ML20003A669

From kanterella
Jump to navigation Jump to search
Forwards Rept Re Nuclear Plant Fire Protection Functional Responsibilities,Administrative Controls & Qa.Document Used by NRC as Supplemental Guidance for Review of Organizational & Administrative Aspects of Fire Protection Evaluation
ML20003A669
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 08/12/1977
From: Desiree Davis
Office of Nuclear Reactor Regulation
To: Bixel D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8102040647
Download: ML20003A669 (23)


Text

__

DISTRIBUTI0ii:

Docket NRC PDR Local PDR AUG 12 577 BRB-2 Reading Docket No. 50-155 EAReeves.

TVWambach RMDiggs 4 %

i

-i TJCarter

i Consumers Power Company DEisenhut sg ATTN
Mr. David Bixel WButler Nuclear Licensing Administrator Attorney, OELD 212 West Michigan Avenue I&E (3)

Jackson, Michigan 49201 JRBuchanan TBAbernathy Gentlemen:

ACRS (16)

RE: BIG ROCK POINT We are enclosing for your infonnation and use a copy of

" Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance." This document is presently being used by the NRC as supplemental guidance for the review of the organizational and administrative aspects of the fire protection evaluation of your facility.

Sincerely.

Don K. Davis, Acting Chief Operating Reactors Branch f2 Division of Opeating Reactors

Enclosure:

Nuclear Plant Fire Protection Functional Responsibilities, j

Administrative Controls and Quality Assurance cc w/ enclosure:

. r See next page

.c I

yf '

ornc=

  • 0 bR

_D0fL g EAReeves: esp..TVMmbach_

D1.a. is

.u_,,

8/ll77 8/pf77 Bll'lf2.7 om >

NRC PORM M8 (9 76) NRCM 0240 W u: s. oovs anusur emiwrewo orne s. esve - essene

t Consumers Power Company August 12, 1977 cc w/ enclosure:

Hr. Paul A. Perry, Secretary

.f Consumers Power Company

~

-t- ' 212 West liichigan Avenue Q[. Jackson, flichigan 49201 Charles F. Bayless 3 -

Of Counsel Consumers Power Company 212 West flichigan Avenue Jackson, Ilichigan 49201 George C. Freeman, Jr., Esquire Hunton, Williams, Gay and Gibson 700 East Main Street Richmond, Virginia 23212 Peter W. Steketee,. Esquire 505 Peoples Building Grand Rapids, Michigan 49503 Charlevoix Public Library 107 Clinton Street Charl evoix,' itichigan 49720

r

,b 6.

C

NUCLEAR PLANT FIRE PROTECTION FUNCTIONAL RESPONSIBILITIES,'ACMINISTRATIVE CONTROLS AND QUALITY ASSURANCE f!

The functional resoonsibilities, administrative controls, and quality

'* f assurance related to nuclear power plant fire protection programs have a significant role in preventing and fighting fires. Because these controls represent a significant portion of the licensee's fire protection program and are subject to periodic reviews by NRC inspectors, it is necessary to

' have a corren understanding between applicant / licensees, NRC reviewers, and NRC inspectors as to what constitutes adequate delineation of respon-sib,ilities, administrative controls and quality assurance and how these responsibilities and activities should be conducted. Therefore, supple-mentary guidance on these controls is desirable.

Appendix A to Branch Technical Position 9.5-1 and Regulatory Guide 1.120 provice overall guidance related to functional respor. ibilities, admin-istrative controls, and quality assurance. The di.cussion in the Attach-ments provides supplemental guidance on specific functional responsibilities, administrative controls, and quality assurance necessary to assure an The table below correlates each subject effective fire protection program.

for wnich supplemental guidance is provided with the respective section(s) of Appendix A and Regulatory Guide 1,.120.

REGULATORY t

" SUBJECT APPENDIX A GUIDE 1.120 1.

Fire Protection A.1, B, C C.1, C.2, C.3 Organization 2.

Fire Brigade A.1(d),B.5 C.1(4),C.2e Training 3.

