ML20148C321

Forwards Review of Fire Protection Program,Describing Summary of Staff Positions,Licensee Response & Status of Corrective Actions Taken to Satisfy NRC Concerns

ML20148C321
Person / Time
Site:	Yankee Rowe
Issue date:	10/24/1978
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Ziemann D Office of Nuclear Reactor Regulation
References
NUDOCS 7811020012
Download: ML20148C321 (38)

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I-3 i 9' h 9 o UNITED STATES -

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, ' NOCLEAR nEGULATORY cOMMissl0M7  :.

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OCT' 2l41978'  ;

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' *j-MEMORANDUM FOR: D. ' Ziemann, Chief, Operating Reactors Branch #2 ,

Division ot Operating. Reactors-

FROM

-G. Lainas,. Chief, Plant-Systems Branch Division of Operating Reactors c

SUBJECT:

uYANKEE R0WE FIRE PROTECTION REVIEW The fire protection review team conducted the onsite review of the Yankee Rowe fire protection program on September 25 to 28, 1978. ;We identified a. number of concerns and positions which were discussed with:

'the licensee during the exit meeting. Our immediate concern was that the fire protection is inadequate to p'revent the loss-of shutdown j_ capability should.a fire occur.

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i At the exit meeting, we recommended that steps should be taken at the j earliest opportunity to implement those corrective actions which could

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'] be~ reasonably made prior to the scheduled refueling outage on October 20,

• 1978. -In addition, we recommended that' steps be taken to implement

! other corrective actions between now and the time that the'. plant will- -

i resume operation following the refueling outage. In subsequent telecons I with the licensee,.the licensee-has indicated what' action will'be taken

!' . to implement corrective actions during these two time intervals.

[ Attachment A includes summary of the' staff-positions,.the' licensee- i

]i response.to these positions, and. status of these corrective actions j which will be taken to satisfy the staff's~ concerns noted above. The.

licensee should be requested to confirm that we have correctlyidentified the l' response on the enclosed summary of staff positions. 3 1

, Based upon our evaluation to date, we recommend that a dedicated shutdown

! system should be provided to ' insure the' capability to safely shutdown as

-l' an essential part of the long-term solution to the fire protection problem. The time required to implement a dedicated shutdown system will, no doubt, take a period of years as it would get involved with the SEP program. However, during this interim period, we should be satisfied ll that appropriate. measures are taken to address both the adequacy of the fire protection program and the capability to shutdown following a j

potential fire. ,

'At the present time we are satisfied that the licensee is taking appro-

priate action to. improve his ability to mitigate the consequences of a r , fire under existing conditions, except in the ared of brigade personnel.

As indicated in Attachment A,. item R.1, we recommended that the fire L

brigade be increased from its present complement of three trained members required by the Technical Specif.ications to seven trained members. The 3 4 ; ,

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. . -00T H 1978 licensee has responded ~that'as a result of this concern .he has taken action-to provide five trained members on the day shifts from 8:00 to.

4:00 during weekdays. In addition, two members of the security force will be tvailable -to assist the fire brigade in the case of a fire emergency.

In' addition, the licensee will establish an hourly fire watch patrol of safety-related areas for those times for which five fire brigade members are not onsite.

until the unit is shutdown for refueling. Thest actions will remain in effect We find this action acceptable for the short tire period 5efore the unit is shutdown due to the low probability of a' fire in this interim period.

For the titre interval following the resumption of plant operation until those long terr modifications are implemented for the fire protection pro: ram as noted_in the enclosure, we fird that the fire brigade should

. consist of sevea trained members. The casis for tSis position is given in the' enclosed draft report, attachment B, from our consultant on manual fire fightino. The licensee's arguments for the existing ~ three.

man fire brigade as noted in his letters of December 14, 1977 and June 26, 1978, have not adequately addressed the following items:

1. The operations which must be performed to centrcl and extinguish potential fires.

2. The availability of equipment to control anc' extinguish potential fir:s.

3. The adequ;cy of the trainino for fire brigade mcmbers and backup suppo't such as ons'te security personnel and offsite assisttoces.

We request that a meeting t,e scheduled with the licensee in Bethesda during the first week in November to resolve the fire bricade issue.

The licensee should be prepared to respond to the concerns identified by our cor.sultant on manual fire fighting as well as to provide the qualifications of those individuals who have established the size and training of the fice brigade. The licensee should also be prepared to discuss the three above notid items which we do not find adequately acdrersed in his prior arguments.

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'icensee will forward information which describes the additional ility to snutcown which results from modifications being incorporated darinc the refueling outage. The licensee ;as indicated that his response to the unresolved steff positions, noti:d in Attachment A, will be provided by December 1,1978.

OV G. Lainas, Chief

• Plant Sy:tems Branch Division of Opera.ing Reactors

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00T 2 41978

Enclosures:

3 As stated i

cc w/ enclosures: D. Eisenhut A. Burger

G. Lainas f R. Ferguson

. T. Dunning l' L. Derderian M. Antonetti PDR

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l ATTACHMENT A l STAFF POSITIONS YANKEE R0WE FIRE PROTECTION PROGRAM i

l The following staff positions were discussed with the licensee during l the fire protection raview site visit exit meeting on September 28, i

l 1978. In the margin the licensee's response is noted as: A'- Accepted, S - Will be given further study, or R - Rejected. Due to the staff's concern for present fire protection capabilities, the licensee has or will complete action on some of these positions at the earliest opportunity.

l The status of this. effort was provided in a telecon with the licensee on October 2, 1978. The action on these items is noted in the margin as:

C - Completed, I - Work . initiated / components ordered for early delivery,

, E - Action taken to complete prior to the end of the refueling outage t

for which plant shutdown is scheduled for October 20, 1978.

I I A. PRIMARY AUXILIARY BUILDING A_ l. A hose station should be provided to reach all areas of the primary auxiliary building.

A 2. Early warning fire detection should be provided over each charging pump cubicle.

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A '3. The wiring-for the rollup door alarm for~the H2 storage

. room should be suitable for a H2 gas tmosphere.

R 4. The H2 storage room should have forced air venting with a a!

low air flow alarm.

e l B. DIESEL GENERATOR ROOM i ,

S 1. Fuel oil piping should be rerouted outside the safety injection pump area of 0-G building.

S 2. An automatic suppression system should be provided to protect each diesel generator room with flame detector i actuation.

l A 3. A hose station should be provided to reach all areas of the diesel generator building.

R 4. The doors between the diesel generator rooms should be electrically supervised.

