ML19317F724

Responds to NRC 780331 Ltr Re Fire Protection.Forwards Revised 780505 Oak Harbor Fire Dept Agreement to Respond to Facility Assistance Requests,Revised Fire Hazard Analysis Rept,Table 4-1 & Revised Emergency Plan Sections 3,2,6,8 &9

ML19317F724
Person / Time
Site:	Davis Besse
Issue date:	05/03/1978
From:	Roe L TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
NUDOCS 8001230614
Download: ML19317F724 (9)

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. of of n s REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

DISTRIDUTION FOR INCOMING MATERIAL 50-346 REC: CTCLZ J F ORG: ROE L E DOCDATE: 05/03/78 NRC TOLEDO EDISON DATE RCVD: #8/08/79 DOCTYFE: LETTER NOTARIZED: NO COPIES RECEIVED

SUBJECT:

LTR 1 ENCL 1 RE5PON5E TO NRC LTR DTD 03/31/78. FURNISHING COMMENTS AND INFO CONCERNING SUGJECT FACILITY"S FIRE PROTECTICN REVIEW W/ATT SUFFORTING LTR DTD 05/05/78 FROM OAK HAREOR FIRE LEPT AND ATT.

PLANT NANC: DAVIS GESSE - UNIT 1 REVIEWER INITIAL: XJM DISTRIBUTOR INITIAL:

+-e-+4:t->~>+*-+++-+->+++ DISTRIEUTION OF THIS MATERIAL I? AS FOLLOWS **++++++++++++++++

NOTE 5:

1. SEND ALL AMENDMENTS TO J. ROE FIRE FROTECTION (PRIOR TO IS5UANCE OF OL).

(DISTRIEUTION CODE BOO 2)

FOR ACTIOiJ: ER CHIEF STOLZ++W/ ENCL PROJ MGR ENGLE44W/ ENCL LIC AS5. ' TON 4 *LTR ONLY INTERNAL: hEGFILE**

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JW B0CIE M SE TOLEDO h EDISON May 3, 1978 LOWELL E. ROE v,e. pc. ...

License No. NPF-3 (4191 259-5242 Docket No. 50-346 Serial No. 433 ,

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Mr. John F. Stolz, Chief '

Light Water Reactor Branch No. 1 ,.

Division of Project Management .

{3j United States Nuclear Regulatory Commission 3 -$

Washington, D.C. 20553 7 g, g

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Dear Mr. Stolz:

In response to your letter dated March 31, 1978 concerning Fire Protec-tion Review, Toledo Edison herein offers the following:

Item 1 The letter of agreement with the Oak Harbor Fire Department states that they will respond to requests for assistance from the Davis-Besse Plant. The letter does not provide sufficient evidence of arrangement and agreements reached with this off-site agency. It is requested that this agreement be revised to more clearly describe the responsibility and authority of the Fire Department when fighting fires at the Site (Regulatory Guide 1.101, Annex A, Section 5.3.2).

Response: The letter of agreement (Attachment 1) has been revised to more clearly describe the responsibility and authority of the Fire Department when fighting fires at the Site.

Item 2 The Fire Hazard Report, Revision 1, at Table 4-1, (Sheet 9) identifies the training and drills provided for the onsite fire brigades and the Oak Harbor Fire Department. It does not state that the Fire Department will participate in fire emer-gency drill at least annually. In addition the Emergency Plan at Sections 3.2.6, 8.5 and 9 is neither specific as to the frequency of the drills to be conducted nor the training pro-vided. Revise the Emergency Plan, at Sections 8 and 9. to include this information and conform to Regulatory Guide 1.101, Annex A, Section 8.1. I and 8.1. 2.

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THE TOLECO EDISCN COMPANY EDISCN PLAZA 300 MACISCN AVENUE TOLECO, CHlO 43652

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Response: The Fire Hazard Analysis Report, Table 4-1 (Sheet 9) will be revised (as shown in Attachment 2) to state that the Oak Harbor Fire Department will participate in a fire emergency drill at least annually.

Appropriate pages in AD 1827.00, " Emergency Plan", Sections 3.2.6, 8 and 9 (Attachment 3) have been revised to specify the frequency of drills and the type of training provided, also Sections 8 and 9 have been revised to conform to Regula-tory Guide 1.101, Annex A, Sections 8.1.1 and 8.1.2 for Fire Protection.

Yours very truly, Attachments db c/1-2 6

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6 Xay 5, 19h i Mr. Te ry D. :'urray, Su;erintendent Davis-secse Nuclear Pcwer Station g Toledo Elisen Cenpany ,

55013. state acute 2 . I Cak Harbor, Ohio 4339 l Dear Mr. Murray Please be advised that the Village of Cak Harbor Fire Departcent will service Davis-Besse Nuclear Power Station in response to fire alarns as required on the site. Based on present trainirg, the Departcent will fight fires, offer fire protection, and will train annually in nuclear fire fightirg techniques per your trainire progran.

