ML19269D090
| ML19269D090 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 02/23/1979 |
| From: | Moody D YANKEE ATOMIC ELECTRIC CO. |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| WYR-79-16, NUDOCS 7902270311 | |
| Download: ML19269D090 (5) | |
Text
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Telephone 617 366-9011 rwx 7 Kr - 3 9 0 - 0 7 3 9 YANKEE ATOMIC ELECTRIC COMPANY 1
.'N 20 Turnpike Road Westborough, Massachusetts 01581
- Ya.,.,.-
uxea WYR 79-16
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February 23, 1979 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
D. L. Ziemann, Chief Operating Reattors Branch 2 Division of Operating Reactors
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b) USNRC letter to YAEC dated January 25, 1979,
Subject:
Additional information on Administrative Controls.
(c) USNRC letter to YAEC dated November 1,1978,
Subject:
Result of Fire I-rotection Program Evaluaton
Dear Sir:
Subject:
Additional Information on Administrative Controla.
Yankee Atomic Electric Company has reviewed Znclosures 1 and 2 included in reference (b) above. Enclosure 1 lists two staff concerns and requests additional information and a confirmation of our commitment to meet various paragraphs of the NRC guidelines on Administrative Controls. Our response is as follows:
Staff Concern 1.0.a - Yankee Atomic Electric Company will satisfy the requirement in NRC guideline, attachment No.1, paragraph 1.b.l.
Staff Concern 1.0.b - Yar.kee Atomic Electric Company will aatisfy the requirement in NRC guideline, attachment No. 2, paragrapt 3r regarding critique of drills.
Staff Concern 1.0.c - As discussed previously with you, ther.e has never been any definition of " safety related areas" with regard to the Yankee Rowe facility. We have always used " areas containing systems or equipment required for safe shutdown".
It is not our intent at this time to depart from that wording. We feel that a review by you of the procedures and administrative controls at the plant will show that effective controls have been established to control bulk storage of combustibles and to control smoking and ignition sources inside or adjacent to any areas where the NRC Fire Hazard Review Team had concern, whether it is defined as a " safety related area" or an " area containing systems or equipment required for' safe shutdown".
790227031\\
United States Nuclear Regulatory Co= mission
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Page 2 February 23, 1979 Staff Concern 2.0 - Yankee Atomic Electric Company feels that the commitment previously made with regard to Fire Protection Quality Assurance was clear, concise, and complete. However, we will restate more fully what our commitment is.
In response to NRC criteria as delineated in Appendix A to BTP9.5-1, Yankee Atomic Electric Company will apply the following sections of our existing QA program under 10 CFR Part 50, Appendix B, as appropriate to provide the level of quality assurance warrented for design, procurement, installation, inspection and testing of fire protection systems and equipment. These sections are:
Section 3 -
Design Control Section 4 -
Procurement Document Control Section 5 -
Instructions, Procedures, and Drawings Section 7 -
Control of Purchased Material, Equipment, and Services Section 10 - Inspection Section 11 - Test Control Section 14 - Inspection, Test, and Operating Status Section 15 - Nonconforming Materials, Parts, and Components Section 16 - Corrective Action Section 17 - Quality Assurance Tiecords Section 18 - Audits We feel that this fuller explanation of our program should answer the Staff Concern. to reference (b) above listed three staff concerns and their attendent positions. We have reviewed the concerns and pasitions, and our comments are as follows:
1.0 Staff Concern The proposed frequency for fire brigade drills does not provide adequate training to assure brigade members can function effectively as a team in the use of fire fighting equipment and tactics to suppress fire manually.
United States Nuclear Regulatory Commission Page 3 February 23, 1979
_ Staff Position Fire Drills should be performed at regular intervals but not to exceed three months for each fire brigade.
At leasc one drill per year should be performed on a back shift for each fire brigade.
A sufficient number of these drills, not less than one for each fire brigade per year shall be unannounced to determine the fire readiness of the plant fire brigade leader, the fire brigade, the fire protection system and equipment.
YAEC Response We strongly disagree with the requirement of quarterly drills for each fire brigade.
As with many operating plants, the Yankee Rowo Fire Brigade for each shift consists of three plant operators and two security persons. We recognize that in a potentially stressful situation such as a fire the ability to work as a team is important, and that drills aid in developing that teamwork. However, it must be realized that the three plant operators already function effectively as a team in the operation of the plant.
