ML20058F724
| ML20058F724 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/1982 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Olshinski J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8208020423 | |
| Download: ML20058F724 (6) | |
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Docket File July 26. 1982 Local PDR ORB Rdg TWambach HSmith MEMORANDUM FOR: John A. Olshinski, Director Division of Engineering and-Technical Programs, Region II FROM:
Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
A1. ITS OF LICENSEE FIRE PROTECTION PROGRAMS This is in response to your memorandum dated March 8,1982 regarding the fire protection audits required by all plants Technical Specifications.
These requirements are stated in items h, i, and j of Section 6.5.2.8 of the Standard Technical Specifications. By copy of this memoranduni we are informing the other four Regions and the Office of Inspections and Enforeament (OIE) of this guidance. We reco - d that OIE. consider the appropriate parts of this guidance for inclusion in the inspection module for fire protection inspections. We also suggest that each Region use whatever mechanism it deems appropriate for informing the licensees of this guidance. discusses the general scope of the three audits and the com-position and qualifications of the audit teams. Section 10.0 of Enclosure 2 provides additional information with regard to the 24-month audit. describes the elements that we recommend be included in the annual and triennial audits. We are also considering a chanje to the StandardJochnicalSpecificationswhichwillmaka clear that the scope of the annual and triennial audits are the same. A copy of the currently proposed wording is provided as Enclosure 4.
If you have questions regarding clarification of these guidelines, please contact Walter P. Hama, Chief, QAB for quality assurance matters or Victor Beneroya, Chief, CHEB for other fire protection matters. We consider that this memorandum completes TIA 82-08.
Original Signed By Darrell C. Eisenhut, % rector i
Division of Licensing Office of Nuclear Reactor Regulation 8208020423 820726 PDR MISC PDR omer >
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4 John A. 01shinsk Enclosure; As stated cc:
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. Crews Region V J. Taylor IE J. Partlow IE W. Johnson R. Wessman V,Bensv<ta W, //a a.s 7. W 'a 6 e t 4 i
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Enclozura
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General Scope of Fire Protection Audits and Composition and Qualifications of Auditors 4
24-Month Audit Item h'of Section 6.5.2.8.
j of Standard Technical Specifications l
The purpose of the 24-month audit of the fire protection program and imple-menting procedures required by item h is to assure that the requirements for design, procurement, fabrication, installation, testing, maintenance,.
p and adminsitrative controls for the respective programs continue to be j
included in the plant QA program for fire protection and meet.the criteria
~ of the QA/QC program dstablished by the licensee in accordance with BTP-CMEB-9.5.1.
These audits should be performed by personnel from the licen-see's QA orgainization who do not have direct responsibility for the program l
being audited. These audits would normally. encompass an evaluation of existing programmatic-documents to verify continued adherence to NRC require-i ments. Additional information is contained in Enclosure 2.
" Nuclear Plant j
Fire Protection Functional Responsibilities, Administrative Controls and j
Quality Assurance," August 29, 1977.
Annual and 3 year Audit's Items i and j of Section 6.5.2.8
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of Standard Technical Specifications The purpose of the audits required by items i and j of Section 6.5.2.8 is to assess the plant fire protection equipment and program implementation in depth to verify continued compliance with NRC requirements, the SAR com-mitments, and the license conditions. These audits include a more compre-i hensive evaluation of the fire protection program.
Elements that should
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be included in these audits are described in Enclosure 3.
These audits are basically the same; the difference lies in the source'of the auditor:(s).