Control of B.2,B.3(c)

C.2.b,C.2.c(3)

Comoustibles 4.

Control of Ignition B.3(a)

C.2.c(1)

Sources

5. -Fire Fighting A.1(d),8.1,4,5 C.la(4), (5),

C.2.a. d, e.

Procedures is C.3 6.

Quality Assurance C.

..~

St sW 9

=

W O

2-ts This supplementary guidance is to be given to utilities and is being i distributed to NRC fire protection program reviewers and NRC Office

!! of Inspection and Enforcement.

4r The licensee should provide the description of fire protection functional responsibilities and administrative controls in a fire orotection plan which describes his organization and its qualifications, fire brigade training, the controls over combustibles and ignition sources, methods for assuring the availability of the fire protection systets and equip-ment; procedures for fighting fires, fire watch, and quality assurance provisions for the fire protection program. The plan should also identify the plant procedures that implement the plan. The plan will be filed with the Nuclear Regulatory Commission and the plant procedures should be available to NRC Inspectors and at the plant site.

e St tr e

~

~.

E Attachment No. 1

. FIRE PROTECTION ORGANIZATION 1sl.0 The organizational responsibilities and lines of communication per-taining to fire protection should be defined between the various I

positions through the use of organizational charts and functional if descriptions of each position's responsibilities. As a minimum the positions / organizations responsible for the following should be designated:

~

The upper level.offsite management position which has management a.

responsibility for the formulation, implementation, and assess-ment of the effectiveness of the nuclear plant fire protection program.

The offsite management position (s) directly responsible "for b.

(1) formulating, implemencing, and periodically assessing the effectiveness of the fire protection program for the licensee's nuclear power plant including fire drills and training con-ducted by the fire brigade and plant personnel. The results of these assessments should be reported to the upper level management position responsible for fire protection with recommendations for improvements or corrective actions as deemed necessary.

Using the following NFPA Publications for guidance to dev-(2) elop the fire protection program:

" Organization for Fire Services" No. 4

" Organization of.a Fire Department" No. 4A

" Industrial Fire Loss Prevention" No. 6

" Management of Fire Emergencies" No. 7

" Management Responsibilities for Effects of No. 8 Fire on Operations"

" Private Fire Brigades" No. 27 The onsite management position responsible for the overall c.

administration of the plant operations and emergency plans which include the fire protection and prevention program and which provides a single point of control and contact for all contingencies.

b.

tr 5, h.

e i

\\

~

1;

~

(

2 d.

The onsite position (s) which:

minimize the amount implements periodic inspections to:

(1) of combustibles in safety related areas; determine the effectiveness of housekeeping practices; assure the avail-

-i ability and acceptable condition of all fire protection

~ 6' systems / equipment, emergency breathing apparatus, emergency

([

lighting, centunication equipment, fire stops, penetration seals and fire retardant coatings; and assures prompt and effective corrective actions are taken to corr'ect conditions adverse to fire protection and preclude.their recurrence.

is responsible for the fire fighting training for operating plant personnel and -the plant's fire brigade; desig (2) fire protection systems and equipment in accordance with established procedures and evaluate test results and deter-mine the acceptability.of the systems under test.

assists in the critique of all fire drills to determine (3) how well the training objectives have been met.

reviews and evaluates proposed work activities to identify

.(4) pote6tial' transient fire loads.

(5) ' implements a program for indoctrination of all plant contractor personnel. in appropriate administrative pro-

~

cedures which implement the fire protection program,.

and the emergency procedures relative to fire, protection.

implements a program for instruction of personnel on the (6) proper handling of accidental events such as leaks or spills of flammable materials that are related to fire protection.

The onsite position responsible for fire protection quality 4

e.

assurance.

This position should be responsible for assuring the effective in-

. implementation of the fire protection program by plannedHe shou spections and scheduled audits.that reaults of these inspectio ported to cognizant management personnel, t'l tr M

l

3 f.

The positions which are part of the plant fire brigade--

-(1) The plant fire brigade positions should be responsible for

_.f fighting fires. The authority and responsibility of each-

_ g fire brigade position relative to fire protection should

[

be c early defined.

