ML20054J261

Forwards Info Clarifying Fire Protection Program,Including Personnel Qualification & Training & Revised Response to Question 420.39,reflecting Mgt Procedural Changes

ML20054J261
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/21/1982
From:	James Smith LONG ISLAND LIGHTING CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.033, RTR-REGGD-1.033 SNRC-718, NUDOCS 8206280379
Download: ML20054J261 (16)

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LONG ISLAND LIGHTING COMPANY

1. 44'O w SHOREHAM NUCLEAR POWER STATION

,, - . m.s P.O. BOX 618, NORTH COUNTRY ROAD + WADING RIVER, N.Y.11792 June 21, 1982 SNRC-718 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322

Dear Mr. Denton:

Enclosed herewith are sixty (60) copies of information which amplifies and clarifies information previously provided in our letter SNRC-658. These changes clarify details relative to qualifications and training of personnel providing or supporting the fire protection program.

Also included are sixty (60) copies of a revised response to NRC Question 420.39. The original response was made in June 1980.

This response has been revised to reflect changes in management organization and to better correspond to the latest wording of the station procedures covering fire protection.

Revisions since SNRC-658 have been identified with a bar in the right hand margin. Please note that these revised pages are not intended to represent an FSAR rewrite of the sections, but are made ,

to clarify points arising from discussions of SER Item No. 52,

" Management Review". The complete scope of changes to the FSAR sections will be forwarded via a formal FSAR amendment in July.

In addition to the above, LILCO commits to comply with the guidance contained within Regulatory Guide 1.33, Revision 2 dated February, 1978 with the following clarifications: e

a. The requirements established by ANSI N18.7-1976, paragraphs 4.3, 4.4 and 4.5 shall be governed by commitments made in Section 6 of Shoreham's Technical Specifications,

b. ANSI N18.7-1976, paragraph 5.2.2(2) is intended to apply to procedural steps such as immediate #f)gjol actions in Shoreham Emergency Procedures.

8206280379 820621 DR ADDCK 05000322 PDR FC-893 5

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June 21, 1982 '

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SNRC-718 ,

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c. In reference to ANSI N18.7-1976, paragraph.5.2.13.~2, the LILCO QA Manual allows and controls-the release of certain specific nonconforming items, which could  ;

be caused by documentation deficiencies, to be

• installed but not operated. The conditional release does.not change _the documentation requirement,'but allows for installation prior to all required docu- '

mentation arriving on site.

Based on the information contained in and attached to this letter, i LILCO feels that SER Item.52 can now be closed. Should you have any questions, please contact this office.

Very truly yours, J. L. Smith Manager, Special Projects Shoreham Nuclear Power Station RSII:mp Attachments cc: 'J. liiggins All parties V

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13.2.1.2.4 Training for Maintenance Personnel Personnel assigned to the Maintenance section possess a high degree of manual dexterity and ability and are determined to be capable of learning and applying basic skills in maintenance operations through entry level testing. Personnel assigned to supervisory positions have, as a minimum, three (3) years experience in one or more crafts. All maintenance personnel participate in the Mechanic Training Program which consists of the following segments:

1. Maintenance Skills Training

2. Power Plant Training

3. Advanced Mcchanic Training The Maintenance Skills Training Course is 12 weeks in duration and consists of classroom and laboratory instruction in basic mechanic skills, shop mathematics, millwright skills, machinist skills, uolding skills, and basic electricity. Satisfactory student performance is documented through the administration of oral or wri tten examinations, or observance of skills development by a qualified instructor. The Maintenance Skills Training Program is administered by The Long Island Lighting Company.

The Power Plant Training Course is approximately 4 weeks in duration and consists of classroom training in Station procedures related to maintenance, Station administrative policies and documents, and SNPS Systems Familiari?.ation Training. Also provided is on-the-job training which includes the performance of preventive maintenance or maintenance repair on plant systems during the preoperational test program (initial staff only).

Evaluation of participant performance during this segment is through use of either written examinations, oral examinations, or supervisory observance of satisfactory skills development.

