ML20023A378
| ML20023A378 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/13/1978 |
| From: | Moody D VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| WVY-78-93, NUDOCS 7810200090 | |
| Download: ML20023A378 (2) | |
Text
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VERMONT YAN KEE NUCLEAR POWER CORPORATION SEVENTY SEVEN GROVE STREET RUTLAND VEMMONT 05701 REPLY TO:
ENGINEERING OFFICE TURNPIKE RQ Ao WESTBoRO. M ASS ACHUSET rs 0 7 581 TELEPHONE 697-366 901i B5.3.2 WW 78-93 October 13, 1978 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Office of Nuclear Reactor Regulation T. A. Ippolito, Chief Operating Reactors Branch 3 Division of Operating Reactors
References:
a) License No. DPR-28 (Docket No. 5'0-271) b)
WNPC Letter (WW 78-74) to T. AhIppo'lito from D. E. Moody, dated August 14, 1978,
Subject:
Fire Brigade Manpower Requirements and Prefire Strategies c) USNRC Letter to R. H. Groce from T. A. Ippolito, dated August 9, 1978,
Subject:
Staff Positions on Fire Protection Administrative Controls q
d)
WNPC Letter (WW 78-86) to T. A. Ippolito from
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D. E. Moody, dated September 7, 1978,
Subject:
Fire Q Eg
,g Protection Program Administrative Controls a
e) USNRC Letter to R. H. Groce from R. W. Reid, dated eq
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~1 CJ Protection Functional Responsibilities, AdministraElve rij Controls and Quality Assurance RE
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Dear Sir:
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Subject:
Fire Brigade. Drill Schedule Reference c) above transmitted to us a staff position that fire drills should be performed at regular intervals but not to exceed three months for "each" fire brigade. At least one drill per year should be performed on a "back shif t" for "each" fire brigade. A sufficient number of these drills, not less than one for "each" fire brigade per year, shall be unannounced, to determine the fire readiness of the plant fire brigade leader, brigade, fire protection systems and equipment.
The staff concern leading to the promulgation of that position was that the proposed f requency for fire brigade drills did not provide adequate training to assure brigade members can function effectively as a team in the use of fire fighting equipment and tactics to suppress fires manually.
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Unittd States Nuclear Regulatory Connaission Octobsr 13, 1978
- Attention: Office of Nuclear Raactor Regulation Paga ho We have reviewed the concerns expressed by the staff and have slightly modified our proposal for drill scheduling and frequency.
l We agree with the staff that drills are necessary to assure that j
fire brigade members can function effectively as a team on the use of fire fighting equipment and tactics to suppress fires manually. We disagree, l
however, with the staff contention that four drills per brigade per year i
are necessary and that they should be held quarterly. We feel that our
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modified proposal, will adequately drill brigade members and, answers the i
concerns of the staff. In making this proposal, we are assuming that l
Reference b) above, which addressed fire brigade size, composition, and i
training has been accepted, although we have received no notice of that j
acceptance.
i Wrmont Yinkee proposes to provide two drills per year for _each operating shift fire brigade. As we have five operating shifts, this would provide a total of ten drills per year. ' One drill will be provided on the j
back shif t for each brigade and one drill will be unannounced for each brigade. One drill of the ten held each year will be held with the-i participation of the Town of Wrnon Fire Department.
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The drill program outlined by your staff in Reference'e) which seems to be the basis for four drills has two basic goals. First, to assess the 4
l overall training and effectiveness of the Fire Brigade Training Program and, second, to assess the effectiveness and availability of fire fighting j
equipment. The insistence on any set number of drills per fire brigade i
each year does not insure the accomplishment of these goals. We are unaware j
of any National Fire Protection Association documents which even recommend
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a set number of drills to be held by an industrial fire brigade. These documents, in particular (NFPA 27-Private Fire Brigades, NFPA Fire Protection j
Handbook,14th Edition, and Training Manual for Industrial Fire Brigades)
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emphasize the need for drills but do not prescribe any periodicity.- Wrmont Yankee feels that ten drills / year will provide ample review of the brigade j
performance to assure that brigade training goals are being met.
All drill critiques will be reviewed by the entire brigade and thus all brigade members I
will learn from the drills. This is the same sound philosophy which is l
applied to site emergency drills which are only required once each year.
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In summary, Wrmont Yankee feels the insistence on four drills for each brigade each year is arbitrary and unnecessary.
Wrmont Yankee plans -
to institute a program of two drills per brigade each year which, combined with the existing training program, will provide a more than adequate fire l
b rigade.
4 We trust that this proposal will, af ter your careful review of our l
bases, meet with your approval. We intend to' implement it starting with our next training cycle.
I Wry truly yours, NERMONT YANKEE NUCLEAR POWER CORPORATION i
6 Donald E. Moody l
Manager of Operations
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