View source for B11702, Forwards Addl Info Supporting Proposed Rev to Tech Spec 6.5.2.8.i, Fire Protection & Loss Prevention Audits. Audits/Insps Will Continue to Be Performed by ANI & Credited Toward Satisfying Tech Spec 6.5.2.8.i

{{Adams
| number = ML20135G607
| issue date = 09/06/1985
| title = Forwards Addl Info Supporting Proposed Rev to Tech Spec 6.5.2.8.i, Fire Protection & Loss Prevention Audits. Audits/Insps Will Continue to Be Performed by ANI & Credited Toward Satisfying Tech Spec 6.5.2.8.i
| author name = Opeka J
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO.
| addressee name = Zwolinski J
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000213
| license number = 
| contact person = 
| document report number = B11702, NUDOCS 8509190545
| package number = ML20135G608
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 5
}}

=Text=
{{#Wiki_filter:f p _f CONNECTICUT YANKEE ATOMIC POWER COMPANY BERLIN, CONNECTICUT P o Box 270    HARTFORD. CONNECTICUT 06141 0270 TELE PHONE 2c u ss-sooo                                         September 6,1985 Docket No. 50-213 Bl1702 Director of Nuclear Reactor Regulation Attn: Mr. John A. Zwolinski, Chief Operating Reactors Branch #5 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

==References:==
(1)  3. F. Opeka letter to J. A. Zwolinski and E. J. Butcher, Jr.,
dated August 12,1985.
(2)  S. D. Ebneter letter to J. F. Opeka, dated August 20,1985.
Gentlemen:
Haddam Neck Plant AdditionalInformation Regarding the Proposed Revision to Technical Specifications Fire Protection and Loss Prevention Audits In response to the NRC Staff's request of September 4,1985, the Connecticut Yankee Atomic Power Company (CYAPCO) hereby provides additional background information to support our proposed revision to Technical Specification 6.5.2.8.i, " Fire Protection and Loss Prevention Audits." Enclosure 1 provides a chronological history of the development of Technical Specification 6.5.2.8.i to its present form. Portions of pertinent correspondence between the NRC and CYAPCO are included. Enclosure 2 is a copy of NRC Region i Inspection Report Number 50-213/85-16 which discusses the results of a recent unannounced inspection of the Fire Protection and Loss Prevention Program at the Haddam Neck Plant. Section 2./.1 of the report discusses CYAPCO's and Northeast Utilities Service Company's (NUSCO) prior agreement with the NRC Staff on the interpretation of Technical Specification 6.5.2.8.i.
It is CYAPCO's intention to continue to have audits / inspections performed by American Nuclear Insurers and to credit these audits / inspections towards the satisfaction of Technical Specification 6.5.2.8.i. In addition, the Generation Fire Protection Engineering (GFPE) group within NUSCO will perform independent audits and inspections utilizing qualified personnel. The nature of the GFPE group within Northeast Utilities, and in particular the organizational relationship and definition of responsibilities between it and the plants, qualifies GFPE as an outside firm in the context and intent of the present Technical Specifications.
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If you have any additional questions or would like to discuss this matter further, please contact my staf f.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY b    M J. F. O eke Senior Vice President Enclosures cc:                                    Dr. Thomas E. Murley Regional Administratcr Region i U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
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Docket No. 50-213 Enclosure i Haddam Neck Plant Development of Fire Protection and Loss Prevention Audits Techni cal Specification September,1985

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i l           DEVELOPMENT OF CYAPCO FIRE PROTECTION AUDIT TECHNICAL SPECIFICATION
: 1. NRC Letter, September 30.1976 The NRC requested Technical Specifications on Fire Protection Systems.
(No guidance or sample Technical Specifications were included.)
: 2. NRC Letter December 1,1976 l
l                 The NRC requested Technical Specifications on Fire Protection Systems, j                 (NRC sample Technical Specifications were included for guidance.)
NOTE: The NRC's sample Technical Specifications require three (3) inspection / audit functions:
(a)  The F:.:llity Fire Protection Program and implementing procedures at least once per 24 months.
(b)  An independent fire protection and loss prevention inspection and audit shall be performed annually utilizing either qualified off-site licensee personnel, or an outside fire protection firm.
(c)   An inspection and audit by an outside qualified fire consultant shall be performed at intervals no greater than three years.
: 3. CYAPCO Letter, February 25,1977 CYAPCO transmitted Fire Protection Technical Specifications as requested.
NOTER CYAPCO cornmitted to one of the three inspection / audit functions in the sample Technical Specifications.
(a)   The Facility Fire Protection Program and implementing procedures at least once per two years.
: 4. NRC Letter, June 17,1977 The NRC revised their sample Technical Specifications and requested CYAPCO to resubmit Technical Specifications to include changes in their sample Technical Specifications.
NOTE: This document again requests three (3) inspection / audit functions (items: 6.5.2.8.1, 6.5.2.8.), 6.5.2.8.k).
: 3. CYAPCO Letter,3uly 20,1977 This letter was responsive to the NRC's new request for Technical Specificatans.
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i In this submittal, CYAPCO deviated from the NRC's standard Technical Specification of three (3) inspection / audit requirements to two (2) requirements. In doing so, the resulting commitment was:
(a)   6.5.4.8.h   The Facility Fire Protection Program and implementing procedures at least once per two years.
(b)    6.5.4.8.1   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.
Inspection / audit item (b) was the result of a compromise solution to consolidate the NRC's two (2) remaining inspection audit requirements.
This consolidation was carefully worded to take full credit for inspections and audits already being performed by ANI (American Nuclear Insurers) and J&H (Johnson & Higgins). NUSCO/CYAPCO sacrificed the option of using in-house personnel for the yearly inspection / audit only because full credit was taken for inspection / audits already being performed, it should also be emphasized that by the exact wording used, NUSCO/CYAPCO deleted the NRC's specific requirement for a shree (3) year inspection / audit by "an outside qualified fire consultant." The letter stated that NRC Standard Technical Specifications 6.5.2.8.) and 6.5.2.8.k were combined to reflect the intent of the NRC requirements.
: 6. NRC Letter, November 25,1977 in this letter the NRC stated that they reviewed our Technical Specifications and that revisions were necessary. The NRC provided a draf t Safety Evaluation Report that did not object to CYAPCO's proposed Technical Specification for Section 6.5.2.8 submitted by {{letter dated|date=July 20, 1977|text=letter dated July 20,1977}}.
: 7. CYAPCO Letter, December 15,1977 CYAPCO was responsive to the NRC's request by revising other outstanding Technical Specification issues.
: 8. NRC Letter, February 6,1978 This NRC letter formally adopted CYAPCOS' Fire Protection Technical Specifications as Amendment 24 to the CYAPCO operating Ilcense. In doing so, the NRC accepted our interpretation of the inspection / audit requirements and frequencies.
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