ML042380298

E-mail, C. Ogle to Gerald Wiseman, My Review of Your Bf Input

ML042380298
Person / Time
Site:	Browns Ferry
Issue date:	12/01/2003
From:	Ogle C NRC/RGN-II
To:	Wiseman G NRC/RGN-II
References
FOIA/PA-2004-0277
Download: ML042380298 (12)

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ragel I I u -1 From: Charles R. Ogle /le7 To: Wiseman, Gerald Date: 12/1/03 3:41PM

Subject:

MY REVIEW OF YOUR BF INPUT Gerry, attached is a document that compares what you submitted to what we put out in the Brown's Ferry report.

Comments:

1) Please try to use inspectors as opposed to team.

2) In regards to your proposed URI: In general, I'd like to process Issues as they come up as opposed to generating additional URIs. In addition, I found the description section of your submittal to be lacking.

Please refer to what was put out in the final report. I believe the final version better describes the finding.

Also, I don't think that your enforcement section really describes what the enforcement Issue was. In general, I think that the writeup for a URI should be more complete. If all we are waiting on is the SDP, everything else should be described as If the final violation was being Issued.

3) It wasn't really clear from the writeup on the URI what work was required on our part. Try to be more specific-determine regulatory significance, complete the SDP, whatever we are working on.

Overall, I thought this was a fully successful writeup. Please see me If you have any questions.

Thanks.

ID

A. -fofPEe1FEN- REPERF INPUT

11. REAO -GRSAFET-

- ornerstones: Initiating Events, Mitigating Systems NONE

.02 Fire Protection of Safe Shutdown fSSB)Capabilit-

a. Inspection Scone-For the selected fire areas, the eisam evaluated the frequency of fires or the potential for fires, the combustible fire load characteristics and potential fire severity, the separation of systems necessary to achieve SSD, and the separation of electrical components and circuits to ensure that at least one SSD path was free of fire damage.

The pc e also reviewed the Fire Hazards Analysis (FHA) to verify the fire loading used by the licensee to determine the i eps~ iveffresve rating of the fire protection barriers and features. The h sppcqtoy.team also inspected the fire protection barriers and features to confirm they were installed Inaccordance with the codes of record to satisfy the applicable separation and design requirements of 10 CFR 50, Appendix R, Section lll.G, and commitments to WT~EB 92.5-1. _Th

~sptrs~a~.Te~r~iel ~s~i~r (D~) heri~a and FM1.terial En~gineering Branehi (GMEB) 9.5-1. The team reviewed the following documents, which established the controls and practices to prevent fires and to control the storage of permanent and transient combustible materials and ignition sources, to verify that the objectives established by the NRC-approved Fire Protection.Program FPP) were satisfiedsz

• Fire Protection Report (FPR) Volume 1, Fire Protection Plan

• 111ire Prateetion Repo Volume 2, Section l-D, Smoking Restrictions

• TVAN Standard Programs and Processes Procedure SPP-10.10, Control of Transient Combustibles

• TVAN Standard Programs and Processes Procedure SPP-1 0.11, Control of Ignition Sources (Hot Work)

Electrical Preventive Instruction EPI-0-000-MCCO01, Maintenance and Inspection of 480 ,Neft AC and 15 5 DC Motor Control Centers The Ipoectrdseam toured the selected-plant fire areas to observe whether the licensee had properly evaluated in-situ combustible fire loads and limited transient fire hazards In a manner consistent with the fire prevention and combustible hazards control procedures. -In addition, the inse em reviewed selected weekly fire safety inspection reports and fire brigade response and emergency/incident reports for 2002 and 20037 to assess the effectiveness of the fire prevention program.

The fire brigade is a dedicated group which Is independent of the control room staff.

The kI petorstem reviewed fire brigade response, fire brigade qualification training, and drill program procedures; fire brigade drill critiques; and drill records for the brigade shifts from January 2001 to- May 2003. The reviews were performed to determine

whether fire brigade drills had been conducted in high fire risk plant areas and whether fire brigade personnel qualifications, drill response, and performance met the requirements of the licensee's approved FPP.

