ML19274D584
| ML19274D584 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 01/30/1979 |
| From: | Cabell A NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Toy H Battelle Memorial Institute, COLUMBUS LABORATORIES |
| References | |
| NUDOCS 7902130201 | |
| Download: ML19274D584 (1) | |
Text
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UP?ED STATES NUCLEAR REGULATORY COMMISSION jf
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s WASHINGTON, D. C. 205SS
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JAN 3 01973 DOCKET N0. 70-8 Battelle Columbus Laboratories ATTN:
Mr. Harley L. Toy License Coordinator 505 King Avenue Columbus, Ohio 43210 Gentlemc':
Th h refers to your recent telephone conversations concerning the fee category for License SNM-7.
We have reviewed the quantities and use of the special nuclear materials authorized in your license and have classified it in fee Categories 10 and lE of Section 170.31 of the enclosed Part 170.
Fee Category 1D pertains to licenses authorizing the " possession and use of 5 Kg or mre of uranium 235 in unsealed form....for activities other than fuel processing and fabrication." License SNM-7 currently authorizes more than 125 Kg of U-235 for research and development purposes at your King Avenue and West Jefferson sites.
Fee Category lE pertains to licenses which permit the possession and use of 2 Kg or more of plutonium in unsealed form for activities other than fuel processing and fabrication.
Since your license authorizes more than 2 Kg of plutonium for research and development purposes, fee Category lE is also applicable.
Please note that the fee categories assigned to License SNM-7 are based on the quantity and use of SNM authorized in the license, and not on the quantity of SNM you may actually have in your possession or use.
If you have further questions concerning the fees for your licenses, please let me know.
Sincerely, kb d Gt(ld/
7 Allen S. Cabell License Fee Management Branch Office of Administration
Enclosure:
10 CFrt 170 79021309801
O RESPONSES TO ENCLOSURE 1 - FEBRUARY 15, 1979 LETTER 1.
Offsite Management Position Restonsibilities Staff Position Discuss the role, function and responsibilities of offsite management positions.
Resconse The Fire Plans submitted (References 3 and h) provided descriptions of functional and operational interfaces for off-site and on-site personnel responsible for fire protection of our power plants.
In discussions with URC staff, the unan-svered concern was primarily " review and approval of changes to the Ccepany's fire protection program, ie, Fire Plans, Implementing Procedures and QA Procedures." In general, the Property Protection Department (Corporate Office) is responsible for preparation and approval of any changes to the Fire Plans.
The plant staff is responsible for preparation and approval cf any changes to the Implementing Procedures with reviews provided by the Property Protection Department.
Audits of fire protection program implementation will be addressed in the Quality Assurance Program Procedures but, _in general, vill involve our P&T-Quality Assurance and Property Protection Departments as well as outside organizations.
Revisions to the Fire Plans vill reflect these responsibilities or reference other applicable procedure documents.
2.
Fire Protection Eneineer Qualifications Staff Position Describe the means provided to document (i.e. fire protection plan) that the minimum eligibility requirements of a fire protection engineer position, as outlines in reference (1), are met.
Resconce A Fire Protection Engineer who is a graduate of an engineering cirriculum of accepted standing and who shall have completed not less than six years of engineering attainment indicative of growth in engineering competency and achievement, three of which shall have been in responsible charge of fire protection engineering work, will either be on the Consumers Pcuer Ccmpany staff or as a consultant to Conseners Power Company to address nuclear plant fire protection problems. The Fire Plans vill be revised to reflect this requirement.
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3 Handling, Use and Storage of Combustibles Staff Position Discuss the administrative controls established to govern the handling of and limitation on the use of combustibles, flnemnble and explosive hazards such as f1mnmable 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.
Response
Administrative controls pertaining to handling, use and storage of combus-tibles are provided in the Nuclear Material Limited (insurance company)
Standards and vill be identifi ed in the Fire Protection Plan Implementing Proce@mes.
The Implementing Procedures vill provide adequate controls and assurance that combustible materials vill not be stored or improperly used and handled (as practical) in safety-related areas of the plant.
h.
Flame-Retardant Wood.
Staff Position Describe the manner in which all lumber anu vooden items in safety-related areas are verified to be pressure-treated fire retardant lumber or coated with a penetrating fire retardant that has good abrasion resistance.
_ Response The Fire Protection Implementing Procedures limit the amount of combustible materials that are allowed in safety-related areas. Lumber and wooden com-bustible materials vill not be allowed nto safety-related areas unless they have been verified to be flame retardant.
5 Area Survey Insnection and Fire Watch Staff Position Describe the means provided to ensure that the responsible foreman or supervisor vill physically survey the area where cutting, velding, or grinding or open-flame work is to be performed and establish that all criteria, as outlined in reference (1), are met.
Reference (1) - URC Guidelines entitled " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance" 2
Resnonse Fire Protection Implementing Procedures or other plant procedures vill require that maintenance orders be filled out prior to any hot work being done.
At Big Rock Point, the first-line supervisor must inspect areas where " hot work" is to be performed.
