ML20002C654
| ML20002C654 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/19/1978 |
| From: | Skibitsky W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8101100669 | |
| Download: ML20002C654 (8) | |
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C0mpany c.n.r.i ome.. m w.. uicnie.n 4..nw.. s ca.on u c%.n.o2oi. Ar.. coa. si7 tes-osso June 19, 1978 1
Director, Nuclear Reactor Regulation Att: Mr Dennis L Ziemann, Chief Operating Reactors Branch No 2
-j US Nuclear Regulatory Commission u
Washington, DC 20555 DOCKETS 50-155 AND 50-255 - LICENSES DPR-6 AND DPR BIG ROCK POINT AND PALISADES PLANTS -
RESPONSE TO FIRE PROTECTION ADMINISTRATIVE GUIDELINES By letters dated February 6 and February 14, 1978, Consumers Power Company was requested to review the guidelines entitled, " Nuclear Plant Fire Protection, Functional Responsibilities, Administrative Controls, and Quality Assurance,"
issued by the NRC staff.
In general, Consumers Power Company has found the staff positions to be acceptable; however, there are areas where the guidelines are deemed to be either too restrictive or incompatible with exisiting Company policy.
In those specific instances where Consumers Power Company's conceptual methods differ from those specified by the guideline, a detailed evaluation is provided.
~ : FIRE PROTECTION ORGANIZATION In general, Consumers Power Company concurs with the Organization Responsibilities specified in this attachment and, when implemented the fire plan for the nuclear plants will incorporate these positions.
It should be noted that this will, in some instances, require Technical Specifications changes. Additionally, there are several areas specified in the guideline that Consumers Power Company deems to be inappropriate.
The staff guidelines contain the followirg:
"The authority and responsibility of each fire brigade position, relative f.o fire protection, should be clearly defined. The responsibility of each fire brigade position should correspond with the actions required by the fire fighting procedure." Consumers Power concludes that these statements are unnecessary in that the authority and d
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e responsibility for each plant position (including fire brigade membership) is incumbent upon the normal range of authority and responsibility as defined in Plant Administrative Procedures.
In order for the fire brigade to be an effective vehicle to combat hazards, it must be developed from within the existing plant authority structures and not create a hierarchy of its own.
Thus, the authority and responsibility of fire brigade positions need not be discussed in the fire plan since it is already adequately defined. Further, the training prograw will train all fire brigade members on each fire brigade position. This will assure 100% backup for all brigade team members and, therefore, negate the necessity to develop any specific responsibilities by position for fire brigade members.
The staff positions further state:
"The recommendation for organization, training, and equipment of ' PRIVATE FIRE BRIGADES' as specified in NFPA 27-1975, including the applicable NFPA publication listed in the Appendix to NFPA 27, are considered appropriate criteria for organizing, training and operating a plant fire brigade." In general, Consumers Power Company concurs with these recommendations; however, it is deemed inappropriate that the commitment be made to abide by all the regulations contained in the cited publications.
Consumers Power Company will make every attempt wherever practicable to follow the guidelines.
However, since they are not required by Technical Specifications, they will be simply used as guidance and not as a committed course of action.
Finally, the staff's guidelines state that:
"The fire brigade members' qualifications should include satisfactory completion of a physical examination for performing strenuous activity, and of the fire brigade training described in Attachment 2."
It is Consumers Power Company's position that each employee shall have a physical prior to being hired, each employee shall have the opportunity to have a physical each year and, that the requirements for physical examinations specified by 10 CFR 20 will be adhered to.
Thus, Consumers Power Company concludes that no further commitments in this area are desirable or necessary.
One additional comment cweerning on-site organization must be made.
Consumers Power Company has not yet determined how NRC staff Position 1.d.
will be implemented at the plants.
If there are exceptions to be taken to this position, they will be stated in the Fire Plan and will be available for staff review upon completion. :
FIRE BRIGADE TRAINING As in Attachment 1, the specific guidelines as preposed in this section are, in general, acceptable to Consumers Power Company; however, there are a few minor areas requiring additional comment.