The inspectorsteam performed walked dw-downs-of the fire brigade house and e~xa minedthe response vehicle to assess the condition of fire fighting and smoke control equipment. Fire brigade personal protective equipment was xamiridrmvewed to evaluate equipment accessibility and functionality. Additionally, the 'nspetoqrsteam observed whether emergency exit lighting was provided for personnel evacuation pathways to the outside exits as identified in the National Fire Protection Association (NFPA) 101, Life Safety Code, and-the Occupational Safety and Health Administration (OSHA) Part 1910, Occupational Safety and Health Standards. This review also included examination of whether backup emergency lighting was provided for access pathways to and within the fire brigade house and equipment storage areas in support of fire brigade operations should power fail during a fire emerency. The fire brigade self-contained breathing apparatuses fPeBAsM were pvaiu'tedreviewed for adequacy as well as the availability, aP. tref[L capablity', of supplemental breathing air tanks-and-their ea ty.

The p' rm reviewed fire fighting pre-fire plans for the selected`jfi~j`areas to determine if appropriate Information was provided to fire brigade members and plant operators to facilitate suppression of a fire that could impeet GOD. Team members also walked down the selected fire areas to compare the associated pre-fire plans and drawings with as-built plant conditions. This was done to verify that fire fighting pre-fire plans and drawings were consistent with the fire protection features and potential fire conditions described in the plant FHA.-

The in o9 a-ydteam-reie. flow F * ;wgdiagrams and engineering calculations associated with the IA and iD battery rOmW' heating, yventatloan, and air~conditioning (HVAC) systems-fthpe eiRorps Ths review was doneto verlfy that sjyjstes uQse'd oace tQi plant in a SSP congil d not beimpaired b W Nryjpor~fW^ starte":as resuzlt facompush SED would not be inhibited by a fire in the battery rooms usd-yb drogen gas buildup jfrnue oe~erbt ventilation itse Oes)supply and exhaust fans. The jspeto6rsteam also reviewed the annunciator response procedure for loss of ventilation In the battery rooms to ,re, that actions were specified iha, udi e~ enesure-tht drogeqTn, gas concentrations generated by the station batteries Wiould be ralitainedremalned below explosive limits. flie components "

nadnt lncl'udedin tXis reviet iphent Tinspetors The team reviewed the licensee's methodology for meeting the requirements of 10 CFR 50.48, and the bases ,for the NRC's acceptance of this methodology as documented In NRC safety evaluation reports. In addition, the

ns~p'ectoream reviewed _pptllcense documentation, such as the YPFSARiSI fy analysis report, submittals made to the NRC by the licensee in support of the NRC's review of their Op",fre protection program, and deviations from NRC regulations to verify that the licensee met license commitments. Additionally, design control procedures were reviewed to verify that plant changes were adequately reviewed for the potential Impact on the FPP, SSD equipment, and procedures as required by "he Browns Ferry Units 2 and Unift3 6Gperating ILcicense 0ondit7on.sdo t -.0.4. The Inspectors reviewed tI_.criterla In planteesee procedures SPP-7.1, On Line Work Management, and SPP-9.3, Plant Modifications and Engineering Change Control, to Ierine Iflfthet risk significant plant modifications; were developed, reviewed, and approved per the procedure requirements.

b. Findings No findings of significance were identified.-

-1

,Fi,';

..F' Communicationsirnemece H .n

a. Inspection Scope Te IriSp~ect~r^Stamr rewvewed thes designl and operatiuon o, and examined~s the manufacturers data sheets for the direct current (DC) self contatned, battery powered emergency lighting units (ELUs) required to support plant personnel in the performance of RV funetiorns to verify it was adoquate to support the performanee of manus! aetions required to achieve and maintain GOD conditions, and for illuminating access and egress routes to the areas where man-ul acuuosl are roquire. The team cheII ifG9 these battery power supplies were rated with at least an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> capacity as required by Seetion Hll.J of Appendix Rl. During plant walk downs of selected areas where operators.

performed lucal manual actions, the teamn inspected area ELUs for operability and checked the aiming of lamp heads to determine if sufficient illumination was available to adequately illuminate the 63D equipment, the equipment identification tags, and the access and egress routes thereto, so that operators would be able to perform the ections without needing to use flashlights. The team also reviewed completed sur.eianee and maintenarce proeedures and test records to ensure that the licensee properly maintained the lighting.

