ML20207N266
| ML20207N266 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/31/1986 |
| From: | Bouchey G, Powers C WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | |
| Shared Package | |
| ML20207N251 | List: |
| References | |
| NUDOCS 8701140088 | |
| Download: ML20207N266 (13) | |
Text
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TASK 3.2 U
ASSESSMENT OF FIRE PROTECTION PROGRAM RESPONSIBILITIES AND ADMINISTRATION December,1986 u
G.D. Bouchey Dir o,
Support Servic s
,{U e AA. lN C.. Powers, WNP-Z nt Manager 8701140088 870102 PDR ADOCK 05000397 p
ASSESSMENT OF FIRE PROTECTION PROGRAM RESPONSIBILITIES AND ADMINISTRATION I.
INTRODUCTION In the 1985 Systematic Assessment of Licensee Performance (SALP) Report (issued in July 1986),.U.S. Nuclear Regulatory Commission (NRC) noted that "In general the fire protection program appears to lack effective comitment and coordination among various aspects of. the program..." They recommended that management consider..." assigning to a member of plant management staff the responsibility for providing overall coordination of the program..."
In sub-sequent discussions with the NRC-Region V Staff, they indicated their major concerns relate to strengthening the role of the registered Fire Protection Engineer and the concept of establishing a WNP-2 Fire Marshall was suggested.
These positions would assure that fire protection issues are adequately con-sidered in the course of plant engineering, operations, maintenance, and modification implementation (including resolution of issues at the proper level of management, if necessary).
Based on NRC comnents in their SALP evaluation and comitments made during recent NRC inspections the Supply System has undertaken a major reevaluation of the WNP-2 Fire Protection Programs (Reference 1). One task in this reeval-uation involves reassessment of our Fire Protection Program, definition of responsibilities, role of the Industrial Safety and Fire Protection (IS&FP) and Plant staff, and administrative / work control processes to assure their adequacy. Examples of areas that will be reexamined and improved by this task include the role of the registered fire protection engineer, fire protection staff review of welding / burning permits, fire protection review of design modifications, maintenance work requests, LERs, etc.
This report summarizes the results of the reevaluation task in two (2) sections. The first deals with organization and roles; the second with admin-istrative processes to ensure adequate implementation. A final section identifies an action plan for implementation of future milestones.
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II. WNP-2 FIRE PROTECTION PROGRAM ORGANIZATIONAL RESPONSIBILITIES AND ROLES A.
Organization Structure The Plant Manager is the line manager responsible for the adequacy of fire protection of WNP-2.
In this role, he is respcnsible for the proper implementation of the WNP-2 Fire Protection Program, including conform-ance with the applicable Federal and State regulations and corporate requirements. The Program is controlled primarily through two positions, (1) a registered Fire Protection Engineer (reporting to the IS&FP Manager) and (2) a WNP-2 Fire Marshall (remting to the WNP-2 Operations Manager).
The Supply System's organization associated with the Fire Protection Program is shown in Figure 1.
This organizational arrangement is fully consistent with NRC regulations and guidance (References 2 and 3). The role of key positions within this organization in the WNP-2 Fire Protec-tion Program are summarized below.
Assistant Managing Director for Operations [J.W. (Jack) Shannon (acting)]:
Senior management official responsible for safe and efficient operation of Supply System nuclear power facilities.
WNP-2 Plant Manager [C.M. (Chris) Powers): Overall line nanager respon-sible for the implementation and effectiveness of the WNP-2 Fire Protec-tion Program. Reports to the Assistant Managing Director for Operations.
Manager, Support Services [G.D. (Don) Bouchey]: Assigned the overall corporate responsibility for fire protection program formulation and for assessment of adequacy of fire protection at Supply Systen facilities including WNP-2. Reports to the Assistant Managing Director for Operation.
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Hanaging Director D.W. Hazur I
1 Assistant Manager Director
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Director for Lic. & Assur.
Operations R.B. Glasscock J.W. Shannon ( Acting)
Director Engineering Manager J.P. Burn Operational Assur. Prog.
C.H. McGilton WNP-2 Plant Manager Manager, WNP-2 Manager Support Srv.
Gen. Engineering C.M. Powers G.D. Bouchey L.T. Harrold Manager WNP-2 Plant QA D.S. Feldman 3
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Manager Manager Manager Manager Manager Man Mech.
Man. Nuc.
WNP-2 Maint.
WNP-2 Technical WNP-2 Operations IS&FP IAC Systems Systems Sys.& Anal:
J.A. Landon K.D. Cowan R.L. Corcoran
_J.C. Bell
,N.S. Porter
,C.R. Noyes G.L. Gelhaus u
Fire Protection WNP-2 Fire Prin. Fire Systems Engr.
