements as specified in the conditions of their
    facility operating license, in commitments made to the NRC, or in
    deviations exemptions or licensee amendments granted by the NRC.
    These requirements are generally similar to those in 10 CFR Part 50
    Appendix R.

d.  [Changes to the fire protection program]{.underline}. The licensee
    may make changes to the approved fire protection program without
    prior approval by the Commission only if those changes would not
    adversely affect the ability to achieve and maintain safe shutdown
    in the event of a fire. In addition the licensees are required to
    retain the fire protection plan and each change to the plan as a
    record pursuant to paragraph 50.48(a).

e.  [Plants in transition to 10 CFR 50.48(c)]{.underline}. The plants
    which have chosen voluntary compliance with 10 CFR 50.48(c) as an
    alternate fire protection methodology to 10 CFR 50.48(b), satisfy
    the requirements of GDC 3 by complying with NFPA 805 as endorsed by
    10 CFR 50.48(c).

03.03 [Licencee notification and information gathering.]{.underline}

a.  [Licensee Notification Letter]{.underline}. The licensee should be
    notified of the triennial inspection in writing at least three
    months in advance of the onsite week. The information gathering
    visit shall be conducted no fewer than three weeks in advance of the
    onsite inspection week. The letter should discuss the scope of the
    inspection, request an information-gathering visit to the licensee
    reactor site/engineering offices, discuss documentation and licensee
    personnel availability needs during the onsite inspection week, and
    request a pre-inspection conference call to discuss administrative
    matters and finalize inspection activity plans and schedules. A
    template for an NRC to licensee triennial fire protection baseline
    inspection notification letter is provided as Attachment 1.

b.  [Information-gathering Site Visit]{.underline}. The inspection team
    leader should conduct a two to three day information gathering site
    visit. The purposes of the information gathering site visit are
    to (1) gather site-specific information important to inspection
    planning, and (2) conduct initial discussions with licensee
    representatives regarding administrative items and inspection
    activity plans and schedules. In advance of the
    information-gathering site visit, the team leader should provide the
    licensee with a list of information and documents that may be needed
    for the team to prepare for and conduct the triennial inspection, as
    well as a list of any planned requests for licensee conducted
    evolutions (e.g., emergency lighting tests, communication tests,
    fire drills, shutdown walkthroughs, etc.).

> Prior to the inspection information gathering trip, the team leader
> should contact the regional senior reactor analyst (SRA) to obtain
> summary of plant specific fire risk insights (e.g., fire risk ranking
> of the rooms/plant fire areas, conditional core damage probabilities
> (CCDPs) for those rooms and areas, and transient sequences for these
> rooms). After considering the focus of past fire protection and
> post-fire safe shutdown inspections, the team leader should select
> three to five fire areas important to risk for inspection.
>
> After the information gathering site visit, the team leader should use
> the SRA developed fire risk insights, as well as technical input from
> the other team members, to develop an inspection plan addressing (for
> the selected three to five fire areas, zones, as applicable) post-fire
> safe shutdown capability and the fire protection features for
> maintaining one success path of this capability free of fire damage.

c.  [Information Required/Preparation]{.underline}. The team members
    should gather sufficient information to become familiar with the
    following during preparation period:

    1.  The reactor plant\'s design, layout, and equipment
        configuration.

    2.  The reactor plant\'s current post-fire safe shutdown licensing
        basis through review of 10 CFR 50.48, 10 CFR Part 50 Appendix R
        (if applicable), NRC safety evaluation reports (SERs) on fire
        protection, the plant\'s operating license, updated final safety
        analysis report (UFSAR), and approved exemptions or deviations.

    3.  The licensee=s strategy and methodology, and derivative
        procedures, for accomplishing post-fire safe shutdown
        conditions. Among the sources of information are the updated
        final safety analysis report (UFSAR), the latest version of the
        fire hazards analysis (FHA), the latest version of the post-fire
        safe shutdown analysis (SSA), fire protection/post-fire
        safe-shutdown related changes that used 10 CFR 50.59, 50.48(a)
        or other criteria, and Generic Letter 86-10 review documentation
        and modification packages, plant drawings, emergency/abnormal
        operating procedures, and the results of licensee internal
        audits (e.g., self assessments and quality assurance (QA) audits
        in the fire protection and post-fire safe shutdown areas).

    4.  The historical record of plant-specific fire protection issues
        through review of plant-specific documents such as previous NRC
        inspection results, internal audits performed by the reactor
        licensee (e.g., self-assessments and quality assurance audits),
        corrective action system records, event notifications submitted
        in accordance with 10 CFR 50.72, and licensee event reports
        (LERs) submitted in accordance with 10 CFR 50.73.

