ML040840376

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Transmittal of Revised Technical Requirements Manual (TRM) Update 3/1/04
ML040840376
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 03/11/2004
From:
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML040840376 (25)


Text

02-KAR-04 Page: 78 DISTRIBUTION CONTROL LIST

  • ument Name: ITS/BASES/TRM CCNAME NAME DEPT LOCATION 1 OPS PROCEDURE GROUP SUPV. OPS PROCEDURE GROUP IP2 3 PLANT MANAGER'S OFFICE UNIT 3(UNIT 3/IPEC ONLY) IP2 5 CONTROL ROOM & MASTER OPS(3PT-DO01/6(U3/IPEC) IP3(ONLY) 6 OPERATIONS MANAGER OPS/FRED SMUTNY 45-3-D 9 MYERS VALERIE SYSTEM ENG. 72'ELEVATION IP2 4329 11 RES DEPARTMENT MANAGER RES (UNIT 3/IPEC ONLY) 45-4-A 16 BOCCIO JOHN I&C OFFICE (SUPERVISOR) 45-2-A 19 ALLEN ROBERT-IP2/ENTERGY LICENSING IP2 20 CHEMISTRY SUPERVISOR CHEMISTRY DEPARTMENT 45-4-A 21 TSC(IP3) EEC BUILDING IP2 22 SHIFT MGR.(LUB-001-GEN) OPS (UNIT 3/IPEC ONLY) IP3 23 LIS LICENSING & INFO SERV OFFSITE 25 SIMULATOR TRAIN(UNIT 3/IPEC ONLY) 48-2-A 26 QA MANAGER QA (UNIT 3/IPEC) GSB-2B 28 RESIDENT INSPECTOR US NRC 88' ELEVATION IP2 32 EOF E-PLAN (ALL EP'S) EOF 47 CHAPMAN N BECHTEL OFFSITE 50 TADEMY L. SHARON WESTINGHOUSE ELECTRIC OFFSITE 54 NUC ENGINEERING LIBRARY DOC (UNIT 3/IPEC ONLY) WPO/7A 55 REFERENCE LIBRARY REC/TRN(UNT 3/IPEC ONLY) BLDG/17 61 SIMULATOR TRAIN(UNIT 3/IPEC ONLY) 48-2-A 99 BARANSKI J (PLAN ONLY) ST. EMERG. MGMT. OFFICE OFFSITE 102 SCHAEFER TROY(I&C ONLY) I&C/ENGINEERING 45-2-D 106 SIMULATOR INSTRUCT AREA TRG/3PT-D001-DO06 ONLY) #48 164 CONTROL ROOM & MASTER OPS(3PT-D001/6(U3/IPEC) IP3(ONLY) 172 PRUSSMAN STEVE LICENSING K-1P2-4343 207 TROY M PROCUREMENT ENG. 1A 273 FAISON CHARLENE NUCLEAR LICENSING WPO-12 319 L.GRANT (LRQ-OPS TRAIN) LRQ (UNIT 3/IPEC ONLY) #48 354 L.GRANT(LRQ-OPS/TRAIN) LRQ (UNIT 3/IPEC ONLY) #48 357 L.GRANT(ITS/INFO ONLY) TRAINING - ILO CLASSES 48-2-A 424 HULBERT TRACY(7COPIES) (UNIT 3/IPEC ONLY) #48 474 OUELLETTE P ENG., PLAN & MGMT INC OFFSITE 483 SCHMITT RICHIE MAINTENANCE ENG/SUPV 45-1-A 484 HANSLER ROBERT REACTOR ENGINEERING 72'UNIT 2 485 DRAKE RICH DESIGN ENG/6SB/3RD FLOOR 6SB-3B 489 CLOUGHNESSY PAT PLANT SUPPORT TEAM TRL# 1A 491 ORLANDO TOM (MANAGER) PROGRAMS/COMPONENTS ENG 45-3-G 492 PETACHI CHRISTA WC/ONE STOP SHOP IP-K-4321 493 OPERATIONS FIN TEAM 33 TURBIN DECK 45-1-A 494 AEOF/A.GROSJEAN(ALL EP'S) E-PLAN (EOP'S ONLY) WPO-12D 495 JOINT NEWS CENTER EMER PLN (ALL EP'S) EOF 496 L.GRANT(LRQ-OPS/TRAIN) LRQ (UNIT 3/IPEC ONLY) #48 497 L. GRANT (LRQ-OPS/TRAIN) LRQ (UNIT 3/IPEC ONLY) #48 A.

500 L.GRANT (LRQ-OPS TRAIN) LRQ (UNIT 3/IPEC ONLY) #48 501 L.GRANT (LRQ-OPS TRAIN) LRQ (UNIT 3/IPEC ONLY) #48 512 L.GRANT (LRQ-OPS TRAIN) LRQ (UNIT 3/IPEC ONLY) #48 513 L.GRANT (LRQ-OPS TRAIN) LRQ (UNIT 3/IPEC ONLY) #48 518 DOCUMENT CONTROL DESK NRC (ALL EP'S) OFFSITE

a IPEC SITE QUALITY RELATED IP-SMM-AD-103 Revision 0 Entergy MANAGEMENT ADMINISTRATIVE PROCEDURE MANUAL INFORMATIONAL USE Page 13 of 21 ATTACHMENT 10.1 SMM CONTROLLED DOCUMENT TRANSMITTAL FORM SITE MANAGEMENT MANUAL CONTROLLED DOCUMENT TRANSMITTAL FORM - PROCEDURES Page 1 of 1 zr:tEn/e CONTROLLED DOCUMENT TRANSMITTAL FORM - PROCEDURES TO: DISTRIBUTION DATE: 3111/2004 TRANSMITTAL NO: 29116 (Circle one)

FROM: IPEC DOCUMENT CONTROL: EEC or IP2 53'EL PHONE NUMBER: 271-7057 The Document(s) identified below are forwarded for use. In accordance with IP-SMM-AD-103, please review to verify receipt, incorporate the document(s) into your controlled document file, properly disposition superseded, void, or inactive document(s). Sign and return the receipt acknowledgement below within fifteen (15) working days.