No firdings of signifieree were identified.

.Uv GEvrrnmunlelativonsltr clr rmaee et l6 ICHGvapaiJ lsy

a. insiection Ceon -

The team reviewed plant communication capabilities to evaluate the availability of the communication systems to support plant personnel In the performance of manual operator actions for shutdown, fire event notification, and fire brigade fire fighting duties.

The ihns petorseam reviewed the licensee's communications systems' separation analysis to verify -that site portable radios; and sound-powered phone systems were designed, perwensleentwith the licensing basis and would be available during fire response activities. The pectprsteam also reviewed the fire brigade drill critiques to assess proper operation and effectiveness of the fire brigade command post radio communications-dtgfire dIs. In addition, the iJnspo.tjorsteem reviewed the fire brigade radio communications systems to assess whether the liaenseels-radio channel features would continue to operate Reshoud the radio repeaters for the primary communications system pppii1eb unavailable.-

b. Findinas-No findings of significance were identified.-

.079 ErnearnedFci _,

e ALiahtin neA Peetrational

a. Inspection Scope The inpecor 'ie'he noti , andmanufacturter's data sheets for th

~iirptcutSr.r~e~n~t,(DCs~elfco~ntained battery powered emnergency lihting <urits (ELUs).^

The inspetorsev~aluted thecapability of the ELUs to suppor plant rnne i th erorrnanoef SSP ritis. inclUdingOJal ma l oTionsad forn, jiumr!intirg #aoces and'egr s routes to the'ie-atwhere those mahual actions w9uld peOrm

~it at]latnShsi MP ~~rqle i VntP1.n o101. CFR-50 A0prendik f3j- 6 Aeuring^.irspect~orwlk downs ,o~f theptarnt #re~a~s ,he,,,oerat.,ors pei f~oned loogl. ~aga!

Actioris, ~he. if..sp~eotors nsp-Pted AA A Es for rpefr oe ioqianr checkeddthe

~go Amp heads. to,,deerrjminj f~fi~ lmn~ati wol be avallable to

~dqutey llmipt te SS quipmet`~h bq~4iiiti Wid~niiatior-tags,-ar. -the~

at cc'sswA arid kegr~es.3suIs .tt eret~ow rsotlastopteratprs9!oud SepIr, bl.tpo,.,orm,.The wthd iIg ,p o,e , ,s~, 'iii'T h pgnd.qdi aMstenam reiewd the selected fire areas to evaluate the adequacy of the fire resistance of fire area barrier eerclosure walls, ceilings, floors, fire barrier meehaneial and eleetridl! penetration seals-,

fire doers, and fire dampers to ensure that at least one train of SSD equipment would be intained free of fire damage. The team selected several fire barrer features for detailed evaluatin an Anpcien to verify proper installation and qualification. The.

team walked down the selected fire areas to observe the material condition and ccnfiguration of the Installed fire barrier features, as well as, reviewed ceonstruction details and supporting fire endurance tests ICr the installed fire barrier features tC verfly the as built cenfigurations were qualified by appropriate fire endurance tests. The team also reviewed the Fl IAto verify the fire loading used by the Iicernsee to determine the fire resistance rating of the fire barrier enclcsures. The team also cmpared the penetration sea! ratings with the ratings of the barrier enclosures in which they were installed. The team reviewed the installation instructions for fire deers, the design details for mechanial and eleetrieal penetrations, the penetration seal database, Generie Letter 66 10 evaluations, and the fire protection penetration seal deviation analysis for the

teehnical basis of fire barrier penetration seals to verify that the fire barrier installatios met design requirements and license commitments. In addition, the team reviewed completed surveillance and maintenance procedures 'ana t'st records to ensure that the 1icere pro'perly m'iptln ' lighting setd

`qu-pmeeter fire barrier features to verify the fire barriers were being adequately maintained.

