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MONTHYEARML12138A1792012-05-16016 May 2012 G20120327/EDATS: OEDO-2012-0282 - Mary Lampert, Margaret Sheehan, Pine Dubois & Wedge Bramhall, Re 2.206 - Enforcement Petition Regarding Labor Dispute - Pilgrim Nuclear Power Station Project stage: Request ML1217700412012-05-18018 May 2012 G20120327/EDATS: OEDO-2012-0282 - Mary Lampert - Supplement to 2.206 Enforcement Petition Regarding Labor Dispute - Pilgrim Nuclear Power Station - Security Project stage: Request ML1215701272012-05-31031 May 2012 G20120327/EDATS: OEDO-2012-0282 - Transcript Mary Lampert 2.206 Regarding Labor Dispute - Pilgrim Pilgrim Nuclear Power Station, Pages 1-19 Project stage: Other ML1216004412012-06-0606 June 2012 G20120327/EDATS: OEDO-2012-0282 - Supplemental Information Mary Lampert 2.206 Regarding Labor Dispute - Pilgrim Nuclear Power Station Project stage: Supplement ML12166A3482012-06-12012 June 2012 G20120327 - Mary Lampert Ltr. Supplement to 2.206 Enforcement Petition Regarding Labor Dispute-Pilgrim NPS (Submitted May 16, 2012) Project stage: Request ML12167A2222012-06-13013 June 2012 G20120327 - Mary Lampert Ltr. Re Supplement to 2.206 Enforcement Petition Regarding Labor Dispute-Pilgrim Nps (Submitted May 16, 2012) Project stage: Request ML12173A2022012-06-20020 June 2012 G20120327 - Mary Lampert Ltr. Supplement to 2.206 Enforcement Petition Regarding Labor Dispute-Pilgrim NPS (Submitted May 16, 2012) - Monthly Communication Test Failure Project stage: Request ML12178A0722012-06-25025 June 2012 G20120327 - Mary Lampert Ltr. Re Supplement to 2.206 Enforcement Petition Regarding Labor Dispute-Pilgrim NPS (Submitted May 16, 2012); CR-PNP-2012-02693 Waiver Fire Brigade Project stage: Request ML1221202862012-08-13013 August 2012 G20120327/EDATS: OEDO-2012-0282 - Closeout Letter to Mary Lampert, Margaret Sheehan, Pine Dubois & Wedge Bramhall, Re 2.206 - Enforcement Petition Regarding Labor Dispute - Pilgrim Nuclear Power Station Project stage: Other 2012-06-13
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Category:2.206 Petition
MONTHYEARML18158A2252018-06-0707 June 2018 (OEDO-15-00479) Pilgrim Nuclear Power Station - 2.206 Petition Regarding Pilgrim Nuclear Power Station - Current Licensing Basis for Flooding - 60-Day Status Report (CAC No. MF6460; EPID L-2015-CRS-0002) ML17345A9362017-12-11011 December 2017 OEDO-15-00479 - 2.206 Petition Regarding Pilgrim Nuclear Power Station'S Current Licensing Basis for Flooding - 60-Day Status Report (CAC No. MF6460; EPID L-2015-CRS-0002) NRC-2016-0035, OEDO-15-00479: Federal Register Notice 2.206 Petition Regarding Pilgrim'S Current License Basis for Flooding2016-02-11011 February 2016 OEDO-15-00479: Federal Register Notice 2.206 Petition Regarding Pilgrim'S Current License Basis for Flooding ML15356A7442016-02-11011 February 2016 OEDO-15-00479: Federal Register Notice 2.206 Petition Regarding Pilgrim'S Current License Basis for Flooding ML15197A4872015-07-13013 July 2015 to 2.206 Petition Pilgrim Emergency Planning (LTR-15-0319), Mary Lampert Pilgrim Watch, Town of Duxbury Nuclear Advisory Committee and Cape Downwinders (07/13/2015) ML16029A4072015-06-24024 June 2015 ODEO-15-00479: 2.206 Petition on Current Licensing Basis for Flooding at Pilgrim ML15162A8832015-06-11011 June 2015 LTR-15-0319 - Mary Lampert, Pilgrim Watch, Town of Duxbury Nuclear Advisory Committee and Cape Downwinders, E-mail 2.206 Petition on Emergency Planning ML14260A4822014-09-16016 September 2014 LTR-14-0535 - Mary Lampert, Pilgrim Watch; William Maurer, Cape Downwinders; Diane Turco, Cape Downwinders Email 2.206 - Pilgrim Security ML14122A1502014-04-16016 April 2014 LTR-14-0249 - Mary Pat Flynn Et Al., County Commissioners, Barnstable County, Massachusetts Ltr. Potential Threats to Cape Cod Associated with the Pilgrim Nuclear Power Station ML13294A4002013-10-16016 October 2013 G20130211 - 10/16/13 Supplement #4 Information to 2.206 Petition Financial Qualifications Fitzpatrick/Vermont - Email from