AFFECTED DOCUMENT IP3 ITSIBASES/TRM DOC # I REV# TITLE INSTRUCTIONS THE FOLLOWING UPDATE HAS BEEN DONE TO THE TRM. REPLACE CURRENT TRM PAGES WITH ATTACHED REVISED TRM PAGES:

TRM UPDATE 3/1/04

                      • PLEASE NOTE EFFECTIVE DATE***********

RECEIPT OF THE ABOVE LISTED DOCUMENT(S) IS HEREBY ACKNOWLEDGED. I CERTIFY THAT ALL SUPERSEDED, VOID, OR INACTIVE COPIES OF THE ABOVE LISTED DOCUMENT(S) IN MY POSSESSION HAVE BEEN REMOVED FROM USE AND ALL UPDATES HAVE BEEN PERFORMED IN ACCORDANCE WITH EFFECTIVE DATE(S) (IF APPLICABLE) AS SHOWN ON THE DOCUMENT(S).

NAME (PRINT) SIGNATURE DATE CC# 610

LIST OF EFFECTIVE SECTIONS TRM EFFECTIVE TRM EFFECTIVE SECTION D Page(s) DATE SECTION o Page(s) DATE Table of 2 i through iii 12/04/2002 3.8.C 0 3.8.C-1 through 10 03/19/2001 Contents _ 3.8.D 0 3.8.D-1 through 2 03/19/2001 1.1 2 1.1-1 through 5 02123/2004 3.9 0 3.9-1 03/19/2001 1.2 0 1.2-1 through 3 03/19/2001 4.0 0 4.0-1 03/19/2001 1.3 0 1.3-1 through 8 03/19/2001 5.0 3 5.0-1 through 7 03/01/2004 I 1.4 0 1.4-1 through 4 03/19/2001 2.0 0 2.0-1 03/19/2001 3.0 1 3.0-1 through 15 07/06/2001 3.1.A 1 3.1 .A-1 through 8 07/06/2001 3.1.B 0 3.1.1B-1 03/19/2001 3.1.C.1 I 3.1.C.1-1 through 8 03/06/2003 3.1.C.2 I 3.1.C.2-1 through 6 03/06/2003 3.2.A 0 3.2.A-1 03/19/2001 3.3.A 0 3.3.A-1 through 3 03/19/2001 3.3.B I 3.3.B-1 through 12 04/16/2003 3.3.C 0 3.3.C-1 through 5 03/19/2001 3.3.D 2 3.3.D-1 through 20 09/03/2003 3.3.E 0 3.3.E-1 through 3 03/19/2001 3.3.F 0 3.3.F-1 through 3 03/19/2001 3.3.G 0 3.3.G-1 through 2 03/19/2001 3.3.H 0 3.3.H-1 through 2 03/19/2001 3.3.1 -- NOT USED--

3.3.J 1 3.3.J.1 through 5 04/16/2003 3.4.A 0 3.4.A-1 through 2 03119/2001 3.4.B 0 3.4.B-1 through 3 03/19/2001 3.4.C 0 3.4.C-1 through 2 03/19/2001 3.4.D 0 3.4.D-1 through 2 03/19/2001 3.5.A 0 3.5.A-1 through 2 03/19/2001 3.6 0 3.6-1 03/1912001 3.7.A. 1 0 3.7.A.1-1 through 5 03/19/2001 3.7.A.2 1 3.7.A.2-1 through 3 03/01/2004 3.7.A.3 4 3.7.A.3-1 through 5 03/01/2004 3.7.A.4 2 3.7.A.4-1 through 3 03/01/2004 3.7.A.5 0 3.7.A.5-1 through 3 03/19/2001 3.7.A.6 0 3.7.A.6-1 through 2 03/19/2001 I 3.7.A.7 1 3.7.A.7-1 through 4 03/01/2004 3.7.B 1 3.7.B-1 through 17 02/23/2004 3.7.C 0 3.7.C-1 through 8 03/19/2001 3.7.D 0 3.7.D-1 through 2 03/19/2001 3.7.E 0 3.7.E-1 through 2 03/19/2001 3.8.A 0 3.8.A-1 through 5 03/19/2001 3.8.B 0 3.8.B-1 through 7 03/19/2001 Technical Requirements Manual (TRM)

Indian Point 3 1 of 1 EFFECTIVE DATE 03/01/2004

Fire Protection Water Spray and Sprinkler Systems 3.7.A.2 3.7 PLANT SYSTEMS 3.7.A FIRE PROTECTION SYSTEMS 3.7.A.2 Fire Protection Water Spray and Sprinkler Systems TRO 3.7.A.2 The following Fire Protection Water Spray and Sprinkler Systems, as listed in AP-64.1, shall be OPERABLE:

a. Electrical Tunnel Preaction Water Spray System (El-34' & El-43').
b. Diesel Generator Building Water Spray System (El-1 5').
c. Containment Fan Cooler Charcoal Filter Dousing System (El-68').
d. Water Spray System at PAB door DR-I-PA to main transformer yard (EI-18').
e. Turbine Building Pipe Bridge Water Spray System (El-41' 2 '2& 52'4').
f. Auxiliary Feedwater Pump Room Wet Pipe Sprinkler System (El-1 8'6").

APPLICABILITY: Whenever equipment protected by the water spray or sprinkler system is required to be OPERABLE.

1. Separate condition entries are allowed.
2. TRO 3.0.C is not applicable.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One or more systems A.1.1 Establish a continuous fire watch and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> described in TRO backup fire suppression equipment for I 3.7.A.2.a and TRO the unprotected area(s),

3.7.A.2.f inoperable. OR A.1.2.1 VERIFY smoke detectors in the affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> area to be OPERABLE, AND A. 1.2.2 Establish an hourly fire watch and backup 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire suppression equipment for the unprotected area(s).

