ML20148F073

Forwards Guidance Re Manpower Requirements for Operating Reactors.Requests Util Reply Re Operating Staff & Security Force Personnel Requirements within 20 Days

ML20148F073
Person / Time
Site:	Yankee Rowe
Issue date:	06/08/1978
From:	Stello V Office of Nuclear Reactor Regulation
To:	Groce R YANKEE ATOMIC ELECTRIC CO.
References
NUDOCS 8011030746
Download: ML20148F073 (10)

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NRC PDR Local PDR JUN B 1978 ORB #2 RDG M DLZiemann ucchet No. Ob [ HSmith ABurger .

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- Yankee Atomic Electric Companv OELD -

ATTil:  !!r. hocert !!. Groce OI&E (3) '

Licensing Engineer DEisenhut 20 Turnpike Road VStello

!!estbcro, !:assachusctts 01581 TBAbernathy ;_ "!

JRBuchanan ,

Gentlemen: ACRS (16) ,.e RE: !!ANPCl!ER P.EOUIP. Diet 1TS FOR OPE!:ATING P.EACTORS lle are enclosing a document entitled, "Manpover Require,cr,ts for Operating Reactors." !!c are using the bases given in this docunent ij for allowing the sharing of duties to r'eet mininun staffing reoutre-r.1ents for fire brigades at nuclear power plants. This is being provided for your guidance in meeting flP.C requirements in this ,

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By letter dated December 14, 1977, you on,iected to e rerguire- F ment for o ninicua fire brigaue size of S beino it, corn > rated in  !

the Tecnnical Specifications for the Yankee-Rowe Atonic Poesr O

. Station. We request that you review the enclosed guionnce in l:

regaro to the use of personnel on the operating staff and security ,

force in r:anning the fire brigade an't infona us by letter vitnin tventy daft vi.ctbor you continue to objcct to our pr sition on nininu, fire brigade size.

Sincerely,

\h ..

ictor

. Stello, Jr. , Di rector Division of Operating reactors Of fice of leuclear Reactor 9eculation Enciescrc:

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Yankee Atomic Electric Company June 8,1978 l l

. cc: Mr. Donald G. Allen, President Yankee Atomic Electric Company 1 20 Turnpike Road l Westbtro, Massachusetts 01581 Greenfield Community College 1 College Drive Greenfield, Massachusetts 01301 0

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l MANPOWER REQUIREMENTS FOR OPERATING REACTORS i l

The NRC has established requirements for personnel at operating reactors for purposes of plant operation, industrial security, and fire fighting. The following discussion considers the extent to which plant personnel assigned to either plant operation or security may also be temporarily allowed to man a fire brigade in the event of a fire for a single unit facility and sets forth an acceptable sharing scheme for operating reactors.

Summary of Manpower Recuirements

1. Fire Brigade: The staff has concitded that the minimum size of the fire brigade shift should be five persons unless a specific site evaluation has been completed and some other

) number justified. The five-man team would consist of one leader and four fire fighters and would be expected to provide defense against the fire for an initial 30-minute period. See Attachment A for the basis for the need for a five-man fire brigade. '

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2. Plant Operation: Standard Review Plan Section 13.1.2 requires that for a station having one licensed unit, each shift crew -

! should have at least three persons at all times, plus two additional persons when the unit is operating. For ease of reference, Attachment B contains a copy of this SRP.

3. Plant Security: The requirements for a guard force are outlined -

in 10 CFR Part 73.55. In the course of the staff's review of proposed security plans, a required minimum security response force will be established for each specific site. In addition to the response team, two additional members of the security  :

force will be required to continuously man the Central Alarm Station (CAS) and Secondary Alarm Station (SAS). It is expected that many facilities will have a security organization with greater numbers of personnel than the minimum number assumed for purposes of discussion in this paper.

l The NRC' staff has given consideration to'the appropriateness of per-t mitting a limited degree of sharing to satisfy the requirements of plant operation, security and fire protection and has concluded that, (1) subject to certain site and plant specific conditions, the fire i brigade staffing could generally be provided through operations and 3 security personnel, and (2) the requirements for operators and'the j security force should remain uncompromised. Until a site specific review is completed, the following indicates the interin distribution and justification for these dual assignments, and there#cre cur interim minimum requirements for a typical presently operating comercial single unit facility. The staff believes that manpower for the fire brigade for multi-unit facilities is not now a problem because of the larger numbers of people generally present at the sites. Situations which do pose problems will be reviewed on a case-by-case basis.

