ML18043B136
| ML18043B136 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/15/1979 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TASK-09-06, TASK-9-6, TASK-RR NUDOCS 7903140164 | |
| Download: ML18043B136 (10) | |
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Mr.* David Bfxel
- Nuclear l icensf ng Admfnf strator_
.~Consumers* Power Company
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- *Jackson, Michigan 49201 DISTRIBUTION Docket NRC PDR-*
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As a result of our review.of your Ju.ne 19 and September 29, 1978
. responses to th~ NRC fire protection guidelines on administrative
. controls, functional responsibfl ities, and quality assurance,.we -
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- find that the additional information identified in Enclosure 1 is.
required to continue our review..Enclosure 2 identifies staff positions on specific concerns 1ri these. matters.
To resolve our.
concerns we request that you either accept the staff positions or propose alternatives* or provide bases that satisfy the concerns.
Your submittals regarding minimum fire brigade size are still under
- review *. *..
- Please provide the additional information and your response.to the staff positions by February 28, 1979.
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Enclosures:
. 1 *. Request for Addit:fonal In format ion 2~ ~-Staff Positions*
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Dijnri1~ L. Ziemann, Chief
- Operating Reactors Branch *12 Q{vf s~~n of Operating Reactors
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Mr. David Bixel cc w/enclosures:
M. !. Miller, Esquire Isham, Lincoln & Beale
- Suite 4200 One First National Plaza Chicago, Illinois 60670
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Mr. Paul A. Perry, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Po\\'1er Cor:ipany 212 West Michigan Avenue Jackson, :lichigan 49201 Myron M. Cherry, Es qui re Suite 4501 One IBM Plaza Chicago, Illinois 60611 Kalamazoo Public Library 315 South Rose Street Kalaaazoo, Michigan 49006 Hunton & Williams George C. Freeman, Jr., Esquire P.. 0. Box 1535 Richmond, Virginia 23212 Peter W. Steketee, Esquire 505 Peoples Building Grand Rapids, Michigan 49503
-ch a r 1 e v o i x Pub l i c Li bra ry 107 Clinton Street Charlevoix, Michigan 49720 ENCLOSURE 1 Request for Additional Information Palis.ades Nuclear Generating Plant
- 1. Offsite Management Position Responsibilities Discuss the role, function and responsibilities of offsite management positions.
2 *. Fire Protection Engineer Qualifications Describe the means provided to document (i.e. fire protection plan) that the minimum eligibility requirements of a fire protectior.
engineer position, as outlines in reference (1), are met.
Example:
Fire Protection Plan 1.0 Organization 1.1 Administrative Organization 1.1.1 Fire Protection Engineer 1.1.1.1 Qualifications:
Graduate of ***.
Conpleted not less than ***
Three of which ***
- 3.
Handling, Use and Storage of Combustibles Discuss the administrative controls established to govern the handling of and limitation on the use of combustibles, flammable and explosive hazards such as flannnable gases and liquids, HEPA and charcoal filters, dry unused ion exchange resins or other combustible supplies* in safety related areas,.and to assure that these items are not stored in safety related areas.
- 4.
Flame-Retardant Wood Describe the manner in which all lumber and* wooden items in safety-related areas are verified to be pressure-treated fire retardant lumber or coated with a penetrating fire retardant that bas good abrasion resistance.
- 5.
Area Survey Inspection and Fire Watch Describe the means provided* to ensure* that the responsible foreman or supervisor will physically. survey the area where cutting, welding, grinding or open-flame ~ork is to be performed and establish that all criteria, as outlined in reference (1), are met.
Reference (1) - NRC Guidelines entitled "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance" 6 *. QA Audit of Fire Protection Program Identify the frequency at which quality assurance audits-are. performed to provide an overall assessment of conformance to fire protection program requirements.
ENCLOSURE 2 Staff Positions Palisades Nuclear Generating Plant
- 1.
Organization Position Description and Functions Staff Concern Consumers Power Company concludes that defining the authority and responsib.ility of each position relative to fire protection is -
- unnecessary.
Staff Position The organizational responsibilities and lines of communication pertaining to fire protection should be defined between the various positions through the use of organizational charts and-functional descriptions of each position's responsibilities as outlined in reference (1).
- 2.
Fire Briga~e Staff Concern Fires in critical areas of the plant may require the use of systems, components or auxiliaries normally not used for plant shutdo~"!l.
A Shift Supervisor who is not a member of the fire brigade, may be needed to direct the intergrated operation of these systems, components or auxiliaries during a fire.
Staff Position The Shift Supervisor should not be a member of the fire brigade.
His presence may be necessary elsewhere if a fire occurs in certain c~itical areas of the plant.
- 3.
Physical Examination for Fire Brigade Members Staff Concern A pre-employment physical is not sufficient to determine an individual's pulmonary and cardiovascular ability to perform the strenuous functions assigned *to members of the fire b~igad~.
Staff Posit ion All fire brigade members should be periodically screened for heart and respiratory disorders.
This program should be developed by a medical doctor and administered by a qualified member of the plant staff (e.g., a plant nurse or first aide supervisor).
Fire brigade members who fail this screening test should be given a physic~]
examination by a medical doctor to determine their physical qualifications for continued assignments as fire brigade members.
- 4.
Initial Classroom Instruction and Records Retention Staff Concern Consumers Power Company concludes that classroon instruction in plant layout familiarization is r.ot necessary for :he fire protection training program.
Sta:f Position Initial classroom instruction and records retention should include all criteria, as outlined in reference (1), for all fire brigade members.
- 5.
Practice Sessions Under Strenuous Conditions Staff Concern Training in the use of emergency breathing apparatus used under strenuous conditions is not conducted.
This practice may result in not maintai~ing adequate proficiency in fighting various types of complex fires.