Marshall Prot Engr.
R.D. Catlow J.V. Hanson
,C.D. Eggen_
(Acting)
Supply System Organizational Element Associated with Fire Protection Figure 1
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' Industrial Safety and Fire Protection Manager [J.C. (Joe) Bell]: Respon-sible for development of corporate fire protection policies / programs for all Supply System operating plants and construction projects. Responsible-for formulation and assessment of the effectiveness of the WNP-2 Fire Protection Program, in support of the WNP-2 Plant Manager. Reports to j
the Manager, Supports Services, which provides an independent management chain for policy matters or resolution of issues.
Principal Fire Protection Engineer [C.D. (Dale) Eggen]: Overall respon-sibility for ensuring the technical adequacy of all elements.of the Fire Protection Program. Encumbent is required to be a Registered Fire Protection Engineer and Member Grade in S.F.P.E.
Reports to the IS8FP Manager. Areas of responsibility and functions are summarized below:
o Safe Shutdown o
Reviews of the safe shutdown method against the Final Safety Analysis Report (FSAR) commitments; o
Reviews the fire barrier required for the safe shutdown system used; and o
Performs the Plant's fire hazards analysis and reviews the safe shutdown methods and analysis for compliance with regulatory requirement and technical adequacy.
Reviews the fire protection systems related to design, FSAR commitments, NRC or ANI letters, etc. to ensure system / program adequacy; o
Reviews new fire protection related work, including PMRs, DCPs, SCNs, and the FSAR (Volume 16 Section 9.5.1 and Appendix "F");
o Reviews NCR and LER corrective actions related to fire protection; and o
Reviews emergency lighting for safe egress, vision at shutdown panels, and adequate maintenance.
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o Administrative Control-1 o
Reviews fire protection procedures to assure commitments are met;-
o Investigates all fires / explosions to determine the root cause, to recommend changes, to prevent recurrence, and to ensure an investigation history file is maintained; o
Reviews fire brigade training ~ to ' assure compliance with proce-
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dures an'd regulations; l
o Periodically tracks fire protection system surveillances and f
preventive maintenance to assure program adequacy and proper i
implementation; o
Reviews QA audits and audit responses related to fire protec-f tion; and
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o Performs periodic plant tours and reports results to the WNP-2 Plant Manager and Manager ISAFP.
o Others 1
o Make recommendations to management to correct any weaknesses identified and help to implement the changes; and o
Provides technical support to Plant and Engineering organiza-tions, as required, to assist with identification of cost effective solutions to problems and with preparation of system designs.
Plant Fire Marshall [J.V. (John) Hanson (Acting)]: Responsible for adequate implementation of the Fire Protection Program requirements by the Plant Staff / support groups. Serves as the principal point of contact for the Program's concerns and is responsible for ensuring proper reviews by the IS&FP Fire Protection Engineering Staff as described above.
Reports to the WNP-2 Operations Manager. The WNP-2 Fire Marshall is delegated the authority necessary to accomplish his responsibilities including authority to stop Plant work if necessary until conformance with fire protection programs is achieved. Areas of responsibilities and functions are summarized below:
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Ensures adequate implementation of commitments within the Plant, o
Coordinates Plant activities, which may impact barriers, detec-tion, and suppression systems, to ensure proper implementation of program requirements; o
Reviews and ensures adequate implementation of new work; o
Reviews NCRs/LERs and assures adequate corrective actions are implemented; and o
Reviews special fire protection requirements for fMRs.
o Administrative Control o
Coordinates implementation of fire protection administrative requirements by Plant organizations; o
Reviews and assures implementation of fire protection related Plant procedures; o
Serves as a point of contact for all fire protection inspections; o
Coordinates system surveillances/ preventative maintenance programs to ensure proper and timely implementation; and o
implements fire barrier and penetration programs.
o Other o
Participates in the investigation of all fires / explosions to determine the root cause and to prevent recurrence.
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Generation Engineering Manager [L.T. Harrold]: Provides for design and discipline support of fire protection systems. Performs safe shutdown analysis and engineering associated with electrical separation.
Responsible for adequacy of design, design documentation, and design control process implementation, including obtaining appropriate fire protection-reviews. Reports to Director of Engineering.
WNP-2 Operations Manager [R.L. (Roger) Corcoran]: Responsible for imple-mentation of numerous Program elements including system operation, performance of certain fire system surveillances, fire brigade staffing and member qualification, recording of proper response to fire alarms, notification of Plant Fire Marshall of all fires and system impairments, approval of fire system impairments, and approval of Program's permits.
Responsible to provide management support for the WNP-2 Fire Marshall.
Reports to the WNP-2 Plant Manager.