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1. Plant Operation: The staff has concluded that for most events at a single unit nuclear facility, a minimum of three operators should be available to place the reactor in a safe condition.

The two additional operators required to be available at the nuclear facility are generally required to be present to perform routine jobs which can be interrupted to accomodate unusual situations that may arise. That is, there is the potential for the remaining two members of the operating crew to assume other short-tem duties such as fire fighting. In light of the original rationale for providing extra plant operators to cope with off-normal conditions, it appears justified to rely on these personnel for this function. The staff recommends that one of the two operators assigned to the fire brigade should be designated as -

leader of the fire brigade in view of his backgrourd in plant operations and overall familiarity with' the plant. In this' regard , .

the shift supervisor should not be the fire brigade leade "

because his presence is necessary elsewhere if fires occur in certain critical areas of the plant.

2. Plant Security: In the event of a fire, a contingency plan and -

proceoures will be used in deploying tne security organization to assure that u appropriate level of physical protection is maintained during the event. The staff has determined that it is possible in the planning for site response to a fire, to assign a maximum of three members of the security organization to serve on the fire brigade and still provide an acceptable level of physical protection. While certain security posts must be manned continuously (e.g., CAS, SAS), the personnel in other assignments, including the response force, could be temporarily (i.e., 30 minutes)- assigned to the fire brigade. In judging the merits of this allowance the underlying question is whether the minimum security force strength must be maintained continuously in the event of a plant emergency l such as a fire. Further examination of this issue leads to two I potential rationales for reaching an affirmative decision. First, could there be a causal connection between a fire and the security threat? Second, are there compelling policy reasons to postulate a simultaneous threat and fire? i l

The first potential rationale would only be credible if, (1) the insider (posed as part of the threat definition) was an active participant in an assault and started a fire coincident with the attack on the plant or, (2) a diversionary fire was started by an attack force somewhere external to the plant itself where no equipment required for safe shutdown is located. The role of the insider will be discussed first. While 73.55 assigns an active status to the insider, the rule also requires that measures be implemented to contain his activities and thereby reduce his

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1 effectiveness. At present, these measures include background checks on plant employees, limited access to vital plant areas, badging systems and the two-man rule. Here, limited access l means that only designated employees are allowed in vital areas and that their entry is controlled by either conventional locks or card-key systems. Also, if separate trains of safety equip-  ;

ment are involved,then either compartmentalization or the two- I man rule is required. These measures to contain the insider are presently being implemented and will provide assurance that people l of questionable reliability would not be able to gain employee status at a nuclear plant and should they become an employee with unescorted access, significant restraints would be inter-posed on the ability of such a person to carry out extensive damage to plant vital areas. Recognizing that additional safeguards may still be appropriate, the staff has recomended to the Comission that plant personnel also be required to obtain an NRC security clearance. The staff believes that the attendant background investigation associated with a clearance, in con-junction with the other 73.55 measures, will provide a high degree of assurance that plant personnel will not attempt to take an active sabotage role. If the clearance rule is adopted the staff believes some of the measures, such as the two-man rule, designed to contain the insider can be relaxed. Thus,'

there does not now appear to be a reasonably credible causative relationship between a fire intentionally set by an insider and the postulated external security threat. For the case of diversionary fires set external to the plant itself, adequate security forces can still be maintained by allowing only part of the fire brigade to respond while both fire fighters and security forc6 armed responders maintain a high degree of alertness for a possible real attack somewhere else on the plant. Thus, the effective number of armed responders required by 73.55 can be i maintained for external diversionary fires.

1 The second potential rationale concerns whether a serious, I spontaneous fire should be postulated coincident with an external security threat as a design basis. In evaluating such a require-ment it is useful to consider the likelihood of occurrence of i this combination of events. While it is difficult to quantify the probability of the 73.55 threat, it is generally accepted that it is small, comparable probably to other design basis type events. The probability of a fire which is spontaneous and located in 'or in close proximity to a vital area of the plant '

and is serious enough to pose a significant safety concern is also small. It would appear, therefore, that the random coincidence l of these two unlikely events would be sufficiently small to not

require protection against their simultaneous occurrence. In  ;

addition, it should be noted that the short time period (30 minutes) (

for which several members of the security force would be dedicated j to the fire brigade would further reduce the likelihood of coincidence. (

As neither of the two potential rationales appear to preclude the use of members of the security force in the event of a fire the staff has concluded that the short assignment of security personnel from the armed response force or other available security personnel to the fire brigade under these conditions would be, acceptable.

