ML19262A424

Forwards Status Rept for TMI-1 Re Portions of App a to Branch Technical Position Apcsb 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to 760701. Addl Info to Be Submitted by 770515

ML19262A424
Person / Time
Site:	Three Mile Island
Issue date:	12/06/1976
From:	Arnold R METROPOLITAN EDISON CO.
To:	Stello V Office of Nuclear Reactor Regulation
References
GQL-1656, NUDOCS 7910290512
Download: ML19262A424 (11)

Text

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,/nw me / a th*, , A.ern pop onOGorss METHOPOLIIAN EDISON COMPANY POST OFFICE BOX 542 AEADING. PENNSYLVANI A 19603 TELEPHONE 215 - 929-2001

%L 1656 December 6, 1976 Ifawwa h.[,5

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Director cf :iuclear Reactor Regulation -

Attn: 73ctor Stello, Jr., Director Division of Operating Feactors U. 3. IIuclear Regulatory Consission

'4ashington, D. C. 20555 Dear Sir; Three Mile Island !uclear Station Unit 1 (D!I-1)

Docket :To. 50-289 Operating License To. PPR-50 Enclosed please find a report of the status of 31I-1 with respect to Portions of Appendix A to Branch Technical Position APCSB 9.5-1 " Guidelines for Fire Protection for !!uclear Power Plants Docketed Prior to July 1, 1976." A: I indicated in ry :!cvember 3,1976 telephone convercation with Mr. R. 'd. Reid, those portions ccncerning personnel, crganizaticn and training will be addrecced at this time. (Positions Al and B)

A descripticn of the DII-l fire protection system can be found in Sections 9.3.6 and 9.3.7 of the 311-1 FSAR.

Response to the remaining portions of APCSB 9 5-1 Appendix A depend upon the cenpleticn of the fire hazards analysis. Thic fire hazar12 analysis is in progress. 'de expect it will be complete, ard we vill provide you the renaining respence by May 15, 1977.

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Note: Numbering used is that of Appendix A to 3TP APCSB 2.5-1 A. Cverall Requirements Of Huclear Plant Fire Protection Procram

1. Percennel Respcnsibility for the overall Responsibility for the overall fire protection program should fire protection program lies be assigned to a designated with the Vice President - Generation.

person in the t;per level of Currently, the Vina President -

management. This persen shculd Generation utilises the Manager-retain ultimate responsibility Generation Engineering, the even though formulation and Manager-Operational Quality assurance of program implementaticn Assurance, and the Man e r-is delegated. Such delegation Ge.le.ation Administratr .. to of authority should be to staff assist in fonnulating, ar perscnnel prepared by training assuring implementation of the and experience in fire protection fire protection progr12. These and nuclear plant safety to managers meet the standards of provide a balanced apprcach in ANSI N18.1. Station management directing the fire protection and supervision perscnnel are programs for nuclear power responsible for day-to-day plants. The qialificatien implementation of fire protecticn requirements for the fire program activities. Documentaticn protection engineer or con- of assigned responsibilities sultant who will assist in the will be acccmplished by means of design and selecticn of equipment, a " Fire Protection Program Plan" inspect and test the ccmpleted which will te issued by the Vice physical aspects of tl system, President -Generation no later develop the fire protecticn than April 1, 1977. At present, program, and assist in the fire the FSAR does not specifically fighting training for the operating discuss the training and updating plant should be stated. Subsequently, provisions regarling fire prctection.