If nonplant personnel are involved, the Shift Supervisor must examine the area where " hot work" is to be performed and sign the hot work permit.
Since the Palisades Plant Fire Protection Implementing Procedures have not been completed, their methods may differ.
If the Palisades Plant uses a different procedure, the NBC staff vill be notified.
In addition, all safety-related maintenance orders are reviewed and s'.gned off by the plant QC organisation.
6.
QA Audit of Fire Protection Procram Staff Position Identify the frequency at whien quality assurance audits are performed to provide an overall assessment of conformance to fire protection program requirements.
Response
Audits are performed biannually in accordance with Technical Specifications.
Ainual inspections / audits vill be made by the Property Protection Department and others to provide an overall assessment of conformance to fire protection program requirements at the plant.
RESPONSES TO ENCLOSURE 2
~ FEBRUARY 15, 1979 LETTER 1.
Organisation Position Description and Functions Staff Concern Consumers Power Company concludes that defining the authority and responsibility of each position relative to fire protection is unnecessary.
Ctaff Position The organisational responsibilities and lines of communication pertaining to fire protection should be defined between the various positions through the use of organisational charts and functional descriptiens of each position's responsibilities as outlined in reference (1).
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Response
Consumers Power Company still concludes that defining the authority and responsibility of each fire brigade member's position is unnecessary; all other responsibilities are identified in the Fire Plan or Procedures.
Consumers Power Company trains all members of the fire brigade the same so that any brigade member can perform all duties required of the brigade.
The only real brigade position that is identified is the brigade leader and a brigade leader is assigned in each shift.
2.
Fire Brigade Staff Concern F
1 in critical areas of the plant may require the use of systems, components or auxiliaries normally not used for plant shutdown. A Shift Sur.rvisor who is not a member of the fire brigade, may be needed to direct the integrated 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 critical areas of the plant.
Restonse The Shift Supervisor is not an active member of the plant fire brigade. He may offer advice to the fire brigade leader on fighting a certain type of fire, but most likely do it from the control room.
3.
Physical Examination for Fire Brigade Members Staff Concern A pre-e=ployment physical is not sufficient to determine an individual's pulmonary and cardiovascular ability to perform the strenuous functions assigned to members of the fire brigade.
Staff Position 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 physical examination by a medical doctor to determine their physical qualifications for continued assignments as fire brigade members.
h
Response
Presently, a preemployment physical examination is given to all employees to determine their ability to perform various activities during their work assignments.
Each employee shall also have the opportunity to have a physical each year.
Also, all plant employees (including fire brigade members) who would have the opportunity to wear self-contained breathing units, have com-pleted a respiratory fitness program performed by an outside agency.
h.
Initial Classroom Instruction and Records Retention Staff Concern Consumers Power Company concludes that classroom instruction in plant layout familiarisation is not necessary for the fire protection training program.
Staff Position Initial classroom instruction and records retention should include all criteria, as outlined in reference (1), for all fire brigade members.
Response
The actual teaching of the plant layout will not be taught, during fire brigade training, as all members of the fire brigade are familiar with the plant layout because of daily normal job functions, activities and other plant training.
The plant layout would be reviewed through discussions on locations of plant fire fighting equipment and fire protection systems. Also, plant layout will be covered when considering access to individual areas for purposes of fire fighting.
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 maintaining adequate proficiency in fighting various types of complex fires.
Staff Position Practice sessions should be held for fire brigade members on the proper method of fighting various types of fires that could occur in a nuclear power plant conaidering such factors as the magnitude of the fire, and the complexity and difficulty of fire fighting.
These sessione should be designed or 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 5
fire brigade training sessions and fire drills and should include fire fighting strategies, (i.e., simple plans showing fire fighting equipment locaticas, entry and egress points, ventilation, co==unicat'nns 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 member.
Resoonse Breathing equipment vill be utilized during fire brigade training and drills.
Consu=ers Power concludes that the use and operation of breathing equipment during fire drill training / practice sessions meets the staff position.
Training /
practice sessions utilizing breathing equipment vill be held once per year.
6.
Planned Meetines, Repeated Instructions, Drills and Criticues Staff Concern The fire brigade vill not maintain a high level of fire fighting exper tise unless:
a.
Classroom instructions and fire drills are provided on a more frequent schedule than the proposed biennial interval for class-room instructions and the annual fire 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 conths 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 me=ber'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 but not to exceed 3 conths for each fire brigade.
Resconse a.
Consumers Power Company nuclear plant fire brigades will be trained annually in a co=plete fire training program.
This progran vill contain both classroom instruction and practical training in operating fire fighting equipment on actual and simulated fires.
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b.
Consumers Power Company's monthly fire drills are critiqued as to the brigade's proficiency.
Consumers Power Company's fire brigades operate as a team, so there is no real need to evaluate each member's proficiency individually, as a mistake or low proficiency would be reflected in the overall brigade team effort.
c.
Fire drills will be critiqued every three years by individuals independent of the plant staff.
d.
Plant fire drills vill be performed conthly.
7 Additional Suonression Eauirment for Transient Fire Loads Staff Concern Transient fire loads should be analyzed. Assessment of '.he need for additional suppression equipment by an individual who may not be trained and qualified to make evaluations cf transient fire loading capabilities is not sufficient.
