ML19329E304
| ML19329E304 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/11/1978 |
| From: | Vassallo D Office of Nuclear Reactor Regulation |
| To: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 8006120610 | |
| Download: ML19329E304 (10) | |
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NUCLEAR REGULATORY COMMisslON g
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50-329 50-330 Consumers Power Company ATTN: Mr. S. H. Howell Vice President 212 West Michigan Avenue Jackson, Michigan 49201 Gentlemen:
SUBJECT:
MANPOWER REQUIREMENTS FOR OPERATING REACTORS (Midland)
We are enclosing a document entitled, " Manpower Requirements for Operating Reactors." We are using the bases given in this document for allowing the sharing of duties to meet minimum staffing requirements for fire brigades at nuclear power plants. This is being provided for you'r guidance in meeting NRC requirements in this area.
Sincerely,
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O. B. Vassallo, Assistant Director for Light Water Reactors Division of Project Management
Enclosure:
Manpower Requirements for Operating Reactors I
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See next page THIS DOCUMENT CONTAINS POOR QUAUTY PAGES l
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' Consumers Pcwer Company ces:
Michael I. Miller, Esq.
Isham, Lincoln & Beale Suite 4200 One First National Plaza Chicago, Illinois 60670 Judd L. Bacon, Esq.
Consumers Power Compry 212 West Michigan A *nue Jackson, Michigan 49201 Mr. Paul A. Perry Secretary Consumers Power Company 212 W. Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq.
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One IBM Tlaza Chicago, Illinois 60611 Honoraole Curt Scnneicer Attorney General State of Kansas Topeka, Kansas 66612 Irving Like, Esq.
Reilly, Like anc Schneider 200 West Main Street dacylon, New York 11702 James A. Kendell, Esq.
Currie and Kendall 136 North Saginaw Road Midland, Michigan 48640,
Lee Nute, Esq.
Michigan Division The Dow Chemical Company 47 Building Micland, Michigan 48640 5
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MANPOWER REQUIREMENTS FOR OPERATING REACTORS The NRC has established requirements for persennel at operating reactors for purposes of plant operation, industrial security, and fire fighting. The following dis:ussion considers the axtent to which plant persennel assigned to either plant operation or security may also be temporarily allowed to man a fire brigade in the event of a fire for a single unit facility and sets forth an acceptable sharing scheme for operating reactors.
Sunnary of Manpower Recuirements 1.
Fire Brigade: The staff has concluded that the minimum size of the fire brigade shift should be five persons unless a specific site evaluation has been completed and seme other nunter justified. The five-man team would censist of ene leader and fcur fire fighters and would be excected to provide defense against the fire for an initial 30-minute pericd.
See Attachment A for the basis for the need for a five-man fire brigade.
2.
Plant Operation: Standard Review Plan Section 13.1.2 requires taat for a station having one ifcensed unit, each shift crew should have at least three persons at all times, plus two additional persens when the unit is operating.
For ease of reference, Attachment 3 contains a copy of this SRP.
3.
Plant Security:
The requirements for a guard force are cutlined in 10 CFR Part 73.55.
In the c urse of the staff's review of proposed security plans, a required minimum security response force will be established for each specific site.
In addition to the response team, ti,o additional memcers of the security force will be required to continucusly man the Certral Alam Station (CAS) and Secondary Alam Station (SAS).
It is expected that many facilities will have a security organization with greater numbers of personnel than the minimum number assumed for purposes of discussion in this pacer.
The NRC staff has given censideration to the appropriateness of per-mitting a limited degree of sharing to satisfy the requirements of plant operatien, security and fire protection and has concluded that, (1) subject to certain site and plant specific conditions, the fire brigade staffing c:uld generally be provided through operations and security persennel, and (2) the requirements for operators and the security force should remain unc:mpremised. Until a site specific review is c:moleted, the follcwing indicates the interim distribution and justification for these dual assignments, and therefore cur interim minimum requirements for a typical presently operating cennercial single unit facility. The staff believes that manpcwer for the fire brigace for miti-unit facilities is not new a problem because of the larger numbers of :eople enerally present at the sites.
Situations which do pose problems wiil be reviewed en a case-by-case basis.
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Plant Oceration: The staff h'as concluded that for most events at a single unit nuclear facility, a minimum of three operators should be available to place the reactor in a safe condition.