T.Judson to R.Guzman ML13267A2342013-08-30030 August 2013 G20130629 - Pilgrim Watch'S 2.206 Petition to Pilgrim'S Emergency Preparedness Plans (MF2656) ML13189A0572013-06-11011 June 2013 G20130174 - Micheal Mulligan 2.206 Petition Transcript of 6/11/13 Teleconference Safety Relief Valves at Pilgrim Nuclear Power Station ML13133A2072013-04-23023 April 2013 G20130211 - Timothy Judson E-mail to R.Guzman 2.206 Supplemental Information Dated April 23, 2013 - James A. Fitzpatrick/Pilgrim/Vermont Yankee Nuclear Power Stations ML13113A2432013-04-22022 April 2013 G20130211 - Paul Gunter E-mail Re 2.206 - James A. Fitzpatrick/Pilrgim/Vermont Yankee Nuclear Power Stations ML13112B0552013-04-11011 April 2013 G20130174 - Micheal Mulligan 2.206 Petition Transcript of 4/11/13 Teleconference Safety Relief Valves at Pilgrim Nuclear Power Station ML13105A0602013-04-10010 April 2013 G20100454 - Mary Lampert, Pilgrim Watch Ltr. Pilgrim Watch'S Request for Extension to Reply to Proposed Director'S Decision Under 10 CFR 2.206 (7590-01-P) - Docket No. 50-293 ML13128A3052013-04-0909 April 2013 G20130211 - Timothy Judson E-mail 2.206 Supplemental Information - Ubs Investment Research Report: Nuclear Decommissioning Discussion with the NRC Staff: Conference Call Transcript (April 9, 2013) ML13079A0222013-03-18018 March 2013 G20130211 - Timothy Judson E-mail 2.206 - James A. Fitzpatrick/Pilrgim/Vermont Yankee Nuclear Power Stations ML13070A0552013-03-0707 March 2013 G20130174 - Michael Mulligan E-mail 2.206: Pilgrim Nuclear Plant SRV Request for Emergency Shutdown ML13128A3022013-02-20020 February 2013 G20130211 - Timothy Judson E-mail 2.206 Supplemental Information - Ubs Investment Research Report: in Search of Washington'S Latest Realities: DC Fieldtrip Takeaways (February 20, 2013) ML13128A3002013-01-0202 January 2013 G20130211 - Timothy Judson E-mail 2.206 Supplemental Information - Ubs Investment Research Report: Re-evaluating Merchant Nuclear (January 2, 2013) ML12178A0722012-06-25025 June 2012 G20120327 - Mary Lampert Ltr. Re Supplement to 2.206 Enforcement Petition Regarding Labor Dispute-Pilgrim NPS (Submitted May 16, 2012); CR-PNP-2012-02693 Waiver Fire Brigade ML12173A2022012-06-20020 June 2012 G20120327 - Mary Lampert Ltr. Supplement to 2.206 Enforcement Petition Regarding Labor Dispute-Pilgrim NPS (Submitted May 16, 2012) - Monthly Communication Test Failure ML12170B0212012-06-17017 June 2012 G20120327 - Mary Lampert Ltr. Re Supplement to 2.206 Enforcement Petition Regarding Labor Dispute Pilgrim NPS (Submitted May 16, 2012) - Condition Reports ML12170B0222012-06-16016 June 2012 G20120327 - Mary Lampert Ltr. Re Supplement to 2.206 Enforcement Petition Regarding Labor Dispute Pilgrim NPS (Submitted May 16, 2012) - Emergency Response ML12167A2222012-06-13013 June 2012 G20120327 - Mary Lampert Ltr. Re Supplement to 2.206 Enforcement Petition Regarding Labor Dispute-Pilgrim Nps (Submitted May 16, 2012) ML12166A3482012-06-12012 June 2012 G20120327 - Mary Lampert Ltr. Supplement to 2.206 Enforcement Petition Regarding Labor Dispute-Pilgrim NPS (Submitted May 16, 2012) ML1216004412012-06-0606 June 2012 G20120327/EDATS: OEDO-2012-0282 - Supplemental Information Mary Lampert 2.206 Regarding Labor Dispute - Pilgrim Nuclear Power Station ML1217700412012-05-18018 May 2012 G20120327/EDATS: OEDO-2012-0282 - Mary Lampert - Supplement to 2.206 Enforcement Petition Regarding Labor Dispute - Pilgrim Nuclear Power Station - Security ML12138A1792012-05-16016 May 2012 G20120327/EDATS: OEDO-2012-0282 - Mary Lampert, Margaret Sheehan, Pine Dubois & Wedge Bramhall, Re 2.206 - Enforcement Petition Regarding Labor Dispute - Pilgrim Nuclear Power Station ML11213A0302011-07-29029 July 2011 G20110563/EDATS: OEDO-2011-0535 - David Lochbaum Ltr. 2.206 - Boiling Water Reactors with Mark I and Mark II Containment Designs ML1032102282010-11-15015 November 2010 G20100689/EDATS: OEDO-2010-0929 - Mary Lampert Ltr. Re Pilgrim Nuclear Power Station - Petitioner'S Request for Review of the