ML19317G976
| ML19317G976 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/08/1977 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8004020635 | |
| Download: ML19317G976 (12) | |
Text
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h-NRC P RM 196 u.s. NUCLEAR RE!ULATcRY cuMMISSI N DOCKET NUMBE.:
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NRC DISTRIBUTION FoR PART 59 DOp,KET MgTERIAh;.. j., 4 TO:
Mr. Robert U. Reid FROMi 3MU6' DATE oP DOCUMENT j
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95813 DATE RECE'VED J. J. Mattiruoe 12/16/77 i
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($sg M oEsCRiPrioN ENCLoSU RE Furnishing response to NRC's 1tr dtd 08/04/77 consisting of information con-cerning requirements, co.unitments and proceduq in conjunction with the proposed Tech Specs concerning fire protection..s' PLAN NAME: RANCHO SECO UNIT # 1 jcm 12/16/77 1p 2p + 8p DI'jTRIBUTION OF FIRE PROTECTION INFO PER S._SHEPPARD 9-22-76 FOR OPERATING REACTORS 3 N1YL WA Ok^ 0Q FOR ACTION /INFORMATION f
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lifornia 95813; (916) 452-3211 December 8,1977
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r-.fg s Di rector of Nuclear Reactor Regulation
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Mr. Robert t,.
Reid, Chief lw.[i Lt.)
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Operating Reactors Branch #4 1
Division of Operating Reactors U. S. Nuclear Regulatory Commission Ob3 g g7}'p h Washington, D.C.
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Re:
Docket No. 50-312 N
Rancho Seco Nuclear Generating k)g Station Unit No. I
Dear Mr. Reid:
Attached is the District reply to your August 4, 1977, letter to J. J. Mattimoe as requested by Mr. L. 01shan from your office.
Per telecon Mr. 01shan on November 9,1977, requested that SMUD reply to the August 4,1977 letter within thirty (30) days.
Our review of your letter finds that we have already complied with the
" Nuclear Plant Fire Protection Functional Responsibilities" during n'..nerous NRC Regien V audits following the Browns Ferry fire.
Followup cudits conducted on August 14, 19, 20, September 3 through 5 and 11 through 13, 1974; April 22 through 25, June 4 and 10 through 12, and December 15 through 18, 1975, reported to you that we had complied with many requirements stated in your letter.
Contrary to the above resolutions between the District and our Region V inspectors, the majority of requirements are repeated in your stated letter.
In light of your regt.ast, we have again reviewed all our requirements, commitments and procedures in conjunction with the proposed Technical Specifications concerning fire protection and find that we have satisfied the aspects stated in the August I., 1977, document.
Respe :tf ul 1y submi tted,
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4 J. J. Mattimoe Assistant General Manager and Chief Engineer JJM:RWC: sal Attachs.
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D.G. Raasch L.G. Schwieger R.J. Rodriguez File A *. ELECTRIC SYSTEY SERVtNG
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7 Attcchment No.~l FIRE PROTECTION ORGANIZATION
'I.0 The' organizational responsibilities and lines of communication are defined in AP.500 Emergency Plan and the fire protection Technical Specifications.
a.
The offsite upper level management position which has management responsibility is the Assistant General. Manager, Chief Engineer.
b.
(1)
Critiques of the fire drills are reviewed by management and assessment of the fire protection program is condected by Quality Assurance for-offsite Management Safety Revies Committee.
(2) The listed NFPA publications are used for guidance in the fire protection program.
c.
The onsite individual responsible for overall administration' of plant operations and the fire protection program is the Plant Superintendent.
d.
(1) TSe Safety Technician-implements periodic inspections of the listed areas of concern under AP.34.
(2) The Safety Technician is responsible for fire training of operations personnel and along with NELPIA and an'outside consultant conducts periodic testsof systems and. equipment.
Generation Engineering is responsible for design.
(3) The Safety Technician assists in critiques of drills and reports results to the Plant Superintendent.
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(4)
Individual department supervisors and-foremen are responsible for reviewing proposed work to determine potential transient fire loads and additional assistance is available from the Safety Technician if requested.
(5) All contractor personnel are required to attend a fire safety 4
Indoctrination as defined by AP.700 and implemented by the.
Training Coordinator.
(6)
A future fire training program under AP.32 will be implemented by the Safety Technician to include flammable leaks and spills.
