ML20136C406

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Discusses Min Fire Brigade Shift Size.Requests Proposal of Tech Spec Mods to Change Min Size to Five Members
ML20136C406
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 08/28/1979
From: Eisenhut D
Office of Nuclear Reactor Regulation
To: Counsil W
NORTHEAST NUCLEAR ENERGY CO.
References
TASK-09-06, TASK-9-6, TASK-RR NUDOCS 7909240109
Download: ML20136C406 (28)


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NUCLEAR REGULATORY COMMISSION

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August 28, 1979 i

Dockets Nos. 50-245 and 50-336 Mr. W. G. Counsil, Vice President Nuclear Engineering & Operations Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101

Dear Mr. Counsil:

SUBJECT:

MINIMUM FIRE BRIGADE SHIFT SIZE By letter dated November 25, 1977, you were sent our position regarding the minimum size of the fire brigade for each operating I

~ shift at Mil.lstone Nuclear Power Station, Units 1 & 2.

Our position i

was that a minimum of five members, fully trained for fire fighting, is necessary.

You responded by letters dated December 15, 1977 and June 27,1978 and proposed a smaller brigade of three members and pro-vided a justification therefor. After reviewing fire protection at

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your facility and other operating facilities, we have concluded, based 1

on the possible demands that may-be placed on the brigade and the consequent actions that may be required of the brigade to fight fires, that five members constitute the minimum acceptable fire brigade size.

Our generic evaluation is enclosed to this letter as Enclosure 1 and addresses the major points you raised to, justify a smaller brigade size.

By letter dated June 5,1978, we sent you a document entitled,

" Manpower Requirements for Operating Reactors." That document provided the bases for allowing the sharing of duties to meet minimum staffing requirements for fire brigades at nuclear power plants.

In perfonning our evaluations of the use of personnel who are not members of the operations staff, an issue was raised as to the amount of training to be given these personnel. We are, therefore, enclosing for your guida~nce our position on minimum fire brigade training (Enclosure 2) which modifies, for up to two members of the brigade, the previous guidance given in " Nuclear Plant Fire Protection Functional Responsi-

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bilities, Administrative Controls and Quality Assurance," June 14, 1977.

Of the seventy plants presently licensed to operate all but eighteen have a requirement in their Technical Specifications for a minimum fire brigade shift size of fiv~e persons. Discussions held with licensees of those 790 %7@/09 h

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e eighteen plants have resulted in a commitment by the licensee to propose such a Technical Specification except for six utilities who are the licensees for twelve plants.

Because the staff believes that the fire brigade at each facility should consist of a minimum of five persons, we are preparing a proposed change to 10 CFR Part 50 which would incorporate this minimum fire brigade, shift size into the Commission's regulations as a requirement for each operating license.

Until this is completed, we feel that it is prudent for you to have such a requirement in the Technical Specificaticas for your plant (s).

We request that within 30 days of your receipt of this letter, you propose an amendment to (Facility / Provisional) Operating License (s) Nos.

DPR-21 and DPR-65 to change the minimum size of the fire brigade contained in the Technical Speci.fications for Millstone Units Nos.1 & 2 to five members. We intend to make this Technical Specification effective within 90 days of the issuance of the amendment.

S ncerely, d MSd (ut, Acting Director 64 Darrell G. Eisen Division of Operating Reactors

Enclosures:

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NRC Evaluation of Minimum Fire Brigade Shift Size 2.

NRC Staff Position - Minimum Fire Brigade Training cc w/ enclosures:

See next page 0

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Northeast Nuclear Energy Company 4

cc:

William H. Cuddy, Esquire Day, Berry & Howard Counselors at Law One Constitution Plaza Hartford, Connecticut 06103 Waterford Public Library-Rope Ferry Road, Route 156 Waterford, Connecticut 06385 Northeast Nuclear Energy Company.

ATTN:

Superintendent Millstone Plant Post Office Box 128 llaterford, Connecticut 06385

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Northeast Utilities Service Company ATTN: Mr. Janes R. Himmelwright Nuclear Engineering and Operations P. O. Box 270 Hartford, Connecticut 06101 Anthony Z. Roisman, Esq.