Under classroom instructions, the guidelines specify that the training program should include familiariza' ion with the layout of the plant including access
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routes to each area.
Consumers Power Company concludes that this is not necessary for the fire protection training program, simply because it is a normal part of each individual fire brigade member's job function and, therefore, is better incorporated in other portions of the plant training program. The program will include, however, classroom training on the location of fire fighting equipment in each area and the potential hazard in j
each area as defined in the applicable fire hazard analysis.
J Also required by the guidelines is the documentation of plant, fire fighting j
plans which specify each individual fire brigade member's responsibilities (previously discussed in the Organizational Attachment).
Consumers Power Company will train all fire brigaje members on all fire brigade positions; therefore, there will be no individual responsibilities defined, with the exception of the fire brigade leaders. As previously discussed, this will provide 100% backup and negate the need for detailed task definition.
The classroom instruction section of the guidelines requires that regular planned meetings be held every three months and that the instruction be repeated over a two-year period.
Since Consumers Power Company utilizes the services of a fire protection consultant for fire protection training, it is virtually impossible to ensure that every three months a training program is given for each plant. The present policy is to conduct all fire protection training during a large portion of time dedicated for this sole purpose.
Since the training will be completed at least every two years, Consumers Power Company concludes that there is no need for quarterly training as long as the program meets the two year commitment.
Under the section entitled Practice, the staff guidelines require that the use of emergency breathing apparatus be accomplished under " strenuous conditions."
Consumers Power Company concludes that this is not necessary.
Emergency breathing apparatus will be utilized in the practice sessions; however, the need for strenuous conditions is not apparent and not desired.
It is more important that operator's are aware of, and instructed in, the proper use of the equipment, than in their ability to simulate performance under strenuous conditions.
Concerning Drills, it is the staff's position that fire drills should be performed at regular intervals, not to exceed three months for each fire
, brigade.
In principle, Consumers Power Company concurs with this recommendation. However, for the detailed type drill required to meet the staff guidelines, it is concluded that a yearly drill is sufficient.
It is important to note that this is consistent with yearly drill requirements for site emergencies. However, because fire protection is an important aspect of the training, Consumers Power Company will conduct monthly drills to augment the major yearly drill.
These fire drills will not be as intensive or controlled as the yearly drill, nor will they necessarily utilize the same equipment. Essentially, they will be walk-throughs.
It will be these monthly p
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E drills that meet the unannounced and backshift requirements of the staff guidelines.
One aspect of this entire section that needs further clarification is the time frames.
It is Consumers Power Company's position that the time frames specified by these-guidelines are under the same 25% tolerance afforded all surveillance requirements by the applicable Technical Specifications. The plans and procedures developed will be based upon.this concept. :
CONTROL OF COMBUSTIBLES Consumers Power Company has concluded that the concepts specified in this attachment are acceptable with only minor clarification.
It is imperative that the definition of safety-related areas be explicitly stated. For any
-fire area, if equipment is required operable by the Technical Specifications only during particular operating conditions (ie, power operation, cold shutdown, refueling, etc) then the area that the equipment is contained within shall be deemed safety related only during the applicable conditions. For instance, if the only equipment in a certain fire area is a pump that is required to be operable during power operations, then the only time that that area will be called safety related is during power operations.
Consumers Power Company concludes that th's definition is acceptable and consistent with i
current Technical Specifications for the operating plants. Accordingly, the fire plan will be developed utilizing this concept.
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There is an additional item in this attachment that requires comment and that is the concept that an on-site staff member shall review work activities for potential transient fire loads.
It is Consumers Power Company's position that the first line supervisor for any specific task will make an assessment of the need for additional suppression equipment in any specific area based upon the transient fire loading of that area. Further, that this assessment will be made as a portion of the applicable maintenance work order and not on a separate document.
It is felt that this adequately meets the intent of guidelines.