'(2) The responsibilities of each fire brigade position should correspond with the actions required by the fire fighting p rocedures.

(3) The responsibilities of the fire brigade members under normal plant conditions, should not conflict with their responsibilities during a fire emergency.

(4) The minimum number of trained fire brigade members avail-able onsite for each rperating shift should be consistent with the activities rcquired to combat the most significant fire. The size of tne fire brigace should be based upon the functions required to fight fires with adequate allow-ance for injuries.

(S) The recommendations for organization, training, and equip-ment of " PRIVATE FIRE BRI.GADES" as specified in NFPA No. 27-1975, including the~ applicable NFPA publications listed in the Appendix to NFPA No. 27, are considered appropriate criteria for organizing, training, and operating a plant fire brigade.

2.0 Qualifications The position responsible for formulation and implementation a.

of the Fire Protection Program should have, within his organ-ization, or as a consultant, a Fire Protection Engineer who is a graduate of an engineering curriculum 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. These requirements are the eligibility requirements as a Member in the Society of Fire Protection Engineers.

m M

t I,fu 4

g a

we e

~,

~

  • 's t-4 b.

The fire brigade members qualifications should include satis -

factory completion of a physical examination for performing strenuous activity, and of the fire brigade trainingdescribed in Attachment No. 2.

e si c.

The personnel responsible for the maintenance and testing of the sr Fire protection Systems should be qualified by training and experience for such work.

d.

The personnel responsible for the training of the fire brigade should be qualified by training and experience for such work.

4 0

f-2* I fl.

g a

f 4

l achment No. 2 i

FIRE BRIGADE TRAINING The training program should assure that the capability to fight potential The program should consist of-an fires is established and maintained.

init'al classroom instruction program followed by periodic classroom ret aining, practice in fire fighting and fire drills:

1:%f-Classroom Instruction The ' initial classroom instruction should include:

'. a.

Identification of the fire hazards and associated types (1) of fires that could occur in the plant, er i an identi-fication of the location of such hazards.

(2)' Identification of the location of fire fighting equip-ment for each fire area, and familiarization with layout of the plant including access and egress routes to each area.

(3) JThe proper use of available fire fighting equipment, and The the correct method of fighting each type of fire.

types of fires covered should include electrical fires, fires in cables and cable trays, hydrogen firc., flam-mable ligdid, waste / debris fires, and record file fires.

Indoctrination of the plant fire fighting plan with (4) specific coverage of each individual's responsibilities.

The proper use of communication, lighting, ventilation (5) and emergency breathing equipment.

The direction and coordination of the fire fighting (6) activities (fire brigade leaders only).

The toxic characteristics of expected products of (7) combustion.

(8) The proper method for fighting fires inside buildings and tunnels.

Detailed review of fire fighting procedures and procedure (9) changes.

Review of latest plant modifications and changes in fire (10) j,[

fighting plans.

,w.

e

2 The instruction should be provided by qualified individuals knowledgeable, experienced, and suitably trained in fignting b.

the types of fires that could occur in the plant and in using the types of equipment available in the nuclear power plant.

"e

't d[

Members of the " Fire Protection Staff" and Fire Brigade Leaders

~L may conduct this training.

Instruction should be provided to all fire brigade members c.

and fire brigade leaders.

Regular planned meetings held every 3 months should repeat the classroom instruction program over a two year period.

d.

2.0 Practice Practice sessions should be held for fire brigade members on the proper method of fighting various types of fires of similar mag-These session; should provide brigade members a nuclear power plant.

with experience in actual fire extinguishment and the use of em-These ergency breathing apparatus under strenuous conditions.

practice sessions should be provided at regular intervals but not to exceed 1 year for each fire brigade member.

3.0 Drill _s Fire brigade drills should be performed in the plant so that the Drills should include the fire brigade can practice as a team.

following:

Assessment of fire alarm effectiveness, time required to notify and assembly fire brigade, and selection, placement and use of a.

equipment.