Advanced mechanic training consists of vendor supplied training in the maintenance and repair of particular plant systems and components. Examples of such short duration courses are; DeLaval Diesel Maintenance, Recirculation Pump Seal Maintenance, Target Rock Relief Valve Maintenance, Control Rod Drive Maintenance, et al. Courses range in duration from 1 to 10 days and may be administered by the equipment vendor or qualified Long Island Lighting personnel. Student performance in the courses listed may be evaluated through instructor observance of satisfactory skills development.

The three segments of training described in detail above will qualify these personnel to perform normal maintenance on plant equipment including fire protection equipment maintenance and inspection.

13.2.1.2.4.1 Rgqualification Training for Maintenance Personnel Requalification training for maintenance personnel consists of refresher training associated with the General Employee Training Program and periodic supervisory led reviews and discussions of the following topics:

1. Scheduled and completed maintenance courses

2. Scheduled maintenance (rehearsals)

3. Completed maintenance (review)

In addition, all maintenance personnel will participate in a continuing program of self study of the following materials:

1. New or revised SNPS procedures related to maintenance

2. Descriptions of plant modifications related to maintenance

3. Event and experience reports related to mTintenance Requalification training exists on a continuous basis and includes supervisory review of the program components described above.

1 13.2.1.2.5 Training for Fire Protection Staff Members Personnel responsible for the implementation of the Station Fire Protection Program will receive Fire Brigade Training (as described in Section 13.2.1.2.6 below) and Fire Protection Technology Training. Both programs will be taught by plant training staff with assistance from suitable vendors. Fire Protection Technology Training will include the following topics:

1. Station building layout and fire protection cystem design.

2. Design of and maintenance on fire detection, suppression, and extinguishing equipment.

3. Fire prevention techniques and procedures.

13.2.1.2.6 Training for Fire Brigade Members Personnel who make up the Station Fire Brigade will be trained via a program of classroom instruction, practice sessions, and drills prior to their official assignment to the Fire Brigade.

The training vill be provided by qualified individuals knowledgeable and experienced in fighting the types of fires that

could occur in the plant and in using the types of equipment availabic at Shoreham. The classroom phace will be taught by plant training staff in conjunction with Suffolk Country Fire Training Center and suitable vendors and will include the following topics:

1. Fire hazard identification by location and fire type, including locations where breathing apparatus is required.

2. Familiarization with plant layout, including routes for ingreso and egress as well as locations of all fixed and portable fire fighting equipment.

3. Methods and equipment appropriate to each type of fire, including electrical fires, cable and cable tray fires, hydrogen fires, flammable liquid fires, waste / debris fires, and record file fires.

4. Indoctrination in the Plant Fire Protection' Program.

Each Fire Brigade member will be trained to accomplish any of the positions of responsibility under Brigade Leader. This approach provides the flexibility necessary in a small brigade of varying membership.

The actual assignment of specific duties will be made on the spot by the Brigade Leader.

5. Proper use of respiratory protection, communication, lic;hting and portable ventilation equipment.

6. Review of the plant Pre-fire Plans, which identify the preferred fire fighting equipment to be used in each specific identified fire hazard area. Training will also include a revicu of proper equipment and procedures to be used for the balance of the site.

7. Review of pertinent modifications, additions, or changes to the Plant Fire Protection Plan or fire fighting equipment.

8. Methods for fighting fires in buildings or tunnels.

9. Toxic and corrosive characteristics of expected combustion products.

10. Station evacuation signals and routes.

Practice sessions will be held at the Suffolk County Fire Training Center and will allow Fire Brigade members to train on actual fires. Each Fire Brigade member will attend at least one practice session per year and will don protective equipment (including respiratory protection) at 1 cast once per year.

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Preplanned drills will be performed at least once per three months for each Fire Brigade, with each Fire Brigade member attending a minimun of two dril]s per year. At least one of these drills per year, per Fire Brigade, will be unannounced. At least one of these drills per year per Fire Brigade, will be on a backshift. At least one drill per year will involve the participation of the Wading River Fire Department onsite.

The drills will conform to the established plant fire fighting plans where possible and will include operating fire fighting equipment where practical. The drill should include on site operation of self-contained breathing apparatus, communication equipment, and portable and/or installed ventillation equipment.