Staff Pcaition Based un qualified cnalysis, when the transient fire load causes the total fire loau to exceed the capabilities of existing suppression systems and equipx.ent, additional portable suppress *.on equipment should be brought into ti.e area.
Response
The problem of transient fire loads and the need for additional fire suppression equipment is a concern for the Property Protection Supervisor (PPS).
The Property Protection Supervisor is the on-site person responsible for plant fire protection and security.
From information supplied to him by plant personnel or by actual inspection of the area, he can request that a spare fire extin-guisher be p] aced at the location.
If the condition varranted a special supp ession system, the Property Protection Supervisor vould request assistance from the Property Protection Department Fire Protection staff to look at the problem to make recommendations and to analyze the need for a fire suppression system.
The Property Protection staff is available to assist the Property Protection Supervisor at all times.
8.
Hot Work Permit Documentaticn Staff Concern The licensee does not utilize a hot work permit system for the control of welding, burning and grinding operations but instead specifies any hot work precautions on the work permit. This practice may result in the caission of important precautions that should be taken during such operations.
T
Staff Position The licensee should adopt a hot work permit system in accordance with NFPA 513 for work operations involving velding, burning or grinding.
Resnonse The plant maintenance work order has an area for fire safety precautions during velding, burning and grinding. This area of the foru may be used in place of a formal hot work permit system. These procedures fulfill and are approved by the Nuclear Mutual Limited and their inspectors to meet their velding and cutting fire protection requirements.
9 Sienature 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 inecessarily restrictive.
Staff Position Signature concurrence of a member of the plant's management ur quality control should be obtained whenever the supervisor or foreman determines that a fire watch is not required.
Resnonce Consumers Power consia
's first-line supervision as part of the plant's management and, therefore, responsible for fire protection needs of any par-ticular work order. '4henever a maintenance order is filled out, fire pro-tection needs (including a fire watch) must be identified.
The plant QC orgar.ization reviews all safety-related maintenance work orders.
10.
Establishment of Fire Emergency Procedures and Special Duties Staff Concern Procedures are not established on strategies for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment.
Staff Position Fire fighting procedures should cover such items as notification of a fire, fire emergency procedures, and cocrdination of fire fighting activities, strategies, and special duties.
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The strategies established for fighting fires in all safety-related areas and areas presenting a hazard to safety-related 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 hallways, stairs, doors, fire equipment and system control 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 dim light. All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate pre-cautions and methods for access specified.
Resuonse Fire fighting strategies are discussed during fire brigade training and drills.
Methods for extinguishing fires from various positions and directions are covered as well as possible problems encountered by the fire brigade's responding to and extinguishing a fire.
Other than developing some basic guides for the fire brigade on attacking and extinguishing fires, the development of hard fast strategies for the brigade could be ineffective and vill not be developed.
Fires are never exactly the same and conditions vary; therefore, a hard fast strategy may be inaccurate when needed. Also, fire fighting strategies or guidelines must be flexible to be effective.
Fire fighting procedures covering items such as notification of a fire, fire emergent procedures and coordination of fire fighting activities, guidelines and special duties are covered in the plant Fire Protection Implementing Procedures, fire brigade training and fire drills.
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 c alling 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 offsite 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 9
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 department's resources and estimated response time by the offsite fire department to provide assistance to the station.
Resoonse Consumers Power Company does include the off-site fire department in an annual drill and training program, but does not noimally involve them in the monthly fire drills conducted at the plant.
Ite=a dealing with the calling of the fire department, by whom and when, is identified in the plant Fire Protection Implementing Procedures.
The direction of off-site fire department personnel when on site has been previously iden-tified during mutual fire training actizities and discussion between plant fire protection personnel, the Property Protection Department and off-site fire departments. Visits and communications with the off-site fire departments are maintained by the plant fire protection staff and the Property Protection Department.
Off-site fire department resources information are atailable to the plant on a standard company fire department information sheet. At the Palisades Plant the response time was determined in August 1978 by having a full unannounced fire drill involving the plant fire brigade, security and the Covert Fire Department. The response time was less than 8 minutes. Response to the Big Rock Point Plant is expected to be about the same.
12.
Safety Related Areas Staff Concern The staff is concerned that the Concumers Fever CoLgany definition of safety-related areas (CPC letter of 6/19/78 response to Attachment 3) implies m lack of control is per=issible 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.
20
s
Response
Consumers Power Company's previous response has been incorrectly interpreted.
Consumers Power does change the classification of safety-related equipment or areas because of equipment outages. We vill implement consistent practices /
procedures that provide for contrcl of combustibles as stated in our response to Item 3, Enclosure 1.
The procedures are, in general, applied to all areas in the plant whether safety-related or not.
13.
Conformance with NEC Guidelines Steff 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 vill undoubtedly be other areas in which total conformance to the staff guidelines vill 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 justirication including any alternative methods by which a commensurate level of fire protection is achieved.
Response
Consumers Power does intend to meet the guidelines provided.
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