Petition Review Board Denial 2.206 Regarding Request Require Hydrological-Geological Subsurface Study ML1028104692010-10-0606 October 2010 G20100527/EDATS: OEDO-2010-0688 - Pilgrim Watch - 2.206 Petition Regarding Hydrogeologic Assessment Pilgrim NPS - Supplement ML1022805682010-08-13013 August 2010 G20100527/EDATS: OEDO-2010-0688 - Mary Lampert and Rebecca Chin Ltr. Re 2.206 - Hydrogeologic Assessment at Pilgrim Nuclear Power Station ML1022104112010-08-0606 August 2010 G20100454/EDATS: OEDO-2010-0589 - Mary Lampert Ltr. Supplement (1) to Pilgrim Watch 2.206 Petition Regarding Inadequacy of Entergy'S Management of Non-Environmentally Qualified Inaccessible Cables & Wiring at Pilgrim Station ML1020202752010-07-19019 July 2010 G20100454/EDATS: OEDO-2010-0589 - Mary Lampert Ltr. Re 2.206 - Inadequate of Entergy'S Management of Non-Environmentally Qualified Inaccessible Cables & Wiring at Pilgrim ML0914000642009-05-14014 May 2009 G20090292/LTR-09-0210/EDATS: SECY-2009-0248 - Mary E. Lampert, Rebecca J. Chin Pilgrim NPS RFO 2009: 2.206 Petition Requesting That NRC Require All Work Packages Inspected Prior to Pilgrim'S Re-start - Urgent Action Requested Due to Timing ML0814002822008-05-14014 May 2008 G20080352/EDATS: OEDO-2008-0390 - Scott H. Strauss Ltr. Re 2.206 Pilgrim Petition of Utility Workers Union of America, Local 369 ML0814001022008-05-13013 May 2008 G20080347/LTR-08-0283/EDATS: SECY-2008-0303 - Ltr., Mary Elizabeth Lampert, Re 2.206 Petition Regarding Potential Worker Strike Pilgrim Station 2018-06-07
[Table view] Category:Letter
MONTHYEARML24240A1692024-09-18018 September 2024 Cy 2023 Summary of Decommissioning Trust Fund Status IR 05000293/20240022024-08-21021 August 2024 NRC Inspection Report No. 05000293/2024002 PNP 2024-030, Update Report for Holtec Decommissioning International Fleet Decommissioning Quality Assurance Program Rev. 3 and Palisades Transitioning Quality Assurance Plan, Rev 02024-08-0202 August 2024 Update Report for Holtec Decommissioning International Fleet Decommissioning Quality Assurance Program Rev. 3 and Palisades Transitioning Quality Assurance Plan, Rev 0 ML24151A6482024-06-0303 June 2024 Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities ML24129A1042024-05-26026 May 2024 Preapplication Readiness Assessment Plan for the Holtec Decommissioning International License Termination Plan ML24136A2382024-05-14014 May 2024 Annual Radiological Environmental Operating Report for 2023 ML24135A3212024-05-14014 May 2024 Annual Radioactive Effluent Release Report, January 1 Through December 31, 2023 IR 05000293/20240012024-05-0707 May 2024 NRC Inspection Report No. 05000293/2024001 L-24-009, HDI Annual Occupational Radiation Exposure Data Reports - 20232024-04-29029 April 2024 HDI Annual Occupational Radiation Exposure Data Reports - 2023 L-24-010, Request for Preapplication Readiness Assessment of the Draft License Termination Plan2024-04-22022 April 2024 Request for Preapplication Readiness Assessment of the Draft License Termination Plan L-24-007, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations – Holtec Decommissioning International, LLC (HDI)2024-03-29029 March 2024 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations – Holtec Decommissioning International, LLC (HDI) IR 05000293/20230032024-02-29029 February 2024 NRC Inspection Report Nos. 05000293/2023003 and 05000293/2023004 L-24-002, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2024-02-0202 February 2024 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G ML23342A1182024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 ML23334A1822023-11-30030 November 2023 Biennial Report for the Defueled Safety Analysis Report Update, Technical Specification Bases Changes, 10 CFR 50.59 Evaluation Summary, and Regulatory Commitment Change Summary – November 2021 Through October 2023 L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23306A0992023-11-0202 November 2023 and Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7) IR 05000293/20234012023-08-31031 