To ensure a timely and effective response to a fire, while still preserving a flexible security response, the staff believes that

, the fire brigade should operate in the following manner. In the event of an internal fire, all five members of the fire brigade should be dispatched to the scene of the fire to assess the nature and seriousness of the fire. Simultaneously, the plant security I force should be actively evaluating the possibility of any security l threat to the plant and taking any actions which are necessary to 1 counter that threat. For external fires, a lesser number than the five-man brigade should respond for assessment and fire fighting.

As the overall plant situation becomes apparent it would be expected-that the most effective distribution of manpower between plant operations, security and fire protection would be made, allowing a balanced utilization of manpower resources until offsite assistance becomes available. The manpower pool provided by the plant operations personnel and security force are adequate to respond to the occurrence of a design basis fire or a security threat equivalent to the 73.55 performance requirements. It is also recognized that other, more likely combinations of postulated fires and security threats of a lesser magnitude than the design basis, could be censidered. .While the probabilities of these higher likelihood events may be sufficient to warrant protecting against them in combination, the manpower requirements required to cope with each event would be similarly reduced thereby allowing adequate coverage by plant personnel.

Conclusion The staff believes tha.t it would be reasonable to allow a limited amount of sharing of plant personnel in satisfying the requirements of plant operhtion, security, and fire protection. An acce'ptable sharing scheme would entail reliance on two plant operators and three members of the security organization to constitute the fire brigade. Since availability of the full fire brigade would only

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be required for fires with potential for serious damage, actual distribution of plant personnel during a plant emergency world be I governed by the exigencies of the situation. Of course, all personnel  !

assigned to the fire brigade would have to fulfill all applicable I training requirements. It should also be recognized that the diversion of personnel to the fire brigade would- be of short duration and that substantial additional offsite assistance would be forthcoming in accordance with the emergency and contingency plan developed for each facility. In evaluating licensee proposals for manpower sharing due consideration will also. have to be made of unique facility characteristics, such as terrain and plant lay-out, as well as the overall strengths of the licensee's fire and security plan 2. Minimum protection levels 4n either area could preclude the sharing of manpower.

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Staff Position Minimum Fire Dri'cade Shift Size _ '

• INTRODF' TION .

Nuclear power plants depend on the response of an onsite fire brigade ~

for d..fense cgainst the effects of fire on plant safe shutdown capabilities. In some areas, actions by the fire brigade are th'e

,only means of fire suppression. In other ereas, that are protected by correctly designed cutenstic detection and suppression systems, manual fire fignting efforts are used to extinguish: (1) fires too small to actuate the autcmatic system; (2) well developed fires if the auten: tic system fails to function; and (3) fires that are not completely controlled by the automatic system. Thus, an adeouste fire brigade is -

essential to fulfiil the defense in depth requirements which protect '

safe shutdewn systems from the effects of fires and .their related

- combur. tion by-products.

. DISCUSSICH There are a number of factors that should be considered in establishing the minircum fire brigade shift size. They include: i

1) picnt cecmet.ry and size;

2) quant-ity and quality of detection and suppression systems;

3) fire fighting strategics for postulated fires;

4) fire brigace training;

5) fire brigado equipment; and

6) fire brigade supplements by plant personnel and local fire

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department (s). .

In all plants, tha majority of postulated fires are in enclosed window-less structures. In such arci.s, the working environment of the brigade

. created by the heat and s=cke buildup within the enclosure, will require the use of self-contained brecthing apparatus, socke ventilation ecuipment,

. and a personnel replacement capability.

Certain functions must be performed for all fires, i.e. , comand brigade actions, infom plant management, fire suppression, ventilation control, provide exira equipment, and account for possible injuries. Until a site specific review can be completed, an interim minimum fire brigade size of five persons has been established. This rigade size should provide a minimum working number of personnel to deal with those postulated fires in a typical presently operating comercial nuclear power station.