Your site is in the Township of Carroll, a political subdivision which is under '

a current fire contract with the Village of Cak Harbor. Should terninstion of fire contract cccur, it will then be necessary for you to enter into a private contract with the Village of Oak Harbor. ,

It is understood that station procedures that discribe the action to be followed in fightirg fires at the station are provided. These procedures will also contain detailed locations of supplecentary fire equipment.

It is also understood that a coordinated schedule cf drills ( at least Annually) will be scheduled to caintain proficiency in workirs with the Station Ftre Brigade.

The Village of Oak Harbor place the responsibility on the Toledo Edison Company for protecting ani safeguardirg the Officials, Officers, and Firenen assigned to energency ala =, against radiation and to provide decontamination of presonnel and equi; cent if necessary.

Sincerely, N i W111ad 31 con Mayor of the Village of Cak Harbcz Acknowledged fu.o e b5 Kenneth R. Retrick Attachmenc 1 l Fire Chief 1 of 1 {

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. Tabic 4-1 (Sheet 9)

• i Appendix A Position Section Davis-Ecsse Unit 1 operator in the control room, and the offsite ,

command post.

Comply - Training sessions are held once a year f'or the 8 B5. (c) To have proper coverage during all phases Oak liarbor Fire Department. The local Oak liarbor Fire of operation, members of each shift crew should Department at least annually responds to drills at the be trained in fire protection. Training of the Station. Training is held on various shifts so that plant fire brigade should be coordinated with each shift fire brigade participates in a training the local fire department so that responsibili- session once every 5 weeks at a minimum. Drills are T ties and duties are delineated in advance. This held on various shifts so each shift fire brigade '

coordination should be part of the training particip'ates in a drill once per quarter.

course and implemented into the training of the local fire department staff. Local fire depart-

• ments should be educated in the operational precautions when fighting fires on nuclear plant -

sites. Local fire departments should be made aware of the need for radioactive protection of ,

personnel and the special hazards associated with a nuclear power plant site.

9 B5. (d) NFPA 27, " Private Fire Brigade" should be Comply - The existing fire brigade organization has followed in organization, training, and fire established training programs and fire drills in drills. This standard also is applicable for accordance with NFPA 27. Fire protection equipment at the inspection and maintenance of fire fighting Davis-Besse' is compatible with the equipment of that equipment. Among the standards referenced in of the local fire department.

this document, the following should be utilized:

NFPA 194, " Standard for Screw Threads and )

Caskets for Fire 11ose Couplings", UFPA 196, ~

" Standard for Fire llose", NFPA 197, " Training Standard on Initial Fire Attacks", NITA 601, . .

" Recommended Manual of Instructions and Duties for the Plant Watchman on Cuard". NFPA booklets 1 and pamphlets listed on page 27-11 of Volume 8, S 1971-72 are also applicable for good training S- references. In addition, courses in fire

! - prevention and fire suppression which are

• N recognized and/or sponsored by the fire protec-p tion industry should be utilized.

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8 AD 1827.00.3 3.2.5 Medical Consultant and Hospitals

1. Three licensed physicians are available to Davis-Besse Station: a lead Medical Coordinator.and two Medical Coordinators.

2. The Lead Medical Coordinator has attended the United States Nuclear Regulatory Commission Training Seminar on Medical Care and a workshop on Medical Planning aspects of radiation accident management. The Medical Coordinators have attended the workshop on Medical Planning aspects of radiation accident management.

3. Magruder Memorial Hospital (11 miles from the Station in a southeasterly direction) has a Radiation Emer-gency area, separate from the rest of the compler_, with facilities which include equipment for emergency surgery, personnel dosimetry, decontamination, radio-active waste recovery and portable shields for attendant personnel. By use of these faci'ities, hospital personnel will be able to perform emergency treatment of contaminated patients.

4. Noncontaminated injuries would be handled by the hospital routinaly. Additional support in the treatment of nonradiation related accident victims is available at St. Charties Hospital, Toledo, Ohio. Additional information is contained in Appendix B.

3.2.6 Fire Department The Oak Harbor Fire Department is located less than ten road miles from Davis-Besse. It is a volunteer organi-zation consisting of 21 men. All members have attended the Ohio State Fireman's Training Courses. Additionally, all members have received the American Red Cross Standard and Advanced First Aid Courses. Drills are conducted each month as well as.a business meeting. Annually, 3l the members are invited to the Davis-Besse Site to i refamiliarize the men with the location of on-site equipment.

The Department is equipped with 2 DUKS and are experienced in evacuating personnel.

3.2.7 Ambulance Service The Robinson Funeral Home, Oak Harbor, located nine (9)

- miles from the station, has agreed to provide ambulance service to the Davis-Besse Station. All persons involved with this service have received first aid training and have been certified by the American Red Cross. Periodic Attachment 3 1 of 4

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6. Periodic Review and Updating 6.1 The Davis-Besse Emergency Plan contains elements of planning that involve assistance and coordination of governmental agencies and -

intra-company groups. In order to achieve and maintain the most efficient course of emergency action, it is necessary to review and update the plan on an annual basis. Liaison will be continu-ously maintained with state and local agencies responsible for public safety. Special attention will be devoted to maintaining effective communication channels and detailing the specific nature of assistance to be rendered.