The team reviewed abno~rmal operating fire procedures, selected fire fighting pre plan~s, fRe damper lIcation and detail drawings, and heatin~g ventilation and air conditioning system drawings to verify that eccess to shutdown equipment and selected operator manual actions would not be inhibited by smoke migration from one area to adjacent plant areas used to GoeemplishlD .

b. Findings No findings of significance were identified.

.10 Fire Protection Systems. Features. and Equipment

a. Inspection Scone-The Inspectorsnm reviewed flow diagrams, cable routing information, operational valve lineup procedures, and system availability studies, associated with the fire pumps and fire protection water supply system. The L "pctorSreview evaluated whether the common fire protection water delivery and supply components toidetemineif they' could be damaged or Inhibited by fire-induced failures of electrical power supplies or control circuits. Using operating and test procedures, the e§p m toured the electric motor-driven fire pumps and diesel-driven fire pump to observe the system material condition, consistency of as-built configurations with engineering drawings and determine correct system controls and valve lineups. Additionally, the ijpectrq§team reviewed periodic test procedures for the fire pumps to assess whether the surveillance test program was sufficient to verify proper operation of the fire protection water supply rsystem in accordance with the system operating requirements specified in Sections 9.Q bn,989.4 of the FPR.

The O r ' reviewed the adequacy of the design, installation, and operation of the- automatic detection and alarm system for the selected fire areas to actuate in the early stage of a fire. This was accomplished by reviewing engineering drawings for fire detector types, spacing, locations, the licensee's technical evaluation of the detector locations and the ceiling reinforcing plans and beam schedule drawings to determine the location of ceiling bays. After the ceiling bay locations were identified, the lpspe6ctbrsteam conducted field tours of the accessible portions of the fire detection systems in uire Aereas 9 and 13 to confirm that detector locations were consistent with the licensee's engineering drawings, FHA, engineering evaluations, and each bay was protected by a fire detector in accordance with the C6ode of tRecord requirements -

NFPA 72E, 1990. -In addition, the Inspeqtorsteam reviewed surveillance procedures and the detection system operating requirements specified in Sections 9.3; aond 93f94 of the FPR to determine the adequacy of fire detection component testing and to ensure that the detection systems could function when needed.

The i spector eam reviewed the adequacy of the design and installation of the automatic pre-action sprinkler system and water curtains surrounding unsealed vertical o1penings and the stairwells of the Unit 3 rReactor building OElevation 621 ft.62-V (Fire breadeft 3-4). The Inspector team pcrftrmed in plant walked -d ow-dwnd of the system to evaluate proper type, placement, spacing of the sprinkler heads, and the extent of the sprinkler head obstructions for effectiveness to prevent a fire from spreading to adjacent fire zones. In addition, the Injspectorsteam examined the sprinkler system hydraulic design calculations to verify that the system could be supplied at sufficient pressure and flow volume to produce the required water density for the protected area. Selected engineering evaluations for NFPA code deviations were reviewed and compared with the physical configuration of the system. Additionally, the nspectorsteam reviewed the physical configuration of electrical raceways and SSDsafe Shutdown components In the selected fire areas to determine whether water from a pipe rupture, actuation of the automatic suppression system, or manual fire suppression activities Inthis area could cause damage that could inhibit the plant's ability to reach a SSD conditio.

