ML051460532
| ML051460532 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/13/2004 |
| From: | Chyu D NRC/RGN-III |
| To: | Karjala D, Morris R NRC/RGN-III |
| References | |
| FOIA/PA-2004-0282 | |
| Download: ML051460532 (5) | |
Text
Duane Karjala - Re: Writeup that promised you as
_week
_e c J1z CL Pa e1 From:
To:
Date:
Subject:
Doris Chyu 2
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RMM3@nrc.gov., DAK2@nrc.gov, 5113104 5:19PM Re: Writeup that I promised you last week 5.-
3 and will be back at Point Beach on May 24th. Thanks again forja
£X.
Duane
>>> Doris Chyu 05/10104 07:34AM >>>
Any question, please give me a call. I am still reading your inspection report writeup. Who should I call if I have comments?
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Page 65, Appendix A to BTP, "The guidelines of the above cited BTP were adopter this appendix and are preferred in all instances." The philosophy of BTP in designing fire protection program is reflected on Page 18 of BTP, "A nuclear power plant must maintain its capability to combat a fire under any operating condition with fuel onsite."
Page 57 in Appendix A, Design Bases, "The overall fire protection......
and minimize radioactive releases to the environment." This is very clear and consistent with BTP that fire protection program is required under all modes of operation. A small portion of the fire protection program (Appendix R, Section 1I1) may not apply during shutdown since safe shutdown was achieved already. However, other portions of the program should be still in place.
Appendix A and Appendix R to 10 CFR 50 were sj1pnt on the modes of operations during which the fire protection program applies.l.
Appendix R, 3' paragraph, clearly defined what is"safety-related' vs "safe shutdown".
Section Ill.K.2, in defining administrative control for combustible control, stated, "prohibit the storage of combustibles in safety-related areas or establish designated storage areas with appropriate fire protection." Criterion 3 in Appendix A (one of the underlying requirement for fire protection as discussed in 50.48) discussed structure, systems, and components important to safety. The combustible control program should not be limited to "safe shutdown" areas but Include areas Important to safety and safety-related area.
Pages 69-70, "administrative control." of Appendix A to BTP discussed the bulk storage as transient combustibles, not something permanently installed. The perr nently installed equipment as part-of a system was later discussed on Page 81.(_.
The following areas were inspected by walkdowns:
Fire Zone 505, Unit I Containment, 8 foot; Fire Zone 511, Unit I Containment, 21 foot; Fire Zone 516, Unit I Containment, 48 foot; Fire Zone 520, Unit I Containment, 66 foot; Fire Zone 263, Primary Auxiliary Building Maintenance Area; and Fire Zone XXX, XXXXXXX.
Findins 5
15 1R06 Flood Protection Measures - External Floods (71111.06)
- a.
Inspection Scone
- b.
Findings No findings of significance were identified.
1 R11 Licensed Operator Requalification.(71 111.1 1)
- a.
Inspection Scope 6
M
§ 50.49 10 CFR Ch. I (1-1-03 Edition)
(ii) Identify the various positions within the licensee's organization that are responsible for the program; (iii) State the authorities that are delegated to each of these positions to implement those responsibilities; and (iv) Outline the plans for fire protec-tion, fire detection and suppression ca-pability, and limitation of fire damage.
l2) The plan must also describe spe-cific features necessary to implement the program described in paragraph (a)(1) of this section such as-(i) Administrative controls and per-sonnel requirements for fire prevention and manual fire suppression activities; (ii) Automatic and manually oper-ated fire detection and suppression sys-tems; and (iii) The means to limit fire damage to structures, systems, or components important to safety so that the capa-bility to shut down the plant safely is ensured.
(3) The licensee shall retain the fire protection plan and each change to the plan as a record until the Commission terminates the reactor license. The li-censee shall retain each superseded re-vision of the procedures for 3 years from the date it was superseded.
(b) Appendix R to this part estab-lishes fire protection features required to satisfy Criterion 3 of appendix A to this part with respect to certain ge-neric issues for nuclear power plants li-censed to operate before January 1, 1979.
(1) Except for the requirements of Sections II.G, III.J, and III.O, the pro-visions of Appendix R to this part do not apply to nuclear power plants li-censed to operate before January 1, 1979, to the extent that-(i) Fire protection features proposed or implemented by the licensee have been accepted by the NRC staff as sat-isfying the provisions of Appendix A to Th'Pnr->,
Technical Position (BTP)
APCSB 9.5-1 was published in August 1976.
(2) With respect to all other fire pro-tection features covered by Appendix R, all nuclear power plants licensed to operate before January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including spe-cifically the requirements of Sections III.G, I11.J, and III.O.
(c)-(e) [Reserved]
(f) Licensees that have submitted the certifications required under
§ 50.82(a)(1) shall maintain a fire protec-tion program to address the potential for fires that could cause the release 0]
spread of radioactive materials (i.e.
that could result in a radiological haz-ard).
(1) The objectives of the fire protec tion program are to-(i) Reasonably prevent these fire:
from occurring; (ii) Rapidly detect, control, and ex tinguish those fires that do occur ant that could result in a radiological haz ard; and (iii) Ensure that the risk of fire-in duced radiological hazards to the pub lie, environment and plant personnel i minimized.
(2) The licensee shall assess the fir protection program on a regular basih The licensee shall revise the plan as al propriate throughout the variou stages of facility decommissioning.
(3) The licensee may make changes t the fire protection program withor NRC approval if these changes do ntC reduce the effectiveness of fire protei tion for facilities, systems, and equi) ment that could result in a radiologic:
hazard, taking into account the decon missioning plant conditions and activ ties.
[65 FR 38190, June 20, 2000)
§ 50.49 Environmental qualification electric equipment important