RBG-45113, Clarifies Statement Contained in NRC SER for Licensing RBS, Per Error That Became Evident During Plant Fire Protection Functional Insp

Clarifies Statement Contained in NRC SER for Licensing RBS, Per Error That Became Evident During Plant Fire Protection Functional Insp

ML20212F964
Person / Time
Site:	River Bend
Issue date:	09/21/1999
From:	King R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0989 50-458-97-201, GL-77-02, RBF1-99-0254, RBG-45113, NUDOCS 9909290036
Download: ML20212F964 (3)

Text

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, rm Ent:rgy Operati:ns, Inc.

/ \ River Bend Station

• !, j 5485 U S. Highway 61

.e ~ P O. Box 220 .

t h St. Francisvdle, LA 70775 Tel 225 336 6225 4

Fax 225 635 5068 Rick J. King Daector ,

Nuclear Safety Assurance J September 21,1999 I

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

Subject:

River Bend Station Docket No. 50-458 Fire Protection Program Commitments for Fire Brigade Members File No.: G9.5 RBG-45113 RBF1-99-0254 Ladies and Gentlemen:

The purpose of this letter is to clarify a statement in the NRC's original Safety Evaluation Report (NUREG-0989) for licensing River Bend Station (RBS). The error became evident during the j RBS Fire Protection Functional Inspection (FPFI). The FPFI team identified an unresolved item  ;

associated with fire brigade membership. Specifically, the item discussed a concern with assignment of personnel to the fire brigade who have normal plant duties that could conflict with .

their response to a plant fire (50-458/97-201-04). Particularly, the five-member fire brigade team observed during the inspection included two members from Plant Security. I The FPFI Inspection Report (50-458/97-201) identified the concern as being in conflict with the NRC's original RBS Safety Evaluation Report (SER). The report stated that "the licensee committed to implement the NRC Supplemental guidance provided in GL 77-02, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance,"

dated August 29,1977." GL 77-02 contained the additional guidance indicating that the responsibilities of fire brigade members, under normal plant conditions, should not conflict with their responsibilities during a fire emergency. Section 9.5.1.3 of the NRC's original RBS SER stated the following:

By letter dated November 8,1983, the applicant committed to implement the requirements of Appendix R to 10 CFR 50, Section III.H (BTP CMEB 9.5-1.

Section C.3) concerning the fire brigade, and the fire protection prc, gram in the f staff supplemental guidance," Nuclear Plant Fire Protection Functional i

Responsibilities, Administrative Controls and Quality Assurance," dated August  ;

29,1977, including fire brigade training and fire fighting procedures.

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Fire Protection Program Commitments for Fire Brigade Members RBG-45113 -

RBF1-99-0254 September 21,1999 j

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.During the follow-up inspection to review the FPFI issues, EOI and the NRC inspectors further

. discussed the letter referenced in the SER and ' determined that the letter, in fact, contained no e such commitment to the referenced NRC generic letter (GL 77-02). The NRC closed the- r unresolved item in Inspection Report 50-458/98-16 based upon current compliance' with Appendix R to 10CFR50, Section III.H, for fire brigade membership, which includes members "

from Plant Security. The inspection reports noted, however, that EOI agreed to send a letter to the NRC to document and correct the error that was in the SER, as quoted above. NRC Inspection Report 50-458/98-16 was' issued December 29,1998. The clarifying history and

position are detailed below.

The history of this issue is that the licensing basis for the RBS fire protection program is ,

' Appendix A to NRC Branch Technical Position APCSB 9.5-1, dated August 23,1976, as

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modified by commitments made in accordance with Appendix R, as described in Section 9.5, j c Appendix 9A, and Appendix 9B of the RBS Updated Safety Analysis Report. The draft NRC '

SER' sections for Fire Protection were transmitted in a letter from the NRC to RBS (A.

Schwencer to W. J. Cahill), dated April 11,1983. In the NRC's letter, twelve open items were - j identified. Item IV dealt with fire brigade and fire brigade training. Specifically, the NRC  ;

requested a more detailed description of the plant fire brigade, including equipment and training, to verify compliance with guidelines in BTP CMEB 9.5-1, Item C.3. No other BTP CMEB 9.5-1 section was listed with the request, nor did the request include any additional fire brigade  !

L questions.

Subsequently, RBS responded to the April 1983 request for information in a letter from J. E.

. Booker to'A. Schwencer dated November 8,1983. The RBS response included selected pages from the RBS Safety Analysis Report, and stated that the RBS fire brigade program conformed wi,th items III.H and III.I of Appendix R to 10CFR50. As documented in Inspection Report 98- l 016, "[t]he team reviewed the licensee's current fire brigade staffing requirements in the ,

approved fire protection program and noted that the licensee complied with the requirements l l ' identified in 10CFR Part 50, Appendix R." These requirements are consistent with BTP CMEB 9.5-1, Section C.3, with regard to' establishing and training the fire brigade. '

! - No specific commitments are contained in this letter. If you have any questions, please contact Patricia Campbell at 225-381-4615.

Sin erely, x

K/PLC l

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Fire Protection Program Commitments for Fire Brigade Members RBO-45113 -

RBF1-99-0254 '

September _21,1999 '

Page 3 of 3-cc: U. S. Nuclear Regulatory Commission - -

Region IV 611 Ryan Plaza Drive, Suite 400 -

Arlington,TX 76011 NRC Senior Resident Inspector P. O. Box 1050 St. Francisville, LA 70775  !

1 Mr. Robert Fretz U.S. Nuclear Regulatory Mail Stop 4-D-3 Washington,DC 20555 l

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