A 5. The C02 protection for Manhole #3 should be modified to provide automatic actuation.

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3-2 R 6. The diesel fuel oil shutoff valve to the diesel generator rooms should be modified to actuate by an electro-thermal

- link actuated by.the automatic suppression system.

R 7. The diesel. generator room should have a drain to outside the room as a backup to the existing limited capcity ,

floor drain.

i j A-I 8. Combustible storage in the diesel generator building 1

- should be removed or suitably protected.

1 C. VAPOR CONTAINER i

Deleted 1. Fire detection should be provided above cable risers in

, the steam generator / coolant pump compartments and major combustibles.  !

i Resolved 2. Hose stations should be pro'vided to provide coverage of (see R.4.b.

item H.1 cable. trays and stored combustible, and to cover the below) operating floor, D. FUEL STORAGE VAULT -

R 1. Wood storage boxes should be removed.

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E. MECHANICAL EQUIPMENT ROOM #3

.j R 1. A fire hose station should be provided, f

F. SCREEN WELL PUMP HOUSE i

4 l 'A-E 1. Cables in the junction box should be coated with a flame-s retardant coating.

G. HEATING BOILER ROOM i

R 1. An automatic sprinkler system should be provided in the >

, heating boiler room.

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H. SWITCHGEAR ROOM

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l A-E 1. The top of switchgear and motor control centers should be 1

! sealed to prevent water damage.

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A 2. An automatic total flooding Halon 1301 suppression system should be provided. '

A-E 3. Covers should be removed f(om cable risers on south wall  !

and conduits below sealed to prevent water damage.

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R 4. Air flow alarms should be provided for the battery room L

j exhaust.

I. CONTROL ROOM i A-I 1. Two 17 lb Halon 1211 portable extinguishers should be j .

provided.

i A-E 2. Two air masks and four spare air bottles should be provided at the control room.

A 3. Early warnin'g detection should be provided in the D-G/SI l  : control panel.

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l R 4. Cables above the false ceiling should be coated with a flame-retardant coating. (Above control board and in side wall risers.)

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j A-E 5. Vertical risers on south wall should have tray covers

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modified for quick removal or permanently removed.

A 6. Early warning fire detection should be provided in offices ,

at east end of room, and in the kitchen area. ,

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J. YARD LOOP AND H0SE HOUSES - PORTABLE EQUIPMENT

1. Each hose house should have the following additional, equipment:

A-C (a) One 2-1/2 x l-1/2 x 1-1/2 gated wye.

A-I (b) One 2-1/2 gate valve on hydrant.

A-I (c) Two 1-1/2 combination fog nozzles.

A-C (d) Two 1-1/2 hose spawner wrenches.

A-C (e) One portable-hand light (7-1/2 volt).

l R (f) One Halligan forceable entry tool, i

l A-C (g) Assortment of hose gaskets.

l A-C (h) 200-foot 1-1/2 hose.

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A 2. All post-indicator valves should be tagged indicating their service. (Licensee will number valves.)

R 3. Post-barricades should be provided for hydrants and PIV's which could be damaged by vehicles.

1 A 4. Hydrants should be checked for drainage in the fall, outlets lubricated, and pressurized in spring to check for winter damage.

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R 5. Hose houses should have weather proof ventilators, i

i A-1 6. Hose house doors should be checked to insure clearance.

! R 7. A foam cart should be provided for foam pickup tubes and ten containers (5 gallons each) of foam. Adapters should-be prdvided so pickup tubes can be fitted to 1-1/2 inch hose.

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8. Additional equipment should be provided at equipment storage location consisting of:

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A-1 (a) Three explosion proof fire service smoke ejectors (N15,000 to 20,000 cfm total capacity).

A-I (b) .Two 2-1/2 inch dottble female adapters.

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A-I (c) Ten portable hand lights.

R (d) Three portable radios dedicated to fire brigade and plant operations personnel emergency use should be provided.

I S (e) Four air breathing apparatus, eight spare bottles i

should be provided.

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I , A-C. (f) Spare hose nozzles, hose, etc. should be stored at central location.

A 9. The three air packs and 12 spare bottles should be relocated l to safe location away from a high fire hazard area.

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R 10. A cooling tank should be provided at the air recharging station (compressor).

t R 11. A cascade recharge system with the existing large air storage bottles should be provided.

, K. FIRE DETECTION SYSTEMS l

A 1. A battery backup emergency power source should be provided for fire alarm systems.

A 2. Remote indicating lights sh'ould be provided for out of sight fire detectors (above control room ceiling and manhole #3).

L. TURBINE BUILDING S 1. 'An automatic foam deluge system should be provided for the following: -

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'l (a) Lube oil. reservoir *.

(b) H2seal oil unit *.

i (c) Transformer oil coolers *.

• The water supply feed should be independent of sprinklers and hose stations protecting the same area.

S 2. The turbine lube oil reservoir should be dyked to contain the' contents of the lube oil reservior plus an allowance for suppression water.

I Deleted 3. The curb' height for the. transformer oil cooler should be l (see'S.2 item  ;

A.2 below) increased to contain suppression agents with consideration of drainage capability.

S 4. An automatic sprinkler system should be provided throughout the turbine building with a 0.3 gpm/ft 2density over the most hydraulically remote 3000 ft2. The feed to the i

system should be independent of deluge systems and hose stations protecting the same area.

A-C 5. Waste oil and combustibles'should be removed from electrical duct bank area at north end of the oil storage room.

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S 6. The oil storage room doors should be curbed to contain normal oil storage plus an allowance for suppression water.

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! M. FIRE WATER SUPPLY S 1. A auto ~matic start diesel fire pump rated for at least 2000 gpm 0 125 psi should be provided with an independent feed to the yard loop underground system. Valving should be provided at the yard loop connection, independent of the existing loop feed, per NFPA 20.

A 2. Bleed and block connections should be provided for existing fire pump start pressure switches to permit full system l

testing.

l S 3. Fire pumps should start at 110 and 100 psig.

.i N. YARD HAZARDS e

A-1 1. The earthen berm around the fuel oil storage tank should be verified to be sufficient to hold the contents plus an allowance for suppression water. (The fuel oil volume will be reduced by normal use during the refueling outage

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-to limit the maximum volume to 26,000 gallons, which is the limit of existing containment capacity of the berm plus an allowance for suppression water. Permanent

modifications to increase containment capacity will'be I

made later).

