ML20127J530
| ML20127J530 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 05/26/1978 |
| From: | Stello V Office of Nuclear Reactor Regulation |
| To: | Mayer L NORTHERN STATES POWER CO. |
| References | |
| NUDOCS 9211190362 | |
| Download: ML20127J530 (11) | |
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See previous yellow Docket No. 50-263
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Northern States Power Company ATTN:. Mr. L. O. Heyer, Manager Nuclear support Services 414 Nicollet Mall - 8th Floor
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Ninneapolis Minnesota. 55401 Gentlemen:
RE: liANPOWER REC /J1REllENTS FOR OPERATING REACTORS We are enclosing a document entitled, "Itanpower Requirenents for Operating Reactors." We are using the bases given in this document for allowing the sharing of duties to meet minimuin staffing require-ments for fire brigades at nuclear power plants. This is being provided for your guidance in meeting NRC requirements in this area.
By letter dated December 16, 1977, you objected to a requirenent for a minimum fire brigade size of 5 being incorporated in the Technical Specifications for Monticello Nuclear Generating Station. We request that you review the enclosed guidance in regard to the use of personnel on the operating staf f and security force in canning the fire brigado and inform us by letter within twenty days whether you continue to object to our position on minimun fire brigade. size.
Sincerely.
Orl inal Signed by G
Victor L. Steno Victor Stello, Jr., Director Division of Operating Reactors Office of Nuclear Reactor Regylation i
Enclosure:
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Manpower Requirements-for Operating Reactors i
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/78 NRC FORM MS (9 76) NRCN 0240 fr us o. novenwuswr enswnwe orrica. sen..aws4 9211190362 780526 PDR ADOCK 05000263 P
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2 D D70 Docket NRC PDR Local PDR ORB #3 Rdg GLear Docket No. 50-263 SSheppard _
RBevan TWambach Worthern States Power Company 0 ELD p g, ;
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ATTW: Mr. L. O. Hayer, Manager DEisenhut i
Nuclear Support Services i
414 Nicollet Mall - 8th Floor
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Minneapolis, Minnesota 5540l Ger.tlemen:
95 RE: MAHPOWER REQUIREMENTS FOR OPERATING REACTORS We are enclosing a document entitled, "flanpower Recuirements for Operating Reactors." We are using the bases given in this document for allowing the sharing of duties to meet minimu.i staffing require-ments for fire brigades' at nuclear power plants. This is being f
provided for your guidance in meeting NRC requirenents in this l
area.
By letter dated December 16, 1977, you objected to a requit...ent for a ninimum fire brigade size of 5 being incorporated in the Technical i
Specifications for Honticello Nuclear Generating Plant. We request that you review the enclosed guidance in regard to the use of Mrsonnel on the operating staff and security force *, manning the fire bridage and inforn us by letter within twenty de;.
A-1r you continue to object to our position on ninimum fire brig-e
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Sincerely, l
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I Victor Stello, Jr., Director Division of Operating Reactors
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Of fice of tuclear Reactor Regulation l
Enclosure:
Manpower Requirements for
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Operating Reactors cc w/ enc 1:
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Northern States Power Company,
Cc Gerald Charnof f, Esquire The Environmental Conservation Library Shaw, Pittman, Potts and Minneapolis Public Library Trowbridge 300 Nicollet Mali 1800 M Street, N. W.
Minneapolis,t'ini.esota 55401 Washington, D. C.
20036 i
Arthur Renquist, Esquire Vice President - Law Northern States Power Company 414 Nicollet full Minneapolis, liinnesota 55401 Mr. L. R. Eliason Plant Manager Monticello Nuclear Generating Plant Northern States Power Company Monticello,11innesota 55362 Russell J. Hatling, Chain,an Minnesota Environmental Control Citizens Association (l'ECCA)
Energy Task Force 144 lielbourne Avenue, S. E.
Minneapolis,liinnesota 55414 Mr. Kenneth D:ugan Environnental Planning Consultant Of fice of City-Planner
, Grace Building 421 Wabasha Street St. Paul,!!innesota 55102 Sandra S. Gardebring Executive Dircctor Minnesota Follution Control Agency 1935 U. County h ad B2 Roseville, Minnesnta 55113 Mr. Steve Gadler 2120 Carter Avenue St. Paul, Itinnesota 55108 Anthony Z. Roist?n f4atural Resources Defense Council 91715th Street, i;. F.
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l MAfdOWER REQUIPE"ENTS FCR OPEP.ATING dACT0p.S The NRC nas established recuirements for personnel at operating reactors for purposes of plant operation, industrial security, and fire fighting.