The drills will be critiqued in order to assess fire alarm effectiveness, response time and equipment selection, placement, and usage, a well as the leader's direction of the effort and each member's response. Unsatisfactory drills shall be repeated within 30 days.

13.2.1.2.6.1 Fire Brigade Refresher Instruction All Station Fire Brigade personnel will be provided with at least four sessions of refresher instruction each year. These will be scheduled such that the topics will be repeated at least every two years, with appropriate updates in the detailed course material.

13.2.1.2.7 Fire Brigade Chief Trajning Candidates for the position of Fire Brigade Chief will receive appropriate training. This training will include Fire Brigade Training (as described in Section 13.2.1.2.6), and Fire Brigade Leadership Training, designed to teach direction and coordination of fire fighting activities. Both programs will be taught by plant training staff with assistance from suitable vendors.

13.2.1.2.8 shift Technical Advisor Training Personnel assigned as Shift Technical Advisors participate in an integrated program of theoretical and practical instruction. The components of this program are the following:

1. Basic theory

2. Plant specific theoretical training

3. Plant systems / procedures training

4. Plant accident / transient analysis training

5. Mitigating core damcge training C. ?lanagerentzSupervisor nkills training

The Basic Theory training segment consists of university level course. work. presented by the, Polytechnic Institute of New York or.

similar accredited institutions. Courses are offered on the graduate level and are presented to those candidates who have not received previous university level instruction related to the following topics:

1. Basic fundamentals of nuclear and reactor engineering

2. Radiation protection

3. Thermodyn6mics

4. Heat transfer

5. Principles of fluid mechanics Courses are presented in a classroom instructional format with written examinations used to measure student performance.

Plant specific theoretical training is provided'in the form of The General Electric Station Nuclear Ungineer Training Course.

The course is S weeks in duration and consists of classroom instruction in fuel' loading, startup testing, power distribution j control, fuel exposure, isotopic' content, cycle length

! . predictions and discharge requirements. Student performance.is -

i evaluated through the administration of-mid course and final written examinations.

I Plant systems / procedures training consists of classroom instruction in SNPS specific systems and procedures. ' Included as i instructional topics are:

1. Nuclear Steam Supply Systems and their operation

2. BWR steam cycle systems and their operation

3. Station general operating procedures .

f 4. Station general administrative procedures ,

! The course is 8 weeks in duration, i.s administered by SNPS

personnel-and uses periodic written examinations as the means for evaluating student performance.

l Shift Technical Advisor candidates are provided with accident /

transient analysis training'through participation in a 4 week simulator' training course. The initial course is provided by the

, General Physics Corporation utilizing the Limerick Simulator Facility. Basic plant operations including plant startup and chutdown will be demonstrated. In addition, Shift Technical

!- - ndvisor candidates will observe various plant accident and~

transient scenarios concurrently with the examination of the technical aspects of each event in the classroom. Evaluation of i

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student performance will be accomplished through the administration of written and oral examinations.

Training in methods for mitigating core damage for Shift Technical Advisors is described in section 13.2.1.2.9.

Each Shift Technical Advisor candidate will participate in a one week management / supervisory skills course presented by the Long Island Lighting Company or qualified vendor. The course will include training in techniques associated with leadership, motivation, proble.m solving, decision making, and organizational management under stress. Evaluation of student performance in this course will be accomplished through che administration of written and/or oral examinations.

13.2.1.2.8.1 Shift Technical Advisor Requalification Training The Shift Technical Advisor Requalification Training Program is tuo (2) weeks in duration and is administered annually by the Long Island Lighting Company or qualified vendor. The program consists of a pne week classroom segment and a one week simulator segment. The classroom segment includes presentations related to the following topics:

1. A review of plant transient and accident analysis emphasizing the Shift Technical Advisor's role in accident assessment

2. A review of plant related industry and licensee event reports

3. A review of major plant modifications and procedure changes affecting the Shift Technical Advisor position.

The simulator training segment will consist of control manipulations and observance of plant transient / accident response. The simulator training segment will be conducted on the Limerick simulator or an equivalent facility.