Assess each brigade member's knowledge of his role in the fire fighting strategy for the area assumed to contain the fire.

b.

Assess the brigcde members conformance with established plant fire fighting procedures and use of fire fighting equipment, including self-contained emergency breathing apparatus, connuni-cation equipment, and ventilation equipment, to the extent practicable.

It I.h3 O

l q

-- +

--9

'. : ~ '..

3 The simulated use of fire fighting equipment required to cepe I

c.

with the situation and type of fire selected for the drill.

The area and type of fire chosen for the drill should be varied

.f such that brigade members are trained in fighting fires in all

~

safety related areas containing significant fire hazards. The

-6

[

situation selected should simulate the size and arrangement

. of a fire wnich could reasonably occur in the area selected, allowing for fire development due to the time required to re-spond, to obtain equipment, and organize for the fire, assuming loss of-automatic suppression capability.

d.

Assessment of brigade leader's direction of the fire. fighting effort, as to thoroughness, accuracy, and effectiveness.

The drills should be performed at regular intervals but not" e.

to exceed 3 months for each fire brigade. At least one drill per year should be performed on a "back shift" for each fire brigade. A sufficient number of these drills, not less than one for each fire brigade per year, shall be unannounced, to de -

termine the fire readiness of the plant fire brigade leader, brigade, fire protection systers and equipment.

f.

The drills shoul.d be pre-planned to establish the training

'objecti es of the drill.

The drills should be critiqued to v

determine how well.the training objectives have been met.

-Unannounced drills should have their critiques performed'-by members of the management staff responsible for plant safety and security. At three year intervals, drills should be critiqued by qualified individuals independent of the utility's staff.

4.0 Records

, Records of training provided to each fire brigade mer.,ber including drill critiques should be maintained to assure tnat each member receives training in all parts of the training program.

These records of training should be tvailable for review.

5.

tr

,Iu.

  • ^

W e

+.

Attachment No. 3 i

i i

CONTROL OF CC:OUSTIBLES Administrative controls should be established to minimize th' e. amount of combustibles that a safety related area may be exposed to..These con-

,g.

trols should be established to govern:

the handling of and limi ation on the use of combustibles, a.

  • f flammable and explosive hazards sucn as flammable gases and liquids, HEPA and charcoal filters, dry unused ion exchange resins or other combustible supplies' in safety rel.ated_ areas,

~

and to assure that these items are not stored in safety related areas.

b.

the transient fire loads during maintenance and modifications such as combustible and flammable liquids, wood and plastic products, spilled oil, oil drums, and other combustibTe mater-ials in buildings containing safety related systems or equip-ment. This control should require an in-plant review of pro-posed work activities to identify potential transient fire loads. The onsite staff member designated the responsibility for reviewing work activities for potential transient fire loads should specify the required additional fire protection in the work activity procedure.

When the transient fire load causes the total fire load to exceed the capabilities of existing ' suppression systems and -

equipment, additional portable suppression equipment should be brought into the area.

c.

the removal of all waste, debris, scrap, rags, oil spills, or other combustibles resulting from the work activity, in the area following completion of the activity, or at the end of each work shift, whichever is sooner.

d.

periodic inspection for accumulation of combustibles.

e.

all wood used in safc'y related areas to assure that it is treated with flame retardant.

tr E7

  • w.

l

Attachment No. 4 CONTROL OF IGNITION SCURCES t

1.0 Administrative Controls Acministrative controls should be instituted to protect safety-related equipment from fire damage or loss resulting from work involving ignition sources, such as welding, cutting, grinding, or open flame work; acministrative controls should prohibit the use of open flam or combustion smoke for leak testing and c

' areas.

Control of Weldine. Cuttino. Grindinc. and Ocen Flame Worf 2.0 All cutting, welding, ' grinding or coen-flame work should ce authorized by the responsible foreman or supervisor a.

The responsible foreman or supervisor through a work perni t..should have received a basic industrial fire fichti prevention course covering anticipated fires, such as elec-trical, fires, fires in cables and cable trays, hydrogen fires, hydrocarbon fires, solvent fires, waste / debris fires, and re-

. cord file fires.