The following discussion considers the extent to which plant personnel assigned to either plant operation or security may also be temporarily allowed to man a fire brigade in the event of a fire for a single unit facility and sets forth en acceptable sharing scheme for operating reactors.
Sumary of Manoower Peovirements 1.
Fire Brigade:
The staff has concluded that the minimum size of the fire brigade shif t should be five persons unless a specific site evaluation has been completed and scce other number justified.
The five-man team would consist of one leader and four fire fighters and would be expected to provide defense against the fire for an initial 30-r.inute pe riod.
See h tachment A for the basis for the need for a five-man fire brigade.
2.
Plant Operation:
Standard Review Plan Section 13.1.2 requires that for a station having one licensed unit, each shift crew should have at least three persons at all tir;es, plus two additional persens when the unit is operating.
For ease of reference, Attachment B contains a copy of this SRP.
3.
Plant Security:
The requirements for a guard force are outlined in 10 CFR Part 73.55.
In the course of the staff's review of proposed sccurity plans, a required minimum security respc se force will be established for each specific sit:.
In addition to the response teto, two additional members of the security force will be required to continuously man the Central Alarm Station (CAS) and Secondary Alarm Station (SAS).
It is expected that many facilities will nave a security organi:ation with grcater numbers of personnel than the minimum number assumed for purposes of discussion in this paper.
The NRC staff has given consideration to the appropriateness of per.
mitting a limited tegree of shering to satisfy the requirements of plant operation, security and fire protection and h:s ccncluded that, (1) subject te certain site and piant spe:ific conditions, the fire brigade staffing ceuld generally be provided through operations and security personnel, and (2) thc requirements for coerators and the security force should remain uncomoromised. Until a site specific review is completed, the following indicates the interim distribution and justification for these dual assignments, and therefore cur interim minimum recuirer.ents for a tycical presently operating comercial single unit fnilit".
The stsff celievt-tr,at r::np:ar 'f or the fire brigade fcr...uhi unit f tcilities is nct now a prct m : c:Jse o# the larger numbers of peonle concrally present at the sites.
Situations which do pose problems will be reviewed on a case-by-case basis.
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Plant Oterction:
The staff has concluded that for most events 1
~at a s1ng W unit nuclear facility, a minimum of three operators 1
should be cvailable to place the reactor in a safe condition.
l The two ad'itiencl operators required to be available at the i
nuclear fccility are generally required to be present to perfonn roatine jebs which can be interrupted to accomodate unusual situatiens tnat may arise.
That is, there is the potential for the remainig tw0 menbers of the operating crew'to assume other i
short-term duties such as fire fighting.
In light of the original
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rationale for providing extra plant operators to cope wi'th off-normal ccnd tions, it appears justified to rely on these personnel for this fun: tion.
The staff recomends that one of the two i
optratcrs assicncd to the fire brigade should be designated as leader of the fire brigade in view of his background in plant i
operations and overall familiarity with the plant, In this. regard, i
the shif t su;2rvisor should not be the fire brigade leader because his ::resence is necessary elsewhere if fires occur in certain critical areas of the plant.
2.
Plant Sec f te In the event of a fire, a contingency plan and pro;eauru. Q be used in deploying the security organ 12ction j
to assure that an aopropriate level of physical protection is maintained during the event.
The staff has determined that it j
is pcssible in the planning for site response to a fire, to assign l
a itaximun of three members of the security organization to serve on the fire brigade and still provice an acceptable levei of pnysical protection.
While certain security' posts nust be manned continuously (e.g., CAS, SAS), the personnel in other assignments, including the 4
response for:c, could be temporarily (i.e., 30 minutes) assigned to the fire brigde.
In judging the merits of tnis allowhnce the unde"lyinc cmtion is c.'hether the minimum security force strength must be maintained continuously in the event of a plant emergency such as a fire.
Further examinatien of this issue lends to two i
pctentiel r ticnoles for reaching an affirmative decision.
- First, could there be a causal ccnnection between a fire and the security threat? Seccnd, are there compelling policy reasons to postulate a simultaneous threat and fire?'
The first potential rationale would only be credible if, (1) the insider (pese: as p;rt of the threat definition) was an active particip st in an assault and starced a-fire coincident with the attack en tra piant or, (2) a diversionary fire was started by an attack force somewhere external to the plant itself where no equipent required for safe shutdown is located.
The role of the insider will be discussed first.
While 73.55 assigns an active status to tne.in:ider, the rule also requires that measures be impler. Ante; to ccntain his activities and thereby reduce his
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effectiveness.