An audit'of the fire protection program is conducted under 0A.28 and e.
the results reported to the Management Safety Review Committee.
f.
(1) The responsibility of Fire Brigade members is spelled out in AP.500 the Emergency Plan.
(2)
Same'as above.
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Attcchment No. 1 - P ga 2 f.
(3)
It 11s not-foreseen that a conflict would exist under normal
- operating conditions.
(4)
T' e minimum is as defined in.Technicci Specification.6.2.2(f).
In addition, during normal working hours there is a backup of plant personnel available.
In view of the automated fire protection systems available throughout the site it is felt that the size of the fire brigade is sufficient to combat the most significant fire-along with the short response time of supporting fire depart-ments.
The NFPA does not reveal any formula for predicting injuries.
during a fire nor do local fire fighting officials feel it is conceivable based on all the variables that exist during any type of fire emergency.
(5) Applicable NFPA publications are utilized for organizing, training, and operating the fire brigade.
2.0 a.
There is a California Professional registered Fire Protection Engineer assigned to the site.
b.
Fire Brigade members have completed a pre-employment physical.
c.
Maintenance and testing is performed by site and manufacturers' personnel under standards established by the manufacturer.
d.
The Safety Technician respons8' ole is qualified by training and experience for this work.
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" Attcchment No. 2
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s FIRE BRIGADE TRAINING The program for training of the fire brigades is detailed in administrative procedure AP.32, " Fire Drills and Firefighters Training Program." The overall training requirements for all Nuclear Operations Department personnel (including fire brigade members) are established in AP.700, " Rancho Seco Personnel Training P rog ram. " Some members of the plant staff other than designated members of the fire brigade also receive firefighters training, and may be available to assist the fire brigades.
1.0 Classroom instruction a.
Initial classroom instruction (1)
Potential fire hazards, their location in the plant and the type of fires involved with these hazards are topics of the initial training session.as specified by AP.32, section 3.2.
(2) The initial training session covers the availability and location of firefighting equipment as specified in AP.32, section 3.3 Familiarization with plant layout is handled as part of normal job training.
(3)
AP.32, section 3 3, requires training in the operation of all firefighting equipment available and in the applicability of that equipment to the fire hazards that are present. The program does not specify a kist of types of fires to be included in this training.
(4) Appendix C to the Emergency Plan (AP.500) contains the fire-fighting plan. Training in fire brigade responsibilities is covered in Emergency Plan training given fire brigade personnel.
(5)
Communications equipment available at Rancho Seco is covered in Emergency Plan Training.
Special training sessions (unscheduled) are held to instruct personnel in the use of especially complicated equipment (radio system). Training in the a e of lighting and ventilation equ'ipment is covered as part of normal job functions.
Respiratory protection training is given to all fire brigade members.
(6)
No specific training in direction and coordination of firefighting activities is given, otner than the responsibilities assigned in the Emergency Plan.
(7) The study of the potential consequences that can be expected from certain types of fires is required by AP.32, section 3 2.
(8) A revision to AP.32 will add a requirement for the classroom i
session training in the proper methods for fighting fires inside buildings and tunnels.
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Attechment No. 2 - Prg2 2 1.0 a.
(9)
The training in' operation and applicability of firefighting equipment encompasses the review of firefighting procedures.
(10)
Through normal training and job functions, the fire brigade members are cognizant of plant modifications.
b.
Firefighting instruction AP.32 specifies that the firefighters training program is the responsibility of the Safety Technician, who is properly qualified.
c.
A revision to AP.32 will require classroom retraining sessions for all fire brigade members on a three-ronth basis, conducted in a manner such that the classroom Instruction program is completed over a two year period.
c0 Practice No specific practice program.
Practice on equipment usage is included in the equiprnent operation training and is refreshed during periodic drills.
30 Drills The section of AP.32 stating the requirements for fire drills will be expanded to provide the detailed direction given in Attachment 2,-
section 3 0 a, b, c, d, e, and f of " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance."
4.0 Records Records of the firefighters training program and fire drills are main-tained by the Safety Technician as required by AP.32.
The responsibility for assuring that each member of the fire brigade receives the necessary training is placed with the Plant Training Coordinator by AP.700. The Plant Training Coordinator maintains records sufficient to document that j
training requirements are met.