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! S 0. SHUTDOWN CONSIDERATIONS t

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1. A dedicated shutdown system should be provided which is independent of the turbine building, switchgcar room,

.j control room, manhole #3 and single cable run in PAB for charging and shutdown pumps.

i S P. FIRE DAMPERS i

i t 1. Fire dampers with a rating equivalent to fire barrier I penetrated should be provided to isolate the control room l

and switchgear room from the turbine building.

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'l Q. FIRE BRIGADE i

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! A-C 1. A procedure should be provided to recall fire brigade members.  !

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A-C 2. Offsite fire assistance should be called on confirmation of a fire'onsite.

1 A-C 3. The fire brigade should respond in force for any fire alarm.

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I R- 4. Fire brigade members should have offsite hands on fire i

fighting training.

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R. Steps should be taken to enhance manual fire-fighting capability, including interim fire fighting actions, at the earliest 1

j possible time, i

R-I 1. Increase fire brigade size to seven trained members.

(Action'has been initiated by the licensee to have five trained members on day shifts and an hourly fire watch of safety-related areas at all other times, until the unit i is shut down for refueling.)

A-C 2. Additional hose should be provided at hose stations for which reach may be insufficient.

A-I 3. Additional foam agent should be provided onsite, 100 gallons minimum.

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4. Fire protection' staff positions and licensee proposed modifications should be implemented as follows:

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(a) Staff positions to be implemented.are noted in the margin above. (C or I items.)

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I (b) Licensee proposed modifications, indicated in the attachment titled Plant Responses to Recommendations Made in the Fire Hazards Analysis, submitted by the licensee's letter of January 31, 1977:

. A. Turbine Building A-I 1. Add a berm on south side of lube oil tank.

j (A sand bag berm will be used as a temporary measure now.)

- H. Vapor Container l

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! A-I 1. Add two additional wheeled fire extinguishers.

(A water hose connection to a demineralized i

water line will be provided as an alternative which would be available during refueling outages. The water supply line is blanked off with flariges during plant operation.)

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.  ; l A-I 2. Remove combustibles away from personnel hatch.

t A-I- 3. Reduce amount of' combustibles by. removing or replacing with fire retardant or noncombustible materials.

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i- A-I 4. Store required combustibles in small, 1

1 widely separated areas.

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'j A-C 5. Inspect and insure piping vapor barrier I

i tightness.

(c) Fire strategies should be implemented.as noted in the license 4 's letter of August 14, 1978. (Draft will be prepared and information will be discussed with the fire brigade. -Document of strategies and i

j incorporation into training program will follow i prior to next cycle of brigade training.)

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S. Fire protection modifications should be completed prior to the end of the forthcoming refueling. outage as follows:

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1. Staff Positions to be implemented as noted in the margin above. (E items).

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2. Licensee proposed modifications, same reference as R.4(b),

! above:

A. Turbine Building A-E 2.- Add drain openings in west wall by transformer oil coolers. (Drain pipes to be provided extending into outside transformer drainage

} basin.)

i D. Heating Boiler Room ,

A-E 1. Provide curb at entrance from turbine hall.

B I G. Diesel Generator Building i

i A-E 1. Provide curbs at all doorways of Diesel Generator i

t Rooms.

A-C 2. Reinforce mounting of diesel day tanks.

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h(h JOHN P. TOWNLEY 913 Southeast 15th Court Deerfield Beach, Florida 33441 Qh C(v")' Q V[Wh 44L#t a October 2, 1978 305/426 0335 DRAFT p

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Group l Leader x}i;Mr.RobertE.

l Hall, Analysis Reactor Engineering

/ Brookhaven National Laboratory 4 Upton, New York 11973 '

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SUBJECT:

FIRE PROTECTION SITE VISIT A;j

.' l LOCATION: YANKEE ATQ4IC ELECTRIC COMPANY - YAN13E RCfdE ..

(, FACILITY, ROWE, MASSACHUSETTS N{,

N REVIEWERS: T. . DUNNING, N.R.C . TEAM LEADER , L. DERDERIAN M. ANTONETTI AND J. TOWHLEY, BNL CONSULTANTS , N.R

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y DATES: SEPTE!4BER 25 28,1978 d

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9 1. INTRODUCTION

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1.1 Yankee Atomic Electric Company, hereafter referred to as n

gj YAEC, Yankee Rowe facility, hereafter referred to as YR, is

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located in the town of Rowe, Massachusetts on the east bank of

,! the Deerfield River's Sherman Pond, approximately 20 miles north West of Greenfield, Massachusetts, Mailing address for YAEC is l 20 Turnpike Road, Westborough, Ma. 01581.

L .. +9 Itinerary for the site visit to YR was to leave 'Deerfield 1.2 Beach, F1. at 0530 on September 25, 1978 proceeding to Fort Lauderdale International Airport for a flight to Hartford, Conn.

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', via Atlanta, Georgia. .j l

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DRAFT-10/2/78

-2 YARKEE ROWE Due to a mechanical problem with the aircraft at Atlanta, the connecting flight was delayed for approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes, setting back my arrival in Hartford to approximately 1245.

On arrival at Hartford, I was met by L. Derderian, the other two members of the team had gone ahead to meet with the YAEC guide at the scheduled time. Under the circumstancos it was necessary to rent a car for transportation from Hartford, Conn. to Rowe, Ma. which was used during the site visit for transportation to and from the plant.

I arrived at the plant site at approximately 1430 to begin the

required processing for both security and health physics reasons.

i Yankee Rowe's requirement that all visitors to the plant receive a total body count and complete the respirator test prior to entry into the controlled areas resulted in an entry meeting that i

was held by the N.R.C. team leader while other members of the team were being processed.

13 At the completion of the processing and entry meeting, the team began the site visit with a walk-through of the safety related areas of the plart as a form of introduction to the facility.

i YAEC assigned Ed Sawyer, Fire Protection Coordinator for YAEC, j Ed May, YR Fire Protection Coordinator, J. Staub, YA technical  ;

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DRAFT-10/2/78 YANIGE ROWE advisor to the plant superintendent and other suitable personnel to serve as guides and resource persons.

1.4 On the days following our format was to arrive at the plant site at 0730, advise and discuss with the plant personnel any questions or positions developed as a result of our obser-vations from the previous day, then continue with the site review throughout the day. Our site visit concluded each day at approximately 1630. On return to our motel, the team would meet to discuss and review the day's observations and develop positions to be presented the following day and at the exit meeting.

1 5 The exit meeting was held on September 28, 1978 beginning at approximately 0930 attended by 15 members of YAEC staff and 9 members of the N.R.C.