the FSAR should discuss the The FSAR vill be updated to training and the updating previsions conform to this position by such as fire drills provided for September 1, 1977 maintaining the competence of the station fire fighting and operating crew, including The Manager-Generation Engineering personnel respcnsible for is designated as Met-Ed's " Fire maintaining and inspecting the Protection Engineer". The fire protecticn equipment, qualificaticns and experience of 1484 183 (1)

the incumbent are set forth in Attachment A. As part of the effort necessary to respond to Appendix A, the design of the fire protection system, and the associated equipment, is being reviewed under the direction of a consultant who is a me=ter of the Society for Fire Frctection Engineers (SFFE). The fire protection equipment has been inspected, and test program results reviewed, by a number of different organizations and individuals with special expertise in fire protection systems and equipment such that Met-Ed is assured of the ability of the installed s/ stems to function as necessary to meet their design objectives. System improvements, modifications and additions necessary as a result of the aforementioned design review in response to AFCSE 9.5-1 will be designed under the direction of a censultant who is a =c=ber of SFFE as appropriate.

a The Met-Ed Fire Protection Engineer Shall review the Met-Ed " Fire Protection Progrs= Plan" for adequacy and cc=pleteness prior to issuance of the Plan.

The Met-Ed Fire Protectica Engineer shall periodically review the technical adequncy of the fire fighting training program.

(2) 1484 184

The fire protection staff should be responsible for:

(a) coordination of building laycut (a) Building laycut and systema design and systems design with fire review are the responsibility of the area requirements, including Met-Ed Fire Protection Engineer.

consideratien of pctential Consultants will be used as necessary hazardc associated with pcotulated when additional specialized design basia firec. qualifications are needed.

(b) design and maintenance of fire (b) Design control of systems is the detecticn, cuppression, and responsibility of the Met-Ed Fire extinguishing systems. Protection Engineer. Maintenance ic the responsibility of the Unit Superintendent.

(c) fire prevention activities, (c) Fire prevention activities are included in the industrial safety program under the Manager - Generation Adminictration.

(d) training and manual fire fighting (d) Training of plant perconnel is the activities of plant perconnel responsibility of the Manager - Cperationa_

and the fire brigade. Quality Accurance.

Supervisicn of manual fire fighting activities 1: the reopensibility of the Unit Cuperintendent and he has assigned specific fire fighting responsibilities to ctation perconnel in the Station Emergency Flan.

The manager licted above all have available the acciatance of the TMI Safety Supervicor for ccordinatien and direction of the implementation of these activities.

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5. Administrative Frccedures, Controls and Fire Erizade Administrative procedures consistent Procedures ecvering these with the need for maintaining the subjects are in effect. The performance of the fire protection TMI-1 fire brigade organization system and personnel in nuclear power is in accordance with 3FPA plants should be provided. recctmendaticns and has been audited by UELPIA and the I!PC .

Guidance is contained in the folicwing publications:

NFPA h - Organization for Fire Services

'!FPA LA - Organization for Fire Department NFPA 6 - Industrial Fire Loss Prevention IiFPA 7 - Management of Fire Energencies IIFPA 8 - Management Responsibility for Effects of Fire en Operations IIFPA 27 - Private Fire 3rigadcs

2. Effective administrative measures Administrative measures controlling should be implemented to prchibit storage of ec=bustible material bulk storage of ec=bustible are now in effect. Additionally, materials inside or adjacent to periodic fire hazards inspections safety related buildings or are performed by the General systems during operaticn or Public Utilities (GPU) Fire Task maintenance periods. Regulatory Force. These inspections Guide 1.39, "Hcusekeeping Require- include audits of follow-up cn ments for Water-Cooled Nuclear open items. Should the fire Pcwer Plants", provides guidance hazards analyses indicate that on housekeeping, including the improvements in cctbustible disposal of ec=bustible cateri tls. caterial control are warranted, they will be implemented.

cu, 1484 186

3. Normal and abnormal conditicnc Normal and abncrmal conditions or other anticipated operations which are associated with maintenance such as =ccifications (e.g., and operations and which have the breaking fire stops, impairment potential to adversely affect of fire detection and suppression reactor safety are centrolled by systems) and refueling activities procedures apprcved by the Unit should be reviewed by appropriate Superintendent. Similarly, the levels of managenent and apprcpriate Manager-Generation Engineering is special actions and prccedures respcnsible for insuring modificaticns such as fire watches or temporary are ecnducted in accordance with fire barriers implemented to procedures which ensure reactor assure adequate fire protection safety. These members of management and reactor safety. are responsible for prescribing In particular: action necessary to ec=pensate for any temporary reduction in fire (a) 'dcrk involvin7 ignition protection or increased risk of cources such s velding and fire as a result of off-normal flame cutting should be conditions.