The jinpextorasem reviewed the manual suppression standpipe and fire hose system to verify adequate design, installation, and operation In the selected fire areas. The fspec~to~rstam examined design flow calculations and flow measurement/pressure test data to verify that the required fire hose water flow for each protected area was available. The jnspectorstea performed in-plant walk-downs and observed placement of the fire hoses and extinguishers to confirm consistency with the fire fighting pre-plan drawings. Additionally, -the sp m checked a sample of manual fire hose lengths to determine whether they would reach the SSD equipment in the selected fire areas. This was done to ensure that manual fire fighting efforts could be accomplished in the selected areas.

b. Findings No findings of significance were identified.

.11 Compensatory Measures-

a. Inspection Scone The InspetQrsteam reviewed the administrative controls for out-of-service, degraded, and/or inoperable- fire protection features, ventilation systems, and post-fire SSD systems and components. The review was performed to verify that the risk associated with removing fire protection and/or post-fire systems or components from serylce

,wrewas properly assessed and adequate compensatory measures were implemented in accordance with the licensees technical specifications (TSI and the approved _FPPfite prite.tkon program. The [nsp,,ctrstem also reviewed the adequacy of shoqt.errr ora tem compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.

b. Findings

==

Introduction:==

KG n reejinon-ited vio'latio'fni(NC. unresolved item was identified Into doeument the inspectors' observations that the licensee IadreeeOtly-made-two changes to the approved FPP'whic'h decreased th,,dfe eetive# ssftpro gra withot prior om~mission appro.-- T.he licensee Ina'ppropriately ud the License Cofldition Impact Fvaluation (LCiE) chapnqe process to revise the6FPP to.allow the removal of fire upr'ession systesandrfire rated barrier ass blies, ecsa t 'isyt spa~raon and supps.sion requi-remean~ts of 10 CF .50, Appendix Re,ctions 'II.G.2 I 8IIGfrpm servce w.,ithout compensatory m ee f ei.e fire watoliesi being Implemiented.

Describtion: t'happrpved Browns Ferr- FPP is 0m'e'nted OntheRFPR d torpor'atted intoettI!F AR by referenc?1. Ih' p~qtor protecticn program and had not evaluated these changes against a liiense condition which states in part that changes to the approved fire protection prcgram are allowed without prior approvalvf the Cormmissior. only if these charnges would not adversely affect the ability to ai and maintain safe shutdown in the event of a fire.

Deserption, The team reviewed the operating requirements of selected fire protection features specified in Sections 9.8 and, A.4 of the FPfiPS% SPP-10.9-Control of Fire Protection ImpairmentsJ andfp the licensee's Fire Protection Impairment pro16rar

{FPIP) fReport p Iog_dated September 29, 2003. During threview of the FPPrepo I the Le found that the licensee had removed the following fire protection features from service:-

• Ithe pre-action-sprIfer fire suppression'-n systems for the Unit 2 and 3.

high pressure core injection (IHIPGF)-areas (FPIP No.03-287),

• psene~rsiop seasPeiset e in a fire barrier wall separating the Unit I reactor building from fireaea +6-the control building (FPIP No.03-303):

The e e noted that the licensee had removed these fire protection features from service without compensatory ri.ie. ,' t ire w watches being posted in the affected plant areasi. Up"o n `nestigation tFhe inepctors eminedrte that the licensee had changed the ' ifequir-rreinfor Wrpplenmentjn'gfire przte#tion program with respect to compensatory measures tiwder h':rb h. F. r;. .,.F P .q -... .1- PA.Ing, 1 i .pf' P .~fft rerit rtint

• 'Ict'-fires v and fapidsusi firs th'at oc to -lii damage;'

DUesignplat' 'afety systems so that #-fire which sta ts" nispit e of thefire efforts and burns for'g sgnifilcant penid of tirne in spite of fire 6reventipn

~uppressio 9tivyitieS wf I not.pr nteiaI t sfetyfunctosifrom ing pertorrnmd..

efeseienMdepth ao elsset 7 ave eVentscanoelo'fset by enhancing the other 'elements. ~Fire atchse are th oscm n industry -

worpeznsato-ry measve;ued to help preyent fies- Fire watc-s str g h hen tle fire

pre ion DtD element. by lookin for tnciotrolled`i6gnition soures, f ha , and combustibl-e materials, and by providin prompt potificatiog of such haards. !n addition, fire watches-can strengthe -the-fire detection DID eleent because