The two additional coerators recuired to be available at the nuclear facility are generally recuired to be present to perform routine jobs which can be interrupted to accomodate unusual situations that may arise. That is, there is the potential for the remaining two members of the operating crew to assume other short-term duties such as fire fighting.
- n light of the original rationale for providing extra plant operators to cope with off-normal conditions, it appears justified to rely on these personnel for this function. The staff recommends that one of the two operators assiped to the fire brigade should be designated as leader of the fire brigade in view of his background in plant operations and overall familiarity with the plant.
In this regard, the shift supervisor should not be the fire brigade leader because his presence is necessary elsewhere if fires occur in certain critical areas of the plant.
2.
Plant Security:
In the event of a fire, a contingency plan and proceoures will be used in deploying the security rgani:ation to assure that an appropriate level of physi. ' '
ection is maintained during the event. The staff has on._ermned that it is possible in the planning for site response to a fire, to assign a maximum of three members of the security organization to serie on the fire brigade and still provide an acceptable level of physical protection. While certain security posts must be manned continuously (e.g., CAS, SAS), the personnel in other assignments, including the response force, could be temporarily (i.e., 30 minutes) assigned to the fire brigade.
In judging the merits of this allewance the underlying question is whether the minimum security force strength must be maintained continuously in the event of a plant emergency such as a fire. Further examinaticn of this issue leads to two potential raticnales for reaching an affirmative decision.
- First, could there be a-causal connection between a fire and the security threat? Second, are there comoelling colicy reasons to costulate a simultaneous threat and fire?
The first potential rationale would only be credible if, (1) the insider (posed as part of the threat definitien) was an active participant in an assault and started a fire coincident with the attack on the plant or, (2) a diversionary fire was started by an attack force somewhere external to the plant itself where no equipment required for safe shutdown is located.
The role of the insider will be discussed first. While 73.55 assigns an active status to the insider, the rule also recuires that measures be imolemented to contain his activities and thereby recuce nis 5
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. effectiveness. At present, these measures include backgrcund checks on plant employees,1imitad access to vital plant areas, badging systems and the two-man rule. Here, limited access means that only designated employees are allowed in vital areas and that their entry is centreiled by either conventicnal locks or card-key systems. Also, if secarate trains of safety equip-ment are involved, then either comoartmentali:stion or the two-man rule is required. These measures to contain the insider are presently being implemented and will provide assurance that people of questionable reliability would not be able to gain empicyee status at a nuclear plant and should they beccme an employee with unescorted access, significant restraints would be inter-posed on the ability of such a person to carry out extensive damage to plant vital areas. Recognizing that additional safeguards may still be appropriate, the staff has recemnended to the Comission that plant personnel also be required to obtain an NRC security clearance. The staff believes that the attendant background investigation associated with a clearance, in cen-junction with the other 73.55 measures, will provide a hign degree of assurance that plant personnel will not attempt to take an active sabotage role.
If the clearance rule is adopted the staff believes some of the measures, such as the txHnan rule, designed to contain the insider can be relaxed. Thus, there does not now appear to be a reascnably credible causative relationship between a fire intentionally set by an insider and the postulated external security threat. For the case of diversionary fires set external to the plant itself, adequate security forces can still be maintained by allcwing only part of the fire brigade to respond while both fire fignters and security force armed responders maintain a hign degree of alertess for a possible real attack somewhere else on the plant.
Thus, the effective numoer of armed responders recuired by 73.55 can be maintained for external diversionary fires.
The second potential rationale concerns whether a serious, spontaneous fire should be postulated coincident with an external security threat as a design basis.
In evaluating such a require-i ment it is useful to consider the likelihood of occurrence of i
this ccmbination of events. While it is difficult to quantify the probability of the 73.55 threat, it is generally accepted that it is small, ccmparable probably to other design basis type events. The procability of a fire which is spontanecus and located in or in close proximity to a vital area of the plant and is serious enough to pose a significant safety concern is also small.
It would acpear, therefore, that the random coincidence of these two unlikely events would be sufficiently small to not
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require protection against their simultaneous occurrence.
In addition, it should be noted that the short time period (30 minutes; for which several members of the security force would be dedicated to the fire brigade would further reduce the likelihcod of coincidence.
As neither of the two potential estionales apcear to preclude the use of memoars of the security force in the event of a fire the staff has concluded that the short assignment of security personnel from the armed response force or other available security personnel to the fire brigade under these conditions would be. acceptable.