Before issuing the permit, the responsible foreman or supe'r-visor should physically survey the area where the work is to b.

be performed and establish that the following precautions have a

been accomplished:

All moveable combustible material below and within a 35 (1) foot radius of the cutting, welding, grinding, or open flame work has been removed.

(See NFPA 515)

All immovable combustible material below and within a 35 (2) foot radius has been thorougnly protected by asbestos curtains, metal gur-ds, or flameoroof covers, and fire extinguishers, hose, or other firefighting equipment are (See NFPA SlB) provided at the work site.

A fire watch trained and equipped to prevent and combat fires is present throughout any operations in which there (3) t<

is potential for fire that might damace safetyA fire watch snourc be prov

- r -

related equipment.

cutting, welding, grinding or open flame is performed

.c above or within a radius of 35 feet of any open cables, flammable liquids, scaffold boards, paper, rags, or other objects on the same elevation of the work or if combustible materials are below the work area whereA fi openings exist.

i

2 cutting, welding, grinding, and open flame work in the Control Roem, Cable Spreading Room, Diesel Generator Rooms, and other safety related areas that contain sig-nificant amount of cable or fla:nnable liquids.

(See NFPA SlB)

The fire watch sould remain on the work site while work is perfonned and remain in the area for at least 30 min-utes after the work is completed to check for smoldering fi res.

(4) All equipment to be used is in a safe, working condition.

Oxyacetylene equipment is checked for leaks before being moved to the work area.

c.

The signature concurrence of a member of the plant's management or a quality control inspector certf fied to make this concurrence should be obtained whenever the supervisor or foreman determir.as that a fire watch is not required.

3.0 Leak Testina Administrative procedures should be established to prohibit the use of.open flame or'comoustion smoke for leak testing. 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.

4.'O Smokinc and Icnition Source Restriction Smoking should be prohibited in safety related areas, except where

" smoking permitted" areas have been specifically designated by a responsible member of plant management and in areas containing flammable or potentially explosive materials or atmospneres tnat present a hazard to safety related equipment. These areas should be identi-fied with "No Smoking" signs.

tc i

Att..nment No. 5 FIRE FIGHTING PROCEDURES 1

I u& ire fighting procedures should be established to cover such items as

{$otificationofafire,fireemergencyprocedures,andcoordinationof fire fighting activities with off site fire departments. The fire fight-

'ing procedures should identify:

Actions to be taken by individual discovering the fire, such a.

as, notification of control room, attempt to extinguish fire, and actuation of local fire suppression systems.

b.

Actions to be taken by the control room operator and the need for brigace assistance upon report of a fire or receipt of announcing alarm on control room annunciator panel, such as:

location of fire over PA system, sounding fire alarms and notifying the shift supervisor and the fire brigade leacer of the type, size, and location of the fire.

Actions to be taken by the fire brigade after notification by c.

the control room operator of a fire, including:

location to assemble; ci,rections given by fire brigade leader; and responsi-bilities of brigade members such as selection of fire fighting equipment and transportation to* fire location, selection of protective equipment, use of fire suopression systems operating instructions, and use of preplanned strategies for fighting

-fires in specific areas.

d.

The strategies established for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment. As a minimum the following subjects should be covered:

(1) Icentification of combustibles in each plant rene covered by the specific fire fignting procedures.

(2) Fire extinguishants best suited for controlling the fires associated with the coccustible loadings in that zone and the nearest location of these extinguishants.

(3) 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 v.

fire-free, and the best station or elevation for fighting

. r A specific identification system shall designate the fire.

=c all hallways, stairs, doors, fire equipment and system '

control locations, and other items described in the fire fighting procedures. This identification should be used em

-e-.-

m y

y

-s w

,,-w--

+

e

--+e w-

\\

1 2

in the procedures and the corresponding plant iteds should be prominently marked so that they can be recogni:ed in All access and egress routes that involve i

dim light.

locked doors should be specifically identified in the

[

procedure with the appropriate precautions and methces gr for access specified.