August 2023 NRC Inspection Report No. 05000293/2023401 & 2023001 (Cover Letter Only) IR 05000293/20230022023-08-0404 August 2023 NRC Inspection Report No. 05000293/2023002 L-23-008, Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI)2023-05-23023 May 2023 Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI) ML23135A2152023-05-15015 May 2023 Annual Radioactive Effluent Release Report, January 1 Through December 31, 2022 ML23136A7792023-05-15015 May 2023 Annual Radiological Environmental Operating Report, January 1 Through December 31, 2022 L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance ML23069A2782023-03-13013 March 2023 Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1 Subsequent License Renewal Application ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000293/20220042023-02-15015 February 2023 NRC Inspection Report No. 05000293/2022004 ML22356A0712023-01-31031 January 2023 Issuance of Exemption for Pilgrim Nuclear Power Station ISFSI Regarding Annual Radioactive Effluent Release Report - Cover Letter ML22347A2782022-12-21021 December 2022 Independent Spent Fuel Storage Installation Security Inspection Plan Dated December 21, 2022 L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 L-22-041, Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension2022-12-0909 December 2022 Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension IR 05000293/20220032022-11-18018 November 2022 NRC Inspection Report No. 05000293/2022003 L-22-036, Decommissioning Trust Fund Agreement2022-11-0808 November 2022 Decommissioning Trust Fund Agreement ML22276A1762022-10-24024 October 2022 Decommissioning International Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22266A1922022-09-23023 September 2022 and Pilgrim Nuclear Power Station - Request to Withdraw Prior Submissions from NRC Consideration ML22272A0352022-09-22022 September 2022 S. Lynch-Benttinen Letter Regarding U.S. Citizen Intent to Sue U.S. Fish and Wildlife and NOAA Fisheries Representing the Endangered Species (Na Right Whale) Which Will Be Adversely Affected by Holtec International Potential Actions ML22269A4202022-09-22022 September 2022 Citizen Lawsuit ML22241A1122022-08-29029 August 2022 Request for Exemption from 10 CFR 72.212(a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim ISFSI Annual Radioactive Effluent Release Report IR 05000293/20220022022-08-12012 August 2022 NRC Inspection Report No. 05000293/2022002 ML22215A1772022-08-0303 August 2022 Decommissioning International (HDI) Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22221A2592022-08-0101 August 2022 LTR-22-0217-1-NMSS - Town of Duxbury Letter Opposing the Irradiated Water Release from Pilgrim (Docket No. 05000293) ML22206A1512022-08-0101 August 2022 NRC Office of Investigations Case Nos. 1-2022-002 & 1-2022-006 ML22175A1732022-07-28028 July 2022 LTR-22-0153-1 - Response Letter to D. Turco, Cape Downwinders, from A. Roberts, NRC, Regarding Holtec-Pilgrim Plans to Dump One Million Gallons of Radioactive Waste Into Cape Cod Bay ML22193A1662022-07-28028 July 2022 LTR-22-0154-1 - Heather Govern, VP, Clean Air and Water Program, Et Al., Letter Regarding Radioactive Wastewater Disposal from the Pilgrim Nuclear Power Station (Docket No. 05000293) ML22154A4882022-06-0101 June 2022 Letter from Conservation Law Foundation Regarding Irradiated Water Release from Pilgrim ML22154A1622022-05-26026 May 2022 Letter and Email from Save Our Bay/Diane Turco Regarding Irradiated Water Release from Pilgrim ML22136A2602022-05-16016 May 2022 Submittal of Annual Radiological Environmental Operating Report for January 1 Through December 31, 2021 ML22136A2572022-05-16016 May 2022 Submittal of Annual Radioactive Effluent Release Report for January 1 Through December 31, 2021 2024-09-18
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0h: L~GQ0G1,20 -X301 Cýý" EDO UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE EDO. U.S. NUCLEAR REGULATORY COMMISSION UEDMRT DEDR DEDCM AO (Z(0Cx~fflae,&PC.