At present, these measures include background checks on plant employees, limited access to vital plant areas, badging systems and the two-man rule.
Here, limited access means that only designated employces are allowed in vital areas and that their entry is controlled by either conventional locks or card-key systems.
Also, if separate treins of safety ecuip-ment are involved, then either compartmentalization or the two-man rule is recuired. These measures to contain the insider are presently bcing implemented and will provide assurance that people 4
of cuestioneble relisbility would not be able to gain employee i
status at a nuclear plant and should they beccme an employee with unescortec access, significant restraints would be inter-posed on the ability of such a person to carry out extensive damage to plant vital areas.
Recognizing that additional safeguards may still be appropriate, the staff has recc nended to the Comission that plant personnel also be required to obtain I
an NRC security clearance.
The staff believes that the attendant background investigation associated with a clearance, in con-junction with the other 73.55 measures, will provide a high degree of assurance that plant personnel will not attempt to take an active sabotage role.
If the clearance rule is adopted the staff believes sore of the meetures, such as the two-man rule, desienti to contain the insider can be relaxed. Thus, there d0es n:.t new apper to be a reasonably credible causetive relaticnship between a fire intenticnally set by an insider and the po:tuleted external security thrett.
For the case of diversionary fires set external to the plant itself, adecuate 4
security ferees can still be maintained by alicwing only part of the fire brigade to respond while both fire fignters and security i
force arme; res:cr:crs maintain a high degree of elertness for a possible reel attack somewnere else on the plant.
Thus, the effective number of armed responders required by 73.55 can be maintained for external diversionary fires.
7 The second p::ential rationale concerns wh:ther a serious, spontaneous fire should be postul:ted coincident with an external security thrcit as a design basis.
In evaluating such a recuire-cent it is useful to consider the likelihood of occurrence of this conbinatien of events.
Whi'e it is difficult to quantify th: proottili;v cf :ne 73.55 threet, it is generally acetoted that it is snall, ccccarable probably t3 other design batis type events.
The pr bability of a fire which is spontaneous and located in or in close proximity to a vital area of tne plant and is sericus encu;5 to pese a significant safety concern is also small, i t w:uld appear, therefore, that tne rendem coincidence of these two unlikely events would be sufficiently small to not
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require protection against their simultaneous occurrence, in addition, it should be noted that the shcrt time period (30 minutes) for which several members of the security force would be dedicated to the fire brigade w0uld further reduce the likelihood of coincidence, As neither of the two potential rationales appear to preclude the s
use of members of the security force in the event of a fire the staff hLs cencluded that the short assignment of security personnel from the amed response force or other available security personnel to the fire brigace under these conditions would be. acceptable.
To ensure a timely and effective response to a fire, while still l
preserving a flexible security response, the staff believes that the fire brigodt should operate in the following manner, in the event of an internal fire, ril five members of the fire brigade should be dispettned to the scene of the fire to assess the nature l
and seriousness of the fire, Simultaneously, the plant security force should be actively evaluating the possibility of any security threat to the pitnt and taking any actions which are necessary to counter that threat.
For external fires, a lesser number than the five-man brigLce should respond for assessment and fire fignting.
As the overall plant situation becomes epoerent it would be expected that the most effective distribution of menpower between plant cpercticos, security and fire protection would be mtde, allowing a belen'.ed utilization of menpnwer resourr.es until-offsite assistance becomes available.
The manpower pool provided by the plant operations personnel and security force are adequate to respond to the occurrence of a design basis fire or a sccurity throat equivalent to the 73,55 perforrance recuirements, It is also retngnized that other, more likely cabinctions of postulated fires and security thre:ts of a lesser magnitucc than the design basis, could be considered.
While the probabilities of these highcr likelihocd events may be sufficient to warrant protecting against them in ccmbinction, the manpower requirements required to cope with ea:h event would be similarly reduced thereby allowing adequate coverage by picnt pers:nnel, 1
Conclusion f
The steff believes that it would be reasonable to allow a limited enount of sharin cf plant oorsonnel in satisfying the re::uire ints of plant eteraticn, security, and fire protection. An acceptaole sharing scheme would entail reliance on two plant operators and three members cf the security organization to constitute the fire bri g:.d t,
Sir.ce availability of the full fire brigade would only I
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be required for fires with potential for serious damage, actual distribution of plant personnel during a plant emergency would be governed by the exigcncies of the situation.
Of course, all personnel assigned to the fire brigade would have to fulfill all applicable training requirements.