Jesignation of plant systems that shculd be managed to (4) reduce the damage potential during a local fire; location of local and remete controls for such management (e.g.,

any hydraulic or electrical systems in the :one cevered by the specific fire fignting procedure that culd increase the ha:ards in the area because of overpres-suri:ation er electrical ha:ards).

(5) Designation of vital heat-sensitive system components that should be kept cool while fignting a local fire.

Critical equipment which are particularly ha:ardous combustible sources should be designated to receive cooling.

Organi:ation of fire fighting brigades and the assignment (5) of special duties acc:rding to jcc title so that all fire fighting functions are covered by any ccmplete shift per-control of the brigade, fire hose laying, applyi,ccmmand sonnel complement. These. duties shculd include ng the extinguishant to the fire, advancing su: cort supplies to the fire scene, communication with the control recm, coordination with cutside fire departments.

(7) Identification radiological and toxic ba:ards in fire cnes.

(3) Ventilation system cperation that assures desired plant pressure distribution when the ventilation flew is mccified for fi:e containment or smoke clearing operations.

(9) Operations requiring control rece and shift engineer coordination or autnerization.

(10) Instructions fer plant operators and general plant per-sonnel during fire.

The validity of the preplanning strategies shoulc be tested by 2!

e.

appropriate full-dress drills to check the logic of the

[,

strategy, the adequacy of the equipment, personnel under-standing, and to uncover unforeseen problems.

==

^

a f.

Actions to be taken by Plant Superintendent and his itaff, and Security Guards after notificati,n of a fire.

i Actions to be taken that will coordinate fire fighting activities

-a g.

d[

with offsite fire departments, including:

identificat.cn of individual responsible for assessing situation and calling in outside fire department assistance when needed; identification of individual who will direct fire fighting activities when aided by offsite fire fighting assistance; provisions for including offsite fire fighting organizations in fire brigade drills at least once per year; and provisions for training offsite fire decartment personnel in basic radiation principles, typical radiation hazards, and precautions to be taken in a fire involving radioactive materials in the plant. The pro-cedures should also describe the offsite fire department's resources and estimated response time by tne offsite fire department to provice assistance to the station.

e h

e e

b'

  • l F

G l

Attachment No. 6 i

QUALITY ASSURANCE 2 y

'I

[

t -

T 4]he quality assurance (QA) program should assure that the requirements

,for design, procurement, installation, testing, anc administrative controls for the fire protection program for safety related areas approved by NRC are satisfied. The Quality Assurance provisions fo:-

fire protection should apply to activities performed after the effective date of the adoption of said provisions. The QA program should be under the management control of the QA organization. This control consists of (1) formulating and/or verifying that the fire crotection QA program incorporates suitable requirements and is acceotaole to the management responsible for fire protection and (2) verifying the effectiveness of the QA program for fire prettetion through review, surveillance, and audits. Performance of other QA program functions for meeting the fire protection program requirements may be performed by pers0nnel outsioc of the QA organization. The QA program,for fire protection should br. part of the overall pi;nt QA program. These QA criteria apoly to those items within the scope of the ' fire p*otection program, such as fire protection systems, emergency lighting, communication and emergency breathing aoparatus as well as the fire protection requirements of applicaole safety related equipment.

Applicants / licensees can meet the fire protection quclity 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 commitment 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. Supplemental guidance is provided below on acceptable measures for implementing each of the fire protection ~QA program criteria of Appendix A to BTP 9.5-1 or Regulatory Guide 1.120.

1.0 Design Control and Procurement Document Control - Measures should be established to assure that the applicable guidelines of the Regulatory Guide 1.120 or approved NRC alternatives are 1ncluded in tr design and procurement documents and that deviations therefrom are Op controlled. These measures should assure that:

a.

Design and procurement document changes, including field changes and design deviations are subject to the same level of controls, reviews, and approvals that were applicable to the original i

i document..

i

~

2-b.

Quality stendards are specified in the design documents such as appropriate fire protecticn codes and standards, and dekiations and changes from these quality standards are controlled.

k c.