~Co-June 25, 2012 R. William Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Via Email hearingdocket@nrc.gov SUPPLEMENT TO 2.206 ENFORCEMENT PETITION REGARDING LABOR DISPUTE- PILGRIM NPS (SUBMITTED MAY 16, 2012): CR-PNP-2012-02693 WAIVER FIRE BRIGADE Pilgrim Watch ("PW") respectfully requests again to supplement its 2.206 enforcement petition submitted originally on May 16, 2012 regarding the labor dispute at Pilgrim Station highlighting its public safety implications.
We submit the following pertinent new information that supports PW's request for NRC to order Pilgrim closed for operations until the labor dispute is resolved and all 369 union workers reinstated back onsite in their original jobs.Fatigue: Entergy's Condition Report, CR-PNP-02693 (pasted below) shows that in order to meet the Fire Brigade staffing requirements a waiver was required to the Fatigue Management Program.I:1 Efltery CONDI TI(Y% KLi'UK I I LK- Vr -21i II~-0-'b!'
Opcmblliq Uequfrcd:
N%Ib ~ Iki ca. " ISkW$diyRoti R s-Tm~I 1Tk.i UcmzW 1 d 2. \l.xjtc"=ES za 4. fatd ý' -1a o m obospak tý ýJ.CJyC(4C 6)0 1~E--41,b S -1 Ebo --61 The safety implications are obvious. Fire brigade work is strenuous.
Fatigue diminishes capability for strenuous work required and the length of time that brigade workers can keep up the pace. Fatigue also diminishes attentiveness.
Training:
The public deserves assurance that the current fire brigade has received all the training, practice, and drills required in the Pilgrim Design Basis Document, pertinent sections are attached.
It is clear to us that if the replacement worker's fire brigade has not received all the training specified or met the qualifications specified the public has no reasonable assurance of public health and safety and the reactor must cease operations.
- 1. Fire Brigade (H): Do at least two Brigade members have sufficient training in or knowledge of plant safety systems to understand the effects of fire and fire suppressants on Pilgrim's safe shutdown capability?
- 2. Have the fire brigade members had a physical exam to determine their ability to perform the strenuous work?3. Is the brigade leader competent to assess the safety consequences of the fire at Pilgrim specifically to advise the control room? Does he/she have an operator's license or equivalent knowledge of Pilgrim's safety-related systems?4. Fire Brigade Trainin2 (I): Have all members received the classroom instruction, including all subsections (I, 1-10) in Pilgrim's design basis document?5. Were the instructors qualified
-knowledgeable in fighting fires specifically at Pilgrim? If yes, how can this be so, if the qualified workers are on strike?6. Practice:
Have all members received a practice session as described in subpart 2 below?7. Drills: Has there been a fire brigade drill (subpart 3) at Pilgrim since the replacement worker brigade has taken over so that the replacement brigade can practice as a team?Siinificance Fire is an important concern because it has the potential to affect critical systems needed to safely maintain and shut down the reactor. The NRC has estimated that the reactor meltdown risk from fire hazards is roughly equal to the meltdown risk from ALL other hazards combined, 2 assuming that the plants are in complete compliance with fire protection regulations.