Staff Position Practice sessions should be held for fire brigade members or. the proper method of fighting various types of fires that coufd o"ccur in a nuclear power plant considering such factors as the magnitude of the fire, and the complexity and difficulty of fire fighting.
These sessions should be designed to provide brigade members with experience in actual fire extinguishment and the.use of emergency breathing apparatus under strenuous working conditions.
The sessions should be in addition to the scheduled fire brigade training sessions and fire drills and.should include fire fighting strategies, (i.e., simple plans showing fire fighting equipment
- locations," entry and egress points, ventilation, cot:II!lunications and emergency lighting locations and controls).
These practice sessions should be provided at regular intervals, but not exceeding a one year interval for each fire brigade me~ber.
- 6.
Planned Meetings, Repeated Instructions, Drills and Critiques Staff Concern The fire brigacie will not maintain a high level of fire fighting expertise.unless:
- a.
Classroom instructions and fire drills are provided on a more frequent schedule than the proposed biennial interval for classroom instructions and the annual :ire drills;
- b.
Fire brigade members are each evaluated during fire drills to assure their proficiency in fire fighting techniques;
- c.
Periodic critiques of the fire brigade are performed by qualified individuals independent of the plant staff to update and correct the existing fire fighting techniques.
Staff Position a..
Regularly planned meetings should be. held every 3 months to repeat the initial classroom instruction programs over a two year interval.
- b.
During fire drills, an evaluation should be made of each fire brigade member's proficiency in the use of fire fighting procedures.
- c.
Fire drills should be critiqued at three year intervals by individuals independent of the plant's staff.
- d.
Fire drills should be performed at regular intervals ~ut not to exceed 3 months for each fire brigade.
- 7.
Additional Suppression Equipment for Transient Fire Loads Staff Concern Transient fire loads should be analyzed.
Assessnient of the need for additional suppression equipment by an individual who may not be
- trained and qualified to make evaluations of transient fire loading capabilit~es is not sufficient.
Staff. Position Based on qualified analysis, when the transient fire load causes the total fire load to exceed the capabilities of existing suppr~ssion systems and equipment, additional portable suppression equipment should be brought* into the area.*
- 8.
Hot Work Permit Documentation Staff Concern
!he licensee does not utilize a hot work permit system for the control of welding, burning and grinding operations but ins teed specifies any hot work precautions on the work permit.
This practice x::ay result in the omission of important precautior.s that should be :aken during such operations.
Staff Position The licensee should adopt a hot work permit system in accordance ~ith NFPA 51B for work operat~ons involving welding, burning or grinding.
- 9.
Signature Concurrence of Fire Watch Staff Concern The licensee concludes that signature concurrence of-a member of plant management or a quality control inspector whenever the first-line supervisor determines that a fire watch is not required, is unnecessarily restrictive.
Staff Position Signature concurrence of a member of the plant's management or quality control should be obtained whenever the supervisor or foreman determines that a fire watch is not required.
- 10.
Establishment of Fire Emergency Procedures and Special Duties
- Staff Concern
. Procedures are not established on strategies for fighting fires in all saf e~y-related areas and areas presenting a hazard to safety-related equipment.
Staff Position Fire fighting procedures should cover suc_h items as not if icat:i.on of a fire, fire emergency procedures, and coordination of fire fighting activities, strategies, and special duties.
The strategies established for fighting fires in all safety-related areas and areas presenting a hazard to safety-relafed equipment should cover the most_ favorable direction from which to attack a fire in each area, in view of the ventilation direction, access hallways, stairs and doors which are most likely to be fire-free, and the best station or elevation for fighting the fire.
A specific identification system shall designate all hall\\..'ays*, stairs, doors, fire equipment and system c~ntrol locations, and other items described in the fire fighting procedures.
- This identification should be used in the procedures and the corresponding plant items should be prominently marked so that they can be recognized in dirr. light. All access and egress routes that im*olve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified.
- 11. Drills Including Offsite Organizations Staff Concern The licensee does not include offsite fire fighting organizations in fire brigade drills.*
Staff Position Actions should be taken to coordinate fire fighting activities with off site fire departments, including:
identification of individual responsible for assessing situation and calling in outside fire department assistance when needed; identification of individuals who will direct fire fighting activities when aided by offsite*
fire fighting assistance; provisions for including off site fire fighting assistance; provisions for including off site fire fighting organizations in fire brigade drills at least once per year; and provisions.for training offsite fire department personnel in basic radiation principles, typical radiation hazards, and precautions to be taken in a fire involving radioactive materials in._the plant.
The procedures should also describe the offsite fire depart~ent's resources aad estimated response time by the off site fire department to provide assistance to the.station.
- 12.
Safety Related Areas Staff Concern The staff is concerned that the Consumers Power Company definition of safety related areas (CPC letter of 6/19/78 response to Attachment 3) implies a lack of control is permissible during an operating mode in which the safety related equipment is not required by Technical Specifications.
The staff is concerned that this definition could result in unnecessary confusion and complication and unnecessarily reduce the effectiveness of administrative control.
Staff Position The definition of "safety related areas" included in the Consumers Power Company letter is not an acceptable basis for establishing administrative controls.
- 13.
Conformance with NRG Guidelines Staff Concern In response to reference (1), the licensee stated, "In those specific instances where Consumers Power Company's conceptual methods differ from those specified by the guidelines, a detailed evaluation is provided." but concluded with, "There will undoubtedly be other areas in which total conformance to the staff guidelines will not exist."
An evaluation is needed for any area not in total conformance with the staff guidelines.
Staff Position If Consumers Power Company does not meet nor intend to meet any specific of the guidelines as outlined in reference (1), it must give justification including any alternative methods by which a commensurate level of fire protection is achieved.