Natural Resources Defense Council 91715th Street, N.W.

Washington, D.C.

20005 Mr. John T. Shedlosky Nuclear -Regulatory Conmission, Region I i

Office of Inspection and Enforcement 631 Park Avenue King of Prussia, Pennsylvania 19406 9

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ATTAClillENT 1 I

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EVALUATION OF MINIMUM FIRE BRIGADE SHIFT SIZE J NE.8, 1979

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EVALUATION OF MINIMUM FIRE BRIGADE SHIFT SIZE Table of Contents I.

Introduction II.

Background

III.

Discussion A. Defense-in-Depth Principle B. Fire, Brigade Performance Objective C. Fire Brigade Actions D. Typical Response to a Postulated Fire in a Nuclear Plant IV.

Conclusion Appendix A - Staff Response to Licensee's Arguments

1. Historical Fires
2. Offsite Personnel

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3. Availability of Onsite Personnel.

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EVALUATIdNOF MINIMUM FIRE BRIGADE SHIFT SIZE I.

I.NTRODUCTION.

Criterion 3 of the General Design Criteria (GDC) for Nuclear Power l

Plants (Appendix A to 10 CFR 50) reads as follows:

" Fire protection.

Structures, syste'as and components important l

to safety shall be designed and located to minimize, consistent i

with other safety requirements, the probability and effect of fires and explosions.

Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control Fire detection and fighting systems of approprfate capacity room.

and capability shall be provided and designed to minimiie the adverse effects of fires on structures, systems and components important to safety.

Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systens, and components."

The above mentioned fire fighting systems consist of both automatic part of the manual fire fighting system (gade shift is an essential and manual systems. The minimum fire bri i e., detectors, portable extinguishers, hose stations and fire brigade) which must function to

" minimize the adverse effects Hof. fires on structures, systems and components important to safety."-

' This evaluation summarizes the staff's and its consultant's evaluation of the factors that establish the minimum fire brigade shift size.

We have concluded that all operating' plant sites should have an onsite fire brigade shift of at least five members appropriately trained for fire fighting. The fire brigade shift should be capable of performing a spectrum of actions that may be necessary to cope with a variety of fire situation's. One member should be assigned as fire brigade leader to assess the situation and direct fire fighting activities.

Four members should be available to transport equipment to the fire, operate suppression equipment, or perform rescue work as required by the specific fire.

II. BACKGROUND 1

The need for and the role 15f thi fire brigade as part' of the fire protection program for operating plants has been under evaluation by the staff since the Brown's Ferry Fire in March 19.75.

Following its study of the Brown'.s Ferry Fire, the Nuclear Regulatory Connission's Special Review Group Report, dated February 1976, stated the need for an adequate fire brigade:

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- "The plant should be self-sufficient with respect to fire fighting activities and rely on public response only for supplemental or backup capability" (Appendix A p.7).

" Guidance is contained in the following publications :... National Fire Protection Association (NFPA) 27 - Private Fire Brigades" (Appendix A p.4).

Regarding.the size of the fire brigade, NFPA 27 states:

"The equipment that must be put into service at a fire will determine the number of men required for each operating unit or company into which the brigade is organized and the total number needed in the brigade.

Each company should have a leader and each brigade should have a chief."

(NFPA p.27-3, Vol.12) (Note tha.t the site fire brigade on each shift corresponds to the company of NFPA 27; the organization of all shift fire brigades corresponds to the brigade of NFPA 27.)

In November 1977, the.NRC issued additional guidance indicating that the fire brigade size should be determined by the functions the fire bri'ade must perfonn after consideration of several factors:

(1) g plant geometry and size; (2) quantity and quilSty of detection and suppression systems; (3) fire fighting strategies for postulated fires; (4) fire brigade training; (5) fire brigade equipment; and (6) fire brigade supplements, by plant personnel and local fire depart-ments. At that time, the staff established an interim fire brigade size of five persons until a site specific review could be completed.