To ensure a timely and effective response to a fire, while still preserving a flexible security response, the staff believes that the fire brigade shculd operate in the follcwing manner.
In the event of an internal fire, all five members of the fire brigade should be dispatched to the scene of the fire to assess the nature and seriousness of the fire. Simultaneously, the plant security force should be actively evaluating the possibility of any security 1
threat to the plant and taking any actions which are necessary to counter that threat. For external fires, a lesser number than the five-man brigade should respond for assessment and fire fighting.
As the overall plant situation becomes apparent it would be expected that the most effective distribution of manpcwer between plant operations, security and fire protection would be made, allowing a balanced utilization of' manpower resources until offsite assistance becomes available. The manpower pool provided by the plant operaticns personnel and security force 're adequate to respond to the occurrence of a design basic fire or a security threat equivalent to the 73.55 perfermance requirsmen:s.
It is also recognized that other, more likely combinaticns of postulated fires and security threats of a lesser magnitude than the design basis, could be censidered. While the prcbabilities of inese nigher likelihood events may be sufficient to warrant protecting against them in comoination, the manpower requirements required to coce with each event wculd be similarly reduced therecy alicwing adecuate coverage by plant perscnnel.
Ccnclusien The staff believes that it would be reasonable to allcw a limited amcunt of sharing of plant personnel in satisfying the requirements of plant Operation, security, and fire protection. An acceptable sharing scheme would entail reliance on two plant coerators and three members of the security organization to constitute the fire brigade.
Since availability of tne full fire brigade would only
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be required for fires with potential for serious damage, actual distribution of plant personnel during a plant emergency would be governed by the axigencies of the situation. Of course, all personnel assigned to the fire brigaae would have to fulfill all applicable training requirements.
It should also be recognized that the diversien of personnel to the fire brigade would be of short duration and that substantial additional offsite assistance would be forthcoming ir. accordance with the emergency and contingency plan developed for each facility.
In evaluating licensee proposals for manpower sharing due consideration will also have to be made of unique facility characcaristics, such as terrain and plant lay-out, as well as the overall strengths of the licensee's fire and security plans. Minimum protection levels in either area could preclude the sharing of manpcwer.
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' Attachment A A
S taf f 'Posi ti en Minimum Fire Grigade Shi ft Si:e INTR 000CTICM Nu, clear power plants depend en the response qf an onsite fire brigade for d:fense against the effects of fire on plant safe shut:cwn capabilities.
In scme areas, actions by the fire brigade are the only tacans of fire sucpression, In other areas, that are crctected by correctly desicr.ed cutcastic detecticn and suppression systems, manual fire fignting offerts are used to e.xtinguish:
(1) fires too small to actuate tne autcmatic system; (2) well develcced fires if the auten: tic system fails to function; and (3) fires that are not ccmoletely controlled by the automatic system.
Thus, an adecuate fire brigade is 1
essential to fulfill the defense in death requiremants which protect safe thutdcwn systems frem the effects cf fires and.their related ccmeuntien by-procucts.
DISCUSSICN There are a numter of factert that should be considered in establishing the minimum fire brigcde snif t si:e.
They include:
- 1) plant cecmetry and si:e;
- 2) cuantity and~4uality of detection and suporessien systems;
- 3) firc fighting strategics for postulated fires;
- 4) fire brigade training;
- 5) fire brigace ecuicment; and
- 6) fire brigade su;plaments by plant personnel and lccal fire department ( s).
In all plants, the majority of :ostulated fires are in enclosed windcw-less structurcs.
Ir. such areas, the working environment of the brigace cre:ted by the Meat and s:cke builduo within the enclosure, will require the use of self-contained brecthing apparatus, s=cke ventilation equi; ment, and a personnel replacecent espasility.
dartain functions must be performed for all fires, i.e., comand brigade actions, infonn plant emnagement, fire suppression, ventilation control, provide extra equicment, and account for possible injuries. Until a site specific review can be ecmoleted, an interim minimum fire brigade size of five persons has been established. This brigade site shculd provide a minimum 4crting numner of personnel to deal with thosa postulated fires in a typical presently operating ccmmercial nuclear pcwer station.
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If the brig:co is coenosed of a smaller numeer of personnel, the fire attack may be stepced whenever new equicment is needed or a person is 19jured ce fatigued. We note that in :Se career fire service, the j
minimum engine c:mpany manning consicered to be effective for an initial attack on.a fire is also five, including one efficer and f:ur team members.
