ML20135G624

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Proposed Tech Specs Re Fire Protection
ML20135G624
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 07/20/1977
From:
CONNECTICUT YANKEE ATOMIC POWER CO.
To:
Shared Package
ML20135G608 List:
References
NUDOCS 8509190587
Download: ML20135G624 (4)
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i PROPOSED TECHNICAL SPECIFICATIONS.

RELATING TO

FIRE PROTECTION 3

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ADMINISTRATIVE CONTROLS AUDITS 6.5.2.8 Audits of facility activities shall be performed under the cognizance of the NRB. These audits shall encompass:

a. The conformance of facility operation to all provisions contained within the Technical Specifications and applicable license conditions at least once per year.
b. The performance, training and qualifications of the entire facility staff at least once per year.

c.

The results of all actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety at least once per six months, d.

The performance of all activities required by the Quality Assurance Program to meet the criteria of Appendix "B",10 CFR 50, at least once per two years.

e. The Facility Emergency Plan and implementing procedures at least once per two years.

f.

The Facility Security Plan and implementing procedures at least once per two years.

g.

Any other area of facility operation considered appropriate by the NRB or the Vice President-System Operations, h.

The Facility Fire Protection Program and implementing procedures at least once per two years.

i.

An inspection and audit of the Fire Protection and loss prevention program shall be performed annually by an outside firm experienced in fire protection and loss prevention.

AUTHORITY 6.5.2.9 The NRB shall report to and advise the Vice President-System Operations on those areas of responsibility spe:ified in Section 6.5.2.7 and 6.5.2.8. Meeting minutes may be used for this purpose.

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Attachment 2 Docket No. 50-213 JUSTIFICATION FOR DEPARTURES FROM SAMPLE TECHNICAL SPECIFICATIONS RELATING TO FIRE PROTECTION

(15) Fire Barrier Penetration Fire Seals All sections relating to penetration fire barriers have been deleted.

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Discussions with the Staff have indicated that the primary concern of the NRC is the integrity of these barriers following repairs or maintenance. Existing plant maintenance and quality assurance pro-cedures ensure integrity of these barriers following repairs or maintenance conducted in the vicinity of these barriers; therefore, Technical Specifications are not appropriate. Penetration fire barriers are passive design features of a significance which typically are not addressed in Technical Specifications in the form of limiting conditions for operation and surveillance requirements. In addition, it is not clear how the " local leakage tests" referenced in your letter would be performed.

(16) 6.5.2.8.1 The requirements of sections 6.5.2.8.j and 6.5.2.8.k were combined to reflect the intent of the requirements of your letter.

(17) Organizational Charts Figures 6.2-1 and 6.2-2 have not been modified to include the

, organizational arrangement for performance and monitoring of the Fire i

Protection Program. These- figures show title positions and line responsibilities of NNECO management and do not address job functions or responsibilities. Such infor=ation is available for Staff review l

in the form of administrative procedures.

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