In November 1977, the NRC sent licensees of operating facilities proposed interim Technical Specifications for fire protection which included the requirement for a five man fire brigade.

The NRC position on Minimum Fire Brigade Shift Size was included with the Safety Evaluation supporting this requirement.

The licensees' response on the requirement for a five man fire brigade was divided. 0f 70 operating facilities, 51 accepted a five man brigade and 19 presented arguments for a smaller fire brigade shift size.

To effect expeditious implementation of interim Technical Specifications requirements for fire protection, license amendments were issued which added Fire Protection Technical Specifications requiring the minimum fire brigade shift size as proposed by the licensees.

Where the licensee proposed a fire brigade of fewer than five persons, the amendments contained the condition that the staff's evaluation of the licensee's basis for the smaller fire brigade size would be included in the site specific review of the licensee's fire protection program.

In April 1978, the NRC issued additional guidance regarding the sharing of personnel required _onsite for the purpose of plant operation, industrial security and fire fighting.

These guidelines recognized that:

(1) the plant requires a minimum number of personnel to be on the site to cope with either an operating, security or fire emergency; (2) the probability of an event which requires entire minimum shift of each discipline ~ dur'ing the first 30 minutes of the event is low; and (3) the shift supervisor should tie able to use available site personnel

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precisely defined and that no single echelon of fire protection can be perfect or complete in itself.

The demands on the manual fire fighting capability and resources will vary depending on their degree of involvement:

1. If the automatic detection and suppression system functions as designed, the combustibles involved in the fire are limited to those evaluated in the design, and all other conditions for the fire are the same as for the design evaluation, the fire will probably be controlled and possibly extinguished by the installed system.

The fire brigade will be needed to enter the involved area to conduct final " mop-up" actions and inspection to ensure the fire is completely extinguished.

2. If the fire is of a larger magnitude than the design assdmption of the automatic systems or the fire spreads beyond the coverage of the automatic system because of the deterioration of design conditions, the fire brigade will be required to assist in the extinguishment operation and possibly in the protection of adjacent safety related equipment which may be jeopardized by the fire.
3. If the automatic systems do not actuate, the fire brigade will be required to independently contain and extinguish the fire in the involved zone.

Similar action is required in all areas that do not have automatic suppression systems.

When determining the minimum fire br,igad'e size ea'ch ~of the above three

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levels of performance must be considered and evaluated, with the third level bounding the brigade size since it places the largest burden on the team.

Further, the specific fire brigade actions that'will be required will vary from area to area within the plant, and with the construction, maintenance or normal operation activities that may be ongoing at the time of the fire.

Because the specific fire brigade actions cannot be precisely defined, the fire brigade must be capable of a spectrum of actions that may be required. The minimum fire brigade and the available manual equipment is the only fire suppression system in many areas of the plant.

Thus, the brigade and their equipment must satisfy the requirements of the General Design Criteria to minimize the adverse effects of fire on systers impor-tant to safety for these areas as well as provide its contribution to the defense-in-depth features in other areas which also have automatic suppression systems.

The fire brigade offers the flexibility to perform actions to mitigate.the consequences of. fires for the event that rey exceed the limits of fixed fire protection systems and, with e:rly warnina fire detection, to e,xtinguish -fires before automatic systems actuate.

l Even though the fire brigade is only one aspect of the " defense-in-depth",

it requires a minimum operating size to successfully fulfill its perfor-mance objectives as defined in the following section of this document.

To reduce the size below the needed level will result i~n the loss of brigade flexibility and the ootential that all performance objectives will

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Some of these factors interact and the combination of effects of such factors also require the consideration of the fire brigade leader.

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f. ' Fire Bricade Actions The actions required of the fire brigade to achieve the performance objectives depend largely on the complexity of the fire; however, the shift fire brigade should be capable df performing a spectrum of actions for any fire.

If a fire alarm sounds for any area'of the plant the following actions should be taken by the fire brigade:

(a) The fire brigade leader and all brigade members should immediately respond to the fire area.