-pp they are 'eith'er contin'uously present within'orr'eguArl ' r fie In thiIssu cas'e, the:fire Watch wou-d notif y th'e main contrQol.ro tocall-out-the firebriade, g the,,firebrigade exactjinformation about the locatio ,ad nature ,of the fire, a d may Initiate fire suppression activities if trained to co so,

.tr , o .~ .,,

Aqn'ggjip The Inspectos reviewed the'lice~nsee's LIE sced wjth ReVision 20 of the :PR.

hls,.L.CIE e'vaIu~ate,,d.cha'ng'e's to he FPR- that .rem fire watches:as a compns frieasuire 'fior'im'pairments' ofthe wvater-s~pray,, wa~tqr.sprinkler, or' gaseous 00, li're

,suppression ,sy~stemns an~d/or,,fire rated assemblies (.e.e- fire ba, rrjeres}. IPrio~r-,t~othi~s change, -'theBrow! s Ferry NR0-approv?1 'F.PP. re'qu~iredthe prograhad previously required the licensee to pest either a continuous or one hour compensatory fire watch patrols with b8ac1up upp1resic Cquiplment whenever arequired fire Asuppression systemn fire rated barri"er assemby*as inoperable, bd/or either a f o~ninuous or, aone-hou.r; comp:enpsa-tory ,fijre, watc ,tpatvr~o (with backu sup-p,,s;rvessiop ,-=;

'e'quip'meht) be statiofned. ,;The' LOE c~oncluded that tthe assignmrepnt and p'resene,ceqof~fjre t eqimetpo~dd~iipaladti POc h persoanel.fo rpurpbseofd.et"9tir g and r'ng fires' wthk peble ~ firc dete ctioin, surnnecessary.a,,nd,poIdb 'xira a.ditonal fira pr ,otectio,,n wq~re>ras Faf emn',argins.'The 4 e ation a stated iso tha,with the detetion sytem utio tg' i' ad tmhe altersate suppreessionequipen t aalablehe ,response wascomparable with t-he firewthin,,place anrl dthat the ability ,to ,,afel shut d~o.w, the, plant wa'srnot advWersej ff~ected. .,Th~e err , inspectors t~:e'_

Z supp.- ,oted,

=xX *e-,v? s C however,O'wn that w.1-.icesees the tr~r -lD--

-- =

z . i, changPevaluatn

-. did not ovid'ea technical basis forthese copclusio`s-.dBasedop thisF lutio,,he ,li ensee' is~e,,d, 'the Y ,luei Sections 9.1 s -FnPF3; ii m anr 9.3J1 .a.3, *'delete insperable,' and the licensee had chanqed it to remove the requirements for fire'.watches in operable fr rtgt bilktij&

afhie anspectors d ed that the iefire ptectiond ei6 y rm .cha~nge proe~s,,sio .rvevise the FPonu 0oper-23, 002,topeermt ,rem ovin, fir, pupp'ress~ionss.twn. erabis, ib -n, ,<e~aitzedarrier ,a,,,,sernbIf ,1,fromservice .wixthopt;e~n.hanci~ng POF Ve ot,'her,DID eemets sacie wtchsas compensatory measureL@p'e,,iiig,1l<y.f~e,