CONTROLS OF IGNITION SOURCES Consumers Power Company concludes that this attachment is acceptable in its entirety with only minor clarifications / interpretations necessary. First, it is concluded that this attachment is applicable only to safety-related areas; safety-related areas as defined in the comments to Attachment 3.
Position 2.b(4) of the staff guidelines states, "All equipment to be used is in safe working condition.
Oryacetylene equipment is checked for leaks before I
being moved to the work area."
In principle, Consumers Power Company concludes that this is acceptable. However, because this is a part of the continuing training for the job skill of an individual who will be performing the work and is an action that is routinely performed in all situations, there
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is no need for documentation of adherence. Thus no documentation will be made.
It should be pointed out that this is a safety requirement that is required at all of Consumers Power Company facilities. The job skill training aspect-is also important when determining whether a fire watch is necessary.
L Consumers Power Company assigns the function of determining fire loading on maintenance work orders to the first line supervisor responsible for the job.
In this capacity he is responsible for ascertaining the need for a fire watch.
In order to ensure that this decision is properly made, first line supervisors are. trained in recognizing conditions of maintenance and fire loading requiring fire watches. Thus, it is concluded that the NRC staff's position requiring the signature of a member of plant Management or a QC inspector for concurrence with the first-line supervisor's determination that a fire watch is not required, is unnecessarily restrictive and inconsistent with job skill responsibilities assigned.
Under leak testing the staff guidelines state:
" Work orders for leak testing should require the concurrence of the Shift Engineer to verify that the leak test method is acceptable and would not present a potential ignition source."
Consumers Power Company concludes that this is not necessary since the leak est methodology is adequately delt with and reviewed by plant procedures.
Any variance would be discovered during the normal course of review of maintenance work orders. Therefore, no additional review by the Shift Engineer is necessary or desired.
r : FILE FIGHTING PROCEDURES 4
Consumers Power Cocoany concurs with Sections A, B, C, E and F of this attachment. However, there are great reservations and concerns about Section D.
Section D requires that a strategy be established for fire fighting in all safety-related areas and specifies all the components that should be implemented in these procedures.
Consumers Power Company finds this section 'nacceptable and inconsistent with u
other plant procedures.
Based on the fire hazards analyses, it is apparent that the time that a fire would most likely occur in any specific area would be when that area was subject to transient fire loading.
In order to write a procedure that consistently and accurately determines probable fire sources, location of such sources, methodology of fire fighting and the equipment necessary to fight such a fire, an exact knowledge of fire loading is necessary.
Since transient fire loading cannot be known beforehand, no procecure can be adequately written to cover all the various possibilitier.
To writ; a fire plan for a specific area would not only be an exercise in futility, it could actually hinder the fire fighting strategy. Many of the assumptions upon which the procedure would be written may in fact be false due to the variables affecting transient loading at any time.
Thus, while a generalized fire fighting strategy is beneficial, it is concluded that a detailed fire area by fire area fire fighting procedure is not. Another portion of this section requires that the duties of each fire b'rigade member i
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L be specifically spelled out. -Again, Consumers Power Company concludes that this is unacceptable. As previously specified, all fire brigade members are being trained in all positions and since, due to illness, injury, absence, etc, the composition of the fire brigade at any.one time cannot be adequately determined, to assign specific individuals to specific functions is tantamount i
to assuring confusion during the casualty. However, Consumers Power Company does conclude that for specific fire areas there are some general plans that can be formulated to implement a fire fighting strategy. These areas and plans will be plant specific and will certainly not be as comprehensive as specified in the staff guidelines.
One other aspect of this addendum that Consumers Power Company finds inconsistent with present policies is the requirement to include off-site fire fighting organizations in the yearly fire brigade drills. The intent of ensuring that the off-site fire fighting forces are familiar with plant equipment, location, procedures and methods, is best served by training the local fire departments in these areas. This would also include " hands on" fire fighting training and site familiarization. The ultimate goal of this training is to assure that the off-site fire fighting organizations are familiar enough with procedures and site layout such that their access time will be minimized should their services be required.