AND A.2 Restore the inoperable system(s) to 14 days OPERABLE status.

B. One or more of the B.1 Establish a continuous fire watch and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> systems described in backup fire suppression equipment for TRO 3.7.A.2.b, accessible unprotected area(s).

3.7.A.2.c, 3.7.2.A.d, AND and 3.7.A.2.e B.2 Restore the inoperable system(s) to 14 days inoperable. OPERABLE status.

C. Required Actions and C.1 Submit a Special Report to the Plant Completion Times of Operating Review Committee according 30 days A.2 OR B.2 not met. to TRM 5.4.B.

Technical Requirements Manual (TRM) (continued)

Reiso 1 Indian Point 3 IniaPon 3 3..-

3.7.A.2-1 Revision 1

Fire Protection Water Spray and Sprinkler Systems 3.7.A.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TRS DEMONSTRATE that each accessible valve (manual, power 3.7.A.2.1 (1) operated, or automatic) in the flow path is in the correct position. 31 DAYS Valve Cycling Test - Exercise each valve necessary for proper TRS functioning of any portion of this system required for protection of 3.7.A.2.2 safe shutdown systems through at least one complete cycle:

(1) (i) Valves testable with plant in MODE 1. (i) 12 months (ii) Valves not testable with plant in MODE 1. (ii) 24 months System Functional Test - Includes simulated automatic / remotely operated actuation of system and verification that automatic /

TRS remotely operated valves in the flow path actuate to their correct 3.7.A.2.3 position.

(1) (i) Systems described in TRO 3.7.A.2.a, 3.7.A.2.b, 3.7.A.2.d, (i) 18 months 3.7.A.2.e, and 3.7.A.2.f (ii) 24 months (ii) System described in TRO 3.7.A.2.c Header Visual Inspection - DEMONSTRATE integrity.

TRS (i) Systems described in TRO 3.7.A.2.a, 3.7.A.2.b, 3.7.A.2.d, (i) 18 months 3.7.A.2.4(1) 3.7.A.2.e, and 3.7.A.2.f (ii) 24 months (ii) System described in TRO 3.7.A.2_c  ;

Visual Inspection of each Spray Nozzle - DEMONSTRATE that TRS each nozzle's spray area is unobstructed.

3.7.A.2.5 (i) Systems described in TRO 3.7.A.2.d and 3.7.A.2.e. (i) 18 months (1) (ii) System described in TRO 3.7.A.2 c (ii) 24 months TRS Air Flow Test - Perform air flow test through each open spray 3.7.A.2.6 nozzle and DEMONSTRATE each open spray nozzle is 3 years (1) unobstructed.

For systems described in TRO 3.7.A.2.a, 3.7.A.2.b, and 3.7.A.2.f, TRS automatic (i.e., closed head) spray nozzles and sprinklers shall be 18 months 3.7.A.2.7 inspected visually to DEMONSTRATE that no damage exists and that the spray nozzle/ sprinkler is unobstructed.

Note 1: Surveillance requirements TRS 3.7.A.2.1 through 3.7.A.2.6 shall not apply to automatic (i.e.,

closed head) spray nozzles/sprinklers that are capable of only one actuation and cannot be cycled or tested periodically. The surveillance requirement for these automatic (i.e., closed head) spray nozzles/sprinklers is TRS 3.7.A.2.7.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.2-2 Revision 1

Fire Protection Water Spray and Sprinkler Systems 3.7.A.2 BASES TRO This Technical Requirement ensures OPERABILITY of fire protection and detection systems that protect safety related systems and components that are required to shutdown the reactor and mitigate the consequences of postulated accidents and maintain it in a safe shutdown condition and those fire suppression systems which form in part the basis for compliance with 10 CFR 50, Appendix R.

APPLICABLE SAFETY ANALYSIS IP3 fire protection and detection systems conform to:

  • NRC FP SER dated March 6, 1979 as supplemented by NRC letter dated May 2,1980
  • NRC FP SER dated January 7,1987.

SURVEILLANCE This Technical Requirement establishes the surveillance program for Fire Protection Water Spray and Sprinkler Systems that protect safe shutdown equipment. This surveillance program DEMONSTRATES OPERABILITY of these systems and provides assurance that the systems will perform their intended function.

Containment is not considered normally accessible during plant operation.

ACTIONS A.1.2.1 When implementing an hourly roving watch in lieu of a continuous watch, VERIFY smoke detectors to be OPERABLE in the affected area. IF the smoke detectors in the affected area are determined to be inoperable while applying this compensatory action, THEN within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, restore the smoke detector(s) to OPERABLE status or apply a continuous watch in the affected area (reference 2).

REFERENCES:

1. Nuclear Safety Evaluation NSE 95-03-334-FP, "Revision to the Operational Specifications to Reflect Electrical Tunnel Smoke Detector System Operability Criteria and Compensatory Measures for Spray/Sprinkler Systems."
2. Nuclear Safety Evaluation NSE 96-3-395-FP, 'Development of Administrative Procedure AP-64.1 and Evaluation of a Change to Operational Specifications 3.2 and 3.5."
3. FSAR 9.6.2 Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.2-3 Revision 1

Fire Separation Devices 3.7.A.3 3.7 PLANT SYSTEMS 3.7.A FIRE PROTECTION SYSTEMS 3.7.A.3 Fire Separation Devices TRO 3.7.A.3 Fire Seals, Fire Doors, Fire Dampers in required Fire Barriers, Controlled Barriers, Fire Barrier Wraps, and Radiant Energy Shields shall be OPERABLE (Refer to AP-64.1 for listing).

APPLICABILITY: AT ALL TIMES, except as modified in Note 3 or 4 below.