And there have been an average of about 10 fires per year at U.S. reactors over the past 15 years, according to NRC records. NRC Commissioner Gregory Jaczko stated in July 2008: "I don't think there is one plant right now that is in compliance with those regulations." Our original filing and each of our supplemental filings when looked at collectively paint a clear picture that reasonable assurance is not adequately protected during this lock-out.
Further, we believe that the filings provide valuable lessons learned for NRC to apply to subsequent lock-outs industry-wide.
Respectfully submitted on behalf of Petitioners, (Electronically signed)Mary lampert Pilgrim Watch, Director 148 Washington Street Duxbury, MA Tel. 781-934-0389 Email: rnarv.larnpert corncast.net June 25, 2012 3 ATTACHMENT H_ Fire brigade. A site fire brigade, trained and equipped for fire fighting shall be established to ensure adequate manual fire fighting capability for all areas of the plant containing structures, systems, or components important to safety. The fire brigade shall be at least five members on each shift. The brigade leader and at least two brigade members shall have sufficient training in or knowledge of plant safety-related systems to understand the effects of fire and fire suppresýants on safe shutdown capability-The qualification of fire brigade members shall include an annual physical examination to determine their ability to perform strenuous fire fighting activities-The shift supervisor shall not be a member of the fire brigade. The brigade leader shall be competent to assess the potential safety consequences of a fire and advise control room personnel.
Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant safety-related systems-The minimum equipment provided for the brigade shall consist of personal protective equipment such a:s turnout coats, boots, gloves, hard hats, emergency communications equipment, portable lights, portable ventilation equipment, and portable extinguishers.
Self-contained breathing apparatus using full-face positive-pressure masks approved by NIOSH (National Institute for Occupational Safety and Health -approval formerly given by the U-S. Bureau of Mines) shall be provided for fire brigade, damage control, and control room personnel.
At least 10 masks shall be available for fire brigade personnel.
Control room personnel may be furnished breathing air by a manifold system piped from a storage reservoir if practical.
Service or rated operating life shall be a minimum of one-half hour for the self-contained units.At least a 1-hour supply of breathing air in extra bottles shall be located on the plant site for each unit of self-contained breathing appratus.
In addition, an onsite 6-hour supply of reserve air shall be provided and arranged to permit quick and complete replenishment of exhausted air supply bottles as they are returned.
If compressors are used as a source of breathing air, only units approved for breathing air shall be used and the compressors shall be operable assuming a loss of offlite power.Special care must be taken to locate the compressor in areas free of dust and contaminants.
L Fire brigade training.
The fire brigade training program shall ensure that the capability to fight potential fires is established and maintained.
The program shall consist of an initial classroom instruction program followed by periodic classroom instruction, fire fighting practice, and fire drills: 1. Instruction
- a. The initial classroom instruction shall include: (1) Indoctrination of the plant fire fighting plan with specific identification of each individual's responsibilities.
TDBD-105 Re-ision EO 4 ATTACHMENT 3 Sheet 9 of 15 (2) Identification of the type and location of fire hazards and associated types of fires that could occur inthe plant.(3) The toxic and corrosive characteristics of expected pioducts of combustiona (4) Identification of the location of fire fighting equipment for each fire. area and familiarization with the layout of the plant including access and egress routes to each area.(5) The proper use of available fire fighting equipment and the correct method of fighting each type of fire. The types of fires covered should include fires in energized electrical equipment, fires in cables and cable trays- hydrogen fires, fires involving flanmable and combustible liquids or hazardous process chemicals, fires resulting from construction or modifications (welding), and record file fires.(6) The proper u-se of comminication.
lighting, ventilatioa and emergency breathing equipment-(7) The proper method for fighting fires inside buildings and confined spaces.(8) The direction and coordination of the fire fighting activities (fire brigade leaders only).(9) Detailed review of fire fighting strategies and procedures.
(10) Review of the latest plant modifications and corresponding changes in fire fighting plans.Note: Items (9) and (10) may be deleted from the training of no more than two of the non-operations pernsonnel udio may be assigned to the fire brigade.b. The instruction shall be provided by qualified individuals who are kmowledgeable, experienced, and suitably trained in fighting the types of fires that could occur in the plant and in using the. types of equipment available in the nuclear power plant.c. Instruction shall be provided to all fire brigade members and fire brigade leaders.d. Regular planned meetings shall be held at least every 3 months for all brigade members to review changes in the fire protection program and other subjects as necessary:
- e. Periodic refresher training sessions shall be held to repeat the classroom instruction program for all brigade members over a two-year period. These sessions may be concurrent with the regular planned meetings.2. Practce Practice sessions shall be held for each shift fire brigade on the proper method of fighting the various types of fires that could occur in a nuclear power plant. These sessions shall provide brigade members with experience in actual fire extingih nt and the use of emergency breathing apparatus under strenuous conditions encoumtered in fire fighting.