    5.  The safe shutdown systems and support systems credited by the
        licensee=s analysis for each fire area, room, or zone for
        accomplishing of the required shutdown functions (e.g.,
        reactivity control, reactor coolant makeup, reactor heat
        removal, and process monitoring and support functions) as
        necessary to comply with the safe shutdown requirements of 10
        CFR 50.48(a) and plant-specific licensing requirements. The
        shutdown logic for each area, room, or zone to be inspected must
        be thoroughly understood by the team members.

03.04 [Inspection Activities]{.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.

If the inspectors determine that the operator manual actions are not
reasonably accomplishable and therefore implementation may not lead to a
safe plant condition, the preliminary finding will be identified and
entered into the SDP.

03.03 [Identification and Resolution of Problems]{.underline}. No
specific guidance is provided.

71111.05-04 RESOURCE ESTIMATE

The resource to perform this inspection procedure is estimated to be 200
hours every 3 years for the triennial inspection regardless of the
number of reactor units at the site.

71111.05-05 PROCEDURE COMPLETION

Inspection of the minimum sample size will constitute completion of this
procedure in the Reactor Programs System (RPS). The minimum sample size
is defined as 3 samples (inspection of three fire areas) regardless of
the number of reactor units at that site:

71111.05-06 REFERENCES

The SDP Guideline AAppendix 4 - Determining Potential Risk Significance
of Fire Protection and Post-fire Safe Shutdown Inspection Findings.@

Appendix H of the Fire Protection Supplemental Inspection Procedure
(FPSI) AGuidance for Making a Qualitative Assessment of Fire Protection
Inspection Findings, Fire Protection Risk Significance Screening
Methodology@ \[FPRSSM\])

Inspection Procedure 71152, AIdentification and Resolution of Problems.@

Generic Letter 91-18 AInformation to Licensees Regarding Two NRC
Inspection Manual Sections on Resolution of Degraded and Non-conforming
Conditions and on Operability.@

Information Notice 97-48 AInadequate or Inappropriate Interim Fire
Protection Compensatory Measures,@ July 9, 1997

NRC Internal Memorandum dated August 17, 1998, from John N. Hannon to
Arthur T. Howell titled AResponse to Region IV Task Interface Agreement
(TIA) (96TIA008) - Evaluation of Definition of Continuous Fire Watch
(TAC No. M96550).

Individual Plant Examination of Externally Initiated Events(IPEEE)

Regulatory Guide 1.189 AFire Protection for Nuclear Power Plants.@

Regulatory Issue Summary, Risk-Informed Inspection Guidance for
Post-Fire Safe-Shutdown Inspections.

END

ATTACHMENT 1

Mr. President

Licensee Nuclear Department

Licensee Corporation or Company

Address

SUBJECT: SELECTED NUCLEAR POWER STATION, UNITS 1 AND 2 - NOTIFICATION OF
CONDUCT OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION WHILE
TRANSITION TO 10 CFR PART 50.48(c) IS IN PROGRESS.

Dear Mr. :

The purpose of this letter is to notify you that the U.S. Nuclear
Regulatory Commission (NRC) Region \# staff will conduct a triennial
fire protection baseline inspection at Selected Nuclear Power Station,
Units 1 and 2 in Month, 20##. The inspection team will be lead by First
Last, a fire protection specialist from the NRC Region \# Office. The
team will be composed of personnel from NRC Region #, and Contracted
National Laboratory. The inspection will be conducted in accordance with
IP 71111.05TTP, the NRC=s baseline fire protection inspection procedure
for plants in the process of implementing 10 CFR 50.48(c), NFPA 805. The
inspection guidance is different from the regular triennial inspections
in that the inspectors will concentrate on the fire protection program
infrastructure and the adequacy of compensatory measures implemented for
identified departures from code requirements. The inspectors will not
routinely inspect for or evaluate circuit related issues.

The schedule for the inspection is as follows:

-   Information gathering visit - Dates \[Note - this date is
    pre-coordinated with the licensee\]

-   Week of onsite inspection - Dates.

The purposes of the information gathering visit are to obtain
information and documentation needed to support the inspection, to
become familiar with the Selected Nuclear Power Station, Units 1 and 2
fire protection programs, fire protection features, and post-fire safe
shutdown capabilities and plant layout, and, as necessary, obtain plant
specific site access training and badging for unescorted site access. A
list of the types of documents the team may be interested in reviewing,
and possibly obtaining, are listed in Enclosure 1.