1. Separate Condition Entries are allowed for individual features.
2. TRO 3.0.C does not apply.
3. For Fire Separation Devices that are only Appendix R type features as identified in AP-64.1, entry into Actions below is not required in Modes 5, 6 or when de-fueled.
4. For Fire Separation Devices that are not required because the equipment they are protecting is not required to be OPERABLE, entry into Actions below is not required.
5. TRO 3.0.D is not applicable.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One or more of A.1.1 Establish a continuous fire watch on at least one 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the following side of the inoperable feature, Fire Protection OR or Appendix R A.1.2.1 VERIFY the operability of fire detectors on at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperle, one side of the inoperable feature.

Inoperable.

(i.e. Fire Seals, AND Fire Doors, A. 1.2.2 For inoperable features outside the Containment 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Fire Dampers Building, establish an hourly fire watch patrol, in required Fire except when Condition B applies.

Barriers, AND Controlled A. 1.2.3 For Fire Barrier Wraps and Radiant Energy Barriers, Fire Shields inside the Containment Building establish 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Barrier Wraps, a fire watch patrol once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when not in and Radiant MODE 1.

Energy Shields .) I AND A.2 For Fire Protection features, restore the inoperable 7 days to OPERABLE status.

AND A.3 For Appendix R features, restore the inoperable 30 days feature to OPERABLE status.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.3-1 Revision 4

Fire Separation Devices 3.7.A.3 CONDITION REQUIRED ACTION COMPLETION TIME B. One or more fire doors or fire B.1 Establish a continuous fire watch 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> seals in the barriers and backup fire suppression I separating the diesel equipment for the diesel generator generator compartments compartments where the C02 fire from each other or from the suppression system(s) is (are)

Control Building, inoperable, unavailable per TRO 3.7.A.7, AND AND C02 fire suppression system B.2 Restore the inoperable feature to 7 days of the diesel generator OPERABLE status.

building, adjacent to the inoperable fire door or fire seal in the barrier(s),

unavailable per TRO 3.7.A.7.

C. Required Actions and C.1 Submt a Special Report to the 14 days Completion Times of A.2, A.3 OSRC in accordance with TRM and/or B.2 not met. 5.4.B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TRS DEMONSTRATE each barrier, wrap, and shield to be 24 months 3.7.A.3.1 OPERABLE by visual inspection. Refer to AP 64.1 for listing.


NOTE -------------------

The inspection sample shall be determined as described in BASES TRS 3.7.A.3.2.

TRS DEMONSTRATE 15% of fire seals located in fire 24 months 3.7.A.3.2 barriers governed by this TRO (refer to AP 64.1 for (i) when accessible listing) to be OPERABLE by visual inspection. but within 15 years (ii) not required (i) not readily accessible penetration seals as AND defined in the BASES TRS 3.7.A.3.2 (ii) inaccessible penetration seals as defined in the Prior to declaring a BASES TRS 3.7.A.3.2 fire seal OPERABLE following repairs or maintenance.

TRS DEMONSTRATE each fire door to be OPERABLE 184 days 3.7.A.3.3 by visual inspection and operation. (Refer to AP 64.1 for listing)

TRS DEMONSTRATE each fire damper to be 24 months 3.7.A.3.4 OPERABLE by visual inspection and operation (Refer to AP 64.1 for listing).

Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.3-2 Revision 4

Fire Separation Devices 3.7.A.3 BASES BACKGROUND These specifications are established to assure the operability and provide surveillance requirements of fire protection and detection systems provided to protect equipment utilized for safe shutdown of the unit.

APPLICABLE SAFETY ANALYSIS The fire protection and detection systems installed at IP3, conform to Appendix A of Branch Technical Position (BTP) APCSB 9.5-1 "Fire Protection for Nuclear Power Plants", as approved by the NRC Regulatory Staff on March 6, 1979 as Amendment No. 24 to facility operating license No.

DPR-64, and supplements thereto, and IP3 Appendix R Analysis (latest revision). NSE 97-03-013-FBAR, revision 1, "Fire Barrier Penetration Seal Inspections," justifies a change in. inspection method at a frequency of 24 months from 100% sample inspection to a 15% defined sample inspection. NSE 97-3-302-FP-C02, Rev. 0, allows an hourly fire watch patrol in lieu of a continuous fire watch in the emergency diesel generator compartment(s) when its C02 fire protection system is unavailable with its fire barriers, sprinkler system and detection system meeting certain requirements. If its sprinkler system, barriers or detection system becomes degraded below these requirements then TRO 3.7.A.2, 3.7.A.3, and 3.7.A.4, respectively, require establishing a continuous fire watch for the affected diesel compartment(s). NSE 96-3-395FP, combined Operational Specification 3.2.13 and 3.5.3 (converted to TRO 3.7.A.3 for inclusion in TRM) into one specification and adapted AP 64.1 for listings.

TRO Fire Separation Devices are those which are required by the Fire Protection Program to separate redundant safety-related systems or isolate safety related systems and components from unacceptable hazards. Appendix R barriers are those barriers which have been credited in the Appendix R Safe Shutdown Analysis. Refer to AP-64.1 for a listing of fire barriers, fire wrap or radiant energy shields governed by this Technical Requirement.

APPLICABILITY Fire Protection Barriers are those that are required by the Fire Protection Program to separate redundant safety-related systems or isolate safety related systems and components from unacceptable hazards. Appendix R barriers are those barriers which have been credited in the Appendix R Safe Shutdown Analysis. Refer to AP-64.1 for a listing of fire barriers, fire wrap or radiant energy shields governed by this Technical Requirement.

ACTIONS Note 1 modifies the Actions to clarify the application of Completion Times for inoperable Fire Protection and Appendix R features. Separate condition entry is allowed for each inoperable features separation device. The Completion Time(s) for the inoperable Fire Protection and Appendix R feature will be tracked separately for each feature starting from the time the Condition was entered for that feature.

