ML20138H065

Safety Evaluation Denying Util 850812 Application to Amend Tech Specs to Permit Qualified Offsite Licensee Personnel or Independent Consultant to Perform Fire Protection Audit. Generic Ltr 82-21 Should Be Utilized

ML20138H065
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	10/21/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20138H029	List: ML20138H026 ML20138H065
References
GL-82-21, TAC-59489, NUDOCS 8510280219
Download: ML20138H065 (3)

Text

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v. g3 [g g UNITED STATES 3

/ o NUCLEAR REGULATORY COMMISSION n  :; WASHINGTON, D. C. 20555

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FACILITY OPERATING LICENSE NOS. DPR-61 AND DPR-65 .

PROVISIONAL OPERATING LICENSE NO. DPR-21 HADDAM NECK PLANT AND MILLSTONE UNITS 1 AND 2 i

- DOCKET NOS. 50-213, 50-245 and 50-336 1

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1.0 INTRODUCTION

0'n August 12, 1985. Connecticut Yankee Atomic Power Com any (CYAPCo) and

! Northeast Nuclear Energy Company (NNECo) (the Licensees submitted an j application fer amendment to the technical specifications for the Hadda.n j Neck Plant and Millstone Units 1 and 2. This application requested 1

changes to the specifications governing required plant audits to permit the annual fire protection and loss prevention inspection and audit to be performed by either qualified offsite licensee personnel or a qualified 1

outside independent consultant. The licensee stated that these proposed changes would clarify the uncertainty concerning the implementation of the current audit requirements.

2.0 EVALUATION

, Technical Specification 6.5.2.8.1 for the Haddam Neck Plant and 6.5.4.7.e for

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- Millstone Units 1 and 2 requires the annual audit of the licensee's, fire i

protection and loss prevention program shall be perfomed by an outside fim.

By letter from T. J. Martin to W. G. Counsil dated August 1, 1984, the NRC

transmitted two inspection reports which expressed concern that the relationship between the fire protection auditors and those being audited may not meet

the present requirements of the technical specifications for Haddam Neck l and Millstone Units 1 and 2.

, The licensee's annual audit is currently being perfomed by Northeast Utilities Service Company (NUSCO), which is part of Northeast Utilities (NU), which in turn,owespartofthelicensee's(ConnecticutYankeeAtomicPowerCompany's)

Haddar Neck Euclear Power Plant. The inspector indicated that NUSCO may not be

, qualified as an outside firm.

Generic Letter 82-21, dated October 6, 1982, from the Director, Division of i Licensing, to all licensees, specified that the annual audit, in accordance with the Standard Technical Specification (STS) 6.5.2.8.1, may be perfomed by qualified utility personnel who are not directly responsible for the site fire

, protection },rogram or an outside independent fire protection consultant, but the i three-year audit in accordance with STS 6.5.2.8.j must be performed by an L

! outside independent fire protection consultant. Haddam Neck Technical i Specifications do not include any requirement for the 3-year audit because j the licensee comitted to annual audits by an outside fim. Therefore, the 1 i

and 3 year audits were combined into one specification.

! .. 8510290219 851021 1 PDR ADOCM 05000213 l P PDR

An accepteble cpproach for the fire protection audits, as set forth in GL 82-21 is to have each audit performed by a qualified audit teer. The teem should include at least a lead auditor from the licensee's_0A .

organization, a systems engineer, and a fire protection engineer. The lead auditor sbculd be qualified per ANSI N45.2.23 as endorsed by Regulatory Guide 1.146. The systems engineer should be knowledgeable in safety systems, operating procedures, and emergency procedures. The fire protection engineer (or engineering consultant) should have the qualifications 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 protection procram for 2 of 3 years, but must be an outside independent fire protection consultant every third year.

The audit team approach will assure that the technical requirements as well as the QA requirements are adequetely audited. These audits would normally encompass an evaluation of existing-documents plus an inspection of fire protection system operability, and inspection of the integrity of fire barriers, and witnessing of procedures to verify that the fire protection program has been fully implemented and is adequate for the objects protected.

Insurance company inspectinns do not satisfy any of the Technical Specification audit reouirements because they do not evaluate plant fire protection programs against NRC requirements. Insurance company inspections do not reassess or re-evaluate the fire protection program, since the insurance company has already agreed to insure the licensee's program as it is being implemented.

Insurance company inspections are generally limited to checking systems and materials for proper condition and maintenance, and evaluating hazardous conditions related to property protection and life safety. However, if the insurance company develops an inspection that has the proper scope and the inspection team includes a person knowledgeable in nuclear safety, we have no objection to an insurance company perfonning these audits in conjunction with a lead auditor from the licensee's OA organization.

By letter dated August 30, 1984, Northeast l'tilities (NU) responded to the NRC by reiterating their position that the Generation Fire Protection Engineering Group within NU fulfilled the requirements of an "outside finn" and as such satisfied the lenguage and intent of the current technical specifications.

By letter dated August 12, 1985, NU submitted proposed revisions to the plant Technicel Specifications to clarify the fire protection auditing requirements.

These revisions reiterated NU practice at this time but did not address the corcerns identified by the inspection reports mentioned above.

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The staff and Fegion I personnel have reviewed the proposed technical specifications and discussed the auditing requirements with the licensees in a September 12, 1985 conference call. Based upon our discussions, we have concluded that NU has not adequately addressed the issue of

" independence" between the groups designing the fire protection systems and those performing the audits. Further the proposed charges do not clearly specify compliance with P!PC positions as stated in Generic Letter 82-21 that a group not associated with the utility should perform,the fire protection audits at least once every 3 years.

In a Senterber 4, 1985 letter from S. Ebneter to J. Opeka, Region I stated that the most recent audits would be accepted to satisfy the reoufrements of the technical specifications. However, as presented in the letter, the sta'f reiterated its concern of separation or independence between the desion and auditing groups, and stated that the utility should provide subrtentiation of the independence of the auditors to meet the requirerents of the current technical specifications and Generic Letter 82-21.

For the reasons stated above, we conclude that the proposed revisions to the technical specifications are not acceptable. We recommend that NU strerely consider use of the generic technical specifications attached to Generic Letter 82-21.

3.0 ACKNOWLEDGEMENTS Principal Contributors: F. Akstulewicz and B. Ferguson, CHEB.

Dated: October 21, 1985.

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