In addition to the N.R.C. team members previously listed, the exit meeting was attended by R. L. Ferguson, Section Leader, NRC-DOR-PSD, D. L. Ziemann, NRC-DOR-ORB 2, A. Burger, DOR-ORB 2, R. Paolino, NRC-I & E and W. Lazarus, NRC-I & E.

The expressed purpose for the attendance of R. Ferguson and D. Ziemann was to aid in obtaining commitments and to resolve i

! scheduling problems wherever possible.

1.6 Ralph Paolino, NRC-I & E, accompanied the team throughout

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] 4 YANKEE ROWE as an observer primarily to prepare for his assignment as one of the NRC-I & E individuals who will be conductihg the F.H. A.

site reviews and who will be responsible for the administrative controls portion of the review at YR.

In this capacity he accompanied this consultant during my interviews with plant personnel regarding the fire protection organization, fire brigade training and administrative controls areas. He also accompanied me on my visits to the two (2) off-site fire suppression assistance forces at Rove and Monroe Bridge. I made every attempt to keep Mr. Paolino advised of the data and information necessary to carry out these areas of

, the site visit and review.

Those members of YAEC staff that we' had contact with during our site visit were cooperative and helpful in aiding us to complete f our evaluation. In turn overy effort was made to explain our concerns and positions as we conducted the visit.

i This consultant worked closely with the team and other N.B.C.

representativos making suggestions, giving advice and adding input to positions and concerns related to manual fire suppression.

2. FIRE PROTECTION ORGANIZATION l

2.1 The fire protection organization for YR is established by the fire protection program developed by YAEC for all their

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facilities.and is well defined.

2.1.1 Organization charts provided as a part of the fire protection program clearly illustrate the management authority and~ responsibility for both the on-site and'off-site organization.

2.1.2 Off-site organizational responsibility for fire protection is under the direct authority of the Assistant Vice President of Operations who in turn delegates this responsibility to the ,

YAEC Fire Protection Coordinator.

The Fire Protection Coordinator meets all the requirements for his position with the exception of the number of years (3) in responsible charge of fire protection, having at present only two years in this capacity.

2.13 On-site the fire protection program is the responsibility of the Plant Superintendent who delegates the direct rssponsi- ,

bility to TAPS and thereby to the plant fire protection coordinator ,

in the TAPS department.

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2.1.4 The plant fire protection coordinator can be considered the plant fire marshal being responsible for all fire protection  ;

except fire fighting. It is his responsibility to see that the required fire provention and fire protection inspections are carried out by the responsible YR department or division.

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DRAFT-10/2/78

~6- YANKEE ROWE Wnile YR does not have a specific fire prevention committee as such, fire prevention and protection matters are covered as a required portion of the facility safety committee meetings.

2.1 5 Responsibility for inspectio ; testing and maintenance of fire protection equipment is clearly defined in the admin-istrative procedure developed for specific areas of the plant.

Coordination and fo1101 up where necessary are under the YR Fire Protection Coordinator.

2.2 Adecuacy of Fire Protection Orrani ation 2.2.1 After careful review of the information contained in YAEC letter to V. Stello, dated May 10, 1978 and an evaluation of the administrative procedures related to the fire protection organization, it is the conclusion of this consultant that the fire protection organization for YR is fully adequate and meets the requirements of the N.R.C. guidelines and appendix A to BTP APCSD 9. 5 1.

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23 Modifications and Recommendations 231 Mone at this time.

i 3 FIRE BRIG ADE 31 The fire brigade for YR is established under the plant l cmergency plan. While there is no organisational chart showing l

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. YANKEE ROLG -

the command structure AP-2001 establishes the Shift LSupervisor '

as.the. brigade leader and' assigns command responsibility to the remain.nc members in descending order matching their plants  :

operations functions.

As stated in YAEC's response letter to D. L. Ziemann, Chief i

' ORB-2 dated August 14, 1978 3 the fire brigade ~at YR will be ,

made up'of three fully trained fire' fighting personnel,cincluding the Shift. Supervisor as the fire brigade leader- and- two additional support people whose primary responsibility will be,to support the fire brigade.

YAEC has proposed'the above for all shifts including backLshifts and holidays. However during the normal day shift .there will be additional trained personnel on duty who will assist the fire brigade when necessary.  !

'3 1.1 The position of direct responsibility for the fire . brigade 1

operations during a fire emergency is the Shift Superintendent. -

Overall responsibility for any emergency rests with the YR l Emergency Coordinator. .

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3 1.2 OP-3017 entitled Fire Emergency directs that' control  !

room personnel shall en11 for assistance from Rowe V.F.D. and-  ;

Monroe V.F.D. , based upon tha estimated ability of personnel to extinguish the fire. The estimate is made by the fire brigade l

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DRAFT-10/5/78 8 YANKEE B0JE 1cader_ following his arrival at the fire.

313 Under normal plant conditions the regular responsibilities ,

of the fire brigade members do not conflict with their fire brigade assignment.

31.4 All fire brigade members qualifications include satis-factory completion of annual medical / physical examinations for ,

performing strenuous activity. (Re: YAEC letter to USNRC dated May 10, 1978.)

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315 It is the intent of YR to schedule fire brigade meetings as part of the required trdning and drill schedule for the fire

brigade. These are intended to be held on each shift by the fire brigade leader.

32 Adequacy of Fire Brinado f

3.2.1 The fire brigade organization as stipulated in YAEC.

letter to the H.R.C. dated August 14, 1978 is inadequate in three areas. .

One concern is that YAEC states that the brigade will consist t

of "three fully trained fire fighting personnel" and "on each shift two (2) support personnel". "These support personnel will receive the training necessary to perform their support roles only."

Inasmuch as all members of a fire brigade should be fully trained as firo fighters, this position is unacceptable.

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DRAFT-10/2/78 YARKEE R0dB A second area of concern is that YAEC states that one of the three fully trained personnel vill be the Shift Supervisor as brigado leader. In view of the need for the Shift Supervisor be to/available to the control room for decisions relating to the conditions that may occur during a fire in the plant, the Shift Supervisor should not be assigned as brigade leader.

The third area of concern is that under present conditions at YR, in relation to the need for additional fire detection, automatic fire suppression, manual fire fighting equipment, fire brigade training and for the development of pre-fire strategies, the proposed strength of the fire brigade, even if all are fully trained, is not adequate at five ($) personnel.