• Written examinations will be administered annually to provide a basis for determining Shift Technical Advisor knowledge and to assist in defining topics for which additional training is required.

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13.2.1.2.9 Tra ining for Mitigating Core Damage The Mitigating Core Damage Training Program provides shift Technical Advisors and ope-ating personnel, from the Plant Manager through the operations chain to licensed operators, instruction related to degraded core recognition and methods for recovery from the degraded core condition. Managers and technicians in the instrumentation and control, health physics, and radicchemistry sections will participate in the program to a degree commensurate with their responsibilities. The course is one week in duration and is administered by the Long Island l Lighting Company, The General Electric Company, or other

qualified organizations. The course serves to draw together specific concepts and is considered the second phase of a two phase program. The first phase consists of participation in selected portions of those programs which constitute the Licensed Operator Training Program (13. 2.1.1 ) . The follouing course components are included

1. Core cooling mechanics / accident recognition: topics included are; adequate core cooling, heat sources, core cooling mechanisms, and inadequate core cooling recognition.

2 Core damage mitigation: topics included are; fixed / movable nuclear instrument use, degraded core effects on coolant chemistry, process instrument response, corrosion effects, gas generation sources.

and accident environment dose determination.

3. Core transient identification and damage mitigation through use of emergency procedure guidelines.

The course is administered in a standard classroom format accompanied by instructor guided procedural walk-throughs.

Evaluation of student performance is accomplished through administration of written examinations and instructor evaluation of student use of procedural guidelines.

13.2.1.2.10 Training for Support Engineering Personnel Support engineering personnel are assigned based on previous academic training and experience related to the assignment.

Following assignment, personnel participate in the following additional programs to a degree commensurate with responsibility.

1. General Employee Training (when rcsigned to the plant site)

2. Plant systems familiarization training The General Employee Training Program is described in section 13.2.1.3.

Plunt systems familiarization training for support engineering personnel is accomplished through participation in selected portions of the licensed operator training program (13.2.1.1.5),

or the Shift Technical Advisor Training Program (13.2.1.8) associated with plant systems. The degree of participation in these classroom programs is based on the systems familiarization needs of each individual to complete particular job assignments.

13.2.1.2.10.1 Requalification Training for Support Engineering Personnel Requalification training for support engineering personnel will consist of refresher training associated with the General Employee Training Program (13.2.1.3) and self study of the following materials:

1. New or revised SNPS procedures related to Uupport Engineering Staff assignments or responsibilities

2. Descriptions of plant modifications requiring review by the Support Engineering Staff

3. Event and operating experience reports requiring review by the Support Engineering Staff Requalification training will exist on a continuous basis and will includc supervisory review of the self-study program described above.

13.2.1.3 General Employee Training The SNPS General Employee Training Program provides general plant and Station orientatior, information to Long Island Lighting Company employees (permanent and temporary), contracted employees, and visitors, so that they are able to complete a wide range of general tasks in a safe and competent manner. The General Employce Training Program is divided into three categories to best fit the needs of all personnel assigned to the Shoreham Nuclear Power Station. These categories are:

1. Permanent station personnel

2. Temporary station personnel

3. Contracted personnel Each listed category participates in the General Employee Training to the extent warranted by position or assignment. The complete program includes the following topics:

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1. . General description of the station and facilities i

I 2. Station Security Program and procedures

, 3. Station Fire Protection Program, including evacuation

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routes and signals, fire and fire hazard reporting, and basic. fire fighting equipment.

4. . Radiological health'and safety including applicable

portions of 10CFR 19 and 10CFR 20 1

-5. Quality assurance

6. Industrial health.and safety j 7. Station emergency plan and implementing procedures The General Employee Training Program is presented in modular form by.Long Island Lighting Company personnel. Each module consists of video tape / slide'or live instruction presentations

, related to each listed topic. Instructor led discussions follow each_ topic presentation to clarify; areas of difficulty. Student performance is documented through administration of a written examination covering applicable topics. Personnel permanently

! assigned to the Shorehnm Nuclear Power Station who require unescorted access to all Station areas, participate in General Employee Training which includes all topics. Personnel permanently assigned to the Shoreham Power Station whose work i assignments involve admittance to Station administration i'

buildings only, participate in the program to the extent necessary to assure safe execution of their duties.

l Long Island Lighting Company Personnel temporarily' assigned but ~

requiring unescorted access to'all Station. areas participate in all-topics of the General Employee Training Program. Temporarily assigned personnel whose work assignment involves. admittance to~

Station administration buildings only, participate in the' program to the extent necessary to assure safe execution of their duties.