(b) The brigade leader should respond directly to the fire area, with an extinguisher that he obtains on the way, and with adequate equipment for communications and a portable handlight.

(c) The other brigade members should respond to the fire area with a personal self-contained breathing apparatus and a portable extinguisher.

If on arrival at the fire area, an incipient fire is in progress, the following actions should be taken by the fire brigade:

(a) An innediate attack should be made on the fire in an attempt to extinguish.

(b) Additional extinguishers should be obtained from the immediate area.

.(c) A hose line should be stretched to the fire area as a precaution.

(d) Additional self-contained breathing apparatus and spare cylinders should be obtained innediately to be ready for use if necessary.

If the fire is not extinguished in its incipient stage, the following actions may be required:

(a) Place the necessary calls for off-site assistance.

(b)

If ladders are equired to ach the fire, fire ladders should be obtained.

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If the fire involves electrical equipment, the equipment should be de-energized. This action requires coordination with operating personnel to assure it will not affect the continued safe operation of the plant.

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Typical Response to a Postulated Fire in a Nuclear plant The following. outline describes how a brigade would respond to a postulated fire and carry out the actions discussed in the previous sections.

The outline illustrates the need for some actions simultaneously and some sequentially.

It also illustrates that the specific circumstances that determines the course of the fire will determine the specific actions required.

The actions being performed by the fire brigade leader and the fire brigade members are summarized in Table 1.

1.

The fire brigade leader and all brigade members should initiate their response to the announced fire area.

2.

The fire brigadt leader should respond directly to the announced fire area with portable communication equipment. He evaluates the situation, and advises the control room and formulates an action plan.

3.

Each member of the fire brigade including the fire brigade leader obtains a fire extinguisher from a location along the way and bring it to the fire a.ea. 'These should be brought from a remote location to assure that sufficient extinguishers will be available. Those in the immediate fire area may have been used by the discoverer

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of the fire.

4.

Each member of the fire brigade should also bring a self-contained breathing apparatus for use by the brigade members.

5.

If conditions are such that self-contained breathing apparatus masks will have to be worn by 'the brigade members, no member should enter the fire area without a mask.

If necessary one or more, depending on the need, brigade members should be sent to obtain additional self-contained breathing apparatus in sufficient number so that each brigade member and the fire brigade leader will have a unit.

At least one man should be sent to obtain spare air cylinders, at least one per self-contained breathing apparatus being used.

(NOTE:

Recent tests at Syracuse Fire Dept. Training Academy showed that the 1/2 hour rated mask, pressure demand type, was breathed down in as little as 7 to 15 minutes during fire fighting activities).

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If the brigade members will pass by the personnel protective clothing storage area, they should obtain their fire fighting gear and bring it to the fire. scene.

If such clothing is needed but is not brought to the scene, at -least one man should be sent to ~obtain such clothing.

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If the fire is not readily extinguished by the use of extinguishers, the following actions should be undertaken by the fire brigade as ordered by the fire brigade leader.

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.(a) the 1-1/2" hose line that has been stretched as a pre-cauthionary measure should be advanced into the fire area by at least two brigade members and; (b) The remaining brigade membe'rs should simultaneously stretch an additional 1-1/2" hose line,' rom the closest available standpipe location to the area immediately outside or adjacent to the fire' area and be prepared to use this line to provide protective spray and/or as a backup attack line if the fire severity demands.

(NOTE:

It is likely that the second 1-1/2" hose line will have to have additional hose added to reach the fire area).

(c)

Once the second line is readied for use and if its immediate use is not required, the fire br.igade leader may.

direct one or more of the back up men to take steps to pro-vide protection for electrical equipment or to set up por'.able ventilation equipment to evacuate ~ smoke and heat, or to obtain additional special equipment that may be required if the fire is not controlled and extinguished in a short time.

(d)

If the brigade leader and the men attacking the fire with the 1-1/2" hose li,ne are, successful i_n extinguishing the fire, the steps subsequent to extinguishment contained in 7 above should be followed.

10.

If the fire is not extinguished by the : attack with 1-1/2" hose

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lines, the area may become untenable as a result of either heat or smoke or both.