3.2.2 At present there is no formal recall plan for fire brigade members.

323 The present annual medical / physical examination given to fire brigade members appears adequate.

33 Modifientions _and necommendations 331 The fire brigade at YR should be comprised of fully trained personnel at all times. To indicate that some nembers

, vill only receive support training is not acceptable for any l

fire brigade. In the opinion of this consultant the fire brigado l

at YR chould be as self-sufficient as possible. This position 1

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- . YAN13E ROWE is taken in view of the physical location of the plaht regarding

- access, and most importantly in relation to the inadequacy of the off-site fire suppression assistance availabic to the plant.

(See 5 2.1)

(x) 3 3.2 The fire brigade strength for YR should be increased to seven fully trained members. This position is taken with due regard to the inadequacies ' mentioned in 3.2.1 and with consid-eration of the present dependence.on yard hydrant hose lines for manual fire fighting in a number of safety related areas of the plant. This dependence would require additional assistance in connecting and advancing the hose into the buildings. Further at this time the yard hose houses are not provided with It" hose, fittings and appliances to facilitate adequate hose line operations by a five man brigade. Where 2t" hose lines are to be used, the number of personnel required to operate these lines is a minimum of three for each line. Assuming a one 2t" line operation, three would be required to operate the line and one is.the brigade leader, leaving three to provide additional equip-ment, back up fire suppression, ventilation of the fire area, self-contained breathing apparatus, communications and to be available for rescue actions or to cover for injuries to other members of the brigado.

(x) indicates YAEC rejection of the position.

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333 When the improvements in the fire detection, automatic fire suppression, manual fire fighting equipment, fire brigade training and theidevelopment of pre-fire strategies are completed, the fire brigade strength may be reduced to five fully trained personnel.

• 3 3.4 An administrative procedure should be instituted for the recall of.off duty fire brigade' members.

4. FIRE BRIGADE TRAINING 4.1 On site responsibility for the fire brigade training program has been assigned to the TAPS department under YAEC's fire protection program.

'4.1.1 Off-site responsibility rests with the YAEC Fire Protection Coordinator who'is directly responsible for the effectiveness of the fire protection program including fire drills and training j conducted for the fire brigade and other plant personnel.

4.1.2 The actual training is conducted by the YR Training Coordinator and Assistant Training Coordinator. Their qualifi-cations to conduct fire brigade trainint; are minimal, primarily based upon qualification as an instructor, some training at the Niagra-Mohawk training site and - service as a volunteer fire fighter.

• indicates YAEC commitment to the position or to the intent.

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4.13 Training is scheduled on a quarterly basis and is designed i to repeat the classroom sessions over a two year period.

Hands on type training is conducted on-site on an annual basis, consisting of the use of extinguishers, operating manual hose streams on oil fires and simulated fire fighting conditions that could occur in the plant.

The training tapes prepared by ITC are used as the basis for the fire brigade training along with personal instruction by the Training Coordinator.

4.1.4 Fire brigade leaders and other members of the fire brigade who may have to assume command of the brigade do not receive any specialized training in Icadership and command tactics.

4.1 5 Records of training are kept both in the individuals' file and in the general training file showing all participants.

Training records show the date, time allocated, subject covered and personnel attendance.

4.1.6 Fire brigade meetings are being scheduled for the future j

and are to be conducted by the fire brigade leader for each l

l of the operating shifts.

4.1 7 Practice sessions will be held for fire brigade members at regular intervals not to exceed one calenday year for each l

l fire brigade member.

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4.1.8 Fire brigade drills will be performe'dlat regular ' intervals with a minimug of L two drills' per calendar year so that each fire brigade member participates in at least one drill per calendar year.

All fire. drills are pre-planned, . some are unannounced 'from time P Lto time, and all are critiqued by the Training Coordinator.

At least annually the'off-site fire' assistance forces are

, invited to participate in training / drills.

,. 4.2 Adeaunov of Fire Bricade Trainine J 4.2.1 Fire. brigade training is generally adequate in frequency i

and content with the exception of the lack of leadership training-and the limited hands)on training. conducted onsite.-

, 4.2.2 The fire drill frequency is not adequate to assurefthat the. brigade members receive sufficient-practice-to assure-that-their fire fighting knowledge and skills will be kept at the-i proper level.

4.2 3 At this time the joint training with the off-sit'e fire suppression forces appears to be inadequate, and there are indications that Laproved participation on the part of the off-site people may be difficult to achieve.

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4.3 Modifications and Reconmendatio,Its.,

4.3 1 The fire brigade leader and assistant leader should-

. receive a special leadership training which includes at least (1) critical factor' analysis, (2) fire action plans, (3) tactics for fire control,.(4) command. decision making, (5)' coordination of fire control efforts.

(x).4.3 2 Fire brigade members should~have additional hands on.

training under live- fire conditions either at a suitable off-site location or on site if suitable facilities can be provided.

4.3 3 Fire ' drills should be scheduled quarterly for each. shift to assure that all' members of the fire brigade receive adequate c

practice and to permit the evaluation of the adequacy of the training program. The position taken by YAEC in the letter to the N.R.C. dated May 10, 1978, "2. Drills" is not acceptable in relation to fire drill frequency. '

4.3.4 The Training Coordinator shoc1d investigate the avail-ability of fire fighting instructors from the Massachusetts fire academy for possible assistance in carrying out the fire brigade training.

4.3 5 A concerted effort should be made to involve the off-site fire forces in meaningful joint training and drills with the YR fire brigade. The involvement of the Massachusetts fire (x) indicates YAEC rejection of the position.

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- 4 t DRAFT-10/2/78 YA1EEE RC7dE academy might help to encourage participation by the off-site assistance forces. (See 5 1 3) 4.3.6 As pre-fire strategies are developed (See 73) these should be used as training aids and as part of the fire drill format. The purpose being to familiarize the fire brigade, and the off-site assistance, with those areas Vhere special precautions must be taken and where fire fighting will be cost difficult.

5. OFF-SITE FIRE SUPPRESSION ASSISTANCE 51 Yankee Howe nuclear power plant is located in the town limits of the town of Rowe, Massachusetts and is entitled to fire protection from the Rowe Volunteer Fire Department.

Fire protection is also provided by the Monroe Volunteer Fire Department on an agreement basis and as part of the aroafire mutual aid.

Both Rove and Monroe are called any time that off-site assistance is deemed necessary by the fire brigade leader.

5 1.1 Both Rowe and Monroe are fully volunteer fire departments.

The roster for Rowe totals approximately 40 members, of which 20 are considered active members.

The Monroe roster totals 7 members, all are considered active.

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' J YANKEE RUDE 51.2 The qualifications of the fire chiefs of both Rowe and Monroe are limited to their personal experience as volunteer fire fighters with minimal formal training.