Contracted personnel assigned to.the Shoreham Nuclear Power-Station requiring unescorted access to-all Station areas, participate in all topics of.the General Employee Training Program. Contracted employees whose work assignments involve

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admittance to Station administration buildings only, participate in the program to the extent necessary to assure safe execution of'their duties.. Contracted personnel who will be continuously escorted by qualified Station personnel while working within the Station. boundary for short' periods of time, will not be required ,

to participate in the General Employee Training Program.

l An annual evacuation drill will be performed'in conjunction with l

the emergency plan in' order to ensure its effectiveness.

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13.2.1.3.1 Security Personnel Fire Protection Training In addition to training required to carry out their normal tasks, security personnel will be trained in the following areas related to the Station Fire Protection Program:

1. Entry procedures for Wad _ng River Fire Department

2. Crowd Control (exiting personnel during an evacuation).

3. Fire llazard reporting.

13.2.1.3.2 Wading River Fire Department Personnel Training The Wading River Fire Department may be called in to assist the SNPS fire brigade in an emergency. In order that Fire Department personnel uay safely carry out their tasks, they will be trained in the following areas:

1. Site security entry and exit procedure

2. Health physics (basic radiation principles and practices and typical radiation hazards).

3. Station layout familiarization

4. Station fire fighting procedures applicable to the Wading River Fire Department.

This training will be performed under the direction of the plant training staff.

In addition to the above training, one station fire drill per year will involve assistance from the Wading River Fire Department.

13.2.1.3.3 General Employee Refresher Training Personnel who receive instruction in the following General Employee Training Program topics, receive repeat instruction and are examined on these topics annually as part of the refresher training progrum:

1. Radiological health and safety including applicable portions of 10CFR 19 and 10CFR 20

2. Station emergency plan and implementing procedures

3. Station Fire Protection Program including evacuation routes and signals, fire and fire hazard reporting, and basic fire tighting equipment.

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Request 420.39:

Your description in Sections I.A. and I.B. of your " Fire Hazards Analysis Report" does not provide adequate information on your fire protection organization for us to complete our review.

Therefore, please provide the following information:

(1) You state that prior to fuel loading the Vice President, Project Management will have overall responsibility for the fire protection program and that after fuel loading the responsibility will transfer.to the Vice President, Operations. Describe the offsite position that has direct responsibility for implementing the provisions of the fire protection program. This should include the responsibility for formulation, implementation, and assessment of the effectiveness of the fire protection program and activities such as fire drills and training conducted by the fire brigade and plant personnel.

(2) Describe who has overall responsibility for the fire protection program at the facility. Describe any delegation of this responsibility for the fire protection program such as maintenance of fire protection equipment and systems, testing of fire protection equipment, fire safety inspections, fire lighting procedures, and fire drills.

(3) Describe the authority of your fire brigade leader relative to that of your Watch Engineers.

Response

(1) The Vice President-Nuclear is responsible for the safe and reliable operation of the Shoreham Nuclear Power Station. He is the offsite official who has overall management responsibility for the establishment, implementation and effectiveness of the SMPS Fire Protection Program. He provides technical direction to the Plant Manager to whom he has delegated these responsibilities.

The Chairman of the Nuclear Review Board is responsible for assuring that independent review and audit of the SNPS Fire Protection Program is conducted by the QA Department under the cognizance of the NRB in accordance with SNPS Technical Specifications. This independent review and audit assesses the effectiveness of the SNPS Fire Protection Program, the training of the station Fire Brigade, and the fire drills conducted at the station.

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(2) The Plant Manager has the direct responsibility for formulating, implementing, administering and periodically assessing the effectiveness of the Fire.