In this situation the fire brigade leader should order the following actions by the fire brigade.

(a) - All personnel should back out of the fire area and take positions where they can either keep the fire contained by the use of the hose lines from the perineter openings or (b) The area. should be sealed off, if possible, by closing the fire doors and the hose lines should be used by brigade members to attempt to keep the fire from passing through any penetrations or, ducts or fire doors or the exterior walls by spraying water on the potentially dangerous areas to, keep it cooled down.

(c)

If the situation develops to this extent in a relatively shor.t time p'eriod (less than 15-20 minutes) it may be necessary for the brigade leader to direct that one individual hold the 1-1/2" hose line from a suitable braced position while the other members are sent.for additional back up hose lines, additional air supply, and to check surrounding areas and floors above the fire for possible extension of the fire.

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2.

One member should be assigned as fire brigade leader and at the time of the fire, he should be free of all duties so that hd can devote his attention to assessment of the fire situation and direction of fire fighting activities.

3.

Four members should be capable of acting individually or as teams to perform the spectrum of basic fire fighting action which may be required e.g., locating the fire, operation of portable extinguisher or hose lines, transporting equipment to the fire scene, or rescue work.

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TABLE 1 l

MANPOWER REQUIRED FOR

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FIRE FIGITING ACTIONS FIRST & SECOND BRIGADE TillRD & F'00RTH BRIGADE LEADER MEDEERS_

WCHRERS A.

ACTIONS REQUIRED FOR FIRE NOT EXTINGUISHED BY PERSON (s) Wil0 DISCOVERED FIRE.

.t Respond to fire with portable Respond to fire with portable fire.

Respond to fire with portabi-fire extinguisher extinguishers.

fire extinguishers.

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l Respond to fire with self-Respond to fire with self-Respond to fire with self-l contained,breating apparatus, contained breathing apparatus, contained breathing apparatt..

. Locate fir'e or source of smoke Locate fire o'r source of smoke.

Locate fire or source of smoe.

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,a Evaluate the fire situation and Operate fire extinguishers on the Operate fire extinguishers o the j

the area involved to determine the fire (if fire location is deter-fire (if fire location is detr-effective actions to be taken and mined).

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j maintain consnunication with control room.

(Required for all III'S' Stretch at least one 1-1/2' hose line to be used as backep to extinguishers.

Direct fire fighting activities.

by the fire brigade members.

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C.

ADDITIONAL ACTIONS REQUIRED FOR. FIRE THAT DEMANDS ASSISTANCE BY OFF-SITE PERSONNEL All actions required in B:

Be prepared to provide rescue of en-Be prepared to provide rescue of en-Be prepared to provide rescue dangered personnel or fire brigade dangered personnel or fire brigade of endangered personnel or fire members if necessary.

- members if necessary, brigade members if necessary.

Provide off-site' fire fighting with Serve as guide, coordinator and Serve as guide, coordinator and sufficient information so they under-control person for off-site fire control person for off-site fire department.

stand the situation as it exists on department.

. their arrival, the objective of the operation, the actions being taken to Isolate and confine fire.

Isolate and confine fire.

achieve the objective, advice and supervision of their act' ions in use hoses to cool and protect Use hoses to cool and protect barriers.

coordination with the fire brigade.

barriers.

Survey barriers for possible Survey barriers for possible break through an,d extention of fire break through and extention of fire.

FOOTNOTES: Operations in fire areas should always be a team effort of at least two If these two members are not members for the purpose of improved operation and personal safety.

fully trained fire brigade members, they would be replaced by the off-shift personnel when they arrive.

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s APP:NDIX A STAFF RESPONSE TO SELECTED LICENSEE'S ARGUMENTS 1.

Historical Fires Some licensees argue that the majority of historical fires in nuclear

, power plants were either self-extinguished or were extinguished by a small response force.

Further, a large number of these fires occurred during the construction phase of the plants.