During the information gathering visit, the team will also discuss the
following inspection support administrative details: office space size
and location; specific documents requested to be made available to the
team in their office spaces; arrangements for reactor site access
(including radiation protection training, security, safety and fitness
for duty requirements); and the availability of knowledgeable plant
engineering and licensing organization personnel to serve as points of
contact during the inspection.

We request that during the onsite inspection week you ensure that copies
of analyses, evaluations or documentation regarding the implementation
and maintenance of the Selected Nuclear Generating Station, Units 1 and
2 fire protection program, including post-fire safe shutdown capability,
be readily accessible to the team for their review. Of specific interest
are those documents which establish that your fire protection program
satisfies NRC regulatory requirements and conforms to applicable NRC and
industry fire protection guidance. Also, personnel should be available
at the site during the inspection who are knowledgeable regarding those
plant systems required to achieve and maintain safe shutdown conditions
from inside and outside the control room (including the electrical
aspects of the relevant post-fire safe shutdown analyses), reactor plant
fire protection systems and features, and the Selected Nuclear Power
Station fire protection program and its implementation.

Your cooperation and support during this inspection will be appreciated.
If you have questions concerning this inspection, or the inspection
team\'s information or logistical needs, please contact First Last, the
team leader, in the Region \# Office at ###-###-####.

Sincerely,

Docket Nos.: 50-###

and 50-###

Enclosure: As stated (1)

ENCLOSURE 1

Reactor Fire Protection Program Supporting Documentation

\[Note: This is a broad list of the documents the NRC inspection team
may be interested in reviewing, and possibly obtaining, during the
information gathering site visit.\]

1\. The current version of the Fire Protection Program and Fire Hazards
Analysis.

2\. Current versions of the fire protection program implementing
procedures (e.g., administrative controls, surveillance testing, fire
brigade).

3\. Fire brigade training program and pre-fire plans.

4\. Post-fire safe shutdown systems and separation analysis.

5\. Post-fire alternative shutdown analysis.

6\. 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.

7\. Plant layout and equipment drawings which identify the physical
plant locations of hot standby and cold shutdown equipment.

8\. Plant layout drawings which identify plant fire area delineation,
areas protected by automatic fire suppression and detection, and the
locations of fire protection equipment.

9\. Plant layout drawings which identify the general location of the
post-fire emergency lighting units.

10\. Plant operating procedures which would be used and describe
shutdown from inside the control room with a postulated fire occurring
in any plant area outside the control room, procedures which would be
used to implement alternative shutdown capability in the event of a fire
in either the control or cable spreading room.

11\. Maintenance and surveillance testing procedures for alternative
shutdown capability and fire barriers, detectors, pumps and suppression
systems.

12\. Maintenance procedures which routinely verify fuse breaker
coordination in accordance with the post-fire safe shutdown coordination
analysis.

13\. A sample of significant fire protection and post-fire safe shutdown
related design change packages and Generic Letter 86-10 evaluations.

14\. The reactor plant\'s IPEEE, results of any post-IPEEE reviews, and
listings of actions taken/plant modifications conducted in response to
IPEEE information.

15\. Temporary modification procedures.

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

17\. If applicable, layout/arrangement drawings of potential reactor
coolant/recirculation pump lube oil system leakage points and associated
lube oil collection systems.

18\. A listing of the SERs which form the licensing basis for the
reactor plant\'s post-fire safe shutdown configuration.

19\. Procedures/instructions that control the configuration of the
reactor plant\'s fire protection program, features, and post-fire safe
shutdown methodology and system design.

20\. A list of applicable codes and standards related to the design of
plant fire protection features and evaluations of code deviations.

21\. Procedures/instructions that govern the implementation of plant
modifications, maintenance, and special operations, and their impact on
fire protection.

22\. The three most recent fire protection QA audits and/or fire
protection self-assessments.

23\. Recent QA surveillances of fire protection activities.

24\. A listing of open and closed fire protection condition reports
(problem reports/NCRs/EARs/problem identification and resolution
reports).

25\. Listing of plant fire protection licensing basis documents.

26\. A listing of the NFPA code versions committed to (NFPA codes of
record).

28\. A listing of plant deviations from code commitments.

29\. Actual copies of Generic Letter 86-10 evaluations.