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Attcchment No. 3 CONTROL OF COMBUSTIBLES a.
The requirements are stated in the Rancho Seco " Safety Manual" Adminis-trative Procedure AP.S.
Section G-12 and G-13 and AP.605, " General Warehousin7." specifically state the requirements for use of combustibles, hazards and storage of these hazards.
b.
The requirements are met by the full-time "onsite" employment of the
" Safety Technician." He inspects work activities daily to establish safe fire protection techniques and assure that the appropriate procedures and equipment are being used.
Routine inspections are stated in the Rancho Seco Administrative Procedure AP.34, " Fire Safety inspection Guide." No preplanned review of proposed work activities is required.
c.
This is the responsibility of all employees. The " Safety Manual" Administrative Procedure AP.5, Section G-1, " Responsibility of the Employee." and G-6, " Housekeeping," require routine cleanup of the work after completion of each Job. The Quality Assurance Program has also established Q.A. Procedure No. 23, " Housekeeping," that follows the requirements stated in Regulatory. Guide 1.39 d.
The periodic inspections are performed by the Safety Technician per AP.5 and the Quality Assurance Engineers per Q.A. Procedure No. 23 The reports are made to the Plant Superintendent and the offsite Management Safety Review Committee, respectively, The requirement to use flame-retardant-treated wood for scaffolding in e.
safety-related areas will be added to the Safety Manual Section G-18 and AP.29, "Use and Control of Combustible Materials and Ignition Sources."
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Attcchment No. A.
CONTROL OF IGNITION SOURCES 1.0 Administrative Procedure AP 29, "Use and Control of Combustible Materials and Ignition Sources" complies with this requirement.
2.0 a.
Authorization for this type of work is controlled through Administrative Procedure AP 3, " Work Request Procedure".
The training program established by Administrative Procedure AP 700 assures that all new employees have Safety and Fire Protection Indoctrination.
Retraining is provided to each foreman responsible for maintenance activities as required in Enclosure 4.6 of AP 700.
b.
The requirements for welding and associated fire protection precautions are controlled by Maintenance Procedure M 113,
" General Welding Standard". Tne requirements for movements, survey below the area, fire extinguishing equipment, notification and fire watch are covered in Section 1.3 of the procedure.
c.
A fire watch is always required during welding.
No exceptions are allowed under the established procedure requirements.
3.0 No open flame leak detectors are used at Ranc na Seco.
4.0 Administrative Procedure AP 29 contains the iestrictions for smoking permitted areas and "No Smoking" limitations where posted.
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Attrchment No.-F FIRE FIGHTING PROCEDURES a.
The actions necessary for discovery, notification and extinguishing a fire are covered in the Rancho Seco Emergency Plan AP 500, Section 111 C, Page C2.
b.
The actions required in the Control Room upon notification are described in the Rancho Seco Emergency Plan AP 500, Section 111 C, Pages C3, 4 and 5 s
,c c.
The actions required for the fire brigade are described in the Rancho Seco Emergency Plan AP 500, Section lli C, Page 5, AP 32 Fire Drills' and Fire Fighters Training Program and in the Rancho Seco Firefighting Training Guide.
d.
(1)
Identification of combustibles in each plant zone has recently been completed by the plant fire hazard analysis and has not been implemented into the training program at this time.
(2)
Fi re Brigade members have been trained in the use of Class A-BSC fires, but not in conjunction with the Fire Hazard Analysis.
(3)
Has not been implemented in training from a standpoint of the Fire Hazard Analysis of these, areas. AP 500 identifies each zone and fire supression equipment in that zone.
Plant items are not identified other than District and Manu-facturer's identification as to what the equipment is.
Normal exit signs would be visible under emergency lighting conditions along with individual room identification which gives precautions and methods of access.
(4)
Operations procedures in the Control Room thoroughly cover the systems that require managing during a fire to reduce damage potential.
Electrical equipment can be isolated at a remote location.
There are no hydraulic systems where over-pressurization would become a hazard during a fire.
(5)
Individual designation of heat sensitive equipment has not been Jone-I nor has critical equipment requiring cooling been specifically identified other than equipment such as diesel generators.
(6)
The duties of fire brigade members remain consistent on each shift as specified under AP 500 Emergency Plan.
(7)
Radiological hazards are identified and the use of respiratory equipment for other hazards is covered in Emergency Plan AP 500.
