ML19261C723
| ML19261C723 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/22/1979 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7903280307 | |
| Download: ML19261C723 (4) | |
Text
I B ALTIMORE G AS AND ELECTRIC COMPANY P.O. BOX 1475 B A LTIM C R E. MARYLAND 21203 ARTHUR C. LU N OVAu,JR.
V'C E 9.E S $ 0 E % f s
..g March 22,1979 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. Robert Reid, Chief Ocerating Reactor Branch 4 Division of Onerau ng Reactors
Subject:
Calvert Cliffs Nuclear Power Plant Units 1 and 2, Decket Nos. 50-317 and 50-318 Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance
Reference:
(a) NRC letter dated February 6,1978, from Mr. D. K. Davis to Mr. A. E. Lundvall, Jr.
(b) BG&E letter dated July 11, 1978, from Mr. A. E. Lundvall, Jr. to Mr. Robert Reid (c) BG&E letter dated November 14, 1978, from Mr. A. E. Lund-vall, Jr. to Mr. Robert Reid (d) BG&E letter dated December 29, 1978, from Mr. A. E. Lund-vall, Jr. to Mr. Robert Reid Gentlemen:
Reference (a) requested that we review our Fire Protection Program for conformance with the guidelines enclosed with your letter. Addition-ally, where we did not meet these cuidelines, you recuested we include justification or alternative methods to achieve a comensurate level of crotection. He resoonded in Reference (b), statino that we met the intent of the guidelines with the exception of several items listed therein. We subseouently were inferred by Mr. Les Gage of Region I-I&E that we must teet the guidelines verbatim or specifically identify those areas where we wish to take exception. We indicated by Reference (c) that we exoected to resubmit our response by December 29, 1978. Reference (d) stated that we had decided to make additional chances to the administrative cortions of our Fire Protection Program and that the coroarison of the cuidelines to our program would be delayed until Parch,1979. We have now cornleted our review and find that we reet your guidelines with the exceotion of those items discussed below.
O T9032803ol
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Fire Protection Prooran Page Two Fire Protection Orcanization Paragranh 1.0.b.(2)
Response
We have used all of the mentioned NFPA nublications for cuidance in develonino our Fire Protection Program with the exception of NFPA No. 4 and No. 4A. We feel that our " Fire Brigades" are caoable of extinguish-inn or containing a fire until local fire companies can rescond.
Paracranh 1.0.d(4)
Pesonnse:
A specific individual has not been assinned the responsibility for reviewing and evaluatina proposed work activities to identify ootential transient fire loads. This resgonsibility has been delegated to resconsible sucervisors overseeina each job. Additionally, the Fire Protection Inscector is reouired to perforn frecuent insnections of all safety related areas to identify transient fire loads which could exceed the cacability of existing sucoression systems.
Fire Bricade Trainino Paragranh 3.0 e Pesponse:
Drills will not be critioued at three-year intervals by individuals indeoendent of Baltimore Gas and Electric Concany. Drills will be critiqued at three-year intervals by either the Fire Protection Engineer assigned to the Electric Engineering Deoartment or the Finance Fire Prevention Unit. Both individuals are members of the Society of Fire Protection Ennineers and are independent of the olant staff having resocnsibility for administration of the Fire Protection Program at Calvert Cliffs.
Control of Cortustibles Paragranh e Restonse:
Use of non flame retardant treated wood in safety related areas will be oermitted only when a non combustible substitute is not available.
If such use is authorized, the time during which the raterial is allcwed to reside in the area will be held to an absolute mininum. Uooden ladders are not subject to these restrictions and nay be used within
Fire Protection Plan Page Three buildinqs containino safety related equiprent. The Fire Protection Inspector will insure through frecuent insoection of all safety related areas that the total fire load does not exceed the canability of existinn suppression systems.
Control of Ionition Sources Paracraoh 2.0.c Resconse:
A fire watch will always be assigned if weldina, cutting, prindinc, or ocen flame work is to be accorolished within an area where safety related equionent is located.
For work in other areas the eerson in charge of the job is authorized to deternine if a Fire Watch is required.
The eerson raking this determination will have cornleted the BG&E Fire Fighting Training Courses or an equivalent trainino nrogran.
Fire Finhtino Procedures Paragrach d Resnonse:
Fire fighting strategies will not be established for fightina fires in all safety related areas. Strateaies will be established to combat fires within the following areas as recormended by the team of oersonnel frem your office during the site visit recardino Fire Protection durino the last week of November,1978:
1.
Horizontal Cable Chases 2.
Hot Machine Shoo 3.
Cable Spreading Pooms 4
Diesel Generator Rooms 5.
Electrical Penetration Rooms 6.
Main Turbine Lube Oil Reservoir Roons 7.
SGFP Turbine Lube Oil Reservoirs A commensurate level of protection will be maintained in other areas as Fire Brigade rerbers are trained and kncwledgeable in fire fichting techniques and are familiar with the operating equioment in each plant area. In addition, drills sinulating fires in other olant areas will be conducted ceriodically.
These drills will encoenass rost of the items in this cuideline.
Paracranh d (3)
Resconse:
We do not intend to mark hallways, stairs, doors, fire ecuiement, and system control locations with a scecific identification system so that
Fire Protection Plan Pace Four they can be recognized in din light. Such markings are unnecessary as the Fire Bricade is composed of plant ocerations cerstunel who are familiar with each area of the plant and the equipment therein.
Cuality Assurance The Quality Assurance Procedure (OAP) addressing design, procurerent, installation, testing, and administrative controls for the Fire Protecticn Program is currently beino developed. A coroarison of this OAP and the guidelines of this section will t' submitted at i. later date.
Should you have further cuestions regarding this reoly, we will be oleased to discuss them with you.
Very truly your,s,
A. E. Lundvall, Jr.
Vice President - Suppiy AEL/JTC/dds
CONSUMERS P0kIR COMPANY SAFEGUARDS CONTINGENCY PIM FOR BIG ROCK NUCLEAR PLANT Prepared by Property Protection Departanent March 1, 1979
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