New designs and plant modifications, including fire protection

- t, systems, are reviewed by qualified personnel to assure inclusion y

of appropriate fire protection requirements. These reviews should include items such as:

(1) Design reviews to verify adequacy of wiring isolation and cable separation criteria.

(2) Design reviews to verify appropriate requirements for room isolation (sealing penetrations, floors, and other fire barriers).

d.

A review and concurrence of the adequacy of fire protection requirements and quality requirements stated in procurement documents are performed and documented by qualified personnel.

This review should determine that fire protection requirements and quality requirements are correctly stated, inspectable and controllable; there are adequate acceptance and rejection criteria; ande the procurement document has Men prepared, re-viewed, ?nd approved in accordance with QA program requirements.

2.0 Ins tructions, Procedures, and Drawing - Inspectit.,ns, tes ts, admin-istrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructions,

~

procedures or drawings and should be accomplished in accordance with these documents. The following provisions should be included.

a.

Indoctrination and training programs for fire prevention and fire fighting are implemented in accordance with documented procedures.

b.

Activities such as design, inst' llation, ins;:ection, test, a

maintenance, and modification of fire protection systems are prescribed and accomplished in accordance with documented in-structions, procedures, and drawings.

c.

Instructions and procedures for design installation, inspec-tion, test, maintenance, modificatien and administrative controls are reviewed to assure that proper inclusion of fire protection requirements, such as precautions, control of ignition sources and combustibles, provisions for backup fire protection of the

[-

activity requires disabling a fire protection system, and re-1 striction on material substitution unless specifically per:nitted by design and confirined by design review.

4'

-~~

~

3 d.

The installation or application of penetration seals and fire retardant coatings is performed by trained personnel using approved procedures.

3.0 Control of Purchased Material, Equipment, and Services - Measures

.%'t s hall be established to assure that purchased material, equipment

-L and services conform to the procurement documents. These measures i[

should include:

a.

Provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnishad by the contractor, inspections at suppliers, or receiving inspections.

b.

Source or receiving inspection, as a minimum, for those items whose quality cannot be verified after installation.

4.0 Inspection - A program for independent inspection of activities affecting fire protertion should be established and executed by, or for, the organi:ation performing the activity to verify conformance to documented installation drawings and test procedures for accomplishing activities. This program should include:

a.

Inspections of (1) installation, maintenance and modification of fire protection systems; and (2) emergency lighting and communica-tien equicment to assure conformance to design anc installation recuirements.

b.

Inspecti.on of penetration seals and fire retardant coating installations to verify tne activity is satisfactorily completed.

c.

Inspections of cable routing to verify conformance with design requirements.

d.

Inscections to verify that a:cropriate recuirements for room isolation (seal-:ng penetrations, ficers, and other fire barriers) are accomplished during ccnstruction.

e.

Measures to assure that inspection personnel are inde:endent frem the indivicuals performing tne activity being inspected and are knowledgeable in the design and installation requirements for fire protection.

f.

Inspection procedures, instructions, and check lists which provide for the following:

c 7'

(1) Identification of characteristics and activities to be inspected er

'_ '~~

(2) Identification of the individuals or groups responsible for performing the inspection operation (3) Acceptance and reje'etion criteria

1 s

4 (4) A description of the method of inspection

=g (5) Recording evidence of completing and verifying a manu-1 facturing, inspection or test operation

-Ey (6) Recording inspector or data recorder and the results of the inspection operation g.

Periodic inspections of fire protection systems, emergency br'eathing and auxiliary ecuipment, emergency lighting, and communication equip-

. ment to assure the acceptable condition of these items.

h.

Periodic inspection of materials subject to degradation such as fire stops, seals, anc fire retardant coatings to assure these iter.s have net deteriorated or been damaged.

5.0 Test and Test Control - A test program should be established and implemented to ensure that testing is performec and verified by inspectica and audit to demonstrate conformance with design ano system readiness repuirements.

The tests shoulc be performed in accordance with written test procedures; test results should be properly evaluated and acted on.

The test program shoulc include the folicwing: [

a.