END

ENCLOSURE 2

INSPECTION CRITERIA FOR FIRE PROTECTION MANUAL ACTIONS

[BACKGROUND]{.underline}

Licensees in transition to adopt 10 CFR Part 50.48(c) are expected to
continue to meet the requirements of 10 CFR Part 50.48(b) which provides
three acceptable methods for protecting at least one safe shutdown train
during a fire when redundant trains are located in the same fire area.
The Section III.G.2 requirements of the code are based on the
combination of physical barriers, spacial separation, fire detection and
automatic suppression systems. Manual actions to respond to
maloperations that may result from the failure to meet one or more of
the code requirements are an acceptable method for compensatory measures
to satisfying code requirements during the transition period.

Such use of manual actions do not correct the underlying performance
deficiency and will not be accepted routinely as final corrective
action. However, the staff concluded that for the transition period,
compensatory measures in the form of manual actions would be acceptable
if the manual actions are feasible and reliable based on the criteria
provided below.

If the inspectors determine that the manual actions cannot be
accomplished and therefore implementation may not lead to a safe plant
condition, alternate compensatory measure(s) or temporary corrective
action(s) must be implemented; and the underlying failure to meet code
requirements must be re-assessed using the SDP to verify that the
licensee continues to meet enforcement discretion guidelines.

[APPLICABILITY]{.underline}

This guidance is provided for assessing of manual actions implemented in
conjunction with a licensee commitment to Section III.G.2.

Verify that the licensee is committed to meet the requirements of
Section III.G.2. Determine whether the requirements are met with or
without the use of manual actions. If manual action are not invoked,
this guidance is not applicable.

If manual actions were previously approved by the staff and an exemption
or deviation has been issued, verify that the licensee continues to meet
the terms of the exemption or deviation.

[DIAGNOSTIC INSTRUMENTATION]{.underline}

Verify that adequate diagnostic instrumentation, unaffected by the
postulated fire, is provided for the operator to detect the specific
spurious operation that occurred. Some licensees may have protected only
the circuits specified in Information Notice 84‑09. Additional
instrumentation may be needed to properly assess a spurious operation.
Annunciators, indicating lights, pressure gages, and flow indicators are
among the instruments typically not protected from the effects of a
fire. Instrumentation should also be available to verify that the manual
action accomplished the intended objective.

[ENVIRONMENTAL CONSIDERATIONS]{.underline}

Evaluate environmental conditions the operators may encounter while
traveling to the area where the manual action will be performed and
within the area where the manual action will take place. The conditions
to be verified may include the following:

-   Radiation levels should not exceed normal 10 CFR Part 20 limits.

-   Emergency lighting is provided as required in Appendix R, Section
    III.J, or by the licensee=s approved fire protection program.

-   Temperature and humidity conditions are such that they do not affect
    the operators= capability to perform the manual action.

-   Fire effects such as smoke and toxic gases do not affect the
    operators= capability to perform the manual action.

[STAFFING]{.underline}

Evaluate licensee shift staffing to determine whether enough qualified
personnel are available to perform the required manual actions and to
safely operate the reactor.

[COMMUNICATIONS]{.underline}

Verify that manual action coordination with other plant operations can
be accomplished, and that communications capability is protected from
effects of a postulated fire.

[SPECIAL TOOLS]{.underline}

Evaluate the need for special tools and verify that such tools are
dedicated and readily available.

[TRAINING]{.underline}

Verify that operator training on the manual actions and the associated
procedure(s) is adequate and current.

[ACCESSABILITY]{.underline}

Evaluate the accessability of tools and equipment. If special access
equipment such as ladders are needed, verify the availability of the
equipment. Verify that an operator can reach the required location
without personal hazard.

[PROCEDURES]{.underline}

Review procedural guidance to ensure that it is adequate and given in an
emergency procedure. Operators should not rely on having time to study
normal plant procedures to find a method of operating plant equipment
that is seldom used.

[VERIFICATION AND VALIDATION]{.underline}

Determine whether the manual actions have been verified and validated by
plant walkdowns using the current procedure. Ensure that the licensee
has adequately evaluated the capability of operators to perform the
manual action in the time available before the plant will be placed in
an unrecoverable condition.

END

Attachment 2

Revision History For

Attachment 71111.05TTP, Fire Protection-NFPA 805 Transition Period
(Triennial)

  ------------ ---------- -------------- -------------- ------------ --------------
  Commitment   Issue Date Description of Training       Training     Comment
  Tracking                Change         Needed         Completion   Resolution
  Number                                                Date         Accession
                                                                     Number

  N/A          05/09/06   New document   No additional               ML061160578
                          to provide     training is                 
                          inspection     needed.                     
                          guidance for                               
                          plants                                     
                          committed to                               
                          transition to                              
                          the NFPA 805                               
                          fire                                       
                          protection                                 
                          program.                                   
  ------------ ---------- -------------- -------------- ------------ --------------