The NRC does not deem the size of historical fires a significant factor in determining the size of the mirtimum fire brigade. The small fires that self-extinguish or the fires that are easily extinguished present little, if any, threat to public health and safety.

i Further, the circumstances that lead to fires in the constiruction phase are not precluded after the plant goes into operation.

New construction at the site, major plant modifications and maintenance activities produce similar circumstances at an operating plant.

It is the fires that do not.self-extinguish because of "off-design" conditions or are not promptly extinguished at operating plant sites which may present a threat to the plants capability to achieve i

and maintain safe shutdown' conditions ~.

For example, a temporary breakdown in the administrative controls over the use of combustibles

'and ignition source, a failure to detect a fire early, or adverse unanticipated events which either delay prompt extinguishment or

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lead to rapid fire development-may lead toward. the development of a severe fire.

Because of the possibility of these fires, the staff deems it prudent to maintain a site fire brigade which can promptly extinguish such fires in safety related areas with-sufficient margin in size to account for adverse conditions and events.

2.

Offsite Assistance Some licensees argue that the minimum fire brigade may be less than five persons because of substantial offsite assistance.

The'NRC concludes that the delay in prompt fire extinguishment incurred by reliance upon support from offsite fire departments or the call back of plant personnel does not provide an acceptable alternative to meeting the ininimum manpower requirements for an onsite fire brigade.

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Offsite fire departments could be coninitted to fighting fire elsewhere when a call goes out for their assistance. -In many areas weather conditions could delay the. response of offsite fire departments as well as operating personnel called back for additional assistance. While the NRC recognizes the importance of a preplanned util.ization of.offsite fire departments and call back personnel, such assistance does not justify a reduction of an adequate onsite fire brigade to provide an insnediate initial attack on a fire.

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ATTACHMENT 2 STAFF POSITION MINIMUM FIR: BRIGADE TRAINING CONCERN During our evaluation of the training given to fire brigade members, the issue of whether all members of a five man fire brigade need be given identical training has been considered.

In several instances licensees These have proposed two levels of training for fire brigade members.

evaluations have established the minimum acceptable level of training.

STAFF POSITION We prefer that all fire brigade members receive training in accordance with the staff guidelines set forth in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," June 14, 1977:

Fire Protection Organization Attachrent 2.

Fire Brigade Training Fire Fighting Procedures (Note: Copies of these attachments are enclosed)

Where the five man fire brigade has two levels of training, at least three members shall have training which fully conforms to the staff guidelines; however, two members may be excepted from the training require-

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ments listed below:

1. :

1 1.0a (6) The direction and coordination of the fire fighting activities.

1.0a (9) Detailed review of fire fighting' procedures and procedure changes.*

1.0a(10)

Review of latest plant modifications and changes in fire fighting plans.

The excepted personnel should have general training in these subjects.

  • The only portion of this item excepted is that associated with the fire fighting strategies which have been developed to conform with attachment 5, item d. "The strategies estab ished for fighting fires in all safety-l related areas and areas presenting a hazard to safety-related equip-ment."

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Attachment No.* 1 FIRE PROTECTION ORGANILATION 1.3 The organizational res:ensibilities and lines o# communication per-taining to fire protection should be defined between the various besitions through tne use of organizational charts and functional descri tions of eacn position's responsibilities. As a minimum the pcsitions/ organizations res:ensible for the following should be designatec:

a.

The u::er level offsite managemen: pcsiti:n which has manage ent res:ensisility for the formulation. ir.:lemen:a:icn, and assess-men of the effectiveness of :ne nuclear plan: fire protection program.

b.

ine offsite management position (s) directly responsible for (1) formulating, imolementing, and periodically assessing the effectiveness of the fire pro:ection program for the licensee's nuclear po er plant including fire drills and training con-ducted by tne fire brigade and plant personnel. The results of these assessments shculd be re:orted to the upper level management position responsible for fire protection with ree:mmendations for improvements or c:rrective actions as deemed necessary..

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

No. A

^ " Organization for Fire ' Services"

" Organization of a Fire Department" No. 4A

" Industrial Fire Loss Prevention" No. 6

" Management of Fire Emergencies" ho. 7

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

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

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

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The ;ositiong which are part of the plant fire brigade (1) The clan: fire brigade positions snould be responsible for fignting fires. The authority and responsibility of each fire brigade position relative to fire protection should be clearly defined.