Installatien Testing - Folicwing construction, modification, re: air or reclacement, sufficient testing is performed to demonstrate that fire protection systems, emergency lighting and c:mmunication equip-ment will perform satisfactorily in service and that design criteria are met. Written test procedures fer installation tests incorporate the requirements and acceptance limits contained in applicable design dccuments, b.

Periodic testing - The schedules and methods for periodic testing are developed and documented.

Fire protection e:uipment, emergency lignting, and c:mmunica. ion epuipment are tested periedically to assure that the equipment will properly function and continue to meet the design criteria.

~

c.

Programs are established for QA/QC to verify testing of fire protection systems and to verify that test personnel are effectively trained.

d.

Test results are documented, evaluated, and their acceptability

]:

determined by a qualified responsible individual or group.

U 6.0 Inspection, Test, and Operating Status - Measures should be established to provide for the identification of items tnat have satisfactorily passed required tests and inspections. These measures should include provisions for:

a.

Identificatier. by means of tags, labels, or similar temporary markings to indicate completion of recuired inspections and tests, and operating status.

,g 4

O

,.s n

e w-_

g

~. - - -

1 s

5-Nonconforming Items - Measures should be established to c"Ontrol items 7.0 that do not conform to specified requirements to prevent inadvertent

.b

_[

use of installation. These measures should include provisions to

?-

assure that:

sf Nonconforming, inoperative, or malfunctioning fire protection a.

systems, emergency lignting, and communication equipment are appropriately tagged or labelled.

The identification, documentation, segregation, review dis-b.

position, and notification to tne affected organization of nonconfcrming materiuls, parts, components, or services are procedurally controlled.

Documentation identifies the nonconforming item, describes the c.

nonconformance and the disposition of the none nforming item and includes signature a;preval of the disposition, Provisions are established identifying those individuals or d.

groups delegated the responsibility and authority for the disposition and approval of nonconforming items.

Action - Measures sh'all be established to ensure that cen-8.0 Corrective ditions adverse to fire protection such as f ailures, =alfunctions, deficiencies, deviations, defective c mponents, uncontrolled c:mous-tible material and nonconformances are pr mptly identified, reported and corrected. These measures should assure:

Procedures are established for evaluation of c:nditions adverse a.

to fire protection (sucn as nonconformance, failures, mal-functions, deficiencies, deviations, and defective material and ecuipment) to determine the necessary corrective action.

In the case of significant or repetitive conditions adverse b.

to fire protection, including fire incidents, the cause of the conditions is determined and analyzed, and prompt corrective actions are taken to preclude recurrence. The cause of the condition and the corrective action taken are orceptly reported to cognizant levels of management for review and assessment.

- Records should be prepared and maintained to furnish

~9.0 Records

'?

evicence that tne criteria enumerated aeove are being met for The follcwing activities affecting the fire protection program.

provisions should be included:

!,)

Records are identifiable and retrievable and should demonstrate s.

conformance to fire protection requirements. The records should a.

. - - ~ - -

6 include 3 2,ults of inspections, tests, reviews, and audits; non-conformance and corrective action reports; construction, maintenance and modification records; and certified manufacturers' data.

U b.

Record retention requirements are established.

  • f ICL,0 Audits

- Audits should be conducted and documented to verify compliance with the fire protection program, including design and procurement documents, instructions, procedures, and drawings, and inspection and test activities. The following provisions shoulc be included:

Audits are periodically performed to verify compliance with the a.

administrative controls and implementation of quality assurance criteria including design and procurenent, instructions, procedures and drawings and inspection and test activities.

These audits are performed by QA personnel in accordance with preestablished written procedures or check lists and conducted by trained personnel not having direct responsibilitie5 in the areas being audited.

Audit results are documented and then reviewed with management b.

having responsibility in the area audited.

Followuo action is taken by responsible management to correct the c.

deficiencies revealed by the audit.

d.

Audits are annually performed to provide an overall assessment of conformance to fire protection recuirements.

e t.

T il ^

9 m.

O e4 9

_ am e-

- -