Note 2 provides an exception to TRO 3.0.C and precludes a plant shutdown if the required actions are not performed in their completion time. These notes are acceptable because it is judged reasonable and determined not to adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.3-3 Revision 4

Fire Separation Devices 3.7.A.3 Note 3 modifies the applicability statement for Fire Separation Devices that are only required for Appendix R compliance. Note 3 is an allowance not to enter Action statement(s) when in modes 5, 6 or when de-fueled for inoperable Appendix R fire separation devices, since Appendix R only applies above cold shutdown.

Note 4 provides an allowance not to enter Action statement(s) for those inoperable fire separation devices when the equipment they are protecting is not required to be operable.

Note 5 provides an allowance for changes in operating MODE while relying on Required Actions.

Allowance of this exception to TRO 3.0.D is also based on the low probability of an event requiring the use of such instruments and reasoning that such instruments can generally be repaired during plant operation without a significant risk of a spurious plant trip.

A.1.1,A.1.2.1 &A.1.2.2 Verification of OPERABILITY of fire detectors is satisfied if the last surveillance test that was performed satisfactorily demonstrated system or component OPERABILITY. If any information is available that challenges OPERABILITY, then the OPERABILITY is questionable until it is demonstrated by performing another test. Information that can challenge OPERABILITY can be (but is not limited to) visual observation, or PIDs, CRs, or work requests written against the system.

The completion time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> was selected as a reasonable time in which a continuous fire watch could be posted or verification of the OPERABILITY of fire detectors could be done along with the posting of an hourly fire watch patrol A. 1.2.3 The completion time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> was selected as a reasonable time in which a fire watch patrol could be established inside the Containment Building considering confined space issues and existing radiological controls governing such an entry. The establishment of an 8-hour fire watch patrol for areas inside the Containment Building was selected to limit radiation exposure to fire watch personnel while still maintaining reasonable compensatory measure given the potential fire hazard: Access to the Containment Building during MODE 1 is limited, as such the presence of transient combustibles or activities that could affect redundant systems and components is also limited.

A.2, A.3 With any barrier inoperable, the barrier must be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or take compensatory actions and restore the barrier to OPERABLE status within 7 days and for Appendix R barrier within 30 days.

The completion times were selected as a reasonable time to restore the barrier to OPERABLE status with compensatory measures in place.

B.1 The completion time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> was selected as a reasonable time in which a continuous fire watch could be posted.

B.2 The completion time of 7 days for restoring an inoperable fire protection feature to OPERABLE status was selected as a reasonable time to restore the barrier to OPERABLE status with compensatory measures in place.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.3-4 Revision 4

Fire Separation Devices 3.7.A.3 SURVEILLANCE REQUIREMENTS TRS 3.7.A.3.2 A minimum 15% sample of penetrations shall be visually inspected on a 24 month frequency. If a non-functional penetration seal is found during the initial inspection, a determination of the cause of unsatisfactory condition shall be performed and an additional 15% sample shall be generated based on that cause (i.e., penetrations most likely to experience the same problem) and inspected. This inspection process shall continue until a sample has rendered satisfactory inspection results.

The initial sample shall be determined based on environmental conditions to which the penetration seals are exposed (i.e., temperature, humidity and radiation). The sample selection shall also ensure that each type of seal is reasonably represented in the sample. In a effort to employ a systematic approach to the inspections thereby eliminating the potential of new penetrations being overlooked if only a few penetrations on any one wall are inspected, the initial sample shall also be determined based on fire barriers. That is, a group of fire barriers will be selected for each inspection period. The barriers will be selected based on environmental conditions. All penetrations in the selected barriers shall be inspected. The number of penetrations shall be reviewed to ensure that at least 15% of all penetrations is obtained. Further, the sample shall be reviewed to ensure that each type of seal is reasonably represented in the sample.

Should a penetration seal that is not readily accessible (as defined below) be selected as part of the sample, the inspection of that seal may be held in abeyance until such time that the several becomes accessible. This may be dependent on the preventive maintenance program (deenergized equipment), plant operating mode (radiation areas) or scaffolding program (physical accessibility, see note below). Another penetration shall be selected if required to fill the minimum 15% sample.

Penetration seals that are defined as not readily accessible include those that are located:

1) within energized electrical enclosures that are high voltage and have an exposed electrical connection or bus work
2) in locked or bolted panels and enclosures that are high voltage and have an exposed electrical connection or bus work, or have a significant trip risk
3) in locked high radiation areas, or high radiation areas where accessibility may be dependent on plant evolutions
4) in areas where physical access is significantly restricted and the use of remote mirrors, binoculars or scopes is significantly difficult
5) in the same fire zone where scaffolding has been erected and some of the inspection sample are readily accessible by use of the scaffolding Note: Generally, the use of scaffolding does not provide the basis for relief from the above unless the erection of that scaffolding may cause a personnel hazard or potential plant transient.

Visual inspection of inaccessible penetration seals may be discontinued. Prior to discontinuing inspection of inaccessible penetration seals, an engineering evaluation in accordance with the guidance of Generic Letter (GL) 86-10 shall be performed for each seal. This evaluation should consider proximate combustible loading, hazards and consequences of seal failure as well as other mitigating features. Penetration seals that are defined as inaccessible include those which are located in areas where physical access is not possible or extreme measures are required to support inspection of the seal (i.e., where destructive measures are required or where removal of fixed equipment or building features is required).

REFERENCE FSAR 9.6.2 Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.3-5 Revision 4

Fire Detection Systems 3.7.A.4 3.7 PLANT SYSTEMS 3.7.A FIRE PROTECTION SYSTEMS 3.7.A.4 Fire Detection Systems TRO 3.7.A.4 The minimum number of fire detectors for each location listed in AP-64.1 shall be OPERABLE.

APPLICABILITY: Whenever equipment in that location is required to be OPERABLE.