The Rowe chief has been a volunteer for 30 years and has a total of 10 years as chief over three broken tenas. The Rowe chief is elected by the membership each year without limitation. He in turn selects his officers who serve at the pleasure of the chief. There are no specific qualifications or standards for becoming an officer of the RVFD.

The Monroe chief has been a volunteer for 10 years and has been chief for the past 2 years. He is appointed by the selectmen and serves at their pleasure. He in turn selects his officers much the same as Rowe. Fire fighters are elected by the fire companies following application and there are no specific requirements regarding training or other qualifications.

Consideration must be given to the fact that Rowe and Monroe are communities of approximately 300 individuals; therefore the volunteer fire companies are forced to take anyone who applies.

513 Rowe VFD does not have specific training requirements.

Meetings and training are held whenever the chief decides to call one. Usually meetings are held mohthly except during the summer.

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s 8 Monroe VFD has. required monthly meeting / training sessions year li round. ,

Neither RVFD or MVFD have any kind of formal training requirements.

. Neither department requ$res.its personnel to attend training schools and neither takes'much advantage of the programs offered by the Massachusetts fire academy.

51.4~ The Rowe V.F.D. has two pumper / tankers, one 750 CPM (1971) and one 500 GPM (1962) both of which are reasonably equipped for rural fire fighting.

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{ Monroe has one pumper / tanker, a' 750 GPM (1960) which is also reasonably equipped for rural fire fighting.

5 1 5 Special equipment that would be valuable to the plant consists of a large supply of fire fighting foams at the'Rowe

, V.F.D. , beyond this neither fire company has any special equipment.  :

5 1.6 Monroe V.F.D's fire station ir, located approximately 1 5 miles from the-plant. Response is limited to one access f

road that is narrow and.often congested at one point by industrial

. trucking operations.

Response time, without obstructions of any sort, is estimated to be 10 minutes. Personnel available during the work day may be limited to something less than the seven active men.

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DRAPT-10/2/78 YANKEE RO'4E Rowe V.F.D. is located approximately 4 miles from the plant over very winding roads and steep hills. Response timo under normal clear vaather conditions is estimated at twenty minutes. l Manpower available during the normal work day is estimated at ten men.

Rowe's active volunteers are each provided with a radio call system at their homes. Monroe V.F.D. depends on a factory steam whistle to alert its members.

517 Command authority for fire fighting at the plant sito rests with the plant fire brigade leader. This is c1carly I

unders tood by both Rowe and Monroo chiefs.

5.1.8 Joint training between the off-site fire companies and the plant fire brigade has been minimal, for the most part consisting of annual familiarization visits to the plant.

519 Doth the Rowe and Monroe V.F.D.'s belong to the tri-state fire mutual aid system that encompasses a 25 mile radius.

There is an automatic move up system employed which would provide additional apparatus and manpower if necessary.

52 Adecuacy of Off-Site Fire Suppression Assistance 5 2.1 The Rowe and Monroc Volunteer Fire Departments are very typical of remote rural volunteer fire companics. They are minimally adequate to protect their communities; however they are considered inadequate as related to providing viable fire suppression assistance to the YR fire brigado.

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DRAFT-10/2/78 YAM:EE ROWE It should be clearly understood that I do not intend to belittle the Rovo V.F.D. and the Monroe V.F.D. in any way; I merely want to make the limitations of these departments clearly known to the N.R.C. as related to a self-sufficient fire brigade at the plant.

5.3 Modifications and Recommendations 5.3.1 YAEC should encourage and support the training of the off-site suppression forces both in the areas of improved internal training, training by the Massachusetts fire academy and by providing training facilities at the plant site for the fire companies to use and where joint fire brigade /off-site suppression forces training can be conducted.

532 YR should mak very possible effort to encourage the off-site fire suppression forces to participate in joint training and drills at the plant. -

533 As soon as the pre-fire strategies are developed for the safety related areas of the plant, the off-site assistance l forces should be advised of the strategies and invited to participate in test drills to check the validity of the strategies.

6. IUJGAL FIRE SUPPRESSION EQUIPMEITf I

l 6.1 The manual fire suppression equipaent and related facilities l

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DRAFT-10/2/78 TAlH3E R0WE 4

were evaluated during the site visit and found to be generally lacking as to fixed manual fire suppression and in relation to the manual equipment available for fire fighting. Generally the equipment that is provided was found to'be in good condition and properly maintained.

6.1.1 Water supply for the fire system is obtained from Sherman Pond, an unlimited supply, through two electric fire pumps located in the screen well house having a single 10" connection to the fire water loop.

Each of the fire pumps are rated at 1000 GPM at 125 psi.

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There is no back-up supply for the fire water system other than having a fire pumper draft from the pond and pump directly into >

the system. Two pumpers could supply approximately 750 Gal.

each for a total flow of about 1500 Gal.

6.1.2 The 8" yard fire water loop is sectionalized through the use of isolation valves located to protect the entire system from shut down in the event of a failure or need for repair of one portion the system.

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Connections to the interior fire protection systems is also through 8" pipe provided with isolation valves.

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i 6.1 3 Hydrants are three way frost proof type connected to

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the fire water loop by 6" branch connections equipped with individual curb box valves. Hydrant outlets have national standard fire hose thread.

Hydrants are not provided with 2t" gate valves. Annua]ly the hydrants are checked for flow and to see that standing water does not remain in the barrel of the hydrant during freezing weather. A manual pump is provided to remove water that does not drain out of the hydrant; however the winterization of the hydrants is not spelled out in administrative procedures covering inspection and maintenance.

With a few exceptions the hydrants are located so that they are not subject to impact damage.

6.1.4 Post indicator valves (PIVs) controlling sections of the fire water loop and interior fire suppression equipment 1

are not labeled to indicate what each valve controls and all are not adequately barricaded to prevent impact damage.

6.15 Five exterior hose houses, of the type that enclose the hydrant, are located around the yard loop spaced approximately 1

at 250' intervals. These hose houses are of wood construction and are ample in size to contain the required equipment. The hose houses are weathorproof, in good condition, but do not I

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., , YANKEE ROWE have sufficient ventilation openings. Hose houses are not adequately secured.

Fire fighting equipment located in the exterior hose houses was found to be minimal. Four of the five did not contain any li" hose and the one that did only had 1 - 50' length of li" hose. Equipment provided included - 250' synthetic jacket, 600 lb. test 2)" fire , hose - 2 hydrant wrenches - 1 axe -

1 crow bar 30" underwriters playpipes (one equipped with a fog tip, the other with a 1 1/8" straight stream tip) and 2 hose holders. A curb box valve wrench is located at each hose house, 150' of 2{" hose and the single length of 1 " hose is stored on shelves in accordion folds with the 2i" hose pre-coupled to the hydrant. 100' of 2 " hose is donut rolled.