done under closely controlled conditions. Procedures Positicn 3(a) and 3(b) are currently governing such verk should met at TMI-1.

be reviewed and approvel by persons trained and equipped to prevent and ccabat fires. If this is not pcssible, a person qualified in fire protection should directly monitor the work and function as a fire watch.

(b) leak testing, and similar procedures such as air flev determination, should use one of the ec mercially available aerosol techniquec.

Open flames or ecsbustion generated smoke should not be permitted.

(c) Use of ecmbustible material, The use of conbustible material in the e.g. EEPA and charcoal TM1-1 Centrolled area is limited. If filters, dry ion exchange the fire hasards analyses indicate resins or other cc=bustible that further controls are necessary, supplies, in safety related they will be in effect by September 1, areas should be controlled. 197~. Ucn-treated vcod will not be Use of vcod inside buildings used incide buildings c;ntaining containing safety related safety related systens.

systems or equipment should be permitted only when suitable non-ccmbustible substitutes are not available.

If voed must be used, only fire retardant treated vocd (scaffolding, lay devn blocks) shculd be permitte2. jq-i.

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Such materials shculd be allcwed into safety related areas only when they are to be used immediately. Their possible and probable use should be considered in the fire hasard analysis to determine the adequacy of tne installed fire protection system.

L. Nuclear power plants are frequently TMI-1 is self-sufficient with respect to located in remote areas, at some fire fighting activities.

distance frcs public fire departments. The Manager-Generaticn Administraticn has Also, first response fire departments primary responsibility for optimising the are often volunteer. Public fire supplemental er backup capability of public department respence should be considered fire departments.

in the overall fire protection program.

However, the plant should be designed to be self-sufficient with respect to fire fighting activities and rely on the public response only for supplemental or backup capability.

5 The need for good organisation, training and equipping of fire brigades at nuclear power plant sites requires effective measures be implemented to assure prcper discharge of these functicnc. The guidance in Regulator-/

Guide 1.101, "Energency Planning for

luelear Power P11nts", should be followed as applicable.

(a) Successful fire fighting requires While we are confident that the intent of testing and maintenance of the the provisions delineated here are currently fire protection equipment, being met, scme of the documentation and emergency lighting and cennunicaticn, prccedural formalisation implied in this as well as practice as brigades positicn may not be overtly stated. Any for the pecple who =ust utilise additional documentation and procedural the equipment. A test plan that formalisation found to be necessary during lists the individuals and their the current review will be required by the respcncibilities in connection Fire Protection Plan discussed ander item with routine tests and inspections A.1, above, of the fire detection and protecticn systems should be developed.

The test plan should contain the types, frequency and detailed procedures for testing. Procedures

, m Ao) 1484 '8P

shculi also contain instructions on maintaining fire protection during thoce perieds when the fire protection system is impaired or during periods of plant maintenance, e.g., fire watches or temporary hcce connections to vater systema.

(b) Easic training is a necessar/ This position is, at present, met at TMI-l element in effective fire fightin8 vith the exception of participation of local operation. In order for a fire fire companies in drills annually an1 with brigade to operate effectively, the implication of the exictence of a fixed it muct operate as a team. All locaticn, pre-designated offaite cc= mand members must kncv vhat their poet. With respect to participation of individual duties are. The7 local fire ecmpanies,it is impractical to must be familiar with the laycut achedule drills involving these ecmpanies of the plant and equipment since they are volunteer companies and location and operation in order catisfactory participaticn for fire drill; to permit effective fire fighting is difficult to obtain. Furthermore , it ic operations during timec when a not necescary to drill thece fire ecmpanies particular area is filled with ~

to respcnd to alarms. However, local fire accke or is insufficientl7 companies have agreed to assist at TMI and lighted. Such training can on17 are receiving annual training at the cite.