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,s' c 2 I if the brigoce is composed of a smaller number of personnel, the fire attcck may be stopped whenever new equipT.ent is needed 'or a person is i injured or f atigued. We note that in t5e career fire service, the j

minimum engine comnany manning considered to be effective for an initial

- attack on .a fire is also five, including one of ficer. and four team members.

It is assured for the purposes of this position that brigade training and equipment 1.s adequate and that a backup capability of trained individuals exist whether through plant personnel call back or from the local fire department.- l POSITIOU .

1. The minimum fire br*,gade shif t size should be , justified by an analysis of the plant specific factors stated above f.or the plant, after modifications are cemplete. " -

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2. In the interim, the minimum fire brigade shift size shall be five persons. These persons shall be fully qualified to perform their assigned responsibility, and shall include: ,

One Su9ervisor - This individual must have fire tactics trainino.

He wili assume all command responsibilities for fighting the fife.

During plant emergencies, the brigade supervisor should not have other resconsibilities that would detract from his full attention being devoted to the fire. This supervisor should not be actively engag7d in the fighting of the fire. His total function should be to survey the fire area, ccmmand the brigade, and keep the upper levels of plant r.ianagement infermed. .

Two Hose Men - A 1.5 inch fire hose being handled within a window-

- less enclosure would require two trained individuals. The two team members are required to physically handle the active hose line and to protect each other while in the adverse environment of the fire.

. . Two Additionc1 Team Mercers - One of these individuals would be requir:c to supply Tilloc air cylinders to the fire fighting

- members of the brig &de and the second t ~ establish smoke ventilation and aid in filling the air cylinder. These two individuals y ould also a'ct as the first backup to the engaged team.

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I 4 a. Assignrents of personnel reeting Ah$1 N18.1 1971 cualifi-stions, Section 4.3.1 or Section 4.$.1, should be made to onsite shif t operatina cys in numbers not less l than the following: l

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• ; 1 i For a station having one licensed unit, each shif t crew should have at least three l 1

persons at all times, plus tw additional persons when the unit is operating. l For a rulti-unit station, each shift crew should have at least three persons per licensed unit at all times, plus one additional person per, operating unit.

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b. Operator license qualifications of persons assigned to operating shift crews should be as follows: ,

(1) A licensed senior operator wne is also a memoer of the station supervisory staff should be onsite at all tirnes when at least one unit is loaded with fuel.

(2) For any station with more than one reactor containing fuel, (1) the fiucer of licensed senior oper: tors onsite at a' oes should n:t be less than the I number of control rooms from which th' 4 units are monitored, and (2) the number of licensed senior ope .cors should not be less than the nutnter of reactors operating.

(3) For e ch rea: tor containing fuel, there should be at least one licensed oper..or in the conte:1 roo- at all times. Shift cre. co ::sitions should be spe:ified such that this condition can be satisfied independently of

!' licensed senior operators assigned to shift crews to meet the :riteria of

(1) and (2) above. -

(41 For each control reor frew which one or more reactors are in coeration, an t

additional operator should be ensite and available te serve as relief operator for that cor. trol ro:1 shif* crew comoesitions sh:uld be spe:ified such that this condition can te satisfied independently of (1), (2), and (3), and for eacn such centrol re:m.

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C. Iladiation prote: tier c',ali#icati ns'ef at least ont person on ea:h operating shif t should oe as follows:

The mar. age ent of each s*1 tion havin; one or rnere writs containing fuel should either, (1) qualify anc designate at least one me .:er of ea:n shif t operating c rew to ir;1e ant radiation prote:ti:n pro:edwres, including routine or spe:ial radiati:n surveys using poeta:1e radiation detectors, use of pr:tec-tive barriers and signs, use of pr tective clothing and breathin; a::aratus, perfornante of contatination surveys, chetis or, radiation m:nitors, and limits of exposure rates and a::grulated dese, or (2) assign a health paysics tethrician to each shift, such assigerent to De in addition to those assigne: to shift operating crews in aCCgedance with (a) and (b) above. ,

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. selecti:n ar: e..p. asis of various aspects of the areas covered by this review plan will be grade by the revies.er on each cast. The judg N'*t on the areas to De given at*entier d.rir; 13.1.2 3 11/24/75 t

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