It is assured for the purposes of this position that brigade training and equipment 1.s adequate and that a backup capability of trained individuals exist whether through plant personnel call back or from the local fire department.
POSITI0t!
1.
The minimum fire brigade shift size should be justified by an analysis of the plant specific factors stated acove for the plant, after modifications are cc plete.
2.
In the interim, the minimum fire brigade shift si:e ~ hall be five s
per ons. These persens shall be fully cualified to perform taeir assign:d rcsconsibility, and shall include:
One Suner.*isor - This individual must have fire tactics training.
Tie iiiTi assune all c:mmand res:cnsibilities for fighting the fire.
During plant emergencies, the brigade sucervisor should not have cther resconsibilities that wculd detract frem his full attentien being devoted t: tne fire.
This sucervisor shculd not be actively engaged in tne fighting of the fire.
His total function shculd be to survey the fire area, c:= mand the brigade, and keep the u;cer levels of plant management informed.
Two lic e Men - A 1.5 inch fire hose being handled <ithin a windew-less enciasure wculd recuire two trained individuals.
The two team memcers are rer.uired t: anysically nandle One active hose line and to protect each otner while in the acverse environment of the fi re.
Two Additional Team "emeers - One of these individuals would be recuir:c to succiy f111ao air cylinders to the fire fignting mem ces of the brigade and the sec:nd t ~ estaolish.smcke ventilation and aid in filling tne air cylinder.
These two indiv1 duals would also act as the first backuo to One engaged team.
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Assigruments of corsonnel sueetine ANSI M18.1-1971 oualifications. Section 4.3.1 se Section 4.5.1. should be mede to onsite snift ooeratine e ows in numoers not less taan the following:
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1 For a statica naving one licensed unit, esca snift : ew snould 'save at leas: tnree
- ersons at all times, plus two additional ;ersons aien tne att is Operating.
For a smal:1-unit station, eacs snift :rew snoul: ave at least three pers:ns :er licensed unit at all times. 21us one additional pers:n :ee. cera:Ing uritt.
3.
Ocerator license :satifications of ;ersons assignec :: Operating sat ft :rews snould be as follows:
(1) A licensee senior coerat:r no is also a memoer of ne station supervisory s aff should se onsite at all times.een at least :ne.ni is loaded wita fuel.
(2) For any station mita more than :ne reactor c:ntaining fuel, (1) the nuncer of Itcensed seni:e coerators ensite at all times snoute not se less taan :n, numoer of control rooms fr:m.nica sne fuelee units are monitored, and (2) the nwneer of licensee senior :serat:rs snould not te less taan the nuncer of reacters ::erating.
(3) For each react:r ::ntaining fuel, tMere saculd :e at least One li:enses
- cerator in :ne ::ntrei a:::' at all ti: es.
shi't cre ::f::sittens snoui:
se soecified sucn ina :315 ::ncition can :e sattsfied inde:encer !y of liceased senior 2: erat:rs assignec :: snif t :rtiws :: -iee: Me Ortterta of (1) and (2) acove.
(4) For esca control coort fr:.nten 3ne or more reac:: s are in coeration, an seditiona: :cerat:r secule :e :nsite and availaole :: serve as relief
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Sht": ;rew ::rreest:1ons snouic to s:ectfied suca Mat ta's ::nci:1on :an :e satisfiec tece:eacertly =f (1). l2), and (3), anc f:e eacn suca ::ntr:1 -::m.
Eactatt:n : rete::t:r ::.aii:att:ns :# at least :ne :e-sen :n este ::eas:**g sni't snoul: me as fall:=s:
- he macagement sf eaca sta:icn aving :re :r : e.r':s ::ntaining 'wei sneui:
ettner, (1) cualify anc cesignate at leas: One mee:er =f eacn snif: ::erating crew to imclement radiati:n mestectieri cro:ecures, including reuttne Or special radiatten surveys using porta:Ie ract att:n cetect:rs, use :f =retec.
tive barrier 1 and signs, use Of 3r:Tec*1ve lotning anc Or*atning a::aratus.
j eer creanca of c:ntarnination surveys. :nects :n radiatier xni::rs, and tir-t:s e
of ex:osure rates anc ac:uruistec c:se. Or (U assig a reai:n : >st:s te: r$: an
- s eacn snitt, sucn assignreent :: :e in adai: ten :s :Mose assi;ree := snt';
a:erating crews in ac:ge ance its (a) anc : ) aceve.
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