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MONTHYEARML1102005092011-02-14014 February 2011 Y020100297 - Response to NEI on Concerns with Triennial Fire Protection Inspection Procedure Project stage: Other 2011-02-14
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Category:Letter
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February 14, 2011 Mr. John Butler Director, Engineering and Operations Support Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
Dear Mr. Butler:
In your letter dated December 17, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110050196), Nuclear Energy Institute (NEI) provided comments on the latest revision to the Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial). Provided with your letter were a series of specific concerns and recommended changes (ADAMS Accession No. ML110050200).
The NRC has reviewed your comments. You indicated that you believe the inspection guidance establishes a new regulatory position, and that the guidance needs to be revised. While the staff agrees that some of your proposed changes provide additional clarification, we do not believe that a regulatory position is being changed or established with Enclosure 3 of the inspection procedure. The enclosure provides additional guidance for NRC inspectors by providing examples of when changes to fire protection programs require NRC approval. These examples are to be taken in context of a plant with similar design features and may not be applicable to all situations. Inspectors consider the specifics of each plants design and licensing basis when conducting inspections. Therefore, the staff concluded that the inspection guidance can be used to support NRC inspections in its current form. The staff will consider revisions to Enclosure 3 of the procedure to clarify the language.
In addition, some of the recommendations provided in your letter are not consistent with the format and content of NRC inspection guidance documents. As part of the baseline inspection program, IP 71111.05T, Fire Protection (Triennial) supports monitoring all power reactor licensees at a defined level of effort to assure licensees performance meet the objectives for each cornerstone of safety under the Reactor Oversight Process. The triennial fire protection inspection supports the initiating events and mitigating systems cornerstones by performing a design-based, risk-informed inspection of the defense-in-depth elements of the fire protection equipment installed to mitigate the consequences of a fire, and by assessing the capability of equipment necessary for plant shutdown following a fire. IP 71111.05T describes the activities necessary to meet the objectives of the inspection. Inspectors are trained to inspect to the requirements of the regulations using the guidance provided in inspection procedures.
J. Butler Finally, you note in your letter that some of the references provided in the inspection procedure are not publicly available. For inspection activities associated with Title 10 of the Code of Federal Regulations Part 50.54(hh)(2), inspectors must review documents which contain sensitive unclassified nuclear safeguards information (SUNSI). In keeping with current NRC policies, SUNSI material is not publicly available. Since NRC inspectors reference these non-publically available documents in their inspection preparation, the applicable references are listed in the inspection guidance document.
The staff will consider enhancements or improvements to the guidance that provides additional clarity for NRC inspectors. Any changes based on the comments provided in your letter will be incorporated into the next revision of the inspection procedure which is currently planned to be issued and effective prior to July 1, 2011.
Thank you for your comments. Please contact Tim Kobetz at 301-415-1932 or Timothy.Kobetz@nrc.gov if you have additional questions.
Sincerely,
/RA/
Fredrick D. Brown, Director Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
ML110200509-memo ML110200476pkg OFFICE NRR/DIRS/ BC:NRR/DIRS/ BC:NRR/DRA/ DDD:NRR/DRA DD: NRR/DIRS IRIB IRIB AFPB Name JBowen TKobetz AKleinDMF for SWeerakkody FBrown SR for Date 01/26/11 01/26/11 2/8/11 2/8/11 2/14/11