,evI5 allowed degraded owr inpe, radul qcIFPP t fire suppression syst~e~ms- a~n~d hee~,fire hare~rs ncessarto'stitsIy

rr"Aq5 ros..o, o-. .~perr r, tplser

-qym:: ,O',

e-.j-t s~^~tand esuppression rato i < -¢i;>4lvs^

jeq'i~rements':o,,fl F iO,.A~p~pe~ndix~iR,3 ectio,~nysl.G.ll-,2.ap'dII',, ,1v'ihXut additicrl, the teraml rvctd tatl at Drcwns wl Ferr, rIIpenlsatcr fir wratchI du-tesO corVssts of detee-tintand reportnq fires Of ign of fire.Thcompensatorv fire watches qthe5 gftected plant 0areas opng" fe dete gWtOiojs t eje gnct!ppal., Te ,hagese IIt LlraWIirTeV ssigned thUdriutiestivnspc fcr TVI trWlcfIV T f1re hTards, Ugntlc scTI urces or combustible materials introduced in the assigned fire watch area. The team found rles I cf tje appIOU d rIr ad nct Ftad epicitly-dtrmi whte thIG cangei would adversey affected the ability to achieve and maintain safe shutown in the event of a firetI at, the,.t~nseed etnt fronsfull compencwth f in the affected ereas.

The NREC previously identified an issue at the Sequoyah Nuclear Power Plant (Unresolved Item (URI) 5e327,32JOp-004-A01) re~Pa,,dwinM t#he acc1ptPb-MlW1it of Qimilar changes to the approved fire protection gafe shI tdprb, s tem -ys ,msepar ation-'nd

§upprepsslo! criteria to0 .less tlhan full ciompiance without Irnlernenting temporary easures toompensate for ,eakness inthis DPelement- .This was contrary to the safety objectives- ofthe .FpP., and constituted ,acha ' fromthe -approved programthat requi~red NCappro~va! priorto implemetation . Ho wever, no NRC approval, as pbtained bythe, licensee.

'n'l'si~s: Beauessue~s r~elated to the fire protectin change process':are consider.ed to b'e -findings,`that -pOote tiallyycoudl-d impede' r mpathe 'e ulry procs te re RIO usinte traditiorial enforcementrssstead of the SDP. in this 6.6,ee issue wassigniicant because the llcensee'..change process for the fi0re jrotection p.roram allowedadecrease Tn theeffectiveness of the fire protection program to be acepted'w ithout prior NRC approva. Wrthermoreth iaa edible; imp'act'l safetybecause theIicenseesfailure toproperly e u t remval of fire Watch posting 'requi reents cbuldadversely affect or degrade the abiliy for achieving' An4 maintaining -SSD fro the r main control ro local shutdown stations, or it~e~rnatne shutdoWstations. However,' theinspectors determined that this findinqgyws 0vey,low significance because, based on an assessment of the impacts of-fte Identified fire proeton features removd frservIce, te l.;icense's ovrl iS inqapabilitips thidanected 'fire;,areas; ard ,relat.ed, Fs fenturs (frebrigaeerned i~dequate t'ciey~and miabitain--SS~Pcorditions2 p!nq8as inPart6, thyt ,`-li-era nJiear lpIow'i mfust have,,a fife p-ro~tecin pr~grarn~Browns Frry Unit 2 Opearting License Co'ndition~

arid'6BownsFerry Unit 3rOperating Lienseoditiori 2,.C7)'state, inpar, a g.,(1 4)-a'1aei 1rowns Ferry Nuclar piant_"mray make cha'riges to appoved FPP withduitprior prpl of the :ormissio only if hs changeswudlaffettebil@

pr jnp-rl thiefeantalvent

, of ',iir F6rtrairy fto ;the above, Xhe; lisee lscarnqed the ES Fry, FP~o remove; the -,, -;

to:pirermewnt ire

,equlremernq"hA§1'pardife ,potection sysems and eatuires Wvhich w e 'r~sm rt a comppenatorv pea~sure necpessary to assuie Fhe abit 6ahlei w'ndmita~in ae htdonln'ii eet-of',li~re.-

j This vlo'la~tiopn ImPacte~d the, NR's a~bihity .t'perf~ormr~ its regulatorf un~lcti'on and; as .such, vWas~

auated ln jnccar nrfewithh d oV.A4d Secton IVB6fB.o.the NlRO'&s'-Ei~orcernient Policy . .Based &n thi',q@uidance', this".violation of .10 C:FR wach-&^

s048ad iit2 rd ni OVertig Llc}nseO~dti.o~ist Is.cas~ e s~ a~vert Le~vel fIV violRationpbe a u~se itresu~ted-i;n. conditions thtw~e~re, ..valu'ated as.,havjpgeS rsvvvvy0r l.00VglWtU! A-~lIIS A 'd "Wi&j

-Aralyaie: The risk significance of these bse V atirns has n.t yet been evaluated.