be acccmpliched by conducting In the future, this training vill include drills several times a year (at practical demonstrations of fire fighting least quarterly) 30 that all peculiar to a nuclear plant. With recpect to memberc of the fire brigade the implied fixed location, pre-designated have had the opportunity to offaite cc= mand post, it is our position train as a team, testing that this ic not nececcary. During the itself in the major arenc of the conduct of fire fighting, remote location plant. The drilla should include ecmmand posts are established as needed on a the simulated use of equipment case by case bacia. The optimum location in each area and 1hould be for such command posta is quite often cncite preplanned and post-critiqued to and virtually impoccible to pre-designate.

establich the training objective of the drilla and determine how well thece objectives have been met. These drilla should periodically (at least annually) include local fire lepartment participation where possible.

Cuch drills also permit supervising percennel to evaluate the effectiveness of ecmmunicatienc within the fire brigade and with the en scene fire team leader, the reactor operatcr in the ecntrol rocm, and the off:it ?

ecmmand pcst. j4}4 }Oh

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3 To have proper coverage during all Members of all shifts are trained in fire phases of operation, members of each protection. Local fire ec=panies are shift crew should be trained in fire annually instructed in the areas listed. In protection. Training of the plant the future, this annual training will be fire brigade should be coordinated coordinated insofar as this coordination with the local fire department so is and remains within the control of Met-Ed.

that responsibilities and duties are delineated in advance. This coordinaticn should be part of the training course and implemented ir.to the training of the local fire department staff.

local fire departments should be educated in the operaticnal precautions when fighting fires on nuclear power plant sites. Local fire departments should be made aware of the need for radioactive protecticn of personnel and the special hazards associated with a nuclear power plant site.

h. NFPA 27, "Frivate Fire Brigade" This position is currently met at TMI-1.

shculd be followed in organization, training, and fire drills. This standard also is applicable for the inspection and maintenance of fire fighting equiptent. A=cng the standards referenced in this document, the following should be utilized: :iFPA 19h, " Standard for Screv Threads and Gaskets for Fire Hose Couplings",

NFPA 196, " Standard for Fire Hose,"

NFT A 197, " Training Standard on Initial Fire Attacks", NFPA 601, "Reccnnended Manual of Instructitns and Outies for the Plant Watchman on Guard." NFPA booklets and pamphlets listed en page 27-11 of Volume 8, 1971-72 are also applicable for good training references. In addition, courses in fire prevention and fire suppression which are recognized and/or cpensored by the fire prctection industry should be utilizen.

/CT

\vl 1484 190

Metropolitan Edison's Fire Prctecticn Engineer received a 3.S. Degree in Mechanical Engineering frcn the Pennsylvania State University in 1952 and received additional tra' .g in nuclear pcver reactor engineering in 1967 from the University of Pdchigan. He has been a licensed professicnal engineer in the Ccnsonwealth of Pennsylvania since 1963. This individual has 25 years practical engineering experience associated with design, construction, testing, and operation of various types of techanical equipment with emphasis en ec=bustion, steam generation, and electrical generaticn equipment. For the past 13 years, he has been primarily associated with fossil and nuclear generating stations. The first 5 of these years were spent on the operating staff of a two unit, fossil-fired ' 00 4 SN electrical generating station, including intimate kncvledge of design, inspection, operation, maintenance, and testing of fire protection systems and training of the in-plant fire brigade. During the = cst recent 8 years, he was involved with the design and operation of one SCC MW nuclear unit and the design of a 900 MW nuclear unit. These efforts included participation in the establishment of fire protection design parameters and selection of equipment, involvement in the determination of test requirements and acceptance criteria for the physical fire protecticn system, and involvement in developing the overall station fire protection program.

1484 191 Attachment "A"