1. Separate Condition entries are allowed.
2. TRO 3.0.C is not applicable.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One or more fire locations A.1 Establish an hourly fire watch patrol, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with less than the minimum where accessibility permits, in the number of required fire affected location(s),

detectors listed in AP-64. 1 OPERABLE. AND A.2 Restore the required fire detectors to OPERABLE status. 14 days B. Less than the minimum B.1 Establish a continuous fire watch and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> number of required fire backup fire suppression equipment for detectors in diesel generator the diesel generator compartment(s) compartment(s), where the C02 Fire Protection OPERABLE System(s) are unavailable, AND AND CO2 Fire Protection B.2 Restore required fire detectors in the System(s) within affected affected diesel generator 14 days compartment(s), compartment(s) to OPERABLE status.

unavailable.

C. Required Action and C.1 Submit a Special Report to the PORC 30 days Completion Time of A.2 OR in accordance with specification 5.4.B.

B.2 not met.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.4-1 Revision 2

Fire Detection Systems 3.7.A.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TRS Smoke Detectors - DEMONSTRATE OPERABILITY of the 12 months 3.7.A.4.1 detectors listed in AP-64.1.

TRS Heat Detectors - DEMONSTRATE OPERABILITY of the 3.7.A.4.2 detectors listed in AP-64.1 as follows:

(i) All detectors except those associated with VC building FCUs (i) 12 months and C02 systems.

(ii) Those detectors associated with the VC building FCUs and (ii) 24 months C02 systems.

TRS Flame Detectors- DEMONSTRATE OPERABILITY of the 18 days 3.7.A.4.3 detectors listed in AP-64.1.

BASES TRO These specifications are established to assure the OPERABILITY of Fire Detection Systems provided to protect equipment utilized for safe shutdown of the unit. Containment is not considered normally accessible during MODEs 1, 2, 3, and 4.

APPLICABLE SAFETY ANALYSIS The fire protection and detection systems installed at 1P3, conform to Appendix A of Branch Technical Position (BTP) APCSB 9.5-1 "Fire Protection for Nuclear Power Plants", as approved by the NRC Regulatory Staff on March 6, 1979 as Amendment No. 24 to facility operating license No.

DPR-64, and supplements thereto.

NSE 97-3-302-FP-CO2, Rev. 0, allows an hourly fire watch patrol in lieu of a continuous fire watch in the emergency diesel generator compartment(s) when its C02 fire protection system is unavailable with its fire barriers, sprinkler system and detection system meeting certain requirements. If its sprinkler system, barriers or detection system becomes degraded below these requirements then TRO 3.7.A.2, 3.7.A.3, and 3.7.A.4, respectively, require establishing a continuous fire watch for the affected diesel compartment(s).

NSE 97-3-400FP C02, Rev. 1, evaluated the installation of a door release system for fire door FDR-30-CB. Fire door FDR-30-CB provides protection from the spread of a fire through the doorway in the fire barrier between the cable spreading room (fire area CTL-3) and the Electrical Tunnel (fire area ETN-4). Since the door is a normally open door, integrity of the barrier in the event of a fire, is assured by automatic closure of the door. Two pairs of heat detectors have been installed in the electrical tunnel entryway that will actuate the door release mechanism upon one pair detecting a Technical Requirements Manual (TRM) (continued)

Revision 2 Indian Point 33 3.7.A.4-2 3.7.A.4-2 Revision 2

Fire Detection Systems 3.7.A.4 fire. Additionally, the door release mechanism will be actuated upon the cable spreading room heat detection associated with the C02 system. The Fire door FDR-30-CB also provides a support function by remaining open during abnormal and accident conditions to ensure ventilation cooling of safety-related equipment in the cable spreading room by the Electrical Tunnel Ventilation System's exhaust fans.

NSE 96-3-395-FP, revision 1 justifies extending the frequency for testing smoke detectors from every 6 months to every 12 months. The frequency of 12 months for periodic testing smoke detectors is adequate for reasonable assurance of system functionality and availability. This is based in part on IP3 experience and NFPA 72-1996 as evaluated in NSE 96-3-395-FP, revision 1.

SURVEILLANCE These Technical Requirements establish the surveillance program for Fire Detection Systems provided to protect equipment utilized for safe shutdown of the unit. This surveillance program is intended to DEMONSTRATE the OPERABILITY of these systems and provide assurance that the systems will perform their intended function.

TRS 3.7.A.4.1 The frequency of 12 months for periodic testing smoke detectors is adequate for reasonable assurance of system functionality and availability. This is based in part on IP3 experience and NFPA 72-1996 as evaluated in NSE 96-3-395-FP, revision 1.

TRS 3.7.A.4.2.(i)

The frequency for periodic testing of the heat detectors associated with the automatic release system provided for fire door FDR-30-CB, is based on the requirements of NFPA 72-1996. This test does not need to DEMONSTRATE that the fire door release mechanism actuates upon a simulated actuation signal because this DEMONSTRATION is performed per TRS 3.7.A.

7.3 REFERENCES

1. FSAR 9.6.2 Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.4-3 Revision 2

CO2 Fire Protection System 3.7.A.7 3.7 PLANT SYSTEMS 3.7.A FIRE PROTECTION SYSTEMS 3.7.A.7 CO2 Fire Protection System TRO 3.7.A.7 As a minimum, one C02 Storage Tank shall be available with a minimum level of 60%

and a minimum pressure of 275 psi and the CO2 System Fire Protection available to supply the C02 areas as listed in AP-64.1.

APPLICABILITY: Whenever equipment in these areas are required to be OPERABLE.