(2) ine resconsibilities of each fire brigade position should corres;one wita :ne actions ' required by the fire fignting procedures.

(3) The res:ensibilities of the fire brigade members under normal plant concitions, should not conflict with their res;ensibilities during a fire emergency.

(a) The minimum numcer of trained fire brigade members avail-able ensite for eacn o;erating shif t should be consistent with :ne activities required to comta the most significant fire. The si:e of the fire brigace should be based uoon the functions re:uired to fignt fires with adequate allow-ance for injuries.

(5) The recomrendations for organization, training, and equip-mer.: of "PRP.' ATE FIRE BRIGACES" as specified in NFPA No. 27-1975, including tne a:clicable NFDA publications listec in :na Apcendix to NFFA No. 27, are considered a;crocriate criteria for organizing, training, and operating a plant fire brigade.

2.0 Qualifications a.

Tne position responsible for formulation and implementation of the Fire Protection Program should have, within his organ-iration, or as" a consultant, a Fire Protection Engineer is a

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graduate of an engineering curriculum of accepted standing and shall have completed not less than six years of engineering attainment indicative of growth in engineering competency and achievement, three of which shall nave been in responsible charge of fire, protection engineering work. These requirements are the eligibility requirements as a Memoer in the Society of Fire Protection Engineers.

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o Attachment No. 2 FIRE SR!"40i IRAINING The training prograd shculd assure that the ca:atility to fignt :ctential fires is esta:11sned and maintained. The :regram shovid consist of an initial classrcem instruction pr: gram follcwec by periodic classrecm ins:ruction, practice in fire fignting and fire crills:

1.0 Classe::m Instruction The initial classrecm instruction should include:

a.

(1). Icentifica-icn of the fire ha:ards and associated types l

of fires that could occur in tne plant, and an icenti-fication of tne lecation of suca ha: arcs.

(2)

Identificatien of the location of fire fighting equ'ip-ment for eacn fire area, and familiarization with layout of ne plant inclucing access and egress routes to each area.

(3) The preper use of available fire fighting equi; ment, and the correct me: nod 'of fignting each type of fire. The ty:es of fires covered snould include electrical fires.

fires in ca:les and cable trays, hydrogen fires, flam-mable if cuic, waste /ce:ris f. ires, and recorc file fires.

(4)

Inc:c rination of the :lan fire fighting plan with specific coverage of eacn individual's res;cnsibilities.

(5)

Th'e' prc:er use of ecmunication, lighting, ventilation

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and emergency breathing equipment.

(6) The directicn and coordination of the fire fighting acti.vities (fire brigade leaders only).

(7). The toxic characteristics of expected products of c mbustion.

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

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

(10) Review of latest plant mcdifications and changes in fire fignting plans.

2 e

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3 c.

The simula:ed use of fire fighting ecuipment required to cc:e with :se situatien anc type of fire selected for the drill.

The area anc ty:e of firt chosen for the drill should be varied sucn tsat brigace members are trained in fighting fires in all safety relatec areas containing significant fire ha:Ards. The situati:n selected should simulate the si:e and arrangement of a # ire wnich coulo reasonably occur in the area selected, allcwing for fire cevelopment due'to tne time required to re-spene, to obtain equi: ment, and organi:e for the fira, assuming less of aut:ma:ic suppression capability, d.

  • ssess.?ent cf brigace leader's direction of the fir e fignting ef'ce:, as to :nor:ugnness, accuracy, and effectiven :s.

e.

The drills should be :erformed at regular intervals but-no:

to ex:eed 3 mentns 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 fer enca fire brigace per year, shall be unannouncec, to de-te-mine the fire readiness of the plant fire brigade leacer, 1

brigade, fire protection systems and equipment.

f.

The drills snould be pre-planned to establish the training

-cbjectives of tne drill. The drills should be critiqued.to ce:emnine h w well the training objectives have been met.