WNP-2 Maintenance Manager [J.A. (Jim) Landon): Responsible for timely, preventative and corrective maintenance of fire protection systems and surveillances of fire detection systems. Reports to the WNP-2 Plant Manager.
WNP-2 Technical Manager [K.D. (Kirk) Cowan]: Provides a Fire Protection System Engineer, implements fire protection system performance trending and modifications, and administers the fire barrier penetration surveillance program. Reports to the WNP-2 Plant Manager.
Director Licensing and Quality Assurance [R.B. (Bob) Glasscock]: Provides independent quality surveillance and audit programs in conformance with regulatory requirements and corporate policies. Reports directly to the Managing Director.
WNP-2 Plant 0A Manager [D.S. (Don) Feldman]: Responsible for on-site QA functions at WNP-2 including QA/QC programs associated with the fire protection program.
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Interface Analysis As part of the review of the WNP-2 fire protection prcgram functional roles within the Supply System a review of the major organizational interfaces was performed. The results of the review were utilized to formulate the organization improvements described in this report.
Figure 2 is a sketch of the major programmatic interfaces involved in the WNP-2 fire protection program implementation.
It is included here because we believe it helps to understand how effective program coordina-tion will be accomplished.
It should be emphasized that Figure 2 is not an organizational chart nor should it be interpreted to prohibit or discourage communication or interfaces not specifically shown in the diagram.
As shown in Figure 2 the Principal Fire Protection Engineer interfaces with all program elements (including the WNP-2 Fire Marshall, Engineering and Training) in a coordinating, technical advisory and assessment role.
The WNP-2-Fire Marshall has the key role in on-site implementation of the program and provides the principal interface with all WNP-2 Plant organi-zations on fire protection matters.-
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Protection l
Engineer l
Program Development Program l
Oversight and Formulation andl Coordination Assessment i
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lMaintl lHP/Cheml WNP-2 Fire Protection Program Interfaces Diagram Figure 2 I
4 III. FIRE PROTECTION PROGRAM ADMINISTRATION An overall review of the Fire Protection Program administration was conducted to assess its adequacy. Areas that were evaluated include design process, system modifications, licensing /FSAR maintenance, incident reporting /investi-gation, records, quality assurance, procedures / procedure review, staffing levels / qualifications, performance assessment, surveillance / maintenance, training / training' records, welding / cutting, control of combustibles, and fire system impairment procedures. As a result of the review, the following improvement initiatives have been identified and are being implemented.
1.
Broader review is needed by a Registered Fire Protection Engineer of significant fire protection program documentation. Specifically, the following improvement to the current administrative review process is being or has been implemented:
o All facilities and Plant modification packages (DCPs) are now being reviewed and signed off by the Principal Fire Protection Engineer for fire protection impacts. The Engineering design control proce-dures has been changed to reflect this process modification.
o The fire protection review of procedures needs to be improved. A list of plant procedures will be identified that require mandatory fire protection reviews. The procedure coordinator for these l
procedures will ensure a fire protection review is performed of all modifications to these procedures.
IS&FP will review plant procedure changes for impact on fire protection. Comments will be tracked by IS&FP to assure appropriate resolution, o
Open fire protection issues should be tracked to completion by the l-Fire Protection Engineer who ensures timely action. Results should j
be periodically reported to Senior Management.
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2.
All MWRs should receive an improved fire protection review by the implementing organizations. PPM 1.3.7, Maintenance Work Requests and associate fire protection plant procedures (PPMs 1.3.10 and 1.3.35) will be revised to require appropriate fire protection review. The review will be documented at least in checklist form.
3.
The fire protection system surveillances and preventative maintenance activities will be overviewed by the WNP-2 Fire Marshall to assure full compliance with regulatory ccmmitment and applicable codes.
IV. FUTURE ACTIONS The following milestones and responsible individuals are established to implement the actions described in Section II and III above:
1.
Draft revision to NOS 39 Policy 1/15/87 G.D. Bouchey Issue revised NOS 1/31/87 2.
Implement Organization Changes 1/1/87 C.M. Powers (i.e. create Fire Marshall position) 3.
Meet with involved staff to clarify roles 1/15/87 G.D. Bouchey/
C.M. Powers 4
Revise plant procedur,e as described in 3/3/87 J.V. Hanson/
Section III J.C. Bell 5.
Conduct management review to assess 6/87 G.D. Bouchey/
adequacy of actions / status.
Implement C.M. Powers mid-course corrections if necessary 11
References 1.
Letter, G.C. Sorensen, Supply System to J.B. Martin, NRC Region V, " Fire Protection Program Reevaluation", dated September 16, 1986.
2.
10CFR50, Appendix R, Fire Protection Program for Nuclear Power Facilities.
3.
NRC Supplementary Guidance, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance",
June 14, 1977.
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