The annual item i audits may be performed by qualified utility personnel l
who are not directly responsible for the site fire protection program or by an outside independent fire protection consultant. The three-year item j' audit must be performed by an outside independent fire protection consultant. These audits would normally encompass an evaluation of exist-ing documents (other than those addressed under item h) plus an inspec-I tion of fire protection system operability,'and inspection of the integrity l
of fire barriers, and witnessing of procedures to' verify that the fire pro-l tegtion program has been fully implemented and is adequate.for'the objects protected. Duplicate audits are' not required, i.e., the three-year item j l
audit replaces the annual item i audit the year it is performed.
l In our opinion, insurance company inspections do not satisfy anF of the Tech-nical Specification audit requirements because they do not evaluate plant l
fire protection programs against NRC requirements. ' Insurance company inspec-
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tions do not reassess or re-evaluate the fire protection program, since the.
insurancy company has already agreed to insure the licensee's program as it 4
is being implemented.
Insurance company inspections are generally limited to checking systems and materials for proper condition and maintenance: and i
evaluating hazardous conditions related to property protection and life safety, However, if the insurance company develops an inspection that has 1
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I the proper scope and the inspection team includes a person knowledgeable in.
nuclear safety, we have no objection to an insurance company performing these audits in confunction with a lead auditor from the licensee's QA i
orgainization.
Our recommended approach for the fire protection audits is to have each audit performed by a qualified audit team.
The team should include at least a i
lead auditor from the licensee's QA organization, a systems engineer, and a fire protection engineer. The lead auditor shouLlbe qualified per ANSI i
N45.2.23 as endorsed by Regulatory Guide 1.146.
The systems engineer should be knowledgeable in safety systems, operating procedures, and emergency pro-cedures. The fire protection engineer (or engineering consultant) should have the qualification's for membership in the Society of Fire Protection Engineers at the grade of member. The fire protection engineer can be a licensee employee who is not directly responsible for the site fire protec-tion program for two of three years, but must be an outside independent fire protection consultant every third year. This audit team approach will assure that the technical requirements as well as the QA requirements are adequately 1
audited.
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- c. Minimum Elements That Should Be Incorporated in 4
4 "7
' Annual. and Triennial Fire Protection Audits A.
Purpose - The purpose of these audits is to assess the plant fire protec-tion equipment and program implementation to verify that a level of safety consistent with NRC guidelines continues to be provided.
B.
Scope - Each audit should verify that the commitments of the SAR and that the req'uirements of the Technical Specifications and license conditions have been met and that modifications to systems and structures or changes i
in operating procedures have not decreased the level of safety in the plant.
The audit should include inspection of all plant areas for which fire pro-tection is pmvided and, in particular, examination of fire barriers, fire c-r detection systems, and fire extinguishing systems provi'de~d for sa.fety-related h;d..._..._. equipment.. The audi t'should verify that: :._,
1.
The installed fire pmtection systems and barriers are appropriate for the objects protected by comparing them to NRC guidelines or SER approved alternatives and noting any deviations.
2.
The fire loading in each fire area has not increased above that which was specifled in the SAR.
3.
Regularly scheduled maintenance is performed on plant fire pro-tection systems.
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Identified deficiencies have been promptly and adequately corrected.
.Speci_al_dpennit procedures (hot work,. valve. positioning) are. being 5.
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Plant personnel are receiving appropriate training in fire pre-l vention and fire fighting procedures and that the training pro-l gram is consistent with approved standards.
(The audit team should witness a typical training session.)
7.
Plant response to fire emergencies is adequate by analyzing inci-den t records and witnessing an unp.lanned.. fi..r.e.. drill.
8.
Administrative controls are limiting transient combustibles in safety-related areas.
9.
Problem areas identified in previous audits have been corrected.
The audit should analyze all problem areas identified by the audit and recommend appropriate fire protection measures to provide a level of j'
safety consistent with NRC guidelines.
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ADMINISTRATIVE CONTROLS
( 6. 5.2. 8) h.
The Fire Protection programatic controls including the implementing pro-cedures at least once per 24 months by qualified offsite licensee QA per-sonnel.
1.
The fire protection equipment and-program implementation at least annually utilizing either qualified offsite licensee fire protection engineer or an outside independent fire protection consultant.
fire protection consultant must be used every third year.An outside independent j.
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