4 l

Unannounced drills snculd have their critiques perfccmed by mem:ers of the manage?ent staff responsible for plant safety 4

and security. At inree year intervals, drills should be critiqued.

by qualifiac incivicuals independent of the utility's staff.

4.0 Recores Rec:rcs of training provided to each fire brigade member including drill criti;ues should be maintained to assure that each member re:tives.tra.ining in all parts of the training program. These rec:rcs of training shcul.4 be ay(ilable for review.

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s Attachment No. 5 FIRE F;"eT;NG PR-~E 'JRE5

~ ire fi;. ting :rece: ares sneul: te esta:lisnec :: ::ver such items as notificati:n Of a fire. fire eme ;emey =recec.res, an: c:crcinatic, of fi e fi t i.- activities witn offsite tire ce:artments.

The fire fignt-ing ;r::; :wr;es sn:wie icentify:

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Acti:es t: :e taken y indivicual dis::ve-ing the fire; suen as. neti*icaticn of c:nt.1 r:cm, atte.: t: extinguish fire, an: acteation et local fire su::ression systems.

b.

Actions to te taken y tne c:ntr:1 reem c:erater arc tae neec f:e triga:e assistance v:en re: Ort of a fire er recei;t of alaam on c:nte:1 r:cm annunciat:r panel, swen as:

annewncing 1ccatice of fire evea DA system, scuncing fire alarms and notifying tne shift sw:e-visce anc the fire brigace leacer of the ty:e, si:e, an: iccation of the fire.

c.

Acti:ns t: 1 re:m ::e y the fire brigade after notification *by

e take :

tne ::Ptr:

at:r of a fire, including:

locati:n to asses:le; cire:ti ns given.:y firt brigade.lescer; anc res:casi-tilities of triga:e mes:ers such as sele: tion of fire fignting e:wi: cent anc trans::etatien to fire locatien, selection =f

retective ecui; ent, use of fire su
:ression systees c:erating inst uctions, anc use of pre:lanned strategies for fighting fires i.1 s;e:ific areas..

The st. atagies esta:iished for fignting fires in all safety-d.

relate: areas anc areas presenting a nazar: to safety-reiated e:wi: ent.

As a mini:ws the fc11owing su:je: s sr.cule be c: vere::

(i) I:entificati:n cf c:maustibles in taca lant Zone covered by the s:ecific fire fignting prececures.

(2) Fire extinguisnants best suited for c:ntrolling the fires associatac with the c:m:ustible loadings in that ::ne and the nearest ic:ation of these extinguisnants.

(3) Fest f avera:1e direction fece which to attack a fire in eacn area, in view of the ventilation cire: tion, ac:ess hallways, stairs and d: rs which are mcs-likely to te fire-free, and the test stati:n or elevatica f:r fighting the fire.

A s:ecific identification system shall designate all hallways, stairs, d:ces, fire stuf; ment and system '

c:nte:1 1ccati:ns, and other items describec in the fire fignting ;r::::ures.

This i:entification shculo be used I

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t Actions to te taken ty Plant SG 8Pi"I'"d'"

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Security Guar s after nc-ification of a fire.

Actions to,.e.aien tha*. will coordinate fire f4gnting activities witn effsite fi e cecartments, ncluding-icentification of g.

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,334n gn incivicual rescensicle for assessassis*ance wnen neece,., ic,ntgf4c,t4,3

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'4:!=;. !v *'!r,1;e"fi'e'ifil!"! '!!!I"a'Eic*i*yq ia fie' ="is'c' s

s a* leas. cr.ce,. year *. anc previsiens for trainjng "C

in asia radiation princ1 les, ced.

- i efsite fire ce:a-tment personne

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g tycical rac'atidh naca-es. anc Drecau. en,e plant. The pre-

:'.ia";1:;;5ti!llil;it;'l',:I cffsite fir e = art = n: =

P t s c u e c t s a n c e s,.,.,,3

  • e,. r e s,,1, g g,, g.y tne offsite fire c e... e vice assis*anCe to th' I*'I 00*

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