_nt lr rs _, _ e i edPER 03-01 8593-000), i this'Volation .

beingrtasn N;Cinaccrne Sectn, o tphe

,withN C', frcm P.olicy: !{CV.Q05Q0002,6Q,?29,6./-20030702, b&e n erhrve zfrn03013 00 .hc .rck the i-su a __-*&t Zeua F l

• r rowe -- nt redn &ddit* "a r_..e t e-.p dRC, 't IV"m-Ufl_ 50 2G0,20G1 03 -

CXX, flview of Caluations for Changes Made to the-Approed Fire Protection Program Regarding Compensatory Fire Watch Implementation Without NR . C anh Duties. Approval.

4. OTHER ACTIVl71ES 40A2 Identification and Resolution of Problems

a. Inspection Scope the insor retive action program (CAP) problem evaluation reports (PERs) resulting from fire moke, sparks, arcing, and equipment overheating incidents for the last 10 months were reviewed to assess the frequency of fire incidents and to identify any maintenanceer material condition problems-related to fire incidents. The team also reviewed other GAP documents, irnludin~g eerpleted eerrestive actiona doeumented-irt selected PERs, and operating experience program (OEP) dournents to verify that industry-identified fire protection problems potentially or actually affecting Browne Ferry wer e appropriately emtered irte amd resolved by the GAP process. Iterns ineluded in1 the OE_effetie . rview OF. were NR_ i__ rmati.n NotXies, industry or vendor generated reports of defects and noencrmplianee under 10 GFfl Part 21, and vendor informatien letters. The Umit 2 and 3 fire pretection syternms health reports for the ta tcmrveed six quarters to evaluate the prioritization for resolving fire protection related deficiencies and the effectiveness of eorreetiveaeions. In addition, the teamr reviewed a sample of licensee i-rdjiiself-assessments -incUPERof the fire protection proqram to verify that items related to Fr Ferry FPb, -apdthec bl tUo.succesfuly ach'eve 0,a ntain~t~hep~ait~in aSSD condition~folj ingk aiirefire protection and to AND were appropriately entered into the licensee's CAP in accordance with the Browns Ferry quality assurance program and procedural requirements. The items selected were reviewed for classification and appropriateness of the corrective acions takenX or initiated~to resolve the issues.H.:lnaddition, -tteinspo ors reviewedthelicensees ivnitatdto rrve actio r selentc Ipd- te expr erssae the fr ltctoara T- olrtn ex3erienerprsiwere eiwdt Verifvhat Hefeedyidi-ts +d r-as~essrrent s o .theBonw~r FPPto asseiss ~type o t pindigs Ahat t -wefreqg'erntr frngsrlt ethat ti Incersen'esnh1.

b. Findings-No findings of significance were identified.

T~ .- - . - .I .,I. ... ,% - - _ _,

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MY REVIEW OF YOUR BF INPUT Creation Date: 12/1/03 3:41PM From: Charles R. Ogle Created By: CRO@nrc.gov Recipients Action Date & Time nrc.gov AT1_PO.ATLhPO Delivered 12/01/03 03:41PM GRW (Gerald Wiseman) Opened 12/02/03 07:26AM Post Office Delivered Route ATLPO.ATlhDO 12/01/03 03:41PM nrc.gov Files Size Date & Time Doc3.wpd 61274 12/01/03 03:26PM MESSAGE 1904 12/01/03 03:41PM Options Auto Delete: No Expiration Date: None Notify Recipients: Yes Priority: Standard Reply Requested: No Return Notification: None Concealed

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