Given this, it is not apparent how involving the off-site fire fighting organizations in on-site drills will provide any additional level of training. Thus, Consumers Power
,f Company concludes that this guideline is not warranted.
Attachmer t 6:
QUALITY ASSURANCE i
Quality Assurance program for fire protection will be under the management of the existing Quality Assurance Organization.
The Quality Assurance program for fire protection is commensurate with the Quality Assurance Topical Report CPC-1-A submitted in accordance with 10 CFR, Part 50, Appendix B, and is applicable to those fire protection systems, equipment and actions that are Q-list.cd.
i The purpose of this letter has been to document specific :.reas cf the staff guidelines entitled, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Control, and Quality Assurance," that Consumers Power Company concludes to be inappropriate or unnecessary for incorporating into the fire plan.
In this letter the major aspects of the guidelines have been discussed. However, since the final fire plan has not
-been completed for Consumers Power Company, there will undoubtedly be other areas in which total conformance to the staff guidelines will not exist.
It is expected that the complete plan will be submitted for staff review by
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s October 1978'.
The plan will consist, in general, of the staff guidelines
- except for those areas delineated above. Upon completion of the fire plan, specific plant procedures will be formulated and implemented by February 1, 1979, assuming that the fire plan as written is acceptable to the staff.
O.
b William S Skibits Senior Licensing Engineer CC: JGKeppler, USNRC 6
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l REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
DISTRIBUTION FOR INCOMING MATERIAL u
" 2.55 REC: NRC ORG: SKIBITSKY W S DOCDATE: 06'19/7E NRC CONSLil1ERS PWR DATE RCVD: 06/21/78 DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED
SUBJECT:
LTR 1 ENCL 49 RESPONSE TO NRC LTRS OF FEE 6 & 14.
1978.
FURNISHING DETAILED EVALUATION OF "NUC PLAN T FIRE PROTECTION", FUNCTIONAL RESPONSIBILITIES, ADMINISTRATIVE CONTROLS, AND QUALITY ASSURANCE. ISSUED BY NRC.
PLANT NAME: BIO ROCK PT REVIEWER INI11 AL:
XJM PALISADES DISTRIBUTER INITIAL:
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DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS *************+****
FIRE PROTECTION INFORl1ATION (AFTER ISSUANCE OF OL).
(DISTRIDUTION CODE A006)
FOR ACTION:
BR CHIFF 'RB!!2 CC**W/S ENCL INTERNAL:
JG FIf -
J/ ENCL NRC PDR*+U/ ENCL
_ t-**W/3 ENCL OELDuLTR ONLY AUXILIARY SYS BR*&U/2 ENCL AD FOR SYS & PROJ**W/ ENCL PLANT SYSTEMS ER**W/5 ENCL WAMBACH u W/ ENCL R.
MURANKA**W/ ENCL HANAUER**U/ ENCL EXTERNAL:
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NRC-3031305-010 UNITED STATES ~ NUCLEAR REGULATORY COMMISS DDC MONTHLY ACCESSION LIST
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'04/01/78 - 04/30/78
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FILE LEVELS DOC. DATE 50-321 GEORGIA power & LIGHT COMPANY EDWIN I HATCH #1 S0 03/29/78 ACCESSION.NBR: 7e?94.-0187 TASK NBR:
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M DOCKET DATE:
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REPORT ~NBR.
RECP:
RECP AFFILIA ORG:
THOMAS C ORG AFFILIAT
SUBJECT:
SUMMARY
OF 03/21/78 MEE)ING TO DISCM PROGRAM AT THE SUBJECT FACILITY.
50 03/29/78 ACCESSION NBR: 78095-0014 TASK NBR:
321 DOCUMENT TYPE: LETTER FICHE NBR :
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WHITMER C F ORG AFFILIAU
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SUBJECT:
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- 321 DOCUMENT TYPE: LETTER FICHE NBR :
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SUBJECT:
RESPONSE TO NRC REQUEST OF 04/26/76c
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MONTH---IN-SERVICE INSPECTION PROGRAM 1978.
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