Protection Program including fire drills and fire training of the fire brigade and plant personnel. 'He is also directly responsible for the effective coordination of the fire protection program with the station emergency plan to assure that a single point of' control and contact will exist for all fire contingencies. The Plant Manager's fire safety responsibilities are delegated as follows:

(a) Fire Protection Program Manager (Maintenance Engineer) is responsible for:

(i) Periodic inspection to: minimize the amount of combustibles in and around the-plant;. determine the effectiveness of

, housekeeping practices; assure that all i fire protection systems / equipment, emergency lighting, communication equipment, fire stops, penetration seals

, and fire-retardant coatings are in a t-fully operational condition; assure-1 prompt and effective corrective actions are taken to correct unsafe conditions.

5 NOTE:- Respiratory protection equipment for.the 4

station fire brigade shall be maintained ,

by the Health Physics Engineer.-

(ii) Development of the' fire fighting training program for operating plant personnel, the Station Fire-Brigade and' the Wading River Fire Department. In conjunction with the training program, he shall be responsible for conducting-fire drills to determine how well the .

training' objectives have been mot. He.

shall be responsible for critiquing.the t fire drills and practice-sessions to

- pin-point deficient areas.

(iii) Testing and maintenance of. fire protection. systems and equipment to assure maximum operational capability.

(iv) Reviewing and evaluating proposed work

, . activities to identify potential transient fire loads, or increased i

sources, and ensuring sufficient fire fighting equipment is moved into an area with temporarily increased fire loading.

(v). Implementation of a program for indoctrination of all plant contractor ,

personnel in. appropriate. administrative procedures which implement the fire protection program, and the emergency.

procedures relative to fire protection.

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

(b) Fire Protection Supervisor shall under the direction of the Fire Protection Manager be responsible.for:

(i) Organizing and implementing all Fire' Protection activities at the Shoreham Nuclear Power Station in accordance with the.SNPS Fire Protectin Program and- r Procedures.

(ii) The application of administrative controls to minimize fire hazards throughout the Shoreham plant site.

(iii) Coordination of all technical aspects of the SNPS Fire Protection Program training.

(iv) Supervision of Fire Brigade supervisory "

1 and contract personnel in. fire protection activities except'at the

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scene of an actual emergency.

(v) Ensuring all commitments to.all Federal and Local Regulatory Agencies associated l with fire protection activities at SNPS -

l are adhered to.

I (vi) Direction and coordination of' activities l involving outside agencies (Insurance,

. Mutual, and Fire Departments, etc.) in matters pertaining.to SNPS Fire i Protection under the direction'of The-Fire Protection-Program Manager.

(vii) Review of new installat' ions, or. requests for.new equipment / material to ensure appropriate restrictions or limitations required by the SNPS Fire Protection Program are met and applicable fire.

precautions are taken.

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• e (c) The Quality Assurance Manager and the Operating Quality Assurance Engineer are responsible.for assuring that the LILCO QA Program as it relates to the Shoreham Fire Protection ~ Program is implemented.- They assure by means of reviews, inspections, surveillance, and sudits.that design, procurement, installation, testing, and administration controls are established and implemented. They report'results to cognizant management.

(d) The SNPS Training Coordinator is responsible for implementing the training requirements of~the fire training program and assuring that plant-personnel and fire brigade personnel receive the appropriate training.

(e) The Fire Brigade Chief is responsible for directing firefighting efforts within the SMPS protected. area and switchyard.

(3) The on-shift Watch Engineer has direct responsibility for the' safe operation of the plant. His immediate subordinate is.the watch supervisor, who also is-the Fire Chief. All fire brigade members including the Fire Brigade Chief are selected such that.theirl normal~

station duties do not prevent'immediate response to a fire.

L (4) Additional details on organization, training, etc. are included in Section 6 of the Shoreham-Technical Specifications and the Station' Procedures,. (SP) listed 1

below:

(a)- SP 39.500.01 - Organization.and Administration of Fire Protection Program (b) SP 39.500.02 - Fire Briga'de Organization, Response, Practice and Drills-

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(c) SP 39.500.03 - Fire Protection Program Training 4

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