-__ NOTES-

1. Separate Condition entries are allowed.
2. TRO 3.0.C is not applicable.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. C02 Storage A.1.1 Establish a continuous fire watch and backup fire 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Tank suppression equipment for the accessible inoperable unprotected area(s),

OR OR A.1.2.1 For the diesel generator room(s) only, VERIFY fire detectors in the affected room(s) are OPERABLE, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> CO2 Fire AND Protection A.1.2.2 VERIFY the fire barriers between the affected System room(s) and adjacent diesel generator room(s) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> unavailable and between the affected room(s) and the Control Building are OPERABLE, AND A. 1.2.3 VERIFY the diesel generator room sprinkler system in the affected room(s) are operable, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND A.1.2.4 Establish an hourly fire watch patrol with backup fire suppression equipment for the affected diesel 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> generator room(s).

AND A.2 Restore C02 Fire Protection System equipment to 14 days OPERABLE status.

B. Required Acompletion B. Submit a Special Report to the PORC in accordance30dy To p f tin2 with specification 5.4.B. 30 days not met.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.7-1 Revision 1

C02 Fire Protection System 3.7.A.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TRS 3.7.A.7.1 DEMONSTRATE availability of CO2 Supply Units 3-1 or 3-2 for that 7 days unit which is lined up to the Control and Diesel Generator Buildings by visual observation of level and pressure indication for associated tank.

TRS 3.7.A.7.2 DEMONSTRATE that each valve (manual, power operated or 31 days automatic) in the flow path is in its correct position.

TRS 3.7.A.7.3 System Functional Test:

(i) DEMONSTRATE that system valves and associated (i)24 months ventilation dampers and fire door release mechanisms actuate upon receipt of a simulated actuation signal.

(ii) Exercise fire dampers. (ii) 12 months TRS 3.7.A.7.4 DEMONSTRATE flow from nozzles. 24 months BASES BACKGROUND These Technical Requirements are established to assure the operability and provide surveillance requirements of fire protection and detection systems provided to protect equipment utilized for safe shutdown of the unit.

APPLICABLE SAFETY ANALYSIS The fire protection and detection systems installed at IP3, conform to Appendix A of Branch Technical Position (BTP) APCSB 9.5-1 "Fire Protection for Nuclear Power Plants", as approved by the NRC Regulatory Staff on March 6, 1979 as Amendment No. 24 to facility operating license No.

DPR-64, and supplements thereto.

NSE 97-3-302-FP-C02, Rev. 0, allows an hourly fire watch patrol in lieu of a continuous fire watch in the emergency diesel generator compartment(s) when its C02 fire protection system is unavailable with its fire barriers, sprinkler system and detection system meeting certain requirements. If its sprinkler system, barriers or detection system becomes degraded below these requirements then TRO 3.7.A.2, 3.7.A.3, and 3.7.A.4, respectively, require establishing a continuous fire watch for the affected diesel compartment(s).

NSE 97-3-400FP C02, Rev.1, evaluates the use of dry air as an alternate test medium to C02 during functional testing of the C02 Fire Protection System.

NSE 97-3-424-FP-C02, Rev. 2, evaluates the use of administrative controls during periodic functional testing of the C02 system to ensure the support function of ventilation to the EDG is maintained ensuring continued operability of the EDG throughout the test. Implicit in the definition of operability of the EDGs, is the assumption that the associated ventilation systems that are required to maintain the room temperature below its design or limiting equipment qualification temperature, are also be capable of performing their function. These administrative controls are defined below in BASES Surveillance section.

NSE 98-03-048 FP C02, Revision 0 recognized that, under specific conditions, it may be necessary to Technical Requirements Manual (TRM) (continued)

Revision 1 Point 33 Indian Point Indian 3.7.A.7-2 3.7.A.7-2 Revision 1

CO2 Fire Protection System 3.7.A.7 isolate C02 storage tank 3-2 to correct deficiencies associated with one or more of the supplied systems. The NSE evaluated the effect on the operating mode (i.e., automatic versus manual) of the C02 fire suppression systems provided for the main boilerfeed pumps and concluded that the backup fire protection provides an acceptable level of protection until the tank valve is re-opened. The NSE specifically considered backup fire suppression (i.e., a manual water spray system or standpipe system); automatic fire detection (i.e., heat detectors or heat responsive automatic sprinklers) and a 24-hour staffed on site fire brigade.

TRO The C02 system fire protection availability by definition shall be interpreted to mean with the system in either the automatic or the manual mode of operation with the automatic mode as the primary mode of operation.

ACTIONS A.1.1 Continuous fire Watch means an individual is, without interruption, physically located in the unprotected area(s), (i.e., the area(s) lacking C02 fire protection). Using a roving watch with other, concurrent responsibilities would not be satisfactory compensatory action. With the C02 fire protection system out of service for the entire control building, three fire watches would be needed: 1) in the cable spreading room, 2) in the switch gear room, and 3) in the diesel generator building (the three diesel cells are contiguous in one fire area and have additional fire water protection). NSE 97-3-400FP C02, Rev.1, evaluated that during C02 functional testing, the continuous fire watch will remain in place unless occupying the Control Building poses an undue risk to personnel safety. In which case the continuous fire watch(es) will be temporarily relieved of their post(s) until the conditions of the building will allow re-entry.

A.1.2 Absent the availability of C02 fire protection system in the Diesel Generator Building, fire detectors of the heat detection systems, the automatic water spray systems and fire walls between adjacent diesel generator rooms and from the Control Building, coupled with compensatory action in the form of an hourly fire watch patrol and backup fire suppression equipment will provide reasonable assurance that a fire will be promptly detected and will ensure that the material condition of the rooms are maintained consistent with the administrative controls established under the IP3 Fire Protection Program. This will provide reasonable assurance that if a fire gets started, fire damage would be limited to a single diesel generator room by means of the automatic water spray system or manual action by the on-site fire brigade. As such, the verification that the fire detectors in the affected room and the fire walls between the affected room and adjacent diesel generator rooms are operable, coupled with an operable water spray system within the diesel generator sump and above the day tank provides reasonable justification to allow for an hourly fire watch patrol in lieu of a continuous fire watch when a Diesel Generator Building C02 fire protection system is unavailable.