-(8)
Operations personnel receive training in Plant Ventilation Systems.
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Attcchment No. 5 FIRE FIGHTING PROCEDURES (9)
Operations procedures and the Emergency Plan AP 500 both detail Control Room and Shift Supervisors' actions during a fire emergency.
(10)
Instructions for all olant personnel during a fire are covered in the Emergency Plan AP 500, AP.5 Safety Manual and in fire safety presentations.
e.
Quarterly drills are_ in effect and each is followed by a critique.
f.
The actions required by the Plant Superintendent and his staff upon notification of a fire are described in the Rancho Seco Emergency Plan AP 500, Section 111 C, Pages 5,6 and 7 The security guard actions are described on Page 7. The actions for security forces are described in the Rancho Seco Security Plan SPIP No. 33, " Radiological incidents and Non-Security Related Emergencies".
g.
In addition to the Emergency Plan yearly letter of agreements are entered into by supporting emergency services including local fire departments.
The Shift Supervisor is the designated Emergency Coordinator and is directed by the Emergency Plan to notify support groups and direct what actions are to be taken.
Local fire support departments are included into annual drills which include rad ia tion training. AP 500 Emergency Plan procedures do describe local department resources and estimated response time.
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Attcchment No. 6' QUALITY ASSURANCE The quality assurance (QA) program for the District assures that require-ments for design, procurement, installation, testing and administrative controls for the fire protection program for safety related areas are met.
Your request has_ asked the District how its quality assurance program is conducted.
It specifically requested whether applicants / licensees can meet the fire protection quality assurance (QA) program criteria of Appendix A to BTP 9 5-1 or Regulatory Guide 1.120 by either:
1.
Implementing those fire protection QA criteria as part of their QA program under 10 CFR Part 50, Appendix B, where such a commit-ment is made, it is not necessary to submit a detailed description of the fire protection QA program or its implementation for NRC review; or 2.
Providing for NRC review a description of the fire protection QA program and the measures for implementing the program.
We wish to clearly state that we elect option No. 1, which implements the fire protection QA criteria as part of our existing QA program under 10 CFR Part 50, Appendix B.
The District has inaugurated a quality assurance program as delineated by the Quality Assurance Manual - Nuclear Operations (approved March 15,1974).
It describes the policies, systems and procedures that govern the operation and maintenance, including redesign and modifications, of Rancho Seco No. 1.
These procedures are followed by all Quality Assurance personnel and by other personnel who may have an effect upon or are responsible for determination or assurance of Rancho Seco plant quality.
The QA manual consists of twenty-eight (28) separate Quality Assurance Procedures (QAP's) that collectively cover the 10 CFR 50 Appendix B criteria.
They cover:
1.
Organization 2.
Design Review 3
Quality Assurance Classifications 4.
Procurement Document Control 5
Supplier Quality Assurance 6.
Inspection Planning 7
Configuration Control 8.
Identification and Control of Material, Parts and Components 9
Control of Special Processes 10.
Receiving Inspection 11.
Source Inspection 12.
Testing inspection 13.
Maintenance inspection 14.
Calibration of Measurement and Test Equipment
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Attachment No. 6 QUALITY ASSURANCE 15 Handling, Storage, Shipping and Preservation 16.
Inspection Status 17.
Nonconforming Material Control 18.
' Documentation Control Center 19 System Auditing 20.
Quality Control Instructions 21.
Inservice Inspection 22.
Plant Security and Visitor Control 23
- Housekeeping 24.
Procedure Requirements 25.
Clearance Procedure 26.
Test Control 27 Glossary of Terms and Definitions.
28.
Fire Protection The last procedure, QAP No. 28, Fire Protection, was added on October 21, 1976, to cover a previously undefined area.
This procedure documents the District's position of placing the fire protection program unde-the
" umbrella" of quality assurance as stated in the " rainbow" serics of books on quality assurance.
The District in its letter to the NRC, Robert W. Reid from J.J. Mattimoe dated July 22, 1976, stated our intention to adhere to the requirements of the " rainbow" series in lieu of committing to ANSI N18.7-1976 as the basis for our quality assurance program. The program developed to meet that criteria is also applicable to fire protection requirements and will be so treated by the District.
In keeping with that philosophy we are not submitting a separate detailed description of the fi re protection QA program.
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