These practice sessions shall be provided at least once per year for each fire brigade member.5 I3DrIls a. Fire brigade chlls shall be performed in the plant so that the fire brigade can practice as a team.b. Drills shall be performed at regular intervals not to exceed 3 months for each shift fire brigade- Each fire brigade member should participate in each drill, but must participate in at least tvo chills per year.A sufficient number of these drills, but not less than one for each shift fui brigade per year, shall be unannounced to determine the fire fighting readiness of the plant fire brigade, brigade leader, and fire protection systems and equipment.
Persons planning and authorizing an unannounced drill shall ensure that the responding shift fire brigade members are not aware that a drill is being planned until it is begua. Unannounced chills shall not be scheduled closer than four weeks.At least one drill per year shall be performed on a "back shift" for each shift fire brigade.TDBD-105 Revision EO 6 ATTACHMENT 3 Sheet 10 of 15 c. The drills shall be preplanned to establish the taining objectives of the drill and shall be critiqued to determine how well the training objectives have been met. Unannounced drills shall be planned and critiqued by members of the management staff responsible for plant safety and fire protectioa Performance deficiencies of a fire brigade or of individual fire brigade members shall be remedied by scheduling additional training for the brigade or members Unsatisfactory drill performance shall be followed by a repeat drill within 30 days.d. At 3-year intervals, a randomly selected unannounced drill must be critiqued by qualified individuals independent of the licensee's staff. A copy of the written report from these individuals must be available for NRC review and shall be retained as a record as specified in section r.I.4 of this appendLtt e. Drills shall as a minimuum include the following:
(1) Assessment of fire alarm effectiveness, time required to notify and assemble fire brigade, and selection, placement and use of equipment, and fire fighting strategies.
(2) Assessment of each brigade members knowledge of his or her role in the fire fighting, strategy for the area assumed to contain the fire. Assessment of the brigade member's conformance with established plant fire fighting procedures and use of fire fighting equipment, including self-contained emergency breathing apparatus, communication equipment, and ventilation equipment, to the extent practicable-(3) The simulated use of fire fighting equipment required to cope with the situation and type of fire selected for the drill. The area and type of fire chosen for the drill should differ from those used in the previous drill so that brigade members are trained in fighting fires in various plant areas. The situation selected should simulate the size and arrangement of a fire that could reasonably occur in the area selected, allowing for fire development due to the time required to respond, to obtain equipment, and organize for the fire, assuming loss of automatic suppression capability.
(4) Assessment of brigade leader's direction of the fire fighting effort as to thoroughness, accuracy, and effectiveness.
4- Records Individual records of training provided to each fire brigade member, inchuting chill critiques, shall be maintained for at least 3 years to ensure that each member receives training in all parts of the training program. These records of training shall be available for NRC review. Retraining or broadened training for fire fighting within buildings shall be scheduled for all those brigade members whose performance records show deficiencies.
7 Jaegers, Cathy From: Sent: To: Cc:
Subject:
Attachments:
Mary Lampert [mary. lampert@comcast.
net]Monday, June 25, 2012 11:13 AM Docket, Hearing Dean, Bill SUPPLEMENT TO 2.206 ENFORCEMENT PETITION REGARDING LABOR DISPUTE-PILGRIM NPS (SUBMITTED MAY 16, 2012): CR-PNP-2012-02693 WAIVER FIRE BRIGADE 06.25.12 PW SUPPLEMENT LABOR DISPUTE-FIRE BRIGADE CR.pdf Hello: Please find attached, SUPPLEMENT TO 2.206 ENFORCEMENT PETITION REGARDING LABOR DISPUTE- PILGRIM NPS (SUBMITTED MAY 16, 2012): CR-PNP-2012-02693 WAIVER FIRE BRIGADE. If u have any difficulty in opening, please call Mary Lampert at 781-934-0389.
Thank-you and enjoy the afternoon.
Mary 1