In addition, the security persons also work together on their shift.
Training sessions are held during which the teanwork concept is developed even further. Yankee Atomic Electric Company strongly believes in an adequate and effective training program. This has been evident during our many years of operation. However, to force upon the plant the onerous and unnecessary requirement for four drills per year per fire brigade, which means a minimum of twenty-four drills a year for the life of the plant, is wrong. We firmly believe that our p roposai of two drills per year, along with a training program which will incluJe even more drilling, will enable us to provide a varied, interesting program for fire brigade personnel. The program will include at least one back shift drill and at least one unannounced drill for each fire brigade. Based upon our past training experience at Yankee Rowe and with other plants, we are confident that this type of program will provide us with an effective, well-trained, well-drilled, fire brigade.
2.0 Staff Concern Your detailed response to NRC Guideline, attachment No.1, Paragraph if, indicates that the Shift Supervisor and two auxiliary operators comprise the plant fire brigade.
Staff Position The Shif t Supervisor should not be a member of the fire brigade. His presence may be necessary elsewhere if the fire occurs in certain critical areas of the plant. The brigade supervisor should not have other responsibilities that would detract from his full attention being devoted to the fire.
His total function should be to survey the fire area, command the brigade and keep upper level management informed.
United States Nuclear Regulatory Commission Page 4 February 23, 1979 YAEC Response As is evident by our original response to the NRC Guideline, Yankee Atomic Electric Company has decided that the Shif t Supervisor is the person who should be the fire brigade leader.
It was act an obvious choice to make him brigade leader, just as it is not an obvious choice to prohibit his being a member of the fire brigade, although tha generic NRC position above seems to indicate that it is.
It is a decision that should be reached for each individual plant, based on its concept of plant operation, knowing what is expected of the operating staff at the plant.At Yankee Rowe, the Shift Supervisor's presence is not necessary elsewhere in the plant in the event of a fire.
Once the Shift Supervisor, upon arrival at the scene of the fire, makes the decision as to what should be done with regard to the operation of the plant and cocmunicates that decision to the control room operators, his duty is to direct the fire fighting effort.
This includes these dutir; that the Staff Position lists for a fice brigade leader - survey the fire area, command the brigade, and keep upper level management informed. The control ' oom operators, by virtue of their training, knowledge, r
conditions of their license, and aided by complete specific procedures on how to alleviate conditions brought on by fire in critical areas, arecompetent to shut down the plant.
For a fire protection consultant no the NRC in canual fire fighting to decide that the Shif t Supervisor needs "to be available to the Control room for decisions relating to ti e conditions that may occur duri" a fire in the plant", and thereftre, "should not be assi Sed as brigade leader" (reference c, Enclosure II, paragraph 3.2.1, page 9) strikes us as being beyond his area of expertise, and a rather flimsy basis for a sweeping NRC position on the sub jec t.
The Shift Supervisor is a highly trained, competent individual, fully capable of handling the duties presented to him as Shift Supervisor and as fire brigade leader. He is supported by trained control room operators, fully capable of safely shutting down the plant, and by a trained fire brigade to help in controlling that fire.
Yankee Atomic Electric Company feels that the Staff Position on this subject is in error, and we do not intend to comply with this position.
3.0 Staff Concern In your response to question PF-2 (YAEC lettar to NRR No. WYR 76) you state Yankee Rowe does not intend to meet the Staff Position pertaining to qualification of electrical penetration fire barriers.
However, you also state that the fire barriers to be installed have been tested previcusly by the supplier with penetration configurations similar to those at Yankee Rowe.
Staff Position Where previous tests can be shown to satisfy the staff concern for adequate electrical cable penetrations as cutlined in your response to question PF-2, provide the test results and bases that existing and new penetrations are adequate.
United States Nuclear Regulatory Coccission Page 5 February 23, 1979 YAEC Response
%nkee Atomic Electric Company is gathering the test results, and will cespond fully to this position as soon as the test results are obtained.
We trust that the above letter adequately responds to your concerns. If there are any further concerns, we are ready to discuss them with you at any time.
Yours very truly, Wf$//c
. E. Moody Manager of Operations dmp