It should also be recognized that the diversion of personnel to the fire brigedc would be of shert duratien and that substantial additional offsite assistance would be forthcoming in accordance with tne emergency and centingency pihn developed for each facility.
In evaluatina licensee proposals for manpo<er sharing due consideration will also have to be made of unique facility characteristics, such as terrain and plant lay-out, es well as the overall strengths of the licensee's fire'and security plans.. Minimum protection levels in either area cocid preclude the sharing of manpower.
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J Attachment A i
Staf f ' Pet ition Minimun J_ ire trigade Shift Size i
1HTRODqCTION
!!uclear pewer plants depend en the resp;nse of an ensite fire brigade for daiense toainst tne ef fects of fire on plant sefe shotdcwn cene.ilitics.' in s re areas, actions by the fire brigace are the In other creas, thtt are er tected i
only econs of fire suppression.
'by ccrrectiy d:sirnsd Out:natic cet:ction and suptrsssicn systems,(1) fires too mans.d fire fighting offerts are used to extinguish:
small to a:tuate tne auttmatic system; (2) well develeped fires if the auttn: tic systen f ails to function; and (3) fires _ that are net ccepletely Tnus, an adeccate fire brigade is 1
controlled by the cut;matic system.
essen:iel to fulfill the def ense in depth recuirements which prettet safe chut:cwn systers fr'm the effects cf fires and their related e
ccmbun'nta py-procucts.
DI SC M..S M There are a nu.ber of f act:cs that should be considered in establishing 4
the rininum firc briccce thiit size.
They include:
- 1) plcnt ocemetry ard size; El cuant-;;r and ~cusiity of dete:tien anf. suporessien systems;
?) fire fignting strategics for postulated fires;
- 4) fire bricace traininc;
- 5) fire bri;c ; e:ui:mcht; tre sap;itments ry plant personnel and local fire
- 6) fire bript::
department (s).
In eli plants, the najority of postulated fires are in enclosed window-
'n su;h orcas, the wori:ing environment of the brigace less stru::ures.
crcatro by int reat and s=cte buildup within the enclosure, will recuire the ene of self-cer.t:inec bret:5ing apparatus, socke ventilation equi;nent.
and a personr.ei rrpis:ement c: adility.
Certain functions cast be performed for all fires, i.e., command brigade actions, inforn plant man 6pesint, fire su;,pressica, ventilation control, Until a site provice _ extra equipment, and account for possible injuries.
specific review can te c;mplettd, an interim minitur fire brigado size This briped? !ize should provide of five persons has been est:blished.
a ninitaum working nuder of perser.nel to de:1 with these postulated fires in a typical oresently operating ccamercial nu: lear power station.
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[f the brig:d2 is compostd of a smaller number of personnel, the fire attt.cl usy be stopced 'ahenever new (quipment is needed er a person is injured er fatigued.
1:e note that in the career fire service, the minimun engite cocnany manning considered to be ef fective f r an initial attack on,a fire is also five, including one officer and four team members.
It is assumed for tne purposes of this position that brigade training and equipment is adequate and that a backup capability of trained individuals exist whether through plant personnel call ba,ck er f rom the local fire department.
.P.C. C ' T I OU 1.
The ninin:o fire brigade shif t size should be justified by on analysis of the plant specific f?cters statt4 above for the plimt, af ter rodificaticas are Ct.nplete.
2.
In the interim, tha minimum fire brigcde shif t size shall be five pertoas.
These persens shall be fully cualified to perform their assigned reso0nsibility, and shall include:
One Su9erviser - This individus1 must heve fire tactics training, he wili assure all commane responsibilities for fighting the fire.
During plant tuer;cncies, the brigade supervisor should not have cther ressensibilities that w:vid detract frca his full attention being cevote: t: t.ie fire.
ibia superviscr should net be actively eng!gSJ in the fighting of the fire.
His total function should be to survty the fire area, cermanc the brigade, and keep the upper levels of plen'. hansgement infermed.
1wo B;;j '%n - A 1.0 ine.h fire hose being handled within a windec-less en:leture neuld re:vire tw0 trained incividuals.
The two team rc-4. ors are reruirec to physically hancie the active hose line and to protect each otner while in the adverse environment of the-fire.
Two 'dditiencl Tstm "e ters - One of these individuals would be rc:Wir :
- scroly (Illa: air cylinders to the fire fighting nembces of tne brigide and the sec:nd to' establish.! cke ventilation and aid in filling the air cylinder.
These two indivicuals would also act as the fi st bactu: :: the engaged team.
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