' 6.2 The Station Review Board will review the Emergency Plan annually and recommend updating procedures, call lists, etc. , as the need arises.

6.3 The Company Nuclear Review Board will have audits performed under their cognizance of the Emergency Plan and implementing procedures as stated in Technical Specifications 6.5.2.8e.

7. Medical Suoport Medical Support is listed in Appendix B, Medical Emergency Plan.

8. Drills 8.1 A procedure for conducting annual radiation emergency drill has 3 been formulated by Toledo Edison. The objective of this drill is

' to familiarize each member of the plant staff with the Emergency plan and in particular, each individual's immediata action responsibilities during a radiation emergency.

8.2 The Oak Harbor Fire Department will annually as a minimum be invited to conduct a fire drill at the station. The objective of this drill 3 will be to provide experience in coordination of the participation of the Fire Department with the Station Fire Brigade, First-Aid Teamst and Radiation Monitoring Teams.

8.3 A secondary function of any drill procedure is to disclose any deficiencies in planning so that appropriate changes can be made in the Emergency Pian.

8.4 During annual emergency drills, telephone and radio communications l

i 3 links and notification procedures will be checked to insure the capability for early warning of the public is maintained.

8.5 State agencies involved in joint emergency planning will be invited 3 to participate and/or send observers to annual drills.

8.6 Drills will be conducted with Magruder Hospital and Robinson Funeral Bone for the transport and receipt of contaminated victims. These will be done as hospital work load and schedule permit. These drills will be supervised by the Radiation Management Corporation and observed by qualified oersonnel. .

Attachment 3 2 of 4

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. m o 36 AD 1827.00.3 8.7 Fire Brigade drills are held on various shifts so that each Fire Brigade participates in a drill once per quarter.

8.8 Each observer will be assigned a specific area to evaluate.

Written instructions will be furnished to the observers detailing 3 what responses to look for.

8.9 A critique will be held following drills at which time the observers will report on discrepancies noted and other items which may need correcting.

9. Training 9.1 All station operations, technical and maintenance personnel are trained in emergency procedures and monitoring duties. It is the intent of this training to provide an adequate number of emergency monitoring personnel, sufficiently familiar with radiation emer-gency, the individual can render effective assistance. The 3 training is addressed under the provisions of AD 1828, Personnel Training.

9.1.1 Emergency Duty Office Training This training will be oriented to supervision of Radiation Monitoring Teams, interpretation of data, use of map over-lays and estimate of radiation dose. It will also include the training given to the Radiation Monitoring Teams.

This group will include station management, shift super-visors, and technical staff.

9.1.2 Radiation Monitoring Team Training This training will include operation of portable radiation survey instruments and air sampling equipment, air sampling techniques, contamination surveys, " field" of air activity and radiation field determinations. Appendix A contains a listing by type, range quantity and location or portable radiation survey instruments, portable air sampling equip-ment, and personnel monitoring devices to be used by the Radiation Monitoring Teams.

3 9.1.3 Fire Brigade Training Fire Brigade training has been established in accordance with NFPA27 and training sessions are held on various shifts so that each Fire Brigade participates in a train-ing session once every five weeks at a minimum.

9.1.4 First-Aid Team First-Aid Team Leaders will have current American Red Cross Standard cards (or equivalent) and will be retrained every two years. First Aid Team members will be instructed on a continuing basis by the TECo Accident Prevention Department.

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37 AD 1827.00.3

' 9.1.5 Magruder Hospital As part of the annual Radiation Drill, Magruder Hospital is given a seminar on Radiation Protection by Radiation Manage-ment Corporation.

9.1.6 Robinson Ambulance Service 3 Robinson Ambulance Service personnel are given annual training in Radiation Protection by the Station.

9.1.7 Oak Harbor Fire repartment Oak Harbor Fire Department are given annual training in radiation protection and fire fighting by the Station.

9.1.8 Corporate Support Personnel Corporate Support Personnel are given emergency plan training every eighteen months.

10. Recovery and Re-Entry ,

10.1 If the reactor has been shut down because a safety limit was exceeded, reactor operation shall not be resu=ed until authorized by the NRC.

A complete analysis of the circumstances leading up to and resulting from the situation together with recommendations to prevent a recurrence shall be prepared by the Station Review Board. This report shall be submitted to the Company Nuclear Review Board.

Prompt notification of such occurrences will be made to the NRC as specified in Davis-Besse Station Technical Specification.

10.2 Although an emergency situation transcends the normal requirements of limiting exposure, there are suggested levels for exposure to be accepted in emergencies. However, every reasonable effort to minimize exposure must be made, even in emergencies. These categories of risk versus benefit must be considered in this order:

Normal rem Volunteer rem

1. Saving human life 12 25 to 100

2. Protection of health and safety of public 12 25

3. Protection of property 12 25 10.2.1 In order to avoid restricting actions that may be necessary to save lives, it shall be lef t up to the judgement of the individual in charge to determine the amount of exposure that will be permitted to perform the emergency mission.

However, in no case will the exposure be permitted to exceed 100 rem. In situations where the bodies of acci-dent victims are in areas inaccessible because of high Attachment 3 4 of 4

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