6.1.6 There are ten interior fire hose , stations located in safety related areas of the plant. Additionally there are standpipe hose stations in non-safety related areas that could be used in safety related areas under some circumstances.

Piping to the interior fire hose standpipe system is generally l

of small diameter with the connection to the hose valves often l' of li" diameter.

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l Hose stations in safety related areas are reel type equipped i

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DRAFT-10/2/78 YANKEE ROJE with 50' of li" rubber jacket rubber lined booster type hose having N,H. hose thread and a li" fog-straight stream nozzle with ball type shut off. It" hose located in the cabinets in non-safety related areas is single jacket, synthetic, rubber lined with U.H. coupling thread.

All fire hose, both interior and exterior, 2t" and It", is tested annually at 250 psi using a fire pumper from the Rowe VFD.

6.1 7 Six self-contained breathing apparatus, pressure demand type, each provided with two spare air cylinders are provided for emergency use in the plant. All are rated for t hour and are manufactured by Scott.

Air packs are stored in wall mounted walk-away cases, three at the controlled access point and three in the stairwell adjacent to the switchgear room.

Yankee Bowe has two large air compressors for recharging of SCBA equipment. The compressors are provided with excellent i

filtering equipment. As presently set up, it is possible to l refill two cylinders at a time off the compressor, no cascade )

system is available nor is the compressor equipped with a cooling tank for cylinder refill.

There is no air system provided to the control room nor does the control room have portable SCBA.

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DRAFT-10/2/78 JA1EEE ROWE 6.1.8 Approximately 92 fire extinguishers are suitably located throughout the plant, ranging in size from 2 3/4 lb. to 150 lb.

units. Extinguishers are predominately dry chemical type with some CO2 and pressure water types.

r Extinguishers are generally suitable for the area to be pro-tected and appear to be spaced according to NFPA #10.

6.1 9 Each member prosently assigned to the fire brigade is provided with a complete set of protective clocb'ng consisting of helmet, turnout coat, boots and gloves. This equipment is all stored in cabinets at a central location in the H.P. area.

l Each brigado member is responsible for his personal protective r

clothing.

l 6.1.10 Two portable foam applicator playpipes with 35 gallons

, of 3% foam is provided to assist in fighting flammable liquid I

l fires. One is designed for use on 2A" hose, the other for it" f hose. These items are stored at opposite points in the plant.

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6.2 Adecuacy of Manual Fire Suppression Ecuipment 1

6.2.1 The inspection, maintenance and testing progren for i 1

manual fire suppression equipment is clearly defined and i adequately carried out through administrative orders and procedures, i

1 6.2.2 Fire fighting equipment located in exterior hose houses l

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, YANKEE ROWE is inadequate.

6.2 3 Self-contained breathing equipment is not adequate to meet the U.R.C. requirement. The refilling system now is use -

does not meet normal safety standards for recharging SCBA air cylinders.

6.2.4 The number and location of interior hose stations is not adequate to provide effective canual fire suppression hose streams to all safety related areas.

6.2 5 The question of the adequacy of the cristing fire pt::aps to meet the system demand has not been resolved; however it appears that the fire pumps are inadequate.

6.3 l'odificq.tions and Recommendations 631 Hose stations

• Hose station should be provided to reach all areas of the primary auxiliary building.

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• A hose station should be provided to reach all areas of the diesel generator building.  ;

l NOTE:

• indicates YAEC commitment to the positicn or to the intent (x) indicates YAEC rejection of the position E indicates YAEC will evaluate the position and respond l

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DRAFT-10/2/78 Y. AlHIE ROWS

• Hose stations should be provided to provide coverage of cable trays and stored combustibles and to cover operations floor.

(x) A fire hose station should be provided in mechanical equipment room #3 E Additional hose should be provided at hose stations for which reach may be insufficient.

6.3 2 Provide two 17 lb. Enlon 1211 portable extinguishers for the control room.

6.3 3 Two air masks and four spare bottles should be at tho I

control room.

l 6 3.4 Yard loop and hose houses - portable equipment

• 1. Each hose house should have the following additional equipments

a. one 2t" x lt" x lt" gated wye

b. one 2 " gate valve on hydrant

c. two It" combination fog nozzles

d. It" hose spanner vrenches

- e. one portable hand light (7t volt)

(x) f. one Halligan forcible entry tool

g. assortment of hose gaskets

h. 200 ft. li" hose r

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• 2. Tall post indicator valves should.be tagged indicating

-service (x)3 Post barricades should be provided for hydrants and PIVs which could be damaged by vehicles.

• 4. Hydrants should.be checked for dra$nage in;the fall',-

outlets lubricated and. pressurized in spring to. check l for vinter damage. I (x)y. Hose houses'should have weather proof ventilators.

• 6. Hose house doors should be checked to insure clearance.

(x)7 A foam cart should be provided for foam. pick up tubes  !

I and ton containers (y gal each) of foam. Adapters should be provided so pick'up tubes can be fitted to i

2i" hose. i

• 8. Additional equipment should be provided.at equipment-storage location consisting-of:

a. 3 explosion proof fire service smoke ejectors (15,000 to 20,000 CFM total' capacity)

b. two 2 " double female ddapters

c. ten portable hand lights O

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DRAFT-10/2/78 YAN1GE ROWE e

(x) d. three portable radios dedicated to fire brigado and plant operations personnel emergency use.

E e. four air breathing apparatus, eight spare bottles.

• f. spare hose nozzles, hose, etc..should be stored at a central location.

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9 Three air packs and twelve spare bottles should be l

relocated to a safe location away from high fire hazard area.

(x)10. A cooling tank should be provided at air recharging station (compressor).

(x)11. A cascade recharge system with existing large air storage bottles should be provided.

6 3 5 Fire water supply E 1. An automatic start diesel fire pump rated at least 2000 GPM at 125 psi should be provided with an independent feed to the yard loop underground system. Valving should be provided at yard loop connection independent for existing loop feed, per NFPA 20.

• 2. Bleed and block connections should be provided for existing fire pump start pressure switches to permit full system testing.

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Firo pumps . should start' at '110 and -100 psig. .