SURVEILLANCE Administrative controls are allowed during C02 functional testing to maintain the ventilation system support function available with manual action ensuring continued EDG operability. During testing, the thermostatic controls of the associated exhaust fans will be defeated such that the fans cannot automatically start on high ambient room temperature. Since the actuation circuit of the C02 system results in the cell intake air/smoke dampers to close, manual action is credited to reopen these dampers and restore EDG cell ventilation upon an EDG automatic start. The controls consist of a dedicated person located in the EDG cell, or in an adjacent room with the door between the two cells Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.7-3 Revision I

CO2 Fire Protection System 3.7.A.7 open, to first manually restore the open position of the smoke damper located on the 15' elevation, then to reposition the control switch for one of the two exhaust fans to start, and lastly manually restore the open position of the smoke damper located in the crawl space below the 15' elevation.

These actions to restore ventilation shall be proceduralized in the test and reviewed as part of the pre-test briefing along with the location of equipment, access through crawl space for the second smoke damper and the equipment necessary to access and hold open the smoke dampers (i.e., a hand-held flashlight and utilizing approved qualified smoke damper open devices, such as un-fused electrical thermo links (ETL). Reference 3.

REFERENCES:

1) NSE 97-3-302-FP-C02, Rev. 0, "Change in the Compensatory Action in the Event of a C02 Fire Protection System of the Diesel Generator Building is Unavailable."
2) NSE 97-3-400-FP-C02, Rev. 1, "Installation of a Seismic Control Panel for the 480V Switchgear Room and Cable Spreading Room C02 Systems."
3) NSE 97-3-424-FP-C02, Rev. 2, "Installation of Seismic Control Panels for the EDG Cell C02 Systems and Supporting System Improvements."
4) NSE 98-3-048-FP C02, Rev. 0, uOperation of the Plant with an Inoperable C02 Fire Suppression System for the Main Boiler Feed Pumps."
5) FSAR 9.6.2 Technical Requirements Manual (TRM) (continued)

Indian Point 3 3.7.A.7-4 Revision 1

Responsibilities 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibilities 5.1 .A The plant manager shall be responsible for overall unit operation in accordance with Technical Requirements Manual.

5.1 .B The shift supervisor shall be responsible for ensuring plant operations are in accordance with Technical Requirements Manual.

Example: Technical Requirements for Operation (TRO) are met or Required Actions are met within associated Completion Time.

5.1.C Department managers shall be responsible for ensurng work activities are performed in accordance with Technical Requirements Manual.

Example: Technical Requirement Surveillance (TRS) are met; Technical Requirements for Operations (TRO) are met.

5.1 .D The Quality Assurance Manager shall be responsible for reviewing effectiveness of Technical Requirements Manual implementation at least once every three years.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 5.0-1 Revision 3

Technical Requirements Manual Update & Basis Control 5.2 5.0 ADMINISTRATIVE CONTROLS (continued) 5.2 Technical Requirements Manual Update & Basis Control 5.2.A Changes to the Technical Requirements Manual (TRM) and Basis shall be made in accordance with SMM-LI-1 13, "Technical Specification Bases, Technical Requirements Manual and Updated Final safety Analysis (UFSAR) Amendment Preparation and Control."

Technical Requirements Manual (TRM) (continued)

Indian Point 3 5.0-2 Revision 3

Procedures 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Procedures 5.3.A Written procedures shall be established, implemented, and maintained covering the Technical Requirements Manual activities.

5.3.B Each procedure of Requirement 5.3.A, and changes thereto, shall be reviewed and approved in accordance with an approved process that meets the requirements of the Quality Assurance Program Manual (QAPM) prior to implementation.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 5.0-3 Revision 3

Reporting Requirements 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Reporting Requirements 5.4.A The following reports shall be made in accordance with 10 CFR 50.72 and 10 CFR 50.73.

  • AMSAC Actuation as per Technical Requirements Manual 3.1 .A Condition D.
  • AMSAC Inoperability as per Technical Requirements Manual 3.1 .A Condition C.

5.4.B Submit a Special Report to the PORC outlining the cause of the inoperability of required fire protection equipment, the extent of condition, and the plans and schedule for restoring the inoperable equipment to OPERABLE status. The review of the inoperability must consider, in aggregate, the other fire equipment inoperability/TROs.

The review must determine whether or not the condition would adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. A copy of the report should be sent to the senior manager responsible for oversight of the Fire Protection.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 5.0-4 Revision 3

Record Retention 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Record Retention In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.

5.5.A The following records shall be retained for at least 5 years:

a. Records of changes made to the procedures required by Technical Requirements Manual.
b. Records and logs of principal maintenance activities, inspections, repair, and replacement of principal items of equipment related to Technical Requirements Manual.
c. Records of surveillance activities, inspections, and calibrations required by the Technical Requirements Manual.

5.5.B The following records shall be retained for the duration of the unit Operating License:

a. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments required by Technical Requirements Manual and pursuant to 10 CFR 50.59;
b. Records of the reviews and audits required by Technical Requirements Manual.
c. Records of service lives of all safety-related snubbers including the date at which the service life commences and associated installation and maintenance records.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 5.0-5 Revision 3

Audits 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Audits 5.6.A Quality Assurance shall perform an effectiveness audit of Technical Requirements Manual implementation at least once every three years.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 5.0-6 Revision 3

Training & Organization 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 Training & Organization 5.7.A A training program for the Fire Brigade shall be maintained and shall meet or exceed the requirements of NFPA 27-1975 with the exception of the training program schedule.

5.7.B A Fire Brigade of at least five members shall be maintained on site. This excludes four members of the minimum shift crew necessary for safe shutdown of the plant and any personnel required for other essential functions during a fire emergency. During periods of cold shutdown the Fire Brigade will exclude two members of the minimum shift crew.

Technical Requirements Manual (TRM) (continued)

Indian Point 3 5.0-7 Revision 3