• 6 3.6=_ Additional foam agents should be provided on site, '

100 gallons minimum.-

7. . FIRE FIGHTING PROCEDURES 71 As part of the overall emergency plan for YR,_a fire  !

emergency is covered under OP-3017 which: details the action to ,

be taken to control any fire that occurs.

7 1.1 OP-3017 defines the basic action to be taken by the. -

individual who discovers a fire and the actions to be taken.

by the control room personnel, office personnel and visitors. .

t Further specific responsibilities as related to a fire emergency l are contained in AP-2001-which defines the responsibilities-of operations department personnel.

7 1.2 The Shift Supervisor 'is designated as the fire brigade leader and in his capacity as shift supervisor has the authority  ;

! and responsibility for all emergencies at the plant including fires until such time as relieved by the plant emergency i

. coordinator.

The Shift Supervisor is responsible for calling for off-site assistance depending upon the severity of the fire. Normal process is for the Shift Supervisor to investigate the severity ,

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of the fire before calling for off-site assistance. l 1

713 Pre-fire plans have not been developed for safety related areas or for other plant areas where fire suppression may be difficult.

7 1.4 The present procedure for response to a fire alarm received from an automatic detection and/or suppression system is to wait for investigation before calling out the fire brigade.

72 Adeauacy of Fire F3 chtine Procedures 7 2.1 At the time of the site visit the fire fighting procedures in effect at YB were inadequate in the areas listed under 7.3 73 Modificati ons and Recommendations-731 Fire Fighting Procedures - Fire fighting strategies should be established and documented for fighting fires in all safety related areas and areas presenting a hazard to safety related equipment, in accordance with the guidance contained in Attachment No.. y sub-sections d and e, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls

- and Quality Assurance". These plans should be simple and straight-forward and may be documented as brigade training aids; but should be availabic for quick reference in a fire situation.

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, ~31- YANKEE R0WE

• 732 Off-site fire assistanco should be called immediately for all confirmed fires that can not be extinguished by the person discovering the fire.

• 733 A specific procedure should be developed for the recall of off duty fire brigade members for all fires where immediate control cannot be achieved.

7 3.4 Procedures shduld be developed to provide direction to all plant personnel as to actions to be taken on discovery of a fire. Visitors and contractor personnel should be included in these procedures.

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8. AUTOMATIC FIRE DETECTION AND SUPPRESSION SYSTEMS 8.1 Generally YR does not have extensive automatic detection and suppression systems, although some safety related areas are covered. There are a number of areas that need additional detection and/or suppression systems.

8.12. At the time of the site visit the automatic fire detection systems consisted of ionization detectors. The automatic suppression systems consisted of sprinkler / deluge systems that are interconnected.

8.2 ' Adecuacy of Automatic Fire Detection and Suporession Systems 8.2.1 In the opinion of this consultant very careful con-A *

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DRAFT-10/2/78 YAIDIE RO'dE sideration must be given to the consequences of a fire in any area of the plant regardless of the safety relation of the specific area. A fire of any seriousness can drastically alter the normal conditions and in many instances can result in conditions that are not being controlled by the expected means.

The build-up of smoke and heat in a confined area also builds pressure. The deteriorating effect of the fire coupled with the precoure build-up often results in smoke and heat passing into other arees, even though the fire area is sealed off for all intens and pu2 ?oses Fire doors, fire dampers and other seal-off methods do not always perform as expected.

One of the results of situations enumerated above is that a fire in a non-cafety related area may have a serious effect on safety related areas considered to be remote from the fire area.

8.2.2 The automatic fire detection and suppression systems at YR are considered to be inadequate as presently in operation.

8.3 Fodif;1 cations and Recommendations

• 8.3.1 Fire detection (early varning) should be provided over each charging pump cubicle.

8.3 2 An automatic suppression system should be provided to protect each diesel generator room, flame detector actuation.

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• Man hole #3 should be modified to make CO 2 protection auto-matic actuation.

(r) 8 3 3 Vapor Container - fire detection should be provided above cable risers in steam generator / coolant pump compartments and major combustibles.

(x) 8.3.1+ An automatic sprinkler system should be provided in the heating boiler room.

E 8.315 Switchgear Room - an automatic total flooding Halon 1301

suppression system should be provided.

• 8.3.6 Control Room - early warning detection should be provided in the D-G/SI control panel.

Early warning fire detection should be provided in offices at east end of room and in the kitchen area.

• 8.3 7 A battery back up emergency power source should be provided for fire alarm systems.

Remote indicating lights should be provided for out of sight fire detectors. (above control room ceiling, man hole #3)

E 8.3.8 An automatic foam deluge system should be provided for the following:

a. lube oil reservoir

b. H2 seal oil unit

c. transformer oil coolers

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-3 + - YAH12E ROWE (The water supply feed should be independent of sprinklers and hose stations protecting- the same area.)-

E An automatic sprinkler system should be provided throughout 2

the turbine building with a 0 3 gpm/ft density over the most 2 The feed to the system should

• hydraulically remote 3000 ft .

be independent of deluge systems and hose stations protecting the same area.

9 GENERAL OBSERVATIONS AND RECom1ENDATIONS ,

91 The overall condition of the plant in relation to house-keeping, general cicanliness, control of combustibles and control of ignition sources was outstanding. As always there are areas where improvement can be achieved and where the result would be an even better general safety condition throughout the plant site.

92 In relation to control of combustibles, the-following staff positions shc'uld be complied with:

• 9 2.1 Combustibic storage in diesel generator buildings should be removed or suitably protected.

(x) 9 2.2 Wood storage boxes should be removed, fuel storage vault.

E 923 The turbine lube oil reservoir should be dyked to contain the contents of the lube oil reservoir plus an allowance for suppression water.

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i E 9 2.4 The curb height for the transformer oil cooler should be increased to contain suppression agents with consideration of drainage capability.

9 2 5 Waste oil and combustibles should be removed from electrical duct bank area at north end ofail storage room.

E 9 2.6 The oil storage room doors should be curbed to contain normal oil storage plus an allowance for suppression water.

• The earthen dike around fuel oil storage tank should 927 be verified to be sufficient to hold the contents plus ,

suppression water.

93 In relation to control of ignition sources, the procedures for controls of cutting and welding are adequate.

It was noted that smoking is adequately controlled throughout the plant. No violations of no smoking rules were noted.

9.4 In general the cooperation received from the utility personnel with whom we had contact was good. It appeared

. that the YR and YAEC people did everything they could to assist the temn in its evaluation. This consultant attempted to offer valuable advice to the N.R.C. team and suggestions for improved fire safety to YR staff.

h OHN F. TOWi! LEY Fire Services Consultant J

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